State official outlines reporting, planning and safety requirements under Utah Sewer Management Program

At a Sewer Summit presentation, Jennifer Robinson of the Utah Division of Water Quality outlined key requirements and operational guidance under the Utah Sewer Management Program (USMP) general permit, including when sanitary sewer overflows (SSOs) must be reported, required elements of sewer system management plans (SSMPs) and safety practices for field staff.

Robinson said the permit applies to any publicly, federally or state-owned sewer collection system in Utah and that SSOs meeting certain thresholds must be reported immediately. “The class ones are required to be reported within 24 hours to the division of water quality,” Robinson said. She summarized two commonly used thresholds that trigger class‑1 reporting: an overflow affecting more than five homes (i.e., six or more) and an overflow totaling 5,000 gallons across structures or into multiple buildings. Robinson also said, “if it ever hits a waterway or a wetland, it’s a class 1.”

The permit requires an annual report and a five‑day followup report for class‑1 events documenting who, what, when, where and how. Robinson told attendees the USMP annual report is due either April 1 or April 15 — “which is also tax day,” she noted — and emphasized the value of keeping contemporaneous documentation of calls, maintenance and cleaning to demonstrate compliance. She said the division accepts emailed submissions but recommends mailing the five‑day followup by U.S. Postal Service so the postmark documents the date received; Robinson added the enforcement team treats the five‑day requirement as calendar days unless otherwise specified.

Robinson described the SSMP as the written record of day‑to‑day maintenance and larger capital plans: “Essentially, that’s kind of just what you’re doing on a daily basis, but it’s in writing.” Required SSMP elements she listed include cleaning and television (TV) schedules, a hot‑spot inventory, a capital improvement plan (CIP), training for on‑call staff, and an inventory of equipment and parts. She said the CIP and flood control plans are targeted at larger systems — she cited a 2,000‑connection threshold mentioned in the permit — but added that communities with existing master plans typically meet the requirement.

Robinson discussed recommended cleaning and inspection frequencies reported during EPA inspections: typical cleaning cycles range from every 3–5 years and TVing every 5–10 years, though some utilities clean more frequently. She said EPA reviewers have at times recommended cleaning at a rate that would cover 50% of a system annually (equating to a two‑year cycle for the entire collection system), but Robinson said the division has used local hot‑spot inventories and operational history when preparing inspection reports.

Robinson urged utilities to document lateral versus mainline responsibilities and to involve health departments when lateral problems persist. For industrial and commercial dischargers, she reiterated pretreatment responsibilities: communities with an approved pretreatment program should coordinate with their pretreatment coordinator, and local enforcement authority should be exercised against industrial users that cause blockages or violations. She recommended dye testing and above/below sampling when investigating sources of contamination, and described a storm‑related SSO investigation in which dilution from storm inflows affected sample results.

The presentation included practical guidance for customer outreach and prevention: distribute multilingual do’s‑and‑don’ts materials or pictorial hang tags, educate residents about grease management and discarding wipes, and require interceptors where appropriate for restaurants or prospective food service tenants. Robinson warned that requiring interceptors up front avoids conflicts when a non‑food tenant later becomes a restaurant tenant.

Robinson concluded with field safety guidance: test manhole atmospheres, work in pairs for safety, and avoid entering confined spaces without appropriate monitoring and procedures. She provided a new contact number for spill notifications and urged utilities to call the division’s emergency spill line for class‑1 events, then follow up with her for technical direction. “Most of the time I send emails, and then you have it well documented of this is what is expected,” she said.

Ending: The talk focused on operational clarity: document cleaning and inspections, report class‑1 SSOs promptly, maintain an up‑to‑date SSMP and CIP, exercise pretreatment and enforcement authority as needed, and prioritize field safety when responding to calls.