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Understanding Statewide Waste Discharge Requirements

An overview of Waste Discharge Requirements for Sanitary Sewer Systems, including history, application process, reporting of overflows, and management plans. Learn about the purpose, basic requirements, and the importance of this regulatory program.

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Understanding Statewide Waste Discharge Requirements

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  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

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