5
Water Quality Improvement: Decision-Making Strategies and Technical Solutions

INTRODUCTION

This chapter explores various wastewater management techniques and recommends actions to address water quality problems—especially wet weather-related problems—in southwestern Pennsylvania. As discussed in Chapters 3 and 4, the aquatic environment of southwestern Pennsylvania is impaired for a variety of designated beneficial uses including recreational use due to the likelihood of waterborne pathogens in surface waters and aquatic life use due to acid mine drainage (AMD). Although AMD is a significant cause of water quality impairment in the region, especially in the predominantly rural counties of southwestern Pennsylvania, this problem is most appropriately addressed at the state and federal levels. Continued funding for these ongoing efforts (see Chapter 4 for further information) is essential to improve water quality in southwestern Pennsylvania.

A fundamental prerequisite to the formulation of cost-effective plans for reducing water quality impairments in southwestern Pennsylvania is a systematic and extensive set of water quality data covering both sources of impairments and in-stream responses. The data should be sufficient to accurately assess the different sources of contamination and their impacts on receiving streams. Toward this end, Chapter 3 summarizes data available for the region. Increased monitoring by different groups and agencies has taken place over the past several years, and the available data are sufficient to conclude that serious water quality problems exist in southwestern Pennsylvania. However, there are not sufficient data to determine the relative seriousness of the related environmental and human health problems, the relative importance of the potential sources of contamination, and the improvements that are likely to result from alternative pollution control measures.

Despite these limitations, the Allegheny County Sanitary Authority (ALCOSAN) and its member communities are now facing enforcement action by the U.S. Environmental Protection Agency (EPA) through the Pennsylvania Department of Environmental Protection (PADEP) and the Allegheny County Health Department (ACHD) (see more below) for violations of the Clean Water Act related to combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs). Thus, remedial actions are anticipated that will alter the relative contribution of different sources to the water quality problems in the region. It will be critical that evaluation of water quality improvements related to these activities be undertaken. Further, the implementation of solutions for identified sources of impairment does not preclude the need for additional information related to other sources and their contributions to water quality impairment. Monitoring and modeling efforts should proceed in conjunction with, and inform decisions with respect to, a variety of mandated water quality improvements currently being pursued (e.g., those listed in Table 5-7).

Several entities (ALCOSAN, 1999; TPRC, 2002; WSIP, 2002) have estimated recently that addressing the region’s CSO and SSO problems by conventional means, using a combination of storage, conveyance, and treatment improvements could cost several billion dollars. Although the problem of excessive discharge of untreated wastewater from CSOs and



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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania 5 Water Quality Improvement: Decision-Making Strategies and Technical Solutions INTRODUCTION This chapter explores various wastewater management techniques and recommends actions to address water quality problems—especially wet weather-related problems—in southwestern Pennsylvania. As discussed in Chapters 3 and 4, the aquatic environment of southwestern Pennsylvania is impaired for a variety of designated beneficial uses including recreational use due to the likelihood of waterborne pathogens in surface waters and aquatic life use due to acid mine drainage (AMD). Although AMD is a significant cause of water quality impairment in the region, especially in the predominantly rural counties of southwestern Pennsylvania, this problem is most appropriately addressed at the state and federal levels. Continued funding for these ongoing efforts (see Chapter 4 for further information) is essential to improve water quality in southwestern Pennsylvania. A fundamental prerequisite to the formulation of cost-effective plans for reducing water quality impairments in southwestern Pennsylvania is a systematic and extensive set of water quality data covering both sources of impairments and in-stream responses. The data should be sufficient to accurately assess the different sources of contamination and their impacts on receiving streams. Toward this end, Chapter 3 summarizes data available for the region. Increased monitoring by different groups and agencies has taken place over the past several years, and the available data are sufficient to conclude that serious water quality problems exist in southwestern Pennsylvania. However, there are not sufficient data to determine the relative seriousness of the related environmental and human health problems, the relative importance of the potential sources of contamination, and the improvements that are likely to result from alternative pollution control measures. Despite these limitations, the Allegheny County Sanitary Authority (ALCOSAN) and its member communities are now facing enforcement action by the U.S. Environmental Protection Agency (EPA) through the Pennsylvania Department of Environmental Protection (PADEP) and the Allegheny County Health Department (ACHD) (see more below) for violations of the Clean Water Act related to combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs). Thus, remedial actions are anticipated that will alter the relative contribution of different sources to the water quality problems in the region. It will be critical that evaluation of water quality improvements related to these activities be undertaken. Further, the implementation of solutions for identified sources of impairment does not preclude the need for additional information related to other sources and their contributions to water quality impairment. Monitoring and modeling efforts should proceed in conjunction with, and inform decisions with respect to, a variety of mandated water quality improvements currently being pursued (e.g., those listed in Table 5-7). Several entities (ALCOSAN, 1999; TPRC, 2002; WSIP, 2002) have estimated recently that addressing the region’s CSO and SSO problems by conventional means, using a combination of storage, conveyance, and treatment improvements could cost several billion dollars. Although the problem of excessive discharge of untreated wastewater from CSOs and

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania SSOs is well documented, the data presented to the committee and those uncovered by its own research as summarized in Chapter 3 are inadequate to arrive at a definitive conclusion as to (1) the impact of these discharges on water quality in receiving streams and (2) what should be done to address the issue in the context of federal CSO policy. Investing large sums of capital based only on currently available data may not ultimately solve the most important problems or provide appropriate solutions. Although it is true that no amount of additional data and analyses would remove all uncertainty about water quality investments, it is clear that currently available information is lacking in several critical areas, including the following: the nature and magnitude of CSO effects on receiving streams during wet weather events; whether effects are limited to indicator microorganisms (i.e., bacterial indicators of fecal contamination and, indirectly, the presence and quantity of fecal pathogens) and the extent to which they include floatable and settleable solids; how much surface water runoff from separate stormwater conveyances affects water quality in receiving streams during wet weather events; whether present discharges constitute a threat to the public as evidenced by health data; and the extent of the effects of present and potential small community and on-site systems. The causes and nature of water quality impairments, the parties responsible, and the individuals and waterways affected differ for each of the problem contaminants in the region. A comprehensive watershed-based approach is needed to address the spectrum of water quality problems; such a systematic approach should recognize interrelationships among problems and the need for the parties responsible for each water quality problem to share in its solution. Responsible groups may be the public at large, a segment of the population, individuals, or a particular industry or group of industries. Recognition of payment capacity of individuals and the region as a whole should also be considered in reaching equitable solutions (see Chapter 6 for further information). EXISTING INFRASTRUCTURE AND INSTITUTIONS FOR WATER QUALITY MANAGEMENT The Commonwealth of Pennsylvania and local governments in the Pittsburgh region have a long history of planning, regulations, capital investments, and development of managerial expertise to control water pollution. It is evident that more is needed, particularly in the management of CSOs, SSOs, separate storm sewers, and other sources of pollution. Future actions will build on or modify existing infrastructure and managerial institutions. Some of those facilities and arrangements are discussed in the sections that follow. Sewer systems that convey wastewater or combined wastewater and stormwater to sewage treatment plants generally have multiple components and multiple owners. First, pipes within a residence collect wastewater and carry it to a house lateral pipe (see Figure 4-5). House lateral pipes are underground and owned by the homeowners. Laterals typically comprise 50 percent of the total length of pipe in a sewer system and are connected to a street sewer pipe; as a general rule, they may account for a substantial portion of the total infiltration and inflow into

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania the sewer system. Because a large portion of them are located on private property, and measuring flows in laterals is not common practice, identifying sources and fixing them requires special detective work and authority to order corrective measures. Sewer pipes are generally owned by the municipality that owns the street above it. This street sewer pipe joins with others and enters an interceptor. This larger pipe might be owned by a municipality, a sewer authority, or the same authority or organization that owns a wastewater treatment plant (WWTP). Finally, major interceptors carry the flow from all the small interceptors and pipes to the treatment plant. Major interceptors are generally owned by the same organization that owns and operates the treatment plant. These complexities are compounded in southwestern Pennsylvania because of fragmented ownership and responsibilities. The Pennsylvania Sewage Facilities Act, commonly referred to as Act 537, was passed in 1966. It requires all municipalities to formulate and implement plans for management of current and future sewage. Individual municipalities may choose to administer their own plans, or they may choose to participate in a joint local agency (JLA) with other municipalities or county health department. These plans, subject to review and approval by PADEP, must be modified when new land development is proposed or other changes occur. By far the largest JLA in the region is ALCOSAN (see Chapter 2 for further information). ALCOSAN owns and operates 83 miles of major interceptors and a wastewater treatment plant that provides primary and secondary treatment of up to 225 million gallons per day. Eighty-three communities are within the ALCOSAN service area (see Figure 1-1), and a total of 12 sewer authorities serve many of these communities. Although these “partner communities” own and operate their own sewer collection infrastructure (street sewer pipes and smaller interceptors), they do not operate WWTPs. All collected sewage (and stormwater flow where combined systems are used, unless released during a CSO event) is sent to the ALCOSAN interceptors and eventually to the central wastewater treatment plant. Thus, ownership and management of wastewater collection and treatment facilities for the most populous county in the region is extremely fragmented. The institutional complexities of the region are discussed more fully in Chapter 6. This complexity is illustrated by the fact that as of March 2004, there were 591 Act 537 plans in the 11-county area. They are summarized by county in Table 5-1. Any development requiring the extension of sewer systems not included in an existing plan will trigger a plan revision. Twenty-eight percent of the plans have been revised in the past five years. Many of the plans cover rural areas in which no sewer systems are located or very little development is occurring. Indeed, more than half of the municipalities have had no reason to revise their plans for 20 years or more. A map of the sewered areas is provided in Figure 5-1. Act 537 also required municipalities to establish a permitting program for on-lot treatment and disposal systems (OLDS; referred to as on-site sewage treatment and disposal systems [OSTDS] in this report) for individual lots and community OSTDSs with design flows of up to 10,000 gallons per day. Like the sewage disposal plans, these programs are to be operated by individual municipalities or through JLAs. Each program is administered by a sewage enforcement officer (SEO) who is trained by PADEP. SEOs are responsible for determining the adequacy of sites to support OSTDSs and ensuring that system designs comply with Chapter 73 of PADEP’s regulations. The PADEP has developed a home buyers’ guide, a homeowners’ guide to maintenance, a manual to SEO’s decisions about repairs, and other educational material that is

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania TABLE 5-1 Act 537 Plans by County by Age of Plan County Age of Plan (years) <5 5-9 10-19 >20 All Allegheny 75 9 5 41 130 Armstrong 5 3 0 36 44 Beaver 7 3 4 40 54 Butler 8 7 4 28 47 Fayette 13 2 4 24 43 Greene 6 1 0 19 26 Indiana 15 8 4 11 38 Lawrence 7 2 2 16 27 Somerset 5 1 6 38 50 Washington 14 7 8 38 67 Westmoreland 9 7 6 43 65 Total 164 50 43 334 591   SOURCE: Data from www.dep.state.pa.us/dep/deputate/watermgt/Wqp/WQP_WM/537Map/. FIGURE 5-1 Approximate boundaries of sewered areas in Allegheny and surrounding counties. NOTE: Lawrence and Somerset Counties of southwestern Pennsylvania (see also Box 1-2) are not included. SOURCE: Adapted from SPC map, “Sewer Service Areas in the SPC Nine County Region.”

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania available on-line,1 but once a system is permitted, there is no program for regular inspection and maintenance. Pennsylvania’s stormwater program operates under authority of the Storm Water Management Act of 1978 (Act 167) and EPA regulations under the 1987 amendments to the Clean Water Act. Act 167 provides grants to counties to prepare stormwater regulations for designated watersheds, although initiation of planning is left to the counties. A county desiring to develop a plan then makes a proposal to PADEP for financial assistance. A requirement of the plan is preparation of a model stormwater ordinance, which must be adopted by any municipality within the watershed that does not have equivalent language in its building subdivision or land development codes. The ordinances address control of stormwater runoff from new development; they do not require retrofitting of existing development. A recent map of Pennsylvania watersheds for which stormwater plans have been prepared2 shows that only six plans have been prepared for the approximately 60 watersheds within the 11-county area of southwestern Pennsylvania. Approved plans and dates of approval include the following: Pine Creek, Girty Run, and Deer Creek in Allegheny County (1986); Turtle Creek in Allegheny and Westmoreland Counties (1991 and 1992); Montour Run in Allegheny County (1990); and Monongahela River in Allegheny County (1990). Two other plans are in preparation, one for Little Sewickley Creek in Allegheny County and one for Cokes Creek in Somerset County. The original Turtle Creek plan was prepared in 1986; its purpose was to reduce the impact of new development on peak discharges and related downstream effects on property and traffic. The plan established standards for post-development peak discharge rates from new development. Standards ranged from pre-development rates to 50 percent of post-development rates, depending on location of development within the watershed. The model ordinance affected about 30 municipalities in the watershed (John Maslanik, ATS-Chester Engineers, personal communication, 2004). Amendments to the Clean Water Act in 1987 directed the EPA to expand the National Pollutant Discharge Elimination System (NPDES) permit system to include stormwater runoff. The EPA implemented that directive in two phases. The Phase I Rule was published on November 16, 1990 (55 Federal Register 47990) and required all operators of medium and large municipal separate storm sewer systems to obtain an NPDES permit and develop a management program to reduce the discharge of harmful pollutants. These regulations covered certain categories of stormwater associated with industrial activity and discharges of stormwater from urban areas with a population of 100,000 or more (EPA, 1996). Notably, Phase I included Allegheny County. The EPA promulgated rules specifying who must apply for Phase II permits in August 1995; final Phase II rules were published in 1999 (EPA, 1999). That program automatically covers all municipal separate storm sewer systems located in an urbanized area as defined by the U.S. Bureau of the Census. A few special waivers apply, and small municipal separate storm 1   See http://www.dep.state.pa.us, “Subjects,” “Wastewater” for further information. 2   Map available on-line at http://www.dep.state.pa.us/dep/deputate/watermgt/wc/subjects/stormwatermanagement/Stormwater_11_18_02_web.jpg.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania sewer systems outside urban areas may be waived by a permitting agency on a case-by-case basis. In December 2002, PADEP updated its stormwater policy to include protection of water quality as mandated by the Phase I and Phase II rules (PADEP, 2002). The federal regulations for Phase II require six minimum measures: public involvement in planning and decision processes; detection and elimination of illicit discharges to storm sewers; reduction of pollutants in stormwater runoff from construction sites; management of post-construction runoff from new development and redevelopment; pollution prevention and good housekeeping; and public education and outreach. The PADEP has developed several guidance documents to assist communities in achieving compliance with federal regulations, including a handbook of best management practices (BMPs) for developing areas3 and a model stormwater ordinance for municipalities (PADEP, 2002). The revised policy establishes post-construction management requirements that emphasize groundwater infiltration and BMPs to control volumes and rates of discharge. The policy sought to integrate those permits with its Act 167 authorities. Acceptable BMPs to promote groundwater infiltration, water quality, and rate and volume control are listed in Table 5-2. The primary limitation of all of these stormwater programs is that they are focused mostly on controlling runoff from new development. They do cover illicit connections to storm sewers and redevelopment projects, but for the most part they have little effect on high density development in the urban core of Pittsburgh and surrounding communities that were developed prior to enactment of these programs. DRIVERS FOR WATER QUALITY IMPROVEMENT UNDER WET WEATHER CONDITIONS As discussed in Chapter 4, although the relative contribution of different sources of microbial loading to surface and groundwaters in southwestern Pennsylvania cannot be determined with available information, sufficient information is available to determine that improperly managed wastewaters resulting from human activities are degrading the microbiological water quality in the region. Furthermore, available water quality and human health data are insufficient to reach sound conclusions about the seriousness of this problem. Wet weather microbiological water quality in the main stem rivers is demonstrably worse than dry weather quality, suggesting that stormwater and sewer overflows may be important contributors. In this regard, bacterial (predominantly coliform) indicator levels greatly exceed acceptable standards for body contact recreation for a significant portion of the year in the three main stem rivers and many of their tributaries, especially during and immediately after precipitation events. This is a particular issue in and around the City of Pittsburgh that is probably exacerbated by upstream and downstream sources of microbial loading, including agricultural runoff. Microbiological water quality in many tributaries does not meet standards in 3   Available on-line at http://www.pacd.org/products/bmp/bmp_handbook.htm.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania TABLE 5-2 Best Management Practices Deemed Acceptable to PADEP for Stated Purposes Groundwater Infiltration Water Quality Rate and Volume Control Permeable paving Permeable paving Permeable paving Grass swale Bioretention Stormwater infiltration Bioretention Grass swale Dry ponds   Filter strip Stormwater wetlands   Wet pond (extended detention pond) Wet ponds (extended detention pond)   Rooftop runoff management Rooftop runoff management     Bioretention   SOURCE: Adapted from www.dep.state.pa.us (“Stormwater”). either wet or dry weather, suggesting that failing OSTDSs and sewers may be important contributors. Notwithstanding the data limitations, the most pressing water quality problem in the region from a regulatory perspective is caused by CSOs, SSOs, and stormwater drainage resulting from wet weather conditions. In fact, the EPA views CSO and SSO problems as sufficiently serious that it has promulgated regulations requiring CSO, SSO, and stormwater controls. Because southwestern Pennsylvania has one of the nation’s most extensive CSO and SSO control problems, EPA, acting through PADEP and ACHD, has issued a series of administrative consent orders to many of the communities served by ALCOSAN (see also footnote 1, Chapter 1) to address this problem. It is important to state that the ALCOSAN draft consent decree with EPA remained attorney-client privileged4 as this report neared completion in December 2004 so the committee’s conclusions and recommendations may not be consistent with whatever actions result from the final legal agreements that may be reached. Thus, the following discussion concerning CSO and SSO problems should be viewed with this caution in mind. However, the consent orders for controlling CSOs and SSOs in the ALCOSAN partner communities have become publicly available during the study period, and many of the committee’s recommendations are aligned with these activities and are discussed later in this chapter. EPA’s Regulatory Approach to CSO Remediation EPA has produced a variety of guidance for municipalities to manage CSOs, including the following: Combined Sewer Overflow Policy (EPA, 1994) Combined Sewer Overflows Guidance for Long-Term Control Plan (EPA, 1995a) Combined Sewer Overflows Guidance for Nine Minimum Control Measures (EPA, 1995b) Combined Sewer Overflows Guidance for Funding Options (EPA, 1995c) Combined Sewer Overflows Screening and Ranking Guidance (EPA, 1995d) 4   The availability of information and of the parties involved in this litigation to fully cooperate with the committee constrained this study at times and will likely continue to impede any process that seeks all available information and the candid input of knowledgeable experts.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania Combined Sewer Overflows Guidance for Financial Capability Assessment and Schedule Development (EPA, 1997) Combined Sewer Overflows Guidance for Monitoring and Modeling (EPA, 1999) Guidance: Coordinating Combined Sewer Overflows (CSO) Long-Term Planning with Water Quality Standards Reviews (EPA, 2001b) Owners of CSOs are required to obtain discharge permits and establish programs that would implement nine minimum control measures (discussed below), and each is required to develop and implement a long-term control plan (LTCP) for controlling CSOs. The 1994 EPA CSO policy states: EPA expects a permittee’s long-term CSO control plan to give the highest priority to controlling overflows to sensitive areas. Sensitive areas, as determined by the NPDES authority in coordination with state and federal agencies, as appropriate, include designated Outstanding National Resource Waters, National Marine Sanctuaries, waters with threatened or endangered species and their habitat, waters with primary contact recreation, public drinking water intakes or their designated protection areas, and shellfish beds. In Pittsburgh’s case, the sensitive areas are those waters below CSOs with primary contact recreation as their designated use and those that serve as public drinking water intakes (see Figure 4-4). There are two basic remedial approaches for controlling CSOs: (1) the demonstration approach and (2) the presumption approach. In brief, the “demonstration approach” relies on data collection and simulation to demonstrate that a proposed management strategy will result in meeting water quality standards and considers all factors that are likely to influence success; there is no reliance on criteria governing by how much CSOs may be reduced. The demonstration approach seems inherently advantageous because it relies on actual data collection and analysis and also has the benefit of lending itself to adaptive implementation (described later) by determining the progressive performance, in the watershed context, of each measure undertaken. Although the demonstration approach has the advantage of focusing investment on measures likely to achieve water quality standards, because it relies on time-consuming data collection and analysis, it could result in delaying the reduction of pollutants to receiving streams. In contrast, the “presumption approach” presumes that meeting certain criteria, including a statistical reduction (85 percent) of the annual volume of wet weather overflows, is likely to result in meeting water quality standards as reasonably determined by the regulatory agency. Under this approach, if the owner of CSOs has satisfied given criteria for reducing CSOs and some uncertainty remains about satisfaction of water quality standards, the owner is given the presumption that CSOs are no longer contributing to noncompliance with water quality standards. Satisfaction of the criteria for reducing CSOs usually involves large capital investments. The presumption approach was included as an alternative by EPA in the 1994 CSO policy because data and modeling of wet weather events do not always provide a clear picture of the level of CSO controls that are necessary to meet water quality standards. More specifically, EPA (1994) noted that “because data and modeling of wet weather events often do not give a clear understanding of the level of CSO controls necessary to protect water quality standards, one of three technology and performance standards could be used to

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania satisfy a presumption that water quality standards would be met.” The criteria include the following: a limit on the number of overflow events per year; elimination or the capture for treatment of no less than 85 percent by volume of the CSO discharge; or elimination or removal of no less than the mass of the pollutants identified as causing water quality impairment through the sewer system. In later guidance, EPA (1999) added some clarification to its CSO control policy: Because CSOs are subject to the technology-based requirements of the Clean Water Act (CWA), permitting authorities must specifically determine best available technology economically achievable (BAT)/best conventional pollutant control technology (BCT) on a case-by-case basis using best professional judgment (BPJ) during the permitting process [emphasis added]…Therefore, evaluation of CSO controls beyond the nine minimum controls may appropriately focus primarily on water quality issues…State and Federal NPDES authorities must coordinate throughout the planning process to ensure that after implementation of the controls in the proposed LTCP, CSOs will not cause or contribute to nonattainment of WQS. The CSO policy is clear—attainment of water quality standards is a requirement. However, the policy also recognizes that an unambiguous determination of what constitutes compliance with water quality standards may not be possible. The policy appears to indicate that when there is significant uncertainty about whether a plan will lead to compliance with water quality standards, the permittee is entitled to the presumption approach if the plan satisfies one of the three aforementioned criteria. As discussed in the next section, ALCOSAN proposed to rely primarily on the 85 percent reduction criterion as described in its March 1999 report Draft Combined Sewer Overflow Program Phase I Activity Report: Regional Long Term Wet Weather Control Concept Plan (ALCOSAN, 1999, pp. 1-2, 3-1). An independent third party review (TPR) of ALCOSAN’s draft LTCP has cast serious doubts on whether the 85 percent reduction criterion would satisfy water quality standards. That analysis itself was based on several reasonable but unverifiable assumptions that are discussed in the TPR report (TPRC, 2002). Until the fundamental gaps in knowledge of regional water quality are filled (see Chapters 3 and 4 for further information), it remains unclear whether achieving an 85 percent reduction in CSO volume would satisfy water quality standards. Use of the demonstration approach for controlling CSOs places a heavy burden of proof on the region to demonstrate that a particular control plan will satisfy water quality standards. As discussed later in this chapter, it is difficult with complex models to get an adequate estimate of uncertainty or to know precisely when a satisfactory “demonstration” has been achieved. Results of water quality modeling must be combined with substantial professional judgment in making a determination about compliance. The demonstration approach for controlling CSOs can be used in southwestern Pennsylvania by incorporating a strategy of adaptive implementation, which is discussed in detail later in this chapter. In brief, it begins with monitoring actual CSO discharges and their water quality impacts. Field monitoring should be coupled with water quality models that enable

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania planners to estimate the extent to which reductions in discharges will be necessary to meet water quality standards. Because effects of CSOs and discharges from separate storm sewers are intermingled in the region’s primary receiving streams, monitoring and modeling of CSOs and their impacts on streams during wet weather events should occur simultaneously with monitoring and modeling of separate stormwater sewer systems during wet weather events. Conventional control strategies for reducing pollutant loading from CSOs should be conducted in parallel with experiments on innovative but unproven technology such as vortex separators (see more below). All of these investigations can be conducted over a relatively short period (e.g., three to five years). Upon completion, information available at that time should be used to help judge which CSO control strategies are cost-effective and subject to acceptable levels of uncertainty. ALCOSAN’s Long Term Wet Weather Control Concept Plan To address the EPA and Commonwealth of Pennsylvania wet weather regulatory requirements, in March 1999 ALCOSAN produced a draft LTCP; its fundamental goal “is to improve and preserve the water environment in the ALCOSAN service area and to fulfill ALCOSAN’s obligations under the Clean Water Act and the Pennsylvania Clean Streams Law.” More specifically, the draft LTCP (ALCOSAN, 1999, p. 1-1) has three primary phases to attain wet weather water quality standards that are summarized below: implement a program for nine minimum CSO controls; plan, design, and implement a regional LTCP; and participate in regional and interstate watershed-based planning and analyses. Phase One—Nine Minimum Combined Sewer Overflow Controls The EPA’s nine minimum controls5 for CSOs do not require significant engineering studies or major construction and can be implemented in a relatively short time frame (EPA, 1995b). These include (1) proper operation and maintenance of the sewer system, (2) maximum use of the collection system for storage, (3) modification of the pretreatment program, (4) maximization of wastewater flow to the treatment plant, (5) elimination of chronic dry weather overflows, (6) control of solids and floatables, (7) pollution prevention, (8) public notification of overflow occurrences and impacts, (9) and monitoring to characterize sewer overflow impacts. Phase Two—LTCP According to the draft LTCP, ALCOSAN (1999, p. 1-2, 3-1) proposed to use the presumption approach guidance as outlined by the EPA to address its CSO problem. This approach permits meeting regulatory requirements by the indirect method of reducing the amount of combined sewage overflow and presuming that this action will meet water quality standards. In brief, the presumption approach as outlined in the draft LTCP includes expanding 5   For further information on EPA’s nine minimum controls for CSOs, see http://cfpub.epa.gov/npdes/cso/ninecontrols.cfm?program_id=5.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania the existing ALCOSAN wastewater treatment plant over a 20-year period from the current 225 million gallons per day (mgd) to a total wet weather capacity of 875 mgd and also bringing about infrastructure changes to the sewerage system in the form of interceptors to significantly increase the proportion of wet weather flows arriving at the treatment plant instead of discharging untreated into streams. Of this increased flow, 310 mgd would receive full secondary treatment and the remaining 565 mgd of wet weather flow would receive primary treatment and disinfection only. ALCOSAN estimates that these proposed changes will permit capture of 85 percent of the wet weather combined sewage flow—the majority of which will be given primary treatment only. A major portion of the ALCOSAN interceptor sewer system roughly parallels the three major rivers in the Pittsburgh area, the Allegheny, Monongahela, and Ohio Rivers. Flows within the sewer system in excess of those planned for conveyance to the main treatment plant would undergo high-rate flow regulation and primary treatment by five of the system’s swirl (vortex) separators (see more below). The other major portion of the ALCOSAN interceptor sewer system roughly parallels four major tributary streams: Chartiers Creek, Saw Mill Run, Turtle Creek, and Thompson Run (see Figure 1-2). These interceptors are installed in relatively shallow excavations, and under the draft LTCP (ALCOSAN, 1999, pp. 1-2, 3-5) the excess wet weather flow in these interceptors would be handled differently from that of the main river interceptors. For these interceptors, up to 85 percent of the wet weather flow would be handled by a combination of interceptor upgrades, peak flow storage, and two of the system’s vortex separators. A portion of ALCOSAN’s existing interceptor sewer system, built for the most part at the upper extensions of the main interceptors, is designed for collection of sanitary sewage only. Unfortunately, at the lower ends of the interceptors this sanitary sewage becomes mixed with combined sewage such that much of the benefit of the separate sewage infrastructure is lost. In addition, the wet weather flow in the separate sewers averages 1,000 gallons per capita per day (gpcd), while the dry weather flow averages only 190 gpcd (ALCOSAN, 1999). This indicates that an excessive amount of runoff from precipitation enters the separate sewage system, leading to separate system overflows, which are illegal under the federal Clean Water Act. According to the draft LTCP, ALCOSAN expects that member municipalities will commit to a long-term (approximately 50-year) effort to reduce this inflow and infiltration. The estimated costs of the interceptor system and associated regulator/grit treatment upgrades under the draft LTCP are provided in Table 5-3. The total construction cost in 1998 dollars is approximately $922 million, with an annual operating cost of $3.51 million. However, this does not include the cost of implementing the previous (1996) ALCOSAN plans for upgrades to expand ALCOSAN’s plant to 875 mgd wet weather flow in accordance with the requirements of Pennsylvania Act 537. Total 2002 costs for the LTCP, expansion of its treatment plant ($210 million), and upgrades to the non-ALCOSAN-owned collection system ($1.9 billion) are expected to exceed $3 billion (TPRC, 2002). In order for the LTCP to be successful, an extensive rehabilitation and/or reconstruction of the overall ALCOSAN sewerage system must ultimately be accomplished to reduce infiltration and inflow. However, ALCOSAN controls only a portion of the sewers and a portion of the total watershed area of the rivers and streams flowing into its service area; thus, the success of much of this effort will depend on action by other entities in the region. The long-

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania day period. The ballasted flocculation facility was operated for 32 hours, with flows ranging from 5 to 28 mgd (Cindy Wallis-Lage, Black & Veatch Corporation, personal communication, 2003). During this period of operation, total suspended solids removal ranged from 80 to 90 percent, and after the first three hours of operation, effluent total suspended solids ranged from 28 mg/L to 11 mg/L. For the entire project, construction costs for all of the facilities to monitor and treat excess flow were about $9 million, or $0.22 per gallon of installed capacity (Wagner et al., 2003). The applicability and feasibility of ballasted flocculation should be evaluated as an alternative to vortex separators for CSO source treatment in the ALCOSAN system, and laboratory or pilot-scale studies should be conducted. In-River CSO Storage Using Flow Balancing In-river CSO storage using the flow balancing method (FBM) may be feasible for certain point sources. The basic concept is that a volume of CSO can be contained in a tank, consisting of flexible plastic curtains placed in a receiving stream for the temporary storage of CSOs. Combined sewer overflow that results during and immediately after wet weather enters the tank and displaces river water contained in the tank. After the storm event, the stored CSO is pumped back into the sewer to be transported to the treatment plant, and river water flows back into the tank. The plastic curtains forming the tank are suspended by pontoons and anchored to the riverbed (thus forming the base of the tank) by concrete weights. A pilot-scale FBM, following a concept developed in the late 1970s in Sweden, was constructed and evaluated by the EPA in conjunction with the New York City Department of Environmental Protection in the 1990s at Fresh Creek in New York City (Field et al., 1994, 1995; Fordran et al., 1991). The Fresh Creek FBM was somewhat different from the original Swedish concept, which was originally designed for installation in a lake. For that purpose, a series of tanks or bays was used, with the first one receiving the CSO and the last one discharging to the lake in a “plug-flow” manner. The series of tanks helped reduce mixing between the CSO and the lake water. In the Fresh Creek study, the receiving water consisted of seawater, which had a higher density than the low-salinity CSO and only a single tank was used. The CSO that entered the tank floated on top, displacing the seawater, which then passed out into Fresh Creek through openings in the tank bottom. The initial capacity of the tank used in the Fresh Creek study was 0.41 million gallons, and this was later expanded to a final capacity of 2 million gallons (Field et al., 1994, 1995). Because the CSO volumes at this location were generally much larger, in the 5 million to 10 million gallon range, the volume of the pilot system was insufficient to contain much of the CSO. Nevertheless, the pilot study was sufficient to demonstrate the principles of operation and the ability of the system to withstand marine environmental conditions. No damage resulted due to stresses caused by saltwater, tidal exchanges, CSO events, or coastal storms. A phase-one study was conducted using the smaller-capacity system to determine the efficiency with which the CSO was captured by the FBM. Notably, 77 percent of CSO was captured for one wet weather event in which the CSO volume was less than the volume of the tank. However, an operational difficulty with the Fresh Creek FBM was that a portion of the suspended solids within the CSO tank settled to the creek bed. For this reason a system of sediment pumps was needed to capture the settled solids.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania An FBM design to help control periodic CSOs in southwestern Pennsylvania—and, more specifically, to help equalize flows to ALCOSAN’s collection system and wastewater treatment plant—would need to be different because of the differences between flow in a creek in New York City and the main stem rivers in the Pittsburgh region. A design more similar to that of the original Swedish design would likely be required, though a number of questions would have to be addressed. These include how the flexible curtains would be anchored in the river bottom; how to provide for differences in river stage between low flow and flood stage, if pontoons are used to suspend the flexible curtains; the extent to which the cross-sectional area of the river would remain available for unimpeded river flow with the curtain walls in place; and the effects of river current on the flexible curtain during flood stage. Although widespread use of an FBM system would not be adequate for the majority of CSO discharges in southwestern Pennsylvania because of the typical volumes involved, there may be locations in which CSO volumes are sufficiently low, and the cost of a conveyance system to a WWTP or more conventional CSO control approaches (e.g., basin or tunnel construction) so high, that an FBM system could be a good alternative to explore. Therefore, the committee recommends that in-river CSO storage using FBM technology be explored and, if feasible, piloted at a particularly suitable location for such a system. Wet Weather Water Quality Standards As part of Step IV of the CWARP planning and implantation process for high-density urban areas, the Pittsburgh region, in cooperation with PADEP and EPA, may find it necessary to revisit Pennsylvania's water quality standards. Existing policy recognizes that absolute limits on water quality parameters may not be economically achievable under all hydrological and climatological events. Water quality criteria for a variety of parameters, including chemical contaminants, microbiological indicators of fecal contamination, and physical characteristics such as color and temperature are usually set and enforced to protect ambient waters during very low flows in streams. For example, in Pennsylvania, effluent limits for temperature and pH are to be established using a design flow of the lowest 30-day average that is expected to occur every year with a probability of 10 percent (25 PA Code §93, Water Quality Standards). If flow drops below that level, exceedances of numerical standards for temperature and pH are not considered to be violations of water quality standards. In southwestern Pennsylvania, wet weather, high-flow events are some of the leading contributors to water pollution. Thus, under very high flow conditions, numerical standards for some contaminants may be exceeded but designated uses of a stream may not be impaired. For example, during flood events, numerical turbidity standards in steams are frequently exceeded, but recreational uses of the stream may be foreclosed for safety reasons, not because of water quality conditions. The stream may then return to normal uses when flood flows recede. Achievement of numerical standards during all high-flow events could be prohibitively expensive. Determining an acceptable frequency and duration for such high flow events when exceedances of numerical standards are allowed is a difficult and controversial decision. The EPA recognized this possibility when it promulgated the national CSO policy in 1994. That policy permits modification of state water quality standards and related uses when the standards cannot be achieved because of CSOs. For example, EPA’s CSO policy allows for

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania the possibility of revisions to wet weather water quality standards as evidenced by the following excerpt from its 1999 memorandum: Data developed during LTCP development can inform decisions about the attainability of designated uses and the appropriateness of any WQS [water quality standard] revisions. State and federal WQS authorities need to be involved throughout the planning process to ensure that, if the LTCP is based in part on anticipated changes to WQS, those changes are appropriate and satisfy federal regulatory requirements. Leo (1999) reviewed the history of EPA's CSO policy through 1999 and stated that the intent of the policy was to control CSOs up to the point at which maximum benefits could be achieved. Water quality standards would then be modified to allow exceedances for wet weather events that were more extreme. Leo reported that EPA had approved water quality standards in Ohio, Maine, and Massachusetts that did account for wet weather flows. In some cases, use attainability analysis would be required before the standards could be applied to particular streams. Adoption of wet weather water quality standards is likely to be a highly controversial process. Woodworth (2000) recounts the process in Washington, D.C. All streams in Washington, D.C., were classified for primary contact recreation, and the related standard prior to preparation of a regional LTCP had both a narrative and a numerical standard. The narrative standard stated that the waters shall be free of untreated sewage, a condition that could not be attained under all high-flow events. Efforts to change the standard to account for wet weather flows were criticized as rolling back environmental standards. Woodworth was very critical of the process by which the standard was modified. This committee recommends that changing water quality standards be considered as a last resort and concurs with Woodworth’s (2000) admonition that “Water quality standards should be reevaluated only after a comprehensive long-term control plan has been designed, approved, and implemented. Provisions should be made to monitor and upgrade the plan as necessary.” In addition, the committee also recommends that (1) a detailed estimate of incremental costs and an assessment of the impact on existing designated uses be included in any reevaluation of water quality standards, and (2) any reevaluation be conducted in close cooperation with PADEP and with broad public participation. SUMMARY: CONCLUSIONS AND RECOMMENDATIONS A fundamental prerequisite to the formulation of cost-effective plans for reducing water quality impairments in southwestern Pennsylvania is a systematic and extensive set of water quality data covering both sources of impairments and instream responses. As discussed in Chapters 3 and 4, serious water quality problems exist in southwestern Pennsylvania, but there are not sufficient data to determine the relative seriousness of the environmental and human health problems, the relative importance of potential sources of contamination, and the improvements that are likely to result from alternative pollution control measures. The most important water quality problem in the region from a regulatory perspective and the potential for adverse human health effects is controlling microbial contamination of streams that derives from the effect of wet weather conditions on sewer systems (CSOs, SSOs, and stormwater), failing OSTDSs, and agricultural and urban runoff. Remedial actions are

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania planned and anticipated by ALCOSAN and many of its partner communities in response to a series of consent orders that will alter the relative contribution of different sources to the water quality problems in the region. The evaluation of water quality improvements related to such activities will be critical. However, the implementation of solutions for identified impairment sources does not preclude the need for additional information related to other sources and their contributions to water quality impairment in the region. To develop better understanding of sources of contamination in southwestern Pennsylvania, water quality monitoring and modeling efforts should take place concurrently with mandated remedial activities. It is clear that the causes and nature of water quality impairments, the parties responsible, and the individuals and waterways affected differ for each of the problem contaminants in the region. A comprehensive watershed-based approach is needed to address the spectrum of water quality problems, including wet weather problems; such a systematic approach should recognize interrelationships among problems and the need for parties responsible for each water quality problem to share in its solution. To achieve this, it is necessary to develop both a technical and an institutional-financial approach. The institutional and financial approach is discussed in Chapter 6, and the technical approach is embodied in what the committee calls the Comprehensive Watershed Assessment and Response Plan or CWARP. The Three Rivers CWARP described in this report is not a single document or program; it is a flexible umbrella concept identifying the activities that can be carried out by the organizations that are most technically and institutionally capable of achieving the desired results depending on existing and potential capabilities. The framework recommended for planning and implementation of CWARP consists of the following five basic steps: (I) problem identification; (II) assessment of existing conditions; (III) projection of future loads; (IV) formulation and evaluation of alternative management strategies; and (V) adaptive implementation of elements of the strategy. This five-step CWARP process must be adapted to address each of the following interrelated scales: river basin, multicounty/metropolitan scale, high-density urban areas, and rural areas. The committee recognizes that the region is not starting with a blank slate, and Step I has been largely completed for each of these scales. Substantial progress has been made on Step II, but as noted in this chapter, significant gaps remain. Because the problems are largely associated with existing conditions and there is only modest growth in the region as a whole, Step III may be less important, but changes in land use that are occurring in suburban (formerly rural) areas cannot be ignored. Lastly, Steps IV and V do not appear to have been well developed at any of the scales, and these steps deserve much greater attention. Because regional information on the biological quality of receiving waters is scant, its collection during and in support of CWARP at the river basin scale is critical. Biological water quality indices and their change over time can yield important information about ecosystem change and help quantify the environmental benefits affected by pollution abatement. Thus, information collection for CWARP should include biological data to both assist in ecosystem health assessment benchmarking and to help document changes to the ecosystem that occur as a result of changing stressors. At a minimum, the CWARP should be designed to establish an Index of Biotic Integrity for the main stem rivers. To this end, an effort should be made to expand the Ohio River component of EPA’s rejuvenated Great Rivers EMAP program, with an emphasis on the biological water quality of the main stem rivers. At least two aspects of water management are of concern at the multicounty/metropolitan scale of CWARP. First, and at the very least, water quality planning at this scale should be

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania sufficient to inform regional interests of the potential effects (including constraints if any) of water quality conditions on future transportation and land development, the consequences of development on water quality where it occurs, and how these effects and consequences can and should be modified. Second, planning at this scale should also result in the identification of opportunities for economies of scale in the delivery of water and wastewater services through cooperative arrangements among local governments. Either SPC or an alternative organization should formulate regional water resource plans and integrate them with transportation and land use plans. Several entities have recently estimated that solving wet weather problems in the urban core of the region by conventional means, using a combination of storage, conveyance, and treatment improvements, could cost several billion dollars. Investing large sums of capital based only on currently available data may not ultimately solve the most important problems or provide appropriate solutions. Although it is true that no amount of additional data and analyses would remove all uncertainty about water quality investments, it is clear that currently available information is lacking in several critical areas (e.g., how much surface water runoff from separate stormwater sewers affects water quality in receiving streams during wet weather events). Until these facts are known better, planning and implementation of cost-effective remedial measures will be impeded. Regardless of the regulatory approach (i.e., presumption or demonstration) used in ALCOSAN’s LTCP for controlling wet weather problems, the committee concludes that it is necessary to address watershed-wide problems and sources of contaminants other than CSOs and SSOs. Step II of CWARP at the urban scale should include simultaneous monitoring of (1) wet weather discharges into the region’s streams and rivers and (2) the impacts on these receiving streams. Pollutants of primary concern in this context include pathogenic microorganisms such as Cryptosporidium and their surrogates (indicator microorganisms); oxygen-demanding substances including suspended solids and sediments; and “conservative” toxic substances such as metals and toxic organic chemicals. Step II should also include the development of a variety of models that are sufficient to disentangle the effects of multiple sources on water quality in receiving streams. The models and data should be available for public review, and data from these technical studies should be reduced and translated to needed corrective actions in a manner that is understandable to decision makers and the public in general. Although receiving water quality modeling activities appear to be extremely limited currently in the region’s three main stem rivers, the committee recommends that it be used to estimate impacts of pollution loadings on the receiving streams and to help prioritize alternatives for pollution control. Other modeling activities needed to implement Step II of CWARP in the region’s urban core include sewer system routing models, dynamic sewer system modeling, dynamic stormwater modeling, and real-time sewer flow control modeling for analysis and operation. Projections of changes in the regional landscape are important in the planning and implementation of Step III of CWARP in the region’s urban core. Planning studies conducted at the multicounty/metropolitan scale should be sufficient for this purpose and include projections for several land use, transportation, water supply, and wastewater parameters discussed in this chapter. At least six components of a strategy to implement Step IV of CWARP for high-density urban areas should be considered and are discussed in this chapter, some of which are mandated under provisions of the Clean Water Act. The first route to successful improvement of water quality in the region is to optimize utilization of existing infrastructure. To this end, the

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania committee strongly recommends that all wastewater collection systems located in the watershed, particularly in the urban core areas of southwestern Pennsylvania, be fully compliant with EPA’s CMOM policy or an equivalent program. Thereafter, related information, approaches, and technologies recommended in this chapter and report would be available to help guide major long-term investments in improving the region’s water quality. Furthermore, ALCOSAN’s draft LTCP should be reevaluated in the context of the overall CWARP approach to reflect ongoing consent order negotiations, CMOM, and information from CWARP as it is developed in the future. The CWARP approach is recommended as a framework for development of the LTCP and similar documents because of the circumstances (especially data limitations) that exist in southwestern Pennsylvania and, in principle, would apply to other regions of the United States with similar water quality problems and circumstances. In addition, in the development of a final LTCP, ALCOSAN and other wastewater treatment providers in southwestern Pennsylvania should evaluate the utilization of real-time control of CSOs. Storage and treatment of CSO in abandoned mine voids, which is currently being evaluated for the Township of Upper St. Clair, Pennsylvania, should also be evaluated. The committee also recommends consideration of the following innovative technologies and approaches for improving water quality in southwestern Pennsylvania, especially in the region’s urban core: (1) at a minimum, implementation of pilot or demonstration projects prior to widespread application of vortex separators for CSO source treatment in the ALCOSAN system; (2) the feasibility of ballasted flocculation facilities and in-river CSO storage using FBM technology for controlling CSOs; and (3) the adoption of wet weather quality standards—although this is likely to be a highly controversial process and should be considered as a last resort. Best management practices for OSTDSs should be implemented throughout the region using the CWARP framework. Although individual OSTDSs are permitted locally and current technical standards are available to ensure proper performance, they may be ignored. Furthermore, prevention of the discharge of untreated sewage into local waterways or ditches is difficult to enforce. The region needs a coordinated, well-funded program for oversight and routine maintenance of OSTDSs. Such a program can be self-sustaining through user charges provided they are applied on a cooperative regional or county basis. The committee recommends the following actions to help improve water quality in the predominantly rural areas of the region: (1) within each county, register all individual on-site and cluster disposal systems with the appropriate SEO; (2) institute a program of periodic mandatory inspection and certification (or decertification), either by a public entity or by a qualified/licensed private contractor; (3) conduct statistically valid surveys of septic tank and absorption field conditions, residence by residence, to identify communities that should be given high priority for funding by PENNVEST or the federal RUS for remediation of failed and failing OSTDSs throughout the region; and (4) use the registration and inspection program to identify and order elimination of illegal direct discharges of human waste to streams and identify where cluster OSTDSs may be feasible. There are no comprehensive estimates of the economic benefits of addressing the remaining water quality problems for southwestern Pennsylvania or of projects proposed to address the region’s water quality problems. Nevertheless, the region would be expected to benefit economically from measures that significantly reduce drinking water risks and enhance recreational opportunities. The CWARP process can identify a list of alternative management strategies and projects that are technically feasible and capable of addressing the region’s water

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania quality problems at a variety of scales, but the question remains: Which is the better option? Comprehensive evaluation of options under CWARP (especially Step IV for high-density urban areas) requires additional considerations, including costs, benefits, and fairness. It continues throughout the process of selecting a preferred long-term management strategy for a particular water quality problem at given scale. It is essential in the formulation of alternatives to provide feedback as to how initial designs should be modified or discarded in the search for a cost-effective strategy. It is also essential to the process of establishing priorities among the several elements that may comprise the management strategy. Finally, it must be a continuing process during implementation to evaluate how well each element has performed. A variety of evaluation frameworks are available; some of the more prominent are discussed in this chapter, including cost-effectiveness analysis, benefit-cost analysis, and multicriteria methods. The use of cost-effectiveness as the primary method for evaluating options for achieving water quality objectives in the region is recommended and should include an analysis of incremental costs to achieve elimination of low-probability contamination events. The committee recommends the use of benefit-cost analysis in evaluating water quality improvement projects in the region and for helping to set priorities. As the CWARP process is being planned and implemented, it is essential that it be integrated with the ongoing process of establishing TMDLs for impaired streams being conducted by PADEP under requirements of the Clean Water Act. There are many parallels between CWARP and the process for establishing TMDLs—especially in the application of adaptive implementation. The TMDL process—supplemented by additional analyses of constituents that may not be readily subject to the rigorous TMDL approach, including biological, environmental, and other measurable factors—should be combined with watershed, regional, and subregional analysis of beneficial uses to provide the basis for selection of remedial actions in the study area. The CWARP effort should be completed quickly to provide timely support for those water quality improvements that are required and others that are in the public interest. It is difficult to estimate the cost of implementing CWARP, but in the committee’s judgment it should be low compared to the cost of improvements and more than offset by potential savings. REFERENCES Abdalla, C. 1994. Groundwater values from avoidance cost studies: Implications for policy and future research. American Journal of Agricultural Economics 76(5):1062-1067. ALCOSAN (Allegheny County Sanitary Authority). 1999. Draft Combined Sewer Overflow Program Phase I Activity Report: Regional Long Term Wet Weather Control Concept Plan. Pittsburgh, PA: ALCOSAN. Anderson, R., K. Beer, T. Buckwalter, M. Clark, S. McAuley, J. Sams, and D. Williams. 2000. Water Quality in the Allegheny and Monongahela River Basins: Pennsylvania, West Virginia, New York, and Maryland (1996-98). Denver, CO: United States Geologic Survey. Casman, E., B. Fischhoff, C. Palmgren, M. Small, and F. Wu. 2000. An integrated risk model of a drinking water borne cryptosporidiosis outbreak. Risk Analysis 20:495-511.

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Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania Clean Water Action Plan Partners. 2000. The Guest River Watershed: River restoration in an Appalachian watershed. In Watershed Success Stories: Applying the Principles and Spirit of the Clean Water Action Plan. Washington, DC: Clean Water Action Plan. Collins, A., R. MacDowell, M. Brooks, A. Kennedy, and J. Murphy. 2000. Water quality on the Left Fork of the Mud River: A watershed survey. Unpublished final report to West Virginia University Lincoln County Extension Office and Kellogg Community Partnership, College of Agriculture, Forestry, and Consumer Sciences. Morgantown, WV. Davis and Simon, eds. 1995. Biological Assessment and Criteria Tools for Water Resource Planning and Decision Making. Boca Raton, FL: Lewis Publishers, Inc. EPA (U.S. Environmental Protection Agency). 1994. Combined Sewer Overflow (CSO) Control Policy. FRL-4732-7. Federal Register (59)75. Available on-line at http://www.epa.gov/npdes/pubs/owm0111.pdf. Accessed March 29, 2004. EPA. 1995a. Combined Sewer Overflows: Guidance for Long-Term Control Plan. EPA 832-B-95-002. Washington, DC: Office of Water. EPA. 1995b. Combined Sewer Overflows: Guidance for Nine Minimum Controls. EPA 832-B-95-003. Available on-line at http://www.epa.gov/npdes/pubs/owm0030.pdf. Accessed March 29, 2004. EPA. 1995c. Combined Sewer Overflows Guidance for Funding Options. EPA 832-B-95-007. Washington, DC: Office of Water. EPA. 1995d. Combined sewer Overflows Screening and Ranking Guidance. EPA 832-B-95-004. Washington, DC: Office of Water. EPA, 1996. EPA Overview of the Storm Water Program. EPA 833-R-96-008. Washington, DC: Office of Water. EPA. 1997. Combined Sewer Overflows Guidance for Financial Capability Assessment and Schedule Development. EPA 832-B-97-004. Washington, DC: Office of Water. EPA. 1999. Economic Analysis of the Final Phase II Storm Water Rule. EPA 833-R-99-002. Washington, DC: Office of Water. EPA. 2000a. A Benefits Assessment of Water Pollution Programs Since 1972: Part 1: The Benefits of Point Source Controls for Conventional Pollutants in Rivers and Streams. Washington, DC: Office of Water and Office of Policy, Economics, and Innovation. EPA. 2000b. Guidelines for Preparing Economic Analysis. EPA-240-R-00-003. Available on-line at http://yosemite.epa.gov/ee/epa/eed.nsf/webpages/Guidelines.html/$file/Guidelines.pdf. Accessed August 16, 2004. EPA, 2001a. Clean Watersheds Needs Survey 2000: Report to Congress. EPA-832-R-03-001. Washington, DC: Office of Wastewater Management. EPA. 2001b. Guidance: Coordinating Combined Sewer Overflow (CSO) Long-Term Planning with Water Quality Standards. EPA-833-R-01-002. Washington, DC: Office of Water. EPA. 2003a. Handbook for Management of Onsite and Clustered Wastewater Treatment Systems (Draft). EPA 832-D-03-001. Washington, DC: Office of Water. EPA. 2003b. Voluntary National Guidelines for Management of Onsite and Clustered Wastewater Treatment Systems. EPA 832-B-03-001. Washington, DC: Office of Water. EPA. 2004. Metals, pH, and Fecal Coliform TMDLs for the Guyandotte River Watershed, West Virginia. Available on-line at http://www.epa.gov/reg3wapd/tmdl/pdf/Guyandotte/Sections%201-8,%20Ref/Sec-1_Guy_WV_TMDL.pdf. Accessed June 24, 2004.

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