Project 172 - Agenda Staff Reports - 2004-09-20 - SANII�Rr
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Memorandum
To: Board of Directors
From: Robin B. Hamers, Manager/District Engineer Sit
Date: September 20 2004
Subject: Waste Discharge Requirements (WDR)
Grease Control Program
At the Special Meeting on October 4 2004 Staff will present the proposed grease
control program for the District to comply with the Regional Water Quality Control
Board's (RWQCB) Waste Discharge Requirements.
Enclosed is the RWQCB WDR Order in its entirety for a re-review by the Board of
Directors of the requirements placed on the District. The grease control program
requirements are found in paragraph (viii) on page 12.
The Order applies to all agencies owning sewer systems that are tributary to the
Orange County Sanitation District and these agencies are shown on pages 1 and 2 of
the Order The city councils and boards of directors of these agencies are also in the
process of determining the parameters of their grease control programs. The Sanitary
District has been in full compliance with the Order for all policies and documents
required to date and the grease control program must be in place by December 30
2004
As a first step for the Sanitary District's grease control program, the Board of Directors
retained Environmental Engineering & Contracting, Inc. (EEC) to perform a fats, oils
and grease (FOG) study —termed FOG Characterization. The study encompassed
determining the source and associated problems of grease discharged into the sewer
system by food service establishments inside the District. The characterization is
nearly complete and will be the basis for the grease control program.
The enclosed proposal from EEC reflects a scope of services negotiated by the
Manager/District Engineer and Assistant Manager in order to be tailored to the
anticipated Sanitary District program. Because the program is, in effect, a commitment
Protecting our community's health 6y prowling solid waste and sewercal7ection services.
costamesasanitarydistrict.org
Waste Discharge Requirements (WDR) September 20, 2004
Grease Control Program Page 2
to a new long-term policy Staff recommends EEC present the proposal and policy
considerations directly to the Board. John Shaffer President of EEC will give the
presentation. The policy and program adopted by the Board will most likely require the
Attorney for the District to revise the existing grease control ordinance.
As a reminder and in order to further understand EEC's qualifications to perform this
work for the Sanitary District, the District and the other co-permittees under the order
retained EEC to prepare a nationwide study of grease control practices, known as the
Phase I study The result of EEC performing this major study is that John Shaffer is
now as knowledgeable as anyone in the United States regarding municipal grease
control programs. This knowledge is especially important when selecting the
parameters that will create an effective program.
EEC and District Staff will be available to answer questions during and after the
presentation. If there are any questions prior to the Special Meeting, please call.
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SANTA ANA REGION
ORDER NO. R8-2002-0014
GENERAL WASTE DISCHARGE REQUIREMENTS
FOR
SEWAGE COLLECTION AGENCIES IN
ORANGE COUNTY
WITHIN THE SANTA ANA REGION
The California Regional Water Quality Control Board, Santa Ana Region (hereinafter
Regional Board), finds that:
1 The following federal agencies, municipalities, counties, districts or other public
bodies, which own or have responsibilities for sanitary sewer collection systems
or any facilities that collect or convey untreated sewage wastewater in the
portions of Orange County within the Santa Ana Region, are named as
dischargers (or permittees) in this Order Since most of these dischargers are
tributary to the Orange County Sanitation District (OCSD), the OCSD may lead a
steering committee for all other entities tributary to OCSD to facilitate
compliance by each discharger with the requirements of this Order
City of Anaheim City of Newport Beach
City of Brea City of Orange
City of Buena Park City of Placentia
Costa Mesa Sanitary District Rossmoor/Los Alamitos Area
Sewer District
City of Cypress City of Santa Ana
City of Fountain Valley City of Seal Beach
City of Fullerton City of Stanton
Garden Grove Sanitary Sunset Beach Sanitary District
District
City of Huntington Beach County of Orange
Unincorporated Area 7
City of La Palma City of Villa Park
Irvine Ranch Water District City of Yorba Linda
City of La Habra Yorba Linda Water District
Order No. R8-2002-0014 Page 2 of 18
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Orange County Sanitation Midway City Sanitation District
District (OCSD)
City of Los Alamitos El Toro Water District
U.S Air Force Reserve Center Joint Forces Training Base Los
Los Alamitos Alamitos
Marine Corps Air Station El Naval Weapons Station Seal
Toro/Tustin Beach
2. A sanitary sewer system is a sewage wastewater collection system including
sewers, pipes, pumps, or other conveyances that convey sewage wastewater
(e.g. domestic, commercial, and industrial wastewaters) to a sewage treatment
plant. This order prohibits the discharge of sewage from collection systems that
result in a discharge of sewage to surface waters of the State. A sanitary sewer
system overflow (SSO), or sewage spill, is each instance of a discharge of
sewage from a sanitary sewer system. If these discharges of sewage from any
sewage spill or SSO are not fully contained and cleaned up, and there is a
discharge of sewage to surface waters of the State, or the SSO causes a
nuisance, it is a violation of this order Sections 13260 and 13376 of the
California Water Code, and Section 301 of the Clean Water Act. The
discharges of sewage from a sanitary sewer system, that are fully contained
above ground, and do not create a nuisance or result in a discharge of sewage to
waters of the State, are not subject to the Prohibition A.1 of this order Sewage
discharged from a collection system that result in a discharge of sewage to an
enclosed storm drain pipe, and not discharged to surface waters, are not
considered discharges to surface waters in terms of this order except that these
sewage discharges shall be reported in the same manner as a sewage
discharged to surface waters and the discharger is required to demonstrate that
the sewage was not discharged from the storm drain to surface waters. Sewage
discharged to open drainage channels, whether iatural, man made, or concrete
lined, are considered to be discharges of sewage to surface waters of the State
The order also requires the discharger to develop and implement a plan to
address subsurface discharges of sewage to ground waters of the State.
Temporary storage and conveyance facilities (such as vaults, temporary piping,
construction trenches, wet wells, impoundments, tanks, highlines, etc.) are
considered to be part of the sanitary sewer system, and discharges of sewage to
these facilities are not sanitary sewer overflows, provided that sewage from these
facilities is not discharged to waters of the State.
3. Sanitary sewer overflows (SSOs) consist of varying mixtures of domestic
sewage, and industrial and commercial wastewater depending on the pattern of
Order No. R8-2002-0014 Page 3 of 18
General WDR, SSO
land uses in the sewage collection system tributary area. SSOs often contain
high levels of suspended solids, pathogenic organisms, toxic pollutants, nutrients,
oxygen demanding organic compounds, oil and grease and other pollutants.
SSOs may cause a nuisance, cause temporary exceedances of applicable water
quality standards when the sewage is discharged to surface waters of the State,
pose a threat to the public health, adversely affect aquatic life, and impair the
public recreational use and aesthetic enjoyment of surface waters. Section
13050(m) of the California Water Code defines a nuisance as anything that
meets the following requirements. (1) Is injurious to health, or is indecent to the
senses, or an obstruction to the free use of property so as to interfere with the
comfortable enjoyment of life or property (2) Affects at the same time an entire
community or neighborhood, or any considerable number of persons, although
the extent of the annoyance or damage inflicted upon individuals may be
unequal. (3) Occurs during, or as the result of, the treatment or disposal of waste.
4 SSOs are a frequent occurrence in the portions of Orange County within the
Santa Ana Region. The chief causes of sanitary sewer overflows include grease
blockages, root blockages, sewer line flood damage, manhole structure failures,
vandalism, pump station mechanical failures, power outages, storm or ground
water inflow/infiltration, debris blockages, collection system age and construction
material failures, lack of proper operation and maintenance, lack of capacity and
contractor caused damages. Most of these SSOs are preventable with
adequate and appropriate source control measures and operation and
maintenance of the sewage collection system.
5. In Orange County from January 1 2000 through August 30 2001 there were
approximately 250 SSOs. SSOs from publicly owned sewage collection systems
accounted for almost 75% of these sewage spills, with the remainder occurring
on private property On 31 occasions during this time period, beach waters were
closed to body contact recreation resulting in a loss of 16.5 beach mile days
(beach mile days = miles of beach X number of days of closure) of beneficial
uses. Seventeen of these beach water closures were caused by sewage spills
from systems owned by public agencies, and the other 14 closures resulted from
sewage spills on private property that were not contained and resulted in a
discharge to waters of the State Areas where beach water was closed to body
contact recreation include portions of Seal Beach, Sunset Beach, Huntington
Beach, Newport Beach, Crystal Cove State Park, Newport Bay and Huntington
Harbor Many of these SSOs that caused beach water closures also caused
violations of water quality standards in other surface water bodies, such as the
San Gabriel River Coyote Creek, San Diego Creek and other surface water
bodies in Orange County
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6. The beach water closures occur when sewage is present (closures), and
warnings are posted when any water quality standard is exceeded (postings). In
addition to SSOs, urban runoff and storm water generally contain elevated levels
of bacteria. Therefore, warning signs are posted at storm drain outlets to the
ocean during storm events along the beach and a rainfall advisory is issued for
all storms. During the January 1 2000 through August 30 2001 period, the
Orange County Health Care Agency (OCHCA) also posted many of the same
beach areas warning the public that concentrations of indicator bacteria at one of
OCHCA's monitoring stations exceeded the State health standards. The OCHCA
has posted notices of exceedances of water quality objectives that has resulted
in 99 4 beach mile days of violations of water quality standards during January
through August 2001
7 A revised 'Water Quality Control Plan for the Santa Ana River Basin (8)'
(hereinafter Basin Plan) became effective on January 24 1995 The Basin Plan
designates beneficial uses, narrative and numerical water quality objectives, and
prohibits certain types of discharges. The Basin Plan establishes body contact
recreation as a beneficial use of the Pacific Ocean and other surface water
bodies within Orange County including Serrano Creek, San Diego Creek, Bonita
Creek, Santa Ana Delhi Channel, the Santa Ana River Talbert Marsh, Newport
Bay Huntington Harbour and Newport Slough. The Basin Plan also includes a
numeric water quality objective for coliform to protect and maintain this beneficial
use. This objective is specified as a 30-day geometric mean of no more than 200
MPN/100 ml of fecal coliform. The Basin Plan also includes, by reference, the
California Ocean Plan standards for ocean waters in the Region.
8. The Basin Plan contains the following prohibition:
The discharge of untreated sewage to al g surface water stream, natural or man-
made, or to any drainage system intended to convey storm water runoff to
surface water streams, is prohibited.
9 California Water Code Section 13243 provides that a Regional Board, in waste
discharge requirements, may specify certain conditions or areas where the
discharge of waste, or certain types of waste, is not permitted. The requirements
specified in this order are consistent with the Basin Plan prohibition and Water
Code Section 13243
10 The issuance of a single general waste discharge requirement to the dischargers
will:
a) Reduce the administrative burden of issuing individual waste discharge
requirements to each discharger and
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b) Provide for a unified regional approach for the reporting and database
tracking of sanitary sewer overflows.
c) Provide consistent and uniform standards of performance, operations, and
maintenance of sewage collection systems.
d) Provide statewide consistency in reporting as per Assembly Bill (AB) 285
(adopted on October 4 2001) and the State Water Resources Control
Board's reporting requirements per AB 285.
e) Facilitate uniform enforcement for violations. (The State Water Resources
Control Board, Office of the Chief Counsel, issued a questions and
answers paper on April 17 2001 stating that SSOs are not subject to
minimum mandatory penalties. However the California Water Code
provides for penalties for unauthorized discharges.)
11 This project involves a prohibition of discharge, and as such, is exempt from the
provisions of the California Environmental Quality Act, in accordance with Title
14 California Code of Regulations, Chapter 3, Section 15308.
12. The Regional Board has notified the dischargers and all known interested parties
of the intent to prescribe waste discharge requirements to prohibit unauthorized
discharges from sanitary sewer systems.
13. The Regional Board has, at a public meeting on April 26, 2002 heard and
considered all comments pertaining to the terms and conditions of this Order
IT IS HEREBY ORDERED that the dischargers, in order to meet the provisions
contained in Division 7 of the California Water Code and regulations adopted
thereunder shall comply with the following:
A. PROHIBITIONS
1 The discharge of untreated sewage to any surface water stream, natural or man-
made, or to any drainage system intended to convey storm water runoff to
surface water streams, is prohibited.
2. The discharge of chlorine, or any other toxic substance used for disinfection and
cleanup of sewage spills, to any surface water body is prohibited. (This
prohibition does not apply to the chlorine in the potable water used for final wash
down and clean up of sewage spills.)
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B. IMPLEMENTATION AND ENFORCEMENT OF PROHIBITION A.1
1 In any enforcement action the Regional Board will consider the efforts of the
discharger to contain, control, and clean up sewage spills from its collection
system as part of its consideration of the factors required by Section 13327 of the
California Water Code. The discharger shall make every effort to contain
sewage spilled from their collection systems and prevent the sewage from
entering storm drains and surface water bodies. The discharger shall also make
every effort to prevent sewage from discharging from storm drains into flood
control channels and open ditches by blocking the storm drainage system and by
removing the sewage from the storm drains. The use of the storm drain pipe
system to contain the sewage by blocking the drain pipes, and recovering and
cleaning up the spilled sewage, in order to prevent the sewage from being
discharged to a surface water body is not a violation of Prohibition A.1
C. PROVISIONS
1 The discharger must comply with all conditions of this Order Any
noncompliance with this Order constitutes a violation of the California Water
Code and is grounds for enforcement action.
2. Discharges Caused by Severe Natural Conditions — The Regional Board may
take enforcement action against the permittee for any sanitary sewer system
discharge caused by natural conditions, unless the permittee demonstrates
through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(i) the discharge was caused by severe natural conditions (such as hurricanes,
tornadoes, flooding, earthquakes, tsunamis, and other similar natural conditions);
(ii) there were no feasible alternatives to the discharge, such as retention of
untreated wastewater reduction of inflow and infiltration, use of adequate backup
equipment, or an increase in the capacity of the system. This provision is not
satisfied if in the exercise of reasonable engineering judgment, at the time that
the facilities were planned, the discharger should have installed auxiliary or
additional collection system components, wastewater retention, adequate back
up equipment or should have reduced inflow and infiltration. This provision is
also not satisfied if the agency does not undergo a periodic or continuing
planning process to identify and correct problems.
3 Discharges Caused by Other Factors For SSOs other than those covered under
this section, the permittee may establish an affirmative defense to an action
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brought for noncompliance if the permittee demonstrates through properly
signed, contemporaneous operating logs, or other relevant evidence that:
(i) the permittee can identify the cause or likely cause of the discharge event;
(ii) the discharge was exceptional, unintentional, temporary and caused by
factors beyond the reasonable control of the permittee;
(iii) the discharge could not have been prevented by the exercise of reasonable
control, such as proper management, operation and maintenance; adequate
treatment facilities at OCSD's two regional treatment plants or collection system
facilities or components (e.g. adequately enlarging treatment or collection
facilities to accommodate growth or adequately controlling and preventing
infiltration and inflow); preventive maintenance; or installation of adequate
backup equipment; and
(iv) the permittee took all reasonable steps to stop, and mitigate the impact of
the discharge as soon as possible.
4 Burden of proof In any enforcement proceeding, the permittee has the burden
of proof to establish that the criteria in this section have been met.
5. In an enforcement action, it shall not be a defense for the discharger that it would
have been necessary to halt or reduce the permitted activity in order to maintain
compliance with this Order
6. Upon reduction, loss, or failure of the sanitary sewer system resulting in a
sanitary sewer overflow the discharger shall, to the extent necessary to maintain
compliance with this Order take any necessary remedial action to 1) control or
limit the volume of sewage discharged, 2) terminate the sewage discharge as
rapidly as possible, and 3) recover as much of the sewage discharged as
possible for proper disposal, including any wash down water The dischargers
shall implement all remedial actions to the extent they may be applicable to the
discharge, including the following:
a. Interception and rerouting of sewage flows around the sewage line
failure,
b. Vacuum truck recovery of sanitary sewer overflows and wash down
water.
c. Cleanup of debris of sewage origin at the overflow site.
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7 The discharger shall properly fund, manage, operate and maintain, with
adequately trained staff and/or contractors possessing adequate knowledge skills
and abilities as demonstrated through a validated program at all times, all parts
of the sewage collection system owned and/or operated by the discharger
8. The discharger shall provide adequate capacity to convey base flows and peak
flows, including wet weather related events to the minimum design criteria as
defined in the discharger's System Evaluation and Capacity Assurance Plan, for
all parts of the collection system owned or operated by the discharger
9 The discharger shall take all feasible steps to stop, and mitigate the impact of
sanitary sewer overflows in portions of the collection system owned or operated
by the discharger
10 The discharger shall provide notification to the OCHCA and the Regional Board
so that they can notify parties with a reasonable potential for exposure to
pollutants associated with the SSO
11 The discharger shall develop and implement a written plan, a Sewer System
Management Plan (SSMP), for compliance with these waste discharge
requirements and make it available to any member of the public upon request in
writing.
12. The essential elements of the SSMP are specified below If the discharger
believes that any element of this section is not appropriate or applicable for their
SSMP program, the program does not need to address it, but the SSMP must
explain why that element is not applicable. The Regional Board will consider the
quality of the SSMP its implementation and effectiveness in any relevant
enforcement action, including, but not limited to, any enforcement action for
violation of the Clean Water Act, the Basin Plan prohibition, or these waste
discharge requirements. The SSMP must include the following components, with
the exception of non-applicable components, as discussed above:
Sewer System Management Plan (SSMP)
(i) Goals. The main goal of the SSMP is to prevent SSOs and to provide a plan
and schedule for measures to be implemented to prevent SSOs.
(ii) Organization: The SSMP must identify.
(A) Administrative and maintenance positions responsible for implementing
measures in the SSMP program, including lines of authority by organization chart
or similar document; and
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(B) The chain of communication for reporting SSOs, from receipt of a complaint
or other information, including the person responsible for reporting SSOs to the
Regional Water Quality Control Board, Orange County Health Care Agency and
State Office of Emergency Services (OES); reporting to the OES is required if the
discharge is 1,000 gallons or larger
(iii) Legal Authority- The SSMP shall include legal authority through sewer use
ordinances, service agreements or other legally binding procedures, to:
(A) Control infiltration and connections from inflow sources, including satellite
systems;
(B) Require that sewers and connections be properly designed and constructed;
(C) Ensure proper installation, testing, and inspection of new and rehabilitated
sewers (such as new or rehabilitated collector sewers and new or rehabilitated
service laterals);
(D) Limit fats and greases and other debris that may cause blockages in the
sewage collection system.
(E) Implement the general and specific prohibitions of the national pretreatment
program under 40 CFR 403.5.
(iv) Measures and Activities. In order to provide an adequate and appropriate
SSO reduction plan, the SSMP must address the elements listed below that are
appropriate and applicable to the discharger's system and identify the person or
position in the organization responsible for each element:
(A) Provide adequate operation and maintenance of facilities and equipment;
(B) Maintain an up-to-date map of the collection system showing all gravity line
segments and manholes, pumping facilities, pressure pipes and valves, and
stormwater conveyance facilities;
(C) Maintain relevant information to establish and prioritize appropriate SSMP
activities (such as the immediate elimination of dry weather overflows or
overflows into sensitive waters, such as public drinking water supplies and their
source waters, swimming beaches and waters where swimming occurs, shellfish
beds, designated Outstanding National Resource Waters or Areas of Special
Biological Significance, National Marine Sanctuaries, waters within Federal,
State, or local parks, and water containing threatened or endangered species or
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their habitat), and identify and illustrate trends in overflows, such as frequency
and volume;
(D) Routine preventive operation and maintenance activities by staff and
contractors; including a system for scheduling regular maintenance and cleaning
of the collection system with more frequent cleaning and maintenance targeted at
known problem areas. The Preventative Maintenance (PM) program should
have a system of tracking work orders and assessing the success of the PM
program.
(E) Establish a program to assess the current capacity of the collection system
owned by the discharger or where the discharger has operational control;
including diversions of urban runoff to the sewer system during dry weather
periods and control of infiltration and intrusion during both wet weather events
and dry weather periods,
(F) Identify and prioritize structural deficiencies and implement short-term and
long-term rehabilitation actions to address each deficiency This shall include a
rehabilitation plan including schedules for the entire system. As with the PM
program, sewer rehabilitation and replacement is crucial for the prevention of
spills. Among the provisions that should be specified in this section is the need
to direct rehabilitation and replacement at sewer pipes which are at risk of
collapse or prone to more frequent blockages due to pipe defects. The program
should also include regular visual and TV inspection of sewer pipes and a system
for assessing and ranking the condition of sewer pipes. Finally the rehabilitation
and replacement plan should include a financial plan that properly manages and
protects the infrastructure assets.
(G) Provide training on a regular basis for sta in collection system operations,
maintenance and monitoring and determine if contractors staffs are
appropriately trained;
(H) Provide equipment and replacement parts irventories, including identification
of critical replacement parts.
(I) Establish an implementation plan and schedule for a public education
outreach program that promotes proper disposal of grease and fats.
(J) In accordance with the County of Orange s Drainage Area Management Plan,
establish a plan for responding to SSOs from private property that discharge to
public right of ways and storm drains, to prevent discharges from SSOs to
surface waters and storm drains, and
51
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(K) Develop a plan and a schedule for providing an analysis of alternative
methods of disposal for grease and fats, and an implementation plan and a
schedule for providing adequate disposal capacity for grease and fats generated
within the sewer system service area. This plan shall include an evaluation of
the feasibility of using sludge digesters at the OCSD treatment plant for grease
disposal and treatment, recycling, rendering, and other disposal alternatives.
(v) Design and Performance Provisions:
(A) Develop design and construction standards and specifications for the
installation of new sewer systems, pump stations and other appurtenances; and
for rehabilitation and repair of existing sewer systems; and
(B) Develop procedures and standards for inspecting and testing the installation
of new sewers, pumps, and other appurtenances and for rehabilitation and repair
projects.
(vi) Monitoring, Measurement and Program Modifications
(A) Monitor the implementation and, where appropriate, measure the
effectiveness of each element of the SSMP.
(B) Update program elements, as appropriate, based on monitoring or
performance evaluations; and
(C) Modify the SSMP program, as appropriate, to keep it updated and accurate
and available for audit at all times.
(vii) Overflow Emergency Response Plan The dischargers shall develop and
implement an overflow emergency response plan that identifies measures to
protect public health and the environment. At a minimum, this plan should
include the following:
(A) Ensure proper notification procedures so that the primary responders are
informed of all SSOs in a timely manner (to the greatest extent possible);
(B) Ensure that all overflows (including those that do not discharge to waters of
the State) are appropriately responded to, including ensuring that reports of
overflows are immediately dispatched to appropriate personnel for investigation
and appropriate response,
(C) Ensure immediate notification of health agencies and other impacted entities
(e.g. water suppliers) of all overflows. Report all SSOs to the Regional Water
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Quality Control Board and the Orange County Health Care Agency and report to
the State OES if the overflow is 1,000 gallons or larger The SSMP should
identify the public health agency and other officials who will receive immediate
notification,
(D) Ensure that appropriate staff and contractor personnel are aware of and
follow the plan and are appropriately trained;
(E) Provide emergency operations, such as traffic and crowd control and other
necessary emergency response,
(F) Take all reasonable steps to contain sewage and prevent sewage
discharges to surface waters and minimize or correct any 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;
(G) Develop and implement a plan for the use of portable aerators where
complete recovery of the sanitary sewer overflows is not practicable and
where severe oxygen depletion in existing surface waters is expected; and
(H) Develop and implement a plan to respond in a timely manner to spills and
other emergencies. Collection system staff should be able to respond to a
sewage spill in less than an hour from the first call. The system should be
capable of meeting this response time day or night, every day of the week.
The system must own or have ready access to spill and emergency
response equipment such as vacuum trucks, hydroflushers, pumps,
temporary bypass hoses, and portable generators.
(viii) Fats, Oils, and Grease Control Program: Prepare and implement a
grease, fat, and oil source control program to reduce the amount of these
substances discharged to the sewer collection system. This plan shall include
the legal authority to prohibit discharges to the system and identify measures to
prevent SSOs caused by fats, oils, and grease blockages of sewers. The
elements of an effective grease control program may include requirements to
install grease removal devices (such as traps or preferably interceptors), design
standards for the removal devices, maintenance requirements, BMP
requirements, record keeping and reporting requirements. An effective grease
control program must also include authority to inspect grease producing facilities,
enforcement authorities, and sufficient staff to inspect and enforce the grease
ordinance.
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(A) The grease control program shall identify sections of the sewer system
subject to grease blockages and establish a cleaning maintenance schedule for
each section; and
(B) The program shall develop and implement source control measures, for all
sources of grease and fats discharged to the sewer system, for each section
identified in (A) above.
(ix) System Evaluation and Capacity Assurance Plan: Prepare and implement
a capital improvement plan that will provide hydraulic capacity of key sewer
system elements under peak flow conditions. At a minimum, the plan must
include:
(A) Evaluation: Steps to evaluate those portions of the collection system
which 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) Capacity Enhancement Measures. Establish a short- and long-term capital
improvement program to address identified hydraulic deficiencies including
prioritization, alternatives analysis, and schedules; and
(C) Plan updates: The plan must be updated, at a minimum annually to
describe any significant change in proposed actions and/or implementation
schedules. The updates should include available information on the performance
of measures that have been implemented
(x) SSMP Program Audits As part of the SSMP the permittee shall conduct an
internal audit, appropriate to the size of the system and the number of overflows,
and submit a report of such audit, evaluating the SSMP and its compliance with
this subsection, including its deficiencies and steps to correct them.
(xi) Communications: The discharger should communicate on a regular basis
with interested parties on the implementation and performance of its SSMP The
communication system should allow interested parties to provide input to the
discharger as the program is developed and implemented.
13. The discharger shall develop and implement the SSMP according to the following
schedule.
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Sewer System Management Plan Time Schedule
Task Completion Date
Monitoring and Reporting Effective on Adoption
Program No R8-2002-0014
SSMP Development Plan September 30 2002
and Schedule
SSO Emergency Response January 1 2003
Plan
Preventative Maintenance June 15 2003
Program
Legal Authority July 30, 2004
Grease Disposal December 30 2004
Alternatives
Grease Control Program December 30, 2004
Capacity Evaluation July 30, 2005
Sewer Rehabilitation Plan September 30, 2005
for Entire System
Final SSMP September 30, 2005
C. PERMIT AVAILABILITY
1 A copy of this Order shall be maintained at appropriate locations and shall be
available to sanitary sewer system operating and maintenance personnel at all
times.
D. ENTRY AND INSPECTION
1 The discharger shall allow the Regional Board, or an authorized representative,
upon presentation of credentials and other documents as may be required by
law to'
a. Enter upon the discharger's premises where a regulated facility or
activity is located or conducted, or where records are kept under the
conditions of this Order.
b Have access to and copy at reasonable times, any records that must
be kept under the conditions of this Order.
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c. Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated
or required under this Order• and
d. Sample or monitor at reasonable times, for the purposes of assuring
compliance with this Order or as otherwise authorized by the California
Water Code, any substances or parameters at any location.
E. GENERAL MONITORING AND REPORTING REQUIREMENTS
1 The discharger shall furnish to the Executive Officer within a reasonable time,
any information which the Executive Officer may request to determine whether
cause exists for modifying, revoking and reissuing, or terminating this Order The
discharger shall also furnish to the Executive Officer upon request, copies of
records required to be kept by this Order
2. Pursuant to California Water Code Section 13267(b), the discharger shall comply
with the attached Monitoring and Reporting Program No.R8-2002-0014 and
future revisions thereto, as specified by the Executive Officer Monitoring results
shall be reported at the intervals specified in Monitoring and Reporting Program
No. R8-2002-0014
3 Any person who, without regard to intent or negligence, causes or permits any
sewage or other waste to be discharged in or on any waters of the State, or
discharged in or deposited where it is, or probably will be, discharged in or on
any surface waters of the State, as soon as that person has knowledge of the
discharge, shall immediately notify the local health officer and the Regional Board
of the discharge Discharges of sewage to storm drains and drainage channels,
whether man made or natural or concrete lined, shall be reported as required
above. All SSOs greater than 1 000 gallons shall also be reported to the Office
of Emergency Services. The discharger shall propose, as part of it's SSMP a
plan and schedule for reporting and evaluating subsurface discharges of sewage
from it's sewage collection system.
F CHANGE IN OWNERSHIP
1 This Order is not transferable to any person, except after notice to the Executive
Officer The discharger shall submit this notice in writing at least 30 days in
advance of any proposed transfer The notice must include a written agreement
between the existing and new discharger containing a specific date for the
transfer of this Order's responsibility and coverage between the existing
discharger and the new discharger This agreement shall include an
Order No. R8-2002-0014 Page 16 of 18
General WDR, SSO
acknowledgement that the existing discharger is liable for violations up to the
transfer date and that the new discharger is liable from the transfer date on.
G. INCOMPLETE REPORTS
1 Where the discharger becomes aware that it failed to submit to the Regional
Board any relevant facts in any report required under this Order it shall promptly
submit such facts or information.
H. REPORT DECLARATION
1 All applications, reports, or information (except for 24 hour Sanitary Sewer
Overflow Reports) submitted to the Executive Officer shall be signed and certified
as follows:
a. All reports, including disks, (except for preliminary Sanitary Sewer
Overflow Reports submitted as soon as possible) required by this
Order and other information required by the Executive Officer shall
be signed and certified by a person designated, for a municipality
state, federal or other public agency by either a principal executive
officer or ranking elected official, or by a duly authorized
representative of that person, as described in paragraph b. of this
provision.
b An individual is a duly authorized representative only if
(1) The authorization is made in writing by a person described in
paragraph a. of this provision,
(2) The authorization specifies either an individual or a position
having responsibility for the overall operation of the
regulated facility or activity and
(3) The written authorization is submitted to the Executive
Officer
c. Any person signing a document under this provision shall make the
following certification:
Order No. R8-2002-0014 Page 17 of 18
General WDR, SSO
'I certify under penalty of law that this document and all
attachments were prepared under my direct supervision in
accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the
information, the information is, to the best of my knowledge and
belief true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the
possibility of fine and imprisonment.
I. REGIONAL BOARD ADDRESS
1 The discharger shall submit reports required under this Order or other
information required by the Executive Officer to:
Executive Officer
Santa Ana Regional Board
3737 Main Street, Suite 500
Riverside, CA 92501 3348
Phone No.(909-) 782-4130
Fax No.(909) 781-6288
J. CIVIL MONETARY REMEDIES FOR DISCHARGE VIOLATIONS
1 The California Water Code provides that any person who violates this Order is
subject to civil monetary remedies.
2. The California Water Code also provides that any person failing or refusing to
furnish technical or monitoring program reports, as required under this Order or
falsifying any information provided in the technical or monitoring reports is also
subject to civil monetary penalties.
K. SEVERABILITY
1 The provisions of this Order are severable, and if any provision of this Order or
the application of any provision of this Order to any circumstance, is held invalid
the application of such provision to other circumstances, and the remainder of
this Order shall not be affected thereby
2. This order does not convey any property rights of any sort or any exclusive
privileges. The requirements prescribed herein do not authorize the commission
of any act causing injury to persons or property nor protect the discharger from
Order No. R8-2002-0014 Page 18 of 18
General WDR, SSO
liability under federal, state or local laws, nor create a vested right for the
discharger to continue the waste discharge.
L. ORDER
1 This order becomes effective on the date of adoption by the Regional Board.
I Gerard J Thibeault, Executive Officer do hereby certify the foregoing is a full, true,
and correct copy of an Order adopted by the California Regional Water Quality Control
Board, Santa Ana Region, on April 26 2002.
44.4/
and J Thibeault
cutive Officer
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SANTA ANA REGION
MONITORING AND REPORTING PROGRAM NO. R8-2002-0014
FOR GENERAL WASTE DISCHARGE REQUIREMENTS
FOR
SEWAGE COLLECTION AGENCIES
IN ORANGE COUNTY
This Monitoring and Reporting Program (MRP) establishes monitoring, record keeping,
reporting and public notification requirements for Order No. R8-2002-0014 "General
Waste Discharge Requirements for Sewage Collection Agencies in Orange County
within the Santa Ana Region. Revisions to this MRP may be made at any time by the
Executive Officer and may include a reduction or increase in the monitoring and
reporting.
A. DEFINITIONS
1 Sanitary Sewer Overflow A sanitary sewer overflow (SSO) is any overflow
spill, release, discharge or diversion of wastewater from a sanitary sewer system.
SSOs include:
(i) overflows or releases of wastewater that reach waters of the United States;
(ii) overflows or releases of wastewater that do not reach waters of the United
States; and
(iii) wastewater backups into buildings and on private property that are caused by
blockages or flow conditions in a sanitary sewer other than a building lateral.
Wastewater backups into buildings caused by a blockage or other malfunction of
a building lateral that is privately owned is a SSO when sewage is discharged off
of private property into streets, stormdrains, or waters of the State.
2. Sanitary Sewer System —Any system of pipes, pump stations, sewer lines, etc.
used to collect and convey sewage to a treatment plant. Temporary storage and
conveyance facilities (such as vaults, temporary piping, construction trenches,
wet wells, impoundments, tanks, highlines, etc.) are considered to be part of the
sanitary sewer system, and discharges of sewage to these facilities are not
sanitary sewer overflows,
Monitoring and Reporting Program No. R8-2002-0014 Page 2 of l l
General WDR, SSO
B. REPORTING REQUIREMENTS
1 If samples are collected, monitoring results must be reported on discharge
monitoring report forms approved by the Executive Officer
2. Records shall be maintained by the discharger for a minimum of five years from
the date of the sample, measurement, report or application. This period may be
extended during the course of any unresolved litigation regarding a discharge or
when requested by the Regional Board Executive Officer
3 All records shall be made available for review upon RWQCB staffs request.
4 All monitoring instruments and devices that are used by the discharger to fulfill
the prescribed monitoring program shall be properly maintained and calibrated as
necessary to ensure their continued accuracy.
5 The discharger shall retain records of all SSOs, including, but not limited to:
a. All original strip chart recordings for continuous monitoring
instrumentation;
b. Service call records and complaint logs of calls received by the
discharger.
c. Spill calls;
d. Spill records;
e. Copies of all reports required by this Order.
f The location of the overflow and the receiving water if any (street address
or GPS coordinates);
g. An estimate of the volume of the overflow-
h. A description of the sewer system component from which the release
occurred (e.g. manhole, constructed overflow pipe, crack in pipe);
The estimated date and time when the overflow began and when it
stopped-
j. The cause or suspected cause of the overflow.
k. Steps that have been and will be taken to prevent the overflow from
recurring and a schedule to implement those steps.
Work orders from the previous 3 years which are associated with
responses and investigations of system problems related to sanitary
sewer overflows;
m. A list and description of complaints from customers or others from the
previous 3 years; and
n. Documentation of performance and implementation measures for the
previous 3 years.
Monitoring and Reporting Program No. R8-2002-0014 Page 3 of 1I
General WDR, SSO
6. If monitoring is conducted of any SSO records of monitoring information shall
include.
a. The date, exact place, and time of sampling or measurements;
b The individual(s) who performed the sampling or measurements;
c. The date(s) analyses performed;
d. The individual(s) who performed the analyses;
e. The analytical technique or method used; and,
f The results of such analysis.
7 All monitoring reports shall be signed by an authorized person as required by
Provision H of the Order
C. SANITARY SEWER OVERFLOW REPORTING
1 All discharges of sewage that occur from the discharger's sanitary sewer system,
that results in a discharge to a storm drain, drainage channel, and surface water
body shall be immediately reported to the Regional Board as soon as the
discharger's field staff is aware of the discharge, by telephone, voice mail, e-mail, or
FAX.
Regional Board office hours are between 8:00 a.m. to 5:00 p.m.
Monday through Friday excluding state holidays. Regional Board
voice mail and Fax machine are on-line 24-hours a day 7 days a
week. Regional Board office has voice mail to enable 24 hour/7
days a week reporting at (909) 782-4130 Fax Number is (909)
781-6288.
2. The discharger shall report all SSOs using the attached Sanitary Sewer Overflow
Report Form, or equivalent, within 5-days of the immediate notification. The
information reported to the Regional Board in the initial telephone, voice mail,
FAX, or e-mail report should include, if known at the time:
a. The name and phone number of the person reporting the sanitary
sewer overflow.
b. The responsible sanitary sewer system agency or private property
owner
c. An estimated date and time when the overflow began and when it
stopped;
Monitoring and Reporting Program No. R8-2002-0014 Page 4 of 11
General WDR, SSO
d. Whether the sewage discharged to a storm drain or surface water
body how the spill was contained and treated and how wash
waters were disposed-
The estimated total sewer overflow volume along with a description
of how the volume was tabulated. (The discharger shall take
photographs of the SSO for submittal as part of the quarterly
report);
f How much of the spilled sewage was returned to the system and
how much of the wash waters and any water that has come into
contact with the spilled sewage was returned to the sanitary sewer
and how much sewage, wash water and sewage contaminated
water was discharged to waters of the State;
g. The location of the overflow and the location of the potential
blockage or problem point. A description of the sewer system
component from which the spill occurred. (e.g. manhole,
constructed overflow pipe, crack in pipe);
h. The cause or suspected cause of the overflow
A notation of whether or not the sewer overflow is still occurring at
the time of the report;
j. Steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the overflow and a schedule of major milestones
for those steps; and
k. Confirmation that the local health services agency was or will be
notified as required under the reporting requirements of the local
health services agency
3. Sanitary sewer overflows to storm drains tributary to Waters of the United States
shall be reported as discharges to surface waters.
4 The Discharger shall report all sanitary sewer overflows greater than 1,000
gallons to the Office of Emergency Services (OES), in accordance with California
Water Code Section 13271
Office of Emergency Services
Phone (800) 825-7550
Use the Fax for follow-up only
Fax (916) 262 1677
Monitoring and Reporting Program No. R8-2002-0014 Page 5 of 11
General WDR, SSO
5. The discharger shall submit monthly reports of all SSOs. The monthly report
shall provide the following information for each SSO
a. All the information requested in C 2, above and listed on Sanitary Sewer
Overflow Form attached to Monitoring and Reporting Program No. R8-
2002-0014
b. How the SSO volume was tabulated;
c. Picture(s) of spill required in C.2 e, above,
d. Cause or suspected cause of the overflow Choose all that apply from a
list of standardized causes: infrastructure failure (specify leak, insufficient
capacity damaged/broken pipe), blockage (specify grease, roots, debris,
vandalism, or identify which multiple causes), pump station failure,
significant wet weather event, natural disaster or other
e. Where the spill entered any storm drain inlet;
f Steps taken or planned to reduce eliminate, and prevent reoccurrence of
the overflow and a schedule of major milestones for those steps;
g. Steps taken or planned to mitigate the impact(s) of the overflow and a
schedule of major milestones for those steps.
h. Any additional correspondence and follow-up reports, as necessary to
supplement the Sanitary Sewer Overflow Report Form and to provide
detailed information on cause, response, adverse effects, corrective
actions, preventative measures, or other information.
Enter the data on a computer disk or spreadsheet attachment to e-mail in
the format described below for submission to the Regional Board at the
end of the month.
j. An IBM-PC DOS compatible disk or e-mail, containing the data described
below on all sanitary sewer overflows for the month shall be submitted
monthly with a certification statement described in Provision No. H.1 of
Order R8-2002-0014
k. The disk shall be 3 1/2 inch, double sided, high density formatted for 1 44
MB or a CD-ROM. The information submitted shall be fully compatible
with Microsoft EXCEL version 5.0 In order to safeguard the integrity of
the information submitted on disk against errors caused by accidental
changes, all information should be write-protected. This can be done with
Microsoft EXCEL version 5.0 by choosing 'Protection' from Tools Menu,
and choosing 'Protect Sheet' If more than one sheet is created, protect
every sheet with the same password. Any form of data protection may be
used which will allow Regional Board staff to open the file and copy the
data to a new file. This procedure will safeguard the integrity of
information submitted on computer disk to the Regional Board An
EXCEL template of the database will be supplied.
Monitoring and Reporting Program No. R8-2002-0014 Page 6 of11
General WDR, SSO
The disk shall be labeled with
1 The dischargers name,
2. Monitoring and Reporting Program No R8-2002-0014
3. The month and the year and,
4 The software format.
m. Each sanitary sewer overflow shall be reported in a separate record in the
file Nonnumeric data shall be entered in capital and lower case letters.
n. The required fields for each record shall be in a format compatible with the
SWRCB's SSO database.
6 A statement certifying that there were no sanitary sewer overflows for the quarter
may be submitted in lieu of a floppy disk or e-mail attachment.
7 Sanitary Sewer Overflow Summary Reports and certification statements shall be
submitted to the Executive Officer by the 30`h day of the month following the spill
reporting period. The first monthly summary report will be due July 30 2002, for
spills occurring during April through June 2002. Reports will be due monthly
thereafter
8. The discharger shall report SSOs resulting from pipe breaks, leaking sewer pipes
and joints, and other subsurface discharges of sewage as part of the SSMP
based upon a methodology developed by the Steering Committee. Subsurface
discharges of sewage, that reach the ground surface, shall be reported
immediately in accordance with C 1 above.
9 Monitoring and Reporting Program No. R8-2002-0014 will become effective on
the date of adoption by the Regional Board.
Ordered by leigae4/
erard Thibeault
xecutive Officer
Dated: 26 April 2002
Monitoring and Reporting Program No. R8-2002-0014 Page 7 of II
General WDR, SSO
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SANTA ANA REGION
SANITARY SEWER OVERFLOW REPORT FORM
April 26, 2002
ALL ITEMS ARE REQUIRED TO BE ADDRESSED.
1 THIS REPORT IS (CIRCLE ONE): PRELIMINARY FINAL
REVISED FINAL
2. SANITARY SEWER OVERFLOW SEQUENTIAL TRACKING NUMBER:
3. REPORTED TO
(ENTER FAX, VOICE MAIL, OR NAME OF REGIONAL BOARD STAFF)
4 DATE REPORTED / / (MM/DD/YY)
TIME REPORTED (MILITARY OR 24-HOUR TIME)
5. REPORTED BY.
6, PHONE. ( )
7 REPORTING SEWER AGENCY
8. RESPONSIBLE SEWER AGENCY
9 OVERFLOW START DATE. / / (MM/DD/YY)
TIME. (MILITARY OR 24-HOUR TIME)
Monitoring and Reporting Program No. R8-2002-0014 Page 8 of 11
General WDR, SSO
10 OVERFLOW END• DATE. / / (MM/DD/YY)
TIME. (MILITARY OR 24-HOUR TIME)
11 ESTIMATED OVERFLOW FLOW RATE. (GALLONS PER
MINUTE)
12.TOTAL OVERFLOW VOLUME. (GALLONS)
13 DESCRIPTION OF HOW VOLUME WAS DETERMINED/CALCULATED ATTACH
PHOTOGRAPH(S)/DIAGRAM(S):
14 OVERFLOW VOLUME RECOVERED' (GALLONS)
15.OVERFLOW VOLUME RELEASED TO ENVIRONMENT (GALLONS)
SANITARY SEWER OVERFLOW LOCATION AND DESCRIPTION:
16.STREET
CITY ZIP CODE.
17 COUNTY _ (SB, RV OR)
18.SANITARY SEWER OVERFLOW STRUCTURE I J
19 NUMBER OF OVERFLOWS WITHIN 1000 FT 01- THIS LOCATION IN PAST 12
MONTHS
20 DATES OF OVERFLOWS WITHIN 1000 FT OF THIS LOCATION IN PAST 12
MONTHS
Monitoring and Reporting Program No. R8-2002-0014 Page 9 of II
General WOR, SSO
21 OVERFLOW CAUSE -SHORT DESCRIPTION CIRCLE ONE
ROOTS GREASE LINE BREAK INFILTRATION
ROCKS BLOCKAGE POWER FAILURE PUMP STATION
FAILURE
DEBRIS VANDALISM FLOOD DAMAGE MANHOLE FAILURE
OTHER UNKNOWN CONSTRUCTION PRIVATE PROPERTY
22.OVERFLOW CAUSE DETAILED DESCRIPTION OF CAUSE
23.SANITARY SEWER OVERFLOW CORRECTION DESCRIPTION OF ALL
PREVENTATIVE AND CORRECTIVE MEASURES TAKEN OR PLANNED
24 WAS THERE MEASURABLE PRECIPITATION DURING 72-HOUR PERIOD PRIOR
TO THE OVERFLOW? _ (Y OR N)
Monitoring and Reporting Program No. R8-2002-0014 Page 10 of 11
General WDR, SSO
INITIAL AND SECONDARY RECEIVING WATERS:
25.DID THE SANITARY SEWER OVERFLOW ENTER A STORM DRAIN?
(Y OR N)
26 DID THE SANITARY SEWER OVERFLOW REACH SURFACE WATERS
OTHER THAN A STORM DRAIN? _ (Y OR N)
27 NAME OR DESCRIPTION OF INITIAL RECEIVING WATERS. (IF NONE, TYPE
NONE)
28.NAME OR DESCRIPTION OF SECONDARY RECEIVING WATERS (IF NONE,
TYPE NONE)
29 IF THE SANITARY SEWER OVERFLOW DID NOT REACH SURFACE WATERS
DESCRIBE THE FINAL DESTINATION OF SEWAGE.
NOTIFICATION
30 WAS THE LOCAL HEALTH SERVICES AGENCY NOTIFIED? _ (Y OR N)
31 IF THE OVERFLOW WAS OVER 1 000 GALLONS, WAS THE OFFICE OF
EMERGENCY
SERVICES (OES) NOTIFIED? _ (Y or N) (NOT APPLICABLE, ENTER NA)
AFFECTED AREA POSTING:
32.WERE SIGNS POSTED TO WARN OF CONTAMINATION? _ (Y OR N)
33 LOCATION OF POSTING (1F POSTED):
Monitoring and Reporting Program No. R8-2002-0014 Page II of i l
General WDR, SSO
34 HOW MANY DAYS WERE THE WARNING SIGNS POSTED?
35 WERE SAMPLES OBTAINED OF CONTAMINATED WATER? (ATTACH
RESULTS)
36.REMARKS.
ter, ENVIRONMENTAL
t J ' ENGINEERING & CONTRACTING, INC.
1 501 Parkcenter Drive, Santa Ana, CA 92705
Phone (714) 667 2300 Fax (714) 667-2310
August 30, 2004
Mr Rob Hamers
Costa Mesa Sanitary District
234 East 17th Street
Suite 205
Costa Mesa, California 92627
Subject: Proposal and Cost Estimate to Provide Fats, Oils, and Grease (FOG) Program
Development and First Year Implementation Services
Dear Rob,
Environmental Engineering & Contracting, Inc. (EEC) is pleased to present this proposal to
provide Fats, Oils, and Grease (FOG) control program development and first year
implementation services for the Costa Mesa Sanitary District (District). A FOG control program
is a requirement of the Santa Ana Regional Water Quality Control Board (SARWQCB) Waste
Discharge Requirements (WDR) Order No. R8-2002-00l4 The District's FOG control
ordinance (soon to be modified) and the FOG Characterization Study will serve as the basis for
the FOG control program development and implementation. The services described in this
proposal intend to provide the remaining elements needed to develop and implement an effective
FOG control program, which will result in a reduction in the District's grease-related sanitary
sewer overflows (SSOs), blockages, and maintenance.
This proposal is for services provided by EEC from October 1 2004 through June 30, 2005
Inspections of FSEs that have already been identified as sources of FOG and those FSEs
upstream of hot spots will begin October I 2004 The bulk of the other field inspections will
begin January l 2005
SCOPE OF WORK
The scope of work for the proposed FOG control program development and implementation for
District will include the following tasks:
1 Program Management
Developing program forms and program guidance documents
Providing FOG control program management, including database management
Providing a FOG control program assessment and recommendations
F -recta Mesa.Sanitary Dig rlrt August 10 9004
2. Inspections
Conducting permitting/registration inspections
Conducting grease removal equipment (GRE) inspections
Conducting kitchen best management practices (BMP) inspections
Conducting combined kitchen BMP and GRE inspections
Conducting compliance inspections
Conducting CCTV Source Inspections
3 Enforcement
Conducting enforcement inspections
Providing enforcement management
The specific details to these tasks are as follows:
1.0 PROGRAM MANAGEMENT
I I PROGRAM GUIDANCE DOCUMENTS
I 1 I FSE FOG Control Program Policies and Procedures Manual
Based on the findings and recommendations of the Orange County FOG Control Study and
the District s FOG control ordinance and FOG characterization study EEC will develop a
FOG control program policies and procedures manual. The manual will include all program
forms (e.g. inspection forms, NOVs) and provide an overview of the District s program
implementation such as sewer hot spot prioritization, hot spot source identification, FSE
inspection methods and forms, enforcement guidelines, database management and GIS
management. The first draft of the manual will focus primarily on program forms, flow
charts, and other conceptual diagrams to simplify the manual and to keep costs low
A preliminary draft of the manual will be distributed to District staff for review and comment
by November 30, 2004
EEC will incorporate the staff comments and develop a final draft manual which will be
updated over time based on the recommendations provided in 1.3
11.2 Residential, Industrial, and Grease Hauler FOG Control Program Guidance Document
Based on the findings and recommendations of the Orange County FOG Control Study and
the FOG characterization study EEC will develop a residential and grease hauler FOG
control guidance document.
The document will outline the steps that the District will follow to control residential grease
and grease-related hot spots, and improve sewer line cleaning. This will include the
education and outreach elements designed to limit the amount of grease that single family
and multi-family housing discharge to the sewer
2
FF('-Costa u • IP Aug ict 3n,7nn4
The document will outline the steps that the District will follow to control industrial
discharge of FOG. This will include coordinating with Orange County Sanitation District on
their industrial source control program.
These documents will be brief and to the point to simplify the manual and to keep costs low
A preliminary draft of the manual will be distributed to District staff for review and comment
by November 30, 2004.
EEC will incorporate the staff comments and develop a final draft manual which will be
updated over time based on the recommendations provided in 1.3
1 1.3 Permitting/Registration
EEC will assist District staff in developing specific FOG control permits or an FSE
registration for the District to distribute to each of the FSEs.
EEC will develop a permit or registration tracking module for the existing FOG
Characterization FSE database to be utilized to assist in managing the program.
1.2 FOG CONTROL PROGRAM MANAGEMENT INCLUDING DATABASE
MANAGEMENT
EEC will review and update the results of the FSE and hot spot inspections into the
associated databases, and will develop database forms and reports, as appropriate, to
summarize the findings of these inspections.
EEC will conduct regular meetings with District staff to provide recommendations and to
prioritize required activities.
On a monthly basis, EEC will report the activities conducted during the month, identify
findings, and provide recommendations to the FOG Control Program Manager
In the first 3 months, the program will be ramping up and there will be less program
management than in the following 6 months. This is reflected in the cost estimate as the
equivalent of 7 5 months of full service program management.
1.3 FOG CONTROL PROGRAM ASSESSMENT AND RECOMMENDATIONS
At the end of the year EEC will conduct a FOG control program assessment and provide
recommendations for program enhancement and resource management. This will include hot
spot mitigation, FSE compliance status, and grease-related SSO status.
2.0 INSPECTIONS
2.1 PERMITTING/REGISTRATION INSPECTIONS
EEC will physically inspect the FSEs in the District based on the prioritization scheme
developed in Task 1 1 Based on current estimates, there are approximately 400 FSEs in the
District. For the sake of this proposal, in the first year of the program, EEC will plan to
3
F.FC-Costa Mesa Sanitary Distort August i) 1(04
perform initial permitting/registration inspections at 30% of the FSEs, focusing first on those
FSEs identified as concerns in the FOG characterization study and those FSEs that are
upstream of known hot spots.
For those FSE that were identified as FOG sources in the FOG Characterization Study EEC
will present the CCTV evidence to the FSE management and will discuss the enforcement
options that are available to the District and the steps that the FSE can take to avoid
additional enforcement.
2.2 GREASE REMOVAL EQUIPMENT (GRE) INSPECTIONS
EEC will physically conduct GRE inspections for FSEs with a grease interceptor or grease
trap and is projecting to perform approximately 100 GRE inspections during the first year
2.3 KITCHEN BEST MANAGEMENT PRACTICES (BMP) INSPECTIONS
EEC will physically conduct kitchen BMP inspections for FSEs and is projecting to inspect
approximately 40 FSEs during the first year
2.4 COMBINED KITCHEN BMP AND GRE INSPECTIONS
EEC will physically conduct combined kitchen BMP and GRE inspections for FSEs and is
projecting to inspect approximately 20 FSEs during the first year
2.5 COMPLIANCE INSPECTIONS
Compliance inspections are FSE inspections that are required to follow-up on an identified
compliance issue. Although it is difficult to estimate the amount of non-compliance at this
time, EEC will plan to perform compliance inspections at 90 FSEs in the first year of the
program due to non-compliance issues or on-going hot spot source identification.
This may include the issuance of written warnings or notices of violation (NOVs) to FSEs
that are found to be in non-compliance of the FOG control ordinance or permit. The detailed
enforcement procedures will be outlined in Task 1 1 1
2.6 CCTV SOURCE INSPECTIONS
EEC will assess hot spots to identify FSEs that are discharging FOG to the sewer collection
system utilizing District s CCTV staff or subcontractor It is projected that 12 days of CCTV
Source Inspections will be conducted during the first year of the program.
4
FTC-Costa Mesa S'nitery Distrirt August 40,MU
3.0 ENFORCEMENT
3 1 ENFORCEMENT INSPECTIONS
Although it is difficult to estimate the amount of enforcement required at this time, EEC will
plan to perform two enforcement inspections at 12 FSEs each (total of 24) in the first year of
the program. Due to the serious nature of these inspections, EEC will attempt to meet with
the FSE manager or property owner to discuss the enforcement and the FSE's plans to come
into compliance.
3.2 ENFORCEMENT MANAGEMENT
Based on the results of the CCTV Source Inspections and continued NOVs, EEC will review
provide recommendations, and assist the District staff and FOG Control Program Manager in
the enforcement process identified in Task 1 1 I For the sake of this proposal, EEC is
assuming that enforcement management will be required for 12 FSEs.
COST ESTIMATE
Based on the aforementioned scope of work, EEC has identified the projected costs (identified as
a time-and-material estimate, a fixed cost, or a unit based cost) for each of the tasks as follows:
October 1 2004— June 30, 2005
TITLE Units RATE TOTAL
Program Documents T&M 1 $ 10,000 $10,000
Program Implementation Fixed 7.5 $ 7,088 $53,160
Annual Assessment Fixed 1 $ 5,415 $5,415
$68,575
FSEs
Registration Inspections Unit 400 0.3 $ 121 $14,520
GRE Inspections Unit 100 1 $ 52 $5,200
BMP Inspections Unit 40 1 $ 74 $2,960
GRE BMP Inspections Unit 20 1 $ 84 $1,680
Compliance Inspections Unit 90 1 $ 124 $11,160
CCTV Source Inspection
Oversite Unit 12 $ 1,190 $14,280
$49,800
Enforcement Inspections T&M 12 2 $ 251 $6,024
Enforcement Project
Management T&M 12 $ 1,490 $17,880
$23,904
Total $142,279
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FFC-Costa Mrca anitary Distort August 40 7004
The total projected cost is $142,279 to complete the aforementioned scope of work. The
payment terms are net 30-days and progress invoices will be submitted on a monthly basis.
These costs do not include CCTV contractor, printing or mailing associated costs and the time
and-materials portion of the work will be based on EEC's 2004 Fee Schedule (attached).
EEC looks forward to this opportunity to assist the Costa Mesa Sanitary District in implementing
a successful FOG Control Program and will be available to start immediately upon issuance of a
purchase order
If you have any questions regarding this proposal, please call Stan Steinbach or John Shaffer at
(714) 667 2300
Sincerely
Environmental Engineering and Contracting, Inc.
54 J4ei
Stan Steinbach
Senior Project Engineer II
Attachments: Environmental Engineering and Contracting, Inc. 2004 Fce Schedule
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