Transcript -Proposed Revisions- STATEWIDE GENERAL WASTE …

-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 reenroll
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, email
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 recertification
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!