David Totman
Two years ago, I wrote about Florida’s new Environmental Resource Management legislation. Now, it seems California is doubling down on that in scope with its proposed 2022 update to the Statewide Waste Discharge Requirements under the General Order for Sanitary Sewer Systems.
The proposed updates apply to ANY exfiltrated sewage reaching virtually ANY water body. California takes a comprehensive view to “Waters of the State” being any surface water body and any groundwater table. The proposed language basically wants you to be omnipotent when it comes to managing sanitary sewer systems. All within reason. The language does state that your Sewer System Management Plan (SSMP) must be of “scale and complexity” that matches the “scale and complexity of the sanitary sewer system(s)”. So, rural systems may breathe a little easier.
When I look at the 73-page update to the General Order, it all boils down to good asset management principles.
Yet, they say that you must implement “current standard industry practices”. So, does that mean Artificial Intelligence? Why not? Building upon our 30-year legacy in desktop products, Innovyze solutions are now fully cloud compliant and leveraging the latest in AI for optimization. These proposed changes also require the prioritization of system repairs and maintenance to be based on risk. Nearly 60 factors of risk!
Get ready… the factors to consider on risk include – but are not limited to:
- 29 threatened beneficial uses
- 7 parameters contributing to the likelihood of an SSO
- 4 sources of blockages
- 7 sources of climate change impact
- 6 factors influencing infrastructure failure
- 3 components of system capacity
- 3 community-based impacts
Believe it or not, this is all achievable with current Innovyze solutions. Our new Info360 platform has live risk modeling built in that can make sense of all these inputs. It’s just data, our tools, and your know-how.
Fortunately, in the state of California, many of these datasets are readily available from the state itself or found from authoritative datasets published in GIS format either in the public domain or from Esri or ArcGIS Online.
How to prepare your responses to these new requirements
When I look at the 73-page update to the General Order, it all boils down to good asset management principles. The key to environmental protection and public health is assuring good public infrastructure. What I most admire is that the update not only considers exfiltration of sewage due to structural failure, but also failure in the context of system capacity. Often I speak of hydrologic and hydraulic modeling in the context of sound asset management principles. The whole premise of water asset management is managing pressure and flow as a service, both in pipes and over/underground.
So how do you prepare to respond to these new requirements? If you’ve seen any of my previous webinars, I often rely on an easy 7-step program using Innovyze tools:
- Create/update your sanitary sewer asset registry (most likely in a GIS)
- Inspect your assets and assess their general health or condition
- Calculate Total Risk by evaluating the Likelihood of Failure (LoF) and the Impact or Consequence of Failure (CoF) per asset or asset class based on the General Order requirements
- Determine the Remaining Useful Life (RUL) per asset using best practice methods
- Define an organizational risk matrix for prioritization
- Process each asset in a decision tree, evaluating the logical grouping based on risk and maintenance/rehabilitation actions
- Aggregate prioritized assets into Capital or O&M projects for optimal spending
Optimizing your plant operations
Taking it a step further, tools are available to perform a full Life Cycle Cost Analysis (LCCA) to determine the optimal time of when to use capital in lieu of O&M dollars, which ultimately drives your budget needs and provides factual data for a possible rate adjustment.
The Innovyze tools give you a digital record of an Asset Management Plan (AMP). The documentation provided in the AMP can easily be a system of record for Section 8 of your SSMP. To respond to Section 8.2 for the Capacity Assessment and Design Criteria in the SSMP requirements update, there is no better tool than our Integrated Catchment Modeling (ICM) solution. The high-fidelity requirements in assessing the 60 factors of risk require a high-fidelity hydrologic and hydraulic (H&H) modeling solution. These are all part of the Innovyze hybrid cloud and desktop solutions.
Much of the updates are focused on the collection system that is comprised of linear assets. How about the vertical assets such as the treatment plants themselves? It does come down to discharges to water bodies which are inherent in the treatment plant permit. Optimizing plant operations is a beneficial use in context of the General Order. We immediately think of energy savings on pump operations in plant optimization, yet COVID-19 and the challenging supply chain issues for chemicals taught us a valuable lesson in using AI, optimizing chemical dosages became more critical than energy savings. Adhering to AI recommended dosages shows a reduction in chemical consumption, which, in turn, optimizes the discharge chemistry being more aligned with the permit requirements.
Everything you need to stay compliant
The 2022 proposed update to the Statewide Waste Discharge Requirements under the General Order for Sanitary Sewer Systems is very comprehensive. And, at first look, it may seem quite daunting. But when you break it down into its elements, it can be achieved with “current standard industry practices” available from Innovyze. Please give us a call – we’d be happy to tackle this together.