100824 CSC Meeting Regulatory Update - SCAP

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18 Νοε 2013 (πριν από 3 χρόνια και 9 μήνες)

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COLLECTION
SYSTEMS
REGULATORY
UPDATE

USEPA


SWRCB

August 2010

USEPA


NPDES

RUMBLINGS

USEPA


In June of 2010 the USEPA published a
notice in the Federal Register its intent to
conduct several “listening sessions” to
obtain information on issues related to
collection systems.


Five questions pertaining to collection
systems were posed.

USEPA

1.
Should EPA clarify its standard permit
conditions for SSO reporting,
recordkeeping, and public notification?

2.
Should EPA develop a standard permit
condition with requirements for capacity,
management, and operations &
maintenance programs based on asset
management principles?


USEPA

3.
Should EPA require permit coverage for
municipal satellite collection systems?

4.
What is the appropriate role of NPDES
permits in addressing unauthorized SSOs
that are caused by exceptional
circumstances?

5.
What are the costs and benefits of
capacity, management, and operations &
maintenance programs and asset
management of sanitary sewers?

USEPA


What is CMOM?


Capacity, Management, Operations and
Maintenance


Asset management program based on
industry standards setting the minimum
requirements for collection systems.


Conceived by the USEPA in the early 1990s
based on the MOM program from USEPA
Region 4.

USEPA


Draft ready for adoption in 2001.


Change in Administration


funding pulled


CMOM never adopted.


CMOM is comprised of:


Spill notification, reporting and records
keeping


Written program


Asset Management


Spill response


O & M Program including:


Line cleaning


Inspection (CCTV, etc.)

USEPA


Mapping


Grease Source Control


Condition Assessment;
Replacement/Rehabilitation


Capitol Improvement Program


Short and long term funding


Capacity Assurance


I&I Control



Sound Familiar?

USEPA

NPDES Permit or WDR


Both are legally enforceable regulations


NPDES Permits originate with the federal
government.


WDRs originate at the state or local
(Regional) level.


Life Expectancy


NPDES Permits are renewed every five years.


WDR’s remain enforceable until they are
repealed although may have periodic review.

USEPA


Coverage


NPDES Permits can be individualized having
specific requirements for a specific agency
thus becoming more prescriptive.


WDRs cover groups of like agencies with the
requirements being the same for all covered
agencies and tend to be more general in
nature.

USEPA


Protection


The Clean Water Act provides for citizen
lawsuits regardless if the agency is under a
NPDES Permit or a WDR.


Some feel that the NPDES Permit system
makes it easier for third party lawsuits.


Some WDRs may include “affirmative
defense” language.


The legality of affirmative defense language is
debatable.

USEPA


How will USEPA’s proposed regulations
effect California collection systems?


If the USEPA proceeds with its apparent
intentions it will take 2 to 3 years (or longer)
for the program to be finalized.


Currently, state officials do not feel that
USEPA’s proposed regulations will have any
effect on California.


California’s current regulations are already
more prescriptive than what USEPA is
proposing.

USEPA


What are the issues?


WEF, CWEA, SCAP and other collection system
stakeholders generally do not object to
sensible regulations that utilize best
management practices and are based on
industry standards such as CMOM programs.


Issues with the NPDES Permit program


NPDES Permits issued to individual agencies.


NPDES Permits issued to POTWs with satellites
as co
-
permittees.


NPDES Permits issued to the states allowing
the states to run their own approved program.

State Water
Resources Control
Board

(SWRCB)

SWRCB


WDR Order Review


WDR is currently under review by the SWRCB


Draft of the revised Order was to be out late
July or August with presentation to the full
Board in August.


New timetable for release of draft is October
or November


Public comment period and Public Hearing to
follow


Adoption by SWRCB in December 2010 or
January 2010

SWRCB


Anticipated changes.


State will not reveal what changes are in the
revised Order except that most of the
changes will be to the reporting and
monitoring with some administrative and
clarification changes to the Order.


Possible notification changes utilizing a one
call system for notification of OES, Regional
Board and health care.


Language to assist those agencies with lateral
responsibilities for spill reporting.

SWRCB


Possible addition of a Category 3 spill for very
small (under 100 gallon & not to the waters of
the US) spills with reduced reporting
requirements.


The issue here is that there are several agencies
(Central Valley & Bay Area) who are experiencing
a large number of very small spills (10 gal or less
and from agency controlled laterals) making
current reporting very costly.


Possible changes to CIWQS reporting to
further insure that private property spill are
not credited to the reporting agency.


Reporting to be event based instead of
appearance based.

SWRCB


SWRCB Audits


The SWRCB is still on track to conduct
random audits throughout the state.


Audits will be conducted by state and regional staff


Audits will be random (unless regional staff wants
a particular agency audited


Audits not based on spill history


WDR In
-
house Audits


Each agency is required to conduct an in
-
house audit every two years by the
anniversary of the initial approval date of the
agency’s SSMP.

SWRCB


Audits should include an evaluation of the
performance of each SSMP element and any
changes made or anticipated to the SSMP and
associated programs.


Audits are to be written and maintained by
the agency.


First audits (agency’s serving populations >
100,000) May 2011. Populations of 10,000 to
100,000, August 2011.


Additional information will be provided at CSC
meetings and the SCAP Monthly Update.

SWRCB


Data Review Committee


Started early 2010 and meets twice a month


Committee Objectives

1.
Refine the CIWQS SSO spill report form data
fields
-

Is there data we are now collecting that
can be eliminated from the spill report? Is there
data we should be but are not currently
collecting on the spill report?


How should we
refine the drop down selection lists for fields like
"Appearance Point", etc.

2.
Re
-
design the SSO spill report form to be event
not location based
-

incorporate multiple
"appearance" points into the spill report form.

SWRCB

3.
What indices of Collection System performance
should be used to compare collection systems in
California?


Performance Indices have occupied most
of the Committee’s time.


Current index used to compare collection
systems is annual spills per 100 miles of
pipe.


Considered unfair to small systems having
less than 100 miles of pipe.

SWRCB


Approximately 10 different indices were
evaluated based upon miles of pipe; number,
category and volume of spills; spill cause;
pipe type, size and age; agency flow vs.
spilled volume, etc.


Different scenarios were analyzed by
committee members utilizing their own data
or masked data provided by the state.


There is no one size fits all.

SWRCB


The Committee has tentatively selected:


SSOs per 100 miles of mainline per year


SSOs per 100 miles of lateral lines per year


Volume spilled verses volume not recovered per
100 miles of mainline per year


Volume spilled verses volume not recovered per
100 miles of laterals per year


Consideration is being given to possibly use
the indices but utilize 10 and 1 mile pipe
segments for smaller systems.

SWRCB


After analyzing the spill data (gravity
systems) the Committee also found:


Smaller pipe sizes have higher spill rates than
larger pipes but smaller volumes.


Smaller systems tend to have higher spill
rates than larger systems.


Roots tend to be the number one cause or
contributing factor for SSOs statewide.

SWRCB


Agency Performance Report


Report generated by and displayed on the
SWRCB’s website.


Report compares an agency’s performance
with other agencies within the Region and
state.


Report allows the viewer to select a 12
-
month
timeframe for the report generation.


SWRCB is soliciting additional input on the
report.


Report can be viewed in Google Groups.

CWEA

Training

2010
-
2011

CWEA WDR Training ’10
-
’11


CWEA training is going to shift from in
-
person seminars to webinars


Low cost 1 ½ to 2 hours in length


Topics


How to estimate SSOs


Enforcement and NGO Actions


SSO
-
WDR Reporting and Order Changes


State is requesting webinar on in
-
house
WDR/SSMP audits

Thank You

Bob Kreg

Program Manager

Dudek