scap collection committee workshop swrcb, region 8scap1.org/collection reference library/050110...

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


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)


Capacity management

Identification of and defect resolution (CCTV?)

Appropriate training on a regular basis

Equipment and parts inventories


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


Action plan updates for changes / schedule updates

Rehab / Capital ImprovementsRehab / Capital Improvements

Programs to identify and prioritize

Structural and hydraulic deficiencies


Information management for review and update

Programs to identify and prioritize

Structural and hydraulic deficiencies


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



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



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




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



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?



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


• 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


• 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


• 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 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 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


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


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??

scap collection committee workshop swrcb, region 8scap1.org/collection reference library/050110...

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