HomeMy Public PortalAboutLetter to EPA with Proposed Revision (3/26/13)rai
I L-1
March 26, 2013
Metropolitan S1, Louis
Sevier District
2350 MdrkdtShoal
St_ LOA VO63103
Ph= 31t.703.6200
mwalivklatim
Chief, Water Enforcement and Compliance Assurance Branch
Water and Wetlands Protection Division
U.S. Environmental •Protection Agency - Region 7
11201 Renner Blvd.
Lenexa, KS 66219
RE: MSD Proposed Revision of CSO Control Measure Design Criteria:
CSO Treatment Unit at Lemay CSO Outfall 063
Greetings:
The Metropolitan St. Louis Sewer District ("MSD" or the "District") submits this letter as a
request under paragraph 61 of the Consent Decree in case number 4:07-ev 01120-CEJ that the
design criteria for a CSO Control Measure listed in Appendix D be revised. MSD requests that
the design criteria for the CSO Control Measure: "CSO Treatment Unit at Lemay CSO Outfall
063" be revised to have a control measure title of just "CSO Treatment Unit". This CSO Control
Measure is included in Appendix D of the Consent Decrees as a CSO control measure for Lower
& Middle River Des Peres.
MSD's proposed revision to this CSO Control Measure will continue to provide an Enhanced
High Rate Clarification facility with a 100 MGD capacity providing the equivalent of primary
clarification, solids/floatables disposal, and disinfection. MSD's proposed revision to this CSO
Control Measure will allow the CSO treatment unit to be changed to a new location near the
downstream end of the CSO storage tunnel (i.e., near the tunnel dewatering pump station and
Lemay WWTP). In essence, the flow that would have been treated by the CSO treatment unit at
Lemay CSO Outfall 063 and discharged to the River Des Peres, will now enter the tunnel, be
transported to the downstream end, and be treated and discharged at that location.
Furthermore, MSD's proposed revision if approved by June 30, 2013 will allow MSD to meet
the Critical Milestone Dates specified in Appendix D. Demonstrating good engineering practice,
the proposed revision, with the relocation of this treatment unit, will benefit water quality on the
receiving streams, allow for greater operation and management efficiencies, improve grit
management in the CSO storage system and allow for future facility expandability if required.
For these and other reasons outlined in the attached documents MSD believes this proposed
revision should be approved by EPA.
Enclosed and hereby incorporated with this letter you will find 1) a proposal document providing
a detailed explanation of the requested revision along with relevant information demonstrating
that the proposed revision reflects good engineering practice and will continue to achieve the
Performance Criteria specified in Appendix D for this CSO Control Measure; and 2) a red -lined
CHIEF, WATER ENFORCEMENT AND COMPLIANCE ASSURANCE BRANCH
WATER AND WETLANDS PROTECTION DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY - REGION 7
MARCH 26, 2013
PAGE
version of relevant portions of the Consent Decree (Appendix D and Appendix E) delineating the
requested revisions to the Consent Decree for this proposed revision.
MSD would like to help facilitate the quickest resolution of this request as possible in an effort to
ensure its ability to meet the Critical Milestone dates specified in Appendix D for this CSO
Control Measure. With that being said, MSD would like to schedule a meeting between your
office and MSD technical staff to discuss any technical questions you may have and the process
moving forward. We will contact your office immediately for help coordinating a meeting.
If you should have any questions with regard to this matter, please feel free to contact me.
Sincerely
gat,K
Susan M. Myers
General Counsel
cc: State of Missouri Department of Natural Resources
Missouri Coalition For The Environment Foundation
Jon Sprague, MSD
Brian Hoelscher, MSD
Brad Nevois, MSD
CHIEF, WATER ENFORCEMENT AND COMPLIANCE ASSURANCE BRANCH
WATER AND WETLANDS PROTECTION DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY- REGION 7
MARCH 26, 2013
PAGE3
Consent Deem. CUnin111lliLaticf Distribution Lisi
United States:
Chief, Environmental Enforcement Section
Environment and Natural Resources Division
U.S. Department of Justice
Box 7611 Ben Franklin Station
Washington, D.C. 20044-7611
Re: DOJ No. 90-5-1-1-08111
EPA:
Chief, Water Enforcement and Compliance
Assurance Branch
Water and Wetlands Protection Division
U.S. Environmental Protection Agency,
Region 7
11201 Renner Blvd.
Lenexa, KS 66219
David Cozad
Regional Counsel
Office of Regional Counsel
U.S. Environmental Protection Agency,
Region 7
901 North 5th Street,
Kansas City, KS 66101
State of Missouri:
Chief Counsel
Agriculture and Environment Division
State of Missouri Office of Attorney General
207 W. High Street
Jefferson City, MO 65102
Chief, Water Pollution Compliance and
Enforcement Section
Missouri Department of Natural Resources
P.O. Box 176
1101 Riverside Dr.
Jefferson City, MO 65101
Director, St. Louis Regional Office
Missouri Department of Natural Resources
7523 South Lindbergh Blvd.
St. Louis, MO 63125
Coalition:
Kathleen Logan Smith
Executive Director
Missouri Coalition for the Environment
6267 Delmar BIvd. #2E
St. Louis, MO 63130
Maxine I. Lipeles
Elizabeth J. Hubertz
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive
Campus Box 1120
St. Louis, MO 63130
MSD:
Executive Director
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103-2555
Director of Engineering
Metropolitan St. Louis Sewer District '
2350 Market Street
St. Louis, MO 63103-2555
Metropolitan St. Louis Sewer District Proposed
Revision of CSO Control Measure Design Criteria: CSO
Treatment Unit at Lemay CSO Outfall 063
In accordance with Paragraph VI.E.61 of Consent Decree No. 4:07-CV-1120 between the United
States of America, the Missouri Coalition for the Environment Foundation and Metropolitan
St. Louis Sewer District ("MSD") MSD hereby proposes the following revision to the Design
Criteria for one of the CSO Control Measures listed in Appendix D of the Consent Decree. For
the proposed revision to the design criteria for the CSO Control Measure: Treatment Unit at
Lemay CSO Outfall 063, MSD herein demonstrates that the revision 1) reflects good engineering
practice, and 2) will continue to achieve the Performance Criteria specified in Appendix D.
MSD has also enclosed red -lined versions of relevant portions of the Consent Decree delineating
the requested revisions to the Consent Decree for this proposed revision.
Overview
This proposed revision is for the CSO Control Measure for the Lower & Middle River Des Peres
titled CSO Treatment Unit at Lemay CSO 0:4a11063. This control measure can be found on
page 6 of Appendix D of the Consent Decree. The location of the treatment unit described in the
Consent Decree is depicted in the figure below, at Outfall 063 at the upstream end of the
proposed CSO storage tunnel. MSD proposes that the location of the CSO treatment unit be
changed to a new location near the downstream end of the CSO storage tunnel (i.e., near the
tunnel dewatering pump station and Lemay WWTP). In essence, the flow that would have been
treated by the CSO treatment unit at Outfall 063 and discharged to the River Des Peres, will now
enter the tunnel. be transported to the downstream end, and be treated and discharged at that
location.
Current location of CSO Treatment Unit at Outfall 063
0 6,800 13,200
Feet
ii Proposed Treatment Facilities
/f Proposed Storage Tunnel Under RCP
CSO Locations
X 'lb Be Separated
[] Maddlnd Pump Station
",/ Major Combined Sewers
/ .J Major Sanitary Sewers
/V Skinker-McCauslandTUnnal
Creeks
�•+ $L Louis City LImits
The CSO treatment unit would still be an Enhanced High Rate Clarification facility with a
100 MGD capacity providing the equivalent of primary clarification, solids/floatables disposal,
and disinfection. No changes to the Critical Milestones dates (Bid Year and Achievement of Full
Operation) are proposed, provided that timely approval of the proposed revision is received.
The Proposed Revision Reflects Good Engineering Practice
The proposed revision reflects good engineering practice for the following reasons:
• Location of the CSO treatment unit nine miles farther downstream along the River Des
Peres reduces the impact, if any, of the primary treated and disinfected effluent on the
River Des Peres. The relocated facility's discharge point will be at a location where
receiving stream flows and stream assimilative capacity are greater.
• Location of the CSO treatment unit near or adjacent to the Lemay Wastewater Treatment
Plant will provide for significantly improved operations and maintenance (O&M) support
compared to a treatment unit at a remote location. O&M issues can be responded to much
quicker, and by personnel who specialize in the operation and upkeep of treatment units.
The anticipated result is overall better performance of the CSO treatment unit.
• Location of the CSO treatment unit at the downstream end of the tunnel will enhance the
ability of the tunnel system to effectively deal with grit that enters the system from
combined sewers. Some older and relatively -ineffective CSO tunnel designs have
emphasized the importance of improving grit management in CSO storage systems by
proper pump station design and avoiding "dead -ended" tunnels.
• In addition to the water quality and operational issues noted above, a site near the
downstream end of the CSO storage tunnel offers several advantages over the site at
Outfall 063. The site at Outfall 063 is in close proximity (approximately 500 feet) to
Gateway High School. Placing a treatment facility near this school is undesirable from
several perspectives: routine chemical deliveries, noise, potential odors, etc. The
Outfall 063 site is further complicated by property title issues, and room for future
expansion is problematic. Relocating the CSO treatment unit to a site near the
downstream end of the tunnel has the advantage of additional land availability, which
allows more alternative treatment technologies to be considered, and allows for future
facility expandability as recommended by the CSO control policy.
The Proposed Revision Will Continue to Achieve the Performance Criteria
Specified in Appendix D of the Consent Decree.
MSD has determined that this proposed revision will not affect the CSO Control Measure's
ability to achieve the Performance Criteria specified in Appendix D of the Consent Decree. Final
design of the tunnel system and CSO treatment unit has not yet begun, but preliminary
evaluations have been conducted to determine the impacts of relocating the treatment unit on
tunnel sizing and CSO control system performance.
Several potential impacts were identified as a result of relocating the CSO treatment unit. The
intake structure and drop shaft at OutfaIl 063 will need to be nominally larger to accept the
additional 100 MGD of flow that otherwise would have been treated and discharged to the River
Des Peres channel at this location. Because of the large intake and drop shaft capacity already
required for this CSO (conceptual peak design flows of approximately 4,000 MGD), the addition
2
of another 100 MGD of flow is not expected to increase the size or cost of these facilities to a
measureable extent.
The impact of the additional 100 MGD flow within the tunnel (i.e., during tunnel filling) was
also considered, and determined, by practical experience and hydraulic modeling, to be
negligible.
Finally, impacts on CSO control system performance (i.e., the Performance Criteria) were
evaluated. The CSO "control system" is considered as consisting of the storage tunnel and
inlet/drop structures, the tunnel dewatering pump station, the CSO treatment unit, and the Lemay
WWTP. Because the exact mode of system operation has not yet been determined, pending final
design, two hydraulic model runs (using the Long -Term Control Plan's XP-SWMM model) were
conducted to "bracket" the performance of the system with the relocated CSO treatment unit.
Precipitation data for the typical year (Year 2000) were input, and the model results were then
compared to the Performance Criteria specified in the Consent Decree.
The two scenarios that were evaluated to bracket system performance are as follows:
• The first scenario (Scenario A) considered that the tunnel dewatering pump station would
pump whatever volume is available in the tunnel up to a maximum flow rate of
100 MGD. This scenario represents the maximum treatment that the CSO treatment unit
would provide.
• The second scenario (Scenario B) only pumped flow to the CSO treatment unit when the
tunnel was completely filled. This represents the minimum flow that the treatment unit
would see.
The results of the two (2) bracketing scenarios are presented in the table below, and compared to
the Consent Decree performance criteria. Either "extreme" scenario meets the Consent Decree
requirements. No increases in tunnel size or treatment unit capacity are needed to accommodate
the treatment unit relocation.
Performance Criteria
Consent
Decree
Scenario A
Scenario B
Number of Overflow Events in Typical
Year
4
3
4
Untreated Overflow Volume (million
gallons)
1,412
980
950
In reality, some intermediate control scheme will be designed wherein the tunnel dewatering
pump station will deliver flow either to the Lemay W W TP or the CSO treatment unit during
portions of the tunnel filling period to assist with grit transfer through the tunnel, and then the
CSO treatment unit would be utilized as necessary to optimize system performance. When the
optimal operational scheme is finally developed, additional hydraulic modeling will be
performed to define the expected system performance, which is expected to fall between the two
scenarios presented above.
3
Conclusion
In summary, the proposed revision, the change in the location of the treatment unit represents
good engineering practice, and continues to meet the Performance Criteria specified in the
Consent Decree. For the reasons outlined above MSD believes that the proposed revision should
be made pursuant to paragraph 61 of the Consent Decree. The proposed revision must be made
promptly so that MSD can continue to meet the critical milestones identified for this CSO
control measure. This document is submitted as MSD's request for EPA approval of this
proposed modification.
4
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 1 of 9 PagelD #: 1615
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Control Measures — Maline
Creek
C5O Canitrol
Measure
Description
Design Criteria
Perfo rma nc e
Criteria
Critical Milestones
Elimination of
Bissell Point CSO
Outfalls 053 and
060
1
CSO Treatment
Unit at Bissell
Point Outfall 051
Sewer separation
to allow
elimination of
CSO Outfalls
Enhanced High
Rate
Clarification
facility
Bissell Point
Outfall 052
Storage Tank
Local storage
facility
MSI) s Kutes anti Kegulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Draina a Facilities
94 MGD capacity providing
equivalent of primary
clarification, solids/floatables
disposal, and disinfection
Provide storage volume of one
million gallons, expandable to
accommodate storage require-
ments, if any, as determined in
SSO Control Master Plan
Elimination of Bissell
Point CSO Outfalls
053 and 060
Reduce overflows to
4 events or less, and
6 million gallons of
untreated overflow
volume in the typical
year('). Comply with
applicable Missouri
Operating Permit. _
Reduce overflows to
4 events or less, and
20 million gallons of
untreated overflow
volume in the typical
vearrl i
• Achievement of Full
Operation — 01/01/2011
• Bid Year-2017
• Achievement of Full
Operation —12/31 /2020
• Bid Year — 2017
• Achievement of Full
Operation —12/31/2020
500 1,000 2,000
Feet
•
CE
Proposed Storage Facility
• Proposed Treatment
CSO Locations
• To Be Separated
• Malin Oropshaq
Bissell Point Interceptor Tunnel
/1/ Major Combined Sewers
/\/ Major Sanitary Sewers
f'." Creeks
*.b St. Louis City Limits
Maline Creek CSO Controls
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 2 of 9 PagelD #: 1616
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Control Measures — Gingras Creek
CSO C. •trol
Measur=
Description Design Criteria
Perform nee
Criteria
Critical Milestones
Sewer Separation
Bissell Point CSO
Outfa11 059
Relocation
Separation of
sewers to reduce
stormwater flow
Relocation of
Outfall 059 from
Gingras Creek to
branch of Baden
Trunk Sewer
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
When incorporated
with other Gingras
Creek CSO controls,
eliminates Outfall
059 to Gingras Creek
When incorporated
with other Gingras
Creek CSO controls,
eliminates CSO
Outfall 059 to
Gingras Creek
• Achievement of Full
Operation — 06/30/2017
• Achievement of Full
Operation — 06/30/2017
„H.lstoT,
500 1,000 2,000
15 Feet
1
Gingras Creek CSO Controls
IY
"" Proposed Outfall Extension
Y New Storm Sewer Alignment
C /\/ Major Combined Sewers
/N,/ Major Sanitary Sewers
N.. Creeks
•'. St. Louis City Limits
Schools
2
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 3 of 9 PagelD #: 1617
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Control Measures — Upper River Des Peres
CSO C. trol
Measur
i
Description Design Criteria
Performance
Criteria
Critical Milestones
Upper River Des
Peres Storage
Tunnel serving
Lemay Outfalls
064, 066 to 096,
099 to 102, 167,
178 and 180
Deep storage
tunnel, near -
surface facilities,
pump station,
sewer separation
and consolida-
tion sewers
Provide storage volume of
30 million gallons in deep
tunnel system to capture flows
from Lemay CSO Outfalls
064, 066 to 096, 099 to 102,
167, 178 and 180
When incorporated
with other River Des
Peres CSO controls,
reduce overflows to
4 events or less, and
94 million gallons of
untreated overflow
volume in the typical
year(1)
Upper River Des Peres CSO Controls
• Bid Year — 2028
• Achievement of Full
Operation — 06/30/2034
3
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 4 of 9 PagelD #: 1618
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Control Measures — River Des Peres Tributaries
CSO C
Measur
trot Description Design Criteria
Performance
Criteria
Critical Milestones
Elimination of
Lemay CSO
Outfalls 108, 110,
114, 115, 157, 164
and 165
Lemay CSO
Outfall 107
Elimination
Lemay CSO
Outfall 112
Elimination
Lemay CSO
Outfall 116
Elimination
Lemay CSO
Outfall 141
Elimination
Sewer separation
to allow
elimination of
CSO Outfalls
Sewer separation
to allow
elimination of
Lemay
Outfall 107
Sewer separation
to allow
elimination of
Lemay
Outfall 112
Sewer separation
to allow
elimination of
Lemay
Outfall 116
Sewer separation
to allow
elimination of
Lemay
Outfall 141
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Draina e Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
Lemay CSO
Outfall 160
Elimination
Lemay CSO
Outfall 161
Elimination
Lemay CSO
Outfall 174
Elimination
Lemay CSO
Outfall 175
Elimination
Sewer separation
to allow
elimination of
Lemay
Outfall 160
Sewer separation
to allow
elimination of
Lemay
Outfall 161
Sewer separation
to allow
elimination of
Lemay
IOutfall 174
Sewer separation
to allow
elimination of
Lemay
Outfall 175
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
Elimination of Lemay
CSO Outfalls 108,
110, 114, 115, 157,
164 and 165
• Achievement of Full
Operation— 01/01/2011
Elimination of Lemay
CSO Outfall 107
Elimination of Lemay
CSO Outfall 112
Elimination of Lemay
CSO Outfall 116
Elimination of Lemay
CSO Outfall 141
Elimination of Lemay
CSO Outfall 160
• Achievement of Full
Operation —12/31/2012
• Achievement of Full
Operation --12/31/2012
• Achievement of Full
Operation-12/31/2012
• Achievement of Full
Operation— 12/31/2012
• Achievement of Full
Operation-12/31/2012
Elimination of Lemay • Achievement of Full
CSO Outfall 161 Operation— 06/30/2021
Elimination of Lemay
CSO Outfall 174
• Achievement of Full
Operation —12/31/2012
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
Elimination of Lemay
CSO Outfall 175
• Achievement of Full
Operation —12/31 /2012
4
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 5 of 9 PagelD #: 1619
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Cc}l trol
Measur=
Description
Design Criteria
Performance
Criteria
COO caI iwliiestones
River Des Peres
Tributaries
Storage Tunnel
serving Lemay
CSO Outfalls 103,
104, 105, 106,
111, 117 to 128,
130, 131, 134, 136
to 140, 166 and
176
Storage /
conveyance
tunnel, near -
surface facilities,
pump station,
sewer separation
and
consolidation
sewers
0 3,000 0,000
Feel
Conveyance tunnel with
storage volume of 28 million
gallons to capture flows from
Lemay CSO Outfalls 103,
104, 105, 106, 111, 117 to
128, 130, 131, 134, 136 to
140, 166 and 176
When incorporated
with other River Des
Peres CSO controls,
reduce overflows to
4 events or less to
River Des Peres main
channel in the typical
yew')
• Bid Year— 2024
• Achievement of Full
Operation — 06/30/2030
River Des Peres Tributaries CSO Controls
a Dewatertng Pump Station
ONalf Conveyance! Storage Tunnel
]t[ To Be Separated
71. Eliminated Claps
/r/ Major Combined Sewers
Major Sanitary Sewers
Creaks
'••• St. Louis City Limits
5
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 6 of 9 PagelD #: 1620
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Control Measures - Lower & Middle River Des Peres
CSO Caritrol Description
Measur-
Design Criteria
Performance
Criteria
Critical Milestones
Elimination of
Lemay CSO
Outfalls 046; 049,
168 and 177
Lemay CSO
Outfall 062
Elimination
CSO Treatment
Unit
COAutfa41.063
In -sewer Storage
Upstream of
Lemay CSO
Outfall 063
Sewer separation
to allow
elimination of
CSO Outfalls
Sewer separation
to allow
elimination of
Lemay CSO
Outfall 062
Enhanced High
Rate
Clarification
facility
Inflatable or
moveable dam
system to allow
flow storage in
upstream 29-fl
horseshoe sewers
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
MSD's Rules and Regulations
and Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
100 MGD capacity providing
equivalent of primary
clarification, solids/floatables
disposal, and disinfection
Provide 25 million gallons
storage capacity within
existing sewer system to
capture flows from Lemay
CSO Outfall 063
Elimination of Lemay
CSO Outfalls 046,
049,168 and 177
Elimination of Lemay
CSO Outfall 062
When incorporated
with other River Des
Peres CSO controls,
reduce overflows to
4 events or less in the
typical year').
Comply with
applicable Missouri
O • erating Permit.
When incorporated
with other River Des
Peres CSO controls,
reduce overflows to
4 events or less in the
ical ear')
A'
• Achievement of Full
Operation - 01 /01 /2011
• Achievement of Full
Operation -12/31/2015
• Bid Year - 2027
• Achievement of Full
Operation-12/31/2030
• Achievement of Full
Operation- 12/31/2030
Lower & Middle
River Des Peres
Storage Tunnel
serving Lemay
CSO OuifalIs 008
to 032, 036, 037,
039, 041 to 044,
048, 050, 052,
053, 054, 057,
058, 061, 063,
163, 170 to 173,
and 181
Deep storage
tunnel, near -
surface facilities,
pump station,
sewer separation
and consolida-
tion sewers
Provide storage volume of
206 million gallons in deep
tunnel system to capture flows
from Lemay CSO Outfalls
008 to 032, 036, 037, 039, 041
to 044, 048, 050, 052, 053,
054, 057, 058, 061, 063, 163,
170 to 173, and 181
When incorporated
with other River Des
Peres CSO controls,
reduce overflows to
4 events or less in the
typical year'), and
untreated overflow
volume to the River
Des Peres of
1,412 million gallons
from the Lower &
Middle River Des
Peres Storage Tunnel
and the River Des
Peres Tributaries
Storage Tunnel
combined.
• Bid Year- 2021
• Achievement of Full
Operation -12/31/2030
6
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 7 of 9 PagelD #: 1621
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
zit.- uN.
�rr'+C;�39'.;+i�.. F
4
,..--ri •1f-_ f ._ -7If j:. -
ama
i fi .$i49
411477 I- 1
,.� -'4' ._.1 MOVE TREATMENT UNIT
, i.-'r
tr
j ^ Liemay-163 t \ •
E — i ��-Lemay 18 e' . _
s
#r'- If *—WL)Eibrol PUMP MITATt6N . e ll'.
' . �.• . "
f . 1
•
43.600 13.200
Feet
Proposed Trealment Facilities
,e've Proposed Storage Tunnel Under RCP
CSO Locations
To Be Separated
Manktind Pump Station
E�3
/\/ Major Combined Sewers
/\/ Major Sanitary Sewers
Skinker-McCausland Tunnel
r Creeks
•••,i SL Louis City Limits
Lower & Middle River Des Peres CSO Controls
7
Case: 4:07-cv-01120-CEJ Doc. #: 159-4 Filed: 04/27/12 Page: 8 of 9 PagelD #: 1622
Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
Other CSO Control Measures
CSO Control Description Design Criteria
Measure
Perforrrtance Criteria
Critical Milestones
Bissell Point CSO
Outfall 055
Elimination
Sewer separation
to allow
elimination of
Bissell Point
CSO Outfall 055
Lemay Treatment
Plant — Increase
Secondary
Treatment
Capacity
Lemay Treatment
Plant — Utilize
Excess Primary
Treatment
Capacity — Phase I
Lemay Treatment
Plant — Utilize
Excess Primary
Treatment
Capacity — Phase II
Bissell Point
Treatment PIant —
Utilize Excess
Primary
Treatment
Capacity
Upgrade aeration
tanks and
ancillary systems
to achieve peak
wet -weather
capacity of
210 MGD
Increase influent
pumping,
preliminary
treatment and
primary
treatment
capacity from
240 MGD to
290 MGD
Increase influent
Pumping,
preliminary
treatment and
primary
treatment
capacity from
290 MGD to
340 MGD
Utilize excess
100 MGD
preliminary and
primary
treatment
capacity to treat
wet weather
flows
MSD's Rules and
Regulations and
Engineering Design
Requirements for Sanitary
Sewer and Stormwater
Drainage Facilities
10 CSR 20-8 for new
facilities
Existing facilities Design
Basis
10 CSR 20-8 for new
facilities
Existing facilities Design
Basis
10 CSR 20-8 for new
facilities
Existing facilities Design
Basis
10 CSR 20-8 for new
facilities
Existing facilities Design
Basis
Elimination of Bissell Point
CSO Outfall 055
• Achievement of Full
Operation —01/01/2011
Provide peak wet -weather
flow capacity of 210 MGD
through secondary treat-
ment. Operate treatment
facilities to comply with
Missouri State Operating
Permit requirements. Upon
completion of the stress test
required by Appendix E,
MSD shall operate the
WWTP in accordance with
the maximum treatable flow
rate for each treatment step.
Provide peak wet weather
flow capacity of 290 MGD
through primary treatment
when plant flows exceed
secondary treatment
capacity. Operate treatment
facilities to comply with
Missouri State Operating
Permit requirements.
Provide peak wet weather
flow capacity of 340 MGD
through primary treatment
when plant flows exceed
secondary treatment
capacity. Operate treatment
facilities to comply with
Missouri State Operating
j Permit requirements_
Provide peak wet weather
flow capacity of 350 MGD
through primary treatment
when plant flows exceed
secondary treatment
capacity and when total
plant flow is not limited by
river flooding. Operate
treatment facilities to
comply with Missouri State
Operating Permit
re uirements.
• Achievement of Full
Operation— 12/31/2015
• Achievement of Full
Operation — 01/01/2011
• Achievement of Full
Operation-12/31 /2015
• Achievement of Full
Operation — 01/01/2011
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Appendix D
CSO Control Measures, Design Criteria, Performance Criteria, and Critical Milestones
CSO Con rol
Measur'•
Description
Design Criteria
Performance Criteria Critical Milestones
Green
Infrastructure
Program — Pilot
Program
Green
Infrastructure
Program
Stormwater
retrofitting of
abandoned
properties in
Bissell Point and
Lemay service
areas
Stormwater
retrofitting of
abandoned
properties in
Bissell Point and
Lemay service
areas
Capture runoff from
existing or future
impervious areas on
properties and, if possible,
adjacent impervious
streets and alleys, in
accordance with
Section 12 of the Long -
Term Control Plan.
Capture runoff from
existing or future
impervious areas on
properties and, if possible,
adjacent impervious
streets and alleys, in
accordance with
Section 12 of the Long -
Term Control Plan and
the plan for full-scale
implementation contained
in the Pilot Program Final
Report.
Apply green infrastructure
on 200 to 400 abandoned
properties, encompassing
20 to 40 acres, with a total
expenditure of at least
$3 million. MSD shall
submit to EPA and the
State for review and for
EPA's approval, with a
copy to the Coalition, the
Pilot Program Final Report.
Performance Criteria to be
identified in Pilot Program
Final Report, with a
minimum expenditure of
$100 million total which
includes the pilot program.
• Achievement of Full
Operation —12/31/2015
• Achievement of Full
Operation — 06/30/2034
CSO Control Measures will be designed to reduce the number of overflows to Maline Creek and the River Des Peres to
achieve a Performance Criteria of 4 overflow events or less in the "typical year." The term "overflow event" means an
overflow at one or more CSO Outfalls on a receiving stream segment, based on a 6-hour inter -event time, that does not
receive the equivalent of primary clarification, solids and floatables disposal, and disinfection, if necessary to meet water
quality standards. "Typical year" performance and achievement of Performance Criteria shall be assessed in accordance with
the Post -Construction Monitoring Program using the annual statistics generated by the hydraulic model based on the Year
2000 hourly precipitation data from Lambert St. Louis International Airport.
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
I. Purpose and Scope
No later than one year from Date of Entry, MSD shall submit to EPA and the State for
review and for EPA's approval, with a copy to the Coalition, a plan for a Post -Construction
Monitoring Program ("PCMP") that (1) demonstrates whether MSD has achieved the Performance
Criteria for each CSO Control Measure set forth in Appendix D and (2) assesses and documents
the impacts on receiving water quality that result from the implementation of the CSO Control
Measures. MSD shall implement the PCMP upon receipt of EPA's written approval of the
PCMP Plan. During implementation of the CSO Control Measures, MSD shall not reroute any
flows in the Sewer System for the purpose of meeting the Performance Criteria other than those
measures consistent with the Long Term Control Plan ("LTCP") or as otherwise approved in
writing by EPA.
The PCMP shall include the following elements:
• Actions to evaluate and document the effectiveness of each CSO Control Measure
set forth in Appendix D;
• Actions to assess and document the environmental benefits attributable to CSO
Control Measures;
• A Water Quality Monitoring Plan that details the monitoring schedule, sampling
locations, and monitoring procedures to collect data related to the Performance
Criteria and the impacts from CSOs on receiving water quality;
• Updates and enhancement of the collection system computer models; and
• Mechanisms for providing public education and information on the need for
implementation of the CSO Control Measures, any water quality improvements,
and the progress made in achieving the Performance Criteria.
II. Performance Monitoring and Sampling
MSD shall conduct performance monitoring and sampling in order to demonstrate that
the Performance Criteria for each CSO Control Measure has been satisfied. The monitoring and
sampling data must enable comparison of post -construction conditions with baseline conditions
determined during the development of the LTCP.
MSD shall initiate long-term monitoring of the performance of major constructed facilities
upon Achievement of Full Operation of each facility and long-term monitoring of the receiving
streams. Major constructed facilities, identified in Appendix D, include pumping station
improvements, wet weather storage tanks and conveyance/storage tunnels, expansions and
upgrades of existing wastewater treatment facilities, and any approved Enhanced High Rate
Treatment facilities planned for the CSS. Long-term monitoring of water quality in the receiving
streams must be performed in accordance with the Water Quality Monitoring Plan described
below.
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
MSD shall periodically evaluate the data it collects in order to document its compliance
with the Performance Criteria. Based on such evaluations, MSD may propose modifications of
the PCMP to EPA, and shall make such modifications to the PCMP once approved by EPA in
writing.
MSD has established its baseline collection system conditions through flow and
activation monitoring of selected CSO outfalls. MSD shall perform post -construction flow
monitoring at approved locations to support analyses demonstrating compliance with the
Performance Criteria for each CSO Control Measure.
Locations to be monitored in the Lemay service area include Outtall 063 and other
outfalls that collectively represent a minimum of 75 percent of the overflow volume in the
typical year, and major components of the CSO Control Measures including pump stations,
conveyance/storage tunnels and treatment facilities. Locations to be monitored in the Bissell
Point service area include remaining CSO outfalls to Maline Creek, and major components of
the CSO Control Measures including pump stations, storage tanks and treatment facilities.
MSD will select monitoring locations that specifically provide system operational and
flow data for calibrating the updated hydraulic models that include the constructed CSO Control
Measures, and locations that provide data for evaluating CSO Control Measure performance.
Specific locations to be monitored will be identified in the detailed monitoring plans to be
developed for the CSO Control Measures as described below.
The data shall also support:
• Characterization of sewer flow for evaluation of long-term collection system
performance.
• Collection of information on overflows at CSOs including overflow volume and
duration.
• Development of a database of flow data for use in future design efforts related to
controlling CSOs.
• Enhanced operation and maintenance actions to further control wet weather
discharges and achieve NPDES permit compliance.
• Demonstration of maximum treatable flow rate through each treatment step following
the secondary treatment upgrade at Lemay (stress test).
Performance monitoring of each CSO Control Measure shall commence within six
months of Achievement of Full Operation of that CSO Control Measure.
MSD shall submit to EPA and the State for review and for EPA's approval, with a copy
to the Coalition, a detailed monitoring plan for each of the following CSO Control Measures one
year prior to the applicable Achievement of Full Operation date set forth in Appendix D:
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
Maline Creek:
• Enhanced High Rate Treatment unit at Outfall 051
• Storage Tank at Outfall 052
Gingras Creek:
• Relocation of Outfall 059
Upper River Des Peres:
• Storage tunnel to store flows from CSO outfalls to the Upper River Des Peres
River Des Peres Tributaries:
• Tunnel to convey/store flows to Lemay WWTF
Lower and Middle River Des Peres:
• Flow storage in 29-ft horseshoe sewers under Forest Park
• Enhanced High Rate treatment unitneaf-enitfa14-0
• Removal of secondary treatment bottlenecks at WWTF
• Tunnel to convey/store flows to Lemay WWTF
Following Achievement of Full Operation of each CSO Control Measure listed in
Appendix D, MSD shall conduct activation monitoring at all CSO outfalls addressed by that
particular CSO Control Measure to determine the number of activation events at each CSO
outfall, and submit the activation information in the Annual Report as set forth in Section VIII
of the Consent Decree. Such activation information shall be submitted as an actual number of
events.
III. Stress Testing of Lemav Treatment Plant
MSD shall construct the CSO Control Measure in accordance with the description, design
criteria, performance criteria, and critical milestones contained in Appendix D to achieve a
minimum secondary treatment design capacity of 210 million gallons per day (MGD) at the
Lemay Treatment Plant. The existing preliminary and primary treatment facilities have a design
capacity of 340 MGD. Effluent disinfection facilities are currently being designed with a
capacity of 340 MGD.
MSD shall submit a stress test protocol to EPA and the State for review and for EPA's
approval, with a copy to the Coalition, at least 30 days prior to Achievement of Full Operation of
the upgraded wastewater treatment facilities. The protocol shall be designed to determine the
maximum treatable wet -weather flow rates for each treatment step (preliminary, primary,
secondary, and disinfection) at the Lemay Treatment Plant following the completion of the
upgrades described above. EPA/MDNR shall review the stress test protocol pursuant to
Section VIE of this Consent Decree (Review and Approval Procedures).
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
In accordance with that review, and by no later than 365 days after the Achievement of
Full Operation of the treatment plant upgrades, MSD shall conduct the approved stress test. The
stress test shall be performed to confirm that the peak wet -weather flow capacity of the preliminary
treatment, primary treatment, and disinfection facilities is 340 MGD or higher, and that the peak
wet -weather flow capacity of the secondary treatment facilities is 210 MGD or higher.
MSD shall submit the results of the stress test to EPA and the State for review and for
EPA's approval, with a copy to the Coalition, by no later than 400 days after Achievement of
Full Operation of the treatment plant upgrades. The results shall include the maximum treatable
wet -weather flow rates for each treatment step (preliminary, primary, secondary, and
disinfection). EPA/MDNR shall review the stress test results pursuant to Section VII of this
Consent Decree (Review and Approval Procedures). Within 60 days after approval of the stress
test results, MSD shall submit an application to modify its operating permit to include the
approved maximum treatable wet -weather flow rates for each treatment step. Upon issuance of
all necessary operating permit modifications, MSD shall operate the Lemay Treatment Plant in
accordance with such maximum treatable wet -weather flow rates for each treatment step. MSD
shall conduct post -construction monitoring of treatment plant performance to verify the
suitability of the approved stress test results.
IV. Water Quality Monitorine Plan
No later than one year from the Date of Entry, MSD shall submit a Water Quality
Monitoring Plan ("WQMP") to EPA and the State for review and for EPA's approval, with a
copy to the Coalition. Sampling locations for receiving waters shall include at a minimum the
sites used during the development of the LTCP. Data collected by the U.S. Geological Survey,
Missouri Department of Natural Resources, Illinois Environment Protection Agency, or other
agencies may be utilized for this monitoring if the data are considered by MSD to be of
acceptable quality.
The WQMP, at a minimum, shall:
• Further characterize baseline water quality conditions prior to development and
implementation of the CSO Control Measures set forth in Appendix D;
• Measure changes in water quality during and after implementation of the CSO
Control Measures; and
• Assess the impacts of CSOs on the water quality of the receiving stream remaining
after the Achievement of Full Operation of each CSO Control Measure.
The WQMP shall define the anticipated schedule for monitoring at each sampling location.
MSD shall conduct field measurements and collect water quality samples at the approved sampling
locations once every two weeks for all parameters except E. coli which shall be collected once
every two weeks during the recreation season. Monitoring shall begin within ninety (90) days of
EPA's approval of the PCMP and will be conducted at approximately the same time of day, on
the same day of the week, at each location, to obtain an appropriate representation of storm event
and non-event conditions. Monitoring shall not be delayed because of weather, except for safety
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
reasons. The monitoring frequency shall provide data sufficient to calculate a geometric mean
E. coli concentration consistent with applicable water quality standards and for tracking long
term trends.
MSD shall record field measurements for temperature, pH, and dissolved oxygen at each
site. Field observations shall also be recorded for floating debris, submerged debris, algal
growth/blooms, odor, and recreational use. Samples shall be collected and analyzed for, at a
minimum, E. coli. Samples from receiving waters other than the Mississippi River shall also be
analyzed for, at a minimum, BOD, ammonia, and total suspended solids.
At least 6 months prior to submitting the WQMP, MSD shall submit to EPA and the State
for review and for MDNR's approval, with a copy to the Coalition, the Quality Assurance Project
Plan (QAPP) to be used in the monitoring plan. The QAPP shall be developed based on the
guidance in the following documents:
• United States Environmental Protection Agency (EPA), December 2002. Guidance for
Quality Assurance Projects Plans, EPA QAIG-5, Washington, DC.
• United States Environmental Protection Agency (EPA), November 2002. Guidance on
Environmental Data Verification and Data Validation, EPA QA/G-8, Washington, DC.
For data collected by the U.S. Geological Survey, Missouri Department of Natural Resources,
Illinois Environment Protection Agency, or other agencies, MSD shall submit the applicable
agency's QAPP (e.g., Quality -Assurance Plan for Surface -Water Activities of the U.S. Geological
Survey, Missouri Water Science Center, October 2007) for MDNR review before that agency's
data may be utilized in the monitoring program.
V. Rainfall Monitoring
MSD shall include rainfall monitoring as an essential component of the PCMP. Detailed
analysis of precipitation is necessary to update MSD's hydraulic model as construction activities
proceed to fully evaluate compliance with the Performance Criteria. Precipitation data shall
consist of total rainfall depth, duration, intensity, and event distribution.
Rainfall data shall be compiled and analyzed as part of the PCMP. The source of rainfall
data is MSD's network of long-term rain gauges spaced throughout MSD's service area. Rainfall
data collected by MSD shall be used for analysis in connection with other post -construction
monitoring data.
VI. Data Management
MSD shall use a Data Management System and associated protocols for the storage,
management, retrieval, and analysis of all data used to assess the performance of MSD's CSO
Control Measures.
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APPENDIX E
POST -CONSTRUCTION MONITORING PROGRAM
VII. Quality Control
Quality control and quality assurance procedures and protocols prepared as part of the
development of the LTCP must continue to be used for the implementation of the PCMP. MSD
shall update the quality control and quality assurance procedures and protocols from time to time
as appropriate. All monitoring plans shall incorporate the procedures and protocols available at
the time of submittal.
VDT. Analysis., Progress Reporting, and Compliance Demonstration
MSD shall use the data from the PCMP to evaluate the performance and effectiveness of
each CSO Control Measure in complying with the Performance Criteria set forth in Appendix D.
Data from the PCMP shall be used to update and improve calibration and verification of
MSD's collection system models. The updated collection system models will be used to
demonstrate compliance with Performance Criteria as set forth in Appendix D using the 2000
design year used in development of the LTCP. At this juncture, it is assumed that accepted
engineering practice at the time the Post -Construction Monitoring Program is conducted will still
rely on a hydraulic model similar to those in use today. In the event that accepted practice at the
time the Post -Construction Monitoring Program is conducted has changed, MSD will submit an
alternate method for approval.
MSD shall report the results and progress of the PCMP in the Annual Report as set forth
in Section VIII of the Consent Decree. This progress report shall include a summary of CSS
Watershed performance to -date, consisting of:
• CSO activation and flow monitoring data;
• Rainfall data;
• Receiving water monitoring results;
• Status in achieving the Performance Criteria for each CSO Control Measure;
• Updating of collection system hydraulic models to reflect implemented CSO Control
Measures. Necessary model modifications, recalibration, and reverification will be
indicated and documented;
• Identification and documentation of CSO Control Measure deficiencies and
performance limitations; and
• Identification and documentation of any proposed supplemental remedial CSO
Control Measures.
6