The City of Columbus, Ohio is currently updating their Combined Sewer Overflow (CSO) Long-Term Control Plan (LTCP) and developing a Capacity, Management, Operation, and Maintenance (CMOM) Program. The LTCP and CMOM programs will ultimately identify in the neighborhood of 2 billion in
capital improvement projects. The programs are being developed by independent consultants under separate budgets. Developing two such programs of this magnitude is a daunting, and perhaps unprecedented, challenge. This paper focuses on the regulatory challenges faced in coordinating the
technical solutions for each program to ensure Columbus receives the best possible overall wet weather program. In addition to the obvious stumbling blocks faced on the road to mitigating Sanitary Sewer Overflows (SSOs), CSOs, and water-in-basement occurrences, and providing the best practical
receiving water quality, the consultants have found that the regulations governing CSO and SSO mitigation may prove to be, in fact, obstacles to providing the best possible reduction in pollutants discharged and receiving water quality. This paper will focus on this issue in some detail, providing
results from SWMM modeling, wastewater treatment plant (WWTP) process models, and a Monte Carlo analysis of blended effluents to prove that the discharge of pollutants could be reduced thereby improving receiving water quality and saving money if the regulatory hurdles that treat CSO and SSO
differently can be overcome.
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