The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
1
of
2
Proposed
Priority:
Wet
Weather:
Combined
Sewer
Overflows/
Sanitary
Sewer
Overflows
(
CSOs/
SSO)
s,
Storm
water,
and
Concentrated
Animal
Feeding
Operations
(
CAFOs)

Universe
and
Types
of
Facilities:
CSOs/
SSOs
are
defined
as
municipal
facilities
with
combined
sewer
overflows
(
CSOs)
and
separate
sanitary
overflows
(
SSOs).
There
are
approximately
900
CSO
communities
serving
over
40
million
people.
Most
combined
sewer
systems
were
constructed
50
or
more
years
ago.
There
are
approximately
19,000
separate
sanitary
sewer
municipal
systems
with
over
40,000
overflows
annually.
The
total
number
of
storm
water
dischargers
is
unknown
but
expected
to
be
several
hundred
thousand.
Storm
water
discharges
are
generated
by
runoff
from
land
and
impervious
areas
such
as
paved
streets,
parking
lots,
and
building
rooftops
during
rainfall
and
snow
events
that
often
contain
pollutants
in
quantities
that
could
adversely
effect
water
quality.
A
CAFO
is
a
livestock
facility
where
animals
are
kept
and
raised
in
confinement
and
which
meets
specific
regulatory
criteria.
The
total
number
of
CAFOs
is
estimated
to
be
about
15,500.
CAFO
discharges
account
for
a
significant
share
of
remaining
water
quality
problems.
(
For
further
information
and
explanations
on
CSOs/
SSOs,
Storm
water
and
CAFOs
go
to
http://
www.
epa.
gov/
compliance/
civil/
programs/
cwa/
cwaenfpriority.
html
and
for
additional
information
on
CAFOs
go
to
http://
www.
epa.
gov/
agriculture/
anafoidx.
html.)

Geographic
Range:
Most
CSO
communities
are
located
in
the
Northeast,
Great
Lakes,
and
Northwest
regions.
Separate
sanitary
sewer
systems
and
storm
water
discharges
are
nationwide
occurrences.
CAFOs
exist
in
all
regions
of
the
country
with
more
facilities
in
the
mid­
plains
states,
the
eastern
sea
board,
and
the
western
coastal
region.

Environmental
Risks:
Discharges
from
wet
weather
events
(
e.
g.,
overflows
from
combined
sewers
or
sanitary
sewers,
CAFO
discharges
and
run­
off,
and
storm
water
run­
off)
are
contributors
to
the
leading
causes
of
water
quality
impairment
as
documented
in
CWA
Section
305(
b)
reports
and
represent
significant
threats
to
public
health
and
the
environment.
EPA
has
prioritized
wet
weather
compliance
problems
by
looking
at
regulated
facilities
contributing
to
the
impairment
of
watersheds,
beaches
and
other
recreational
areas,
shellfish
beds,
source
water
protection
areas,
environmental
justice
areas,
and
other
sensitive
areas.

The
main
pollutants
in
sewer
overflows
are
fecal
coliform
(
raw
sewage),
bacteria,
pathogens,
and
nutrients,
untreated
industrial
wastes,
toxic
pollutants
such
as
oil
and
pesticides,
and
debris
washed
into
the
sewer
system.
Storm
water
runoff
is
a
major
cause
of
water
quality
impairment.
According
to
the
Report
to
Congress
on
The
Phase
I
Storm
Water
Regulations
(
U.
S.
EPA,
2000),
urban
storm
water
runoff
contributes
to
13
percent
of
impaired
river
and
stream
miles,
21
percent
of
impaired
lake
acres,
55
percent
of
impaired
ocean
shoreline
miles,
and
46
percent
of
impaired
estuary
square
miles.
Storm
water
runoff
can
carry
high
levels
of
pollutants
such
as
sediment,
oil
and
grease,
suspended
solids,
nutrients,
heavy
metals,
pathogens,
toxins,
and
trash
into
sewer
systems
and
ultimately
into
our
streams,
rivers,
lakes,
estuaries,
wetlands,
and
oceans.
The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
2
of
2
This
creates
an
unhealthy
environment
for
aquatic
organisms,
wildlife
and
humans.
Pollutants
in
sewer
overflows
and
storm
water
discharges
can
cause
a
variety
of
diseases
in
humans,
ranging
from
dysentery
to
hepatitis.
They
can
also
contaminate
fish,
shellfish,
and
drinking
water
sources
create
harmful
algal
blooms,
and
impair
water
quality.

Discharges
from
CAFOs
to
water
bodies
can
occur
through
poor
maintenance
of
waste
lagoons,
improper
storage
of
animal
waste,
excessive
and
improper
application
of
manure
to
crops,
and
excessive
rainfall
resulting
in
spills
and
leaks
of
manure
management
areas.
Key
pollutants
from
CAFOs
that
impair
water
quality
include
nutrients
(
nitrogen
and
phosphorus)
and
pathogens
(
i.
e.
fecal
coliform)
These
pollutants
kill
fish
and
contaminate
shellfish,
cause
excessive
algae
growth,
harm
marine
mammals,
and
contaminate
drinking
water.
Changes
within
the
sector
such
as
increases
in
the
number
of
large
CAFOs,
the
increased
size
of
individual
CAFOs
slaughterhouses,
and
concentration
of
CAFOs
in
some
geographical
areas
has
resulted
in
increased
potential
for
environmental
impacts.

Noncompliance
Information:

The
noncompliance
universe
of
CSOs
and
SSOs
is
currently
being
developed
as
directed
under
the
CSO
and
SSO
Compliance
and
Enforcement
Strategy.
The
NPDES
storm
water
requirements
have
been
in
effect
for
more
than
ten
years.
However,
EPA
and
state
storm
water
inspection
data
reveal
that
a
majority
of
industrial
facilities
inspected
over
the
last
ten
years
do
not
have
an
NPDES
storm
water
permit.
Moreover,
there
is
significant
non­
compliance
at
permitted
sites.
In
August,
2003,
EPA
issued
a
national
strategy
to
improve
compliance
with
storm
water
requirements
and
protect
our
nation's
waters
from
the
harmful
effects
of
polluted
storm
water.
The
Strategy
was
developed
for
use
by
EPA
Regions.
In
addition,
the
Regions
are
encouraged
to
work
with
their
states
in
adopting
similar
approaches
to
storm
water
enforcement.
The
IG
Audit,
"
State
Enforcement
of
Clean
Water
Act
Dischargers
Can
be
More
Effective,"
noted
the
need
for
states
to
have
more
effective
risk­
based
enforcement
strategies
to
better
protect
human
health
and
the
environment
and
to
meet
the
goals
of
the
CWA.
The
Strategy
anticipates
a
strong
EPA/
state
partnership
to
address
non­
compliance
with
storm
water
requirements.
On
February
12,
2003,
EPA
promulgated
new
regulations
to
update
the
national
program
to
manage
and
avoid
environmental
harm
from
animal
manure
and
waste
generated
by
CAFOs.
Educational
outreach
and
compliance
assistance
over
the
next
several
years
will
be
necessary
to
bring
into
compliance
the
approximately
15,500
CAFOs
that
require
National
Pollutant
Discharge
Elimination
System
permits
under
the
Clean
Water
Act.
EPA
regional
offices
and
States
are
working
to
balance
varying
State
circumstances
and
program
approaches
so
that
all
CAFOs
will
be
covered
by
NPDES
permits
and
have
adopted
nutrient
management
plans
by
2006.
On
August
18,
2003,
the
Office
of
Regulatory
Enforcement
issued
the
Final
CWA
Enforcement
Strategy
Update
for
Concentrated
Animal
Feeding
Operations
to
address
noncompliance
problems
at
large
CAFOs
regulated
since
1974
whose
discharges
are
causing
significant
public
health
impacts
or
environmental
harm.
