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Sanitary Sewer Overflow Federal Advisory Subcommittee

OVERVIEW

In the fall of 1994, EPA initiated a stakeholder process to address factual and policy issues related to SSOs; this process included the formation of a Federal Advisory Committee, or FAC. The FAC was the primary means for EPA to solicit stakeholder input as it developed the SSO Rule. There were five general categories of stakeholders who were represented on the FAC. These were:

  • Sanitary sewer system operators;
  • SSO-related health professionals;
  • State regulatory agencies;
  • Technical professionals; and
  • Environmental and other citizen groups.

In 1995, EPA decided to incorporate the development of an SSO Rule in a more comprehensive effort to address the water quality impacts from urban wet weather flows. As a result, the Urban Wet Weather Flows Federal Advisory Committee was formed to identify and evaluate issues associated with water quality and other impacts from wet weather in a municipal setting. Two subcommittees were established under the Urban Wet Weather Flows Federal Advisory Committee: the Phase II Storm Water Subcommittee, and the SSO Policy Dialogue Subcommittee also known as the SSO Subcommittee.

This SSO Subcommittee examines the need for national consistency in permitting and enforcement, effective sewer operation and maintenance principles, public notification for SSOs with potential health or environmental dangers, and other public policy issues. EPA carefully considers the Subcommittee's recommendations for regulatory and nonregulatory actions to reduce SSOs nationally.

The SSO Subcommittee has identified the need for EPA to work with technical trade organizations, States, and local governments to develop a range of tools, including but not limited to fact sheets, guidance documents, technical publications, and funding resources for SSO abatement. The toolbox described by the SSO Subcommittee would serve as the primary reference for municipalities looking to EPA for assistance in implementing the SSO rule in an efficient and cost-effective manner.

KEY ISSUES IDENTIFIED BY THE SSO SUBCOMMITTEE

Stakeholder interviews identified the following key issues for consideration by the SSO Subcommittee:

  • Need for better information on the extent and causes of SSOs;
  • Difficulties faced by operators in proactively identifying and correcting sanitary sewer line problems which may lead to SSOs;
  • Technical feasibility of achieving zero wet weather related SSOs;
  • Need for guidance on how to consider the impacts of SSOs in the larger context of achieving clean water goals (watershed approach);
  • Cost of compliance;
  • Minimum SSO volume to trigger reporting requirements;
  • Use of the CSO (combined sewer overflow) Control Policy as a basis for any SSO Rule;
  • Use of a national performance standard versus a design standard;
  • Timing of issuance of an SSO policy;
  • Need for consistency in enforcement actions initiated by State and Federal regulatory authorities.
SUMMARY OF SSO SUBCOMMITTEE ACTIVITIES

Between 1995 and 1999, the SSO Subcommittee held 12 meetings to discuss policy issues associated with SSOs.

At the SSO Subcommittee Meeting in October 1999 PDF (7 pp, 20KB), the SSO Subcommittee supported basic principles expressed in documents addressing suggested NPDES permit requirements for:

  • Capacity, management, operation and maintenance (CMOM) programs for municipal sanitary sewer collection systems;
  • A prohibition on SSOs, which includes a closely circumscribed framework for raising a defense for unavoidable discharges;
  • Reporting, public notification, and record-keeping requirements for municipal sanitary sewer collection systems and SSOs;

Additionally, the SSO Subcommittee unanimously supported a set of principles for municipal satellite collection systems and watershed management, although members did not develop detailed language addressing these topics.

ADDITIONAL DOCUMENTS

Contact Information for SSO Subcommittee Members (PDF) (5 pp, 110KB)

Charter for SSO Federal Advisory Subcommittee (Text) (6511 bytes)

Draft Action Plan for the SSOs Federal Advisory Subcommittee (PDF) (3 pp, 12KB)

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Last updated on January 28, 2011 11:02 AM
URL:http://cfpub.epa.gov/npdes/sso/faca.cfm