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