HomeMy WebLinkAbout11.a. (Handout) Paul Causey Report on CWEA Collections Committee I I.a. Causey Report
From: PAUL CAUSEY (Handout)
Subject: SWRCB WDR Presentation Highlights from Morro Bay CWEA Meeting
Date: July 31,2019 at 4:08 PM
To: Adam Link alink@casaweb.org, Jared Voskuhl JVoskuhl@casaweb.org
Adam/Jared,
I attended the CWEA Collections Committee last weekend in Morro Bay. Diana Messina made
a two hour presentation centered on the States proposed changes to the WDR from previous
discussions with stakeholders. Here are my bullet notes of her presentation - anything in red is
or should be discussed by the CWG I think.
• Expect draft wording very soon -to a very broad group
• State Goals for WDR
o Want proactive system management
o Effective spill response
o Proactive planning and management
o Transparent reporting
o "Feasible and reasonable" regulations-good faith effort to comply- personnel,
budget, equipment by governing board
• Looking for common ground - RWQCB, enrollees, environmental groups
• Thanked CASA for several redlined documents
• New term - discharges from "non-federal waters" this will bring groundwater in to regs-
will require new definition
• Temporary pipe systems (bypass) no SSOs
• Expect enrolled to have storm water system information
• Must use at least two volume estimation methods
• Expect firmer enforcement of intentional falsification of spill reporting i.e. don't know or
explain start times; currently 900 start times games as notification time
• CWA compliance does not equal WDR compliance
• SSO Rate/100 miles/year- <2 witnout cat 4 overnows? Well performing agency
o Establish baseline rate as average of last five years SSO rate from WDR effective
date
o Expect biannual reduction (i.e. 10% per period) until reach 2 or below
o Enviros state current rate is 1.6 across entire state
o Some strong push back from group
o Incerns raises
* Just small pipes 6 and 8?
Agencies with laterals vs no laterals
Only use main SSOs not laterals
■ Small agencies with less than 100 mile systems
5 year averaging to account for single year highs so results from significant
rainfall
Focus by diameter of pipe
■ Ignore large diameter pipe -trunk and interceptor sewers
* Impacts of timing for capital project that result from pipe conditions may take
more than 2 years
■ Will force elected to add funding if this is requirement
• Exfiltration call it leakage - will neea to ue In WDR somenow
• Want enhanced ability for external desk top audits by SWRCB/RWQCB
• Greater focus on LRO penalty of purgery requirements- LRO certification of reports and
supporting information
• PLSD will probably be mandatory
• Resiiiency- evaluated thru risk anafysis ana prioritization i.e. wipes maybe, etc.)
• Will require enrollees to report private systems to SWRCB- CIWQS??
• Agree with minor spills
• Category 4
• Documentation available on request
• Concern for lots of 49 gallon reports-will be watching for this
• Expect this to be contentious in front of SWRCB hearings
• May require number of minors to be reported with no spill reporting
• SSMP Audits
• 3-3-2 requirement for audits
• SSMP revisions at 8 years or significant changes
• Expect to see implementation of audit findings
• May require LRO certification just like SSMP
• Will be very contentious in front of SWRCB
• Certification - might be tied to LRO requirement- want professional association formal
position in writing to SWRCB
• Annual Compuance RCKnowieagement - well performing agency
• Based upon SSO rate, timeline compliance with deadlines, etc,
• Letter to enrollee issued by SWRCB Deputy Director
• List of agencies on state website annually
Lots of information and great discussion by the Collection Committee-2 plus hours was used
for this exchange of ideas. Hope this helps. Dianna has promised to send me her presentation
and I will forward it when received. Lots to mull over and consider as we get ready for the drafts
from the SWRCB staff.
Paul H. Causey
Causey Consulting