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Energy and Environment Cabinet

Division of Water

Division of Water
Requirements and expenses for cities with CSOs

What are federal and state requirements for cities with CSOs?

In 1994, the U.S. Environmental Protection Agency (EPA) adopted a Combined Sewer Overflow Control Policy designed to reduce and eliminate combined sewer overflows nationwide. The purpose of the CSO Control Policy was to elaborate on the 1989 EPA CSO Control Strategy and to facilitate compliance with Clean Water Act (CWA) requirements.

The three objectives of the 1989 CSO Control Strategy are:

  • Ensure that if CSOs occur, they are only as a result of wet weather.
  • Bring all wet weather CSO discharge points into compliance with the technology-based and water-quality-based requirements of the CWA.
  • Minimize the impacts of CSOs on water quality, aquatic biota and human health.

The goal of the CSO Control Policy is to:

  • Provide guidance to permittees with CSOs, to permitting and enforcement authorities of the National Pollutant Discharge Elimination System (NPDES) and to authorities of state water quality standards.
  • Ensure coordination among the appropriate parties in planning, selecting, designing and implementing CSO management practices and controls to meet the requirements of the CWA.
  • Ensure public involvement during the decision-making process.

In Kentucky, combined sewer systems exist in several municipalities, the majority of which are along the Ohio River. For this reason, Kentucky’s strategy incorporates not only the federal EPA strategy, but also that of the Ohio River Valley Water Sanitation Commission (ORSANCO).

Microsoft Powerpoint (.ppt) format presentations from the Sept. 13, 2005, CSO LTCP Workshop for small communities can also be viewed on this resource site. The one-day workshop was held in Fort Mitchell, Ky.

The Division of Water drafted a CSO permitting strategy in 1990 designed to complement the control programs for sanitary sewers and separate storm sewers. The strategy established a statewide approach to developing and issuing Kentucky Pollutant Discharge Elimination System (KPDES) permits for municipalities with CSOs. The Kentucky strategy adopted the objectives of the 1989 EPA CSO Control Strategy. In 1997, the Kentucky strategy was updated to incorporate the 1994 EPA CSO Control Policy. Also included in the 1997 Kentucky CSO Control Strategy is ORSANCO’s Strategy for Monitoring Impacts of Combined Sewer Overflows on the Ohio River.

Click here to view information about Kentucky's Combined Sewer Systems

The first major permit requirement for the Kentucky CSO communities was the submittal of a Combined Sewer Operational Plan (CSOP). The requirements of the CSOP are similar to the Nine Minimum Controls listed in the CSO Control Policy. Nine Minimum Controls implementation was to be completed before Jan. 1, 1997.  According to EPA, this is an enforceable deadline. Furthermore, the following additional requirements are part of approved CSOPs:

  • Coordination of the implementation of the community’s Flood Protection Program with the CSO Abatement Program to ensure any modification to ensure one program will not adversely affect the other.
  • Evaluations of alternatives with special consideration of environmentally sensitive areas, cost/benefit analysis and public participation to allow for effective prioritization of implementation of CSO controls. This evaluation of alternatives should be based on a comprehensive watershed management approach to include all point and nonpoint sources. The watershed management approach will necessitate the coordination of separate sanitary sewer, separate storm water and combined sewer programs to develop a comprehensive water management plan.
  • Establishment of an implementation schedule of CSO controls updated with the annual report submittal.

Annual reports are submitted to the Division of Water detailing implementation and updates to the CSOPs.

Will it be expensive to reduce and/or eliminate CSOs?

Useful CSO and related Web sites

For information on combined sewer overflows or sanitary sewer overflows, contact the Wet Weather Section, 502-564-3410.

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