WASTEWATER COLLECTION SYSTEM MODELING AND DESIGN

Authors Thomas M. Walski Thomas E. Barnard Eric Harold LaVere B. Merritt Noah Walker Brian E. Whitman Contributing Authors Christine Hill, Gordon McKay, Stan Plante, Barbara A. Schmitz Peer Review Board Jonathan Gray (Burns and McDonnell), Ken Kerri (Ret.), Neil Moody (Moods Consulting Pty, Ltd.), Gary Moore (St. Louis Sewer District), John Reinhardt (Massachusetts Department of Environmental Protection), Reggie Rowe (CH2M Hill), Burt Van Duin (Westhoff Engineering Resources)

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CHAPTER

15
Regulatory Issues

Modelers must be aware of the numerous laws and regulations that apply to the design, construction, rehabilitation, management, and operation of sanitary sewer networks. These regulations are used to specify design and performance standards, permitting requirements, and compliance assessment methods. This chapter reviews the major environmental laws, policies, and regulations as they relate to sanitary sewers in the United States, Canada, and the European Union and presents examples of how hydraulic models can be used to demonstrate regulatory compliance.

15.1

United States Laws and Regulations

Until the middle of the twentieth century, water pollution was primarily considered a state and local problem. No federal goals, objectives, limits, or even guidelines existed. Initially, federal involvement was in enforcement and was strictly limited to matters involving interstate waters, but only with the consent of the state in which the pollution originated. The first federal legislation pertaining to water pollution was the Rivers and Harbors Act of 1899, which prohibited the dumping of any material other than sewage or runoff into navigable waterways without a permit from the U.S. Army Corps of Engineers (Zwick and Bernstock, 1971). Although this law was enacted to mitigate interference with navigation, it was used to prosecute some pollution issues until later federal legislation was enacted. Beginning in the middle of the twentieth century, a number of legislative statutes have been put in place in an effort to reduce water pollution and improve water quality.

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The highlights of these policies are described in this section, with an emphasis on the relationship to sanitary sewers and wastewater discharges.

Clean Water Act

The Federal Water Pollution Control Act (FWPCA) of 1948 was the first comprehensive statement of federal interest in water pollution control, and it provided research funds and grants for state and local pollution control programs. During the 1950s and 60s, water pollution control programs were shaped by four federal laws that amended the 1948 statute. These statutes and amendments are known collectively as the Clean Water Act (CWA). While the 1948 FWPCA provided federal assistance to municipal dischargers, the subsequent amendments extended federal involvement to enforcement programs for all dischargers. During this period, federal jurisdiction was extended to include not only navigable interstate waters, but intrastate waters as well. In 1965, water quality standards also became a feature of federal law through the Water Quality Act, which required states to set standards for interstate waters that would be used to determine actual pollution levels. Table 15.1 lists the dates of CWA legislation and subsequent major amendments, which are described in the paragraphs that follow.
Table 15.1 Clean Water Act and Amendments.
Year 1948 1956 1961 1965 1966 1970 1972 1977 1981 1987 Act Federal Water Pollution Control Act Water Pollution Control Act of 1956 Federal Water Pollution Control Act Amendments Water Quality Act of 1965 Clean Water Restoration Act Water Quality Improvement Act of 1970 Federal Water Pollution Control Act Amendments Clean Water Act of 1977 Municipal Wastewater Treatment Construction Grants Amendments Water Quality Act of 1987 Public Law # P.L. 80-845 P.L. 84-660 P.L. 87-88 P.L. 89-234 P.L. 89-753 P.L. 91-224, Part I P.L. 92-500 P.L. 95-217 P.L. 97-117 P.L. 100-4

Starting in the late 1960s, there was a growing perception that existing enforcement procedures were too time-consuming and that the water quality standards approach was flawed. Difficulties in linking a particular discharger to violations of stream quality standards, mounting frustration over the slow pace of pollution cleanup efforts, and a suspicion that control technologies were being developed but not applied to the problems increased dissatisfaction with the approach. These perceptions and frustrations, together with increased public interest in environmental protection, set the stage for the 1972 amendments. In 1972, Congress passed the Federal Water Pollution Control Act Amendments, followed by significant amendments in 1977, 1981, and 1987 (see Table 15.1). This created a comprehensive collection of federal programs to address the serious pollution problems affecting the nation's rivers, lakes, and coastal waters.

Section 15.1

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Titles II and VI of the CWA are the primary funding-related sections and authorize federal financial assistance for the planning, design, and construction of municipal sewage facilities. Title II provides federal grants for projects based on priorities established by the states and funds as much as 55 percent of the total project cost. Congress began the transition toward full state and local government financing with the 1987 amendments. Title VI provides federal grants to capitalize state water pollution control revolving funds, which are used for sewer and treatment plant expansion and improvement projects.

U.S. Federal Regulations

The United States Code of Federal Regulations (CFR) is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. Regulations of the Environmental Protection Agency (EPA) are located in Title 40 of the CFR. Many states have adopted the federal regulations either in whole or with minor modifications. Table 15.2 presents a list of the most important EPA regulations applicable to sanitary sewers. For example, 40 CFR 35 specifies the maximum allowable rates for inflow and infiltration. Strictly speaking, these allowable rates are only applicable to recipients of grants under the CWA. However, they have evolved into de facto standards for sewer systems where alternative infiltration and inflow rates are not justifiable by engineering and economic evaluations. Other related regulations found in 40 CFR 122 are associated with National Pollutant Discharge Elimination System (NPDES) permits, which are described in the next subsection. National Pollutant Discharge Elimination System Permits. Title IV of the CWA created the National Pollutant Discharge Elimination System (NPDES) for permitting wastewater discharges (Section 402). Under NPDES, all facilities that discharge pollutants from any point source into waters of the United States are required to obtain a permit, which is a license for a facility to discharge a specified amount of a pollutant into a receiving water under specified conditions. More than 65,000 industrial and municipal dischargers must obtain NPDES permits from the Environmental Protection Agency (EPA) or qualified states. Currently, 44 states and one territory are authorized to implement the NPDES program on behalf of the EPA. The NPDES permit program provides two levels of control: technology-based limits (based on the ability of dischargers in the same industrial category to treat wastewater), and water-quality-based limits (if technology-based limits are not sufficient to provide protection to the receiving water body). Sewage treatment plants with NPDES permits are required to submit information on their collection systems, including documentation on system operation and maintenance, and reporting on noncompliance with permit requirements. The two basic types of NPDES permits issued are individual and general permits. An individual permit is specifically tailored to an individual facility and is usually used for more distinct and complex dischargers. Once a facility submits the appropriate application(s), the permitting authority develops a permit based on information in the application, such as type of activity, nature of discharge, and receiving water quality. The authority issues the permit to the facility for a specific time period (not to exceed five years), with a requirement that the facility reapply before the expiration date.

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Table 15.2 Important Federal regulations concerning sewers.

Citation* Title and Applicability 35 Inflow and Infiltration; Definitions Regulation Text 35.2005(a) (16) Excessive infiltration/inflow. The quantities of infiltration/inflow which can be economically eliminated from a sewer system as determined in a cost-effectiveness analysis that compares the costs for correcting the infiltration/ inflow conditions to the total costs for transportation and treatment of the infiltration/inflow. (20) Infiltration. Water other than wastewater that enters a sewer system (including sewer service connections and foundation drains) from the ground through such means as defective pipes, pipe joints, connections, or manholes. Infiltration does not include, and is distinguished from, inflow. (21) Inflow. Water other than wastewater that enters a sewer system (including sewer service connections) from sources such as, but not limited to, roof leaders, cellar drains, yard drains, area drains, drains from springs and swampy areas, manhole covers, cross connections between storm sewers and sanitary sewers, catch basins, cooling towers, storm waters, surface runoff, street wash waters, or drainage. Inflow does not include, and is distinguished from, infiltration. 35.2120(b) Inflow. If the rainfall-induced peak inflow rate results or will result in chronic operational problems during storm events, or the rainfall-induced total flow rate exceeds 275 gpcd during storm events, the applicant shall perform a study of the sewer system to determine the quantity of excessive inflow and to propose a rehabilitation program to eliminate the excessive inflow. All cases in which facilities are planned for the specific storage and/or treatment of inflow shall be subject to a cost-effectiveness analysis. (c) Infiltration. (1) If the flow rate at the existing treatment facility is 120 gpcd or less during periods of high groundwater, the applicant shall build the project including sufficient capacity to transport and treat any existing infiltration. However, if the applicant believes any specific portion of its sewer system is subject to excessive infiltration, the applicant may confirm their belief through a cost-effectiveness analysis and propose a sewer rehabilitation program to eliminate the specific excessive infiltration. 122 NPDES Permitting; Information required in an NPDES permit application for new and existing POTWs 122.21(j)(vii) Collection system. Identification of type(s) of collection system(s) used by the treatment works (i.e., separate sanitary sewers or combined storm and sanitary sewers) and an estimate of the percent of sewer line that each type comprises. 122.21(j)(viii) Outfalls and other discharge or disposal methods. Extensive list of information required for each outfall.

35

State and Local Assistance; Standards applicable to recipients of federal financial assistance

122

122.26(b)(2) Illicit discharge means any discharge to a separate municipal storm NPDES Permitting; Stormwater discharges prohibits sewer that does not consist entirely of stormwater. cross connections between storm and sanitary sewers NPDES Permitting; Conditions applicable to all permits 122.41(d) Duty to mitigate. Permittee shall take all reasonable steps to minimize or prevent any discharge. 122.41(e) Proper operation and maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of backup or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. 122.41(l)(6) Twenty-four hour reporting. The permittee shall report any noncompliance which may endanger health or the environment. Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances. 122.41(m)(4)(i) Prohibition of bypass. Bypass is prohibited.

122

*Citation number denotes part of 40 CFR (Code of Federal Regulations).

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United States Laws and Regulations

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General permits offer a cost-effective option to permitting agencies addressing a large number of facilities under a single permit. These permits typically cover categories of point sources having common elements, such as stormwater point sources, facilities that involve the same or substantially similar types of operations, facilities that require the same permit conditions, or facilities that require the same or similar monitoring. The initial focus of the NPDES program was on treatment technology and contaminant-specific effluent limitations. Since then, two trends have developed. The first is an increase in the administrative requirements for permittees, including the development of management plans, record keeping, reporting, and public participation. Second is that the NPDES requirements have expanded from covering the discharge and treatment method to addressing the entire collection system. Combined Sewer Overflow (CSO) Control Policy. Section 502(4) of the CWA defines a combined sewer system (CSS) as a wastewater collection system, owned by a state or municipality, which conveys sanitary wastewaters (domestic, commercial, and industrial) as well as stormwater through a single-pipe system to a publicly owned treatment works (POTW). A combined sewer overflow (CSO) is the discharge from a CSS at a point before the POTW. The US EPA issued the National Combined Sewer Overflow Control Strategy on August 10, 1989 (54 FR 37370). This strategy reaffirmed that CSOs are point-source discharges subject to NPDES permit and CWA requirements. The EPA then issued the Combined Sewer Overflow Control Policy on April 19, 1994 (US EPA, 1994) as a national framework for CSO control through the NPDES permitting program. The Policy provides guidance to municipal, state, and federal permitting authorities for meeting the CWAs pollution control goals in a flexible, cost-effective manner. The four key principles of the CSO Control Policy are: Clear levels of control to meet health and environmental objectives Site-specific considerations to assure flexibility for developing the most appropriate solution Phased implementation of CSO controls to accommodate a communitys financial capability Review and revision of water quality standards during CSO control plan development to account for wet weather impacts. NPDES permit conditions for CSOs require an accurate characterization of the adjoining sewer systems to demonstrate adequate implementation of the following nine minimum control measures: Proper operation and regular maintenance programs for the sewer system Maximum use of the collection system for storage Review and modification of pretreatment requirements to mitigate CSO impacts Maximization of flow to the POTW for treatment Elimination of CSOs during dry weather Control of solid and floatable materials in CSOs Pollution prevention

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Public notification of CSO occurrences and CSO impacts Monitoring to effectively characterize CSO impacts and the efficacy of CSO controls. Permittees with CSOs must submit documentation addressing each of the measures and are responsible for developing and implementing long-term CSO control plans that will ultimately result in compliance with the requirements of the CWA. The longterm plans should consider the site-specific nature of CSOs and evaluate the costeffectiveness of a range of control options and strategies. The selected controls should be designed to allow cost-effective expansion or retrofitting. The minimum elements of the long-term control plan are: 1. 2. 3. 4. 5. 6. 7. 8. 9. Combined sewer system characterization, monitoring, and modeling Public participation Sensitive area analysis Evaluation of alternatives Cost and performance considerations Operational plan development Existing POTW treatment maximization Implementation schedule development Postconstruction-phase compliance monitoring.

Under item 4, Evaluation of alternatives, permittees may select from two approachesthe Presumptive Approach and the Demonstrative Approach. Under

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the Presumptive Approach, a program that meets any of the following three criteria is presumed to be in compliance with the water quality-based requirements of the CWA: No more than an average of four overflow events per year The elimination or capture for treatment of 85% (by volume) of the combined sewage collected in the CSS during a precipitation event in which an overflow will occur (Example 15.1) on a systemwide annual basis The elimination or removal of no less than 85% of the mass of pollutants. Under the Demonstration Approach, the permittee must demonstrate that the planned control program is adequate to meet the water quality standards of the receiving body. Sanitary Sewer Overflow Proposed Rule. A sanitary sewer overflow (SSO) is defined as an overflow, spill, release, or diversion of wastewater from a sanitary sewer system. SSOs do not include combined sewer overflows (CSOs) or other discharges from combined sewers. On January 4, 2001, the US EPA published proposed rules that address NPDES permit requirements for municipal sanitary sewer systems and SSOs. On January 24, the SSO Proposed Rule was withdrawn to give the new administration an opportunity to review it (US EPA, 2001). In the meantime, several state regulatory agencies officially adopted the SSO Proposed Rule, and portions of the rule frequently appear in regional EPA enforcement mechanisms. Even without adoption of the SSO Proposed Rule by the EPA, any discharge of wastewater from a collection system at a point not allowed under the NPDES permit is prohibited and is subject to enforcement. The SSO Proposed Rule (US EPA, 2001) defines SSOs as: Overflows or releases of wastewater that reach waters of the United States Overflows or releases of wastewater that do not reach waters of the United States Wastewater backups into buildings that are caused by blockages in a sanitary sewer other than a building lateral. Some wastewater utilities have expressed the view that the EPA has exceeded their authority under the CWA to include releases in the definition that do not reach waters of the United States. The CWA only prohibits SSOs that reach waters of the United States. Under the SSO Proposed Rule, the standard permit conditions to be included in NPDES permits for POTWs and municipal sanitary sewer collection systems are: Incorporation of a capacity assurance, management, operation, and maintenance (CMOM) program Establishment of a public and health authority notification process Prevention of overflows. In addition, the SSO Proposed Rule calls for expanded permit coverage to satellite systems (i.e., collection systems where no treatment is provided and the owner/operator is different from the owner/operator of the facility providing treatment).

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Capacity Assurance, Management, Operation, and Maintenance (CMOM) Program. A major goal of the SSO Proposed Rules CMOM program is to improve the ability of permitting authorities to comprehensively and proactively evaluate the management programs and performance of municipal sanitary sewer collection systems. It provides the permittee and the NPDES authority with a basis of comparison to assess how the collection system operates and performs relative to the needs and priorities of the local receiving waters and community interests. Municipalities implementing CMOM programs will have to meet the following five standards: Properly manage, operate, and maintain, at all times, the parts of the collection system that the permittee owns or over which it has operational control Provide adequate capacity to convey base and peak flows Take all feasible steps to stop and mitigate the effects of sanitary sewer overflows Provide notification to parties with a reasonable potential for exposure to pollutants associated with an overflow event Develop a written CMOM program summary and required program audits and make them available to the public. Recognizing that not all requirements need the same attention, the rules allow municipalities flexibility in developing their CMOM programs. At a minimum, the permittee must implement a variety of measures, activities, and programs to meet the five performance standards above. Permittees should consider the following: Maintenance facilities and equipment adequacy Collection system map maintenance Information timeliness and relevance (is it up-to-date?) Routine preventative operation and maintenance activities Collection system and treatment facility capacity assessment Identification and prioritization of structural deficiency and rehabilitation response actions. The SSO Proposed Rule preamble discussion states that modeling may be a valuable tool for providing general predictions of sewer system response to various wet weather events and evaluating control strategies and alternatives. As described in Section 15.4, modeling is especially useful for identifying the capacity of the collection system and the effects of rehabilitation and maintenance. Treatment Plant Discharges During Wet Weather. During normal operation at a sewage treatment facility, the incoming wastewater is treated by the primary units and then sent to the secondary (biological) treatment units. However, when wet weather flows exceed the capacity of the secondary treatment units, they are sometimes diverted around the flow-sensitive biological units and later recombined or blended with the wastewater that has been treated by the secondary units. These blended flows are then disinfected and discharged. In November 2003, the US EPA issued a draft policy on the practice of blending (EPA, 2003). This proposed policy states that peak wet weather discharges from POTWs that consist of effluent routed around biological treatment units (or other advanced treatment units) blended with effluent from the biological units (or from other advanced treatment units) would not constitute a prohibited bypass and could be authorized in an NPDES permit if all of the following conditions applied. (A bypass is defined in 40

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CFR 122.41(m) as the intentional diversion of waste streams from any portion of a treatment facility.): 1. 2. The final discharge meets effluent limitations based on the secondary treatment regulation (40 CFR Part 133). The NPDES permit application for the POTW provides notice of, and specifically recognizes, the treatment scenario that would be used for peak flow management. The treatment scenario that would be used for peak flow management should provide, prior to blending, at least the equivalent of primary clarification for the portion of flow routed around biological or other advanced treatment units. The peak flow treatment scenario chosen by the permittee for use when flows exceed storage/equalization, biological treatment, or advanced treatment unit capacity should be operated as designed and in accordance with the conditions set forth in the scenario-specific permit. The permit must require sufficient monitoring, including type, interval, and frequency to yield data representative of the final blended discharge and ensure compliance with applicable water quality-based effluent limitations. The permittee must properly operate and maintain all parts of the collection system over which the permittee has operational control in a manner consistent with 40 CFR 122.41(e).

3.

4.

5.

6.

If a POTW uses peak flow treatment scenarios consisting of effluent routed around biological or other advanced treatment units and then blended together with the effluent from the biological units prior to discharge, its permit should also address the following (EPA, 2003): To the extent practicable, NPDES permit requirements for discharges of peak wet weather flows at the POTW should be developed in a manner that encourages the permittee to consider the relationship between the performance of the collection system and the performance of treatment plants serving the system. The permit writer should ensure that the POTW adequately reflects the incidence frequency and treatment effectiveness of the peak flow treatment scenarios in developing local limits for industrial users. The use of hydraulic sewer models to predict the magnitude and frequency of wet weather flows can be an invaluable tool for managing the flows at the treatment plant and demonstrating compliance with the regulations.

Water Quality Standards and Total Maximum Daily Loads (TMDLs)

Under section 303(d) of the 1972 CWA, states, territories, and authorized tribes are required to develop lists of impaired waters. Statewide Watershed Assessment Reports mandated by the CWA and other legislative and regulatory programs identify water quality deficiencies and prioritize watersheds for assessment. The 305(b) report, or State Water Quality Assessment, identifies and ranks waterbodies with known violations based on narrative or numeric water quality data. The 305(b) reports are prepared by the states biennially.

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States are required to identify impaired water bodies through 305(b) assessments and develop total maximum daily loads (TMDLs) for each. A TMDL is a quantitative assessment of water quality problems, contributing sources, and pollution reductions needed to attain water quality standards. It further allocates pollution control or management responsibilities among sources in a watershed and provides a science-based policy for taking action to restore a water body. Pollutant loadings from CSOs and SSOs are considered when developing the TMDL. Models may be used to estimate the frequency of overflows and the loads of pollutants to the watershed. When the TMDL is established, it may result in requirements for monitoring and/or sewer rehabilitation. TMDLs have been required by the Clean Water Act since 1972. However, by 1996, states, territories, authorized tribes, and the US EPA had not developed many. Between 1996 and 2003, approximately 9600 were approved. The current regulations governing TMDLs were adopted in 1985 and amended 1992 (40 CFR 130.7). Many of the waters still needing TMDLs are impaired by contributions from CSOs and SSOs. Operators of wastewater collection systems should be aware of the status of the receiving waters [as per the 305(b) report] in their watersheds.

Section 404 Dredge and Fill Permits

Section 404 of the CWA requires a permit, issued by the US Army Corps of Engineers, for discharge or fill of dredge materials into the waters of the United States. This jurisdiction includes not only navigable waters, but also their tributaries and associated wetlands. The Supreme Court has held that this jurisdiction extends to lands supporting plant growth typical of wetlands. The scope of activities covered by Section 404 is much broader than the traditional dredging and filling of navigable ship channels. Regulated activities include construction in areas that affect navigable waters, such as the laying of sewers or any appurtenances. These activities may also require permits. The Corps has streamlined the program by issuing nationwide permits for some activities (see 33 CFR 330, Nationwide Permit Program). If certain conditions are met, a specified action can proceed without an individual permit. In these instances, little paperwork is involved and permits may be obtained in a relatively short time (020 days).

15.2

Canadian Laws and Regulations

This section contains an overview of the Canadian laws and regulations that govern the design, expansion, and rehabilitation of wastewater collection systems, including sanitary and combined sewer systems. It is based, in part, on material in the draft Combined Sewer Overflow Treatment Technologies Manual (Environment Canada, 2004). The management of sanitary and combined sewer systems is both a federal and provincial responsibility. At the federal level, there is no national standard. Instead, Environment Canada and Health Canada are responsible for preventing environmental and human health impacts. The provincial requirements are outlined in this section. Where applicable, guidance is also provided on the types of model analysis necessary to meet the regulatory requirements.

Section 15.2

Canadian Laws and Regulations

539

Sanitary Sewer Systems

Most Canadian provinces have established minimum guidelines for the sizing and construction of sanitary sewer systems and for environmental assessments. However, the detailed design, construction, and operation of sanitary sewer systems is ultimately the responsibility of individual municipalities, and their requirements may be more stringent. The following section highlights the current regulations, policies, guidelines, and practices in the Province of Ontario. Similar regulations, policies, guidelines, and practices are in place in the other provinces of Canada. Under the Ontario Water Resources Act, the Ontario Ministry of the Environment reviews and approves applications for all new sanitary sewer works in the province. Local and regional municipalities also review and approve these applications, and in some cases, may complete the review on behalf of the Ministry. The province has prepared guidelines (Ontario Ministry of the Environment, 1985) that describe the minimum acceptable levels of sanitary servicing to assist consulting engineers and municipalities in designing sanitary sewer systems. Key elements of the provincial guidelines are: All new sewers are to be separate. New combined sewers or connections to existing combined sewers are not permitted, except as an interim measure where circumstances allow no alternative. The design of new sanitary sewers is to be based on the ultimate sewage flows expected from the tributary area. The design period is to extend a minimum of twenty years. Sanitary sewers should be designed using Kutter's or Manning's formula with a minimum roughness coefficient of 0.013 and sufficient slope such that a minimum velocity of 2 ft/s (0.6 m/s) will be achieved under full-flow conditions. A minimum velocity of less than 2 ft/s (0.6 m/s) will be considered appropriate where a higher slope would require extensive deepening of a sewage collection system or the addition of a pumping station, provided the municipality accepts that there may be increased maintenance requirements.

Combined Sewer Systems

All provinces in Canada have municipalities served by combined sewers, but in most cases, the construction of new combined sewers is not permitted except where there is no other alternative. Where new combined sewers are planned, they are designed to convey both sanitary and peak storm flows. The management of CSOs in Canada is a multi-jurisdictional responsibility. The following sections present an overview of provincial regulations and guidelines and how modeling is being used to achieve compliance. Some provinces, such as Ontario and British Columbia, have established CSO procedures or regulations. In other provinces, no formal guidelines, procedures, or regulations have been developed, so individual communities have developed CSO control programs in consultation with provincial authorities. The following provinces do not have formal CSO control policies: Newfoundland Nova Scotia

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Prince Edward Island Saskatchewan Yukon Nunavut Northwest Territories New Brunswick. The Province of New Brunswick currently does not have any specific guidelines or regulations for CSO control and does not permit the construction of new combined sewers. Instead, individual municipal agencies, such as the Greater Moncton Sewerage Commission (GMSC), have identified CSOs as a wastewater management issue and developed CSO control targets and strategies to manage them. The GMSC reviewed various CSO control regulations in other North American jurisdictions, and based on their review, identified the following targets: A CSO abatement control target for the GMSC system of 85% wet weather flow capture. The 85% level of control corresponds to the level of control set by the US EPA and has been adopted by a number of major municipalities in Canada, such as the Cities of Winnipeg and Edmonton. Captured CSO flows are to receive equivalent-to-primary treatment, not necessarily including disinfection. Additional management objectives, including improving system reliability by decreasing the number of overflow structures, ensuring the proper operation of the overflows under extreme conditions, reducing the level of surcharging, and reducing the risk of flooding from the operation of the GMSC system. GMSC has addressed these targets with the development of a short-term plan (3-10 years) and a long term plan (10-20 years). The short-term plan includes measures that address the hydraulic performance of the collector system, system reliability, and risk of basement flooding. The long-term plan includes provisions for new storage and treatment facilities. A fully dynamic hydraulic model capable of long-term continuous simulation is used to assess the current performance of the collection system and to develop short- and long-term plans that meet control targets. Quebec. At this time, the Province of Quebec does not have a formal CSO control policy. However, the Quebec Water Policy (Quebec, 2002) highlights issues regarding integrated management of water with a view towards sustainable development. The policy contains a commitment that the province will supplement municipal cleanup efforts. With regard to untreated urban discharges, Quebec undertakes to: Urge and assist municipalities to reduce, by 2007, the frequency of CSOs during wet weather by 20%. The government of Quebec will attempt to achieve this goal by encouraging the installation of control infrastructure such as retention ponds, the optimization of existing systems by utilizing retention capacities of existing sewer lines, and the implementation of more effective management systems. Eliminate wastewater discharges during dry weather periods by 2007. Municipalities are required to develop action plans to meet this commitment. Plans must focus on elimination of illegal connections and the intersection of sewer lines.

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Put into place a strategy governing urban discharges, such as CSOs and storm discharges. The strategy will include long-term environmental targets for discharges, a mechanism for issuing renewable depollution attestations, and environmental guidelines for grant programs. The Quebec Urban Community (Quebec City) is now implementing a long-term CSO control plan. The plan includes the implementation of a real-time control system (RTC) to optimize the existing system with the construction of off-line and in-line storage facilities. To date, a global optimal RTC system is operational. The Quebec Urban Community has used a nonlinear hydraulic model, SWIFT, as a reference model, and MED-SOM as a dedicated application for the real-time control of its sewer networks. SWIFT models both hydrology and hydraulics. The hydrology is based on a conceptual relation between rainfall events and flows and takes into consideration pervious and impervious surface runoff, as well as pipe discharges. A Muskingum algorithm approximates hydraulic behavior, and a numerical solution of simplified Saint-Venant equations gives the attenuation of a wave traveling along a stream. Ontario. In Ontario, the construction of new combined sewers is not permitted except where there is no alternative. Management of CSOs from existing combined sewers is governed by Procedure F-5-5, Determination of Treatment Requirements for Municipal and Private Combined and Partially Separated Sewer Systems (Ontario Ministry of the Environment, 1997). This procedure is a supporting document for Guideline F-5, Levels of Treatment for Municipal and Private Sewage Treatment Works Discharging to Surface Waters.

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Procedure F-5-5 is prescriptive and includes the following: Minimum CSO volumetric control and treatment criteria. The volumetric control criterion for CSOs is applied to the flow collected by the sewer system immediately upstream of each overflow location, unless it can be shown through modeling and/or ongoing monitoring that the criterion is achieved system wide. No increase in CSO volumes above existing levels at each outfall is allowed, except where the increase is due to the elimination of upstream CSO outfalls. The minimum level of treatment required for CSOs is primary treatment or the equivalent. Table 15.3 presents the specific quality and quantity guidelines specified in F-5-5. A requirement for the development and implementation of pollution prevention and control plans. Additional controls for beaches impaired by CSOs. Effluent disinfection is required where the effluent affects swimming and bathing beaches or where there are other public health concerns. Where chlorination is used, any adverse effects from chlorine residuals must be minimized. Provisions for new sanitary and storm connections to combined sewer systems.
Table 15.3 Procedure F-5-5 quantity and quality requirements.
Parameter Volumetric control Carbonaceous biochemical oxygen demand (BOD) Total suspended solids (TSS) Disinfection
1

Guideline 90% capture of wet weather flows1 30% removal1 50% removal1 and not to exceed 90 mg/L for more than 50% of the time Monthly geometric mean not to exceed 1,000 E. coli per 100 mL during wet weather

Over a 7-month period commencing within 15 days of April 15 during an average rainfall year.

To determine specific volumetric control requirements at individual outfall locations, it is customary to utilize a continuous-simulation system model. The model can be fully dynamic to allow for the prediction of surcharge conditions or may be quasidynamic. Treatment of wet weather flows from combined sewer systems may occur at a central wastewater treatment plant or at other locations, such as satellite treatment facilities. Satellite treatment facilities must provide the minimum level of primary treatment specified in Table 15.3. Where there are combined sewage discharges to beach areas, the following additional requirements are imposed. It is customary to use a continuous system model to assess the ability of a proposed facility to meet these criteria. No violation of the body-contact recreational water-quality objective of 100 E. coli per 100 mL based on a geometric mean at swimming and bathing beaches (as a result of CSOs for at least 95% of the 4-month season [June 1 to September 30] for an average year).

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No more than two overflow events per season (June 1 to September 30) for an average year. The combined total duration of CSOs at any single overflow location must be less than 48 hours. Procedure F-5-5 requires municipalities to establish and implement pollution prevention programs that focus on source pollution reduction activities. These programs are usually contained in a formal Pollution Prevention and Control Plan. To address the impact of CSOs, the plan must include the following: Characterization of the combined sewer system. An examination of the nonstructural and structural CSO control alternatives, which may include source controls, inflow/ infiltration reduction, operational and maintenance improvements, control structure improvements, collection system improvements, storage, treatment, and sewer separation. An implementation plan with cost estimates and a schedule of all practical measures to eliminate dry weather overflows and minimize wet weather overflows. A sewer system monitoring program for use in assessing upgrade requirements and determining compliance with provincial requirements. Municipalities implementing a Pollution Prevention and Control Program are expected to meet the following minimum CSO controls: Eliminate CSOs during dry weather periods except under emergency conditions. Establish and implement proper operation and regular inspection and maintenance programs for the combined sewer system to ensure continuation of proper system operation. Establish and implement a floatables control program for coarse solids and floatable materials. Maximize the use of the collection system for the storage of wet weather flows conveyed to the sewage treatment plant when capacity is available. Maximize the flow to the sewage treatment plant for the treatment of wet weather flow. With respect to new sanitary and storm connections to existing combined sewers, Procedure F-5-5 gives the province the authority to: Stop the connection of new sanitary sewers to a combined sewer system until that system has been upgraded. Prevent the connection of new storm drainage to existing combined sewer systems, except where evaluations indicate there is no practical alternative. In addition, proposed CSO control facilities such as storage tanks and treatment facilities are subject to the requirements of the Ontario Environmental Assessment Act (Municipal Engineers Association, 2000). For CSO facilities, the Municipal Engineers Association (MEA) Class EA process is followed. Manitoba. Manitoba does not have a formal CSO control policy. However, specific municipalities, such as Winnipeg, are working to formulate a CSO management program in consultation with the Manitoba Clean Environment Commission. In setting the scope for Winnipeg's management plan, the commission considered CSO regula-

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tions across Canada, the United States, and Europe. Highlights of the proposed plan include: Adoption of the US EPA standard of CSO reduction (four overflows per recreational season or 85% volumetric control), and compliance with the Manitoba Surface Water Quality Objectives. Optimization of existing infrastructure and the development of new initiatives through a progressive, staged program. Enhancements to the existing collection system, including raising weirs, dewatering latent storage, modifying interception rates, and keeping a monitoring system in place. Establishment of an in-line storage demonstration project before the actual implementation of the in-line program. The illustrative control program will be developed based on a 60-year period, with a projected target of three overflows per RS. Periodic reporting on the overall CSO control program, costs, improvement in control, and compliance with objectives is scheduled for review every 5-10 years. The CSO Control program is conceptual and subject to ongoing review. A brief timeline is presented in Table 15.4.

Table 15.4 Winnipeg CSO control program timeline.

Year 20022005 20042043 20282033 20342050 Planned Activities Implement a SCADA system, raise interception rates, conduct an in-line storage demonstration project, and conduct additional engineering studies. Integrate with basement flooding relief and sewer rehabilitation studies. Access existing latent and available in-line storage. Develop additional storage to meet the long-term CSO control target of four CSOs per recreational area.

A fully dynamic, continuous simulation model continues to be utilized to assist in the planning and design of the Winnipeg CSO Control Program. Alberta. Only a few communities in Alberta have combined sewers. As a result, the Province of Alberta has not yet developed a formal CSO control policy. The City of Edmonton is the largest community served by combined sewers. Despite the lack of a formal policy, the City of Edmonton has developed a CSO control strategy as part of its Towards a Clean River campaign for the North Saskatchewan River. The CSO control strategy is a 16-year-long program that includes an Early Action Control Plan (EACP) and a Long-Term Control Plan (LTCP). The implementation process begins with the EACP, which carries out selected CSO controls over a 10year period. Key elements of the EACP include the following: In-line system storage to enable downstream sewer systems to transport and treat more wastewater with fewer overflow occurrences. Separation of storm and sanitary sewers as city sewers are upgraded. Floatables and solids control.

Section 15.2

Canadian Laws and Regulations

545

Key elements of the LTCP include: Increased system conveyance capacity. Construction of new storage facilities. The City of Edmonton has developed and continues to develop a sophisticated hydrologic and hydraulic model of their sanitary and combined sewer system. The hydrologic model has been calibrated with extensive historical data and provides flow inputs into a continuous, fully-dynamic hydraulic model with the ability to simulate real-time controls, such as modulating gates and weirs. British Columbia. Historically, CSO control in British Columbia has been accomplished on a voluntary basis through the development of municipal liquid-waste management plans. The province has moved to codify the development and implementation of these plans, making them a requirement under the new Waste Management Act, which came into force on January 1, 2004. The act applies to all municipalities, but imposes different requirements depending on the municipal population, as shown in Table 15.5.
Table 15.5 Waste Management Act requirements.
Population > 10,000 The liquid-waste management plan must address existing CSOs, including measures to eliminate overflows. Population < 10,000 Either a liquid-waste management plan shall be developed or a study conducted to lead to implementation of measures to eliminate CSOs.

The Municipal Sewage Regulation, made under the Waste Management Act, describes municipal responsibilities concerning combined sewer systems and control of CSOs. The regulation defines a combined sewer system as ditches, drains, sewers, treatment facilities, and disposal facilities that collect, transport, treat, or dispose of a combination of municipal sewage and stormwater in a single system. The regulation stipulates that: No one is allowed to construct or expand a combined sewer system. Emergency repairs to existing combined sewer systems are permitted; however, the feasibility of sewer separation is to be assessed, and, wherever possible, the storm and sanitary sewers should be separated at the time of repair. The regulation also states that no one shall allow a combined sewer overflow to occur during storm or snowmelt events with less than a 5-year return period. Further, an environmental impact study must be completed prior to the construction of any facility, and the study must identify any water-quality requirements as well as the treatment necessary to protect the quality and designated uses of receiving waters. A focus of British Columbia's legislation is the eventual elimination of CSOs by replacing combined sewers with separate storm and sanitary sewers. To that end, storage or conveyance facilities may not be employed to reduce the amount of sewer separation required, unless the facilities immediately reduce and ultimately prevent the occurrence of CSOs. Furthermore, the regulation states the following: If storage or conveyance facilities are used, and primary and secondary treatment are available, then, at a minimum, primary treatment for flows greater than two times the average dry weather flow must be provided and the full secondary capacity of the treatment plant should be used. The primary and secondary effluent should be combined before discharge.

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A minimum receiving-environment-to-discharge dilution ratio of 40:1 should be maintained. Where disinfection of the effluent is required, adequate disinfection capacity should be provided to ensure disinfection of the entire discharge flow. Within two years of the date that the Municipal Sewage Regulation comes into effect, municipalities with combined systems are required to: Estimate the existing flow quantity, frequency, and number of individual CSO occurrences. Estimate the total annual volume of all CSOs that occur during storm or snowmelt events with less than a 5-year return period. Develop and implement steps to reduce the quantity, frequency, and number of CSO occurrences. Reduce the total annual CSO volume by an average of 1% per year over each 10-year reporting period. Assess the potential impact on the receiving environment at all overflow locations. Create a database of all overflows that occur during storm or snowmelt events with less than a 5-year return period. To address these requirements, several modeling strategies can be used. To determine annual CSO volumes, continuous modeling is required. The model can be fully or quasi-dynamic, depending on the characteristics of the system. To assess the effects of storm or snowmelt events with return periods of less than 5 years, an event model can be used.

15.3

European Union Laws and Regulations

European Union (EU) member countries have adopted several Directives for controlling urban pollution, particularly with regards to overflows. The Directives include the EU Urban Wastewater Treatment Directive (UWWTD), the proposed Water Policy Framework Directive (WPFD), the Integrated Pollution Control and Prevention Directive (IPPC), and some of the Product Directives. The following sections outline the requirements of the Directives and how they are being implemented.

Urban Wastewater Treatment Directive (UWWTD)

The UWWTD (CEC, 1991a) provides the main legislation for the control of urban pollution in the EU. The aim of the UWWTD is to avoid the pollution of fresh and marine waters from urban sewage systems, and it requires the following: All agglomerations greater than 2,000 Pe must discharge into collection systems for urban wastewaters. (1 Pe is defined as the organic loading with a 5day biochemical oxygen demand [BOD5] of 60 g/day.) The effluent from sewage treatment plants must meet the minimum effluent standards, which depend on the sensitivity of the receiving waters. Sewage discharges to less sensitive waters, defined as estuarine and coastal waters with a high dispersion capacity, may undergo only primary treatment.

Section 15.3

European Union Laws and Regulations

547

Sewage discharges to normal waters must receive biological treatment, as described in Table 15.6. Sewage discharges greater than 10,000 Pe to sensitive waters must be subjected to both biological treatment and nutrient removal (see Table 15.6).
Table 15.6 Requirements for discharges from urban wastewater treatment plants (from CEC, 1991a).
Parameter Carbonaceous biochemical oxygen demand (BOD5 20 C)2 Chemical oxygen demand (COD) Total suspended solids (TSS) Concentration, mg/L Requirements for discharges to normal water 25 mg O2/L or 40 mg O2/L 125 mg O2/L 354 35 60
5 6 3

Minimum Reduction1, %

7090 75 904 905 706

Additional requirements for discharges to sensitive areas Total phosphorus (P) 1 mg P/L (Pe of 10,000100,000)8 80 1 mg P/L (Pe > 100,000) 15 mg N/L (Pe of 10,000 100,000) 10 mg N/L7 (Pe > 100,000)
1 The values for concentration or for the percentage of reduction shall apply. A look-up table shows the number of samples allowed to exceed the given values for BOD, COD, and TSS; for P and N the annual mean should not exceed the given values. 2 This parameter can be replaced by total organic carbon or total oxygen demand if a relationship can be established between BOD5 and the substitute parameter. 3 Under Article 4 of the Directive. 4 Requirement is optional. 5 For plants >10,000 Pe. 6 For plants 2,00010,000 Pe. 7 Alternatively, the daily average must not exceed 20 mg N/L. This requirement refers to a water temperature of 12C or more during the operation of the biological reactor of the wastewater treatment plant. As a substitute for the condition concerning the temperature, it is possible to apply a limited time of operation, which takes into account the regional climatic conditions. This alternative applies if it can be shown that the monitoring requirements laid down in the Directive are met. 8 Pe is defined as the organic loading having a 5-day biochemical oxygen demand of 60 g/day.

Total nitrogen (N)

7080

Industrial discharges into collection systems and urban treatment plants must be pretreated to ensure that: The health of the staff working in collection systems and treatment plants is protected. The collection systems, treatment plants, and associated equipment are not damaged. The operation of treatment plants and the treatment of sludge are not impeded. Discharges from the treatment plants do not adversely affect the environment or prevent receiving waters from complying with other Community Directives. Sludge can be disposed of safely in an environmentally acceptable manner.

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The design, construction, and maintenance of the collection system is in accordance with the best available technical means not entailing excessive costs (BATNEEC), with particular emphasis on minimizing pollution of receiving waters due to stormwater overflows. All industrial, biodegradable discharges entering receiving waters from plants where the discharge contains 4,000 Pe or more are authorized and meet all national legislative requirements set for that industry. Sewage sludge is recycled whenever possible and is not disposed to sea by pipeline or ship (since 31 December 1998). The UWWTD does not specify any standards for CSOs. However, the directive suggests that member states regulate them based on dilution rate, treatment capacity in terms of dry weather flow, or spill frequency. Based on Article 5 of the UWWTD, member states are required to identify sensitive areas for waters that are, or are likely to become, eutrophic, and freshwaters intended as sources for drinking water where the nitrate content is or could become more than 50 mg N/L. Sewage treatment plants discharging to sensitive waters must also comply with the additional standards laid down for the nutrient. Five member states (Denmark, Luxembourg, the Netherlands, Finland, and Sweden) have designated all their waters as sensitive. In addition, seven member states (Belgium, Germany, Spain, France, Ireland, Portugal, and the UK) have designated parts of their waters as sensitive. Austria, Greece, and Italy have not identified any sensitive areas. The designation of the term sensitive area is still being considered (COM, 1999). Member states have the option of designating certain coastal and estuarine waters as less sensitive, provided that they meet certain morphological, hydrological, or hydraulic conditions. Two member states, the UK and Portugal, have used this option.

Section 15.3

European Union Laws and Regulations

549

Water Policy Framework Directive (WPFD)

In 1997, the European Commission adopted a draft proposal for a Council Directive establishing a framework for community action in the field of water policy (COM, 1997). The overall purpose of the proposed Directive is to establish a framework for the protection of freshwater, estuaries, coastal waters, and groundwaters in the EU. The main part of the directive relevant to CSOs is the requirement to prevent deterioration of ecological quality and pollution of surface waters and to restore polluted surface waters to achieve at least good surface water status in all surface waters. In order to achieve at least good quality, Member States will have to establish improvement programs which may involve requirements to improve CSOs to reduce their impacts on river quality (CEC, 1999).

Integrated Pollution Prevention Control Directive (IPPC)

The primary objective of the IPPC Directive (CEC, 1996) is to prevent or reduce emissions to air, water, and land from the most-polluting installations. The directive applies to effluents from 50 industry sectors that discharge to surface waters and to sewers. The application of Best Available Techniques (BAT) is required for the control of effluents. The application of this directive to sewage discharges will result in an improvement of effluent to sewers and of the untreated discharges from CSOs.

Product Directives
The EU Product Directives contribute to controlling pollution from non-point sources to sewers and therefore have an effect on the quality of the discharges from CSOs. Some examples include the Marketing and Use Directive (76/769/EEC) (CEC, 1976) and its amendments, which prohibit or restrict the marketing or use of certain dangerous substances and preparations containing dangerous substances, and the Detergent Directive (CEC, 1982), which requires a certain biodegradability of the surfactant before it may be marketed in detergents.

Control of CSOs in EU Member States

Whereas the effluents from sewage treatment plants are licensed in all countries, current practices for the permitting and monitoring of CSOs vary widely throughout the EU (Table 15.7). In most countries where CSOs require authorization, the permits are related to the spill frequencies. In terms of monitoring, only a low proportion of CSOs are monitored; although, depending on the country (e.g., Germany, UK), major new CSOs may require permanent monitoring facilities.
Table 15.7

CSO discharge permits in some European countries, modified from European Waste Water Group 1995 (Milne et al., 1997).
Country Belgium (Flanders) Denmark France Regulatory Body Environmental Agency (VLANSREM) Regional Authority Departments Comments Discharge permit may specify overflow frequency. Discharge permit specifies overflow frequency, but it is rarely checked. Some municipalities monitor problem CSOs. Permit required if polluting load exceeds 500 Pe. 12% of CSOs are monitored, mainly near bathing waters and shellfish waters.

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Table 15.7 (Continued) CSO discharge permits in some European countries, modified from European Waste Water Group 1995 (Milne et al., 1997).
Country Regulatory Body Comments Permits required for all wastewater discharges, including CSOs. Monitoring, regulation, and sampling procedures vary between individual states. Some states require new CSO structures to be equipped with a monitoring/telemetry facility for operational and regulatory reasons. Monitoring allows compliance with A128 guidelines. Legislation proposed that will require discharge licenses. New CSOs require authorization (approval permits). Existing CSOs must be registered. Discharge permit sets limit on overflow frequency. This is rarely checked except for problem CSOs causing public complaint (<5%). Monitoring facilities are being added to many systems. All CSOs must be registered; formal permits (with conditions) are not issued at present. Discharge consents are required for CSOs. Monitoring of problem CSOs only at present by Environment Agency. Spill frequencies assessed by short- or long-term monitoring, plus modeling studies by water companies. Major new CSO structures may include permanent monitoring facilities. Same as England and Wales, except monitoring and regulatory functions are performed by SEPA.

Germany

States (Lnder)

Ireland Luxembourg

Environmental Protection Agency Ministry of Environmental Affairs Water Boards National River Authority, Regional Authorities

Netherlands

Spain

UK England and Wales

Environment Agency

UK Scotland

Scottish Environmental Protection Agency (SEPA)

Design Criteria for CSOs.

Sewage treatment plants are usually designed to accept a certain maximum flow expressed as a multiple of dry weather flow (e.g., three times dry weather flow [DWF]). Any excess flow is discharged through CSOs, without further treatment, to the receiving waters. The permitting of CSOs in the different member countries usually reflects the design criteria used. Table 15.8 provides an overview of the CSO design criteria used in select EU countries.
Table 15.8

Overview of CSO design criteria in certain European countries, from European Waste Water Group 1995 (Milne et al., 1997).
Country Belgium Design Criteria and Practice Minimum CSO setting has traditionally been 25 times mean DWF (510 times mean DWF for new systems). Seven overflow events allowed per year (local requirement for new CSOs in Flanders). Effects on receiving water are considered. Frequency of overflow, related to nature of the receiving water. Traditionally, CSO setting is 5 times daily peak DWF (equivalent to 810 times mean DWF). Yearly rates of BOD in spilled flow are compared to those discharged from sewage treatment works (STW). Intermittent and annual loads considered (for rivers and lakes). EQO/EQS approach has been introduced, together with modeling techniques. CSO setting is 3 times peak DWF (normally equivalent to 46 times mean DWF). Setting for CSOs at STWs is usually 23 times mean DWF. Pollutant load is considered. EQO/ EQS approach being introduced, together with modeling techniques.

Denmark

France

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Use of Models for Regulatory Compliance

551

Table 15.8 (Continued) Overview of CSO design criteria in certain European countries, from European Waste Water Group 1995 (Milne et al., 1997).
Country Germany Design Criteria and Practice Minimum CSO setting is 7 times DWF where no storage is provided. 2 times mean DWF plus return to treatment. ATV Guideline A128 requirement of 90% of load to treatment, also state regulations. Storage up to 40 m3/impervious hectare, typically 2030 m3/ha. Greece Ireland Italy Luxembourg Netherlands Portugal Spain CSO setting generally 36 times mean DWF. Effects upon receiving waters and pollutant strength of the discharge are sometimes considered in determining the setting. Traditionally, 6 times mean DWF, more recently UK Formula A. EQO/EQS and modeling approach is now being introduced for some situations. No nationally agreed upon criteria (national guidelines exist for minimum water quality standards). CSO setting generally 35 times mean DWF. Spill frequency criteria are being introduced on a local basis only. German ATV Guideline A128 is now the main design procedure. Traditionally, the minimum CSO setting was 3 times peak DWF (equivalent to 46 times mean DWF). Locally negotiated frequency of overflow, usually 310 times per year, depending on sensitivity of receiving waters. Minimum total storage equivalent to 7 mm of runoff over impervious area. EQO/EQS approach is being introduced, together with modeling techniques. CSO settings are based on national guidelines. Most new CSOs have a setting of 6 times mean DWF. Receiving watercourse is considered in a few cases. Most new CSOs have a setting of 35 times mean DWF. Five times mean DWF is the most frequently used setting for smaller towns. Historically, CSO setting is 6 times mean DWF to treatment (generally 3 times DWF to full treatment, 3 times DWF to storm tanks). Formula A Setting = DWF + 1360P + 2E L/day where P = population, E = industrial effluent. (Formula A is typically 6.59 times mean DWF but may be higher). Storage is added where dilution is low. This is increasingly being replaced by the EQO/EQS approach and modeling techniques where appropriate. Scottish practice is similar to England and Wales and takes into account receiving stream dilution in sizing the storage equipment.

UK England & Wales

UK Scotland

Note:Dry Weather Flow (per capita) is broadly comparable throughout northern EU Countries.

15.4

Use of Models for Regulatory Compliance

Design engineers and utility managers use hydraulic models as tools to understand the performance of sewage collection systems. This section describes how hydraulic sewer models are used to assess and demonstrate compliance with the combined and sanitary sewer overflow regulations in the United States. Although the CSO and SSO regulations have no specific requirement for the use of sewer models, EPA policies and guidance documents strongly recommend their use for maintaining compliance. The CSO policy (Section II.C.1.d, US EPA, 1994) states the following:
Modeling of a sewer system is recognized as a valuable tool for predicting sewer system response to various wet weather events and assessing water quality impacts when evaluating different control strategies and alternatives. EPA supports the proper and effective use of models, where appropriate, in the evaluation of the nine minimum controls and the development of the long-term CSO control plan. It is also recognized that there are many models, which may be used to do this. These models range from simple to complex. Having decided to use a model, the permittee should base its choice of a model on the characteristics of its sewer system, the number and location of overflow points, and the sensitivity of the receiving water body to the CSO discharges.

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Table 15.9 lists the type of analysis and the appropriate modeling approach for meeting the technical requirements of the US EPAs CSO policy and the SSO proposed rules. Example 15.1 demonstrates the use of a hydraulic sewer model to determine compliance with one of the requirements in the US EPAs CSO Control Policy.
Table 15.9
Requirement Demonstrate implementation of the minimum controls: Maximize use of collection system for storage Maximize flow to publicly owned treatment works for treatment Prohibit CSOs during dry weather

Applications of software to meet CSO and SSO requirements.

Type of Analysis Required Model Approach

CSO Minimum Control Measures RDII (rainflow-derived inflow Calibrate model to monitored flows and infiltration) quantification to determine RDII Hydraulic analysis of sewer Steady-state runs using peak dry system weather flows to assess capacity Extended-period simulation of wet Operations simulation weather events to determine storage and flow to treatment plant Evaluation of real-time controls

CSO Long-Term Control Plan Presumptive Approach Limit average number of over- Simulation with design storms Continuous simulation of design storm event flow events per year Long-term simulation Long-term simulation of multiple or Operations simulation events Capture at least 85% of wet weather volume per year or Eliminate or reduce mass of pollutants equivalent to 85% of capture volume requirement CSO Long-Term Plan Demonstrative Approach Demonstrate that a selected con- Simulation with design storms Continuous simulation of design storm event or long-term simulation of trol program is adequate to meet sewer system water quality requirements of the Long-term simulation of multiple CWA events Use measured concentrations or transport simulations of the receiving body SSO Capacity, Management, Operations, and Maintenance (CMOM) Programs Maintenance of a collection sys- Maintenance of up-to-date astem map built drawings Program to assess the capacity of the collection system RDII analysis Hydraulic analysis of sewer system components Simulation of control alternatives Use model to generate CAD-style drawings Interface with AutoCAD and GIS Calibrate model to measured flows to determine RDII Model as steady-state, extendedperiod, or continuous simulation Use model to evaluate alternatives, costs, and impacts

System evaluation and capacity assurance plans

Section 15.4

Use of Models for Regulatory Compliance

553

Example 15.1 Capture volume analysis. A trunk main consists of ten 300-ft long segments as shown in the following figure. A constant flow of 200 gpm enters the system at each manhole. During wet weather, RDII enters the system at manholes 2, 5, and 10.
MH-10
P-1 0

MH-9
P-9

MH-8
P-8

MH-7
P-7

MH-6
P-6

Overflow Collector
MH-5
P-5

MH-4
P-4

MH-3
P-3

MH-2 MH-1
P-2

P-1

Outlet

The inflow to each of the three manholes is simulated as a hydrograph having a 4.5-hour duration. This hydrograph is shown in the following figure. A model of the system is developed and an extended-period simulation is conducted for a 5-hour event. The resulting hydrographs of the total flow entering pipe P-1, the overflow, and the flow conveyed to treatment are shown in the following figure. When
2000.0 1800.0 1600.0 1400.0 1200.0

Flow, gpm

1000.0 800.0 600.0 400.0 200.0 0.0 0.0 0.5 1.0 1.5 2.0 2.5 Time, hr 3.0 3.5 4.0 4.5

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flows exceed pipe capacity, overflow occurs at the upstream end of pipe P-1. Determine if the system meets the 85% capture volume requirement in the Presumptive Approach of the Long-Term Control Plan in CSO policy.
5500.0 5000.0 4500.0 4000.0 3500.0 MH-5 Outlet Overflow Collector

Flow, gpm

3000.0 2500.0 2000.0 1500.0 1000.0 500.0 0.0 0.0 0.5 1.0 1.5 2.0 2.5 Time, hours 3.0 3.5 4.0 4.5 5.0

For the 5-hour simulation period, the loads are: Sanitary flow = 811,362 gal RDII = 417,147 gal The discharges are: To treatment = 1,020,147 gal Overflow = 208,509 gal The percent capture volume is 417,147 208,509 -------------------------------------------- 100 = 50.0% 417,147 The model showed that 50% of the RDII was captured for this storm event. The regulatory requirement was to capture 85% of the wet weather flow on an annual basis. Additional simulation of storm events that occur over the course of a year will be required to assess compliance.

References
Copeland, C. 1999. Clean Water Act: A Summary of the Law. CRS Issue Brief for Congress. RL 30030. Commission of the European Communities (COM). 1997. Proposal for a Council Directive Establishing a Framework for Community Action in the Field of Water Policy (COM (97) 49 final). Official Journal C184, 17 (June).

References

555

Commission of the European Communities (COM). 1999. Water Quality in the European Union. Implementation of the Council Directive 91/271/EEC of 21 May 1991 concerning urban wastewater treatment, as amended by Commission Directive 98/15/EC of 27 February 1998. European Commission Directorate Environment. http://europe.eu.int/water/water-urbanwaste/report/chapter6.html. Council of the European Communities (CEC). 1976. Directive on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations (76/769/EC). Official Journal L262, 27 (September). Council of the European Communities (CEC). 1982. Directive relating to the testing the biodegradability of nonionic surfactants and amending Directive (82/242/ EEC). Official Journal L109 (22 April). Council of the European Communities (CEC). 1991a. Directive concerning urban waste water treatment (91/271/EEC). Official Journal L135 (30 May). Council of the European Communities (CEC). 1996. Directive on Integrated Pollution Prevention and Control (96/61/EC). Official Journal L257 (10 October). Council of the European Communities (CEC). 1999. Common Position (EC) No 41/ 1999 adopted by the Council, 22 October 1999, with a view to the adoption of a Directive 1999/../EC of the European Parliament and of the Council establishing a Framework for Community Action in the field of water policy (1999/C 343/01). Official Journal C 343 (30 November). Environment Canada. 2004. Combined Sewer Overflow Treatment Technologies Manual, draft. Ottawa, Canada. Milne, I., B. Crabtree, S. Clarke, C. Wennberg, and J. Larson. 1997. Best Management Practices for the Regulation of Passive Urban Wastewater. Technology Validation Project IN10187D. Medmenham Marlow, UK: WrC. Municipal Engineers Association. 2000. Municipal Class EA (replaces Class EA for Municipal Road Projects and Water and Wastewater Projects). Mississagua, ON, Canada: Municipal Engineers Association. Ontario Ministry of the Environment. 1985. Guidelines for the Design of Sanitary Sewage Systems. Prepared by the Environmental Approvals and Project Engineering Branch of the Ministry of the Environment. Ontario Ministry of the Environment. 1997. Ontario CSO Control Procedure F-5-5. Toronto, Canada. Percival, R.C. and D.C. Alevizatos. 1997. Law and the Environment: A Multidisciplinary Reader. Philadelphia, PA: Temple University Press. Quebec. 2002. Water. Our Life. Our Future. Quebec Water Policy. Envirodoq ENV/2002/ 0310A. Bibliotecheque national du Quebec. US Environmental Protection Agency (US EPA). 1994. Combined Sewer Overflow Policy. 59 FR 18688. US Environmental Protection Agency (US EPA). 2001. National Pollutant Discharge Elimination System (NPDES) Permit Requirements for Municipal Sanitary Sewer Collection Systems, Municipal Satellite Systems and Sanitary Sewer Overflow. 66 FR 7701

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US Environmental Protection Agency (US EPA). 2003. National Pollutant Discharge Elimination System (NPDES) Permit Requirements for Municipal Wastewater Treatment Discharges During Wet Weather Conditions. 68 FR 63042. Zabel, T., I. Milne, and G. McKay. 2001. Approaches Adopted by the European Union and Selected Member States for the Control of Urban Pollution. Urban Water 3: 25-32. Zwick, D. and M. Benstock. 1971. Water Wasteland. New York: Grossman Publishers.

Problems
15.1 Match each abbreviation with the appropriate description.
Abbreviation 1 2 3 4 5 6 7 8 9 10 CWA NPDES CFR POTW SSO CSO CEAA UWWTD IPPC BOD Definition a b c d e f g h i j Downstream end of a sewer Canadian water quality law Pollution prevention in Europe Problem in sanitary sewer Law requiring permits for discharge in the US Must have permit to overflow (in US) Permit to discharge in the US Indicator of wastewater strength Repository of US regulations European Union water quality regs

15.2 In the US, the NPDES nine minimum controls are applicable to what kind of system? 15.3 What are the two levels of control specified in NPDES discharge permits and how do they differ? 15.4 Name two Canadian agencies that monitor wastewater collection systems. 15.5 What type of collection system is most commonly found in urban areas of Europe?