Administrative Consent Order (ACO)


ADMINISTRATIVE CONSENT ORDER (ACO) UPDATE

What is an ACO? An ACO is an Administrative Consent Order (sometimes also called Consent Order and Agreement). It is a legal document issued by a regulatory agency to correct violations of an environmental law.

In 2004, ACOs have been distributed to each of 83 municipalities, including South Fayette Township Municipal Authority in Allegheny County. The order was signed by both the regulatory agency and MATSF, is enforceable in court. (South Fayette Township also passed a Resolution of support to the Authority in this matter as required by ACHD.) The ACO usually outlines violations, requires corrective active and identifies penalties, if applicable.

The consent order received by all communities in the Allegheny County Sanitary Authority (ALCOSAN) service area requires that municipalities begin complying with the federal Clean Water Act. Enacted in 1977, the Clean Water Act prohibits any person or entity from discharging pollutants into waterways.

One of those pollutants is sewage, which has historically been a problem for the Pittsburgh region. During wet weather (rain or snow melt), raw sewage overflows into our rivers and streams, spills from manholes in the street or backs up in homeowners' basements. Much of the problem stems from deterioration of the area's sewage collection systems. Extra water seeps into pipes, overloads the system and overflows before it can reach the ALCOSAN treatment plant.

Under this order from the Allegheny County Health Department, all communities in the ALCOSAN service area including South Fayette Township Municipal Authority were required to complete a number of sewer-related projects by specific deadlines.  ACO requirements included an assessment of the municipal sewer system by mapping the location of system structures (manholes, etc.) and recording their condition, cleaning out sewer lines and then televising them using robotic technology to identify any problem areas. Any portion of the sewer system required a repair if it was in danger of collapsing, severely restricted wastewater flow or has a large volume of water getting into the system.

After this comprehensive assessment, flow monitoring was also performed on a regional basis by ALCOSAN. Meters were installed at various sewer system locations to measure how much wastewater (and stormwater in some cases) the system is carrying during both dry and wet weather. This information was subsequently inserted into a system “model” that was provided by ALCOSAN to the tributary communities to help develop a long-term control plan.

In addition, the ACO required municipalities to pass an ordinance that prohibits stormwater connections to a separate sanitary sewer system (a system designed to carry only wastewater). South Fayette Township already had an ordinance with these prohibitions in place. Any improper stormwater connections from homes to the sanitary system, such as rainspouts, driveway drains or foundation drains must be disconnected.

Accurately locating and mapping the Authority's manholes, approximately 4,000 in number, was one of the first requirements of the order. 3 Rivers Wet Weather, a non-profit environmental organization dedicated to the sewage overflow issue, is coordinating and funding this $2 million ALCOSAN service area project at no cost to the communities. By participating in this coordinated project, ALCOSAN communities realized a total $9 million savings.

Additionally, MATSF field personnel performed other required tasks, including the inspection of manholes throughout the system and pipe televising work. In performing these tasks, a number of manholes were identified as being buried as a result of landscaping activities. Covering manholes, thus making them inaccessible, is prohibited by MATSF regulations and by Township ordinances. These ordinances provide for significant monetary penalties that may be assessed to property owners that have covered manholes. MATSF personnel and their contractors must have ready access to manholes not only for performing the required assessment activities, but to provide prompt response to any emergency blockages that may occur.  As part of a required Operations and Maintenance plan that each community also needed to submit as part of the ACO, a key aspect is routine televising of the sewer piping and routine manhole inspections.

The ACO process culminated in the preparation of a feasibility study by each community tributary to ALCOSAN.  Those studies were due to be submitted to the regulatory agencies in July 2013.   The feasibility studies are intended to provide specific actions that each tributary municipality or Authority envision implementing between now and 2026 to curtail sewer system overflows.  MATSF submitted their feasibility study which envisions approximately $7.5 Million Dollars of capital improvements (in current dollars) to the sanitary sewer system prior to 2026.   That report can be viewed by clicking this link: MATSF Feasibility Study.   MATSF will await comments from the regulatory agencies and ALCOSAN prior to moving forward with the key recommendations of the feasibility study.  That review process is expected to take at least 1 year.