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TIMELY, COST EFFECTIVE SANITARY SEWER OVERFLOW CONTROL MEETING WATER QUALITY STANDARDS WHILE TESTING THE REGULATORY ENVELOPE

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This paper presents an alternative approach to Sanitary Sewer Overflow (SSO) control that would achieve water quality standards while testing the limits of the Clean Water Act as interpreted by the Michigan Department of Environmental Quality (MDEQ). It provides SSO elimination within two years by maximizing in-system storage and creatively using all existing Combined Sewer Overflow (CSO) Retention/Treatment Basins (RTB). This rapid SSO elimination provides temporary relief which thereby allows the communities ample time to remove excess flows through traditional methods, as well as aggressive footing drain removals. While the technical solutions are creative, they are also easily implemented. The regulatory challenges proved to be far more difficult.

The office of the Oakland County Drain Commissioner (OCDC) proposed a 25 million alternative approach to SSO control that would achieve superior environmental results to the 180 million program originally advocated by the MDEQ. The MDEQ, however, was reticent to allow this alternative approach because it was inconsistent with its traditional approach and was contrary to its strict reading of the Clean Water Act. In the end, the program was allowed to proceed after the MDEQ revisited three policy decisions. These constraining policies had been used for many years at MDEQ staff level but had not been vetted through Michigan's rule making process nor, in the opinion of the Oakland County Drain Commissioner, were they required by Federal environmental laws. The SSO control program proposed by the OCDC maximizes the use of existing CSO basins during wet-weather periods when storage and/or treatment is most valuable. Oakland County believes that their program will save over 100 million, is consistent with all Federal policies, and will achieve water quality standards.

This innovative strategy utilizes existing facilities to provide in-system storage early in the program that prevents most SSOs while the communities continue their efforts to eliminate Inflow/Infiltration (I/I). The operation of these facilities can be easily folded into the Capacity, Management, Operation, and Maintenance (CMOM) programs as they are developed. The challenge was to encourage the MDEQ to revisit its existing programs and regulations affecting the collection systems and allow a control program that was not envisioned when Congress first enacted the Clean Water Act. In the end, MDEQ and the OCDC were able to craft a creative consent order that allowed the project to proceed.
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Document Type: Research Article

Publication date: 2004-01-01

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