Summary of 1996 CWNS Documentation Types

DOCUMENTATION TYPE

Allowable for Justification of

1. Capital Improvement Plan

A capital plan must adequately address why the project is needed and provide costs which are project specific.

1. Infiltration/Inflow (I/I) Analysis

An I/I analysis is a document that identifies excessive flow problems due to infiltration or inflow into the sewage conveyance system. The I/I analysis itself may be contained within a Facility Plan, a Sewer System Evaluation Survey, or a Combined Sewer Overflow Report.

1. Sewer System Evaluation Survey (SSES)

An SSES is a document that contains the results of a sewer system survey, manhole inspection, smoke testing, and flow monitoring. It is used to evaluate the physical condition of a sewer system and identifies areas of combined sewers, downspout connections, and locations where the sewer system is at capacity. In many cases a CSO study is placed in this category.

1. Final Engineer's Estimate

The final engineer's report is typically submitted as a result of a detailed facility design.

1. Cost of Previous Comparable Construction

This document may be used to justify costs if stringent guidelines are followed and the costs are project specific.

1. Facilities Plan

Excerpts from a facilities plan are acceptable forms of documentation to justify a need and to update cost estimates.

1. Plan of Study

This documentation type must be an official project description. A plan of study precedes a facilities plan.

The 1-year fundable plus 4-year planning portion of the FY1996 or 1997 list may be used to document need as long as it was accepted by the Region. The cost estimate report on the priority list may be used to document a cost estimate for the facility if the project is in the fundable portion of the priority list. Projects on the fundable portion of the current intended use plan may also be used for cost estimates.

CWA Section 208 and 303 Regional Basin Plans are broad-based water quality management plans written to identify future planning for areas within a State. Only Section 208 and 303 documents that contain site-specific information and a description of a need can be accepted as documentation of need. Documentation of cost is assessed on a case-by-case basis depending on the amount of detail reported and the source of the information.

Federal or equivalent State grant applications or SRF applications may be used to document needs and to update costs for the categories in which the grant money is requested. Applications should contain sufficient clearly written narrative that defines the specific project and the water quality and/or public health problem. If an equivalent State grant program application is used as documentation, the form must be submitted.

A MCP is developed when a municipality needs to construct a wastewater treatment facility to achieve compliance. The MCP should describe the necessary treatment technology and estimated cost, outline the proposed sources and methods of financing the proposed facility (both construction and operation and maintenance), and provide a schedule for achieving compliance as soon as possible.

A diagnostic evaluation is usually performed when a facility cannot achieve effluent discharge permit limits or when it experiences design, operational, analytical, or financial problems that limit the performance of the facility. This type of evaluation may be used to document a need if the results indicate that construction is necessary to achieve compliance.

These official documents are usually issued as the result of continued violation of an NPDES permit or other pollution control requirements. The order or decree must state a need for construction to correct the violation in order to document the need. Cost curves will be used to calculate associated costs.

A Sanitary Survey is a logical, investigative approach to gather information to evaluate the condition of existing on-site wastewater systems. The sanitary survey must document high area-wide failure rates that are considered serious enough to be a health hazard (such as ground water contamination caused by malfunctioning septic tanks) in order to document a need. The documentation must clearly state that on-site failures are contributing to a water pollution or health-related problem. This documentation will be reviewed by EPA on a case-by-case basis.

These plans are similar to State-Approved Area-Wide Basin Plans. These local plans also cover fairly large areas and might not contain project-specific information. These local plans must clearly identify a water quality or health-related problem and must be project specific to be acceptable as documentation.

This document may be used to demonstrate that a need exists for infiltration/inflow correction.

A Municipal Wasteload Allocation Plan is a water quality analysis done to determine the level of treatment required by a specific project, which is ultimately translated into an effluent limitation for the NPDES permit. These plans can be used to justify the need for a treatment plant enlargement or upgrade as long as the study identifies a specific sewage treatment point source and appropriate design flows and treatment levels. This plan can be used to document a need and may be used to update costs if the project descriptions identify specific costs.

States should not use this documentation code.

and

20. Partial Grant/Loan Award

The costs in the CWNS database should be reduced based on the grant awards or SRF loans. If the total needs have been satisfied, the needs should be reduced to zero and a "19" entered in the documentation type. If only a part of the needs have been satisfied, the needs estimate should be reduced by the grant or loan amount, with the difference entered in the correct needs category and a "20" (partial grant/loan award) entered as the documentation type.

The National Pollutant Discharge Elimination System (NPDES) is a permitting program implemented under authority of the CWA that is designed to control point source discharges of pollution. Facilities not meeting effluent limitations and on compliance schedules or facilities required to plan because they are at or near plant capacity may submit documentation under documentation type 21.

A Municipal Storm Water Management Plan is a plan submitted as a proposed municipal storm water management program as part of a municipality's NPDES storm water permit application. It includes a description of structural and source control measures that are to be implemented to (1) reduce pollutants in runoff from commercial and residential areas that are discharged from the storm sewer, (2) detect and remove illicit discharges and improper disposal into storm sewers, (3) monitor pollutants in runoff from industrial facilities that discharge to municipal separate storm sewers, and (4) reduce pollutants in construction site runoff that is discharged to municipal separate storm sewers.

A Nonpoint Source Management Plan is a 4-year plan developed by a State to address nonpoint source pollution problems. Elements in the program include: identification of the best management practices and measures to reduce pollutant loading; programs to achieve implementation; a schedule with annual milestones, costs, and identification

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of specific projects; certification that the laws of the State will provide adequate authority to implement the plan; and sources of funding and assistance. A Nonpoint Source Assessment Report assesses the extent of pollution due to diffuse or nonpoint sources within a State. The report identifies navigable waters that require nonpoint source controls to achieve CWA water quality standards, sources and amounts of such pollution, and State and local control programs. It also describes the process that will be used to identify best management practices. EPA will consider other documentation, such as nonpoint source grant applications and State's surveys, on a case-by-case basis.

States can use a Comprehensive Ground Water Protection Strategy to document NPS needs if the strategy is part of a Nonpoint Source Management Program. The goals of this major Federal initiative addressing ground water protection are to strengthen State ground water programs; deal with significant, poorly addressed ground water problems; create a policy framework within EPA for the guidance of ground water policy; and strengthen the ground water organization within EPA. Included in such a strategy are programs established under the SDWA such as regulation of the injection of wastes into deep wells, the Wellhead Protection Program, and the Sole Source Aquifer program. Provisions in the Resource Conservation and Recovery Act (RCRA) for leaking underground storage tanks, goals in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for contaminated ground water sites, and State grant programs in the CWA for ground water protection activities are covered by this strategy.

A well-head Protection Plan can be used to document NPS needs if it is part of a Nonpoint Source Management Program. As part of its overall ground water protection strategy, each State must delineate well-head protection areas for wells or well fields used for public water supply. Contaminant sources within the well-head protection area must be identified and a management plan developed to protect the water supply in that area from contamination. Contingency plans for each public water supply system must be developed to ensure an appropriate response in the event that contamination occurs, and standards must be established for locating new wells so as to minimize the potential for contamination of the water supply.

States can document needs to address NPS aspects of a Delegated Underground Injection Control Program Plan if it is part of the State's Nonpoint Source Management Program. As part of the Safe Drinking Water Act, EPA and State Underground Injection Control Programs were established to protect potential underground sources of drinking water from contamination by injection wells.

A Comprehensive Conservation Management Plan (CCMP) is a management plan developed for an estuary that has been nominated for the CWA section 320 National Estuary Program. The CCMP summarizes findings, identifies and establishes a priority for addressing problems, determines environmental quality goals and objectives, identifies action plans and compliance schedules for pollution control and resource management, and ensures that designated uses of the estuary are protected.

All applications for funding (with signed agency review sheets, e.g., Rural Economic and Community Development - formerly Farmers Home Administration, Community Development Block Grant - Housing and Urban Development) other than SRF are acceptable for need. The application is acceptable for cost if an engineering report is reviewed by qualified state project staff. (See documentation type 10 for SRF loan applications.)

All State Needs Surveys are acceptable for documenting need if:

• A local government official's signature is included ("local" means city, community, town, borough, village, or county).

• Information describing the problem is attached.

• Information describing prior or ongoing planning efforts and descriptions of the cost-effective control option are offered.

State Need Surveys are acceptable for documenting cost if a cost estimate that has been prepared and signed by an engineer or engineer circuit rider is attached. The cost estimate need not be as detailed as that found in a facility plan, but must include the engineer's rationale for the estimate. Qualified state project staff must also sign a statement of cost reasonableness after reviewing the estimate.

Use of a standard or "model" survey form (only for populations <1,000) is acceptable for documenting need (and cost) as long as signatures are included. If costs are not included, cost curves will be used.

A statement of need from a technical assistance provider (State training center, health department, circuit rider, etc.) with soils/geologic report would document need for communities. Local official and provider signatures must be included. Cost curves will be used to document costs. Remember that cost curves are based on simple regressions of data in the CWNS and represent "comparable costs" even though the cost curves might not include all allowable costs.

b Only the 1-year fundable portion can be used to justify cost.

c Documentation may have information that can be used to justify cost. Cost justification for Categories I-VII

must be project specific, and distributable among Categories I-VII.