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Sewage Bypasses and Overflows in 6500 Events Since 1997

Prepared by Katy Kintzele and Tom Neltner

Improving Kids’ Environment (IKE)
http://www.ikecoalition.org

Indiana Clean Water Coalition

July 10, 2002

Summary:

The Indiana Clean Water Coalition obtained a copy of a database developed by the Indiana Department of Environmental Management to log sanitary sewer overflows, dry-weather combined sewer overflows and wastewater treatment plant bypasses reported to IDEM in its Bypass & Overflow Incident Reporting Program. The database does not include wet-weather combined sewer overflows or discharges of fully-treated wastewater. These discharges are reported differently -- through monthly discharge monitoring reports and not as incidents.

Incidents are reported to IDEM by operators of facilities covered by a wastewater discharge permit known as a National Pollutant Discharge Elimination System (NPDES) permit pursuant to their permit requirements. While permit requirements vary, typically the operator calls IDEM within 24 hours and later submits a written incident report.

The database only contained incidents reported between January 1, 1997 and May 2, 2002. The vast majority of the incidents involved raw sewage or partially treated sewage from municipalities or sewage treatment utilities. The balance involved industrial or commercial facilities.

The results were shocking:

• 271 municipalities reported releases of more than 3.5 billion gallons of untreated and partially treated sewage in 6757 incidents from January 1, 1997 to May 2, 2002.
• The problem appears to be getting worse. From 2000 to 2001, the reported gallons released increased 67% and the number of reported incidents increased 31%. IDEM believes that part of the increase is due to more accurate and complete reporting.
• 45 municipalities and two private sewage treatment utilities reported more than 10 million gallons released during the 5.3–year period covered by the database. Two industrial facilities also exceeded 10 million gallons.
• Four cities contributed 36% of the total reported gallons released.
• The reported volume released from 13 cities and one private, sewage utility was more than 100 million gallons – representing 64% of the total reported gallons.
• One city – Indianapolis – contributed almost 10% of the total incidents from its two plants with an average of ten incidents per month.

The results raise doubts about IDEM's consistency and effectiveness in enforcing water quality and public health regulations. While many of these bypasses and overflows may be excused under the NPDES permit conditions if they are unavoidable and are properly reported, IDEM does not appear to take enforcement action when the events routinely occur or are not timely reported. In addition, several municipalities complained to the Coalition that they report more incidents and more gallons released because they are simply being more honest in their reporting. They suggest that some municipalities do not report many incidents that occur.

Instead of enforcing the NPDES permit requirements, IDEM appears to rely heavily on sewer connection bans and early warning notices to reduce bypasses and overflows. When the Coalition compared the reported bypass and overflow information to IDEM's implementation of the State's sewer connection ban and early warning notice regulation, it found inconsistencies that raise serious questions about the program. For example:

• More than half of the 47 sewage treatment facilities with more than 10 million gallons released since 1997 are or have been subject to a sewer connection ban or early warning notice.
• Of the 109 facilities that are currently subject to a sewer connection ban or early warning notice, 22 have not reported an incident since 1997. Yet, an IDEM report specifically notes that most of these facilities were listed because they were receiving or close to receiving too much flow to effectively treat the sewage. While a facility can be close to being hydraulic overloaded without having a bypass or overflow, it is unlikely that it never had an incident.

The Coalition has concluded that the data is crucial to understanding the overall performance of the sewage treatment plant and collection system. Any decisions regarding combined sewers, new sewer connections and plant upgrades must use this overflow / bypass event information to provide necessary context. IKE believes that IDEM is not considering this information when reviewing CSO Long-Term Control Plans.

Indiana Clean Water Coalition
Sewage in Our Streams Newsletter

• June 2002 Edition
• Full copy of the special report above

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 St. Joe Valley Greens, South Bend, IN