Implementation Plan

Transcription

Implementation Plan

ALCOSAN Wet Weather Plan
Section 11 – Implementation Plan
11.0 IMPLEMENTATION PLAN
Executive Summary: This section details ALCOSAN’s plan for the successful delivery of the
Recommended 2026 Plan by September 30, 2026; and ALCOSAN’s adaptive management
strategy for the development of subsequent phased improvements.
ALCOSAN’s implementation schedule is outlined in Sub-Section 11.1. To meet this schedule
ALCOSAN is assuming that the final version of this WWP will be approved no later than
January 31, 2014. Along with the assumed WWP approval date, the implementation phase is
also dependent on another key milestone regarding municipal improvements. Per the
municipal orders, municipal feasibility studies must be submitted to the regulatory agencies by
July 2013. These studies are expected to establish firm and enforceable flow rate projections at
each ALCOSAN point of connection, and will be used by ALCOSAN to establish the basis of
design for all ALCOSAN improvements. The implementation schedule assumes that the
municipal feasibility studies will be approved by the Pennsylvania Department of
Environmental Protection and the Allegheny County Health Department no later than July 31st,
2014. As noted in Section 10.2, implementation of key complementary and WWTP early action
projects such as initial improvements to the Woods Run Wastewater Treatment Plant are
already underway.
Sub-Section 11.2 includes a brief summary of the current operation and maintenance plan and
how that plan will be updated as the Wet Weather Plan is implemented. A wet weather routing
plan is included, covering the bypassing of the secondary treatment process during some wet
weather events.
Sub-Section 11.3 describes ALCOSAN’s Interim and Post-Construction monitoring program. It
will support ALCOSAN’s evaluation of the effectiveness of the CSO and SSO control program
in achieving the performance targets established for the Recommended 2026 Plan. ALCOSAN
will expand upon prior monitoring programs to augment baseline data sets with information
collected before, during and after construction of facilities, including outfall activation
monitoring, in-stream water quality sampling, stream flow gauging and rainfall monitoring.
ALCOSAN will also use the hydrologic/hydraulic and water quality models to measure the
performance of the Program Elements detailed in Section 10. The results of these analyses will
be shared with the regulatory agencies, stakeholders and the general public.
ALCOSAN’s strategy for financing the implementation of the Recommended 2026 Plan and the
related municipal financing of municipal improvements are addressed in Section 11.4. The
Recommended 2026 Plan will result in $1.5 billion in new capital expenditures for ALCOSAN
and an additional $0.5 billion in expenditures for the municipalities. Accounting for inflation,
ALCOSAN and the municipalities will face capital expenditures of approximately $2.8 billion
through 2026. ALCOSAN anticipates using combinations of revenue bond financing owing to
ALCOSAN’s strength in the municipal bond market and pay-as-you-go funding utilizing
accumulated reserve funds. The financing of the municipal improvements is beyond the scope
of this document.
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The “affordability” of the Recommended 2026 Plan is detailed in Sub-Section 11.5, as measured
by the impacts on annual household wastewater costs and the financial capabilities of
ALCOSAN and the municipalities to finance the required wet weather controls. Preliminary
analysis by ALCOSAN has indicated that annual ALCOSAN rate increases ranging from 10% to
12% through the implementation of the Recommended Plan may be necessary.Wastewater costs
per household are evaluated under USEPA criteria through the “Residential Indicator” which
measures total annual wastewater costs as a percentage of median household income for a
permittee’s service area. Annual wastewater costs representing 2% or more of the median
household income are considered to impose a high burden.
At a regional level11-1, implementation of the Recommended 2026 Plan will result in a
Residential Indicator just over 2% (high burden) based on the median household income in the
ALCOSAN service area. By definition, half of the approximate 330,000 households have
incomes less than the median. ALCOSAN projects that around 100,000 households within the
service area will face wastewater service costs exceeding 2.5% of their incomes and that over
60,000 households could experience costs exceeding 3% of their household incomes. Section
11.5 provides a graphical representation of these projections.
At the municipal level11-2, the costs per household are projected to exceed 2% of median
household income in more than 200,000 households upon implementation of the Recommended
2026 Plan. For example, the Residential Indicator for the City of Pittsburgh is projected to be
2.3%. Note that these statistics include the estimated $530 million (current dollars) for
municipal system upgrades. An inter-municipal allocation of the $530 million, which could
materially affect the results for individual municipalities, has not occurred.
ALCOSAN’s legal and institutional capacities to implement the Recommended 2026 Plan are
evaluated in Sub-Section 11.6. While ALCOSAN has the requisite authority to build new
conveyance, storage and treatment facilities, their 2008 consent decree, Pennsylvania statute and
existing service contracts limit ALCOSAN’s ability to mandate or implement the reduction of
wet weather flows from the municipal collection systems through green infrastructure or other
source reduction strategies. Under their respective PaDEP or ACHD orders, the municipalities
are required to address municipal overflows and required conveyance capacities. ALCOSAN
expects that PaDEP and ACHD will enforce the design flow quantities and flow rates from the
municipalities that have served as the basis of ALCOSAN’s wet weather planning, and that will
be updated in the feasibility studies to serve as ALCOSAN’s final basis of design.
ALCOSAN is committing through this WWP to implement a multi-billion dollar public
investment program over a time period that spans decades and that will occur during climatic,
economic and demographic changes which are largely unknowable and uncontrollable. To deal
with these uncertainties, ALCOSAN will implement an Adaptive Management strategy as
described in Sub-Section 11.7. Additional regulatory requirements (e.g. future nutrient loading
requirements or municipal stormwater regulations) could increase costs, reduce affordability
and materially erode ALCOSAN’s ability to finance the proposed wet weather controls.
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Regional level meaning ALCOSAN costs plus service-area wide average municipal costs.
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Municipal level meaning ALCOSAN costs plus projected municipality specific costs.
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Revised water quality standards, as may emerge from USEPA’s 2012 draft recreational water
quality criteria, could change the environmental endpoint for which the WWP was developed.
Economic and demographic factors such as interest rates and population changes could also
erode, or conversely improve the affordability of future controls. At minimum, climate change
will potentially produce increased intense and atypical weather events that may defy long
established scientific knowledge bases. As conditions change, ALCOSAN program reviews
and adaptive management responses will be developed in coordination with the regulatory
agencies.
ALCOSAN is also setting forth a process for a Wet Weather Plan Update to be developed as the
facilities built under the 2026 Recommended Plan come on line and are evaluated. These
evaluations, coupled with the post-construction water quality monitoring results, will serve as
the basis for determining whether the remaining elements of the Selected Alternative remain
the best solution given then current conditions. The Plan Update will recommend the scope of
additional facilities necessary to control remaining overflows to achieve the full objectives of the
Clean Water Act and the National CSO Policy.
11.1
Implementation Schedule
This section describes the proposed implementation schedule and construction sequencing for
the Program Elements of the Recommended 2026 Plan as described in Section 10. The key
milestones, priorities and criteria used to develop the implementation schedule are
summarized; along with a description of several factors that can affect the implementation
schedule.
Along with the assumed WWP approval date, the implementation phase is also dependent on
another key milestone regarding municipal improvements. As described in Section 9.3, existing
municipal orders (COA or ACO) require the development of municipal feasibility studies to
evaluate alternatives for elimination of SSOs and control of CSOs from municipal sewer
systems. Municipal feasibility studies must be submitted to the regulatory agencies six months
after the submission of the ALCOSAN WWP. ALCOSAN expects that these studies will be
used by PaDEP and ACHD to establish firm and enforceable flow rate projections at each
ALCOSAN point of connection (POC). Such projections will be used by ALCOSAN to establish
the basis of design for all ALCOSAN improvements in the Recommended 2026 Plan and the
Selected Plan.
The implementation schedule assumes that the municipal feasibility studies will be approved
by PaDEP and ACHD no later than July 31st, 2014. The schedule also assumes that all necessary
supporting information from each approved municipal feasibility study (e.g. cost calculations,
models, etc.) will be supplied to ALCOSAN by the assumed date of feasibility study approval:
July 31, 2014.
11.1.1 Implementation Steps
Specific projects included in each Program Element in the implementation schedule will be
implemented through the following steps:
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Preliminary Design - This step in the implementation schedule includes the initial procurement
of engineering services to perform additional studies, field investigations and preliminary
engineering necessary for establishing the basis of design for the ALCOSAN facilities. (For
most projects, this step can begin once the municipal feasibility studies for each tributary POC
have been approved by PaDEP and ACHD, but some projects such as the WWTP expansion
may be able to proceed before that approval.) The studies and investigations anticipated under
this step may include topographic and right-of-way surveys, inspection of existing facilities,
geotechnical investigations, hydraulic analysis and modeling, utility mapping, site assessments
and sewer system evaluation surveys. Engineering plans and specifications will typically be
developed to 30 percent completion and will identify the basis of design parameters including
design criteria, equipment and material selection, preliminary layout plans and profiles,
summary of geotechnical recommendations, process and instrumentation diagrams,
preliminary coordination with utility companies and municipalities, public notification and
preliminary estimate of costs.
Land Acquisition, Permitting and Approvals - The acquisition of land where needed for new
facilities and issuance of permits and receipt of approvals from regulatory and municipal
agencies are shown to coincide with the design phase to allow bidding and construction to
commence following completion of design.
Final Design - Once the basis of design is established, final design includes the preparation of
plans, specifications and contract documents for bidding the projects. The design-bid-build
program delivery method is assumed for this implementation schedule.
Construction - The construction phase scheduling includes the public bidding and award of
construction contracts through completion of construction, performance testing, acceptance and
initiation of operation of new facilities.
11.1.2 Description of Schedule
Figure 11-1 shows the implementation schedule of capital improvements in the Recommended
2026 Plan. These projects are identified by the Program Elements defined in Section 10 and
scheduling is shown in years following the assumed approval date of the WWP (January 31,
2014).
Woods Run WWTP Early Action Projects – Early action projects as described in Section 10.2 are
not included in Figure 11-1 as they are independent of the WWP approval and many are
included in the current ALCOSAN capital improvements program.
Woods Run WWTP Expansion – The Recommended 2026 Plan focuses on capture of overflows
and conveyance to the WWTP for treatment. A priority is also given to the proposed plant
expansion to 480 mgd (wet weather peak flow treatment capacity) as described in Section 10.3.
The WWTP must be operational prior to tie in of the regional tunnel.
Tunnel Dewatering Pump Station – The new pump station as described in Section 10.4 is the
link between the regional tunnel and the WWTP and must be completed prior to initiating
operation of any portion of the regional tunnel. Thus, the construction sequence shows
completing the Tunnel Dewatering Pump Station as well as the Ohio River Segment and
Facilities concurrent with the Woods Run WWTP expansion.
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Figure 11-1: Capital Projects Implementation Schedule for the Recommended 2026 Plan
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Ohio River Segment and Facilities - This segment of the regional tunnel begins at a junction
shaft near ALCOSAN structure O-39 and continues downstream to a junction shaft at the
WWTP as described in Section 10.5. The proposed construction sequence coordinates
completion of the Ohio River Segment and associated consolidation sewers with the Tunnel
Dewatering Pump Station and the WWTP expansion.
Allegheny River Segment and Facilities – As described in Section 10.6 this segment of the
regional tunnel extends from a shaft near ALCOSAN Structure A-22 and continues downstream
to a junction shaft near ALCOSAN structure O-39. Construction on this segment of the tunnel
and associated consolidation sewers will start once the tunneling portion of the Ohio River
Segment is complete.
Monongahela River Segment and Facilities – This segment of the regional tunnel begins at a
shaft near ALCOSAN structure M-29 and continues downstream to a junction shaft near
ALCOSAN structure O-39 as described in Section 10.7. Construction of this portion of the
tunnel and associated consolidation sewers will start once the tunneling portion of the
Allegheny River Segment is complete.
The conceptual schedule and construction sequence for the Tunnel Dewatering Pump Station
and the three regional tunnel segments described above are based on the following assumptions
and criteria:

The regional tunnel and facilities are shown to be constructed sequentially starting with
the Ohio River Segment, followed by the Allegheny River Segment and then the
Monongahela River Segment. This sequential approach will facilitate competitive
bidding, improve quality management and provide opportunities for adaptive
management of final design and construction.

As each segment is completed it will be placed in operation assuming the Woods Run
WWTP expansion and Tunnel Dewatering Pump Station are complete and operational.

Preliminary design of the regional tunnel system and dewatering pump station will be
performed concurrently to establish a uniform basis of design.

Final design work for each segment is shown to be staggered with the construction
phases. This sequence provides adaptive management opportunities for final design as
noted above.
Chartiers Creek Conveyance and Facilities – The Chartiers Creek projects focus on the control
of SSOs in the planning basin, and control of selected CSOs upstream of POC C-23 in order to
achieve the goal of not precluding the attainment of water quality standards, as described in
Section 10.8. At the downstream end of the new relief interceptor, dry weather flows will be
pumped into the existing interceptor. In wet weather, excess combined sewage that cannot be
conveyed to the WWTP via the existing interceptor will be pumped into the RTB for treatment
before discharging to Chartiers Creek. This work is independent of the regional tunnel
construction and can commence when the design flows are established based on ALCOSAN’s
receipt and review of the approved municipal feasibility studies.
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The Pennsylvania Environmental Defense Fund (PEDF) consent decree requires all ALCOSAN
SSOs to Chartiers Creek to be eliminated by 2019. The capital improvements in the
Recommended 2026 Plan will comply with the SSO removal requirement, however, due to the
extensive relief sewer construction required it cannot be completed by 2019. Multiple
concurrent construction contracts will be needed just to complete it by the 2026 CD milestone.
Municipal Improvements – The implementation schedule also includes another program
element for the municipal improvements. These improvements will be implemented by others
and are not part of ALCOSAN’s responsibility under the Wet Weather Plan, but are included
for reference purposes. Design and construction of municipal improvements are expected to
parallel the implementation schedule for ALCOSAN capital improvements.
11.1.3
Schedule Factors
The foundation for the implementation schedule presented in this section is the Recommended
2026 Plan described in Section 10. Recognizing the implementation schedule is for planning
purposes, unexpected events and uncertainties will require that this schedule be adjusted
accordingly. The following list summarizes a range of uncertainties that may affect the
implementation schedule:

Changes to the Clean Water Act, National CSO policy; US EPA or PADEP rules,
regulations, or water quality standards

Changes to ALCOSAN’s NPDES permits

Future judicial or administrative orders

Timing of land acquisition, permits and approvals for construction

Findings of preliminary design

Escalation of costs

Fluctuation of labor and material markets

Unforeseen construction issues

Changes to funding capacities and mechanisms indicated in the WWP financial
assessments

Changes to the assumed municipal improvements could require modifications to
particular components of the WWP.
Throughout implementation of the WWP, the schedule will be monitored and adjusted through
periodic reviews to incorporate new data and assess impacts on all steps of the capital
improvements. This is further described in Section 11.7: Adaptive Management.
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11.2 Operation and Maintenance
ALCOSAN has a comprehensive operation and maintenance (O&M) program to ensure
consistent and reliable operation of the existing collection and treatment system. This program
has been documented as complying with the CSO policy requirements for Nine Minimum
Controls and numerous other Consent Decree requirements that go beyond the Policy. This
subsection briefly summarizes the current O&M program and how that program will be
updated as the Wet Weather Plan is implemented. In addition, since the WWP includes a
proposed bypass of the secondary treatment process during some wet weather events, this
subsection describes the required wet weather routing plan for future operation with the
bypass.
11.2.1 Current Operation and Maintenance Program
ALCOSAN’s current O&M program consists of the following:
Operation & Maintenance Manuals – In accordance with paragraph 8 of Appendix I of the
consent decree, ALCOSAN maintains two libraries at its treatment plant as central locations for
current O&M manuals for equipment considered critical to its operations, including operation
of the main sewage pumps and other pumps. In addition, manuals regarding specific pump
operations are available at ALCOSAN’s remote pump stations. The manuals are catalogued in
a computerized data base to provide ready access and location information. For new
equipment, vendors must supply operating instructions, a maintenance summary, description
and frequency of maintenance activity, lubricant list, and recommended spare parts. ALCOSAN
has a procedure for cataloging and disseminating these manuals to the two on-site libraries and
other appropriate locations. In addition, as new equipment is acquired, procedures are in place
to add data to ALCOSAN’s computerized maintenance management database and to place
recommended spare parts into inventory.
MP-2 Automated Operation and Maintenance Management System - The MP-2® system is an
automated O&M management system that develops work orders, documents and archives field
maintenance activities, and produces reports for managerial staff. The primary use of the
system is to schedule and manage preventive maintenance activities and ensure that complaints
and needs observed in the field are resolved in a timely manner. Observed conditions,
problems and corrective actions at critical facilities in the ALCOSAN conveyance system are
documented and entered into the O&M database using an automated bar-code system known
as the Dolphin® System. Automated preventive maintenance reports for ALCOSAN facilities
are generated by the MP-2 system on a trimester basis in January, May and September. Both the
MP-2 and Dolphin O&M database systems are used to prepare monthly, quarterly, semiannual
and annual reports for regulatory agency review and compliance. The system also is used to
conduct trending analyses for key operational parameters of the system, including the
frequency, duration and volume of overflows.
Revised Nine Minimum Control Plan – ALCOSAN submitted the Revised Nine Minimum
Control Plan on February 17, 2009. The most recent agency review comments were received in
June, 2011. ALCOSAN responded to all agency comments in July, 2011 but a formal approval
of the Plan has not been received from the agencies. The Plan describes ALCOSAN’s
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implementation of the Nine Minimum Controls (NMC) in accordance with USEPA guidance
documents. ALCOSAN continues to employ the NMC practices documented in this Plan.
Sewage Treatment Plant Wet Weather Operating Plan – ALCOSAN’s Wet Weather Flow
Sewage Treatment Plant Operating Plan was approved by US EPA in its letter of February 2,
2009, and a revised Operating Plan was approved by US EPA in its letter of June 11, 2009. This
Plan documents ALCOSAN’s compliance with paragraphs 23 (Operation of Plant Influent
Pumps) and 24 (Sewage Treatment Operating Plan) of the Consent Decree. The Operating Plan
is not intended to be an explanation of ALCOSAN’s wastewater treatment process, but rather is
focused on the operating plan to be used before, during and after wet weather flow events. The
Operating Plan considers wet weather flow events to be events that increase flows to and
through the regional conveyance system such as rainstorms or snow melt. ALCOSAN’s
Operating Plan also addresses responses at the treatment plant necessary during those periods
in which the Ohio River elevation rises through the various flood stages, referred to in the
Operating Plan as river elevation events.
11.2.2 Operation and Maintenance Program Updates for Wet Weather Plan
As required by the Consent Decree, ALCOSAN will prepare annual updates to the current
O&M program to incorporate any new facilities which are part of the Recommended 2026 Plan
that have been placed into operation in the preceding year. The annual updates will begin after
the first proposed facilities from the Recommended 2026 Plan are constructed and placed into
operation, and will follow a two step process:
Step 1: Proposed Operation and Maintenance Practices – In the first quarter of each year,
ALCOSAN will submit to EPA and PADEP, for review and comment, the proposed best
management practices for the O&M of each facility that is placed into operation for the first
time in the prior year. The facilities are expected to be placed into operation in accordance with
the sequence shown in the implementation schedule presented in Section 11.1.
Step 2: Operation and Maintenance Program Updates – Upon approval by EPA and PADEP,
ALCOSAN will incorporate the proposed best management practices into each affected portion
of the current O&M program which is described in Section 11.2.1.
11.2.3 Wet Weather Routing Plan
Since the proposed expansion of the Woods Run WWTP includes a bypass of secondary
treatment during wet weather, the CD requires a Bypass Demonstration in accordance with
Appendix T and a Wet Weather Routing Plan in accordance with Paragraph 62 to be included
in the WWP. Section 9.2.5 summarizes the Bypass Demonstration for the WWTP in compliance
with Appendix T and the Wet Weather Routing Plan is presented below.
The anticipated specific actions for wet weather operation of the WWTP at up to 480 mgd under
the Recommended 2026 Plan are as described below. This preliminary plan is subject to
refinement during the design phase of the WWP implementation:
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Prior to Wet Weather Event
1. Inspect and verify raw sewage pumps in the Main Pumping Station are ready and setup for wet weather operation with pump discharges appropriately aligned to existing
headworks and wet weather headworks.
2. Inspect and verify Tunnel Dewatering Pump Station is ready for service.
3. Prepare additional screening and grit removal process trains for wet weather operation;
pre-fill screening channels and grit tanks and initiate operation.
4. Prepare primary sedimentation tanks for wet weather operation; pre-fill tanks and
initiate operation. Verify sludge blankets in the primary sedimentation tanks are low;
pump down sludge blankets if necessary. Separate waste activated sludge thickening
facilities are proposed as part of the capital improvements so that co-settling of primary
and waste activated sludge in the primary sedimentation tanks (current practice) is not
performed during wet weather.
5. Verify wet weather disinfection process is ready for service and pre-fill chlorine contact
tank if necessary.
6. Verify adequate number of aeration basins and final settling tanks are in service for
operation at 295 mgd and similarly verify adequate secondary effluent disinfection is
ready.
During Wet Weather Event
1. Operation of the Main Pumping Station and Tunnel Dewatering Pumping Station will
be automatically controlled based on water levels in their respective wet wells and flow
monitoring feedback from the WWTP through the plant wide distributed control
system. The Main Pumping Station may be able to handle small storms without
activating the Tunnel Dewatering Pump Station. The sequence of operation of the pump
stations will be developed as the controls for the regional tunnel system are further
defined during design. The maximum wet weather flow pumped to the WWTP is 480
mgd under the Recommended 2026 Plan with up to 120 mgd of this flow coming from
the Tunnel Dewatering Pump Station.
2. As wet weather flow exceeds 295 mgd the secondary bypass will be initiated along with
the wet weather disinfection process. Automatic flow controls will maintain flow to
secondary treatment at 295 mgd throughout the wet weather event. Operational
experience will determine optimum process operating conditions for the aeration basins
and final settling tanks (i.e., return ratios, wasting rates and sludge blankets) during wet
weather conditions.
3. Operators will monitor treatment processes by field inspection and the distributed
control system to verify proper operation or identify problems and take corrective
action.
4. Automatic sampling and instrumentation will provide continuous feedback on chlorine
residual in the wet weather disinfection process and adjust chemical dosing as necessary
and provide samples for laboratory analysis of discharge quality.
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5. The maximum peak flow rate into the plant during wet weather will be 480 mgd as
maintained through pump speed controls in the Main Pumping Station and Tunnel
Dewatering Pump Station and flow monitoring in the WWTP.
After the Storm Event
1. The Tunnel Dewatering Pump Station will remain in operation at a flow rate of up to
120 mgd until the regional tunnel has been dewatered.
2. As the plant influent flow subsequently drops below 295 mgd the secondary bypass and
wet weather disinfection processes will be stopped and all flow will be directed to
secondary treatment.
3. The plant will remain operationally ready for wet weather operation until it is
determined the storm system has cleared and there are no additional storms anticipated.
4. Dry weather operation will be restored by sequentially taking process units out-of
service. Draining and cleaning operations will be sequenced to avoid excessive recycle
flow and loadings on the WWTP.
The Wet Weather Routing Plan for operation of the WWTP at 600 mgd peak treatment capacity
under the Selected Plan is essentially the same as the Recommended 2026 Plan described above.
Additional pumping, headworks and primary treatment process units are placed in-service for
wet weather operation up to 600 mgd. The additional operational and maintenance measures
required following the WWTP expansion will be integrated into the existing O&M procedures
described in Section 11.2.1.
The size of the storm event and the resulting variation of wet weather flows to the WWTP do
not change the basic wet weather operating strategy to maximize full secondary treatment of
flow up to the proposed capacity of 295 mgd. The key factors for successful operation of the
WWTP during storm events are the preparation of process units and the transition into
secondary bypass when flows exceed 295 mgd.
The preparation element refers to those actions noted above as Prior to Wet Weather Event with
the objective to have sufficient treatment process units in-service, or on ready standby. Smaller
storms may allow for fewer process units to be placed in-service as future operating experience
reveals.
The transition into wet weather operation at the WWTP via the initiation of a secondary bypass
for flows above 295 mgd is a function of sequencing the diversion of primary effluent to wet
weather disinfection facilities. Although the detailed transition procedures will be refined
during design, the operating concept is the rate of flow entering the plant will ramped up to 295
mgd via control of the raw sewage pumping rate and held until the bypass control gate located
at the west end of the primary effluent channel is opened and the wet weather chlorine contact
tank is placed in operation. The wet weather chlorination/dechlorination disinfection process
will be designed via automatic chemical feed controls to respond to variations in wet weather
flow based on flow monitoring and chlorine residual monitoring instrumentation.
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The regional tunnel system will provide sufficient flow storage capacity to allow for initiation of
wet weather operation at the WWTP. This will be accomplished through cross connections
between the existing interceptor tunnels and the new regional tunnel. These cross connections
will provide select points of relief as the hydraulic grade line in the existing interceptor tunnels
rises above hydraulic control elevations.
Section L (Paragraphs 62.c and 62.d) of the CD requires an estimated reduction in BOD and TSS
that ALCOSAN shall achieve upon implementation of the Wet Weather Routing Plan and to
propose a date when such percent reductions shall become enforceable under the CD. Two
methods were employed to evaluate performance criteria for the proposed Wet Weather
Routing Plan; primary stress testing and water quality modeling, as presented below.
Primary Stress Testing - As described in Sections 9.2.1 and 9.2.2, ALCOSAN performed full
scale stress testing of the primary treatment process to evaluate hydraulic capacity and evaluate
process performance at the proposed high rate operation during wet weather. The stress testing
program provided a unique opportunity to obtain primary treatment process performance data
without the influence of WAS co-settling. The proposed Wet Weather Routing Plan eliminates
the current practice of co-settling in the primary tanks and separately handles WAS through a
new mechanical thickening process prior to dewatering and disposal. This testing concluded
that the primary sedimentation tanks have a unit hydraulic (peak flow) capacity of 60 mgd
which corresponds to a peak surface overflow rate of 3,100 gpd/ft2. Under stress testing
conditions, the primary treatment process exhibited average daily BOD removals during dry
and wet weather periods of 50% and 44%, respectively; and average daily TSS removals of 68%
and 61% during dry and wet weather, respectively. The TSS and BOD percent removals were
subject to wide fluctuations resulting from the variation in wet weather duration and influent
concentrations. However, it was observed the primary effluent TSS and BOD concentrations
were less subject to fluctuations and remained approximately 50 mg/L during dry and wet
weather conditions.
An analysis was performed of the predicted discharge characteristics using the typical year flow
model and the proposed Woods Run WWTP expansion to 600 mgd peak flow capacity under
the Selected Plan. The combined effluent quality of flows receiving full treatment and flows
bypassing secondary treatment during wet weather resulted in TSS and BOD mass loadings
and discharge concentrations below the current NPDES monthly maximum, weekly maximum
and instantaneous maximum limits for the plant. The facility was also predicted to maintain a
monthly overall TSS and BOD removal of 85% or greater.
Water Quality Modeling - Using the water quality model developed for the Selected Plan an
hourly time series of plant flow and influent TSS and BOD concentrations was prepared for the
typical year rainfall pattern including future base flows. From this model an analysis was
conducted to determine the effects of primary treatment process performance (i.e., percent TSS
and BOD removals) on the overall performance and quality of the plant discharges. This
analysis assumed, based on historical data, that the plant effluent receiving secondary treatment
has BOD and TSS concentrations at or below 10 mg/L and 15 mg/L TSS, respectively. The
percent removals in the primary treatment process were varied to determine the lowest
allowable percent BOD and TSS removals to maintain monthly average overall removals above
85 percent, as required in the NPDES permit. The analysis indicates the primary treatment
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process needs to achieve at least 25% BOD reduction and 60% TSS reduction to maintain above
85% TSS and BOD monthly average removals during the typical year.
Of the two performance-evaluation methods described above the water quality modeling
defines the lowest percent BOD and TSS removals necessary to maintain NPDES permit
compliance. However, it must be noted that these criteria specifically apply to the typical year
and do not address variations in annual rainfall conditions. For example, during years with
higher rainfall than the typical year the wastewater entering the WWTP will have lower
pollutant strength, which will result in lower percent removal while simultaneously meeting
discharge concentrations and mass loading criteria. Thus, enforceable percent removal criteria
must also account for variations in annual rainfall.
It is concluded that percent removals are not the most appropriate metrics to enforce
performance criteria. Rather it is suggested that the current NPDES discharges limits for
concentration and mass loadings of the combined discharges from secondary treatment and
secondary bypasses remain the future enforcement criteria under the CD and future NPDES
permit renewals.
Allowing one year for collection of WWTP performance data after the expanded plant is placed
into operation, the anticipated date by which final performance criteria can be established,
either as percent removals or limiting concentrations, is one year after the initiation of
operation of the expanded plant. In order for the expanded plant to be placed into operation,
the plant expansion must be completed and the first regional tunnel segment and points of
connection must be completed and placed into operation. Based on the implementation
schedule presented in Section 11.1 for the Recommended 2026 Plan, the above activities
required to initiate plant operation would be completed approximately nine years following
approval of the WWP.
11.2.4 Staffing
In developing the Wet Weather Plan, ALCOSAN has prepared preliminary estimates of O&M
costs – including labor – for purposes of evaluating and comparing various wet weather control
alternatives. The actual level of staffing for O&M will be determined during the
implementation of the program and gradually increased as the proposed facilities are
constructed and placed into service. Operator experience gained with the first new facilities
placed into service will refine the staffing plans for later facilities. At a minimum, O&M
staffing will be reviewed annually as part of the annual budget process.
11- 14
11.3 Interim and Post-Construction Monitoring Plan
11.3.1 Introduction
The primary objective of the Interim and Post-Construction Monitoring Plan (IPCMP) is to
demonstrate, via H&H monitoring and modeling of the constructed improvements and
facilities, that performance criterion, as noted below, are met upon completion of the 2026 Plan.
This section discusses the methods and tasks to achieve this objective.
For the long term (beyond 2026), the objective is to demonstrate, via receiving water quality
monitoring and modeling, that ALCOSAN CSO discharges; do not cause or contribute to nonattainment of water quality standards, are sufficient to ensure compliance with ALCOSAN’s
then-current NPDES permit and additionally to demonstrate, via H&H monitoring and
modeling of constructed improvements and facilities, that long term performance criterion are
met. This section does not discuss the monitoring and modeling required for the IPCMP
beyond the 2026 Recommended Plan.
Regulatory Requirements: U.S.EPA requires CSO communities to conduct a post-construction
monitoring program during and after WWP implementation “to help determine the
effectiveness of the overall program in meeting Clean Water Act requirements and achieving
local water quality goals 11-3.” The program should collect data that measure the effectiveness of
CSO controls and their impact on water quality, and should utilize existing monitoring stations
used in previous studies of the waterways and sewer system in order to compare results to
conditions before controls were put in place. The program should include a map of monitoring
stations, a record of sampling frequency at each station, a list of data to be collected, and a
quality assurance/quality control (QA/QC) plan.
In U.S.EPA’s December 2001 Report to Congress: Implementation and Enforcement of the
Combined Sewer Overflow Control Policy, the Agency noted the difficulty of establishing a
monitoring and tracking program for CSO control programs. “Monitoring programs need to be
targeted and implemented in a consistent manner from year to year to be able to establish precontrol baseline conditions and to identify meaningful trends over time as CSO controls are
implemented,” the report said. “In practice, it is often difficult, and in some instances
impossible, to link environmental conditions or results to a single source of pollution, such as
CSOs. In most instances, water quality is impacted by multiple sources, and trends over time
reflect the change in loadings on a watershed scale from a variety of environmental programs.”
The report also noted that weather conditions and rainfall totals vary significantly from storm
to storm and year to year, making comparisons difficult.
The proposed IPCMP recognizes these challenges and limitations of a monitoring program and
will utilize updated H&H Models, supplemented by an ongoing monitoring program, to
determine if performance measures are achieved.
11‐3 Combined Sewer Overflows, Guidance for Long-Term Control Plan (EPA 832-B-95-002, August 1995),
p. 4-15.
11- 15
Purpose and Scope: The IPCMP will collect data needed to determine whether CSO control
measures have met the required Performance Criteria and to document stream improvements
that can be attributed to implementation of CSO control measures by ALCOSAN.
As part of the planning and development of the WWP, ALCOSAN developed and calibrated a
H&H Model of the collection system. This model was then used to document the baseline CSO
characteristics. ALCOSAN also completed a comprehensive receiving water assessment
documenting water quality conditions in major CSO-impacted receiving streams. This
assessment established baseline conditions for in-stream water quality data, as documented in
Section 5.4.
The monitoring program has been developed based upon the following scope of work:

Execute Interim Monitoring: Based on the receiving water assessments, ALCOSAN
identified bacteria as the primary pollutant of concern. ALCOSAN will use fecal
coliform and E. coli bacteria to monitor interim baseline water quality during the
construction and implementation of long term CSO control measures on receiving
streams.

Prepare 2024 Update to the Post-Construction Monitoring Plan: Utilizing information
gained during interim water quality monitoring and the construction and
implementation of the CSO control measures, the Post-Construction Monitoring Plan
will be revised as necessary to better evaluate the established Performance Criteria.

Prepare and Execute Post-Construction Monitoring: The collection system post
construction monitoring program will determine whether CSO control measures are
performing as proposed to meet its Performance Criteria. The program will also
identify how ALCOSAN will collect data needed to document receiving waters
improvements achieved through implementation of these control measures.

Report results to State and Federal Agencies: The results of the IPCMP will be reported
to the U.S. EPA and PaDEP. Upon completion of all interim and post-construction
monitoring, ALCOSAN will prepare a Final Post-Construction Monitoring Report that
evaluates whether the constructed projects have achieved the desired results. The
following sections present ALCOSAN’s approach for tracking and reporting on the
achievement of Performance Criteria.
11.3.2 Program Elements
Performance Criteria: Performance Criteria are those used to assess the performance of
controls so as to determine whether or not they are meeting the Wet Weather Plan goals. For
the 2026 Wet Weather Plan (WWP) ALCOSAN has three performance criteria.
1. Reduction of untreated ALCOSAN CSO volume to 4,000 MG/year in a typical year
2. Control ALCOSAN CSOs near Sensitive Areas to zero or one overflows in a typical year,
depending upon the specific outfall
3. Control of ALCOSAN SSOs in the Chartiers Creek basin to a long term average of one
overflow every 2 years.
11- 16
ALCOSAN will carry out the evaluation of performance criteria by collecting precipitation and
flow monitoring data beginning 12 months following the implementation and successful
operation of all SSO and CSO control measures. ALCOSAN will update and validate the H&H
model prepared during development of the WWP using the collected monitoring data. The
models will then be used to generate appropriate simulations demonstrating “typical year”
compliance with the Performance Criteria in terms of CSO and 1 overflow every 2-year by
continuous simulation or design storm for SSO performance.
Receiving Water Quality Measures: Water Quality Measures are those used to assess
improvements in water quality of receiving streams due to implementation of wet weather
overflow control measures. ALCOSAN will use bacteria (fecal coliform and E. coli) as its water
quality measure. ALCOSAN will collect data to measure and evaluate improvements to instream bacteria counts that can be attributed to wet weather overflow control measures. CSO
and SSO controls alone will not result in attainment of bacteria standards for water contact
recreation due to numerous bacteria sources in the environment. Therefore, there are no
performance criteria for bacteria as a water quality measure for the 2026 WWP. Instead,
ALCOSAN will analyze trends in both dry and wet-weather bacteria values and compare them
to historic monitoring data and modeling predictions to determine improvement in water
quality.
11.3.3 Interim and Post-Construction Monitoring and Data Collection
CSO Outfall Monitoring: During post-construction monitoring for the 2026 Plan, selected
ALCOSAN CSO outfalls will be monitored for activations after each wet weather event.
Approximately 20 outfalls will be monitored for activation for one year. Outfalls will be
monitored either with a recording depth meter or marked with chalk and a fishing bobber
placed in the overflow opening. If the chalk is washed away and the bobber has been
dislodged, an overflow event will assume to have occurred. CSO outfall locations will be
determined and documented in the 2024 PCMP update.
SSO Outfall Monitoring: SSO outfalls will continue to be monitored during the interim and
post-construction period for activations consistent with Appendix L Section 1c of the CD using
a bobber/chalk method. Selected SSO monitoring locations within the ALCOSAN service area,
together with their monitoring rationale, monitoring frequency, and monitoring protocols are
presented in Table 11-1. These SSO outfall locations are shown on Figure 11-2.
Collection System Monitoring: Flow monitoring is currently being conducted at 15 shallow
cut interceptor locations and HGL levels are being monitored at 10 locations in the existing deep
interceptors. These monitoring locations will continue to be operated and maintained. In
addition, four depth monitors will be located in the new deep tunnel and two flow monitors on
the relief interceptor for Chartiers Creek.
11- 17
Table 11-1: List SSO Outfall Monitoring Locations
Location Description
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
A-45
Fairview Avenue (Verona
Borough)
Allegheny
River
Monitoring
of SSO
Activation
Continuous
Bobber/
Chalk
A-82
First Street (Blawnox
Borough)
Allegheny
River
Monitoring
of SSO
Activation Continuous
Bobber/
Chalk
A-85
Powers Run (O'Hara
Township)
Allegheny
River
Monitoring
of SSO
Bobber/
Chalk /
C-21
L.B., end of Thornburg Sewer
opposite Crafton Borough
Sewer (Thornburg Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-26
L.B. rear of Columbia Steel &
Shafting Co, Foot of Arch St.
ext (Rosslyn Farms Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk /
C-33
Vine Street (Carnegie
Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-38B
Left Bank, at foot of Barrett
Way (Carnegie Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk /
C-42
Right Bank, foot of Center
Way (Scott Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-45
RB, approximately 30 ft. U/S
of West Main St. highway
bridge (Scott Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk /
C-45A
L.B., landward side of RR
Culvert, approx 550 ft. U/S of
highway bridge (Carnegie
Borough)
Chartiers
Creek
Continuous
Bobber/
Chalk
C-46
Left Bank, end of Grant
Avenue near RR Bridge
(Heidelberg Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk /
C-47
R.B., across creek from
American Steel Band
Company (Scott Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-48
R.B., approx 30 ft. D/S of
East Railroad St. Highway
Bridge (Scott Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk /
Site ID
11- 18
Monitoring
of SSO
Activation ALCOSAN Wet Weather Plan
Site ID
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
C-49
Collier St. Highway Bridge
(Scott Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-50
L.B., approx 750 ft. D/S of
Woodville Rd. Highway
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-50A
Woodville Rd. Highway
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-50B
R.B., approx 1400 ft.
upstream of P.C.Y. RR
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-52
L.B., approx 100 ft. D/S of
P.C.C. & St. L. RR Bridge
(Collier Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-53
Approx 100 ft. D/S of mouth
of Painters Run (Scott
Township)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-54
Right bank, mouth of
McLaughlin’s Run (Bridgeville
Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
C-55
Pgh. W. Va. RR Bridge
(Bridgeville Borough)
Chartiers
Creek
Monitoring
of SSO
Bobber/
Chalk
O-15
O-15 Outfall structure
(Emsworth Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-16
Western Avenue (Ben Avon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-17
Irwin Avenue (Ben Avon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-18
Spruce Run (Ben Avon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-18y
Cliff Street lateral (Ben Avon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
11- 19
Site ID
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
O-18z
Ridge Ave. lateral (Ben Avon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-19
Birmingham Avenue (Avalon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-20
Elizabeth Avenue (Avalon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-21
West Street (Avalon
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-22
Meade Avenue (Bellevue
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-23
South Fremont Avenue
(Bellevue Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
O-24
Shiloh Avenue (Bellevue
Borough)
Ohio River
Monitoring
of SSO
Bobber/
Chalk
SMR.CS-14
Interceptor Relief at Grove
Road (Castle Shannon
Borough)
Saw Mill
Run
Monitoring
of SSO
Bobber/
Chalk
SMR.CS-50
Interceptor Relief at Smith St.
(Castle Shannon Borough)
Saw Mill
Run
Monitoring
of SSO
Bobber/
Chalk
SMR.CS-53
Interceptor Relief at Connor
Rd. (Castle Shannon
Borough)
Saw Mill
Run
Monitoring
of SSO
Bobber/
Chalk
T-08
L.B. Turtle Creek approx 300
ft. D/S from mouth of
Thompson Run (North
Versailles Township)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-18
Left bank under Viaduct
(Wilmerding Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-25
Left bank approx 400 ft.
downstream of Wall Bridge
(North Versailles Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
11- 20
Site ID
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
T-26A
Moss Side Boulevard
(Municipality of Monroeville)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-26B
S. Pitcairn connection for
Monroeville Boro, just D/S of
Bridge going to Pitcairn RR
yards (Monroeville)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-27
Left bank under PitcairnTrafford Road Viaduct
(Trafford Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-29
Left bank approx 600 ft. D/S
of Firth Sterling Company
fence (Trafford Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-29A
Left bank approx 200 ft. D/S
of Firth Sterling Company
fence (Trafford Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-31
Right bank Brush Creek
approx 250 ft. D/S from PA
RR Bridge (Trafford
Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-32
Right bank Brush Creek
approx 90 ft. upstream of PA
RR Bridge (Trafford Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
T-33
R.B. Brush Creek & Maple
Street (Trafford Borough)
Turtle Creek
Monitoring
of SSO
Bobber/
Chalk
TR-03
Larimar Ave. (Wilkins
Township)
Thompson
Run
Monitoring
of SSO
Bobber/
Chalk
TR-04
Chalfant Run Culvert
(Wilkins Township)
Thompson
Run
Monitoring
of SSO
Bobber/
Chalk
TR-05
Eastmont (Wilkins Township)
Thompson
Run
Monitoring
of SSO
Bobber/
Chalk
TR-06
Lick Run (Municipality of
Monroeville)
Thompson
Run
Monitoring
of SSO
Bobber/
Chalk
11- 21
Figure 11-2: Map of SSO Outfall Monitoring Locations
11- 22
Rainfall Monitoring: A radar rainfall system has been implemented and maintained by 3 Rivers
Wet Weather since April 2000 to provide high resolution, spatially distributed precipitation
data for the ALCOSAN service area. The radar rainfall system accounts for the temporal and
spatial distribution of rainfall in greater detail than would otherwise be possible with a
traditional rain gauge network, resulting in additional accuracy and confidence in the model
results. A regional network of 34 rain gauges is used to calibrate the recorded radar reflectivity
and produce the precipitation data used to populate the radar-rainfall pixel grid with rainfall
summed over 15 minute increments for each pixel of 1-km by 1-km (0.6 mile by 0.6 mile). A list
of the rain gauge network supporting this system is provided on Table 11-2. A map of the
rainfall gauge network and corresponding pixel grid for the ALCOSAN service area is provided
on Figure 11-3.
Table 11-2: List of Rain Gauges Supporting the Calibrated Radar-Rainfall System
Site ID
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
RG1
PWSA (Montana Street)
Precipitation
Monitoring Continuous
3RWW Rain
Gauge RG2
ALCOSAN (Alcosan Lab)
Precipitation
3RWW Rain
Gauge RG3
Shaler
Precipitation
3RWW Rain
Gauge RG4
Kennedy Twp.
Precipitation
3RWW Rain
Gauge RG5
Upper St. Clair
Precipitation
3RWW Rain
Gauge RG6
Carnegie
Precipitation
3RWW Rain
Gauge RG7
Greentree
Precipitation
3RWW Rain
Gauge RG8
Lawrenceville (ACHD)
Precipitation
3RWW Rain
Gauge RG9
University of Pittsburgh (Pitt)
Precipitation
3RWW Rain
Gauge RG10
Highland Park (PWSA)
Precipitation
3RWW Rain
Gauge RG11
Nine Mile Run (M46)
Precipitation
3RWW Rain
Gauge RG12
Baldwin
Precipitation
3RWW Rain
Gauge RG13
Braddock (M59)
Precipitation
3RWW Rain
Gauge RG14
Churchill
Precipitation
3RWW Rain
Gauge RG15
Trafford
Precipitation
3RWW Rain
Gauge 11- 23
Table 11-2: List of Rain Gauges Supporting the Calibrated Radar-Rainfall System
Site ID
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
RG16
Castle Shannon
Precipitation
Monitoring
Continuous
RG17
Bridgeville (SFA Chartiers PS)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
3RWW Rain
Gauge
RG18
Oakdale
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG19
Penn Hills North (Sandy Creek)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG20
Penn Hills South (Gascola PS)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG21
Moon Twp (Flaugherty Run)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG22
North Fayette
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG23
Findlay
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG24
Lewis Run (Pleasant Hills /
Jefferson Hills)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG25
White Oak
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG26
Elizabeth Twp.
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG27
Marshall
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG28
Plum
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG29
Bell Acres
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG30
McCandless
(Franklin Park / MTSA)
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG31
Hampton
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG32
Creighton
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG33
Richland
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
RG34
Arnold
Precipitation
Monitoring
Continuous
3RWW Rain
Gauge
11- 24
Figure 11-3: Rainfall Gauge Network and Pixel Grid
11- 25
Water Quality Monitoring: Building upon the Receiving Water Quality Program (RWQP) used
for development of the WWP, ALCOSAN will monitor bacteria (E. coli and fecal coliform) at
selected water quality monitoring locations. These monitoring locations will be selected to allow
for data collection needed to document stream improvements attributed to the implementation
of the CSO controls. Wherever possible, sampling sites will be selected that correspond to sites
sampled during the RWQP to allow for comparison.
Selected monitoring stations within the ALCOSAN service area, together with their monitoring
rationale, monitoring frequencies, and monitoring protocols are presented in
Table 11-3. Locations of receiving stream monitoring stations are shown on Figure 11-4.
Sampling will occur in three year cycles during the defined recreational period of May 1
through October 15. For the three year period of each cycle, three wet and three dry samples
will be collected. Dry weather is defined by an antecedent dry weather period of 72 hours with
less than 0.1 inches of precipitation with the dry weather conditions prevailing throughout the
event. Wet weather events are defined as no precipitation greater than 0.1 inches in the local
watershed for 48 hours followed by a minimum of 0.30 inches of rainfall (spatially averaged)
over a 24-hour period along the Allegheny, Monongahela or Ohio rivers. Each sample will
consist of a single vertical (SV), depth-integrated, isokinetic grab.
Table 11-3: List of Water Quality Monitoring Stations
Site ID
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
03049652
Allegheny River at
Hulton bridge at
Oakmont, 0.7 mi
downstream from Deer
Creek, at river mile
12.7.
Allegheny
River
Track WQ
Upstream of
CSOs
See Section
11.3.3
Bacteria
03049674
Allegheny River near
Blawnox PA
Allegheny
River
Track WQ
Upstream of
CSOs See Section
11.3.3
Bacteria
03049677
Allegheny River at RM
8.1
Allegheny
River
Track WQ
Upstream of
CSOs See Section
11.3.3
Bacteria
03049825
Allegheny River at RM
2.5 Herrs Island
Marina
Allegheny
River
Track WQ
Upstream of
CSOs See Section
11.3.3
Bacteria
03049832
Allegheny River at 9th
St. Bridge (Transect at
downstream end of
Convention Center on
left bank.)
Allegheny
River
Track WQ
Upstream of
CSOs See Section
11.3.3
Bacteria
11- 26
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
03085290
Chartiers Creek near
Bridgeville
Chartiers
Creek
Track WQ
Upstream of
CSOs See Section
11.3.3
Bacteria
03085500
Chartiers Creek at
Carnegie at gage.
Chartiers
Creek
Track WQ
of Receiving
Water
See Section
11.3.3
Bacteria
03085550
Chartiers Creek at
Thornburg at
Thornburg Bridge.
Chartiers
Creek
Track WQ
Downstream
of new CSO
Controls
See Section
11.3.3
Bacteria
03083903
Monongahela River at
McKeesport at RM
14.7
Monongahela
River
Track WQ
Upstream of
CSOs
See Section
11.3.3
Bacteria
See Section
11.3.3
Bacteria
Site ID
03085116
RM 5.5**
Monongahela
River
Track WQ
Immediately
Downstream
of Sensitive
Area
03085120
Pennsylvania
American Water
Intake, 20 yards
upstream of intake.
Monongahela
River
Track WQ
Immediately
Upstream of
Sensitive Area
See Section
11.3.3
Bacteria
03085140
RM 2.2 PAFBC
Launch
Monongahela
River
Track WQ
Immediately
Upstream of
Sensitive Area
See Section
11.3.3
Bacteria
03085150
Smithfield St. Bridge
on upstream side of
Matrix nightclub on left
bank.
Monongahela
River
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03085154
Ohio River at RM 0.0
at the Point at
Pittsburgh
Ohio River
Track WQ
Immediately
Upstream of
Sensitive Area
See Section
11.3.3
Bacteria
O1.4
ORSANCO
Ohio River
Track WQ
of Receiving
Water
See Section
11.3.3
Bacteria
O4.3M
ORSANCO
Ohio River
Track WQ
of Receiving
Water
See Section
11.3.3
Bacteria
11- 27
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
03085700
Ohio River at West
View Water Intake, 20
yards upstream of
intake.
Ohio River
Track WQ
Immediately
Upstream of
Sensitive Area
See Section
11.3.3
Bacteria
030859515
Ohio river on the back
channel near Interstate
79
Ohio River
Track WQ
of Receiving
Water
See Section
11.3.3
Bacteria
03085986
Ohio River at
Sewickley
Ohio River
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03085160
Sawmill Run at Castle
Shannon
Saw Mill Run
Track WQ
Upstream
of CSOs
See Section
11.3.3
Bacteria
03085213
Sawmill Run at
Duquesne Heights at
Minnotte Street Bridge.
Saw Mill Run
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03084400
Turtle Creek at
Trafford
Turtle Creek
Track WQ
Upstream
of CSOs
See Section
11.3.3
Bacteria
03084808
Turtle Creek at East
Pittsburgh at railroad
bridge.
Turtle Creek
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03049819
Girty’s Run above
Grant Avenue at
Millvale
Girty’s Run
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
030859501
Lowries Run below
CSO downstream of
Ohio River Blvd
Lowries Run
Track WQ
Upstream
of CSOs
See Section
11.3.3
Bacteria
03085050
Nine Mile Run at
mouth at M46
Nine Mile
Run
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03049810
Pine Creek at
Industrial Park
Pine Creek
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
03085113
Streets Run below
CSO near mouth
Streets Run
Track WQ
Downstream
of CSOs
See Section
11.3.3
Bacteria
Site ID
11- 28
Figure 11-4: Receiving Stream Monitoring Locations
11- 29
Stream Flow Monitoring: ALCOSAN will make use of 12 existing United States Geological
Survey (USGS) real-time flow discharge and water stage gauging stations in and around the
ALCOSAN service area to monitor flow in the receiving streams. These gauges are listed in
Table 11-4 and are shown on Figure 11-5.
In the event stream flow monitoring is discontinued by USGS at some locations, adequate
historic data is available to estimate stream flow discharge using water depth measurements.
Table 11-4: USGS Stream Gauging Stations
Site ID
Receiving
Stream
Monitoring
Rationale
Monitoring
Frequency
Monitoring
Protocols
03049500
Allegheny River at Natrona, PA
Allegheny River
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03049800
Little Pine Creek near Etna, PA
Little Pine
Creek
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03049807
Pine Creek at Grant Avenue at
Etna, PA
Pine Creek
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03049819
Girty’s Run above Grant Avenue
at Millvale, PA
Girty’s Run
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03075070
Monongahela River at Elizabeth,
PA
Monongahela
River
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03083500
Youghiogheny River at
Sutersville, PA
Youghiogheny
River
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03084698
Turtle Creek at Wilmerding, PA
Turtle Creek
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03084800
Thompson Run at Turtle Creek,
PA
Thompson Run
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03085000
Monongahela River at Braddock,
PA
Monongahela
River
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03085213
Saw Mill Run at Duquesne
Heights near Pittsburgh, PA
Saw Mill Run
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03085500
Chartiers Creek at Carnegie, PA
Chartiers Creek
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
03086000
Ohio River at Sewickley, PA
Ohio River
USGS
Gauging
Station
Continuous
Stream Flow,
Water Stage
11- 30
Figure 11-5: USGS Stream Gauging Station Locations
11- 31
Monitoring Schedule: Interim water quality monitoring will commence in 2015 and consist of
two three year cycles. Post-construction water quality monitoring will begin in 2027 and last for
three years.
SSO activation monitoring consistent with Appendix L, paragraph 1c of the CD, along with
rainfall and stream flow monitoring, will continue throughout the interim and postconstruction period. CSO monitoring will begin in 2027 and continue for one year.
The Interim and Post-Construction Monitoring Schedule is shown in Table 11-5.
Table 11-5: Interim Water Quality Monitoring Schedule
Cycle 2
Stream Flow
Rainfall
2029
2028
2026
CSO Activation
SSO Activation
2025
2024
2023
2022
2021
2020
2019
2018
2017
2016
Cycle 1
PCMP Update Water Quality
2015
2014
Monitoring Type
2027
Post
Construction
Interim
In 2024 if appropriate, ALCOSAN will submit proposed modifications to the Post-Construction
monitoring provisions of the Receiving Water Quality Monitoring Plan consistent with
paragraph 9c of Appendix Q of the CD.
11.3.4 Data Retrieval, Management and Analysis
Data retrieval, management and analysis are an integral part of any monitoring program.
ALCOSAN currently has a system to store, retrieve, and analyze existing data. This postconstruction monitoring program was developed to make use of the existing database to
facilitate evaluation of new water quality data which will be used, along with the water quality
models, to measure the effectiveness of CSO controls. The program activities are designed to
ensure collection of appropriate data, establish consistency of sampling methods and data
acquisition, and define performance standards for maintaining data integrity. All necessary
measures will be taken to validate, track, store and manage the collected data to ensure that
monitoring objectives are attained.
Specific sampling protocols are administered and performed by experienced personnel familiar
with sampling procedures used in support of the ongoing monitoring program for ALCOSAN.
As data are generated during interim and post-construction monitoring, the program may need
to be revised to accommodate alternative data collection techniques or data evaluation
11- 32
approaches to meet monitoring objectives. Any revisions or additions to the data retrieval or
management aspects of such program will be made after consulting with PaDEP and U.S. EPA.
ALCOSAN has developed a dynamic H&H model that fully integrates the hydrology and
hydraulics of the combined sewer system (collection system model). ALCOSAN will utilize
sound engineering judgment and best industry practices, and take the following steps, to
update and utilize the collection system model to determine whether ALCOSAN has achieved
compliance with the Performance Criteria.
1. Collect flow and depth data in the collection system for the 12-month post-construction
monitoring period as described in section 11.3.3
2. Perform quality assurance and quality control of the data collected in Step 1.
3. Utilize the H&H Model in its previously-calibrated state and the rainfall data collected
during the monitoring period, to run a continuous simulation of CSO discharges for the
12- month post-construction monitoring period.
4. Compare the continuous simulation CSO discharge outputs to the CSO monitoring data
for the 12-month post-construction monitoring period to determine whether recalibration of the collection system model is needed. Model re-calibration will be not be
needed if the model achieves at least the same degree of calibration as was achieved for
existing conditions during the WWP development process, and there is a high degree of
agreement between the model output and CSO monitoring data for activation frequency
for the 12-month post-construction monitoring period. Otherwise, model re-calibration
will be needed in accordance with Steps 5-7.
5. If re-calibration is needed, select two or more appropriate rainfall events from the 12month post-construction monitoring period for model recalibration.
6. Develop an initial data set for use with the model and perform successive applications of
the model with appropriate parameter adjustment until there is a high degree of
agreement between the model output and the CSO monitoring data for the 12-month
post-construction monitoring period. In making such adjustments, the ALCOSAN will
consider the inherent variability in both the collection system model and in flow
monitoring data, and will exercise sound engineering judgment and best industry
practices so as to not compromise the overall representativeness of the model.
7. Once the model has been re-calibrated in accordance with Step 6, ALCOSAN will verify
the re-calibrated model by again utilizing the model and the rainfall data collected
during the 12-month post-construction monitoring period, to run another continuous
simulation for the 12-month post construction monitoring period. ALCOSAN will again
compare the continuous simulation CSO discharge outputs to the CSO monitoring data
for the 12-month post-construction monitoring period as described in Step 4, to
determine whether additional re-calibration of the collection system model is needed.
Re-calibration will be determined to be adequate if the model achieves at least the same
degree of calibration, as was achieved for pre-CSO Long-Term Control conditions
during the WWP development process, and there is a high degree of agreement
between the model output and CSO monitoring data for activation frequency for the
11- 33
12-month post-construction monitoring period. Otherwise, further re-calibration will be
needed in accordance with these Steps 5-7 until the model achieves at least the same
degree of calibration as was achieved for pre-CSO Long-Term Control conditions during
the WWP development process, and there is a high degree of agreement between the
model output and CSO monitoring data for activation frequency for the 12-month postconstruction monitoring period.
8. Once ALCOSAN has satisfactorily re-calibrated the model in accordance with Steps 5
through 7 (or shown that re-calibration is not necessary in accordance with Step 4),
ALCOSAN will then utilize the original or recalibrated model (if recalibration was
necessary in accordance with Steps 4-7) to run a continuous simulation of the typical
year to determine whether ALCOSAN has achieved the Performance Criteria.
9. ALCOSAN shall be deemed to have achieved the Performance Criteria if:
•
ALCOSAN untreated CSO volume is less than 4,000 MG/year in a typical year,
•
ALCOSAN CSOs near Sensitive Areas overflow zero or one time in the typical
year, depending on the specific outfall.
•
ALCOSAN SSOs on Chartiers Creek are controlled to a long term average of 1
overflow every 2 years.
11.3.5 Quality Control
QA/QC will utilize many of the same procedures and processes that were developed and
implemented during the development of the WWP. A summary of these procedures is given
below along with references to more detailed descriptions.
Water Quality: The water quality monitoring and sampling program will employ similar data
quality assurance review procedures to those used for development of the WWP to ensure that
program objectives are met. Internal quality control checks will be performed on field and
laboratory generated measurements as summarized herein.
Field Measurements: Field quality control checks consist of quality assurance (QA)/quality
control (QC) samples that will be collected or prepared by the field crews and will be submitted
for laboratory analysis. These samples consist of duplicates, field blanks, and equipment
blanks. Acceptable control limits will be established, the data reviewed, and an assessment
made of the adequacy of the quality control checks. When problems are identified; corrective
actions will be discussed and implemented, as appropriate. In addition, quality control checks
will be conducted in advance of, and following, the use of multi-parameter meters. Procedures
will be similar to those used for the collection of data for development of the WWP.
Laboratory Measurements: The laboratory will perform quality control checks on all samples
analyzed, which includes sample duplicates, matrix spikes, matrix spike duplicates, control
samples, and method blanks as appropriate. The laboratory will conduct quality control
procedures for analytical services in accordance with their standard operating procedures and
the individual method requirements referenced by U.S. EPA methods or Standard Methods
11- 34
(18th, 19th and 20th Editions) with acceptable control limits. Quality control check issues will
be identified and corrective actions will be implemented.
Data Review, Validation and Usability: All environmental measurement data and samples collected will be subjected to quality control. This is a multi‐step process where the Program Managers are responsible for verifying the data and the Quality Assurance Manager will conduct the data validation. The data generated from the sampling program will be subjected to a multi‐
tiered review process which includes: •
Review of the data at the bench (laboratory) and field levels
•
Secondary review of field records by the Field Program Manager and laboratory
analytical results by the Quality Assurance Manager to verify the data against method
and standard operating procedure requirements
•
Screening level review of the verified data by the appropriate Program Managers for
reasonableness and to identify obvious data anomalies
•
Validation and data usability by the Quality Assurance Manager
If data does not meet QA/QC criteria, additional review of the quality control checks and any
relevant laboratory bench sheets will be conducted. Upon completion of QA/QC review, the
data will be flagged appropriately, identifying the limitations of the data.
Data Verification: The data quality assurance review process includes a series of data
verification activities that are conducted during field activities and in the laboratory.
Field Activities Data Verification - The Field Program Manager will be responsible for
ensuring that the samples are collected and handled according to the procedures specified.
Sample collection verification includes confirming that the samples are collected with the
proper equipment at the appropriate locations with the appropriate frequency using proper
labeling protocol. Sample handling verification includes confirmation by the laboratory that the
samples are stored in the appropriate containers with the correct preservative, that the samples
were stored at the proper temperature during transport from the field to the laboratory, proper
change-of-custody procedures were followed and that all appropriate information was logged
on the chain-of-custody records.
Laboratory Activities Data Verification - The Laboratory QA/QC Manager is responsible for
verifying and approving laboratory generated data. Laboratory verification includes assessing
that the procedures used to generate the data are consistent with the method requirements as
specified in the laboratory’s SOPs and that the QA/QC requirements for each method are met.
Examples of method requirements include verifying the calibration and data reduction
procedures. Method QA/QC requirements vary by analyte. A laboratory report will be
released to the Quality Assurance Manager after the data is verified and approved.
11- 35
Data Validation Requirements - The Quality Assurance Manager − who is not directly
involved with the field program, sample collection, or analysis – will perform data validation
for this program which includes the following.
•
Inspect the data verification and review records to ensure that no oversights were made
during that process.
•
Evaluate the data against the project’s Data Quality Objectives.
•
Evaluate the data in the context of the project’s overall objectives, which include using
the data collected to support the development, calibration and application of numerical
assessment tools.
•
Communicate the data validation results to the rest of the project team.
Field measurements data collection, field sample collection, sample custody, laboratory
analytical results and case narrative, laboratory data reviews, and laboratory quality control
data will all be checked as part of the measurement data and analytical data validation
activities. After a review of the laboratory data for compliance with the established quality
control criteria, qualifiers will be assigned to the data.
A complete description of QA/QC procedures for water quality data can be found in
ALCOSAN’s Receiving Water Quality Monitoring Plan, Revised April 2009.
Rain Data: Monitoring equipment calibration, maintenance, and data quality assurance checks
will be performed and/or verified by 3RWW such that monitoring accuracy is optimized, and is
in conformance with the equipment manufacturers’ recommendations.
CSO and SSO Outfall Monitoring: Outfall activation will be corroborated by use of
independent chalk and bobber methods.
In-stream Flow Monitoring: Standard USGS equipment, procedures, and protocols will apply
to all long-term stream monitoring data.
11.3.6 Reporting
Final Post-Construction Monitoring Report: Two years after implementation and successful
operation of the 2026 plan controls, ALCOSAN will submit a final Post-Construction
Monitoring Report (PCMR) to U.S. EPA and PaDEP for their approval. The report will contain
the following information:
•
CSO and SSO Monitoring Results
•
Rainfall Monitoring Results
•
Receiving Stream Flow Monitoring Results
•
Water Quality Monitoring Results
11- 36
•
Re-validation of the collection system models using afore mentioned data for the outfalls
to be determined in the 2024 PCMP update.
•
Evaluation of CSO and SSO Control Measures (including whether or not the measures
meet the Performance Criteria).
•
Significant Variances and Impacting Factors (with regard to verification of level of
control and water quality impacts)
•
Re-Evaluation and Corrective Actions (if necessary)
The purpose of the Final Post-Construction Monitoring Report is to document how well
ALCOSAN’s entire sewer system is performing as a whole, following completion of all WWP
projects, and shall include an assessment of whether the improvements are meeting
Performance Criteria. In the event the final PCMR fails to demonstrate that ALCOSAN has met
the established Performance Criteria; deficiencies or performance limiting factors in system
design, process, operations and/or maintenance that may limit the effectiveness of the CSO
control measures in achieving their intended performance will be identified and necessary
corrective actions documented.
11.3.7 Summary
ALCOSAN’s post-construction monitoring program will determine the effectiveness of the CSO
and SSO control program in achieving its performance requirements and water quality goals.
The program includes the following elements:
•
Implementation of a defined monitoring program designed to measure reductions in
overflow activations and changes in stream water quality;
•
Analysis and assessment of monitoring data and/or model simulation results to
determine whether implemented CSO and SSO control measures are meeting the
Performance Criteria;
•
A monitoring schedule, monitoring locations, and associated monitoring procedures to
collect data related to the Performance Criteria;
•
Preparation and dissemination of a revised PCMP and a final post-construction
monitoring report.
ALCOSAN’s IPCMP addresses the U.S. EPA and PaDEP requirements for monitoring the
performance of the CSO control measures. ALCOSAN will use the Performance Criteria
outlined in section 11.3.2 as performance measures to determine the effectiveness of the overall
WWP CSO and SSO control measures. ALCOSAN will use existing monitoring systems,
augmented as necessary, to collect and evaluate data. This includes flow and/or outfall
activation monitoring, in-stream sampling and rainfall monitoring. ALCOSAN will also use the
H&H Model to measure performance of the CSO and SSO control measures. ALCOSAN shall
submit a Final Post-Construction Monitoring Report to the U.S. EPA and PaDEP, as required, to
demonstrate performance and achievement of WWP objectives.
11- 37
Section 11 - Implementation Plan
11.4 Financing Plan
This section describes ALCOSAN’s strategy for financing the implementation of the
Recommended 2026 Plan. The parallel municipal financing of improvements to the municipal
collection systems is beyond the scope of this document.11-4
11.4.1 Capital Requirements
Based upon the implementation schedule outlined in Section 11.1 of this document, the
Recommended 2026 Plan will result in $1.45 billion in new capital expenditures for ALCOSAN
and $0.53 billion in new capital expenditures for the municipalities for a total of approximately
$2.0 billion through 2026. Accounting for inflation, ALCOSAN and the municipalities will face
wet weather control capital expenditures of $2.8 billion over the next fifteen years.
The projected annual capital requirements are shown on Table 11-6 below. Based upon the
anticipated implementation schedule as detailed in Section 11.1, ALCOSAN’s annual capital
needs are projected to average $144 million and to peak at around $336 million during
construction. The aggregated rates of municipal expenditures shown are preliminary
estimates, pending the development of specific municipal implementation schedules under the
respective municipal Feasibility Studies.
Table 11-6: Recommended 2026 Plan Projected Annual Capital Expenditures
Year
ALCOSAN Annual Cost
($ millions)
Current $
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Total
Average
$14
$23
$37
$34
$96
$78
$149
$204
$240
$188
$141
$114
$75
$59
$1,450
$104
Inflated
$15
$26
$43
$41
$118
$100
$196
$277
$336
$271
$209
$174
$118
$96
$2,020
$144
Municipal Annual Cost
($ millions)
%
1%
2%
3%
2%
7%
5%
10%
14%
17%
13%
10%
8%
5%
4%
100%
Current
Cost
Inflated
$0
$1
$1
$13
$26
$38
$64
$64
$64
$64
$64
$61
$60
$11
$530
$38
$0
$1
$1
$16
$32
$48
$84
$86
$89
$92
$95
$94
$96
$19
$752
$54
%
0%
0%
0%
3%
5%
7%
12%
12%
12%
12%
12%
12%
11%
2%
100%
Total
Current
Cost
$14
$24
$38
$47
$122
$116
$213
$268
$304
$252
$204
$175
$135
$70
$1,980
$141
Inflated
$15
$27
$44
$57
$151
$148
$280
$363
$425
$363
$304
$268
$214
$114
$2,772
$198
%
1%
1%
2%
2%
6%
6%
11%
14%
15%
13%
10%
9%
7%
4%
100%
11-4
The municipal orders do not address the financing of the municipal improvements. (See Paragraph 14(d) of
the PaDEP COA and 15(d) of the ACHD ACO relating to the municipal Feasibility Studies).
11-38
11.4.2 Capital Funding
Alternative Capital Funding Options: ALCOSAN evaluated alternatives to the municipal
revenue bond market as capital sources as suggested in EPA’s LTCP guidance document11-5 and
other EPA guidance.11-6 As noted in the 1995 Guidance for Funding Options:
“Grants will likely play only a limited role in future CSO funding. The reliance on direct
federal wastewater construction grants has been replaced with a reliance on SRF loans
and other local funding options.”
The Federal funding situation since 1995 has not improved. Moving forward, ALCOSAN has
and will continue to work with the region’s state Legislative and Congressional delegations
towards workable funding for wet weather controls. Funding that has been obtained to date as
USEPA Special Appropriations Projects and from Sections 219 and 206 of the Water Resources
Development Act through the Corps of Engineers has been used by ALCOSAN to support
projects such as direct stream inflow removals.11-7
Some options listed in the Guidance are more applicable to the municipalities than to
ALCOSAN due to eligibility or funding restrictions. For example, PennVest has a $20 million
limit on total financing by any recipient. The Rural Utilities Services (RUS) provides low interest
loans, and limited grants for municipal water and sewer infrastructure. This program would be
more applicable to the ALCOSAN municipalities with populations of less than 10,000.
ALCOSAN has worked with the local RUS office towards availing the municipalities of this
program.
ALCOSAN’s Capital Financing Strategy: ALCOSAN anticipates using combinations of payas-you-go funding utilizing accumulated reserve funds and revenue bond financing owing to
ALCOSAN’s strength in the municipal bond market. As detailed in Section 6.3 of this
document, as of October 14, 2011 ALCOSAN has a rating of ‘A’ long-term (with a stable
outlook) from Standard & Poor’s Rating Services and A1 from Moody’s Investors Services.
As a special purpose governmental enterprise established pursuant to the Pennsylvania
Municipality Authorities Act, ALCOSAN has no legal authority to establish or levy property tax
assessments. Therefore, ALCOSAN cannot issue general obligation bonds. ALCOSAN’s uppermedium grade bond ratings are supported by the current contractual relationship between
ALCOSAN and the municipalities wherein ALCOSAN’s revenues flow from the municipalities
rather than through retail billings. As a result, ALCOSAN’s revenue bonds are arguably
analogous to “double barreled” bonds as described in the EPA guidance documents.
For planning purposes only, the financial modeling done in support of ALCOSAN’s
affordability analysis (Section 11.5) assumes that bonds will be sold as necessary to meet
11-5
Section 4.3.3, Combined Sewer Overflows - Guidance For Long-Term Control Plan, EPA 832-095-002, September 1995.
11-6
Combined Sewer Overflows Guidance for Funding Options EPA 832-B-95-007, August 1995
11-7
See Section 10.2 of this document for additional details on some of these projects.
11-39
forthcoming construction draw requirements (typically annually). The actual size and timing of
revenue bonds necessary to implement the Recommended 2026 Plan will be determined by the
eventual construction progress on the various components of the Plan and by the conditions in
the municipal bond markets, and are therefore beyond the scope of this document.
11.4.3 Annual Revenue Requirements
The planning level estimated annual incremental revenue requirements resultant from the
implementation of the Recommended 2026 Plan are shown on Table 11-7.
Table 11-7: Projected Annual Revenue Requirements
($ millions)
Year
ALCOSAN
Current
System
Incremental
2026 Plan
Total
Year
ALCOSAN
Current
System
Incremental
2026 Plan
Total
a
b
c
d
e
f
g
2012
$112.6
$0.0
$112.6
2030
$206.2
$177.1
$383.3
2013
$121.6
$0.0
$121.6
2031
$212.3
$178.3
$390.6
2014
$127.4
$0.0
$127.4
2032
$220.8
$179.6
$400.4
2015
$131.6
$1.2
$132.8
2033
$229.7
$181.0
$410.6
2016
$137.6
$4.3
$142.0
2034
$238.9
$182.4
$421.2
2017
$143.4
$7.2
$150.6
2035
$248.5
$183.8
$432.3
2018
$149.4
$16.0
$165.5
2036
$258.4
$185.3
$443.7
2019
$155.7
$23.4
$179.0
2037
$268.8
$186.9
$455.7
2020
$162.2
$38.0
$200.2
2038
$274.5
$188.5
$463.1
2021
$169.0
$58.8
$227.7
2039
$285.8
$190.2
$476.0
2022
$175.9
$83.9
$259.9
2040
$297.0
$191.9
$488.8
2023
$183.2
$103.9
$287.1
2041
$288.9
$193.4
$482.4
2024
$176.7
$119.0
$295.7
2042
$300.3
$195.0
$495.4
2025
$177.7
$131.5
$309.1
2043
$312.1
$196.7
$508.8
2026
$176.3
$150.5
$326.8
2044
$324.3
$198.4
$522.7
2027
$183.6
$173.6
$357.2
2045
$335.2
$198.9
$534.2
2028
$190.8
$174.7
$365.6
2046
$345.7
$197.7
$543.4
2029
$198.4
$175.9
$374.3
11-40
Columns “a” and “e” show the projected annual costs for ALCOSAN’s existing Regional
Conveyance System and for the Woods Run Wastewater Treatment Plant, including operations,
maintenance, and debt service costs. The operation and maintenance costs are inflated
annually. The debt service costs include the costs of amortizing ALCOSAN’s existing debt,
based upon existing amortization schedules plus projected new debt related to ALCOSAN’s
Capital Improvements Program beyond the Wet Weather Plan. ALCOSAN’s current
amortization schedule may be revised as ALCOSAN refinances outstanding debt in response to
favorable market conditions. The current system costs also include debt service as may be
incurred in the future in support of ALCOSAN’s ongoing Capital Improvement Plan. For
planning purposes, ALCOSAN has assumed that ongoing capital improvements that are not
related to the Wet Weather Plan will occur at an average annual cost of approximately $31
million (current dollars) based upon recent history.
11.4.4 Annual Cost Recovery
As described elsewhere in this document, ALCOSAN has been proactively addressing wet
weather issues since 1992. As noted in Section 10.2, ALCOSAN has invested more than $210
million in capital improvements over the past ten years in support of sewer overflow control
and improved water quality. To finance these improvements, along with other cost pressures
such as increased staffing to meet consent decree requirements and rising health benefit costs,
ALCOSAN has increased it rates by an average of 9% annually since 2004 as shown on Table 118.
Table 11-8: Rate Increase History
Commodity Charge
Service Charge
Year
Rate
Increase
Rate
Increase
2004
$2.50
12%
$5.25
12%
2006
$2.75
10%
$5.78
10%
2005
$2.75
0%
$5.78
0%
2007
$2.98
8%
$6.27
8%
2008
$3.25
9%
$6.83
9%
2009
$3.77
16%
$7.92
16%
2010
$4.04
7%
$8.48
7%
2011
$4.04
0%
$8.48
0%
2012
$4.32
7%
$9.07
7%
Based upon the preliminary analysis presented herein, the implementation of the
Recommended 2026 Plan would require an average annual revenue increase of at least 8%
through the first full year of implementation in 2027. This projection is for illustrative purposes
only and should not be construed as a wet weather plan component. Annual rates will be set in
11-41
rate increases ranging from 10% to 12% through the implementation of the Recommended 2026
Plan may be necessary.
ALCOSAN receives user charge revenues directly from the customer municipalities based
upon a fixed service charge per account and a commodity charge (also described in Section 7.3).
Additional surcharges are imposed for high strength compatible wastewater. (wastewater with
concentrations of BOD5 and TSS exceeding 300 and 275 milligrams per liter (mg/l)
respectively). The rates are uniform across user classes pursuant to the requirements of Section
507(d)(9) of the Municipality Authorities Act which requires “reasonable and uniform rates”.
As ALCOSAN moves into the implementation of this WWP, it may choose to evaluate
refinements or alternatives to the cost allocation and cost recovery structure that is represented
by its current user charge system towards enhanced cost allocation or revenue generation. Such
evaluations and ultimate policy directions are beyond the scope of this document.
11.4.5
Alternative Revenue Streams
EPA’s 1997 financial capability guidance references four funding mechanisms and sources of
funding “if loans and grants are not available or if a need exists to reduce the financial impact of
CSO controls on the users.”11-8 The applicability of these revenue sources to ALCOSAN may be
summarized as follows.

Establish special assessment district – Unlike municipalities, ALCOSAN as a municipal
authority has no legal authority to establish or levy property tax assessments ;

Increase user fees –The implementation of ALCOSAN’s WWP is premised on a series of
substantial rate increases;

Impose / increase taxes (such as income taxes, sales taxes or property taxes) – as noted
above, ALCOSAN has no statutory authority to impose taxes. Even if ALCOSAN could
impose taxes, the “affordability” of wet weather controls would not improve. The
portion of tax revenue attributed to residential properties would need to be factored
into the calculation of annual wastewater costs per household as a component of total
wastewater service costs; and

Privatize wastewater treatment – To date, the option of the privatization of wet
weather control facilities has not appeared to be viable or advantageous.
Moving forward into the WWP implementation phase, ALCOSAN will evaluate evolving
financial instruments as appropriate.
11-8
Combined Sewer Overflows – Guidance for Financial Capability Assessment and Schedule
Development, EPA 832-B-97-004, Page 48
11-42
Section 11- Implementation Plan
11.5 Affordability and Financial Capability Assessment
11.5.1 Introduction
This section of ALCOSAN’s WWP integrates the cost impacts of the Recommended 2026 Plan as
detailed in Section 10 of this document with the current conditions (2010) financial and
institutional assessment that was presented in Section 6. The estimated current dollar capital,
operation and maintenance costs for improvements to ALCOSAN’s regional conveyance and
treatment system are summarized and are also presented on an annualized basis for the period
of 2012 through the 2046 planning period.
In parallel with ALCOSAN, the estimated municipal costs required to upgrade municipal wet
weather conveyance capacities or otherwise address municipal overflows are included to
provide a full understanding of the future costs of wastewater services in the ALCOSAN
Service Area. The affordability of the Recommended 2026 Plan is evaluated using the EPA
defined Residential Indicator (RI) through 2046. The Residential Indicator is derived in this
section by dividing the projected annual cost per household by the median household income at
regional (ALCOSAN service-area wide) and municipal levels. The affordability analysis
focuses on the key year of 2027, the first year after full implementation of the Recommended
2026 Plan. These projections are based upon planning level assumptions for financing strategies
and revenue requirements (See Section 11.4).
The impacts of the proposed wet weather program on the financial capabilities of ALCOSAN
and the municipalities are also presented based upon the current conditions analysis that was
presented in Section 6.0 of this document and the projected capital costs of the ALCOSAN and
municipal improvements. For example, ALCOSAN’s current annual debt service payments
total approximately $42 million while the projected annual debt service for the recommended
program upon full implementation in 2027 is more than $210 million. In addition, there will be
an additional $66 million in annual municipal debt service payments anticipated as a result of
collection system improvements.
11.5.2 Key Institutional Assumptions
The analyses presented herein are based upon the following assumptions as to ALCOSAN’s
operating environment during the implementation of the WWP:
Current Cost Allocation and Rate Structure - ALCOSAN’s current user cost allocation and rate
structure described in sub-section 7.3 will continue to be utilized for this analysis.
Municipal Costs Evenly Distributed Across Service Area - Estimated capital costs for municipal
wet weather conveyance and other improvements are estimated to total approximately $530
million in current dollars, and it is assumed that these costs will be evenly distributed across the
service area.
The allocation of costs among municipalities is pending on-going development and
coordination of municipal feasibility studies. For example, there are a number of costly
conveyance upgrades that are exclusively or primarily located in a downstream municipality
11-43
for which a substantial portion of the hydraulic load may be attributed to upstream
municipalities. Determination of the inter-municipal cost sharing of such upgrades will require
significant time and effort on the parts of the municipalities.
Current Institutional Framework - Wastewater services within the ALCOSAN service area are
delivered by combinations of municipalities, municipal authorities and ALCOSAN. The
municipal collection systems are typically owned and operated by a municipality or municipal
authority. These sewers discharge into downstream municipal systems or into the ALCOSAN
regional conveyance interceptor system. This WWP is based on the assumption that the current
institutional framework will remain in place throughout the implementation of the WWP.
Nonetheless, as of the writing of this Plan, the Allegheny Conference on Economic
Development is facilitating an evaluation by stakeholders, the municipalities, and ALCOSAN as
to the suitability of other institutional frameworks to deliver future wastewater services,
including wet weather controls. Should institutional revisions occur, ALCOSAN will
coordinate any necessary revisions to the WWP with the regulatory agencies.
11.5.3 Future Conditions without Wet Weather Compliance Costs
ALCOSAN System Costs (Without Recommended 2026 Plan): The forces of inflation and
the costs of ALCOSAN’s ongoing Capital Improvements Program will result in steadily
increasing annual costs for the existing ALCOSAN regional conveyance system and treatment
plant without the incremental costs of implementing the Recommended 2026 Plan. As
summarized on Table 11-9, the annual costs for the current ALCOSAN facilities are projected to
increase from an estimated $113 million in 2012 to $362 million in 2046. The projected costs in
2027, the first year of full operation of the facilities to be built under the Recommended 2026
Plan would be around $180 million.
Table 11-9: Projected Annual ALCOSAN Costs Without Wet Weather Plan
($ millions –Including Inflation and Ongoing Capital Improvements)
ALCOSAN Annual Cost
2012
2027
2046
O&M
$65
$117
$237
Debt Service & Reserves
$48
$62
$125
$113
$179
$362
Total
The projected annual costs are shown graphically Figure 11-6. Costs are projected through 2046
according to current and historical spending patterns. The revenue requirements for
ALCOSAN necessary to maintain current level of service are provided as a baseline to which
Wet Weather affordability impacts and spending can be compared. For planning purposes,
annual debt service revenue requirements include the current amortization schedule for
existing debt refinanced in 2011 as well as payments for anticipated annual capital
improvements at a average costs of $31 million (current dollars).
11-44
Figure 11-6: Projected ALCOSAN Annual Costs for O&M and Debt Service Payments
(In Millions Without Wet Weather Program Spending)
$450
Annual Debt Service
$400
Annual O&M
$350
$300
$250
$200
$150
$100
$50
$0
2011
2016
2021
2026
2031
2036
2041
2046
The typical cost per household for ALCOSAN’s wastewater conveyance and treatment services
has been estimated to be $260 in 2012.11-9 Without the Recommended 2026 Plan, the annual
ALCOSAN cost per typical household would be projected at $400 in 2027.
Municipal Collection System Cost Projections (Without Recommended 2026 Plan):
Budget projections for the 83 municipalities are not available. ALCOSAN is anticipating that
municipal collection system costs will increase by at least the rate of inflation for operation and
maintenance. The ALCOSAN service-area-wide weighted average cost per household for
municipal collection systems was estimated to be $183 in 2012, increasing to $330 annually in
2027.
11-9
See Sub-Section 6.2 of this document.
11-45
Total Cost Per Household (Without Recommended 2026 Plan): The total cost per typical
household in 2027 without the Recommended 2026 Plan and the concomitant municipal
improvements would be $730 annually. As detailed in Section 7, household income is projected
to increase at 2.5% annually. The ALCOSAN service-area-wide median household income of
$46,400 in 2012 would therefore increase to $67,300 in 2027. Dividing the total wastewater costs
by the median income yields a Residential Indicator of 1.1%.
The projected costs per typical household without the wet weather controls for the planning
period are shown on Table 11-10 for 2012, 2027 and 2046.
Table 11-10: Regional Residential Indicator Without the Recommended 2026 Plan
Cost per Household
Year
ALCOSAN
Municipal
Total
Median
Household
Income
RI
2012
1.0%
$260
$180
$440
$46,400
2027
1.1%
$400
$330
$730
$67,300
2046
1.4%
$810
$670
$1,480
$108,800
11.5.4 Revenue Requirement Impacts of the Recommended 2026 Plan
ALCOSAN Incremental Annual Revenue Requirements: The total capital costs for the
Recommended 2026 Plan as detailed in Section 10 of this document are approximately $2 billion
(current dollars), including approximately $1.45 billion in costs for ALCOSAN facilities and
$0.53 billion for improvements to municipal conveyance capacities and other municipal wet
weather controls.
The projected ALCOSAN annual revenue requirements resulting from the implementation of
the Recommended 2026 Plan are detailed on Table 11-11 and are shown graphically on
Figure 11-7 through the 2046 planning period. Total ALCOSAN revenue requirement will
roughly double for 2027, the first full year of operation for the 2026 Plan facilities from $180
million without the Plan to nearly $360 million. This amount includes $133 million in
Recommended 2026 Plan debt service (not including related reserves) and an additional $27
million in incremental O&M costs (2027 dollars).
11-46
Table 11-11: ALCOSAN Recommended 2026 Plan
Estimated Annual Costs (In $ millions)
Line Item
2012
2027
2046
$65
$117
$237
$0
$27
$55
$65
$144
$293
$42
$24
$0
Capital Improvement Program
$0
$35
$96
Recommended 2026 Plan
$0
$133
$129
$0
$168
$224
Operations & Maintenance
$1
$2
$4
Debt Service
$4
$19
$22
Subtotal
$5
$21
$26
TOTAL
$113
$357
$543
Operations and Maintenance
Current System
Recommended 2026 Plan
Subtotal
Debt Service
Current Debt
Incremental Debt Service
Subtotal
Coverage and Reserves
$700
$600
$500
WWP Debt Service
$400
WWP O&M
$300
Exisitng System
Debt Service
Existing System
O&M
$200
$100
11-47
2049
2047
2045
2043
2041
2039
2037
2035
2033
2031
2029
2027
2025
2023
2021
2019
2017
2015
2013
$0
2011
ALCOSAN Revenue Requriements in Millions
of Dollars, Inflated
Figure 11-7: Projected ALCOSAN Revenue Requirements
Municipal Incremental Annual Revenue Requirements: For planning purposes, ALCOSAN
is assuming that the estimated $530 million in municipal capital investments will be funded
through bonds issued by the municipalities as needed during the course of design and
construction. Twenty-year bonds at a 6.5% interest rates are assumed, resulting in an
incremental annual debt service of $66 million in 2027 to be allocated among the municipalities.
Incremental O&M (including renewal and replacement) costs totaling 3% of the total capital
costs are also assumed. For the first year of full operation in 2027, the incremental municipal
O&M costs are estimated to be an additional $30 million (2027 dollars).
11.5.5
Affordability Impacts of the Recommended Program
Projected Cost per Household: The projected costs per household resultant from the
implementation of the Recommended 2026 Plan and the related municipal improvements are
shown through the 2046 planning period on Table 11-12. The ALCOSAN cost per household
will effectively double from a projected $410 for the current system to a total of $800 during the
first full year of operation (2027 dollars). Projected municipal costs (ALCOSAN service-areawide weighted average) will total $545, including about $210 for the municipal improvements.
It must be noted that the incremental municipal cost per household estimate reflects the
diffusion of the municipal improvement costs across the 83 municipalities pending the
allocation of costs among the municipalities per the assumptions described above. Adding the
projected ALCOSAN costs of $800 to the projected municipal costs of $545 results in an
estimated cost per household of $1,340 in 2027.
Table 11-12: ALCOSAN Recommended 2026 Plan
Projected Annual Cost per Typical Household
Cost per Household
2012
2027
2046
ALCOSAN
Current System Cost
$260
$410
$770
$0
$390
$440
$260
$800
$1,210
$180
$330
$670
$0
$210
$140
Subtotal
$180
$540
$810
Total
$440
$1,340
$2,020
$46,400
$67,300
$108,800
1%
2.0%
1.9%
Recommended 2026 Plan Costs
Subtotal
Municipal (weighted average)
Current System Cost
Wet Weather Costs
Projected Median Household Income
Residential Indicator
11-48
Projected Regional Residential Indicator: The current (2012) ALCOSAN service-area-wide
median household income of $46,400 is projected to increase at 2.5% annually to $67,300 in 2027.
Dividing the projected annual cost per household of $1,365 by the projected MHI results in a
Regional Residential Indicator of 2.0%, or a “high burden” based upon the EPA criteria. The
Regional Residential Indicator is projected to stay at or above 2% through 2041, at which time
the indicator is projected to fall below 2% to around 1.85% through the planning period. This
slight decrease reflects the full amortization of ALCOSAN’s existing debt as of 2041. The
Residential Indicator trend line is shown on Figure 11-8.
Figure 11-8: Residential Indicator Trend Line through 2046
2.5%
2.0%
1.5%
1.0%
0.5%
0.0%
2012
2022
2032
2042
11.5.6 Analysis of Impacts
Household Impacts: As shown in Figure 11-9, the implementation of the Recommended 2026
Plan and the related municipal improvements will result in a dramatic increase in the number
of households within the ALCOSAN service area for whom annual wastewater costs will
constitute a high burden. The number of households in the service area with a high burden will
increase from about 4,600 households (1%) to 214,000 households (65%). The number of
households with a low burden will decrease from 133,000 households (41%) to 7,500 households
(2%).
11-49
Figure 11-9: Burden Level of Households
(Number of Households Rounded to Nearest 10,000)
300,000
Low Burden
Number of Households
Medium Burden
250,000
200,000
150,000
High Burden
100,000
50,000
2050
2048
2046
2044
2042
2040
2038
2036
2034
2032
2030
2028
2026
2024
2022
2020
2018
2016
2014
2012
0
The household impact can also be evaluated in terms of a cumulative frequency distribution of
residential indicators across the service. A cumulative frequency distribution of the residential
indicators by household is shown on Figure 11-10. Also shown are the relative number of
households by residential indicator brackets (0%-0.5%, etc.).
The data underlying Figure 11-10 reveal the following statistics relating to the impact of the
Recommended 2026 Plan:

The RI for the highest burden quartile of the households within the ALCOSAN service
population is projected to be 2.7%. There are 81,500 households within the quartile, with
a population of approximately 199,000. This population is analogous to the cities of Des
Moines, Iowa; Richmond, Virginia; and Akron, Ohio;

The RI will exceed 2.5% of household income for approximately 240,000 residents within
the ALCOSAN service area, representing a population equivalency of the cities of
Madison, Wisconsin; Orlando, Florida; and Norfolk, Virginia; and

The RI will exceed 3.0% of the household income for approximately 160,000 residents,
representing the population equivalent of Chattanooga, Tennessee and Jackson,
Mississippi.
11-50
80
100%
70
90%
80%
60
70%
50
60%
40
50%
30
40%
30%
20
20%
10
10%
-
0%
Residential Indicator
Households in Burden Levels
Cumulative Percentage
The household level impacts can be shown geographically by Census block groups.
Figure 11-11 maps the projected 2027 residential indicators amongst the Census block groups
within the ALCOSAN service area, with seven gradations of residential indicator.
11-51
Cumulative Percentage
Households (thousands)
Figure 11-10: Residential Indicator Cumulative Frequency Analysis (Projected 2027)
Figure 11-11: Projected 2027 Residential Indicators by Census Block Group
11-52
Municipal Analysis: The above analysis was based upon the aggregated ALCOSAN service
area, including uniform ALCOSAN rates and the service-area-wide weighted average
municipal collection system cost. A service-area-wide uniform allocation of the projected $530
million (current) in municipal upgrades was also included.
A similar analysis can be performed at the municipal level. Uniform ALCOSAN costs per
household are again utilized, along with the projected municipal collection system charges for
current municipal systems, based upon extrapolation of the current municipal charges. An
allocation, by necessity uniform, of the projected municipal upgrades is also made.
The results of the municipal level analysis is provided on Table 11-13.
Table 11-13: Projected Municipal Cost Per Typical Household with Recommended Plan
Municipality
Total Cost
per
Household
Projected
Municipal MHI
(2027)
Residential
Indicator
(2027)
EPA Score
1
Aspinwall Borough
$1,180
$82,300
1.4%
Mid-Range
2
Avalon Borough
$1,290
$53,400
2.4%
High
3
Baldwin Borough
$1,500
$85,600
1.8%
Mid-Range
4
Baldwin Township
$1,450
$98,500
1.5%
Mid-Range
5
Bellevue Borough
$1,230
$56,500
2.2%
High
6
Ben Avon Borough
$1,010
$108,000
0.9%
Low
7
Ben Avon Heights Borough
$1,010
$154,500
0.7%
Low
8
Bethel Park, Municipality of
$1,290
$93,500
1.4%
Mid-Range
9
Blawnox Borough
$1,260
$57,300
2.2%
High
10
Braddock Borough
$1,160
$33,100
3.5%
High
11
Braddock Hills Borough
$1,170
$45,700
2.6%
High
12
Brentwood Borough
$1,490
$68,400
2.2%
High
13
Bridgeville Borough
$1,250
$58,300
2.1%
High
14
Carnegie Borough
$1,720
$66,200
2.6%
High
15
Castle Shannon Borough
$1,480
$72,200
2.0%
High
16
Chalfant Borough
$1,460
$72,700
2.0%
High
17
Churchill Borough
$1,310
$125,800
1.0%
Mid-Range
18
Collier Township
$1,440
$86,600
1.7%
Mid-Range
19
Crafton Borough
$1,690
$66,900
2.5%
High
20
Dormont Borough
$1,450
$70,900
2.0%
High
21
East McKeesport Borough
$1,250
$61,400
2.0%
High
11-53
Municipality
Total Cost
per
Household
Projected
Municipal MHI
(2027)
Residential
Indicator
(2027)
EPA Score
22
East Pittsburgh Borough
$1,250
$35,700
3.5%
High
23
Edgewood Borough
$1,370
$88,400
1.5%
Mid-Range
24
Emsworth Borough
$1,450
$80,600
1.8%
Mid-Range
25
Etna Borough
$1,260
$52,100
2.4%
High
26
Forest Hills Borough
$1,360
$82,400
1.7%
Mid-Range
27
Fox Chapel Borough
$1,350
$324,300
0.4%
Low
28
Franklin Park Borough
$1,720
$195,200
0.9%
Low
29
Green Tree Borough
$1,300
$102,800
1.3%
Mid-Range
30
Heidelberg Borough
$1,550
$53,400
2.9%
High
31
Homestead Borough
$1,410
$36,400
3.9%
High
32
Indiana Township
$1,660
$131,100
1.3%
Mid-Range
33
Ingram Borough
$1,380
$68,800
2.0%
High
34
Kennedy Township
$1,110
$87,100
1.3%
Mid-Range
35
Kilbuck Township
$1,450
$131,000
1.1%
Mid-Range
36
McCandless Township
$1,220
$108,500
1.1%
Mid-Range
37
McDonald Borough
$1,590
$65,700
2.4%
High
38
McKees Rocks Borough
$1,230
$33,500
3.7%
High
39
Millvale Borough
$1,250
$52,200
2.4%
High
40
Monroeville, Municipality of
Mount Lebanon, Municipality
of
$1,360
$92,000
1.5%
Mid-Range
$1,400
$115,400
1.2%
41
Mid-Range
42
Mount Oliver Borough
$1,780
$47,000
3.8%
High
43
Munhall Borough
$1,330
$66,200
2.0%
High
44
Neville Township
$1,580
$62,600
2.5%
High
45
North Braddock Borough
$1,460
$36,000
4.1%
High
46
North Fayette Township
$1,060
$100,400
1.1%
Mid-Range
47
North Huntingdon Township
$1,480
$76,700
1.9%
Mid-Range
48
North Versailles Township
$1,510
$33,100
4.6%
High
49
Oakdale Borough
$1,350
$86,800
1.6%
Mid-Range
50
O'Hara Township
$1,160
$126,500
0.9%
Low
51
Ohio Township
$1,290
$138,200
0.9%
Low
52
Penn Hills, Municipality of
$1,740
$65,100
2.7%
High
53
Penn Township
$1,390
$98,200
1.4%
Mid-Range
54
Peters Township
$1,250
$115,000
1.1%
Mid-Range
11-54
Municipality
Total Cost
per
Household
Projected
Municipal MHI
(2027)
Residential
Indicator
(2027)
EPA Score
55
Pitcairn Borough
$1,170
$59,100
2.0%
Mid-Range
56
Pittsburgh City
$1,290
$55,700
2.3%
High
57
Pleasant Hills Borough
$1,280
$116,500
1.1%
Mid-Range
58
Plum Borough
$1,330
$112,600
1.2%
Mid-Range
59
Rankin Borough
$1,130
$25,400
4.4%
High
60
Reserve Township
$1,190
$86,000
1.4%
Mid-Range
61
Robinson Township
$1,360
$53,700
2.5%
High
62
Ross Township
$1,230
$87,700
1.4%
Mid-Range
63
Rosslyn Farms Borough
$1,590
$185,700
0.9%
Low
64
Scott Township
$1,160
$80,100
1.4%
Mid-Range
65
Shaler Township
$1,260
$92,900
1.4%
Mid-Range
66
Sharpsburg Borough
$1,150
$49,300
2.3%
High
67
South Fayette Township
$1,380
$102,300
1.3%
Mid-Range
68
Stowe Township
$1,450
$49,700
2.9%
High
69
Swissvale Borough
$1,220
$60,100
2.0%
High
70
Thornburg Borough
$1,010
$177,400
0.6%
Low
71
Trafford Borough
$1,470
$58,800
2.5%
High
72
Turtle Creek Borough
$1,190
$56,200
2.1%
High
73
Upper St. Clair Township
$1,550
$139,900
1.1%
Mid-Range
74
Verona Borough
$1,010
$66,400
1.5%
Mid-Range
75
Wall Borough
$1,310
$50,400
2.6%
High
76
West Homestead Borough
$1,260
$75,600
1.7%
Mid-Range
77
West Mifflin Borough
$1,550
$68,200
2.3%
High
78
West View Borough
$1,690
$75,900
2.2%
High
79
Whitaker Borough
$1,280
$57,400
2.2%
High
80
Whitehall Borough
$1,520
$96,000
1.6%
Mid-Range
81
Wilkins Township
$1,260
$69,900
1.8%
Mid-Range
82
Wilkinsburg Borough
$1,140
$44,200
2.6%
High
83
Wilmerding Borough
$1,260
$35,300
3.6%
High
11-55
The impact of the Recommended 2026 Plan and related municipal improvements on the
municipal costs per household can be summarized as follows:
•
The residential indicator is projected to exceed 2% of median household income in 40 of
the 83 ALCOSAN municipalities;
•
The residential indicator is projected to exceed 2.5% of median household income in 19
municipalities;
•
The RI is projected to exceed 3% of median income in 9 municipalities;
•
The RI is projected to exceed 4% in 3 municipalities;
•
The projected RI for the City of Pittsburgh is 2.3%;
•
Fox Chapel Borough is projected to have the lowest RI at 0.4%; and
•
North Versailles is projected to have the highest RI at 4.6%.
It should be noted that the results of this analysis would likely change upon the inter-municipal
allocation of the municipal capital improvements. The projected 2027 residential indicator by
municipality is shown on Figure 11-12.
11-56
Figure 11-12: Projected 2027 Residential Indicators by Municipality
11-57
11.5.7 Uncertainties
As noted elsewhere in this document, key variables beyond ALCOSAN’s control reduce the
accuracy of long term financial projections, including household wastewater costs. Through
sensitivity analysis, ALCOSAN has identified six factors that could materially affect the future
residential indicator. These include: the residential share of wastewater costs, total capital cost,
capital cost inflation, operations and maintenance cost inflation, income growth, and bond
interest rates.
A default, best, and worst case scenario were simulated in order to determine the possible range
of regional affordability the service area. Table 11-14 displays the inputs used to generate the
best, default, and worst case scenarios for the residential indicator. The isolated effect of each
input variable on the residential indicator (in 2027) is shown in the last two columns. Changes
in total program capital cost have the highest impact on the residential indicator, followed by
income growth rate and O&M Cost inflation.
Table 11-14: Sensitivity Analysis Variables
Variable Input
Default Case
Input Range
Tested
Change in RI
2027 Best Case
2027 Worst Case
Capital Cost Inflation
3.1%
2.60% - 3.67%
-0.04%
+0.05%
O&M Cost Inflation
4.0%
3.40% - 4.50%
-0.09%
+0.09%
Income Growth
2.5%
2.10% - 2.70%
-0.06%
+0.13%
ALCOSAN Bond Interest Rate
6.0%
5.00% - 7.00%
-0.06%
+0.07%
Program Capital Costs ($ billions)
$2.0
$1.4 - $3.0
-0.25%
+0.42%
The default scenario results in a projected residential indicator of 2.0% for 2027 and 1.9% for
2046. In 2027, a best and worst case scenario for all inputs suggests the possibility of a
residential indicator as low as 1.5% and as high as 3.1%. The input value trends continue over
time, resulting in greater uncertainty as the time horizon expands, as shown by Figure 11-13.
11-58
Figure 11-13: Residential Indicator Sensitivity to Uncontrollable Variables
3.50%
3.00%
2.50%
2.00%
1.50%
1.00%
0.50%
Worst Case
Default Case
Best Case
0.00%
2010
11.5.8
2015
2020
2025
2030
2035
2040
2045
2050
Phase 2 Analysis – Financial Capability Assessment
In this Sub-Section, the analysis of the six “financial capability” indicators that were presented
in sub-section 6.3 will be refined to reflect the projected impacts of the estimated $2 billion in
new public investments represented by the Recommended 2026 Plan and the related municipal
improvements. The six financial indicators reflect the approach used by the municipal bond
rating agencies to evaluate municipal general obligation bonds, the strength of which is
evaluated based upon property taxation. As a municipal authority, ALCOSAN utilizes revenue
bonds, which are evaluated against the projected revenues stream from the user charges for
services rendered. Therefore, the applicability of financial indicators 2 through 6 is limited to
the municipalities.
Indicator 1 - Bond Ratings
ALCOSAN Bond Ratings – ALCOSAN recently received a rating of ‘A’ long-term with a stable
outlook from Standard & Poor’s Rating Services and A1 from Moody’s for its series 2011 sewer
revenue refunding bonds. Standard & Poor’s also recently affirmed its ‘A’ rating on
ALCOSAN’s outstanding debt. The ‘A’ revenue bond rating is the lowest that qualifies for a
“strong” rating for the EPA bond rating financial capability indicator.
The Wet Weather Program and current renewal and replacement levels will require ALCOSAN
to increase its debt service payments over 300% to around $170 million per year. Further, the
11-59
raw amount of debt ALCOSAN will take on during the implementation period, over $2 billion
including existing renewal and replacement needs, will substantially increase ALCOSAN’s debt
to equity ratio. The risks associated with carrying such a large amount of debt will put
downward pressure on ALCOSAN’s current bond ratings. Nonetheless, ALCOSAN remains
committed to maintaining its historically favorable bond ratings through timely and sufficient
rate increases as necessary and the maintenance of reserve funds adequate to maintain their
ratings. The ALCOSAN score under the EPA criteria will remain “strong” for a numeric score
of 3.
Municipal Bond Ratings – Moody’s rating methodology for municipal general obligation bonds
is based off of analysis of four key rating factors: economic strength, financial strength,
management and governance, and debt profile. Moody’s credit rating assessment weights
economic strength at 40% of its calculation, emphasizing the property tax base as the source of
bondholder security and the economy as the source of leverage that supports municipal
operations. The debt burden, debt structure and composition, and debt management, of a
municipality is generally weighted at 10%.
Moody’s regularly monitors absolute changes by seeking significant multi-year trends in annual
financial disclosure documents and notes that “while economic factors carry the greatest weight
in Moody’s rating assessments, we have seen that over time, financial changes are most likely to
drive rating movements”11-10. The amount of wet weather program spending marks a
substantial financial change for many municipalities in the ALCOSAN service area and is likely
to place downward pressure on Municipal Bond Ratings.
As described in Sub-Section 6.3, eighteen of the largest municipalities within the ALCOSAN
service area have rated debt, for which the population weighted average of numeric score was
2.5, or a “mid-range” EPA rating. The remaining 65 municipalities do not have bond ratings, as
is typical for small towns.
It is anticipated that bond ratings will worsen over the span of the Wet Weather program.
However, the current bond rating EPA capability score is at 2.49, the uppermost “mid-range”
value, and ratings changes are not expected to be so severe as to change the score for this
indicator to “weak”. Many of these smaller municipalities are also classified as subject to a
“high” burden in the affordability analysis and are also rated as weak under the other financial
criteria as detailed in Section 6 of this document. In aggregate, the un-rated municipalities
would likely receive a weak rating if there were to be rated based upon current conditions. This
assessment, coupled with the half of a billion dollars in new capital costs suggests that an
overall weak rating for the municipalities en-mass would be reasonable.
Combining the ALCOSAN and municipal bond rating scores, an overall service area rating of
mid-range and an EPA numeric score of 2 is assigned.
11-10
Moody’s U.S. Public Finance- general Obligation Bonds Issued by U.S. Local Governments Rating
Methodology page 20.
11-60
Indicator 2 – Municipal Debt Burden
The EPA financial capability assessment considers overall net debt as a percent of property
value a measure of the local government’s ability to issue additional debt. The current overall
net debt calculated in section 6.3.1 was found to be $3.38 billion for the service area and total
market value of real estate was assessed at $51.6 billion. This results in a current populationweighted debt burden value of 6.4%, a “weak” financial capability rating. If the municipal
burden of Wet Weather costs were issued in only general obligation debt, this would result in a
increase of the indicator score to more than 7.5%. Since there are 15 municipal authorities in the
service area which would issue revenue bonds, the actual future burden will be somewhere
between 6.4% and 7.6%.
It should be noted that the cutoff for a “weak” indicator score for municipal debt burden is 5%.
A debt burden around 7.5% could rightfully be called “extremely weak” and have a larger
impact on the financial capability score, if the EPA criteria allowed for this magnitude to be
captured.
Indicator 3 – Unemployment Rate
Under the EPA methodology, unemployment rates that are within one percentage point of the
national average are “mid-range”. The current (April 2012) unemployment rate in the
ALCOSAN service area is eight-tenths of a percentage point lower than the national average.
This proximity to the national unemployment rate is consistent with the trend over the past two
decades during which the Pittsburgh area closely tracked the national rate of unemployment.
The total economic output of Allegheny County in 2010 was estimated at $36 billion.11-3 The
$2.0 billion in wet weather spending through the eleven year period of 2014 – 2026 would be
equivalent to around 0.5% of Allegheny County economic activity over the same period. While
this amount of activity is significant, it is unclear what the direct effect on service area
unemployment rate and MHI will be.
Indicator 4 – Median Household Income
Like the unemployment rate, EPA evaluates this criterion against the national value. EPA
suggests that a local median household income that is within 25% of the national median
household income is “mid-range” in their metric. As documented in Sub-Section 6.3, the
median household income within the ALCOSAN service area is approximately 85% of the
national figure. Since 1990, the in the greater Pittsburgh region has grown at around a 2.5%
rate. This compares to a national income growth rate of around 2.6%11-4. If this close correlation
continues through the planning period, the MHI in the ALCOSAN service area will remain with
the + 25% range.
11-3
2010 Census data.
11-4
State Median Household Income Patterns: 1990 – 2010 by Proximity.com based upon US Census
American Community Survey.
11-61
Indicator 5 – Property Tax Burden
The property tax burden indicator is derived by dividing property tax revenue by the assessed
full market value of taxable property. Total 2009 expected property tax revenue collected for
the region was around $1.11 billion and total 2009 full market property value of the region was
approximately $52 billion, resulting in a calculated property tax burden of 2.14%, a Mid-Range
score.
A maximum annual debt service payment financed by additional property tax revenue was
estimated by assuming that all WWP general obligation debt would be issued in one year with
an interest rate of 6.5% and 20 year bond term. Under this assumption, additional property
taxes of around $49 million would be levied for the service area at the peak of Wet Weather
spending. Using this analysis, the financial capability value of property tax burden for the
region would increase to 2.24%, still within the EPA “mid-range”.
Indicator 6 – Property Tax Collection Rate
The current property tax collection rate is 93%, which corresponds to a financial capability score
of “Weak”, the lowest capability score. Property tax collection rates are not anticipated to
improve in light of increased taxes used to finance municipal borrowing for Wet Weather
Improvements.
11.5.9 Financial Capability Matrix Score and Implications
Based on the analysis above, despite the level of investment required by the Wet Weather
Program, it is anticipated that the overall financial capability score will remain mid-range after
full implementation. The lack of change to the financial capability score is more indicative of
limitations of the EPA methodology when applied to a diverse service area such as
ALCOSAN’s. For example, the exclusion of all revenue debt from the net debt calculation
removes ALCOSAN’s overlapping debt and municipal authority debt from the consideration of
the municipal financial capability. Moreover, several of the criteria (municipal debt burden and
tax collection rate) are already weak under the EPA criteria; however there is no provision
under the EPA scoring to quantify the magnitude of the weaknesses. Nonetheless, the large
capital requirements for the region will have significant impacts which may be described
qualitatively as shown on Table 11-15.
11-62
Table 11-15: Impacts on the Financial Capability Indicators
Qualitative Impacts
Financial Capability Indicator
Score
ALCOSAN
Municipal
1
Bond Ratings
2.0
Worse
Worse
2
Debt Burden
1.0
N/A
Worse
3
Unemployment Rate
2.0
N/A
Unknown – potential improvement
4
Median Household Income
2.0
N/A
Unknown – potential improvement
5
Property Tax Burden
2.0
N/A
Worse
6
Property Tax Collection Rate
1.0
N/A
Worse
Overall Score
1.67
(Sum of the scores divided by six)
Implementing the Recommended 2026 Plan and the related municipal improvements will result
in a high burden Residential Indictor. As seen in Table 11-16, the Financial Capability Score of
1.67 falls into the bottom of the EPA “mid-range”, being 11% above the trigger score for a
“weak” rating. Therefore, the overall matrix score is “high burden.”
Table 11-16: Post Implementation Financial Capability Matrix
Residential Indicator (Cost Per Household as a % MHI)
Financial Capability
Indicators
Low (<1.0%)
Mid-Range (1.0 - 2.0%)
High (>2.0%)
Weak (<1.5)
Medium Burden
High Burden
High Burden
Mid-Range (1.5 - 2.5)
Low Burden
Medium Burden
High Burden
Strong (>2.5)
Low Burden
Low Burden
Medium Burden
11-63
11.6 Institutional Assessment
11.6.1 ALCOSAN’s Authority to Implement the Plan
ALCOSAN is a body corporate and politic created in March 1946, under Pennsylvania
Municipality Authorities Act (Act). The Authority is authorized to collect, transport, treat and
dispose of sewage in Allegheny County, and certain adjacent areas. Key powers11-14 under the
Act include:

To have existence for a term of 50 years and for such further period or periods as may
be provided in articles of amendment;

To sue and be sued;

To acquire, purchase, hold, lease as lessee and use any franchise, property

To finance projects by loan, mortgages, security agreements or any other instruments;

To make bylaws for the management and regulation of its affairs;

To fix, alter, charge and collect rates and other charges in the area served by its facilities
at reasonable and uniform rates;

To borrow money, make and issue negotiable notes, bonds, refunding bonds and other
evidences of indebtedness or obligations;

To make contracts and to execute all instruments necessary or convenient for the
carrying on of its business;

To pledge revenues of the authority as security for obligations of the authority;

To have the power of eminent domain;

To do all acts and things necessary or convenient for the promotion of its business and
the general welfare of the authority to carry out the powers granted to it; and

To contract with any municipality, corporation or a public authority;
Under the Act, ALCOSAN may not pledge the credit or taxing power of the Commonwealth or
its political subdivisions; moreover ALCOSAN’s financial obligations are not obligations of the
Commonwealth or its political subdivisions. Pursuant to the Act, ALCOSAN appears to have
sufficient powers to implement the Recommended 2026 Plan as described in this document.
ALCOSAN’s tenure currently extends to the year 2060 as amended in preparation for issuing
the 2010 new construction bonds.
11.6.2 Limits to ALCOSAN’s Authority
While ALCOSAN has the requisite authority to build new conveyance, storage and treatment
facilities; the 2008 consent decree, Pennsylvania statute and existing service contracts limit its
11-14 Condensed from 53 Pa.C.S.A. 5607(d).
11-64
ability to mandate or implement the reduction of wet weather flows from the municipal
collection systems through green infrastructure or other source reduction strategies.
Under its consent decree, ALCOSAN is required to design and construct facilities sufficient for
a flow volume equivalent to all of the flow that is generated in the municipal sanitary sewer
systems and to design and to construct facilities sufficient to capture and treat all flows
conveyed from the combined sewered municipalities to meet the requirements of the Clean
Water Act, consistent with EPA’s Combined Sewer Overflow Policy. The consent decree
precludes ALCOSAN from planning for source reduction from the municipal collection systems
unless a municipality has constructed or is legally committed under an Enforceable Document
to construct facilities or PaDEP and EPA have determined that the municipality can comply
with the Clean Water Act through means other than conveying the wet weather flow to
ALCOSAN’s conveyance interceptor system.11-15
Pursuant to their respective Administrative Consent Orders (ACO) with the Allegheny County
Health Department (sanitary sewered municipalities) or the Consent Orders and Agreements
(COA) with the PaDEP (combined sewered municipalities), each municipality required to
develop a Feasibility Study to address its respective wet weather strategy. The Feasibility
Studies, which would be the mechanism through which the municipalities would propose
source controls, are not due under the orders until six months after ALCOSAN submits its Wet
Weather Plan in January of 2013.
ALCOSAN has limited institutional abilities to implement source reduction projects within the
municipalities. As an authority, ALCOSAN does not have control over the municipal codes
and policies covering zoning, building codes, stormwater management, etc. that would be
necessary to implement an integrated source reduction program. The tight implementation
timeframe that is mandated by the consent decree coupled with ALCOSAN’s lack of the
jurisdictional controls in the municipalities necessary to assure the timely implementation of
municipal source reduction also push towards regional wet weather control.
ALCOSAN’s municipal service agreements (detailed in Section 6.6) also restrict ALCOSAN’s
ability to mandate municipal source reduction. The agreements provide for uniform sewage
charges throughout the service area based upon metered or estimated water consumption.
There were no provisions for metering actual wastewater flows to the ALCOSAN interceptor
system which would have been infeasible at the time and remains infeasible due to the large
number of points of connection with the ALCOSAN system and the large number of
intermunicipal connections. In addition, with the exception of the more recent agreements as
detailed in Section 6.6, the service agreements imposed no upper limits on the quantity or rate
of flow arriving at the points of connection with ALCOSAN.
11.6.3 Municipal Institutional Capacities
The municipal feasibility studies will address municipal overflows in terms of additional
conveyance capacities downstream to points of connection with the ALCOSAN regional
11-15
See paragraphs 17(a) and 18(b) of the ALCOSAN consent decree (U.S. District Court – Western PA
District Civil Action 07-0737.
11-65
conveyance system through local control facilities or through source reductions. The municipal
orders require that each municipality establish:
“…with ALCOSAN the quantity and rate of sewage flow from the Municipality that
ALCOSAN will be able to retain, store, convey and treat upon implementation of a Wet
Weather Plan and/or LTCP” (by ALCOSAN)11-16
The ACOs and COAs do not include provisions addressing:

The basis and mechanism for agency approval of the quantities and rates of sewage
flows from the municipalities vis-à-vis ALCOSAN’s planning projections in the WWP;

The regulatory mechanism for the coordination and finalization of inter-municipal
design flows between the municipalities sharing points of connection with the
ALCOSAN regional conveyance system or with ALCOSAN;

PaDEP and ACHD mechanisms to enforce the design flow quantities and flow rates
from the municipalities that have served as the basis of ALCOSAN’s wet weather
planning and will serve as ALCOSAN’s final basis of design.
ALCOSAN expects that PaDEP and ACHD will address outstanding regulatory and
institutional issues relating to the municipal wet weather control efforts through follow-up
administrative orders, NPDES permit requirements, Act 537 planning or other appropriate
enforceable mechanism. The manner in which these issues are addressed in the years ahead
may have an impact on the Wet Weather Plan, and will be addressed as part of the adaptive
management strategy described in Section 11.7.
As outlined in Section 6.6 of this document, ALCOSAN’s eighty-three customer municipalities
appear to have the legal powers and responsibilities to provide adequate wastewater services
within their jurisdictions to implement their respective municipal feasibility studies. The
upgrades to the municipal collection systems required under their respective feasibility studies
may however pose difficulties for the smaller municipalities. The relatively high level of
turnover of municipal governing boards and their appointed managers can limit institutional
commitment to long term projects such as sewer system upgrades.
Of the 83 municipalities within the service area, 45 are physically connected directly to
ALCOSAN’s regional interceptor system. The remaining 38 municipalities’ sewers connect to
downstream municipalities who are connected to the ALCOSAN system. Of the 45
municipalities that flow directly into the ALCOSAN system, 39 convey wastewater from
upstream municipalities. Due to the jurisdictions over watersheds and sewersheds being
fragmented between the many small municipalities, the institutional capacity to implement
intermunicipal projects that may be recommended in the feasibility studies is expected to be
problematic.
11-16
Paragraph 14(c)(i) of the PaDEP Consent Order and Agreement and paragraph 15(c)(i) of the ACHD
Administrative Consent Order
11-66
11.7
Adaptive Management
ALCOSAN is committing through this WWP to implement a multi-billion dollar public
investment program over a time period that spans decades. ALCOSAN’s future regulatory
compliance will be based upon the timely implementation of new wastewater systems and their
successful operation in a climatic, economic and social environment which is largely
unknowable and uncontrollable by ALCOSAN, the municipalities, their wastewater authorities
or regulatory agencies. In short, ALCOSAN, its customer municipalities and the agencies must
proceed, despite uncertainties and risks, armed with their best professional judgments and
good faith and expecting proactive refinements as the implementation of the WWP progresses.
This sub-section of the WWP presents an identification of trends and potential events beyond
ALCOSAN’s control that could materially affect the scope or performance of wet weather
controls that otherwise would be adequate to meet the requirements of the Clean Water Act,
consistent with EPA’s Combined Sewer Overflow Control Policy. This sub-section also
describes the adaptive management process that will be used to track implementation progress,
and to address potential unanticipated trends and events. This adaptive management process
may result in periodic amendments to the Wet Weather Plan, in coordination with the
regulatory agencies.
The development, analysis, selection and anticipated implementation of wet weather control
strategies that are documented in this Plan are premised on ALCOSAN’s best understanding
and professional judgment as to current and future conditions consistent with the provisions of
the CD. The wet weather control facilities proposed in Section 10 of this Wet Weather Plan have
been developed for the foreseeable range of conditions through the planning period (2046).
Such current and future conditions bound the ranges for important variables used in the
development of the Plan, including but not limited to hydrologic, climatic, regulatory,
demographic and economic parameters documented elsewhere in this document.
11.7.1 Factors Beyond ALCOSAN’s Control
Clean Water Act: Changes to the Clean Water Act or federal regulations promulgated pursuant
thereto, the CSO Control Policy, The Pennsylvania Clean Streams Law and associated state
administrative code, designated uses of the ALCOSAN receiving waters and associated water
quality standards which would materially affect the scope, cost or schedule of ALCOSAN’s
Recommended 2026 Plan will result in a review and modification of the Plan in coordination
with the regulatory agencies.
Other Emergent Regulatory Requirements: There are a number of emergent Federal
regulatory initiatives which could materially affect the operation and resources of
municipalities and regional wastewater authorities such as ALCOSAN. Key examples of
potential regulatory mandates which cannot be fully accounted for in the development of this
Wet Weather Plan include the following:
Revised Water Quality Standards – The USEPA recently released for scientific views draft
recreational water quality criteria which incorporate the latest research and science linking
illness and fecal contamination in recreational waters since EPA’s last issued recommended
11- 67 ALCOSAN Wet Weather Plan
water quality criteria for recreation in 1986. The USEPA anticipates publishing final
recreational criteria recommendations in the fall of 2012. If PaDEP revises water quality
standards to reflect EPA’s latest recommendations, the environmental endpoint for which the
WWP was developed will also change. Such a change could materially impact the controls
necessary to comply with the CWA and CSO Policy, warranting a review and revision to the
WWP.
Integrated Municipal Stormwater and Wastewater Planning – USEPA’s Office of Water issued
a memorandum in October of 2011 concerning the achievement of improved water quality
through integrated municipal stormwater and wastewater planning. In May of 2012, USEPA
finalized an Integrated Municipal Stormwater and Wastewater Planning Approach Framework
that provides further guidance in developing and implementing effective integrated plans
under the CWA. ALCOSAN and its customer municipalities anticipate working with the
USEPA and PaDEP in addressing all NPDES obligations in an orderly manner to identify costeffective and proactive solutions and to implement the most important projects first. As this
framework is implemented by the regulatory agencies, modifications to the scope, schedule and
priorities of wet weather controls that are identified in this Wet Weather Plan might emerge.
Total Maximum Daily Loads – Total Maximum Daily Loads (TMDL) rulings applicable to
ALCOSAN receiving waters that are finalized after the development of ALCOSAN’s draft Wet
Weather Plan could materially affect the scope, schedule and water quality compliance strategy
of the Plan depending upon the allocation of the subject pollutant to combined sewer overflow
and sanitary sewer overflow discharges in the respective TMDL.
Municipal Stormwater Regulations – Nationally, there is movement to utilize the Phase II
municipal stormwater permits held by the sanitary sewered municipalities as a mechanism to
implement TMDLs through the use of wasteload allocations to establish stormwater end-ofpipe effluent limits. The timing of municipal implementation of their respective SSO control
Feasibility Studies might also be impacted if integrated stormwater and wastewater planning
were to determine that addressing stormwater impacts had greater or timelier water quality
benefits than the SSO controls. Applied to the ALCOSAN sanitary sewered municipalities, new
stormwater regulatory requirements would affect the municipalities’ financial capabilities if
new stormwater infrastructure or capital-intensive best management practices were to be
required.
Nutrient Limits11-17 – There is increased awareness of and concern about the hypoxic conditions
within the Gulf of Mexico attributable to nutrient loadings from the Mississippi River
watershed which could lead to additional nutrient discharge limitations on publically owned
treatment works (POTWs) or other forms of regulatory controls. For example, the Ohio River
Valley Water Sanitary Commission (ORSANCO)’s Ohio River Sub Basin Committee for
Reduction of Hypoxia in the Gulf of Mexico recommended that POTWs be upgraded to Biologic
Nutrient Removal (BNR) or Enhanced Nutrient Removal (ENR) technologies. Paralleling this
potential development, there is movement in some states towards numeric water quality criteria
for nutrients. Such developments and corresponding upgrades to the ALCOSAN wastewater
11-17 ORSANCO: October 2009 Commission and Technical Committee Meeting Presentations
treatment plant could constitute a significant capital investment that would erode affordability
and financial capability available for wet weather controls.
Sewage Sludge Incineration Rule – On March 21, 2011 EPA promulgated rules transferring the
regulation of sewage sludge incineration (SSI) from Section 112 to Section 129 of the Clean Air
Act. This change required the development of Maximum Achievable Control Threshold
(MACT) standards for SSIs. The final rule set limits for nine pollutants under section 129 of the
Clean Air Act: Cadmium, carbon monoxide, hydrogen chloride, lead, mercury, nitrogen oxides,
particulate matter, polychlorinated dibenzo-pdioxins and polychlorinated dibenzofurans, and
sulfur dioxide. The technical and cost implications of the MACT standards on ALCOSAN’s
Resource Recovery Facility have not been determined but could represent a significant capital
investment that would erode affordability and financial capability available for wet weather
controls.
POTW Greenhouse Gas Management – The USEPA currently regulates greenhouse gases
(GHG) emissions from industrial wastewater treatment plants in their GHG mandatory
reporting regulation. Should POTWs be regulated to control GHG from stationary power
sources (e.g. sewage sludge incineration) or treatment processes (e.g. aeration tanks),
ALCOSAN could face future capital and operation & maintenance costs which might erode
affordability and financial capability available for wet weather controls.
Implications – If and when federal or state requirements covering these issues and such
requirements pose a material impact (positive or negative) on ALCOSAN’s ability to implement
the Recommended Alternatives (Section 10) pursuant to the Implementation Plan (Section 11),
ALCOSAN will coordinate its adaptive management strategies with the regulatory agencies.
Climate Change: Water resource impacts of climate change have been increasingly
documented in various governmental, industry and academic institution research. Western
Pennsylvania lies at the interface between the Northeastern and Midwestern regions of the
United States, and the potential effects are a combination of the two regions. Among the most
significant impacts directly applicable to wet weather discharge controls that have been
projected for Northeastern and Midwestern US in next century include11-18:

Increases in precipitation and changes to seasonal variation of precipitation;

Increases in frequency and intensity of extreme precipitation events;

Increased air temperature leading to greater evaporation rates and earlier snowmelt;

Changes in soil moisture and surface runoff; and

Greater in-stream flow uncertainty.
The magnitude and cumulative effects of these climatologic changes vis-à-vis the currently
foreseeable range of conditions through the planning period (2046) is uncertain. ALCOSAN will
integrate evolving climate change predictions into its planning and design efforts. Through its
ongoing flow monitoring and modeling activities, ALCOSAN will evaluate precipitation
11-18
Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C.
Peterson,(eds.). Cambridge University Press, 2009.
patterns and the system’s hydraulic responses thereto to identify divergences from the current
understanding that could materially affect the design or performance of the wet weather
controls.
If ALCOSAN becomes aware of changes to wet weather flow characteristics due to climate
change that could materially change the planning, design construction or performance of its
proposed wet weather controls, it will coordinate with regulatory agencies as to appropriate
steps to be taken, including as appropriate changes to the Wet Weather Plan. Examples of such
changes include the predicted or observed variations which exceed the design or operating
ranges of the proposed facilities.
Changes in Municipal Flow Estimates: The wet weather control alternatives evaluated and
recommended in this Wet Weather Plan are based in part upon the relevant information
obtained by ALCOSAN from the Customer Municipalities pursuant to Section VI, Subsection N
(Coordination with Customer Municipalities) of the ALCOSAN consent decree. As detailed
elsewhere in this document, ALCOSAN has utilized municipal and regional planning agency
population and development projections in projecting future system design flow characteristics.
However there are a number of uncertainties regarding future municipal flows.
Future municipal flows will be dependent on actual population growth and actual expansion of
the area served by the sewers. These flows may be higher or lower than what was assumed for
the sizing of wet weather controls. As a result, design flows for some ALCOSAN facilities may
need to be revised if growth projections are revised at a future date.
Another uncertainty regarding future municipal flows is a result of the timing of the Feasibility
Studies. The Feasibility Studies to be developed by ALCOSAN’s customer municipalities
pursuant to their respective Administrative Consent Orders (sanitary sewered municipalities)
or Consent Order and Agreement (combined sewered municipalities) are not due to be
submitted to the regulatory agencies until six months after the date of submittal of ALCOSAN’s
Wet Weather Plan. As a result, this Wet Weather Plan is based on preliminary municipal plans
and flow rates. The municipal plans and projected flow rates will not be finalized until each of
these Feasibility Studies is approved by the regulatory agencies. ALCOSAN and the
municipalities have coordinated concerning municipal flow projections throughout the
development of this WWP. However, as a result of the timing of the completion of the
municipal feasibility studies, the design approaches to some ALCOSAN wet weather controls
that were described in Section 10 of this WWP might need to be revised.
Given the timeframe of the Municipal Feasibility Studies, this Wet Weather Plan has also been
developed with limited utilization of the provisions of consent decree paragraphs 17(b)(i) and
(ii) or 18(a) )(i) and (ii) which provide flexibility for ALCOSAN to account for reductions in
municipal flows to ALCOSAN due to municipal conveyance limitations or through
municipality based control or treatment facilities.
Notwithstanding the above uncertainties, it is ALCOSAN’s intention to ultimately utilize the
municipal flow rates or quantities that are specified in the municipal feasibility studies, as
modified by evolving understanding, as a key basis of design for its wet weather controls.
ALCOSAN's schedule is highly dependent on receiving final flows from the municipalities and
prompt regulatory approval of the feasibility studies and these flows is necessary for
ALCOSAN to stay on schedule. ALCOSAN assumes that the Municipal Feasibility Studies will
include each municipality’s firm and enforceable flow and flow rate projections. For planning
purposes, ALCOSAN is assuming that the municipal feasibility studies will be approved by
PaDEP and ACHD no later than July 31st, 2014. ALCOSAN would consider flow quantities or
rates exceeding the specified municipal bases of design to constitute force majeure under the
provisions of ALCOSAN’s consent decree.
ALCOSAN’s Wet Weather Plan is premised upon the customer municipalities providing
maintenance, renewal and replacement to their respective collection systems that will be
sufficient to maintain or reduce current levels of extraneous flows. ALCOSAN anticipates that
the municipal flow characteristics reported in the municipal feasibility studies will be enforced
as necessary by the Allegheny County Health Department and/or the Pennsylvania
Department of Environmental Protection.
As the municipalities develop their respective wet weather control strategies, it is likely that
some may pursue wet weather flow reduction strategies through such steps as system
rehabilitation, direct stream inflow removals and green infrastructure. These source reduction
efforts would be in response to the estimated costs of providing increased municipal
conveyance to the ALCOSAN system and/or local control facilities as well as in response to the
growing municipal and public appreciation as to the environmental and aesthetic benefits of
incorporating green controls into municipal sewerage. Conversely, ALCOSAN must consider
the risk of increased municipal extraneous wet weather flows (volumes or flow rates) beyond
the reasonable margins of safety that have been assumed in the development of ALCOSAN’s
control alternatives.
If ALCOSAN becomes aware of changes to municipal flow characteristics that could materially
change the planning, design, construction or performance of its proposed wet weather controls,
it will coordinate with the municipalities concerned and with the regulatory agencies as to the
appropriate steps to be taken.
Economic and Demographic Variables: Several economic variables beyond ALCOSAN’s
control could materially affect ALCOSAN’s ability to fully implement the Wet Weather Plan as
outlined in Sections 10 and 11 of this document.
Capital Cost Inflation – As noted in section 7.3.1 of this document, future costs related to the
construction of the recommended control facilities are inflated from the base year at an annual
rate of 3.1%. The Engineering News Record’s Construction Cost Index shows an average annual
increase of 4.9% for the fifty-year period of 1962 through 2011 (inclusive). The standard
deviation for the period was 3%; therefore an inflation rate one standard deviation higher than
the fifty-year average would be 8%. Construction inflation rates above the fifty-year average
would materially impact the implementation schedule of the WWP in conformance with Section
II(c)(8) of the CSO Control Policy.11-19 For example, a $2 billion (current dollar) investment in
wet weather controls would result in a regional residential indicator of approximately 2% of the
median household income in 2027. If inflation were to run at the fifty year average, the same
11-19
59 FR 18694.
current dollar investment would result in a residential indicator of 2.14%. If inflation were to
run at one standard deviation higher than the fifty-year average, the residential indicator would
be around 2.5% of median household income in 2027.
Debt Interest Rates and Other Financing Variables – As also documented in Section 7.3.1, an
assumed interest rate of 6% is used as the base case for future debt service payments for the
Affordability and Financial Capability Assessment related to the recommended wet weather
controls. This rate closely matches the forty-one year (1971 – 2011) average for the Bond Buyer
20 Bond Index of municipal bonds which was 6.24%. The standard deviation of interest rates
for the period was 1.8%, therefore an interest rate one standard deviation higher than the
average would be around 8%. Using an 8% interest rate for a $2 billion (current dollar) program
would result in a regional residential indicator of 2.15% compared to 2.0%. The peak for
municipal bonds during the period occurred in 1982 when the average interest rate was 11.5%.
A $2 billion (current $) program financed through 11.5% bonds would result in a regional
residential indicator of around 2.5%. Material changes to the financial factors impacting the
affordability of the program such as ALCOSAN’s bond rating could also require refinement to
the Plan.
Demographic Changes – As noted in Sections 6.5 and 7.3 of this document, ALCOSAN’s service
population, typical household size and water consumption have all declined over the past
twenty years. Should these trends continue or accelerate during the planning period, the
overall rate base to pay for the wet weather controls will erode and, regardless of the cost
allocation or rate structure, the costs per household will increase. This could result in a
Residential Indicator that is significantly higher than the 2% rate presented in Section 11.1 of
this report both upon the first year of full implementation (2027) and beyond as the impacts of
the demographic trends compound in the future. Conversely, should the service population,
household size and water consumption increase in a sustained pattern, the resultant
affordability improvements will be evaluated towards increasing ALCOSAN’s wet weather
control efforts.
Changes to Billable Flow Composition – As detailed in Sub-Section 7.3, the quantity of billable
flow received by ALCOSAN has declined by more than 26% over the past twenty years and
percentage of billable flow that is attributable to residential users has increased from 65% in the
mid-1990s11-20 to around 73% currently (Sub-Section 7.3). The Affordability and Financial
Capability analyses presented in Sub-Section 11.5 were premised on the residential class’ share
of billable flow and the volume of billable flow stabilizing. Should the flow contributions from
major industrial, institutional or commercial users decline significantly, the resultant shift of
costs to the residential class could materially affect the affordability of the Recommended 2026
Plan.
Changes to Household Income – The Affordability Analysis presented in Section 11.5 was
premised on the ALCOSAN service-area-wide median household income growing at an annual
rate of 1.8% through (and beyond) 2027, the first full year of operation of the facilities
constructed under the Recommended 2026 Plan. Should 2020 Census data or other economic
data that becomes available in the interim indicate that the projected future incomes are
11-20
ALCOSAN Pennsylvania Act 537 Comprehensive Sewage Facilities Plan (1996) page 4-14.
materially different from the assumed values, the affordability impacts will be considered
towards the possible refinement to the Plan.
Municipal Compliance Costs: As detailed elsewhere in this report, ALCOSAN is utilizing a
working estimated cost of the municipal upgrades necessary to control or convey wet weather
flows of $530 million dollars. This estimated cost was factored into the Affordability
Assessment (Section 11.4). The preliminary nature of this estimate pending the completion and
approval of the municipal feasibility studies must be emphasized. Should the projected
municipal costs estimated in the forthcoming feasibility studies exceed this estimate, the
affordability of the Recommended 2026 Plan could be materially eroded and could necessitate a
revision to the Plan. Conversely, should the municipal cost estimate be significantly lower,
ALCOSAN would evaluate revisions to the Plan that any increase in affordability might
suggest.
11.7.2 Cost Estimation Accuracy
The cost estimates for the controls that were evaluated in Section 9 and which serve the basis of
ALCOSAN’s proposed control strategy were based on concepts developed to a level of detail
appropriate for the selection of wet weather controls in conformance with the CSO Policy,
related guidance (e.g. CSO Guidance for Long-Term Control Plan EPA 832-B-95-002 (Sept. 95))
and ALCOSAN’s consent decree. The Association for the Advancement of Cost Engineering
International would consider such estimates as Class 4 estimates, with an expected accuracy
within plus 50 percent to minus 30 percent of the estimated cost.11-21 As ALCOSAN moves from
wet weather planning into preliminary and final design phases, the uncertainty ranges for the
cost estimates will narrow. Ultimately, the actual cost of projects will be determined based on
bids received and change orders resulting from construction. Using the Adaptive Management
approaches outlined in Section 11.7.6, ALCOSAN will refine its implementation plan to reflect
the additional resources or limitations that the more detailed program cost estimates, along
with actual bids for early projects, reveal.
11.7.3 Construction and Engineering Resource Availability
A preliminary review of construction and engineering resource availability provided input into
the proposed implementation schedule (Section 11.1). This review was intended to inform
ALCOSAN and the regulatory agencies as to potential issues that could affect timely program
delivery.
During the previous ALCOSAN capital improvements program for the Woods Run WWTP
expansion, ALCOSAN managed design engineering using in-house engineering and
11- 21
AACE International Recommended Practice No. 18R-97:
“Class 4 estimates are generally prepared based on limited information and subsequently have fairly
wide accuracy ranges. They are typically used for project screening, determination of feasibility,
concept evaluation, and preliminary budget approval. Typically, engineering is from 1- to 15-percent
complete, and would comprise, at a minimum, the following: plant capacity, block schematics,
indicated layout, process flow diagrams (PFDs) for main process systems, and preliminary
engineered process and utility equipment lists.”
construction management staff supplemented by engineering program management and
construction management consultants. Design consultant teams were formed using national
and local consulting firms to complete design and prepare construction bid documents. A
similar engineering and construction management approach is appropriate for the WWP
implementation, albeit, at a larger scale.
Assuming design engineering costs are typically around ten percent of the overall capital costs;
the design costs for the Recommended 2026 Plan are in the magnitude of $150 million. With a
design phase duration between five-to-seven years the annual costs for engineering services
may be in the range of $20 to $30 million. It is anticipated that the national and local
engineering resources in the region can support this additional engineering demand with some
growth. Certain specialty design services, such as for TBM tunneling and microtunneling, will
be needed to supplement the local engineering resources. Similar conclusions were reached
regarding resource availability and magnitude of cost for the construction management
components of the plan implementation.
The regional tunnel and associated facilities represent approximately 50% of the capital
improvements under the Recommended 2026 Plan. The balance of capital improvements are
split between the Woods Run WWTP expansion and other planning basin improvements. A
sequential approach to TBM tunnel construction as proposed for the three regional tunnel
segments described in Section 10 provides a relatively even distribution of annual capital costs;
maintains a more stable demand for specialized and non-specialized labor forces; and promotes
competitive bidding from tunnel construction contractors.
The facilities construction for the WWTP expansion and RTB in the Chartiers Creek planning
basin will draw largely upon the general construction trades, but are not expected to exceed the
growth capacity of construction contractors within western Pennsylvania and the surrounding
region.
The plan elements for construction of consolidations conduits, connections to the regional
tunnel, new relief sewers and municipal collection system improvements may be one of the
more challenging demands on the local construction industry. With capital costs in the order of
$1 billion ($500 million ALCOSAN improvements plus $500 million municipal improvements)
for microtunneling, traditional open trench pipeline construction and regulator structure
modifications there is a potential shortage of utility contractors. As the program continues and
the municipal plans develop it will be necessary to further evaluate the impacts of these
potential limitations in the utility construction capacity.
11.7.4 Green Infrastructure Controls
There is a strong regional interest in including green technologies as part of the solution to wet
weather pollution in the Pittsburgh region. However, due to current institutional
arrangements, ALCOSAN has limited ability to implement green technologies. This is because
land uses, development and re-development activities are controlled by local municipalities and
land owners. Green technologies that reduce or treat runoff from directly connected
impervious areas require local control.
Regional efforts to support the use of green infrastructure controls include those by the 3 River
Wet Weather (3RWW) Program. This non-profit group is assembling a database and map of
existing green infrastructure (GI) controls. They are also developing tools that can be used by
municipalities and private homeowners to help determine where and what type of GI controls
could be implemented. Other examples of regional efforts include:

The Pennsylvania Environmental Council promotes protection and restoration of the
environment including facilitation of collaboration, partnerships, education and
advocacy for green infrastructure as part of water resources programs.

The Clean Water Campaign is promoting use of green technologies and strategies
through education, advocacy and civic engagement.

The Green Infrastructure Network is a collaborative network of organizations and
agencies that actively promote green infrastructure approaches to environmental issues.
ALCOSAN has and will continue to support GI implementation in the region in several ways:

Development of and participation in pilot studies, such as those in the municipality of
West View and on the Bell’s Run system.

Coordination and funding (with municipal involvement) of stream removal projects,
such as those required in ALCOSAN’s CD as Supplemental Environmental Projects.

Participation in pilot study efforts with municipalities funded by local foundations.

Hosting or providing support for GI technology transfer through presentations,
workshops, seminars and training sessions.

Continued involvement in regional stakeholder groups interested in green technologies,
such as The Green Infrastructure Network.

Seeking funding for green infrastructure projects.

Preparation of flyers, fact sheets and other information for public education.

Hosting of ALCOSAN’s annual Open House which features extensive information
through booths and displays from numerous organizations that promote use of GI.
As these regional efforts evolve, ALCOSAN will maintain involvement, consider creative ways
to encourage use of GI and assess how these efforts impact the Wet Weather Plan.
11.7.5 Solids and Floatables Controls
Appendix G of ALCOSAN’s Consent Decree requires that ALCOSAN submit an assessment of
the types and amounts of solid and floatable materials entering receiving waters as well as a
plan to control solids and floatables. As of the date of submittal of this Wet Weather Plan,
ALCOSAN has submitted to the Agencies a Solids & Floatables (S&Fs) Supplemental
Assessment & Control Plan. The Plan includes the installation of solids and floatables control
devices at six locations utilizing baffles, end-of-pipe netting, and screens. The submission is
pending approval and, at this time, ALCOSAN and the Agencies are working together on an
expanded S&Fs assessment that includes a short-term physical study with measurements at a
number of CSOs representative of the entire service area, as well as the evaluation of various
control technologies. Should the S&F plan evolve into a broader, more expensive program, the
impacts of this expansion on the affordability and the implementation schedule for the
Recommended 2026 Plan would be evaluated.
11.7.6 Regulatory Approvals
ALCOSAN’s ability to fully implement the Recommended 2026 Plan on or before September
30th, 2026 is premised upon timely regulatory approvals of construction and discharge permits
as necessary. Assumed timeliness includes but is not limited to the approval of this Wet
Weather Plan and of the municipal feasibility studies no later than January 31st, 2014.
11.7.7
Adaptive Management
Given the risks and uncertainties that will be inherent in the implementation of ALCOSAN’s
Wet Weather Plan, ALCOSAN intends to use an adaptive management strategy. Adaptive
Management, as defined by the EPA, is “the process by which new information about the health
of a watershed is incorporated into the watershed management plan.” In the context of the
WWP, adaptive management assumes that while the strategic goals of the Wet Weather Plan
that were outlined in Section 10 of this document will remain constant, the tactical approaches
to achieving the goals must be adjustable. These adjustments will be based on the combination
of technical, regulatory and socio-economic changes.
Periodic Program Reviews: ALCOSAN’s adaptive management process provides for progress
tracking and reporting annually through the consent decree annual report and through
ALCOSAN’s ongoing public participation program. Topics to be addressed may include:

Schedule conformance (regulatory approval status of critical path submittals, etc.)

Hydraulic loadings vis-à-vis the design flow and flow rate assumptions that were used
in the development of the WWP or in subsequent design due to changing demographics,
municipal collection system conditions, climate change, etc.;

Emergent regulatory requirements specific to the ALCOSAN system or receiving
streams (e.g. TMDLs) or in general (e.g. the promulgation of a National SSO Policy);

Emergent economic and other developments and trends that could materially affect the
affordability of the WWP.

Changes to water quality standards and guidance that could affect the types and levels
of wet weather controls necessary to meet the program objectives;

Innovative and alternative technologies that could enhance water quality and/or reduce
costs thereby enabling expanded control efforts.

The unavailability of supplies, materials, contractors or labor necessary to implement the
WWP as scheduled in the WWP due to conditions beyond ALCOSAN’s control such as
a natural disaster or other emergency; and

Local, state or federal legal impediments to the timely or orderly implementation of the
WWP, e.g. lengthy litigation over land acquisition or inability to obtain required
permits.
The adaptive management process would also be activated immediately upon ALCOSAN’s
awareness of trends and potential events beyond ALCOSAN’s control that could materially
affect the implementation of the WWP or the subsequent performance of the wet weather
controls.
ALCOSAN will utilize adaptive management to preserve the affordability of the WWP. Over
time, factors such as household incomes; energy, raw material and labor costs; and the cost of
capital tend to revert to long-term trends. However, history shows that economic conditions
and financial markets can be extremely volatile from year to year. In a given year, this volatility
can have a significant impact on the financial capability of a community to finance public
infrastructure improvements without economic hardship.
A flexible, adaptive approach to financial capability analysis will be considered to maximize
ALCOSAN’s chances of success in implementing its chosen program. ALCOSAN proposes to
periodically reassess its affordability and financial capability analysis in light of any new
information. Local economic conditions will be assessed including changes in household
income, revenue, capital spending in response to new regulations or requirements, construction
and operating costs, and ALCOSAN’s financial position and cost of capital. Adjustments to the
program will be considered to either increase the rate of progress toward goals if conditions are
favorable or to decrease spending to avoid economic hardship.
Adaptive Management Responses: ALCOSAN will notify the regulatory agencies when it
becomes aware of or foresees any of the following adverse conditions:

The implementation schedule set forth in the WWP cannot be met;

The design and performance assumptions used in the development of the WWP are
rendered obsolete due to changing conditions;

The type, size, location or scope of wet weather controls set forth in the WWP must be
changed to meet the water quality goals of the WWP;

Economic, demographic or other conditions change such that the ALCOSAN regional
Residential Indicator projected upon full implementation of the WWP would increase by
more than one tenth of one percent over the Residential Indicator that was projected in
Section 11.5 of this document (e.g. from a RI of 2.0% to a RI of 2.1%); and

Any other factor which could materially affect ALCOSAN’s ability to implement its Wet
Weather Plan, including those described in Sub-Sections 11.7.1 through 11.7.5 of this
document.
ALCOSAN will coordinate with the regulatory agencies pursuant to Section XIII of the consent
decree or other appropriate mechanism and present to the agencies:

An analysis of the issues and implications posed by the condition;

An analysis of the impacts on the implementation of the WWP or the efficacy of the
controls; and

An Action Plan to address the adverse conditions that will preserve ALCOSAN’s
compliance with the financial capability and water quality requirements of the CSO
Control Policy.
Upon agency approval, the Action Plan will become an amendment to the WWP.
11.7.8
Wet Weather Plan Update
ALCOSAN will prepare a Wet Weather Plan Update (WWPU) to evaluate the performance of
the controls to be completed under the Recommended 2026 Plan and to determine the scope of
additional controls necessary for remaining overflows to comply with the CWA and the CSO
Policy. Based upon the September 30th, 2026 date for the initiation of operation of the controls
proposed under the Recommended 2026 Plan and the schedule for implementation of the
Interim and Post-Construction Monitoring Plan (IPCMP), ALCOSAN proposes to submit the
WWPU on or before September 30th, 2031. Anticipated key elements of the WWPU include:

2026 Plan Performance Evaluation – The WWP Update will include an evaluation of the
control facilities constructed under the 2026 Plan in terms of their respective design
criteria, i.e. reduction of CSO volume, control of CSOs near Sensitive Areas and control
of SSOs on Chartiers Creek. The WWPU will document the hydraulic performance of
the completed facilities and remedial steps to be taken if design performance standards
have not been met.

Coordination with Municipal Source Reduction – ALCOSAN’s WWP Update will
account for municipal flow reduction efforts which may have occurred since the
development of this document, including I&I reductions in the sanitary sewered
municipalities and green stormwater management practices that may have been
implemented by the combined sewered municipalities.

Receiving Water Quality Conditions–The WWP Update will include an analysis of the
receiving water quality data collected as a part of the IPCMP. The report will include a
status update on progress towards not precluding attainment with bacteria water
quality standards.

Evaluation of Additional Controls – Based upon IPCMP evaluation, ALCOSAN will
evaluate additional controls necessary for full compliance with the CWA requirements.
This will include an analysis as to cost-effectiveness of implementing the remaining
components of the Selected Alternative (Section 9.6) given contemporary technical,
water quality, regulatory and economic conditions. The Selected Alternative will be
evaluated against other control strategies that may emerge in the future.
11- 78

Implementation Plan

Transcription

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