Why does BES require sewer access authorization?
This authorization ensures consistent notification and coordination of access to Environmental Services conveyance systems (i.e., storm sewers, sanitary and combined sewers) to protect the systems from damage and to protect both the public and city personnel at risk if work is going on simultaneously in the same areas of the system. In addition, the city has the right to refuse access to parties who want access for actions that are not in the public interest.
What is access?
Access is entering, or causing something to enter, a city conveyance system. For example, putting a camera into a sewer (even if no people go down after it) requires authorization. But someone lifting a manhole cover for a visual inspection does not need authorization, as long as they don’t break the plane of the manhole.
Access does not include right-of-entry into bureau buildings (e.g., pump stations). That authorization, if needed, must be obtained separately through the existing right-of-entry process.
Who is covered? What actions are covered? Is anyone exempt?
Sewer access authorization is needed for any access to city stormwater, sanitary, or combined sewer conveyance systems which has not been authorized by another city agreement, permit, contract, or approval mechanism. Access is defined as entering, or causing something to enter, a city conveyance system. In order to obtain sewer access authorization, the requested access must not conflict with the bureau’s mission (i.e., protecting public health, water quality, and the environment). Requested access must have a defined duration and cannot include structural changes to city assets.
Examples of activities that may be allowed via sewer access authorization:
- Sample or data collection activities required by a state or federal agency (e.g., characterization of discharges from contaminated sites under approved DEQ or EPA work plans) or in anticipation of obtaining a city permit. NPDES permit holders that need to collect samples in the sewers will require a permit with multiple entries unless they have other authorization from the city that allows entry.
- Work complying with an enforcement action from the city.
- Conveyance or other system cleaning by non-city contractors.
- Video surveys to:
1) confirm locations of lateral connections;
2) evaluate dry and wet weather discharges to the system;
3) monitor the effects of construction activities (e.g., grouting);
4) confirm locations of contaminants for required cleaning or to check cleaning effectiveness; and
5) identify locations of future sampling activities related to permits or required cleaning activities.
- For emergency response work by other agencies, an annual permit allowing multiple entries is required.
- The Environmental Services director may make specific exceptions to this provision to facilitate public interest projects that don’t adversely affect the protection of human health and the environment. Requests for exceptions should be made to Environmental Services.
Examples of activities that are allowed without system access authorization:
Prior notification of activity is required for items in italics.
- Visual observations where access does not entail breaking the system plane (e.g., manhole or inlet).
- Data collection or entry activities that are covered by other permits or authorizations (e.g., wastewater, stormwater, batch discharges)
- Dye-testing where appropriate notifications have been made to the city and any other required agency.
- Routine discharges through approved stormwater and sanitary connections.
- Work that is performed under the direction of BES employees (covers BES, PBOT Maintenance, and city contractors’ work).
- Survey work that does not require confined space entry.
Authorization will not be issued if:
- Required documentation (e.g., insurance certificate, materials management plan, safety plan) were either insufficient or were not provided by the requesting party.
- The request poses an unacceptable risk to city assets or operations.
- The request is for an activity that is not in the public interest or may be detrimental to the public health, water quality, or the environment.
- Activity does not fall into one of the allowed categories.
Will everyone who applies be given authorization?
Not necessarily. Environmental Services reviews authorization requests to confirm that the requested access does not conflict with the bureau’s mission (i.e., protecting public health, water quality, and the environment), that the requested access has a defined duration and does not include structural changes to city assets, and does not go against the public interest. The city has the right to refuse access to its conveyance systems.
How does someone apply for authorization?
The Bureau of Environmental Services issues authorization. Download and complete the request form.
What conditions does Environmental Services put on entering parties?
Entering parties are required to:
- Notify the bureau of the times of entry;
- Comply with all other regulatory requirements (e.g., OSHA confined space entry and PBOT right-of-way requirements);
- Allow access by a bureau inspector (if appropriate); and
- Provide any data obtained from entry activities (including TV and chemical data) to Environmental Services.
The authorization may require that copies of all recorded data collected under the authorization be provided to Environmental Services. Details of this requirement are included in the terms of the authorization.
What fees are charged for an authorization?
There is no fee for a system entry authorization.
FOR MORE INFORMATION
For questions regarding a system entry authorization, see contacts below.