Report for the Huntington Sanitary Board CSO Long Term Control Plan

Prepared By: Huntington Sanitary Board

1217 Adams Avenue Huntington, WV 25704

http://www.huntingtonsb.com/

March 2010

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TABLE OF CONTENTS

Page No.

SECTION 1.0-INTRODUCTION AND EXECUTIVE SUMMARY............................................... 3

SECTION 2.0-NINE MINIMUM CONTROLS........................................................................... 8

SECTION 3.0-SENSITIVE AND PRIORITY AREAS................................................................ 14

SECTION 4.0-SYSTEM CHARACTERIZATION...................................................................... 21

SECTION 5.0-PUBLIC PARTICIPATION.............................................................................. 26

SECTION 6.0-CSO VOLUME AND EVALUATION OF CONTROLS......................................... 27

SECTION 7.0-AFFORDABILITY ........................................................................................... 55

SECTION 8.0-RECOMMENDED CSO CONTROL PLAN ........................................................ 62

APPENDICES

APPENDIX A-CSO-RELATED REPORTS AND CORRESPONDENCE APPENDIX B-CSO CHARACTERIZATION APPENDIX C-TABLE 6-9,1 THROUGH 13 APPENDIX D-PUBLIC HEARING RELATED DOCUMENTS APPENDIX E-DETAILED PRELIMINARY IMPLEMENTATION SCHEDULE

TABLES 4-1 System Characterization................................................................................. 21

4-2 Pumping Station Information ........................................................................... 22

4-3 Gravity Sewer Information.............................................................................. 22

4-4 Force Main Information .................................................................................. 22

4-5 CSO Occurrences.......................................................................................... 22

6-1 Two-Month Storm Intensities for Southern Ohio Rainfall Frequency Atlas

of the Midwest............................................................................................... 27

6-2 CSO Calculation Method (Follows Schedule 4 for LTCP-EZ).............................. 28

6-3 CSO Time of Concentration Adjustment ........................................................... 30

6-4 Constrained Time of Concentration Adjustment ................................................ 31

6-5 Rational Method Basin Flow Volumes .............................................................. 31

6-6 Separation Analysis....................................................................................... 32

6-7 Unit Costs for Force Main Construction............................................................. 37

6-8 Unit Costs for Gravity Construction.................................................................. 39

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6 - 9 1 through 13 .......................................................................................... Appendix C

6- 10 Preliminary Present Value Projections (in millions).............................................. 46

6-11 Further Preliminary Present Value Projections (in millions) ................................. 47

6-12 Basins with Potential Savings for Separation ..................................................... 51

6 -13 Basins with Significant Potential Cost Savings Through Roof Drain Disconnection 51

6-14 Project Priority Groups..................................................................................... 52

7-1 Existing HSB Operating Costs............................................................................ 55

7-2 Projected FY 07 Operating Costs ....................................................................... 56

7-3 HSB Existing Debt Retirement Schedule............................................................. 56

7-4 Current HSB Sewer Service Rate (Schedule I)................................................... 57

7-5 HSB Annual Cash Budget Cash Balances Including Non-CSO CIP and "Presumptive"

CSO Control ................................................................................................... 58

7-6 Local Financial Capability Assessment ............................................................... 61

8 -1 Detailed Implementation Schedule-by Project .................................................... 63

FIGURES

3 -1 Existing System.............................................................................................. 14

6 -1 Synthetic Basin Flow Hydrographs ................................................................... 30 6 -2 The Actiflo® Process ....................................................................................... 39 6 -3 Proposed Improvements.................................................................................. 40

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1.0 INTRODUCTION AND EXECUTIVE SUMMARY

The City of Huntington Sanitary Board (HSB) provides sewer service to areas in and around the City of Huntington, located at the confluence of the Guyandotte and Ohio Rivers in Wayne and Cabell Counties, West Virginia.1 The HSB sewer system is largely served by single sewers having both storm and sanitary connections, although there are some areas in the system with separate storm and sanitary sewers. The HSB system is therefore classified as a combined sewer system (CSS). Wastewater from the CSS is conveyed to the activated sludge wastewater treatment plant (WWTP) on the far west side of Huntington.2

During wet weather, a CSS receives very high flows as a result of stormwater contributions, with flows greatly exceeding the carrying and treatment capacity of the sewer system and treatment facilities. At such times, combined sewer overflows (CSOs) can occur and result in the discharge of untreated wastewater to local waterways. Although CSOs and wastewater flowing to the WWTP becomes dilute owing to the large quantity of stormwater at such times, CSOs contain solids, bacteria, and other constituents that may impair water quality, in particular bacteria standards. CSOs, together with other point and nonpoint sources, interfere with designated uses (water supply and recreation) and water quality standards during and following wet weather. The HSB CSS contains 25 permitted relief points where CSOs may occur, and records show that 49 overflow events occurred during 2006.

The United States Environmental Protection Agency (EPA) is the federal agency responsible for administration and enforcement of water quality regulations. In West Virginia, this responsibility has been delegated to the West Virginia Department of Environmental Protection (DEP). The EPA's CSO Control Policy (April 19, 1994, 59 Federal Register 18688) establishes regulations regarding the reduction of CSOs. National requirements and specific requirements contained in HSB's National Pollutant Discharge Elimination System (NPDES) Permit WV 0023159 require HSB to prepare a Long-Term Control Plan (LTCP). EPA and DEP Policies require the abatement of CSOs to the extent necessary to avoid interference with designated uses and to protect water quality.

The end purpose of the LTCP is to develop a series of prioritized, phased projects for controlling CSOs to achieve compliance with water quality standards and to support designated uses, giving priority to lower cost projects that would have the most immediate water quality benefit. There are two general approaches to determining the "design standard" for developing an LTCP:

A Presumptive Approach where CSOs are controlled to limit CSOs to four to six events per year or to maintain treatment of over 85 percent of flow or pollutants during wet weather events; DEP has determined that control to no more than six events per year complies with these criteria.

A Demonstrative Approach that provides a lower level of control than the Presumptive Approach, but can be shown to achieve water quality standards and support designated uses.

This LTCP has been prepared using the Presumptive Approach, following the guidance provided in the Long-Term Control Plan-EZ (LTCP-EZ) Template: A Planning Tool for CSO Control in Small Communities (EPA-833-R-07-005).3 The Template outlines LTCP requirements for communities of fewer than 75,000 residents, and this report follows these requirements: 1The service area within the City of Huntington is approximately 8,700 acres. The service area outside the city is approximately 40,000 acres. 2Information on typical WWTP flows and treatment capacities is provided in Section 4. 3 This document was prepared under the guidance of the September 2006 version of the LTCP-EZ Template. As HSB's LTCP was being finalized for the public, the May 2007 version of the Template was published. This LTCP incorporates the version changes that could be readily implemented.

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Section 2-Nine Minimum Controls (NMCs) describes HSB's ongoing operation and maintenance program to help minimize CSOs. All CSO communities are required to adhere to and document their implementation of the NMCs.

Section 3-Sensitive Areas identify water bodies that may be of higher concern for CSO reduction, such as areas where contact recreation exists. These areas may be considered in Section 6 when prioritizing projects.

Section 4-System Characterization provides a description of the CSS and how it operates during wet weather.

Section 5-Public Participation summarizes the public presentations and news releases.

Section 6-CSO Volume and Evaluation of Controls covers several important steps in the LTCP process: (1) determines preliminary wet weather design flows based on the Presumptive Approach; (2) evaluates alternatives that would handle the design flows; (3) identifies design criteria and costs for the CSO projects; and (4) develops project priority groups based on projects that would logically be performed together.

Section 7-Affordability evaluates HSB's larger financial picture to determine how the proposed projects may be phased to maintain affordability to HSB's customers.

Section 8-Recommended CSO Control Plan identifies an affordable long-term approach to HSB's CSO abatement based on affordability and prioritization and provides recommendations for further action.

Based on the analysis performed in Section 6, it appears that abatement of HSB's CSOs to the six-event-per-year standard would have a capital cost of nearly $775 million. Some of the larger projects would include:

■ Two above ground CSO storage locations near the Guyandotte River. ■ Two CSO treatment locations in central and western Huntington. ■ New pumping stations at 18 of the existing CSOs. ■ Fourteen miles of new force main.

The affordability analysis in Section 7 shows that financial conditions within the City of Huntington are not able to support the proposed array of projects. EPA policy allows communities to phase projects so that they do not result in widespread negative economic impact. EPA and DEP will require HSB to act on the recommendations of the LTCP. DEP policy is that CSO communities will raise their sewer rates as necessary to support an affordable level of CSO control; communities do not have the option of doing nothing. Among the projects identified in this LTCP are a series of more modest "low hanging fruit" projects that can be afforded and will result in CSO reduction. These include:

■ Raising overflow weirs in the CSO regulator structures.

■ Upgrading the existing pumping station piping to support higher flows to the WWTP.

■ Hydraulic modifications to allow more wastewater to be treated at the WWTP.

■ Separation of sanitary and stormwater sewers in select areas of the city.

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This LTCP represents a preliminary analysis of projects that would be required to meet the presumptive standard of the National CSO Control Policy and recommendations to address Huntington's CSOs in an affordable fashion. Primary recommendations of this LTCP include:

1. Pursue a program of public participation to keep the public and the City Council informed on the LTCP and what it may mean for sewer rates in the future. A presentation was made to the City Council on June 11, 2007 and May 26, 2009, and public presentations on the LTCP were held on July 31, 2007 and between January through June 2009. A record of the City Council presentation and public presentations are included in Appendix D.

2. Meet with DEP staff to facilitate their acceptance and approval of the LTCP recommendations. Following approval, initiate discussion on an approvable level of CSO controls and their implementation.

3. Perform an engineering analysis to determine how river water intrusion into the sewer system can best be reduced or prevented.

4. Perform an analysis to determine how best to implement hydraulic modifications at the WWTP (Control Level 3) as well as the piping modifications and replacements required at pumping facilities required to support the hydraulic modifications.

5. Develop a program to track CSO occurrences at the non monitored locations and to verify that supervisory control and data acquisition (SCADA) monitoring is providing representative information at monitored locations.

6. Perform an evaluation for potential new storm sewers required to eliminate manhole overflows within the sewer sheds that have readily disconnectable storm inputs.

7. Make regular and effective contact with the West Virginia (WV) congressional delegation, EPA, the WV Infrastructure and Jobs Development Council, DEP, the WV Department of Transportation (DOT), and other potential funding agencies to pursue grant funding for system improvement projects. Given the low MHI values in Huntington, the high levels of unemployment and poverty, and the very high cost of identified system improvements, HSB should receive priority consideration for available grant funding.

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B. Abbreviations

The following list of abbreviations is provided as an aid to the reader

B&O Tax - Business and Occupation Tax CIP Capital Improvement Program CSO Combined Sewer Overflow CSS Combined Sewer System DAF Dissolved Air Floatation DEP Department of Environmental Protection DIPRA - Ductile Iron Pipe Research Association DMR Discharge Monitoring Report DO Dissolved Oxygen DOT Department of Transportation DWI Drinking Water Intake EPA United States Environmental Protection Agency ESFM East Side Force Main F: M Food to Microorganism Ratio FM Force Main FPS Flood Pumping Station FS Factor of Safety GIS Geographic Information System GPS Global Positioning System GRFM Guyandotte River Force Main HSB Huntington Sanitary Board l/l Infiltration/Inflow LTCP Long-Term Control Plan MCRT Mean Cell Retention Time MHI Median Household Income MLSS Mixed Liquor Suspended Solids NMC Nine Minimum Controls NPDES National Pollutant Discharge Elimination System O&M Operation and Maintenance ORFM - Ohio River Force Main ORI Ohio River Interceptor ORSANCO- Ohio River Valley Water Sanitation Commission PE Plant Effluent POTW Publicly Owned Treatment Works PSC Public Service Commission PSD Public Service District PS Pumping Station RAS Return Activated Sludge SCADA - Supervisory Control and Data Acquisition SIU Significant Industrial User SWMM - Stormwater Management Model TDH Total Dynamic Head TMDL Total Maximum Daily Load UAA Use Attainability Analysis

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UVT Ultraviolet Transmittance UV Ultraviolet VFD Variable Frequency Drive WAS Waste Activated Sludge WV West Virginia WVAWC West Virginia American Water Company WWPS Wet Weather Pumping Station WWTF Wet Weather Treatment Facility WWTP Wastewater Treatment Plant

C. Community Information

Huntington Sanitary Board 1217 Adams Avenue Huntington, WV 25704 Phone: (304) 696-5564 Fax: (304) 696-5596 Email: lcovington@huntingtonsb.com NPDES Permit Number WV 0023159

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2.0 NINE MINIMUM CONTROLS

Line 5 and Schedule 1 of the LTCP-EZ require information on the city's execution of the Nine Minimum Controls (NMC). Appendix A provides several documents regarding the NMC program, including:

DEP NMC Implementation Audit Form – February 7, 2008

Hunting Sanitary Board Combined Sewer System Operations and Maintenance Plan Combined Sewer Overflow (CSO Summary Reports – July 20, 2009

Example Pollution Control Letter sent to industries – Dec 2008 .

Letter from Huntington Sanitary Board (HSB) to DEP on NMCs-January 10, 2000

Letter from DEP to HSB on drinking water intake—February 15, 2007.

A brief summary of HSB's approach to each of the nine NMCs is provided as follows:

NMC-1: Proper Operations and Regular Maintenance Programs for the CSS and CSO Outfalls

The focus of the first minimum control is to have in place a program of proper operations and regular maintenance of the combined sewer system (CSS) and CSO outfalls.

Please see the Combined Sewer System (CSS) Operations and Maintenance Plan contained in Appendix A.

NMC-2: Maximum Use of the CSS for Storage

The focus of the second minimum control is on implementing relatively simple modifications to the system or its operation that will allow the CSS to store as much wet weather flow as possible.

HSB works to achieve this by performing regular collection system inspections and inspecting new construction to minimize new sources of Infiltration/Inflow (l/l). The HSB has three Vactor trucks and one camera truck that are used for cleaning and inspection of sewer lines within the City of Huntington. One Vactor truck is used for daily cleaning of sewer lines and one Vactor truck is used to clean sewer lines for video inspection. The third Vactor truck is used for a backup if one of the other two Vactor trucks is down for service.

The Vactor truck supervisor will assign Truck 1 to any call-ins or areas within the system where trouble has been reported. This truck is also used for 24-hour emergency response calls that are received after normal working hours. Each Vactor truck operator is required to fill out a daily work sheet with location of the CSS problem, what work was performed by the operator to solve the problem, and the amount of time spent at each call. All daily work sheets are reviewed by HSB's field supervisor each day.

Operators of the Vactor and camera trucks that operate together are also required to fill out daily log sheets that describe what work they performed each day and problems that might affect flows to the treatment plant. If a problem would affect flows in the future, the problem area is videotaped and given to the supervisor to review. Decisions are then made to determine the right course of action to solve the identified problem. Written documentation is prepared concerning the action taken in response to issues that may reduce flow capability to the WWTP.

All materials that are vacuumed to the manhole such as grit, gravel, sand, and grease are removed with

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the Vactor truck and are then transported to an approved landfill. The manhole is then hosed down with a high pressure water jetting system that is provided on each truck. This also allows better future inspection of the manhole and reduces odor problems.

In addition to preventive maintenance, HSB also has a full-time inspection department to verify that new construction will not contribute excessive l/l flows to the CSOs. All connections made by outside contractors to the city sewer system are inspected before they are covered. All sewer lines that are to be tied into the HSB system are light and pressure tested for integrity prior to acceptance. Sewer plans for new projects are reviewed by the engineering department to first check line size and other capacity issues. Someone from the engineering department will meet owners or builders on-site before construction begins to provide pertinent HSB construction guidelines and to discuss project-specific requirements. The HSB engineering department also performs global positioning system (GPS) mapping of sewer lines and manholes for entry of updated information to a database to track cleaning and system maintenance needs.

One significant problem with the CSS is that water from the Ohio River intrudes into the collection system when the Ohio River levels are high. This occurs because the HSB sewer system was designed and built prior to the construction of the Greenup Dam downstream, which has raised river levels. HSB has begun preliminary evaluation of potential structural modifications at regulators and an evaluation of improved backflow prevention valves on the CSOs subject to high river levels, so that this problem can be reduced. For example, a recent project has increased the B&O regulator (CSO 022) elevation approximately 3 feet. Based on HSB's preliminary evaluation, it appears that some of the other regulator levels can be increased, although they would need to be raised several feet in order to prevent intrusion.

An engineering analysis of individual basins is recommended to verify that increasing regulator elevations and/or providing backflow prevention will not adversely affect properties or cause overflows from manholes or other structures. This analysis may include a compilation of historical data available from government agencies, including river levels, local rainfall, flood pumping station records, and records of customer-reported backups. Occurrences of high river levels with rain events may provide test cases to demonstrate whether increased hydraulic levels in sewers impacted customers in the past.4 This analysis would also include detailed evaluation of weir and invert elevations in the low-lying areas of each basin. HSB considers this to be a high priority and a relatively low cost approach to reducing this significant problem in the CSS.

NMC-3: Review and Modification of Pretreatment Requirements

Minimization of pollution from nondomestic sources during overflow events is the goal of the third of the NMCs. Nondomestic sources include commercial users (such as restaurants and gas stations) and significant industrial users (SlUs), which include manufacturing facilities and hospitals.

HSB has an approved Pretreatment Program that maintains inspections and sampling records as required by EPA Regulations (40 CFR 403) regarding compliance of all its Significant Industrial Users (SlUs) including hospitals. Customers suspected of representing a potential problem are inspected and sometimes sampled by the HSB Pretreatment Department. The SlUs were issued a letter in the winter of 2008 (included in Appendix A) with regard to the Board's combined sewer system and HSB's ongoing pollution prevention programs. HSB is aware of the need for more education and communication in this area.

4 HSB believes that tropical storm Gaston (late August-early September 2004) may represent an appropriate test case.

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With regard to smaller businesses and schools, the Pretreatment Department is currently reviewing the commercial and industrial users list provided by the West Virginia American Water Company (WVAWC). This list is large with more than 2,000 entries. HSB intends to perform a regular review of WVAWC customer information regarding commercial and industrial users to ensure that all significant commercial and industrial dischargers are included in the program.

Mailing and correspondence will be ongoing to determine the need for oil-water separators, screens or sediment traps, spill prevention programs, or other appropriate pretreatment for specific dischargers. Permits will be issued accordingly. Because of the large number of commercial and industrial entities that must be addressed with this program, HSB intends to implement the program in a priority fashion over the next several years.

In addition, HSB has a Grease Program that involves inspections and permitting grease traps for all food service establishments. HSB provides a three-year discharge permit and sewer use ordinance pertaining to grease. An example can be found in Appendix A. Each permitted facility is inspected quarterly, as are their receipts from third-party grease trap cleaners. This program is under the direct supervision of the Operations Superintendent.

In accordance with DEP and EPA regulations, HSB has developed local limitations on quantities of potentially toxic substances that may be discharged to the HSB sewer system. The local limitations have been updated and reviewed by HSB as needed in response to future changes in water quality standards and other pertinent programs and regulations.

NMC-4: Maximization of Flow to the Publicly Owned Treatment Works (POTW) for Treatment

The purpose of the fourth minimum control is to perform simple modifications to the CSS and treatment plant to enable the maximum amount of flow to the WWTP.

Currently, under wet weather conditions, the HSB conveyance system can convey more flow to the WWTP than the plant can effectively treat. Stormwater runoff and river intrusion from submerged outfalls contribute to operational difficulties and result in the need to throttle back flow into the plant to maintain proper operation. The intent of throttling back the stations is to provide relief from flows that occur above the WWTP capacity. Although the rated peak hourly capacity of the plant is 46 mgd, based on operators' experience, the WWTP can only sustain this flow for a few hours. The plant has demonstrated the ability to treat up to 25 mgd of flows for durations of several days. Sustained flows in excess of 25 mgd can adversely affect plant performance and contribute to solids washout from the final clarifiers. In addition, HSB staff has expressed concern that grit in the wastewater causes abrasion within the pumping station (PS) internal piping, resulting in pipe failures in the past. Therefore, the condition and remaining life of piping in the pumping stations is also a concern.

Flow as well as process performance is monitored closely beyond 25 mgd to ensure sufficient treatment is obtained. If the WWTP sustains a flow greater than 25 mgd, the plant foreman may call out a maintenance crew to manually throttle back flow to the plant via pumping station motors, according to a set procedure, as described below:

1. Fourpole PS standby pump is turned off.

2. The variable frequency drive (VFD) controls at the Fourpole PS are switched from automatic to manual operation and reduced accordingly.

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3. Wait 30 minutes to see if the above reductions are sufficiently reducing plant flow.

4. If the flow is still too high, the crew begins to throttle back flow from the following major stations by turning off all pumps except for one.

a. East Road b. 5th Avenue c. Pats Branch d. Robey Road

5. If the flow persists, one ejector pot at each of the four ejector stations is removed from service.

a. Krauts Creek b. 22nd Street c. Oak Street d. Richmond Street

6. Immediately following the wet weather event and, after confirmation from the foreman that plant flows can be increased, the stations are returned to normal service levels in the reverse order that they were removed.

One potentially straightforward solution to increase the flow to the WWTP up to the 46 mgd peak hourly flow would be to construct hydraulic modifications, although it would be necessary to address the ability of the pumping stations to sustain longer term high flows. The hydraulic modifications would provide preliminary treatment, primary treatment, and disinfection of all flow, but provisions would be made to route a portion of flows during wet weather around the activated sludge system. This alternative will be discussed in Section 6.

NMC-5: Elimination of CSOs During Dry Weather

An effective operation and maintenance (O&M) program that includes routine sewer cleaning, prompt response to backups, and regular pump station (PS) maintenance has been successful in minimizing dry weather overflows.

HSB's preventive maintenance program is intended to prevent dry weather overflows. Except when demands exceed staff resources, pumping stations are inspected daily. This includes cleaning bar screens, performing maintenance or repair on pumps or motors, inspecting electrical systems, checking valves and piping, and repairing or replacing damaged piping. Regulators and diversion chambers are inspected daily during dry weather, and, because of staffing resource constraints, they are inspected weekly during wet weather. These include inspecting the mechanical and side weir overflows and outfalls and repairing or replacing damaged piping.

All calls to the HSB regarding spilled wastewater on private property, on a public right-of-way, or to a waterway are investigated. The HSB has a very good working relationship with both the Wayne and Cabell County Health Departments and the City of Huntington Public Works Department. Information on wastewater spills is routed to the appropriate organization in a timely manner for regulatory agency reporting, preventive action, and cleanup response.

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To minimize the potential for human exposure to wastewater, Vactor and camera trucks are equipped with clean water tanks, and cleanup response includes hosing any spilled wastewater around manholes back into the system. Spills that result from a backed-up sewer line around either a cleanout or manhole are cleaned up and lime is used to disinfect the area and to control potential odors.

Even with the above efforts, HSB does experience dry weather overflows. In the period of July 2008 – June 2009, a total of 7 known dry weather overflows occurred. Of these, two were due to blocked pipes, two were due to broken check valves, two were due to power outages, one was due to a water main break. HSB observes permit requirements for notification to DEP of planned and unplanned bypass events.

HSB intends to modify all CSOs to eliminate entries in favor of visual inspection. Weirs will be raised and mechanical regulators eliminated. We also plan to purchase video equipment to improve inspection efforts. This should reduce the labor requirements and increase

NMC-6: Control of Solid and Floatable Materials in CSOs

The purpose of the sixth of the NMCs is to reduce visible solids and floatables from CSOs that may potentially cause aesthetic concerns or interfere with designated uses in receiving waters. The HSB CSS does not include any specialized structures, screens, or baffles designed specifically for solids and floatables control at CSOs.5 As previously stated in the discussion of NMC-2, HSB conducts routine inspection and cleaning of the CSS, which reduces the discharge of solids and floatables from CSOs during wet weather events. Also, bar screens are provided at many of HSB's wastewater pumping stations. This screening step reduces the discharge of solids and floatables from CSOs from wet wells at these pumping stations.

NMC-7: Pollution Prevention Programs

The purpose of the seventh NMC is to, as much as possible, prevent pollutants from entering the CSS.

All departments of the HSB are responsible for pollution prevention in their activities. Construction crews are required to clean up construction areas upon completion of the construction work, and to take steps to minimize soil erosion and other potential causes of pollution during construction. Contaminated soils from construction are hauled away to a suitable disposal site. Hosing or liming around a work site is sometimes required. A Vactor truck can be dispatched to a site if this is necessary. All old pipe, fittings, and other material from construction are removed and taken to the sewer storage lot pending proper disposal. These measures minimize solid material from construction-related activities from entering the CSS.

In addition, the Board's Pretreatment Program requires all SlUs to develop and implement a Spill Prevention/Slug Discharge Plan. During annual inspections, SIU waste manifests are reviewed by HSB staff to verify that waste oils and hazardous wastes are properly disposed. HSB is evaluating the SlUs' Best Management Practices for their facilities.

At this time it is the City of Huntington's responsibility to clean street catch basins and collect garbage within the city. Routine street sweeping and attention to the details of solid waste management programs can significantly reduce the entry of solids and floatables to the CSS.

5 Although the HSB overflow structures do not include screening, the large flood pumping stations through which CSOs flow during high river levels do include screening. Therefore, CSOs at these locations are screened when the flood pumping system is operating.

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NMC-8: Public Notification

The purpose of the eighth of the NMCs is to inform the public about the locations, occurrences, and possible health effects of CSOs. All permitted CSOs are designated with a sign reading:

WARNING This is a combined sewer overflow outfall. The water from this outfall may become polluted during or after heavy or prolonged rain events. For more detailed information regarding combined sewer overflows and their effect on local water quality, please call the Huntington Sanitary Board at (304) 696-5917. NPDES #WV0023159. CSO # XXX.

HSB currently works to notify the public regarding CSOs through the following means:

HSB issues press releases when CSO discharge events occur.

HSB attends neighborhood Association meetings and has explained NMC-8 controls.

HSB annually publishes an advertisement explaining the CSOs, the location of the discharge points identified, and the system CSOs' function.

HSB's web page (www.huntinqtonsb.com) is currently being evaluated for use as an effective means of notifying the public about CSOs and their occurrences.

In developing the LTCP, HSB intends to improve opportunities for the public to learn about the CSS, CSOs and potential CSO impacts, and the LTCP and CSO control program. HSB also intends to improve opportunities for the public to provide comments and suggestions. Please see the LTCP "Public Participation" section (Section 5.0).

NMC-9: Monitoring to Effectively Characterize CSO Impacts and the Efficacy of CSO Controls

The purpose of the ninth NMC is to perform visual reviews and apply other simple methods to characterize the CSO occurrences and impacts. Limited sampling and water quality analysis may also be performed to improve knowledge concerning CSO characteristics and potential water quality impacts.

HSB has a supervisory control and data acquisition (SCADA) system in place that monitors flow and overflows at the major pumping stations, which includes 14 of the 25 CSOs. This information is reported to the DEP in the monthly Discharge Monitoring Report (DMR) and the semiannual CSO reports, including the number and duration of CSO events. The SCADA system also gathers rainfall information at several locations within the HSB service area.

The SCADA system does not monitor 11 of the CSO outfalls. HSB monitors these outfalls through the visual inspection program performed by field maintenance personnel. HSB is actively evaluating addition of simple overflow detection devices such as floats and chalk marks in the non-monitored CSOs and expanding its visual monitoring so that CSO events at these CSO locations can be better characterized.

HSB has performed sampling and characterization of several outfalls, including Krauts Creek (CSO 002), 20th Street (CSO 013). East 25th Street (CSO 014), and Pats Branch (018 and 018A). Appendix B contains the sampling protocols used.

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3.0 SENSITIVE AND PRIORITY AREAS

The City of Huntington is located on the south shore of the Ohio River between river miles 304 and 314. Over 25 million people reside in the Ohio River Basin, which is approximately 8 percent of the United States population. An estimated 3.6 million people live in cities and towns adjacent to the Ohio River, from which most receive their drinking water. The river is also used for power generation and commercial navigation. A series of locks and dams, operated and maintained by the United States Army Corps of Engineers, regulate pool elevation on the Ohio River. Long-term average flows in the Ohio River, depending on location and time of year, range from 35,000 to 250,000 cubic feet per second (cfs).

Huntington is one of approximately 52 CSSs along the Ohio River. These CSSs plus nonpoint sources have been designated by Ohio River Valley Water Sanitation Commission (ORSANCO) as a source of bacteria during heavy rains. Huntington is located midway between the Robert C. Byrd Dam (mile point 279.2) and the Greenup Dam (mile point 341.0), commonly called the Greenup Pool, since its elevations are regulated by the Greenup Locks and Dam.

The HSB's direct influence on the Ohio River is limited from mile point 304 to mile point 314, or about 0.9 percent of the entire Ohio river basin. HSB serves approximately 66,000 people in Huntington and the surrounding communities. This is less than 0.4 percent of the population on the Ohio River Basin. Figure 3-1 shows the CSO locations described.

A. Sensitive Areas

The National CSO Control Policy requires that special consideration be given to potentially sensitive waters that may be adversely impacted by CSO discharges. This includes drinking water supplies, unique scientific areas or shellfish beds, rare or threatened fish and aquatic life, or areas of significant water contact recreation. HSB has only two CSOs that discharge to sensitive waters. CSOs 014 (25th Street East) and 015 (Division Street) are within one mile upstream of the WVAWC's drinking water intake (DWI). Based on the configuration of the discharges and intake, which will be described in this section, HSB believes that the impact of these CSOs on the intake is likely negligible. (Correspondence with the DEP dated April 24, 2006, and others regarding the drinking water intakes is included in Appendix A.)

The drinking water intake (DWI) is located at River Mile 307. The 36-inch submerged intake pipe has a screened intake located 438 feet from the river bank in the middle of the Ohio River channel. The intake and drinking water plant are owned by WVAWC, located at 24th Street East and the Ohio River. HSB's contact at WVAWC is Sandra Johnson, 4002 Ohio River Rd., Huntington, WV 25702-9684, (304)525-8193.

The DEP regulations include a public drinking water supply bacteria standard of less than 200 col/100 mL fecal coliform (30-day geometric mean) with no more than 10 percent of samples exceeding 400 col/100 mL fecal coliform. ORSANCO routinely samples the Ohio River for water quality, including bacteria. During 2005, fifteen samples were collected near Huntington by ORSANCO during May and fifteen samples during June. The DEP bacteria standards for public water supply were met during the 2005 ORSANCO sampling. During 2006, ORSANCO collected samples near Huntington in May, June, July, August, September, and October. Fifteen samples were collected in each month, except for June when twelve samples were collected. DEP bacteria standards were met in May and June of 2006. In July, August, and September of 2006, the average geometric mean criterion was met, but over 10 percent of samples exceeded 400 col/100 mL. In October of 2006, both the geometric mean and 10 percent of sample criteria were exceeded.

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Ohio River samples were also collected by HSB staff upstream and downstream of the 25th Street CSO, and at the water supply intake, during dry weather on June 21, June 27, and September 7, 2005, for multiple parameters. Fecal coliform counts in all samples were 140 count/100 mL or less, with a typical value around 15 count/100 mL. The HSB data indicate compliance with DEP water quality standards for public drinking supply use during dry weather conditions.

Based on the available data, it appears the Ohio River complies with the DEP criteria for public water supply use much of the time, but the criteria are exceeded at times. It is likely the elevated values that occur at times are the result of bacteria loadings from nonpoint sources, stormwater discharges, and upstream CSO discharges during wet weather.

CSO 014 is located at 25th Street East and the Ohio River, one block upstream of the DWI, at river mile 306.6. This is the East 25th Street Diversion Chamber with a 30-inch outfall that remains above the river level until the river is 30 feet above the normal pool elevation. The CSO is not equipped with a tide gate, and it is not monitored by SCADA. This CSO serves a relatively small (51-acre) sewer basin, which includes local businesses. All businesses have been inspected and their employees interviewed to verify the absence of significant pollutant and spill hazards.

Wet weather sampling was performed on CSO 014 during 2005, with samples collected on August 16, October 7, and November 29. The sampling program included a wide range of parameters.6 Since CSOs typically cause bacterial impairment only, just the fecal coliform results will be discussed. Upstream data from these events showed fecal coliform counts ranging from about 30 to 7,600 col/100 mL, with a geometric mean of 244 col/100 mL. Downstream data for August 16 and October 7 ranged from 80 to over 2,000 col/100 mL, with a geometric mean of approximately 1,100 col/100 mL.7 Wastewater from the regulator was sampled during wet weather on 2005. Fecal coliform counts (col/100 mL) varied from about 7x103 to about 2x105. However, data for the water intake itself shows minimal impact on the intake, with values ranging from 14 col/100 mL up to 630 col/100 mL, with a geometric mean of 36 col/100 mL. Data for these events can be found in Appendix B.

CSO 015 is located at Division Street East and the Ohio River. This is the Division Street diversion chamber with a 32-inch outfall, which is not monitored by SCADA. This CSO serves a small basin (94.2 acres) and includes domestic, small businesses, and a portion of St. Mary's Hospital (which is regulated under the Pretreatment Program). This outfall was briefly studied for CSO occurrences and the impact on water quality, although this was a challenge since this CSO is reported to overflow only rarely and for a short period of time. Because of the similarities between the Division Street and 25th Street watersheds and because bacterial impairment is the primary concern, the Division Street outfall was studied for only flow and fecal coliform. It is not expected to have any greater impact on the Water Company than 25th Street.

WVAWC tests raw water daily and sends a copy of its monthly report to the HSB. From our interview with employees of the Water Company, the installation of the new submerged water intake averts the noticeable increases in fecal counts, with relation to rainfall, as they had previously seen with the previous surface water intake. They believe their immediate upstream impacts are more likely due to the Guyandotte River. WVAWC is in the process of developing a source protection plan.

6 Testing included 5-day biochemical oxygen demand (BOD), total suspended solids (TSS), ammonia nitrogen (NH3N), chemical oxygen demand (COD), hardness, metals, fluoride, fecal coliform, oils and grease, phenols. 2-Bis (2-ethyl hexyl) phthalale, pH, temperature, and dissolved oxygen (DO). 7No sample values were available for the November 29 event for downstream. Data for about 40 percent of the downstream grab samples collected shows only "greater than" values, so geometric mean should be considered uncertain.

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Based on the following factors, HSB believes that HSB's CSOs cannot reasonably be considered to have a significant impact on the drinking water:

■ Favorable WVAWC water intake bacteria levels following relocation of their outfall to the mid-channel submerged location.

■ The likely inability of HSB CSOs, located in a plume along the South bank of the river, impacting the water intake

■ The minimal percentage impact of the CSOs on the Ohio River and therefore on the drinking water intake. HSB-performed calculations of relative volumes of CSOs and the Ohio River performed for three events in 2005 show that, at their peak rates, CSOs are typically diluted by four to six orders of magnitude or more. In addition, the drinking water intake flow rate represents about only about one-thousandth of the flow of the Ohio River (see Appendix B).

B. Priority Areas

The DEP has recently developed the concept of Priority Areas:

"Areas having some environmental significance but not to the level of "sensitive areas" as defined in the federal CSO Control Policy. These priority areas may include: public access areas (i.e., near marinas, schools, playgrounds, parks, or athletic fields); or use of shallow streams for recreational activity, with something less than full contact (i.e., wading)." (CSO Long-Term Control Plan Preparation Procedure, DEP, dated August 4, 2006, Revised November 30, 2006.)

It is understood that designating "priority areas" does not place a higher requirement for CSO control and is not a requirement of the National CSO Control Policy. However, in evaluating CSO abatement alternatives, communities may choose to prioritize those CSOs that impact Priority Areas. This section discusses several areas that could be identified as priority areas:

1. Ohio River

a. Harris Riverfront Park

Harris Riverfront Park is located adjacent to the Ohio River and associated with a marina, boat launch, and a public park but no bathing beaches. It is a central area in the city that is a site for different summertime festivals, concerts, and carnivals. The CSO outfalls that influence this area are 20th Street Regulator (013), 16th Street Regulator (012), 11th Street Regulator (011), and 9th Street Regulator (010). These CSOs are not monitored by SCADA.

i. The 20th Street Regulator is located on the river side of the levee and 20th Street and is

the 20th Street diversion chamber (013). HSB staff considered this overflow to be one of the more significant in terms of CSO volume and potential impact. The outfall is submerged, but during heavy storms, the discharge can sometimes be visible on the surface. The outfall pipe is 35 feet under ground and past attempts to install a flow meter have been completely unsuccessful with most of the meters being washed out to the river; therefore, flow studies on CSO 013 will require further consideration. This drainage area is mostly municipal and large industries: ACF (train parts manufacturer), XSYS Corporation (organic dyes), Tri-State Plating (metal plater), CSX Transportation

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(train engine repair), and Steel of WV (steel manufacturer) along with Marshall University and downtown Huntington. As discussed above, the 20th Street CSO was characterized in January and May of 2001 with extensive sampling and analysis (please see Appendix B for sampling results).

A preliminary sampling program was performed on CSO 013 during 2001 which showed that CSO discharge fecal coliform levels were relatively low, about 1,400 to 14,000 col/100 mL, with a geometric mean of about 4,700 col/100 mL. Upstream sampling showed fecal coliform values ranging from 1 to 1,200 col/100 mL, with a geometric mean of about 27 col/100 mL. At that time, HSB had not developed its sampling protocol to include downstream sampling, and this outfall is currently being studied. (The data for this event can be found in Appendix B.)

ii. The 16th Street (Hal Greer Boulevard) Regulator (012) is located on the river side of the levee upstream of Harris Riverfront Park. Although not as significant as the 20th Street basin, this CSO can produce significant overflows during wet weather and is a priority for HSB. This relatively large drainage area includes industries, local municipal flow, restaurants, and small businesses. This outfall has not been studied for flow and wastewater characteristics. The 16th Street CSO weir is within the flood protected area.

iii. The 11th Street diversion chamber (011) is located on the levee side of Harris Riverfront Park. This outfall has not been studied for flow and wastewater characteristics. The 11th Street CSO weir is outside of the flood protected area.

iv. The 9th Street Regulator (010) is located on the river side of the levee at Harris Riverfront Park. The drainage area includes local municipal flow with domestic (apartments), restaurants, and small businesses. This outfall has not been studied for flow and wastewater characteristics.

This area is considered a priority area because of the public use of Harris Riverfront Park and the associated boat launching facilities, if implementation of such projects would be practical.

b. Lighthouse Marina

The Lighthouse Marina is located at 90 Guyan Street in Huntington above the confluence of the Ohio and Guyandotte Rivers. This is a business involved in the docking and maintenance of privately owned boats. The outfall in this area, Outfall 020, Richmond Street Lift Station, is considered a priority area because of complaints by the owner of the marina. There is a box company that prints boxes with food-grade, nontoxic inks, and during wet weather events, it can impart color to the river. The drainage area also includes domestic and other small businesses. Outfall 020 wastewater characteristics have not been studied but flow is monitored by SCADA. This is considered a priority area because of the public use of the Lighthouse Marina and past property owner complaints. The 35th Street Pump Station CSO 021 is also located upstream of the Lighthouse Marina; however, since it overflows infrequently, this is not considered a concern by HS8 staff.

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2. Fourpole Creek

Fourpole Creek has its headwaters near Beech Fork State Park, and in Huntington, it runs the entire length of Ritter Park and St. Cloud Common and has its confluence with the Ohio River near mile point 312. Major tributaries to Fourpole Creek are Grapevine Branch, Unnamed Tributary along Woodville Lane, and Hisey Fork. The total length of Fourpole Creek is over 10 miles, about half of which is within the HSB service area. This area is mostly residential. In Ritter Park the creek has a shallow area near the picnic shelter, which is an area where children commonly play and wade. Throughout the park, the creek is crossed by numerous wooden and stone footbridges and, during the dry summer months, is very shallow. Upstream of Huntington, the creek is influenced by septic tanks and several homeowner associations' sewage treatment systems, including extended aeration plants and aerated ponds. This creek also flows through many rural unsewered or partially sewered areas.8 In the past, fecal coliform samples upstream of Huntington have revealed elevated background concentrations. Fourpole Creek was considered a "Sensitive Area" in HSB's 2000 LTCP because of public accessibility, but it would now be determined as "Priority" because it does not support full body contact but is wadeable. The only HSB CSO outfall that can influence the creek is in the St. Cloud Common area (James River Road Regulator-CSO 024). HSB has collected samples for fecal coliform the entire length of the creek within the city limits. HSB continues to monitor several locations of the creek for public health reasons. (See Appendix B for water quality monitoring data related to this area.)

St. Cloud Common is the site of several little leagues ball park and a larger park that sees some city adult league activity. It also has a daycare located on the property. The area of concern is the shallow pools adjacent to the ball parks where children can wade and play in the creek. The James River Road outfall, CSO 024, serves an area that receives mostly domestic flows with a few local businesses. HSB has attempted to monitor the flows and sample the discharges, but these have all proven unsuccessful. The possibility and extent of the impacts of this outfall on the creek are not known; however, it remains a priority for HSB because of the public access to the associated waters.

3. Guyandotte River (CSOs 016, 017, 018, 018A, 019, 036)

The Guyandotte River is approximately 166 miles in length and enters the Ohio River at mile point 305.2, upstream of the City of Huntington and the WVAWC. The Guyandotte River has its headwaters in Raleigh County and flows through several rural counties in the state with many unsewered or partially sewered areas. There are numerous extended aeration treatment systems, ponds, and septic tanks that influence the water quality of the river.9 Past studies of the river from 1996 to current show that the river has elevated background concentrations of fecal bacteria, mostly because of its rural setting and associated bacteria loadings from nonpoint sources and failing or poorly performing on-site or small public wastewater systems. The area of the river influenced by HSB's CSS is approximately 3 miles from the mouth to the most upstream CSO 036 at Altizer Pumping Station. This represents less than 2 percent of the entire river length.

The only boat launch in this area is located at the mouth of the Guyandotte at the confluence of the Ohio River. There are no "swimming holes" or parks on the Guyandotte in Huntington, and it is not considered a common place to swim. Other than the area associated with the boat launch, the steep banks of the river do not favor accessibility.

8 The entire list of dischargers to Fourpole Creek can be found at http://www.wvdep.oro/Docs/2977_fourpole_ tmdl_odf. 9 The TMDL can be found at http://www.epa.go v/rea3wapd/tmdl/wv tmd l/Gu vandotte/index. htm.. AppendixC of the TMDL for discussion of these dischargers.

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Because of the upstream impacts on the Guyandotte River and the relatively low human contact with the river in Huntington, HSB believes that Guyandotte River outfalls may not warrant special priority for the HSB CSO LTCP. However, consideration is given to past discussions with the DEP that have suggested the Guyandotte as a possible sensitive water body. A further discussion of the outfalls and the past total maximum daily load (TMDL) on the Guyandotte is provided here.

a. Outfall 016, Fifth Avenue Pump Station, receives a great deal of domestic stormwater runoff. There is some housing on the system and local restaurants, businesses, and industry. This outfall was characterized in 1994 (see Appendix B) and has not been studied since that time. Outfalls are monitored through SCADA. The outfall is not submerged and is therefore visible from the river.

b. Outfall 017, Robey Road Pump Station, serves a large mostly impervious area that includes both residential and commercial customers. The outfall is not submerged and is visible.

c. Outfalls 018-1 and 018-2 are located at the Pats Branch Pump Station, with a large industry, landfill leachate, and an urban setting with many streets, driveways, and roof drainage.10 These outfalls were characterized by the Board in August and September of 2002,11 and the flows are monitored by SCADA. The outfalls are visible.

i. Outfall 018-1 takes a lot of stormwater and it discharges very quickly during a rain event.

ii. Outfall 018-2 has a 30-inch pipe feeding it from a more rural setting with landfill leachate and industrial drainage. Overflows go to the Pats Branch basin through a 30-inch outfall pipe. Because of a lower level of imperviousness, this outfall occurs less often than 018-t and does not generally overflow unless 0.25 inches/hour (or greater) of rain occurs.

d. Outfall 019, Oak Street Station, serves a small drainage area. This outfall has not been characterized but is monitored by SCADA. The outfall is not submerged.

e. Outfall 036 is the Altizer Pump Station, which is monitored by SCADA. HSB staff report that silt deposition in the pipe may constrict its ability to overflow.

The DEP TMDL12 for the Guyandotte River states that, in setting Waste Load Allocations, the following assumption was made in allocating fecal coliform sources: "All point sources in the Guyandotte River watershed were set at permit limits (200 counts/100mL monthly average) and all illicit, non-disinfected discharges of human waste (straight pipes, etc.) were eliminated." The TMDL was based on a study performed by ORSANCO, which showed that the background fecal coliform values are high upstream of HSB's CSOs. The study also showed further impairment within HSB's area of influence. Based on this TMDL, HSB's permit, Section E.05.c, requires discharges from CSOs 016, 017, 019, and 036 to comply with water quality standards for Fecal Coliform.13

10 Although named Pats Branch, the outfall is to the Guyandotte River. Pats Branch was listed on the 303d list at one time but has since been delisted. http://www.wvdep.orq/Docs/3001 PatsBranch Final.pd ( A new TMDL for this stream is not anticipated.) 11 Pats Branch CSO (CSO 018 and 018A sample data appear in Appendix B 12 http://www.epa.gov/reg3wapd/tmd/wv_tmdl/Guyandotte/index.htm

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13 CSOs 018 and 018A are also located on the Guyandotte River but are not listed in this section of the permit.

Meeting a 200 counts/100mL fecal coliform limit on the Guyandotte would require primary treatment and disinfection, since CSO discharges are typically several orders of magnitude higher than the limit. However, HSB strongly believes that setting such limits is inappropriate when background impairment from nonpoint sources appears to have a significant impact and makes designated uses unattainable. In addition, HSB staff notes that at the time the study was conducted (1995), one of HSB's force mains had failed and had been discharging wastewater into the Guyandotte River for three weeks. The 2004 TMDL is based on data collected from 1990 to 1995. The force main has been replaced and there have been other collection system improvements. It is recommended that a new TMDL analysis of the Guyandotte be performed in advance of requiring costly projects to eliminate HSB CSOs to the Guyandotte.

4. Krauts Creek

Krauts Creek is an intermittent stream that has one CSO outfall near the mouth of the creek at the confluence of Twelve Pole Creek, very near the Ohio River. This creek was impacted by a benzene spill and remediation work is still ongoing. This is not a typical area where children play. HSB has performed an ambient water quality study, which entailed walking from mud puddle to mud puddle, suggesting that this waterbody is not appropriate for water contact recreation. (The data for this ambient sampling appears in Appendix B.) HSB has not characterized this outfall, but it is monitored for flow by SCADA. Krauts Creek is not considered a priority area.

5. Basement Backups

The HSB receives a couple of hundred calls to the sanitary board office each year, and all are investigated by the field supervisor or a Vactor truck crew. Main sewer lines are checked by a manhole being opened on either side of the affected residents and if any sewage appears to be backed up, the line is then pulled and cleaned. If the property owner has an outside cleanout, it is also checked for a potential backup.

From June 30, 2005, to July 1, 2006, the main sewer was the cause of the backup only 54 times. In this same time period, 146 dig down repairs were made to repair main sewer lines that had bells of the pipe leaking or needed repairs to the service lateral.

Many of the sewers that serve Huntington are laid in gravel alleys or rights-of-way. If several homes on a section of line have water that backs up and goes down after the rain event, this indicates, in some cases, that gravel is in the line. These lines are then pulled and cleaned. The affected customers are then contacted to see if cleaning has eliminated the problem. Main blockage causing basement backups do not appear to happen in one area. No pattern has been observed pertaining to main backups that were addressed over the last couple of years.

When a backup call is received by the sanitary board, a work sheet is filled out with name, location of problem, and phone number. A field supervisor is dispatched to investigate. The field supervisor will write on his copy of the work order what was found and how the problem was handled. The completed form is then returned to the HSB department head for review and filing. At the morning meeting on the next work day, it is determined if further action is required. The property owner is notified of findings and the recommended next course of action that will be needed to address the problem.

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4.0 SYSTEM CHARACTERIZATION

A. System Description

Figure 3-1 shows an overview of the sewer system serving the City of Huntington and the adjacent municipalities. The HSB owns and operates a combined sewer system that serves the entire city of Huntington and certain outlying areas. The estimated population within this service area is about 51,475, based on year 2000 census figures for Huntington and the nearby areas. Huntington also provides conveyance and/or treatment for several other municipalities and public service districts (PSDs). Wastewater from the Pea Ridge PSD on the far east side of Huntington and the Spring Valley PSD on the southwest side is conveyed through Huntington's CSS to the WWTP.

In addition, the City of Kenova, Town of Ceredo, and Northern Wayne PSD convey their wastewater directly to the WWTP via pumping stations and force mains. The population of these areas is estimated to be approximately 14,500, based on the number of customers reported for each by HSB. Because the wastewater from these municipalities does not enter the CSS, their flows will only be considered in the evaluation of the WWTP for this LTCP. The combined total population of all communities served by the WWTP is estimated to be just over 66,000.

The system is divided into 20 separate sewersheds, named for the primary CSO that serves them, as shown on Figure 3-1. (Sewersheds that have been identified by Chester Engineers were applied for this analysis.) Each sewershed is served by one or more trunk sewers or interceptors, portions of which are shown. Wastewater is conveyed by these sewersheds toward the Ohio or Guyandotte Rivers, where the major pumping stations, force mains, and interceptors are located.

About 80 percent of the HSB system has combined sanitary and storm sewers. HSB staff indicates that subsewershed areas having separate storm and sanitary sewer service are concentrated in the western sewersheds (002, 003, and 004) and in the far east (portions of 018). For the purpose of this LTCP analysis, it will be assumed that the remaining basins are fully combined. The partially separate basins represent approximately 45 percent of the entire area of Huntington. It will be assumed that Basins 002, 003, 004, and the Altizer area of 018 (served by 036) are about 50 percent combined and that the remainder of Basin 018 is 80 percent combined, based on some stormwater separation at the industry Inco within the basin.14

During wet weather, regulators within each sewershed allow flow that exceeds the capacity of the conveyance system downstream to be discharged into nearby streams and rivers. The majority of basins are served by one CSO. One exception to this is Basin 004 (Fourpole), which is also served by upstream CSOs 024 (James River Road), 023 (Park Avenue), and 022 (B&O Regulator). The second exception is Basin 018 (Pats Branch), which is served by upstream CSO 036 (Altizer Pump Station) and by 018A (Pats Branch No. 2), located adjacent to 018.15 Table 4-1 provides detailed information on each sewer shed and CSO, including information on the customers who discharge to HSB's CSS or WWTP. The format of this information is similar to that of Schedule 4 in the LTCP-EZ Template and provides information such as latitude and longitude of the CSO and acreage.

14 It is recommended that any modeling that may be performed in advance of design in the future carefully delineate areas of separate storm sewers, basin by basin. In particular. HSB notes that there are several areas in the Robey Road (017), 20th Street (013). 16th Street (012), 4th Street (009). and 7th Street (007) Basins in which storm sewers are installed and flow south toward Fourpole Creek, even though sanitary sewers and downspouts flow toward the north. In many cases, the stormwater enters the Fourpole interceptor, rather than Fourpole Creek. These represent good opportunities for separation. However, these must also be considered for projection of flows throughout each basin. 15 For the basin flow computations performed in Section 5, Basins 004 and 018 are subdivided into the basin areas

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served by each CSO. with allowances made for the fact that the sub-basins within the larger basin act in series. Areas shown in Table 4-1 reflect the subdivided areas. Table 4-1 also reflects recent separation improvements to the Park Avenue (023) Basin.

Wastewater from the sewer sheds is conveyed to the WWTP at the far western portion of the city via intercepting sewers and force mains that parallel the Guyandotte and Ohio Rivers. On the southeast side of the city, wastewater from each basin [017 (Robey Road PS), 018 (Pats Branch PS), 019 (Oak Street PS), and Pea Ridge PSD (5th Street tie-in)] flows to dedicated pumping stations and is conveyed through the 14- to 24-inch Guyandotte River Force Main (GRFM) to the east side of the Guyandotte River near the 3rd Avenue Bridge. On the northeast side of the city, wastewater from Pea Ridge PSD (39th Street tie-in) and Basins 021 (35th Street PS) and 020 (Richmond Street PS) enters the 6- to 10-inch East Side Force Main (ESFM), which joins the GRFM and crosses the Guyandotte River (24-inch), and discharges to the 36-inch Ohio River Interceptor (ORI). Flow from Basin 016 (5th Avenue PS) enters the 10-inch 5th Avenue FM, discharging into the ORI at the same point as the GRFM.

For the most part, combined wastewater from Basins 007 through 015 (between the 17th Street Bridge and the Guyandotte River) flows by gravity into the 36- to 54-inch ORI. One exception is the 4th Street PS, which pumps from Basin 009 and lifts all of the upstream flow from the ORI and discharges it at a higher elevation in the 48-inch ORI. Wastewater in the ORI flows to the 13th Street PS (at Basin 006), which pumps all of the flow into the 48- to 54-inch Ohio River Force Main (ORFM) that discharges directly to the WWTP. Other PSs that discharge directly to the ORFM include the 22nd Street PS (Basin 005), Fourpole PS (Basin 004), and East Road PS (Basin 003). The Fourpole PS serves the largest major basin in the city, which covers the southern, upland portion of Huntington. As mentioned, the interceptors that flow to the Fourpole PS have upstream CSOs. Basin 003 also provides conveyance for flow from the Spring Valley PSD.

Basin 002 in extreme western Huntington is served by the Krauts Creek PS, which conveys flow directly to the WWTP via its 6-inch force main.

Tables 4-2 through 4-4 provide detailed information on the pumping stations, gravity sewers, and force mains that form the major part of the CSS nearby and downstream of the CSOs. The system also includes many smaller pumping stations and many miles of collecting sewer upstream of the CSOs that are not discussed in this report.

B. CSS Response to Rainfall

1. Occurrences of Permitted CSOs

Of HSB's 25 CSOs, 14 are monitored through SCADA at their associated pumping stations. Table 4-5 summarizes identified CSO days for 2003 through 2005 and CSO "events" for an 18-month period from July 2005 through December 2006.16 The two sets of data yield somewhat different conclusions. The 2003 through 2005 data suggest that West 22nd Street (005) and Oak Street (019) are the most significant CSOs, followed by 5th Avenue (016), Robey Road (017), Richmond Street (020), and 35th Street (022). The July 2005 through December 2006 data suggests that East Road (003), 5th Avenue (016), and Richmond Street (020) are the most significant CSOs; together with Fourpole Creek (004), these are the four CSOs that would be considered to exceed DEP's six-occurrence per year criterion. However, this data should be interpreted with caution, as particular aspects of the SCADA monitoring system suggest that some CSOs may be over- or underreported.

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16 As of January 2006. DEP changed the definition of a CSO event. Prior to 2006, a 3-day long CSO event was reported by HSB to be three CSOs. Since 2006. this would be defined as one CSO.

For example, SCADA information from the Pats Branch PS (018 and 018A) suggests about three and five overflows per year, respectively. At this location the two diversion chambers are external to the pumping station, neither of which is directly monitored; instead, a float in the pumping station wet well itself, set to the approximate elevation of the diversion weirs, is used as an indicator of overflow. However, the configuration of the influent piping to the station suggests that these may overflow before the float is activated in the wet well. HSB staff reports that this CSO likely occurs more than the SCADA system reports, approximately 12 times per year.

On the other hand, the 5th Avenue PS is reported by SCADA to have 27 CSOs per year. The SCADA-monitored float on this station is located on the downstream side of the weir and may be activated by high river levels. HSB staff reports a frequency closer to 12 times per year may be more accurate. In another example, the Richmond Street CSO is reported to have over 20 overflows per year. HSB staff reports this air ejector pumping station experiences operational difficulty when stressed during wet weather, although its nominal rated capacity suggests it should be able to operate with fewer CSO occurrences.

Currently, the remaining 11 CSOs are not monitored through SCADA, although certain critical CSOs are regularly inspected, including 012, 013, and 014 (16th Street, 20th Street, and 25th Street). HSB staff indicates that installation of a simple chalk line, float, or block-and-cord system, which would allow inspectors to visually assess whether a CSO had occurred, would be practical and would not represent a significant additional burden on staff when these outfalls are inspected. A method for daily record keeping of these inspections have been developed.

HSB staff was interviewed regarding each of the CSOs to better assess whether the SCADA-reported values appear accurate based on experience and what the frequency of the non-monitored CSOs likely is. Table 4-5 shows the CSO frequencies as approximated by the field staff interviewed, although there was a variance of opinion among the staff regarding the frequency and severity of some of the overflows. In some cases, staff felt that the SCADA reported values were likely correct. For the purposes of this analysis, these observations will be used in lieu of the SCADA-based CSO occurrence data. However, it is noted here that these estimates are uncertain and will need to be adjusted once a new program for evaluating the non-monitored CSOs is in place.

2. Occurrences of Other Overflows

The HSB staff was interviewed regarding basement backups and overflows at nondesignated CSO manholes during wet weather. The staff indicates that the basement backups that occur in the system (described in Section 2) are typically caused by blockages or pipe collapses unrelated to wet weather. However, there are several areas in the city that experience surcharging manholes during wet weather conditions, shown on Figure 3-1:

Arlington Boulevard and Route 60 (Basin 017-Robey Road).*

Ferguson Road and Robey Road (Basin 017- Robey Road).*

3rd Avenue to 5th Avenue, 23rd Street to 27th Street (Basin 016-5th Avenue).

Doulton Avenue, Hal Greer to 18th Street (Basin 012-16th Street).*

16th Street and Washington Boulevard, Enslow Park area (Basin

004-Fourpole).*

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Jackson Avenue between 8th and 13th Streets West (Basin 006-West 13th

Street and 007-West 7th Street).*

Chase Street along railroad tracks, west of Vinson Street (Basin 003-East Road*)

5th Street West and 11th Avenue

These surcharge conditions indicate that the trunk sewers and interceptors upstream of the permitted CSOs are not adequate to handle projected flows. However, as will be discussed in Section 6, HSB staff has identified straightforward stormwater separation projects that would reduce or eliminate flooding in those basins marked with an asterisk above. It is assumed for this analysis that those projects would be pursued as part of the LTCR While detailed analysis of the remaining areas (primarily 5th Avenue) is beyond the scope of this LTCP, it will be assumed that the trunk sewers serving this area may require reinforcement or replacement. These improvements would be required in any CSO abatement alternative considered and therefore do not affect the selection of the best alternative.

It will be assumed that the remaining basins do not have flooding problems and that no trunk reinforcement would be necessary. This is a significant assumption that will affect the wet weather flow projections developed, which will be discussed in Section 6.

C. River Water Intrusion

A significant threat to the system is the intrusion of river water into the CSOs with low-elevation weirs and/or nonexistent or improperly functioning tide gates. This intrusion only exacerbates overflows, although intrusion may occur irrespective of rainfall. A detailed evaluation of the feasibility of raising weirs or installing new backflow prevention valves on the CSOs is beyond the scope of this LTCP, but HSB is working towards an evaluation

D. WWTP Description

Located on the far western end of Huntington (in Wayne County), at Vinson Road and the floodwall, the HSB WWTP is a Class IV facility that provides treatment for up to 17.0 mgd average daily flow, 46 mgd peak hourly flow, and 60 mgd maximum hydraulic capacity. Design Criteria for the WWTP can be found in Appendix A. The current average daily flow at the plant is 14 mgd, but flow is typically about 10 mgd during dry weather conditions. Although minor growth is expected in Pea Ridge at the east end of the service area, the flow to the plant is not expected to increase by more than about 1 mgd over the foreseeable future. Wet weather flows from the PSs typically exceed the capacity of the plant, and PSs are throttled down as an operating practice to limit the total WWTP influent flow to the available hydraulic capacity. PS throttling does, of course, result in CSOs at the designated CSO locations in the CSS.

All flow is conveyed via force main directly to the WWTP, and no influent pumping is provided at the plant. Preliminary treatment is provided by two mechanically cleaned bar screens followed by two pre-aeration/grit removal chambers. The wastewater then flows to the four rectangular primary clarifiers, each with a 563,000-gallon volume and 5,000-square-foot surface area.

Conventional activated sludge treatment is provided in eight rectangular aeration basins (volume of each basin is 552,000 gallons), which use coarse bubble aeration. With respect to the solids loadings to the secondary clarifiers, TSS removal data suggests that all eight secondary clarifiers are required. This is especially true since Huntington is a combined sewer community and the WWTP encounters peak hourly wet weather flows that are higher than three times the average dry weather flows. Operating the aeration

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tanks at a mixed liquor suspended solids (MLSS) concentration of 2,000 mg/L can reduced the MCRT and also reduce the solids loadings to the secondary clarifiers during wet weather events. Based on this recommendation, two aeration tanks can be removed from regular service. However, if necessary because of operational problems or excessive wet weather flows, one or more of these tanks can be readily brought into service as needed.

Following treatment in the aeration basins, the wastewater flow enters the final clarifiers for final sedimentation and skimming. Final clarification is achieved in eight rectangular final settling tanks, each with a 456,000-gallon capacity and 5,100 square-foot surface area. Clari-Vacs run continuously to remove the settled sludge from the tank bottoms and skim the surface to remove scum or floatable substances. A portion of the removed sludge is then wasted from the system.

This waste activated sludge (WAS) is sent to one of two dissolved air floatation (DAF) units for thickening and is then pumped to a 150,000-gallon gravity sludge thickener. The remaining portion of final clarifier underflow is returned to the primary effluent (PE) as return activated sludge (RAS) and reenters the aeration basins. The skimmings from the secondary clarifiers are pumped to the influent end of the number four primary tank and are collected with the primary scum, which is sent to the scum concentrator. Flow from the final clarifiers then enters two chlorine contact chambers (260,000 gallons each) where disinfection with gaseous chlorine takes place. Dechlorination is provided in the effluent discharge flume by liquid sodium bisulfate.

Primary sludge is sent to a circular 150,000-gallon gravity sludge thickener. The thickened and blended primary and secondary sludge is dewatered on two belt filter presses. The dewatered sludge cake is then sent to a landfill for disposal.

Most of the plant equipment is operated manually from push button (start/stop, hand/off/auto, or open/close) stations located at each piece of equipment or from the main control room,The pH and dissolved oxygen (DO) levels are monitored with HACH SC 100 meters and LDO probes and linked to a computer in the foreman's office for monitoring purposes. However, the aeration equipment is controlled manually. Most gates and valves, particularly in the primary portion of the plant, are hand-operated. Most secondary gates are motorized; however, many do not operate properly because of faulty motors or controls. Sludge line valves are manually operated and configured according to the specific job being performed.

HSB is currently working to upgrade portions of the plant. The pressurized chlorine disinfection equipment has been upgraded to an all vacuum system. We are also exploring solids handling and disposal alternatives. Additional improvements at the plant and system wide will be discussed in Section 7 with the Capital Improvement Plan (CIP).

G. Regulation During High Flow Events

Regulation of the flow to the plant during wet weather events was discussed in Section 2, NMC 4.

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5.0 PUBLIC PARTICIPATION

The City Council members were provided with individual copies of the Draft LTCP in early June, and a presentation on the LTCP was given to the City Council on June 11, 2007. In addition, the LTCP was made available for public viewing at area libraries and at the HSB offices during July and a public hearing on the LTCP was held in the City Building Auditorium on July 31, 2007, at 7 pm. The purpose of the public hearing was to present to the public the Draft LTCP and to encourage feedback. Approximately 40 to 50 people attended the meeting and there was a question and answer session. Aside from the comments made during the hearing, HSB received one written comment from the public. Appendix D includes materials relevant to the public participation, including:

Presentation made to the City Council on June 11, 2007

Advertisement for the Public Hearing and Affidavit of Publication

Letter from HSB to the Mayor, Board, and City Council announcing the public hearing

Letter from HSB to the City Planning and Development and the Neighborhood Association Presidents announcing the public hearing

Letter from HSB to the Army Corps of Engineers informing them of the public hearing

Presentation as made at the public hearing on July 31, 2007

Sign-in sheets for the public hearing

Questions and Comments from the public hearing

Newspaper coverage on the LTCP

Letter received from the League of Women Voters, In addition, the advertisement for public hearing was e-mailed to ORSANCO

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6.0 CSO VOLUME AND EVALUATION OF CONTROLS

Unless there are local economic constraints, EPA and DEP regulations require that 85 percent or more of wet weather flows or loadings be conveyed to a treatment location for treatment equivalent to primary treatment plus disinfection or that all flow be conveyed and treated except for the most intense storm conditions that occur up to about six times per year. The LTCP, therefore, must focus on the potential cost impact of constructing system improvements that would reduce flows and/or provide adequate conveyance and treatment capacity to achieve such a goal.

Projecting design sizing for proposed facilities with the various alternatives to be evaluated requires estimates of the volume and rate of CSO that may be generated during an established design storm. EPA's LTCP-EZ Template provides a method by which CSO flows and volumes can be projected for smaller CSO communities where construction of a computer-based hydrologic modeling program might be cost prohibitive. It must be recognized, however, that the LTCP-EZ flow development methods are very simplified in nature and cannot develop the level of accuracy and confidence available from detailed modeling or for the eventual design of system improvements.

This LTCP applies a multistep approach in identifying design flows under varying scenarios. First, the "rational method" prescribed in the EZ Template is applied. Next, adjustments to individual basin flow rates are then made based on a time of concentration analysis similar to that performed in stormwater analyses. Third, for basins that do not experience interior flooding, adjustments to individual basin flow rates are then made based on the capacity of each basin's sewers.

A. Identification of Design Storms

The LTCP-EZ Template assumes the application of a 3-month (four occurrences per year) 1-hour storm for long-term control planning and provides recommended rainfall intensities for all counties in the eastern US. The recommended rainfall is 0.75 in/hour for nearly all WV counties, based on extrapolation for frequent storms from information in the Rainfall Frequency Atlas of the United States.

The CSO control policy allows individual states to relax the standard to six occurrences per year (a 2-month storm). The DEP LTCP procedure proposes use of a 0.65 in/hour design storm but allows communities to identify alternative storm intensities based on local information. The Rainfall Frequency Atlas of the Midwest provides more detailed information on storm frequencies and durations and covers areas to the immediate north of Huntington in Ohio. This report will apply the 2-month storm intensities (e.g., 0.59 in/hr for a 1-hour storm) provided in that document for southern Ohio, as shown in Table 6-1.

B. Rational Method Determination of CSO Rates and Volume

Duration Inches

30 minutes 0.47 1 hour 0.5924 hour 1.2910 days 1.91Table 6-1: Two-Month Storm Intensities for Southern Ohio Rainfall Frequency Atlas of the Midwest

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Schedule 4 of the Template follows the rational method, which assumes that all rainfall onto impervious areas enters the CSS and combines with the industrial, commercial, and domestic wastewater flow to generate combined wastewater. The method assumes the rate that stormwater enters the system is directly proportional to the design storm rainfall rate averaged over an hour.

Table 6-2 performs the rational method calculation for each of the basins from information provided in Table 4-1. Table 4-1 shows the sub-sewer-shed area, percent combined, principal land use, and sub-sewer-shed imperviousness. This section describes each step of the analysis in the table. Land use and imperviousness were identified based on review of aerial photography contained in the City of Huntington geographic information system (GIS). Where a sewer-shed contained several types of uses or densities, the basin was segregated into two to four separate sub-sewer-shed areas. Imperviousness for each segregated area was visually estimated based on the roof and pavement areas relative to the entire area.17 Because of the density of development in Huntington, residential areas in the heart of the city were typically estimated to be between 50 and 80 percent impervious, with 60 to 65 percent being most typical. This is consistent with the 50 to 90 percent recommendation provided in the LTCP Template. The upland low density residential areas were assigned impervious values of 10 to 40 percent, which is generally consistent with the 10 to 30 percent recommended in the Template. Commercial and industrial areas were typically assigned impervious ratings between 50 and 100 percent, with an average of about 90 percent. This is somewhat higher than the Template-recommended 30 to 70 percent for commercial and 50 to 80 percent for industrial; however, this was considered appropriate since the Huntington industrial areas appear densely developed. In general, an effort was made to be slightly conservative in determining impervious percentages. The aggregated estimated impervious areas are shown in Table 4-1.

The next step was to determine the stormwater volumes and rates generated. Table 6-2 shows the estimated impervious area from Table 4-1 and the design storm applied. The total calculated runoff in acre-inches and million gallons per day is calculated. The next column allows the user to enter a factor of safety (FS), where 1.0 is recommended for flat areas and 2.0 is recommended for hilly areas by the Template. For two reasons, a FS of 1.0 is applied for this analysis throughout Huntington. First, the rational method is considered to be conservative in identifying flow rate. Second, analysis of total volumes generated is a key component of this LTCP and applying a FS greater than 1.0 would likely overestimate the volume produced during a storm. The adjusted runoff rate (mgd) is the product of the runoff and the FS.

To determine the dry weather base flows, approximate populations based on GIS-analysis of census block "Tiger files" for each basin were determined for basins in Huntington. For satellite communities, the number of customers as provided by HSB was applied, assuming 2.1 to 2.4 persons. It was assumed that residents generate approximately 100 gallons per capita per day. Commercial/Industrial flows were added to determine total dry weather flows. In general, dry weather flows are dwarfed by the stormwater flows and a great deal of accuracy regarding dry weather flows is therefore not critical to the analysis; where specific commercial and industrial flows were not easily determined, this was left blank. The basin wet weather flow rate is the sum of the adjusted runoff and dry weather flow. The "basin + customers" and cumulative wet weather flow takes into account that the flow that arrives at a point, such as a pumping station, may include some flow coming from customers and from upstream basins that did not escape the CSO.

The next step was to identify what the EZ form calls the "hydraulic control capacity"-the capacity of the existing interceptor/force main system to accept the wet weather flow. For CSOs with PSs, the PS firm capacity was used. For gravity connections to the interceptor, determining the regulator capacity is somewhat less straightforward. For the purpose of this analysis, it was assumed that during wet weather the ORI operates under somewhat surcharged conditions and that its hydraulic capacity is about 50 percent higher than the capacity computed by the Manning Equation based on diameter and slope.

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17 It is assumed for this analysis that all roof drains in combined areas are connected to the CSS.

Subtracting the capacity taken up by flow from the GRFM, ESFM, and 5th Avenue FM identifies an amount that can be allocated among the gravity connections. The rate of CSO at each regulator was then determined as the difference between total wet weather flow and the regulator capacity. The total one-hour volume of CSO was computed as the CSO rate divided by the 24-hour day. The combined wastewater collected at the basin and conveyed to the WWTP was

computed as the difference between the cumulative wet weather flow rate and the regulator capacity. Because of the double or triple pumping that occurs in the system, the combined wastewater collected includes some "double counting" of flow. Therefore, the combined wastewater collected to the WWTP was computed as only those flows from the pumping stations that pump directly to the WWTP. The table then shows the calculated sum of this column, excluding the flow from satellite communities that discharge to the plant. The total flow from the satellite communities of Kenova, Ceredo, and Northern Wayne was added to show that the total flow to the plant could be as high as 53.7 mgd. However, the primary treatment capacity of the plant is 46 mgd. Plant personnel intentionally throttle back flows at major pumping stations, as described above, to limit the sustained flow to 25 mgd. Therefore, an additional primary and disinfection capacity of 28.7 mgd would be required to treat the flow that could be conveyed to the WWTP.18 Table 6-2 also shows the rational method calculation of 1-hour volume of 54.8 million gallons (mg) at the CSOs and 1.2 mg at the WWTP. Volumes for longer duration storms will be discussed in Section 6E.

The sum of the CSO peak rates at the basins is 1,314 mgd. The Table 6-2 rational method results suggests that the existing capacity of the system is only a very small fraction of the total capacity required for conveyance and treatment of all or a significant portion of the Huntington wet weather flow and that Huntington would require in excess of 1,350 mgd of treatment capacity to provide treatment of all CSOs. Further, this method suggests that virtually every CSO would be expected to overflow during the 2-month design storm. However, SCADA records and interviews with HSB staff (Table 4-5) show that only about half of the CSOs overflow more than six times per year. Therefore, further analysis was performed to determine whether these values may be adjusted downward.

It is important to note that the projected peak flows from the rational method assume only rainfall and wastewater entering the CSS. The rational method does not consider the effect of backflow into the CSS from high river levels. An accurate analysis of this effect during a storm event would likely require computer-based hydrologic modeling, which is discussed below.

C. Time of Concentration (Ta) Analysis

One conservative aspect of the rational method is that it assumes that a basin's stormwater from a 1-hour storm would arrive at the interceptor over the course of one hour, neglecting the dampening effect of a large area basin. The method assumes that the hydrograph representing flow rate at the interceptor would look rectangular, as shown in Figure 6-1 (a). This is a conservative approach to determining the peak flow.

The "time of concentration" as used in the stormwater field is the length of time that it would take stormwater entering the most remote part of the combined sewer to arrive at the interceptor. For each individual basin, this "most remote" distance was estimated using topographic information and GIS data, assuming that collecting sewers were generally aligned with the surface streets. Table 6-3 shows this distance for each basin and the calculated Tc, assuming that gravity combined sewers would flow at a conservative 6 fps during a storm event.19

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18 However, the space for expansion of conventional primary clarification and chlorine disinfection at the WWTP is limited and is not considered an option for this LTCP. 19 Peak flow rates in sewers vary considerably depending on terrain, size of sewer, and whether surcharging conditions occur. Values of 3 to 6 fps or higher have been observed in other flow metering programs in Parkersburg and Morgantown. The value of 6 fps is applied as it provides a conservative result in the Tc calculation.

The computed time of concentrations ranged from about 4 minutes for the smaller basins to nearly an hour for the largest basins.

For a short duration storm (5 to 10 minutes), a simple stormwater hydrology analysis would include developing a triangular "hydrograph" to represent the flow rate at a point of interest. The peak of the triangle would occur at the Tc, the base of the triangle would be approximately 2.67 times Tc, and the area under the triangle would be the total volume of flow as calculated by the rational method. This concept is shown in Figure 6-1 (b).

Where Tc is much shorter than the storm duration, the "peak" of the storm would most likely last somewhat longer, and the shape of the curve may be more trapezoidal, as shown in Figure 6-1 (c). Because the Tc values for the HSB basins are generally shorter than the duration of the storm, the trapezoidal hydrograph will be applied. As with the shorter duration storm, the area under the hydrograph is the rational method volume and peak flow is determined there from.

Table 6-3 shows the individual basin peak flows as determined by this method. Note that the peak flow is somewhat lower but not a great deal lower on a percentage basis than the peak flow rate determined by the rational method. The Tc method does not resolve the question of why there are fewer overflows than the method would predict, since calculated basin Qpeak values still exceed the capacity of the interceptor/force main system more frequently than HSB staff believes CSOs actually occur. The next section addresses this question further.

D. Trunk Sewer Limitation of CSO Rates and Volume

The rational method analysis suggests that the peak wet weather flow in an area like Basin 005 (W. 22nd Street) might reach about 13 mgd. The Tc analysis suggests that this flow may be somewhat lower, but in most areas, it does not reduce it by much. However, W. 22nd Street PS is served by an 8-inch influent trunk sewer. Assuming a surcharged condition that may cause flow rates as high as 6 fps or hydraulic gradients three times the slope of the sewer (whichever is higher), this sewer could convey only up to about 1.4 mgd (see Table 4-3). In addition, HSB staff reports that this sewer only overflows about twice per year and that there are no unpermitted CSOs within the basin. It is believed that system constraints upstream of the permitted CSOs may limit the frequency of CSO occurrences by dampening their arrival at the pumping stations and interceptor.

This could occur, for example, by stormwater inlet capacities being exceeded or other constraints on the entry of stormwater to the CSS that would tend to divert stormwater to surface waters and away from the CSS.

This trunk constraint analysis was performed for each of the basins and their major trunk sewer(s) leading to the pumping station, using the preliminary assumptions above. This trunk constraint was applied for any basin that was not reported to have interior flooding or any basin with flooding that can apparently be alleviated by stormwater separation in selected areas. As shown in Table 6-4, the preliminary projection of peak wet weather trunk sewer flow is a significant constraint on the input to the pumping station/force main/interceptor system at a few points in the system. This method suggests that actual peak flows in the main portion of the conveyance system may be significantly lower than projected by the rational or Tc methods.

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E. CSO Volume

The rational method as applied by the earlier versions of the LTCP-EZ Template on which this report was based suggest that determination of CSO volume should be based on the 2-month 1-hour storm (0.59 in/hour). Based on Strand's experience with stormwater and sewer system modeling, a 1-hour storm produces a fraction of the overflow volume that would be generated in a 1-day or 10-day storm and evaluation of storage as an abatement option must be based on the longer duration storms. The rational method calculation was performed again using the 1-day and 10-day storms from Table 6-1. Because the simplicity of the rational method does not provide for intensity variation during the storm, a constant rainfall rate throughout the storm was assumed.20 Table 6-5 shows the total wet weather and CSO volumes generated based on the rational method for the 1-hour and 1-day storms. The 10-day storm produced smaller CSO volumes than the 1-day storm because of the constant rainfall assumption. However, because the 10-day storm typically controls required storage based on our analysis for similar communities, the CSO volume was approximated to be about 3.2 times the 1-hour CSO volume, based on the ratio of the total rainfall for the 10-day (1.92 inches) versus 1-hour (0.59 inches) events. It is assumed for this preliminary analysis that the largest of the 1-hour total volume, the 1-day CSO volume, and the 10-day projected CSO volume would need to be stored to abate CSO. As this report was being completed, the LTCP-EZ Template was revised (May 2007) incorporating several changes. One change proposed applying determining overflow volumes based on a "Diversion Fraction" method. Because this work was nearly complete at the time of Template revision publication, the storage volumes determination above has been applied.

F. Evaluation of Controls

This LTCP contains a combination of CSO control measures that most cost-effectively achieve CSO control to the required standard. The overall cost-effectiveness various alternatives is evaluated using a "Present Value" cost analysis, which includes: the up-front capital cost of the project, plus the costs to operate and maintain the project for 20 years, less the salvage value of the project at the end of 20 years. O&M costs include not only additional power and chemicals, but also additional staffing requirements to operate the new facilities. A discount rate21 is applied to bring all costs back to current year dollars. In other words, the present value cost is the amount of money that is required now to own and operate the project for 20 years, less the salvage value at 20 years.

Control measures for which costs will be evaluated generally fall into one of the following categories:

1. Inflow reduction 2. Storage 3. Conveyance

a. Pumping stations b. Force mains c. Gravity Sewers

4. Treatment

20 SWMM modeling allows the application of rainfall events that vary in intensity throughout the storm, which is a more realistic representation of rainfall conditions. 21 The discount rate is the interest rate that invested funds could yield, less inflation.

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Each control measure is further described here.

1. Inflow reduction

The purpose of inflow reduction is to keep as much Clearwater out of the CSS as possible, thereby reducing the amount of combined sewage that must be stored, conveyed, and treated. There are many potential alternatives for inflow reduction, including:

■ Porous pavements ■ Stormwater flow detention ■ Sewer Separation ■ Area drain and rood leader disconnection ■ Commercial and industrial runoff control ■ Green Roofing ■ Rain barrels and rain gardens

Of these, two primary methods of inflow reduction appear practical for CSO reduction in Huntington: sewer separation and roof drain disconnection.

a. Sewer Separation

Sewer separation is the physical separation of the sanitary and storm sewer systems. Typically this entails construction of new sanitary sewer facilities and utilizing the existing CSS for stormwater management purposes. New sewers would be used for sanitary sewer service that would be of tighter design, allowing for lower l/l rates than would be the case if the present sewers were used for sanitary service. In this way, all stormwater would be discharged to the waterways with sanitary sewage only conveyed to the WWTP. An obvious advantage is that this method significantly reduces demand on the conveyance facilities and on the WWTP.

Disadvantages of sewer separation are that the physical construction required produces significant construction impacts in congested areas and that separation is often very expensive for densely developed areas. Strand performed a survey of literature-reported sewer separation costs discussed in Appendix E of the Charleston Sanitary Board Long-Term Control Plan-Phase II (December 2005). Based on that review, a 4th Quarter 2005 sewer separation capital cost of $90,000 per acre in residential areas and $130,000 per acre in commercial areas was applied for fully developed areas. (Based on the Engineering News Record, construction costs have increased approximately 3 percent since the Charleston report was written.) Because of the very high density of development in much of the city, it is believed that these values may be somewhat low for Huntington. For simplicity of cost projection in this LTCP, an aggregate sewer separation capital cost of $140,000 per acre will be applied in fully developed areas.22 This cost includes construction, contingencies, engineering, and legal and administrative costs. A present value cost of $110,000 per acre is projected based on a 50-year life of the sewers. It will be assumed that sewer separation within a basin (or part of a basin) will reduce wet weather peak flow to approximately three times the dry weather average daily flow.

22 Based on the analysis performed for Charleston, the sewer separation cost projections provided in the LTCP-EZ Template ($40,000 per acre) are believed to be too low to apply to densely developed Huntington.

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Table 6-6 shows preliminary capital and present value cost for separation and projected flow that would result for each basin. This will allow an analysis of potential cost-effectiveness of separation later in this section.

The Sanitary Board has expressed a general preference for sewer separation over conveying and treating combined sewage, including investigation of nonconventional sewer installation techniques, such as directional drilling. In particular, a high priority for the Board is performing separation where it is easily accomplished. The analysis discussed above concerns new separation, that is, installation of new storm sewer where none currently exist. HSB indicates that there are several areas in the city where storm sewers exist but that flow nevertheless enters the CSS rather than nearby creeks. Staff reports that these areas could be separated relatively easily. These "low hanging fruit" areas are discussed specifically later in this section. Because most of the areas identified relieve flooding that should be considered a high priority, it is assumed that all of the separation projects discussed would be performed prior to construction of additional CSO projects.

b. Roof Drain Disconnection

The City of Huntington currently has an ordinance in place that limits HSB's authority to require disconnection of roof drain downspouts from the CSS. Many cities' sewer ordinances prohibit connection of roof and foundation drains because they contribute such a significant volume of Clearwater to the sewer system. The Clearwater instead is discharged to a separate storm sewer, if available, or to the land surface for overland flow to the nearest discharge point. Roof drain disconnection is a very low-cost means of reducing flow to the CSS, but it requires public cooperation and sanitary board authority to verify that homeowners disconnect and remain disconnected. From a legal perspective, it may be difficult to implement this approach unless on a citywide basis. However, separation or discharge to pervious areas may not be an option in all areas of the city because of the concern of adjacent property owners.

To project the wet weather flows if roof drains were disconnected, a revised impervious percentage in each basin excluding roof areas was approximated. Because wet weather flows dominate the total basin flows, it was assumed that the reduction in imperviousness is directly proportional to the reduction in flow rate, as determined by the Tc analysis. The trunk constraint was also applied (please see above discussion).

For the purpose of cost projection, it will be assumed that, where practical, capital costs to disconnect would be approximately $250 per home if carried out by HSB.23 It was assumed that the number of homes in a basin is approximately the population divided by 2.1 to 2.4 persons per home. Table 6-6 summarizes the results of these projections. This will allow an analysis of potential cost-effectiveness of downspout disconnection later in this section.

c. Raising Regulator Weirs

As mentioned previously, HSB reports that the weir levels on the CSO regulators are generally low and allow intrusion of Ohio River water into the CSS.

23 Cost may be reduced to $100 per home if carried out by the homeowner. Costs projections provided by the LTCP-EZ Template, Appendix A.

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A preliminary analysis performed by HSB suggests that many of the weirs could be raised to prevent this intrusion. Although river water intrusion is not technically a wet weather problem, raising the weirs would have the additional benefit of reducing the frequency of CSOs.

Because of the limitations of the rational method, the analysis discussed here does not explicitly evaluate the potential reduction in flows and overflow that could be achieved. However, like the potential for separation in areas where storm sewers already exist, raising the regulator weir is considered to be a "low hanging fruit" project and will be recommended as part of the LTCP.

2. Storage

Wet weather flows can be stored for discharge to the conveyance and treatment systems during nonpeak flow periods to eliminate or reduce CSOs Three methods of storage include

a. In-line storage-where storage within the sewer system provides a dampening of peak flows.

b. Off-line surface storage-where a portion of flows are diverted from the CSS into aboveground storage tanks, to be released into the CSS when flows have abated.

c. Deep tunnel storage-similar to off-line storage, except that large tunnels constructed below the land surface provide large volumes of storage with minimal surface disturbance.

Off-line surface storage is generally the most practically implementable means of storage and will be considered in this LTCP. Strand's experience with LTCPs shows that storage may be most cost-effective when applied in upstream or remote areas of the system since it reduces the amount of infrastructure for all downstream components.

For the purposes of cost evaluation, the available sources suggest costs ranging from less than $0.50 to over $5.00 per gallon of storage volume, with an average value of $2.00 per gallon. It is unclear whether these costs include any pumping that may be required. Strand's analysis for the Charleston Sanitary Board identified a linear capital cost function based on actual costs for aboveground steel or prestressed concrete tanks. For this analysis, that cost function, adjusted for inflation to 1st Quarter 2007, will be applied:

Capital cost = $0.90 million + $0.80/gallon, up to 15 mg = $0.86 million/gallon, greater than 15 mg

Present value cost = $0.65 million + $0.65/gallon, up to 15 mg = $0.69 million/gallon, greater than 15 mg

This acknowledges that larger storage systems will see a significant economy of scale. Any cost for an influent or effluent pumping station would need to be added to this cost. Although approximate, belowground storage will be assumed to have a cost about 2.5 times that for aboveground storage. For determining acreage requirements for surface storage, it will be assumed that side-water depths of up to 50 feet would be applied, based on the recommendations of pre-stressed concrete tank manufacturers.

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Some important limitations of aboveground storage should be noted. Because of visual impacts, it is most appropriate for nonresidential locations. Because the most cost-effective aboveground storage is a circular tank, square-shaped properties are optimal.24 Also, because of the circular shape, these tanks cannot take full advantage of available areas, and belowground storage should be considered where space is at a premium. Storage tanks (above- or belowground) may not be located within the 100-year flood plain because of the buoyancy of empty tanks

. 3. Conveyance

HSB's CSOs are spread out along the rivers and creeks in the city; however, it is impractical and costly to provide storage or remote treatment at each CSO location. Therefore, it becomes necessary to provide the means to convey wastewater either to the WWTP or to storage or special wet weather treatment facilities located remotely from the CSO or the present WWTP site.

Conveyance can either be accomplished by gravity sewers, which are generally more costly to install but have lower O&M costs, or by a network of pumping stations and force mains. Gravity sewers are not a practical way to convey the largest wet weather flows from the overflow locations to points of treatment or storage. This is because force mains are usually less costly to install, they can operate at higher velocities, and they do not have as many design limitations. In addition, wastewater typically needs to be pumped for discharge into aboveground or at-grade treatment or storage units. Experience has also shown that "parallel" pumping stations that pump into a common force main without wastewater being "double pumped" are more cost-effective. Based on this experience, it will be assumed that conveyance would be accomplished with a network of pumping stations and force mains.25

a. Wet Weather Pumping Stations

Wet weather pumping stations (WWPSs) are typically located at CSOs, in particular those that exceed the six-occurrence per year frequency and those with a potentially large volume of CSO. To limit the number of locations where pumping stations are required, Strand has typically applied an "interceptor relief concept whereby, when CSOs may occur, WWPSs take the entire flow out of the gravity sewers, thereby leaving capacity for downstream trunk sewer flow to be completely accepted by the interceptors. This design means that not every CSO requires a WWPS.

Because the projected CSO flows based on the rational, time of travel, and trunk constrained methods are so significantly in excess of the existing conveyance capacities, it will be assumed that new PSs would be constructed to manage wet weather flows, instead of determining whether and how existing PSs could be expanded. The City currently operates the flood pumping station system, a series of high capacity, low head flood pumping stations (FPS) that prevent flooding in Huntington. It may be possible to convert some of the FPSs to WWPSs, with considerable cost savings.

However, there are a few significant drawbacks to this approach. First, because these FPSs were constructed for the singular purpose of preventing flood damage in Huntington,

24 Except where multiple tanks are required 25 Application of gravity may be applied in localized segments of the system or where two CSOs are located closely enough that they warrant being served by a single pumping station.

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obtaining permission from the City and the Corps to modify the purpose and operation of the system may be very difficult. Second, the LTCP addresses flows up to a 2-month recurrence interval event. A converted FPS would convey much larger flow volumes and rates to the treatment and storage facilities during extreme events, requiring these facilities to be larger, which may mitigate any cost savings. Finally, FPSs likely are intended to manage some stormwater or surface water that should not be commingled with the combined sewage.26

Large pumping stations come in two general configurations: submersible and wet well/dry well. In submersible pumping stations, the pumps sit directly within the station's wet well and are submerged in wastewater and may be removed from the wet well with permanently installed vertical railing. A vault houses the discharge piping, shut-off valves, and surge relief valves. A separate room houses the electrical controls and odor controls, where required. This configuration is generally lower cost and has a smaller footprint than wet well/dry well pumping stations. Centrifugal nonclog pumps would be used. Because of their lower cost and smaller footprint, this LTCP will assume the application of submersible WWPSs. However, because the existing PSs are dry pit submersible, HSB may elect to apply dry pit submersible stations for the WWPSs.

It will be assumed that WWPSs will be designed for "firm capacity" (with the largest pump out of service) based on the required capacity determined from the trunk-constrained/time of travel analysis. WWPSs will have three to four pumps, with space for installation of one additional pump. For control of flow, it is assumed that all pumps will be equipped with VFDs.27 Finally, it will be assumed that the pump stations will be SCADA-controlled at the WWTP through telemetry and that redundant power feeds from separate substations would be supplied. No significant aesthetic features are included in the costs.

In addition to flow rate, a second significant driver of cost is the total dynamic head (TDH) of the pumping station. Networked pumping stations that are farthest from the discharge point typically have to be able to operate at higher heads than stations that are close to the discharge point. TDH will be approximated based on the length of force main and the

Hazen-Williams equation, which will be discussed below. It will be assumed that pumping station wet well levels are approximately 25 feet belowground [approximate elevation 540 feet mean sea level (MSL)], that discharge for treatment would be at 550 MSL, and that discharge for aboveground storage would be at 570 MSL.

Detailed cost evaluations were performed for individual wet weather pumping stations for the Parkersburg and Charleston LTCPs and recently bid large PS projects. Based on those evaluations and the construction cost index, cost functions for submersible pumping stations were developed for the HSB LTCP:

Capital Cost = $1.2 million + $65,000 x mgd062 x TDH045 Present Value Cost = $1.2 million + $95,000 x mgd062 x TDH045

26Once the overall LTCP is developed and design flows confirmed through modeling, it is recommended that individual wastewater pumping stations be evaluated for possible cost savings by expansion. It is also recommended that individual flood pumping stations be evaluated for potential application as WWPSs. 27Some cost savings could be achieved by including installation of VFDs on one or two of the proposed pumps.

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b. Force Mains

For evaluation of force main (FM) alternatives and costs, it was generally assumed that FMs would be located parallel with the existing sewers and FMs along the Ohio and Guyandotte Rivers and as necessary to convey flow to the proposed CSO abatement locations, described in the following section. However, in the area between 20th Street East and the 5th Avenue PS, it was assumed that construction along the riverbank would be impractical, and the FM was assumed to be located within city streets. For evaluation of all options, it was assumed that FMs would be sized based on a peak flow rate of approximately 10 fps, applying the constrained/time of travel flow rates. (Flow velocities of about 7 fps were assumed for smaller diameter FMs to reduce TDH.) Construction costs for FMs were developed from per foot costs presented in Table 6-7 below, based on size and construction condition.

Pipe Size

(in) Open Go + Riverbank Reinforcement In Street Bore /

Jack6 $55 +$250 $400 $5508 $75 +$250 $410 $580

10 $85 +$250 $425 $61512 $100 +$250 $440 $64014 $115 +$250 $450 $67016 $125 +$250 $465 $70018 $130 +$250 $470 $72520 $150 +$250 $490 $75524 $185 +$250 $515 $82027 $215 +$250 $550 $87530 $250 +$250 $580 $92536 $325 +$300 $650 $1,04042 $430 +$350 $765 $1,25548 $570 +$400 $900 $1,69054 $700 +$450 $1,030 $2,12060 $840 +$500 $1,165 $2,60072 $1,155 +$550 $1,460 $3,90084 $1,550 +$600 $1,840 $5,200

Table 6-7 Unit Costs for Force Main Construction (per foot)

Four major construction conditions were applied:

1. Open Go-Construction in relatively open areas that would not have significant traffic, other nearby utilities, or significant restoration requirements.

2. Riverbank Reinforcement-This cost will be applied in addition to Open Go costs for construction along the river, where it is understood that slope stability may be an issue.

3. In Street-Construction in city streets would likely require sheeting to protect adjacent

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utilities and surface improvements, traffic diversion, and roadway restoration and may have a complex array of utilities that would have to be managed.

4. Bore/Jack-It is assumed that river, stream, highway, or railroad crossings would require installation by boring and jacking.

To develop capital cost projections, ductile iron pipe pricing was used for on-land construction conditions and polyethylene bonded pipe for in-river construction plus installation costs. To determine capital costs, the following costs were added: General Conditions (8 percent), technical services (15 percent), contingencies (35 percent), business and occupation (B&O) tax (2 percent), and 6 percent sales tax on goods. Costs were adjusted to reflect recent projects.

To develop present value cost projections, O&M was assumed to be $0.50 per foot of pipe per year, and the FM was assumed to have a 50-year service life. A discount rate of 4.875 percent was applied for determining salvage value and present value.

For determining WWPS TDH, unit head loss within FMs was approximated using the Hazen-Williams equation:

HL/100 feet = 0.2083 x (100/C)1852 x q1852/d48r, where

HL = Head Loss C = Friction factor of 120 q = Flow in gpm d = pipe diameter in inches

c. Gravity Sewers

The capacity of gravity sewers is typically determined by the application of Manning's Equation:

Q = vA=(1.49/n)AR(2/3)M'S

where

Q = flow capacity in cfs

v = flow velocity in fps

A = cross sectional area of the pipe in square feet

n = Manning roughness coefficient (0.013 for new pipe up to .017 for older pipe)

S = hydraulic slope, as a decimal fraction

The hydraulic radius, R, is given by R=A/P where R = hydraulic radius in feet

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Pipe Size (in) Open Go In Street12 115$ 840$ 18 130$ 850$ 24 180$ 860$ 30 250$ 900$ 36 325$ 950$ 42 430$ 1,000$ 48 570$ 1,070$ 54 700$ 1,120$ 60 840$ 1,300$ 72 1,155$ 1,460$ 84 1,150$ 1,840$

Table 6-8: Unit Costs for Gravity Construction (per foot)

P = wetted perimeter (circumference) of the pipe in feet For a circular full pipe (diameter = D), the hydraulic radius is equal to D/4. The capacities of the existing gravity sewers downstream of CSOs to convey wet weather flow was evaluated based on Manning's equation. Table 4-3 shows selected segments of gravity sewer and their Manning-based capacity.

Although this plan assumes that most conveyance will be by force main, some portions of the improvements downstream of the CSOs may be best served by gravity sewers. For new proposed gravity sewers, the size was determined with Manning's equation, based on the slope of the existing gravity sewers. As with FMs, unit construction costs for gravity sewers were developed for different sizes and the Open Go and In Street construction conditions described above, as shown in Table 6-8. Capital Costs, O&M, and present value apply the same assumptions as for FMs described above.

4. Wet Weather Treatment Facilities

One potentially cost-effective way to manage wet weather flows is to provide wet weather treatment facilities (WWTFs) intended to provide primary treatment and disinfection only for flows above the system capacity. WWTFs can be located at or near the existing WWTP or at a remote location. For Huntington, a large volume of CSO is generated on the east side of the city in the Guyandotte River area; the ability to treat and discharge wet weather flow on the east side of the city has the potential to significantly decrease overall LTCP costs.

The purpose of treating CSO prior to discharge is to reduce the level of impairment in the rivers and streams. Sampling programs elsewhere have consistently shown that the only impairment caused by CSOs is due to bacteria (fecal coliform and E. coli, for example). Therefore, selected treatment technologies must facilitate disinfection in particular. Effective solids removal is a key first step to achieving adequate disinfection. Without effective solids control, bacteria are "shielded" by the solids and are not effectively destroyed by disinfection.

LTCP efforts and other municipalities have evaluated numerous treatment technologies on the basis of their ability to help achieve a WWTF that is compact, reliable, easy to operate and clean up, simple, and safe. Huntington has undeveloped flat areas outside the floodplain are extremely limited, and compactness of design is therefore a critical feature.

Chemically assisted high rate clarification holds promise for creating a compact WWTF and is known commercially as Actiflo®, DensaDeg®, or by other trade names. Actiflo®, shown in Figure 6-2, introduces a chemical coagulant, polymer, and fine sand ("ballast") to the wastewater in the "flash mixing zone." The

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wastewater then flows to a gentle mixing zone where large sand-ballasted floes form. The flocculated wastewater then flows to a settling zone equipped with lamella (diagonally oriented plates) to enhance the settling rate. DensaDeg® follows the same concept using solids from the wastewater stream instead of sand. In both cases, the ballasted floe settles to the bottom of a settling tank. Solids are drawn off the bottom of the tank and are sent to a hydroclone that separates the wastewater solids from the denser solids. Wastewater solids are returned to the sewer and the denser solids are reused. Because of the ballast, floe settles significantly faster than normal wastewater floe, and solids clarification can be achieved in about one-tenth the area normally required for primary settling. The process is significantly more costly and complex than traditional primary clarification, but limited land areas in Huntington will likely dictate a high rate clarification system.

High rate clarification followed by liquid chlorine disinfection and liquid dechlorination was considered. Liquid chlorine and liquid sodium bisulfite are safe, relatively simple to use, and cost-effective. However, between the contact tank (sized for 15 minutes of contact time at peak flow) and the storage for these chemicals, chlorine disinfection occupies approximately as much space as the high rate clarification system. However, based on HSB staff review, it appears that potentially available properties may be very limited, as discussed below. Therefore, an alternate means of achieving disinfection is recommended.

Ultraviolet (UV) disinfection is a viable alternative to chlorine disinfection when space is not available. Clarified wastewater is sent through a channel in which closely spaced UV lamps are suspended. Pathogens are inactivated because UV light causes damage in the DNA, leaving them unable to reproduce. The footprint of these systems is a fraction the size of chlorination facilities.

However, there are some important limitations or disadvantages to UV disinfection. The capital and operation cost of UV systems is highly dependent on the quality of the wastewater to be treated. In particular, the expected UV transmittance (UVT) dictates UV system design and cost. Where high UVT (>85 percent) can be achieved, UV is cost-effective relative to chlorine. However, costs increase dramatically with decreasing UVT. A 50 percent UVT is assumed for projecting costs.

Projected cost functions for a WWTF with mechanical bar screen, high rate clarification, and UV disinfection are as follows:

Capital Cost = $7.5 million + $0.75 million x mgd Present Value Cost = $8.2 million + $0.8 million x mgd.

If larger sites for storage or treatment can be found, it may be possible to apply chlorine disinfection instead of UV disinfection for a lower overall cost:

Capital Cost = $9.0 million + $0.50 million x mgd Present Value Cost = $9.5 million +$0.54 million x mgd

G. CSO Abatement Locations

Evaluating alternatives for CSO control requires identification of locations within the system that may be available for storage or treatment. Recommended criteria to be used for site selection are as follows:

Size-Properties would need to be a minimum of about 2 usable acres, with a strong

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preference for larger sites.

Location near river and proposed conveyance facilities-To be cost-effective, the property should be located near the FM network and near the river to minimize the length of influent FM and discharge sewer.

Neighborhood-There is a preference for commercial or industrial sites over residential sites.

Topography and elevation-It is preferable that the selected site be flat, above the 100-year floodplain, near the same elevation as the surrounding area, and not currently serving as a drainage way during storm events.

Construction readiness-Sites that would require removal of densely planted trees, extensive property acquisition and relocation of homes or businesses, construction of replacement parking, or river bank modification are considered to be less desirable than sites not requiring this kind of preparation.

HSB staff identified five potentially available sites that may be useful for off-line storage or a WWTF, which are described from west to east. (These locations are shown on Figure 6-3.)

1. Camden Park Site-Immediately south of the Huntington WWTP across Krauts Creek is an approximately 3- to 4-acre parcel of property that is owned by the Camden Park amusement park. The property appears to be within the floodplain. Staff reports that Camden Park has turned down requests by the HSB to purchase this property in the past.

2. Park Avenue Site-This 3.4-acre site is bounded by Camden Street, Vernon Street, Chase Street, and the Kanawha Turnpike, about 1.5 miles east of the WWTP, at the east end of Park Avenue. This site has the advantage of being relatively large but is located about one-half mile from the most feasible identified FM routes and would require conveyance of wastewater to and from the site for discharge in the Ohio River. This site is considered, however, to be the most viable location for treatment or storage on the west side of Huntington

3. 15th Street East Site-This 2.0-acre site is bounded by 14th and 15th Streets on the west and east and 2nd Avenue to the south near the Ohio River. Although small, this site has some important advantages: it is located in an industrial and commercial area and near to planned FM routes and the Ohio River for discharge. The site is on the inside of the flood wall, and constraints on crossing the flood wall with an FM or a discharge would need to be evaluated. This site is considered the most viable location in the middle of Huntington.

4. 31st Street Sites (A and B)-Between 31st Street and the Guyandotte River north of the railroad crossing are two potentially viable sites. Site A appears to be an open area of about 6.7 acres. Site B to the north is 4.8 acres and is wooded. Either of these sites has the advantage of being located relatively near to identified potential FM routes and near the Guyandotte River for discharge, and it is not located in a residential neighborhood. The area is outside of the flood wall, and the elevation of the site appears to be around 540 to 550 feet MSL, so the site may need to be raised to the 100-year flood elevation. However,

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this location avoids the issue of crossing the flood wall. Should discharge be required to the Ohio River, the distance would be about 0.6 miles long. Because of their size, these sites will be considered among the more viable sites on the east side of Huntington

5. 9th Street Site-Located within 1,000 feet of the Oak Street Ejector Station is a 1.3-acre site at the corner of 9th Street and Hite Street. This site is located within a residential neighborhood. Because of the size and location, this site would only be considered if the 31st Street Sites would not be available.

6. Pats Branch Site—Adjacent to the Pats Branch PS is an approximately 250- by 700-foot (4-acre) site that appears to currently serve as a flowage easement inside of the flood wall. This site may be suitable for storage or treatment. In particular, because of its shape, it may be suitable to provide storage in an earthen basin. Although this type of storage may not provide the large capacities that may be required for complete CSO reduction to the required levels, this may be useful where storage of smaller volumes could achieve partial CSO reduction. This location has the advantage of being located near two of the more significant CSO locations, Pats Branch (018) and Robey Road (017).

H. WWTP Hydraulic Improvements

Specialized hydraulic modifications have been an innovative means of allowing WWTPs to process higher than normal sustained peak flows during wet weather conditions. With this approach, all influent flows receive preliminary and primary treatment plus disinfection. The biological wastewater treatment system, however, is only operated up to its maximum sustained hydraulic capacity so that "washout" of activated sludge microorganisms does not occur. Using this method, the HSB WWTP could potentially process up to its maximum 46 mgd hydraulic capacity, on a sustained basis, rather than the current 25 mgd of sustained flow. The 25 mgd could receive full treatment, as is the current practice. Additional increments of flow could be shunted around limiting treatment units to provide additional treatment. A design of this nature is currently under construction at the Parkersburg Utility Board WWTP facilities.

Although a detailed evaluation of hydraulic modifications at the HSB WWTP is beyond the scope of this LTCP and such an analysis is recommended prior to design of any plant modifications, a preliminary review has been conducted. In addition, WWTP staff believes that a detailed analysis on the condition and remaining service life of the primary part of the plant, which has been in nearly continuous operation for 50 years, should be performed whether hydraulic modifications are made or not. (Appendix A contains an aerial photograph and existing flow diagrams of the plant to aid in this discussion.)

1. Aeration Tank Flow Rerouting

Shunting primary effluent directly to the final clarifiers could help reduce solids washout but still provide some treatment for rerouted flows. The first of the eight aeration tanks is currently not used and may be useful for these hydraulic modifications. The existing arrangement of the RAS channel just upstream of the aeration tanks means that a rerouting splitter structure upstream of the RAS channel would be required to pipe flow directly into the first aeration tank. To be effective, the shunted flow would need to be commingled with the aeration tank effluent, distributing to all of the final clarifiers approximately evenly. However, the existing channel systems between the aeration tanks and the clarifiers are connected with four short-section large-diameter pipes distributed along the channel. This arrangement does not facilitate commingling.

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However, it may be possible to construct a channel parallel to the aeration tank effluent channel that would allow commingling. Because this area is immediately above the piping tunnel that runs between the aeration tanks and clarifiers, this would require some detailed evaluation.

2. Activated Sludge Flow Rerouting

Shunting primary effluent directly to disinfection appears to be a relatively straightforward option for the HSB. Prior to the construction of the secondary treatment system, this had been the normal mode of operation. New chlorine contact tanks now provide disinfection of secondary effluent and the original channel and old chlorine contact tanks remain, although they are not used. The existing unused chlorine tanks are slightly smaller than the 520,000-gallon tanks in use, about 316,000 gallons. Assuming a contact time of 15 minutes during wet weather, the chlorine contact tanks could provide about 30 mgd of capacity.

The chlorine contact tanks (currently used and unused) are not equipped with baffles creating serpentine plug flow through the tanks. Installation of concrete baffles in both sets of tanks would be recommended to optimize disinfection. In addition, the currently unused tanks would require some rehabilitation of spalling concrete and exposed reinforcement. A means of removing settled solids from the old tank would be necessary. It is recommended that improvements be made to allow chlorine contact tanks to be used either in series or in parallel for maximum flexibility.

3. Primary Clarification and Activated Sludge Flow Rerouting

If flows to the plant begin to exceed the treatment capacity of the primary clarifiers, it may be useful to direct flow from preliminary treatment to disinfection. Currently, the plant has no direct means of achieving this. However, the downstream end of the primary clarifier influent channel is physically located within only a few feet of the influent channel of the in-use chlorine contact tanks. Additionally, the path from this proposed channel location to the old chlorine contact tank influent channel appears to be about 70 feet along an area that is currently sidewalk. Therefore, it appears a channel could be constructed to reroute the flow around the primary clarifiers directly to either of the sets of chlorine contact tanks. Appropriate gates or weirs would be required to achieve routing control.

4. Primary Clarification Rerouting

Currently, the WWTP is not equipped to be able to take the primary clarification channel out of service at any time, as there is no means to direct flow from preliminary treatment to the aeration tanks. This has been a problem for plant staff, since there is no means to repair the aeration piping in this channel. Based on the current layout of the plant, it appears that such a flow routing mechanism may have been intended, as the channel from the grit tank is located in proximity to the primary clarifier effluent channel in the northeastern corner of the process portion of the plant. A construction of a short segment of channel with gate control is recommended.

5. Polymer Addition

During flow rerouting operations, the ability to add polymer upstream of the primary clarifiers has the potential to enhance solids removal. Enabling the HSB WWTP to accomplish this appears relatively straightforward. There are currently three polymer tanks located in the administration

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building: two 1,600-gallon tanks that serve the belt filter presses and the incinerator and one 600-gallon day tank that feeds the DAF thickener in the blower building. The polymer feed line to the blower building runs in the pipe tunnel immediately adjacent to the primary clarifier influent channel. Although the piping is not currently arranged to feed polymer to this channel, the modifications to accomplish this feed appear straightforward. However, the 600-gallon polymer day tank is not intended for continuous use, and it may be necessary to manifold the larger polymer tanks to the DAF polymer distribution line or install another parallel polymer distribution line from the larger tanks to serve the primary clarifiers. Also, the type of polymer used for biosolids dewatering and/or for DAF thickening may not prove effective for improving primary clarification.

It would be optimal if each of these rerouted flows could be metered, so the flow through each process of the plant could be known, and flow split adjustments could be made when processes reach their capacities. Because accurate flow measurement through a weir or flume typically requires some head loss, a detailed analysis of the plant hydraulic profile would be required to determine how flow measurement could be achieved.

If these improvements are found to practical, HSB staff believes that several additional modifications should be made to improve operations at the plant during high flow. First, the existing 6-foot wide, 1-inch opening, mechanically cleaned bar screens are reported to blind during first flush events. Replacement of these screens with more modern, finer bar spacing stair or other type of screen may improve screen performance as well as improve downstream processes because of removal of a greater amount of solids at the head of the plant. Installation of a third channel for screening would require a significant building modification. As part of a detailed hydraulic modification analysis, the screening system should be evaluated to determine whether addition of another screen and channel may be feasible. For the purpose of this overview, no additional screening channel is assumed.

Second, the gates in the screening building are currently manually operated and do not function effectively. For example, closing or opening gates to one of the screening/grit treatment trains requires about 30 minutes of hand operation. In addition, cross-channel gates that allow both aerated grit tanks to be used when one screen is out of service (or vice versa) have not been utilized and may require repair or replacement. It is recommended that these gates be replaced with mechanized gates.

Third, the aeration system at the plant is in need of repair. For example, the air tunnel between the aeration tanks and final clarifiers has cracks that allow leakage. In January 2001, Burgess and Niple designed repairs to this system, although these repairs were never undertaken. According to HSB staff, the cost for these improvements was projected at the time to be $500,000.

Fourth, allowing additional flow to the plant to achieve more combined wastewater treatment is anticipated to put some additional strain on the existing system. Plant staff reports that excess clearwater at the plant at times compromises the plant's treatment. Plant staff also reports that the existing belt presses are over 20-years old and require frequent maintenance. This and other aspects of solids handling is currently being studied by an engineering firm for improvements. Since this study and followup is being performed independently of the LTCP, costs for these improvements are not included in this report.

To gauge the likely impact of WWTP hydraulic modifications on LTCP monetary costs, it was assumed that they could provide an additional 21 mgd of wet weather hydraulic capacity at the WWTP. A detailed analysis may show that treatment up to the 60 mgd may be practical, which would yield 35 mgd of

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additional treatment at the WWTP. Although detailed cost analyses for these improvements is beyond the scope of this report, it will be assumed these improvements could be achieved for a preliminary capital cost of $4 million and a preliminary present value cost of $4 million. It should be noted that some of the improvements (screen replacement and aeration improvements) represent capital improvements that have significant benefits aside from CSO reduction.

These relatively straightforward improvements to the hydraulic flow scheme at the plant and at the major pumping stations would result in a substantial increase in peak flow handling capability. Such improvements would reduce the need for "throttling" of the pumping stations during wet weather conditions, especially during more minor storms. This would also provide at least a small reduction in the CSO control facilities required to meet the National CSO Control Policy.

I. Pumping Station Improvements

As discussed above, the condition of the station piping at virtually all the major pumping stations, built in the late 50s and early 60s, is a concern. According to HSB staff, the straight segments of piping within the stations have failed when these stations have been under high loads. The most straightforward solution to this problem would be to perform nondestructive ultrasonic testing or other types of testing to determine which pumping stations require pipe replacement. Plans for these pumping stations show that the piping is primarily cast iron. Discussions with the Ductile Iron Pipe Research Association (DIPRA), the American Cast Iron Pipe Company, and companies that specialize in nondestructive pipe testing suggest that ultrasonic testing of cast iron pipe is often not successful, since the granular structure of the metal interferes with the accuracy of the test. Because of this, it is believed the only way to determine the condition of the piping would be to take stations off-line, remove a segment of the piping, and send a camera in to televise the condition of the pipe. (Depending on the layout of the station piping, it may be possible to take one pump off-line and perform partial inspections without taking the whole station off-line.) To minimize pumping station downtime, it may be advisable to have replacement piping on hand to replace damaged sections immediately. Because the pumping station piping has already served its useful life, it is recommended that HSB consider implementing a program replacing the piping in all stations. HSB staff recommends starting with the 13th Street, Fourpole, and 5th Avenue pumping stations for pipe replacement.

A detailed review of pumping station piping would be required to identify a cost for replacement and is beyond the scope of this LTCP. For the purpose of planning, it will be assumed that the larger stations (13th Street, 4th Street, and Fourpole) would require replacement of the weight equivalent of 60 feet of piping and the smaller stations about 40 feet. Bypass pumping of $10,000 to $20,000 per station was assumed, depending on station size. The total cost for piping replacement in the major pumping stations was projected to be about $2.5 million. Because piping replacement is strongly advised in advance to hydraulic modifications at the WWTP, this is considered a high priority project that would be implemented concurrently.

J. Evaluated CSO Control Options

To meet the DEP's standard of six or fewer CSOs per year, or conveyance to treatment of at least 85 percent of system wet weather flows, for compliance with the National CSO Control Policy, HSB would require construction of one or more WWTFs and possibly construction of storage at the three main alternative sites discussed in the previous section.

The primary alternatives to meet this requirement that will be evaluated in this LTCP are as follows:

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Alternative 1-One UV WWTF at the Park Avenue Site. Alternative 2-Two UV WWTFs, one at the Park Avenue Site, and one at the 31st Street Site Alternative 3-Three UV WWTFs, as above (Alt. 2), and one at the 15th Street Site.

Alternative 4-One chlorine-based WWTF at the Park Avenue Site. Alternative 5-Two chlorine-based WWTFs, at the Park Avenue Site, and at the 31st Street Site Alternative 6-Three chlorine-based WWTFs, as above (Alt. 5), and one at the 15th Street Site.

Alternative 7-One storage facility at the Park Avenue Site. Alternative 8-Two storage facilities, one at the Park Avenue Site, and one at the 31st Street Site. Alternative 9-Three storage facilities, as above (Alt. 8), and one at the 15th Street Site.

These alternatives assume the construction of WWPSs at many of the CSO sites and force mains to convey flow to one or more of the treatment or storage sites. Tables 6-9, 1 through 9, (see Appendix C) show in detail the improvements, land area requirements, and projected costs associated with each alternative. Table 6-10 summarizes the preliminary opinion of present value costs for each alternative. Alternatives shown with an asterisk (*) are those whose land requirements exceed the area available at the proposed sites. Alternatives shown with a double asterisk (**) significantly exceed the available land area at the proposed sites.

Alt Present Value Alt Present Value Alt Present Value

Park Avenue 1 1,126$ 4* 922$ 7** 592$ Park and 31st 2 965$ 5 763$ 8** 449$ Park, 15th, and 31st 3 954$ 6* 754$ 9* 424$

ALL COSTS IN 1st QUARTER 2007 DOLLARS

Table 6‐10: Preliminary Present Value Projections (in millions)

UV Treatment Chlorine Treatment Storage

Based on these costs, several significant conclusions can be drawn:

It is most cost-effective to provide storage or treatment at multiple sites around Huntington.

Costs for liquid chlorine-based treatment are lower than UV-based treatment, although the space limitations may make liquid chlorine-based treatment infeasible.

Costs for storage options appear significantly lower than for treatment options, although space limitations may make storage infeasible.

The most cost-effective alternative that will fit on the sites provided and reduce CSOs to fewer than six occurrences per year would have high monetary cost impact, at a projected present value of $763 million

Alternative 10 Alternative 12 Alternative 13

31st St Site Storage Storage StoragePats Branch Site Storage Storage15th St Site UV Treatment UV Treatment UV TreatmentPark Ave Site Chlorine Treatment Chlorine Treatment Chlorine Treatment

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Four additional alternatives, all of which were selected to fit on the available sites, were identified that combine storage, UV-based treatment, and chlorine-based treatment at the different sites, an additional storage site at Pats Branch, and hydraulic modifications at the WWTP. Tables 6-9 (10 through 13) detailing the cost of these alternatives can be found in Appendix C.

Alternative 10 includes storage at 31st Street, UV treatment at 15th Street, and chlorine-based treatment at Park Avenue. Alternative 11 is similar to Alternative 10, but instead applies chlorine-based treatment at the Pats Branch Site. (Note that the Pats Branch site is not large enough to accommodate the same storage as at 31st Street.) Both alternatives would require the facilities at 15th and Park Avenue to be designed in a particularly compact way, with minimal setback. This may be a problem at the residential Park Avenue Site. Alternative 12 is similar to Alternative 10, except the storage on the east side of the city is split between the 31st Street Site and the Pats Branch Site. Alternative 13 applies the same options as Alternative 12 and assumes that hydraulic modifications are implemented at the WWTP, allowing the plant to operate at the peak hourly flow of 46 mgd for an extended duration, rather than 25 mgd. This analysis shows that hydraulic modification offers a significant cost savings for the LTCP

For the purpose of this LTCP, it will be assumed that Alternative 13 would be the most practical and advantageous alternative. Alternative 13 is shown in Figure 6-3.

K. Area-Specific Sewer Separation and Flooding Reduction

HSB staff has also identified particular areas of the system where relatively small changes to the system could dramatically reduce either flooding, stormwater entry into the CSS, or both. Because reduction of surface flooding is essential for protecting public safety, these improvements are considered necessary and are included in each of the Alternatives discussed above. Detailed cost evaluations have not been performed on these projects, and the preliminary costs provided here should be considered "placeholders" for these projects until their costs can be evaluated more fully.

1. 13th Street West Area

A fifteen-block area bounded by 14th Street West, 9th Street West, Madison Avenue, and Van Buren Avenue experiences significant backup of combined sewers during wet weather. Storm sewer mapping shows there is a storm sewer on 14th Street West at Jackson Avenue that discharges to Fourpole Creek. However, the CSS in the 13th Street West area is not connected to it. HSB staff familiar with the problem proposed a few modifications that could be made to the infrastructure in this area to substantially reduce or eliminate combined sewer flooding. First, the 14th Street storm sewer would need to be extended by one block, and one-half mile of storm sewer in the alley between Van Buren and Jackson would need to be constructed. Second, stormwater catch basins in the fifteen-block area should be disconnected from the combined

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system, allowing the stormwater to flow to the 14th Street sewer. Third, roof leader drains would be disconnected from the CSS and allowed to discharge to the street, since the homes in this area are closely spaced. This would require construction of about 3,000 feet of storm sewer and disconnection of about 250 homes. An engineering evaluation for new sewers in the area should be undertaken prior to construction, and it may be determined that additional storm sewers would be required in the long term to relieve flooding. However, HSB staff believes this would at least reduce the presence of combined sewage in the street. This project is preliminarily projected to cost about $3 to $4 million, depending on the difficulty of construction. HSB staff believes this would be a priority area for separation.

2. Robey Road Area

Currently, during storm events there is flooding along Robey Road where wastewater emerges out of combined manholes and runs down the street. Large storm sewers already exist in this basin from the intersection of Norway Avenue and Olive down Robey Road to Highway 60. In addition, there is a storm sewer on 28th Street from Priddle down to Robey Road. Ironically, these storm sewers only run half full during storm events. HSB staff believes the wastewater flooding in this area could be relieved by taking better advantage of storm sewers that are in place. First, roof leader drains from the approximately 200 to 250 homes located on these streets should be disconnected from the CSS and connected to the storm sewer. In addition, HSB staff recommends that additional storm catch basins be built on the streets with storms sewers and that existing CSS catch basins be removed where stormwater could enter a storm sewer at another location. For this LTCP, it will be assumed that disconnecting 250 homes and modifications to the sewer catch basins may cost approximately $500,000. This assumes that disconnected roof leader drains could be allowed to discharge to the ground for reception by catch basins.

3. Enslow Park

The area around Enslow Park at 16th Street and Washington Boulevard experiences flooding because of lack of capacity in the CSS. Because this area is relatively close to Fourpole Creek, it would be relatively straightforward to construct a separate storm sewer to remove stormwater from the CSS in this area. Staff indicates that lining the existing 48-inch storm line may be necessary. Although a detailed study of this would need to be

performed, for the purpose of the LTCP, it will be assumed this project would cost $2 to $4 million.

4. Doulton Avenue Area

Doulton Avenue from Hal Greer Boulevard to 18th Street E. experiences some flooding because of its elevation and lack of capacity of the 16th Street trunk sewer. HSB staff believes that flooding could be relieved in this small area by installation of about 1,500 feet of storm sewer, connecting it with the stormwater infrastructure in the Basin 009 area, and disconnection of roof leader drains. Assuming disconnection of 100 roof leader drains and installation of a storm sewer, the cost is projected to be $2 to $4 million, depending on the density of other utilities in this corridor.

5. Arlington Boulevard

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HSB staff reports the primary problem in this area is a creek in the area was diverted into a culvert which runs, in some cases, through the front yards of residents in this area. A section of this 36-inch culvert has collapsed, significantly reducing the capacity. When this culvert overflows, this Clearwater enters the CSS, causing surcharging of combined sewer manholes. Determining the magnitude of cost for reconstruction of a large diameter culvert along Arlington Boulevard from Norway to Larkspur (approximately 2,500 feet) would require engineering analysis that is beyond the scope of this LTCP. For the purpose of planning, it will be assumed the cost would be $7 to $10 million.

6. Chase Street

The area in west Huntington along Chase Street, between Tudell and Camden Streets, experiences flooding from the CSS because of a blocked storm line. This could be relieved by cleaning/repairing the existing blockage and construction of storm sewer to Fourpole Creek. Assuming this would require relining or new construction of approximately 1 mile of storm sewer and disconnection of the homes in this area, a preliminary cost of $7 to $10 million is projected.

There are a few areas identified by HSB that, while not associated with flooding, could be easily separated. Although these areas are not considered strictly necessary for the relief of flooding, they are considered "low hanging fruit" areas where some reduction of flow into the system could be achieved with relative ease. Because of this, they are also considered as part of the assumed high priority improvements.

1. Basin 009 Area

The large area south of 8th Avenue to Fourpole Creek between 3rd Street West and 15th Street East is reported by HSB staff to have stormwater infrastructure that would allow disconnection of roof leader drains. However, not all of the storm sewers in the area drain to Fourpole Creek; some connect to the Fourpole Interceptor, thereby exacerbating the CSO problem. This represents an area where reduction of stormwater entry in the CSS

could be achieved. This area has approximately 1,800 roof leader drains to be disconnected. For the purpose of planning, it is assumed that disconnecting the storm sewers from the interceptor and allowing them to drain into the creek would cost about $3 to $6 million, which includes extension of some existing storm sewers to Fourpole Creek.

2. 25th Street Basin

Although not a flooding problem, the small 25th Street (014) Basin has been identified by HSB as relatively straightforward to separation, with the installation of a new sanitary sewer system with grinder pumps for the few individual customers. An analysis would need to be performed to determine what pumping capacity these industries would need. Assuming that approximately 2,000 feet of small diameter gravity sewer is required and that existing utilities can be avoided, plus the installation of several grinder pumps, a preliminary cost of $500,000 has been identified for this project.

It is recommended that easily separable areas be implemented as part of the LTCP. In addition, areas that experience street flooding are also recommended for separation. Although a detailed cost analysis is beyond the scope of this analysis, it will be assumed that the capital cost for these projects would be

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approximately $25 to $40 million. For the purpose of planning, a cost of $40 million will be assumed. It will be assumed that these projects will result in no additional O&M costs. All the above listed projects will be included in the LTCP implementation schedule.

There are some additional areas of flooding identified by HSB staff that may be viable for separation in the future, but whose cost or magnitude suggests these are larger projects that may not be considered "low hanging fruit." In addition, separation of these areas may alleviate flooding without removing the flow from the CSS. Because of their magnitude, costs have not been identified for these projects. These will not be included in the LTCP implementation schedule but are discussed here for completeness.

1. 5th Avenue Area

HSB staff reports that the flooding along 5th Avenue could be alleviated by installation of a new separate storm line from 23rd Street to the Guyandotte. This may require installation of a new local pumping station to serve the 28th Street trunk line. However, this flow would enter the CSS at the 5th Avenue PS, unless another pumping station for discharge of the stormwater were constructed.

2. 24th and 3rd Avenue Area

HSB indicates that flooding in this area could be alleviated by the removal of roof drains from the existing storm line on 24th Street and extension of the storm sewer line up to the flood wall. However unless this could be tied into the existing flood pumping station, this storm flow would simply enter the CSS farther downstream. It may be practical to connect this stormwater outlet to the 25th Street CSO if separation is pursued at that location.

Citywide Sewer Separation

In addition to the specific separation areas discussed above, it is possible that sewer separation could help reduce the overall cost of CSO control by reducing the overall quantity of flow. Separation of the entire city of Huntington is projected to cost approximately $650 million, which is slightly lower than the Alternative 13 cost. However, for several reasons, separation is not considered a viable citywide approach to eliminating CSOs. First, because sewer separation cannot eliminate overflows from \/\, wet weather conveyance, storage, and treatment systems would still be required. Because overflows from a separate sewer system are technically illegal (versus CSOs which are allowed to a limited degree) a "design storm" for a separate sewer system would be much more stringent, such as a 5-year storm rather than a 2-month storm. In addition, the continuous disruption of traffic and business resulting from installation of new sewers would be a significant nonmonetary factor against such an approach. Finally, because the rational method applied here projects conservative flows and volumes, the present value cost of Alternative 13 is considered to likely be more conservative than projections for separation.

Individual basins were evaluated for cost-effective separation, and Table 6-12 lists the CSO basins for

which present value costs could be significantly reduced from the Alternative 12 cost. Those listed as "High Value" appear to have the best potential to reduce the overall LTCP present value cost, and "Good Value" Basins are those that appear to reduce the LTCP present value cost.

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Interestingly, all of the basins in the "High" and "Good" value columns are located in the center of Huntington where the space is most at a premium and UV-based treatment is the only viable alternative. It appears that minimizing flow that requires treatment or conveyance a long distance is the best way to reduce LTCP present value costs. Preliminary projections appear to suggest that the overall Alternative 13 LTCP cost could be reduced to approximately $578 million (1st Qtr 2007 dollars) if complete separation were achieved in the "High" and "Good" value basins.

M. Roof Leader Disconnection Sewer separation is a costly and disruptive process. However, in certain basins, disconnections of roof downspouts from the CSS and directing the Clearwater to existing storm drains or to yards may be an attractive way to reduce overall cost. If it were practical to remove all roof downspouts from the CSS, it is projected the total cost of Alternative 13 could be reduced from $673 million to $627 million (1st Qtr 2007 dollars), which includes the $250 per home disconnection cost. This cost assumes that disconnection does not require installation of new storm sewers. In many locations in Huntington, new storm sewers would be required to achieve CSO reduction by disconnection, making disconnection more costly. However, the cost reduction described above illustrates that, where it is easy to implement, roof drain disconnection has the potential to reduce CSO project costs. Table 6-13 lists high value and good value basins for downspout disconnection, based on this citywide analysis. However, downspout disconnection is likely not practical in all parts of the city, and detailed evaluation of where disconnection may be achieved is recommended. On the other hand, HSB has identified some areas where roof drain disconnection may be readily implementable, including the Division Street Basin (015) and the 4th Street Basin (009).

N. Raising Weir Levels and Backflow Prevention Valve Installation

HSB and its staff feel strongly that raising the weir levels and installation of backflow prevention valves on outfalls would go a long way toward relieving river water infiltration and likely reduce CSO occurrences. However, because the rational method performed here does not take into account river infiltration, the weir raising project would not have a direct reduction on LTCP costs as determined here.

A detailed engineering analysis would be required to determine where these improvements should be implemented and their cost. As a placeholder for these projects, it will preliminarily be assumed that the total capital cost for all modifications would be about $8 million, which includes engineering and contingency. This assumes that construction costs for modifications to the larger separation structures would be $0.2 million each and smaller structures would cost $50,000 each, plus purchase and installation of duckbill valves, anticipated to be approximately $1 to $1.5 million. This assumes that modifications to the 20th Street Regulator structure would be complex, costing about $0.5 million, and that modifications to the James River Road would be $0.2 million. Once engineering evaluation on the overflow structures is performed, costs projections should be adjusted. It is assumed that there would be no significant additional O&M cost associated with this project.

High Value Good ValueRobey Road (017) 35th St (021)Pats Branch (018) Richmond St (020)16th St (012) B&O (022)East Road (003) Fouropole (004)

Table 6-13: Basins with Significant Potential Cost Savings Through

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O. Selection and Prioritization of LTCP Projects

Thus far, Section 6 has identified a large suite of projects (Alternative 13, including low hanging fruit projects) that would reduce the rational-method derived overflows to six times per year or fewer. In this subsection, projects are prioritized and selected to reduce CSOs:

In the sensitive and priority areas. At the most active locations. Where significant reduction can be achieved for low cost.

Table 6-14 details the capital and O&M costs of the Project Priority Groups:

1. Raising Weirs and Backflow Prevention It is believed that river water intrusion is among the most significant threats to the existing CSS but that this problem may be among the most readily addressed. It is recommended that HSB implement a program of weir raising and installation or repair of backflow prevention valves within the next year.

2 and 3.WWTP Hydraulic Modifications and Pumping Station Reinforcement

WWTP operators typically throttle back the pumping stations to reduce the flow to 25 mgd, even though the rated plant capacity is 46 mgd peak hourly flow. This causes overflows to occur at pumping stations that would otherwise have conveyance capacity. It is recommended that hydraulic modifications be pursued at the WWTP to allow treatment of the wastewater to much higher sustained flows, hopefully up to or approaching 46 mgd. Although a preliminary analysis on hydraulic modification potential has been described above, a complete engineering analysis is recommended. The improvements to the pumping stations piping should be pursued concurrently.

4. Specific Area Sewer Separation

Section 6K identified several viable areas for sewer separation, which could be pursued in phases. HSB is conducting an inventory of all areas for which separate storm sewers may be readily disconnected from the system and begin performing these repairs with HSB staff as available. As part of this project group, HSB envisions separation of the 25th Street basin (014) immediately upstream of the DWI.

5. Pats Branch and Robey Road Area Improvements

Robey Road (017) and Pats Branch (018 and 018A) CSOs are widely recognized by HSB staff as problematic CSOs. Since the DEP has identified the Guyandotte River as sensitive because of the TMDL, Pats Branch and Robey Road Area Improvements are considered a high priority. In this project, new WWPSs could be constructed at Robey Road and Pats Branch to convey CSO via FM to storage located at the Pats Branch Site.

6. East Side Improvements-Part 1

The 5th Avenue (016) overflow is problematic for HSB. WWPSs are an option at this overflow to be constructed with a FM to convey CSO to storage at the 31st Street Site.

7. Far West Side Improvements

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The East Road (003) CSO is reported to overflow frequently. The James River Road (024) CSO has been identified as a priority area, but the frequency of overflows remain unknown. WWPSs could be constructed at these locations, plus Fourpole Pump Station with FMs to convey CSO to chlorine-based treatment at the Park Avenue Site. It may only be necessary to construct the amount of treatment needed to handle these three CSOs, and future projects would expand the storage capacity as necessary.

8. 16th and 20th Street Improvements

HSB staff indicated that the 20th Street CSO (013) is a priority because of the large volume of overflow that affects the Harris Riverfront Park priority area. However, because this is the largest project group in terms of cost, it was not felt practical for implementation early in the program. To address the CSOs, this project would include construction of UV-based treatment at the 15th Street Site and WWPSs and FMs at the 16th and 20th Street CSOs.

9. Richmond Street and Oak Street Improvements

Richmond Street (020) is reported to overflow many times per year; however, HSB staff indicates it is an air ejector-type pump station that is unreliable. All ejector stations will be replaced with more reliable dry pit submersible station. Assuming this, Richmond Street and Oak Street WWPSs should be constructed as part of Project Priority Group 9, which would include FMs to convey the flow to the 31st Street site, plus expansion of storage.

10. Near West Side Improvements

4th Street (009), W. 7th Street (007), and W 13th Street (006) are also reported to overflow six or more times per year. WWPSs are an option at these CSOs with a force main connecting them to additional treatment at the Park Avenue Site.

11. East Side Improvements-Part 2

The Division Street (015) overflow is currently seen by DEP as a potentially sensitive area because of the drinking water plant intake. However, HSB staff indicates the volume of this overflow at this location is relatively small. that a WWPS are an option at Division Street, with a FM connecting it to storage at the 31st Street Site. Depending on discussions between HSB and DEP, the priority of this project may be adjusted.

With completion of Project Priority Groups 1 through 11, it appears HSB will have addressed all the CSOs that are reported to overflow more than six times per year. The remaining projects are listed for completeness, although they may not be necessary to achieve the CSO reduction requirements of the National CSO Control Policy.

12. Krauts Creek Improvements

Reduction of CSO occurrences at the Krauts Creek CSO (002) would call for a WWPS near the existing PS and a FM to the WWTP. However, Krauts Creek is reported to overflow about two times per year and likely may not require any improvements.

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13. Altizer Improvements

Reduction of CSO occurrences at the Altizer PS CSO (036) would call for a WWPS near the existing PS and a FM to the Pats Branch wet weather FM. However, the Altizer PS is reported to overflow two or fewer times per year and likely may not require any improvements.

14. 35th Street Improvements

Reduction of CSO occurrences at the 35th Street PS CSO (021) would call for a WWPS near the existing PS and a FM to the Richmond Street wet weather force main. However, according to recent SCADA information and staff experience, the 35th Street PS does not overflow in a typical year. This location may not require any improvements.

P. Conclusions and Cautionary Notes

There are a few important notes of caution to be made on the analyses discussed in this section.

First, because this cost analysis was performed on flows developed with the simplified rational method included with the LTCP-EZ analytical approach, it is possible that more accurate flow rate and volume projections may yield somewhat different results. Because of this, HSB may pursue a careful flow metering and modeling program prior to implementing CSO control projects to develop more accurate flow and volume projections. This could be accomplished over time on a sewershed priority basis, with the metering and modeling conducted prior to the design of improvements within each sewershed.

Second, determination of whether CSO abatement is required at particular locations should be based on actual observed overflow frequencies. Because of the uncertainty of some of the CSO occurrence observations, this evaluation applies rationally derived flow rates and volumes to project whether CSOs occur. That is, it does not eliminate any projects based on fewer than six observed occurrences at the CSOs. HSB will establish a consistent method of counting CSOs at the nonmonitored locations and determine whether any modifications are required to floats at the SCADA-monitored locations to make them more accurate in monitoring CSO events. Also, HSB will evaluate the SCADA-monitored CSOs to determine if the monitoring method is representative of actual CSO events and make adjustments where needed.

Third, the projects presented here should be considered a "big picture" approach that would achieve CSO reduction called for in the National CSO Control Policy. However, it is recommended that HSB further its ongoing support of the existing facilities and programs and pursue its interest in reducing storm flow into the CSS where it appears practical.

Finally, HSB will view the LTCP as a flexible plan, and continue to evaluate areas where it appears flow reduction can be achieved with localized improvements. Projects such as weir raising and the specific area separation are attractive as they may result in some "payback" since they will result in lower O&M costs in the future.

7.0 AFFORDABILITY

Affordability is a key concept within the National CSO Control Policy. EPA guidance for the policy includes methods of fiscal impact analysis which help identify locally appropriate implementation schedules that allow phasing of projects over an extended timeframe to avoid excessive customer sewer

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use charges. EPA guidance generally indicates that, as a function of MHI, residential annual costs for sewer service have the following financial impact on residential customers:

Low Less than 1 percent MHI Mid-range 1 percent to 2 percent MHI (~ 1.5 percent)

High Greater than 2 percent MHI

For West Virginia communities, the DEP issued CSO Long-Term Control Plan Preparation Procedure Guidelines on May 4th, 2006. Because West Virginia communities are generally economically stressed as compared with national averages, considering MHI, unemployment rates, poverty rates, and other factors, the DEP has identified that sewer rates of 2.0 percent or more28 of MHI represent a hardship on communities.

This section will review current budget requirements for HSB programs and then adjust the budget as required to fully fund capital improvement programs that have been identified as necessary to maintain current operations and facility functions (facility rehabilitation and replacement programs). This analysis will then identify the "headroom" that would be available to fund further improvements to the HSB system directed toward CSO control considering various potential levels of rate increase to fund such programs. Selected CSO control projects will then be identified for implementation over an extended timeframe to keep local sewer service costs at a locally affordable level. The selected CSO control projects will be prioritized from the entire listing of projects for the options evaluated in Section 6.0 above, based on perceived benefits in relation to monetary costs for individual projects and project groupings.

A. Current Costs and Revenue

1. Operating Expenses

HSB's most recent report of operating expenses filed with the West Virginia Public Service Commission (WV PSC) provides operating cost information as summarized in Table 7-1 below for the most recent fiscal year.

28The 1.5 percent rate includes not only CSO control projects, but also existing operations and other required sewer system and treatment improvements.

For the last fiscal year (June 30, 2006, through June 30, 2007), budget projections for operating expenses developed for this LTCP are shown in Table 7-2:

Category Year Ending June 30, 2009Collecting Sewers $670,325Wastewater Pumping $838,792Wastewater Treatment $2,918,912Billing & Collecting $310,722Administration & General $1,398,371TOTAL $6,137,122

Table 7-1: Actual HSB Operating Costs

Category Projection-Year Ending June 30, 2010 Collecting Sewers $681,723Wastewater Pumping $450,400Wastewater Treatment $3,364,400Billing and Collecting $332,000Administration & General $1,521,580TOTAL $6 350 103

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The above projections represent a 4 percent increase over actual costs for the previous fiscal year.

2. Existing Annual Debt Service

HSB's current debt service schedule is shown in Table 7-3 below:

Information for the 1993 through 2000 issues is based on HSB's most recent reported data to the WV PSC. Information on the 2006 issues was obtained from the HSB Controller and reflects averages over the next five years or to the maturity date (2006B).

Based on the above debt service schedule, current revenues must be sufficient to meet $1.55 million of annual debt service expenses. In addition, the provisions of the local bond ordinances require that revenue be sufficient to provide a rehabilitation and replacement fund annual fund contribution of 2.5 percent of gross revenues and to provide a "coverage ratio" of 120 percent over and above the funds required to meet operation expenses.

3. System Rehabilitation and Replacement Costs

According to HSB's report to the WV PSC, the HSB system includes capital assets with a book value of about $76 million, with pumping and treatment plant assets over 15 years old having a book value of about $42 million. It is important to recognize that these book value figures are based on the initial cost of the facilities at the time of their construction and do not represent replacement costs in current dollars, which would be much higher. The value indicated for the pumping and treatment facilities is of significance as those facilities typically have an overall average useful life of about 30 years with major items of equipment generally having a useful life of about 20 years. With

Issue Maturity Balance Annual Interest Annual Principle Annual Debt Service11/25/97 3/1/19 1,569,977 $33,209 $144,425 $177,6346/22/99 6/1/20 1,247,813 $26,215 $100,440 $126,65510/24/00 12/1/21 1,225,563 $25,582 $85,471 $111,053

2006 11/1/16 2,635,000 $126,660 $270,000 $396,6602007 11/1/23 5,250,000 $201,135 $250,000 $451,135

TOTALS 11,928,353 $412,801 $850,336 $1,263,137

Table 7-3: HSB Existing Debt Retirement Schedule

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a major portion of these facilities more than 15 years old, it is evident that significant future investments in capital projects will be necessary to maintain service and function of the facilities. Assets have a finite useful life and must be replaced or rehabilitated prior to their causing or contributing to a system failure or the lack of HSB's ability to provide effective customer service and compliance with environmental regulations.

Some examples of rehabilitation and replacement in the system follow:

Rehabilitation-Lining an existing sewer to repair cracks or joint defects; grouting of manholes to reduce infiltration/inflow; rehabilitation of building structures to extend useful life; replacement of existing manholes, sewers or services that are in a failed or poor structural condition.

Replacement-Replacement of pumps or wastewater treatment equipment with new pumps or equipment; new electronic monitoring and control facilities to replace existing outmoded systems in poor condition; replacement of outdated office and laboratory equipment and furnishings; replacement of vehicles and other rolling equipment.

Budgeting for rehabilitation and replacement is generally accomplished as part of a utility's CIP with funds provided either through a capital improvement account funded directly from revenue or from borrowing for specific projects. Major projects would generally be financed through borrowing by means of local bonding or through a government agency-operated loan program such as the DEP Revolving Fund or the WV Water Development Authority loan program. Grants were available in the past to help pay for major wastewater system construction projects but have generally not been widely available in recent years. Please refer to additional discussion in Section 7.0 B relating to HSB's Capital Improvement Plan.

4. Revenue

HSB's report to the WV PSC lists an annual revenue of $8.7 million from an average of 22,482 customers, with additional miscellaneous annual revenue of $424,000, for a total annual revenue of $9.1 million.

Current rates for sewer service (Schedule I of WV PSC Order of 7/2009) are listed in Table 7-4:

Item Current RateCustomer (minimum) Charge $2.86/monthFirst 2,240 gal of water used per month $3.85 per 1,000 galNext 12,720 gal of water used per month $3.80 per 1,000 galNext 134,640 gal of water used per month $3.61 per 1,000 galNext 7,330,000 gal of water used per month $3.50 per 1,000 galAll Over 7,480,000 gal of water used per month $1.62 per 1,000 galFlat Rate (equivalent of 4,500 gal for unmetered) $20.07/monthMinimum Change (no volume) $2.86/month

Table 7‐4: Current HSB Sewer Service Rate (Schedule I)

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For a residential customer using 4,000 gallons of water per month, the current monthly charge would be $18.18 per month, or about 0.938 percent of the MHI ($23,234 for City of Huntington from 2000 census). For a residential customer using 4,500 gallons of water per month, the current monthly charge would be $20.07 per month, or about 1.04 percent of the MHI.

B. Potential CSO Program Costs to Fully Comply with the National CSO Policy

In Section 6, alternatives were evaluated that would control HSB's CSOs to comply with the Presumptive Control Level of the National CSO Control Policy. This is a level of control where CSO events would be limited to six per year, with all flows from less intense storm conditions receiving conveyance and treatment prior to discharge to area waters. Based on the LTCP-EZ analysis, the monetary cost of such a program would be absolutely astonishing. As indicated in Table 6-14, capital cost could be as high as $657 million with increased operating costs (not including debt service) of $6.2 million.

What would be the local cost impact of such a program? If it is assumed that HSB would receive grants for 50 percent of the capital cost and would fund the remaining capital cost through local bonding, about $365 million would need to be borrowed to meet bond issuance expenses and to fund a debt reserve account. If the bonds were sold with a maturity of 30 years and an effective interest rate of 6.0 percent, the annual debt service on the bonds would be $26,517,000. It is assumed that local bonding would be necessary to meet these costs, rather than the DEP-administered Revolving Fund Program, because HSB's effective access to Revolving Fund funding would have likely been exhausted with the borrowing necessary for non-CSO CIP requirements. Annual HSB budget requirements for implementing the non-CSO improvements as well as the CSO control projects identified in Table 6-14 would be about as indicated in Table 7-5

The existing Bond Ordinance requires that total annual revenues equal or exceed 120 percent of the sum of annual operational costs and debt service. The Non-CSO Capital Improvements Fund, Operating Reserve and Additional Cash Reserve total of Table 7-5 would meet that requirement. It is recognized that the total annual "reserves" of about $8.7 million may be excessive, but reducing this amount would appear to require a change to the Bond Ordinance language and negotiations with existing bond holders, which is likely to be complex and difficult.

The above budget would be about 5.7 times the current budget. A residential rate 5.7 times the current rate (470 percent increase) would result in monthly sewer service charges of about $99 per month for a

Item Annual Budget (Millions)Non-CSO Operations $6.69Non-CSO Debt Service $3.92Non-CSO Capital Improvements Fund $1.69CSO Program Debt Service $26.50CSO Program Operations $6.19Operating Reserve $1.29Additional Cash Reserve (Debt Coverage) $5.68TOTAL $51.96Table 7-5: HSB Annual Cash Budget Cash Balances Including Non-

CSO CIP and "Presumptive" CSO Control

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customer using 4,500 gallons of water. This would equal 5.1 percent of the MHI and would clearly be locally unaffordable.

C. Local Factors and Locally Affordable CSO Control

Discussion Section 7D has indicated the very high monetary cost of fully meeting the Presumptive Control level of the National CSO Control Policy. This section will review local economic, fiscal, and demographic factors to help arrive at a level of CSO control effort that might be considered locally affordable given local conditions and constraints.

1. Local Bonding Factors

In the recent past the HSB has had a weak financial condition and bonds have been sold on an unrated (e.g., Moody's or S&P) basis. At the present time, HSB finances are more sound, and it is hoped that this will continue in the future so that bonds can be sold on a rated "investment grade" basis. To better understand the logistics of a very large bond sale to fund major CSO control improvements, preliminary discussions were held with Ross Sinclair (HSB's underwriter for its most recent issues). For a very large bond sale (hundreds of millions of dollars), it was felt that the bonds could be sold as long as a rate ordinance imposing the necessary fees was adopted and the rate increase stood challenges that would likely be made through the WV Public Service Commission. Given the very high rate increase required, as discussed above, passage of such an ordinance and PSC approval may be very difficult if not impossible. If rates and other matters were resolved, the interest on such bonds would likely be about 6 percent, or perhaps even higher depending upon the bond rating and economic conditions at the time of the bond sale.

Given the size of potential bond sales, the very high impact on local sewer use rates, and the difficulty gaining approvals for the rates needed to support the borrowing, HSB's bonding capacity for projects with the high capital costs indicated in Table 6-14 is viewed as weak.

2. Local Employment Statistics and Median Household Income

According to the year 2000 U.S. Census, 56.6 percent of the Huntington population over 16 years of age was in the labor force. This compares with a national average of 63.9 percent. The census data also indicate an annual Median Household Income (MHI) of $23,234 for Huntington residents, compared with a West Virginia average of $29,696 and a national average of $41,994. In addition, the census data show 24.7 percent of individuals and 17.5 percent of families in Huntington live below the poverty level. This compares to a state average of 17.9 percent of individuals and 13.9 percent of families and a national average of 12.4 percent of individuals and 9.2 percent of families living below the poverty level. The census data list a 5.8 percent unemployment rate for the Huntington civilian workforce.

On a regional basis, current information reported by the Census Bureau indicates that West Virginia incomes are the lowest in the nation and that poverty levels are among the highest. On the basis of 2003-2005 income, West Virginia ranks at the bottom of the nation, with an annual MHI of about $35,000 compared with a median annual MHI for all states of about $47,000. The 2003-2005 census data also indicate that West Virginia continues to have a poverty rate among the highest of states.

U.S. Department of Labor employment statistics for December 2006 list an unemployment rate of 5.1 percent for West Virginia and a national average unemployment rate of 4.3 percent. Data for

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the Huntington metropolitan area, including Cabell and Wayne counties in West Virginia, Boyd and Greenup counties in Kentucky, and Lawrence County, Ohio, indicate an average 2006 unemployment rate of 5.1 percent.

In summary, Huntington is economically depressed compared with the rest of West Virginia, with West Virginia itself having very low income and high poverty rates compared with the rest of the nation. High unemployment rates persist in the Huntington area. Of all metropolitan areas in the nation, Huntington, with low income and high poverty and unemployment, appears to be among the least likely to be able to finance major infrastructure improvements with local funds.

3. Population Trends

A lack of local economic opportunity is demonstrated in the loss of Huntington's population over the last five decades.

The 2000 census population for Huntington indicates a loss of 40.3 percent of the resident population, whereas West Virginia lost 9.8 percent of its population and the U.S. population increased by 87.7 percent over this timeframe. Migration from Huntington in pursuit of economic opportunity in other population centers in the region and country is the obvious cause of the loss of population. The 2000 census data list West Virginia as among the highest of states in relation to net out-migration. Because of the very high historic population loss from Huntington, it is evident that net out-migration is far more serious locally than for the state as a whole. It is likely that Huntington has experienced one of the highest rates of out-migration of urban areas in the nation. A declining population places clear limits on the ability of the local population to fund major capital improvements when a declining number of people will likely be present in future years to pay for those improvements.

4. Residential Property Values

Year 2000 U.S. Census data indicate a median value of owner-occupied housing of $65,400 in Huntington. This compares with $72,800 in West Virginia and $119,600 nationwide. Homes in Huntington are only a little more than half the value of owner-occupied homes on a nationwide average. Although HSB lacks the legal authority to levy taxes for wastewater infrastructure, so that local property values are not directly relevant to sewer financing matters, the low property values are an indication of the relatively low financial capacity in the Huntington area population to locally support significant infrastructure improvements.

5. Affordability Matrix Score

An "affordability matrix" concept was originally developed in EPA guidance to assist in determining appropriate phased implementation timing for a complete CSO control program. A very high stress score would, for example, justify extending the total implementation timeline to a period of 15 to 20 years. A low stress score would mean that a relatively short implementation

Census Year Huntington Population2000 51,4751990 54,8441980 63,6841970 74,3151960 83,6271950 86,353

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schedule for the entire CSO control program would be favored.

With the above factors in mind, local capability to implement the CSO controls presented in Table 6-14 can be assessed as indicated in Table 7-6.

When weak local financial capability is considered together with the very high cost of implementing CSO controls, as indicated in Table 7-5, it may be readily concluded that a CSO control program meeting the Presumptive Control Level as stated in the National CSO Control Policy would place such a high burden on the local ratepayers as to be unaffordable.

6. Preliminary Evaluation of Locally Affordable CSO Control Projects

The agency’s CSO Long-Term Control Plan Implementation Policy states that “A minimum sanitary customer rate of at least 1.5% MHI would be expected by this agency, if additional revenue would be needed to adequately finance a CSO control program and to provide an acceptable implementation schedule. WVDEP and each permittee shall negotiate an acceptable implementation schedule on a case-by-case basis.”

EPA guidance indicates that the cost for sewer services would likely have the following financial impact on residential customers:

• Low impact when less than 1% MHI • Mid-range impact when at 1% to 2 % MHI • High impact when greater than 2% MHI

WVDEP has determined that the maximum limit should currently be established at 1.75% MHI. This value is not only the midpoint between the minimum of 1.5% MHI and the high impact point of 2.0% MHI, but will also provide financial funding to address Huntington Sanitary Board’s long overdue capital improvements projects, and also completing some of the most cost effective CSO controls needed to improve water quality of the discharges from the CSO outfalls.

However, it must be stated that there is a possibility that the maximum limit may have to be raised to approach, or even exceed the 2% MHI, if additional cost effective CSO controls are mandated by WVDEP or USEPA, or if additional capital improvement projects are needed.

Factor Local Capability

OVERALL WEAK

Difficult if not impossible to locally finance $365 million in bonds for CSO controlWeakLocal Bonding

Local Tax Base and Property Values Weak Low local value for owner-occupied housing

Household Income Weak Median Household Income 55 percent of US average

Local Employment Weak Local unemployment about 1 percent higher than national average

Table 7-6: Local Financial Capability Assessment

Remarks

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The above maximum affordability limits could be altered based on future changes in financial conditions and/or environmental rules and regulations, or by requirements that may be established by USEPA. To evaluate what level of CSO control project implementation may be affordable in Huntington, the project groupings in Table 6-14 were reviewed with respect to their impact on the required HSB budget. A preliminary HSB annual budget was developed that includes the budget requirements and the additional budget costs for debt services, operating cost, and reserve funds that would be associated with Table 6-14. Grants equal to 50 percent of CSO Control project costs were assumed. Local bond financing (6 percent, 30 years) was assumed for the CSO project.

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8.0 LTCP IMPLEMENTATION SCHEDULE

This CSO Long-Term Control Plan has identified a suite of projects that are intended to allow HSB to meet the presumptive approach requirement of fewer than six CSO occurrences per year. DEP has indicated that this level of control would be consistent with the National CSO Control Policy. An expenditure of this magnitude if funded locally would represent a very significant hardship on the residents of Huntington. Our fiscal impact analysis indicates that CSO control projects totaling over about $31.4 million appear to be locally unaffordable.

Providing WWTP hydraulic modifications is anticipated to increase the volume of combined wastewater treated during CSO events by approximately 84 percent, based on the flow rate increase from 25 to 46 mgd. Based on the rational method volume and time of concentration calculations, it is anticipated that Projects 1-3 would result in an approximately 5 percent decrease in overflow volume during the 2-month, 1 hour design storm. However, most storms during the year would be less intense than this design storm, and greater percent captures would be anticipated on a yearly average. For example, a 2-month, 24-hour storm is anticipated to see an approximately 18 percent reduction in the volume of overflow. Assuming that this 2-month, 24-hour lower intensity storm is more representative of a typical storm during the year, Projects 1-3 are anticipated to reduce CSO volume by about 750 to 800 million gallons per year.

An Implementation Plan for the LTCP was developed based HSB's interest in pursuing Projects 1 and 2 in phases over the next several years, starting with the most critical problems and those most readily addressed. Project 3 will be coordinated with the upcoming solids handling project at the WWTP; because of the magnitude of this project, careful project planning is considered an essential step. In addition, several critical financial and regulatory constraints factor into project implementation:

HSB's current budget is constrained and an increase in rates is required to support current needs.

Rate increases are anticipated for each phase of the project, including design loans and HSB-constructed projects.

PSC reviews of proposed rate increases are anticipated.

Design and construction funding will be sought via the WVIJDC, which requires facilities plans as part of the application.

All planning and contract documents will require Health Department and/or DEP review.

Larger projects will require PSC Certificates of Convenience and Necessity for which DEP-approved plans and specifications are necessary.

SRF requirements for approvals, bid hold times, etc. must be met.

Table 8-1 presents the Implementation Plan and is anticipated to form the basis for negotiations with DEP for approval of the LTCP. An important part of the Implementation Plan are its footnotes, which allow for HSB and DEP to negotiate future adjustments to the schedule to reflect funding availability, the need to keep rates at an affordable level, and the regulatory approval process. Such language is necessary since there are numerous critical factors in the CSO program implementation that may be beyond Huntington's control.

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In addition to the above, HSB gives consideration to implementing separation projects on a pilot basis in limited select areas. One area that HSB might consider is the area tributary to CSO 014 (25th Street), where this evaluation has concluded that CSO 014, located upstream of the drinking water plant intake, might be able to be eliminated at a cost of about $0.5 million.

This plan represents a preliminary evaluation of projects that may be required to reduce CSOs. This plan provides information for the Sanitary Board, the Huntington City Council, and the DEP on the overall magnitude and cost of CSO reduction projects. Prior to implementation of CSO control projects, HSB will pursue the following:

1. Pursue a program of public participation to keep the public and the City Council informed on the LTCP and what it may mean for sewer rates in the future. A presentation was made to the City Council on June 11, 2007 and May 26, 2009, and public presentations on the LTCP held on July 31, 2007 and between January through June 2009. A record of the City Council presentation and public presentations are included in Appendix D.

2. Eliminate river water intrusion into the sewer system. at CSO locations.

a. Simplify CSO operation and maintenance through the elimination of Brown & Brown regulators

b. Structural modification to improve entry

c. Raise weirs

d. Overflow monitoring equipment

3. Implement hydraulic modifications at the WWTP.

4. Implement modifications and replacements as needed at pumping facilities.

5. Reduce the amount of I&I through manhole and sewer rehab, roof drain removal, and transference of storm water to existing storm lines.

6. Make regular and effective contact with the WV congressional delegation, EPA, the WV Infrastructure and Jobs Development Council, DEP, and WV DOT to pursue grant funding for system improvement projects. Given the low MHI values in Huntington, the high levels of unemployment and poverty, and the very high cost of identified system improvements, HSB should receive priority consideration for available grant funding.

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Table 8-1

Huntington Sanitary Board’s Implementation Schedule

Current Activities: A. The permittee shall complete the following items on or before June 30, 2010:

1. Submit documentation of a schedule for compliance for full implementation of the Nine Minimum Controls.

2. Provide brief summation of current activities in CSO Summary Reports.

B. The permittee shall complete the following items on or before December 31, 2010:

1. Establish a policy for evaluating catch basins for separation of stormwater into the collection system.

2. Schedule a meeting with all food service businesses regarding best management practices (BMP) emphasizing their role in reducing pollutants in their facilities and storm water runoff.

3. Install flow meters or calibrated electronic devices to record the flow and/or the duration of all CSO discharges at 35th St. pump station (area of C-021), Altizer Pump Station (area of C-036), and Pats Branch (area of C-018 and area of C-018A) because these CSO outfalls are considered priority areas.

4. Install flow meters or calibrated electronic devices to record the flow and/or the duration of all CSO discharges at 20th St. Regulator (area of C-013), 16th St. Regulator (area of C-012), 9th St. Regulator (area of C-010), Roby Road (area of C-017), and 5th Avenue (area of C-016), Four Pole (area of C-004), West 22nd St. (area of C-005), West 7th St. (area of C-007), 1st St. Regulator (area of C-008), 4th St. Regulator (area of C-009), B&O Regulator (area of C-022), and Park Avenue (area of C-023).

5. Should the permittee obtain the Storm Water Utility, then necessary storm lines shall be removed in the B&O Regulator area and outfall C-022 shall be taken out of service.

6. Complete Lagoon Remediation Plan design. 7. Develop13th St. Pump Station design. 8. Replace the line in the Hal Greer sewer from Washington Blvd. to Mount Union Rd., which will

reduce I&I and create flow capacity to open up the area for economic development, and also prevent basement backup in the Enslow Park area.

9. Complete the first phase Roof Drain Removal project (Appendix B, Item No. 1) at B&O Regulator (area of C-022).

10. Submit the results of the post construction monitoring of Park Avenue (area of C-023) to the agency.

11. Submit post construction monitoring evaluation within twelve (12) months after Completion of Current Activities projects.

12. Provide brief summation of current activities in CSO Summary Reports.

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Phase I – The permittee shall complete the following items on or before December 31, 2015: Phase I, Items A:

1. Begin construction on 13th St. Pump Station. 2. Convert Richmond St. Ejector Station to a Submersible Pump Station to increase dependability

and volume and install flow meters or calibrated electronic devices to record the flow and/or the duration of all CSO discharges.

3. Convert Oak St. Ejector Station to a Submersible Pump Station to increase dependability and volume and install flow meters or calibrated electronic devices to record the flow and/or the duration of all CSO discharges.

4. Convert 22nd St. Ejector Station to a Submersible Pump Station to increase dependability and volume and install flow meters or calibrated electronic devices to record the flow and/or the duration of all CSO discharges.

5. Convert Krauts Creek Ejector Station to a Submersible Pump Station to increase dependability and volume.

6. Modify Krauts Creek (C-002) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

7. Rehabilitate 13th St. West Sewer-sections that are failing. 8. Rehabilitate 19th St. Sewer-sections that are failing. 9. Modify 13th St. (area of C-006) CSO to provide the following improvements: safer entry, increase

weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 10. Develop plan for the replacement of the WWTP’s Solids Handling Process (Appendix A-Phase I,

Step 1). 11. Initiate design and engineering of Merrill Ave. ½ Alley sewer line replacement. 12. Complete the second phase Roof Drain Removal (Appendix B, Item No. 2) at 1st St. (area of C-

008). 13. Submit post construction monitoring evaluation within twelve (12) months after Completion of

Phase I, Items A projects. 14. Provide brief summation of current activities in CSO Summary Reports.

Phase I, Items B:

1. Modify 20th St. (C-013) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

2. Modify 16th St. (C-012) to provide the following improvements: safer entry, increase weir elevation to increase line storage, instrumentation, and measures to prevent river intrusion.

3. Modify B&O (C-022) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

a. Remove storm lines allowing the B&O Regulator (C-022 to be removed from the outfall list.).

4. Modify James River (C-024) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

5. Modify 4th St. (C-009) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

6. Complete the Solids Handling Process project at WWTP (Appendix A-Phase I, Step 2). 7. Complete Lagoon Remediation project at WWTP (Appendix A-Phase I, Step 2). 8. Initiate WWTP’s Capacity Enhancement design to increase maximum treatment capacity during

wet weather flows (Appendix A-Phase I, Step 2). 9. Initiate study of I&I Reduction projects. (Appendix A-Phase I, Step 2) 10. Initiate study of Combined sewer Separation projects. (Appendix A-Phase I, Step 2) 11. Develop design and separate combined sewers at 25th St. 12. Initiate replacement of the sewer line at Daulton Ave. ½ Alley to reduce I&I (Appendix A-Phase I,

Step 2). 13. Complete Alley near Saad’s Market sewer improvement project. 14. Complete Edgemont Rd. sewer improvement project.

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15. Develop design for separation of combined sewer at 1st St. (C-008) 16. Complete the third phase Roof Drain Removal project (Appendix B, Item No. 3) at 25th St. E. (area

of C-014). 17. Develop Storm Water Infiltration Policy. 18. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase I, Items B projects. 19. Provide brief summation of current activities in CSO Summary Reports.

Phase I, Items C:

1. Design upgrade of Pat’s Branch Pump Station to improve reliability and reduce dry weather overflows.

2. Eliminate 25th St. (C-014) CSO due to proximity to Drinking Water Intake. 3. Modify Division St. (C-015) to provide the following improvements: safer entry, increase weir

elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion and reduce volume of outfall discharge above the Drinking Water Intake.

4. Modify Fourpole (C-004) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

5. Modify 35th St. (C-021) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

6. Complete the first phase of Capacity Enhancements project (Appendix A-Phase I, Step 3) at the WWTP.

7. Complete Fourpole Trunk sewer project near Church. 8. Complete Richmond St. sewer improvement project. 9. Complete separation of combined sewer at 1st St (area of C-008). 10. Initiate I&I Reduction program based on the engineering study. (Appendix A-Phase I, Step 3) 11. Initiate Combined Sewer Separation program based on the engineering study. (Appendix A-Phase

I, Step 3) 12. Replace sewer line at Altizer Ave. to reduce I&I. 13. Complete replacement of the sewer line at Daulton Ave. ½ Alley to reduce I&I (Appendix A-Phase

I, Step 3). 14. Complete 1525 Washington Blvd sewer improvement project. 15. Complete Forest Rd. to Ferguson Rd. sewer improvement project. 16. Complete L-Shaped Alley 10th Ave. W. sewer improvement project. 17. Initiate the Dietz Hollow sewer improvement project. 18. Complete the fourth phase of Roof Drain Removal (Appendix B, Item No. 4) at 35th St. E. (area of

C-021). 19. Begin active pursuit of grant funding in order to maintain capital improvement projects. 20. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase I, Items C projects. 21. Provide brief summation of current activities in CSO Summary Reports.

Phase I, Items D:

1. Initiate design upgrade of Fourpole Pump Station to improve reliability and reduce dry weather overflows (Appendix A-Phase I, Step 4).

2. Complete upgrade of Pat’s Branch Pump Station. 3. Modify Richmond St. (C-020) to provide the following improvements: safer entry, increase weir

elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 4. Modify Pat’s Branch (C-018 and C-018A) to provide the following improvements: safer entry,

increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

5. Modify Oak St. (C-019) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

6. Modify West 22nd St. (C-005) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

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7. Modify 9th St. (C-010) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion.

8. Modify 1st St. (C-008) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion

9. Modify West 7th St. (C-007) to provide the following improvements: safer entry, increase weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion

10. Complete the second phase of Capacity enhancement projects (Appendix A-Phase I, Step 4) at the WWTP.

11. Initiate replacement design of collapsed outfall line at WWTP (Appendix A-Phase I, Step 4). 12. Complete Phase 2 of I&I Reduction program according to prioritized projects identified in the

engineering study. (Appendix A-Phase I, Step 4) 13. Complete Phase 2 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study. (Appendix A-Phase I, Step 4) 14. Complete L-Shaped Alley sewer improvement projects. 15. Complete the Dietz Hollow sewer improvement project. 16. Complete Campbell Park (2 Lines) sewer improvement project. 17. Initiate the 4th Ave. ½ Alley 14th-16th Street sewer improvement project (Appendix A-Phase I, Step

4). 18. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase I, Items D projects. 19. Provide brief summation of current activities in CSO Summary Reports.

Phase I, Items E:

1. Complete upgrade of Fourpole Pump Station (Appendix A-Phase I, Step 5). 2. Should it become necessary to achieve water quality in the receiving stream during CSO

discharges, complete the third phase of Capacity Enhancement project at the WWTP (Appendix A-Phase I, Step 5).

3. Initiate Outfall replacement (Appendix A-Phase I, Step 5). 4. Initiate Aeration System Improvement design to increase reliability and decrease energy

consumption at WWTP (Appendix A-Phase I, Step 5). 5. Complete Phase 3 of I&I Reduction program according to prioritized projects identified in the

engineering study. (Appendix A-Phase I, Step 5) 6. Complete Phase 3 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study. (Appendix A-Phase I, Step 5) 7. Complete the 4th Ave. ½ Alley 14th-16th Street sewer improvement project (Appendix A-Phase I,

Step 5). 8. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase I, Items E projects. 9. Provide brief summation of current activities in CSO Summary Reports.

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Phase II - Should it become necessary in order to achieve water quality in the receiving stream during CSO discharges, the permittee shall continue to apply for grant funding, and upon obtainments of the grant funding, shall complete the following items on or before December 31, 2020: Phase II, Items A:

1. Initiate design upgrade of Fourpole Pump Station to improve reliability and reduce dry weather overflows (Appendix A-Phase II, Step 1).

2. Initiate Roby Rd Pump Station Improvement project (Appendix A-Phase II, Step 1). 3. Initiate Pats Branch Pump Station Improvement project (Appendix A-Phase II, Step 1). 4. Modify Roby Rd. (C- 017and C-017A) to provide the following improvements: safer entry, increase

weir elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 5. Modify East Road (C-003) to provide the following improvements: safer entry, increase weir

elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 6. Should it become necessary to achieve water quality in the receiving stream during CSO

discharges, complete the fourth phase of Capacity Enhancement project (Appendix A-Phase II, Step 1) at the WWTP.

7. Initiate design upgrade for the Chlorination System for increased safety, reliability, and capacity at WWTP (Appendix A-Phase II, Step 1).

8. Complete 5th Ave. in the Guyandotte sewer improvement project. 9. Complete Upper and Lower Glendale sewer improvement project. 10. Complete 10th Ave. ½ Alley sewer improvement project. 11. Complete 13th St. at 9 ½ Alley sewer improvement project. 12. Complete Phase 4 of I&I Reduction program according to prioritized projects identified in the

engineering study. (Appendix A-Phase II, Step 1) 13. Complete Phase 4 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study. (Appendix A-Phase II, Step 1) 14. Initiate study of Brick Sewer Rehabilitation (Appendix A-Phase II, Step 1). 15. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase II, Items A projects. 16. Provide brief summation of current activities in CSO Summary Reports.

Phase II, Items B:

1. Initiate the design for the4th St. Pump Station Improvement project (Appendix A-Phase II, Step 2). 2. Complete Fourpole Pump Station (Appendix A-Phase II, Step 2). 3. Complete Roby Rd Pump Station Improvement project (Appendix A-Phase II, Step 2). 4. Complete Pats Branch Pump Station Improvement project (Appendix A-Phase II, Step 2). 5. Modify 5th Ave. (C- 016) to provide the following improvements: safer entry, increase weir

elevation to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 6. Should it become necessary to achieve water quality in the receiving stream during CSO

discharges, complete the fifth phase of Capacity Enhancement project (Appendix A-Phase II, Step 2) at the WWTP.

7. Complete upgrade of Chlorination System for increased safety, reliability, and capacity at WWTP (Appendix A-Phase II, Step 2).

8. Complete 1710 Williams Ave. Alley sewer improvement project. 9. Complete 1401 11th Ave. sewer improvement project. 10. Complete 1802 Rural Ave. sewer improvement project. 11. Complete 630 Jefferson Ave. Rear 7th-5th Street sewer improvement project. 12. Complete Phase 5 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase II, Step 2). 13. Complete Phase 5 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase II, Step 2). 14. Initiate Brick Sewer Rehabilitation program based on the engineering study (Appendix A-Phase II,

Step 2). 15. Initiate 5th Ave. Storm Cutoff Sewer improvement project (Appendix A-Phase II, Step 2).

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16. Submit post construction monitoring evaluation within twelve (12) months after completion of Phase II, Items B projects.

17. Provide brief summation of current activities in CSO Summary Reports.

Phase II, Items C: 1. Complete the upgrade of the 4th St. Pump Station to improve reliability and reduce dry weather

overflows (Appendix A-Phase II, Step 3). 2. Initiate the design for the East Road Pump Station Improvement project (Appendix A-Phase II,

Step 3). 3. Continue construction of the Outfall Replacement project at the WWTP (Appendix A-Phase II,

Step 3). 4. Should it become necessary to achieve water quality in the receiving stream during CSO

discharges, complete the sixth phase of Capacity Enhancement project at the WWTP (Appendix A-Phase II, Step 3).

5. Complete Phase 6 of I&I Reduction program according to prioritized projects identified in the engineering study (Appendix A-Phase II, Step 3).

6. Complete Phase 6 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase II, Step 3).

7. Complete Phase 3 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase II, Step 3).

8. Continue the 5th Ave. Storm Cutoff Sewer Improvement project (Appendix A-Phase II, Step 3). 9. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase II, Items C projects. 10. Provide brief summation of current activities in CSO Summary Reports.

Phase II, Items D:

1. Initiate the design for the 5th Ave. Pump Station Improvement project (Appendix A-Phase II, Step 4).

2. Complete East Road Pump Station Improvement project (Appendix A-Phase II, Step 4). 3. Complete Altizer Pump Station Improvement project. 4. Modify Altizer (C-036) to provide the following improvements: safer entry, increase weir elevation

to increase sewer line storage, upgrade instrumentation, and prevent river intrusion. 5. Continue the Aeration System Improvement project at the WWTP (Appendix A-Phase II, Step 4). 6. Complete the Outfall Replacement project at the WWTP (Appendix A-Phase II, Step 4). 7. Complete Phase 7 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase II, Step 4). 8. Complete Phase 7 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase II, Step 4). 9. Complete Phase 4 of Brick Sewer Rehabilitation program according to prioritized projects

identified in the engineering study (Appendix A-Phase II, Step 4). 10. Continue the 5th Ave. Storm Cutoff Sewer improvement project (Appendix A-Phase II, Step 4). 11. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase II, Items D projects. 12. Provide brief summation of current activities in CSO Summary Reports.

Phase II, Items E:

1. Complete the 5th Ave. Pump Station Improvement project (Appendix A-Phase II, Step 5). 2. Complete 40th St. Pump Station Improvement project. 3. Complete the Aeration System Improvement project at the WWTP (Appendix A-Phase II, Step 5). 4. Complete Phase 8 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase II, Step 5). 5. Complete Phase 8 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase II, Step 5).

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6. Complete Phase 5 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase II, Step 5).

7. Complete 5th Ave. Storm Cutoff Sewer improvement project (Appendix A-Phase II, Step 5). 8. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase II, Items E projects. 9. Provide brief summation of current activities in CSO Summary Reports.

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PHASE III - Should it become necessary in order to achieve water quality in the receiving stream during CSO discharges, the permittee shall continue to apply for grant funding, and upon obtainments of the grant funding, shall complete the following items on or before December 31, 2025: Phase III, Items A:

1. Initiate WWTP-UV Disinfection project (Appendix A-Phase III, Step 1). 2. Initiate 3rd Ave. & 29th St. Storm Sewer improvement project (Appendix A-Phase III, Step 1). 3. Complete Phase 9 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase III, Step 1). 4. Complete Phase 9 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 1). 5. Complete Phase 6 of Brick Sewer Rehabilitation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 1). 6. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase III, Items A projects. 7. Provide brief summation of current activities in CSO Summary Reports.

Phase III, Items B:

1. Complete UV Disinfection project at WWTP (Appendix A-Phase III, Step 2). 2. Complete 3rd Ave. & 29th St. Storm Sewer sewer improvement project (Appendix A-Phase III, Step

2). 3. Complete Phase 10 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase III, Step 2). 4. Complete Phase 10 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 2). 5. Complete Phase 7 of Brick Sewer Rehabilitation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 2). 6. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase III, Items B projects. 7. Provide brief summation of current activities in CSO Summary Reports.

Phase III, Items C:

1. Initiate Pump Station Improvement Backup Power Supply study (Appendix A-Phase III, Step 3). 2. Initiate WWTP-Lagoon Reclamation (Appendix A-Phase III, Step 3). 3. Complete Phase 11 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase III, Step 3). 4. Complete Phase 11 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 3). 5. Complete Phase 8 of Brick Sewer Rehabilitation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 3). 6. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase III, Items C projects. 7. Provide brief summation of current activities in CSO Summary Reports.

Phase III, Items D:

1. Complete Pump Station Improvement Backup Power Supply project as identified by the study (Appendix A-Phase III, Step 4).

2. Complete WWTP-Lagoon Reclamation (Appendix A-Phase III, Step 4). 3. Complete Phase 12 of I&I Reduction program according to prioritized projects identified in the

engineering study (Appendix A-Phase III, Step 3). 4. Complete Phase 12 of Combined Sewer Separation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 3). 5. Complete Phase 9 of Brick Sewer Rehabilitation program according to prioritized projects

identified in the engineering study (Appendix A-Phase III, Step 3).

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6. Submit post construction monitoring evaluation within twelve (12) months after completion of Phase III, Items D projects.

7. Provide brief summation of current activities in CSO Summary Reports. Phase III, Items E:

1. Complete Phase 13 of I&I Reduction program according to prioritized projects identified in the engineering study (Appendix A-Phase III, Step 4).

2. Complete Phase 13 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase III, Step 4).

3. Complete Phase 10 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase III, Step 4).

4. Submit post construction monitoring evaluation within twelve (12) months after completion of Phase III, Items E projects.

5. Provide brief summation of current activities in CSO Summary Reports.

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Phase IV - Should it become necessary in order to achieve water quality in the receiving stream during CSO discharges, the permittee shall continue to apply for grant funding, and upon obtainments of the grant funding, shall complete the following items on or before December 31, 2030: Phase IV, Items A:

1. Complete Phase 14 of I&I Reduction continuation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 1).

2. Complete Phase 14 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 1).

3. Complete Phase 11 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 1).

4. Pats and Roby Area Improvements (areas of C-017 and C018 outfalls) ~$40M 5. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase IV, Items A projects. 6. Provide brief summation of current activities in CSO Summary Reports.

Phase IV, Items B:

1. Complete Phase 15 of I&I Reduction program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 2).

2. Complete Phase 15 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 2).

3. Complete Phase 12 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 2).

4. East Side Improvements- Part 1 (area of C-016) ~$36M. 5. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase IV, Items B projects. 6. Provide brief summation of current activities in CSO Summary Reports.

Phase IV, Items C:

1. Complete Phase 16 of I&I Reduction program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 3).

2. Complete Phase 16 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 3).

3. Complete Phase 13 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 3).

4. Richmond Street and Oak Street Improvements (Area of C-019 and C-020 outfalls).~$20M. 5. Submit post construction monitoring evaluation within twelve (12) months after completion of

Phase IV, Items C projects. 6. Provide brief summation of current activities in CSO Summary Reports.

Phase IV, Items D:

1. Complete Phase 17 of I&I Reduction program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 4).

2. Complete Phase 17 of Combined Sewer Separation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 4).

3. Complete Phase 14 of Brick Sewer Rehabilitation program according to prioritized projects identified in the engineering study (Appendix A-Phase IV, Step 4).

4. Submit post construction monitoring evaluation within twelve (12) months after completion of Phase IV, Items D projects.

5. Provide brief summation of current activities in CSO Summary Reports.

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Phase V - Should it become necessary in order to achieve water quality in the receiving stream during CSO discharges, the permittee shall continue to apply for grant funding, and upon obtainments of the grant funding, the permittee shall complete the following items on or before December 31, 2035: Phase V, Items A:

1. The permittee shall complete the planning, selection, design and implementation of CSO management practices and controls to meet the requirement of the Clean Water Act (CWA), the 1994 USEPA Combined Sewer Overflow (CSO) Control Policy or other USEPA guidance documents or West Virginian’s CSO Long-Term Control Plan Implementation Policy. Some possible projects are: Far West Side Improvements (~$109M), 16th Street and 20th Street Improvements ($~185 M), or Near West Side Improvements ($~184M).

2. Submit post construction monitoring evaluation within twelve (12) months after completion of Phase V projects.

3. Provide brief summation of current activities in CSO Summary Reports.