59 month compliance schedule

This presentation is designed to assist permittees in understanding what requirements are due in the first year.

The content is provided for general

information purposes and is not intended to replace any part or condition of the NJPDES CSO permit. Please refer to your NJPDES CSO permit for the most accurate information.

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Review the CSO Submittal Summary and Facility Submittals pages located after the cover letter of the permit. These summaries are also tailored to each individual permittee.

The CSO Submittal Summary is broken into two tables (in

chronological and permit order, respectively):

• The first table represents reports that need to be submitted to the Department.

• The second table represents items that are to be maintained on-site for use and review, but not submitted to the Department.

For more details on each condition, you can refer to the permit

condition referenced. 3

DMR Submission for Solids/Floatables and Precipitation

Begin collecting Solids/Floatables and Precipitation data on July 1, 2015 (EDP) DMR Due Date: August 25, 2015 (and monthly thereafter) Location in Permit: Part III – Limits and Monitoring Requirements - for the FIRST CSO outfall ONLY Additional Information: • DMR Training www.nj.gov/dep/dwq/cso-events.htm

• Response to Comments document: Section A, pages 68-71

• See FAQ #12, page 4 www.nj.gov/dep/dwq/pdf/cso-faqs-03-

11-2015.pdf 4

• Install or determine the location of an existing rain gauge(s) within the CSS or an alternate appropriate location.

• Begin keeping daily records of precipitation and

solids/floatables on July 1, 2015 so that reports can be completed at month’s end.

• Be sure to understand the reporting requirements for Solids/Floatables and “Precipitation” • DMR training at http://www.nj.gov/dep/dwq/cso-events.htm

• ***Register for EDI to allow for electronic submissions of DMRs (see www.state.nj.us/dep/dwq/mrf.htm).

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Quarterly Progress Reports

• Begin keeping track of activities related to all permit requirements on July 1, 2015 (EDP)

• Report Due Date: October 25, 2015 (and quarterly thereafter)

• Location in Permit: Part IV.D.4.a

• Response to Comments document: Section B, pages 133-136

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DMR Submission for “Duration of Discharge”

Begin collecting Duration of Discharge data on January 1, 2016 (EDP + 6 months) DMR Due Date: February 25, 2016 (and monthly thereafter) Location in Permit: Part III (For ALL CSO outfalls) Additional Information:

• DMR Training www.nj.gov/dep/dwq/cso-events.htm

• Response to Comments document: Section A, pages 68-71

• See FAQ #12, page 4 www.nj.gov/dep/dwq/pdf/cso-faqs-03-

11-2015.pdf 7

• Begin keeping daily records of the days during which a CSO discharge occurred beginning on January 1, 2016 so that reports can be completed at month’s end.

Measurement Options:

• Use updated collection system model to predict overflows based on

various weather events

• Install “alternate apparatus” such as a chalk line, wooden block on rope/chain etc.

• Flow meter or sensor 8

Submit GPS latitude and longitude for pump stations, CSO regulators and CSO outfalls

Due Date: January 1, 2016 (EDP + 6 months) Location in Permit: Part IV.D.2.a Response to Comments document: Section B, pages 100-102 How to prepare: • Review existing GPS data to identify which pump stations, regulators

and outfalls need to be GPS’d • Note: The Department may have some of this GPS data that can be shared and

verified to reduce resource burden.

• Hire contractor or acquire GPS equipment and assign staff to begin performing work. • Note: there are accuracy standards of at least 0.1 seconds and hand held smart

phone apps alone do not provide adequate accuracy. Receiver devices, such as the Trimble’s R1 GNSS Receiver, www.trimble.com/mappingGIS/R1-GNSS-Receiver, enables users to collect higher-accuracy location data with a device you already have, such as a smart phone.

• Contact county offices to assess available GPS resources/data. 9

Work Plan for the System Characterization

a.k.a.

Characterization, Monitoring and Modeling of the CSS

Due Date: January 1, 2016 Location in Permit: Part IV.D.3.b.i and Part IV.G.1 Response to Comments document: Section B, pages 112-114 and Section D, pages 230-241 10

• Review DEP guidance available at www.state.nj.us/dep/dwq/pdf/cso-receiving-water-mon-work-plan-guid-03-2015.pdf

• Rainfall Records: Review historical rainfall records for CSS area and evaluate flow variations in receiving waters to correlate between CSO discharges and receiving water conditions

• Combined Sewer System Characterization: Evaluate existing information regarding the number, location, and frequency of overflows, proximity to Sensitive Areas and other pollution sources, such as SIUs. • Update information – has anything changed since the model was

developed? For example, are there more or less outfalls? Have any sewers been separated? Have any CSO pumps been installed? 11

• .

• CSO Monitoring and Modeling: • Choose which Sewer System Model (e.g. Stormwater Management Model

or SWMM) will need to be used or updated (reflective of characterization data).

• Review applicability of existing data that was collected under an

approved QAPP for the receiving waterbody (e.g. Storet)

• Evaluate where ambient monitoring will need to be collected, if outfalls should be grouped, what pathogens will need to be sampled, etc.

• Note that the initial ambient monitoring under Part IV.G.9 can be

combined with this monitoring. 12

Compliance Monitoring Program Work Plan Due Date: January 1, 2016 (EDP + 6 months) Location in Permit: Part IV.D.3.c and Part IV.G.9 Response to Comments document: Section B, pages 119-121; Section D, pages 292-302 How to prepare for this:

• As for the previous Work Plan, review applicability of existing data that was collected under an approved QAPP for the receiving waterbody (e.g. Storet)

• Evaluate where ambient monitoring will need to be collected, if outfalls should be grouped, what pathogens will need to be sampled, etc.

• Review DEP guidance available at:

www.state.nj.us/dep/dwq/pdf/cso-receiving-water-mon-work-plan-guid-03-2015.pdf • Contact team leader to schedule discussion of work plans and site visit for

location selection 13

These are reports or requirements are

required to be completed and RETAINED ON-SITE.

These requirements are in the second table of the CSO Submittal Summary.

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Install CSO Outfall Signs

Due Date: January 1, 2016 (EDP + 6 months) Location in Permit: Part IV.D.2.c & IV.F.8 Response to Comments document: Section C, pages 219-220

How can I prepare for this? • Confirm with the Department that design meets the

requirements of the permit pertaining to size, information, and posting.

• Evaluate if alternate posting methods need to be approved

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Characterization of the System’s infrastructure

Due Date: January 1, 2016 (EDP + 6 months) – Retain report on-site Location in Permit: Part IV.F.1.f Requirement: Under the Operations & Maintenance Program and Manual section for the sewer system characterization, develop a spreadsheet of the system’s infrastructure (list of sewer system components and SIUs) organized by related CSO outfall. Response to Comments document: Section C, pages 149-157 16

• Determine where infrastructure components and SIUs are in the permittee’s sewer system. • Are additional staff or equipment needed to complete this

task?

• Are there any areas where ownership is in dispute?

• The Department can assist with SIU locations and information if necessary.

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Revise Rules or Agreements with customer municipalities regarding

I/I requirements Due Date: January 1, 2016 (EDP + 6 months) – Retain on-site Requirement and corresponding permit condition: Create anticipated schedule to revise Rules/Ordinances/Sewer Use Agreements to reduce I/I (Part IV.F.1.h)

Response to Comments: Section C, pages 159-160; 212-214 How do I prepare for this? • If there are no customer municipalities, just state so in the Progress

Reports. • Review existing Rules, Ordinances or Sewer Use Agreements and

determine which need to be revised. • Contact customers to begin discussions to revise agreements. • Revise Rules or Ordinances as required. 18

Due Date: July 1, 2016 (EDP + 1 year)

Location in Permit: Part IV.D.2.b

Response to Comments document: Section B, pages

102-104

How Do I Prepare for this?

• Review existing maps, etc. to determine if area owned/operated by the permittee has been mapped and is still accurate – and what additional work is necessary

• Assign staff or hire contractor begin performing additional work.

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Telephone Hot Line or Website Due Date: July 1, 2016 (EDP + 1 year) – Maintain on-site Requirement: Create and maintain Telephone Hot Line or Website (Part IV.F.8.c.iii) How can I prepare for this: • Determine if you will create a separate hot line or a

website or join somebody else’s?

• Is contractor needed to assist in development? 20

Update O&M Manual and include Asset Management Plan

Due Date: July 1, 2016 (EDP + 12 months) (and at least annually thereafter) – Retain report on-site Requirement and corresponding permit condition:

• Update O&M Program and Manual.

• Include Asset Management Plan and updated SOPs,

and Emergency Plan (Part IV.D.4.b.iv and IV.F.1.a & k). 21

But there are Other Plans and Reports to be submitted to the Department in future years that need to be started this year... 22

Characterization, Monitoring and Modeling Report

aka - System Characterization Report

Due Date: July 1, 2018 (EDP + 3 years) Requirements: • Submit System Characterization Report (Part IV.D.3.b.ii)

• DEPENDENT on NJDEP’s approval of work plan and weather

How do I prepare for this?

Compile existing data and conduct sampling as per Departmentally approved CSS Characterization, Monitoring and Modeling Work Plan

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Due Date: July 1, 2018 (EDP + 3 years)

Requirements: Submit Compliance Monitoring Report (Part IV.D.3.d) • DEPENDENT on NJDEP’s approval of work plan and

weather

How do I prepare for this? ◦ Compile existing data and conduct sampling as per

Departmentally approved Compliance Monitoring Program Work Plan

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Due Date: July 1, 2018

Requirements: Submit Public Participation Plan (Part IV.D.3.b.iii)

How do I prepare for this? • Conduct ‘Outreach’ during LTCP development using methods such

as public meeting, direct mailers, billing inserts, newsletters, press releases, website, hotline, developing advisority committees, etc.

• Invite members of the affected/interested public to join a Supplemental CSO team that will work as a liason group with the permittee assigned staff. 25

Due Date: July 1, 2018 (EDP + 3 years)

Requirements: Submit Consideration of Sensitive Areas Plan (Part IV.D.3.b.iv)

How do I prepare for this? ◦ Review location of all CSO outfalls.

◦ Determine proximity of each CSO outfall to designated Sensitive Areas.

◦ Determine if elimination or relocation of those CSO outfalls is possible.

◦ If not possible, evaluate treatment options. 26

Development and Evaluation of Alternatives Report

Due Date: July 1, 2019 (EDP + 4 years) Requirement: Submit Development and Evaluation of Alternatives Report (Part IV.D.3.b.v and IV.G.4) Response to Comments document: Section D. Responses to Comments 60-149. 27

How do I prepare for this? • Review all permit requirements • Comply with all Nine Minimum Controls (Part IV.F) • Characterize sewer system (Part IV.F.1) • Complete Characterization, Monitoring and Modeling

Report (Part IV.G.1) • Conduct Public Participation Program (Part IV.G.2) • Conduct Sensitive Area Evaluation (Part IV.G.3) • Evaluate all CSO Control Measures for each outfall (Part

IV.G.4) • 7 measures – can be alone or in combo for each outfall • Choose Presumption or Demonstration Approach

• Conduct Cost Performance Considerations (Part IV.G.5) • Maximizing Treatment at the STP (Part IV.G.7) 28

Due Date: June 1, 2020 (EDP + 59 months)

Requirement: Submit Selection and Implementation of Alternatives Report for the Final LTCP (Part IV.D.3.b.vi and

IV.G.1 thru G.10) How do I prepare for this? ◦ Submit and receive Departmental Approval for the Development and

Evaluation of Alternatives Report ◦ Base the Final LTCP on the approved Development and Evaluation of

Alternatives Report ◦ Develop an Operational Plan for the new SO Control Measures to be

implemented (Part IV.G.6) ◦ Develop an Implementation Schedule for construction and financing

schedule for approved CSO Control Measures (Part IV.G.8) ◦ Develop Compliance Monitoring Program sampling schedule based on CSO

Control Measure implementation milestones (Part IV.G.9) 29

Thank you for your attention.

Questions??

Please contact your Team Leader whenever you need additional assistance.