A point source of a different color: identifying a gap in United States regulatory policy for "green" cso treatment using constructed wetlands

International audienceUp to 850 billion gallons of untreated combined sewer overflow (CSO) is discharged into waters of the United States each year. Recent changes in CSO management policy support green infrastructure (GI) technologies as “front of the pipe” approaches to discharge mitigation by detention/reduction of urban stormwater runoff. Constructed wetlands for CSO treatment have been considered among suites of GI solutions. However, these wetlands differ fundamentally from other GI technologies in that they are “end of the pipe” treatment systems that discharge from a point source, and are therefore regulated in the U.S. under the National Pollution Discharge Elimination System (NPDES). We use a comparative regulatory analysis to examine the U.S. policy framework for CSO treatment wetlands. We find in all cases that permitting authorities have used best professional judgment to determine effluent limits and compliance monitoring requirements, referencing technology and water quality-based standards originally developed for traditional “grey” treatment systems. A qualitative comparison with Europe shows less stringent regulatory requirements, perhaps due to institutionalized design parameters. We recommend that permitting authorities develop technical guidance documents for evaluation of “green” CSO treatment systems that account for their unique operational concerns and benefits with respect to sustainable development

Constructed wetlands for treatment of combined sewer overflow in the US: a review of design challenges and application status

International audienceAs combined sewer systems and centralized wastewater treatment facilities age, many communities in the world are challenged by management of combined sewer overflow (CSO). Constructed wetlands are considered to be one of the green infrastructure solutions to CSOs in the US. Despite the wide application of constructed wetlands to different types of wastewaters, the stochastic and intermittent nature of CSO presents challenges for design and performance assessment of constructed wetlands. This paper reviews the application status of CSO constructed wetlands in the US, assesses the benefits of CSO constructed wetlands, identifies challenges to designing CSO constructed wetlands, and proposes design considerations. This review finds that constructed wetlands are effective in CSO treatment and relatively less expensive to build than comparable grey infrastructure. Constructed wetlands not only remove pollutants, but also mitigate the event-associated flow regime. The design challenges include incorporating considerations of green infrastructure into permit requirements, determining design capacity for highly variable flows, requiring pretreatment, and needing adaptive design and intensive monitoring. Simultaneous monitoring of flow rate and water quality at both the inflow and outflow of CSO constructed wetlands is required for performance assessment and needed to support design, but is rarely available