EPA has released beta test versions of three tools that communities and permitting authorities can use to plan and manage different aspects of combined sewer overflow (CSO) programs.  These tools do not present new or changed requirements – instead, they help break down information in a more digestible and interactive fashion.  The tools released are:

• Long-Term Control Plan (LTCP) Review Checklist – This checklist is designed to help CSO permittees and NPDES authorities determine if LTCPs meet the requirements of the Clean Water Act (CWA) and the CSO Control Policy, and conform with EPA guidance on developing LTCPs.

• Post-Construction Compliance Monitoring (PCCM) Checklist – This checklist is designed to help CSO permittees and NPDES authorities develop and evaluate PCCM programs to meet the requirements of the CWA and the CSO Control Policy, and conform with EPA guidance on PCCM.

• Combined Sewer Overflow Model for Small Communities – This planning tool is for small CSO communities that want a reasonably simple approach to estimating a CSO occurrence, as well as treated or untreated CSO volume over a 24-hour period, and have limited resources to invest in more advanced CSO monitoring and modeling.

Each tool consists of an interactive spreadsheet, fact sheet or user guide, and two recorded trainings, with a third coming soon.  EPA is requesting suggestions on the tools via web form by December 31, 2022. 

NACWA asks its members to review the tools and submit comments, and the Association will also be reviewing these tools.  NACWA members with comments or questions about the tools should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.