ALTHOUGH HAVERHILL MA ( CITY OR HAVERHILL ) HAS IMPLEMENTED PHASE I CSO ABATEMENT PROJECTS, UNTREATED OVERFLOWS FROMT THE CITY'S COLLECTIONS SYSTEM CONTINUE TO OCCUR. MA WATER QUALITY STANDARDS ( WQSs )VIOLATIONS, THEREFORE, ALSO CONTINUE. HAVERHILL HAS ALSO REPORTED NUMEROUS SANITARY SEWER OVERFLOWS ( SSOs )FROM ITS SANITARY SEWER MANHOLES.
THE ORDER REQUIRES THE CITY TO SUBMIT TO EPA, AND TO MASS DEP, A SCOPE OF WORK FOR PREPARING A DRAFT PHASE II CSO ABATEMENT PROGRAM. THE PHASE II PROGRAM MUST RECOMMEND A PLAN AND A PROPOSED SCHEDULE FOR ADDRESSING ALL REMAINING CSO OUTFALLS TO RESULT IN FULL NPDES COMPLIANCE AND COMPLIANCE WITH THE WQSs AS SOON A PRACTICABLE. THE ORDER ALSO REQUIRES: (1)WASTEWATER TREATMENT FACILTIY WET-WEATHER CSO RELATED BYPASS EVENT MONITORING AND REPORTING; (2)AN ASSESSMENT OF THE CITY's COLLECTION SYSTEM CAPACITY, MANAGEMENT, OPERATION AND MAINTENANCE PROGRAMS( CMOM ); (3)PREPARATION AND SUBMISSION OF A CMOM CORRECTIVE ACTION PLAN INCLUDING A PROPOSED IMPLEMENTATION SCHEDULE TO PREVENT SSOs IN THE FUTURE; (4)ANNUAL CMOM PROGRAM IMPLEMENTATION REPORTING; (5)DEVELOPMENT AND IMPLEMENTATION OF AN UPDATED ILLICIT DISCHARGE DETECTION AND ELIMINATION ( IDDE )PROGRAM AND ANNUAL REPORTING AND (6)QUARTERLY WORK PROGRESS/WORK PROJECTIONS REPORTING.