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SWRCB Adopts Waste Discharge Requirement

On May 2, 2006, the State Water Resources Control Board (SWRCB) adopted a General Waste Discharge Requirement (WDR) for all publicly owned sanitary sewer collection systems in California with more than 1 mile of sewer pipe. The goal of the WDR is to provide a consistent statewide approach for reducing Sanitary Sewer Overflows (SSOs). The WDR requires that:

  1. In the event of an SSO, all feasible steps be taken to control the released volume and prevent untreated wastewater from entering storm drains, creeks, etc.

  2. If an SSO occurs, it must be reported to the SWRCB using an online reporting system developed the SWRCB. (Note: All spills greater than 1000 gallons still must be reported to the Office of Emergency Services, as is currently required.)

  3. All publicly owned collection system agencies with more than 1 mile of sewer pipe in the State develop must develop a Sewer System Management Plan (SSMP). The WDR specifies mandatory elements that must be included in the SSMP. The SSMP must be made publicly available.

The above is just a summary of key provisions in the WDR. You are encouraged to review the full text and requirements to understand how your collection system agency will be affected by the WDR. The final document should be available by Monday, May 8, 2006, on the SWRCB web site at http://www.waterboards.ca.gov/sso.

The WDR contains a schedule for implementation of the online reporting and SSMP requirements. Below is a summary of the schedules. The schedules initially proposed by the SWRCB were much tighter than those shown below. At the public hearing on May 2, 2006, the SWRCB agreed to modify the schedule based on its recognition that training is needed to assist with the successful implementation of the online reporting and SSMP development and based on the wastewater communities stated commitment to provide such training. CWEA, CASA, SCAP, BACWA, CVCWA, and the League of California Cities will be working to develop training materials to assist collection system agencies with understanding the reporting requirements and SSMP requirements contained in the WDR. More details on these materials will be made available in the near future.

Implementation Schedules:

On Line Reporting:
All Collection System Agencies are required to begin on-line reporting by October 2006 (within 6 months of WDR adoption) unless the State Water Board Executive Director enters into a memorandum of agreement (MOA) with wastewater associations by July 1, 2006 to provide training to the approximately 1,500 agencies covered by the new requirements. If the MOA is in place, compliance with the reporting requirements will be phased-in by region over a 16-month timeframe as noted below.

  • Collection System Agencies in Regions 4, 8, and 9: No later than January 3, 2007
  • Collection System Agencies in Regions 1, 2, and 3: No later than May 3, 2007
  • Collection System Agencies in Regions 5, 6, and 7: No later than September 3, 2007

SSMP Development:
This is being implemented based on the size of the population served by the Collection System Agency. There are four categories: population greater than 100,000; population between 100,000 and 10,000; population between 10,000 and 2,500; and population less than 2,500. There are nine specific “milestones” identified in the schedule that relate to the specific elements required in the WDR. For more detailed information on these requirements you are encouraged to read the full description in the WDR. The nine milestones include:

  1. SSMP Development Plan and Schedule
  2. Goals and Organization Structure
  3. Overflow Emergency Response Program
  4. Legal Authority
  5. Operation and Maintenance Program
  6. Grease Control Program
  7. Design and Performance Standards
  8. System Evaluation and Capacity Assurance Plan
  9. Final SSMP, incorporating all the SSMP elements.

The SWRCB made a number of changes to the proposed implementation schedule for the SSMP development during the meeting on May 2. SWRCB staff is incorporating those changes and they should be available at the above referenced web site by Monday, May 8, 2006.

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