How To Write A Water Board Water Management Plan
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1 Sanitary Sewer Overflow (SSO) Reduction Program Revised Sanitary Sewer System Waste Discharge Requirements State Water Resources Control Board 1001 I Street, Sacramento, CA
2 Overview Proposed Revisions to the Sanitary Sewer System WDRs 1. SSS WDR Timeline 8. Compliance Schedules 2. Findings 9. Spill Notification 3. Regulatory Considerations 4. Definitions 5. Application Requirements 6. Prohibitions & Provisions 10. Private Lateral Sewage Discharge (PLSD) Reporting 11. SSO Reporting 12. Record Keeping 7. Sewer System Management Plan (SSMP) Requirements 2
3 SSS WDR Timeline Sanitary Sewer Systems WDR Adopted Review Process Begins Written Comment Request for SSS WDR Draft Reporting Required Regions 4,8, and 9 Reporting Required Regions 1,2, and 3 Reporting Required Regions 5,6, and 7 Comment Letters Requested Two Public Workshops Written Comments Due May 13, 2011 Expected Public Workshop & Adoption May-06 Jun-06 Aug-06 Oct-06 Dec-06 Feb-07 Apr-07 Jun-07 Aug-07 Oct-07 Dec-07 Feb-08 Apr-08 Jun-08 Aug-08 Oct-08 Dec-08 Feb-09 Apr-09 Jun-09 Aug-09 Oct-09 Dec-09 Feb-10 Apr-10 Jun-10 Aug-10 Oct-10 Dec-10 Feb-11 Apr-11 Jun-11 Aug-11 Oct-11 Dec-11 Jan-12 Mar-12 May-12 Jul-12 Sep-12 Nov-12 Compliance Reminders Sent SSMP Deadline for all Enrollees All publicly owned Collection Systems Enroll for Coverage 120 NOVs Sent 3
4 Findings Changes to Items #1-16: Applicability criteria Items # 3, discussed under application requirements Clarification of how to enroll multiple collection systems under one agency Items # 4, discussed under application requirements Clarification regarding reporting and management from systems of pipe not meeting applicability criteria Items # 5, under application requirements Clarification regarding coverage of combined sanitary sewer systems Item # 6, these are not covered under the SSS WDR, spill reporting per NPDES permit requirements Clarification to Item#14 Develop and implement an SSMP for each CS enrolled Other minor changes to SSS WDR text 4
5 Regulatory Considerations Changes to Items #17-29: Removed reference to ground waters, Item #21 Added references to applicable/relevant Water Code and Health and Safety Code Sections, Item #23 Reference to the Monitoring and Reporting Program portion of the WDR added Other minor changes to SSS WDR text 5
6 Definitions added for: Definitions Data Submitter Combined Sanitary Sewer Systems Drainage channel Enrollee Lateral Legally Responsible Official Private lateral Private Lateral Sewage Discharge Spill Storm Drain Untreated or partially treated wastewater Surface waters of the state 6
7 Definitions (continued) Definitions clarified for: Sanitary Sewer Overflow Clarified these are only spills upstream of the treatment plant head-works Sanitary sewer system Added reference to private sewer systems Satellite sanitary sewer system Clarified the definition 7
8 Questions? 8
9 Application Requirements Proposed WDR Applies to (B.1): Private and public sanitary sewer systems Sanitary sewer systems with over one mile of pipe and with a peak flow over 25,000 gallons per day To establish flow, can use either measured peak daily flow or calculated peak daily flow (e.g., number of EDUs x Flow per EDUs x Peaking Factor) All enrolled and potential enrollees will be required to submit a new Notice of Intent (NOI) or Notice of Non-Applicability (NON) 9
10 Application Requirements (continued) Enrollment of multiple sanitary sewer systems by an agency (B.2) Enrollees who own multiple sanitary sewer systems meeting the applicability criteria and that are not physically connected are required to enroll each distinct sanitary sewer system separately under the SSS WDRs If they are managed as distinct assets in the form of separate sanitation districts, Under separate operations and maintenance and/or capital improvement budgets, and/or Managed as distinct and separate sanitary sewer systems. 10
11 Application Requirements (continued) If an enrollee owns at least one sanitary sewer system meeting the applicability criteria (B.3): Any sanitary sewer systems with connected systems of pipes less than one mile in contiguous length not physically connected to the enrolled sanitary sewer system, Enrollee is required report spills from those sanitary sewer systems under one mile in contiguous length, and Manage them under a Sewer System Management Plan. 11
12 Prohibitions Changed prohibition from waters of the U.S. to surface water of the State, Discharges to storm drains that are not fully captured are prohibited Fully recovered discharges are not prohibited (still need to report them) Discharges to drainage channels if the drainage channel is a surface water of the state or tributary to a surface water of the state. Prohibition against creating a nuisance is unchanged, Prohibition of discharge of chlorine, or any other toxic substance used for disinfection and cleanup of wastewater spills to any surface water body. This prohibition applies to the chlorine residual in the potable water used for wash down and clean-up of wastewater spills. 12
13 Provisions PLSD reporting proposed to be mandatory when the enrollee becomes aware of the spill (D.4) Professional evaluation and judgments shall be provided by a professional engineer registered in California for the SSMP, At a minimum, for the System Evaluation and Capacity Assurance Plan (D.11) If the Enrollee believes that any element of the SSMP is not appropriate or applicable Shall still address each element listed below in its SSMP and justify why that element is not applicable. Other minor changes to SSS WDR text 13
14 Questions? 14
15 Organization SSMP Requirements Specify contact information for governing board members, LROs and DSs (D.b.ii) Specify the website address where the SSMP can be accessed, if applicable (D.b.iv) Legal Authority Ensures access to all enrollee owned pipe (D.c.iii) Authority for enrollee to limit flows to the system and ban new connections (D.c.iv and v) Specify which portion of the lateral the enrollee owns (D.c) 15
16 SSMP Requirements (continued) Operations and Maintenance Program Clarified requirements for mapping (D.d.i) A map illustrating up-to-date Sewer System to be included in SSMP Identify contractors working on the sewer system (D.d.ii) Private sewer lateral inspection and replacement programs being implemented be specified in the SSMP (D.d.iii) Staff training and assessment (D.d.iv) Contingency planning based on risk and threat of SSOs (D.d.v) O&M and sewer system replacement funding budgets (D.d.vi) 16
17 SSMP Requirements (continued) Design and Performance Provisions Enrollees shall adopt and implement standards and specifications for sewer design, construction, inspection, and testing (D.e) Overflow Emergency Response Plan Planning for natural disasters, hazardous weather events, and other severe circumstances that will affect sewer system operation (D.f.ii) SSMP addresses a Risk and Threat analysis (D.f.vi) FOG Control Program Legal authority to require dischargers to implement measures to prevent FOG blockages (D.g) System Evaluation and Capacity Assurance Plan Budget for capital improvements be addressed in the SSMP (D.h.v) 17
18 SSMP Requirements (continued) Performance Targets and Program Modifications Clarified that SSMP should address developed performance targets (D.i) Include a change log including a list of all modifications and changes made to the SSMP (D.i.vi) SSMP Program Audits Changed 5 year re-certification requirement to a 4 year re-certification requirement (requires approval by governing board) (D.j) Communication Program Enrollee should communicate with satellite sewer systems on an annual basis, at a minimum (D.k) Other minor changes to SSS WDR text Make SSMP Publicly available or upload into CIWQS database SSMP internal audit every two years with recertification of the SSMP and approval by governing board every 4 years (D.13) 18
19 Compliance Schedules Current enrollees of Order No DWQ Enroll 6 months after adoption SSMP have until next full bi-annual audit to add new/enhanced SSMP elements New Enrollees Meeting the Enrollment Criteria Enroll 6 months after adoption Complete SSMP months after enrollment depending on size of collection system Expanding or New Collection Systems (after adoption) Apply for coverage three (3) months prior to operation of facilities Complete SSMP months after enrollment depending on size of collection system Public Sanitary Sewer Systems that Never Enrolled Should have enrolled under No DWQ but never did Enroll on adoption or as soon as practicable State Water Board to approve SSMP Development Schedule Provide historic spill data back to when enrollment was required 19
20 Other minor changes to SSS WDR Change of ownership (H.2) Notify State Water Board staff In addition, Identify Historic spills that occurred in the transferred portion(s) Report Declaration Clarification (J.2) Enrollees may designate multiple LROs and DSs for the purposes of reporting for the SSS WDRs Minor changes in sections E, F, G, I, K, and L 20
21 Questions? 21
22 Monitoring and Reporting Program (MRP) Changes Spill Notification Private Lateral Sewage Discharge (PLSD) Reporting SSO Reporting Record Keeping 22
23 Spill Notification NOTIFICATION: ONLY REQUIRED FOR CAT 1 SSO Reaching Surface Water 2hrs after aware: Notifies California Emergency Management Agency (CalEMA), formerly OES. 23
24 PLSD Reporting Mandatory Reporting of PLSDs PLSD - discharges of wastewater resulting from a failure in a privately owned sanitary sewer system asset, When become aware Report within 30 Calendar days after end of calendar month in which PLSD occurred, Enrollee not responsible for the cause, clean-up, or lateral repair, Enrollee encouraged to notify CalEMA when applicable, or advise the discharger to do so, PLSDs still do not count towards No-spill Certifications You can file a no-spill certification even if you had one or more PLSDs 24
25 Spill Reporting Streamline Spill Reporting Category 1 and 2 SSO Mandatory information: Actual or estimated SSO start date and time SSO Failure Point (main, lateral, etc.) Category 1 SSO Mandatory information: Identification of method(s) used for volume estimates, Name surface waters impacted (if applicable) PLSD information to be included: The address, or most accurate location information known (e.g., GPS Coordinates), of where the PLSD occurred; 25
26 Record Keeping Photographic records of each SSO event A printed or electronic record of each SSO initial draft report A printed record of certified SSO report, plus any amended and re-certified report(s); Records of all incoming SSO and/or PLSD complaints Field crew records to document SSO response activities Steps that have been and will be taken to prevent SSOs from recurring, Records of inspections, maintenance, operations, repairs, and funding of assets, and Records of implementation all the elements of the SSMP. 26
27 Proposed Revisions NOT Included in Draft SSS WDR Re-adopting as a NPDES permit or NPDES/WDR hybrid permit Require certification of sanitary sewer system operators Establish a De-minimis spill volume for which reporting not required 27
28 Questions? 28
29 Program Contacts & Info Russell Norman, P.E. SSO Program Lead State Water Resources Control Board (916) Victor Lopez, E.I.T SSO Program Lead State Water Resources Control Board (916) SSO Main Website: List Serve Sign-Up: cb_subscribe.shtml 29
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