scap collection committee workshop swrcb, region 8scap1.org/collection reference library/050110...
TRANSCRIPT
30200 Rancho Viejo Road, Suite B
San Juan Capistrano, CA 92675
SCAP Collection Committee Workshop SWRCB, Region 8
May 12, 2004 9:00 am – 12:00 pm
Inland Empire Utilities Agency 6075 Kimball Avenue, Chino
Agenda 1. Introduction.......................................................................................................................Ray Miller
Purpose of having this workshop. • Information exchange on what’s on the horizon for collection system owners and
operators.
2. What cMOM really is .................................................................................................Nick Arhontes A proposed federal regulation that will affect California. An asset management program for collection systems. Guideline for the operation, maintenance and financial responsibility of owning a collection
system. Improved SSO response.
• Porter Cologne and Clean Water Act.
3. Although it is not yet law, is cMOM being enforced? .....................................................Bob Kreg Federal EPA, Region 9.
• Case histories of “Orders for Compliance” issued by EPA Region 9 in September 2003.
4. What is currently happening at the SWRCB (collection systems)?.......................... Ken Theisen Statewide electronic SSO reporting update. WDRs, what are they and where are they being applied? A statewide WDR when cMOM is adopted? Where does Region 8 stand on collection system issues? Governor’s Environmental Action Plan.
5. What’s next?......................................................................................................................Ray Miller Who is SCAP? What is SCAP trying to accomplish? How can SCAP help? Working together. Long range needs.
6. Open Discussion – Q&A.................................................................................................................All
Fax: 949/489-0150 Tel: 949/489-7676
May 12, 2004Chino, CA
May 12, 2004Chino, CA
SCAP Collection Systems Workshop for
SWRCB Region 8 Area Partners
SCAP Collection Systems Workshop for
SWRCB Region 8 Area Partners
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
OCSD Background InformationOCSD Background Information471 square mile service area
2.3 million people
240 MGD w/550+ MGD hourly wet weather peaks
475 miles of regional sewers up to 96 inches
150 miles of local sewers
17 regional pumping facilities
26 satellite systems
471 square mile service area
2.3 million people
240 MGD w/550+ MGD hourly wet weather peaks
475 miles of regional sewers up to 96 inches
150 miles of local sewers
17 regional pumping facilities
26 satellite systems
What cMOM really is:What cMOM really is:A proposed Federal Regulation
Contains an asset management program
Improved O&M and financial planning
Improved SSO response and reporting
An integrated approach
A proposed Federal Regulation
Contains an asset management program
Improved O&M and financial planning
Improved SSO response and reporting
An integrated approach
cMOMcMOMA proposed NPDES Permit process for regional and satellite systems.
cAPACITY for base and peak flows
a MANAGEMENT Program
proper OPERATIONS
and proper MAINTENANCE
provisions for an Affirmative Defense
A proposed NPDES Permit process for regional and satellite systems.
cAPACITY for base and peak flows
a MANAGEMENT Program
proper OPERATIONS
and proper MAINTENANCE
provisions for an Affirmative Defense
cMOM GoalscMOM GoalsProper management, operation and maintenance, at all times, of all parts of the collection system that you own or have operational control over
Discover deficiencies and develop a plan to correct them
Minimize spills and their impacts on the waters and public
Proper management, operation and maintenance, at all times, of all parts of the collection system that you own or have operational control over
Discover deficiencies and develop a plan to correct them
Minimize spills and their impacts on the waters and public
Capacity IssuesCapacity IssuesBase and Peak Flows
No guidance on Design Storms
Community Growth and re-Development?
Field Staff or Contractor input:
SSOs?
Surcharging?
Low Flows?
Base and Peak Flows
No guidance on Design Storms
Community Growth and re-Development?
Field Staff or Contractor input:
SSOs?
Surcharging?
Low Flows?
Management ProgramManagement ProgramWritten program with your site specific goals
O&M record keeping
SSO response reporting plan
Capacity planning / Engineering standards
Public notification / Protection plan
An auditable and public document
Maintenance facilities and equipment with adequate parts
Written program with your site specific goals
O&M record keeping
SSO response reporting plan
Capacity planning / Engineering standards
Public notification / Protection plan
An auditable and public document
Maintenance facilities and equipment with adequate parts
Information Management SystemsInformation Management Systems
Map of collection system
Identify and track trends in overflows
3 years of work order history
3 years of performance and implementation measures
List of components with lack of capacity
Track non-compliance events
Map of collection system
Identify and track trends in overflows
3 years of work order history
3 years of performance and implementation measures
List of components with lack of capacity
Track non-compliance events
Legal Authority (Ordinances)?Legal Authority (Ordinances)?Controls for minimizing I/I
Proper design and construction
Ensure proper installation, testing, and inspection of new and re-hab
Flow agreements with satellites?
Pre-treatment programs, if needed
Controls for minimizing I/I
Proper design and construction
Ensure proper installation, testing, and inspection of new and re-hab
Flow agreements with satellites?
Pre-treatment programs, if needed
Measures and ActivitiesMeasures and ActivitiesWho is responsible for and how do you handle:
Maintenance of facilities
Map maintenance
Management of relevant information for cMOM related activities
Routine preventative maintenance and operations
Who is responsible for and how do you handle:
Maintenance of facilities
Map maintenance
Management of relevant information for cMOM related activities
Routine preventative maintenance and operations
Measures and Activities (cont’d)Measures and Activities (cont’d)
Who is responsible for and how do you handle:
Capacity management
Identification of and defect resolution (CCTV?)
Appropriate training on a regular basis
Equipment and parts inventories
Who is responsible for and how do you handle:
Capacity management
Identification of and defect resolution (CCTV?)
Appropriate training on a regular basis
Equipment and parts inventories
Design and Performance ProvisionsDesign and Performance Provisions
Engineering and constructions issues
Agency design and performance standards
Procedures and specifications for inspection and testing
Engineering and constructions issues
Agency design and performance standards
Procedures and specifications for inspection and testing
Monitoring, Measurement and Program ModificationsMonitoring, Measurement and Program Modifications
Implementation and effectiveness of your cMOM program
Update program elements as appropriate
Keep program summary updated and accurate
Implementation and effectiveness of your cMOM program
Update program elements as appropriate
Keep program summary updated and accurate
Overflow Response PlanOverflow Response PlanAware of all overflows/back-ups (any size)?
Ensure a proper response …
Ensure appropriate reporting …
Ensure appropriate notifications …
Ensure trained staff follows the SSORP
Provide for emergency operations for a wide range of failures
Aware of all overflows/back-ups (any size)?
Ensure a proper response …
Ensure appropriate reporting …
Ensure appropriate notifications …
Ensure trained staff follows the SSORP
Provide for emergency operations for a wide range of failures
System Evaluation and Capacity Assurance Plan?System Evaluation and Capacity Assurance Plan?
IF you have peaking problems with :
Collection system or treatment plants
Short and long-term action plans
Action plan updates for changes / schedule updates
IF you have peaking problems with :
Collection system or treatment plants
Short and long-term action plans
Action plan updates for changes / schedule updates
Rehab / Capital ImprovementsRehab / Capital Improvements
Programs to identify and prioritize
Structural and hydraulic deficiencies
Short and long-term action plans
Information management for review and update
Programs to identify and prioritize
Structural and hydraulic deficiencies
Short and long-term action plans
Information management for review and update
cMOM Program AuditscMOM Program Audits… NPDES permit application with audit of your program, SSOs, compliance, deficiencies, and corrective actions
… NPDES permit application with audit of your program, SSOs, compliance, deficiencies, and corrective actions
Compliance AuditsCompliance AuditsConduct and certify that an audit to evaluate a cMOM Program including SSORPDevelop an audit report based on interviews with:– Staff– Field inspections of equipment– Observations of crews– Records reviews – Address findings and deficiencies– Document steps taken to respond to findings– Schedule of additional steps needed to respond
to findings
Keep two most recent compliance audits on file
Signature, Certifications and Director’s ReviewSignature, Certifications and Director’s Review
Required when major modifications are made
Make the SSORP and cMOM Program data available to State and EPA
Make available to downstream system and Plant Operators
CommunicationsCommunications… with various parties
… how your cMOM program is working …
… with input from interested parties to help your cMOM program be responsive
Local community stakeholders, Regional Water Quality Control Board, County Health Care Agency, and others
… with various parties
… how your cMOM program is working …
… with input from interested parties to help your cMOM program be responsive
Local community stakeholders, Regional Water Quality Control Board, County Health Care Agency, and others
Small System Exemptions?Small System Exemptions?Less than 1 MGD and / or less than 2.5 MGD eliminates some provisions in the proposed program
Less than 1 MGD and / or less than 2.5 MGD eliminates some provisions in the proposed program
State IssuesState IssuesPermitting of satellite systems?
Oversight through Regional Boards?
Fines for SSOs and Program non-compliance?
Permitting of satellite systems?
Oversight through Regional Boards?
Fines for SSOs and Program non-compliance?
Update on EPA’s cMOMUpdate on EPA’s cMOMReport due to Congress on Dec. 15, 2003:
Locations, constituents, volumes of SSOs and their impacts on human health and environment
Resources spent by municipalities to address these impacts
Evaluation of technologies used by municipalities to address these impacts
Report due to Congress on Dec. 15, 2003:
Locations, constituents, volumes of SSOs and their impacts on human health and environment
Resources spent by municipalities to address these impacts
Evaluation of technologies used by municipalities to address these impacts
Update on EPA’s cMOM (cont’d)Update on EPA’s cMOM (cont’d)
Currently in OMB
NRDC report “Swimming in Sewage” www.nrdc.org
Also see: www.epa/gov/npdes/sso and see: SSO Toolbox and also search on cMOM
HR 2215 “The Raw Sewage Overflow” Community Right-to-Know Act Rep. T. Bishop (D-NY)
Currently in OMB
NRDC report “Swimming in Sewage” www.nrdc.org
Also see: www.epa/gov/npdes/sso and see: SSO Toolbox and also search on cMOM
HR 2215 “The Raw Sewage Overflow” Community Right-to-Know Act Rep. T. Bishop (D-NY)
OK … How do I get Ready?OK … How do I get Ready?Have a good design and construction program
Have a good documented O&M programP.M. / C/M. / Emergency Repsonse / SSORP
Maps and data
Have a good rehab and CIP process
Advise your Council / Board on $
Have a good design and construction program
Have a good documented O&M programP.M. / C/M. / Emergency Repsonse / SSORP
Maps and data
Have a good rehab and CIP process
Advise your Council / Board on $
OK … How do I get Ready? (cont’d)OK … How do I get Ready? (cont’d)
Follow EPA through http://cfpub.epa.gov/npdes/home.cfm?program_id=4
Existing: discover / document / develop action plans
Prepare to assist your agency during the public comment period
Do a “gap” analysis (EPA Tool Kit)
Be proactive within your agency
Follow EPA through http://cfpub.epa.gov/npdes/home.cfm?program_id=4
Existing: discover / document / develop action plans
Prepare to assist your agency during the public comment period
Do a “gap” analysis (EPA Tool Kit)
Be proactive within your agency
OK … How do I get Ready? (cont’d)OK … How do I get Ready? (cont’d)
Collaborate with your associates
cMOM linkage to GASB 34 effort
Get involved with CWEA and SCAP
Live by your written program
Learn how to pass audits!
Form a proactive Regional cMOM Team
Invite the public to participate
Collaborate with your associates
cMOM linkage to GASB 34 effort
Get involved with CWEA and SCAP
Live by your written program
Learn how to pass audits!
Form a proactive Regional cMOM Team
Invite the public to participate
Asset Management Fundamentals
Asset Management Fundamentals
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
What Do You Own?What Do You Own?
Records
Lists of assets
Maps and drawings
Specifications
Vendor information
Records
Lists of assets
Maps and drawings
Specifications
Vendor information
What Is It Worth?What Is It Worth?
Asset condition
Asset value
O&M cost inputs
Work with finance department
Asset condition
Asset value
O&M cost inputs
Work with finance department
How Do You Care For It?How Do You Care For It?
Preventive, predictive, corrective maintenance
Trained staff and contractors
Records Management
Preventive, predictive, corrective maintenance
Trained staff and contractors
Records Management
When Do You Replace It?When Do You Replace It?
Life cycle maintenance and replacement strategies and plans
Capital improvement programs (CIP)
Life cycle maintenance and replacement strategies and plans
Capital improvement programs (CIP)
How Do You Fund These Needs?How Do You Fund These Needs?
Adequate O&M revenue stream
Adequate CIP revenue stream
Adequate reserves
Adequate O&M revenue stream
Adequate CIP revenue stream
Adequate reserves
See Some Similarities to cMOM?See Some Similarities to cMOM?
Logical
Documented
Auditable
Logical
Documented
Auditable
Improved SSO Response
Improved SSO Response
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
Why Do We Care?Why Do We Care?Comply with Federal CWA and State Water Code and Basin Plans
Protect watershed from sewage overflows (SSO)
Protect the public and property
Protect wildlife
Avoid fines / penalties
Affirmative defense
Local economics / development
Comply with Federal CWA and State Water Code and Basin Plans
Protect watershed from sewage overflows (SSO)
Protect the public and property
Protect wildlife
Avoid fines / penalties
Affirmative defense
Local economics / development
What Can We Learn At A Training Facility?What Can We Learn At A Training Facility?
How to respond and notify
How to contain sewage
How to set up traffic control for worker safety
How to estimate flows and volumes
How to control flows
How to clean up
How to document for reporting purposes
How to respond and notify
How to contain sewage
How to set up traffic control for worker safety
How to estimate flows and volumes
How to control flows
How to clean up
How to document for reporting purposes
Why an SSO Training Facility?Why an SSO Training Facility?Prepare for the real event
Isolated from traffic hazards
Environmentally safe
Assess individual and team skills
Evaluate methods, equipment and materials
Practice, practice, practice !
Prepare for the real event
Isolated from traffic hazards
Environmentally safe
Assess individual and team skills
Evaluate methods, equipment and materials
Practice, practice, practice !
What is It?What is It?Simulated manhole (vault with cover)
Potable water supply
Street surface
Curb and gutter and catch basin
Storm drainage to the treatment plant
Simulated manhole (vault with cover)
Potable water supply
Street surface
Curb and gutter and catch basin
Storm drainage to the treatment plant
Water Supply
Water Meter
Valve #1Valve #1Valve #2Valve #2
Manhole Vault
ManholeDrain Valve
Manhole
Street Surface and Gutter
Catch Basin
Typical EventTypical Event
500 gallonsper minute spill
500 gallonsper minute spill
6 gallonsper minute spill
6 gallonsper minute spill
Flow downgutter
Flow downgutter
Q = A x VQ = A x V
Containment at Catch BasinContainment at Catch Basin
Put containmentin place
Put containmentin place
Spill pondingSpill ponding
Spill containmentSpill containment
Estimating Flow RatesEstimating Flow Rates
6 gallonsper minute spill
6 gallonsper minute spill
Flow downgutter
Flow downgutter
Traffic Control
Clean UpClean Up
Combination cleaning truckremoves ponded material
Combination cleaning truckremoves ponded material
Direct flow to anatural low areaDirect flow to anatural low area
Clean Up (cont’d)Clean Up (cont’d)
Wash down and recoverWash down and recover
Prepare field report,photograph and document
Prepare field report,photograph and document
SSO Report DocumentationSSO Report Documentation
Support Activities –Dispatch CenterSupport Activities –Dispatch Center
Closeout ActivitiesCloseout ActivitiesFinish and submit the field report
Assemble and complete the written report for RWQCB
Restock materials
Post mortem with lessons learned
Modify response procedures
More training?
Finish and submit the field report
Assemble and complete the written report for RWQCB
Restock materials
Post mortem with lessons learned
Modify response procedures
More training?
What is currently happening at the
SWRCB on collection systems?
What is currently happening at the
SWRCB on collection systems?
Statewide Electronic SSO Reporting Update Statewide Electronic
SSO Reporting Update
WDRs-what are they and where are they being applied?
WDRs-what are they and where are they being applied?
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
Nick Arhontes, P.E.Orange County Sanitation District (OCSD) Fountain Valley, CA
What is the Region 8 Order?What is the Region 8 Order?Santa Ana RWQCB Order R8-2002-0014
issued April 26, 2002 covering:
Waste Discharge Requirements (18 pages)
Spill Reporting and water quality monitoring program (11 pages)
Both available at: www.swrcb.ca.gov/rwqcb8/See: Orange County SSO General WDRs
Santa Ana RWQCB Order R8-2002-0014issued April 26, 2002 covering:
Waste Discharge Requirements (18 pages)
Spill Reporting and water quality monitoring program (11 pages)
Both available at: www.swrcb.ca.gov/rwqcb8/See: Orange County SSO General WDRs
Deliverables and ScheduleDeliverables and ScheduleApr. 26, 2002 – Reporting of all SSOs and
water quality monitoring
Sep. 30, 2002– Development Plan and schedule for Sewer SystemMgmt Plan (SSMP) – Done
Jan. 1, 2003 – SSO Emergency ResponsePlan – Done
Apr. 26, 2002 – Reporting of all SSOs and water quality monitoring
Sep. 30, 2002– Development Plan and schedule for Sewer SystemMgmt Plan (SSMP) – Done
Jan. 1, 2003 – SSO Emergency ResponsePlan – Done
Deliverables and Schedule (cont’d)Deliverables and Schedule (cont’d)
June 15, 2003 – Preventative MaintenanceProgram - Done
July 30, 2004 – Legal authority
Dec. 30, 2004 – Grease disposal alternatives
June 15, 2003 – Preventative MaintenanceProgram - Done
July 30, 2004 – Legal authority
Dec. 30, 2004 – Grease disposal alternatives
Deliverables and Schedule (cont’d)Deliverables and Schedule (cont’d)
Dec. 30, 2004 – Grease Control Program
July 30, 2005 – Capacity evaluation
Sep. 30, 2005 – Sewer Rehab Plan forentire system
Sep. 30, 2005 – Final SSMP
Dec. 30, 2004 – Grease Control Program
July 30, 2005 – Capacity evaluation
Sep. 30, 2005 – Sewer Rehab Plan forentire system
Sep. 30, 2005 – Final SSMP
SWRCB’s ProposedStatewide Model?
SWRCB’s ProposedStatewide Model?
Where does Region 8 stand on collection
system issues?
Where does Region 8 stand on collection
system issues?
Governor’s environmental action
plan?
Governor’s environmental action
plan?
Questions?Questions?Nick Arhontes, P.E.ManagerRegional Assets and Services Divisions(714) [email protected]
Nick Arhontes, P.E.ManagerRegional Assets and Services Divisions(714) [email protected]
Orange County Sanitation Districtwww.ocsd.comSearch: WDR – for more info and links
Orange County Sanitation DistrictOrange County Sanitation Districtwww.ocsd.comSearch: WDR Search: WDR –– for more info and linksfor more info and links
cMOM – Its Not Law, But
A Case History
Compliance Orders Issued by EPA Region 9• EPA Region 9 has jurisdiction over the
southwestern United States including California• In 2002, Compliance Orders issued to the City of
Laguna Beach, City of San Diego and Carpinteria Sanitary District
• September 2003, Compliance Orders issued to Los Angeles County Sanitation Districts (LACSD) and South Coast Water District (SCWD)
• April of 2004, Compliance Order issued to the City of Oakland
• Reason for Compliance Orders – Excessive Sanitary Sewer Overflows (SSO)
SCWD Profile
• SCWD is a water/reclamation/wastewater public agency located in southwest Orange County
• Sanitary collection system is comprised of approximately 139 miles of pipelines with 14 lift stations
• 49 SSOs from 1999 to 2003 – 21 reached the waters of the U.S.
SCWD Profile (Cont.)
• Action started with a complaint from San Diego Water Quality Control Board – Region 9 - for failure to provide a Sanitary Sewer Overflow Prevention Plan and failing to submit complete SSO reports
• District fined $136,100 and settled for a fine of $105,000 in March 2003
• EPA’s Compliance Order was issued the following September
What is in the EPA Compliance Orders?
• The other compliance orders are very similar – their violations are unique –requirements and timelines for compliance are essectially the same
• Primary goal – to substantially reduce the number and the volume of SSOs annually
What is in the EPA Compliance Orders? (Cont.)
• Create a Sanitary Sewer Overflow Response Plan (SSORP)
• Plan must:– Provide written instructions on how to respond to an
SSO– Provide measures for spill containment– Establish interim method of operation– Maintain a list of spare parts and emergency equipment
What is in the EPA Compliance Orders? (Cont.)
• Establish a Sewer System Cleaning and Root Control Program – Submit schedule for cleaning of entire system– Submit schedule for cleaning hot spots and describe procedures for
adding or removing pipe segments from the hot spot list– Plan for comprehensive root control program including methods
for controlling root intrusion into mains and private laterals and the repair, replacement or rehabilitation of root prone mains
– Written procedures for cleaning, repairing and maintaining sewerlines located in easements - including schedules and instructions for gaining access to lines in easements
What is in the EPA Compliance Orders? (Cont.)• Maintenance Management System
– Consider implementing computerized maintenance management system for scheduling and tracking system maintenance that should eventually be tied to a GIS mapping system
• Sewer Pipe Inspection and Condition Assessment Plan– Submit a plan for periodic sewer pipeline inspection and
assessment to include maintenance holes, method of inspection (i.e. CCTV), frequency of inspection, evaluation of inspection findings, and documentation of assessed condition
– Submit annual report to EPA summarizing miles of pipe and number of maintenance holes inspected and their condition assessment
What is in the EPA Compliance Orders? (Cont.)• Sewer Repair, Rehabilitation and
Replacement Plan– Submit a plan for the repair, rehabilitation or
replacement that (1) provides the timely repair or replacement of pipelines imminently in danger of failure or blockage; (2) ensure the sustainable replacement of obsolete assets; (3) reduce spills caused by pipe defects
Sewer Repair, Rehabilitation and Replacement Plan (Cont.)
• The plan must include:– Estimate of how many sewer pipes will annually
require emergency repair or replacement– Estimate of how many miles of pipeline will be
rehabilitated or replaced over the next 5 and 10-year periods
– Submit a 10-year financial plan for the short and long term rehabilitation or replacement of the sewer pipes
– Annually submit a report to the EPA documenting the repair, rehabilitation or replacement history for the previous year including an update to the 10-year capital improvement plan
What is in the EPA Compliance Orders? (Cont.)• Capacity Assessment and Capacity Assurance
– Requires the agency to assess the capacity of the collection system to ensure sufficient capacity during wet weather including the control of all I/I that could pose a risk of exceeding the collection system’s capacity and to submit a report to the EPA on capacity limitations and the plan for assuring adequate capacity
• Pump Station Maintenance and Inventory– Complete a condition assessment for each lift station and
associated force mains, identifying potential problems, provide recommendations for standby generators, and submit a plan to theEPA of the assessment findings and for the repair, renovations or upgrades necessary to ensure the continuous operation of each lift station
What is in the EPA Compliance Orders? (Cont.)• Create a Fats, Oils, and Grease (FOG) Control
Program • The program shall be sufficient to eliminate or
significantly reduce sewage spills caused by FOG including:– Line cleaning of lines prone to FOG blockage– In conjunction with the cities, implement necessary best
management practices (BMP) for food service establishments
– Require the installation of grease interceptors for new or remodeled food service establishments
– Require food service establishments that cause FOG related blockages to install grease interceptors
FOG Control Program (Cont.)
– Establish FOG inspection program for food service establishments
– Establish FOG educational outreach program for food service establishments and homeowners
– Submit annual report to EPA documenting the FOG program activities carried out, including inspections and enforcement actions, the previous year
What is in the EPA Compliance Orders? (Cont.)
• Plan Review and Approval– EPA requires submission of the plan for EPA’s review,
comment and approval• Quarterly Spill Reports
– As per EPA’s schedule, quarterly spill reports must be submitted summarizing all sewage spills occurring the previous quarter
• Annual Progress Reports– Must submit an annual progress report to the EPA for
review and approval summarizing all aspects of the spill reduction plan and its effectiveness including the annual budget for the current year
Timeframe for Compliance
• The South Coast Water District compliance order was issued in September 2003. Most of the required programs were to be completed by the following March, six months after the issuance of the order with reports due the following September, twelve months after the order
• Annual reports are due each September• Quarterly reports are due each quarter• No sunset
Penalty for Non-ComplianceFailure to respond, or any other violation of the terms of this Order could subject (Agency) to a civil action…… negligent violations may be punished by a fine of not less than $2,500 per day or more than $25,000 per day of violation, or imprisonment for not more than one year, or both…… knowing violations may be punished by a fine of not less than $5,000 per day or more than $50,000 per day of violation, or imprisonment for not more than three years, or both…… penalties for knowingly making false statements.
The Other Boogie Man
• Third party lawsuits brought by environmental groups and others under the Clean Water Act– Ecological Rights Foundation v. City of Pacific
Grove, in 2004– Divers Environmental Conservation
Organization v. Fallbrook Public Utilities District in 2003
The Other Boogie Man (Cont.)
• Ecological Rights Foundation v. City of Pacific Grove– Approximately 58 miles of collection pipelines– Worst spill year, 2000 (8 spills or a rate of 13.7 spills
per 100 miles of pipe)– Worst spill – 70,000 gallons– FOG Program - as of July 2002, 14 grease interceptors
and 86 grease traps had been installed– Budget of $1,895,065 (2002-2003) up from $620,442
(2000-2001)
The Other Boogie Man (Cont.)Ecological Rights Foundation v. City of Pacific Grove
• The Settlement– $300,000 for plaintiff’s legal fees plus the City’s legal
expenses– Pay $50,000 to the Save Our Shores environmental
organization– $200,000 to establish a lateral replacement program for
businesses and homeowners– $500,000 in improvement projects (1st year) increased
by $50,000 in successive years to $1,000,000 per year– Reduce the number of spills to 4 annually by 2013
through increased maintenance and system improvements
The Other Boogie Man (Cont.)
• Divers Environmental Conservation Organization v. Fallbrook Public Utilities District– Fallbrook is located east of Camp Pendleton, not a
coastal community– Approximately 72 miles of collection pipelines– In 2003, there were 10 SSOs spilling approximately
6,100 total gallons of sewage– Roots and FOG account for 99% of all SSOs in
Fallbrook
The Other Boogie Man (Cont.)
• The Settlement – FPUD settled out of court– Settlement was for $135,000
• Included – $60,000 in plaintiff’s legal fees– $65,000 to the San Diego Oceans Foundation– $10,000 to the Mission Resource Conservation District
• Estimate for FPUD to defend itself in court -$2,000,000
• Additionally, FPUD to establish a mandatory FOG program and initiate a $65,000 public outreach campaign
The Other Boogie Man (Cont.)
• The City of San Diego Metropolitan Wastewater Department compliance order was issued in April 2002. Prior to this, in October 2000, the City was notified by San Diego Bay Keeper and Surfrider Foundation of their intent to sue under the Clean Water Act
So What’s the Point?
• EPA is getting actively involved with those it feels are not complying with the Clean Water Act
• When cMOM is adopted, it could be enforceable on the day of adoption
• Environmental groups are using third party lawsuits to ensure compliance with the Clean Water Act
• Get ahead of the curve, don’t wait to be forced to manage your collection system asset
CMOM IN CALIFORNIA
SAN DIEGO REGION WDRs
SANTA ANA REGION WDRs
SAN FRANCISCO BAY REGION, RESOLUTION/MOA
STATE WATER RESOURCES CONTROL BOARD EFFORTS, GUIDANCE, WDRs, POLICY?
WILL YOUR NEXT PERMIT, AN ENFORCEMENT ACTION, LAWSUIT, OR
NEW WASTE DISCHARGE REQUIREMENTS, REQUIRE A CMOM PROGRAM
Numerous sewage collection systems in California have chronic sewage spills
Many sewage spills are caused by neglect and poor operations andmaintenance, and can be prevented
CMOM only requires the basic minimum operation and maintenance for sewage collection systems, as recommended by WEF, ASCE, AMSA and other industry groups
Current Implementation of CMOM is through enforcement actions, consent decrees, or 3rd Party Lawsuits
WHY CMOM? BECAUSE IT REDUCES SEWAGE SPILLS
The basic sewage collection system maintenance and operation guidelines, recommended by WEF, ASCE, etc., have been proven to reduce sewage spills
Those sewage collection systems that use video to identify maintenance problems and regularly clean their sewers have fewer spills than those who neglect these basic maintenance tasks
FOG Control Programs reduce sewage spills
I & I Control Reduces Sewage Discharges
SWRCB’s STATEWIDE EFFORT TO REDUCE
SEWAGE SPILLS1. The Discharge of Sewage to any Surface Water Body of
the State is a Violation of the CWA, CWC, and Basin Plan
2. SWRCB’s Enforcement Policy Requires staff to notify their Respective RBs of all Sewage Spills, and Recommend Appropriate Enforcement Action
3. Enforcement Actions address Correction of the Cause of the Sewage Discharge (by requiring implementation of a CMOM program), as well as impose Penalties for the Discharge
SWRCB’s STATEWIDE EFFORT TO REDUCE
SEWAGE SPILLS4. Enforcement Options Include: 1) Informal Notice to
Discharger of Violation and Voluntary Correction of the Violation, 2) Cease and Desist Order for Permitted Dischargers, 3) Cleanup and Abatement Order for Systems not currently under permit, 4) Administrative Civil Liability up to $10,000 for each day of discharge and $10 per gallons over 1,000 gallons not cleaned up, 5) Referral to the Attorney General or District Attorney for Civil or Criminal Prosecution
SWRCB’s STATEWIDE EFFORT TO REDUCE
SEWAGE SPILLSSWRCB’s staff has set up a Sewage Spill Prevention Committee to evaluate alternative approaches to reduce sewage spills, and make recommendations to the SWRCB by November 2004.
Alternatives to be considered include Statewide General Waste Discharge Requirements for all sewage collection systems in California, a guidance document for dischargers on implementing CMOM, guidance for Regional Board staff on enforcement actions for sewage discharges, and any other alternatives that may be proposed by stakeholders that will result in a reduction of sewage discharges to waters of the State
1. Provide a floor level of O and M that minimizes the chance of spills within some affordability limits
2. Have effective contingency capability3. Have adequate capacity4. Have a very high level of O and M
and contingency capability at high risk sites
5. Consistent and accurate Tracking and reporting on performance
6. Develop opportunities for grants and low interest loans
WHY CMOM?: SEWAGE SPILLS IN CALIFORNIA
Sewage Spills to Waters Reported to the Office of Emergency Services
0
100
200
300
400
500
600
Num
ber o
f Inc
iden
ts
1997 1999 20001998 2001 2002
IMPACTS OF SEWAGE SPILLS-BEACH CLOSURES
Total
0
20
40
60
80
100
120
140
160
Janu
ary
Febr
uary
Mar
chAp
rilM
ayJu
neJu
lyAug
ust
Sep
tem
ber
Oct
ober
Nov
embe
rD
ecem
ber
Janu
ary
Febr
uary
Mar
chAp
rilM
ayJu
neJu
lyAug
ust
Sep
tem
ber
Oct
ober
Nov
embe
rD
ecem
ber
Janu
ary
Febr
uary
Mar
chAp
rilM
ayJu
neJu
lyAug
ust
Sep
tem
ber
Oct
ober
Nov
embe
rD
ecem
ber
Janu
ary
Febr
uary
Mar
chAp
rilM
ayJu
neJu
lyAug
ust
Sep
tem
ber
Oct
ober
Nov
embe
rD
ecem
ber
Janu
ary
Febr
uary
Mar
chAp
rilM
ayJu
neJu
lyAug
ust
Sep
tem
ber
Oct
ober
Nov
embe
rD
ecem
ber
1999 2000 2001 2002 2003
Total
NAME State Wide
Sum of BMDS
Year Month
CONCLUSION1. Discharges of Sewage are illegal under current law and regulation
2. Alternative enforcement actions available to correct these violations are informal enforcement, enforcement orders, waste discharge requirements, civil liability, and civil and criminal prosecution
3. SWRCB will be considering alternatives to reduce sewage discharges to waters of the State in November 2004
4. CMOM is coming to your sewage collection system in one form or another, whether it is guidance, General WDRs, enforcement actions, or penalties, because CMOM only requires basic operations and maintenance recommended by the wastewater collection industry to prevent and minimize sewage discharges
What’s Next?What’s Next?
Who is SCAP?Who is SCAP?History of SCAP– Originally formed in 1992 to meet the needs of
the POTWs– Structured by Committees
Air QualityWater IssuesBiosolidsCollection Systems
What is SCAP Trying to What is SCAP Trying to Accomplish?Accomplish?
As has been done with the POTWs, establish a liaison with regulators to provide information and assistance from the collection system perspectiveProvide an information and education exchange for collection system owners/operators relative to regulatory compliance
How Can SCAP Help?How Can SCAP Help?SCAP represents its members interests before various regulatory agenciesSCAP provides a monthly informational newsletterSCAP is currently involved in the statewide effort to address collection system issuesProvide guidelines and model programs for regulatory complianceProvide guidelines, advice, and assistance to individual agencies as needed
Working TogetherWorking TogetherSCAP’s historical basis for success is “working together”Working together by sharing resources between larger and smaller agenciesWorking together by sharing experience and expertiseWorking together by providing a communications conduit within the wastewater communityWorking together by providing a two way communications conduit to the regulatory community
Long Range NeedsLong Range Needs
Collection systems have the attention of the regulators as never beforeFuture regulations will probably by more stringentTo provide you with the best help, SCAP needs your helpA united front through a strong dedicated
membership is essentialSCAP membership is open to all collection system owner/operators with low annual dues
DO YOU OR SOMEONE DO YOU OR SOMEONE YOU KNOW HAVE:YOU KNOW HAVE:
• Regulatory malaise?
• Blockages?
• Spills?
• Facility or Capacity Problems?
• Enforcement Issues?
CALL SCAP! We can CALL SCAP! We can help! (949) 489help! (949) 489--76767676
QUESTIONSQUESTIONS??