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2017 SSMP Audit Regional San – SRWTP of 25

Region San SSMP Audit - FINAL

1. Purpose

The purpose of this document is to report the results of the Sewer System Management Plan (SSMP) Audit conducted for Sacramento Regional County Sanitation District’s (Regional San) interceptor system covering Calendar Years (CY) 2015 and 2016. This report was prepared and is being submitted pursuant to the requirements included in the State Water Resources Control Board Order No. 2006-0003 – Statewide General Waste Discharge Requirements for Sanitary Sewer Systems (WDR). The audit requirements are:

“As part of the Sewer System Management Plan (SSMP), the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee’s compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them.”

In addition to the evaluation of the SSMP’s programs and effectiveness, this report will also identify potential weaknesses and determine improvement opportunities for use in future SSMP modifications.

2. InterceptorSystemDescription

Since 1974, Regional San has worked with other local agencies to collect, convey (via an Interceptor System), and treat wastewater (via the Sacramento Regional Wastewater Treatment Plant - SRWTP) for the urbanized parts of Sacramento County, an area covering more than 250 square miles. Today, Regional San owns and operates two main facilities: the Interceptor System and the SRWTP. The Interceptor System conveys wastewater collected by four contributing agencies directly to the SRWTP in Elk Grove: 1) the City of Folsom, 2) the City of Sacramento, 3) the City of West Sacramento, and 4) the Sacramento Area Sewer District (SASD, formerly known as CSD-1).

Regional San maintains 1641 total miles of pipeline. This pipeline is broken up into approximately 110 miles of gravity interceptors with diameters generally ranging from 36 inches to 144 inches and 58 miles of force mains with diameters generally ranging from 16 inches to 66 inches2. Included in the interceptor system are eight pump stations, inverted siphons, flow meters, valve vaults, fall and gate structures. Regional San also owns and incurs the cost of maintaining 3 pumping stations that are operated by the City of Sacramento. The table below provides a breakdown of the interceptor pipelines by decade of construction.

1 Regional San owns 169 total miles of pipeline; however the City of Sacramento maintains approximately 5 miles of it and reports these miles as part of the miles they maintain in their CIWQS Questionnaire. 2 For the purposes of delineating Regional San’s Interceptor System from contributing agencies, Regional San’s system is generally defined as pipes 36 inches and larger. There are some exceptions as Regional San owns and maintains some pipes that are smaller than 36 inches.



Table 2-1: Interceptor System Miles

Decade of Construction Gravity Force Main 1960-69 0.2 2.8 1970-79 5.9 5.9 1980-89 47.6 7.6 1990-99 9.0 0.1 2000-09 43.4 41.4 2010-Present 4.1 0.3 Total 110.3 58.1

3. AuditApproach

This audit, covering from January 1, 2015 through December 31, 2016, is the fourth SSMP Audit performed to meet WDR requirements for completion of an audit a minimum of once every two years. This audit assesses the current state of SSMP programs in accordance with Provision D.13 of the WDR, identifies any deficiencies found in the SSMP, and suggests corrective actions. In addition the audit provides an evaluation of SSMP effectiveness. Regional San intends to use the audit results to improve SSMP efficiency and performance to eliminate sewer overflows and to ensure proper operation and maintenance of its interceptor system.

Regional San staff conducted the audit through a series of meetings with staff involved with implementation of activities required by provisions included in Provision D.13 of the WDR. The Audit Team and Regional San staff supporting the audit interviews and audit process are identified in Table 3-1 and Table 3-2 organized in alphabetical order by last name.

Table 3-1: Audit Team Members

Team Member Department Role Gabe Apgar Operations Support Lead Auditor, Associate Civil Engineer Anna Johnson Operations Support Audit Supervisor, Senior Civil Engineer Mitch Maidrand Operations Support Audit Reviewer, Principal Civil Engineer Christy Warhola Operations Support Audit Reviewer, Associate Civil Engineer



Table 3-2: WDR Audit Interviewees

Name Title Gary Bailey Interceptor Operations &Maintenance (O&M) Superintendent John Bailhache Wastewater Treatment Plant Operations (WTPO) Supervisor Paul Baker Interceptor O&M Supervisor Carolyn Balazs Environmental Specialist Mike Crooks Principal Civil Engineer Charles Duty Environmental Program Manager Andrew Frankel Senior Civil Engineer Kyle Frazier Senior Civil Engineer Anna Johnson Senior Civil Engineer Troy Jurach Interceptor O&M Supervisor Jack Naves Geographic Information System (GIS) Analyst Sharon Sargeant Communications & Media Officer Oscar Starks Interceptor O&M Supervisor Jennifer Swinney Senior Civil Engineer Dean Wyley Principal Civil Engineer

SSMP audit interviews were performed over multiple weeks in March 2017. In addition to the interviews, phone calls and emails were conducted on an as-needed basis. The WDR provision audited and Regional San staff interviewed is documented in Table 3-3:



Table 3-3: Audit Participants

WDR Provision Section

Topics Participants

D.13 (i) SSMP Goal Anna Johnson D.13 (ii) SSMP Organization Anna Johnson D.13 (iii) Legal Authority Carolyn Balazs, Charles Duty D.13 (iv) O&M Program

Mapping Maximo PM Activities Rehab & Replacement Inspection/Condition Assessment Training Spare Parts & Inventory CIP

Jack Naves Dean Wyley Gary Bailey, Dean Wyley Gary Bailey, Kyle Frazier Kyle Frazier, Andrew Frankel Gary Bailey Dean Wyley, Gary Bailey Kyle Frazier, Mike Crooks

D.13 (v) Design and Performance Provisions

Kyle Frazier, Mike Crooks

D.13 (vi) Overflow Emergency Response Plan

Anna Johnson, Gary Bailey, Charles Duty

D.13 (vii) FOG Control Program Anna Johnson D.13 (viii) System Evaluation and

Capacity Assurance Plan Jennifer Swinney, Andrew Frankel, Kyle Frazier

D.13 (ix) Monitoring, Measurement, and Program Modifications

Anna Johnson, Gary Bailey, Dean Wyley

D.13 (x) SSMP Program Audits Anna Johnson D.13 (xi) Communication Program Sharon Sargeant, Anna

Johnson

4. SSMPEffectiveness

Overall, based on analysis of the sanitary sewer overflow (SSO) trends over the past five (5) years and the results of the SSMP audit, the interceptor system program implementation has kept SSOs to a minimum. In the last 5 years, from January 2012 through February 2017, the Regional San Interceptor System has had seven reportable SSOs in the California Integrated Water Quality System (CIWQS) as detailed in Table 4-13. A breakdown of the SSO causes can be seen in Table 4-2.

3 The WDR requires that SSO records be kept for the previous 5 years as a minimum.



Table 4-1: CIWQS Summary of Regional San SSOs January 2012- February 2017

NO. DATE SSO

CATEGORY SSO DESCRIPTION

SSO

VOLUME

(GAL.)

VOLUME

RECOVERED

(GAL.)

VOLUME

REACHED

SURFACE

WATER

(GAL.)

1 7/8/2016 1

N19 (Arden Pump Station) The SSO occurred when flow entered the surge tanks and a valve to the PCF was left open. The flow spilled from the PCF and entered a storm drain.

1,722 299 1,413

2 7/5/2016 3

N51 (New Natomas Force Main) The SSO occurred out of a manhole that contains an ARV. The spill occurred after routine maintenance was performed on the ARV when the ARV drain valve was left open. Spilled onto an unpaved surface.

356 235 0

3 11/13/2014 3

The SSO occurred out of a manhole that contains an ARV. The spill occurred after routine maintenance was performed on the ARV when the ARV drain valve was left open.

750 750 0

4 10/15/2013 3

Backpressure from the maintenance activity bled through a valved off section of pipe and pushed wastewater out of the open access point.

25 20 0

*New Monitoring and Reporting Program Started in September of 2013 includes new category differentiation

5 6/10/2013 2

The SSO occurred out of a manhole due to root intrusion in the pipe and manhole channel downstream of the SSO location.

2 0 0

6 1/28/2013 2

N33 (McClellan Interceptor) Spill occurred out of a manhole due to the size of the storm (50-years) exceeding the design storm of 10-years.

910 0 0

7 12/14/2012 2

N13 (City Interceptor Air Intake Structure) Spill occurred out of a pick hole of a sealed manhole lid under surcharged condition on combined sewer line

365 0 0



Table 4-2: Regional San SSOs Causes January 2012- February 2017

SSO CAUSE SSO COUNT TOTAL VOLUME Maintenance Caused /

Operator Error 4 2,853

Rainfall Exceeded Design 1 910 Surcharged Pipe 1 365 Root Intrusion 1 2

In comparison with other systems of similar size, Fairfield Suisun Sanitation District (FSSD) and Orange County Sanitation District (OCSD), the Regional San Interceptor System has performed comparably well. Table 4-3 provides a comparison of SSO count, total SSO volume, and Category 1 SSO count with FSSD and OCSD. Regional San does not have the fewest amount of SSOs over the last five years; however, Regional San has spilled far less wastewater than its counterparts during that time.

Table 4-3: SSOs by Agency January 2012- February 2017

AGENCY SSO COUNT TOTAL SSO VOLUME CATEGORY 1 SSO COUNT Regional San 7 4,130 1

FSSD 5 770,791 0 OCSD 21 103,480 14

5. ReviewofEffectivenessofSSMPElements

The following sections focus on evaluating the effectiveness of each element of the SSMP.

5.1. Introduction

WDR Requirement: The WDR does not require this section to be part of the SSMP.

Audit Finding: The Introduction provides a detailed overview of the interceptor system including its attributes and characteristics, contributing agencies and its historical background. The Introduction does not include a specific count of pumping stations currently operated and maintained by Regional San.

The Introduction also provides the background of the WDR requirements and Regional San’s approach. The Introduction does not reference WQ 2008-0002-EXEC which establishes the SSO Monitoring and Reporting Program (MRP) and WQ 2013-0058-EXEC which further amends the MRP, however the amending orders are included in Appendix A. Regional San may consider adding a reference to the amending orders in the Introduction.

As the interceptor system ages, the references to the system age with respect to 2013 will become more inaccurate. In the next update of this section, Regional San may want to include a table identifying the miles of interceptors by decade of construction.

Program Manager Response

In the next SSMP update, this section will be updated to (1) include the number of pumping stations currently operated and maintained by Regional San, (2) include all executive orders affecting the SSMP to date, and (3) add a table that lists the interceptor pipelines by decade of construction.



Management Response

Agree with Program Manager Response.

5.2. Element1‐Goal

WDR Requirement: The goal of the Sewer System Management Plan (SSMP) is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent SSOs, as well as mitigate any SSOs that do occur.

Audit Finding: Regional San has the appropriate goals stated in the SSMP.


No exceptions to the audit findings.

Management Response


5.3. Element2‐Organization

WDR Requirement: The Sewer System Management Plan (SSMP) must identify:

a. The name of the responsible or authorized representative as described in Section J of this Order. b. The names and telephone numbers for management, administrative, and maintenance positions

responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation; and

c. The chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services (OES)).

Audit Finding: Regional San has assigned roles and responsibilities for development and implementation of specific measures in the SSMP program. The phone number for Regional San reception desk is listed in Appendix B – Table B-1. The audit did discover the following minor issues with the SSMP organization and related appendices:

Appendix B – Figure B-1: The audit discovered that the hard copy organization chart does not match the online version. In the next SSMP update, Regional San may consider including an updated hard copy version of the organizational chart and reference the online organizational chart for the most current personnel currently assigned to the respective roles.


The WDR SSMP SharePoint site contains the latest files. In the next SSMP update, Figure B-1 in the Appendix will be updated to include the same reference to the SharePoint files.



Management Response


5.4. Element3–LegalAuthority

WDR Requirement: Each Enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to:

a. Prevent illicit discharges into its sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc.);

b. Require that sewers and connections be properly designed and constructed; c. Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or

maintained by the Public Agency; d. Limit the discharge of fats, oils, and grease and other debris that may cause blockages, and e. Enforce any violation of its sewer ordinances.

Audit Finding: The Regional San Consolidated Ordinance contains provisions for sewer use, enforcement, and illicit discharges including prohibited substances and characteristics and prohibited discharge locations. Regional San also employs proper standards and specifications regarding interceptor construction which is further discussed in Element 5 – Design and Performance Provisions. Enforcement of the Consolidated Ordinance is conducted by the Wastewater Source Control Section (WSCS), who uses the WSCS Enforcement Response Plan as the guiding document for enforcement actions.

There have been no updates to the sewer use section of the Consolidated Ordinance in the last three years; therefore, the Legal Authority Section of the SSMP still accurately addresses the ability for Regional San to enforce illicit discharges and violations of the ordinance.



Management Response




5.5. Element4–OperationandMaintenanceProgram

WDR Requirement: The Sewer System Management Plan (SSMP) must include those elements listed below that are appropriate and applicable to the Enrollee’s system:

a. Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities;

b. Describe routine preventive operation and maintenance activities by staff and contractors, including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The Preventative Maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders;

c. Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed for the capital improvement plan;

d. Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained; and

e. Provide equipment and replacement part inventories, including identification of critical replacement parts.

Audit Finding: The following sections describe the audit findings as they pertain to the specific components of the operation and maintenance program.

System Mapping

Regional San meets the System Mapping requirement of the WDR Provision D.13. Regional San maintains an up-to-date map of the interceptor system in GIS which is viewable for all personnel in digital format via the SewerViewer online application. In addition, digital files such as drawings and schematics are available through the Electronic Document Management (EDM) software. Map updates and changes are made through the Document Change Notification (DCN) process. Regional San may consider including a description of the accessibility of the GIS maps via SewerViewer in the next SSMP update.

The interceptors, pumping stations, and inverted siphons are listed in the SSMP, however the pumping stations that are owned by Regional San and operated by the City of Sacramento are not discussed. It is recommended that the SSMP be updated to reference the operating agreements between Regional San and the City of Sacramento as identified in Element 8.




The availability and use of GIS maps is stated in several sections of the SSMP, including the Operations Program. Additional reference to “Sewer Viewer” is not warranted. In the next SSMP update, a reference to the operating agreements between Regional San and the City of Sacramento will be considered.

Management Response


Preventative Maintenance

It is recommended that the reference of “minimal maintenance as a result of age” be removed from the SSMP during the next SSMP update. Age is used as one factor in evaluating the preventative maintenance frequency. While the SSMP does not identify routine cleaning as a preventative maintenance activity, contractor cleaning activities have been conducted on an as-needed basis within the last five years. Due to the self-cleaning characteristics of the interceptor system, Regional San has only experienced one cleaning related SSO in the last five years. The minimal amount of cleaning related SSOs and use of as-needed contractor cleaning activities should be identified as a justification for the current interceptor cleaning strategy in the next SSMP update.

Regional San conducts force main flushing during the dry season for force mains that have experienced historical solids accumulation.

Regional San utilizes Maximo to schedule, track, and document all preventative, predictive, corrective, and emergency maintenance activities associated with the interceptor system. Regional San utilizes the SCADA and PCCS software to monitor and remotely operate the interceptor system.


Regional San has only experienced one SSO in the past five years that might be related to cleaning. The spill was two gallons in volume and occurred from root intrusion in a 6-inch line. As stated in the SSMP, a majority of the pipes Regional San maintains are 36 inches in diameter or greater with less than one half mile of pipe that is 6 inches or less, thus, a 6-inch line is not a common size line that Regional San maintains.

In the next SSMP update, Regional San will consider adding text to document our current cleaning activities which includes contractor cleaning conducted on an as-needed basis citing the minor amount of cleaning related SSOs as a justification for the current interceptor cleaning program.

Management Response




Rehab and Replacement Plan

It is recommended that the reference of the interceptor system age be removed from this SSMP element during the next SSMP update. The system age and corrosion-resistant liners are not a justification for lack of a holistic inspection program as it relates to the WDR requirements.

Regional San has developed an Interceptor Condition Assessment Implementation Plan Phase 1 (ICAIP) in 2015 that was partially implemented. The ICAIP provided a schedule of gravity pipeline inspection for three gravity interceptors and the manholes along those interceptors. The Central Interceptor (N21) was inspected in late 2016 as part of this plan. The remaining interceptors inspections identified in the ICAIP are currently not scheduled to be implemented.

Regional San does not have a formal plan to inspect force mains, pump stations, gate structures, inverted siphons, or other facilities that are not identified in the ICAIP. The need for inspection is triggered by field staff observations during maintenance work, and rehabilitation and repair projects are identified and implemented based on criticality. Regional San O&M staff do conduct surface inspections of historical trouble areas following rain events and readings are taken from some of the cathodic testing stations. There is currently an effort to issue an RFP to have a contractor conduct cathodic testing on the interceptor facilities on a regular basis. It is recommended that Regional San continue the implementation of the ICAIP and develop additional inspection and condition assessment plans for the remaining interceptor system facilities. Regional San has collected some condition assessment data, which is reviewed by Engineering staff; however, a set process or guideline to evaluate this condition assessment data needs to be established.

Regional San maintains a rehabilitation and replacement process that includes a capital funding projection (CFP) over a 10 year window. Rehabilitation and replacement projects on the capital improvement plan (CIP) are reviewed annually to determine their prioritization. These CFP and CIP changes to the rehabilitation and replacement process should be included in the next SSMP update.


In the next SSMP update, reference to the interceptor age will be evaluated and will indicate that age is a criteria used in the rehab and replacement plan. This section will be updated to reflect ongoing condition assessment efforts, as well as any updates to the process for prioritizing rehab and replacement projects.

Management Response

The ICAIP does generally define the asset groups within the Interceptor System and lays out a strategy and logic for screening and prioritizing condition assessment efforts for each. The asset groups do include gravity pipes as well as pressure pipes (including siphons), pump stations, and manholes and structures. An initial screening, prioritizing, and inspection of gravity pipes has been partially implemented starting with the CCTV inspection of the Central Interceptor. The methodology and schedule for implementing assessments on the other asset groups has not yet been determined however the District will develop this plan over the next few years. Also, although not part of a formal plan, staff is developing a scope of work for rehabilitation portions of the N19 - Arden Pump station. The focus is the wet well and related equipment. In a separate but related effort, staff is evaluating the need for pump improvements and repairs at N19.



Training

Regional San provides formal training and on-the-job training for its O&M staff for operational needs, safety compliance, as well as vendor training on an as-needed basis. O&M staff conduct bi-weekly tailgate meetings that cover various safety and training topics. SSO response training is held annually for all O&M staff and PCC supervisors. All training events are documented and tracked by the County’s online Meridian software.

Contractors are made aware of the Sanitary Sewer Overflow Response Plan SSORP during the Access Request (AR) process. Regional San does not conduct mock SSO training events and may consider implementing such an event in the future.


Mock SSO training events are not practical for the size of Regional San’s collection system, and not warranted based on SSO history. Other training events and meetings are conducted annually to coordinate and prepare for emergency response activities including SSO Response Training, Emergency Response Plan updates, wet weather preparation meetings and associated preparation events (e.g. testing emergency generators’ ability to automatically transfer to emergency power).

Management Response


Equipment and Replacement Parts

Regional San maintains an inventory list of spare parts and equipment in Maximo and the spare parts are stored at the SRWTP. The Availability of Critical Equipment (ACE) Table identifies critical parts and equipment. When replacement parts are used, the inventory is replenished by purchasing requests through Maximo.



Management Response




5.6. Element5–DesignandPerformanceProvisions

WDR Requirement:

a. Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems; and

b. Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects.

Audit Finding: Regional San has appropriate design and construction standards and specifications as well as procedures and standards for inspection and testing of new sewers and rehabilitation and repair projects. Regional San utilizes the Interceptor Design Manual, the County of Sacramento Standard Construction Specifications (CSSCS) and the SRCSD Pump Station Design Manual (PSDM).

The Interceptor Standard Specifications are specifications for specialized interceptor needs that are used and developed on a project by project basis, however the Interceptor Standard Specifications were not formally adopted and currently are in draft form. Regional San may consider removing references to the Interceptor Standard Specifications during the next SSMP update, or indicate that they exist in draft form only and that their development is on-going.

Regional San should remove the reference to the interceptor system age as an indicator of immediate rehabilitation needs. Pipelines that are under 35 years old may still be in need of rehabilitation or repair. Pipe age can be used as a tool along with other factors to identify and prioritize pipelines for further inspection or evaluation. Program Manager Response

Regional San prioritized pipelines for further evaluation in the 2012 Interceptor Condition Assessment Plan (ICAP). The 2015 Interceptor Condition Assessment Implementation Plan (ICAIP) provided a schedule of gravity pipeline inspection for three gravity interceptors and the manholes along those interceptors. The Central Interceptor (N21) was inspected in late 2016 as part of this plan. In the next SSMP update, this section will be updated to reflect current practice.

Management Response

The further development of Interceptor Standard Specifications is not currently needed because there are no new interceptor facility construction projects scheduled to occur within the 10-year CFP planning horizon. The need for updating or finalizing such standard specifications will be revisited when there is a need for capital construction projects within the interceptor system. However, if there are larger repair and rehab projects within the next few years, if needed, the Interceptor Standard Specifications will be updated.



5.7. Element6–OverflowEmergencyResponsePlan

WDR Requirement: Each Enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, this plan must include the following:

a. Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner;

b. A program to ensure an appropriate response to all overflows; c. Procedures to ensure prompt notification to appropriate regulatory agencies and other

potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP. All SSOs shall be reported in accordance with this MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The Sewer System Management Plan (SSMP) should identify the officials who will receive immediate notification;

d. Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Emergency Response Plan and are appropriately trained;

e. Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and

f. A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge.

Audit Finding: Regional San maintains an SSO Response Plan (SSORP) as well as a SSO Response Plan Quick Reference (SSORPQR) document. The SSORP and SSORPQR identifies the response procedures, notification and reporting requirements, water quality monitoring procedures, roles, responsibilities and respective contact information. Regional San has recently updated its SSORPQR document in September 2016 and may consider reviewing and updating the SSORP to include current contact personnel and contact information to correspond with the recent SSORPQR update, or include a statement in the SSORP that refers to the SSORPQR as it is more regularly updated.

Regional San conducts an annual wet weather preparation meeting to ensure that the interceptor facilities are prepared for rain events. Each pump station has backup generators available for use in the event of power failure. O&M staff conducts regular generator maintenance and testing on all of its pumping station backup generators.

A PCC supervisor was interviewed regarding the SSMP and SSORP procedures. The PCC supervisor identified a hard copy of the SSORP and SSORPQR in the control room as well as knowledge of the online document location. The PCC supervisor explained the SSO response protocol which corresponded with the steps identified in the SSORP and identified a list of contacts and contact information to be used in the event of an SSO.

The O&M supervisors were also interviewed regarding the SSMP and SSORP process. The O&M supervisors displayed knowledge of the SSORP procedures and indicated steps taken to respond to an SSO. The supervisors also identified where the proper contacts and contact information is located if



needed for an SSO event. The supervisors also indicated that they coordinate an SSO response with SASD to procure a vactor truck for use.


Contact information may change more frequently than SSORP updates. For contact updates, revising the SSORPQR and applicable SharePoint sites is more practical. Staff are notified of these updates during each annual SSORP refresher training.

Management Response


5.8. Element7–FOGControlProgram

WDR Requirement: Each Enrollee shall evaluate its service area to determine whether a FOG control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate:

a. An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG;

b. A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of FOG generated within a sanitary sewer system service area;

c. The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG;

d. Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, BMP requirements, record keeping and reporting requirements;

e. Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance;

f. An identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and

g. Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above.

Audit Finding: Regional San has determined that WDR requirements for a FOG Control Program is not warranted for the Interceptor System. The Consolidated Ordinance does provide legal authority to require FOG control devices if a future FOG control program is implemented. In over 20 years of recorded maintenance history, Regional San has not experienced a FOG related SSO. This is due to the characteristics of the Interceptor System and from the implementation of FOG control programs at Regional San’s satellite agencies. The status of the satellite agencies’ FOG programs are discussed at the contributing agency coordination meetings, which typically occur annually.

Regional San has FOG receiving capabilities at the SRWTP. The FOG station accepts FOG waste from collection trucks and provides a site to properly dispose of FOG generated within Regional San’s service area.





Management Response


5.9. Element8–SystemEvaluationandCapacityAssurancePlan

WDR Requirement: The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate design storm or wet weather event. At a minimum, the plan must include:

a. Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events;

b. Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and

c. Capacity Enhancement Measures: The steps needed to establish a short- and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding.

d. Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the Sewer System Management Plan (SSMP) review and update requirements as described in Section D. 14.

Audit Finding: The following sections describe the audit findings as they pertain to the specific components of the system evaluation and capacity assurance plan.

Evaluation

Regional San partners with the SASD Hydraulic Modeling group to conduct a dynamic flow model, described in the Interceptor Sequencing Study (ISS), as the basis for determining the interceptor system capacity needs. Innovyze’s InfoWorks Integrated Catchment Modeling software is used to develop and execute the model. The flow model takes into account land use information and flow generation parameters from satellite agencies. The flow model is updated periodically to identify any new capacity project needs due to increased development within the service area.

Regional San has experienced one rainfall event in 2013 that exceeded design as well as a surcharged pipe related SSOs in the last five years; however, there are no on-going capacity issues encountered on a regular basis and no capacity related SSOs have been experienced in the last four years.



Design Criteria

In the ISS, Regional San utilized the 2006 New Year’s Storm as the representative 10-year peak flow event in its dynamic flow model. The use of the New Year’s Storm provides Regional San with a realistic capacity simulation that identifies capacity needs in the interceptor system. The hydraulic software can also model based on a synthetic design storm which utilizes the Nolte 6 hour design as an additional design criteria, which was historically used to model and evaluate the system prior to the ISS evaluation and the use of the 2006 New Year’s Storm.

Capacity Enhancement Measures

Regional San has the ability to conduct flow monitoring on an as-needed basis. In the past, flow monitoring studies have been conducted to collect inflow data on select gravity interceptors to identify average wet and dry weather flows. Historical flow data, the ability to conduct ad-hoc flow studies, and the use of a dynamic model provides Regional San with the ability to identify and determine areas of the interceptor system to be evaluated during the capacity assurance process.

Schedule

Regional San currently relies on the 10 year capital funding projections for use on a 5 year capital improvement program list. The CIP list is reviewed annually to determine the priority of upcoming project needs. This has deviated from the use of the Master Plan 2000 and the subsequent 2003 Reconciliation Report as described in the SSMP. Regional San may consider updating the SSMP to reflect these changes in the CFP and CIP process during the next update.


In the next SSMP update, Regional San will consider updating this section to reflect current practice.

Management Response


5.10. Element9–Monitoring,Measurement,andProgramModifications

WDR Requirement: The Enrollee shall:

a. Maintain relevant information that can be used to establish and prioritize appropriate Sewer System Management Plan (SSMP) activities;

b. Monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP;

c. Assess the success of the preventative maintenance program; d. Update program elements, as appropriate, based on monitoring or performance evaluations; and e. Identify and illustrate SSO trends, including: frequency, location, and volume.

Audit Finding: The following sections describe the audit findings as they pertain to the specific components of the monitoring, measurement, and program modifications requirement.



Relevant Information

Regional San retains relevant information used to establish and prioritize SSMP activities. Maximo is utilized to schedule, track, and document all preventative, predictive, corrective, and emergency maintenance activities associated with the interceptor system.

Regional San enters all SSO information into CIWQS and maintains local files containing SSO event information and SSO response documentation and maintains a SSO Response Plan Quick Reference document for internal use.

Regional San utilizes the PCCS to store and track pertinent system data points such as pumping station flows, wet well elevations, and valve positions. Regional San can also develop custom PCCS displays as needed. Interceptor staff also uses the TiPPS system to receive specific alarms (such as high water elevation alarms) encountered at the pump stations.

Regional San utilizes a dynamic hydraulic flow model as the basis for determining the interceptor system capacity needs and retains historical flow data captured during flow studies.

Regional San documents and tracks all training activities in the County’s online Meridian software.

Monitor and Measure

Regional San monitors and measures the SSMP effectiveness by maintaining a prioritized list of Improvement Opportunities that is reviewed on an annual basis. All SSO events have a follow-up debrief with O&M supervisors and the appropriate responsible staff that is used to measure the SSO response effectiveness and identify improvement opportunities.

Reporting software called Actuate utilizes Maximo data to populate tables and graphs that track and display maintenance activities. Scorecard is also a report that utilizes Maximo data to track maintenance activities. These maintenance activities that are monitored and measured include completed, missed, and cancelled activities and identifies the backlog of work for each O&M craft group.

Assess Preventative Maintenance Program

Regional San actively assesses the preventative maintenance program on a consistent basis. The goal for the O&M staff is to complete 80% of its scheduled preventative maintenance activities every month. The SMP Section 4 and ACE table establish criteria for work order priority in Maximo. The O&M Manager 2 and the Interceptor System O&M Superintendent meet once a month to discuss the preventative maintenance program status.

Regional San may consider referencing the SMP and ACE table as the document that identifies the various metrics and data sources used to assess the preventative maintenance program during the next SSMP update.


The ACE Table is referenced under SSMP Element 4 - O&M Program. In the next SSMP update, Regional San will consider adding a reference to the associated SMPs (SMP Section 4) in this section.



Management Response


Update Elements

Regional San updates the SSMP elements based on findings from the Improvement Opportunities identified in the biennial SSMP audits; however, the preventative maintenance program is not updated or modified based on its monitoring and measurement tools and reports.

Regional San has sufficient preventative maintenance tracking tools and reports; however, they are not used to adjust the strategies and approach to optimize maintenance activities. Rarely is the monthly 80% scheduled maintenance completion goal accomplished and there have been no recent staffing level evaluations, The ACE table was recently reviewed and updated in December 2016. As of March 2017, over 88% of all outstanding work orders have a work priority between 31 and 37, signifying Priority 1 Mandatory (Not Corrective) Work4.

The Interceptor System sprawls across vast areas of the Sacramento area and travel time is not accounted for in Maximo. Without tracking this metric, it will be difficult to determine the amount of potential wrench on bolt time O&M staff lose on a daily basis and how that lost time impacts the monthly completion goal. Furthermore, a staffing analysis has not been conducted since 2013 and in addition to the monthly preventative maintenance activities, the O&M staff has a constant backlog of work. Table 5-1 lists the maintenance activity backlog at the end of calendar years 2015 and 2016 as well as the backlog as of this audit.

Table 5-1: O&M Maintenance Activity Backlog Hours by Craft

DATE CONTROLS MECHANIC ELECTRIC

12/29/2015 434.80 1,092.39 1,298.03 12/27/2016 369.60 1,035.38 1,454.86 2/28/2017 283.61 1,339.65 1,637.85


Defer to Management response.

Management Response

The Interceptor O&M team has mobile work crews composed predominantly of Mechanics. A wave of attrition impacted this class for the last 5 years, however staffing has recently returned to almost full levels. Regional San probates all crafts including Mechanics through its central shops at the treatment Plant in Elk Grove. Following probation, reassignments to the Interceptor team are considered.

Regional San regularly monitors and evaluates its maintenance program. In 2007, the maintenance supervisors populated the computerized maintenance management system (CMMS) with preventive maintenance (PM) activities. However, the PMs added to system were based on legacy information therefore the information continues to be updated and refined. A consultant contract is being developed to conduct a reliability centered maintenance (RCM) analysis to validate and streamline the workload which

4 Based on Maximo data as of March 15, 2017 for N15, N17, N19, N20, N40, N50, N51, N52, N53, and S33.



will lead to optimized PM activities. This analysis should be complete in about 12 months and the results will be incorporated into CMMS.

GPS travel time data has been collected but it is not fully utilized. An analysis will be completed to determine if schedulable travel time should be added to the preventive maintenance program to compensate for lost wrench on bolt time.

Identify and Illustrate SSO Trends

Regional San identifies and illustrates SSO trends. Table 4 of this document identifies every SSO event date, location, and volume from the last five years and is updated during each SSMP audit. Regional San’s entire SSO history can be obtained online via CIWQS. SSOs are also displayed in the Scorecard software and publicly displayed Service Levels show Category 1 spills. SSOs are also illustrated via a GIS layer that can be viewed on the SewerViewer software made available to all Regional San staff.



Management Response


5.11. Element10–SSMPProgramAudits

WDR Requirement: As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee’s compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them.

Audit Finding: Regional San conducts SSMP Program Audits on a biennial basis. Regional San conducted an internal audit in 2011, 2013, and 2015. All previous audits are kept on file and are available via Regional San’s website. Past audits have determined which programs Regional San manages and their findings as they relate to the WDR requirements. The 2015 audit identified areas of deficiency and provided a table of Improvement Opportunities and target completion dates.

This audit will serve as the 2017 audit which falls within the WDR requirement of conducting an SSMP audit every two (2) years. The 2017 audit contains steps to correct deficiencies and identifies SSMP updates for Regional San consideration that reflect the current programs and management of the interceptor system. Regional San should consider adding an audit log to the SSMP to document the dates past audits were performed and the schedule for future audits.


In the next SSMP update, Regional San will consider adding an Audit Log to show when past audits were completed.



Management Response


5.12. Element11–CommunicationsProgram

WDR Requirement: The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented.

The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee’s sanitary sewer system.

Audit Finding: Regional San properly maintains its website and Facebook page to include any notifications and announcements pertaining to the interceptor system. A vast amount of documents pertaining to the interceptor system, SSMP, and SSORP are maintained online.

Regional San should consider steps to ensure that the most current documents are available online and to update the SSMP to properly reflect Regional San’s communication strategies with satellite agencies. Currently, Regional San communicates with satellite agencies on an annual basis or more often as needed. Regional San may also consider referencing the contributing agencies webpage that lists each satellite agency and their points of contact in the next SSMP update.


As stated above, Regional San uses various social media in its Communications Program. In the next SSMP update, Regional San will consider adding references to the SharePoint page where operating agreements and contact lists for the contributing agencies are listed for internal use, as well as references to the various social media use for public communication.

Management Response


6. StrengthsandImplementationAccomplishments

Documenting the strengths and implementation accomplishments of the SSMP is an important component of the audit findings. Regional San should both recognize the areas of strength in interceptor system management as well as continue building upon success in these areas. Table 6-1 includes the strengths and implementation accomplishment that were identified during the audit.



Table 6-1: Strengths and Implementation Accomplishments

NO. WDR PROVISION STRENGTH AND IMPLEMENTATION ACCOMPLISHMENTS

1 D.13(ii) - Organization Regional San has assigned roles and responsibilities for development and implementation of the SSMP.

2 D.13(iii) – Legal Authority Regional San has ordinances and design guidelines providing the authority to:

Prevent illicit discharges; Require interceptors to be properly designed

and constructed; Limit discharge of fats, oils, and grease, and; Enforce violations of sewer ordinances via

the WSCS Enforcement Response Plan. 3 D.13(iv) – Operations and

Maintenance Program Regional San currently:

Maintains an up-to-date map of the interceptor system in GIS and properly update it as needed via the DCN process.

Provides access to digital files and schematics via EDM.

Utilizes EDS to monitor and remotely operate the interceptor facilities as-needed.

Documents, tracks, and schedules all maintenance activities in Maximo.

Uses the ACE table to identify critical parts and maintains spare parts inventory.

Documents all training events and classes in Meridian.

Developed the ICAIP for interceptor gravity pipe condition assessment.

Conducts capital funding projections on a 10 year window and prioritizes projects on an annual basis.

4 D.13(v) – Design and Performance Provisions

Regional San utilizes appropriate design and construction standards and specifications.

5 D.13(vi) – Overflow Emergency Response Plan

Regional San maintains an SSORP and recently updated the SSORPQR that identifies all roles, responsibilities, procedures and points of contact needed during an SSO event. Regional San conducts an annual wet weather preparation meeting prior to the wet season. Staff is knowledgeable of the SSO response procedures.

6 D.13(vii) – FOG Control Program Regional San provides historical trends justifying that a FOG Control Program is not warranted for the interceptor system.



NO. WDR PROVISION STRENGTH AND IMPLEMENTATION ACCOMPLISHMENTS

7 D.13(viii) – System Evaluation and Capacity Assurance Plan

Regional San maintains a dynamic flow model that identifies capacity needs for the interceptor system. Regional San has not experience a capacity related SSO in the last four (4) years.

8 D.13(ix) – Monitoring, Measurement, and Program Modifications

Regional San has developed multiple reports that utilizes Maximo data. The reports monitor and track maintenance activities and identify backlog work for each O&M craft. Regional San enters all SSO events into CIWQS and illustrates each SSO in GIS and other pertinent reports.

9 D.13(x) – SSMP Program Audits Regional San has conducted SSMP audits every two (2) years since 2011 and maintains a list of SSMP Improvement Opportunities that is reviewed annually. Each audit document is available on-line.

10 D.13(xi) – Communication Program Regional San utilizes its website and Facebook page to deliver notifications and announcements to the public. Regional San meets with its satellite agencies annually.



7. OtherFindingsandImprovementOpportunities

This section includes other findings and opportunities for improvements not linked directly to WDR requirements. These are ideas which resulted from the audit and are presented for Regional San’s consideration.

Table 7-1: Other Findings and Improvement Opportunities

NO. WDR PROVISION FINDING OPPORTUNITY 1 None – SSMP

Document The online version on the intranet has dead links and/or links that point to irrelevant pages.

Review and update all online links.

2 None – SSMP Document

Not all acronyms used in the SSMP are listed in the acronyms and abbreviations list.

Update acronyms and abbreviations list.

3 None - Introduction The Introduction does not reference the executive orders that generate changes to the WDR or the current collection system mileages and attributes.

Update the Introduction to properly reference the executive orders that generate changes to the WDR as well as to reflect the current interceptor system attributes.

4 None - Introduction The Introduction does not include a specific count of the pumping stations maintained and operated by Regional San.

Add the count of pumping stations currently maintained and operated.

5 None - Introduction The reference to the interceptor system age as of 2013 are no longer valid.

Add a table that lists the interceptor pipelines by decade of construction.

6 D.13(iv) – Operations and Maintenance Program

Interceptor system in GIS is viewable for all personnel via the SewerViewer online application.

Add a description of the accessibility of the GIS maps via SewerViewer.

7 D.13(x) – SSMP Program Audits

Past and future SSMP audit dates are not provided.

Add an audit log to the SSMP.

8 D.13(xi) – Communication Program

Social media is used to provide notifications and announcements.

Update the SSMP to properly reflect the use of social media in its Communication Program.


Response provided within the applicable section of this audit.

Management Response
