Key Issues Identified by the SSO Subcommittee

Stakeholder interviews identified the following key issues for consideration by the SSO Subcommittee:

• Need for better information on the extent and causes of SSOs;
• Difficulties faced by operators in proactively identifying and correcting sanitary sewer line problems which may lead to SSOs;
• Technical feasibility of achieving zero wet weather related SSOs;
• Need for guidance on how to consider the impacts of SSOs in the larger context of achieving clean water goals (watershed approach);
• Cost of compliance;
• Minimum SSO volume to trigger reporting requirements;
• Use of the CSO (combined sewer overflow) Control Policy as a basis for any SSO Rule;
• Use of a national performance standard versus a design standard;
• Timing of issuance of an SSO policy;
• Need for consistency in enforcement actions initiated by State and Federal regulatory authorities.

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Last updated on April 22, 2003 5:12 PM
URL:http://cfpub1.epa.gov/npdes/sso/keyissues.cfm