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Regulatory / WDR Update

Regulatory / WDR Update. What’s Going On?. Waste Discharge Requirements. Adapted by the State Water Resources Control Board on May 2, 2006 Implementation based on population Complete implementation by August 2010 WDRs do not sunset Triennial Review process

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Regulatory / WDR Update

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  1. Regulatory / WDRUpdate What’s Going On?

  2. Waste Discharge Requirements • Adapted by the State Water Resources Control Board on May 2, 2006 • Implementation based on population • Complete implementation by August 2010 • WDRs do not sunset • Triennial Review process • Stakeholder involvement encouraged

  3. SSO Users Group • Public comment meetings 2009 • Southern California • Northern California • Order Review Committee • Review SSMP Elements • Review reporting requirements • Mantis List • Data Review Committee

  4. Mantis List Update

  5. Data Review Committee • Refine the CIWQS SSO spill report form data fields • Re-design the SSO spill report form to be event not location based • What indices of Collection System performance should be used to compare collection systems in California?

  6. Performance Indices • Current index • # spills per 100 miles of pipe per year • Under 3 – Over 6 Prospective Indices • Number of Spills (or Volume of Spills) per 100 miles of pipeline. • Number of Spills (or Volume of Spills) per capita.

  7. Performance Indices • Number of Category 1 spills (or Volume of Spills); number of Category 2 spills (or Volume of Spills). • Number of Spills (or Volume of Spills) by pipe diameter or pipe area. • Number of Spills (or Volume of Spills) by volume class of spill.

  8. Performance Indices • Separate out number of spills (or Volume of Spills) by portion of collection system pump station, force main, gravity, lateral. • Separate out spills (or Volume of Spills) caused by outside contractors. • Number of Spills (or Volume of Spills) by cause category (fog, roots, debris, etc.).

  9. Performance Indices • Gallons Conveyed versus Gallons Spilled versus Gallons Recovered versus Gallons Reach Surface water. • Volume of Spills per Year by Total Volume Conveyed (measured or estimated based upon population served).

  10. Miscellaneous • Data shows that smaller pipes have more frequent SSOs • Smaller systems tend to have more SSOs per mile than larger systems • Roots tend to be the primary source of SSOs statewide • A new reporting category (3) may be developed for very small SSOs.

  11. Additional Information • Google Groups • SSO Data Review Committee • Non committee members can review all posted data • Non committee members can not post to the group

  12. Opening the WDR

  13. Opening the WDR • Draft of new Order scheduled for public release in late July or August 2010 • Public comment period • Presentation to SWRCB for adoption in November 2010 – Public hearing • Adoption by SWRCB in December 2010 • Anticipated that most changes will be administrative • MRP changes and notification streamlined

  14. AUDITS X 2

  15. Audits - State • SWRCB intends on conducting at least 2 audits per Region • Audits will be conducted in conjunction with Regional staff • Audits may be random or selected based upon reporting history • Zero spills as likely as numerous spills • EPA Region 9 online audit files • Regions may conduct additional audits • Some Regions already conducting enforcement

  16. SSMP Audit Requirements • The SSMP requires that each agency conduct an audit every two years based upon the date that the final SSMP was approved • Audits must remain on file and be available to the State or Regional Boards upon request • Audits are performance based and should reflect all elements of the SSMP

  17. 3 Key SSMP Elements - Audits SSMP is an asset management program • Goals • Monitoring, Measurement, and Program Modifications • SSMP Program Audits

  18. Goals • Specific • Attainable • Measurable • Prioritized • Modify as needed • Add or delete goals as needed

  19. Goals - Example • Eliminate all SSOs including those caused by roots • By (date) identify all root prone areas in the system; develop a remediation strategy; review the effectiveness of the root remediation program and its effect on SSOs

  20. Monitoring, Measurement, and Program Modifications • Ongoing evaluation of SSOs • Cause, response, frequency, category, damage • Ongoing evaluation of maintenance practices and inspections • Ongoing effectiveness of FOG, root or other special programs • Revenue and expense

  21. SSMP Program Audits • Formal written audit due every two years based upon the date that original SSMP was approved • Performance oriented • Pertains to all elements of the SSMP • Document any changes to the SSMP since last audit • Maintain on file

  22. Questions / Discussion

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