CSPA Comments on Sanitary Sewer System Order

On 13 May 2011, CSPA submitted comments to the State Water Resources Control Board regarding the proposed revision of the general waste discharge requirements (WDRs) for sanitary sewer systems.  Sanitary system spills of untreated sewage are a chronic and serious problem that threatens both fisheries and human health. CSPA has initiated enforcement actions against municipalities that have failed to provide adequate maintenance and sewer line capacity that cause egregious discharges of sanitary wastes.  These enforcement efforts include lawsuits against Stockton, El Dorado Irrigation District and the City and County of Sacramento.  The purpose of the revised WDRs is to provide consistent statewide requirements for quantifying and reducing the number of wastewater spills and the volume of wastewater spilled in the state.  The original WDRs were issued in 2006 and revised in 2008.  The State Board will consider the proposed revision at an upcoming meeting. Proposed revisions presented in the draft WDRs include modifying applicability criteria to include a flow threshold in addition to the pipe mileage threshold, expanding coverage of the SSS WDRs to private collection systems meeting the pipe mileage and proposed flow thresholds, mandating the reporting of private lateral spills by enrollees when they become aware of the spills, revisions to streamline spill notification points of contact, changing the prohibition against spills to “waters of the United States” to a prohibition against spills to “surface waters of the state,” revisions to the Sewer System Management Plan requirements, audit schedules, and re-certification schedules, and other changes.     CSPA Comments SSS WDRs