Reporting Outcomes from CWA CSO, and CWA SSO Enforcement Actions
For CWA Combined Sewer Overflow (CSO) and Sanitary Sewer Overflow (SSO) enforcement actions, both the gallons of untreated discharge eliminated, and the pounds of pollutants reduced should be reported to ICIS. This data is entered on the Final Order, Complying Action/Injunctive Relief Screen. The pollutant name to associate with the gallons of untreated discharge eliminated is "Untreated Sewage", "Sanitary sewage", "Wastewater", or "Sanitary waste". The screen shot below shows an example of a correctly entered case.
The ICIS report "National Enforcement Initiative Environmental Benefits" can be used to review the gallons of untreated discharge eliminated, and the pounds of pollutant reduced. The gallons are counted in the metric: "Volume (gallons) of Untreated Discharge Eliminated". The pounds are counted in the metric: "Estimated Water Pollutants Reduced, Treated, or Eliminated (pounds)".