Assumed Regulatory Critiques of Hypothetical Utility SSO Reporting Practices
There is no industry-accepted, consistent definition of a sanitary sewer overflow (SSO) event. The federal SSO Rule attempted to institute a consistent definition for U.S. utilities, but this rule was immediately withdrawn after it’s initial January 2001 publication and has not been reissued. The proposed definition of an SSO under the SSO Rule was broad in that it included discharges to the environment as well as backups into customer homes or businesses.
The definition issue gets further complicated for reportable versus non-reportable SSO events. Numerous factors affect whether or not an SSO event is considered reportable or non-reportable. How these factors are applied can significantly impact SSO totals for a given utility, which in turn can affect regulatory impressions of a particular utility as well as overall benchmarking comparisons between utilities.
This paper provides assumed regulatory agency critiques of hypothetical utility’s reporting practices for various SSO scenarios based on actual events. The role of various assumed regulatory agencies will be played by David James, Program Specialist, Texas Commission on Environmental Quality (TCEQ). The role of various hypothetical utilities will be played by Jane McLamarrah, MWH.
SSO Reporting Scenarios
Several SSO scenarios will be presented. The format will be to: a) lay out the facts associated with the overflow event; b) present a hypothetical utility’s decision on how, or if, to report the event; and c) provide an assumed regulatory agency’s critique of what the utility should have done to report the event. Because of the inconsistent SSO reporting requirements across the country, the “assumed” regulatory agency role will represent varying regulatory requirements and will not provide a single, uniform reporting critique.