Contract - Environmental Engineering & Contracting - 2022-10-27October 12, 2022
October 12, 2022
Ms. Noelani Middenway
Clerk of the Board
nmiddenway@cmsdca.gov
Costa Mesa Sanitary District
Subject: Proposal to Conduct a Sewer System Management Plan Internal Audit for the Costa
Mesa Sanitary District
Dear Ms. Middenway:
Thank you for the opportunity to submit this proposal to provide professional auditing services to the
Costa Mesa Sanitary District (District). EEC is submitting this proposal in response to the District’s
Request for Proposal for a Sewer System Management Plan (SSMP) Internal Audit, due October 12,
2022. EEC understands that the District is seeking a consultant who is familiar with the agency’s SSMP
needs and is available to begin providing services immediately.
EEC staff has comprehensive experience in conducting a wide range of program audits, including SSMP
audits. This broad experience has provided EEC with a unique insight to both a regulator’s view on
conducting audits and a regulated entity’s view on being audited. EEC has applied this insight in
developing and implementing practical and defensible programs designed to reduce sanitary sewer
overflows (SSOs).
EEC continues to serve local governments in developing, implementing, and monitoring sensible sewer
system management programs tailored to address each agency’s specific local conditions. EEC has
extensive expertise in key SSO mitigation strategies, including fats, oils, and grease control programs,
overflow emergency response plans, and SSMP performance assessment and program audits. EEC
supports cities and independent special districts throughout Southern California to develop, implement,
and/or audit their SSMPs. Having conducted an internal audit of the District’s SSMP in 2011, 2013, 2018
and 2020. EEC is uniquely qualified to cost effectively provide the requested services to the District.
This proposal is valid for a 90-day period and EEC’s project team is prepared and eager to begin work on
this project immediately upon receipt of authorization to proceed. Joseph Jenkins, project manager, will
serve as the primary point of contact for this project. I, John Shaffer am authorized to negotiate a
contract with the District on behalf of the firm. Should there be any questions, please contact Joseph
Jenkins at (714) 667-2300 or jjenkins@eecenvironmental.com.
Sincerely,
EEC Environmental
John Shaffer
CEO/Principal
Proposal to Provide SSMP Internal Audit Services to CMSD i October 12, 2022
Table of Contents
A. Submittal Letter .............................................................................................................................. 1
B. Description of Firm.......................................................................................................................... 1
C. Proposals ......................................................................................................................................... 4
D. Organizational Structure ................................................................................................................. 6
E. References and Description of Experience ..................................................................................... 7
F. Project Overview ........................................................................................................................... 11
G. Detailed Work Plan ....................................................................................................................... 12
H. Distinguishing Characteristics ....................................................................................................... 16
Table
Table 2-1 Summary of SSMP Experience ............................................................................................ 5
Table 3-1 Key Personnel ..................................................................................................................... 6
Table 4-1 EEC Project References ....................................................................................................... 8
Figures
Figure 3-1 Project Team Organization Chart ....................................................................................... 7
Figure 6-1 Proposed Project Schedule ............................................................................................... 15
Appendix
Appendix A Key Personnel Résumés
Proposal to Provide SSMP Internal Audit Services to CMSD 1 October 12, 2022
A. Submittal Letter
See submittal letter on previous page.
B. Description of Firm
Pursuant to your request, EEC Environmental (EEC) has prepared this proposal to provide a sewer system
management plan (SSMP) internal audit for the Costa Mesa Sanitary District (District). In compliance with
the Statewide General Waste Discharge Requirements (WDR) for Sanitary Sewer Systems (State Water
Resources Control Board Order No. 2006-003-DWQ), the District developed and implemented a SSMP
with the primary goal of reducing and preventing sanitary sewer overflows (SSOs). Pursuant to the WDR,
routine audits of the District’s SSMP are conducted on a biennial basis, with the last audit being conducted
in 2020.
EEC’s proven approach to SSMP audits revolves around objective assessment of the performance and
effectiveness of current SSMP programs in light of established District goals and the overarching goals of
the WDR. EEC approaches the internal audit not only as necessary step to fulfilling the WDR, but as an
opportunity to identify alternatives for practical program enhancements that further advance the
performance of the SSMP and/or improve the efficiency of implemented programs.
Based on EEC’s experience with the
development and assessment of SSMPs, our
involvement with previous internal SSMP audits
for the District, and the variety of SSMP audits
EEC has conducted for other California
agencies, EEC is uniquely qualified to provide
the services required to assist the District with
continued compliance with the WDR.
Company Details
Number of Employees: 45
Years in Business: 27
Corporate headquarters: One City Boulevard West, Suite 1800
Orange, California 92868
Firm Structure: Corporation
Website: www.eecenvironmental.com
Phone Number: (714) 667-2300
Fax Number: (714) 667-2310
Certifications/Licenses: Class A General Engineering Contractor License
Hazardous Substances Removal Certification
Small Business Enterprise (California Department of General Services)
Small Business as prescribed by the Federal Acquisition Regulations
Tax Identification Number: 33-0665828
Primary Project Contact:
Mr. Joseph Jenkins
Project Manager
Phone: (714) 667-2300
Fax: (714) 667-2310
E-Mail: jjenkins@eecenvironmental.com
Secondary Project Contact:
Mr. Jim Kolk
Principal Engineer
Phone: (714) 667-2300
Fax: (714) 667-2310
E-Mail: jkolk@eecenvironmental.com
Proposal to Provide SSMP Internal Audit Services to CMSD 2 October 12, 2022
Background
EEC is a national environmental consulting firm that specializes in wastewater, storm water, regulatory
compliance, and assessment and remediation of soil and groundwater. EEC is a privately held corporation
and was founded in 1995 to fulfill a need for technical excellence and professional service in
environmental consulting. EEC comprises a team of experts in engineering, environmental compliance,
environmental science technology and data management systems, chemistry, toxicology, hydrogeology,
geology, and industrial hygiene.
EEC comprises four main divisions: engineering,
environmental, construction, and technology. The
engineering division provides FOG control
services; SSMP development and internal audits,
wastewater treatment and reuse design; National
Pollutant Discharge Elimination System (NPDES) /
storm water management; soil and groundwater
remediation design; chemical delivery system
design; and operation and maintenance of
wastewater treatment systems. The division also
designs and implements plans for remediation of
soil and groundwater, mitigation of lead and
asbestos, treatment and reuse of wastewater, and
management of storm water.
The environmental division routinely performs
Phase I/II Environmental Site Assessments (ESAs),
soil and groundwater investigations, air
monitoring, and asbestos and lead testing. The
division also prepares and implements site
assessment work plans, preliminary endangerment
assessments, remedial action plans, and closure
reports for regulatory acceptance and approval.
Finally, the division undertakes coordination and
negotiation with regulatory agencies on behalf of
clients throughout a project’s duration.
The construction division supports projects
originating from the engineering and
environmental departments, but also undertakes
projects independently. This division removes
underground and aboveground storage tanks;
installs, operates, and maintains remediation
systems; designs and builds electrical
panels/control systems, and performs general
construction services, including operation of
heavy equipment.
KEY SERVICES
Engineering
✓FOG Program Management
✓FOG Program Inspections
✓NPDES Program Management
✓NPDES Program Inspections
✓SSMP Audits and Support Services
✓CIP Support
✓Wastewater Treatment & Water Reuse Design
✓Soil & Groundwater Remediation Design
✓Pumping System, Water/Wastewater Pipeline, Storage, and
Treatment Facility Design
✓Computer-Aided Drafting and Design
✓Sewer System Elevated Maintenance Location
Investigations
✓SSO Response and Fog Inspection Training
✓Odor Investigations
Construction
✓Soil & Groundwater Remediation Systems
✓Wastewater / Stormwater Treatment Systems
✓Removal/Installation of Aboveground/Underground
Storage Tanks
✓General Construction
✓Mechanical/Electrical Installation
Technology Services
✓Database Management
✓Geographic Information Systems
✓Computerized Maintenance Management Systems
✓Modeling
✓Asset Management
✓Cloud Services and Support
Environmental
✓Phase I & II ESAs
✓Brownfield Assessments
✓Groundwater Monitoring Well Installations
✓Groundwater Monitoring and Sampling
✓Vapor Intrusion Investigations
✓Indoor Air Sampling
✓Lead/Asbestos/Formaldehyde Assessment and Abatement
✓Waste Management
✓Preliminary Endangerment Assessments
✓Removal Action Work Plans
✓Regulatory Compliance
✓Remediation Design and Construction
✓Remediation System Operation and Maintenance
Proposal to Provide SSMP Internal Audit Services to CMSD 3 October 12, 2022
EEC’s technology services division offers services for efficient collection, storage, QA/QC, graphical
display, and analysis of large data inventories. This department uses computer-aided drafting and design
(AutoCAD), geographic information systems (GIS), and database technologies to support and manage
projects across the firm’s divisions.
Finally, the administrative team supports the entire firm with project-related activities, such as accounting
and invoicing.
“EEC’s expertise and responsiveness was instrumental in helping our city meet
new stringent sewer regulations.”
Ray Burk, Former Principal Civil Engineer
City of Santa Ana
Proposal to Provide SSMP Internal Audit Services to CMSD 4 October 12, 2022
C. Proposals
EEC staff has comprehensive experience in
conducting a wide range of program audits, including
SSMP audits. In addition to the overall team
expertise, key individuals have unique SSMP and
auditing expertise. This broad experience has
provided EEC with a unique insight to both a
regulator’s view on conducting audits and a
regulated entity’s view on being audited. Since the
issuance of Order No. R8-2002-0014 by the California
Regional Water Quality Control Board in 2002, and
subsequent issuance of the current Statewide
General Waste Discharge Requirements for Sanitary Sewer Systems (Order No. 2006-0003-DWQ) in 2006
and the established Monitoring and Reporting requirements (WQ 2013-0058-Exec), EEC has applied this
insight in developing and implementing practical and defensible programs designed to reduce sanitary
sewer overflows (SSOs).
EEC is a local firm with a demonstrated understanding of the SSO WDR, from its inception in 2002 to its
current form. Since 2003 EEC has provided services, including internal SSMP audits, to local agencies such
as the Costa Mesa Sanitary District, Orange County Sanitation District, City of Santa Ana, City of Buena
Park, City of La Habra, Moulton Niguel Water District, the City of Stanton, and the City of El Segundo.
Additionally, EEC has completed audits of OCSD’s member agencies discharging to the SARI (Santa Ana
Regional Interceptor) line; this project provided suitable recommendation for current and future
discharges to maintain permit requirements. EEC’s unique combination of experience and knowledge will
ensure the most efficient utilization of the District’s technological and human resources in the audit
process. EEC’s existing relationships with key District staff will also contribute to efficient exchange of
information and result in more candid program discussions and comments. A summary of EEC’s SSMP
related projects is provided in Table 2-1, Summary of SSMP Experience.
A District Sewer Vactor Truck
“EEC has played a significant role in helping our
City protect the environment and our citizens.”
Jake Wager, Former City Manager
City of Stanton
Proposal to Provide SSMP Internal Audit Services to CMSD 5 October 12, 2022
Table 2-1, Summary of SSMP Experience
Client Project Type Contact Info Year Completed
Costa Mesa
Sanitary District
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
• Corrective Actions Identification
Board Approval
Mr. Scott Carroll
General Manager
scarroll@cmsdca.gov
(949) 645-8400
2011/2013/2018/2020
Orange County
Sanitation District
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
Corrective Actions Identification
Mr. Dindo Carrillo
Regulatory Specialist
dcarrillo@ocsan.com
(714) 593-7476
2021
City of Santa Ana
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
• Corrective Actions Identification
Mr. Rodolfo Rosas
Senior Civil Engineer
rrosas@santa-ana.org
(714) 647-3387
2013/2015/
2017/2019/2021
City of La Habra
SSMP/WDR Audit
• Documentation Review
• Staff Interviews
• Final Report
• Corrective Actions Identification
Mr. Brian Jones
Water and Sewer Manager
brianj@lahabracity.com
(562) 905-9792
2011/2015/
2017/2019/2022
City of Buena Park
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
• Corrective Actions Identification
Mr. Doug Brodowski
Senior Management Analyst
dbrodowski@buenapark.com
(714) 562-3652
2011/2013/
2015/2017/2019/
2021
County of Ventura
Water &
Sanitation District
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
Corrective Actions Identification
Mr. Shane Dass
Water Services Supervisor
shane.dass@ventura.org
(805) 378-3015
2018
City of Anaheim
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
• Corrective Actions Identification
Mr. Johnathan Heffernan
Operations Supervisor
jheffernan@anaheim.net
(714) 765-6903
2013/2015/
2017/2019
City of El Segundo
SSMP/WDR Audit
• Staff Interviews
• Documentation Review
• Final Report
• Corrective Actions Identification
Mr. Lifan Xu
Senior Civil Engineer
lxu@elsegundo.org
(310) 524-2368
2014
Proposal to Provide SSMP Internal Audit Services to CMSD 6 October 12, 2022
D. Organizational Structure
EEC has assembled a team of highly qualified and experienced key personnel to complete the scope of
work for the requested SSMP internal audit. All key personnel have the necessary credentials, licenses,
and relevant experience required to successfully complete the proposed scope of work on schedule and
within budget in accordance with the requirements of the Costa Mesa Sanitary District. EEC key personnel
along with their regulatory experience, registrations, and credentials are summarized in Table 3-1, Key
Personnel, and the project team organization is presented in Figure 3-1, Project Team Organization Chart.
Résumés of the key personnel are provided in Appendix A, Key Personnel Résumés.
Table 3-1, Key Personnel
Key Personnel/ Role Years’
Exp. Registrations/Licenses/ Credentials Project
Commitment
Joseph Jenkins
Project Manager /
SSMP Auditor
15
B.A. Business Administration
Environmental Management Certification, University of California
Irvine Extension
OSHA 40-Hour HAZPWOPER Certification
Pipeline Assessment And Certification Program
CWEA Environmental Compliance Inspector Grade I
SSMP Development, SSMP Internal Audits, SSMP Updates, SSMP
Program Elements Development (SSOERP, FOG Control Programs,
Sewer System O&M), SSOERP Training
75%-100%
(as needed)
Jim Kolk
Technical Support 27
B.S. Industrial Engineering
PACP/NASCCO Certification, CWEA SSO Reporting Certified, Co-
Author and Researcher for the Orange County FOG Control Study –
Phase II, Managed Over 10 SSMP Related Projects
15%-20%
(as needed)
John Shaffer
Principal-in-Charge 32
General Engineering Contractor
Co-Author and lead researcher for the Orange County FOG Control
Study – Phase I and Phase II, WEF/EPA FOG Control Workshop
contributor & speaker, IAPMO FOG Task Group member
5%-10%
(as needed)
Proposal to Provide SSMP Internal Audit Services to CMSD 7 October 12, 2022
Figure 3-1, Project Team Organization Chart
E. References and Description of Experience
Based on a proven approach to objective and practical program development and assessment, EEC has
established a reputation as an expert in auditing complex programs, including SSMPs. This experience and
reputation continues to prompt clients to select EEC for critical auditing projects. Most recently, EEC
completed an SSMP audit for the City of La Habra and the City of Santa Ana. Tasks for the City of Santa
Ana included an update to the City’s SSO Emergency Response Plan to address SSO response measures as
well as to comply with the established Monitoring and Reporting requirements (WQ 2013-0058-Exec). In
addition, EEC completed a comprehensive audit for the Orange County Sanitation District that included
detailed assessment of several complex industrial pretreatment programs.
As with any program audit, the SSMP audit must be conducted objectively to assess how effectively
current SSMP programs are performing in light of established agency goals and the overarching goals of
the WDR. EEC approaches the internal audit not only as necessary step to fulfilling the WDR, but as an
opportunity to identify alternatives for pragmatic program enhancements that further advance the
performance of the SSMP and/or improve the efficiency of the implementation of these programs.
References
It is through this approach that EEC’s SSMP audits have consistently provided the firm’s clients with
pragmatic recommendations that enable development of clear and attainable plans for ongoing sewer
system management, operation, and maintenance. In addition to prior audits performed for the District,
EEC has conducted comprehensive SSMP audits for the following sewer system agencies (Table 4-1, EEC
Project References):
Costa Mesa Sanitary District
SSMP Program Management
Project Manager/Auditor
Joseph Jenkins
Principal-in-Charge
John Shaffer
Technical Support
Jim Kolk
Proposal to Provide SSMP Internal Audit Services to CMSD 8 October 12, 2022
Table 4-1, EEC Project References
Agency Contact Details Collection System Size
City of Anaheim
Mr. Johnathan Heffernan
Operations Manager
jheffernan@anaheim.net
(714) 765-4044
568 Miles
City of Buena Park
Mr. Doug Brodowski
Senior Management Analyst
dbrodowski@buenapark.com
(714) 562-3652
168 Miles
City of La Habra
Mr. Brian Jones
Water and Sewer Manager
brianj@lahabra.com
(562) 905-9792
125 Miles
City of Santa Ana
Mr. Rodolfo Rosas
Senior Civil Engineer
rrosas@santa-ana.org
(714) 647-3387
390 Miles
City of El Segundo
Mr. Lifan Xu
Principal Civil Engineer
lxu@elsegundo.org
(310) 524-2368
56 Miles
Experience
The cornerstones of EEC’s expertise in SSMP program audits are an extensive knowledge of key SSMP
program elements in line with regulatory requirements and a breadth of experience that informs a
complete, candid assessment of an agency’s level of conformance or deficiency. Pursuant to the WDR
requirements for SSMPs, EEC’s experience focuses on evaluating the following key elements of the SSMP:
• Legal authority
• Operation and maintenance program
• Design and performance provisions
• Overflow emergency response plan
• FOG control program
• System evaluation and capacity assurance plan
• Monitoring, measurement, and program modifications
Proposal to Provide SSMP Internal Audit Services to CMSD 9 October 12, 2022
Legal Authority
For more than 20 local, regional, and national sewer system agencies, EEC has evaluated whether these
agencies have been afforded the sufficient legal authority to effectively operate a sewer system pursuant
to the WDR requirements. Currently, EEC is assisting the City of El Segundo to identify options for legal
authority that will enable the City to implement a FOG program that will more effectively protect their
sewer system assets.
EEC has recommended language for existing legal authority documents that may enable agencies to
establish and enforce corrective actions, fines, and such for illegal dischargers, while still maintaining a
business friendly approach.
Operation and Maintenance Program
EEC has been instrumental in the development and implementation of modern operations and
maintenance programs for clients including the District. Few will argue that an accurate mapping system
is essential to an efficient operation and maintenance program. EEC is proud to have contributed to the
District’s implementation of a fully functional geographic information system (GIS) and computerized
maintenance management system (CMMS), which is currently providing the District with key sewer
system management and monitoring capabilities. The District’s data management capabilities are also
enabling accurate tracking of sewer system maintenance requirements and activities, as well as
supporting staff responses to SSO events. Through the SSMP audit process, EEC will continue to identify
opportunities to expand the District’s utilization of GIS tools to further enhance the planning,
management, and monitoring of these vital sewer system assets.
Design and Performance Provisions
EEC is experienced in sewer pipeline design projects that include new construction, replacement,
rehabilitation, and sewer capacity evaluation. This experience informs development of future
performance provisions and construction standards for the firm’s clients to ensure the long-term
utilization of the critical sewer system assets. This experience can assist the District in further developing
sewer system design standards, including emerging techniques and design considerations, as well as
future expansion requirements.
Overflow Emergency Response Plan
Responding to and reporting any sewer overflows is an essential element of an effective SSMP. EEC has
reviewed and developed overflow emergency response plans and recommended standard procedures for
chain of communication, SSO volume estimation, data recording for future reference, investigation of the
cause of the event, and final inspection. For many of the firm’s SSMP clients, EEC has developed mitigation
plans to prevent the reoccurrence of SSOs.
EEC also has experience with identifying areas of the sewer system that present difficult situations for
proper SSO response, including limited access, proximity to the storm drain inlets, and lift station issues.
EEC will utilize this unique expertise to evaluate the Districts SSO Emergency Response Plan to determine
if such areas of exposure exist and provide recommended updates to address those situations.
Proposal to Provide SSMP Internal Audit Services to CMSD 10 October 12, 2022
FOG Control Program
EEC is recognized nationally as a leading FOG control expert and has developed, implemented, and
assessed more than 25 FOG control programs. EEC completed FOG characterization studies for 15 cities
and wastewater districts and conducted the largest FOG control study in the country on behalf of Orange
County Sanitation District and its 26 member agencies in Orange County. EEC has been involved with every
facet of a FOG control program, including, plan review, facility inspection, enforcement, permitting,
standard forms, and outreach/education.
EEC was instrumental in changes to the Uniform Plumbing Code grease interceptor sizing criteria to
address concerns associated with incomplete cleaning, corrosive conditions, hydrogen sulfide generation,
and odors. Based on EEC’s unique FOG control expertise, five cities and districts, including the Costa Mesa
Sanitary District, have turned to EEC to help manage their FOG control programs.
System Evaluation and Capacity Assurance Plan
EEC has in-house expertise evaluating condition assessment and capacity analysis for sewer system
pipelines. EEC staff have analyzed countless hours of closed-circuit television inspection and condition
assessment data and used this data as a driver for capital improvement and sewer master plan
development. This experience and expertise is drawn upon in the SSMP audit process to ensure the
District’s planning and funding is aligned with current asset condition evaluation data.
Monitoring, Measurement, and Program Modifications
Clear program goals, together with appropriate data collection and management, are the keys to effective
monitoring and measurement of SSMP program performance. EEC understands the importance of
developing measurable goals and has employed this knowledge throughout the SSO reduction programs
it has developed. EEC has also implemented data management systems, such as GIS and CMMS, that
provide the mechanism to collect, maintain and report the critical data in an ongoing manner rather than
only during the audit process. This expertise is crucial in developing recommendations for ongoing
monitoring and measurement and driving program modification.
“EEC brings unique technical expertise to our projects and provides practical solution
for our agency, our satellite agencies, and our industries.”
Mahin Talebi, Former Source Control Manager
Orange County Sanitation District
Proposal to Provide SSMP Internal Audit Services to CMSD 11 October 12, 2022
F. Project Overview
Often, the SSMP internal audit is conducted merely as a formality to satisfy the minimum requirements
of the WDR. Based on our experience with a wide variety of program audits, EEC takes a somewhat
different approach and views the audit from the perspective of a regulator. A regulator is looking for an
honest assessment and program modification that brings about true improvements in program
performance (where needed). Therefore, the key objective of our SSMP audit is to candidly evaluate how
implemented programs are impacting the reduction of SSOs and the proper ongoing management,
operation, and maintenance of the District’s sewer system assets.
EEC’s general approach to SSMP internal audits is threefold:
1. Evaluate the level of conformance of the District’s SSMP to the WDR. This is accomplished
primarily through a desktop review of the SSMP and supporting documentation. EEC is intimately
familiar with the Monitoring and Reporting element of the WDR and will utilize this understanding
to ensure the District’s SSMP appropriately
addresses these changes.
2. Assess the level of conformance of the District’s
practices with the policies and procedures
identified in the SSMP. This effort includes detailed
review of program-related documents (e.g., work
orders, standard procedures, etc.) and data (e.g.,
line cleaning history, staff training records, etc.), as
well as comprehensive interviews with District
staff and field observation of key staff activities.
EEC understands how valuable District staff’s time
is and how busy their daily schedules can be. Since EEC is located close to the District, EEC will be
able to work around the District staff’s busy schedules to ensure the audit process is non-intrusive
but also thorough enough to comply with the requirements of the WDR and improve the District’s
SSMP related programs.
3. Utilize the audit findings to develop practical and defensible recommendations for program
improvement. A report will be prepared summarizing the assessment findings, including
classification of identified nonconformance (e.g., major or minor nonconformance). The report
will also provide recommendations for program improvements based on EEC’s experience with
successful aspects of similar programs and input received during the staff interview process.
Analyzing the SSMP and identifying deficiencies in this manner will allow the District to maintain control
of the definition and implementation of its programs rather than putting that control in the hands of a
regulator. For example, in evaluating the District’s SSO emergency response plan, EEC will not only confirm
that current practices are in place and followed, but will also assess the defensibility of key response
procedures, such as SSO volume estimating techniques. This approach is parallel to the approach a
regulator would take, and allows the District to stay ahead in the process.
SSMP Audit Staff Interview
Proposal to Provide SSMP Internal Audit Services to CMSD 12 October 12, 2022
G. Detailed Work Plan
The following work plan details each task required to complete the proposed SSMP internal audit,
including significant deliverables. An estimated project schedule is also provided in Figure 6-1, Proposed
Project Schedule; however, dates are subject change based on the notice to proceed date and any other
potential scheduling considerations.
1. Preparation for Internal Audit and Kick-off Meeting
EEC will coordinate and facilitate a project kick-off meeting with District management and relevant staff
to discuss the purpose and intent of the audit. At the kick-off meeting, EEC will explain the audit process
and allow District staff to ask questions. EEC will identify the documents and data necessary for the audit,
and the group will identify the staff responsible for providing the documents/data. It is anticipated that a
single one-hour kick-off meeting will be required.
Deliverables
• Audit kick-off meeting and meeting materials
• Request for initial documentation and data
2. SSMP and WDR Assessment
Based on the previous internal SSMP audits EEC has conducted for the District, EEC is intimately familiar
with the District’s SSMP and whether or not it complies with the requirements of the WDR. For this audit,
EEC will review the District’s SSMP and supporting program documents to compare with the requirements
of the WDR and the overall District practices.
3. Documentation/Data Gathering and Review
EEC will review all provided documentation and data, including the following:
• Historical SSO data
• Budget
• SSO Emergency Response Plan
• Sewer maintenance data (line cleaning, inspections, repair, etc.)
• SSMP
• Municipal code
• Master plans
• Training program
• Other relevant documents (design standards, procedures, organization charts etc.)
The final list of documents reviewed will be provided as an attachment to the final audit report. The
desktop review is intended to provide the audit team with an overview of the District’s SSMP program.
EEC will identify areas that appear to be in compliance with the WDR and any areas that may be deficient.
This review will serve as the basis for developing the needs and questionnaires for staff interviews.
Proposal to Provide SSMP Internal Audit Services to CMSD 13 October 12, 2022
Deliverables
• Staff interview questionnaires
4. Staff Interviews and Review of Operations/Work Practices
EEC will work with District staff to schedule interviews with the staff responsible for the implementation
and management of the SSMP elements. Interviews will be scheduled with the following District staff at
a minimum:
• General Manager
• District Engineer
• Finance Manager
• Wastewater Superintendent
• SCADA Technician
• Wastewater Maintenance Worker III
• Wastewater Maintenance Worker II
• Wastewater Maintenance Worker I
Staff interviews will focus on the procedures, documents, and records, as well as the work practices and
operations, related to the SSMP program. It is anticipated that 6 to 8 interview sessions will be needed,
with each session lasting 1 to 2 hours. 1 to 2 additional interview sessions will be conducted with field
staff to observe field activities and procedures. These sessions are anticipated to last between 1 and 2
hours. During interviews EEC will ask District staff for their opinions on the performance of the District’s
programs as well as for any recommendations for program improvements.
Deliverables
• Interview Schedule
• Conduct 6–8 Interview Sessions
• Conduct 1–2 Field Interview Sessions
5. Final Report
EEC will compile the notes, observations, and findings gathered through the audit process into a draft
Sewer System Management Plan Audit Report and will submit the draft report to the District for review
and comment. In addition to identifying the strengths and compliance areas of the program, the report
will identify any areas where the District is out of compliance with the SSMP and/or WDR. Based on the
findings, EEC will provide recommendations for corrective actions in a format suitable for ongoing tracking
of corrective actions by the District. Where applicable, the draft report will also include identified non-
regulatory, that is, discretionary, recommendations for improvements that could further enhance the
efficiency or effectiveness of the program. EEC will meet with District staff to review the report and
findings prior to completing the final report.
EEC will incorporate the District’s comments into the final SSMP Audit Report. All findings and
recommendations will be organized into one of the following:
Proposal to Provide SSMP Internal Audit Services to CMSD 14 October 12, 2022
• Major Non-Conformance
• Minor Non-Conformance
• Recommended Corrective Action
• Recommended Enhancement and Best Practice
Deliverables
• Draft SSMP internal audit report
• Meeting to provide preliminary findings
• Final SSMP internal audit report
• Corrective action tracking spreadsheet
6. Present Findings to the Board of Directors
EEC will prepare a presentation of the final report for the Costa Mesa Sanitary District Board of Directors
and a Study Session. Having conducted the internal SSMP audit for the District in 2011, 2013, 2018, and
in 2020 EEC is familiar with the process of the District’s Board of Directors, and is comfortable with
presenting the audit findings to the Board and Citizens Advisory Committee in a clear, concise, and easy
to understand manner.
Deliverables
• Presentation of final report to Costa Mesa Sanitary District Board of Directors and Study
Session.
7. Training
EEC has provided SSMP and WDR related training to multiple clients since the implementation of the initial
WDR. EEC has established training curriculum and useful information that EEC staff can share with District
staff to ensure District staff are familiar with all aspects of the WDR and SSMP elements. EEC is also closely
tracking the upcoming revisions to the WDR, and can include these updates in training activities especially
if the updated WDR is adopted during the time of the audit. EEC anticipates there will be 1-2 training
events that will last 1-2 hours each. At a minimum training will include the following topics:
• Audit results and rational for audit suggestions
• District SSMP contents, purpose, and rationale
• State of California WDR requirements
8. Meeting(s)
EEC will attend at a minimum the following meetings:
• Kick-off meeting
• Up to eight interview sessions
• Meeting to provide preliminary findings
• Presentation of final report findings (District Headquarters)
• Board Study Session
Proposal to Provide SSMP Internal Audit Services to CMSD 15 October 12, 2022
In addition to the meeting listed above, EEC may request additional meetings throughout the project.
Additional meetings may be required to receive additional explanation for materials, or for a general
project status update.
Project Schedule
Following is a general schedule of tasks and milestones based on the scope of work. During the project
kick-off meeting, the schedule will be reviewed with the District’s staff and revised as necessary.
Additionally, the schedule will be routinely updated as needed as tasks are completed and milestones are
reached.
Figure 6-1, Proposed Project Schedule
Proposal to Provide SSMP Internal Audit Services to CMSD 16 October 12, 2022
H. Distinguishing Characteristics
Audit Expertise
EEC’s proven experience in conducting program audits for public agencies and private entities, including
SSMP audits, industrial pretreatment program audits, health and safety audits, and environmental
compliance audits, equips the firm with an expert bilateral perspective that will benefit the District. This
perspective will ensure that program deficiencies are identified from a regulator’s point of view, while
providing sensible recommendations that don’t unnecessarily burden the technological and human
resources of the District.
History with the Costa Mesa Sanitary District and the Orange County Region
EEC is a local firm with a demonstrated understanding of the SSO WDR, from its inception in 2002 to its
current form in 2022. EEC has worked with the District since 2003 and conducted the agency’s internal
SSMP audit in 2011, 2013, 2018 and in 2020; as a result, EEC has in-depth knowledge of the District’s SSMP
and associated programs and development history. This unique combination of experience and local
knowledge will ensure the most efficient utilization of District technological and human resources in the
audit process. EEC’s existing relationships with key District staff will also contribute to efficient exchange
of information and result in more candid program discussions and comments.
National Perspective
The District will benefit from EEC’s national experience with development and implementation of critical
SSO reduction programs drawing upon the best practices and concepts employed by programs outside of
Orange County.
APPENDIX A
KEY PERSONNEL RÉSUMÉS
Assessment/Remediation
Wastewater/Stormwater
Litigation Support
Regulatory Compliance
Technology/GIS
Corporate Office – Tel: (714) 667-2300 | Fax: (714) 667-2310 | One City Boulevard West | Suite 1800 | Orange, CA 92868
Mid-Atlantic Office – Tel: (410) 263-2234 | Fax: (410) 266-8660 | 200 Harry S Truman Parkway | Suite 330 | Annapolis, MD 21401
eecenvironmental.com
JOSEPH JENKINS
Project Regulatory Specialist
Joseph is EEC’s lead auditor for sewer system management plan (SSMP) audits. To date,
Joseph has conducted internal SSMP audits for the Costa Mesa Sanitary District, Orange
County Sanitation District, City of La Habra, City of Buena Park, City of Santa Ana, and City
of Anaheim. Joseph manages and schedules EEC’s FSE inspection programs and provides
training and quality control / quality assurance of EEC’s FOG inspectors. Joseph has
assisted in the development of multiple stormwater programs for both industrial and
municipal clients.
Joseph has also performed more than 4,000 inspections of food service establishments (FSEs) for compliance with fats,
oils, and grease (FOG) control programs, including those of the Costa Mesa Sanitary District, City of Santa Ana, City of
La Habra, City of Anaheim, and Irvine Ranch Water District. Joseph has also conducted thousands of industrial
pretreatment and stormwater inspections of industrial and commercial facilities.
Joseph holds a Bachelor of Science in Business Administration from York College in Nebraska; a certificate in
Environmental Management from the University of California, Irvine, Extension; a certificate as a Grade I
Environmental Compliance Inspector through the California Water Environment Association; and a certificate as a QISP.
Joseph also maintains certification in OSHA 40-hour HAZWOPER training and in the Pipeline Assessment and
Certification Program.
EXPERIENCE
Lead Auditor, SSMP Internal Audits for Various Municipalities | Statewide, CA
• Assists EEC’s project managers to provide support for conducting internal audits of SSMPs.
• Reviews SSMP-related documentation and conducts interviews of municipality staff members.
• Completes technical report documents specifying important findings and recommendations.
Lead Trainer, SSO Prevention and Response Program, City of San Gabriel | San Gabriel, CA
• Trained City of San Gabriel staff on prevention of and response to SSO.
• Training consisted of a classroom instruction session that reviewed State and City monitoring and reporting requirements,
proper response procedures, and proper volume calculation methods. Training also entailed field training sessions during
which varying volumes of water were spilled and trainees practices containing the spills, estimating the volume of spilled
water, and completing reporting forms.
Project Manager/Lead Inspector, Industrial Pretreatment Program, City of El Segundo | El Segundo, CA
• Developed and implemented industrial pretreatment program for the City
• Permitted categorical industrial users
• Performed Industrial Waste Surveys
• Conducted inspections for industrial users
• Conducted and managed enforcement actions
• Completed Annual Pretreatment Program Reports for submittal to local Regional Water Quality Control Board
FOG Inspector, FOG Inspection Programs for Multiple Cities and Sewer Agencies | Statewide, CA
• Serves as the lead FOG inspector in support of FOG multiple cities and sewer districts including IRWD.
• Completed thousands of FSE inspections in support of agencies’ FOG control programs and has achieved a high rate of
compliance for those FSEs.
JOSEPH JENKINS
2
E N V I R O N M E N T A L
ASSESSMENT/REMEDIATION | WASTEWATER/STORMWATER | LITIGATION SUPPORT
REGULATORY COMPLIANCE | TECHNOLOGY/GIS
EXPERIENCE (CON.)
Senior Staff, FOG Control Consulting for Various Municipalities | Nationwide
• Assists EEC’s project managers to provide support for FOG control consulting services ranging from ordinance and permit
development, grease interceptor sizing and installation requirements, sewer line characterization, inspection and
enforcement procedures, sanitary sewer overflow response procedures, and database and GIS management.
Senior Staff, FOG Control Program Manual Development, Baltimore County | Baltimore, MD
• Developed the FOG Control Program Manual for the Baltimore County FOG Control Program.
• Manual included procedures for inspecting FSEs, requirements for installation of grease control devices, and FSE
educational materials that were created by EEC, including best management practices.
Compliance Inspector, NPDES Inspections and Program Management, Cities of Santa Ana and Anaheim | Orange
County, CA
• Performed hundreds of NPDES inspections for the City of Anaheim and the City of Santa Ana.
• Currently manages the monthly NPDES inspection program and trains inspectors on the proper inspection procedures.
Compliance Inspector, NPDES Inspections and MS4 Program Management, Various California Cities, Southern
California
• Performed hundreds of NPDES inspections for the City of Anaheim, City of Santa Ana, City of El Segundo, and City of
Huntington Beach.
• Currently manages the monthly NPDES inspection program and trains inspectors on the proper inspection procedures.
Stormwater Program Development, SWPPP Updates and Monitoring Plan Implementation, Hehr International | Los
Angeles, CA.
• Performed updates for the facility’s SWPPP
• Developed Stormwater Monitoring Plan
• Conducted training for stormwater sampling and BMP implementation
ENVIRONMENTAL
Corporate O ffi ce — Tel: (714) 667-2300 | Fax: (714) 667-2310 | One City Boulevard West | Suite 1800 | Orange, CA
92868 Regional O ffi ce: Annapolis, MD
eecenvironmental.com
Assessment/Remediation
Wastewater/Stormwater
Litigation Support
Regulatory Compliance
Technology/GIS
JIM KOLK
Principal Engineer
Jim is an industrial engineer with 20 years of project management experience. He has exten-
sive expertise in wastewater/sewer system program support, including fats, oils, and grease
(FOG) program development, industrial wastewater pretreatment program development,
sanitary sewer overfl ow (SSO) response and data management, stormwater compliance,
collection system characterization, and geographic information system (GIS) / database in-
tegration. Jim routinely manages projects with complex regulatory compliance issues related
to state enforcement, consent decrees, and compliance audits. He has managed multiple
projects involving development and management of hundreds of permits, including thousands
of facility inspections and enforcement actions. Jim hold a Bachelor of Science in Industrial
Engineering from San Jose State University. He maintains professional certifi cation in Sanitary Sewer Overfl ow Reporting
from the California Water Environment Association and in Pipeline Assessment and Certifi cation from the National Associa-
tion of Sewer Service Companies.
EXPERIENCE
Project Manager, Pretreatment Program Development and Implementation for Various Municipalities | Nation-
wide
• Manage pretreatment program assessment, development, and implementation of key program elements, including legal
authority review/development, industrial waste survey screening and local limits development/implementation.
• Prepare program manuals and procedures/guidelines for industrial user inspection, sampling, and enforcement activities.
Technical Lead, Industrial Wastewater Pretreatment Audits, Multiple Clients | Nationwide
• Conducted multiple industrial wastewater pretreatment audits for industries involving categorical industrial user permit
compliance, slug discharge control plans, discharge monitoring, enforcement response, and program reporting.
Project Manager Various Commercial and Industrial Wastewater Treatment Projects | Statewide, CA
• Routinely hired by commercial and industrial clients to assess, design, and develop eff ective, economical solutions for
wastewater treatment systems.
• Projects include enhancements to aeration system to increase effi ciency, digester systems to reduce sludge disposal
costs, and lift stations and interceptors to address odors.
Project Manager, Stormwater Management Services, Airgas Products | El Segundo, CA
• Managed the development and implementation of a stormwater pollution prevention plan and monitoring and reporting
program for the Airgas facility in Torrance, California.
• Managed the National Pollutant Discharge Elimination System compliance and training services provided by EEC.
Project Manager, Water Supply Assessment, Development, and Implementation, Confi dential Client | CA
• Served as project manager for a water supply feasibility study for a community that was not currently served by a mu-
nicipal supply.
• The project resulted in development and implementation of a viable solution to serve the short-term water supply needs
of the rural community.
ENVIRONMENTAL
ASSESSMENT/REMEDIATION | WASTEWATER/STORMWATER | LITIGATION SUPPORT
REGULATORY COMPLIANCE | TECHNOLOGY/GIS
EXPERIENCE (CON.)
Project Manager, Food Service Establishment Inspection Management Services, Various Municipal Clients |
Southern CA
• Manages FOG control food service establishment inspection programs for fi ve cities and sewer districts.
• Under his direction, 16,000+ inspections have been performed to date and 5,000+ notices of noncompliance or notices
of violation have been issued.
• Managed issuance of all compliance enforcement measures and tracking of implemented corrective actions.
Project Manager / Technical Lead, FOG Control Consulting for Various Municipalities | Nationwide
• Routinely hired by municipalities to provide expert FOG control consulting services ranging from ordinance and permit
development, grease interceptor sizing and installation requirements, sewer line characterization, inspector and enforce-
ment procedures, and database and GIS management.
• Clients include Boston Water and Sewer, Seattle Public Utilities Commission, Orange County Sanitation District, Irvine
Ranch Water District, and the City of Santa Ana.
Project Manager / Subject Matter Expert, SSO Consent Decree Support, Confi dential Client | CA
• Managed all technical support activities related to an SSO consent decree response for a California sewer agency.
• Work involved detailed assessment of SSO-related programs, recommendation of program enhancements, development
and negotiation with the environmentalist group on behalf of the client for reasonable performance measures, and devel-
opment and implementation of critical program upgrades.
•
JIM KOLK
2
ENVIRONMENTAL
Corporate O ffi ce — Tel: (714) 667-2300 | Fax: (714) 667-2310 | One City Boulevard West | Suite 1800 | Orange, CA
92868 Regional O ffi ce: Annapolis, MD
eecenvironmental.com
Assessment/Remediation
Wastewater/Stormwater
Litigation Support
Regulatory Compliance
Technology/GIS
JOHN SHAFFER
CEO and Principal Chemist
John is the founder and president of EEC. John has more than 25 years’ experience managing
water resource projects and more than 17 years of experience representing municipalities
and private industries, including forming stakeholder groups and business coalitions. He has
managed many large projects, including a 2.5-million-gallon-per-day design/build wastewater
treatment project in China. John developed the Water Environment Federation (WEF) / U.S.
EPA fats, oil, and grease control program workshop and served as a speaker at workshops
throughout the United States. He also designed and conducted 10 wastewater treatment
operator training courses for metal fi nishers and circuit board manufacturers in Southern Cal-
ifornia on behalf of the Orange County Sanitation District (OCSD). John has delivered numer-
ous presentation to city councils and special district boards on behalf of municipal clients and industry stakeholder groups.
John holds a General Engineering Contractors License (A-743267), with a Hazardous Substances Removal Certifi cation. He
is a long-standing, active member of the Water Environment Federation, California Water Environment Association, and the
California Association of Sewering Agencies. John studied biochemistry at the University of California, Los Angeles.
EXPERIENCE
WASTEWATER/PRETREATMENT
Principal-in-Charge, Local Limits Evaluation, OCSD | Fountain Valley, CA
• Provided oversight and senior QA/QC review of all project tasks, including technical memoranda, fi nal reports, and
presentations to the OCSD.
• The evaluation consisted of employing EPA Local Limits Development Guidance (2004) to develop maximum allowable
headworks loadings and allowable industrial loadings.
Principal-in-Charge, QA/QC, Santa Ana Watershed Project Authority Pretreatment Program Audit
• Interviewer, principal-in-charge, and QA/QC lead for a thorough audit of the Santa Ana Watershed Project Authority’s
Industrial Pretreatment Program on behalf of OCSD.
Principal-in-Charge, QA/QC, Pretreatment Program Upgrade and Local Limits Development, Salt Lake City
Corporation | Salt Lake City, UT
• Principal-in-charge and QA/QC lead for an upgrade of the Salt Lake City’s Industrial Pretreatment Program for which
work included writing new permits, revising pretreatment ordinance, training inspectors, developing standard operating
procedures, and corresponding with State of Utah regulatory agents.
• Principal-in-charge and QA/QC for local limits development project.
Sewer Use Ordinance and Pretreatment Program Evaluation and Revision, Salt Lake City | Salt Lake City, UT
• Teaming with PSI, John was the project manager for the development and rewriting of the Salt Lake City Wastewater
Control Ordinance.
• In addition, John worked with Salt Lake City to develop all procedural documentation required for the ordinance revision,
including updating the Industrial Waste Survey, permitting procedures, inspection and monitoring procedures, and en-
forcement procedures.
ENVIRONMENTAL
ASSESSMENT/REMEDIATION | WASTEWATER/STORMWATER | LITIGATION SUPPORT
REGULATORY COMPLIANCE | TECHNOLOGY/GIS
EXPERIENCE (CON.)
Principal-in-Charge, Sewer Use Ordinance and Enforcement Response Plan Evaluation and Revision, City of
Ventura | Ventura, CA
• Principal-in-charge providing QA/QC for the evaluation and revision of the City’s sewer use (pretreatment) ordinance
and enforcement response plan.
Program Manager, Sanitary Sewer Overfl ow Study, OCSD and County of Orange | National
• Oversaw research study for OCSD and County of Orange on the causes of and solutions to sanitary sewer overfl ows.
The study was commissioned in response to increasing beach closures in Orange County due to sewer blockages.
• Evaluated the causes of grease blockages linked to wastewater discharge from restaurants and residences.
Project Manager, Sewer System Characterization | Orange County, CA
• Managed more than $1M worth of sewer system characterization projects for local cities and wastewater agencies.
• Oversaw CCTV inspections, sewer mapping using geographic information systems, and identifi cation of structural and
sewer blockage issues.
Project Manager/Chemist, 150 Industrial Wastewater Treatment Projects | Nationwide
• System designer and chemical specialist for wastewater treatment and/or water reuse systems in 150+ industrial plants.
• Work has included performing feasibility studies; designing complete treatment and water reuse systems; devising
chemical treatment processes for removal of oil, grease, heavy metals, toxic organics, chemical oxygen demand, biolog-
ical oxygen demand, and suspended solids; designing biological treatment; and providing technical service, operator
training, and ensuring compliance with local agency discharge regulations.
Developer/Instructor, Wastewater Treatment Operators Training Course, OCSD | Fountain Valley, CA
• Created and instructed 10 training courses for wastewater treatment system operators working in the metal fi nishing and
circuit board manufacturing industries to achieve and maintain compliance with OCSD’s discharge regulations.
• Course topics: system design, equipment operation, chemical treatment, pollution prevention, and troubleshooting.
Pretreatment Program Training, City of San Jose | San Jose, CA
• Program manager and co-trainer for a one-year comprehensive pretreatment training program for 20 City of San Jose
pretreatment inspectors and engineers.
• Topics included 40 CFR 403, legal authority, permitting, sampling, enforcement, reporting, industrial user tracking, and
local limits development.
• The training was required in response to an EPA Administrative Order.
Program Manager, Wastewater Compliance Programs / Water Reuse Programs, ALSCO | Nationwide
• Project manager for wastewater compliance programs and/or water reuse programs for 10 ALSCO facilities in the U.S..
• Work has included sampling studies, feasibility studies, pilot testing, treatment system design and installation, compli-
ance negotiations, and permitting.
Project Manager, Compliance and Water Rate Negotiations with Various Municipalities and Government Agencies |
National
• Retained by various private industries to negotiate with state regulators, cities, water agencies, sanitation districts, and
publicly owned treatment works (POTWs) throughout the country.
• Negotiated with such agencies as the California Regional Water Quality Control Board, Los Angeles County Department
of Public Works, Los Angeles County Sanitation Districts, Inland Empire Utilities Agency, Orange County Sanitation
District, City of Los Angeles Bureau of Sanitation, San Francisco Public Utilities Commission, San Diego Metropolitan
Wastewater Department, Massachusetts Water Resources Authority, City of Phoenix Water Services Department, and
Quebec City Provincial Wastewater Department.
JOHN SHAFFER
2
ENVIRONMENTAL
ASSESSMENT/REMEDIATION | WASTEWATER/STORMWATER | LITIGATION SUPPORT
REGULATORY COMPLIANCE | TECHNOLOGY/GIS
EXPERIENCE (CON.)
Project Manager, Wastewater Compliance Consulting, Genentech | South San Francisco and Oceanside, CA
• Consulted on various wastewater-related projects involving permitting and treatment design and compliance negotia-
tions with the Cities of Vacaville, South San Francisco, and Oceanside, CA, in which Genentech facilities are located.
Project Manager, Oil Refi nery Wastewater Treatment System Design and Construction | Mainland, China
• Oversaw the design and construction management of a 2.5 million gpd wastewater treatment plant at an oil refi nery in
China to assist the refi nery to meet ocean discharge standards.
• Designed a new system for treatment of stormwater and process water using API oil/water separation, PPI oil/water
separation, dissolved air fl otation, chemical coagulation and fl occulation, multimedia fi ltration, biological treatment, and
activated carbon polishing.
• Designed sludge treatment system consisting for sludge thickening, sludge dewatering, and sludge drying.
•
JOHN SHAFFER
3