REPORT TO COUNCIL
SUBJECT
Title
Approve Revised 2015 Sewer System Management Plan (SSMP)
Report
BACKGROUND
On May 2, 2006, the State Water Resources Control Board (Board) adopted Order No. 2006-0003 - Statewide General Waste Discharge Requirements (GWDR) for Sanitary Sewer Systems. The Order requires public agencies that own or operate sanitary sewer systems to develop and implement a SSMP aimed at reducing sanitary sewer overflows (SSOs). It also requires these agencies to report all SSOs to the Board. The SSMP must include 11 elements demonstrating how the agency constructs, manages, operates and maintains its sanitary sewer system. These elements are described in the attached revised SSMP and are summarized below:
1. Goals of the SSMP
2. Organization and chain of communications for SSMP
3. Legal Authority to operate and maintain its sewage collection system
4. Sewer Collection System Operation & Maintenance Program
5. Sewer Collection System Design and Performance Provisions
6. Sewer Overflow Emergency Response Plan
7. Fats, Oil and Grease Control Program
8. Collection, System Evaluation and Capacity Assurance Plan
9. Monitoring, Management and Plan Modifications
10. SSMP Program Audits
11. Communication Program with Public and Stakeholders
The Order required that the governing body for each agency approve its agency's SSMP at a public hearing. Council approved the SSMP on September 11, 2012.
On July 26, 2013, the State Water Board's Executive Director issued a revised Monitoring and Reporting Program (MRP) that became effective on September 9, 2013. The revised MRP required staff to make changes to the 2012 SSMP for monitoring and reporting SSOs. In addition, the GWDR requires that the SSMP be updated and recertified at least every five years.
This report recommends the adoption of the revised SSMP in its entirety to meet State Board's MRP requirements.
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 SSOs in the City. (CEQA Guideline 15308.) .
DISCUSSION
Sanitary sewers often contain high levels of pathogenic organisms and toxic pollutants. When overflows of the system occur, untreated sewage can flow into streets, onto properties, and through the storm drain system into local waterways. Consequently, SSOs have the potential to pollute surface water and groundwater, threaten public health, adversely affect aquatic life and impair the recreational use and aesthetic enjoyment of surface waters. There are many causes of SSOs. Some of the more common causes of SSOs include grease and root blockages in sewer lines, sewer line damage, manhole structure failures, pump station outages or failures, excessive storm or ground water inflow and infiltration, sewer system aging, various operation and maintenance issues and/or insufficient capacity. Many SSOs are preventable with effective management, operations and maintenance of the sewer system. The purpose of the City's SSMP is to implement source control measures and improve the management, operation and maintenance of the sewer system in order to reduce the number of SSOs and mitigate the impacts of the SSOs that do occur.
The Environmental Services Department (ESD) has prepared the City's revised SSMP (Attachment 1) in compliance with the new MRP requirements. Attachment 2 contains the list of revisions made to the 2012 Plan. The revised plan will be posted on the City's website after Council approval.
The following are the highlights of the changes in the revised 2015 SSMP:
1. Change in Notification Requirement for spills that reach surface water:
- Three notification calls were required (California Office of Emergency Services, Regional Water Quality Control Boards, and local Health Departments). Required notification has been changed to call California Office of Emergency Services (Cal OES) only since Cal OES notifies the Regional Water Quality Control Boards and local Health Departments when a spill notification is received.
- Elimination of requirement to submit a certification to Regional Water Quality Control Boards within 24 hours of making notification calls.
- Requiring notification calls for only spills of 1,000 gallons or more. Notification of Cal OES was required for all spills to surface water.
- Addition of requirement to update Cal OES when there are substantial changes to previously reported spill volume estimates or impacts.
2. Defined new spill categories and refined spill report fields:
- Replaced spill Categories 1 and 2, with Categories 1, 2, and 3. Spills are now classified as follows:
- Category 1 - Spills of any volume that reaches surface water
- Category 2 - Spills greater than or equal to 1,000 gallons that do not reach surface water
- Category 3 (formerly Category 2) - Spills less than 1,000 gallons that do not reach surface water
All spills to surface water will be in a distinct category with this change.
3. Addition of requirement to submit a technical report within 45 days of the end date for spills to surface water over 50,000 gallons.
4. Addition of requirement to develop a Water Quality Monitoring plan to be implemented within 48 hours after initial notification for spills where 50,000 gallons or more reach surface water.
5. Addition of requirement to submit an electronic copy of Sewer System Management Plan (SSMP) or provide the web address where SSMP is posted.
6. Addition of enhanced record keeping requirements.
7. Addition of a 120-day time limit for amending and re-certifying spill reports.
The City is required to monitor implementation and effectiveness of the SSMP. Various
performance indicators related to the implementation of the SSMP are reported to City Council as part of the annual budget process.
The City is also required to update and recertify the SSMP at least every five years. Future SSMP revisions will be brought forward to the City Council for approval .and recertification as necessary.
FISCAL IMPACT
There is no fiscal impact from adoption of the revised SSMP.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City's official-notice bulletin board outside City Hall, at the Sunnyvale Senior Center, Community Center and Department of Public Safety; and by making the agenda and report available at the Sunnyvale Public Library, the Office of the City Clerk and on the City's website.
ESD conducts ongoing public outreach and education to residents and businesses related to sanitary sewer overflows, preventing grease blockages and Best Management Practices for handling of grease waste. Residential education on the negative impacts of discharging fats, oil, and grease (FOG) into the sanitary sewer system includes distribution of flyers, information at community events and bill inserts. Additionally, ESD inspects all food service facilities annually for compliance with grease removal device maintenance requirements, and distributes educational materials during these inspections. The Community Development Department also conducts the plan checks for all new and remodeling restaurants and other food service facilities to determine proper grease removal device sizing
ALTERNATIVES
1. Approve the revised 2015 Sewer System Management Plan in its entirety to meet State Board requirements.
2. Provide other direction to staff.
RECOMMENDATION
Recommendation
Approve the revised 2015 Sewer System Management Plan in its entirety to meet State Board requirements.
Staff
Prepared by: Mansour Nasser, Water & Sewer Systems Division Manager
Reviewed by: John Stufflebean, Director, Environmental Services Department
Reviewed by: Robert A. Walker, Assistant City Manager
Approved by: Deanna J. Santana, City Manager
ATTACHMENTS
1. Sewer System Management Plan, May 2015
2. List of Significant Revisions