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Guide for Developing and Updating of Sewer System Management Plans
A Sewer System Management Plan is developed specifically for an agency and the size and complexity of its sewer system. The Sewer System Management Plan is, in essence, a declaration of how the agency will operate their collection system.
The Water Board requires that the Sewer System Management Plan be evaluated for compliance, implementation and effectiveness while addressing system resilience. To properly manage the Sewer System Management Plan, these concepts must be considered when developing each element.
Endorsed by the Following Organizations:
This Sewer System Management Plan Guidance Manual was prepared with the generous support of the Bay Area Clean Water Agencies (BACWA) with expert input from a consortium of sewer collection system agencies and leading subject matter experts.
It has been reviewed by State/Regional Water Board staff to help collection system agencies develop and update their Sewer System Management Plans (Sewer System Management Plans).
Frequently Asked Questions About the SSMP Guidance Manual
Although both WDRs require all publicly-owned sewer agencies with >1 mile of sewer pipes to enroll for regulatory coverage (due date was June 5, 2023), the 2022 WDR (referred to throughout this manual as the “Reissued” WDR) has significant additions, changes and new requirements.
This manual focuses on the key Reissued WDR requirements for facilitating agencies with developing and updating their Sewer System Management plans.
A summary of the key differences between the 2006 and 2022 WDRs is provided in Appendix 1 of the manual. In addition, official regulatory guidance published by the State Water Board is provided in Appendix 3.
- Visit the State Water Board's Spill Reduction website and Spill Reduction Library to stay current and review all the latest regulatory compliance information.
- Attend and document the completion of available industry training.
- Complete a Sewer System Management Plan (SSMP) Change Log for documenting all agency SSMP modifications for the Reissued WDR.
- Complete a checklist of compliance deadlines for the Reissued WDR.
This manual was developed to provide compliance assistance to small/medium-sized collection system owners and operators charged with complying the State Water Resources Control Board (SWRCB) General Reissued Waste Discharge Requirements (WDR) for Sanitary Sewer Systems (“Reissued WDR”, Order No. 2022-0103-DWQ).
The Reissued WDR replaced the 2006 WDR (Order No. 2006-003-DWQ and its Monitoring and Reporting Program, Order No. 2013-0058-EXEC), which became effective on June 5, 2023.
Although the manual will be useful to any size agency, it was carefully designed to match the size, scale, and complexity of small/medium-sized sewer systems to help facilitate practical use by all levels of agency personnel responsible for developing, updating, and implementing a Sewer System Management Plan.
Suggested strategies for compliance with the WDR appear in the document but due to the various sizes or complexities of sanitary sewer systems, compliance strategies will vary greatly.
It replaces the previous versions of the guidance manual prepared in 2015. However, a 2015 version of this manual is available for reference in the State Water Resources Control Board Spill Reduction Library. Many recommendations from the 2015 version have been incorporated into this manual including a summary of recommendations distilled from the document (see Appendix 4).
The manual offers a practical approach to developing a Sewer System Management Plan in a step-by-step fashion.
Full compliance with the 2022 Reissued WDR can help operators demonstrate proactive management to enforcement regulators in the event of a spill.
A point-by-point technical review of the Reissued WDR was completed by subject matter experts with over 150 years of combined experience to distill content in this manual for helping agencies expedite compliance, implementation, and improve effectiveness of their Sewer System Management Plans.
Over 300 individual collection system agency managers/operators were surveyed to ascertain opinions about the 2015 version and solicit additional input and guidance for development of this manual.
This manual provides guidance aimed at small/medium sized collection system agencies charged with conforming to all the requirements of the Reissued WDR.
It also refines, updates, and provides additional tools for helping Legally Responsible Officials, managers, supervisors, and field operators overcome challenges with the increased depth and complexity of the Reissued WDR (compared to original WDR, Order 2006-003-DWQ which has been rescinded).
- Replace legal review/assurances or shielding of an agency against potential enforcement.
- Substitute responsibility of an agency to complete/adopt a fully compliant Sewer System Management Plan.
- Provide a “One Size Fits All” document or checklist substitute.