1. SITE LOCATION AND DESIGN APPROVAL FOR DOMESTIC WASTEWATER TREATMENT WORKS
David Kurz, P.E.
Lead Wastewater Engineer
Water Quality Control Division
January 17, 2014

2. Objectives Provide information to facilitate:
A better, general understanding of Regulation 22.
More efficient interactions between Domestic WWTW owners, their engineers, and the WQCD on Regulation 22

3. Presentation Format Overview of General Process
Not a detailed review of Regulation 22 or Design Criteria
Specifics are included in those documents
Clarifications of common misunderstandings

4. REFERENCE DOCUMENTS
Colorado Water Quality Control Act (Title 25, Article 8, C.R.S.)
Regulation No. 22 (Site Application/Design Review) and others listed in Regulation 43.4(A)(1)(b)
Policies
Regulation 22 Guidance Document (August 2010)
Policy 6 (WQSA-6 Multiple OWTS)
Wastewater Design Criteria

5. Authority and Requirements
Water Quality Control Act,
“No person shall commence the construction of any domestic wastewater treatment works or the enlargement of the capacity of an existing domestic wastewater treatment works, unless the site location and the design for the construction or expansion have been approved by the division.” [emphasis added]
Fees set in statute [ (b.7)] – effective July 1, 2007

6. Domestic Wastewater Treatment Works (DWWTW)
Facility with capacity 2,000 gpd or more
Includes pumping stations and interceptor sewers
Does not include industrial wastewater treatment plants

7. Structure of Regulation 22
Key Components
Definitions (22.2)
Core Requirements (22.3 through 22.10)
Section 22.3 – Policy considerations
Project Specific Sections (22.4 through 22.8)
WWTF requirements in 22.4, 22.5, or 22.8, as applicable to situation
Pilot Study in 22.8
Section Factors
Section – In-Kind Replacement
Design Review Process (22.11)
Basis and Purpose (Starting at 22.12)
Regulation 22 Guidance Document provides explanations
My background

8. Evaluate Suitability of Proposed Site [25-8-702(2) C.R.S.]
Local review
Consider local long-range comprehensive plan and any approved water quality management plan for the area
Confirm DWWTW can be managed to minimize potential adverse impact on water quality
Encourage consolidation where feasible

9. Preliminary Effluent Limitations (PELs)
Current PELs required:
New WWTF and WWTF with capacity changes.
Other WWTF modifications may require PELs.
Obtain PELs before Site Location Application (incomplete without)
PELs developed in the Permits Section of WQCD.
Fee is required.
Need capacity & discharge point
Impacted by changes in:
water quality standards
stream flows and ambient water quality
18 month “shelf life”

10. Site Location Application Process
Local approval
PELs from Permit Section
Submit fee, Site Location Application, and Engineering Report
Assigned to Reviewer
Comment and Response Letters as needed
Approval

11. Notes re: SA Process Local Review / Completeness
Emphasis on local review and public notification processes
WQCD is not the only agency involved in review
Owner must submit SA local authorities and 208 planning agency (if one exists).
These agencies may have other requirements and time lines that may impact timing of SA processing.
WQCD cannot take action on a site location application until the local review process is completed
The Division review begins after receiving fee and complete submittal (e.g., Emergency Operations Plan in §22.4(1)(b)(xiv) to demonstrate owner’s ability to operate and maintain).

12. Items of Note re: SA Review and Approval
Site Location Application Review and Approval
Systems evaluated for other water quality requirements
Informs the CDPS permit writing (evaluation of proposed treatment, changes to PELs/permit limits, capacity, etc.)
Division does not issue concurrent site location and design approvals or verbal approvals. All approvals are issued in writing on CDPHE letterhead.
Site Location Approvals good for 18 months to start construction. Site Location Approval is NOT approval for construction. Design approval is required prior to commencement of construction.

13. The Design Review Process
Submit fee and Design Report
Two step process for WWTF (new, expansions, modifications)
Process Design Report (Division approval)
Final Design (Design Engineer approval if streamlined as in section 22.11)
Assigned to Reviewer
Comment and Response Letters as needed
Approval

14. ‘Streamlined Final Design Approval’
Available ‘streamlined design review’ process for WWTFs. Allows ‘certification’ for approval of final design (plans and specifications) as long as specific requirements are met.
SA and PDR approvals still required.
Specific requirements in section

15. Items of Note re: Design Review Process
Small systems with groundwater discharge have closely coordinated SA, design review, and permit development. Design must be consistent with site location approval (organic & hydraulic capacities, SA conditions, etc.).
Ensure that all submittals fully address design criteria requirements. Wastewater Design Criteria (Policy WPC-DR-1) has specific requirements for content of Process Design Report and final design.
DORA requirements for P.E. signing and stamping engineering reports and drawings must be met. This includes technical documentation and drawings submitted in response to issues letters.

16. Notes to Speed Review SA and Design Review Submittals
Contact Engineering Section Unit Manager to discuss project and clarify information before and after submittals are made.
If the Division sends RFI letter regarding a SA or DR submittal, the sooner that the (adequate) response is received, the sooner that the review work can resume and move toward approval.
Possible Alternative Technology? Don’t wait until the SA or design submittal. Contact WQCD to discuss. Design approval is still required for each site.

17. Common Process Pitfalls
Not providing all necessary documentation
Incompatible SA and DR capacity
Alternative Technology
Unsubstantiated data
Planning Values
Non-peer reviewed references
Computer model input/output
Compliance Points (flow, samples)

18. Available Resources Regulation 22 Regulation 22 Guidance Document
Format Follows Regulation 22
Explains Interpretations
Sets expectations for fulfilling requirements
Engineering Section Unit Managers
North = Douglas Camrud
South = Amy Zimmerman

19. Effective Use of Resources
Entities and Consultants May:
overlook or not foresee regulatory pitfalls
misinterpret regulations
not understand full implications of process
Open communication with Division
Discuss issues with Unit Manager/Review Engineer
Set a clear pathway through the regulatory maze
Get regulatory interpretations
Find best and creative ways to work within regulations

20. Questions?

21. Reference Links (Note: Website may be changing …again.)
Site Application Forms: Use the link in “Services” box for Facility Design and Approval, then left bar or bottom of the page select Domestic Wastewater Facility Approval page, and the forms are provided under the ribbon for Domestic Wastewater Design Submittal Forms.
Regulation 22: Use the link in the top navigation bar to “Boards/Commissions”, Water Quality Control Commission, lower middle box select Current Commission Regulations, Regulation 22
Policies: Use the link in “Services” box for Facility Design and Approval, then left bar or bottom of the page select Domestic Wastewater Facility Approval page, and the policies are provided under the ribbon for Domestic Wastewater Design Policies.