Pipeline Separation Variance Waiver Process

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STATE REQUIREMENTS

The State Water Resources Control Board’s Division of Drinking Water (DDW) has established various standards to protect public health. Water purveyors (including Sacramento Suburban Water District) are required to comply with DDW regulations.

Included in DDW regulations are requirements for separation of potable (drinking) water pipelines and those pipelines that convey non-potable fluids (such as storm drains and sewers).

Where project physical constraints prevent meeting DDW pipeline separation requirements, a Separation Variance Waiver is required to be obtained from DDW for the design - prior to construction.

Note that DDW:

issues waivers only to water purveyors – not to developers or designers.
does not issue waivers for separation variances already installed.

Projects that are constructed in violation of a DDW requirement and without a DDW waiver will not be approved by the District and connection to the District’s water supply will be denied.

DISTRICT PROCESS

The District understands that achieving DDW separation may not be entirely possible on some projects. Engineering staff are committed to providing the necessary guidance to developers to move projects forward efficiently while maximizing protection of the water system and public health.

If project design has carefully and thoroughly evaluated ALL alternatives to encroaching on DDW separation criteria (including alternatives that require re-routing existing non-potable pipelines), the developer should submit this information with a proposed waiver-required design for District review.

Developers should be aware that there are significant cost and schedule implications to projects requiring waivers, including:

Receiving waivers from DDW can take months, which delays the District’s approval of a project.
Extensive construction inspection and documentation requirements.
Construction waiver-compliance certification is required by the developer’s engineer.

Following is an overview of the waiver process for projects that propose to include a DDW separation variance.

Step 1	Designer exhausts all alternatives to a DDW separation variance. All options are required to be considered to protect the public health regardless of impacts to the project. This will be examined very closely during the District’s plan submittal review process (and again by DDW during their own review process).
Step 2	Designer submits a Separation Information Report to the District: containing full and detailed information on all exhausted alternatives to a separation variance. includes an analysis and statement to the effect that separation variance is unavoidable with all possible alternatives. states that the designed project both minimizes encroachment into DDW separation criteria and includes sufficient mitigation to protect the public health. requests variance(s) and identifies variance locations(s) on the included plan review submittal set. stamped and singed by a licensed Civil Engineer.
Step 3	District reviews submittal and provides comments to plans and the Separation Information Report.
Step 4	District response to proposed variance: Denied: Consultant re-designs as necessary: or Approved: Move to next step.
Step 5	Consultant prepares a Separation Variance Request Letter to District, stamped and signed by a licensed Civil Engineer. District will provide guidance on a case-by-case basis.
Step 6	District prepares Separation Waiver Request package and submits to DDW.
Step 7	District receives response from DDW and communicates next steps with consultant and/or developer.