Statewide General Waste Discharge Requirements for Sanitary Sewer Systems

1. BACWA Statewide General Waste Discharge Requirements forSanitary Sewer Systems

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

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

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

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

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

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

8. Caution! • Key issue unresolved: Potential conflicts between Regional Board and SWRCB requirements • Allows Regional Boards to be more stringent • Unclear as to implementation issues, such as schedule for reporting, etc.

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

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

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

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.

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!

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

15. On-Line Reporting Requirements • Reporting deadlines by Region • Timeframes for reporting actual SSOs • Required information for reports

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

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

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

19. Caution! • These requirements do not supercede required timeframes for reporting to the Office of Emergency Services, County Health Departments and Regional Water Boards!!!!

20. Sewer System Management Plan • Sewer System Management Plan (SSMP) components • Phased implementation timeframes by size of community served

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

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

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

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

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

27. Stay Tuned! • Details on training are under development • Materials being developed • Focus first on Monitoring and Reporting and On-line reporting • Interested in helping prepare training materials/conduct training/assist with logistics? • Then Nick is your man!

28. Thank you! • Nick Pinhey • CWEA SSO WDR Training Task Force Chair • Phone: 209-577-5205 • npinhey@modestogov.com • Maura Bonnarens • CWEA President-Elect • Phone: 510-287-1141 • mbonnare@ebmud.com