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April 1999

Y2K & The State Water Resources Control Board

The California State Water Resources Control Board (SWRCB) is working to establish a reasonable standard of due diligence, or reasonable care, for POTWs in dealing with the Y2K Bug.  The purpose of the policy is to mitigate penalties that would result from violations of discharge permit requirements that might occur despite efforts to alleviate the effects of the Y2K Bug.  Any mitigation of penalties would be based upon a reasonable attempt, under standards yet to be established, to identify and remediate Y2K problems that can be avoided which might result in violation of discharge standards if not identified and dealt with in a timely fashion. 

As part of CSRMA's ongoing efforts to assist members in combating the potential losses the Y2K Bug can cause, CSRMA Risk Control is monitoring the development of these due diligence standards and will provide input to the SWRCB in their development. 

The US Environmental Protection Agency (USEPA) have issued a number of guidance documents that were developed with input from Y2K remediation professionals detailing risk management strategies for approaching the Y2K Bug.  These strategies are described in the
EPA 2000 papers.  It is anticipated that any reasonable care policy the SWRCB adopts will include the strategy elements outlined in the EPA 2000 papers.  These strategy elements are:

    1.  Awareness:The following must be made aware of the Y2K Bug and the need to address it within their organizations:

    •   Owners and operators of POTWs
    •   Industrial dischargers to POTWs
    •   Equipment manufacturers
    •   Communications providers
    •   Energy providers
    •   Computer and software providers
    •   Support services providers
    •   Local emergency response organizations

    All communication efforts made to these organizations should be documented, as should all responses received.

    Letters and questionnaires should be sent to all dischargers that have the potential for non-standard flows to the waste stream (a sample letter is included with this Bulletin and is available from www.csrma.org).  Follow-up efforts should be undertaken if their responses indicate a lack of preparedness.

       

    2.  Assessment/Inventory:Assessing the extent of the problem is the next step.  Members should use the CSRMA Y2K Preparedness Guide and Survey to assist them in locating and identifying all software and equipment that may be vulnerable. 

    3.  Correction:Once the CSRMA Y2K Preparedness Guide and Survey has been completed, those areas where a risk exposure exists will be clearer.  It is at this point that members should prioritize the exposures into those that pose the greatest threat to safety, health, the environment and property, and treatment quality.  Given the limited time remaining, Members should focus their efforts and resources on correcting these exposures.

    4.  Contingency Plans:Many exposures will not be able to be completely corrected in the time remaining.  For these exposures, and for general operations, each member should develop a contingency plan to deal with unforeseen problems and emergencies.  Among other things, the plan should address the manual operation of systems until computerized control is restored and problems resolved.  This includes remote sites whose control is dependent upon telephone service.

    5.  Testing/ Validation:Y2K testing must have a minimal disruptive effect on the continued operation of each member's facility.  Once a testing procedure is developed, tests using the following dates should be performed:

     

    • 04/09/1999Special use Julian date (99th day of 99th year)
    • 07/01/1999Many governments begin their fiscal year
    • 08/21/1999Global Positioning System date rollover affects military, transportation, Geographic Information System (GIS) and Automatic Vehicle Locator
    • 09/09/1999Programmers use 9/9/99as an end of file or infinity indicator
    • 10/01/1999Federal government and others begin FY2000
    • 12/31/1999End of year baseline
    • 01/01/2000Date rollover will halt, confuse or otherwise disrupt many systems and devices
    • 01/10/2000First date requiring full use of seven digits
    • 02/28/2000Day prior to leap year
    • 02/29/2000Many systems will not recognize leap year in 2000
    • 02/30/2000Invalid date; test to ensure that leap year logic is functioning
    • 10/10/2000First date requiring the use of 8 digits; may cause failures
    • 12/31/2000Some systems using Julian dates may not recognize the 366th day of the year (another leap year problem)

    ( IMPORTANT!  Document all Y2K preparedness activities! )

       

CSRMA Risk Control will continue to monitor the SWRCB's activities in this area and provide updates to members as they develop.

 

Please Complete the Y2K Preparedness Guide and Survey and Return to

David Patzer

 

This and other useful Y2K risk control information is available on the CSRMA web site at

WWW.CSRMA.ORG

David Patzer, Risk Control Advisor

(415) 371-5430

dpatzer@rfdriver.com

 

 

 

_______________________________________________________________________________

CSRMA Sample Y2K Letter To Industrial Dischargers

Download this letter word_doc_icon2

 

Dear ___________________:

The (your organization) is notifying dischargers of potential Year 2000 (Y2K) problems that may occur in some of your operational systems.  This problem is due to embedded microchips and software that record the year using only the last two digits (e.g., "98" rather than "1998").

On January 1, 2000, these embedded microchips have the potential to cause system failure for operational systems, such as heating and air conditioning, elevators, energy management control systems, alarms, security systems, processes and electronic access.  Any equipment or building system that contains date-sensitive microchips or software may not work if they cannot recognize "00" as the year 2000.  The result could be disruptive, at least.

The (your organization) wants to ensure uninterrupted services through the 01/01/2000 date.  Compliance with wastewater discharger standards continue and all fines and criminal penalties are unabated by Y2K problems.

We know that you strive to ensure uninterrupted operation of operating systems.  It is your responsibility to ensure that all computer-controlled facility components and facility systems are Y2K-compliant.  Failure to ensure this may violate your discharge requirements to (your organization) sanitary district.

In order for us to ensure that your discharge to (your organization ) sanitary district meets requirements, we are requesting that you provide information on your organization's Y2K preparedness, specifically as it relates to your permitted discharges and any other activity that may impact the sanitary server.  Please return this information within thirty (30) days from the date of this letter to : ____________________________________.

Also, please provide us with the most up-to-date information available should you for any reason find out at a later date that your operation is not Y2K-compliant or that you will not be able to meet your scheduled date(s) for compliance.

If you need additional information on the Y2K issue, it can be obtained at the Internet site <www.year2000.com> as well as many news and business publications.  For other questions regarding your permit, please contact ___________________________________.  Thank you for your cooperation in this matter.

 

Sincerely,

 

General Manager

(Your Sanitary District)