11

Statewide General Waste Statewide General Waste Discharge Requirements Discharge Requirements

forfor Sanitary Sewer SystemsSanitary Sewer Systems

BACWA

22

DisclaimersDisclaimers

We did not write the WDR!We did not write the WDR! This is an overview only – though lengthy This is an overview only – though lengthy

at that!at that! CWEA will be offering much more CWEA will be offering much more

comprehensive training for the wastewater comprehensive training for the wastewater communitycommunity

33

Presentation OutlinePresentation Outline

1.1. HistoryHistory

2.2. Purpose of the WDRPurpose of the WDR

3.3. The Basic Requirements of the WDRThe Basic Requirements of the WDR• Application Application • On-line reporting of Sewer System Overflows On-line reporting of Sewer System Overflows • Development of a Sewer System Management Development of a Sewer System Management

Plan Plan

44

HistoryHistory

State Water Resources Control Board State Water Resources Control Board (SWRCB) Resolution 2004-80(SWRCB) Resolution 2004-80 Required staff to develop work with Required staff to develop work with

stakeholders to develop a regulatory program stakeholders to develop a regulatory program that would provide a consistent approach to that would provide a consistent approach to reducing Sewer System Overflows (SSOs)reducing Sewer System Overflows (SSOs)

SSO Guidance Committee formedSSO Guidance Committee formed Committee included SWRCB Staff, Industry Committee included SWRCB Staff, Industry

Representatives and NGOsRepresentatives and NGOs

55

HistoryHistory(continued)(continued)

Committee developed a draft Waste Discharge Committee developed a draft Waste Discharge Requirement (WDR)Requirement (WDR) Applies to entities that own or operate collection Applies to entities that own or operate collection

systems greater than one-mile in lengthsystems greater than one-mile in length Basic RequirementsBasic Requirements

All public operated sewer collection systems must All public operated sewer collection systems must applyapply for coverage under the WDR for coverage under the WDR

All covered collection systems must begin All covered collection systems must begin on-line on-line reportingreporting of SSOs. of SSOs.

All covered collection systems must All covered collection systems must developdevelop a Sewer a Sewer System Management PlanSystem Management Plan

66

HistoryHistory(continued)(continued)

First public hearing held February 8First public hearing held February 8 Comment period extended two weeks by SWRCB to Comment period extended two weeks by SWRCB to

receive additional information from attendeesreceive additional information from attendees Second public hearing held May 2, 2006 Second public hearing held May 2, 2006

Final WDR adopted on May 2, 2006Final WDR adopted on May 2, 2006 Granted extension to original compliance schedules Granted extension to original compliance schedules

contingent upon CWEA/industry and SWRCB contingent upon CWEA/industry and SWRCB entering into an Memorandum of Agreement for entering into an Memorandum of Agreement for trainingtraining

77

Purpose of WDRPurpose of WDR

Proactive approach to ensure system wide Proactive approach to ensure system wide operation, maintenance and management plans operation, maintenance and management plans to reduce SSOsto reduce SSOs Concept is that many SSOs are preventableConcept is that many SSOs are preventable

Allows SWRCB to gather consistent data on Allows SWRCB to gather consistent data on causes and sources of SSOscauses and sources of SSOs Intents is to provide SWRCB with better Intents is to provide SWRCB with better

understanding of the issueunderstanding of the issue

88

Caution!Caution!

Key issue unresolved: Potential conflicts Key issue unresolved: Potential conflicts between Regional Board and SWRCB between Regional Board and SWRCB requirementsrequirements Allows Regional Boards to be more stringentAllows Regional Boards to be more stringent Unclear as to implementation issues, such as Unclear as to implementation issues, such as

schedule for reporting, etc.schedule for reporting, etc.

99

Basic DefinitionsBasic Definitions

Sanitary Sewer Overflow (SSO)Sanitary Sewer Overflow (SSO) Releases of untreated or partially treated Releases of untreated or partially treated

wastewater to waters of the United Stateswastewater to waters of the United States Releases of untreated or partially treated Releases of untreated or partially treated

wastewater that do not reach waters of the wastewater that do not reach waters of the United StatesUnited States

Wastewater backups into buildings and on Wastewater backups into buildings and on private property that are caused by blockages private property that are caused by blockages in the publicly owned portion of the sanitary in the publicly owned portion of the sanitary sewer systemsewer system

1010

Basic DefinitionsBasic Definitions(continued)(continued)

SSO Reporting SystemSSO Reporting System On-line spill reporting system hosted, On-line spill reporting system hosted,

controlled and maintained by the SWRCBcontrolled and maintained by the SWRCB Untreated or partially treated wastewaterUntreated or partially treated wastewater

ANY volume of waste discharged from the ANY volume of waste discharged from the sanitary sewer collection system upstream of sanitary sewer collection system upstream of a wastewater treatment planta wastewater treatment plant

1111

SSO CategoriesSSO Categories Category 1Category 1

Exceeds 1,000 gallons, orExceeds 1,000 gallons, or Results in discharge to surface waters, or Results in discharge to surface waters, or Discharge to storm drain and not capturedDischarge to storm drain and not captured

Category 2 Category 2 All other discharges from Enrollee’s sewer All other discharges from Enrollee’s sewer

systemsystem Private Lateral Sewage DischargePrivate Lateral Sewage Discharge

Discharges caused by privately owned lateralDischarges caused by privately owned lateral

1212

Application RequirementsApplication Requirements

All “known” collection systems in the State All “known” collection systems in the State database will receive an instruction letter database will receive an instruction letter from the SWRCB by July 2006.from the SWRCB by July 2006.

All “other” collection systems must also All “other” collection systems must also apply. apply. Their responsibility to go online and get Their responsibility to go online and get

informationinformation Application must be submitted by Application must be submitted by

November 2, 2006.November 2, 2006.

1313

(Some) Application Details(Some) Application Details

The application must be submitted to the The application must be submitted to the SWRCB, and signed by the enrollee’s SWRCB, and signed by the enrollee’s “legally authorized representative”“legally authorized representative” Must be hard copy since SWRCB needs wet Must be hard copy since SWRCB needs wet

signature of representativesignature of representative Enrollee is covered under program once Enrollee is covered under program once

completed application package approved completed application package approved by the SWRCB Division of Water Qualityby the SWRCB Division of Water Quality Tip: Don’t wait until the last minute!Tip: Don’t wait until the last minute!

1414

Caution!Caution!

Log on to system with username and Log on to system with username and password within 30 days of receipt of both password within 30 days of receipt of both and prior to reporting your first spilland prior to reporting your first spill Must fill out “Collection System Questionnaire”Must fill out “Collection System Questionnaire” Questionnaire must be updated every 12 Questionnaire must be updated every 12

monthsmonths

1515

On-Line Reporting RequirementsOn-Line Reporting Requirements

1.1. Reporting deadlines by RegionReporting deadlines by Region

2.2. Timeframes for reporting actual SSOsTimeframes for reporting actual SSOs

3.3. Required information for reportsRequired information for reports

1616

Phased ReportingPhased Reporting

Regions 4, 8, 9: January 2, 2007

Regions 1, 2, 3: May 2, 2007

Regions 5, 6, 7: September 2, 2007

1717

SSO Reporting TimeframesSSO Reporting Timeframes

Category 1 SSOsCategory 1 SSOs Initial Report ASAP but no more than 3 Initial Report ASAP but no more than 3

business daysbusiness days Final Certified Report within 15 days of Final Certified Report within 15 days of

conclusion of response and remediationconclusion of response and remediation

Category 2 SSOsCategory 2 SSOs Report within 30 days of the end of the Report within 30 days of the end of the

monthmonth

1818

Reporting TimeframesReporting Timeframes(continued)(continued)

Private Lateral SSOsPrivate Lateral SSOs May be reported at Enrollee’s discretionMay be reported at Enrollee’s discretion

No SSOs During MonthNo SSOs During Month Report no SSOs within 30 days of end of Report no SSOs within 30 days of end of

the monththe month

1919

Caution!Caution!

These requirements do These requirements do not supercede required not supercede required timeframes for reporting to timeframes for reporting to the the Office of Emergency Office of Emergency Services, County Health Services, County Health Departments and Departments and Regional Water Regional Water BoardsBoards!!!!!!!!

2020

Sewer System Management PlanSewer System Management Plan

1.1. Sewer System Management Plan Sewer System Management Plan (SSMP) components (SSMP) components

2.2. Phased implementation timeframes by Phased implementation timeframes by size of community servedsize of community served

2121

SSMP ComponentsSSMP Components

Plan and SchedulePlan and Schedule GoalsGoals OrganizationOrganization Legal AuthorityLegal Authority Overflow Emergency Response PlanOverflow Emergency Response Plan Operation and Maintenance PlanOperation and Maintenance Plan FOG Control ProgramFOG Control Program

2222

SSMP ComponentsSSMP Components(continued)(continued)

Design and Performance StandardsDesign and Performance Standards System Capacity Assurance PlanSystem Capacity Assurance Plan Monitoring, Measurement, and Program Monitoring, Measurement, and Program

ModificationsModifications SSMP Program AuditsSSMP Program Audits Communication ProgramCommunication Program Final CertificationFinal Certification

2323

SSMPSSMPFinal CertificationFinal Certification

SSMP and program to implement SSMP must SSMP and program to implement SSMP must be certified in compliance with GWDR by be certified in compliance with GWDR by Enrollee’s governing body at a public meetingEnrollee’s governing body at a public meeting Authorized representative follows up with submittal to Authorized representative follows up with submittal to

SWRCB of signed and completed form regarding SWRCB of signed and completed form regarding certification certification

Program must be internally audited every two Program must be internally audited every two yearsyears

Program must be updated at least every five Program must be updated at least every five yearsyears

2424

SSMPSSMPImplementation ScheduleImplementation Schedule

TaskTask Population > Population > 100,000100,000

Population Population 10,000 to 10,000 to 100,000100,000

Population Population 2,500 to 2,500 to 10,00010,000

Population < Population < 2,5002,500

Plan and Plan and ScheduleSchedule

8/02/078/02/07 11/02/0711/02/07 2/02/082/02/08 5/02/085/02/08

Goals Goals OrganizationOrganization

11/02/0711/02/07 11/02/0711/02/07 5/02/085/02/08 5/02/085/02/08

Emer. Resp. PlanEmer. Resp. Plan

Legal AuthorityLegal Authority

O&M PlanO&M Plan

FOG PlanFOG Plan

11/02/0811/02/08 5/02/095/02/09 11/02/0911/02/09 2/02/102/02/10

Design and Design and Perfor. StandardsPerfor. Standards

System Capacity System Capacity PlanPlan

Final SSMP and Final SSMP and CertificationCertification

5/02/095/02/09 8/02/098/02/09 5/02/105/02/10 8/02/108/02/10

2525

SummarySummary

All public owned sewer collection systems All public owned sewer collection systems in the State greater than one-mile in length in the State greater than one-mile in length must:must:

Apply for the State General Waste Apply for the State General Waste Discharge Requirements for Sanitary Discharge Requirements for Sanitary Sewer SystemsSewer Systems

Report SSOs using SWRCB on-line Report SSOs using SWRCB on-line reporting systemreporting system

Develop a comprehensive Sewer System Develop a comprehensive Sewer System Management PlanManagement Plan

2626

CWEA Training PlansCWEA Training Plans

CWEA is planning on conducting training CWEA is planning on conducting training for:for: On-line reportingOn-line reporting Monitoring and Reporting RequirementsMonitoring and Reporting Requirements SSMP development and implementationSSMP development and implementation

CWEA’s commitment to training has CWEA’s commitment to training has allowed compliance deadlines that were allowed compliance deadlines that were presented todaypresented today Original deadlines were unrealisticOriginal deadlines were unrealistic

2727

Stay Tuned!Stay Tuned!

Details on training are under developmentDetails on training are under development Materials being developedMaterials being developed Focus first on Monitoring and Reporting and Focus first on Monitoring and Reporting and

On-line reportingOn-line reporting Interested in helping prepare training Interested in helping prepare training

materials/conduct training/assist with materials/conduct training/assist with logistics?logistics? Then Nick is your man!Then Nick is your man!

2828

Thank you!Thank you!

Nick PinheyNick Pinhey CWEA SSO WDR Training Task Force ChairCWEA SSO WDR Training Task Force Chair Phone: 209-577-5205Phone: 209-577-5205 npinhey@modestogov.comnpinhey@modestogov.com

Maura BonnarensMaura Bonnarens CWEA President-ElectCWEA President-Elect Phone: 510-287-1141Phone: 510-287-1141 mbonnare@ebmud.commbonnare@ebmud.com