To:
Members, Affiliates, & SSO Workgroup
From:
National Office
Date:
November 6, 1998
Subject:
Status of SSO Policy Development
Reference:
RA 98-22
ACTION PLEASE BY: NOVEMBER 18, 1998 & DECEMBER 7, 1998
EPA’s Office of Wastewater Management (OWM) is currently developing a draft Federal Register notice that will include:
- An interim policy statement addressing NPDES permit requirements for municipal sanitary sewer collection systems. The policy will clarify how existing ‘generic’ standard NPDES permit conditions apply to municipal sanitary sewer collection systems; and,
- Proposed modifications to the NPDES regulations which would establish standard permit conditions specifically for municipal sanitary sewer collection systems. These standard permit conditions will address: reporting requirements for sanitary sewer overflows (SSOs); and a prohibition on discharges from a municipal sanitary sewer collection systems.
The Office of Water currently plans to release a draft of the Federal Register notice to the sanitary sewer overflow (SSO) Federal Advisory Committee for comment before the end of January 1999. The Agency is also preparing a series of discussion papers to highlight key technical issues associated with the development of the interim policy statement and the proposed regulations. AMSA is soliciting comment on EPA’s draft discussion papers which are attached and are summarized below. AMSA will forward compiled member comments to EPA for review. If you would like to provide comments on the discussion papers, please send via e-mail to mhoeke@amsa-cleanwater.org , or to the attention of Mark Hoeke, AMSA National Office, 1000 Connecticut Ave., Suite 410, Washington, DC 20036 (or fax: 202/833-4657).
This six-page paper outlines minimum requirements for operations, maintenance, and remediation programs for municipal sanitary sewer collection systems. EPA is trying to determine the key components of these programs and inventory major industry practices and guidelines. It also suggests that EPA is not considering applying numeric criteria when defining proper operation and maintenance in a national SSO policy/regulation. Please review and provide comments to AMSA on EPA’s discussion paper by November 18, 1998.
EPA is considering two regulatory approaches in setting a minimum standard for collection systems under peak, wet-weather induced flow conditions. One approach is a design standard related to a design storm event; the other, is a performance standard, defined by how often wet weather induced overflows occur per time period (e.g., the number of overflows per year). EPA is currently requesting additional data from states and municipalities to better evaluate current practices and guidelines and determine how peak wet weather flow capacity requirements for sanitary sewer collection system rehabilitation projects have historically been established. If you would like to contribute data, or comment on EPA’s approach, please provide these to AMSA by December 7, 1998.
EPA is considering allowing the use of wet weather treatment facilities that provide less than secondary treatment for infrequent, intermittent wet weather induced flows from sanitary sewer collection systems. EPA presents a discussion of existing and emerging technologies used to treat wet weather flows, and solicits input on the best way to characterize performance of treatment systems for intermittent wet weather flows. Please review and provide comments to AMSA on EPA’s discussion paper by December 7, 1998.