WASHINGTON INSIGHT

EPA releases SSO/CSO Report to Congress: APWA members reporting substantial decline in discharges

Heather McTavish Doucet
Manager, Government Relations
APWA Washington Office

A newly released report on SSO/CSO activity from the Environmental Protection Agency (EPA) reports sewer overflows cause up to 860 billion gallons of wastewater to be discharged annually into U.S. rivers and lakes. EPA recommends an investment of $140 billion over 20 years to solve the problem.

EPA's "Report to Congress on the Impacts and Control of Combined Sewer Overflows (CSOs) and Sanitary Sewer Overflows (SSOs)," the second of two reports required under the fiscal year 2001 Appropriations Act amending the Clean Water Act, does not make recommendations for solving overflows but rather, details the numbers of overflows, costs of controls, and health and environmental impacts.

EPA reports that 756 communities in 32 states have combined sewer systems with 9,348 outfalls regulated by 828 NPDES permits. EPA estimates that combined sewer overflows (CSOs) discharge 850 billion gallons of untreated wastewater annually, a decline from more than a trillion gallons before 1994.

EPA estimates that between 23,000 and 75,000 SSO events occur each year in the United States, discharging a total volume of three to 10 billion gallons per year.

In 1994, EPA issued a policy requiring municipalities to take specific measures to reduce CSOs. The 1994 CSO policy laid out a set of "nine minimum controls" cities should implement, including proper maintenance of the system, control of debris, public notification of discharge points, etc. These policies were to have been implemented by cities in a long-term control plan by 1997. This report states that 59% of the CSO communities have submitted their plans to permitting authorities, up from 34% in 2001.

The report also estimates that $10 billion has been spent since the early 1990s to control overflows. The report cites EPA's Clean Water Needs Survey which discussed the need for a greater investment of $140 billion to curb CSOs by 85% and control SSOs. The primary funding mechanism to control SSOs and CSOs is the Clean Water State Revolving Fund (CWSRF). The CWSRF has been appropriated at $1.35 billion since 1996 but the FY05 request from the Bush Administration was for $850 million, diminishing any hope that sufficient funds would be available to address overflows.

The report also details EPA's enforcement actions against municipalities for sewer overflows. These include 15 CSO and 25 SSO enforcement cases, with more than $14 million in civil penalties and $11 billion in injunctive relief from settlement agreements.

The most important aspect of the report for APWA members may be the fact that EPA recognized municipalities' suggestions that limited resources prevent them from acquiring and implementing technologies as quickly as they and regulatory agencies would prefer.

A survey recently conducted of APWA members reports a positive message, signaling dramatic reductions in stormwater discharges likely because of the use of new technologies. The City of Urbana, Illinois has seen a dramatic decline of almost 75% in the sanitary sewer overflow arena. Urbana spent $750,000 a year over the last ten years to employ a second Vactor dedicated to cleaning sewers and a TV crew identifying problem areas, along with dye water flooding, smoke testing, and in-home inspections. The city dedicates $300,000 to sewer repairs, linings, grouting, and pipe replacement.

Archbold, Ohio has spent millions to completely separate storm and sanitary sewers, and to replace and rehabilitate older sanitary sewers. They have utilized smoke testing, dye testing, and sewer video investigations.

Duncanville, Texas has implemented a manhole rehabilitation contract to stop the inflow and infiltration through the manholes and reduce sanitary sewer overflows. They have also used Cured-In-Place-Pipe (C.I.P.P.) to stop the inflow and infiltration in the sanitary sewer trunk mains. They spent $65,000 per year on the manhole rehabilitation contract, have spent approximately $3.5 million on C.I.P.P. in the last five years and will average between $500K to $1 million per year on the project until it is completed.

The costs for these successful projects is not cheap. Because the only available federal funding for these programs is the Clean Water State Revolving Fund, it is often the ratepayer that absorbs the costs for compliance, maintenance projects, and upgrades.

APWA is committed to working with EPA and the states to strive toward a better integration of wet weather programs with other NPDES, compliance assistance, and enforcement activities.

The Report to Congress on the Impacts and Control of Combined Sewer Overflows and Sanitary Sewer Overflows is available at http://cfpub.epa.gov/npdes/cso/cpolicy_report2004.cfm.

For additional information on the survey APWA conducted on CSOs and SSOs, please contact Heather McTavish Doucet at (202) 408-9541 or hdoucet@apwa.net.