Will the U.S. Environmental Protection Agency give local communities at least 10 more years to stop raw sewage from overflowing out of their sewerage systems?
In 2009, EPA ordered 14 municipalities in Lehigh County to stop raw sewage from overflowing into the environment during and after heavy rains.
The federal government gave them five years — until Dec. 31, 2014 — to complete that work.
On Friday, those communities are sending a letter to EPA asking for an open-ended time extension of that 2009 administrative order.
That letter will be accompanied by “a plan of action” explaining the municipalities won’t be able to comply with EPA’s order until at least 2025 — more than 10 years from now.
But exactly what will be done, and how much it will cost, to comply with EPA still has not been determined.
The municipalities already have spent a total of more than $13.3 million to begin to comply with the federal order.
But that’s just the start.
“Preliminary estimates have us at $50 million or greater to address all that issues that we need to do to comply with the administrative order,” said Tony Dill, an engineering consultant working with the municipalities.
Aurel Arndt, chief executive officer of Lehigh County Authority, said the amount of money that has to be spent on the sewerage system will be unprecedented.
The big unknown is whether EPA will agree to an open-ended time extension.
Arndt is optimistic EPA will extend Dec. 31 deadline because the federal agency recognizes the complexity of what it takes to solve the problem “and will work with us.”
Said Arndt: “The alternative is to do it in a very adversarial way. Then we can begin to spend money on lawyers’ fees as opposed to contractors and engineers and resolution of the problem.”
He added that getting into an adversarial position with EPA “would be very ineffective and wasteful and do nothing more than defer the time when the problem would ultimately be solved.”
LCA, which provides sewer service to some of the communities, also is named in the EPA order.
Pat Mandes, LCA’s compliance director, said LCA met with EPA in October and advised the agency of work that has been done so far and what more has to be done. “They committed to considering whatever we presented them,” she said.
“Five years was not realistic,” said Mandes. “It couldn’t have been done in five years.”
LCA and its partner municipalities plan to develop a complete plan by late 2017, then probably will spend more than eight additional years to implement that plan with actual construction that solves the problem.
“We’re dealing with a lot of different entities,” said Dill, explaining the time delay. “It’s not just one system, one owner.
“It would be highly unlikely that you could do a massive project —fund it, budget it, engineer it, permit it, award it and everything — in less than eight years.”
Participating municipalities
Arndt said the primary requirement of EPA’s order is to “eliminate sanitary sewer overflows” throughout the system connecting all those municipalities.
He explained a second EPA requirement is that Allentown and the communities that pipe sewage to the city’s wastewater treatment plant should work together to eliminate those overflows.
The interconnected sewer system serves the city and all or parts of 13 surrounding municipalities.
Municipalities ordered by EPA to solve the problem include Allentown and the boroughs of Alburtis, Emmaus and Macungie.
The order also applies to eight Lehigh County townships — Hanover, Lower Macungie, Lowhill, Salisbury, South Whitehall, Upper Macungie, Upper Milford and Weisenberg.
And it applies to three municipal authorities: Coplay-Whitehall Sewer Authority, Upper Macungie Township Authority and LCA.
Learning about the problem
More than 60 people attended a public program Thursday night about the effort to comply with EPA’s order.
It was presented by LCA in the Lehigh County government center in center city Allentown.
During the program, LCA officials acknowledged higher rates are inevitable for consumers to pay for millions of dollars worth of improvements that need to be made.
They denied that suburban residential, commercial and industrial development is causing the overflows.
And, despite the order coming from the federal agency charged with environmental protection, one of them minimized the environmental impact of sewage overflows.
Pollutants in that “gray water” are minimal after heavy rains, said Mandes. “The danger to the public is really minimized.”
But she also said: “We do not want to put any raw sewage into our streams and waterways,”
Arndt said some projects already have been completed to comply with the administrative order and others are works in progress.
Officials also outlined “the work that remains to be done in the coming years to achieve the goal that EPA has set forth.”
I&I
During the program, LCA officials explained the problem is that too much stormwater is getting into sanitary sewer lines that are not designed to handle stormwater.
Those sewer lines become overloaded and raw sewage flows out of manhole covers and across lawns, perhaps most conspicuously along Little Lehigh Creek in Allentown’s Lehigh Parkway.
The problem facing the municipalities often is referred to as I&I, which stands for inflow and infiltration.
Dill explained inflow is when stormwater goes directly into sewer lines, such as water flowing into a manhole lid in a low-lying area.
He said infiltration is when stormwater hits the ground, permeates through soil, then leaks into cracks and other defects in sewer pipes.
What’s been done
Much of the work done since EPA issued its order in 2009 has been “investigative,” said Dill.
“All these communities have put in a lot of effort to better characterize their systems,” he said. “It’s very important that we understand what our problem is before jump in and try to spend a lot of money to fix it.
“We get the most bang for the buck if we go to the areas that leak the most and spend our money there.
Locating those areas involves inspecting manholes, smoke testing to find leaks in pipes, sending TV cameras into pipes to evaluate their condition and installing meters on sewer lines to determine where flows “spike way up” during heavy rains.
The consultant said all that data is being used to identify areas that leak the most “to prioritize our future efforts.”
But he added some projects, including pipeline rehabilitation, already have been completed.
One major improvement already made is a three-million-gallon tank installed at LCA’s pre-treatment plant in Upper Macungie.
That tank stores sewage that otherwise would flow through the pipes during peak periods of heavy precipitation, then gradually releases it after those peak periods end.
Dill said the tank has reduced overflows by 50 percent in part of the sewerage system.
He also said new liners have been installed inside 73,000 feet of old pipelines that have fractures or leaking joints. He said leaking joints have been sealed on nearly another 43,000 feet of pipe.
What’s next if extension is approved
Dill said a schedule and a budget have not yet been developed to comply with EPA. “It’s hard for us to say how long it’s going to take to complete these projects when we don’t know exactly what the projects are.”
In the coming months, he said, the municipalities will create a list of final alternatives that will be evaluated to comply with the EPA order.
He indicated the long-term solution probably will be multi-faceted.
It may include rehabilitating pipelines by putting liners inside them or sealing their joints, repairing manholes, installing additional and/or bigger pipes, adding pumping stations and constructing more storage tanks that hold sewage during storm events “rather than having it all just go down the pipe.”
Dill said keeping stormwater out of existing sewer lines can cost anywhere from “a couple hundred thousand dollars” to as much as $1 million a mile.
First EPA order for Allentown
EPA’s first administrative order was issued to Allentown in 2006 because millions of gallons of untreated sewage were being discharged into Little Lehigh Creek, just upstream from where it flows into the Lehigh River, from the city’s Klines Island wastewater treatment plant during extreme wet weather events.
The Allentown plant is designed to handle 40 million gallons of sewage a day but can handle as much as 87 million gallons a day during wet weather, said Bob Kerchusky, LCA’s wastewater services director.
“Any more than that will cause tanks to overflow in the plant,” he said.
Dill said those heavy rains usually only happen once every other year, causing more sewage than can be treated to flow into the plant.
The consultant said other overflow problems caused by excessive rain occur about once each year in other parts of the “interceptor system” that carries sewage from the suburbs to Allentown’s plant. He said typically those overflows occur along streams or rivers.
Questions from the audience
People in the audience had no opportunity to raise their hands and comment on the issue during the program.
Questions were taken, but they had to be written on cards.
Arndt read some of them in the latter part of the program and he, Dill and other LCA officials answered them.
One question read by Arndt asked why more time is needed to repair problems that have existed for many years.
A related question asked: “Why should EPA extend the administrative order when you have ignored this for five years and continue exceeding capacity while you accept continued development?”
Responding, Arndt repeated that what’s driving the EPA order are extreme wet weather circumstances that cause the overflows.
He explained the sewerage system is designed to handle about two times the normal daily flow, but in extreme rain conditions there are three to five times normal daily flow.
Regarding future development, he indicated additional flow coming from future customers still will be well within the capacity of the sewer system.
Responding to a related question, Dill said in planning to solve the problem, they are considering population projections to 2040 — “where we think there will be some development or redevelopment” — as well as future industrial needs.
In response to another question, Ed Bielarski, LCA’s chief financial officer, said the impact the work will have on rates has not yet been determined, but LCA will try to keep rate increases as low as possible for its customers.
“We’re looking to maintain an affordable system,” he said.
Arndt said all questions submitted during the program, as well as answers to them, will be posted on LCA’s website: http://ift.tt/1EDxdCK.
A number of local municipal officials were in the audience, including three of the five Lower Macungie Township commissioners.
Also in the audience was Jan Keim of the Little Lehigh Watershed Coalition.
She is a long-time critic of LCA, who maintains it has failed to stop raw sewage overflowing into one source of Allentown’s water supply –Little Lehigh Creek -- for more than 40 years.
“They’ve had 40 years to correct the sewer problems and they’re just taking some action now?” asked a skeptical Keim at the end of the meeting. “Sewage overflows are still occurring.”
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