Guidance and Sewer Extension/Addition Report Form

Sewer Extension/Addition Report Form

State Law title 38 section 412-B reads " Any person who proposes a new system of drainage*, sewage disposal, sewage treatment or industrial waste disposal into any waters of the State shall submit plans and specifications for the system to the commissioner for approval."
*"drainage" as written refers to sewered drainage, not stormwater drainage. Stormwater drainage is exempt from this law.

This law is interpreted by the Department of Environmental Protection (DEP) to include all sewer work and any changes made at wastewater treatment plants. Because of the potentially large number of reviews this interpretation would generate (and subsequent backlog of reviews), we feel that it is necessary to limit the submittals for full review to changes or additions that are “significant”. “Significant” changes are changes to the treatment facility or cumulative wastewater additions to the facility of 10% or 50,000 gallons per day within a one-year period, whichever is the lesser flow. Sections A through C below include criteria the Department will consider when reviewing such sewer extensions/additions. Section D includes discussion on submission of a Sewer Extension/addition Report Form to both streamline the review process and allow a municipality or sewer district to comply with DEP statute §412.B. without generating considerable paperwork.

A. Significant additions to the sewer system that result in a cumulative increase in flow of 10% or 50,000 gallons per day within a one-year period, whichever is less, need to be reviewed and approved by DEP.

When the changes are "significant", the following information must be submitted to the DEP:

1. Plans and Specifications for the construction work;
2. the amount and nature (commercial, industrial, domestic) of the additional flow and anticipated pollutant load; if commercial or industrial, what type of pollutant loadings are anticipated (laundry, metal plating, cooling water, etc.);
3. letter from the treatment facility acknowledging capacity to transport and treat the increased flow.

Plans are the engineering drawings that show sewer plan and profile views, pump station cross sections and typical construction details such as trenches and manholes. Specifications are the requirements for construction material, qualifying conditions for equipment and procedures for construction. The plans and specifications for the sewer work must be prepared following good engineering practices. The single most important aspect of new sewer line construction is not the review by DEP but the inspection during construction by qualified people to ensure that new lines and manholes are properly constructed and tested, and services are properly installed and connected to the sewer lines.

Note: Changes to the sewer system that involve sewer separation or sewer replacement for structural reasons or infiltration/inflow reduction need not be submitted to the DEP for review. But certain projects may require permits under the Natural Resources Protection Act (NRPA) for replacement of existing structures that pass through specific habitats or wetland areas. If you think such a permit may be necessary, call a Land Resource Regulation staff member for more details (287-3901).

Note: Reviews for additions of less than 10% or 50,000 gallons can be required by the Department for wastewater treatment facilities that are already hydraulically limited or are considered by the Department to be in significant noncompliance with discharge licenses.

B Significant additions or changes to the waste treatment facilities include new unit processes, additional tankage for treatment, changing from one treatment process to another treatment process, or a change in plant location or outfall location.

Note: Replacement of equipment that has out-lived its useful life with similar type of equipment is not considered significant and does not require Department review. Replacement of equipment that involves some process changes shall be considered for review. An example of such a replacement would be changing from Chlorine gas disinfection to hypochlorite disinfection.

C. Sewer Extensions Affecting Combined Sewer Overflows (CSO's). In addition to the above requirements, if your community has Combined Sewer Overflows (CSO's), then language in renewed state waste discharge licenses will require the licensee to list any sewer extensions and new, commercial or industrial flows added each year, along with what mitigating measures were accomplished to prevent these flows from contributing to CSO's. Plans and specifications for proposed flow additions that fall into the criteria listed above must be submitted along with information to substantiate that the new addition will not increase the quantity of wastewater discharged through CSO's.

The following information should be submitted with the plans and specifications:
A narrative stating whether the sewer extension ties into a sewer line that has CSOs between the development and the treatment plant. If it does, then explain:

1) Which CSOs are affected;
2) What is being done by the developer to prevent the flow from discharging to CSOs;
3) Does the community have a CSO Master Plan that is approved by the DEP;
4) What type of wastewater is generated by the development (domestic, commercial, or industrial (with flows and pollutant loadings);
5) How does the development comply with the community's plan for accommodating additions to the sewer system without increases in quantities of pollutants discharged through CSOs from the addition.

IF you have questions about what is "significant", please contact your DEP Inspector.

D. Sewer Extension Reporting Form. The Department offers the Sewer Extension Reporting Form to help simplify sewer extension review process and priorities. The municipality or sewer district planning for various sewer extension projects may complete this form and submit it to the Department. The Department will then be able to make a cursory review of the requested information and either require a full review or not depending on the applicability of criteria listed in the various sections above. If you have any questions about the report form, contact your DEP Inspector.

Contributed by Stuart Rose