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COLLECTION SYSTEMS REGULATORY UPDATE

COLLECTION SYSTEMS REGULATORY UPDATE. USEPA – SWRCB August 2010. USEPA NPDES RUMBLINGS. USEPA. In June of 2010 the USEPA published a notice in the Federal Register its intent to conduct several “listening sessions” to obtain information on issues related to collection systems.

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COLLECTION SYSTEMS REGULATORY UPDATE

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  1. COLLECTION SYSTEMS REGULATORY UPDATE USEPA – SWRCB August 2010

  2. USEPA NPDES RUMBLINGS

  3. USEPA • In June of 2010 the USEPA published a notice in the Federal Register its intent to conduct several “listening sessions” to obtain information on issues related to collection systems. • Five questions pertaining to collection systems were posed.

  4. USEPA • Should EPA clarify its standard permit conditions for SSO reporting, recordkeeping, and public notification? • Should EPA develop a standard permit condition with requirements for capacity, management, and operations & maintenance programs based on asset management principles?

  5. USEPA • Should EPA require permit coverage for municipal satellite collection systems? • What is the appropriate role of NPDES permits in addressing unauthorized SSOs that are caused by exceptional circumstances? • What are the costs and benefits of capacity, management, and operations & maintenance programs and asset management of sanitary sewers?

  6. USEPA • What is CMOM? • Capacity, Management, Operations and Maintenance • Asset management program based on industry standards setting the minimum requirements for collection systems. • Conceived by the USEPA in the early 1990s based on the MOM program from USEPA Region 4.

  7. USEPA • Draft ready for adoption in 2001. • Change in Administration – funding pulled – CMOM never adopted. • CMOM is comprised of: • Spill notification, reporting and records keeping • Written program – Asset Management • Spill response • O & M Program including: • Line cleaning • Inspection (CCTV, etc.)

  8. USEPA • Mapping • Grease Source Control • Condition Assessment; Replacement/Rehabilitation • Capitol Improvement Program • Short and long term funding • Capacity Assurance • I&I Control • Sound Familiar?

  9. USEPA NPDES Permit or WDR • Both are legally enforceable regulations • NPDES Permits originate with the federal government. • WDRs originate at the state or local (Regional) level. • Life Expectancy • NPDES Permits are renewed every five years. • WDR’s remain enforceable until they are repealed although may have periodic review.

  10. USEPA • Coverage • NPDES Permits can be individualized having specific requirements for a specific agency thus becoming more prescriptive. • WDRs cover groups of like agencies with the requirements being the same for all covered agencies and tend to be more general in nature.

  11. USEPA • Protection • The Clean Water Act provides for citizen lawsuits regardless if the agency is under a NPDES Permit or a WDR. • Some feel that the NPDES Permit system makes it easier for third party lawsuits. • Some WDRs may include “affirmative defense” language. • The legality of affirmative defense language is debatable.

  12. USEPA • How will USEPA’s proposed regulations effect California collection systems? • If the USEPA proceeds with its apparent intentions it will take 2 to 3 years (or longer) for the program to be finalized. • Currently, state officials do not feel that USEPA’s proposed regulations will have any effect on California. • California’s current regulations are already more prescriptive than what USEPA is proposing.

  13. USEPA • What are the issues? • WEF, CWEA, SCAP and other collection system stakeholders generally do not object to sensible regulations that utilize best management practices and are based on industry standards such as CMOM programs. • Issues with the NPDES Permit program • NPDES Permits issued to individual agencies. • NPDES Permits issued to POTWs with satellites as co-permittees. • NPDES Permits issued to the states allowing the states to run their own approved program.

  14. State Water Resources Control Board (SWRCB)

  15. SWRCB • WDR Order Review • WDR is currently under review by the SWRCB • Draft of the revised Order was to be out late July or August with presentation to the full Board in August. • New timetable for release of draft is October or November • Public comment period and Public Hearing to follow • Adoption by SWRCB in December 2010 or January 2010

  16. SWRCB • Anticipated changes. • State will not reveal what changes are in the revised Order except that most of the changes will be to the reporting and monitoring with some administrative and clarification changes to the Order. • Possible notification changes utilizing a one call system for notification of OES, Regional Board and health care. • Language to assist those agencies with lateral responsibilities for spill reporting.

  17. SWRCB • Possible addition of a Category 3 spill for very small (under 100 gallon & not to the waters of the US) spills with reduced reporting requirements. • The issue here is that there are several agencies (Central Valley & Bay Area) who are experiencing a large number of very small spills (10 gal or less and from agency controlled laterals) making current reporting very costly. • Possible changes to CIWQS reporting to further insure that private property spill are not credited to the reporting agency. • Reporting to be event based instead of appearance based.

  18. SWRCB • SWRCB Audits • The SWRCB is still on track to conduct random audits throughout the state. • Audits will be conducted by state and regional staff • Audits will be random (unless regional staff wants a particular agency audited • Audits not based on spill history • WDR In-house Audits • Each agency is required to conduct an in-house audit every two years by the anniversary of the initial approval date of the agency’s SSMP.

  19. SWRCB • Audits should include an evaluation of the performance of each SSMP element and any changes made or anticipated to the SSMP and associated programs. • Audits are to be written and maintained by the agency. • First audits (agency’s serving populations > 100,000) May 2011. Populations of 10,000 to 100,000, August 2011. • Additional information will be provided at CSC meetings and the SCAP Monthly Update.

  20. SWRCB • Data Review Committee • Started early 2010 and meets twice a month • Committee Objectives • Refine the CIWQS SSO spill report form data fields - Is there data we are now collecting that can be eliminated from the spill report? Is there data we should be but are not currently collecting on the spill report?  How should we refine the drop down selection lists for fields like "Appearance Point", etc. • Re-design the SSO spill report form to be event not location based - incorporate multiple "appearance" points into the spill report form.

  21. SWRCB • What indices of Collection System performance should be used to compare collection systems in California? • Performance Indices have occupied most of the Committee’s time. • Current index used to compare collection systems is annual spills per 100 miles of pipe. • Considered unfair to small systems having less than 100 miles of pipe.

  22. SWRCB • Approximately 10 different indices were evaluated based upon miles of pipe; number, category and volume of spills; spill cause; pipe type, size and age; agency flow vs. spilled volume, etc. • Different scenarios were analyzed by committee members utilizing their own data or masked data provided by the state. • There is no one size fits all.

  23. SWRCB • The Committee has tentatively selected: • SSOs per 100 miles of mainline per year • SSOs per 100 miles of lateral lines per year • Volume spilled verses volume not recovered per 100 miles of mainline per year • Volume spilled verses volume not recovered per 100 miles of laterals per year • Consideration is being given to possibly use the indices but utilize 10 and 1 mile pipe segments for smaller systems.

  24. SWRCB • After analyzing the spill data (gravity systems) the Committee also found: • Smaller pipe sizes have higher spill rates than larger pipes but smaller volumes. • Smaller systems tend to have higher spill rates than larger systems. • Roots tend to be the number one cause or contributing factor for SSOs statewide.

  25. SWRCB • Agency Performance Report • Report generated by and displayed on the SWRCB’s website. • Report compares an agency’s performance with other agencies within the Region and state. • Report allows the viewer to select a 12-month timeframe for the report generation. • SWRCB is soliciting additional input on the report. • Report can be viewed in Google Groups.

  26. CWEATraining2010-2011

  27. CWEA WDR Training ’10-’11 • CWEA training is going to shift from in-person seminars to webinars • Low cost 1 ½ to 2 hours in length • Topics • How to estimate SSOs • Enforcement and NGO Actions • SSO-WDR Reporting and Order Changes • State is requesting webinar on in-house WDR/SSMP audits

  28. Thank You Bob Kreg Program Manager Dudek

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