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Post-Construction Compliance Monitoring Program

Post-Construction Compliance Monitoring Program. Julia Moore, P.E. Limno-Tech, Inc. What Does the CSO Control Policy Say About Compliance Monitoring?.

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Post-Construction Compliance Monitoring Program

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  1. Post-Construction Compliance Monitoring Program Julia Moore, P.E. Limno-Tech, Inc.

  2. What Does the CSO Control Policy Say About Compliance Monitoring? The selected CSO controls should include a post-construction water quality monitoring program adequate to verify compliance with water quality standards and protection of designated uses as well as to ascertain the effectiveness of CSO controls. Post-Construction Compliance Monitoring

  3. What Does the CSO Control Policy Say About Compliance Monitoring? This water quality compliance monitoring program should include a plan to be approved by the NPDES authority that details the monitoring protocols to be followed, including the necessary effluent and ambient monitoring and, where appropriate, other monitoring protocols such as biological assessments, whole effluent toxicity testing, and sediment sampling. Post-Construction Compliance Monitoring

  4. Post-Construction Compliance Monitoring • In short, post-construction compliance monitoring is: • Intended to determine the effectiveness of LTCP in meeting CWA requirements and local goals • Required under some Phase II and most post-Phase II permits Post-Construction Compliance Monitoring

  5. CSO Permitting and Monitoring Post-Construction Compliance Monitoring

  6. Reasons for Post-Construction Compliance Monitoring • Verify attainment of WQS or evidence that CSOs are not precluding attainment of WQS • Determine effectiveness of CSO controls with respect to reduction in volume/load, reduction in CSO frequency, etc. • Compare to conditions before the controls were put in place (baseline). • Build on data and analysis supporting the development of LTCP • Determine adherence to permit conditions Post-Construction Compliance Monitoring

  7. Reasons for Post-Construction Compliance Monitoring • Compliance monitoring lets us know whether or not: • The assumptions in the LTCP were correct • The anticipated degree of control and improvement in WQ have been realized • Interim adjustments to LTCP are warranted Post-Construction Compliance Monitoring

  8. Expectations for Post-Construction Compliance Monitoring • Consistency with goals of LTCP • May include: • Rainfall monitoring • Monitoring and/or modeling of CSS to show reduced CSO volumes and frequency over time • WQ monitoring during wet weather • Monitoring upstream and downstream of CSO outfalls Post-Construction Compliance Monitoring

  9. Expectations for Post-Construction Compliance Monitoring • Monitoring should be focused on performance measures to track progress of LTCP implementation in meeting goals, such as: • Reduced volume/frequency of overflow (#/yr) • Reduced floatables (e.g., tons/year collected) • Improved bacteria concentrations (E. coli) • Reduced beach closures (# season) • Restored habitat (length or acres) Post-Construction Compliance Monitoring

  10. A Post-Construction Compliance Monitoring Program Should… • Establish performance measures and metrics based on goals • Describe data/analysis required to assess performance • Provide plan for data collection/analysis (who, when, where, how often) • Identify compliance reporting products and schedule Post-Construction Compliance Monitoring

  11. Compliance Monitoring • Demonstration of compliance requires monitoring of CSO outfalls in simple systems or application of hydrologic/hydraulic models • Example permit language: The permittee shall discharge no more than an average of four overflow events per year not receiving minimum treatment. Post-Construction Compliance Monitoring

  12. CSO Event Frequency (Overflows per Year) Post-Construction Compliance Monitoring

  13. Site Specific Monitoring • Specific parameters are developed on a site specific basis related to WQ impairment and/or LTCP goals and objectives • Example permit language: The permittee shall monitor for E. coli and dissolved oxygen from April through October per the attached schedule. Post-Construction Compliance Monitoring

  14. Example Permit Condition:Site Specific Monitoring Post-Construction Compliance Monitoring

  15. Data Collection and Management Can include: • Physical observations and inspections of CSS (NMCs) • Flow measurement in CSS and at outfalls • Receiving water quality sampling • CSO operation and maintenance logs (NMC) • System and protocols for data management Post-Construction Compliance Monitoring

  16. Water Quality Surveys • Can include wet and dry weather surveys • Monitoring above, within and below CSO impacted areas Post-Construction Compliance Monitoring

  17. Weekly water quality monitoring station Wet weather survey station Example Receiving Water Monitoring Locations 17 Post-Construction Compliance Monitoring

  18. Challenges • Variations in rainfall • Year-to-year precipitation differences produce different CSS response • Monitored events are never identical to previously sampled conditions (duration/intensity of rainfall, land use, season, period since previous storm, etc.) • Isolation of CSO impacts • CSOs happen during wet weather at the same time as storm water discharges, SSOs, agricultural runoff, streambank erosion occur. Post-Construction Compliance Monitoring

  19. More Challenges • Wet weather monitoring is difficult • Access is often limited • Safety is an issue during high flows • Equipment is often unreliable • Expenses are great Post-Construction Compliance Monitoring

  20. Considerations • Phased nature of CSO implementation over 5, 10, 15+ years. • Pre-control or baseline information is needed to quantify improvement and benefit of CSO controls. • Monitoring parameters and frequency must align with water quality criteria: • Water quality criteria is monthly geomean <126 E. coli per 100 ml for recreation use • Geomean requires a minimum of 5 samples per month Post-Construction Compliance Monitoring

  21. Morgantown, WV LTCP Post-Construction Compliance Monitoring

  22. NYC Bacteria TrendInner Harbor (summer geomean) Post-Construction Compliance Monitoring

  23. DC Water and Sewer AuthorityProposed Post-Construction Compliance Monitoring • CSS and receiving water monitoring: • Phase 1. Following implementation of system rehab projects and upgrades (5-8 years) • Phase 2. Following completion of deep storage tunnels (10-30 years) • Phase 3. Recurring every 5 years after implementation of all controls Post-Construction Compliance Monitoring

  24. HUGUENOT BRIDGE - HB (RIVER SHORE & MID RIVER) (ABOVE CSO) S MAYOS BRIDGE NORTH AND SOUTH (MBN & MBS) ASH STREET (ASH) AND ANCARROW (ANC) SAMPLING STATIONS G FALL LINE SHOCKOE CSO OUTFALL SAMPLING LOCATION S JAMES RIVER W G GORDON AVE. CSO OUTFALL SAMPLING LOCATION RICHMOND WWTP BUOY 168 BUOY 166 JONES NECK BUOY 157 0 1 2 3 HENRICO COUNTY CSO Areas & Outfalls MILES SAMPLING LOCATION (TYP) HENRICO COUNTY BUOY 151 BUOY 146 JAMES RIVER CHESTERFIELD COUNTY CITY OF RICHMOND HENRICO COUNTY CSO AREA SHOCKOE BASIN WITHIN CSO AREA GORDON AVENUE WITHIN CSO AREA Richmond, VA – Post-Construction Monitoring Schematic

  25. Reporting • Consider annual report of some type: • NMC reporting • Reporting on rainfall and CSOs • Post-construction monitoring data • And consider making information available on the Internet Post-Construction Compliance Monitoring

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