DEPARTMENT OF ENVIRONMENTAL
PROTECTION

 

March 27, 2015

Dear Municipal Of?cer or Council President:

As a customer municipality of ALCOSAN (?Customer Municipality?), you entered into either a
Consent Order and Agreement with the Department or an Administrative Consent
Order with the Allegheny County Health Department for the evaluation,
repair and maintenance of your sewer system. These COAs and ACOs expire on March 30,
2015. Many Customer Municipalities have asked to extend the termination date or enter into a
new COA or ACO.

Speci?cally, the City of Pittsburgh and other Customer Municipalities have asked the
Department to afford them 12 to 18 months to explore the potential bene?ts of Green
Infrastructure as a means of reducing ?ows. The Department, ACHD and the United
States Environmental Protection Agency (collectively ?Regulatory Agencies?) are fully
supportive of the implementation of GI as an effective method of reducing stormwater ?ow
volume and offer the following two phase approach going forward. With this in mind, the
Regulatory Agencies are offering the opportunity for the Customer Municipalities to investigate
?ow reduction opportunities, including GI.

Realization of these ?ow reduction opportunities will be conducted in two phases. Phase I will
be implemented under an interim COA with a duration of 18 months. Different agreements will
be developed for Customer Municipalities operating sanitary sewer systems and for
Customer Municipalities operating combined sewer systems or a combination of 
and CSS (?Hybrids?). During this Phase, the parties will negotiate the provisions of Phase 11,
new COAs or ACOs that will meet the time line contained in the federal Amended Consent
Decree currently being negotiated between the Regulatory Agencies and ALCOSAN.

As a condition of entering into the Phase I COA or ACO, Customer Municipalities must agree to
provide a GI or Source Reduction Study designed to reduce ?ows entering into the regional
sewer collection system. As part of the G1 or Source Reduction Study, Customer Municipalities
will conduct a pilot GI project to demonstrate that GI will reduce the C80 volume or be a
component of removing 880 volume.

Under the Phase I COA, CSS Customer Municipalities will develop a GI Plan and
Implementation Schedule, and determine anticipated flow reductions through the use of the
Storm Water BMP Manual or other well established Design Documents and/or (ii) the removal
of ?ow through other types of proj ects such as stream removals etc. The CSS and Hybrid
Customer Municipalities will continue to address incomplete obligations under the previous
COA. Customer Municipalities with CSS will implement statutorily required Nine Minimum
Controls.

400 Waterfront Drive 1 Pittsburgh, PA 15222 412.442.4179 mvw.depweb.stale.pa.us

 

Municipal Of?cer/Council President - 2 - March 27, 2015

Customer Municipalities will determine whether a GI Plan will result in bene?cial ?ow
reductions and, if so, provide a plan and schedule for implementation. Alternatively, they can
propose to develop a Source Reduction Study identifying source reduction projects and
anticipated ?ow reductions. In addition to completing a Source Reduction Study, Customer
Municipalities will implement one or more ?ow or source reduction projects during the term of
the Phase I ACO. Examples of source reduction projects include stream removal, sewer
replacement in high in?ow in?ltration areas, private lateral replacements or a private lateral
resale ordinance. Furthermore, under the Phase I ACO, Customer Municipalities will
continue to address any incomplete obligations under the previous ACOs. This latter obligation
will include the continued implementation of the Operations and Maintenance Program Plan
developed under the previous ACOs. Upon execution of the Phase I COA or ACO, Customer
Municipalities may continue to self-regulate connections under the same provisions that
currently appear in their respective COAs or ACOs.

It should be understood that entry into the interim Phase I agreements will not result in delay of a
project to expand the capacity of the Woods Run STP owned and operated by ALCOSAN. This
expansion is necessary regardless of any ?ow reductions that may be anticipated from G1 or
Source Reduction.

The Department and ACHD intend to send you a draft COA or ACO, as applicable, shortly. For
ease of communication with the Department, please use 3Rivers Wet Weather Association as a
facilitator or clearing house for issues you have in common with other Customer Municipalities.

Moving forward, the Department recommends that an evaluation of a GI and or Source
Reduction plan begin immediately. This will provide you with the bene?t of more than 18
months of analysis. The Regulatory Agencies anticipate that ALCOSAN will use the GI and
Source Reduction plans of the Customer Municipalities to re?ne and ?nalize its regional Wet
Weather plan. The Regulatory Agencies will use the re?ned information in Phase II COAs and
ACOs with the Customer Municipalities.

If you have any questions or concerns in this matter, please contact Chris Kriley of my staff at
412.442.4312, or by email at ckriley@pa.gov .

Sincerely,

jimmy- 9411772 

Susan Malone
Regional Director
Southwest Regional Of?ce