Statewide General Waste Discharge Requirements for Sanitary Sewer Systems

1. BACWA Statewide General Waste Discharge Requirements forSanitary Sewer Systems Presentation to [fill in] [Date]

2. 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

3. Presentation Outline • 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. SSO Categories • Category 1 • 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 Lateral Sewage Discharge • Discharges caused by privately owned lateral www.cwea.org/sso

12. 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

13. (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

14. 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

15. On-Line Reporting Requirements • Reporting deadlines by Region • Timeframes for reporting actual SSOs • Required information for reports www.cwea.org/sso

16. Phased Reporting Regions 5, 6, 7: September 2, 2007 Regions 1, 2, 3: May 2, 2007 Regions 4, 8, 9: January 2, 2007 www.cwea.org/sso

17. 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

18. 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

19. 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

20. Sewer System Management Plan • Sewer System Management Plan (SSMP) components • Phased implementation timeframes by size of community served www.cwea.org/sso

21. SSMP Components • Plan and Schedule • Goals • Organization • Legal Authority • Overflow Emergency Response Plan • Operation and Maintenance Plan • FOG Control Program www.cwea.org/sso

22. SSMP Components(continued) • Design and Performance Standards • System Capacity Assurance Plan • Monitoring, Measurement, and Program Modifications • SSMP Program Audits • Communication Program • Final Certification www.cwea.org/sso

23. SSMPFinal 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

24. SSMPImplementation Schedule

25. 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

26. 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

27. 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

28. Training Elements from MOA • 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

29. CWEA Deliverables from MOA • 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

30. State Deliverables from MOA • 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

31. CWEA Planning & Program Development Board Committee CWEA SSO WDR Training Task Force CWEA SSO WDR Training Task Force Chair Nick Pinhey, CWEA Advisory Group dBase Work Group Warren Tellefson Training Design Team Kathy Suter Training Roll Out Team Julie Taylor Subject Matter Experts Sandbox Testers CWEA Staff Trainers www.cwea.org/sso

32. 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

33. 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

34. How you can help • Trainers • 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 • sso@cwea.org www.cwea.org/sso

35. Thank you! • Nick Pinhey, Public Works Director, City of Modesto • CWEA SSO WDR Training Task Force Chair • sso@cwea.org www.cwea.org/sso