Regulatory / WDR Update

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Regulatory / WDRUpdate

• Whats Going On?

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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

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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

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Mantis List Update
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Data Review Committee

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

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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.

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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.

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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.).

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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).

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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.

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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

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Opening the WDR
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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

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AUDITS X 2
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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

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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

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3 Key SSMP Elements - Audits

• SSMP is an asset management program
• Goals
• Monitoring, Measurement, and Program
  Modifications
• SSMP Program Audits

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Goals

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

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Goals - Example

1. Eliminate all SSOs including those caused by
   roots
2. 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

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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

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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

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Questions / Discussion