Water Quality:

The Western Lake Superior Sanitary District (WLSSD) and City of Duluth submitted a Plan of Action to the United States Environmental Protection Agency (EPA) on May 14, 2004. The plan, required by an Administrative Order from EPA received in January 2004, details the separate and joint efforts that the City of Duluth and WLSSD will take to eliminate sanitary sewer overflows within the region. WLSSD and the City of Duluth received the 14-page Administrative Order as Joint Permittees of a National Pollutant Discharge Elimination System Permit (NPDES) issued in August 2002.

In the summer of 2003, WLSSD experienced an unprecedented series of spills and overflows. The highly-publicized overflows brought the region's decades-old problem of sewer overflows resulting from inflow and infiltration (I&I) to the attention of the EPA. Although WLSSD and communities throughout the region have made progress toward the elimination of overflows, the EPA has stepped in, stating that the problem isn't getting fixed fast enough.

Over the past 10 years, WLSSD has invested millions in local funds to eliminate overflows by increasing capacity of its pump stations, interceptor sewers and the WLSSD treatment plant itself. This work has paid off. The WLSSD plant no longer overflows. The frequency and duration of overflows at other locations has dramatically declined, but still occur during more-serious wet weather events.

Despite this significant local effort, in early January 2004, the EPA issued the Administrative Order to Duluth and WLSSD demanding a plan of action and schedule for complete elimination of all sewage overflows.

The plan details a 12-year schedule to stop sewage overflows by removing the sources of excess clear water entering the system and adding overflow storage facilities to hold sewage until the system can handle it. It also outlines an aggressive program to keep trunk sewers cleaned and repaired. In addition, upgrades made to pump stations, refined operations and maintenance procedures and WLSSD capital improvement plans that focus on the replacement and modernization of facilities and equipment will all contribute to reducing the overflows. Elements in the City's portion of the plan will cost the City of Duluth's residents $36 million, and WLSSD ratepayers $65 million over the 12-year period. And, although the sewer system in Duluth experiences the vast majority of overflows, all communities and industries serviced by WLSSD are stepping up efforts and submitting I&I elimination plans to WLSSD.

WLSSD and the City of Duluth have already completed some projects, and the effort will continue with the construction of storage basins at strategic locations in the system, rebuilding of pump stations and the rehabilitation of residential sewer connector lines. The key component to success, however, is an aggressive program to prevent clear water from entering the sanitary sewer system during heavy rains and snowmelt. Installation of home sump pumps and disconnecting home footing drains are critical to achieving this goal.

Unless this problem is resolved, state and federal regulators could curb development in the city of Duluth so that existing overflow problems are not exacerbated. Some restrictions are already in place. As of June 1, 2004, housing developments of more than 25 units or 10,000 gallons per day of new flow are prohibited in some areas of the District unless a sewage storage system is included in the project.

This isn't the end of the process. The EPA has inspected WLSSD and City of Duluth wastewater facilities. They will review the results of the inspection and the Plan of Action to determine if the plan is acceptable or if they will require changes. A consent decree/binding agreement will then be ordered by federal courts, likely in 2007.