Regulatory / WDR Update

Regulatory / Regulatory / WDRWDR

UpdateUpdateWhat’s Going On?What’s Going On?

Waste Discharge Waste Discharge RequirementsRequirements

Adapted by the State Water Resources Adapted by the State Water Resources Control Board on May 2, 2006Control Board on May 2, 2006

Implementation based on populationImplementation based on populationComplete implementation by August Complete implementation by August

20102010WDRs do not sunsetWDRs do not sunsetTriennial Review processTriennial Review processStakeholder involvement encouragedStakeholder involvement encouraged

SSO Users GroupSSO Users Group

Public comment meetings 2009Public comment meetings 2009Southern CaliforniaSouthern CaliforniaNorthern CaliforniaNorthern California

Order Review CommitteeOrder Review CommitteeReview SSMP ElementsReview SSMP ElementsReview reporting requirementsReview reporting requirementsMantis ListMantis List

Data Review CommitteeData Review Committee

Mantis List UpdateMantis List Update

Data Review CommitteeData Review Committee

1.1. Refine the CIWQS SSO spill report Refine the CIWQS SSO spill report form data fields form data fields

2.2. Re-design the SSO spill report form Re-design the SSO spill report form to be event not location basedto be event not location based

3.3. What indices of Collection System What indices of Collection System performance should be used to performance should be used to compare collection systems in compare collection systems in California? California?

Performance IndicesPerformance Indices

Current indexCurrent index # spills per 100 miles of pipe per year# spills per 100 miles of pipe per year Under 3 – Over 6Under 3 – Over 6

Prospective IndicesProspective Indices

1.1. Number of Spills (or Volume of Number of Spills (or Volume of Spills) per 100 miles of pipeline. Spills) per 100 miles of pipeline.

2.2. Number of Spills (or Volume of Number of Spills (or Volume of Spills) per capita. Spills) per capita.


3.3. Number of Category 1 spills (or Number of Category 1 spills (or Volume of Spills); number of Volume of Spills); number of Category 2 spills (or Volume of Category 2 spills (or Volume of Spills). Spills).

4.4. Number of Spills (or Volume of Number of Spills (or Volume of Spills) by pipe diameter or pipe Spills) by pipe diameter or pipe area.area.

5.5. Number of Spills (or Volume of Number of Spills (or Volume of Spills) by volume class of spill. Spills) by volume class of spill.


6.6. Separate out number of spills (or Separate out number of spills (or Volume of Spills) by portion of Volume of Spills) by portion of collection system pump station, force collection system pump station, force main, gravity, lateral. main, gravity, lateral.

7.7. Separate out spills (or Volume of Separate out spills (or Volume of Spills) caused by outside contractors. Spills) caused by outside contractors.

8.8. Number of Spills (or Volume of Spills) Number of Spills (or Volume of Spills) by cause category (fog, roots, debris, by cause category (fog, roots, debris, etc.).etc.).


9.9. Gallons Conveyed versus Gallons Gallons Conveyed versus Gallons Spilled versus Gallons Recovered Spilled versus Gallons Recovered versus Gallons Reach Surface versus Gallons Reach Surface water. water.

10.10. Volume of Spills per Year by Total Volume of Spills per Year by Total Volume Conveyed (measured or Volume Conveyed (measured or estimated based upon population estimated based upon population served).served).

MiscellaneousMiscellaneous

Data shows that smaller pipes have Data shows that smaller pipes have more frequent SSOsmore frequent SSOs

Smaller systems tend to have more Smaller systems tend to have more SSOs per mile than larger systemsSSOs per mile than larger systems

Roots tend to be the primary source Roots tend to be the primary source of SSOs statewideof SSOs statewide

A new reporting category (3) A new reporting category (3) maymay be be developed for very small SSOs. developed for very small SSOs.

Additional InformationAdditional Information

Google GroupsGoogle GroupsSSO Data Review CommitteeSSO Data Review Committee

Non committee members can review all Non committee members can review all posted dataposted data

Non committee members can not post Non committee members can not post to the groupto the group

Opening the Opening the WDRWDR

Opening the WDROpening the WDRDraft of new Order scheduled for public Draft of new Order scheduled for public

release in late July or August 2010release in late July or August 2010Public comment periodPublic comment periodPresentation to SWRCB for adoption in Presentation to SWRCB for adoption in

November 2010 – Public hearingNovember 2010 – Public hearingAdoption by SWRCB in December 2010Adoption by SWRCB in December 2010Anticipated that most changes will be Anticipated that most changes will be

administrativeadministrativeMRP changes and notification MRP changes and notification

streamlinedstreamlined

AUDITS X 2AUDITS X 2

Audits - StateAudits - StateSWRCB intends on conducting at least SWRCB intends on conducting at least

2 audits per Region2 audits per RegionAudits will be conducted in Audits will be conducted in

conjunction with Regional staffconjunction with Regional staffAudits may be random or selected Audits may be random or selected

based upon reporting historybased upon reporting historyZero spills as likely as numerous spillsZero spills as likely as numerous spillsEPA Region 9 online audit filesEPA Region 9 online audit files

Regions may conduct additional Regions may conduct additional auditsaudits

Some Regions already conducting Some Regions already conducting enforcementenforcement

SSMP Audit RequirementsSSMP Audit Requirements

The SSMP requires that each agency The SSMP requires that each agency conduct an audit every two years conduct an audit every two years based upon the date that the final based upon the date that the final SSMP was approvedSSMP was approved

Audits must remain on file and be Audits must remain on file and be available to the State or Regional available to the State or Regional Boards upon requestBoards upon request

Audits are performance based and Audits are performance based and should reflect all elements of the should reflect all elements of the SSMPSSMP

3 Key SSMP Elements - Audits3 Key SSMP Elements - Audits

SSMP is an asset management SSMP is an asset management programprogram

GoalsGoals

Monitoring, Measurement, and Monitoring, Measurement, and Program ModificationsProgram Modifications

SSMP Program AuditsSSMP Program Audits

GoalsGoals

SpecificSpecificAttainableAttainableMeasurableMeasurablePrioritizedPrioritizedModify as neededModify as neededAdd or delete goals as neededAdd or delete goals as needed

Goals - ExampleGoals - Example

1.1. Eliminate all SSOs including those Eliminate all SSOs including those caused by rootscaused by roots

2.2. By (date) identify all root prone By (date) identify all root prone areas in the system; develop a areas in the system; develop a remediation strategy; review the remediation strategy; review the effectiveness of the root effectiveness of the root remediation program and its effect remediation program and its effect on SSOson SSOs

Monitoring, Measurement, Monitoring, Measurement, and Program Modificationsand Program ModificationsOngoing evaluation of SSOsOngoing evaluation of SSOs

Cause, response, frequency, category, Cause, response, frequency, category, damagedamage

Ongoing evaluation of maintenance Ongoing evaluation of maintenance practices and inspectionspractices and inspections

Ongoing effectiveness of FOG, root or Ongoing effectiveness of FOG, root or other special programsother special programs

Revenue and expenseRevenue and expense

SSMP Program AuditsSSMP Program Audits

Formal written audit due every two Formal written audit due every two years based upon the date that years based upon the date that original SSMP was approvedoriginal SSMP was approved

Performance orientedPerformance orientedPertains to all elements of the SSMPPertains to all elements of the SSMPDocument any changes to the SSMP Document any changes to the SSMP

since last auditsince last auditMaintain on fileMaintain on file

Questions / Questions / DiscussionDiscussion

Documents

Regulatory / WDR Update