Authored by Yazdan Emrani, M.S., P.E., Sr. Vice President / Principal
Part I of this blog series focused on the whys and whats of the regulations adopted by the State Water Resources Control Board known as the Waste Discharge Requirements (WDRs) Order No. 2006-0003-DWQ. Those regulations require that all publicly owned sanitary sewer systems greater than one mile comply. In Part II, we focus on the Sewer System Management Plan (SSMP) that is required for each entity enrolled in the WDR program.
Program Overview
Sanitary sewer systems have long been treated as “Out of sight, out of mind” in our profession and funds to fix or upgrade these systems have been few and scarce. So has implementation of the Sewer System Management Plan (SSMP) by some municipalities. The SSMP is required by the State Water Board as part of the WDR. The SSMP has been treated as an afterthought or even a commodity that any consulting firm should be able to do for the least amount of money. This has led to several negative consequences ranging from putting the agency in hot water with the State Water Board’s Office of Enforcement and Investigation, to having to re-do part or parts of their SSMP at great cost. Nobody wants to have to “re-do” a task. In our personal lives we don’t want to have to “re-do” a re-modeling job because it wasn’t done properly nor “re-do” a car repair because of shoddy workmanship. We shouldn’t have to “re-do” any part of the SSMP either. That is why the only good SSMP is the one you do once and maintain over time. In future blog posts we will share some of the Best Management Practices (BMPs) of an effective SSMP. But first let’s get to the elements of an SSMP.
Like many programs in our country, SSMP is a “12-step” program! And not all of these steps are created equal from a time and expenditure point of view. Here they are in chronological order:
- Goals
- Organization
- Legal Authority
- Operations & Maintenance Program
- Design and Performance
- Emergency Response
- FOG Program
- System Evaluation and Capacity Assurance (SECAP)
- Monitoring, Measurement and Modification
- Program Audits
- Communication
- Final Certification
From a State Water Board perspective and depending on the population your agency serves, all SSMPs should have been completed, at the latest, by August of 2010. Many agencies have not complied and that is why the State Water Board has moved into the “audit and compliance enforcement” mode. Hall & Foreman, Inc. recently held a workshop on the status of WDR Overview and BMPs for SSMP implementation. As part of this workshop, Jim Fischer of the State Water Board’s Office of Enforcement and Special Investigation gave a comprehensive overview of his office’s work on auditing agencies’ efforts on WDR compliance. Jim also gave examples of how agencies can perform a “Gap Analysis” to ensure compliance. Our next blog post on this subject will discuss some of the effective and proven BMPs for implementing a successful SSMP.
In the meantime, contact Hall & Foreman, Inc., if you need assistance with elements of your SSMP or meeting your WDR requirements.







