Sanitary Sewer System General Order


On Dec. 6, 2022, the State Water Resources Control Board unanimously adopted the Statewide Sanitary Sewer Systems General Waste Discharge Requirements Order Reissuance (SSS WDR). The new regulations are set to go into effect on June 5, 2023.

The Water Board explained that the SSS WDR order reissuance will regulate sanitary sewer systems designed to convey sewage longer than one mile in length and addresses reporting and other requirements in response to sanitary sewer overflows. In this case, a sanitary sewer overflow is any overflow, spill, release, discharge, or diversion of untreated or partially treated wastewater from a sanitary sewer system.

More information on the new reissued SSS WDRs can be found at

During this Featured Track at CWEA’s AC23, three separate sessions will include subject matter that will update participants on some of the new regulations.

James E. Fischer, Jr., Fischer Compliance

James E. Fischer, Jr., Fischer Compliance

Wednesday, April 19, 2023
11:00 AM – 12:00 PM
James E. Fischer, Jr., Fischer Compliance, Principal Jed Beyer, West Bay Sanitary District, Water Quality Manager

During this morning session, Fischer and Beyer will update participants on the latest practices on avoiding being a target for inspections, violations, and fines by the SWRCB and preparing for audits of Sewer System Management Plan. The speakers will also give insightful advice on how to prepare regulatory scrutiny from inspectors, and non-governmental organizations (NGOs).

It’s been over 16 years since the initial adoption of California’s Sanitary Sewer Systems Waste Discharge Requirements (SSS WDR). Fischer and Beyer have over 50 years of combined experience are Legally Responsible Officials (LROs), data submitters, leads, supervisors, and managers with specific case studies and strategies for managing your collection system “like your mission statement says.”

James E. Fischer, Jr. has over 33 years of professional regulatory experience in both the public and private sectors. He retired from the State Water Resources Control Board as statewide lead for collection system compliance and enforcement, and started Fischer Compliance, LLC in September of 2020. Through his company, he serves municipalities with best practice support for reducing
risks, enforcement risks, and optimizing compliance.

Fischer’s expert consulting services include Sewer System Management Plan (SSMP) audits, SSMP updates, and ‘simulated’ regulatory inspections to help agencies meet and exceed the requirements of the WDRs.

Jed Beyer has more than 20 years of service with West Bay Sanitary District, beginning his career as a maintenance technician and working his up to the position of Water Quality Manager. Beyer’s field of work requires meticulous attention to detail, as laws and regulations are continuously changing, which necessitates frequent updates to policies, protocols, and procedures. He engages a strategic approach to managing a wide spectrum of issues and regularly collaborates with industrial, commercial, and residential customers to conceptualize, design, and review complex plans for wastewater flow, storage, discharge, and treatment to meet strict environmental regulations.

Currently, Beyer’s scope of experience includes OSHA regulation, safety training, regulatory compliance, wastewater collection systems, EPA regulations, risk management, reporting and documentation, SMART Goals, pretreatment facility inspections, and emergency response.

Paul H. Causey, Causey Consulting, Principal

Paul H. Causey, Causey Consulting, Principal

Wednesday, April 19, 2023
9:45 AM – 10:45 AM PST
Paul H. Causey, Causey Consulting, Principal

During this mid-morning session, Paul Causey from Causey Consulting will speak on what’s new with SSS WDR after more than three years of California State Water Resources Control Board and stakeholder collaborations regarding the waste discharge requirements for sanitary sewer systems impacting 1200 public collection systems across California.

During the collaboration, Causey chaired a group of stakeholders that includes six professional executive officers and many of the enrolled agency representatives negotiating directly with the SWRCB SSO office staff. His group submitted extensive comments and redlines, as well as attended all Staff WDR workshops on the indirect and draft SSS WDR documents circulated by the SWRCB staff.

Mr. Causey will discuss the Dec. 6, 2022 adopted SSS WDR and the important changes and implementation timing that an enrolled agency will be required to comply with its sanitary sewer programs with the new SSS WDR.

Some of the important changes that will be covered during this session include:

  • Re-enrollment requirements for currently enrolled agencies;
  • Timing for compliance with the new requirements –adoption vs. effective dates; changes that must be made in the agency Sewer System Management Plan;
  • Changes to the overflow emergency response plans and sampling requirements;
  • Changes to the certification requirements for LROs and CWEA-certified operators;
  • Discussion of new requirements for operations like:
  • Resiliency to Asset Management
  • Blockage Control Plans
  • Internal Audit reporting/submittals
  • Annual Service Area Mapping
  • Expanded Historical Performance Reporting and graphing
  • SSMP and Internal Audit certification and submittal requirements
  • Financial Planning and Budgeting
  • CIWQS revised reporting requirements
Afrooz Farsimadan, State Water Resources Control Board

Afrooz Farsimadan, State Water Resources Control Board

Wednesday, April 19, 2023
8:30 AM – 9:30 AM
Afrooz Farsimadan, State Water Resources Control Board

This presentation will provide an update on new requirements in the reissued Sanitary Sewer Systems General Order. Participants will have an opportunity to ask questions regarding the new and updated requirements.

Afrooz Farsimadan is a professional civil engineer with over 15 years of civil engineering experience in the transportation and water quality sector. Afrooz graduated from Sacramento State University with a master’s degree in Civil Engineering and has been practicing as a registered civil engineer for over 11 years. She started her career working as a civil engineer for the California Department of Transportation, inspecting highway construction projects. Afrooz then joined the Division of Water Quality at the State Water Resources Control Board. For the past six years, Afrooz has served as a Senior supervising engineer. In addition to her Statewide NPDES Program Manager role in overseeing the development and implementation of numerous statewide NPDES general permits, Afrooz manages the implementation the Statewide Sanitary Sewer Systems General Order.

  • Understand revisions to 2006 Statewide Sanitary Sewer Systems General Order
  • Will be informed of new requirements in 2022 Statewide Sanitary Sewer Systems General Order
  • Formulate a plan to comply with the new requirements


Wednesday, April 19, 2023
2:15 PM – 3:15 PM
Rusty Nezat, Nezat Training and Consulting

The afternoon session will begin with a discussion on how wastewater collection system cleaning maintenance departments can improve their daily production rates and lower equipment downtime. Rusty Nezat provides this information from more than 20 years of evaluations, formal reports, and recommendations provided to numerous municipal wastewater collection departments across the
United States.

Issues that cause the greatest reductions in performance will be highlighted and will feature ways to improve areas of concern. Nezat will include in his presentation multiple videos, animations, graphics, and charts that will help to support the different factors influencing a department’s ability to improve service to the taxpayer base.

Nezat is a second-generation sewer cleaner, who began cleaning sewers at the young age of thirteen and is still in the field more than forty years later. Working in the private sector for Texas-based Insituform Technology Group, Nezat was responsible for a massive fleet of sewer cleaning equipment and associated personnel.

In January 1991, Nezat opened his own consulting firm called Nezat Training and Consulting. Now 32 years later, his company’s main objective is to reduce sewer cleaning equipment downtime, increase daily sewer cleaning production rates, improve the quality of sewer cleaning work and increase safety awareness. As Director, Nezat has completed extensive evaluation and testing of sewer
cleaning nozzles and the methodology associated with sewer cleaning procedures.

Wednesday, April 19, 2023
3:30 PM – 4:30 PM
Lars Stenstedt, V&A Consulting Engineers
Rick Pina, Town of Hillsborough,  Assistant Superintendent of Public Works

Data science and machine learning can be leveraged by small and medium-sized collection systems for gravity main cleaning optimization. This mid-afternoon presentation will introduce and overview data science processes and best practices for collection systems. The presentation will feature a case study from the Town of Hillsborough, Calif.

The presentation will detail the three phases of V&A Consulting Engineer’s data science process and their application by the Town of Hillsborough. Information provided includes gathering, cleaning, and joining all available collection system data, including, but not limited to GIS, CCTV, SmartCovers, and Cleaning Condition Data.

Speaker Lars Stenstedt, from V&A Consulting Engineers, explains that Cleaning Condition Data includes cleaning condition assessment data gathered during the cleaning process by observing flow and caught material at the access manhole. Because gravity mains are cleaned before CCTV inspection, CCTV data has very limited use for the assessment of FOG, roots, or debris, rags, and grit in gravity mains.

V&A, the Town of Hillsborough, and Padre Dam Municipal Water District collaborated on a standard index for Cleaning Condition data. V&A adds external data to improve data, quality or provide variables supporting plausible theories of causation. The result is analytics-ready data set for all gravity main segments in the collection system.

The discussion moves to the creation of sophisticated analytical models using machine learning, which delivers a unique cleaning Condition Assessment prediction for each gravity main segment in the collection system.

The case study discussion will focus on the data science process where the Town of Hillsborough is adopting the analytical outputs for continuous, incremental improvements in its gravity main cleaning efficiencies.

Lars Stenstedt has over 30 years of experience in high-technology business development. He has a BS degree in Mechanical Engineering from Stanford University and an MBA from the UC Berkeley Haas School of Business with an emphasis in the Management of Technology.

His most recent experience includes working in Data Science Services for V&A Consulting Engineers, Inc, in business development for ELSys, Inc., and he was the co-founder and CIO of Fracta, which he company through two strategic pivots: from a pipe inspection robot provider to oil/gas markets, into the potable water condition assessment space, and finally to being an independent
company focused on SaaS-based, machine learning condition assessment solutions for water and other capital intensive infrastructure. A majority interest in Fracta was acquired by Kurita Water in 2018.

Rick Pina is the Town of Hillsborough, Assistant Superintendent of Public Works. The Town of Hillsborough is located in San Mateo County, Calif., in the San Francisco Bay Area, with a population of 11,387 in 2020. Hillsborough’s sanitary sewer system is comprised of 98 miles of collection system mainlines, 2,477 manholes, 247 cleanouts, and four sewer pump stations.