Statewide General Waste Discharge Requirements for

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Transcript Statewide General Waste Discharge Requirements for

Statewide General Waste
Discharge Requirements
for
Sanitary Sewer Systems
Presentation to [fill in]
[Date]
BACWA
1
Disclaimers
 We
did not write the WDR!
 This is an overview only – though lengthy
at that!

CWEA will be offering much more
comprehensive training for the wastewater
community
www.cwea.org/sso
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Presentation Outline
1.
2.
3.
History
Purpose of the WDR
The Basic Requirements of the WDR
•
•
•
Application
On-line reporting of Sewer System Overflows
Development of a Sewer System Management
Plan
www.cwea.org/sso
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History
 State
Water Resources Control Board
(SWRCB) Resolution 2004-80

Required staff to develop work with
stakeholders to develop a regulatory program
that would provide a consistent approach to
reducing Sewer System Overflows (SSOs)
 SSO

Guidance Committee formed
Committee included SWRCB Staff, Industry
Representatives and NGOs
www.cwea.org/sso
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History
(continued)

Committee developed a draft Waste Discharge
Requirement (WDR)


Applies to entities that own or operate collection
systems greater than one-mile in length
Basic Requirements



All public operated sewer collection systems must
apply for coverage under the WDR
All covered collection systems must begin on-line
reporting of SSOs.
All covered collection systems must develop a Sewer
System Management Plan
www.cwea.org/sso
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History
(continued)

First public hearing held February 8


Comment period extended two weeks by SWRCB to
receive additional information from attendees
Second public hearing held May 2, 2006


Final WDR adopted on May 2, 2006
Granted extension to original compliance schedules
contingent upon CWEA/industry and SWRCB
entering into an Memorandum of Agreement for
training
www.cwea.org/sso
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Purpose of WDR

Proactive approach to ensure system wide
operation, maintenance and management plans
to reduce SSOs


Concept is that many SSOs are preventable
Allows SWRCB to gather consistent data on
causes and sources of SSOs

Intents is to provide SWRCB with better
understanding of the issue
www.cwea.org/sso
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Caution!
 Key
issue unresolved: Potential conflicts
between Regional Board and SWRCB
requirements



Letter of commitment to resolve potential
conflicts was received from State Board
Allows Regional Boards to be more stringent
Unclear as to implementation issues, such as
schedule for reporting, etc.
www.cwea.org/sso
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Basic Definitions
 Sanitary



Sewer Overflow (SSO)
Releases of untreated or partially treated
wastewater to waters of the United States
Releases of untreated or partially treated
wastewater that do not reach waters of the
United States
Wastewater backups into buildings and on
private property that are caused by blockages
in the publicly owned portion of the sanitary
sewer system
www.cwea.org/sso
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Basic Definitions
(continued)
 SSO

Reporting System
On-line spill reporting system hosted,
controlled and maintained by the SWRCB
 Untreated

or partially treated wastewater
ANY volume of waste discharged from the
sanitary sewer collection system upstream of
a wastewater treatment plant
www.cwea.org/sso
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SSO Categories
 Category



Exceeds 1,000 gallons, or
Results in discharge to surface waters, or
Discharge to storm drain and not captured
 Category

2
All other discharges from Enrollee’s sewer
system
 Private

1
Lateral Sewage Discharge
Discharges caused by privately owned lateral
www.cwea.org/sso
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Application Requirements
 All
“known” collection systems in the State
database will receive an instruction letter
from the SWRCB by July 2006.
 All “other” collection systems must also
apply.

Their responsibility to go online and get
information
 Application
must be submitted by
November 2, 2006.
www.cwea.org/sso
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(Some) Application Details
 The
application must be submitted to the
SWRCB, and signed by the enrollee’s
“legally authorized representative”

Must be hard copy since SWRCB needs wet
signature of representative
 Enrollee
is covered under program once
completed application package approved
by the SWRCB Division of Water Quality

Tip: Don’t wait until the last minute!
www.cwea.org/sso
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Caution!
 Log
on to system with username and
password within 30 days of receipt of both
and prior to reporting your first spill


Must fill out “Collection System
Questionnaire”
Questionnaire must be updated every 12
months
www.cwea.org/sso
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On-Line Reporting Requirements
1.
2.
3.
Reporting deadlines by Region
Timeframes for reporting actual SSOs
Required information for reports
www.cwea.org/sso
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Regions 5, 6, 7: September 2, 2007
Regions 1, 2, 3: May 2, 2007
Phased Reporting
Regions 4, 8, 9: January 2, 2007
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SSO Reporting Timeframes
Category 1 SSOs
 Initial Report ASAP but no more than 3
business days
 Final Certified Report within 15 days of
conclusion of response and remediation
Category 2 SSOs
 Report within 30 days of the end of the
month
www.cwea.org/sso
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Reporting Timeframes
(continued)
Private Lateral SSOs
 May be reported at Enrollee’s discretion
No SSOs During Month
 Report no SSOs within 30 days of end of
the month
www.cwea.org/sso
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Caution!
 These
requirements do
not supercede required
timeframes for reporting to
the Office of Emergency
Services, County Health
Departments and
Regional Water
Boards!!!!
www.cwea.org/sso
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Sewer System Management Plan
1.
2.
Sewer System Management Plan
(SSMP) components
Phased implementation timeframes by
size of community served
www.cwea.org/sso
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SSMP Components







Plan and Schedule
Goals
Organization
Legal Authority
Overflow Emergency Response Plan
Operation and Maintenance Plan
FOG Control Program
www.cwea.org/sso
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SSMP Components
(continued)



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Design and Performance Standards
System Capacity Assurance Plan
Monitoring, Measurement, and Program
Modifications
SSMP Program Audits
Communication Program
Final Certification
www.cwea.org/sso
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SSMP
Final Certification

SSMP and program to implement SSMP must
be certified in compliance with GWDR by
Enrollee’s governing body at a public meeting

Authorized representative follows up with submittal to
SWRCB of signed and completed form regarding
certification

Program must be internally audited every two
years
 Program must be updated at least every five
years
www.cwea.org/sso
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SSMP
Implementation Schedule
Task
Population >
100,000
Population
10,000 to
100,000
Population
2,500 to
10,000
Population <
2,500
Plan and
Schedule
8/02/07
11/02/07
2/02/08
5/02/08
Goals
Organization
11/02/07
11/02/07
5/02/08
5/02/08
11/02/08
5/02/09
11/02/09
2/02/10
5/02/09
8/02/09
5/02/10
8/02/10
Emer. Resp. Plan
Legal Authority
O&M Plan
FOG Plan
Design and
Perfor. Standards
System Capacity
Plan
Final SSMP and
Certification
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Summary
All public owned sewer collection systems
in the State greater than one-mile in length
must:



Apply for the State General Waste
Discharge Requirements for Sanitary
Sewer Systems
Report SSOs using SWRCB on-line
reporting system
Develop a comprehensive Sewer System
Management Plan
www.cwea.org/sso
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CWEA Training Plans
 CWEA is
planning on conducting training
for:



On-line reporting
Monitoring and Reporting Requirements
SSMP development and implementation
 CWEA’s
commitment to training has
allowed compliance deadlines that were
presented today

Original deadlines were unrealistic
www.cwea.org/sso
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Training Goals from MOA

General understanding of WDR requirements
 Skills to report data using the State Water Board
electronic reporting system, including
understanding database fields and what
constitutes valid values, definitions of terms, and
overview of methods of gathering the data that
must be reported
 Knowledge of Monitoring & Reporting Program
 Knowledge of components and timeframes for
SSMP development and implementation
www.cwea.org/sso
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Training Elements from MOA




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Overview presentation of key GWDR
requirements
Hands-on exercises, examples, and
demonstrations of the data base functionality
Training manual for each attendee
Evaluation tool to gauge training program
effectiveness (continuous improvement)
Database simulation (web-hosted)
Feedback mechanism to State Water Board
www.cwea.org/sso
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CWEA Deliverables from MOA

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
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Develop & execute a work plan to meet training
objectives & compliance schedule. Offer
periodic training at conferences.
Develop presentations to meet training goals
Develop training manual
Develop evaluation tool, update training
Work with Summit partners
Provide feedback to State
Develop dBase simulation
www.cwea.org/sso
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State Deliverables from MOA


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Modify database (resource dependent)
Provide access to produce dBase simulation
Review training materials & provide timely feedback
Provide regional water board training venues & staff
contacts as possible
Develop Q&A guidance doc on GWDR
Provide functional and responsive help desk
Provide feedback on quality of inputs to dBase
Post CWEA training announcements
Provide agency contact information to CWEA
www.cwea.org/sso
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CWEA
SSO WDR
Training
Task
Force
dBase Work
Group
Warren
Tellefson
Sandbox
Testers
www.cwea.org/sso
CWEA Planning & Program
Development Board
Committee
CWEA SSO WDR Training
Task Force Chair
Nick Pinhey, CWEA
Training Design
Team
Kathy Suter
Subject Matter
Experts
Trainers
Advisory Group
Training Roll
Out Team
Julie Taylor
CWEA Staff
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Training model highlights

Instructional designer



Develop course curriculum
Develop training manual
Lead train-the-trainer

Screen qualified volunteer speakers
 Train-the-trainer sessions for qualified volunteer
speakers led by instructional designer
 Offer information in several “modes”
 SSMP 101, 201?, 301?
www.cwea.org/sso
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Stay Tuned!

Training is in development & will roll out in Fall
• Beta Tests at NRTC 9/17 and Tri-State Seminar 9/30
• Regions 4, 8, 9 Targeted roll out late October– December
2006
• Regions 1, 2, 3 Targeted roll out February– April 2007
• Regions 5, 6, 7 Targeted roll out May – August 2007


Focus first on Monitoring and Reporting and On-line
reporting
Check www.cwea.org/sso often for updates on
training, resources, presentations you can use
www.cwea.org/sso
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How you can help

Trainers




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
50 students in each 4 hour session. Two sessions per
each training day (8 hours of facilitation for trainer per
day).
Experiential training, using real-world case studies
Facilitation role for the qualified volunteer trainers selected
Trainers selected to deliver the training will participate in a
Train-the-Trainer session (1 day) and will be asked to
commit to facilitate at least 2 days of training. Estimated
volunteer hours = 3-6 days per trainer.
Submit trainer interest form: www.cwea.org/sso
Venues
[email protected]
www.cwea.org/sso
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Thank you!
 Nick
Pinhey, Public Works Director, City of
Modesto


CWEA SSO WDR Training Task Force Chair
[email protected]
www.cwea.org/sso
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