CSO Best Management Practices
DEC enforces the CSO requirements under the Wet Weather Water Quality Act of 2000.
DEC developed 15 Best Management Practices (BMPs), they are equivalent to the "Nine Minimum Control Measures" (NMCs) required under the USEPA National Combined Sewer Overflow policy, and require the control of CSO discharges from combined sewer systems. The EPA's policy is available at via the link to Combined Sewer Overflows CSO Control Policy available in the right column "Links Leaving DEC's Website" navigation of this page.
The BMPs are technology-based controls, designed to implement operation and maintenance procedures, utilize the existing treatment facility and collection system to the maximum extent practicable, and implement sewer design, replacement and drainage planning, to maximize pollutant capture and minimize water quality impacts from combined sewer overflows. BMPs do not require major engineering studies or construction.
The BMPs are included in all SPDES permits for combined sewer systems as applicable and implemented by the permittee.
Typical BMP Permit Requirements
1. CSO Maintenance/Inspection
The permittee shall develop a written maintenance and inspection program for all CSOs listed on page(s) _____ of this permit. This program shall include all regulators tributary to these CSOs, and shall be conducted during periods of both dry and wet weather. This is to insure that no discharges occur during dry weather and that the maximum amount of wet weather flow is conveyed to the _________ POTW for treatment. This program shall consist of inspections with required repair, cleaning and maintenance done as needed. This program shall consist of e.g. (monthly/weekly) _______ inspections.
Inspection reports shall be completed indicating visual inspection, any observed flow, incidence of rain or snowmelt, condition of equipment and work required. These reports shall be in a format approved by the Regional Office and submitted to the Region with the monthly operating report (Form 92-15-7).
2. Maximum Use of Collection System for Storage
The permittee shall optimize the collection system by operating and maintaining it to minimize the discharge of pollutants from CSOs. It is intended that the maximum amount of in-system storage capacity be used (without causing service backups) to minimize CSOs and convey the maximum amount of combined sewage to the treatment plant in accordance with Item 4 below.
This shall be accomplished by an evaluation of the hydraulic capacity of the system but should also include a continuous program of flushing or cleaning to prevent deposition of solids and the adjustment of regulators and weirs to maximize storage.
3. Industrial Pretreatment
The approved Industrial Pretreatment Program shall consider CSOs in the calculation of local limits for indirect discharges. Discharge of persistent toxics upstream of CSOs will be in accordance with guidance under (NYSDEC Division of Water Technical and Operational Guidance Series (TOGS) 1.3.8 New Discharges to POTWs (PDF) (3.0MB - for smaller sections to download, see Important Links in the right column). For industrial operations characterized by use of batch discharge, consideration shall be given to the feasibility of a schedule of discharge during conditions of no CSO. For industrial discharges characterized by continuous discharge, consideration must be given to the collection system capacity to maximize delivery of waste to the treatment plant. Non-contact cooling water should be excluded from the combined system to the maximum extent practicable. Direct discharges of cooling water must apply for a SPDES permit.
To the maximum extent practicable, consideration shall be given to maximize the capture of nondomestic waste containing toxic pollutants and this wastewater should be given priority over residential/commercial service areas for capture and treatment by the POTW.
4. Maximize Flow to POTW
Factors cited in Item 2. above shall also be considered in maximizing flow to the POTW. Maximum delivery to the POTW is particularly critical in treatment of "first-flush" flows. The treatment plant shall be capable of receiving and treating: the peak design hydraulic loading rates for all process units; i.e., a minimum of _____ MGD through the plant headworks; a minimum of ______ MGD through the primary treatment works and disinfection works if applicable; and a minimum of _______ MGD through the secondary treatment works during wet weather. The collection system and headworks must be capable of delivering these flows during wet weather. If the permittee cannot deliver maximum design flow for treatment, the permittee shall submit a plan and schedule for accomplishing this requirement within ____ months after the effective date of this permit.
5. Wet Weather Operating Plan
The permittee shall maximize treatment during wet weather events. This shall be accomplished by having a wet weather operating plan containing procedures so as to operate unit processes to treat maximum flows while not appreciably diminishing effluent quality or destabilizing treatment upon return to dry weather operation. The wet weather operations plan shall be developed in accordance with the DEC guidance, Wet Weather Operating Practices for POTWs With Combined Sewers (PDF) (286 KB), and submitted to the Regional Office and the Bureau of Water Permits, 625 Broadway, Albany, NY 12233-3505 for review and approval within _____ months after the effective date of this permit.
The submission of a wet weather operating plan is a one time requirement that shall be done to the Department's satisfaction once. However, a revised wet weather operating plan must be submitted whenever the POTW and/or sewer collection system is replaced or modified. When this permit is administratively renewed by NYSDEC letter entitled "SPDES NOTICE/RENEWAL APPLICATION/PERMIT", the permittee is not required to repeat the submission. The above due dates are independent from the effective date of the permit stated in the letter of "SPDES NOTICE/RENEWAL APPLICATION/PERMIT".
6. Prohibition of Dry Weather Overflow
Dry weather overflows from the combined sewer system are prohibited. The occurrence of any dry weather overflow shall be promptly abated and reported to the NYSDEC Regional Office in accordance with 6 NYCRR Part 750-2.7.
7. Control of Floatable and Settleable Solids
The discharge of floating solids, oil and grease, or solids of sewage origin which cause deposition in the receiving waters, is a violation of the NYS Narrative Water Quality Standards contained in Part 703. As such, the permittee shall implement best management practices in order to eliminate or minimize the discharge of these substances. All of the measures cited in Items 1, 2, 4 & 5 above shall constitute approvable "BMPs" for mitigation of this problem. If aesthetic problems persist, the permittee should consider additional BMP's including but not limited to: street sweeping, litter control laws, installation of floatables traps in catch basins (such as hoods), booming and skimming of CSOs, and disposable netting on CSO outfalls. In cases of severe or excessive floatables generation, booming and skimming should be considered an interim measure prior to implementation of final control measures. Public education on harmful disposal practices of personal hygienic devices may also be necessary including but not limited to: public broadcast television, printed information inserts in sewer bills, or public health curricula in local schools.
8. Combined Sewer System Replacement
Replacement of combined sewers shall not be designed or constructed unless approved by NYSDEC. When replacement of a combined sewer is necessary it shall be replaced by separate sanitary and storm sewers to the greatest extent possible. These separate sanitary and storm sewers shall be designed and constructed simultaneously but without interconnections to maximum extent practicable. When combined sewers are replaced, the design should contain cross sections which provide sewage velocities which prevent deposition of organic solids during low flow conditions.
9. Combined Sewer/Extension
Combined sewer/extension, when allowed should be accomplished using separate sewers. These sanitary and storm sewer extensions shall be designed and constructed simultaneously but without interconnections. No new source of storm water shall be connected to any separate sanitary sewer in the collection system.
If separate sewers are to be extended from combined sewers, the permittee shall demonstrate the ability of the sewerage system to convey, and the treatment plant to adequately treat, the increased dry-weather flows. Upon a determination by the Regional Water Engineer an assessment shall be made by the permittee of the effects of the increased flow of sanitary sewage or industrial waste on the strength of CSOs and their frequency of occurrence including the impacts upon best usage of the receiving water. This assessment should use techniques such as collection system and water quality modeling contained in the 1999 Water Environment Federation Manual of Practice FD-17 entitled, Prevention and Control of Sewer System Overflows, 2nd edition.
10. Sewage Backups
If, there are documented, recurrent instances of sewage backing up into house(s) or discharges of raw sewage onto the ground surface from surcharging manholes, the permittee shall, upon letter notification from DEC, prohibit further connections that would make the surcharging/back-up problems worse.
11. Septage and Hauled Waste
The discharge or release of septage or hauled waste upstream of a CSO is prohibited.
12. Control of Run-off
It is recommended that the impacts of run-off from development and re-development in areas served by combined sewers be reduced by requiring compliance with the New York Standards for Erosion and Sediment Control and the quantity control requirements included in the New York State Stormwater Management Design Manual.
13. Public Notification
Within _____ months of the effective date of this permit, the permittee shall install and maintain identification signs at all CSO outfalls owned and operated by the permittee. The permittee shall place the signs at or near the CSO outfalls and ensure that the signs are easily readable by the public. The signs shall have minimum dimensions of eighteen inches by twenty four inches (18" x 24") and shall have white letters on a green background and contain the following information:
The permittee shall implement a public notification program to inform citizens of the location and occurrence of CSO events. This program shall include a mechanism (public media broadcast, standing beach advisories, newspaper notice etc.) to alert potential users of the receiving waters affected by CSOs. The program shall include a system to determine the nature and duration of conditions that are potentially harmful to users of these receiving waters due to CSOs.
14. Characterization and Monitoring
The permittee shall characterize the combined sewer system, determine the frequency of overflows, and identify CSO impacts in accordance with Combined Sewer Overflows, Guidance for Nine Minimum Controls, EPA, 1995, Chapter 10. These are minimum requirements, more extensive characterization and monitoring efforts which may be required as part of the Long Term Control Plan.
15. Annual Report
The permittee shall submit an annual report summarizing implementation of the above best management practices (BMPs). The report shall list existing documentation of implementation of the BMPs and shall be submitted by January 31st of each year to the Regional office listed on the Recording, Reporting and Additional Monitoring page of this permit and to the Bureau of Water Permits, 625 Broadway, Albany, NY 12233-3505. Examples of recommended documentation of the BMPs are found in Combined Sewer Overflows, Guidance for Nine Minimum Controls, EPA, 1995. For guidance on developing the annual report, a BMP checklist (PDF) (410 KB) is available from DEC on-line. The permittee must submit a completed copy of this checklist along with the annual report. The actual documentation shall be stored at a central location and be made available to DEC upon request.