Clinton CSO Abatement: Environmental Information Document (Nov 2005)
Clinton Street CSO Abatement Project (Nov 2005)
Prepared by SGD Environmental Services for Environmental Engineering Associates, LLP
LEAD AGENCY: Onondaga Co. Dept of Water Environment Protection
650 Hiawatha Blvd., W., Syracuse, NY 13204
Contact: Randy R. Ott, PE, Commissioner, 315-435-2260

1. Introduction

The Introduction section of this document is designed to provide information regarding the Onondaga County Combined Sewer Overflow (CSO) Lake Improvement Program and how it relates to the Clinton Street CSO Abatement Project (background/project description, need and benefits). The evolution (selection process) of the Clinton Street CSO Abatement Project is also included. Lastly, the schedule for completion of selected project components, regulatory review requirements, and a summary of permits and/or approvals associated with the Clinton Street CSO Abatement Project are described in this section. A list of commonly used terms and acronyms can be reviewed in Appendix A.
 Click here for Appendix A. Commonly used terms and acronyms.

1.1 Background

The Onondaga County Sanitary District owns, and the Onondaga County Department of Water Environment Protection (OCDWEP) operates and maintains, certain combined trunk sewers and interceptor sewers within the City of Syracuse. (Prior to January 2001, Onondaga County Department of Water Environment Protection was referred to as Onondaga County Department of Drainage and Sanitation [OCDDS].) Transfer of ownership from the City of Syracuse to Onondaga County was effected by a joint act of the Syracuse Common Council and the Onondaga County Legislature once in 1978 and again in 1982. The City of Syracuse continues to own, operate, and maintain the combined tributary collector sewer system. During periods of wet weather, this combined tributary collector sewer system generates a mixture of storm water and untreated sewage that exceeds the conveyance and storage capacity of the trunk and interceptor sewer system resulting in discharges of this combined flow to Onondaga Creek and eventually Onondaga Lake.

In January 1989, Onondaga County (County) entered into a Judgment on Consent with the State of New York and the Atlantic States Legal Foundation (ASLF) in settlement of litigation in connection with alleged violations of state and federal water pollution control laws. The conditions of the Judgment on Consent required the County to perform a series of engineering and scientific studies to evaluate the need for upgrading the Metropolitan Syracuse Wastewater Treatment Plant (Metro) and abating CSOs that occur within that portion of the Metro service area located within the City of Syracuse and served by the City's combined collector system.

Based on the results of the required studies, and in consultation with the New York State Department of Environmental Conservation (NYSDEC) and the U.S. Environmental Protection Agency (USEPA), the County developed a plan for upgrading the Metro plant and providing abatement of CSOs (long-term control plan). The County submitted a proposed Municipal Compliance Plan (MCP) to the NYSDEC and ASLF in January 1996. Subsequent negotiations with regard to the proposed MCP resulted in the execution of an Amended Consent Judgment between the parties, which was executed by the U.S. District Court in January 1998 (see Appendix B - Amended Consent Judgment).
Appendix B. Amended Consent Judgment (1998): Email Susan Miller, Project Deputy Director or phone 315-435-2260 for copy.

The 1998 ACJ replaced and superseded the 1989 Judgment on Consent including the requirement for an approved MCP and Effluent Compliance Schedule. Pursuant to the ACJ (1998), the County is required to implement a collection of projects that focus on improving the water quality of Onondaga Lake including the following programmatic elements:

• Upgrades and improvements at Metro (interim and major)
• Interim and major improvements concentrating on abating CSOs in the Metro service area
• An oxygenation demonstration project
• An ambient water quality monitoring project.

(The ACJ settlement divided improvements into two groups: interim - to be completed by 7/1/02 [except for sewer separation); major - completion dates established by project [OCDDS LIPO 2001a). The Clinton Street CSO Abatement Project is considered a "major" project [Section 1.4 - Schedule identifies project component completion dates].)

With regard to improvements to the combined sewer system, paragraph 14 of the ACJ states the following:

The County shall design, construct, maintain, and modify and/or supplement, as necessary, a CSO control and upgrade program in accordance with DEC CSO guidance, as set forth in TOGS 1.6.3 (CSO Control Strategy), which implements the "presumptive approach" in EPA's CSO control policy, as set forth in 59 F.R. 18688 (April 18, 1994). The County's program shall achieve the following:
- elimination or the capture for treatment of no less than 85% by volume of the combined sewage collected in the combined sewer system during precipitation events on a system-wide annual average basis,
- elimination or minimization of floating substances in Onondaga Lake attributed to the County's CSOs, and
- achievement of water quality standards for bacteria for all portions of Onondaga Lake that are classified as 'Class B' (As defined in Title 6 of the New York State Compilation of Codes, Rules and Regulations [6 NYCRR] Part 701, the best usages of Class B waters are fishing and secondary contact recreation [e.g. boating]. The waters shall be suitable for fish propagation and survival.) pursuant to 6 NYCRR Part 895"[6 NYCRR 895, Onondaga Lake Drainage Basin].
 
To achieve compliance with the above requirements, the County shall complete the specific tasks by the applicable milestone compliance date set forth in the CSO Control and Upgrade Schedule that is attached as Appendix B and hereby made an enforceable part of this Amended Consent Judgment. All elements of the CSO Control and Upgrade program shall be completed and in full operation on or before January 1, 2012.

As previously noted, the Clinton Street CSO Abatement Project is one component of the Lake Improvement Program. Other CSO projects associated with the ACJ, and addressed elsewhere by others, include the following (OCDDS LIPO 2001a):
 
Interim phase projects:
- Hiawatha Boulevard Regional Treatment Facility (RTF) Demonstration
- Newell Street RTF Disinfection Demonstration
- Harbor Brook In-Water System
- Erie Boulevard Storage System Upgrade
- Kirkpatrick Street Pumping Station Upgrade
- Onondaga Creek Floatables Control
- Harbor Brook Floatables Control Facility (FCF)
- Teall Brook FCF
- Siphon Crossings Evaluation and Rehabilitation
- CSO Toxicity Evaluation
 
Major projects:
- Midland RTF and Conveyances
- Franklin FCF
- Maltbie FCF
- Sewer Separation

1.2 Project need and benefits

The ACJ stipulates that the Clinton Street CSO Abatement Project "will abate those CSO discharges located within the downtown portion of the Onondaga Creek basin." This area represents the Clinton Street CSO Abatement Project service area (see Figure 1-1) and is the second largest service area in the County's combined sewer system (approximately 1000 acres) (EEA 2005).

Figure 1-1. Clinton Street combined sewer service area

As listed in Table 1-1, there are eleven NYSDEC-permitted CSOs within the Clinton Street CSO service area.
 

TABLE 1-1. CLINTON STREET COMBINED SEWER SERVICE AREA OVERFLOWS
No.	ID	Drainage in acres	Location
1	027	134	West Fayette Street - East
2	028	24	Walton Street - West
3	029	8	Walton Street - East
4	030	312	West Jefferson Street - East
5	031	25	West Jefferson Street - West
6	032	25	Tully Street - West
7	033	18	Dickerson Street - West
8	034	214	Gifford Street - East
9	035	23	Gifford Street - West
10	036	188	West Onondaga Street - West
11	037	33	West East Adams Street - East
		Total 1004
Source: EEA 2005, 2003b

Click to enlarge

A map depicting the location of these overflows within the Clinton Street CSO service area is presented on Figure 1-2.

To assist in meeting ACJ requirements, the Clinton Street CSO Abatement Facilities Plan prepared by Environmental Engineering Associates, LLC (EEA) identifies that the proposed Clinton Street CSO Abatement Project will involve the conveyance, storage, and high-rate treatment of overflows at a Clinton Street Regional Treatment Facility (RTF) prior to discharge to Onondaga Creek. (Overflows from existing CSOs 027 through 037 up to the 1-year 2-hour duration, 15-minute rainfall interval design storm event [1-yr design storm event].) Incorporated herein by reference, the Facilities Plan identifies the minimum CSO abatement requirements for the Clinton Street CSO Abatement Project as follows:

• Eliminate or capture for treatment at Metro at least 107 million gallons (MG) of combined sewage on an average annual basis,
• Provide adequate facilities to eliminate or minimize floating substances (floatables) from discharging to Onondaga Creek from the Clinton Street service area CSOs,
• In combination with other CSO abatement projects, provide sufficient facilities to reduce bacterial concentrations to less than 200 colony forming units (cfu)/100 milliliters (ml) for the Clinton Street service area CSO discharges for the 1-year design storm event, and
• Satisfy the additional requirements outlined in pages 7 and 8 of ACJ-Appendix B (herein see Appendix B - Amended Consent Judgment).

Implementation of the Clinton Street CSO Abatement Project and achievement of the above noted treatment requirements will assist in complying with ACJ requirements and will provide significant water quality benefits as part of the County's overall CSO control and upgrade program (EEA 2005).

1.3 Project evolution and description

In February 2000, facilities planning efforts were initiated to identify the recommended/preferred alternative (siting and treatment technology) for the Clinton Street CSO Abatement Project. In February 2005, the Clinton Street CSO Abatement Project Facility Plan (Feb 2005 draft) (EEA 2005) summarized an assessment undertaken by EEA to identify viable CSO treatment technologies and potential RTF locations for the project. The facilities planning process took into consideration the ACJ requirements (summarized above), design criteria associated with such requirements, and the concerns expressed by the service area community. To date, more than 30 public meetings involving potentially affected community groups/organizations and businesses have been conducted (see Section 9, Community and public participation).

As described in greater detail in Section 7, Alternatives, a variety of CSO treatment approaches, technologies, and RTF locations were preliminarily identified:
 
Treatment approaches:
- Sewer separation
- Regional conveyance and storage
- Regional conveyance and treatment (with disinfection)
 
Treatment technologies:
- Vortex separators
- Enhanced vortex separators
- Continuous deflective separation (CDS)
- Ballasted flocculation
- Coarse screening (mechanically cleaned)
- Fine screening
- Brush screens
- Rotary drum screens/sieves
- Microscreens
- Net bags
- Overflow retention facility (ORF)
 
Regional treatment facility locations:
- Clinton Station
- Tully Street
- West Onondaga Street
- West Washington Street
- Wyoming Street
- Gifford Street
- Dickerson Street (East and West alternatives)

Based upon screening evaluations identified in the Facilities Plan, the most feasible CSO treatment technology/approaches for achieving compliance with the Clinton Street CSO service area ACJ treatment requirements were:
 

Utilizing non-cost criteria (e.g., proximity to residents, businesses, and sensitive receptors, community enhancements, engineering considerations, and ACJ compliance, etc.), two preferential sites for the Clinton Street CSO abatement facilities were identified: Clinton Station (Trolley Lot) and Dickerson Street (EEA 2005, Section 3, Alternative Site Analysis).

Click to enlarge

Figure 1-7 depicts preliminary conveyances and in-line storage/vortex separator RTF at Clinton site (CSO 037 inc)

In February 2005, following review of project-specific plans, reports, and memorandums, as well as input from the City of Syracuse and potentially affected community groups (residential and business), a recommended/preferred alternative for the Clinton Street CSO Abatement Project (siting and technology) was identified by the County. As reflected in the Facilities Plan (EEA 2005), it was identified that the Clinton Street CSO Abatement Project would involve the construction and operation of an RTF at Clinton Station (Trolley Lot) using in-line storage/vortex separators and closure of existing CSOs 028 and 029.

Click to enlarge

Figure 1-8 shows an aerial view of the Clinton Station RTF and conveyances

The existing system currently stores approximately 74% of the total average annual wet weather flow. The Clinton CSO Abatement Project will store an additional 12% of the total average annual wet weather flow within the service area for treatment at Metro with remaining peak wet weather flows representing 14% being treated (removal of solids, disinfection, dechlorination) onsite and discharged to Onondaga Creek (18 times on an average annual basis). This represents approximately 118 MG of treated CSO being discharged to Onondaga Creek.
 

Click to enlarge

Figure 1-9 provides a draft schematic of the building

In general, the RTF and conveyances are proposed as follows:
 

Table 1-2 General Design Features
Building
- Site acreage: 2 acres (Note: Clinton Station parking lot is 5 acres but only 2 acres is needed for construction)
- Height: 1.5 stories or approximately 25 feet with a 10-foot stack
- Size: 35,000-40,000 square feet
- Storage capacity of RTF and conveyance: 3.7 million gallons (MG)
- Figure 1-9 provides a draft schematic of the RTF.
Disinfection facilities
- Disinfection tank use: estimated 31 times per year (an estimated 13 events will be captured and returned for treatment at Metro and an estimated 18 events will be disinfected and discharged to the Creek).
- Disinfection tank entirely underground
- Disinfection tank outfall: 120-inch diameter (emergency controlled diversion spillway has not been designed at this time).
- Size: approximately 16,000 square feet
- Pipe depth: 15 - 20 feet below grade
- Chemical tank sizes: liquid sodium hypochlorite = 6200 gallons; liquid sodium metabisulfite = 2100 gallons (tanks located inside building)
Conveyances
- Total estimated length: 6,000 linear feet of conveyance, force main, and outfall piping
- Easements: 30 - 75 feet temporary; permanent easement 30 feet
- Pipe depth: 12 - 40 feet
- RTF influent conveyance diameter: 27 - 108 inch
Construction
- Anticipated construction period: 3 - 3.5 years:
- Phase 1 conveyances (Fayette to West Jefferson): 6 - 9 months
- Phase 2 RTF and remaining conveyances: 2.5 - 3 years
- Construction conveyance easement: 30 - 75 foot width maximum
- Depth of disturbance: 10 to 50 feet maximum (influent sump/wet well)
- Estimated area of disturbance: 5.5 acres:
- RTF: 2 acres
- Piping: 3.5 acres
- Green design and construction techniques will be utilized to the extent practicable
Operation
Intermittent (only during wet weather conditions): estimated 49 overflow events going to RTF per year:
- 31 events will be captured and returned for treatment at Metro:
- 18 events will be stored in conveyances and non-disinfection tank portion of RTF.
- 13 events will be stored in the conveyances and RTF including the disinfection tank.
- 18 events will require treatment at the RTF and will be discharged following dechlorination to Onondaga Creek. This represents approximately 118 MG of treated CSO being discharged to Onondaga Creek.
Sources: EEA 2005 and 2003a

The regional treatment facility using vortex separation with high rate disinfection acts as a storage facility for smaller storms while providing treatment for larger storms. The storage capacity of the RTF and conveyances is estimated at 3.7 MG. As previously noted, approximately 49 overflow events per year will be captured and stored within the disinfection facilities. An estimated 31 events will be captured and pumped back to the main interceptor sewer for conveyance to Metro for treatment. An estimated 18 overflow events per year will result in discharges of treated/disinfected effluent to Onondaga Creek. The recommended/preferred alternative identified by the County, therefore, maximizes the flow to Metro while providing cost-effective treatment of larger storms. Others will address detailed engineering aspects of the project in yet-to-be developed design reports. This document focuses on the natural and human environmental setting, potential impacts, and mitigation measures associated with implementation of the above facilities (see Figures 1-7 and 1-8).

1.4 Schedule

The following (Table 1-3) is a summary of the current ACJ construction milestone dates related to the Clinton Street CSO Abatement Project.
 

Table 1-3 ACJ Compliance Milestone Schedule
No.	Project component	Milestone	Current milestone date
1	Commence construction of conveyances	Minor	Oct 28, 2004
2	Commence construction of RTF	Minor	Oct 28, 2004
3	Complete construction of conveyances	Minor	May 1, 2007
4	Complete construction of RTF	Major	Jan 1, 2012
Source: EEA 2005

The County is currently in negotiations with the ACJ parties regarding revisions to milestone dates for several ACJ projects, including the Clinton Street CSO Abatement Project (Clare 2005).

1.5 State Environmental Quality Review Act

The State Environmental Quality Review Act (SEQR) and its implementing regulations (6 NYCRR Part 617) require the consideration of environmental factors in certain actions that are directly undertaken, funded, or approved by local, regional, or state agencies. In accordance with 6 NYCRR Part 617, subject actions are classified as either "Type I" actions or "Unlisted" actions. Actions specified by SEQR as "Type II" actions are not subject to SEQR review.

With respect to the Clinton Street CSO Abatement Project, Onondaga County plans to undertake the proposed project. Given that the action is the direct result of an amended consent order, the project is classified by SEQR as a Type II action under 6 NYCRR 617.5(c)(29):

civil or criminal enforcement proceedings, whether administrative or judicial, including a particular course of action specifically required to be undertaken pursuant to a judgment or order, or the exercise of prosecutorial discretion

In accordance with SEQR, such a classification would negate the SEQR environmental review process for the project. However, in 1998 the NYSDEC required that the Clinton Street CSO Abatement Project (as well as other selected ACJ projects) undergo the SEQR review process as a Type I action. Although by regulation, the project would be classified as a Type II action because it is a product of enforcement, the Clinton Street CSO Abatement Project is being analyzed as if it were a Type I action.

In accordance with 6 NYCRR Part 617(a)(2) for Type I actions, a full Environmental Assessment Form (fEAF) must be used to evaluate the significance of the action. The fEAF must contain enough information to describe the proposed action, its location, its purpose and its potential impacts on the environment so that the environmental significance or nonsignificance of the proposed action can be identified. The fEAF consists of three parts:
 

A Lead Agency must be designated to coordinate the environmental review process and assure compliance with the procedural requirements of SEQR when two or more agencies are involved in a review of a Type I action. (Involved agency means a state or local agency that has jurisdiction by law to fund, approve or directly undertake an action. If an agency will ultimately make a discretionary decision to fund, approve or undertake an action, then it is an "involved agency" notwithstanding that it has not received an application for funding or approval at the time the SEAR process is commenced [6 NYCRR Part 617].)

The involved/interested agencies for this action due to their actual and/or potential direct involvement (as described in Section 1.6 below) consist of:
 
- Onondaga County
- Office of Parks, Recreation, and Historic Preservation (OPRHP)
- City of Syracuse
- Onondaga County Industrial Development Agency (OCIDA)
- United States Army Corps of Engineers (USACOE)
- NYS Environmental Facilities Corporation (NYSEFC)
- NYS Department of Transportation (NYSDOT)
- NYSDEC
- USEPA
 
(An interested agency is an agency that lacks the jurisdiction to fund, approve or directly undertake an action but wishes to participate in the review process because of its specific expertise of concern about the proposed action. An "interested agency" has the same ability to participate in the review process as a member of the public [6 NYCRR Part 617].)

In March 2005, Onondaga County submitted a Lead Agency designation letter to provide notice of the County's desire to serve as Lead Agency. In addition, the following documents were provided:

• Parts 1 and 2 of the fEAF (forms) prepared by the County under separate cover.
• The Clinton Street CSO Abatement Project EID represents Part 3 of the fEAF.

Following submittal of the Lead Agency designation letter, a possible Lead Agency dispute arose "based on the City's failure to specifically concur with the County's proposal to serve as lead agency following the County's March 2005 coordination letter." In July 2005, the NYSDEC "agreed that the County should serve as lead" (NYSDEC 2005).

Following coordinated environmental review of SEQR documents, the County as Lead Agency will make a formal determination of environmental nonsignificance (negative declaration) or environmental significance (positive declaration). The filing of a negative declaration by the County will conclude the SEQR review process wherein the filing of a positive declaration requires the preparation of an Environmental Impact Statement (EIS) (draft and final) and a statement of findings. Should it be concluded that a positive declaration be filed in connection with the Clinton Street CSO Abatement Project, it is the intent of the County that this document also serve as the draft Environmental Impact Statement (dEIS).

1.6 Anticipated approvals/permits

The implementation of the Clinton Street CSO Abatement Project will require a series of reviews and approvals, as well as obtaining various permits from regulatory agencies (federal, state, and local). Table 1-4 summarizes the various reviews, approvals, and permits anticipated for the Clinton Street CSO Abatement Project (both construction and operational).
 
required.

Table 1-4 Anticipated Approvals/Permits
Type (citation)	Governing agency(ies)	Activity covered	Comment
SEQR: Description of SEQR activities is in Section 1.5.	Lead Agency & involved/interested agencies	NYS env review	This document is Part 3 of fEAF. Co. seeks to be Lead Agency. Involved agencies have approval authority/ jurisdiction.
Co. approvals (various)	Onondaga Co.	Funding, Lead Agency designation**, final determination.	Inc. Capital Improvement Prog, Annual Capital Budget, Commissioner's Hearing, Co. Executive Approval, Co. Health Dept Approval, Legislative Approval
Federal & State Historic Preservation Laws (9 NYCRR 428 & 36 CFR 800)	Office of Parks, Recreation, & Historic Preservation (OPRHP) & Onondaga Nation	Archeological sensitivity assessment review (Phase 1A & Phase 1B)	See Sections 3.5 & 5.5
City permits***	City of Syracuse	Permanent easements & road cut permits for sewers in City streets
Railroad crossing permit/easement	OCIDA & New York Susquehanna & Western	Installation of conveyances under/adjacent to railroad tracks	OCIDA easement also needed to install conveyances on OCIDA property
Federal stream crossing & excavation or fill of navigable waters permit (§10 Rivers & Harbors Act/§404 of Clean Water Act)	USACOE	Navigable waters/waters of U.S.	Same permit as required by state but undergoes independent federal review
Revolving Loan Fund	NYSEFC	Project funding of reimbursable work items
Road crossing	NYSDOT	Work within a state roadway	A small portion of the conveyance will be in right-of-way of West Street (a NYSDOT roadway).
Excavation/fill of navigable waters (6 NYCRR 608.5)	NYSDEC	Excavation/fill of waterway during stream crossing	Stream classification of Creek in project area is "C": suitable for fishing (6 NYCRR 701, 895). Therefore 6 NYCRR 608.5 permit
State Pollutant Discharge Elimination System (SPDES) permit (6 NYCRR 750-757)	NYSDEC	Construction activity storm water permit & discharge permit for treated effluent
Bulk chemical storage permit (6 NYCRR 595-599)	NYSDEC	Tank permits for treatment chemicals
Air facility registration	NYSDEC	Odor control units	Confirmation will be based on final design
Facilities Plan, Eng. Design Report, & Const. documents	NYSDEC	Design & build
Note: Should the County receive federal funding for the project, review & approval of the project by the USEPA under NEPA will be required.

*** Source: Macry (2002), Wallace (2002), & Esposito (2002)

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Susan Miller, Project Deputy Director
Phone 315-435-2260   Fax 315-435-5023
 Onondaga County Dept of Water Environment Protection