CWEA NTC 2008: Statewide SSO General OrderSlide 1 “You, Me and the SSO GWDR” (Order No. 2006-0003-DWQ) James Fischer, P.E. Water Resource Control Engineer

CWEA NTC 2008: Statewide SSO General Order Slide 1

“You, Me and the SSO GWDR” (Order No. 2006-0003-DWQ)

James Fischer, P.E.

Water Resource Control Engineer

Division of Water Quality

State Water Resources Control Board, Sacramento


Overview

1. Background on Statewide SSO General Waste Discharge Requirements (GWDR) Permit

2. Current Program Status

3. Outreach and Training

4. Common Questions and Answers

5. Program Issues


Background on SSO GWDR

• 2004: State Water Resources Control Board passed a Resolution to reduce number and volumes of SSOs

• Provides streamlined approach to permitting collection systems compared with numerous Regional Water Board permits

• GWDR modeled after USEPA Capacity, Management, Operations and Maintenance (CMOM) Program

• GWDR adopted May 2, 2006 to address SSOs in consistent/uniform manner throughout the state

• First comprehensive regulatory program in the nation to comprehensively address sanitary sewer systems (both for reporting spills and collection system management)



• Applicability: Requires any publicly-owned agency with a collection system (sewer pipes) greater than one mile in length and connected to publicy-owned treatment facility (regardless of treatment technology) to enroll for coverage

• Collection systems must be individually enrolled regardless of number owned



• Notice of Intent (NOI) initially mailed out to “potential enrollees” on June 16, 2006

• Application for Coverage was required by all applicable collection systems by November 2, 2006

• 1,100 Collection Systems Currently Enrolled (Sept 2008)– Represents over 840 collection system local agencies– Notice of Non-Applicability filed by several dozen agencies– Website:

www.swrcb.ca.gov/water_issues/programs/sanitary_sewer_overflow/– Type “Sanitary Sewer Overflow” in State Board “search” box

http://www.swrcb.ca.gov/water_issues/programs/sanitary_sewer_overflow/


SSO GWDR Website


GWDR Permit Requirements


GWDR Permit Requirements:Enrollment and NOI

• State Board Staff Primary: DWQ/WDR Unit• Regional Boards (RBs): Secondary: perform follow-

up only on “as-needed” basis– Combined efforts successfully obtained NOI

responses from 98% of all known “potential enrollees”

– Outstanding agencies must either enroll or request and complete a “Notice of Non-Applicability” for coverage and send to State Board


GWDR Permit Requirements: Reporting Schedule

• Enrollees required to begin reporting SSOs via CIWQS according to following schedule:– Regions 4, 8, 9 January 2, 2007– Regions 1, 2, 3 May 2, 2007– Regions 5, 6, 7 September 2, 2007


GWDR Permit Requirements:Misc.

1. Enrollment / establishment of Legally Responsible Official (LRO)

2. Maintain compliance with SSO MRP (2/20/2008 version)

3. Complete mandatory Collection System Questionnaire (must be completed within 30 days of enrollment & updated annually or no SSOs may be reported)

3. Must electronically report any SSO or do a monthly “No-Spill” Certification” if no SSOs for any individual calendar month

4. Develop and Implement Sewer System Management Plan (SSMP):- Ensures proper management, operation and maintenance - Supports State’s WDR regulatory goals- Provides State with ability to compare SSO reports with adopted SSMP

elements to measure effectiveness of individual local agency collection system operations, maintenance and management practices


GWDR Permit Requirements:Notification/Reporting

Category 1 SSO: ANY volume:1) Reached a surface water; or2) Entered storm drain pipe and not fully captured/returned to sewer; or3) >1,000 gallons

Category 2 SSO: any other SSO not meeting definition for Category 1

NOTIFICATIONCategory 1 SSO: 2hrs to notify OES, local health, and Regional Water Board of SSO;

24hrs to certify to Regional Board that OES/local health were notifiedCategory 2 SSO: none

REPORTING (CIWQS) Category 1 SSO: 3 days to “Submit Draft” and 15 days to “Certify” Category 2 SSO: 30 days to “Certify”


GWDR Permit Requirements:SSMP Required Elements

i. Plan and Schedule (requires local gov. board ok)ii. Organizationiii. Legal Authorityiv. Operation and Maintenancev. Design and Performancevi. Overflow Emergency Responsevii. Fats, Oils and Grease (FOG)viii. Systems Evaluation and Capacity Assuranceix. Monitoring, Measurement and Program Mods.x. SSMP Auditsxi. Communication Programxii. Final Certification (requires local gov. board ok)


GWDR Permit Requirements:SSMP Requirements

• Enrollee “self approves” all SSMP Task Elements and Certifies in CIWQS online when each element is completed– Element schedule on SSO Website– All SSMPs will be fully implemented by

August 2, 2010• Regional Boards can review SSMPs upon

request (approval is not required)


Current Program Status


SSO “Non-Responsive Agency Trend


SSO GWDR Enrollment Trend


Statewide Reporting Compliance

01020304050607080

Sep-07

Oct-07

Nov-07

Dec-07

Jan-08

Feb-08

Mar-08

Apr-08

May-08

Jun-08

SSO Statewide Reporting Compliance (%)

Series1 62 61 60 60 59 56 65 68 68 74

Sep-07 Oct-07 Nov-07 Dec-07 Jan-08 Feb-08 Mar-08 Apr-08 May-08 Jun-08


Collection System Questionnaire Compliance

19%

81%

0%

50%

100%

Collection System Questionnaire Compliance (%)

Series1 19% 81%

Not Completed Total Statewide


CIWQS SSO Report Statistics

0

10,000,000

20,000,000

30,000,000

40,000,000

Jan 2007 to Sept 2008 (7,265 Certified SSO Reports)

Series1 33,056,093 25,137,471 11,996,711

Total Vol of SSOs (gal)

Total Vol Reach Surface Water

Total Vol Recover (gal)


Common Questions and Answers


Common Questions

• What if my agency has a collection system(s) that meets the minimum GWDR requirements and has still not applied for coverage under the SSO General Order?

• What if my agency has not yet “Certified” any of the required SSMP task elements?

• What if my agency has missed “No Spill Certifications” for any months without any SSOs?


Answers

To avoid enforcement action, your agency must:

• Enroll any applicable collection systems(s) for coverage under SSO GWDR

• Update all records in CIWQS, including any information back to the date when mandatory reporting was required within your Region (see website for details)


Outreach and Training Resources

http://cwea.org/index.shtml


Outreach

• Blanket and Direct emails (using email addresses pulled from our CIWQS system)– Non-Compliance with Reporting Requirements– Communicate other pertinent program information

• SSO Website to be redesigned and will soon host more data, including all Enrollee compliance status

• State Board continues to coordinate outreach with CWEA / CVCWA / BCWA and other trade organizations


Outreach

CIWQS SSO External User Group– Represents 40+ Enrollees (large and small

collection systems)– Extensive tracking of all technical CIWQS/SSO

Program-related issues– Regular testing, review and comment on CIWQS

changes prior to production roll-out– Quarterly meetings (participation also available

via conference call and WEBEX)– Email us if interested in participating

([email protected])


Training Resources• CWEA has MOA with State Water Board

– SSO Program training classes and outreach

• CVCWA, CRWA and others conducting extensive training on SSO GWDR throughout California

• Regional Board staff being trained internally on GWDR and attending some statewide training classes

• CWEA Training Calendar:www.cwea.org/calendar.shtml


SSO Discharger User Guide• Available on CIWQS (SSO) websitewww.waterboards.ca.gov/water_issues/programs/ciwqs/chc_sso.shtml


CWEA MOA/Training


Current SSO Program Issues



• CIWQS Reporting Compliance ~ 74%

• CIWQS Questionnaire Compliance ~ 81%

• CIWQS SSMP Certification Elements Input ~ 50%

• MRP (2/20/08 version) is inconsistent with Water Code and some GWDR Requirements– Q&A under development– Program review 2009 will address inconsistencies



• SSO Program Review– Begins in May 2009– Board will consider “re-opening” GWDR– Will include extensive public outreach

including workshops around the state– Industry encouraged to participate, attend

workshops and provide input


Beta (draft) SSO Mapping Tool

• Presents all individual SSO and Private Lateral Sewage Discharge data in CIWQS reported to date in a map format

• Serves as an SSO data Q/A & Q/C tool• Dischargers have been given the opportunity

to review and correct any data errors before public posting in November 2008


Beta (draft) SSO Mapping Tool


Program Contacts

• Usernames/Passwords/Registration/Data Issues:CIWQS HELP CENTER

1-866-792-4977 (M-F, 8am-5pm)[email protected]

• SSO Program Technical Assistance:James Fischer, P.E.

Program Lead / Statewide SSO Program 916-341-5548

[email protected]

mailto:[email protected]

mailto:[email protected]

Documents

CWEA NTC 2008: Statewide SSO General OrderSlide 1 “You, Me and the SSO GWDR” (Order No. 2006-0003-DWQ) James Fischer, P.E. Water Resource Control Engineer