16 - Sewer System Management Plan Self AuditProtecting our community's health and the environment by providing solid waste and sewer collection services.
www.cmsdca.gov
Costa Mesa Sanitary District
….an Independent Special District
Memorandum
T o: Board of Directors
From: Scott Carroll, General Manager
Date: June 27, 2013
Subject: Sewer System Management Plan (SSMP) Self Audit
Summary
CMSD entered into an agreement with Environmental Engineering & Contracting
(EEC) to perform a self-audit of the Districts’ Sewer System Management Plan
(SSMP). EEC performed the last self-audit in 2011. EEC has completed the audit
and is ready to present their findings to the Board at tonight’s meeting
S ta ff Recommendation
That the Board of Directors:
1. Accepts the SSMP self-audit performed by EEC; and
2. Direct staff to report back with an implementation plan for the minor corrective
actions identified in the audit; and
3. Direct staff to bring back the SSMP with amendments for recertification
approval.
Analysis
In February 2013, staff solicited proposals for conducting an internal audit of the
Distirct’s Sewer System Management Plan (SSMP). Staff sen t RFPs to the following
consultants:
1. Larson Consulting
2. Environmental Engineering & Consulting (EEC)
3. Dudek
4. Willow Enterprises
5. Dexter Wilson Engineering
6. RMC Water and Environment
ITEM NO. 16
Board of Directors
June 27 , 2013
Page 2 of 2
All the firms mentioned above have demonstrated experience conducing SSMP aud its
for various sanitation and sanitary agencies. EEC was the only consulting firm that
submitted a proposal.
In compliance with the Statewide General Waste Di scharge Requirements (GWDR)
for Sanitary Sewer Systems (State Water Resources Control Board O rder No. 2006 -
003 -DWQ), the District developed and implemented a comprehensive Sewer System
Management Plan (SSMP ), with the primary objective of reducing and preventing
Sanitary Sewer Overflows (SSOs). A key requirement of the SSMP is that every two
years routine internal audits be performed to evaluate the effectiveness of the SSMP
as well as the District’s compliance with the SSMP elements. The last self -audit was
performed in April 2011.
EEC identified several minor nonconformance issues that are easil y rectified. Some of
the nonconformance issues are identified below:
1. Standard sewer permits do not mention pretreatment requirements recognized
by OCSD.
2. All employees training related to operations and maintenance of sewer system
are not documented. Spe cifically, training seminars to the California Water
Environment Association are not documented.
3. The District does not conduct routine refresher training for staff on SSO
response procedures.
EEC staff will be giving a brief presentation to the Board rega rding their findings to the
self -audit.
Strategic Plan Element & Goal
This item complies to the objective and strategy of Strategic Plan Element 1.0, Sewer
Infrastructure , which states:
“Our objective is to collect and transport wastewater to meet the ne eds of existing and
future customers.”
“We will do this by the careful management of the collection infrastructure using
prudent planning and maintenance, with financial strategies to maintain sufficient
capacity and respond to changing regulatory demands .”
Legal Review
Not applicable
Financial Review
The cost to perform the self -audit by EEC is $15,500 . This cost is approved in the FY
2013 -14 Budget.
There are no financial impacts for revising the SSMP. All revisions were performed by
in -house staff.
Board of Directors
June 27 , 2013
Page 3 of 2
Committee Recommendation
Not applicable
Public Notice Process
Copies of this report are on file and will be included with the entire agenda packet for
the June 27 , 201 3 Board of Directors regular meeting at District Headquarters and on
District’s websit e.
Alternative Actions
1. Direct staff to report back with more information.
Attachment s A: CMSD Self -Audit performed by EEC
Waste Discharge Requirements
Sewer System Management Plan Audit
June 18, 2013
Prepared for:
Costa Mesa Sanitary District
628 West 19th Street
Costa Mesa, California
Prepared by:
Environmental Engineering & Contracting, Inc.
501 Parkcenter Drive
Santa Ana, California 92705
EEC W2489.01
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District i EEC
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................................ 1
2.0 AUDIT METHODS .............................................................................................................................. 1
2.1 Performance Measures ....................................................................................................... 2
2.2 Results Reporting ................................................................................................................ 2
3.0 RESULTS ........................................................................................................................................... 3
3.1 Goals ................................................................................................................................... 3
3.1.1 Plan and Schedule for Management, Operation, and
Maintenance of Sewer System ........................................................................ 3
3.1.2 Reduction and Prevention of Sewer System Overflows ........................................ 3
3.1.3 Areas of Nonconformance to the Sewer System Management Plan .................... 5
3.1.3.1 Recommended Corrective Actions ........................................................... 5
3.2 Organization ........................................................................................................................ 5
3.2.1 Areas of Nonconformance to the Sewer System Management Plan .................... 6
3.2.1.1 Recommended Corrective Actions ........................................................... 6
3.3 Legal Authority .................................................................................................................... 6
3.3.1 Areas of Nonconformance to the Sewer System Management Plan .................... 6
3.3.1.1 Recommended Corrective Actions ........................................................... 7
3.4 Operation and Maintenance Program ................................................................................ 7
3.4.1 CMSD Sanitary Sewer System Map ........................................................................ 7
3.4.2 Preventative Maintenance Plan ............................................................................. 8
3.4.2.1 System-Wide Cleaning .............................................................................. 8
3.4.2.2 Hot Spot and Lift Station Maintenance .................................................... 9
3.4.3 Rehabilitation and Replacement Plan .................................................................... 9
3.4.3.1 Rehabilitation Projects .............................................................................. 9
3.4.3.2 Capital Improvement Program ............................................................... 10
3.4.4 Staff Training ........................................................................................................ 12
3.4.5 Equipment and Replacement Parts Inventory ..................................................... 12
3.4.6 Areas of Nonconformance to the Sewer System Management Plan .................. 12
3.4.6.1 Recommended Corrective Actions ......................................................... 12
3.5 Design and Performance Provisions ................................................................................. 13
3.5.1 Areas of Nonconformance to the Sewer System Management Plan .................. 13
3.5.1.1 Recommended Corrective Actions ......................................................... 13
3.6 Overflow Emergency Response Plan ................................................................................ 13
3.6.1 Areas of Nonconformance to the Sewer System Management Plan .................. 14
3.6.1.1 Re commended Corrective Actions ......................................................... 14
3.7 FOG Control Program ........................................................................................................ 15
3.7.1 Public Education and Outreach Program ............................................................. 15
3.7.2 Inspection of Grease-Producing Facilities ............................................................ 16
3.7.3 Legal Authority to Prohibit Discharges to the System ......................................... 17
3.7.4 Grease-Removal Device Requirements ............................................................... 17
3.7.5 Cleaning Schedule for Sewer System Sections Subject to FOG Blockages and
Source-Control Measures for Enhanced Maintenance Areas ....................... 17
3.7.6 FOG Disposal Plan ................................................................................................ 17
3.7.7 Areas of Nonconformance to the Sewer System Management Plan .................. 17
3.7.7.1 Recommended Corrective Actions ......................................................... 17
3.8 System Evaluation and Capacity Assurance Plan .............................................................. 18
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District ii EEC
3.8.1 Evaluation ............................................................................................................ 18
3.8.2 Design Criteria ...................................................................................................... 18
3.8.3 Capacity Enhancement Measures ....................................................................... 18
3.8.4 Capital Improvement Plan Schedule .................................................................... 18
3.8.5 Areas of Nonconformance to the Sewer System Management Plan .................. 18
3.8.5.1 Recommended Corrective Actions ......................................................... 19
3.9 Monitoring, Measurement, and Program Modifications ................................................. 19
3.9.1 Areas of Nonconformance to the Sewer System Management Plan .................. 19
3.9.1.1 Recommended Corrective Actions ......................................................... 19
3.10 SSMP Program Audit ......................................................................................................... 19
3.10.1 Areas of Nonconformance to the Sewer System Management Plan .................. 19
3.10.1.1 Recommended Corrective Actions ........................................................ 20
3.11 Communications Program ................................................................................................ 20
3.11.1 Areas of Nonconformance to the Sewer System Management Plan .................. 20
3.11.1.1 Recommended Corrective Actions ........................................................ 20
4.0 SUMMARY ...................................................................................................................................... 20
Figures
Figure 3-1 Public Sanitary Sewer Overflows per 100 Miles of Sewer Line in
CMSD Service Area, 2009 –2012 ................................................................................... 8
Figure 3-2 Percentage of Sanitary Sewer Overflow Volume Recovered in
CMSD Service Area, 2009 –2012 ................................................................................... 7
Figure 3-3 GIS-Based Sewer Atlas Legend ............................................................................................ 8
Figure 3-4 CMSD Capital Improvement Plan Budget Allocation for Fiscal Year 2013 –2014 ............. 11
Figure 3-5 Sewer Lateral Assistance Program Participation in CMSD Service Area ........................... 11
Figure 3-6 Percentage of Sanitary Sewer Overflow Volume
That Reached Surface Waters in CMSD Service Area, 2009 –2012 ............................ 14
Figure 3-7 FOG-Related Sanitary Sewer Overflows Compared to
Total Public Sanitary Sewer Overflows in CMSD Service Area,
Fiscal Years 2008/09 –201 1/12 ................................................................................... 15
Figure 3-8 Percentage of Food Service Establishment Employees Not Trained in Kitchen Best
Management Practices in CMSD Service Area, Fiscal Years 2008/2009 –2011/2012 16
Tables
Table 2-1 Costa Mesa Sanitary District Personnel Interviewed .......................................................... 2
Table 3-2 Length of CMSD Sewer Lines Scheduled for Cleaning in the Past 3 Fiscal Years ................ 8
Table 3-3 CMSD Sewer System Rehabilitation Projects ................................................................... 10
Table 3-7 Number of Food Service Establishments Inspected per Frequency in
CMSD Service Area ..................................................................................................... 16
Table 4-1 Summary of Sewer System Management Plan Audit Results .......................................... 21
Appendices
Appendi x A List of SSMP Documents and Data Reviewed
Appendix B Ex ample Enforcement Letter
Appendix C Example Standard Sewer Permit
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
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Appendix D Example Sewer Cleaning Work Order
Appendix E Enforcement Response Flow Chart
Appendix F Summary of Findings
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1.0 INTRODUCTION
The Costa Mesa Sanitary District (CMSD) is an independent special district that provides sewer and solid
waste collection service to the City of Costa Mesa , portions of the City of Newport Beach, and portions
unincorporated Orange County. The CMSD headquarters are located at 628 West 19th Street and the
District Yard is lo cated at 174 West Wilson Street in the City of Costa Mesa, California . The CMSD serves
a population of approximately 116,700, as well as public, commercial, industrial, and retail businesses.
The CMSD ’s sewer system assets consist of 22 4 miles of mainline sewers, 4 miles of pressurized sewer
lines (force mains), and 20 wastewater pumping stations.
In 2006, the State Water Resources Control Board adopted statewide sewer regulations, termed waste
discharge requirements (WDR), aimed at reducing the occurrence of sanitary sewer overflows (SSOs ). In
an effort to create uniformity in the way sewer systems are managed across the state, the SWRCB,
through the WDR, requires any sewer agency with a sewer system of greater than 1 mile to implement a
sewer system management plan (SSMP). To comply with the WDR, the CMSD developed an SSMP
establishing policies and procedures to direct sewer system management in its service area and uphold
California water quality standards.
The SSMP must be audited every two years to assess the effectiveness of the plan and identify
improvements that could further increase the plan’s effectiveness in limiting SSOs. The CMSD conducted
an initial audit in 2011 that identified necessary revisions to the SSMP. CMSD subsequently updated the
SSMP based on the findings of the 2011 audit .
Environmental Engineering & Contracting, Inc. (EEC) was retained to support the CMSD in developing
and performing a follow-up audit of the SSMP following the results of the initial audit. This report
documents the results of the second audit conducted in April and M ay 2013 .
2.0 AUDIT METHODS
EEC’s framework for the SSMP audit consist s of five key elements:
1) Audit Kick-O ff Meeting – A kick-off meeting with CMSD staff was conducted to describe the
audit process, define the purpose of the audit, and set expectations for the audit.
2) SSMP Assessment – While the 2011 audit evaluated the conformance of the CMSD ’s SSMP to
the statewide WDR, the 2013 audit focused on the conformance of the CMSD ’s practices to the
policies of the SSMP. The audit especially considered changes that have been made in response
to the findings and recommendations of the 2011 audit.
3) Documentation/Data Gathering and Review – All available data and previously prepared
documents relevant to the SSMP were gathered and reviewed (Appendix A, List of SSMP
Documents and Data Reviewed ). Information from this review was used to plan staff interviews
regarding CMSD practices, policies, and procedures related to the SSMP.
4) Staff Interviews – Multiple interviews with CMSD staff were conducted to assess the level of
conformance of CMSD practices with the policies and procedures identified in the SSMP (Table
2-1, Costa Mesa Sanitary District Personnel Interviewed ). Personnel were asked to opine on the
performance of, and recommend improvements to, the sewer system management program.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 2 EEC
Table 2-1, Costa Mesa Sanitary District Personnel Interviewed
Name Title Responsibility
Mr. Scott Carroll General Manager Oversight of D istrict operations
Mr. Rob in Hamers District Engineer Management of d esign and improvement
Mr. Steve Cano Maintenance Supervisor Supervision of maintenance activities
Mr. Tim Henson Maintenance Worker Maintenance of p ump station s
Mr. Joel Ortiz Maintenance Worker Operation of v acuum/j etter truck
5) Report Preparation – A report was prepared documenting the audit findings and
recommendations. The report was provided to CMSD staff for review.
2.1 Performance Measures
EEC evaluated the CMSD’s sewer system management operations against the established SSMP policies
and procedures:
1. Goal
2. Organization
3. Legal Authority
4. Operation and Maintenance Program
5. Design and Performance Provisions
6. Overflow Emergency Response Plan
7. FOG Control Program
8. System Evaluation and Capacity Assurance Plan
9. Monitoring, Measurement, and Program Modifications
10. SSMP Program Audits
11. Communications Program
2.2 Results Reporting
To enable the CMSD to focus on improving its sewer system management program, EEC’s findings for
each performance area are described in terms of the degree of nonconformance with the SSMP:
A minor nonconformance is a minor deficiency in the CMSD ’s sewer management program that
would not normally warrant issuance of a notice of violation, fine, or other enforcement action
by the regulatory oversight agency . This type of nonconformance usually occurs when an SSMP
requirement is not being met and can occur when repeated deficiencies become a trend.
A major nonconformance is a serious deficiency in the CMSD ’s sewer management program that
may warrant a notice of violation, fine, or other enforcement action by the regulatory oversight
agency . This type of nonconformance is normally the result of noncompliance with an applicable
State regulation or permit.
For each identified nonconformance, EEC recommends specific actions to correct the nonconformance
to the extent practicable.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 3 EEC
A recommended corrective action is a recommended change to CMSD sewer system
management operations where existing practices do not conform to the SSMP. Implementation
of these actions is expected to improve the efficiency and effectiveness of the SSMP and should
be implemented as soon as practicable.
3.0 RESULTS
The following sections describe each SSMP performance category, outline performance criteria, and
document the CMSD ’s conformance to each category . Corrective actions are recommended where the
CMSD ’s practices do not conform to the SSMP.
3.1 Goals
Finding: CMSD is fully conformant to the SSMP in this area .
The CMSD measures the effectiveness of its sewer system management program against three goals
established by the SWRCB for the SSMP:
1. Provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary
sewer system in order to provide reliable service in the future
2. Reduce and prevent SSOs
3. Help mitigate any SSOs that do occur
3.1.1 Plan and Schedule for Management, Operation, and Maintenance of Sewer System
The CMSD has formed a Sewer System Operations Committee composed of directors, engineering staff ,
field staff, administrative staff, and contractors who meet monthly to discuss the state of the sewer
system. The CMSD has established maintenance schedules for sewer lines; pump stations; force mains;
siphons; and hot spots, or areas of the sewer that are prone to SSOs and require more frequent
cleaning. CMSD monitors the status of these maintenance activities to ensure that designated schedules
are being met. In addition, the CM SD has established and implemented a condition assessment plan,
Capital Improvement Plan, Inflow and Infiltration (I/I) Reduction Program, Hot Spot Abatement Program,
and a Sewer Lateral Assistance Program . The combination of these plans and programs with the
established maintenance efforts allows the CMSD to keep SSO incidents consistently low. These plans
and programs are discussed in detail in later sections of this audit.
3.1.2 Reduction and Prevention of Sewer System Overflows
In 201 2, the CMSD experienced a total of four public SSOs (1.8 per 100 miles of sewer) in its service area
and recovered 88% of the total volume of spilled wastewater. Th e SSO rate in 2012 was 42 % lower than
in 2011 and remained below the State average of 6.2 SSOs for every 100 miles of sewer for similarly
sized sewer systems (Figure 3-1, Public Sanitary Sewer Overflows per 100 Miles of Sewer Line in CMSD
Service Area, 2009 –2012 ).
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 4 EEC
Figure 3-1, Public Sanitary Sewer Overflows per 100 Miles of
Sewer Line in CMSD Service Area, 2009 –2012
Since 2011, the CMSD has implement ed SSO response procedures that have improved response times
and increase d the volume of spilled wastewater recovered after SSOs. With the exception of one SSO
that occurred in 2011, the CMSD consistently recovers more than 80% of wastewater spilled during SSOs
(Figure 3-2 , Percentage of Sanitary Sewer Overflow Volume Recovered in CMSD Service Area, 2009 –
2012 ).
Figure 3-2 , Percentage of Sanitary Sewer Overflow Volume Recovered in CMSD
Service Area, 2009 –2012
In 2010, the CMSD opened the new District Yard at 174 West Wilson Street in Costa Mesa. The District
Yard is a centralized storage area located in the heart of Costa Mesa. The centralized location of the
District Yard enables CMSD staff to access necessary equipment and respond quickly to SSOs. CMSD
attributes its fast SSO response times to the centralized, accessible location of the District Yard .
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
2009 2010 2011 2012
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P
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S
S
O
s
Year
SSOs per 100
Miles of
Sewer Line
0
10
20
30
40
50
60
70
80
90
100
2009 2010 2011 2012
% SSO
Volume
Recovered
SS
O
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(
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The CMSD uses closed-circuit television (CCTV) to inspect locations where SSOs previously occurred to
determine causes of the SSOs. The CMSD determines the need for repairs, enhanc es maintenance and
source-control efforts, or implements other applicable corrective actions for SSO-prone locations to
preclude repeated SSOs . If an SSO event occurs on private property, the CMSD requires the property
owner to inspect the private lateral sewer line using CCTV and then works with the property owner(s) to
ensure proper correctiv e actions are taken to prevent reoccurrence. If necessary, the CMSD escalates
enforcement, including requirements to clean the private sewer lateral, continued inspection of the
private lateral with CCTV, and/or repair the private lateral . The CMSD personnel follow up on
enforcement cases through phone calls or by visiting the offices of property owners to ensure that the
required actions are being implemented (Appendix B , Ex ample Enforcement Letter ).
3.1.3 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to SSMP goals were identified .
3.1.3.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.2 Organization
Finding: CMSD is fully conformant to the SSMP in this area.
The CMSD is in conformance with Section II, Organization , of the SSMP. The WDR requires sewer
agencies to appoint Legally Responsible Official s (LRO) to oversee the implementation of the SSMP. The
SSMP must include the names and telephone numbers of staff responsible for implementing the
elements the SSMP program and must outline the chain of communication for reporting SSOs.
The CMSD has adequately defined an organizational structure for sewer system management:
Responsible officials
Lines of authority and responsibilities for the CMSD SSMP program
Chain of Communication for Reporting SSOs
The CMSD updated the SSMP in 2011 to reflect the current organizational structure, including the
names and telephone numbers of persons responsible for managing the sewer system:
General Manager – Alternate LRO responsible for overall sewer management program and
manages SSO reporting process.
District Engineer – LRO responsible for standards and specifications of the sewer system,
creati on and implementation of the Capacity Assurance Plan and Capital Improvement Plan,
reporting SSOs to the California Integrated Water Quality Control Board, and updating and
maintenance of CMSD maps.
Maintenance Supervisor – Primary responder for SSOs; responsible for routine operations and
maintenance activities, oversight of staff training, and management of equipment and spare
parts inventories .
Maintenance Workers – Responsible for general field maintenance activities, including cleaning
of enhanced maintenance locations and maintenance of pump stations.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
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Inspector – Responsible for ensuring new construction meets standards, implementation of
emergency response, and oversight of contractors hired to work on CMSD facilities.
3.2.1 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to the CMSD’s organizational structure were identified .
3.2.1.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.3 Legal Authority
Finding: One minor nonconformance identified ; o ne corrective action recommended.
The CMSD is in conformance with Section III, Legal Authority , of the SSMP. The WDR requires that sewer
agencies have appropriate legal authority to implement and enforce certain elements of the SSMP. The
CMSD Operations Code affords the CMSD the required legal authority to implement and enforce key
elements of the SSMP :
Prevent illicit discharges into the sanitary sewer (Operations Code Section 6.07.040)
Require that sewers and connections be properly designed and constructe d (Operations Code
Section 6.01.010)
Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or
maintained by the CMSD; not applicable, as the CMSD does not own or maintain laterals
Limit the discharge of fats, oils, and grease (FOG) and other debris that may cause SSOs
(Operations Code Section 6.07.040 and Section 6.04.060)
Enforce any violation of its sewer ordinances (Operations Code Title I)
The CMSD reviews plumbing plans, inspect s the sewer system repairs and new construction, and enforces
established policies. The CMSD has applied the necessary enforcement actions to promptly mitigate illicit
discharges. While enforcement actions are rarely required, the CMSD has been able to effectively mitigate
fats, oils, and grease discharge issues by requiring installation of grease interceptors for several existing
facilities that are considered significant contributors to SSOs . Although the CMSD does not own or
maintain lateral sewer lines, i t can legally require property owners to inspect and repair private lateral
sewer lines that connect the private property to the public sewer system (Operations Code Section 6.03).
Operations Code Section 6.8.060 states that pretreatment requirements recognized by the Orange
County Sanitation District for facilities are set forth in CMSD’s standard sewer permit, however; the
standard sewer permit does not mention pretreatment requirements recognized by the Orange County
Sanitation District (Appendix C, Example Standard Sewer Permit ).
3.3.1 Areas of Nonconformance to the Sewer System Management Plan
One minor nonconformance related to sewer system operation and maintenance was identified:
a) Standard sewer permits do not mention pretreatment requirements recognized by OCSD.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 7 EEC
3.3.1.1 Recommended Corrective Actions
One corrective action to remedy the identified nonconformance is recommended:
a) Update standard sewer permits to identify pretreatment requirements recognized by OCSD.
3.4 Operation and Maintenance Program
Finding: Two minor nonconformances identified; two corrective actions recommended.
The SSMP outlines five key elements of the CMSD’s sewer system operation and maintenance program :
CMSD sanitary sewer system map
Preventative maintenance plan
Rehabilitation and replacement plan
Education and training
Equipment and replacement parts inventory
3.4.1 CMSD Sanitary Sewer System Map
In 2012, CMSD completed development of a geographic information system (GIS) and transitioned hand-
drawn sewer system atlases to a GIS-based sewer atlas. The GIS-based atlas shows the location of gravity
sewer lines and manholes, pumping facilities, and force main pipelines (Figure 3-2, GIS-Based Sewer Atlas
Legend ). A separate map showing the location of all storm water conveyance facilitie s is also available to
field staff.
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W2489.01 Costa Mesa Sanitary District 8 EEC
Figure 3-3, GIS-Based Sewer Atlas Legend
Any necessary corrections to the sewer atlas identified by CMSD staff and contractors are provided to
the District Engineer for review and, where appropriate, revision of the atlas. In the past, revisions were
made by red-lining a master copy of the paper atlas, but they are now made directly to the GIS.
3.4.2 Preventative Maintenance Plan
3.4.2.1 System -Wide Cleaning
The CMSD uses a combination of contractors (National Plant Services) and CMSD staff to clean all sewer
lines as a preventive maintenance measure. CMSD divided the service area into 62 zones based on the
wastewater drainage watersheds and distributed the 62 zones evenly between contractor and CMSD staff.
In previous years, the entire sewer system was cleaned once every three years, but in the past year,
CMSD increased the cleaning frequency with a target of at least once every two years (Table 3-2, Length
of CMSD Sewer Lines Scheduled for Cleaning in Past 3 Fiscal Years ). Based on computerized maintenance
management system (CMMS) data for work completed to date (77%) and the work remaining, CMSD is
evaluating options to achieve its internal target. If adjustments are not made to increase the current
cleaning rate, CMSD risks falling short of the goal (Appendix D , Example Sewer Cleaning Work Order ). To
address this issue, CMSD is considering remedy options that include increasing working hours or
requesting additional services from contractors . The contractor has completed its portion of the
cleaning.
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Table 3-2 , Length of CMSD Sewer Lines Scheduled for Clean ing in Past 3 Fiscal Years
Cleaning Frequency
Total Length of Sewer Line s Cleaned
(feet)
Fiscal Year 2010 –2011 Fiscal Year 2011 –2012 Fiscal Year 2012 –2013
Every year 120,240 242,619 246,880
Every two years 95,160 136,920 462,858
Every three years 274,273 240,973 0
3.4.2.2 Hot Spot and Lift Station Maintenance
CMSD staff periodically evaluate hot spot locations with CCTV and determine individual cleaning
frequencies for these locations. Since 2010, CMSD has reduced the number of hot spot locations in its
service area from 95 to 45. The reduction can be attributed to several preventive maintenance
measures that include proactive lining of locations susceptible to root intrusion, improved cleaning
practices, and detailed analysis of sources of fats, oils , and grease (FOG) discharges to the sewer system.
Staff inspect the CM SD’s 20 lift stations on a weekly basis, document pump run times and routine
maintenance activities, and further evaluate abnormalities to identify any significant issues. CMSD
contracts with JIMNI Systems for emergency response and Xylem, Inc. to conduct comprehensive pump
station maintenance. All maintenance activities are documented in journals located at each lift station,
and days and times of maintenance are logged in a separate spreadsheet. Work orders are currently not
created for lift station maintenance.
3.4.3 Rehabilitation and Replacement Plan
3.4.3.1 Rehabilitation Projects
The CMSD has a proactive rehabilitation and replacement program that includes measures for reducing
I/I. In 2009, CMSD completed the second CCTV inspection of the entire sewer system to assess the
system in detail and identi fy I/I issues. CMSD subsequently established eight rehabilitation projects to
address major issues identified during the CCTV study and incorporated the projects into the SSMP. As
of April 2013, the CMSD has completed all rehabilitation projects planned up to 2013 (Table 3-3, CMSD
Sewer System Rehabilitation Projects ).
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Table 3-3 , CMSD Sewer System Rehabilitation Projects
Project
Number Project Description
Projected
Completion
Date
Percentage
Complet ed to
Date
Budgeted
Expense
Actual
Expenditures
129 Bristol Street Sewer Replacement 6/28/2012 100% $634,324 $611,0 61
164 Root Control Program 7/2/2012 100% $121,400 $104,570
171 Irvine Pump Station Force Main
Repairs 6/8/2012 100% $405,665 $37 9 ,087
185 System Wide Sewer
Reconstruction Phase I 2/1/2012 100% $1,086,000 $767,275
189 Rehabilitating 6 Sewers
Transferred to CMSD 11/24/2011 100% $697,666 $672,700
190 Canyon Force Main Rehabilitation 6/20/2012 100% $141,000 $125,433
191 Emergency Work on Santa Ana
23rd Street Force Mains 12/5/2012 100% $850,000 $758,726.16
192 System Wide Sewer
Reconstruction Phase II 4/19/2013 100% $1,115,361 $184,675
Total $5,051,416 $3,603,527.16
3.4.3.2 Capital Improvement Program
The CMSD has implemented an Asset Management Plan that tracks life expectancy, expected
rehabilitation and reconstruction, and costs for the sewer system. The minimum balance in the fund was
established at $5 million. Projects identified in the Asset Management Plan are completed as part of the
Capital Improvement Program (CIP).
CMSD has allocated $1,960,000 for the CIP for fiscal year 2013/2014. By law, funds from the CIP must be
used for maintenance and rehabilitation projects. The CMSD balance s funding from the CIP for new
sewer system improvement projects that aim to improv e the operating efficiency and life expectancy of
the entire sewer system. Based on statements from CMSD staff and past performance of the CIP, CMSD
has allocated sufficient funds to complete rehabilitation and repair projects planned for fiscal year
2013/2014 . CMSD appropriately details each planned project in the CIP and has allocated appropriate
funds to those projects (Figure 3-4, CMSD Capital Improvement Program Budget Allocation for Fiscal
Year 2013/2014 ).
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 11 EEC
Figure 3-4 , CMSD Capital Improvement Program Budget Allocation for
Fiscal Year 2013 /2014
Upgrades to the force mains will make up the majority of capital improvements planned for 2013/2014 .
CMSD uses Pipeline Inspection and Condition Analysis Corporation (PICA) technology to assess the condition
of force mains. In 2012, CMSD identified two separate force mains (located at 23rd St reet and Santa Ana
Avenue) requiring rehabilitation; CMSD completed rehabilitation work for the two force mains in 2012.
CMSD plans to continue similar assessments on the remaining force main locations as soon as possible , but
has not committed to a date for completing the assessments d ue to the complexity of the work.
With the goal of preventing SSOs and potential I/I from private properties, the CMSD implemented a
Sewer Lateral Assistance Program (SLAP) in 2007 that provides financial incentives to encourage
property owners to repair and rehabilitate private lateral sewer lines. Since 2010, 501 residents have
taken part in SLAP to improve their sewer laterals. In 2012, the CMSD contributed $208,876 to
homeowners as part of SLAP (Figure 3-5, Sewer Lateral Assistance Program Participation in CMSD
Service Area ).
Figure 3-5 , Sewer Lateral Assistance Program Participation in CMSD Service Area
400,000
1,000,000
260,000
150,000
150,000
Westside Pump Station
Abandonment
Force Main Upgrades
Replace Pump Station
Equipment
Valve & Pipe Replacement For
Elden Pump Station
Emergency Generator for CMSD
Yard
0 50 100 150 200 250
2010
2011
2012
Total Number of Participants
Ye
a
r
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 12 EEC
3.4.4 Staff Training
In accordance with SSMP requirements, CMSD staff responsible for operation and maintenance of the
sewer system actively participate in education and training activities. The CMSD’s Maintenance
Supervisor has acquired Grade 3 certification as a collection system maintenance operator through the
California Water Environment Association, and two field personnel have completed Grade 1 operator
certification. CMSD personnel routinely attend training seminars and events for continued education
and professional development; however, CMSD does not currently document some of these events . In
addition, the District Engineer actively directs meetings and events for the Orange County WDR Steering
Committee that provide educational opportunities for personnel of CMSD and other agencies.
Based on discussions with CMSD staff, CMSD does not regularly provide employee training related to
SSO response and SSMP elements. Employees are occasionally trained on how to operate the sewer
combination (Sancon) truck, but CMSD does not document the training activities.
3.4.5 Equipment and Replacement Parts Inventory
CMSD has developed an inventory of available equipment and replacement parts that are important for
performing operations within the CMSD service area. The inventory lists the availability, quantity, and
listing date of each part and piece of equipment. The Maintenance Supervisor reviews the inventory
periodically and updates the inventory as parts and equipment are used or replaced.
3.4.6 Areas of Nonconformance to the Sewer System Management Plan
Two minor nonconformances related to sewer system operation and maintenance were identified:
a) CMSD is not currently on pace to complete cleaning of all wastewater drainage watershed
sections scheduled for fiscal year 2012/2013 and risks falling short of the target without
immediate adjustment.
b) A ll employee training efforts are not documented.
3.4.6.1 Recommended Corrective Actions
Two corrective actions are recommended to remedy the identified nonconformances:
a) Reevaluate the system-wide cleaning frequency to identify the necessary actions for CMSD to
meet the sewer system cleaning commitment. CMSD may consider the following actions to
support this goal:
Increase contractor cleaning frequencies.
Add maintenance staff.
Add maintenance equipment.
Reduce the cleaning frequency for segments that do not require annual cleaning.
b) Document and track staff training activities.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 13 EEC
3.5 Design and Performance Provisions
Finding: CMSD is fully conformant to the SSMP in this area.
CMSD has established design and performance provisions for the installation, rehabilitation, and repair
of sewer system assets; the provisions are established in four documents:
Title 7 of the CMSD Operations Code
Costa Mesa Sanitary District Standard Plans and Specifications for the Construction of Sanitary
Sewers
Standard Specifications for Public Works Cons truction (“Green Book”)
American Public Works Association Standard Plans for Public Works Construction
In addition, CMSD has standardized procedures for the use of equipment in pumping stations to
facilitate maintenance and replacement.
All new construction and rehabilitation activities must adhere to the established design standards
adopted by CMSD. CMSD tracks each project and logs the construction plans that have been created for
each project. CMSD ’s written standards are made readily available and accessible to staff members, who
refer to the se standards when performing repairs or inspections. CMSD is also receptive to new
construction and rehabilitation methods that may be more economical and efficient.
During interviews, CMSD staff indicated that facility installations and repairs are regularly tested and
inspected . Documentation provided by CMSD shows that installation and repair procedures are
documented and tracked. Documentation also shows that CMSD keeps records of plan reviews
conducted for new business construction and where property owners have been required to alter plans
to comply with CMSD design standards.
3.5.1 Areas of Nonconformance to the Sewer System Management Plan
No noncomformances with SSMP design and performance provisions were identified .
3.5.1.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.6 Overflow Emergency Response Plan
Finding: One minor nonconformance identified ; one corrective action recommended.
The SSMP requires six key elements for the CMSD Overflow Emergency Response Plan :
SSO notification procedures
Appropriate response to all overflows
Regulatory notification procedures
Oral notification
Written notification
Training procedures
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 14 EEC
Emergency response operations
Program to contain and prevent sewage discharges to surface waters
CMSD’s criteria for determining Category 1 and Category 2 (level of severity) SSOs, as well as procedures
for response and reporting of each SSO, are consistent with the SSMP. CMSD has also developed a
separate emergency response plan to address sewer pumping stations.
Based on the documentation review, CMSD’s internal SSO records are consistent with the California
Integrated Water Quality Control Board’s data. For each SSO occurrence, CMSD notified the proper
authorities and submitted all reports pursuant to the documented procedure. CMSD has been
increasingly effective in containing spills and preventing sewage from reaching surface waters
(Figure 3-6, Percentage of Sanitary Sewer Overflow Volume That Reached Surface Waters in CMSD
Service Area, 2009 –2012 ).
Figure 3-6 , Percentage of Sanitary Sewer Overflow Volume
That Reached Surface Waters in CMSD Service Area, 2009 –2012
Based on interviews with CMSD staff, staff members keep a copy of the SSO Emergency Response Plan
in each service vehicle and have read the plan; however, CMSD staff do not lead training activities for
SSO response procedures or volume estimations.
3.6.1 Areas of Nonconformance to the Sewer System Management Plan
One minor nonconformance related to the CMSD overflow and emergency response plan was identified:
a. CMSD does not conduct routine refresher training for staff on SSO response procedures.
3.6.1.1 Recommended Corrective Actions
One corrective action is recommended to remedy the identified nonconformance:
a. Conduct and document annual employee training for SSO response procedures.
0
10
20
30
40
50
60
70
80
90
100
2009 2010 2011 2012
% Reached
Surface
Waters
Year
To
S
u
r
f
a
c
e
W
a
t
e
r
s
(
%
)
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 15 EEC
3.7 FOG Control Program
Finding: CMSD is fully conformant to the SSMP in this area .
The SSMP requires seven key elements for the CMSD FOG Control Progra m:
Public education outreach program
FOG disposal plan
Legal authority to prohibit discharges to the system
Grease removal device requirements
Inspection of grease-producing facilities
Cleaning schedule for sewer system sections subject to FOG blockages
Source control measures for enhanced maintenance areas
Based on the historically low number of FOG-related SSOs in the CMSD service area, CMSD ’s FOG
Control Program is effective at preventing FOG accumulation in the sewer system and FOG-related SSOs.
In the past four years, CMSD experienced relatively few FOG-related SSOs compared to the total number
of SSOs; this ratio can be attributed to a successful FOG Control Program (Figure 3-7, FO G-Related
Sanitary Sewer Overflows Compared to Total Public Sanitary Sewer Overflows in CMSD Service Area ).
Figure 3-7 , FOG-Related Sanitary Sewer Overflows Compared to
Total Public Sanitary Sewer Overflows in CMSD Service Area, 2009 –2012
3.7.1 Public Education and Outreach Program
In 2005, CMSD began providing all identified food service establishments (FSEs) in its service area with
educational and outreach materials, including the FOG Program Rules and Regulations, regarding the
proper disposal of FOG generated in their facilities. These materials are still provided to each FSE as
needed during routine FOG inspections . The educational materials are also available on the CMSD ’s
website (http://www.cmsdca.gov/index.php?option=com_content&view=article&id=114&Itemid=409).
0
1
2
3
4
5
6
7
8
2009 2010 2011 2012
Nu
m
b
e
r
o
f
P
u
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i
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S
S
O
s
Year
Total Public SSOs
FOG Related
Public SSOs
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 16 EEC
3.7.2 Inspection of Grease-Producing Facilities
Each FSE within the CMSD service area is supposed to be inspected at least once every two years;
however, higher-risk FSEs, such as those with grease-removal equipment or those associated with
enhanced maintenance locations that are prone to sewer blockages, are inspected more frequent ly .
Seventy-five FSEs were recently identified through annual reviews of Orange County Health Care Agency
lists and ha ve been prioritized accordingly (Table 3-7, Number of Food Service Establishments Inspected per
Frequency in CMSD Service Area ).
Table 3-7 , Number of Food Service Establishments Inspected per Frequency
in CMSD Service Area
Quarterly Semi a nnual Annual Bi e nn i al
Recently Identified
FSEs
46 43 121 194 75
Among the FOG Control Program requirements, CMSD requires FSE owners to train their employees on
kitchen best management practices for FOG. Due to frequent inspection of FSEs, the percentage of FSE s
not complying with employee training requirements has remained low from year to year (Figure 3-8 ,
Percentage of FSE Employees Not Trained in Kitchen Best Management Practices in CMSD Service Area ,
Fiscal Years 2008/200 9 –2011/2012 ). However, high turnover among FSE employees has prevented CMSD
from obtaining 100% compliance from FSEs. In addition, in fiscal year 2010/2011 , CMSD identified a large
number of new facilities from the Orange County Health Care Agency list whose employees required
training on kitchen best management practices.
Figure 3-8 , Percentage of Food Service Establishment Employees Not Trained on
Kitchen Best Management Practices in CMSD Service Area ,
Fiscal Years 2008/2009 –20 11 /2012
0
10
20
30
40
50
60
70
80
90
100
2008/2009 2009/2010 2010/2011 2011/2012
Em
p
l
o
y
e
e
s
(
%
)
% Noncompliant
Employees
Fiscal Year
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 17 EEC
3.7.3 Legal Authority to Prohibit Discharges to the System
Where additional enforcement of the FOG Control Program is required, Sections 6.07.040 and 6.04.060
of the Operations Code provide the CMSD with the legal authority to enforce the FOG Program Rules
and Regulations. In some instances in 2012, CMSD issued enforcement letters to FSEs and required one
FSE to attend a CM SD Board of Directors hearing to discuss compliance issues. CMSD has adopted an
enforcement flow chart to guide FSE enforcement procedures (Appendix E, Enforcement Response Flow
Chart ); however, CMSD does not have written enforcement procedures for responding to FOG
noncompliance.
3.7.4 Grease-Removal Device Requirements
CMSD requires all new FSEs to install a grease interceptor, which must first be approved by CMSD . In
addition, existing FSEs that have been identified to cause or contribute to sewer system blockages are
required to install a grease interceptor. CMSD is receptive to alternative grease-control technologies,
particularly for facilities with physical constraints (i.e., space, slope) that make installation of traditional
interceptors impracticable.
3.7.5 Cleaning Schedule for Sewer System Sections Subject to FOG Blockages and Source-
Control Measures for Enhanced Maintenance Areas
CMSD identifies sewer locations subject to FOG accumulation and designates the sewer in that area as a
hot spot (requires cleaning more than once per year). CMSD staff routinely monitor hot spot locations to
identify and mitigate the cause of FOG accumulation. Where applicable, structural repairs or escalated
source-control measures are implemented to reduce the maintenance frequency for hot spots.
3.7.6 FOG Disposal Plan
Once a grease interceptor is pumped, pumping companies can take grease waste to the Orange County
Sanitation District’s FOG waste receiving facility. In addition, some of the larger pumping companies
have their own treatment facilities on -site that receive FOG waste.
In 2011, CMSD implemented a residential FOG recycling program. Residents can deliver grease waste to
the Orange Coast College Recycling Center, which is open 7 days a week. Over 1,000 gallons of
residential grease have been collected at the recycling center.
3.7.7 Areas of Nonconformance to the Sewer System Management Plan
No noncomformances related to the FOG Control Program were identified.
3.7.7.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 18 EEC
3.8 System Evaluation and Capacity Assurance Plan
Finding: CMSD is fully conformant to the SSMP in this area .
SSMP outlines four key elements of the CMSD ’s System Evaluation and Capacity Assurance Plan:
Evaluation
Design criteria
Capacity enhancement measures
Capital Improvement Program schedule
3.8.1 Evaluation
CMSD’s Sewer Master Plan; last updated in 2005, includes a hydraulic capacity analysis; CMSD has
addressed all deficiencies identified through this analysis. The CMSD plans to update the Sewer Master
Plan upon completion of GIS-based flow modeling development . In addition, CMSD routinely analyzes
pump station data to identify trends in sewer flow changes that have the potential to become hydraulic
capacity issues, including indicators of I/I.
3.8.2 Design Criteria
The CMSD uses industry-standard design criteria that state that sewer lines up to 18 inches in diameter
should not flow more than half full during peak wet weather and lines 21 inches in diameter or larger
should not flow more than three quarters full. CMSD is planning t o use the new GIS-based flow
modeling capabilities to evaluate whether sewer lines are exceeding standard capacities. According to
interviews with the District Engineer, CMSD will conduct this analysis during the next Sewer Master Plan
update scheduled for 2014.
3.8.3 Capacity Enhancement Measures
In 2011, CMSD established a program to plug and seal manholes located in low-lying gutters and alley
areas to minimize storm-water inflow. To date, CMSD has plugged and sealed 1,021 manholes ; 734
manholes remain candidates to be plugged and sealed.
3.8.4 Capital Improvement Plan Schedule
The 2005 Sewer Master Plan identifies CIP projects to be completed over 10 years. As discussed in
Sections 3.4.3.1 and 3.4.3.2, CMSD has completed the majority of identified CIP projects and has
scheduled the remaining projects for the 2013/2014 fiscal year. According to the District Engineer, the
updated Sewer Master Plan may provide a CIP schedule for the next 10 years.
3.8.5 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to system evaluation and capacity assurance were identified .
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 19 EEC
3.8.5.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.9 Monitoring, Measurement, and Program Modifications
Finding: CMSD is fully conformant to the SSMP in this area .
The CMSD established the Sewer System Operations Committee comprising CMSD staff, Board of
Directors members, subcontractors, and consultants who meet monthly to evaluate the operating
effectiveness of the sewer system programs . During the meetings, the committee members discuss
preventive maintenance activities, SSO data, and funding issues. In addition, the committee established
a subcommittee that meets quarterly to review areas that require more frequent preventive
maintenance activities .
CMSD reviews all elements of the SSMP annually and updates the SSMP document as needed. The SSMP
was last updated in 2013 to reflect the current conditions of the CMSD.
3.9.1 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to the program monitoring, measurement, and modifications were
identified .
3.9.1.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.10 SSMP Program Audit
Finding: CMSD is fully conformant to the SSMP in this area .
CMSD has conducted the required SSMP audits. The first audit was conducted in 2011 and covered all
sections of the SSMP. Six minor nonconformances were identified in 2011:
The SSMP did not reflect the current organizational structure of CMSD.
The SSMP did not reflect the current Operations Code section numbers.
The miles of sewer reported in California Integrated Water Quality System did not match the
actual miles of sewer lines for CMSD.
The SSMP did not reflect usage of the GIS or CMMS.
Field staff had not read and signed off on the SSMP and SSO Emergency Response Plan.
The SSO Emergency Response Plan was not present in each CMSD field vehicle.
As of the 2013 audit, CMSD addressed each noncompliance identified in 2011 within the established time
frame. CMSD addressed most of the noncompliances during the SSMP updates in June 201 1 and 2013 .
3.10.1 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to the SSMP program audits were identified .
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 20 EEC
3.10.1.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
3.11 Communications Program
Finding: CMSD is fully conformant to the SSMP in this area .
The CMSD posted the updated SSMP on its website (http://cmsdca.gov) and has certified the SSMP on the
State’s California Integrated Water Quality System website. The SSMP is always available to any interested
party; CMSD will consider any comments or recommendations made by outside organizations.
3.11.1 Areas of Nonconformance to the Sewer System Management Plan
No nonconformances related to the CMSD’s communications program were identified .
3.11.1.1 Recommended Corrective Actions
No corrective actions are recommended at this time.
4.0 SUMMARY
CMSD developed a comprehensive SSMP in compliance with the State WDR . Based on personnel
interviews, documentation review, and consistently low number of SSO events, the CMSD has effectively
implemented the SSMP to reduce and prevent SSOs within CMSD service area. CMSD continually
evaluates the condition of its sewer system assets and conducts routine preventive maintenance to
ensure the system is functioning efficiently.
However, the current audit identified several areas in which the CMSD ’s sewer system management
practices are not consistent with the SSMP (Table 4-1, Summary of Sewer System Management Plan
Audit Results ). N o major nonconformances were identified; however, 4 minor nonconformances, with 4
recommended corrective actions , were identified .
Most of the nonconformances are due to the recent implementation of GIS and CMMS systems, CMSD’s
more proactive approach to sewer cleaning frequencies, and CMSD’s in -depth analysis of potential FSEs
that were not previously inspected. Based on interviews with CMSD staff, EEC anticipat es that CMSD will
be able to address the identified nonconformances within the 2013/2014 fiscal year.
EEC has recommend ed corrective actions to address nonconformance areas and anticipates that CMSD ’s
sewer system management operations will satisfy the SSMP once the recommended corrective actions
are fully implemented (Appendix F, Summary of Findings ).
Waste Discharge Requirements Sewer System Management Plan 2013 Audit June 18, 2013
W2489.01 Costa Mesa Sanitary District 21 EEC
Table 4-1, Summary of Sewer System Management Plan Audit Results
Sewer System Management Plan Section Finding
Section 1 , Goals In Conformance
Section II , Organization In Conformance
Section III , Legal Authority Minor Nonconformance
Section IV , Operations and Maintenance Minor Nonconformance
Section V , Design and Performance Provisions In Conformance
Section VI , Overflow Emergency Response Plan Minor Nonconformance
Section VII , FOG Control Program In Conformance
Section VIII , System Evaluation and Capacity Assurance Plan In Conformance
Section IX , Monitoring, Measurement, and Program Modifications In Conformance
Section X , SSMP Program Audits In Conformance
Section XI , Communications Program In Conformance
APPENDIX A
LIST OF SSMP DOCUMENTS AND DATA REVIEWED
SSMP AUDIT PROGRAM REQUESTED DOCUMENTS
Hard Copy
• Sewer System Management Plan (2013)
• Sewer Master Plan
o 2009 ‐2010
o 2005
• CIPP 2010 ‐ 2014
• Sewer System I/I Evaluations
• SSO Data
o Reporting figures
• SSO Emergency Response Plan
o Sewer Pumping Stations
o Reporting guidelines
o Emergency call list
• Sewer System Committee Meeting Minutes
• Flow Monitoring Data and Capacity Evaluations for Pump Stations
• Certificates
• Updated Hot Spot List
• Plan Review Procedures and Documents
• Operations Code
Digital Copy
• Cleaning History
• FOG Inspection Information
o FOG Control Program Manual (2004)
o Ordinance
o Slides and Healthcare Data
o Inspections Conducted
• Strategic Plan 2010 ‐2015
• Education materials (No More Wipes letters, etc.)
• Updated Hot Spot List
• Plan Review Procedures and Documents
• Operations Code
• Equipment and Spare Parts Inventory
• Annual Report (2012)
• Plans and Specs for Construction/Rehab
• S.L.A.P. Participation Spreadsheet
• Pumping Station Maintenance History
APPENDIX B
EXAMPLE ENFORCEMENT LETTER
APPENDIX C
EXAMPLE STANDARD SEWER PERMIT
SEWER PERMIT
BUILDING ADDRESS: CITY: STATE: CA ZIP:
PARCEL NO:
PROPERTY OWNER NAME: PHONE NO.:
CONTRACTOR NAME: PHONE NO.:
CONTRACTOR ADDRESS: CITY : STATE : CA ZIP:
STATE LICENSE NO.: CITY BUSINESS LICENSE NO.:
WORK TO BE DONE:
I hereby acknowledge that I have read this application and state the above is correct and agree to comply with
State laws, City and County ordinances and Sanitary District ordinances pertaining to sanitary sewers. I certify
I possess the above valid State of California classification or am legal owner of the property described above.
________________________________
Signature of Permittee Date
The Costa Mesa Sanitary District shall maintain and provide the following endorsements on the additional insured
endorsement form used by the contractor’s insurance company while work is being performed under this permit: “The
Costa Mesa Sanitary District and its elected and appointed boards, officers, agents, and employees are additional
insured and its respect to this project and other insurance maintained by the Costa Mesa Sanitary District Shall be
excess and not contributing with the insurance provided by this policy .”
_______________________________________________________________________________
Office Use Only
PERMIT FEE: $ PERMIT NO.:
OTHER FEE: $ PERMIT ISSUED BY:
TOTAL: $ INSPECTED BY: Date
APPROVED: YES____ NO ____
Date
NOTES:
ALL SEWER CONNECTIONS MUST BE INSPECTED – CALL (714 ) 290 -6831
628 W. 19 th Street, Costa Mesa, CA 92627
Costa Mesa Sanitary District
APPENDIX D
EXAMPLE SEWER CLEANING WORK ORDER
Costa Me sa Sanitary District - Work Order November 19, 2012 Work Order #16164
Clean Main Priority 3
Supervisor CANO, STEVE Location
Contractor Address
Comments Map attached, pipes to be cleaned are highlighted vibrant blue. Select CCTV observations also
appear on map, labeled with distance from downstream ma nhole. Legend attached.
Instructions Always clean upstream pipe segments before advancing downstream.
Projected Start Date 7/1/2012 Actual Start Date
Projected Finish Date 6/30/2013 Actual Finish Date
Associated Asset IDs
Facility Condition Assessment Notes (Debris, Grease, Roots : Zero, Light, Moderate, Heavy )
138790
138792
138793
138794
138797
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Work Order Lifecycle
Requested By
Initiate d By GALLEGOS, RAMON On 11/6/2012 5:01:35 PM
Submitted To ORTIZ, JOEL On 11/6/2012 5:01:36 PM
Opened By On
Work Completed By
Closed By On
Costs
Labor 0
Materials 0
Equipment 0
Permits 0
Total 0
Page 1 of 2
Costa Me sa Sanitary District - Work Order November 19, 2012
138799
138801
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Debris: Z L M H Grease: Z L M H Roots: Z L M H
Labor
Estimated
Name Dates Hours / Units
-
Actual
Name Dates Hours / Units
-
Field Crew Comments
Page 2 of 2
APPENDIX E
ENFORCEMENT RESPONSE FLOW CHART
Ro
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-
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Fo
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?
No
Yes
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I
s
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Second Follow-up Inspection Conducted Noncompliance Requiring Follow-up 1 Identified?No Yes
Th
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Noncompliance Requiring Follow-up 1 Identified?Issue Fine or Hearing for Termination of Service
In
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i
o
n
Fr
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q
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i
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d
No Yes
1.
N
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2. Noncompliance Requiring Immediate Elevated Enforcement Include:FOG > 80%Restricted Effluent Evidence of Recent SSO
Ye
s
No
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4/13/2012
APPENDIX F
SUMMARY OF FINDINGS
Summary of Corrective Actions
Costa Mesa Sanitary District Sewer System Management Plan 2013 Audit
Report Section Section Title Waste Discharge Requirement SSMP Section Minor Nonconformane Follow-Up Action
Target Date for
Correction Date Corrected
3.1 Goal Create goals specific to system operations and SSO
reduction.I N/A N/A N/A N/A
3.2 Organization Identify LROs, management personnel, and chain of
communication for reporting SSOs.II N/A N/A N/A N/A
3.3 Legal Authority
Legal Authority to prevent illicit discharges to the sewer
system. Sewer connections are properly designed and
constructed. Ensure access to laterals/mains. Limit the
discharge of FOG. Enforce violations of its sewer
ordinances.
III Standard sewer permits do not mention
pretreatment requiments recognized by OCSD
Update the Standard Sewer Permit to mention
the pretreatment requirements recognized by
OCSD
December 2013
CMSD is not currently on pace to complete
cleaning of all wastewater draining watershed
sections scheduled for fiscal year 2012/2013,
and risks falling short of the target without
immediate adjustment
Reevaluate the whole-system cleaning frequency
to identify the necessary actions to meet the
sewer cleaning commitment.
July 2013
All employee training efforts are not
documented Document and track staff training efforts July 2013
3.5 Design and Performance Provisions
Create standards for installation, rehabilitation and
repair; and for the inspection and testing of new and
rehabilitated facilities.
V N/A N/A N/A N/A
3.6 Overflow Emergency Response
Plan
Provide SSO notification procedures, appropriate
response to all overflows, regulatory notification
procedures, training procedures, emergency response
operations, program to contain and prevent sewage
discharge to surface waters.
VI CMSD does not conduct regular trainign for
staff regarding SSO response procedures
Conduct regular training for SSO response
procedures December 2013
3.8 System Evaluation and Capacity
Assurance Plan
Create a system evaluation and capacity assurance plan
which includes; evaluation, design criteria, capacity
enhancement measures, and CIP schedule
VIII N/A N/A N/A N/A
3.9 Monitoring, Measurement, and
Program Modifications
Maintain relevant information to prioritize SSMP
activities. Monitor the implementation and effectiveness
of the SSMP. Assess the success of the preventative
maintenance program. Update program elements as
necessary. Identify and illustrate SSO trends.
IX N/A N/A N/A N/A
3.10 SSMP Program Audit Conduct periodic audits at a minimum of once every two
years.X N/A N/A N/A N/A
3.11 Communication Program
Enrollees shall communicate with the public on the
development, implementation, and performance of the
SSMP.
XI N/A N/A N/A N/A
VII
Enrollees must implement a FOG source control program
in order to reduce the accumulation of FOG in the sewer
system and FOG related SSOs.
FOG Control Program 3.7
IV
Maintain an up-to-date map, develop a preventative
maintenance plan, develop a rehabilitation and
replacement plan. Provide education and training.
Provide equipment and spare parts inventory.
Operation and Maintenance
Program 3.4
N/A N/A N/A N/A
W2489.01 Costa Mesa Sanitary District Page 1 of 2 EEC