Method to Verify I/I Reduction to Obtain Moratorium Relief
Abstract:The US EPA and the State of Tennessee use sewer connection moratoriums as an enforcement tool to stop the addition of flow sources to sewage collection systems that may cause an increase in the number or duration of sewage overflows. Operators of collection systems under moratorium need sound approaches for requesting partial or total relief from these enforcement actions. The purpose of this paper is to focus on the methods used for measuring the actual improvements for the sewage collection system (in contrast to how regulatory agencies make decisions about giving credit for those improvements). In that regard, documentation of improvements using uniform levels of I/I removal for classes of defects (derived from literature reviews) may be invalidated by local migration of groundwater from newly repaired defects to nearby, previously undetected defects. Permits and Orders also require flow monitoring to be conducted to demonstrate I/I reduction or to corroborate previous estimates based on defect estimates. Flow (and rainfall) monitoring are important steps. However, the present state of the art for monitoring and analysis lacks standardized procedures needed to assure measurable, objective, and reproducible results. This paper will demonstrate how a standardized procedure for measuring before and after flow and rainfall monitoring results may be applied to verify I/I reduction and capacity recovery for incremental moratorium relief. Data from The City of Brentwood, Tennessee will be used for the example. Flow and rainfall monitoring from the E-11 basin before and after the initial phase of lining 46% of the public sewers resulted in a reduction of 205 million gallons of I/I annually. The City is committed to additional work following the system approach to rehabilitate the associated manholes and sewer service laterals.
Document Type: Research Article
Publication date: 2009-01-01
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