BACWA Wet Weather Management Workshop

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BACWAWet Weather Management Workshop

• BACWA Workshop
• San Leandro, CA
• May 28, 2008
• Presentation By Ken Greenberg
• U.S. Environmental Protection Agency

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Where Are We andWhat Has Changed?

• Nothing Has Changed
• Clean Water Act prohibits spills
• Clean Water Act prohibits WWTP bypass
• Cities and Districts continue to serve customers
  by conveying sewage to WWTPs

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What Has Changed?

• 2004 RWQCB 13267 letters
• SSO reporting
• SSMP development
• Statewide WDR (SSO reporting, SSMPs)
• Blending restrictions
• EPA inspections and enforcement
• Jan/Feb 08 storms - Publicity
• Collection systems implement SSMPs

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SSOs
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California Statewide General WDR for Sanitary
Sewer Systems

• Sewer System Management Plans
• Organization Legal Authority
• OM Program
• SSO Response Plan
• FOG Control Program
• Capacity Evaluation and Assurance
• SSMPs will help systems improve
• Proliferation of Best Practices
• Help secure necessary funding and resources

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GENERAL WDR - SSO Reporting

• CIWQS SSO Database the power of information
• The public right to know
• Recognition of best performers
• Motivation to improve
• Statistics/data analysis
• Data available to regulators and NGOs

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Blending

• Bypass of WWTP units during peak wet weather flow
• EPA proposed policy
• on hold at OMB
• permit provisions based on bypass regulation
• anticipated bypass if no feasible alternatives
• RWQCB issued NPDES permits mirror proposed
  blending policy/bypass regulation
• Goal reduce blending with feasible
  infrastructure renewal and WWTP improvements

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EPA National Priorities

• Sustainable Infrastructure
• Compliance and Enforcement Priorities
• CAFOs
• Storm Water
• Combined Sewer Overflows (CSOs)
• Sanitary Sewer Overflows (SSOs)
• www.epa.gov/compliance/planning/priorities/

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EPAs Performance-Based Strategy for SSOs, FY05
to 07

• Goal 1 Protect health and water quality in
  priority watersheds
• 75 of EPA SSO enforcement in priority watersheds
• Goal 2 Protect public investment in wastewater
  infrastructure by ensuring proper CMOM
• Address systems to ensure adequate CMOM at 100
  of large systems (gt100 mgd) and 10 of medium
  systems (10 to 100 mgd)
• Address inspect or inspect and enforce

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EPAs Performance-Based Strategy for SSOs, FY08
to 10

• Goal 1 Protect health and water quality in
  priority watersheds
• Goal 2 Protect public investment in wastewater
  infrastructure by ensuring proper CMOM
• Address systems to ensure adequate CMOM at 100
  of large systems (gt100 mgd) and 50 of medium
  systems (10 to 100 mgd)
• Address inspect or inspect and enforce

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EPA InspectionsSF Bay Area 2007/2008

• 27 systems inspected
• Targeted based on spill rates and WW peaking
  factors
• Findings
• Wet weather capacity problems - SSOs and WWTP
  impacts
• Frequent blockage spills
• Aging/deteriorating pipes
• Fragmented governance - small districts
• SSMP - path to improvement

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The Power of InformationSo. Cal./Arizona Spill
Rates
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SF Bay Region SSO Data

• Median 9.6 SSO/100 miles/year (from CIWQS
  7/07 to 4/08)
• Capacity related spills in Jan/Feb 08
• Storms bring increase in number and volume of
  spills
• Jan/Feb 08 - 493 spills, 12.3 MG
• Mar/Apr 08 - 241 spills, 211,000 gal
• WWTP blending and overflows

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EPA Enforcement Orders April 2008

• Sewerage Agency of Southern Marin
• Almonte SD
• Alto SD
• Homestead Valley SD
• Mill Valley, City of
• Richardson Bay SD
• Tamalpais CSD

• Sausalito-Marin City Sanitary District
• Sausalito, City of
• Tamalpais CSD

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Sanitary Districts of Southern Marin
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Southern Marin Orders

• Findings
• Wet weather spills and WWTP bypasses
• Frequent blockage spills
• Aging/deteriorated pipes
• Fragmented governance (9 districts/cities flow to
  2 WWTPs)

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Fragmented Governance

• Small districts (6 miles of pipe)
• Limited staff and equipment
• Reliance on maintenance contractors
• Fees sufficient to support pipe replacement?
• Treatment fees based on EDU (little incentive to
  control I/I)
• Missed opportunities

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Southern Marin Orders

• Spill response plans
• Sewer cleaning (increase hot spot cleaning)
• Short-term contingency plans
• CCTV and condition assessment
• Capacity assessment
• Capacity management plan
• Rehab/replacement plan (long-term sustainable
  renewal)

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Spill Reduction and Wet Weather Management

• Short-term spill reduction
• Sewer cleaning and FOG control
• Information management
• Assessment
• CCTV condition assessment
• Flow measurement/capacity assessment
• Long-term Spill and Blending Reduction
• Sustainable infrastructure renewal vs
• Convey/storage/treatment
• Collaboration/consolidation of fragmented agencies

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(No Transcript)
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SSMP Will Spur Infrastructure Renewal
Rehab/Replace Rate
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QUESTIONS or COMMENTS

• Ken Greenberg, EPA Region 9
• 415-972-3577
• greenberg.ken_at_epa.gov
• On the web
• www.epa.gov/region09/water/npdes/compliance.html
• www.epa.gov/npdes/sso