MRP Revisions

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Sanitary Sewer Overflow (SSO)
Reduction Program:
MRP Revisions
Division of Water Quality
State Water Resources Control Board
October 23, 2012
Overview
 Review and Update Overview
 Proposed MRP changes
 Database Changes
 Comments Received
 Reissuance of MRP Schedule
Slide 2
Review and Update Process
 January 24, 2012 Board Workshop
outcome
 Postpone Re-Adoption of the SSS WDRs
Until A Later Date,
 Revise & Re-Issue the Monitoring &
Reporting Program (MRP) for the SSS
WDRs.
Slide 3
Review and Update Process
 The MRP establishes monitoring, record keeping,
reporting and public notification requirements for the SSS
WDRs,
 The Executive Director may make revisions to this MRP
at any time pursuant to the authority delegated by Water
Code section 13267(f) & Resolution No. 2002-0104,
 These revisions may include a reduction or increase in
monitoring and reporting.
Slide 4
Major Proposed MRP Changes
 Change Notification Requirement - SSOs that Reach or May
Reach a Surface Water or Drainage Channel from Three Calls
to One (i.e., Have to Call Cal EMA Only)
 Category 1 SSO greater than or equal to 1,000 gallons
 Change Spill Categories to:
 Category 1 – Spills that Reach a Surface Water,
 Category 2 – Spills that Do Not Reach a Surface Water and Are
Greater Than or Equal to 1,000 Gallons,
 Category 3 – Spills that Do Not Reach a Surface Water and Are Less Than
1,000 Gallons (i.e., All Current Category 2 Spills).
 Change reporting system to Event Based Spill Reporting
 State Board agreed to make this change per the 2008 MOA between the State
Water Board and the California Water and Environment Association (CWEA)
 Spill appearance points to be associated with each spill event caused by a
single asset failure.
Slide 5
Major Proposed MRP Changes (Cont.)
 Private Lateral Sewage Discharges (PLSDs) reporting
remain voluntary and certification will not be required
 Add Clarification on Who May Certify Reporting Elements
(i.e., LRO)
 Add Requirement that the Collection System Questionnaire
be Certified by the LRO for the Sanitary Sewer System.
 Spill Reporting Streamlining
Slide 6
Major Proposed MRP Changes (Cont.)
 Proposed Record Keeping Requirements:
 Records to demonstrate compliance with subsections
D.7 through D.9 of the SSS WDRs.
 Records to document annual in-house training on the
SSS WDRs, MRP, and SSMP for sewer crews, staff,
management, and contractors.
 Records to document Water Quality Monitoring, SSMP
Implementation, SSMP Program Audits, and Electronic
Records.
Slide 7
Database Changes
 MRP and New Spill forms will be released simultaneously
 CIWQS releases occur every 2 months
 Spill Forms
 Questionnaire
 SSO CIWQS Guidance Document
 Will be released with the new MRP
 Will provide step-by-step guidance and will provide FAQs
Slide 8
Comments Received
General Comments:
 Is it inappropriate to make all these changes to the MRP based on the
limited number of inspections
 A few agencies are reporting a significant number of spills and spills to
surface waters. All agencies Should not be required to comply with
these new requirements
 The State Water Board should consider the cost to agencies of these
additional MRP requirements
 New requirements will burdensome and will take resources from other
resources intended to reduce SSOs
 Additional record keeping requirements will not reduce SSOs
 SWRCB provide guidance to the stakeholders on how to ascertain which
water bodies are a "water of the state"
 These changes deviate from the intent of the SSS WDRs, which is to
reduce the number of SSOs. Slide 9
Comments Received
General Comments:
 Agencies support the addition of a third sanitary sewer
overflow (SSO) category to the reporting requirements.
 Agencies support the change from a location based report
to an event‐based
 Agencies generally support streamlining of notification
requirements by only requiring only one telephone call to the
Cal EMA
Slide 10
Reissuance Schedule
 Revise draft MRP per comments received
 Reissuance of MRP expected early 2013
Slide 11
Questions?
Slide 12
Program Contacts & Info
Russell Norman, P.E.
SSO Program Lead
State Water Resources Control Board
rnorman@waterboards.ca.gov
(916) 323-5598
Jim Fischer, P.E.
Office of Enforcement
State Water Resources Control Board
jfischer@waterboards.ca.gov
(916) 341-5548
Victor Lopez, E.I.T
SSO Program Lead
State Water Resources Control Board
vlopez@waterboards.ca.gov
(916) 323-5511
Julie Berrey
Office of Enforcement
State Water Resources Control Board
jberrey@waterboards.ca.gov
(916) 341-5872
SSO Main Website:
http://www.waterboards.ca.gov/water_issues/programs/sso/
List Serve Sign-Up:
http://www.waterboards.ca.gov/resources/email_subscriptions/s
wrcb_subscribe.shtml
Slide 13
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