“You, Me and the SSO GWDR” (Order No. 2006-0003-DWQ)

1. “You, Me and the SSO GWDR” (Order No. 2006-0003-DWQ) James Fischer, P.E. Water Resource Control Engineer Division of Water Quality State Water Resources Control Board, Sacramento CWEA NTC 2008: Statewide SSO General Order

2. Overview Background on Statewide SSO General Waste Discharge Requirements (GWDR) Permit Current Program Status Outreach and Training Common Questions and Answers Program Issues CWEA NTC 2008: Statewide SSO General Order

3. Background on SSO GWDR • 2004: State Water Resources Control Board passed a Resolution to reduce number and volumes of SSOs • Provides streamlined approach to permitting collection systems compared with numerous Regional Water Board permits • GWDR modeled after USEPA Capacity, Management, Operations and Maintenance (CMOM) Program • GWDR adopted May 2, 2006 to address SSOs in consistent/uniform manner throughout the state • First comprehensive regulatory program in the nation to comprehensively address sanitary sewer systems (both for reporting spills and collection system management) CWEA NTC 2008: Statewide SSO General Order

4. Background on SSO GWDR • Applicability: Requires any publicly-owned agency with a collection system (sewer pipes) greater than one mile in length and connected to publicy-owned treatment facility (regardless of treatment technology) to enroll for coverage • Collection systems must be individually enrolled regardless of number owned CWEA NTC 2008: Statewide SSO General Order

5. Background on SSO GWDR • Notice of Intent (NOI) initially mailed out to “potential enrollees” on June 16, 2006 • Application for Coverage was required by all applicable collection systems by November 2, 2006 • 1,100 Collection Systems Currently Enrolled (Sept 2008) • Represents over 840 collection system local agencies • Notice of Non-Applicability filed by several dozen agencies • Website: www.swrcb.ca.gov/water_issues/programs/sanitary_sewer_overflow/ • Type “Sanitary Sewer Overflow” in State Board “search” box CWEA NTC 2008: Statewide SSO General Order

6. SSO GWDR Website CWEA NTC 2008: Statewide SSO General Order

7. GWDR Permit Requirements CWEA NTC 2008: Statewide SSO General Order

8. GWDR Permit Requirements:Enrollment and NOI • State Board Staff Primary: DWQ/WDR Unit • Regional Boards (RBs): Secondary: perform follow-up only on “as-needed” basis • Combined efforts successfully obtained NOI responses from 98% of all known “potential enrollees” • Outstanding agencies must either enroll or request and complete a “Notice of Non-Applicability” for coverage and send to State Board CWEA NTC 2008: Statewide SSO General Order

9. GWDR Permit Requirements: Reporting Schedule • Enrollees required to begin reporting SSOs via CIWQS according to following schedule: • Regions 4, 8, 9 January 2, 2007 • Regions 1, 2, 3 May 2, 2007 • Regions 5, 6, 7 September 2, 2007 CWEA NTC 2008: Statewide SSO General Order

10. GWDR Permit Requirements:Misc. 1. Enrollment / establishment of Legally Responsible Official (LRO) 2. Maintain compliance with SSO MRP (2/20/2008 version) 3. Complete mandatory Collection System Questionnaire (must be completed within 30 days of enrollment & updated annually or no SSOs may be reported) 3. Must electronically report any SSO or do a monthly “No-Spill” Certification” if no SSOs for any individual calendar month 4. Develop and Implement Sewer System Management Plan (SSMP): - Ensures proper management, operation and maintenance - Supports State’s WDR regulatory goals - Provides State with ability to compare SSO reports with adopted SSMP elements to measure effectiveness of individual local agency collection system operations, maintenance and management practices CWEA NTC 2008: Statewide SSO General Order

11. GWDR Permit Requirements:Notification/Reporting Category 1 SSO: ANY volume: 1) Reached a surface water; or 2) Entered storm drain pipe and not fully captured/returned to sewer; or 3) >1,000 gallons Category 2 SSO: any other SSO not meeting definition for Category 1 NOTIFICATION Category 1 SSO: 2hrs to notify OES, local health, and Regional Water Board of SSO; 24hrs to certify to Regional Board that OES/local health were notified Category 2 SSO: none REPORTING (CIWQS) Category 1 SSO: 3 days to “Submit Draft” and 15 days to “Certify” Category 2 SSO: 30 days to “Certify” CWEA NTC 2008: Statewide SSO General Order

12. GWDR Permit Requirements:SSMP Required Elements • Plan and Schedule (requires local gov. board ok) • Organization • Legal Authority • Operation and Maintenance • Design and Performance • Overflow Emergency Response • Fats, Oils and Grease (FOG) • Systems Evaluation and Capacity Assurance • Monitoring, Measurement and Program Mods. • SSMP Audits • Communication Program • Final Certification (requires local gov. board ok) CWEA NTC 2008: Statewide SSO General Order

13. GWDR Permit Requirements:SSMP Requirements • Enrollee “self approves” all SSMP Task Elements and Certifies in CIWQS online when each element is completed • Element schedule on SSO Website • All SSMPs will be fully implemented by August 2, 2010 • Regional Boards can review SSMPs upon request (approval is not required) CWEA NTC 2008: Statewide SSO General Order

14. Current Program Status CWEA NTC 2008: Statewide SSO General Order

15. SSO “Non-Responsive Agency Trend CWEA NTC 2008: Statewide SSO General Order

16. SSO GWDR Enrollment Trend CWEA NTC 2008: Statewide SSO General Order

17. Statewide Reporting Compliance CWEA NTC 2008: Statewide SSO General Order

18. Collection System Questionnaire Compliance CWEA NTC 2008: Statewide SSO General Order

19. CIWQS SSO Report Statistics CWEA NTC 2008: Statewide SSO General Order

20. Common Questions and Answers CWEA NTC 2008: Statewide SSO General Order

21. Common Questions • What if my agency has a collection system(s) that meets the minimum GWDR requirements and has still not applied for coverage under the SSO General Order? • What if my agency has not yet “Certified” any of the required SSMP task elements? • What if my agency has missed “No Spill Certifications” for any months without any SSOs? CWEA NTC 2008: Statewide SSO General Order

22. Answers • To avoid enforcement action, your agency must: • Enrollany applicable collection systems(s) for coverage under SSO GWDR • Update all records in CIWQS, including any information back to the date when mandatory reporting was required within your Region (see website for details) CWEA NTC 2008: Statewide SSO General Order

23. Outreach and Training Resources CWEA NTC 2008: Statewide SSO General Order

24. Outreach • Blanket and Direct emails (using email addresses pulled from our CIWQS system) • Non-Compliance with Reporting Requirements • Communicate other pertinent program information • SSO Website to be redesigned and will soon host more data, including all Enrollee compliance status • State Board continues to coordinate outreach with CWEA / CVCWA / BCWA and other trade organizations CWEA NTC 2008: Statewide SSO General Order

25. Outreach CIWQS SSO External User Group • Represents 40+ Enrollees (large and small collection systems) • Extensive tracking of all technical CIWQS/SSO Program-related issues • Regular testing, review and comment on CIWQS changes prior to production roll-out • Quarterly meetings (participation also available via conference call and WEBEX) • Email us if interested in participating (jfischer@waterboards.ca.gov) CWEA NTC 2008: Statewide SSO General Order

26. Training Resources • CWEA has MOA with State Water Board • SSO Program training classes and outreach • CVCWA, CRWA and others conducting extensive training on SSO GWDR throughout California • Regional Board staff being trained internally on GWDR and attending some statewide training classes • CWEA Training Calendar: www.cwea.org/calendar.shtml CWEA NTC 2008: Statewide SSO General Order

27. SSO Discharger User Guide • Available on CIWQS (SSO) website www.waterboards.ca.gov/water_issues/programs/ciwqs/chc_sso.shtml CWEA NTC 2008: Statewide SSO General Order

28. CWEA MOA/Training CWEA NTC 2008: Statewide SSO General Order

29. Current SSO Program Issues CWEA NTC 2008: Statewide SSO General Order

30. Current SSO Program Issues • CIWQS Reporting Compliance ~ 74% • CIWQS Questionnaire Compliance ~ 81% • CIWQS SSMP Certification Elements Input ~ 50% • MRP (2/20/08 version) is inconsistent with Water Code and some GWDR Requirements • Q&A under development • Program review 2009 will address inconsistencies CWEA NTC 2008: Statewide SSO General Order

31. Current SSO Program Issues • SSO Program Review • Begins in May 2009 • Board will consider “re-opening” GWDR • Will include extensive public outreach including workshops around the state • Industry encouraged to participate, attend workshops and provide input CWEA NTC 2008: Statewide SSO General Order

32. Beta (draft) SSO Mapping Tool • Presents all individual SSO and Private Lateral Sewage Discharge data in CIWQS reported to date in a map format • Serves as an SSO data Q/A & Q/C tool • Dischargers have been given the opportunity to review and correct any data errors before public posting in November 2008 CWEA NTC 2008: Statewide SSO General Order

33. Beta (draft) SSO Mapping Tool CWEA NTC 2008: Statewide SSO General Order

34. Program Contacts • Usernames/Passwords/Registration/Data Issues: CIWQS HELP CENTER 1-866-792-4977 (M-F, 8am-5pm) ciwqs@waterboards.ca.gov • SSO Program Technical Assistance: James Fischer, P.E. Program Lead / Statewide SSO Program 916-341-5548 jfischer@waterboards.ca.gov CWEA NTC 2008: Statewide SSO General Order