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BACWA Wet Weather Management Workshop. BACWA Workshop San Leandro, CA May 28, 2008 Presentation By – Ken Greenberg U.S. Environmental Protection Agency. Where Are We and What Has Changed?. Nothing Has Changed Clean Water Act prohibits spills Clean Water Act prohibits WWTP bypass
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BACWAWet Weather Management Workshop BACWA Workshop San Leandro, CA May 28, 2008 Presentation By – Ken Greenberg U.S. Environmental Protection Agency
Where Are We andWhat Has Changed? Nothing Has Changed • Clean Water Act prohibits spills • Clean Water Act prohibits WWTP bypass • Cities and Districts continue to serve customers by conveying sewage to WWTPs
What Has Changed? • 2004 RWQCB 13267 letters • SSO reporting • SSMP development • Statewide WDR (SSO reporting, SSMPs) • Blending restrictions • EPA inspections and enforcement • Jan/Feb ‘08 storms - Publicity • Collection systems implement SSMPs
California Statewide General WDR for Sanitary Sewer Systems • Sewer System Management Plans • Organization & Legal Authority • O&M Program • SSO Response Plan • FOG Control Program • Capacity Evaluation and Assurance • SSMPs will help systems improve • Proliferation of “Best Practices” • Help secure necessary funding and resources
GENERAL WDR - SSO Reporting CIWQS SSO Database – “the power of information”: • The public “right to know” • Recognition of best performers • Motivation to improve • Statistics/data analysis • Data available to regulators and NGOs
Blending • Bypass of WWTP units during peak wet weather flow • EPA proposed policy: • on hold at OMB • permit provisions based on bypass regulation • anticipated bypass if no feasible alternatives • RWQCB issued NPDES permits mirror proposed blending policy/bypass regulation • Goal: reduce blending with feasible infrastructure renewal and WWTP improvements
EPA National Priorities • Sustainable Infrastructure • Compliance and Enforcement Priorities: • CAFOs • Storm Water • Combined Sewer Overflows (CSOs) • Sanitary Sewer Overflows (SSOs) • www.epa.gov/compliance/planning/priorities/
EPA’s Performance-Based Strategy for SSOs, FY05 to 07 Goal 1: Protect health and water quality in priority watersheds • 75% of EPA SSO enforcement in priority watersheds Goal 2: Protect public investment in wastewater infrastructure by ensuring proper CMOM • “Address” systems to ensure adequate CMOM at 100% of large systems (>100 mgd) and 10% of medium systems (10 to 100 mgd) • “Address” = inspect or inspect and enforce
EPA’s Performance-Based Strategy for SSOs, FY08 to 10 Goal 1: Protect health and water quality in priority watersheds Goal 2: Protect public investment in wastewater infrastructure by ensuring proper CMOM • “Address” systems to ensure adequate CMOM at 100% of large systems (>100 mgd) and 50% of medium systems (10 to 100 mgd) • “Address” = inspect or inspect and enforce
EPA Inspections:SF Bay Area 2007/2008 • 27 systems inspected • Targeted based on spill rates and WW peaking factors • Findings: • Wet weather capacity problems - SSOs and WWTP impacts • Frequent blockage spills • Aging/deteriorating pipes • Fragmented governance - small districts • SSMP - path to improvement
SF Bay Region SSO Data • Median = 9.6 SSO/100 miles/year (from CIWQS 7/07 to 4/08) • Capacity related spills in Jan/Feb ‘08: • Storms bring increase in number and volume of spills • Jan/Feb ‘08 - 493 spills, 12.3 MG • Mar/Apr ‘08 - 241 spills, 211,000 gal • WWTP blending and overflows
Sewerage Agency of Southern Marin Almonte SD Alto SD Homestead Valley SD Mill Valley, City of Richardson Bay SD Tamalpais CSD Sausalito-Marin City Sanitary District Sausalito, City of Tamalpais CSD EPA Enforcement Orders – April 2008
Southern Marin Orders • Findings • Wet weather spills and WWTP bypasses • Frequent blockage spills • Aging/deteriorated pipes • Fragmented governance (9 districts/cities flow to 2 WWTPs)
Fragmented Governance • Small districts (6 miles of pipe) • Limited staff and equipment • Reliance on maintenance contractors • Fees sufficient to support pipe replacement? • Treatment fees based on EDU (little incentive to control I/I) • Missed opportunities
Southern Marin Orders • Spill response plans • Sewer cleaning (increase hot spot cleaning) • Short-term contingency plans • CCTV and condition assessment • Capacity assessment • Capacity management plan • Rehab/replacement plan (long-term sustainable renewal)
Spill Reduction and Wet Weather Management • Short-term spill reduction: • Sewer cleaning and FOG control • Information management • Assessment: • CCTV condition assessment • Flow measurement/capacity assessment • Long-term Spill and Blending Reduction • Sustainable infrastructure renewal vs • Convey/storage/treatment • Collaboration/consolidation of fragmented agencies
QUESTIONS or COMMENTS Ken Greenberg, EPA Region 9 415-972-3577 greenberg.ken@epa.gov On the web: www.epa.gov/region09/water/npdes/compliance.html www.epa.gov/npdes/sso