ADMINISTRATIVE CONSENT ORDER (ACO)
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
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.
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
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
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.
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.