The State Water Resources Control Board (State Water Board) adopted Statewide General Waste Discharge Requirements (WDRs) for Sanitary Sewer Systems on May 2, 2006. Now that 10 years have passed since the plan was set, we wanted to find out how the state is doing. So we recently interviewed Sam Rose, Superintendent-Wastewater Collection System at South Placer Municipal Utility District and CWEA Technical Certification Program Chair/Director. As a refresher, the WDR plan was put in place to provide a consistent, statewide regulatory approach to address SSOs. The Sanitary Sewer Systems WDR requires public agencies that own or operate sanitary sewer systems to develop and implement sewer system management plans and report all SSOs to the State Water Board’s online SSO database.
After 10 years of the WDR what has been the main impact on California?
Transparency and magnitude. Transparency – The SSO Incident map is available for anyone to see. Agency SSMPs are posted on websites. All of our cards on the table. Magnitude – I think we have better defined the problem. The cause(s) of spills, number of spills and spill volume and (hopefully) impact on the environment and public health.
What impact has implementation of the WDR had on your agency?
It has changed the way records are kept. We used to keep records for internal purposes. Records were less complete then because everyone internally knew what and how we did things. It didn’t take as many words to communicate. After implementation of the WDR, we had a new audience in the Water Boards. An audience that was not familiar with our operations and the industry as a whole. We realized our records appeared incomplete and could be interpreted differently than what we intended.
This was a big cultural change to implement and a huge challenge for field staff. We now require supervisory staff to complete English 1A at the college level and we established “On-Call Supervisors” that are required (amongst other duties) to be involved with all spill responses to support first response personnel and ensure the pertinent data is collected for reporting purposes.
The WDR made us better at some aspects of SSO prevention and response. We have developed more consistent ways to estimate spill volume. We have developed a more structured way to train response personnel. We developed a more comprehensive hydraulic model and we established a source control program where prior to WDR implementation we simply cleaned lines that were known to have grease issues.
Looking back would you do anything differently in the way you implemented WDR compliance?
Probably not. We started by using engineering consultants to perform a Gap Analysis and, after completion, we believed we could argue that we were essentially in compliance doing what we have always been doing. We recognized some areas where we could improve and we pursued these improvements.
What has been the best outcome resulting from the WDR?
The obvious answer is the reduction in number and volume of spills. That said, prior to implementation of the WDR, we did many things in an informal manner. We were doing all the work, but we did not have formal, written programs and SOP’s and our documentation was minimal. Developing these programs and procedures has helped all employees to gain a better understanding of why we are doing what we are doing, which made expectations more clear and has led to better employee buy-in and performance.
What is your least favorite part of the WDR?
We have made adjustments and settled into a new normal now, but the process and everything involved is burdensome. It requires significant staff time to document and report SSO events.
What do you want to see happen over the next 10 years with the WDR?
Evaluation of the data collected and program adjustments made accordingly, with the hope that the whole process could be made to be less onerous. It is essential to understand the impact that SSOs have on the environment and public health. I’m not sure how this could be measured and quantified, but does a one gallon spill from a clean-out onto a lawn that is properly retrieved and cleaned have a meaningful impact on public health and the environment?
Anything else you’d like to add?
One size does not fit all in the world of wastewater collection systems and I think caution should be exercised when comparing agencies.