-Proposed Revisions- STATEWIDE GENERAL WASTE DISCHARGE REQUIREMENTS for SANITARY SEWER SYSTEMS

DON’T SHOOT THE MESSENGER! Please

What’s New?

A New Name  Sanitary Sewer Overflow Waste Discharge Requirements – SSOWDR – Emphasis on reducing sewer system overflows  Sanitary Sewer System Waste Discharge Requirements – SSSWDR – More emphasis on system operation and enforcement

Who Needs To Apply?  Collection systems having one or more miles of contiguous pipe (contiguous is adjoining, neighboring or connected) and…..  Collects and conveys 25,000 gallons of untreated or partially treated wastewater on any single day

Who Needs To Apply?  Public Collection Systems (counties, cities, districts, schools, parks, prisons, etc.)  Private Collection Systems (HOAs, trailer parks, amusement parks, commercial or industrial centers, etc.)  Federal Collection Systems (military installations, prisons, parks or reserves, etc.)

Who Needs To Apply?  Non-contiguous collection systems if one of the segments meets the enrollment qualification all of the pipelines owned must comply with the WDR and be managed and operated under a sewer system management plan (B.3)

Who Needs To Apply?  New Enrollees, those who were not eligible under the existing Order will have 6 months to apply – Implementation for new Enrollees is based on population served  Existing Enrollees will be required to re- enroll

The Waters Have Changed!  Existing Order refers to “Waters of the U.S.” for Category I spills  Revised Order refers to “Waters of the State” – Definition: any surface water, including saline, within the boundaries of the state of California excluding ground water

What’s a PLSD?  Private Lateral Sewage Discharge – Discharges of wastewater from private laterals or sewer systems that are tributary to the Enrollees collection system but are not owned by the Enrollee and do not meet the requirements for enrollment  All PLSDs Must Be Reported As The Enrollee Becomes Aware Of Them

Money, Money, Money  Funding has a much greater emphasis than in the existing Order – “Budgets shall include costs, revenues, and revenue sources for funding the work over a sufficient period to demonstrate the agency’s ability to properly fund the sewer system in perpetuity.” (D(d)(vi))

Chlorine – A No No?  The revised Order prohibits the discharge of chlorine, including chlorine residual such as that in potable wash water, or any other toxic substance used for disinfection to the waters of the state (C.3) – Waters of the state include storm water systems that are tributary to the waters of the state

Take-Aways  Section D.6 describes the responsibilities of the Regional Boards in an enforcement action and has replaced the word “will” with the word “may” – Language in the current Order was there to ensure that the Regional Board(s) considered the efforts of the Enrollee to prevent SSOs during an enforcement action

Take-Aways  In the definition of a sanitary sewer system (A. 11) the term “construction trenches” has been removed – Can have a major negative effect on construction and repairs of sewer lines

A WDR Or Not?  The state is also asking for comments on whether WDR should become a hybrid NPDES permit – Hybrid NPDES permit means any Enrollee that has had or has in the future a Category I sewage spill will have their WDR converted to an NPDES permit

Proposed Changes To The Sewer System Management Plan

Goal  Language is almost unchanged but intent may be different  Under existing Order Goal(s) were the basis for improving performance over time  Under the revised Order this requirement appears to have been moved to another element

Organization  Revised Order requires the names, addresses and telephone numbers be listed for the current governing board and management in addition to the staff responsible for the development and implementation of the SSMP  Each individuals role and responsibility must be included

Legal Authority  Similar to the existing Order with two new requirements – Must have the legal authority to limit flows from connected sources including laterals and satellite systems – Must have the legal authority to ban new connections  Must specify whether the Enrollee owns or maintains laterals

Operations & Maintenance  Maps must now include siphons and backflow prevention devices  O&M Section shall identify names of contractors providing routine work and a description of services provided  Rehabilitation and Replacement Section shall include a description of any private lateral inspection and or replacement program

Operations & Maintenance  Develop a Staff Assessment Program to assess the proficiency of operations staff including supervisors and contractors  Must indentify deficiencies and be updated annually  Develop a Contingency Plan that identifies the most critical assets posing the highest risk for an SSO

Operations & Maintenance  O&M and Sewer System Replacement Funding – Include budgets for routine system O&M including the CIP and proposed replacement of assets over time due to normal aging – Demonstrate the ability to properly fund the sewer system in perpetuity

Design & Performance Provisions  Essentially the same as the existing Order  Enrollee must adopt and implement sewer design, construction, inspection and testing standards and specifications

Overflow Emergency Response Plan  In addition to current requirements the OERP must include steps needed to prepare for natural disasters and severe weather events  Risk and Threat Analysis to be conducted to identify highest risks and threats posed by a sewer system failure  Analysis shall include the expected consequences of each identified failure

FOG Control Program  Requirements are basically the same as in the current Order  Must identify staffing levels required to inspect and enforce the FOG Ordinance

System Evaluation & Capacity Assurance Plan  Remains basically the same as in the current Order  Must include budget information that demonstrates the ability to properly fund sewer system capital improvements

Performance Targets & Program Modifications  Section extensively rewritten & name changed from Monitoring, Measurement & Program Modification  Must develop performance targets & implement program modification to reduce SSOs  Collect & maintain data to establish & prioritize performance targets

Performance Targets & Program Modifications  Link performance targets to appropriate SSMP elements  Maintain an SSMP change log that records changes made to the SSMP including date and staff responsible for implementing each change

SSMP Program Audits  Audit must be performed every two years and attached to the SSMP  Audit will include an narrative of each SSMP element and the progress the Enrollee has made in attaining performance targets  Deficiencies shall be identified and the corrective action taken or planned

Communications Program  Communication with the public at least annually on the performance of SSMP  Communication at least annually with any satellite system that contributes to the Enrollee’s system  Document communications activities and include in the SSMP

SSMP Certification  SSMP must be certified to the Online SSO Database every two years  SSMP must be approved at a public meeting by the Enrollee’s governing body when major changes occur or at least every four years  SSMP must be posted on the Enrollee’s website or electronically submitted to the Online SSO Database with each re- certification

Monitoring and Reporting Program

Monitoring & Reporting  For sewage discharges that reach or may reach surface waters of the state directly or by drainage channel or storm drain:  Enrollee must notify Cal EMA within two hours of: – Having knowledge of the discharge – Notification is possible – Notification can be accomplished without substantially impeding cleanup or emergency activities

Monitoring & Reporting  Reporting to be event based as opposed to appearance based  Online report forms & the annual questionnaire have been revised  GPS coordinates will be used instead of street addresses for Category I & II except PLSDs

Monitoring & Reporting  Mandatory reporting of PLSDs as the Enrollee becomes aware of them  PLSDs are reported as Category I or II with the same guidelines as Enrollee’s discharges  Category I spills include any volume of wastewater that enters the storm drain system that is not fully recovered unless it discharges to a infiltration or percolation pond

Monitoring & Reporting  Time frames for report are unchanged  If the Enrollee reports a PLSD but no SSOs from the Enrollee’s system a no spill certification for that month must still be made  The records keeping requirement has been rewritten

What’s Next?  Written comment period ended in May 2011 – Comments will be collected and reviewed by SWRCB Staff for presentation to the Board  Public workshop TBA sometime in June or July  Adoption could occur in August

Questions But Don’t Shoot The Messenger!