Visit the dedicated website RainstormReady.com for highlights on work happening in your community to help solve this regional problem.
EPA Administrative Order regarding sewer systems
In 2009, the USEPA issued an Administrative Order to all fourteen municipalities that are served by the regional sewer system in our area, including LCA, the City of Allentown, and all outlying municipalities that connect to the system. The order requires all municipalities to make significant improvements to the sewer systems to eliminate sewer overflows. Sewer overflows can happen when rainwater, runoff from floods, melting snow or other sources overwhelm the existing sewer system.
Update – March 11, 2019
The U.S. Environmental Protection Agency accepted the region’s plan to address sanitary sewer overflows and provided notice to Lehigh County Authority (LCA) and the City of Allentown that the parties have completed the requirements of the Administrative Orders EPA issued about a decade ago to address the problem. In the letter, EPA Water Protection Division Director Catherine Libertz handed the program over to state regulators to oversee, noting that EPA will continue to monitor the region’s work on the issues. Last summer, LCA joined the City and 13 other municipalities in preparing a regional flow management strategy to address wet-weather system challenges that cause overflows at the regional wastewater treatment plant in Allentown, and from manholes in other locations throughout the system. The strategy represented a cooperative and collaborative effort among all municipalities to eliminate leakage into the nearly 900 miles of sanitary sewer system pipes that run throughout western and central Lehigh County, including Allentown. The leakage comes from a variety of sources including aging sewer pipes, leaking customer laterals, unauthorized connection of sump pumps and roof drains into the sewer system, and aging or damaged manholes. LCA views the EPA release of the Administrative Order as a clear sign that collaboration works. The municipalities have worked together to develop a plan that will work to solve the system issues we are experiencing.
Update – July 26, 2018
To meet an August 1, 2018 submission deadline, all municipalities including LCA and the City of Allentown jointly submitted a Regional Flow Management Strategy to the U.S. Environmental Protection Agency on July 26, 2018. The submission represents a collaborative and cooperative effort among the municipalities within the Kline’s Island Sewer System and includes the following critical elements: 1) collection system operation and maintenance; 2) system characterization; 3) inflow and infiltration removal; and 4) flow monitoring. The Regional Flow Management Strategy documents are available below and include a description of work expected to be completed by each municipality, in addition to collaborative strategies for the management of flows in our system, along with copies of letters from each of them indicating their commitment to this work moving forward.
Municipal Commitment & Submission Letters
Regional Flow Management Strategy – All Municipalities
APPENDIX A – City of Allentown O&M Plan
APPENDIX B – LCA, Lowhill, Weisenberg & Upper Milford O&M Plan
APPENDIX C – South Whitehall Township O&M Plan and I&I Source Reduction Plan
APPENDIX D – Coplay-Whitehall Sewer Authority O&M Plan and I&I Source Reduction Plan
APPENDIX E – Salisbury Township O&M Plan
APPENDIX F – Borough of Emmaus O&M Plan
APPENDIX G – Borough of Alburtis O&M Plan
APPENDIX H – Borough of Macungie O&M Plan
APPENDIX I – Upper Macungie Township O&M Plan
APPENDIX J – Lower Macungie Township O&M Plan
APPENDIX K – Hanover Township O&M Plan
APPENDIX L – City of Allentown I&I Source Reduction Plan
APPENDIX M – Western Lehigh Sewerage Partnership Rehabilitation Plan (includes LCA, Alburtis, Macungie, and Upper Macungie, Lower Macungie, Upper Milford, Weisenberg and Lowhill townships)
APPENDIX N – Salisbury Township I&I Source Reduction Plan
APPENDIX O – Borough of Emmaus I&I Source Reduction Plan
Other Recent Updates:
June 25, 2018 – Regional Flow Management Strategy – Update to LCA Board
August 14, 2017 – EPA Administrative Order – Update
November 11, 2016 – Summary of 11/9/16 City of Allentown meeting & public comments
November 9, 2016 – City of Allentown presentation on options to address wet-weather flows at the City wastewater treatment plant
July 11, 2016 – Public presentation of the region’s selected approach to becoming “Rainstorm Ready”
What else are we doing?
The order requires LCA to provide regular reports on our progress. We’ve been working diligently to upgrade the sewer system since then, and our work has included (but is not limited to):
- Working with all the municipalities in our service area to develop strategies to reduce clear water leakage into our sewer system, called “Inflow and Infiltration,” which causes sewer system overflows during period of heavy rain.
- Flow monitoring to determine where the leakage is coming from. Some communities in LCA’s service area are utilizing “smoke testing” to help find the source of sewer leaks. Download LCA’s Fact Sheet about Smoke Testing. You can also visit the Charleston Water System website to see a short YouTube video on smoke testing.
- Bolting down manholes and other manhole repairs to prevent rainwater from entering the system
- Camera / video taping of sewer lines to look for cracks and leaks
- Repairing cleanout caps
- Customer outreach and in-home inspections to find unauthorized connections, such as sump pumps and roof drains.
Official Documents & Reports:
- EPA’s Administrative Order
- Western Lehigh Sewerage Partnership PA DEP Annual Report – 2018 (March 2019)
- Western Lehigh Sewerage Partnership EPA Semi Annual Report -2017 (March 2018)
- Western Lehigh Sewerage Partnership EPA Semi Annual Report 07.2017 (July 2017)
- Request for Extension of EPA Administrative Order (Submitted to EPA on November 14, 2014)
- Administrative Order Extension on Consent – Extended to December 31, 2017 (Received February 11, 2016)
- LCA-Western Lehigh Sewerage Partnership 5-Year Report
- City of Allentown 5-Year Report
- Borough of Emmaus 5-Year Report
- Hanover Township 5-Year Report
- Salisbury Township 5-Year Report
Resources, Research & Presentations:
- Rainstorm Ready – Presentation of Selected Alternative & Cost Overview (July 2016)
- System-Wide Alternatives Analysis (maps & costs – November 2015)
- Abbreviations & Definitions (Reference guide for all the acronyms and terms used in the presentation and other documents)
- Download Overview Presentation to Learn More About Infiltration & Inflow
- Public Presentation (Comprehensive update presented to the community on November 13, 2014)
- Q&A about Sewer Overflows and the Administrative Order (Compiled questions from our public outreach program)
- Public Meeting Agenda (Outline of material presented at the November 13, 2014 public meeting)