Audit Findings and Recommended Corrective Actions
SSMP Element Recommended Corrective Action or Opportunity for Improvement Finding Category Schedule Element 1 – Goal and Introduction Update the SSMP Introduction to reiterate the goal of the SSMP to match the language in the Order. B-minor 5/2/2025
Element 1 – Goal and Introduction Update the SSMP Introduction to reference the reissued General Order. B-minor 5/2/2025 Element 1 – Goal and Introduction
Update the SSMP Introduction to include a plan update schedule with milestones for implementation of planned activities to minimize sanitary sewer spills.
B-minor 5/2/2025
Element 1 – Goal and Introduction
Update the Plan Introduction to include a description of the locations of all City-owned sewer system assets as required by the Order. Update the Plan Introduction with accurate statistics on the size of the population and community served, the size of the sanitary sewer system; including, total length in miles, length of gravity mainlines, length of pressurized force mains, number of pump stations and number of siphons. Align the information reported with the information that is provided in CIWQS.
B-minor 5/2/2025
Element 1 – Goal and Introduction Update the Plan to include all data management systems being used and how they are used for management of the City’s sanitary sewer system. B-minor 5/2/2025 Element 2 - Organization Update the plan to include the name and contact information of the Legally Responsible Official as required in Section 5. B-minor 5/2/2025 Element 2 - Organization
Update the website to include the Appendix with the position titles, telephone numbers, and email addresses of the people responsible for implementing elements of the Plan. To avoid including contact information for each individual responsible, add a statement to the website stating that if there are any comments, questions, or concerns regarding a specific element of the Plan, contact a specific number and email address.
B-minor 5/2/2025
Element 2 - Organization Break down the Plan by element and assign positions responsible for each element on of the plan. B-minor 5/2/2025
Element 3 – Legal Authority
Update the Plan to document the City’s procedure to obtain easement accessibility agreements for specific locations requiring operations and maintenance when needed for maintenance access.
B-minor 5/2/2025
Element 4 – Operation and Maintenance Program Update the Plan to mention the storm drain system mapping is available and updated on the GIS mapping tool. B-minor 5/2/2025
Element 4 – Operation and Maintenance Program Update the plan with the contact information of the Legally Responsible Official to request up-to-date maps of the system. B-minor 5/2/2025 Element 4 – Operation and Maintenance Program
Update the SSMP to include a schedule for how often sections of sewer are being cleaned, how priority sewer areas are identified and how the cleaning schedule differs for the priority sewer areas.
B-minor 5/2/2025
Element 4 – Operation and Maintenance Program Update the Plan to include a plan for closed-circuit television (CCTV) inspection; specify that inspections occur every five years. B-minor 5/2/2025 Element 4 – Operation and Maintenance Program Update the plan to describe how CCTV data is used to adjust sewer pipeline maintenance schedules. B-minor 5/2/2025
Element 4 – Operation and Maintenance Program
Update the Plan to document the system being used to store all CCTV data and the type of data it documents, including system areas/ components prone to root-intrusion potentially resulting in backup and/or failure.
B-minor 5/2/2025
Element 4 – Operation and Maintenance Program Update the Plan to specify that staff is trained on the Spill Emergency Response Plan on a regular basis. B-minor 5/2/2025
Element 4 – Operation and Maintenance Program Update the Plan to include the use of regular practice drills to help staff practice the procedures in place in case of an emergency. B-minor 5/2/2025 Element 4 – Operation and Maintenance Program Update the Plan to include training for the estimation of spill volumes for field operators. B-minor 5/2/2025
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Audit Findings and Recommended Corrective Actions
Element 4 – Operation and Maintenance Program Update the Plan to include description of staff training for CIWQS data updates. B-minor 5/2/2025
Element 4 – Operation and Maintenance Program
Update the Plan to include an inventory of sewer system equipment, including the identification of critical replacement and spare parts, or add the required information to the website.
B-minor 5/2/2025
Element 5 – Design and Performance Provisions
Under ‘Inspection and testing Standards’, update the name of Greenbook 2012 to be “Construction Standards and Specifications Sewer Design Guidelines - 2012.”
B-minor 5/2/2025
Element 5 – Design and Performance Provisions
Update the Plan to include more information on how feedback is collected from designers, contractors, project managers, construction managers, and engineers during capital improvement projects.
B-minor 5/2/2025
Element 6 – Spill Emergency Response Plan
Update “Reporting Requirements for City of Burbank” flowchart to say reporting to LA County Department of Public Health shall be within 15 minutes.
B-major 5/2/2025
Element 6 – Spill Emergency Response Plan
Update the box to say Department of Public Health (DPH) instead of DHS.
Update the “Reporting Requirements for the City of Burbank” flowchart to indicate that in a Category 2 spill, the Office Lead shall report the spill to OES within two hours, RWQCB within two hours unless DPH and OES have been contacted, and CIWQS as soon as possible but later than within three business days.
B-minor 5/2/2025
Element 6 – Spill Emergency Response Plan
Update the Spill Response Plan to define the term “aware.” Defining the term “aware” holds the city responsible for promptly reporting the spill and adequately addressing the issue. Consider adding procedure to warn the RWQC if there is a potential for a spill to reach the drainage system or water of the state prior to occurrence of the event.
B-minor 5/2/2025
Element 6 – Spill Emergency Response Plan Update the SSMP to include how the City uses traffic and crowd control devices consistent with the Watch manual in the case of a spill. B-minor 5/2/2025 Element 6 – Spill Emergency Response Plan
Update the SSMP or Sanitary Sewer Overflow Emergency Response Plan to include a procedure to contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system.
B-minor 5/2/2025
Element 6 – Spill Emergency Response Plan
Update the Spill Emergency Response Plan to document the steps the City takes to clean/disinfect the street while taking care not to impact beneficial uses of water of the State.
B-minor 5/2/2025
Element 7 – Sewer Pipe Blockage Control Program Update the Plan to include procedures for evaluating the sanitary sewer system for blockages due to rags and debris. B-minor 5/2/2025 Element 7 – Sewer Pipe Blockage Control Program Update the Plan to say bi-weekly, instead of monthly. B-minor 5/2/2025 Element 7 – Sewer Pipe Blockage Control Program
Update the Plan to mention that extensive outreach efforts are ongoing.
Update the Plan to only include relevant outreach methods, as DVDs are no longer used.
B-minor 5/2/2025
Element 7 – Sewer Pipe Blockage Control Program
Update the plan to include a schedule for public outreach programs, include how often the City’s Recreation guide is distributed and how the City’s Industrial Source Reduction and Control Program is enforced.
B-minor 5/2/2025
Element 7 – Sewer Pipe Blockage Control Program
Update the Plan to include the most up-to-date information on where the City disposes of fats, oils and grease, include locations for FOG disposal that are accessible to the public. Where appropriate, reference the County of Los Angeles grease collection program.
B-minor 5/2/2025
Element 7 – Sewer Pipe Blockage Control Program Update the Plan to include design standards for such removal devices. B-minor 5/2/2025 Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to move this section to Chapter 8 of the updated Plan. B-minor 5/2/2025 Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include procedures for evaluating the sanitary sewer system assets utilizing best management practices and technologies available.
B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include how the City uses CCTV and SmartCovers to evaluate its sanitary sewer system. B-minor 5/2/2025
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Audit Findings and Recommended Corrective Actions
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include the City’s procedure for how many miles of sewer is being evaluated and the timeline for which the evaluation is being completed.
B-major 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include the appendices or with a procedure to obtain the appendices easily. B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include a procedure of prioritizing the condition assessment of system areas within the vicinity of surface waters, steep terrain, and environmentally sensitive areas.
B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to a procedure for prioritizing areas with high environmental consequences if vulnerable to collapse, failure, blockage, capacity issues or other system deficiencies.
B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include a procedure for identifying sewage that may enter water of state or a justification for why it is unnecessary. B-minor 5/2/2025 Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to include the procedure for maintaining documents and recordkeeping of system evaluation and condition assessment inspections and activities.
B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the SSMP to document a procedure the City will use to identify system assets vulnerable to direct and indirect impacts of climate change. B-minor 5/2/2025 Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the SSMP to incorporate the System Evaluation and Capacity Assurance Plan (SECAP) update. B-major 11/2/2027
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to document how the findings of sewer condition assessments and capacity assessments are used to prioritize corrective actions within the City. Prioritization must consider the severity of the consequences of the potential spills.
B-major 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the plan to include a description of joint collaboration between operation and maintenance staff, and engineering staff/consultants during CIP development.
B-minor 5/2/2025
Element 8 – System Evaluation, Capacity Assurance and Capital Improvements Update the Plan to describe the City’s approach to monitoring and validating the need for capital improvements included in the System Evaluation and Capacity Assurance Plan not funded in the City’s 5-year capital improvement plan.
B-minor 5/2/2025
Element 9 – Monitoring, Measurement, and Program Modifications Update the SSMP to separately discuss these topics. B-minor 5/2/2025 Element 9 – Monitoring, Measurement, and Program Modifications Update the Plan to provide more clarity on how the success of the preventive maintenance program is assessed. B-minor 5/2/2025
Element 10 – SSMP Internal Audits This audit will serve as the 2024 internal audit required by the reissued General Order. A 11/2/2024
Element 10 – SSMP Internal Audits Update the Plan to say program audits are required to be uploaded to the CIWQS Sanitary Sewer System Database every three years. B-minor 5/2/2025 Attachment 2 - Page 3
Audit Findings and Recommended Corrective Actions
Element 11 – Communication Program
Update the Spill Emergency Response Plan to include how the City communicates to the public the impacts of sanitary sewer spills and refer to the Spill Emergency Response Plan within the Sanitary Sewer Management Plan. Include notification methods such as posting signage or updating the City’s website with information on beach closures and water quality issues.
B-minor 5/2/2025
Element 11 – Communication Program Update the Plan to include quarterly and annual reports being exchanged between entities and regular technical group meetings. B-minor 5/2/2025 Element 11 – Communication Program
The City should consider updating the City website to provide contact information for public input on the Sanitary Sewer Maintenance Overflow page and updating the Plan with the procedure for receiving public comments and input on the Sanitary Sewer Management Plan.
B-minor 5/2/2025
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