Transcript Document

“You, Me and the SSO GWDR”
(Order No. 2006-0003-DWQ)
James Fischer, P.E.
Water Resource Control Engineer
Division of Water Quality
State Water Resources Control Board, Sacramento
CWEA NTC 2008: Statewide SSO General Order
Slide 1
Overview
1. Background on Statewide SSO General
Waste Discharge Requirements
(GWDR) Permit
2. Current Program Status
3. Outreach and Training
4. Common Questions and Answers
5. Program Issues
CWEA NTC 2008: Statewide SSO General Order
Slide 2
Background on SSO GWDR
• 2004: State Water Resources Control Board passed a
Resolution to reduce number and volumes of SSOs
• Provides streamlined approach to permitting collection systems
compared with numerous Regional Water Board permits
• GWDR modeled after USEPA Capacity, Management,
Operations and Maintenance (CMOM) Program
• GWDR adopted May 2, 2006 to address SSOs in
consistent/uniform manner throughout the state
• First comprehensive regulatory program in the nation to
comprehensively address sanitary sewer systems (both for
reporting spills and collection system management)
CWEA NTC 2008: Statewide SSO General Order
Slide 3
Background on SSO GWDR
• Applicability: Requires any publicly-owned agency
with a collection system (sewer pipes) greater than
one mile in length and connected to publicy-owned
treatment facility (regardless of treatment technology)
to enroll for coverage
• Collection systems must be individually enrolled
regardless of number owned
CWEA NTC 2008: Statewide SSO General Order
Slide 4
Background on SSO GWDR
• Notice of Intent (NOI) initially mailed out to “potential enrollees” on
June 16, 2006
• Application for Coverage was required by all applicable collection
systems by November 2, 2006
• 1,100 Collection Systems Currently Enrolled (Sept 2008)
– Represents over 840 collection system local agencies
– Notice of Non-Applicability filed by several dozen agencies
– Website:
www.swrcb.ca.gov/water_issues/programs/sanitary_sewer_overflow/
– Type “Sanitary Sewer Overflow” in State Board “search” box
CWEA NTC 2008: Statewide SSO General Order
Slide 5
SSO GWDR Website
CWEA NTC 2008: Statewide SSO General Order
Slide 6
GWDR Permit Requirements
CWEA NTC 2008: Statewide SSO General Order
Slide 7
GWDR Permit Requirements:
Enrollment and NOI
• State Board Staff Primary: DWQ/WDR Unit
• Regional Boards (RBs): Secondary: perform followup only on “as-needed” basis
– Combined efforts successfully obtained NOI
responses from 98% of all known “potential
enrollees”
– Outstanding agencies must either enroll or request
and complete a “Notice of Non-Applicability” for
coverage and send to State Board
CWEA NTC 2008: Statewide SSO General Order
Slide 8
GWDR Permit Requirements:
Reporting Schedule
• Enrollees required to begin reporting SSOs
via CIWQS according to following schedule:
– Regions 4, 8, 9 January 2, 2007
– Regions 1, 2, 3 May 2, 2007
– Regions 5, 6, 7 September 2, 2007
CWEA NTC 2008: Statewide SSO General Order
Slide 9
GWDR Permit Requirements:
Misc.
1. Enrollment / establishment of Legally Responsible Official (LRO)
2. Maintain compliance with SSO MRP (2/20/2008 version)
3. Complete mandatory Collection System Questionnaire (must be completed
within 30 days of enrollment & updated annually or no SSOs may be reported)
3. Must electronically report any SSO or do a monthly “No-Spill” Certification” if
no SSOs for any individual calendar month
4. Develop and Implement Sewer System Management Plan (SSMP):
- Ensures proper management, operation and maintenance
- Supports State’s WDR regulatory goals
- Provides State with ability to compare SSO reports with adopted SSMP
elements to measure effectiveness of individual local agency collection
system operations, maintenance and management practices
CWEA NTC 2008: Statewide SSO General Order
Slide 10
GWDR Permit Requirements:
Notification/Reporting
Category 1 SSO: ANY volume:
1) Reached a surface water; or
2) Entered storm drain pipe and not fully captured/returned to sewer; or
3) >1,000 gallons
Category 2 SSO: any other SSO not meeting definition for Category 1
NOTIFICATION
Category 1 SSO: 2hrs to notify OES, local health, and Regional Water Board of SSO;
24hrs to certify to Regional Board that OES/local health were notified
Category 2 SSO: none
REPORTING (CIWQS)
Category 1 SSO: 3 days to “Submit Draft” and 15 days to “Certify”
Category 2 SSO: 30 days to “Certify”
CWEA NTC 2008: Statewide SSO General Order
Slide 11
GWDR Permit Requirements:
SSMP Required Elements
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.
x.
xi.
xii.
Plan and Schedule (requires local gov. board ok)
Organization
Legal Authority
Operation and Maintenance
Design and Performance
Overflow Emergency Response
Fats, Oils and Grease (FOG)
Systems Evaluation and Capacity Assurance
Monitoring, Measurement and Program Mods.
SSMP Audits
Communication Program
Final Certification (requires local gov. board ok)
CWEA NTC 2008: Statewide SSO General Order
Slide 12
GWDR Permit Requirements:
SSMP Requirements
• Enrollee “self approves” all SSMP Task
Elements and Certifies in CIWQS online
when each element is completed
– Element schedule on SSO Website
– All SSMPs will be fully implemented by
August 2, 2010
• Regional Boards can review SSMPs upon
request (approval is not required)
CWEA NTC 2008: Statewide SSO General Order
Slide 13
Current Program Status
CWEA NTC 2008: Statewide SSO General Order
Slide 14
SSO “Non-Responsive Agency Trend
CWEA NTC 2008: Statewide SSO General Order
Slide 15
SSO GWDR Enrollment Trend
CWEA NTC 2008: Statewide SSO General Order
Slide 16
Statewide Reporting
Compliance
SSO Statewide Reporting Compliance (%)
80
70
60
50
40
30
20
10
0
Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- May- Jun07 07 07 07 08 08 08 08 08 08
Series1
Sep-07
Oct-07
Nov-07
Dec-07
Jan-08
Feb-08
Mar-08
Apr-08
May-08
Jun-08
62
61
60
60
59
56
65
68
68
74
CWEA NTC 2008: Statewide SSO General Order
Slide 17
Collection System
Questionnaire Compliance
Collection System Questionnaire Compliance (%)
81%
100%
50%
0%
Series1
19%
Not Completed
Total Statewide
19%
81%
CWEA NTC 2008: Statewide SSO General Order
Slide 18
CIWQS SSO Report Statistics
Jan 2007 to Sept 2008 (7,265 Certified SSO Reports)
40,000,000
30,000,000
20,000,000
10,000,000
0
Series1
Total Vol of
SSOs (gal)
Total Vol Reach
Surface Water
Total Vol
Recover (gal)
33,056,093
25,137,471
11,996,711
CWEA NTC 2008: Statewide SSO General Order
Slide 19
Common Questions and Answers
CWEA NTC 2008: Statewide SSO General Order
Slide 20
Common Questions
• What if my agency has a collection system(s)
that meets the minimum GWDR requirements and
has still not applied for coverage under the SSO
General Order?
• What if my agency has not yet “Certified” any of
the required SSMP task elements?
• What if my agency has missed “No Spill
Certifications” for any months without any SSOs?
CWEA NTC 2008: Statewide SSO General Order
Slide 21
Answers
To avoid enforcement action, your agency must:
• Enroll any applicable collection systems(s) for
coverage under SSO GWDR
• Update all records in CIWQS, including any
information back to the date when mandatory
reporting was required within your Region (see
website for details)
CWEA NTC 2008: Statewide SSO General Order
Slide 22
Outreach and Training Resources
CWEA NTC 2008: Statewide SSO General Order
Slide 23
Outreach
• Blanket and Direct emails (using email addresses
pulled from our CIWQS system)
– Non-Compliance with Reporting Requirements
– Communicate other pertinent program information
• SSO Website to be redesigned and will soon host
more data, including all Enrollee compliance status
• State Board continues to coordinate outreach with
CWEA / CVCWA / BCWA and other trade
organizations
CWEA NTC 2008: Statewide SSO General Order
Slide 24
Outreach
CIWQS SSO External User Group
– Represents 40+ Enrollees (large and small
collection systems)
– Extensive tracking of all technical
CIWQS/SSO Program-related issues
– Regular testing, review and comment on
CIWQS changes prior to production roll-out
– Quarterly meetings (participation also
available via conference call and WEBEX)
– Email us if interested in participating
([email protected])
CWEA NTC 2008: Statewide SSO General Order
Slide 25
Training Resources
• CWEA has MOA with State Water Board
– SSO Program training classes and outreach
• CVCWA, CRWA and others conducting extensive
training on SSO GWDR throughout California
• Regional Board staff being trained internally on
GWDR and attending some statewide training
classes
• CWEA Training Calendar:
www.cwea.org/calendar.shtml
CWEA NTC 2008: Statewide SSO General Order
Slide 26
SSO Discharger User Guide
• Available on CIWQS (SSO) website
www.waterboards.ca.gov/water_issues/programs/ciwqs/chc_sso.shtml
CWEA NTC 2008: Statewide SSO General Order
Slide 27
CWEA MOA/Training
CWEA NTC 2008: Statewide SSO General Order
Slide 28
Current SSO Program Issues
CWEA NTC 2008: Statewide SSO General Order
Slide 29
Current SSO Program Issues
• CIWQS Reporting Compliance ~ 74%
• CIWQS Questionnaire Compliance ~ 81%
• CIWQS SSMP Certification Elements Input ~ 50%
• MRP (2/20/08 version) is inconsistent with Water
Code and some GWDR Requirements
– Q&A under development
– Program review 2009 will address inconsistencies
CWEA NTC 2008: Statewide SSO General Order
Slide 30
Current SSO Program Issues
• SSO Program Review
– Begins in May 2009
– Board will consider “re-opening” GWDR
– Will include extensive public outreach
including workshops around the state
– Industry encouraged to participate, attend
workshops and provide input
CWEA NTC 2008: Statewide SSO General Order
Slide 31
Beta (draft) SSO Mapping Tool
• Presents all individual SSO and Private
Lateral Sewage Discharge data in CIWQS
reported to date in a map format
• Serves as an SSO data Q/A & Q/C tool
• Dischargers have been given the opportunity
to review and correct any data errors before
public posting in November 2008
CWEA NTC 2008: Statewide SSO General Order
Slide 32
Beta (draft) SSO Mapping Tool
CWEA NTC 2008: Statewide SSO General Order
Slide 33
Program Contacts
• Usernames/Passwords/Registration/Data Issues:
CIWQS HELP CENTER
1-866-792-4977 (M-F, 8am-5pm)
[email protected]
• SSO Program Technical Assistance:
James Fischer, P.E.
Program Lead / Statewide SSO Program
916-341-5548
[email protected]
CWEA NTC 2008: Statewide SSO General Order
Slide 34