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11
Statewide General Waste Statewide General Waste Discharge Requirements Discharge Requirements
forfor Sanitary Sewer SystemsSanitary Sewer Systems
Presentation to [fill in]Presentation to [fill in]
[Date][Date]
BACWA
22
DisclaimersDisclaimers
We did not write the WDR!We did not write the WDR! This is an overview only – though lengthy This is an overview only – though lengthy
at that!at that! CWEA will be offering much more CWEA will be offering much more
comprehensive training for the wastewater comprehensive training for the wastewater communitycommunity
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Presentation OutlinePresentation Outline
1.1. HistoryHistory
2.2. Purpose of the WDRPurpose of the WDR
3.3. The Basic Requirements of the WDRThe Basic Requirements of the WDR• Application Application • On-line reporting of Sewer System Overflows On-line reporting of Sewer System Overflows • Development of a Sewer System Management Development of a Sewer System Management
Plan Plan
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HistoryHistory
State Water Resources Control Board State Water Resources Control Board (SWRCB) Resolution 2004-80(SWRCB) Resolution 2004-80 Required staff to develop work with Required staff to develop work with
stakeholders to develop a regulatory program stakeholders to develop a regulatory program that would provide a consistent approach to that would provide a consistent approach to reducing Sewer System Overflows (SSOs)reducing Sewer System Overflows (SSOs)
SSO Guidance Committee formedSSO Guidance Committee formed Committee included SWRCB Staff, Industry Committee included SWRCB Staff, Industry
Representatives and NGOsRepresentatives and NGOs
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HistoryHistory(continued)(continued)
Committee developed a draft Waste Discharge Committee developed a draft Waste Discharge Requirement (WDR)Requirement (WDR) Applies to entities that own or operate collection Applies to entities that own or operate collection
systems greater than one-mile in lengthsystems greater than one-mile in length Basic RequirementsBasic Requirements
All public operated sewer collection systems must All public operated sewer collection systems must applyapply for coverage under the WDR for coverage under the WDR
All covered collection systems must begin All covered collection systems must begin on-line on-line reportingreporting of SSOs. of SSOs.
All covered collection systems must All covered collection systems must developdevelop a Sewer a Sewer System Management PlanSystem Management Plan
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HistoryHistory(continued)(continued)
First public hearing held February 8First public hearing held February 8 Comment period extended two weeks by SWRCB to Comment period extended two weeks by SWRCB to
receive additional information from attendeesreceive additional information from attendees Second public hearing held May 2, 2006 Second public hearing held May 2, 2006
Final WDR adopted on May 2, 2006Final WDR adopted on May 2, 2006 Granted extension to original compliance schedules Granted extension to original compliance schedules
contingent upon CWEA/industry and SWRCB contingent upon CWEA/industry and SWRCB entering into an Memorandum of Agreement for entering into an Memorandum of Agreement for trainingtraining
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Purpose of WDRPurpose of WDR
Proactive approach to ensure system wide Proactive approach to ensure system wide operation, maintenance and management plans operation, maintenance and management plans to reduce SSOsto reduce SSOs Concept is that many SSOs are preventableConcept is that many SSOs are preventable
Allows SWRCB to gather consistent data on Allows SWRCB to gather consistent data on causes and sources of SSOscauses and sources of SSOs Intents is to provide SWRCB with better Intents is to provide SWRCB with better
understanding of the issueunderstanding of the issue
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Caution!Caution! Key issue unresolved: Potential conflicts Key issue unresolved: Potential conflicts
between Regional Board and SWRCB between Regional Board and SWRCB requirementsrequirements Letter of commitment to resolve potential Letter of commitment to resolve potential
conflicts was received from State Board conflicts was received from State Board Allows Regional Boards to be more stringentAllows Regional Boards to be more stringent Unclear as to implementation issues, such as Unclear as to implementation issues, such as
schedule for reporting, etc.schedule for reporting, etc.
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Basic DefinitionsBasic Definitions
Sanitary Sewer Overflow (SSO)Sanitary Sewer Overflow (SSO) Releases of untreated or partially treated Releases of untreated or partially treated
wastewater to waters of the United Stateswastewater to waters of the United States Releases of untreated or partially treated Releases of untreated or partially treated
wastewater that do not reach waters of the wastewater that do not reach waters of the United StatesUnited States
Wastewater backups into buildings and on Wastewater backups into buildings and on private property that are caused by blockages private property that are caused by blockages in the publicly owned portion of the sanitary in the publicly owned portion of the sanitary sewer systemsewer system
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Basic DefinitionsBasic Definitions(continued)(continued)
SSO Reporting SystemSSO Reporting System On-line spill reporting system hosted, On-line spill reporting system hosted,
controlled and maintained by the SWRCBcontrolled and maintained by the SWRCB Untreated or partially treated wastewaterUntreated or partially treated wastewater
ANY volume of waste discharged from the ANY volume of waste discharged from the sanitary sewer collection system upstream of sanitary sewer collection system upstream of a wastewater treatment planta wastewater treatment plant
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SSO CategoriesSSO Categories Category 1Category 1
Exceeds 1,000 gallons, orExceeds 1,000 gallons, or Results in discharge to surface waters, or Results in discharge to surface waters, or Discharge to storm drain and not capturedDischarge to storm drain and not captured
Category 2 Category 2 All other discharges from Enrollee’s sewer All other discharges from Enrollee’s sewer
systemsystem Private Lateral Sewage DischargePrivate Lateral Sewage Discharge
Discharges caused by privately owned lateralDischarges caused by privately owned lateral
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Application RequirementsApplication Requirements
All “known” collection systems in the State All “known” collection systems in the State database will receive an instruction letter database will receive an instruction letter from the SWRCB by July 2006.from the SWRCB by July 2006.
All “other” collection systems must also All “other” collection systems must also apply. apply. Their responsibility to go online and get Their responsibility to go online and get
informationinformation Application must be submitted by Application must be submitted by
November 2, 2006.November 2, 2006.
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(Some) Application Details(Some) Application Details
The application must be submitted to the The application must be submitted to the SWRCB, and signed by the enrollee’s SWRCB, and signed by the enrollee’s “legally authorized representative”“legally authorized representative” Must be hard copy since SWRCB needs wet Must be hard copy since SWRCB needs wet
signature of representativesignature of representative Enrollee is covered under program once Enrollee is covered under program once
completed application package approved completed application package approved by the SWRCB Division of Water Qualityby the SWRCB Division of Water Quality Tip: Don’t wait until the last minute!Tip: Don’t wait until the last minute!
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Caution!Caution!
Log on to system with username and Log on to system with username and password within 30 days of receipt of both password within 30 days of receipt of both and prior to reporting your first spilland prior to reporting your first spill Must fill out “Collection System Questionnaire”Must fill out “Collection System Questionnaire” Questionnaire must be updated every 12 Questionnaire must be updated every 12
monthsmonths
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On-Line Reporting RequirementsOn-Line Reporting Requirements
1.1. Reporting deadlines by RegionReporting deadlines by Region
2.2. Timeframes for reporting actual SSOsTimeframes for reporting actual SSOs
3.3. Required information for reportsRequired information for reports
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Phased ReportingPhased Reporting
Regions 4, 8, 9: January 2, 2007
Regions 1, 2, 3: May 2, 2007
Regions 5, 6, 7: September 2, 2007
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SSO Reporting TimeframesSSO Reporting Timeframes
Category 1 SSOsCategory 1 SSOs Initial Report ASAP but no more than 3 Initial Report ASAP but no more than 3
business daysbusiness days Final Certified Report within 15 days of Final Certified Report within 15 days of
conclusion of response and remediationconclusion of response and remediation
Category 2 SSOsCategory 2 SSOs Report within 30 days of the end of the Report within 30 days of the end of the
monthmonth
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Reporting TimeframesReporting Timeframes(continued)(continued)
Private Lateral SSOsPrivate Lateral SSOs May be reported at Enrollee’s discretionMay be reported at Enrollee’s discretion
No SSOs During MonthNo SSOs During Month Report no SSOs within 30 days of end of Report no SSOs within 30 days of end of
the monththe month
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Caution!Caution!
These requirements do These requirements do not supercede required not supercede required timeframes for reporting to timeframes for reporting to the the Office of Emergency Office of Emergency Services, County Health Services, County Health Departments and Departments and Regional Water Regional Water BoardsBoards!!!!!!!!
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Sewer System Management PlanSewer System Management Plan
1.1. Sewer System Management Plan Sewer System Management Plan (SSMP) components (SSMP) components
2.2. Phased implementation timeframes by Phased implementation timeframes by size of community servedsize of community served
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SSMP ComponentsSSMP Components
Plan and SchedulePlan and Schedule GoalsGoals OrganizationOrganization Legal AuthorityLegal Authority Overflow Emergency Response PlanOverflow Emergency Response Plan Operation and Maintenance PlanOperation and Maintenance Plan FOG Control ProgramFOG Control Program
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SSMP ComponentsSSMP Components(continued)(continued)
Design and Performance StandardsDesign and Performance Standards System Capacity Assurance PlanSystem Capacity Assurance Plan Monitoring, Measurement, and Program Monitoring, Measurement, and Program
ModificationsModifications SSMP Program AuditsSSMP Program Audits Communication ProgramCommunication Program Final CertificationFinal Certification
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SSMPSSMPFinal CertificationFinal Certification
SSMP and program to implement SSMP must SSMP and program to implement SSMP must be certified in compliance with GWDR by be certified in compliance with GWDR by Enrollee’s governing body at a public meetingEnrollee’s governing body at a public meeting Authorized representative follows up with submittal to Authorized representative follows up with submittal to
SWRCB of signed and completed form regarding SWRCB of signed and completed form regarding certification certification
Program must be internally audited every two Program must be internally audited every two yearsyears
Program must be updated at least every five Program must be updated at least every five yearsyears
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SSMPSSMPImplementation ScheduleImplementation Schedule
TaskTask Population > Population > 100,000100,000
Population Population 10,000 to 10,000 to 100,000100,000
Population Population 2,500 to 2,500 to 10,00010,000
Population < Population < 2,5002,500
Plan and Plan and ScheduleSchedule
8/02/078/02/07 11/02/0711/02/07 2/02/082/02/08 5/02/085/02/08
Goals Goals OrganizationOrganization
11/02/0711/02/07 11/02/0711/02/07 5/02/085/02/08 5/02/085/02/08
Emer. Resp. PlanEmer. Resp. Plan
Legal AuthorityLegal Authority
O&M PlanO&M Plan
FOG PlanFOG Plan
11/02/0811/02/08 5/02/095/02/09 11/02/0911/02/09 2/02/102/02/10
Design and Design and Perfor. StandardsPerfor. Standards
System Capacity System Capacity PlanPlan
Final SSMP and Final SSMP and CertificationCertification
5/02/095/02/09 8/02/098/02/09 5/02/105/02/10 8/02/108/02/10
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SummarySummary
All public owned sewer collection systems All public owned sewer collection systems in the State greater than one-mile in length in the State greater than one-mile in length must:must:
Apply for the State General Waste Apply for the State General Waste Discharge Requirements for Sanitary Discharge Requirements for Sanitary Sewer SystemsSewer Systems
Report SSOs using SWRCB on-line Report SSOs using SWRCB on-line reporting systemreporting system
Develop a comprehensive Sewer System Develop a comprehensive Sewer System Management PlanManagement Plan
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CWEA Training PlansCWEA Training Plans
CWEA is planning on conducting training CWEA is planning on conducting training for:for: On-line reportingOn-line reporting Monitoring and Reporting RequirementsMonitoring and Reporting Requirements SSMP development and implementationSSMP development and implementation
CWEA’s commitment to training has CWEA’s commitment to training has allowed compliance deadlines that were allowed compliance deadlines that were presented todaypresented today Original deadlines were unrealisticOriginal deadlines were unrealistic
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Training Goals from MOATraining Goals from MOA
General understanding of WDR requirementsGeneral understanding of WDR requirements Skills to report data using the State Water Board Skills to report data using the State Water Board
electronic reporting system, including electronic reporting system, including understanding database fields and what understanding database fields and what constitutes valid values, definitions of terms, and constitutes valid values, definitions of terms, and overview of methods of gathering the data that overview of methods of gathering the data that must be reportedmust be reported
Knowledge of Monitoring & Reporting ProgramKnowledge of Monitoring & Reporting Program Knowledge of components and timeframes for Knowledge of components and timeframes for
SSMP development and implementationSSMP development and implementation
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Training Elements from MOATraining Elements from MOA
Overview presentation of key GWDR Overview presentation of key GWDR requirementsrequirements
Hands-on exercises, examples, and Hands-on exercises, examples, and demonstrations of the data base functionalitydemonstrations of the data base functionality
Training manual for each attendeeTraining manual for each attendee Evaluation tool to gauge training program Evaluation tool to gauge training program
effectiveness (continuous improvement)effectiveness (continuous improvement) Database simulation (web-hosted)Database simulation (web-hosted) Feedback mechanism to State Water BoardFeedback mechanism to State Water Board
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CWEA Deliverables from MOACWEA Deliverables from MOA
Develop & execute a work plan to meet training Develop & execute a work plan to meet training objectives & compliance schedule. Offer objectives & compliance schedule. Offer periodic training at conferences.periodic training at conferences.
Develop presentations to meet training goalsDevelop presentations to meet training goals Develop training manualDevelop training manual Develop evaluation tool, update trainingDevelop evaluation tool, update training Work with Summit partnersWork with Summit partners Provide feedback to StateProvide feedback to State Develop dBase simulationDevelop dBase simulation
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State Deliverables from MOAState Deliverables from MOA
Modify database (resource dependent)Modify database (resource dependent) Provide access to produce dBase simulationProvide access to produce dBase simulation Review training materials & provide timely feedbackReview training materials & provide timely feedback Provide regional water board training venues & staff Provide regional water board training venues & staff
contacts as possiblecontacts as possible Develop Q&A guidance doc on GWDRDevelop Q&A guidance doc on GWDR Provide functional and responsive help deskProvide functional and responsive help desk Provide feedback on quality of inputs to dBaseProvide feedback on quality of inputs to dBase Post CWEA training announcementsPost CWEA training announcements Provide agency contact information to CWEAProvide agency contact information to CWEA
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CWEA SSO WDR Training Task Force Chair
Nick Pinhey, CWEA
dBase Work GroupWarren
Tellefson
CWEA Planning & Program Development Board
Committee
Training Design Team
Kathy Suter
Training Roll Out TeamJulie Taylor
Subject Matter Experts
Sandbox Testers
CWEA Staff
Trainers
Advisory Group
CWEA SSO WDR Training Task Force
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Training model highlightsTraining model highlights
Instructional designerInstructional designer Develop course curriculumDevelop course curriculum Develop training manualDevelop training manual Lead train-the-trainerLead train-the-trainer
Screen qualified volunteer speakersScreen qualified volunteer speakers Train-the-trainer sessions for qualified volunteer Train-the-trainer sessions for qualified volunteer
speakers led by instructional designerspeakers led by instructional designer Offer information in several “modes”Offer information in several “modes” SSMP 101, 201?, 301?SSMP 101, 201?, 301?
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Stay Tuned!Stay Tuned!
Training is in development & will roll out in FallTraining is in development & will roll out in Fall• Beta Tests at NRTC 9/17 and Tri-State Seminar 9/30Beta Tests at NRTC 9/17 and Tri-State Seminar 9/30
• Regions 4, 8, 9 Targeted roll out late October– December Regions 4, 8, 9 Targeted roll out late October– December 20062006
• Regions 1, 2, 3 Targeted roll out February– April 2007Regions 1, 2, 3 Targeted roll out February– April 2007
• Regions 5, 6, 7 Targeted roll out May – August 2007Regions 5, 6, 7 Targeted roll out May – August 2007 Focus first on Monitoring and Reporting and On-line Focus first on Monitoring and Reporting and On-line
reportingreporting
Check Check www.cwea.org/ssowww.cwea.org/sso often for updates on often for updates on training, resources, presentations you can usetraining, resources, presentations you can use
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How you can helpHow you can help TrainersTrainers
50 students in each 4 hour session. Two sessions per 50 students in each 4 hour session. Two sessions per each training day (8 hours of facilitation for trainer per each training day (8 hours of facilitation for trainer per day). day).
Experiential training, using real-world case studies Experiential training, using real-world case studies Facilitation role for the qualified volunteer trainers selectedFacilitation role for the qualified volunteer trainers selected Trainers selected to deliver the training will participate in a Trainers selected to deliver the training will participate in a
Train-the-Trainer session (1 day) and will be asked to Train-the-Trainer session (1 day) and will be asked to commit to facilitate at least 2 days of training. Estimated commit to facilitate at least 2 days of training. Estimated volunteer hours = 3-6 days per trainer.volunteer hours = 3-6 days per trainer.
Submit trainer interest form: www.cwea.org/ssoSubmit trainer interest form: www.cwea.org/sso VenuesVenues [email protected]@cwea.org
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Thank you!Thank you!
Nick Pinhey, Public Works Director, City of Nick Pinhey, Public Works Director, City of ModestoModesto CWEA SSO WDR Training Task Force ChairCWEA SSO WDR Training Task Force Chair [email protected]@cwea.org
www.cwea.org/ssowww.cwea.org/sso