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10/16/2007, BUS 2 - SEWER SYSTEM MANAGEMENT PLAN
ADcounat �1011(010'r1 agenbA Repoat �N CITY OF S A.N LUIS 0 B 1 S P 0 FROM: .John Moss, Utilities Director Prepared By: David Hix, Wastewater Division Manager SUBJECT: SEWER SYSTEM MANAGEMENT PLAN CAO RECOMMENDATION Approve the Development Plan and Schedule for the City's Sewer System Management Plan. DISCUSSION Regulatory Background On May 6, 2006, the State of California adopted General Waste Discharge Requirements for Sanitary Sewer Systems to provide a consistent, statewide regulatory approach to address Sanitary Sewer Overflows (SSOs). The regulations require a public agency that owns or operates a sanitary sewer system to develop and implement a sewer system management plan and report all SSOs to the State Water Board's online SSO database. SSOs have been identified as a major threat to public health and water quality because of the pathogens, toxic pollutants and nutrients they contain and have been a focus of State Water Quality Regulators over the past several years. Public agencies that own or operate a sanitary sewer system that is comprised of one mile or more of pipeline which transports sewage to a treatment facility must file a Notice of Intent (NOI) to comply with the requirements. The program has two major components;reporting all SSOs in the statewide spill reporting database and development of a Sewer System Management Plan (SSMP). On July 13, 2006 the City submitted its NOI and began using the statewide spill- reporting database on May 2nd of this year. Sewer System Management Program (SSMP) The SSMP documents an agency's provisions to provide proper and efficient management, operation, and maintenance of its sanitary sewer system, including a spill response plan to ensure a standard and effective response to SSO's. The Program has 11 elements. Below is a brief description of each element: C�"_ Sewer System Management Plan J Page 2 1. GoaL Provide goals for the management and operation of the sanitary sewer system. Z Organization. The name of the responsible or authorized City representative, and description of the organization including positions responsible for implementing specific portions of the SSMP and reporting to other agencies. 3. Legal Authority. Demonstration that the agency has the legal authority to; prevent illicit discharges, require sewer connections, limit the discharge of constituents that would cause blockages, and enforcement of its sewer ordinance. 4. Operation and Maintenance Program. Descriptions of sewer maps and infrastructure documentation, preventative maintence activities,rehabilitation and replacement programs, training and equipment. S. Design and Performance Program. Design and construction standards and specifications for new and existing sewer facilities. 6. Overflow Emergency Response. Notification procedures, training, emergency operations, and mitigation and minimization of overflows. 7. Fats, Oils and Grease(FOG) Control Program. Evaluate, and if needed, implement a program to reduce and/or prevent the discharge of fats, oils and grease into the sewer. 8. System Evaluation and Capacity Assurance. Evaluate the collection system to determine hydraulic capacity and include, if needed, funding for capital improvement. 9. Monitoring,Measurement and Program Modifications. Maintain information for evaluation of program effectiveness and guiding modifications. 10. SSMP Program Audits. Conduct periodic internal audits to evaluate program effectiveness. IL Communication Program. Public participation and outreach of program implementation and effectiveness. The regulations also include provisions that the agency's governing body approve, at a public meeting, the development plan and schedule of the SSMP by November 2, 2007 and the final SSMP by August 2, 2009. Below is a table that outlines the deadlines for the compliance with the regulations. o� 'o< Sewer System Management Plan Page 3 Table 1. Compliance deadlines for SanitarE Sewer Regulations Sewer Svstem .1%,lanagement Plan Elements Required Completion bate Approved SSMP Development.Plan and Schedule I Goal November 2, 2007 2 Organization 3 Legal Authority 4 Operation and Maintenance Program 5 Design and Performance Program May 2, 2009 6 Overflow Emergency Response 7 Fats, Oils and Grease FOG Control Program 8 System Evaluation and Capacity Assurance 9 Monitoring, Measurement and Program Modifications August 2, 2009 10 SSMP Program Audits 11 Communication Program Approved Final Sewer System Management Plan Development Plan and Schedule. Attached to this report is the Development Plan and Schedule for the SSMP. This document outlines the necessary steps,with deadlines, staff intends to take to comply with the regulations. While extensive, we have already accomplished much of the order's requirements and staff believes the SSMP can be developed with relative ease by documenting the existing elements and activities of the Wastewater Collection and Pretreatment programs. Provided below is a brief summary of the City's existing activities and corresponding SSMP elements: Legal Authority. element 3. The City possesses legal authority through its Sewer Use Ordinance and uses the ordinance to prevent or control illegal discharges, require sewer connections and enforce violations. Operations and Maintenance: element 4. Wastewater Collection staff hydro-clean lines daily, and routinely repairs pipes, update maps, perform video and other inspections and maintain facilities to ensure uninterrupted flow of wastewater and efficient operation and maintenance of the collection system. Wastewater Collection staff utilize a database to document and store all maintenance activities. This comprehensive database allows staff to trend activities, assess capacity, establish capital project priority, evaluate program effectiveness, produce work orders and store and retrieve information. Staff began using this database in the late 1980's and it has allowed the section to efficiently manage resources resulting in increased productivity and a decrease in overflows,blockages, overtime and customer service interruptions. All of the City's lift stations are continually monitored using a computerized control and monitoring system. The system allows operators to monitor wet well levels and pumping. It is connected to a paging system that alerts staff to problems 24 hours a day. The system has resulted in advance notice of pending problems and decreased spills. C� Sewer System Management Plan Page 4 The Wastewater Collection Section has an ample training budget to not only ensure staff obtains the required training, but also help staff achieve advanced competency in the wastewater collection profession. This approach is part of the Utilities Department Skills Based Pay Program designed not only to ensure employee training,but on-going professional growth and employee retention. Design,Engineering and Construction element S.. Utilities staff spends significant time developing its capital improvement program. Utilities and engineering staff have worked cooperatively to develop and improve design standards and specifications for new construction to ensure the most up to date and effective construction plans and specifications possible. Overflow Response. element 6. Wastewater Collection and Pretreatment staff have developed and currently use a comprehensive overflow response plan. The City has been reporting spills per State and local guidelines for the past 18 years. FOG Program: element 7. The City's Pretreatment section permits and inspects grease and oil generating facilities to ensure control discharges that may cause blockages. A FOG program has been developed that includes discharger education on control of Fats, Oil and Grease, and specific guidelines they must follow. Program Administration: elements 8& 9. Utilities staff routinely evaluate program effectiveness and make changes or modifications when necessary or when it will enhance the program. The information used to evaluate program effectiveness comes from maintenance and operations documentation and record keeping maintained in the system's database. System capacity is also evaluated using this method and, where needed, projects are identified and prioritized for capital replacement. Communication:element 11. The Utilities Department website contains Wastewater Collection and Pretreatment program information with contact numbers. In the past staff have held public meetings to introduce and take comments about new and existing programs and service levels. The Utilities Department's quarterly newsletter, "The Resource", also includes program information, contact numbers, and encourages customer input and comment. The development plan and schedule will also be placed on the website. Summary Almost all of the required activities and program elements for this regulation are currently being performed by the Wastewater Collection and Pretreatment sections. Development of the SSMP will require the compilation of these existing activities into one comprehensive document. Staff believes that will not be an overly complicated effort and development of the SSMP can be accomplished within the required deadlines by City staff or use of a temporary employee or intern. Over the last 18 years the Wastewater Collection section has strived to efficiently and effectively manage the City's wastewater collection system and comply with the required water quality 1' Sewer System Management Plan Page 5 regulations. During this period of time, budgets have been developed to adequately fund operations and maintenance and capital replacements, additional staff have been added, equipment purchased, capital projects approved and constructed, regular maintenance programs implemented, Master Plans developed, enforcement and spill response improved and updated, and ongoing and expanded professional growth and training have been put into action. These constant improvements, supported by Council, have resulted in the one of the best managed wastewater collection programs in the state and the City being in compliance with the majority of the State's Sanitary Sewer regulations. The City is in an excellent position to easily comply with the upcoming deadlines. FISCAL IMPACT There is no fiscal impact at this time. Staff is currently evaluating the time and resources needed to prepare the SSMP and may be requesting funding in the 2007-08 Mid Year for assistance in its development. ALTERNATIVES Staff believes this is the most reasonable approach to this mandatory regulation. ATTACHNIENT City of San Luis Obispo Sewer System Management Plan Development and Schedule G: File Path a -s� ATTACHMENT City of San Luis Obispo Sewer System Management Plan Development Plan and Schedule October 4, 2007 i. A - f o . city Ui 5"j,Wii• �_ d—, . Prepared by: The City of San Luis Obispo Utilities Department: Bud Nance & Patti Gwathmey Contact: Bud Nance, Wastewater Collection Supervisor 879 Morro Street, San Luis Obispo, C�k. 93401 805-781-7033 or bnance@slocity.ora ATTACHMENT Table of Contents Introduction...................................................................................................................3 RegulatoryRequirement.......................................................................................... 3 Collection System Description ................................................................................. 3 Wastewater Collections Division and Industrial Waste ............................................ 3 SSMP Development Plan and Schedule.........:............................................................ 4. Table 1. Development Plan and Implementation Schedule .................................... 4 Collection System Assessment..............................:................................................. 5 I. Goal ...................................:.................................................................................... 5 WDRRequirement:................................................................................................... 5 Development plan action Items to be included in the SSMP:.................................... 5 2. Organization........................:................................................................................. 5 Development plan action Items to be included in the SSMP:................................... 6 3. Legal Authority.................. ..................... ......... ...:.:............ .... ...............................6 TheWDR Requirement:........................................................................................... 6 Development plan action Items to be included in the SSMP:................................... 6 4. Operations and Maintenance Program...............................................................7 TheWDR Requirement:......................................................................................-- 7 Development plan action Items to be included in the SSMP:................................... 7 5. Design and Performance Provisions.................:.................................................8 TheWDR Requirement:.............................. ............................................................ 8 Development plan action Items to be included in the SSMP,................................... 8 6. Overflow Emergency Response Plan.................................................................9 WDRRequirement:................................................................................................... 9 Development plan action Items to be included in the SSMP:................................... 9 . 7. Fats, Oils, and Grease Control Program........................................................... 10 WDRRequirement:................................................................................................ 10 Development plan action Items to.be included in the SSMP:................................. 11 8. System Evaluation and Capacity Assurance Plan..............................:......:..... 11 WDRRequirement:................................................................................................ 12 Development plan action Items to be included in the SSMP:................................. 12 9. Monitoring, Measurement, and Program Modifications.................................. 13 WDRRequirement:................................................................................................ 13 Development plan action Items to be included in the SSMP: ....................:.......... 13 10. SSMP Program Audits.................:.................................................................... 13 WDRRequirement:................................................................................................ 13 Development plan action Items to be included in the SSMP:................................. 14 11. Communication Program................................................................................. 14 WDRRequirement:................................................................................................ 14 Development plan action Items to be included in the SSMP:................................. 14 Table 2. Summary of Development Plan Action Items.......................................... 15 2 ATTACHMENT Introduction Regulatory Requirement On May 2, 2006, the State Water Resources Control Board (SWRCB) enacted Order No. 2006-0003, Statewide General Waste Discharge Requirements for Sanitary Sewer Systems (WDR). The WDR requires any public agency that owns or operates a sanitary sewer system more than one mile in length that conveys treated or partially treated wastewater to a publicly owned treatment facility in the State of California, comply with the requirements of the WDR. The City of San Luis Obispo (City) owns and operates a wastewater collection system more than one mile in length that conveys untreated wastewater to a publicly owned treatment facility and therefore is required to comply with the WDR. The City submitted a Notice of Intent to the State on July 13, 2007 for coverage under WDR and will develop a Sewer System Management Plan (SSMP) according to this Development Plan and Schedule. Collection System Description .The City of San Luis Obispo's wastewater collection system serves residential, commercial and industrial users. The City's wastewater collection system includes 133 miles (702,240 feet) of gravity sewer line, 3 miles of force main, 3000 manholes, and 10 lift stations which are monitored by telemetry. The mainlines are made of a variety of materials, depending on the age, terra cotta salt glazed pipe, vitrified clay. pipe (VCP), polyvinyl chloride, and asbestos concrete (AC). The City's primary goal is to maintain uninterrupted sewage flow without health hazard, effluent leakage, or water infiltration and inflow. Wastewater Collections Division and Industrial Waste The City has a separate Wastewater Collections Division (WWC) to oversee the operations and maintenance of the collection system. The Division includes a Wastewater Collection Supervisor and eight operators. The Division responds to all sewage spills 7 days a week, 24 hours a day. In 1990, a comprehensive maintenance and operations program was developed which includes a computerized maintenance program integrated with a Geographical Information System (GIS) program used to schedule preventative maintenance work orders, organize area maintenance activities, evaluates and prioritizes Closed Circuit Television (CCTV) inspections and records historical data about the system. This program meets many of the requirements of the WDR. 3 ATTACHMENT The City also has a State approved Pretreatment Program that includes a Fats, Oils, and Grease (FOG) Program which inspects food establishments.on an annual basis for the proper maintenance of grease removal devices as well as record keeping and employment of Best Management Practices (BMPs) related to FOG. SSMP Development Plan and Schedule The following Development Plan and Schedule outlines the development plan actions and compliance dates that the City will take in the development Of the SSMP. This document is required to be approved by the City Council during a public meeting. While most of the development plan action items are already in place, some of the items will need to be documented in writing. The City will complete each of the eleven SSMP elements by the SWRCB's scheduled compliance date. Table 1 outlines the Development Plan and Implementation Schedule which will be performed by the Wastewater Collection Division (WWC), Industrial Waste (IW), and the Public Works Department (PW). Table 1. Development Plan and Implementation Schedule lie 1101 W-mill - 00'- D. 0 1. Goals WWC November 2, 2007 2. Organization WWC November 2, 2007 3. Legal Authority WWC May 2, 2009 4. Operation and Maintenance Program WWC May 2, 2009 5. Design and Performance Provisions WWC/PW August 2, 2009 6. Overflow Emergency Response Plan WWC/IW May 2, 2009 7. FOG Control Program IW May 2, 2009 8 System Evaluation and Capacity WWC August 2, 2009 Assurance Plan 9 Monitoring, Measurement, and Program Modifications WWC August 2, 2009 10. SSMP Program Audits WWC August 2, 2009 11. Communication Program WWC August 2, 2009 a, 4, J ATTACHMENT Collection System Assessment The City's Contractor; Brown and Caldwell, conducted a sewer system management assessment of the collection system to identify additional activities that the City's needs to meet the requirements of the WDR. The assessment showed that the City meets the requirements of the WDR although many of these activities are not documented in writing. The City will review the current programs in place and expand or modify them to be consistent with the WDR. 1. Goal S WRCB Completion Date: 11/2/2007 WDR Requirement: A. The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent SSOs, as well as mitigate any SSOs that do occur. Development plan action Items to be included in the SSMP: 1. The City currently has an operations and maintenance program to maintain all parts of the sanitary sewer system which meets the goals of the SSMP. This program will be reviewed to ensure that it complies with the WDR and included in the SSMP. 2. Organization SWRCB Completion Date: 11/2/07 The WDR Requirement: The SSMP must identify: A. The name of the responsible or authorized representative as described in Section J of this Order; B. The names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation; ID 5 ATTACHMENT C: The chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable(such as County Health Officer, County Environmental Agency, Regional Water Board, and/or State Office of Emergency Services (OES)). Development plan action Items to be included in the SSMP: 1. The City has identified the staff responsible for the SSMP and has a chain of communications for responding to and reporting SSOs in place. 2. The City will develop an organization chart that identifies the chain of responsibilities communication, staff and job title of the responsible position for each element of the SSMP before November 2, 2007. 3. The City has Standard Operating Procedure on Sanitary Sewer Overflow Reporting Guidelines which outlines the staff responsible for: contacting regulatory agencies (RWQCB, OES, County Health, Department of Fish and Game, County Proposition 65 office), and completing the spill report for the RWQCB. The City will modify the SSO Guidelines to outline staff responsible for entering the spill information on the CIWQS computer program.. 3. Legal Authority SWRCB Completion Date: 05/2/09 The WOR Requirement: Each Enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to: A. Prevent illicit discharges into its sanitary sewer system (examples may include infiltration and inflow 1/I1, stormwater, chemical_dumping, unauthorized debris and cut roots, etc.); B. Require that sewers and connections be properly designed and constructed; C. Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency; D. Limit the discharge of fats, oils and grease (FOG) and other debris that may cause blockages; and E. Enforce any violation of its sewer ordinances." Development plan action Items to be included in the SSMP: 1. The City's Sewer Use Ordinance (SUO) currently contains all of the above requirements with the exception of access to laterals owned or maintained by the Public Agency. The City does not maintain or own private laterals. 6 r ATTACHMENT 2. The City will review the SUO and Municipal Code to determine if any revisions need to be made to ensure compliance with this WDR. 4. Operations and Maintenance Program SWRCB Completion Date: 11/2/2008 The WDR Requirement: The SSMP must include those elements listed below that are appropriate and applicable to the Enrollee's system: A. Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities; B. Describe routine preventive operation and maintenance (O&M) facilities by staff and contractors, including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The Preventive Maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders; C. Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes, sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement plan should include a capital improvement plan that addressed proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed for the capital improvement plan; D. Provide training on a regular basis for staff in sanitary sewer system operations and maintenance and require contractors to be.appropriately trained; and E. Provide equipment and replacement part inventories, including identification of critical replacement parts. Development plan action Items to be included in the SSMP: 1. The City has completed the mapping of the wastewater collection system and continuously maintains and updates the maps as needed on the GIS. The City's wastewater collection system conveys sewage only and does not include any storm water conveyance facilities. C�l - o� 7 ATTACHMENT 2. The City has a computerized maintenance program integrated with a GIS which schedules preventative maintenance work orders, organizes area maintenance activities, evaluates and prioritizes CCTV inspections and records historical data about the system. 3. The City has an ongoing sewer mainline and related facilities replacement program. Replacement is prioritized based on failure due to age, structural deficiencies, alignment, grade problems, capacity, root intrusion blockages and maintenance. The City also has a Wastewater Master Plan developed to be a long range plan to guide implementation of recommended improvements of collection and treatment facilities and expansion of service to future annexation areas. The goal of the Wastewater Master Plan is a capital improvement program that identifies improvements needed to mitigate existing collection systems and treatment plant deficiencies and provide wastewater services to future annexation areas. 4. The City's Wastewater Collection Operators are required to obtain California Water Environment Association Certification for wastewater collection to advance within their job classification. The Skills Based Pay (SBP) Program was developed by the City's Utilities Department to ensure that staff obtains the proper skills and training in order to maintain and operate the wastewater collection system at a journeyman level or better. The City requires ongoing training to maintain certification and to promote through the SBP program. Wastewater Collections staff also receive training such as confined space and rescue training and respiratory training to meet California Occupational Safety Health Act. 5. The City currently has an inventory of equipment, replacement parts, including location and critical replacement parts. 5. Design and Performance Provisions SWRCB Completion Date: 5/2/2009 The WDR Requirement: A. Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations and other appurtenances, and for the rehabilitation and repair of existing sanitary sewer systems; and B. Procedure and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects. Development plan action Items to be included in the SSMP: 1. The City currently has Engineering Standards and Standard Specifications for design, and construction of new sanitary sewer systems, pump stations, other a � I3 8 ATTACHMENT appurtenances, and for the rehabilitation and repair of existing sewer systems. These Standards are updated annually and includes inspection and testing of new systems. These Standards and Specifications meet the requirements of the WDR. 6. Overflow Emergency Response Plan SWRCB Completion Date: 11/2/2008 WDR Requirement: Each enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, this plan must include the following: A. Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner; B. A program to ensure an appropriate response to all.overflows; C. Procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP (monitoring and reporting program). All SSOs shall be reported in accordance with this MRP, the California Water Code, other State law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP should identify the officials who will receive immediate notification; D. Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Emergency Response Plan and are appropriately trained; E. Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and F. A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct and adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge." Development plan action Items to be included in the SSMP: 1. The City has Standard Operating Procedure on Sanitary Sewer Overflow Reporting Guidelines. The guideline outlines the staff responsible for: contacting regulatory agencies (RWQCB, OES, County Health, Department of Fish and Game, County Proposition 65 office), and completing the spill report for the RWQCB. The City will modify the SSO Guidelines to outline staff responsible for entering the spill information on the CIWQS computer program. 2. The City's Wastewater Collection staff currently respond to all reports of sewage spills 7 days a week, 24 hours a day. Spill response procedures will be put into a 9 ATTACHMENT written format and will include: emergency operations such as traffic and crowd control, and steps taken by staff to contain and prevent the discharge of sewage to a waterway and minimize or correct any impact on the environment from the SSO. 2. Wastewater Collection staff inspects any line which experiences an SSO using CCN to help determine the cause of the overflow and determines if repairs need to be made to prevent future SSOs or put on the preventative maintenance schedule and continually evaluate the line. 3. Staff will receive annual refresher training on SSO Reporting Guidelines and spill response. 7. Fats, Oils, and Grease Control Program SWRCB Completion Date: 11/2/2008 WDR Requirement: Each Enrollee shall evaluate it's service area,to determine whether a Fats, Oils, and Grease (FOG) control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If Fog is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate: A. An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG; B. A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of FOG generated within the sanitary sewer system service area; C. The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG; D. Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, BMP requirements, record keeping and reporting requirements; E. Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance; F. An identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and G. Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each.section identified in (f) above. 10 ATTACHMENT Development plan action Items to be included in the SSMP: 1. The City has had a FOG control program in place since 1989. The program was revised in 2005 to be more comprehensive including the development of public education materials on FOG control, maintenance logs for grease trap and interceptor maintenance, requiring no grease stickers to be posted over sinks, and BMPs to be implemented. A written program has not been done. The Industrial Waste Coordinator will develop a written FOG program. 2. The City currently has public education materials for food establishments permitted under the FOG program. The schedule for distributing public education materials to food establishments described in the City's Municipal Storm Water Management Plan will be used for the SMMP. Public education is also conducted for residents through tours of the Water Reclamation Plant and. articles in the Utilities quarterly newsletter. 3. The City regulates the frequency of grease traprinterceptor cleaning and the disposal of FOG from food establishments during annual inspections. 4. The City's SUO, Section 13.08.140 prohibits the discharge of any oil or grease to the POTW. The Wastewater Collections Division performs preventative maintenance and area maintenance along with CCN to prevent SSOs and blockages from FOG. Areas of the collectionsystem known to have FOG related problems are on increased preventative maintenance schedules. 5. The City's SUO, Section 13.08.160 requires the installation and maintenance of grease removal devices. This section also specifies certain design standards and requires the devices to be installed per the Uniform Plumbing Code. Annual inspections of facilities which generate FOG ensure that correct maintenance, cleaning, record keeping and BMPs are in place. 6. The City's SUO, Section 13.08.201 provides the authority to inspect and requires all documents pertaining to the pretreatment program be accessible at the time of the inspection. Food establishments are inspected on an annual basis. 7. The Wastewater Collections Division has identified certain areas of the collection system known to have problems with FOG. The Wastewater Collections Division will further develop (or determine a system of rating areas or the degree of the problem).a plan for identifying all areas in the collection system. 8. The Wastewater Collections Division and the.Industrial Waste Program will work together to develop source control measures that will reduce SSOs or blockages in area identified as having FOG related problems. Source control measures may include increased preventative maintenance, inspections, and additional public education materials. 8. System Evaluation and Capacity Assurance Plan SWRCB Completion Date: 512/2009 CD-- lie J ATTACHMENT WDR Requirement: The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate design storm or wet weather event. At a minimum, the plan must include: A. Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape,,from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events; B. Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; C. Capacity Enhancement Measures: The steps needed to establish a short- and long- term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, 1/1 reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include and implementation schedule and shall identify sources of funding; D. Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D.14. Development plan action Items to be included in the SSMP: 1. As previously discussed in the Operations and Maintenance section, the City has an updated Wastewater Master Plan developed to be a long range plan to guide implementation of recommended improvements of collection and treatment facilities and expansion of service to future annexation areas. The goal of the Wastewater Master Plan is a capital improvement program that identifies improvements needed to mitigate existing collection systems and treatment plant deficiencies and provide wastewater services to future annexation areas. 2. The City evaluates hydraulic capacity using maintenance and operation information stored in its databases and staff participation. 3. The City will develop an evaluation plan on those portions of the collection system that contribute to SSOs caused by hydraulic deficiencies. 4. The City has established design criterion that is identified in the updated Wastewater MasterPlan. 5. The City currently develops a four year CIP plan which identifies an implementation schedule and funding. 12 ATTACHMENT 9. Monitoring, Measurement, and Program Modifications SWRCB Completion Date: 5/2/2009 WDR Requirement: The Enrollee shall: A. Maintain relevant information that can be used to establish and prioritize appropriate SSMP activities; B. Monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP; C. Assess the success of the preventive maintenance program; D. Update program elements; as appropriate, based on monitoring or performance evaluations; and E. Identify and illustrate SSO trends, including: frequency, location, and volume. Development plan action Items to be included in the SSMP: 1. The City uses the computerized infrastructure:management system to maintain historical data including service calls, blockages, SSO's, causes of the SSO's and blockages. 2. The computerized infrastructure management system generates work orders to perform scheduled maintenance, organize area maintenance activities, evaluate and prioritize CCN inspections. 3. The Wastewater Collection Supervisor assesses the effectiveness of each of the maintenance programs, such as the preventative maintenance program and generates annual reports. 10. SSMP Program Audits SWRCB Completion Date: 5/2/2009 WDR Requirement: As part of the SSMP, the Enrollee shall conduct periodic internal audit, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee's compliance with the SSMP requirements identified in subsection D.13 of the Order, including identification of any deficiencies in the SSMP and steps to correct them. 13 ATTACHMENT Development plan action Items to be included in the SSMP: 1. The City will develop an audit check list and criteria for evaluating the effectiveness of each SSMP element in terms of eliminating preventable SSOs. 2. The Wastewater Collection Supervisor will conduct an internal audit every two years. 3. The City will initiate any corrective actions to correct any deficiencies identified in the audit to ensure compliance the WDR. 11. Communication Program SWRCB Completion Date: 5/2/2009 WDR Requirement: The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented. The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee's sanitary sewer system. Development plan action Items to be included in the SSMP: 1. The City will hold an open,session public meeting for the City Council to approve the SSMP Development Plan and Implementation Schedule and the final SSMP. 2. A copy of the SSMP Development Plan and Implementation Schedule and the final SSMP will be posted on the Utilities Department web page on the City's web Site at www. Slocity.org. 3. On-going training will be provided for wastewater staff on WDR and SSO reporting requirements. 4. The City will solicit public input through its website, public meeting, newsletters, public contacts and other means. 5. 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