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