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Agenda Packets - Sewer System - 2011-05-17 SEWER SYSTEM COMMITTEE May 17, 2011, 10:30 a.l'q"I. Costa Mesa San,itary District 626 W. 19th Street Costa Mesa, California Directors Ooten and Ferryman All Directors Welcomed STANDING REPORTS Iw Monthly Spill Statistics 0 Review Sanitary Sewer Overflow Occurrence Report Summary, CY2011 NEW DISCUSSION ITEMS III. Administrative Civil Liability(ACL) against Santa Margarita Water District 0 Review report on $1,7 million fine and cause of force main failure III. New Condition Assessment Method for Force Main Inspection M Review handouts lei. CIlWQS Performance Reports—Results for CMSD—Oral Report by District.Engineer DR Triennial Review, Open Comment Period Extension to May 13, 2011 a Review City of Orange response V1. 'WDR Seminar; Flo-Dig Installations of Sewers a Review seminar flyer 'III. Inflow at OC Fair& Event Center Review response letter from OC Fair& Event Center VIK articles of Interest; • A Paris School Turns to Sewers for Sustainable Heat Source • Oceanside'Facing Possible$10 Million Fine for December Sewage Spill ACTION ITEMS IX, Removal of Stromboli Sewer from Proposed 2011-201'2 CIIP a Review handouts and recommendations from Sewer Subcommittee Alternative SCADA System—Aquavx Review alternative system;and Recommends staff continues having discussions with Aquavx; and Return to the Board of Directors with a proposed alternative SCADA system XL Revisions to CMSD SSMP Approve schedule for revisions to SSMP Page 1 of Sewer System Committee May 17, 2011 XH. Street Sweeping Services—Oral Report CMSD PROJECTS: X111. A, Project#101 —Westside Pumping Station Abandonment B. Project#129—Bristol Street Sewer Phase 111 C. Project#164—Miscellaneous Sewer Work D. Project#171 —Irvine Pumping Station Force Main Rehabilitation E. Project#183 —System-Wide Sewer Reconstruction R Project#186—Sewer Lateral Assistance Program, Gi Project#189-.-Rehabilitation of Six Sewers Transferred to CMSD PUBLIC COMMENT'S XI V. This is the time to receive any comments from members of the public Next Meeting Date.- June 14,2011 Dated: May 12, 2011 Clerk of the District Page 2 of 2 o O_ 0000 Q CD O a ° c CL o Lo E o m m E Z v m = r c ause M O O M U N i ° O m C w m o c wits o 0 0 C ct N a M C D c w azs � tc Qv C a p °o C a C p °o t ffi m D �q R P � W w V' L Ar } Cl- cu cu e r m = Y Y ?m e a-�; }Z c m © tno o � U U U U 4f7'O Ln 0 O 0 to Lo �7F� o m U? m CL� c c e n e !� O U � } w } w O U a U LO Lf) vy- C P1'6] M N N i C r N V NJ d b0 IE NJ OO 0 E � � � z oW = y - � " �irL N to % 0 ' �C 01 a O i O tn it y, ° H O o N 7 O ,N V V O C C o �Cq o CD '6'E- 4) m a > > a 0 0 Q Z L 3 ' c 3 > q° � �S Y C p! uj LLJ h Q E W 3 L w a fA '� m m m m t� C ' in o [C a" C W C 0 O� co wIL °a N fVcO�V .. ;'NrN � m` Ned W z co 0��;c4 I`-W U) VJ J Q t- Sl7 co V) qf � axa ,Qua s' z e}ia 80 ura09 o � o YU" � a 01- YtJKa OF California Regional Water Quality Control Board item No. II San Diego Region Over 50 Years Serving San Diego,Orange,and Riverside Counties Linda S.Adams Recipient of the 2004,Environmental Award for Outstanding Achievement from U.S.EPA Edmund G.)Brown Jr, Acting Secretary for Environmental Protection 9174 Sky Park Court,Suite 100,San Diego,California 92123-4353 Governor (858)467-2952•Fax (858)571-6972 http;//www.waterboards.ca.govlsandiego Certified Mail-- Return Receipt Requested March 10, 2011 Article Number: 7010 1060 0000 4952 7440 Mr. John J. Schatz In reply refer to: General Manager Place ID: 751027.-means Santa Margarita Water District 26111 Antonio Parkway Rancho Santa Margarita, CA 92688 To Mr. Schatz: NOTICE OF HEARING AND ISSUANCE OF COMPLAINT NO. R9-2011-0023 FOR ADMINISTRATIVE CIVIL LIABILITY AGAINST SANTA MARGARITA WATER DISTRICT FOR VIOLATIONS OF ORDER NOS. 2006-0003-DWQ AND R9-2007-0005, WASTE DISCHARGE REQUIREMENTS FOR SANITARY SEWER SYTEMS AND SEWAGE COLLECTION AGENCIES IN THE SAN DIEGO REGION, COLLECTIVELY. Enclosed find Complaint No. R9-2091-0023 (Complaint) for Administrative Civil Liability against Santa Margarita Water District (Discharger) for$1,731,970 for violation of Prohibitions contained in State Water Resources Control Board Order No. 2006-0003- DWQ, Statewide General Waste Discharge Requirements for Sanitary Sewer Systems and San Diego Water Board Order No. R9-2007-0005, Waste Discharge Requirements for Sewage Collection Agencies in the San Diego Region, by discharging 2.293 million gallons of untreated sewage to Tijeras Creek, Arroyo Trabuco Creek, San Juan Creek and ultimately the Pacific Ocean, starting March 23, 2010 and ending March 26, 2010: The violations are described in the Complaint and the attached Technical Analysis to the Complaint. To further assist you in understanding this administrative process, the Administrative Civil Liability Complaint Fact Sheet is attached. Waiver of Hearing Pursuant to Water Code section 13323, the San Diego Water Board will hold a hearing on the Complaint no later than ninety (90) days after it is issued. You may elect to waive your right to a hearing before the San Diego Water Board. Waiver of the hearing constitutes admission of the violations alleged in the Complaint and acceptance of the assessment of civil liability in the amount of$1,731,970 as set forth in the Complaint. For the San Diego Wafter Board to accept the waiver of your right to a public hearing, you must submit the following to the San Diego Water Board by 5 p.m., April 6, 2011. California Environmental Protection Agency (a Recycled Paper John J. Schatz 2 March 10, 2011 Santa Margarita Water District Complaint No. R9-2011-.0023 1. The enclosed waiver form signed by an authorized agent of SMWD; and 2. A check for the full amount of civil liability of$1,731,970 made out to the "State Water Resources Control Board" Public Hearing Alternatively, if you elect to proceed to a public hearing, a hearing is tentatively scheduled to be held at the San Diego Water Board meeting on June 8, 2011. The meeting is scheduled to convene at the San Diego Regional Water Quality Control Board located at 9174 Sky Park Court, Suite 100, San Diego, California and the meeting will begin at 9 a.m. At that time, the San Diego Water Board will accept testimony and public comment and decide whether to affirm, reject, or modify the proposed liability, or whether to refer the matter for judicial civil action. Enclosed are recommended procedures the San Diego Water Board to follow in conducting the hearing. Please note that comments on the proposed procedures are due by March 17, 2011, to the San Diego Water Board's advisory attorney, Catherine Hagan at the address indicated in the hearing procedures. Please contact Mr. Christopher Means at (858) 637-5581 or by e-mail at cmeans _waterboards.ca.gov if you have any questions concerning this matter. PLEASE INCLUDE "751027:MEANS " IN THE SUBJECT LINE OF FUTURE CORRESPONDANCE Respectfully, JAMES G_ SMITH Assistant Executive Officer JCGS:jch:cjrn Enclosures 1. Complaint No. R9-2011-0023 2. Technical Analysis 3. Administrative Civil Liability Complaint Fact Sheet 4. Waiver of Public Hearing Form 5. Proposed Hearing Procedures California Environmental Protection Agency a Recycled Paper John J. Schatz 3 March 10, 2011 Santa Margarita Water District Complaint No_ R9-2011-0023 cc via email (w/enclosures): Dan Ferons, Santa Margarita Water District, DANF @smwd.com David Gibson, San Diego Water Board, DGibson @waterboards.ca.gov David Barker, San Diego Water Board, DBarker @waterboards.ca.gov Catherine Hagan, Office of Chief Counsel, CHagan @waterboards.ca.gov Jessica Newman, Office of Chief Counsel, jmnewman @waterboards.ca.gov Christian M. Carrigan, Senior Staff Counsel, State Water Board, Office of Enforcement, ccarrigan @waterboards.ca.gov James Fischer, State Water Board, Office of Enforcement, jfischer @waterboards.ca_gov Russell Norman, State Water Board, SSO Program, rnorman @waterboards.ca.gov Judy Gibson, US Fish &Wildlife Service, Judy_Gibson @fws•gov Bill Paznokas, CA Department of Fish & Game, wpaznokas @dfg.ca.gov Grant Sharp, County of Orange, Grant.Sharp @ocpw•ocgov.com CIWQS Entries I Order No_ R9-2011-0023 i Place ID 751027 Reg_ Measure 1D 377796 Party ID 39979 [_Violation ID 865403 I California Environmental Protection Agency Za Pecycled Paper, r Item No. I11 w PICAPipeflne inspection and Condition Analysis Corp. Company profile Russell NDE Systems Inc (RNSI) is the parent company of PICA Corp. RNS[ is a well- known manufacturer of non-destructive testing equipment with a strong expertise in eddy current methods.The company was founded in 1972 and many of our experienced research and development personnel have remained with the company over the past 3 decades. Our products are used in a variety of industries, including power generation, pulp and paper, petrochemical, municipal water and waste water mains, oil & gas pipelines, and the chemical processing industry. Over the past 25 years, RNSI has become a pioneer in the research and development of remote field testing (RFT) technology. Building on this experience, the company is considered a world leader in the application of RFT. In deploying this truly unique technique, Russell NDE has successfully designed and built a variety of innovative instruments for the inspection of heat-exchangers, boilers, pipelines, down-hole well casings, and cast- and ductile-iron mains. A 1992 AWWARF study found RNSI's RFT pipe inspection technology to provide the highest measure of success for cast-iron water main condition analysis. RFT tool description The Russell NDE Systems' line of pipeline inspection tools consists of flexible tools that employ Remote Field Technology for measuring pipe wall thickness. RFT technology works by detecting changes in an AC a ectromagnetic field generated by the tool. The field interacts with the metal in the en :ompassing pipe and becomes stronger in areas of metal loss. The field interactions are measured by on board detectors, and subsequently processed on the tool itself using A/D converters and DSPs.The processed data is either stored onboard, or sent uphoie over a multi-conductor wire-line for storage on a laptop. Once all the data is acquired, sophisticated analysis software is applied to generate accurate information on the wall thickness of the line. Figure 1 schematically shows the magnetic coupling path between the exciter section of the tool and the detectors. Russell NDE Systems Inc CONFIDENTIAL Page 1 of 11,.�, EYCKer Coll Plpo l Lead To KW" instrument and Data Acquish Ion Signal Flow Path Computer Figure 1.Schematic of magnetic interaction between RFT too]and Pipe Remote Field Inspection tools have the lollowing advantages: • Non-contact NDT method; liquid couplant not required. RFT has the advantage over competing technologies that it does not require intimate contact with the pipe wall to detect changes in remaining wall thickness. Therefore, internal scale, sludge, sand and liners such as HDPE, cement mortar or clay do not interfere significantly with the operation of the Tool. • Equally sensitive to internal and external flaws. RFT also has the advantage that it is equally sensitive to ID or OD wall loss. In other words, it does not matter whether the wall loss (usually graphitization in cast iron pipes) is on the soil side, or the product side of the pipe: it will be detected equally well. • Complete coverage at fast inspection speeds. RIFT is faster and more complete than isolated excavations and spot measurements, which could miss localized corrosion.The maximum speed is 10m/min (33ft/min). • Rugged mechanical design can traverse short radius bends (and tees). The Tools are fully able to negotiate short radius elbows, and can operate at pressures up to 700 psig. The new See Snakes are also completely self contained and "free swimming". That is, they have all required electronics, batteries, memory and sensors on board, and they can travel un-tethered down long lengths of pipeline. • Reliable and repeatable data. The new See Snake Tools have multiple channels. Effectively, this segments the pipe into "clock positions" (small fractions of the pipe circumference), which provides enhanced resolution to defects. The free swimming Tools have their own odometer and can sense and report the clock orientation of wall-loss defects. Russell NDE Systems Inc CONFIDENTIAL Page 2 of 11,.., HydroScope and HydraSnake Tools The HydraSnake and HydroScope tools are RIFT tools specifically developed for the assessment of cast and ductile iron mains. These tools can negotiate Tees, and have the ability to send data uphole over a wire[ine. The HydroScope tools were developed in the mid 1990s, and are gradually being replaced by HydraSnake tools. HydraSnake tools have superior resolution, higher pressure rating and the ability to store data on board. Figure 2 provides a system-overview showing a HydroScope/HydraSnake tool in its typical tethered configuration. As can be seen, the tools employ a beads-on-a-string configuration, which gives it its flexibility to negotiate 90-degree elbows. The diameter of the tool is several inches smaller than the ID of the pipe to allow for protrusions, lining and scale. Centralizers maintain a uniform annulus between the tool and the pipe. The connection with the uphole world is made through a wire line, which runs over an odometer sheave to provide an accurate distance reading of the tool. power Data Acquisition D.C. Winch and Analysis Supply Wireline !i �'Ifll YPl�ll!lU�?d�(%fUl�) (�b�l�/1(�' r1.WJU' 1 !((1�7��1''%�11,7L4'(f,411 _�! "Jtir' 'VIpldl�lJ�l 'l!!r011�I17GlU/111((��r✓tJ/' f�11NC11/Ni�ffillllllk�J1J7��Cyll!11111111111 1111 k1;itfa1Y!(!!(YVY�dWl�P1UJYlfI�YIIIV(Y1B � r� �I�l�uwldRi1°�!Nli' ;r i�bp»lGl 1t1!U„ ti ll�lfI�UYI r ! "rrrP„r �rJ�ll/J�✓�'IJIJ%Ia1C�J�lm� '�dfdflJ!!ll�l�llY!>� Pig Exciter Processing Detector Towing coil electronics coil adapter Figure 2.RFTTethered HydroScope/HydraSnake Inspection. The tool detects wall thinning caused by corrosion or erosion, as well as line features such as joint couplings, branches and elbows. The range is limited by the amount of wire-line on the winch.The current winches can hold over 3300ft. Russell NDE Systems Inc CONFIDENTIAL Page 3 of 11 ,�� Inspection Procedure During one of the preliminary site reviews, RFT technicians will have "walked"the line to be inspected. The purpose of this "line walk" is to document above ground visible features and their GPS locations, as well as scope out potential AGM sites if the distance between line features exceeds 350m. On the day of the inspection our emplo yes will hold a "Tailgate Safety and Operations" meeting to discuss potential site/operations hazards as well as the procedure for the inspection. During the tailgate we would normally ask to see the pigs that were run through the pipe as part of the cleaning. For tethered inspection runs,the crew will mobilize a winch, which is normally mounted on a truck or a trailer. Once the tailgate is completed the truck will be aligned with the launch point to insure the straightest pull possible from the winch to the entry point. The truck or trailer is then anchored in position using its brake and blocks under each wheel. Fire-Hydrant and Adapter The 6-inch HydraSnake tools can be launched through fire-hydrants, without the need for excavation and cutting into the pipe. In preparation of the tool launch the existing fire-hydrant must be removed and replaced by a temporary hydrant adapter. The odometer adapter is mounted on the hydrant stem using C-clamps. Next a support rod is attached to the adapter and braced against the base of the winch. The images below show the adapter as well as the bracing rod used with a trailer. i� �p .... � i d p r i P y � iii.; �( 5, ir✓�L�✓ y r / r /W�If��ii Figure 2.Typical 6-inch HydraSnake Setup Russell NDE Systems Inc CONFIDENTIAL Page 4 of 11 �� AW SM WM s f i i Figure 4.Sanitization of tool before deployment Figure S.Hydrant Adapter Preparation of the RIFT inspection tool. Tools are thoroughly cleaned and soaked in a 5%chlorine solution between jobs and are sprayed down again just prior to insertion. When all launch equipment is in place and the tools have been sprayed with a sanitizing chlorine solution, the RFT tool will be powered up outside the pipe to confirm proper operation. For the HydraSnake tools proper tool operation is confirmed through a wireless link. In case the pre-inspection checks turn up any tool problems, the crew will mobilize the back-up tool, and prepare it for inspections. Next the wireline is attached to the tool and pull pig, and the tool-train fed through the hydrant adapter into the line. Once the entire tool is completely inserted into the hydrant, the top of the temporary adapter is closed off with a cap. Water supplied from an upstream fire hydrant (and connected through the side ports on the adapter) is used to push the tool out to distance. After reaching the target distance, the tools are pulled back and retrieved from the (same) entry point at the launch hydrant. Data is logged at about 3-5 m/min and recorded in both directions for redundancy. The figures below show typical RIFT signals from cast and ductile iron mains, as well as a graphical representation of the results. For larger mains, launcher and receiver piping can be installed as shown on the next page. Russell NDE Systems Inc CONFIDENTIAL Page 5 of 11,. 0, Ildr„ i nr V �V �p ui �f�`� l � J�Jf tr' `, �i� �v,r l"r i �✓ .t� ��j� aJ r � "�,ati„; N M�` �' 1, r✓�” � y N,N a�f , Figure 6.Examples of launcher and receiver set-ups. Russell NDE Systems Inc CONFIDENTIAL Page 6 of 11,.,E See Snake Tools See Snake Tools gather and store the data on board the Tool. The Tools are fully self- contained and can travel through the pipe without having a wireline attached; however, if short sections are to be inspected (up to 2 km) it is recommended that a wireline be attached so that only one point of entry/exit is needed. For longer lines (up to 30km currently) it is more cost effective to launch the Tool at one end and extract it at the other. In this case AGM's (above Ground Markers) are placed above the pipeline to record the time that the Tool passed. The geographic location of the AGM is known through the use of survey-grade GPS units. Secondary Tool Tracking equipment is available and is used to find the location of a tool. See Snake tools have integrated electronics contained within the probe. The RFT field interactions are thus measured by on board detectors, and subsequently processed on the tool itself using A/D converters and DSPs. The See Snake Tools have multiple channels, effectively segmenting the pipe into "clock positions" (small fractions of the pipe circumference). This provides enhanced resolution to defects and allows the clock orientation of wall-loss defects to be reported by also logging the roll of the tool. The processed data is either stored onboard, or sent uphole over a multi-conductor wire-line for storage on a laptop. Once all the data is acquired, sophisticated analysis software is applied to generate accurate information on the wall thickness of the line. A 3-inch See Snake tool prior to deployment is illustrated in Figure 7. f Figure 7 3minch,See make tool Russell NDE Systems Inc CONFIDENTIAL Page 7 of 11,., The rugged mechanical design of See Snake tools allow it to traverse bends, and to operate at pressures up to 700 psig.The latest generation See Snakes are completely self contained and "free swimming". That is,they have their own odometer and all required electronics, batteries, memory and sensors on board, and they can travel un- tethered down long lengths of pipeline.The illustration below shows RFT data from a localized pit at the 6 o'clock position as seen by a free swimming 6-inch See Snake tool. 41 .V 9r 6 14M W., % �1 1 o IV4 Q9"�+r BtlRti�4 d' J i, h°' ` 1 �' _ IiB 44�1 dl iiil I1 V,' ➢ I`�Y g .�' �I ., �� i u iy 6 Old f llY YA l . — ---t .. 9 1%6.25m 059241 PAJ 115751 chentiockyo3:40 Figure 8 RIFT Local Wall loss indication at the bottom of the pipe(5:30 clock position)as seen by 6-inch See Snake Tool.Subsequent RT inspection showed this defect to be a deep linear indication of 1.5-inch length surrounded by less severe corrosion(RT photograph shown in inset) Due to their flexible and free swimming nature See Snake tools can accommodate back- to-back bends. Free swimming See Snake tools are launched from launch barrels and retrieved through catch or receive barrels. Figure 9 below show an example setup. The image on the left shows two 90-elbows in a water line just upstream of a typical receive barrel. Russell NDE Systems Inc CONFIDENTIAL Page 8 of 11,l � rlr'df ✓� 'al ii �/i � r/ // 9 i,.w,�Y' rte., //Oa,, I /; y AN r Figure 9 Typical launch or receive setup with oversize barrel Commercially Available RFT Tools RFT Tools are customized for certain applications, and therefore cover different ranges of pipe sizes, pressures, resolutions, and bend capabilities. The table below lists the available tool sizes and their specific features: Table 1-1 Commercially Available RFT Tools Tool Name Pipe Wall resolution Deploy- Range Min Pressure Thickness ment Bend capability Radius 3-inch See 3-inch Schedule 40 3/16-inch Tethered 1km 10D 700 PSI Snake (Gen Il) Through typ. Hole or better 4-inch See 4-inch Schedule 40 See 3-inch Tethered 1km 6D 700 PSI Snake (Gen II) See Snake typ. 6-inch See 6-Inch Schedule 40 See 3-inch Tethered 1km 3D 700 PSI Snake(Gen II) See Snake typ. Russell NDE Systems Inc CONFIDENTIAL Page 9 of 11,w, 6-inch See 6-inch Heavy Wall 1/4-inch Free 30km 1.5D 700 PSI Snake (Gen III) or lined (up Through Swimming to 1-inch Hole thickness) 6-inch Hydra- 6-inch Lined or 3/8-inch Tethered 1km 1D 300 PSI Snake Cast/ Scaled up to Through (Tees) Ductile 1-inch Hole thickness) 8-inch See 8-inch Heavy Wall 1/4-inch Free 30km 1.51) 700 PSI Snake (Gen 111) or lined (up Through Swimming to 1-inch Hole °° thickness) 8-inch Hydra- 8-inch Lined or 3/8-inch Tethered 1km 1D 300 PSI Snake Cast/ Scaled up to Through (Tees) r� Ductile 1-inch Hole thickness) 10-inch Hydro- 10-inch Lined or 1-inch Tethered 1km 1D 150 PSI Scope Cast/ Scaled up to Through (Tees) Ductile 1-inch Hole thickness) 12-inch See 12-inch Lined or 3/4-inch Tethered 1km 1D 150 PSI Snake (Gen II) Cast/ Scaled up to Through typ. (Tees) Ductile 1-inch Hole I adthickness) 12-inch See 12-inch Heavy Wall 1/2-inch Free 30ktn ID 700 PSI Snake (Gen III)* or lined (up Through Swimming to 1-inch Hole thickness) 16-inch Hydra- 15/16- Lined or 1-inch Tethered 1km 1D 300 PSI Snake* inch Scaled up to Through (Tees) Cast/ 1-inch Hole Ductile thickness) 20-28 inch See 20-28- Heavy Wall 1-inch Free 20km 1.5D 300 PSI Snake (Gen inch or lined (up Through Swimming 111) to 1-inch Hole thickness) *Target completion Nov 2010 Russell NDE Systems Inc CONFIDENTIAL Page 10 of 11,x,9, IMU Tools Inertial Measurement Tools have been de )ed for locating pipeline bends and deflections. Using orthogonally mounted gyroscopes and accelerometers, these tools can measures rotation rate and acceleration in each of the pitch, yaw and roll directions. Coupled with 3 redundant odometers an IMU can quantitatively specify the distance and clock position location and indicate the severity of bends. The tool is powered by on-board batteries and is capable of autonomous operation of up to one hundred hours with on-board memory data capture. An on-board transmitter allows for above ground tracking. This enables the operator to monitor inspection progress at every step of the way and provides GPS referenced way points along the pipeline. Commercially available IMU tools cai i inspect pipe sizes of four inches and larger and navigate through bends as small as 1.51 in the larger pipe sizes. The tool design can accommodate pipe reductions exceeding 2_`% of the the nominal diameter. Due to this compact design an IMU tool is typically run as a proving tool prior to an ILI RFT inspection. A gauging module can be attached consisting of aluminum leaves that deflect when they encounter an inner diameter restriction. The operator evaluates the aluminum leaves at the end of the IMU in and determines whether there is safe passage in the line. IV Y / [ \� Y ggtl. 'M /�//N�wid o%�e�✓//�%/ ,� p s, '�f,��!!�//' �/r f'W� i �� rr %1 , I j 1 , y- %i,/�i%%/fin t/i/f, 1! '�! ,r�i�}r ! r i� ! ,r%%J 11, f�1` � 1! ,.! � ✓ ,�,VG�//�i�f/ i� �`' �` I t „iJ' I � "a� ✓ t 4 k r d � V tt �� Figure 10.Above ground riser with IMU represents ion indicated below. Inspection services using RFT Tools are ofzered by RNSI for oil, gas, slurry and chemical pipelines while inspection of water and waste water pipelines is offered by PICA Corp. Russell NDE Systems Inc CONFIDENTIAL Page 11 of 11,.» Item No. V " CITY OF Of` 1V1GE NrpP,y4p�, PUBLIC WORKS DEPARTMENT ENGINEERING DIVISION MAINTENANCE DIVISION TRAFFIC DIVISION WATER DIVISION (714)744-5544 (714)532-6480 (714)844--5540 (714)288-2475 FAX:(714)744-5573 FAX:(714)532-6444 FAX:(714)744-5573 FAX:(714)744-2973 May 5, 2011 Ms. Jeanine Townsend, Clerk to the Board State Water Resources Control Board 1001 1 Street 24th Floor Sacramento, CA 95814 Subject: Draft Waste Discharge Requirements for Sanitary Sewer Systems Dear Ms. Townsend: The City of Orange appreciates the opportunity to comment on the draft March 22, 2011 Waste Discharge Requirements for Sanitary Sewer Systems Permit (WDR). Our initial impression after reading the WDR staff report and information gathered from informal group discussions with state board staff and various committees was that there would be minimal changes to the existing WDR. We were informed that the WDR would be revised to include private system enrollees and clarify certain existing requirements. However, after reading the WDR and redlined version, we were surprised to see the number of changes proposed that were not discussed in the accompanying staff report. Our review of the WDR has identified a number of very prescriptive requirements and significant changes that are of concern such as the revision of the enforcement language regarding what may be considered in possible enforcement actions; the dictation of specific actions that go beyond the requirements of Porter Cologne; the addition of new administrative burdens that will result in additional compliance costs and other compliance issues. These are more fully discussed in the enclosed attachment. Orange completed development of its sewer system management plan (SSMP) in May 2009 as required by Order 2006-0003 and has been implementing it for the past two years. Some of the smaller agencies serving populations less than 100,000 have recently completed their SSMPs and have just begun implementing them. We do not believe this short implementation period is sufficient time to assess whether program modifications are needed. The purpose of WDR program is to reduce SSOs over time and we believe the current program is working. In Orange, we have placed additional emphasis on sewer maintenance and hot spots and have seen the number of public spills reduced from 16 in 2006 to 9 in 2010 (a 44% reduction). When vandalism, which is out of our control, is factored in the number is reduced to 6. We believe this and other programs required by ORANGE CIVIC CENTER o 300 E,CHAPMAN AVENUE o ORANGE.,CA 92866-1591 o P,O.BOX 449 QQ*PRINTED 014 RI_CYCLED PAPER Comment Letter March 22, 2011 Draft WDR May 5, 2011 our SSMP and the WDR is proof that the current program is working and should be allowed to continue for at least another permitting cycle before significant changes are proposed. We urge the State Board to scale back the number of proposed changes until such a time when the program has had more time to develop and changes can be justified. As proposed, most changes are not justified and will simply add significant new costs and staff to an already expensive program during a time of shrinking City budgets and adverse economic conditions. We hope you will reconsider the proposed changes. Questions regarding these comments may be directed to Gene Estrada at 714-744-5547. Sincere) , oe DeFrancesco Director Public Works cc. John Sibley, City Manager Attachments: Attachment A Attachment A Page 1 of 7 The following are the City of Orange's comments on the proposed draft WDR. Compliance Beyond Porter Cologne Porter Cologne Section 13360 (a) prohibits WDR permits from specifying how compliance is to be achieved with permit requirements yet the draft WDR contains many new provisions that specify specific requirements to achieve compliance with the WDR. 1. Of Particular concern is the specificity relating to the funding of the sewer system operation and maintenance program. Paragraphs D.6.(e) and D.7 include the words "proper funding" and paragraph D.8 goes so far as to require the development of a rate structure to fund the eventual replacement of the entire sewer system. In the context specified in D.8, it can be interpreted to mean that a public agency must develop a cost recovery plan to be imposed on rate payers or a cost recovery plan to be voted upon by rate payers. The requirement to eventually replace the entire sewer system is unnecessary since history has shown that clay pipe, used predominately by most agencies, has a life of hundreds to thousands of years and requiring to fund the eventual replacement of the pipe is imposing an unnecessary burden. A more reasonable requirement is to ensure a plan exists to carry out the maintenance requirements of the system as required by provisions 12.(d).iii, 12.(d).vi. and 12.(h). Recommendation — (1) delete the D.(8) requirement to create a rate structure and delete the requirement to fund eventual replacement of the entire sewer system. (2) define proper funding as used in D.6.(e) and D.7 to mean development of a funding mechanism to carry out the requirements of an agency's SSMP. 2. Paragraph D.12.(f).vi requires development of a risk and threat analysis to identify the most problematic areas that may create future overflows. While we agree such an analysis may be useful in the planning of future overflows, there may be many other considerations that need to be included in planning for future overflow conditions and such planning should be left to an individual agency . Recommendation —delete D.12.(f) requirement for a risk and threat analysis. 3. Provision D.10 requires a governing board to approve the SSMP Development Plan and Schedule. This requirement exceeds the requirements in Porter Cologne by dictating how a plan is to be developed. The only WDR requirement should be that agencies develop an SSMP development plan and schedule, which can be done without governing board approval. Attachment A Page 2 of 7 Recommendation — delete D.10 requirement to have governing board approve SSMP Development Plan and Schedule. 4. Paragraph D.12.(g)(v) requires the FOG program to specify staffing levels. The FOG program needs to contain the elements identified in D.12(g) however, how the program is carried out should be left to individual agencies. Requiring staffing levels goes beyond the requirements of Porter Cologne. Recommendation — delete D.12.(g).(v) "staffing level" requirement with "staff to carry out program." Expanded Administrative Burden The draft VVDR contains many provisions that increase the administrative burden and are unnecessary. 5. Paragraph D.13. requires recertification of the SSMP every 4 years. This requirement, while it may appear beneficial, creates an unnecessary burden of time and expenses on agencies. There is no clear justification for this requirement. A more reasonable requirement would be to recertify the SSMP when there are major changes as required in the existing WDR. Recommendation — require SSMP recertification only when there are major changes to the existing SSMP. 6. Paragraph 12.(f) requires adoption of an SSO emergency response plan. The term "adoption" has a number of meanings and interpretations and it is not clear what is meant in the draft WDR. It could be interpreted to mean adoption or approval by the governing board or simply adoption by a department or division. The precise meaning is unclear but we believe an SSO emergency response plan can be carried out by an agency without the formal adoption by a governing board as is done for many programs in the City. As mentioned above in reference to Porter Cologne, the requirement should be to develop a plan but not require approval by a governing board. This comment is also applicable in other section of the WDR where the term adoption is used. Recommendation --- (1) revise "adopt" to "develop a plan" in paragraph 12.(f).(2) review WDR to ensure that"adoption" is clear in its meaning. 7. In the Monitoring and Reporting program, Paragraph C- Record Keeping requires keeping copies of the SSO draft report, keeping names of field crews responding to a spill and other information such as steps to prevent future recurrence and Attachment A Wage 3 of 7 methods of determining spill volumes and recovery. Keeping copies of the draft SSO report seems of little value and would only be duplicative of the information contained in the final report. The final SSO report in the state SMARTS system also contains information related to spills volumes and recovery. Keeping copies of the final SSO report is reasonable and all other information noted above would be contained in this report. The names of the field crew responding to an overflow incident seems of little value and should not be a WDR requirement. The important information is how a spill response is carried out and mitigated: this is information provided in the final SSO report. Recommendation —delete reporting requirements to identify field crew names and other information contained in the final SSO report in the SMARTS system. Private Sewer Overflows The draft WDR expands coverage to individual private owners of sewer systems that are greater than one mile in length and collect over 25,000 gallons per day of wastewater. In carrying out this new WDR provision, clarification is required in certain sections relating to new enrollees and the reporting of SSOs. 8. In the draft WDR there is no provision regarding how existing Enrollees will be notified when a private Enrollee is responsible for their private system and the public agency does not need to report SSOs for the private system. Recommendation — include a provision that the State or private Enrollee will notify an existing Enrollee of existence of an individual WDR permit within the Enrollees jurisdiction who will now be responsible for reporting their system's SSOs. 9. Within the Monitoring and Reporting section provision 3 of Section B - SSO Reporting requires clarification that reporting of PLSDs is required by the Enrollee only if the SSO is not from a Private Enrollee. Recommendation — add clarification to reporting of private SSOs that if a Private Enrollee is responsible for the system, the Private Enrollee is responsible for reporting any SSOs and notifying the appropriate agencies. 10.In Monitoring and Reporting under Mandatory Information to be Included in SSO Online Reporting — the information in paragraph (2) Private Lateral Sewage is to be made by the Enrollee with jurisdiction in the area only if there is no Private Enrollee. Page 4 of 7 Recommendation — add clarification that reporting of private SSOs is by the Enrollee with jurisdiction in the area only if there is no Private Enrollee responsible for the private system. SSOs Not Fully Captured Paragraph B.1.0 of the Monitoring and Reporting program states that SSOs not fully captured in storm drains and returned to the sanitary system are considered discharges to waters of the state. 11.We strongly disagree with this premise. It has been the City's experience that SSOs that travel significant distances to reach existing channels or other water bodies do not always reach these water bodies. Determining if SSOs reach a water body or not depends on a number of factors such as volume, distance to water bodies and other structural elements within the storm drain system such as siphons. To categorically state that unrecovered wastewater in storm drains is a discharge to waters of the state is premature and incorrect. As an example: a discharge of 5 gallons that travels one mile or more will probably not end in a discharge to a water body but will be trapped or will evaporate over time in the storm drain. However, the same volume of discharge that has to travel only 100 feet will most likely reach a water body_ Whether or not a discharge reaches a water body can be verified by visual inspection for odor and wastewater at the storm drain's outlet point into the water body. We believe this is the reasonable standard to determine whether a discharge to a water body has occurred and not simply that an SSO was not completely recovered. Recommendation — revise Paragraph 8.1.0 of the Monitoring and Reporting program to indicate that a discharge to waters of the state has occurred only when there is visual evidence of a discharge. Prohibitions on SSO discharges 12_Prohibition C.1.(a) prohibits a wastewater discharge to storm drains if the wastewater is not fully captured and incorrectly assumes a discharge to waters of the state as noted above. This prohibition if not revised could place an agency in noncompliance if all of the wastewater is not recovered from the storm drain. This could result in enforcement actions without proof that a discharge to waters of the state has occurred. This is a very serious violation that should be revised to ensure noncompliance occurs only when there is real evidence that an agency has violated a part of the WDR. AttaGhment A Page 5 of 7 Recommendation —see comment number 11 above on partial capture of wastewater from storm drains. Enforcement Considerations 13. Paragraph D.6 contains what appears to be a relatively minor change in language in reference to what the State or Regional Boards will consider in follow-up enforcement actions. The existing WDR states "In assessing these factors, the State and/or Regional Water Boards will also consider whether"; the draft WDR states "In assessing these factors, the State and/or Regional Water Boards may also consider whether"followed by a number of factors to be considered in enforcement actions. The change from "will" to "may" is significant in that the listed factors do not necessarily need to be considered in follow-up enforcement actions. The factors to be considered during enforcement actions were the subject of extensive discussions in the adoption of the existing WDR and language has now been changed arbitrarily without cause and discussion. Recommendation — revert to previous approved language in D.6 Performance Targets 14.Section 12.D.i has created a new section to be incorporated into an agency's SSMP. While there is value in monitoring to assess program development and implementation, the goal of the WDR and SSMP is to reduce SSOs over time. The inherent assumption in this section is that employing performance targets will result in reduced SSO and program improvement. This may or may not be true depending on the number of SSOs and an agency's program. Showing improvement in SSOs and meeting specified targets may be difficult if the SSO number is low and program is already efficient. More value can be obtained by ensuring implementation of the SSMP and modifying programs as necessary, Recommendation — revise Section 12.D as follows. (i) Identify SSO trends; (ii) Collect and maintain appropriate records and information to identify SSO causes and preventive measures; (iv) Monitor the effectiveness and success of each SSMP element; (v) Update SSMP elements, as appropriate; and (vi) Maintain an SSMP Change Log that includes a list of all modifications and changes made to the SSMP including date and identification of staff responsible for implementing each change. Attachment A Page 6 of 7 Clarifications 15.Paragraph B.2 requires separate permits for each system of sewer lines over one mile that collects over 25,000 gallons of wastewater per day. It appears that this provision applies only to sanitary districts that have sewer lines managed under different operating districts and not agencies that have multiple lines over one mile and collect 25,000 gallons or more as is the case for many agencies operating in Orange County. Requiring each line that is over one mile to obtain a WDR permit would place an unnecessary and significant administrative burden on agencies that connect to existing sanitation district trunk lines and would be a extremely difficult to administer. W� do not believe this is the intent of this provision and suggest that this regr.irement be clarified to address agencies with multiple sewer lines that connect to another agency's trunk lines. Recommendation — clearly state that only a single WDR permit is required for agencies with multiple sewer lines that connect to larger trunk lines owned by another agency. 16.Paragraph D.13 requiring an SSMF development Plan and Schedule seems to apply to new enrollees only and sh ;uld be clarified. Agencies or Enrollees that already have a certified SSMP do r.Dt need to comply with this requirement. Recommendation — clarify that only new Enrollees need an SSMP Development Plan and Schedule. It is recommended that the WDR include appropriate sections that apply only to new Enrollees and section that includes all of the requirements for existing Enrollees. 17.Section A of the Monitoring and Reporting program requires a 2 hour time frame to notify Cal EMA of spills that discharge to a storm drain or channel. This time frame has been revised in Section B - SSO Reporting Timeframes to "as soon as" to be consistent with Porter Cologne. Recommendation — revise the 2 hour notification time frame in Section A to be consistent with Section B and Porter Cologne. TWO Tiered WDR and NPDES Permit The City supports continued use of the collection system permit as a WDR permit instead of an NPDES permit. We agree with state board staff recommendations that the current program is working well and do not see any justification to create confusion by adopting a tiered WDR and NPDES permit. The exiting WDR allows for enforcement by state and regional board staff and citizens can call the state or regional boards if they believe an Enrollee is out of compliance. For these and other reasons previously discussed during the adoption of the existing WDR, the state should not move towards 3. Attachmvr,L Page 7 of 7 the more complex form of an NPDES permit -nply because there is one SSO that reaches waters of the United States. This i:' illogical and would greatly increase the number of NPDES permits issued statewide that would become an administrative night mare for the State that would likely result in delaying issuance of permits, which could number in the hundreds to thousands of permits. Item No. V! Another in a series of Sewer System Education Seminars hosted by the (--)range Coun,y Waste Dfischarge Requirements (WDR) Steering Committee.... No-Dig histallation, of Sewer's Crossing Under Rivers,,, Railroad M,c , FreewaYS, and Flood 0 o Channels HOSTED BY Glenn Hermanson, P.E. Principal Project Manager RMC Water and Environment Discussion: ➢ Three pipeline construction projects that cross rivers ➢ Compare and contrast the projects o Three trenchless methods will be compared: horizontal directional drilling, pilot tube guided auger boring, and microtunneling ➢ Installation of gravity sewers, inverted siphons, and force mains using trenchless methods will be discussed ➢ Questions and answers Attendance by staff engineers, maintenance staff, and WDR general group members recommended 14 ;d'q, ,canlact hot, rs art,, available tba mats !3�51°Tlinar I Date &Time: Thursday, May 19, 2011 from 9:30-11:30 AM Location: Orange County Sanitation District Administration Building -- Board Conference Room 10844 Ellis Avenue, Fountain Valley, CA 92708 714-962-2411 Please arrive early as the program will begin at 9:30 A.M. Item No. VII RECLINED APR 2 8 2011 w COSTA MESA SANITARY DISTRICT April 20, 2011 Scott Carroll, General Manager Costa Mesa Sanitary District 628 W. 19d'Street Costa Mesa,Ca 92627--2716 Subject: Sewer system inflow contingency plan. Dear Scott, Thank you for sending your letter of recognition,recognizing our efforts to resolve the inflow during the storms of December 2010. AIthoughh we have not completed all the projects I addressed in my letter dated January 15"',it gives us confidence that our efforts are on the right track for success. I would Re to address your letter from December 22nd 2010 requesting a contingency plan for our inflow issues. 1. Covering the Maintenance yard We are in the process of R&D with Enviro-valves and studying the needs for holding pump stations and or redesign slab work to accommodate the rain water infiltration.Due to the states financial situation our goal is to have this system designed and installed before 2013. In a letter addressed to me dated Match 11,2010 from Robin Hamers; it stated.that CMSD would assist OCFEC with professional assistance from CMSD District Engineer, Maintenance Supervisor, and Senior Inspector to put together the proper applications of the Enviro valve and other sewer/storm drain connections.I would like to request your team's assistance on this through review in the field. 2. Epuesh ian wash rack coye This cover is in R&D and will be completed in 2012. 3. Maternity barn wash rack The Maternity Barn will have an Enviro Valve installed in this location also. This project will be complete in 2013. 4. Clean out caps on sewer connections OCFEC is currently half way thru completing the installation of the spring loaded caps. OCFEC will be complete in 2012. OC Fair&Event Center•32nd District Agricultural Association 88 Fair Drive,Costa Mesa,CA 92626•(714)708.1500•odair.com Page 1 Scott Carroll, General Manager Costa Mesa Sanitary District 628 W. 19'h Street Costa.Mesa,Ca 92627-2716 Subject: Sewer system inflow contingency plan. 5. Mart hole cowers OCF&EC will be removing the restroom structure in parking lot I on 4/21/2411.In the NW corner of this restroom is a man hole that was getting infiltrated during heavy storms due to its location being in a very low point in the parking lot;which continued to flood.This low point will be re graded and new asphalt installed to raise the elevation thus putting the man hole at the high point. Respectfully, Jerry ledge Director of Facilities OC Fair&Event Center OC Fair&Event Center^32nd District Agricultural Association 88 Fair Drive,Costa Mesa,CA 92626,(714)708-1500•ocfair.com Page 2 "S, Item No. Vill 1 �� sated water running through Paris"sewers will be put to use beating a school.Phorc: under a Paris has been on an alternative energy roll as of late:installing testing the and using solar power to, n ata . ....... -.Now the French capital is going further-.using heat from wastewater in its sewers to keep,the students loc-al school group warm and toasty. It's the first time this process has been used in Paris,but its not unprecedented. Oast year,a nearby town began using the heat from wastewater in its pipes-to The Watbgnies school group,in Paris!12 arrondissement,has been equipped with a heat pump and 60 meters of heat exchangers. The energy that goes into heating water for dishwashers, laundry machines,showers and sinks usually goes to waste,but now it will be recovered,and the projected stets are impressive.If ail goes according to plan,the new System will meet 70%of the school's heating needs and avoid the emission of 76.3 tons of CO2 per year. The process is safe and dear),,,,,' It requires no combustion and there's no cause for alarm odor-wise:only the heat is recovered from the sewer water,not the smell.And it's a great creative way to save not only energy,but money. Formore stories like this, More unusual,sustainable energy sources: ............ A, ARM OF &REEN cominEruzl 169 people recommend this. 11c,cleatv', Start for as low as SC Join the discussion! EXCLUSIVE. Oceanside facing possible $10 million fine for December sewage spill Page 1 of 2 X The North County Times-Californian EXCLUSIVE: Oceanside facing possible $10 million fine for December sewage spill Buena Vista Creek spill much worse than originally thought By RAY HUARD-rhuard @nctimes.com I Posted: Tuesday,May 3,20117:54 pm A December sewage spill along Buena Vista Creek in Oceanside was far worse than officials first feared,turning out to be what they said was the worst such spill in recent memory and leaving the city vulnerable to a substantial fine----as much as $10 million. Instead of the 180,000 gallons of raw sewage Oceanside Water Utilities Department officials initially estimated, they now say the spill dumped up to 5.4 million gallons of untreated sewage into the environmentally sensitive creek. The creek meanders from just east of Vista's Brengle Terrace Park to the Buena Vista Lagoon. A state environmental agency,the San Diego Regional Water Control Board,is investigating the spill to determine how much harm it caused and whether the city is at fault. The environmental scientist heading the board's investigation,Christopher Means,said it will be at least two months before its review is completed and the board staff decides whether to recommend that the city be fined. By law,the maximum fine the board can levy is$2 for every gallon of sewage spilled;but Means said he couldn't recall an instance when such a high fine was imposed. Water Utilities Department Director Cari Dale said it would be counterproductive for the water control board to fine the city for the spill,because the money would be better spent replacing worn pipelines such as the one that broke to prevent more spills. Luckily,the heavy December rains and flooding that officials blamed for the pipe break also prevented the spill from turning into an environmental disaster,according to the city and an environmentalist who monitored the spill and its aftermath. "If this was a dry-weather situation,it would have been much worse," said Mark Anderson,operations manager with the Water Utilities Department. Environmentalist Diane Nygaard said because of the rain, "the pollutants got immediately diluted." "If this had been stagnant,it would have been horrific," she said. Dale said the initial estimate on the size of the spill was so much smaller than the final count because no one knows when the pipe broke,how long untreated sewage was flowing into the creek and how much there was. The pipe that broke has been exposed,hanging over the creek,for more than a decade,Nygaard said. Dale said the city was aware of the problem and had plans in place to replace the pipeline,but kept running into snags getting the required permits from various state agencies. In December,the creek was so swollen from several days of steady rain that the pipe was submerged,Dale said. "We couldn't see the pipe to know if it was broken,"Dale said. When the water receded,workers detected the break.The sewage that was carried in the broken line was diverted into an adjacent sewer line owned by the city of Vista and pumped to the Encina Water Authority plant in Carlsbad for treatment. Even now,no one knows for sure when the pipe gave way,but Anderson said the best guess is that it happened around Dec. 22; it wasn't discovered until Dec.2$. Since the spill, about 500 feet of pipeline was replaced at a cost of$245,000,with the new line moved so it would no longer be in the creek itself. http://www.netinnes.con-/news/local/oceanside/article_c7f4e5bc-97aa-5123-aedf eaef56f45... 5/11/2011 EXCLUSIVE: Oceanside facing possible $10 million fine for December sewage spill Page 2 of 2 Dale said the long-term plan is to move the sewer line north of Highway 7$,far from the creek and the ecological preserve through which it passes. That's expected to cost about$13 million and take about 11 years to complete,Dale said. Meanwhile,Nygaard said she's worried that Oceanside,like many other cities,isn't moving fast enough to replace aging sewer lines. Even the new pipe that replaced the broken line along Buena Vista Creek connects on both ends to pipes that are 50 years old, she said. "The whole area is still at very high risk of spills,"Nygaard said. "The scary thing is,we don't know how many bad situations we have." Call staff writer Ray Huard at 760-901-4062. http://www.netimes.com/news/local/oceanside/article_c7f4e5be-97aa-5123-acdf-eaef56f45... 5/11/2011 Item No. IX s-r8� SEE 9>EEfT NO.req T • 11 • �' HOT SPOT NO,18 ,.• ��y eaiM ,a,�u, sw� aw.y izr�� 94� ,•°® � � ^n °®�' ® �� T 6 _ YJ�•r' ®m @�.d'ya°' ski ..�: •a:. ®°° - Vw ,„h 5 y'` © +°`p •• O u O �®q �L' ® YBra a 44'aZ � .rJ'y0 �•• � 4� '' \ • ® E � �� N� x zaza zen xu+a yasa �. � ® '•`� ��. r*I""'n �-... •° '°"�.,�� +yd � �' — � •(�.°' `°® \, .r '•w �, w9x °exz 9rez assz ,..r, �yex sx 9 .,°'�..- S mix u .a x sass 5sxa yi u O N 1 + � •� 'rie f� H - 3 I e s za 5 e xesT z9ae xeal ¢eel I 3 � i y .'ti ®°•a� °ate Vass T ° � � 5 Qe. a @ . °s •1 $ AYEA7/E 6 s i � ax#_ r �n ® •C°o ,�, jj+ � ,° 5 -� ss 0 eF.e®�v i � E'LL ME y � �y�,'�� Y V •°O0 ® � ., ie� ai �a g �eaea zs°° zeoa siv�al�1�{a i �,� �e lO:ze'7 ., a~ x r• CORVO PLA £ ®it°®, �� e 7 w.+;� j m 1� • °'� ® ® • �Q �' �' ®fig '.� x851 9 a5 leer 2961 9 S• — ” + a '�r \ ABA PLA r$ i *.,6^O°°.0"., �•..�, �� C 1 P� d` �^I � �� ® s° *•" � ey® 4 01'x° {n �x 2653� 6 Z'91 1 BST µ N• r _ � ®�° u"r MY ! / I{` H®per 2 .•� e� 2x ® °Imp„ �c,N®4 m0 � ���� b 'ydP'p�j n �,� SERAHfi. 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IYlfl�,�'t IB�P+�t�mllll iG/��,�/��/fIXII����IJ�1�AlI'7��NN�p,�@ 7�I�d1�l lY�l di7�1�➢1,l K�fPfll�l°/�d�Jr'�dV"dE'�lt�l l�l!7('R�l ggll�lYN'YII�YIINIM�iI J�ifii�uhf�ll IN)ll!G!fY+�>�YSB+r�����1�����i��` FEATURED The Aquavx Store is Open! Check out the Aquavx Store, where you can purchase the Aquavx Scout RTU and support packages. > V,1!12,1 Our Store DID YOU KNOW? Come See Aquavx Aquavx is planning our events for 2011.Visit us at the NEWEA, NYWEA, and Colorado Rural Water Association conferences as well as AWWA ACE and WEFTEC 2011. What events are you attending? We want to know! Call Us Toll-Free 877-827-8289 © 2010 . ,.. 0%��tiaLti° "° All Rights Reserved. Item No. XI Costa Mesa Sanitary District Proposed Completion Schedule for Revised Sewer System Management Plan (SSMP) 1. Revise the Legally Responsible Official (LRO) identified in CIWQS Section II: Organization 2• Identify who is replacing the Operations Manager for July 28, 2011 several key responsibilities 3. Identify personnel names in the SSMP 1. Update Operations Code Section III: Legal Authority section numbers in the SSMP July 28, 2011 so that it is consistent with actual code 1. Update total miles so that it is consistent with CIWQS database Section IV: O&M July 28, 2011 2. Include recent GiS and CMMS development activities Section VI: Overflow Emergency 1. Sign off of the SSMP and spill Response Plan reporting requirements July 28, 2011 completed by all field staff