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1 TO: FROM: DATE: SUBJECT: Board of Directors ~ AJ Frederick A. Laskey, Executive Director/--.../ June 27, 2012 Comparison of the MWRA Long-Term CSO Control Program with the CSO Programs of other Agencies and Municipalities Pamela A. Heidell, Policy & Planning Manager David A. Kubiak, Senior Program Manager Preparer/Title In response to a request from the Board of Directors, this staff summary compares MWRA 's progress on Combined Sewer Overflow (CSO) control with other communities. The comparison reveals that MWRA appears to be closer to completing its long-term CSO control obligations and achieving water quality benefits than most large CSO metropolitan areas in the country. MWRA 's accomplishments relative to others are evident and measureable by progress with plan implementation and progress toward compliance with water quality standards. Nationwide, there are 772 CSO communities, which are regulated by 853 permits. The large majority of CSO communities are in the Northeast (EPA Regions 1, 2 and 3) and in the Great Lakes states (EPA Region 5). In a 2001 report, EPA indicated that approximately 30% ofcso communities have populations greater than 75,000 and approximately 30% are small with service populations less than 10,000. The 2001 report noted that 34% of CSO communities had submitted draft Long-Term Control Plans (LTCP) to a NPDES authority, and 19% had an approved LTCP. Data provided by EPA in 2012 indicated that by the end of 2011, 736 of 853 CSO permittees, or 86%, were committed to a schedule incorporated into either a NPDES permit or an Enforcement Order that contains specific program dates and milestones. EPA Region 1 has no comprehensive database on CSO control progress in New England, and data from EPA's national headquarters

2 were limited to administrative measures. Therefore, MWRA staff conducted its own survey of CSO control progress by extensive consultation of web-sites of cities and states with CSOs (see Attachment 1). Staff looked at major metropolitan areas across the country with CSOs, as well as other communities in Massachusetts and throughout New England. The amount and quality of information available varied. Findings of MWRA Survey: How MWRA Compares to Major Cities By December 2015, MWRA and its CSO communities will complete implementation of MWRA s approved LTCP. The LTCP, as mandated by the Federal District Court Order in the Boston Harbor Case, consists of 35 projects to bring CSO discharges at 84 outfalls into compliance with the Federal Clean Water Act and Massachusetts Surface Water Quality Standards. MWRA and its CSO communities have completed 29 of the 35 projects. Four projects are well into construction, and MWRA recently commenced design of the remaining two projects. MWRA has expended $784 million on development and implementation of its LTCP, approximately 91% of the CSO Control Plan budget of $857 million in the FY12 Capital Improvement Program. MWRA has reduced average annual CSO volume from 3.3 billion gallons in the late 1980s when its CSO control efforts began to about 0.5 billion gallons today (an 84% reduction), and 83% of the remaining discharge is treated at MWRA s four CSO facilities. In total, the amount of untreated CSO discharges has been reduced by 94.5% so far, and is expected to be reduced by an overall 98% when the plan is fully implemented in December CSO discharges have been eliminated at 32 of the 84 MWRA or community owned outfalls and there has been virtual elimination (25-year storm level of control) at the five remaining outfalls along the South Boston beaches. There are no longer CSO discharges to the other beaches formerly affected by CSOs. Schedule Seven of the Federal District Court s order requires MWRA to complete the last of its 35 CSO projects by December 2015 and to commence a three-year performance assessment of its LTCP by The last milestone in Schedule Seven requires MWRA to submit the results of the assessment demonstrating it has achieved compliance with the levels of control specified in its LTCP by December The performance objectives, performance measures and levels of control in MWRA s LTCP were recommended by MWRA and agreed upon by EPA and DEP during the years of technology-based and water quality evaluations MWRA conducted to support the Final CSO Conceptual Plan and System Master Plan (1994), Final CSO Facilities Plan and Environmental Impact Report (1997) and revised recommended plan (2006) and other related planning documents. The summary table on the following page compares MWRA s progress regarding CSO Control plan development and implementation with other major metropolitan areas/sewer districts. More detailed information is included in Attachment 1, with some highlights noted below. 2

3 SUMMARY OF NATIONAL METROPOLITAN AREAS CSO CONTROL PROGRAM STATUS* CSO Community CSO LTCP % Complete Year Complete Total Cost Approval/ Status Cost spent/total cost (Infrastructure) San Francisco % 1997 $1.45 billion Atlanta % 2008 $759 million Milwaukee 1983 (Facilities Plan) 100% 2010 $1.0 billion Portland, OR % 2011 $1.4 billion MWRA 1998 (revised 2006) 91% 2015 $857 million Baltimore 2002 (CO) 90% (approx.) 2016 $900 million Cincinnati (Phase 1) $1.5 billion Louisville 2009/2012 (reassess) 62% 2020 $2.25 billion Washington D.C $2.6 billion Indianapolis 2009 (revised) <15% 2025 $1.7 billion Seattle /King County 2012 for revised Plans 20% 40% $ 282 million $1.2 billion Pittsburg/ALCOSAN In development 2026 $10 +billion Chicago % 2029 $3.4 billion Columbus 2007/ $2.5 billion New York Revised Plan to be submitted % 2030 $5.7 billion Philadelphia 2011 (revised) 20% 2030 $1.0 billion Kansas City 2010 <10% $2.5 billion Detroit 1993/2011 <50% 2034 $1.58 billion Cleveland 2011 (revised) 30% 2035 $3.0 billion St. Louis % 2036 $2.4 billion *Based on best available information on the web Regulatory Context for CSO Control The EPA s National CSO Policy was published in 1994 and codified into federal law in 2000 (it replaced a less flexible 1989 policy). The 1994 CSO Policy envisioned that CSO communities were expected to develop LTCPs that would provide for full compliance with the Clean Water Act and attainment of water quality standards. The LTCPs were to assess a range of control options, and provide project milestones and a financing plan for design and construction. In 2007, EPA signed the Green Stormwater Infrastructure Statement of Intent and since then, EPA has authorized permitting authorities to structure their permits as well as guidance or criteria for stormwater plans and CSO LTCPs to encourage permittees to utilize green infrastructure (GI) approaches. EPA has issued five policy memos supporting the integration of green infrastructure into NPDES permits and CSO solutions, including the June 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework to facilitate the use of sustainable and comprehensive solutions, including green infrastructure, that protect human health, improve water quality, manage stormwater as a resource, and support other economic benefits and quality of life attributes that enhance the vitality of communities. Projected CSO reductions as a result of implementing a GI approach frequently rely upon modeling and smaller scale demonstration projects. Actual effectiveness of GI requires additional actual field experiences and monitoring. For example, New York City s Consent Order requires their LTCP to include performance metrics for GI CSO reductions and the 3

4 preparation of a Contingency Plan of additional grey and green infrastructure projects if green projects do not achieve the projected CSO reductions. While much of the EPA s GI guidance came after the bulk of MWRA projects were completed (pursuant to a Court ordered schedule), there are elements of GI in the MWRA and communities CSO control programs. The Cambridge Outfall and Wetland Basin, one of the last large MWRA CSO control projects to be implemented, includes a green technology that consists of a new storm drain to convey separated stormwater to a new, constructed wetland that was designed and constructed to conform to existing ecological patterns and natural processes. This wetland basin is the largest GI project in New England. It will provide detention storage and control pollutants, as well as provide recreational and educational benefits consistent with DCR s Alewife Brook Reservation Greenway Master Plan. Its concept is similar to Philadelphia s much heralded Green City, Clean Waters program and is consistent with the latest regulatory thinking on storm water/cso control/green technology. Elsewhere, in the combined sewer area of Boston, BWSC has a Downspout Disconnection Program targeted at downspouts that discharge to the sewer system, thereby removing stormwater from the combined system and replenishing groundwater; downspout disconnection is a recognized GI measure. BWSC estimates that 23,602 downspouts have been disconnected from sewer systems to date. In addition, to reduce stormwater volume and reduce nutrient loading, BWSC has been requiring project developers to infiltrate stormwater into the ground. BWSC is also requiring projects in the City s Groundwater Conservation Overlay District to recharge groundwater into the ground, and projects in the lower Charles River watershed to infiltrate stormwater discharging from impervious areas. Project proponents must fully investigate methods for retaining stormwater on-site before the Commission will consider a request to discharge stormwater to the Commission s system. For projects implemented later in MWRA s CSO federal court schedule and after the introduction of GI, MWRA considered and in some cases incorporated components of GI. As part of the Morrissey Boulevard Drainage Conduit project, flood drainage swales in ball parks and other public lands were evaluated, although this GI component was not adopted as a result of concerns regarding retained water on area recreational facilities. At Union Park, MWRA incorporated a stormwater capture and infiltration basin for the facility paved parking area. A similar stormwater capture and infiltration basin was also installed at the South Boston CSO Pump Station. Further Information on CSO Communities Nationwide Larger cities like New York, Philadelphia, Chicago, Detroit, Cleveland/Northeast Regional Sewer District, Seattle/King County, Washington D.C., St. Louis, Columbus, Cincinnati, Indianapolis, Kansas City, and Pittsburgh are not as far advanced in implementing their LTCPs as MWRA. All have Consent Orders with more extended timelines for completion and schedules out to 2025 and beyond are common. More detailed information is included in Attachment 1. In some instances, longer implementation plans reflect revised LTCPs and the incorporation of green infrastructure. For example: 4

5 New York City now plans to substitute GI projects for certain grey projects included in its 2005 Consent Order; however, grey technology continues to deliver the vast majority of annual CSO volume reduction. The City s Green Strategy includes both cost effective grey infrastructure (built and planned) plus GI, and system optimization. It does not include potential tanks, tunnels, and expansions that New York City concluded were not cost effective and would not have a meaningful impact on CSO volume or water quality. The results of more sophisticated collection models, updated population projections, and ongoing and future water conservation efforts were also factors leading to a substantial reduction in projected discharges and allowing certain grey projects to be eliminated, irrespective of green infrastructure (not unlike MWRA s reassessment of its original 1990 tunnel plan for CSO control). The City is developing a city-wide LTCP that is to be submitted by 2017; the LTCP date was extended to benefit from initial green infrastructure pilot results. Its Consent Order allows elimination of certain grey infrastructure, and defers construction of less cost-effective grey infrastructure projects, based on an agreement to construct other grey and green infrastructure projects. As initial steps, the City is undertaking two GI demonstration projects to field-verify concepts in the green infrastructure plan. Pre- and post construction flow monitoring of certain implemented grey infrastructure and demonstration projects will also support the development of the LTCP. New York City s proposed plan includes expenditures of $187 million by 2015 to advance GI strategies, and other grey water quality related projects in lieu of storage tanks and other wet weather controls. New York City s revised CSO program is purported to achieve better performance than its 2005 program by incorporating the latest technologies, and is estimated to save more than a billion dollars. New York City has already spent $1.8 billion on grey infrastructure. Philadelphia received approval in 2011 for revisions to its original LTCP, which had included capital projects and watershed planning. The revised Green City, Clean Waters plan includes more than $1 billion for GI, as well as funds for stream corridor restoration, and $320 million for wet weather treatment upgrades. Prior to considering GI projects, Philadelphia was pursuing tunnels for CSO control. The city has spent about $200 million on LTCP commitments. The LTCP includes large scale implementation of GI within a 25-year period. Philadelphia notes that it is creating, testing, and implementing new integrated strategies which promote the economic and social growth in the city while meeting the environmental, ecological, and business missions of the utility. It speaks of a paradigm shift, and the greening of the city. Philadelphia s LTCP level of control is an 85% reduction in annual CSO discharge volume, a level of control already achieved by MWRA. Indianapolis original LTCP was modified in 2009, by replacing a proposed major new interceptor with a tunnel and a comprehensive GI program. It has a 25-year timeline for meeting its Administrative Consent Decree to reduce average annual CSO volumes from 7.8 billion to 642 million gallons. Northeast Ohio Regional Sewer District (NEORSD) serves Cleveland and 61 other communities. Its 2003 LTCP included the construction of seven storage tunnels to reduce overflows to less than four per year. The plan was estimated to cost $1.6 billion. By 2009, the estimated costs had risen to more than $3 billion. NEORSD developed a 5

6 new plan, eliminating one tunnel and including a combination of grey infrastructure and GI ($42 million is allocated for green infrastructure projects). The Consent Decree allows 25 years for build-out of controls. Also, approvals for schedule extensions may reflect greater comprehensiveness of revised plans that address non-cso, as well as CSO, wet-weather problems. For example: Chicago has constructed Phase 1 of its Tunnel and Reservoir Program, including more than 109 miles of tunnels that have captured 84% of pollutant loads. The tunnels are intended to provide 17 billion gallons of storage. Three reservoirs are to be constructed to provide additional storage as well as flood control, with total cost of $3.4 billion. The city has expended more than $1 billion to date. The reservoirs are long-term components to be completed over the next 20 years. In addition, Chicago is pursuing GI as well as purchase of new skimmer boats to collect floating debris on the river. Financial hardship has also delayed/crippled CSO implementation efforts: Detroit adopted its Rouge River Remedial Action plan in 1988 which called for substantial investment in CSO control facilities, and included a $2.2 billion program to eliminate, capture or treat combined sewage and reduce CSO discharge volumes by 85%. Parts of the program have been completed including 4 of 6 detention basins where diverted flows are screened and disinfected, a new pumping station, wastewater treatment plant improvements, and in-system storage facilities. CSO volumes have purportedly been reduced by 65%. However, the centerpiece of Detroit s plan and a condition of its consent decree, the Upper Rouge Tunnel, at a cost of $1.5 billion, was cancelled in Detroit has indicated that EPA s criteria for financial hardship will be exceeded for the foreseeable future. Detroit s Alternative Rouge River Control Plan includes 25 phased projects focusing on GI (to reduce CSO volume by 10-20%). A few large cities/districts have made comparable or greater progress than MWRA: Baltimore signed a consent order with EPA in 2002 that requires $900 million in expenditures over 14 years to address both SSOs and CSOs, and it appears that the bulk of projects have been completed (sewer separation, pump station, construction of force main and interceptor). Baltimore is seeking to eliminate all CSO discharges. Portland, Oregon has met a series of milestones identified in its 1994 CSO Facilities Plan and Final Order with Oregon DEQ, including completion of various interceptors, large tunnels, and green infrastructure, at a cost of $700 million. Implementation of its plan has reduced CSO discharges by 99% to one river way, and 94% to another, reducing CSO from 6 billion gallons a year to million gallons a year today. Milwaukee completed its $1 billion Inline Storage System Tunnel Plan in 2010, and has reduced CSO discharges system-wide to less than 3 activations per year (claimed by Milwaukee to meet presumptive goals of the National CSO policy). Milwaukee s plan also includes GI components. While Milwaukee is currently working on a 2020 Facilities Plan to supplement CSO control levels, its primary purpose is said to be controlling sanitary overflows. 6

7 San Francisco implemented its LTCP by 1997 which reduced CSOs at 43 locations to the range of 1-10 per year, depending upon location (e.g., 10 overflows were permitted where the shoreline was primarily industrial or maritime). The city has reduced CSO volume by 85% system-wide, and all remaining flows receive treatment. Atlanta has completed the CSO components of its wet-weather Consent Decrees (the Consent Decrees also have components to address SSOs, which have not been completed). Via tunnels, extensive sewer separation, and a storage and dechlorination facility, Atlanta has reduced overflow volumes by 95% and has reduced overflow events to a handful annually. Massachusetts In Massachusetts, the cities outside the MWRA service area with the larger number of CSOs, such as Springfield, Chicopee and Fitchburg are all considerable distance from completion of LTCP implementation. Springfield has updated its LTCP (2012), which recommends implementation of projects over two phased 20-year periods. It has spent approximately $87 million to date on new pumping stations, rehabilitated sewers, sewer separation and new regulator structures but has identified additional CSO projects totaling $136 million as well as other wastewater projects. Chicopee is similar, in that it has made progress via sewer separation and a new CSO control (treatment) facility, but is facing additional costs of approximately $150 million and in 2009 recommended a 20-year phased plan for CSO control, primarily involving sewer separation. Fitchburg, too, has much work to do, and has requested an extension of time to complete its $60 million control plan due to financial hardship. Some smaller Massachusetts communities have eliminated CSOs and/or are compliant with CSO standards, including Palmer, Agawam, Ludlow, Montague, South Hadley, and West Springfield. CSO controls were achieved by sewer separation and/or treatment plant upgrades. In terms of other cities in Massachusetts with CSOs, some have made progress towards CSO control: Worcester constructed a CSO treatment facility; Greater Lawrence Sanitary District has completed improvements to increase capacity; Haverhill has completed Phase 1 CSO upgrades that have reduced CSO volume by 66% but has recommended no further capital investment until data indicate there is a clear benefit to additional CSO reduction efforts; Taunton has increased pumping and treatment capacity and is in the process of implementing a 10-year long pipeline repair and replacement program, with the objective to eliminate CSOs by 2013; Fall River has constructed and is operating a CSO tunnel and is in the process of implementing a modified plan to be completed by

8 New England There were 13 communities in Connecticut with CSOs in the 1970s, now there are only five. Hartford s plan is to be implemented over 25 years. In Maine, the number of CSO communities has been reduced from 60 to 32, and of the remaining 32, 39% of the total overflow volume occurs in Portland. The lower number of communities with CSOs is primarily a result of sewer separation work in smaller communities having relatively limited CSO discharge. The largest New Hampshire communities are similarly grappling with CSOs, with implementation plans out to 2020, whereas other communities have eliminated CSOs by extensive sewer separation. Staff are continuing to collect data on CSO programs from other utilities. ATTACHMENT: 1. Summary of Nationwide Agency and Community CSO Program Efforts 8

9 ATTACHMENT 1 TABLE OF CONTENTS SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS City/Agency Page MWRA 1 New York City 1 Chicago/Metropolitan Water Reclamation District 3 Philadelphia 4 Detroit Water and Sewer Department ` 5 Cleveland Ohio/Northeast Regional Sewer District 5 Seattle/King County 6 Washington D.C. 7 San Francisco 7 St. Louis Metropolitan Sewer District 8 Columbus 8 Cincinnati 9 Indianapolis 10 Milwaukee/Milwaukee Metropolitan Sewer District 10 Atlanta 11 Louisville 11 Kansas City 12 Pittsburg/Alleghany County Sanitary Sewer Authority 13 Portland 13 Baltimore 14 Nashville 14

10 SUMMARY OF MASSACHUSETTS COMMUNITIES CSO CONTROL PROGRAM STATUS City/Agency Page Springfield Water and Sewer Commission 16 Chicopee 16 Fitchburg 16 Fall River 16 Worcester 17 New Bedford 17 Taunton 17 Palmer 17 Haverhill 17 Lowell 17 Holyoke 18 West Springfield 18 Agawam 18 Gloucester 18 Greater Lawrence Sanitary District 18 Lynn 18 Ludlow 18 Montague 18 South Hadley 18 SUMMARY OF OTHER NEW ENGLAND STATES CSO CONTROL PROGRAM STATUS State Page Connecticut 19 Maine 19 New Hampshire 20 Rhode Island 20 Vermont 20

11 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS MWRA 84 CSOs Approved Plan: Final CSO LTCP approved in 1998 and revised in Early phases included system optimization projects and Deer Island pumping improvements. The LCTP is comprised of 35 projects, 29 of which are complete and operational. LTCP s objective is to bring CSO discharges at 84 outfalls into compliance with Federal Clean Water Act and MA Water Quality standards. The LCTP was developed based on a demonstration approach, demonstrating compliance with water quality standards. MWRA has specific numerical levels of control at each CSO location, which become numerical limits in the MWRA s and communities CSO permits. The LTCP is scheduled to be complete and fully functional for its intended CSO and environmental benefit by In 2020, MWRA is required to verify the level of CSO control attained. Cost: Total cost of CSO control program is $857 million (FY12 CIP). To date, MWRA has spent $784 million. Major Dates: As of 2012, 29 projects are complete, four of the remaining six projects are in construction, and the last two are in design as of April Full implementation by December, Level of Control: Discharges have been eliminated or effectively eliminated (i.e. 25 year storm level of control for South Boston beaches) at 37 outfalls, including sensitive beaches and shellfish areas. MWRA began CSO Control efforts in 1987 when average annual CSO discharge was 3.3 billion gallons. By 2011, CSO discharge volume was reduced to 0.5 billion gallons, with 82% treated. Target of LTCP is 0.4 billion gallons a year with 93% treated, thereby reducing untreated discharges by 98%. Consent Decree/Order: MWRA has Federal Court Order. New York City and New York City Department of Environmental Protection CSOs Approved Plan: Revised City wide LTCP to be submitted in LTCP for various watersheds submitted between Currently modifying LTCP and extending dates to incorporate initial Green Infrastructure (GI) pilot results. Defers decision to move forward with CSO tunnels to 2017 (tunnels would cost $1 billion each). Modeling projected CSO reductions based on managing stormwater equivalent to one inch of rainfall on 10% of available impervious surfaces in City s combined sewer area. The City is now is substituting some green infrastructure and alternative grey infrastructure projects for grey projects previously proposed that the City concluded were not cost effective, and that would bring little CSO reduction benefits. Its Green Plan includes GI as well as both built and planned grey infrastructure; and most of the CSO reduction in the Green Plan is being

12 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS achieved by grey infrastructure, as illustrated below. Goals of GI are to manage 1.5% of available impervious surface in CSO areas by 2015, 4% by 2020, and 7% by 2025 and 10% by If 1.5% GI application rate not achieved by 2015, contingency plan that includes mixture of additional and gray and GI must be submitted. Cost: New York City has spent $ 1.8 billion so far to significantly reduce CSO discharges. The City now plans to spend $1.5 billion for GI plan implementation and an additional $1.6 billion for grey infrastructure (including cost effective grey infrastructure projects now under construction). For GI alone, plans to spend $187 million through 2015 and in subsequent years, additional public expenditures on implementation of infiltration 2

13 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS technologies, including biofiltration, vegetated swales, pocket wetlands, and porous and permeable pavements on public lands and right of ways. Additional private expenditures are also contemplated. Major Dates: So, far the City has met more than 120 milestones in that order and has brought four large retention/storage facilities on line, is in the process of maximizing treatment capacity, and has constructed other sewer improvements. Level of Control: The City has increased CSO capture rates from 30% in the 1980s to over 72% today, and greater than 90% of the Harbor is in compliance with existing water quality standards. The Green Strategy is predicted to provide greater CSO reductions in nine watersheds, but less CSO reduction than the Potential Tanks, Tunnels and Expansions (enormous CSO tunnels and tanks) in four watersheds, where the City s Plan states it is necessary to assess whether the gap in CSO reduction will translate to a significant impact on water quality. Consent Decree/Order: 1992, 1996 CSO related Orders, and also 2005 Order on Consent with the New York Department of Environmental Conservation, which was modified in 2008 and 2009, and recently in March Chicago IL/ Metropolitan Water Reclamation District of Greater Chicago serves Chicago and 51 communities 3 Chicago owns 36 CSO outfalls. 51 satellite communities served by Metropolitan Water Reclamation District of Greater Chicago own 334 outfalls. Approved Plan: Capital CSO program has centered on TARP (Tunnel and Reservoir Plan), which is designed to capture CSO from 369 outfalls in Chicago and surrounding communities. TARP Phase 1 (Tunnel portion) approved as Chicago s LCTP under Presumptive Approach of 1994 National CSO Policy. TARP includes 109 miles of tunnels that have a storage capacity of approximately 2.3 billion gallons and three storage reservoirs. Cost: Total cost estimate for CSO control approximately $3.4 billion. Chicago has spent a little more than a billion dollars for the first two phases of deep tunnel. Major Dates: Construction began in 1976, and various tunnel segments were completed between 1980 and One reservoir has been operational since The mining of the two reservoirs yet to be constructed has began (private mining operators are recovering limestone) but are long term projects with one reservoir to be operational by 2015, and the other by in 2017 (first stage) and 2029 (second stage). Recent December 2011 settlement with EPA requires Chicago to eliminate a substantial percentage of CSOs by December 31, Level of Control: Tunnels (first phase) are estimated to capture 84% of pollutant loads.

14 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS Second phase will provide flood control benefits as well as increased capture of combined sewage. Storage of CSOS in tunnels and reservoirs intended to provide for 17 billion gallons of storage. Consent Decree/Order: Yes, Department of Justice and EPA. Other: In addition to tunnels, CSO control plan also includes a plan for floatables control, purchase of new skimmer boats, and post construction monitoring. Consent Decree includes a Green Infrastructure program for additional CSO control at a cost of $25 50 million. Philadelphia 177 CS0 discharge locations, down to 164 outfalls in 2009 Approved Plan: Philadelphia submitted its LTCP in A CSO LTCP update was approved by PA DEP in Plan includes green infrastructure, stream corridor restoration and preservation, wet weather treatment upgrades including expansion of one treatment plant to include secondary system bypass, a 60 mgd increase at another WTP, and a 50 mgd increase through hydraulic and process improvement. Cost: $200 million already spent toward LTCP commitments (including NMC, capital projects, and watershed planning). Plan entails about $1.0 billion for green infrastructure, and in total, an estimated $3 billion in full investment through addition of leveraged activities. Major Dates: As of 2009, more than $336 million in commitments already in place for green infrastructure. At the 20 year mark, City will have spent $ 1.6 billion, to provide for capture of 80% of mixture of sewage and stormwater that would otherwise flow into rivers Level of Control: LTCP requires elimination or removal of pollutants that would be removed by capture of 85% of volume of CSO collected on a system wide annual average basis. Consent Decree/Order: 2008 Consent Order with PADEP to update LTCP. US EPA and City of Philadelphia have signed a Partnership Agreement to ensure that the Green City Clean Waters program meets the requirements of the Clean Water Act and is legally authorized and protected by both parties. Administrative Consent Order to be developed. Other: Large scale, gradual implementation of green infrastructure. Committed to developing 9,564 greened acres by end of 25 year period, including publicly owned lands and larger commercial properties. The theory is that each greened acre will manage the first inch of runoff from one impervious acre of combined sewer service area and a green acre will stop % of pollution from occurring. 4

15 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS Detroit Water and Sewer Department (Detroit plus suburban communities) 86 discharge locations (more than 25% of the service area is combined) Approved Plan: Originally, four part strategy to address CSOs: source reduction, in system storage via Upper Rouge Tunnel with storage volume of 760 mg, wastewater treatment plant construction, and end of pipe treatment which includes facilities to store and treat. Now, an alternative Rouge River CSO control Plan advanced that includes a 25 year phased plan that focuses on Green Infrastructure along with right sized conventional CSO facilities. GI components projected to reduce CSO volumes by 10 20%, and enable smaller more cost effective grey facilities. Cost: Initially committed to construction of a nearly $2.2 billion program to eliminate, capture, or treat combined sewage. Upper Rouge Tunnel was $1.5 billion of this and was cancelled. Major Dates: Work on CSO remedial plans began in 1985; Rouge River Remedial Action Plan was adopted in Lack of funding crippled the Upper Rouge Tunnel in 2009, which was supposed to have been completed in Level of Control: Original plan estimated that the volume of CSO would be reduced by 85% when facilities completed. Designed with demonstrative approach. Investments in CSO control have reduced CSO discharges 64% by volume from 1995 (from 7.7 billion to 2.8 billion/year). Consent Decree/Order: 2008 NPDES permit and Consent Decree by EPA Comments: Although tunnel cancelled, 4 out of 6 detention basins complete and operational (flow diverted to basins is screened and treated with disinfectant), with two in construction. There are three screening and disinfection facilities in operation (facilities treat CSO without ever storing it) and dams and gates to maximize storage capacity of sewers during storms are operational, as well as new pump station and pumps at WWTP. The Nine Minimum Controls (NMC) were implemented. Environmental outcomes for the revised plan are supposed to be similar, but with cost savings, and DWSD projects that there will be no untreated CSO volume to Rouge River once facilities are placed in service. Cleveland OH/Northeast Regional Sewer District (serves Greater Cleveland and 62 communities) permitted CSO locations. NEORSD has three treatment plants, 200 miles of large interceptors, and 80 square miles Approved Plan: Original 2003 approved plan included seven storage tunnels, as well as computer aided gates and inflatable dams to store CSOs and then release flow to treatment plants when the rain subsides, NMC, interceptors to reduce CSO, as well as floatable control netting facilities at 10 locations. Revised plan includes combination of grey infrastructure and green infrastructure and construction of six or seven storage tunnels. Cost: So far, NEORSD has spent approximately $900 million in projects to reduce CSO by

16 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS of combined area 50%. The 2003 LTCP included a $1.6 billion program with a 30 year schedule. Costs escalated; revised plan cost is $3 billion. Major Dates: 2003 Plan had 30 year schedule. The new Plan has CSO control measures to be implemented over the next 25 years. Aspects must be completed within 8 years (from 2011) to demonstrate control, but 25 years is allowed for build out of all controls. Level of Control: The 2003 original plan included 7 storage tunnels and would reduce overflows to less than 4 a year and capture 98% of total volume of wet weather flow (2 3 overflows/year depending upon location). Overall goal of entire program is to reduce CSO discharges from 4.5 billion gallons/year to less than 0.5 billion gallons. Discharge is to Lake Erie, which is designated a sensitive receiving water. Consent Decree/Order: NEORSD signed a Consent Decree in July 2011 with U.S. Department of Justice, EPA and Ohio Environmental Protection Agency which replaced a LCTP submitted in Seattle, WA and King County 6 Seattle and King County share responsibility for managing CSOs. 92 outfalls and 968 miles of combined sewers in Seattle. Seattle is part of King County. King County manages CSOs in the larger basins Approved Plan: Seattle s CSO control includes a combination of the following CSO control strategies: sewer system upgrades (minor modifications to the existing system); natural drainage solutions measures such as rain gardens, porous pavement, and cisterns that use soil to absorb stormwater); and underground storage, that would be jointly built by King County and Seattle. Seattle had a CSO Reduction Plan approved in 2001 with updates in 2005 and A revised LCTP is expected to be completed in 2012, with approval by King County s CSO Control Plan update is under review: it proposes nine projects, some of which are collaborations with Seattle (2 treatment facilities, 4 storage tanks, storage pipe, conveyance improvements, as well as green infrastructure. King County and Seattle regularly update their CSO plans. Seattle and King County has already reduced CSO volume from 30 billion gallons annually to 2 billion. Cost: King County s proposed plan has cost of $711 million. Total investment of $1.2 billion since 1980s. Major Dates: Seattle s plan implementation between ; King County required to meet targeted CSO levels by Level of Control: While EPA s standard is 4 6 overflows per system per year or 85 percent capture of overflows by mass or by volume, the Washington State Department of Ecology has delegated authority and requires 1 overflow per outfall per year on average. Seattle indicates that one overflow per outfall per year is roughly equivalent to about an 85

17 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS percent reduction system wide. Consent Decree/Order: EPA issued Seattle and King County a Consent Order in 2009 to step up efforts to reduce CSOs. Washington, DC 53 CSOs Approved Plan: NMC implemented and documented in 1996, with updates in 1997 and Phase 1 CSO controls included a swirl facility, inflatable dams for in system storage, expanded pumping capacity and expanded wastewater treatment. The LTCP includes three storage tunnels (8 mile tunnel to control Anacostia River, a 3 mile tunnel for Potomac and one mile long tunnel to control Piney Branch and Rock Creek overflows). The tunnels will hold flows until they can be treated. The Control Plan also includes diversion structures to divert flow into the tunnels, rehabilitated pump stations, low impact development, and green infrastructure. Cost: The approved LCTP was estimated to cost $1.3 billion. More recently, D.C. said Clean Rivers Project will cost $2.6 billion and take 15 years to complete. Require $ 1.7 million to be spent for rain garden and tree plantings, and $3 million to promote green infrastructure in D.C. Major Dates: The LTCP was developed in 2002 and approved in The Plan is to be implemented over 20 years and is to be completed in Level of Control: The LCTP reduces CSO volume from 3,254 mg/year to 138 mg/year, and overflows from 82 to 2 in Anacostia River, 74 to 4 in Potomac River, and 30 to 1 at a major CSO in Rock creek, and 30 to 4 at other small Rock Creek CSOs. As of 2011, D.C. was six years into its Clean River Project, and had already reduced CSOs by 46%. The full scale project will reduce CSOs overall by 96 percent, and to the Anacostia River by 98%. LTCP s goal is to meet water quality standards. Consent Decree/Order: Yes (2005). Is appealing to EPA to reopen to extend deadline to allow for Pilot Green project. San Francisco, CA 7 By 2001, San Francisco had eliminated 7 of 43 CSOs and reduced volume of 7.5 billion gallons of overflow annually by 80% Approved Plan: San Francisco Storage/Transport program designed for sufficient storage to hold flows during wet weather until treatment capacity is available and to reduce CSOS and protect beneficial uses. The discharges from storage/transport structures are permitted and considered treated CSOs. Cost:$ 1.45 billion Major Dates: San Francisco implemented its LTCP by 1997 and NMC by Bayside system brought into operation in The west side system was completed in 1994.

18 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS Level of Control: CSO volume has been reduced by more than 85%, dry weather overflows eliminated and all flows received treatment varying from sedimentation and floatables removal (9%) to primary treatment (9%) through full secondary treatment (82%). System designed and constructed to protect beneficial uses per the Clean Water Act. Designed to allow ten overflow events per year where shoreline use is industrial or maritime, between 4 8 overflows per year where contact water recreation occurs, and one overflow event per year where there are shellfish beds. Review of operational data resulted in conclusion performance complied with design criteria. St Louis Metropolitan Sewer District Columbus, OH CSO outfalls. 75 square miles of 535 square mile service area has combined sewers. 60 CSO locations discharge to Mississippi River, 52 discharge to the lower and middle River Des Peres, 39 to Upper DePeres, 42 CSOs to tributaries of DePeres, and 6 CSO to other areas 62 CSO discharge locations Approved Plan: Ongoing improvements (source control, collection systems, sewer separation, full utilization of excess primary capacity, overflow regulation system), as well as new components (includes treatment of overflows, more sewer separation, tunnel to convey wastewater, and flow storage in 29 foot horseshoe sewers and new storage, 100 mgd treatment unit, and removal of secondary treatment bottlenecks at WWTP). Also, green infrastructure. Cost: In 2009, the estimated costs for completed and ongoing improvements is $634 million. Another $ 1.8 billion is proposed in CSO control plan, including $100 million for enhanced green infrastructure. Major Dates: 25 year baseline schedule for implementing CSO controls with substantial rate increases. Consent Decree/Order: Yes, issued by EPA and State of Missouri to St. Louis Sewer District in 2011, also including SSOs. Level of Control: St. Louis has pursued a control scenario characterized as knee of the curve on urban streams (to point where further expenditures yield significantly diminished returns), coupled with enhanced green infrastructure programs in areas with CSO discharges are to the Mississippi. The plan s objective is either complete elimination in some areas, or control of overflows to a level of four overflows per year, with exception of Mississippi where goal is meaningful reduction. Comments: None of the areas identified as sensitive areas and some modeling for larger rivers indicated that removal of CSO doesn t increase compliance with WQ criteria they are urban streams Approved Plan: An LTCP and System Evaluation Capacity Assurance Plan was submitted in 2005 and approved in The Plan includes the OSIS sewer tunnel which will intercept

19 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS wet weather flows that currently enter into river and instead will convey flows to the city s two treatment plants. Phase 1 includes three shafts and a 23,300 feet 20 foot diameter tunnel; Phase 2 includes additional surface pipes and a pumping system. The project addresses SSOs as well as CSOs. Cost: The Wet Weather Management Plan is estimated to cost $2.5 billion Major Dates: First improvements by Construction of Phase 1 of the tunnel began in 2010 and scheduled for completion in The CO includes a requirement that an Affordability Analysis be submitted in 2015, to determine if the CSO control projects can still be afforded. 20 year schedule for LTCP; conditional 40 year schedule for wet weather improvements. Level of Control: Currently discharge 1.65 billion gallons a year; by 2025, discharges projected to be reduced to 250 million gallons. Once all projects completed, projected discharge is 100 million gallons a year. Consent Decree/Order: Two separate Consent Orders from Ohio EPA and US EPA. Comments: Water quality in certain areas has been temporarily lowered. Cincinnati, Ohio/ Metropolitan Sewer District of Greater Cincinnati (MSD) CSO locations Approved Plan: Has remedied 20 CSOs since 1990 and is working on a plan to address remaining CSOs by Final Wet Weather Improvement Plan approved in federal court in 2010 that focuses on CSO control and implementation of SSO correction plan. The Plan includes completion of 23 pre identified projects to reduce CSOs, implementation of a LTCP, investment in local environmental enhancement projects, and payment of fines. MSD has a three prong approach storage and conveyance (large sewers or underground tunnels including a 30 diameter 1.2 mile tunnel), product control (upgrading existing treatment plants to handle more wastewater or building new plants to treat CSOs before discharge), and source control to control sources of overflows (includes bio infiltration basins, retention basins, pervious pavement, rainwater harvesting. Cost: Capped at $1.5 billion over a period of 19 years. Major Dates: Phase 1, , mandated to capture, treat and remove 2 billion gallons of annual overflows from CSOs. The Phase 2 is beyond 2018, and schedule is not developed; schedule must be submitted to US and OHO EPA by 2017 for approval. Level of Control: EPA mandated that MSD must capture, treat, or remove 85% of the 14 billion gallons of CSO and eliminate all SSO. If costs exceed cap, will have additional time to complete. Currently, discharges 14 billion gallons annually, and more than 100 overflows

20 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS annually. Consent Decree/Order: Approved Decree in 2003 for SSOs, and 2006 Consent Decree for a global wet weather plan Indianapolis Milwaukee, WI/ Milwaukee Metropolitan Sewerage District CSO discharge locations 120 discharge locations. Sewer District includes Milwaukee and 28 municipalities Approved Plan: Submitted its LTCP in 2006, which showed ongoing compliance with the NMC. Whereas the 2006 Plan called for 31 control measures including a shallow interceptor, the Plan was modified in 2009 and the interceptor was replaced with a tunnel and with a comprehensive GI program. Cost: CSO LTCP is estimated to cost $1.7 billion; overall wet weather control plan is estimated to cost $3.5 billion. Major Dates: Entered into Consent Order in timeline for meetings its Consent Decree Level of Control: To reduce CSO volume of 7.8 billion gallons a year to 642 million gallons a year. Consent Decree/Order: Yes, amended twice Approved Plan: Includes two new deep tunnels, to increase storage capacity (ISS, inline Storage System). In addition to the ISS, Milwaukee s CSO permit required rehabilitation of leaky sewers, real time controls, flood management, and green infrastructure, and both NMC and LTCP requirements. Milwaukee is currently working on a 2020 Facilities Plan Recommended Plan that continues to supplement CSO control measures. The 2020 Facilities Plan includes a capital facility to increase the capacity of the ISS pump station, and its purpose is primarily for controlling sanitary overflows, but it will also result in CSO volume reduction Cost: Approximately $1 billion to build deep tunnels, to limit CSOs and eliminate SSOs. Major Dates: First tunnel went into operation in Second tunnel completed by Level of Control: Since start up of ISS, the average system wide frequency of CSO discharges has been reduced to less than 3 and Milwaukee has stated that this performance currently meets presumptive goals of CSO control policy. Consistent with the presumption approach, Milwaukee s Wisconsin Pollution Discharge Elimination System permit requires that CSO discharges be limited to no more than six per year. The CSO control objective was determined based on water quality monitoring, which indicated little water quality improvement from either completely ending all CSOs or nominally reducing them beyond the permit requirements. For most wet weather events, CSOs are captured, stored, and

21 SUMMARY OF NATIONWIDE LARGE AGENCIES/MUNICIPALITIES CSO CONTROL PROGRAM STATUS then pumped for treatment. Monitoring indicates that less than three CSO discharges occur annually on average. Performance meets the presumptive goals of the national CSO Policy. Atlanta, GA Combined area represents about 15% of Atlanta s total area Louisville, KT 106 active CSOs. 37 square mile combined area out of 385 square mile service area serving 700,000 Approved Plan: Components include a deep rock tunnel to convey to two new CSO treatment facilities. Atlanta has constructed the 8 mile long 16 foot diameter Nancy Creek tunnel to reduce SSOs by 70%, from 1000 overflows in 2000 to 300 in 2008; has constructed the Custer Avenue Storage and Dechlorination facility; has separated 33 miles of combined sewers, purchased 2000 acres of streamside property, and has constructed an 8.5 mile long 24 foot diameter West Areas CSO tunnel which can store up to 177 million gallons of combined sewage for transfer to dedicated WTP. Ongoing work includes a sewer system evaluation survey, cleaning of sewers, and construction of the South River tunnel, projects that relate to sanitary sewer overflows. Cost: Costs associated with CSO Consent Decree requirements totaled $759 million. Estimated of total wet weather program are $3 billion; approximately $1.5 billion so far for CSO and SSO control projects. Major Dates: LTCP submitted in 2001, and EPA authorization in NMC implemented in Extensive system characterization in 1999 and LTCP Plan implementation completed in November In 2010, requested 15 year extension to 2029 for completion of other wet weather plan requirements due to a high cost burden. Level of Control: Storage to capture 99% of sewage and 85% of stormwater. Has already reduced overflow volumes by 95% and overflow events are limited to 4, and those will be screened, disinfected, and chlorinated to meet water quality standards. Consent Decree/Order: Yes, 1998 and 1999 and recent amendment request for SSO requirements of amended Consent Decree (Federal Court, Federal EPA and State Environmental Protection Department). Approved Plan: Louisville started CSO control work in 1991, before EPA CSO Control Policy LTCP. CSO control includes NMC (substantial compliance in 2006) and implementation of LTCP elements including: pump station improvements, sewer separation of 66,000 linear feet of CSS, storage basins, solids and floatables removal facilities, and the construction and expansion of treatment plants. The LTCP also includes optimized operating rules and real time control program to maximize in line storage, flow redirection, 11