CSO Long Term Control Plan

Administrative Order for Compliance on Consent executed with the U.S. Environmental Protection Agency on September, 21, 2012.

On April 10, 2012, the City of Philadelphia and the U.S. Environmental Protection Agency signed a partnership agreement to recognize the Green City, Clean Waters plan and its approach to stormwater management.

Consent Order and Agreement executed with the Pennsylvania Department of Environmental Protection on June 1, 2011 for the implementation of the Philadelphia Water Department’s Combined Sewer Overflow Long Term Control Plan Update (Green City, Clean Waters Plan)

The following documents were submitted to the Pennsylvania Department of Environmental Protection as required by Appendix G of the Consent Order and Agreement.

The Implementation and Adaptive Management Plan (IAMP) was submitted to the PADEP by December 1, 2011. This plan provided the implementation framework for the Green City, Clean Waters program proposed in the LTCPU and its supplements. This plan described the programmatic elements that will be developed during the first five years of COA implementation.

The Green Stormwater Infrastructure (GSI) Maintenance Manual Development Process Plan was submitted to the PADEP by June 1, 2012. This plan describes the current green stormwater infrastructure maintenance program and provides an overview of the process to develop the GSI Maintenance Manual by June 1, 2014.

The Plant Identification Manual contains information needed to make informed decisions about plant selection for GSI projects. When choosing plants for a GSI project, the information in this manual can help narrow the choices down to the most appropriate plant for each location.

The Water Department’s Comprehensive Monitoring Plan was approved May 28, 2014. The plan was originally submitted on June 1, 2013 and revised January 10, 2014 to incorporate PWD’s responses to comments received from PADEP and USEPA. It is our initial plan for performing monitoring of natural and engineered systems associated with our Green City, Clean Waters program and addresses the monitoring and assessment of surface waters, groundwater, rainfall, CSO discharges, sewer flows, and green infrastructure performance.

The Facility Concept Plans for the three Water Pollution Control Plants (NE, SE, SW) were submitted to the PADEP by June 1, 2013. These plans describe the specific engineering and construction activities proposed to increase the maximum wet weather flow into each water pollution control plant facility and thereby increase the capture rate of combined sewage.The Northeast Facility Concept Plan was revised based on comments from PADEP and re-submitted on December 31, 2013.

The Wet Weather Facility Plan for the three Water Pollution Control Plants (NE, SE, SW) was submitted to the PADEP by June 1, 2016. This plan supersedes the Facility Concept Plans for all three Water Pollution Control Plants (WPCP) and provides details on scheduling, cost, and anticipated construction completion for each project listed in the Facility Concept Plans. An update on ongoing studies and new concepts being developed by Philadelphia Water Department to increase wet weather flow capacity in both the Collection System and the WPCPs are included.

The Updated Nine Minimum Controls Report was submitted to the PADEP by June 1, 2013. This report is an update to the 1995 “Implementation of Nine Minimum Controls” document and indicates how the City’s activities are being carried out currently, and highlight how these activities may have changed as a result of new technology, new practice, or other circumstances to address the CSO Nine Minimum Controls.

The Tributary Water Quality Model for Bacteria was submitted to the PADEP by June 1, 2013. This report describes the methods and results of a model that simulates bacteria concentrations in the nontidal reaches of Tacony/Frankford Creek and the Cobbs Creek that are affected by CSOs.

The Tributary Water Quality Model for Dissolved Oxygen was submitted to the PADEP by June 1, 2014. This report describes the methods and results of a receiving water quality model for Dissolved Oxygen (DO) in the nontidal extents of Tacony-Frankford Creek and Cobbs Creek. Extensive field monitoring data were used to develop and validate the model, which simulates existing DO conditions and underlying stream processes in the receiving waters.

The First Edition of the Green Infrastructure Maintenance Manual was submitted to the PADEP by June 1, 2014. The Manual describes the operation and maintenance of the full range of types of green stormwater infrastructure projects that have been, and that are proposed to be, implemented by the City as part of the CSO Program. The Manual is designed to be used by City agencies and anyone else who has responsibility for performing maintenance of green stormwater infrastructure. The Deliverable required by the Consent Order and Agreement should be considered the “first edition” of the Manual, since it is expected that the Manual will need to be updated periodically as the technology of green stormwater infrastructure advances, and as experience is gained with specific practices.

The GSI Maintenance Manual was submitted as a Green City, Clean Waters deliverable in June 2014 and was updated in 2016 to reflect lessons learned in the field and to provide a more user-friendly interface.

The Sanitary Sewer Evaluation Survey (SSES) Report was submitted to the PADEP by June 1, 2014. The report describes the results of analyses performed using the USEPA sanitary Sewer Overflow Analysis and Planning Toolbox on flow metering data collected in the areas of the city served by separate sanitary sewers. The primary goal of the SSES is to address I/I in the separate sewer areas tributary to the City’s water pollution control plants by quantifying and characterizing monitored wastewater flows. The results characterize the base wastewater flows, the groundwater infiltration, and the rainfall-derived infiltration and inflow conditions within these portions of the City.

The Tidal Waters Water Quality Model – Bacteria and Tidal Waters Water Quality Model – Dissolved Oxygen were submitted as one report to the PADEP by June 1, 2015. The report describes the methods, and provides the results, of a project to model the receiving water quality in the tidal Delaware River and the tidal Schuylkill River. Some errors and omissions identified by the authors after the publication of this report are corrected through an addendum posted to this location. As expected, those changes did not have a significant influence on the tidal water quality results described herein, and did not lead to any alteration of the conclusions reached in this report. The corrections address the inadvertent omission of the discharges from 12 combined sewer overflow points (of the 176) in the City (F04, F05, F06, F07, R18 in the Tacony-Frankford creeks basin; C19, C20, C21, C22 and C23 in the Cobbs Creek basin; and, P01 and P02 in the Pennypack Creek basin). In addition, some minor inadvertent anomalies occurred with respect to a small subset of municipal/industrial point source discharges, model boundary conditions, and minor stream/direct watershed inputs, as listed below. The updated report, with addendum, is available through the link below.

The Outlying Communities Report was submitted to the PADEP by June 1, 2015. The report describes the activities conducted by PWD to analyze, quantify and characterize the dry weather and wet weather flows conveyed from outlying community points of connection to the City’s combined and separate sewer systems.

The Year 5 Evaluation and Adaptation Plan was submitted to the PADEP by October 30, 2016. This plan represents the culmination of the first five years of program progress and includes an assessment of compliance with the Water Quality Based Effluent Limits (WQBEL) Performance Standards.

The Year 10 Evaluation and Adaptation Plan was submitted to the PADEP by May 30, 2022. This plan consists of a comprehensive assessment of program progress at the Year 10 milestone, including an assessment of compliance with Water Quality Based Effluent Limits (WQBEL) Performance Standards, an updated assessment of receiving water conditions, and descriptions of program elements expected to be implemented in the next five-year period.

Summary Report – amended June 1, 2011

On April 13^th, 2021, the Pennsylvania Department of Environmental Protection (PADEP) granted the Water Department a seven-month extension for the requirements and deliverables associated with the Year 10 Performance Standards of the Consent Order & Agreement due to impacts from the COVID-19 pandemic.