Regulatory / WDR Update What’s Going On?

Waste Discharge Requirements Adapted by the State Water Resources Control Board on May 2, 2006 Adapted by the State Water Resources Control Board on May 2, 2006 Implementation based on population Implementation based on population Complete implementation by August 2010 Complete implementation by August 2010 WDRs do not sunset WDRs do not sunset Triennial Review process Triennial Review process Stakeholder involvement encouraged Stakeholder involvement encouraged

SSO Users Group Public comment meetings 2009 Public comment meetings 2009 Southern California Southern California Northern California Northern California Order Review Committee Order Review Committee Review SSMP Elements Review SSMP Elements Review reporting requirements Review reporting requirements Mantis List Mantis List Data Review Committee Data Review Committee

Mantis List Update

Data Review Committee 1. Refine the CIWQS SSO spill report form data fields 2. Re-design the SSO spill report form to be event not location based 3. What indices of Collection System performance should be used to compare collection systems in California?

Performance Indices Current index Current index # spills per 100 miles of pipe per year # spills per 100 miles of pipe per year Under 3 – Over 6 Under 3 – Over 6 Prospective Indices 1. Number of Spills (or Volume of Spills) per 100 miles of pipeline. 2. Number of Spills (or Volume of Spills) per capita.

Performance Indices 3. Number of Category 1 spills (or Volume of Spills); number of Category 2 spills (or Volume of Spills). 4. Number of Spills (or Volume of Spills) by pipe diameter or pipe area. 5. Number of Spills (or Volume of Spills) by volume class of spill.

Performance Indices 6. Separate out number of spills (or Volume of Spills) by portion of collection system pump station, force main, gravity, lateral. 7. Separate out spills (or Volume of Spills) caused by outside contractors. 8. Number of Spills (or Volume of Spills) by cause category (fog, roots, debris, etc.).

Performance Indices 9. Gallons Conveyed versus Gallons Spilled versus Gallons Recovered versus Gallons Reach Surface water. 10. Volume of Spills per Year by Total Volume Conveyed (measured or estimated based upon population served).

Miscellaneous Data shows that smaller pipes have more frequent SSOs Data shows that smaller pipes have more frequent SSOs Smaller systems tend to have more SSOs per mile than larger systems Smaller systems tend to have more SSOs per mile than larger systems Roots tend to be the primary source of SSOs statewide Roots tend to be the primary source of SSOs statewide A new reporting category (3) may be developed for very small SSOs. A new reporting category (3) may be developed for very small SSOs.

Additional Information Google Groups Google Groups SSO Data Review Committee SSO Data Review Committee Non committee members can review all posted data Non committee members can review all posted data Non committee members can not post to the group Non committee members can not post to the group

Opening the WDR

Draft of new Order scheduled for public release in late July or August 2010 Draft of new Order scheduled for public release in late July or August 2010 Public comment period Public comment period Presentation to SWRCB for adoption in November 2010 – Public hearing Presentation to SWRCB for adoption in November 2010 – Public hearing Adoption by SWRCB in December 2010 Adoption by SWRCB in December 2010 Anticipated that most changes will be administrative Anticipated that most changes will be administrative MRP changes and notification streamlined MRP changes and notification streamlined

AUDITS X 2

Audits - State SWRCB intends on conducting at least 2 audits per Region SWRCB intends on conducting at least 2 audits per Region Audits will be conducted in conjunction with Regional staff Audits will be conducted in conjunction with Regional staff Audits may be random or selected based upon reporting history Audits may be random or selected based upon reporting history Zero spills as likely as numerous spills Zero spills as likely as numerous spills EPA Region 9 online audit files EPA Region 9 online audit files Regions may conduct additional audits Regions may conduct additional audits Some Regions already conducting enforcement Some Regions already conducting enforcement

SSMP Audit Requirements The SSMP requires that each agency conduct an audit every two years based upon the date that the final SSMP was approved The SSMP requires that each agency conduct an audit every two years based upon the date that the final SSMP was approved Audits must remain on file and be available to the State or Regional Boards upon request Audits must remain on file and be available to the State or Regional Boards upon request Audits are performance based and should reflect all elements of the SSMP Audits are performance based and should reflect all elements of the SSMP

3 Key SSMP Elements - Audits SSMP is an asset management program Goals Goals Monitoring, Measurement, and Program Modifications Monitoring, Measurement, and Program Modifications SSMP Program Audits SSMP Program Audits

Goals Specific Specific Attainable Attainable Measurable Measurable Prioritized Prioritized Modify as needed Modify as needed Add or delete goals as needed Add or delete goals as needed

Goals - Example 1. Eliminate all SSOs including those caused by roots 2. By (date) identify all root prone areas in the system; develop a remediation strategy; review the effectiveness of the root remediation program and its effect on SSOs

Monitoring, Measurement, and Program Modifications Ongoing evaluation of SSOs Ongoing evaluation of SSOs Cause, response, frequency, category, damage Cause, response, frequency, category, damage Ongoing evaluation of maintenance practices and inspections Ongoing evaluation of maintenance practices and inspections Ongoing effectiveness of FOG, root or other special programs Ongoing effectiveness of FOG, root or other special programs Revenue and expense Revenue and expense

SSMP Program Audits Formal written audit due every two years based upon the date that original SSMP was approved Formal written audit due every two years based upon the date that original SSMP was approved Performance oriented Performance oriented Pertains to all elements of the SSMP Pertains to all elements of the SSMP Document any changes to the SSMP since last audit Document any changes to the SSMP since last audit Maintain on file Maintain on file

Questions / Discussion