REPORT TO COUNCIL
SUBJECT
Title
Approval of the 2025 Sewer System Management Plan
Report
BACKGROUND
On December 6, 2022, the State Water Resources Control Board (SWRCB) adopted new Statewide Waste Discharge Requirements (WDRs) for sanitary sewer systems under Order WQ 2022-0103-DWQ (General Order). These updated requirements mandate the development and/or revision of a Sewer System Management Plan (SSMP) every six years. Under the previous General Order issued in 2006, SSMPs were required to be updated every five years.
The SWRCB requires each agency’s governing body to approve its SSMP in a public meeting. The 2020 SSMP (link in Attachment 1) was approved by Council on May 19, 2020 (RTC 20-0490.)
The General Order requires public agencies that own or operate sanitary sewer systems to develop and implement an SSMP aimed at reducing sanitary sewer spills (spills). It also mandates agencies to report all spills to the Board. The SSMP must include 11 key elements demonstrating how the agency constructs, manages, operates, and maintains its sanitary sewer system. These elements, outlined in the attached 2025 SSMP update, include:
1. SSMP Goals
2. Organizational Structure & Communication Chain
3. Legal Authority to Operate and Maintain the Sewer System
4. Sewer Collection System Operation & Maintenance Program
5. Design and Performance Provisions for the Sewer Collection System
6. Sewer Overflow Emergency Response Plan
7. Sewer Pipe Blockage Control Program
8. Collection System Evaluation & Capacity Assurance Plan
9. Monitoring, Measurement & Plan Modifications
10. SSMP Internal Audits
11. Public and Stakeholder Communication Program
Key Updates since the 2020 SSMP are as follows:
• The term “SSO”, Sanitary Sewer Overflow, has been replaced with “spill.”
• The FOG Control Program has been expanded into a broader Blockage Control Program.
• In June 2023, the City published a Spill Emergency Response Plan (SERP) to fulfill a General Order requirement; this document is included as an appendix to the SSMP.
• In December 2022, the City published a Wastewater Collection System Model Expansion and Capacity Analysis (Capacity Analysis) to meet another General Order requirement; this document is also included as an appendix to the SSMP.
Per the General Order, going forward, the City must update the SSMP every six years, with the next update scheduled for 2031.
EXISTING POLICY
General Plan Goal EM-6: Effective Wastewater Collection System
Continue to operate and maintain the wastewater collection system so that all sewage and industrial wastes generated within the City are collected and conveyed under safe and sanitary conditions to the Water Pollution Control Plant.
ENVIRONMENTAL REVIEW
Implementation of the SSMP will apply to sanitary sewer collection systems that constitute "existing facilities" of the City or may require the installation of minor sewer system facilities which will involve either minor alterations to existing facilities, or repair or replacement of existing facilities involving negligible or no expansion of sewer capacity. Such activities are exempt from review under the California Environmental Quality Act. (CEQA Guidelines 15301, 15302.) The adoption of the SSMP is also exempt from environmental review because it requires the implementation of management operations programs and plans to enhance and protect the environment by limiting the occurrence of spills in the City. (CEQA Guideline 15308.).
DISCUSSION
The 2025 SSMP (Attachment 2), prepared by the City’s Environmental Services Department (ESD), updates the 2020 SSMP to ensure compliance with the General Order. It includes formatting improvements, clarifications, and modifications to meet updated requirements. Key provisions include:
• Development and Implementation of SSMPs: Sewer agencies must create and enforce SSMPs to ensure the proper management, operation, and maintenance of their sanitary sewer systems.
• Spill Reporting: All sanitary sewer spills must be reported to the State Water Board’s online California Integrated Water Quality System (CIWQS) Sanitary Sewer System Database. The order categorizes spills to standardize reporting and response efforts.
• Electronic Mapping Requirements: Starting July 1, 2025, sewer agencies are required to submit geospatial data delineating their sanitary sewer system service area boundaries. This information must be updated annually to reflect any changes.
The proposed City of Sunnyvale SSMP aims to:
• Reduce, prevent, and mitigate the impacts of spills.
• Ensure adequate capacity to convey all flows, including peak flows.
• Respond effectively to public concerns and collaborate with local, state, and federal agencies to reduce, mitigate, and report spills.
• Identify, prioritize, and renew or replace sewer infrastructure for long-term reliability.
• Conduct regular, proactive maintenance to remove roots, debris, and fats, oils, and grease (FOG) in blockage-prone areas.
• Maintain high standards for new public and private sewer construction.
Sanitary sewer overflows contain pathogenic organisms and toxic pollutants. When spills occur, untreated sewage can enter streets, properties, and storm drains, potentially contaminating local waterways, endangering public health, and harming aquatic life. Major causes of spills include:
• Root and grease blockages in sewer lines
• Damaged sewer pipes or manhole failures
• Pump station outages or failures
• Excessive stormwater or groundwater infiltration
• Aging sewer infrastructure
The Table below summarizes the causes of reported spills over the last 10 years.
Spills Trends (2015-2024)
|
|
2015 |
2016 |
2017 |
2018 |
2019 |
2020 |
2021 |
2022 |
2023 |
2024 |
Percent of Total |
|
Roots |
3 |
2 |
4 |
4 |
5 |
4 |
3 |
5 |
3 |
3 |
64% |
|
Debris |
0 |
1 |
0 |
0 |
0 |
0 |
0 |
2 |
0 |
1 |
8% |
|
FOG |
0 |
0 |
2 |
1 |
1 |
2 |
1 |
3 |
2 |
2 |
24% |
|
Pipe Structural Issue |
0 |
0 |
0 |
0 |
1 |
0 |
0 |
1 |
1 |
0 |
4% |
|
Other |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
1 |
0 |
0 |
|
Total Spills |
3 |
3 |
6 |
5 |
7 |
6 |
4 |
11 |
7 |
6 |
100% |
The 2025 SSMP will be posted on the City’s website following Council approval.
Adopting the 2025 SSMP ensures that Sunnyvale remains in compliance with the State Water Board’s requirement to update and certify the SSMP. Ongoing implementation and monitoring of the 2025 SSMP will enhance sewer system management and help reduce spills in the City.
FISCAL IMPACT
There is no fiscal impact at this time. Approval of the revised SSMP does not require additional funding.
PUBLIC CONTACT
Public contact was made by posting the Council meeting agenda on the City's official-notice bulletin board at City Hall, at the Sunnyvale Public Library and in the Department of Public Safety Lobby. In addition, the agenda and this report are available at the City Hall reception desk located on the first floor of City Hall at 456 W. Olive Avenue (during normal business hours), and on the City's website.
RECOMMENDATION
Recommendation
Approve the 2025 Sewer System Management Plan in its entirety to meet State Water Board requirements.
Levine Act
LEVINE ACT
The Levine Act (Gov. Code Section 84308) prohibits city officials from participating in certain decisions regarding licenses, permits, and other entitlements for use if the official has received a campaign contribution of more than $500 from a party, participant, or agent of a party or participant in the previous 12 months. The Levine Act is intended to prevent financial influence on decisions that affect specific, identifiable persons or participants. For more information see the Fair Political Practices Commission website: www.fppc.ca.gov/learn/pay-to-play-limits-and-prohibitions.html
An “X” in the checklist below indicates that the action being considered falls under a Levine Act category or exemption:
SUBJECT TO THE LEVINE ACT
___ Land development entitlements
___ Other permit, license, or entitlement for use
___ Contract or franchise
EXEMPT FROM THE LEVINE ACT
___ Competitively bid contract*
___ Labor or personal employment contract
___ Contract under $50,000 or non-fiscal
___ Contract between public agencies
_X_ General policy and legislative actions
* "Competitively bid" means a contract that must be awarded to the lowest responsive and responsible bidder.
Prepared by: Mansour Nasser, Water & Sewer Systems Division Manager
Reviewed by: Ramana Chinnakotla, Director, Environmental Services
Reviewed by: Sarah Johnson-Rios, Assistant City Manager
Approved by: Tim Kirby, City Manager
ATTACHMENTS
1. 2020 Sewer System Management Plan (link)
2. 2025 Sewer System Management Plan