Turn to the nation's most objective and informative daily environmental news resource to learn how the United States and key players around the world are responding to the environmental...
The Environmental Protection Agency issued proposed guidance Aug. 9 to help municipal and state water officials determine the effectiveness of post-construction, long-term plans for monitoring and controlling combined sewer overflows.
The document, CSO Post Construction Compliance Monitoring Guidance, was released on the EPA website.
Comments are being sought until Sept. 30, and EPA said it is particularly interested in how the guidance might help small communities in their planning.
According to EPA, the goal of combined sewer overflow (CSO) post-construction monitoring is to evaluate whether the level of control proposed in long-term compliance plans—including proposed water quality goals—has been achieved.
Post-construction monitoring helps in adjusting CSO controls based on data collected during implementation phases of the CSO long-term control plan, the agency said in the proposed guidance.
Combined sewer systems are designed to collect rainwater runoff, sewage, and industrial waste in the same pipe. CSOs pose a major water pollution concern for the approximately 770 cities that have combined sewer systems, according to EPA.
The combined sewer overflow policy, issued April 11, 1994, under the Clean Water Act, established a national framework under the National Pollutant Discharge Elimination System permit program for controlling discharges into the nation's waters from combined sewer systems. One provision was that regulated communities would develop comprehensive CSO control measures, including controls based on long-term plans (59 Fed. Reg. 18,688).
“The post-construction compliance monitoring is a continuous process to determine whether the CSO [long-term control plan] is meeting the regulatory requirements as planned,” the proposed guidance said.
The 1994 policy includes nine controls. The ninth, and the subject of the proposed guidance, is development of a post-construction compliance monitoring program sufficient to verify compliance with water quality requirements and to ascertain the effectiveness of CSOs, the agency said.
The policy defines expectations for regulated communities and state water authorities addressing water quality standards and NPDES permits.
Many communities served by combined sewer systems have developed and are implementing long-term control plans “or about to take the next step of implementing a post-construction compliance monitoring program,” James Hanlon, director of EPA's Office of Wastewater Management, said in a memorandum contained in the proposed guidance.
The proposed guidance stresses the importance of continuously updating and evaluating data to ensure its quality. While post-construction monitoring programs should build on previous collected data, they also should provide followup data to determine whether controls that have been put in place have met their objectives and whether the permittee is complying with water quality-based effluent limits in its NPDES permits, the proposed guidance said.
“Because this information will ultimately be used to verify compliance with water quality-based requirements, reducing data uncertainty should be a high priority,” it said.
If data analysis indicates a community cannot meet water quality standards because it is financially or technologically infeasible, the community “should develop a schedule for incremental improvements and then revisit additional controls as financial conditions change or as new control technologies emerge,” the document said.
The proposed guidance gives examples of planning documents that permittees should consider in preparing for post-construction monitoring. These include quality assurance project plans, plans for assessing CSO controls, field sampling plans, and standard operating procedures.
The agency said that while it recognizes it is often difficult to document the direct relationship between individual CSO controls and specific improvements in water quality, “the comparison of long-term quality trends before and after implementing the [long-term control plan], if the data are available, can provide a correlation between CSO controls and improvements in water quality if other things stay the same.”
Alexandra Dunn, executive director of the Association of State and Interstate Water Pollution Control Administrators, told BNA, “We're pleased that EPA has put out a guidance that can assist us with determining that water quality improvements have been made. … The document will help implement post-construction monitoring programs—a requirement in the CSO policy.”
Many municipal long-term plans have been required by legal agreements, with some taking more than a decade to implement, Dunn said.
Nathan Gardner-Andrews, general counsel for the National Association of Clean Water Agencies, told BNA Aug. 10 that NACWA has not yet evaluated the proposed guidance, but plans to submit comments.
By Linda Roeder
EPA's proposed CSO Post Construction Compliance Monitoring Guidanceis available at http://www.epa.gov/npdes/pubs/final_draft_cso_pccm_guidance.pdf .
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to firstname.lastname@example.org.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)