The State Water Board passed the updates to the Statewide Waste Discharge Requirements December 6, 2022, with a compliance date of June 5, 2023. Resilience planning is required as part of the SSMP. Chris Ewers spoke twice to the Water Board in public workshop sessions on how to improve the draft requirements to make them more effective. In a letter to Diana Messina, shown here, we say what makes resilience planning uniquely valuable for water, wastewater, and stormwater utilities.
Building System Resilience
System resilience is vital for water, wastewater, and stormwater utilities. A resilient system will take upsets without emergency and will get back online quickly in the event of disasters. We incorporate resilience in our design and implementation work, but our work with resilience assessment came into focus with Emergency Response Planning for water systems to comply with the 2018 America’s Water Infrastructure Act. Our successful resilience development process is based on three elements:
Focus on asset-level analysis to demonstrate the greatest gains.
Use engineering design and system experience to zero in on critical elements and their protection.
Customize analysis with community impacts to make sound decisions. (Federal regional population and industry data provide the basis for economic impacts of water, wastewater, and stormwater emergencies. Community impacts can easily be more than 10,000 x the impacts on water utilities!)
Chris Ewers has conducted classes around California on assessing and improving system resilience in water and wastewater systems. Contact us to discuss how to improve system resilience assessment effectively and practically.
Complying with the new WDRs: Force main condition assessment
Force main condition assessment is an integral to getting your agency to comply with the Waste Discharge Requirements update approved 12/6/22 for full implementation 6/5/23. Here are some highlights:
Day-to-day requirements:
Increase system resilience - Condition assessment is required under Section 5.6 to develop system resilience, together with O&M improvements and repair and rehabilitation efforts.
Evaluate system performance - Spill volumes and spill counts reporting are required under Section 5.11, and as you probably know, force main failure-caused spills are the most destructive to the public and to an agency's finances and agenda. Proactive management of force mains using condition assessment can reduce your agency's spill volumes and spill counts.
Plan for spills - The WDR update requires the preparation of a Spill Emergency Response Plan (Section 5.12 and Section 6 of Attachment D), and because force mains figure so prominently in consequential spills, they can play a large role in the development of your agency's Spill Response Plan. Condition assessment builds knowledge of the risks of failure (and of likely failure causes), which will sharpen your planning and make it more effective.
Reduce penalties and likelihood of enforcement - Proactive action like condition assessment can lower the financial penalties against your agency if a spill occurs by demonstrating effort and expenditure toward reducing the likelihood of spills and can reduce the likelihood of enforcement per Section 6.1.6.
With next SSMP update:
SSMP system evaluation - The WDR update requires condition assessment as part of the SSMP update (Attachment D, Section 8.1). You'll need to prioritize condition assessment of system areas (something we do by implementing a failure risk model). This evaluation must also incorporate the impacts of climate change, changes in weather patterns, and power disruptions.
Next steps to bring your agency into compliance before the 6/5/2023 deadline:
Get started. As you can see, condition assessment is a direct and indirect requirement for the June 5, 2023 compliance deadline. Though your agency may be at the long end of the six-year SSMP update period, give yourself time to develop a programmatic, systematic, and effective force main condition assessment program. Ewers Engineering has helped develop Force Main Condition Assessment Programs for agencies that integrate with their overall objectives, with their ongoing projects, and as staff extension to limit the impact on agency staff. We would enjoy discussing how this could be accomplished with you.
