The California Water Board is charged with preserving, enhancing, and restoring the quality of California’s water resources and drinking water for the protection of the environment, public health, and all beneficial uses of water quality. The Water Boards utilize the SSS WDRs as the primary regulatory tool for regulating publicly owned sewer systems part of its Sanitary Sewer Overflow Reduction Program (SSORP) mandated by the California Legislature. For addressing noncompliance, the State Water Board’s Water Quality Enforcement Policy is used by the state and regional water board staff as necessary to address noncompliance.
The California Water Boards is charged with preserving, enhancing, and restoring the quality of California’s water resources and drinking water for the protection of the environment, public health, and all beneficial uses of water quality. The Water Boards utilize the SSS WDRs as the primary regulatory tool for regulating publicly owned sewer systems part of its Sanitary Sewer Overflow Reduction Program (SSORP) mandated by the California Legislature. For addressing noncompliance, the State Water Boards' Water Quality Enforcement Policy is used by the state and regional water board staff as necessary to address noncompliance.
The United States Environmental Protection Agency (U.S. EPA) is charged with enforcing the federal Clean Water Act. Since California has taken the lead with implementation of its own regulations for addressing SSOs, the U.S. EPA relies on the SSS WDRs as the primary tool for evaluating compliance with the federal Clean Water Act. Historic records for collection system compliance inspections, compliance and enforcement cases and other information can be found using U.S. EPA’s Enforcement and Compliance History Online (ECHO):
SSMP Audits play significant importance to U.S. EPA staff with implementation of a National Enforcement Initiative for collection systems to keep raw sewage out of the nation’s waters.
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SSMP Audits are more than just regulatory requirements. They play a significant role in Water Board statewide prioritizations for compliance inspections and individual enforcement actions for addressing noncompliance. Historic examples of compliance inspections, audits, and enforcement actions are available on the SSORP library. “Self-reporting” data including individual spill reports certified by Enrollees covered under the SSS WDRs is hosted in the California Integrated Water Quality Management System (CIWQS) online. Additional detailed compliance and enforcement reports are also available online in addition to the individual SSO data “flat files.”
The SSMP Audit sheds light on many existing successful work programs in place by the District. When comparing the District SSO metrics performance with other collection systems in the Santa Ana Regional Board area and the throughout the State, the District performs near the top. Detailed document review incorporating review of the Water Board’s Pre-Inspection Questionnaire for collection systems, online video conference meetings, field staff interviews, and virtual asset inspections were relied on for evaluating the District’s SSO reduction efforts, SSMP strengths, effectiveness, and compliance.
The Audit further revealed the District’s dedication to continuous improvement and dedication to address historic violations and SSO prevention strategies. Successful staff involvement with the SSMP development, implementation, and updates, proactive force main predictive system monitoring, and detailed data work activity tracking represent specific examples of District effective SSMP practices currently in place.
The audit findings and best practices provide an advantage to help the District reflect on additional ways to improve its existing SSMP effectiveness, work programs and SSO reduction measures. Additional Key performance indicators (KPIs) for improved tracking of SSMP effectiveness, improvements to the existing District collection system critical spare part identification/inventories, improved data collection and training for field staff are some of the examples of the core best practices presented from the Audit.
The District maintains a robust SSO reduction program supported by key evidence obtained during the Audit. The final Audit results also provide the District with added compliance resilience and preparedness for regulatory inspections by the Water Boards, U.S. EPA or other entities.
The Audit approach by Fischer Compliance incorporates proprietary standards including inspections following procedures in use by the U.S. Environmental Protection Agency (U.S. EPA) and California Water Board personnel conducting compliance inspections under the Clean Water Act. These standards are also utilized by California Water Board inspectors with evaluating SSS WDRs compliance. This approach benefits the District through an objective evaluation using regulatory standards in use for added compliance resilience and preparedness for inspections by regulators or others.
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- 12+ years experience as California Water Board’s lead collection system compliance/enforcement inspector.
- 30+ years regulatory/environmental compliance engineering experience.
- Credentialed USEPA Clean Water Act Compliance Inspector (NPDES).
To provide a consistent, statewide regulatory approach to address Sanitary sewer overflows, the State Water Board adopted Statewide General Waste Discharge Requirements for Sanitary Sewer Systems, Water Quality Order No. 2006-0003 (Sanitary Sewer Systems General Order) on May 2, 2006. The Sanitary Sewer Systems General Order requires public agencies that own or operate sanitary sewer systems to develop and implement sewer system management plans and report all sanitary sewer overflows to the State Water Board’s online sanitary sewer overflow database. All public agencies including the City that own or operate a sanitary sewer system that is comprised of more than one mile of pipes or sewer lines which conveys wastewater to a publicly owned treatment facility must apply for coverage under the Sanitary Sewer Systems General Order. More detailed information on these requirements is included on the State Water Board website.
These sewer regulations require the City to conduct a bi-annual audit of the SSMP at least every 2 years and update of the entire plan at least every 5 years (see Provisions D.13(x) and D.14 contained in Order No 2006-003-DWQ).
While many consulting firms provide compliance services, Fischer Compliance LLC is credential by the USEPA and is uniquely qualified with technical review, evaluation compliance with SSMP Audits and SSMP updates derived from decades of inside knowledge and experience working at the Water Boards. This includes:
- Over 10 years as a professional engineer (P.E.) conducting 100 sewer system audits as a regulatory official supporting regional board staff throughout California.
- This expert knowledge, skills and experience delineates Fischer Compliance from others for helping ensure the city or special district strategically positions itself for reducing future violations, enforcement, and negative attention.
- Proprietary audit procedures developed and employed by Fischer Compliance LLC mirror procedures in use by USEPA and California Water Board inspectors, including:
- Pre-Inspection desktop data review, analysis, and conference.
- Onsite field inspection using Compliance Evaluation Inspection (CEI) procedures employed by USEPA inspectors.
- Post-Inspection data review, evaluation of SSMP implementation and best practice recommendations needed for updating SSMPs at best practice level.
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