Cities Index.
Attachment 2 - Sewer System Management Plan (SSMP)

Foster City City Council
August 18, 2025

Document
Attachment 2 - Sewer System Management Plan (SSMP)
Meeting
August 18, 2025
Body
Foster City City Council
Original file
1.6 MB
Text extracted from the city's file for reading and search. Open the original on fostercity.primegov.com. That file is the official record.

Sewer System Management Plan (SSMP)
2025 Update
Sanitary Sewer Collection System for
Waste Discharge ID (WDID): # 2SSO10135
Foster City and Estero Municipal Improvement District

REVIEWED AND APPROVED BY:

Frank Schoening, Maintenance Superintendent
Legally Responsible Official
Foster City and Estero Municipal Improvement District
Sanitary Sewer Collection System
(includes Element Development Plans & Schedules)

Date Signed

THIS PAGE INTENTIONALLY LEFT BLANK

SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. COPY THIS PAGE AS NEEDED Revision
Date
SSMP
Section
Approval
Date Description of Change/Revision Made Initials

SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. COPY THIS PAGE AS NEEDED Revision
Date
SSMP
Section
Approval
Date Description of Change/Revision Made Initials

LETTER OF COMPLIANCE

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page i

Foster City/Estero MID
Att: Frank Schoening
Legally Responsible Official (LRO)
Public Works Department, Maintenance Division
100 Lincoln Centre Drive
Foster City, CA 94404

Dear Mr. Schoening,

We are pleased to present the new 2025 Sewer System Management Plan (SSMP) Update developed in partnership with the management of Foster City and Estero Municipal Improvement District (EMID). The 2025 Update meets and exceeds compliance with the WDR (State Water Board, Water Quality Order No. 2022 -0103-DWQ, Attachment D -10 and Specifications 5.4). The 2025 SSMP has been completely revised to harmonize with industry standard guidelines and incorporates the City and EMID’s latest SSMP Audit findings.

The 2025 SSMP is a declaration of what the City and EMID are doing to demonstrate full compliance with the WDR. Attachment A of the WDR (page A-4), states “A sewer system management plan is a living document an Enrollee develops and implements to effectively manage its sanitary sewer system(s) in accordance with this General Order.” We suggest that the City and EMID review the SSMP on a regular basis, and as required by the WDR, continuously document changes to the SSMP in a change log attached to the Plan.

We look forward to assisting the City and EMID wherever necessary to fully implement the 2025 SSMP Update.

Sincerely,

James Fischer, P.E.

Principal, Fischer Compliance LLC
Credentialed U.S. EPA NPDES Compliance Inspector

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page ii

TABLE OF CONTENTS
INTRODUCTION ............................................................................................................................................................. 1 SSMP Organization ..................................................................................................................................................................... 2 Abbreviations and Acronyms...................................................................................................................................................... 3

1. GOAL AND INTRODUCTION .................................................................................................................................. 4

1.1. Regulatory Context ............................................................................................................................................................ 4

1.2. SSMP Update Schedule ...................................................................................................................................................... 5

1.3. Sewer System Asset Overview ........................................................................................................................................... 7 Specifications 5.2 – SSMP Development and Implementation ................................................................................................ 10 Specifications 5.7 – Allocation of Resources ............................................................................................................................ 11 Provisions 6.1 - Enforcement Provisions .................................................................................................................................. 12 Provisions 6.3 Sewer System Management Plan Availability ................................................................................................... 13

2. ORGANIZATION ................................................................................................................................................... 14

2.1. Organizational Chart ........................................................................................................................................................ 17

2.2. Organizational Staffing Responsibilities ........................................................................................................................... 18

2.3. Chain of Communication for Reporting Spills .................................................................................................................. 19

3. LEGAL AUTHORITY .............................................................................................................................................. 22

4. OPERATION AND MAINTENANCE PROGRAM ..................................................................................................... 24

4.1. Updated Map of Sewer System ....................................................................................................................................... 24

4.2. Preventive Operation and Maintenance Activities .......................................................................................................... 26

4.3. Training ............................................................................................................................................................................ 28

4.4. Equipment Inventory ....................................................................................................................................................... 30 Specifications 5.19 - Operations and Maintenance .................................................................................................................. 32

5. DESIGN AND PERFORMANCE PROVISIONS ......................................................................................................... 34

5.1. Updated Design Criteria/Construction Standards/Specifications .................................................................................... 34

5.2. Procedures and Standards ............................................................................................................................................... 35

6. SPILL EMERGENCY RESPONSE PLAN ................................................................................................................... 36

7. SEWER PIPE BLOCKAGE PROGRAM .................................................................................................................... 38

8. SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS ........................................................ 42

8.1. System Evaluation and Condition Assessment ................................................................................................................ 42

8.2. Capacity Assessment and Design Criteria ........................................................................................................................ 45

8.3. Prioritization of Corrective Action ................................................................................................................................... 47

8.4. Capital Improvement Plan ............................................................................................................................................... 48

9. MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ................................................................... 51

10. INTERNAL AUDITS ............................................................................................................................................... 53

11. COMMUNICATION PROGRAM ............................................................................................................................ 55 LIST OF APPENDICES ................................................................................................................................................... 57

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page iii

LIST OF FIGURES
Figure 1 - Collection Spill Summary: Operational Indices for Foster City/Estero MID with State and Regional Data .. 1 Figure 2 - Sewer System Management Plan, Subsequent Update and Audit Due Dates ............................................. 5 Figure 3 - City Service Area ........................................................................................................................................... 8 Figure 4 - Organization Chart ...................................................................................................................................... 17 Figure 5 - Chain of Communication for Reporting Spills ............................................................................................. 20

LIST OF TABLES
Table 1 - Abbreviations and Acronyms ......................................................................................................................... 3 Table 2 – City sewer connection flow classifications and connections data ................................................................ 9 Table 3 - Implementation Responsibilities ................................................................................................................. 15 Table 4 - Responsible Position Contact Information .................................................................................................. 16 Table 5 - Lift Station Pump Inventory ......................................................................................................................... 30

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 1 of 57 Introduction
This Sewer System Management Plan (SSMP) or “Plan” has been prepared for the Estero Municipal Improvement District/City of Foster City (jointly referred to as “City”) with technical assistance from Fischer Compliance LLC with the goal of meeting and exceeding compliance with the State Water Resources Control Board 2022 General Waste Discharge Requirements, Order No. WQ 2022-0103-DWQ for Sanitary Sewer Systems (referred to throughout this document as the WDR ). The City provided all details, information and institutional insights for preparation of the SSMP. The document has been developed to meet the size, scale, and complexity of the City, serving as a “living document” used as a tool for managing and operating the City’s sanitary sewer collection system. Additionally, the latest 2024 Sewer System Management Plan Guidance Manual published by the Bay Area Clean Water Agencies (BACWA) was utilized as a model for development of the document to harmonize formatting/content and incorporate recommended suggested guidance wherever possible.

Although the District is in the process of achieving full compliance with the WDR, the summary of spill metrics (below) shows that the City consistently performs better than both the statewide and regional spill rate indices and net spill volumes for all categories of spills from its sanitary sewer collection system.

This SSMP, including Appendix 10, provides a list of items which the City intends to complete such that it will comply with the WDR.

Figure 1 provides key spill metrics, including data comparing the City’s spill record with state and regional system data for the five-year period of May 2020 through May 2025.

Figure 1 - Collection Spill Summary: Operational Indices for EMID/Foster City with State and Regional Data

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 2 of 57 SSMP Organization
This SSMP is organized into 11 core elements following Attachment D of the WDR, with inclusion of applicable Specifications requirements.

Each individual element in the SSMP includes the following technical contents.

1. Requirements – Provides the actual description of applicable requirements in the WDR.

2. Compliance – Describes the City’s approach to complying with the WDR requirements.

3. Effectiveness – As measured by Key Performance Indicators (KPIs.)

4. Implementation – Demonstrates how the City will ensure the SSMP will be carried out as described.

5. Resilience – Demonstrates the resilience that is addressed in the SSMP and built -in to the City’s collection system and procedures.

6. Appendix Inclusions – List the items included in the Appendix for each SSMP Element, if any.

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 3 of 57 Abbreviations and Acronyms
BMP Best Management Practices
CCTV Closed Circuit Television
CIP Capital Improvement Program
CIPP Cured in Place Pipe
CIWQS California Integrated Water Quality System (State Water Board Online Spill Database) CMMS Computerized Maintenance Management System
EPA US Environmental Protection Agency
FOG Fats, Oils and Grease
FSE Food Service Establishment
GCD Grease Control Device
GIS Geographic Information System
I & I Inflow and Infiltration
LRO Legally Responsible Official
RWQCB Regional Water Quality Control Board
SCADA Supervisory Control and Data Acquisition
SERP Spill Emergency Response Plan
SOP Standard Operating Procedure
SSMP Sewer System Management Plan
Spill Sanitary Sewer Spill
WDR Sanitary Sewer Systems General Wastewater Discharge Requirements Order issued by the State Water Board (Order No. 2022-0103-DWQ)
SWRCB State Water Resources Control Board
WDID Waste Discharge ID Number (CIWQS)

Table 1 - Abbreviations and Acronyms

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 4 of 57

1. Goal and Introduction

WDR REQUIREMENTS
Att. D-1 (pg. D-2)
“The goal of the Sewer System Management Plan (Plan) is to provide a plan and schedule to: (1) properly manage, operate, and maintain all parts of the Enrollee’s sanitary sewer system(s), (2) reduce and prevent spills, and (3) contain and mitigate spills that do occur.

The Plan must include a narrative Introduction section that discusses the following items:”

1.1. Regulatory Context

WDR REQUIREMENTS
Att. D-1.1 (pg. D-2)
“The Plan Introduction section must provide a general description of the local sewer system management program and discuss Plan implementation and updates”.

COMPLIANCE
The City is committed to fully implementing the WDR which includes addressing all requirements by integrating a wide range of programs specifically designed for ensuring the integrity and efficiency of the District’s sanitary sewer collection system. Moreover, the City is dedicated to maintaining its collection system in a systematic manner by implementing various work programs, with a focus on critical areas, to prevent spills, allowing for a comprehensive approach to maintenance. Work programs include pipe cleaning, manhole inspections, and lift station maintenance, just to name a few. Work programs are described in more detail in Specifications 5.19 – Operation and Maintenance of this SSMP.

By prioritizing proactive measures and taking a comprehensive approach, the City is well-equipped with a proven track record of effectively operating its sanitary sewer collection system with the highest levels of service, complying with the WDR, and reducing/eliminating sewage spills.

EFFECTIVENESS
N/A

IMPLEMENTATION PLAN/SCHEDULE
N/A

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 5 of 57

1.2. SSMP Update Schedule

WDR REQUIREMENTS
Att. D-1.2 (pg. D-3)
“The Plan Introduction section must include a schedule for the Enrollee to update the Plan, including the schedule for conducting internal audits. The schedule must include milestones for incorporation of activities addressing prevention of sewer spills.”

COMPLIANCE
The City utilizes the State Water Board’s online lookup tool to ensure compliance with all required due dates for updating its SSMP and completing its required SSMP Audits (see chart below) . The City’s most recent SSMP audit was completed for the period August 2021 through August 2024.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are SSMP Audits and SSMP Updates being performed as scheduled? • Has the SSMP been approved by the governing board on the required schedule (i.e., every six years)? • Are specific internally established sewer program milestones being monitored?

Figure 2 - Sewer System Management Plan, Subsequent Update and Audit Due Dates

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 6 of 57

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

1.2.1 Prepare for next SSMP Audit Begin 8/2/2027 X X X

1.2.2 Complete and Upload next SSMP Audit By 2/2/2028 X X x

1.2.3 Incorporate Audit Findings, update Change
Log and Update SSMP
Begin after
completion of SSMP
Audit
X x

1.2.4 Prepare for next SSMP Audit Begin 8/2/2030 X X X

1.2.5 Complete and Upload next SSMP Audit By 2/2/2031 X X x

1.2.6 Incorporate Audit Findings, update Change
Log and Update SSMP
Begin after
completion of SSMP
Audit
X x

1.2.7 Prepare for next SSMP Update Begin 2/2/2031 X X x

1.2.8 City Council deadline for next SSMP Update* By 7/2/2031 X X x * The City’s timeline must incorporate adequate review time and Council approval prior to the required submittal deadlines.

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 7 of 57

1.3. Sewer System Asset Overview

WDR REQUIREMENTS
Att. D-1.3 (pg. D-3)
“The Plan Introduction section must provide a description of the Enrollee-owned assets and service area, including but not limited to:
• Location, including county(ies);
• Service area boundary;
• Population and community served;
• System size, including total length in miles, length of gravity mainlines, length of pressurized (force) mains, and number of pump stations and siphons; • Structures diverting stormwater to the sewer system;
• Data management systems;
• Sewer system ownership and operation responsibilities between Enrollee and private entities for upper and lower sewer laterals;
• Estimated number or percentage of residential, commercial, and industrial service connections; and
• Unique service boundary conditions and challenge(s).

Additionally, the Plan Introduction section must provide reference to the Enrollee’s up- to-date map of its sanitary sewer system, as required in section 4.1 (Updated Map of Sanitary Sewer System) of this Attachment.”

COMPLIANCE
The Estero Municipal Improvement District (EMID) maintains the sanitary sewer collection and pumping system within Foster City. EMID is governed by the Foster City’s City Council /EMID Board of Directors and Foster City provides the staff for EMID. Because CIWQS shows Foster City as the Enrollee under the WDR, this SSMP considers both Foster City and EMID to be one entity and refers to both jointly as “City”.

Foster City is in San Mateo County. The City’s wastewater collection system serves a population of 37,200 people through 13,937 service connections. Due to the City’s flat topography, the existing collection system is designed as a network of lift stations that collect and transport sewage from the outer basins to the inner basins until the wastewater ultimately reaches pump station 59, which is the fi nal and largest capacity station within the City’s collection system. From pump station 59, w astewater is transported to the San Mateo Regional Wastewater Treatment Plant for treatment and disposal. The WWTP is jointly owned by the City of San Mateo and Foster City and is operated by the City of San Mateo. Figure 3, below, shows the area served by the wastewater collection system. The system serves all of Foster City.

The City’s sanitary sewer system includes 63 miles of gravity sewers, 3 miles of force mains, 48 lift stations and one pump station. The 48 lift stations include five medium size lift stations (125,000 to 500,000 gpd) and 43 small lift stations (less than 125,000 gpd). The largest pump station has a capacity of 9 million gallon per day (mgd) and is in the District’s Corporation Yard. Th is pump station is the last stop before almost 3 mgd of the wastewater is pumped to the San Mateo WWTP. The Corporation Yard pump station and 14 of the lift stations have dedicated standby generators. In addition, the City has two newer and two older portable generators with “quick connect” features to provide power to the other lift stations.

Most of the collection system was installed between 1960 and 1980. Pipe sizes range from 4 to 21 inches in diameter with 88% at 12 inches or less. G ravity sewers are constructed of clay (65%), polyvinylchloride

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 8 of 57 (16%), asbestos cement (6%), and high -density polyethylene (1%). The force mains are constructed of asbestos, cement, and high-density polyethylene.

The City is not responsible for maintenance or repair of sewer service laterals. Each property owner is fully responsible maintenance of their private sewer lateral to the main in the street.

The City does not have any structures that divert stormwater to the sewer system.

The City recently acquired a Computerized Maintenance Management System ( CMMS) to manage its collection system and anticipates deployment by the end of 2026. Currently , the City use s Excel spreadsheets to manage its data. The City keeps its maps up to date.

The percentage of residential, commercial, and industrial service connections is shown in Table 2, below.

The City is unique in that it is a master planned community, constructed by filling in marshland in the San Francisco Bay. The area has a high groundwater table, potentially leading to infiltration of the sewer system during storms or high tides. In addition, the City was constructed around a 5-mile-long lagoon. Two force mains go underneath the lagoon while one force main goes over the lagoon on Shell Blvd bridge.

Figure 3 - City Service Area

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 9 of 57 Use Type Number of Connections
Residential 13,685
Commercial 216
Institutional 36
Total: 13,937

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are asset statistics periodically reviewed and updated as necessary? • Are omissions or errors addressed in a timely manner? • Are system maps up to date?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

1.3.1 Review City-owned asset
statistics and element
description; update as
necessary.

At the beginning of the audit cycle and
when significant changes have been made. X X

1.3.2 Update maps. Within 30 Days of Submittal of Completion of Development Project X

RESILIENCE
Resilience is addressed in Element 1 by:
• Adhering to an SOP for collecting and managing asset data. • Redundancy: More than one member of staff is trained and able to retrieve and manage the data. • Implementing a QA/QC process to help ensure information is accurate. • Using Calendar Reminders to ensure compliance deadlines are met.

APPENDIX 1 INCLUSIONS:
• None

Table 2 – City sewer connection flow classifications and connections data

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 10 of 57 Specifications 5.2 – SSMP Development and Implementation

WDR REQUIREMENTS
Specification. 5.2 (pg. 18)
“To facilitate adequate local funding and management of its sanitary sewer system(s), the Enrollee shall develop and implement an updated Sewer System Management Plan. The scale and complexity of the Sewer System Management Plan, and specific elements of the Plan, must match the size, scale, and complexity of the Enrollee’s sanitary sewer system(s). The Sewer System Management Plan must address, at minimum, the required Plan elements in Attachment D (Sewer System Management Plan – Required Elements) of this Genera l Order. To be effective, the Sewer System Management Plan must include procedures for the management, operation, and maintenance of the sanitary sewer system(s).

The procedures must: (1) incorporate the prioritization of system repairs and maintenance to proactively prevent spills, and (2) address the implementation of current standard industry practices through available equipment, technologies, and strategies.”

COMPLIANCE
The City’s current Sewer System Management Plan (SSMP) has been updated to meet the requirements of Order WQ 2022 -0103-DWQ and addresses the required Elements. The SSMP addresses management, operations and maintenance procedures specific to the City’s collection system. The City maintains a proactive O&M program to operate its system and identify defects, which are then prioritized for repair, replacement, rehabilitation, or placed on modified maintenance schedules. (See Elements 4 and 8 and Specifications 5.19 of this SSMP for more detail.)
The City keeps up with current industry standards, technology and best practices by reviewing industry periodicals, networking , attending training classes, attending CWEA conferences and workshops , and talking to v endors about new products . The City continuously evaluates emerging practices, equipment and technologies for possible implementation to enhance sewer operations.

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 11 of 57 Specifications 5.7 – Allocation of Resources

WDR REQUIREMENTS
Specification. 5.7 (pg. 22)
“The Enrollee shall comply with the following requirements:
• Establish and maintain a means to manage all necessary revenues and expenditures related to the sanitary sewer system; and
• Allocate the necessary resources to its sewer system management program for:
• Compliance with this General Order,
• Full implementation of its updated Sewer System Management Plan, • System operation, maintenance, and repair, and
• spill responses.”

COMPLIANCE
The Estero Municipal Improvement District (EMID) is an independent special district of Foster City. Foster City provides the staff for all management and operations of the EMID assets for sewer collection . All services provided to support EMID are billed to EMID and are funded by an enterprise fund managed by the City. The City regularly (annually) conducts evaluations of its sewer program rate and charges to assure full funding of the program, including treatment costs for all dischargers in the service area. The EMID service area is coterminous with the City of Foster City, and all sewage is discharged into assets owned and managed by EMID.

There are two main sources of revenue:
• The Wastewater Enterprise Fund is funded by wastewater rates charged to the City’s customers. This money can be used on operation and maintenance, capital improvement, professional services, and the City’s share of the cost to operate and maintain the San Mateo Regional Water Quality Control Facility.
• “Developer fees” (connection fees) are charged to developers of new projects that will tie into the collection system. This money is used to pay for the project ’s fair share of the existing wastewater treatment and collection infrastructure capacity.

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 12 of 57 Provisions 6.1 - Enforcement Provisions

WDR REQUIREMENTS
Provisions 6.1 (pg. 27)
“The following enforcement provisions are based on existing federal and state regulations, laws and policies, including the federal Clean Water Act, the state Water Code and the State Water Board Enforcement Policy.”

COMPLIANCE
The City is aware of the consequences for noncompliance including associated penalties for violations. The City maintains a proactive stance with full implementation of its SSMP.

Noncompliance with requirements of this General Order or discharging sewage without enrolling in this General Order constitutes a violation of the Water Code and a potential violation of the Clean Water Act and is grounds for an enforcement action by the State Water Board or the applicable Regional Water Board.

Failure to comply with the notification, monitoring, inspection, entry, reporting, and recordkeeping requirements may subject the City to administrative civil liabilities of up to $10,000 a day per violation pursuant to Water Code section 13385; up to $1,000 a day per violation pursuant to Water Code section 13268; or referral to the Attorney General for judicial civil enforcement. Discharging waste not in compliance with the requirements of this General Order or the Clean Water Act may subject the District to administrative civil liabilities up to $10,000 a day per violation and additional liability up to $10 per gallon of discharge not cleaned up after the first 1,000 gallons of discharge; up to $5,000 a day per violation pursuant to Water Code section 1335 0 or up to $20 per gallon of waste discharged; or referral to the Attorney General for judicial civil enforcement.

GOAL AND INTRODUCTION

© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 13 of 57 Provisions 6.3 Sewer System Management Plan Availability

WDR REQUIREMENTS
Provisions 6.3 (pg. 31)
“The Enrollee’s updated Sewer System Management Plan must be maintained for public inspection at the Enrollee’s offices and facilities and must be available to the public through CIWQS and/or on the Enrollee’s website, in accordance with section 3.8 (Sewer System Management Plan Reporting Requirements) of Attachment E1 (Notification, Monitoring, Reporting and Recordkeeping Requirements) of this General Order.”

COMPLIANCE
The City publishes its SSMP, available for public review, on its website at the Public Works wastewater management plan page. The City also maintains a paper copy of the SSMP in its offices which can be made available for inspection during regular business hours.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 14 of 57

2. Organization

WDR REQUIREMENTS
Att. D-2 (pg. D-3)
“The Plan must identify organizational staffing responsible and integral for implementing the local Sewer System Management Plan through an organization chart or similar narrative documentation that includes:
• The name of the Legally Responsible Official as required in section 5.1 (Designation of a Legally Responsible Official) of this General Order;
• The position titles, telephone numbers, and email addresses for management, administrative, and maintenance positions responsible for implementing specific Sewer System Management Plan Element;
• Organizational lines of authority; and
• Chain of communication for reporting spills from receipt of complaint or other information, including the person responsible for reporting spills to the State and Regional Water Boards and other agencies, as applicable. (For example, county health officer, county environmental health agency, and State Office of emergency Services.)

COMPLIANCE
The above items are addressed in order below:

The City’s Legally Responsible Official is Frank Schoening, the Wastewater Maintenance Superintendent.

The City intends to add Zaheed Danish , the Maintenance Manager, as a second LRO. Both people meet the requirements set forth in Specifications 5.1 of the WDR.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 15 of 57

IMPLEMENTATION RESPONSIBILITIES
Sewer System Management Plan Elements Responsible Position

1. SSMP Plan, Goal and Introduction Maintenance Manager/Superintendent

1.1. Regulatory Context Maintenance Manager/Superintendent

1.2. SSMP Update Schedule Maintenance Superintendent

1.3. Sewer System Asset Overview Maintenance Manager/Superintendent

2. Organization Maintenance Manager/Superintendent

3. Legal Authority Maintenance Manager/Superintendent

4. Operations and Maintenance Program Maintenance Manager/Superintendent

4.1. Updated maps of Sanitary Sewer System IT and Maintenance Manager/Superintendent

4.2. Preventive Operation & Maintenance Maintenance Manager/Superintendent

4.3. Training Maintenance Manager/Superintendent and Human Resources

4.4. Equipment Inventory Maintenance Manager/Superintendent

5. Design/Performance Engineering Manager

5.1. Updated Design Criteria & Construction
Standards
Engineering Manager

5.2. Procedures and Standards Engineering Manager

6. Spill Emergency Response Plan Maintenance Manager/Superintendent

7. Sewer Pipe Blockage Program Maintenance Manager/Superintendent

8. System Eval, Capacity Assurance, Capital Imp. Engineering Manager

8.1. System Evaluation and Condition Assessment Engineering Manager

8.2. Capacity Assessment and Design Criteria Engineering Manager

8.3. Prioritization of Corrective Action Engineering Manager and Maintenance Manager/Superintendent

8.4. Capital Improvement Plan Engineering Manager

9. Monitoring, Measurement & Program Modifications Maintenance Manager/Superintendent

10. Internal Audits Maintenance Manager/Superintendent

11. Communication Program Maintenance Manager/Superintendent. IT, and City Clerk

Table 3 - Implementation Responsibilities

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 16 of 57

RESPONSIBLE POSITION CONTACT INFORMATION
Responsible Position Contact Information Phone Email
Maintenance Manager (Zaheed Danish) 650.286.3544 [email protected] Maintenance Superintendent (Frank Schoening) 650.286.3550 [email protected] Engineering Manager (Laura Galli) 650.286.3280 [email protected] IT (Rob Lasky) 650.286.3216 [email protected]
Human Resources (Dawud Brewer) 650.286.3221 [email protected] City Clerk /Communications (Austin Walsh) 650.286.3206 [email protected]

Table 4 - Responsible Position Contact Information

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 17 of 57

2.1. Organizational Chart

Figure 4 - Organization Chart

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 18 of 57

2.2. Organizational Staffing Responsibilities
The City’s organizational lines of authority and staffing are as follows:

District Manager:

Under general guidance of the EMID (District) Board of Directors, serves as the chief executive officer with responsibility for developing and meeting the mission and vision of the District. The Manager is responsible for all operational, fiscal, technical, and administrative functions related to the treatment plant, conveyance system, and related facilities.

Finance Director:

Plans, organizes, leads and continuously improves the activities and operations of the Finance Department, including accounting information systems and overall customer service, coordinating assigned activities with other departments and outside agencies t o provide advice and direction on the District’s financial condition.

Public Works Director:

Organizes, directs and reviews the activities and operations of the Engineering and Maintenance Divisions.

Has overall responsibility for E MID’s Capital Improvement Program. Coordinate assigned activities and programs with the Wastewater Division and associated Divisions and outside agencies.

Maintenance Manager:

Manages, plans, coordinates, and reviews the Operation and Maintenance of the Wastewater Division.

Ensures the compliant operation of all regulatory requirements, Policies and Procedures, manages division budget, trains, mentors, and manages staff . Supervises and participates in the conduct of operations and maintenance planning, and investigation activities connected with the maintenance and operation, expansion and refurbishment of a system of sanitary treatment and conveyance facilities.

Engineering Manager:

Plans, organizes, directs and manages the Engineering Division; coordinates and directs the activities of the Capital Improvement Program; supervises and participates in the conduct of complicated engineering, , design, and investigation activities connected with the maintenance, operation, expansion and refurbishment of a system of sanitary treatment and conveyance facilities.

Maintenance Superintendent:

Is responsible for planning, organizing, supervising, reviewing, and evaluating the day -to-day work of assigned personnel. Ensures the compliant operation of all regulatory requirements, Policies and Procedures, manages division budget, trains, mentors, and manages staff.

Lead Worker:

Is responsible for planning, organizing, supervising, reviewing, and evaluating the day -to-day work of assigned personnel. The Lead Worker is accountable for Operations Division goals and objectives.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 19 of 57

2.3. Chain of Communication for Reporting Spills
The City may learn of a spill from the public, receipt of an alarm, or observation by City staff.

Public Observation. Public observation is the most common way that the City is notified of blockages and spills. Contact information for reporting sewer spills and backups is on the City’s website on the Public Works page. The website states “ In the event of a sewer overflow or backup during working hours (Monday through Thursday, 7:30 am - 4:30 pm; Friday, 7:30 am - 3:30 pm), please notify the Wastewater Division IMMEDIATELY by calling (650) 286 -8140. After working hours, please contact Police Dispatch at (650) 286-3345. Please do not email or report electronically.” When a report of a sewer spill or backup is made, City staff receives the call, takes the information from the caller, fills out the first section of the Sewer Report Form, and communicates it to the Wastewater Lead Worker who responds to the site and/or dispatches a field crew.

The Public Works (PW) Field Crew determines from the information provided if the PW Maintenance Superintendent and/or PW Maintenance Manager need to be notified and immediately responds to the site.

After hours, the Police Dispatcher receives the call, takes the information from the caller, and communicates it to the PW Standby Person.

Receipt of an alarm. The City’s large ( 9 mgd) p ump station, four medium sized lift stations and remaining 44 smaller lift stations are monitored using SCADA. Alarm conditions are monitored by the City’s administrative staff during normal working hours and Police Dispatch after hours. If an alarm is received, they notify appropriate City staff of the lift station alarms.

City staff observation: City staff conduct periodic inspections of the sewer system facilities as part of their routine activities. Any problems noted with the sewer system facilities are reported to appropriate City staff who, in turn, respond to emergency situations.

Staff respond to the spill using the procedure in the Spill Emergency Response Plan (Section 6) and complete relevant forms. The information is then submitted to the Maintenance Superintendent for review and verification of data , including reviewing spill volume ca lculation, prior to submittal to CIWQS.

The Spill Response Flowchart, below, summarizes the spill reporting procedure.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 20 of 57

Figure 5 - Chain of Communication for Reporting Spills

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 21 of 57

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Have there been any changes requiring updates to the Organizational Chart? • Have there been instances when a service call for a spill was not properly routed to response personnel?
• Were all spill response activities documented and forwarded to the LRO? • Have there been any changes in assigned responsibilities for implementing the SSMP? • Is there a process in place to ensure all contact information remains up to date?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

2.1 Review names, contact information and position
responsibilities. Update as necessary.

Semi-Annually
X X

2.2 Review Chain of Communication outcomes for all spill responses.

Each Spill Event
X X

2.3 Review Organizational Chart for any changes. Update as necessary.

Semi-Annually
X X

2.4 Update CIWQS to add a second LRO and data
submitter.

See Appendix 10
X X X

RESILIENCE
Resilience is addressed in Element 2 by:
• Ensuring that more than one person is capable and responsible for specific duties for SSMP implementation, e.g., back-up personnel.
• Designation of more than one LRO to help ensure full and continuous coverage of duties. • Testing the phone notification system to ensure calls are received and routed to appropriate personnel.

APPENDIX 2 INCLUSIONS:
• None

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 22 of 57

3. Legal Authority

WDR REQUIREMENTS
Att. D-3 (pg. D-4)
“The Plan must include copies or an electronic link to the Enrollee’s current sewer system use ordinances, service agreements and/or other legally binding procedures to demonstrate the Enrollee possesses the necessary legal authority to:
• Prevent illicit discharges into its sanitary sewer system from inflow and infiltration (I&I); unauthorized stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including rags and other debris that may cause blockages; • Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to storm sewer systems during spill events, and prevent unintentional cross connections of sanitary sewer infrastructure to storm sewer infrastructure; • Require that sewer system components and connections be properly designed and constructed; • Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee;
• Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and
• Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable.”

COMPLIANCE
The above items are addressed in order below. Regulations pertaining to sewer service are found in Title 8 of the Estero Municipal Improvement District Code, which is a component of the Foster City Municipal Code.

Authority to prevent illicit discharges into the wastewater collection system.

Section 8.37.110 prohibits general discharges of wastewater that may interfere with the POTW or damage the conveyance system. Section 8.37.120 prohibits specific types of discharges such as explosives, corrosives, solids (including fats, oils, grease), debris, and unpolluted water. Section 8.37.150 prohibits the discharge of groundwater except under certain conditions and with a permit.

Pre-planned collaboration and coordination with storm drain agencies.

In addition to owning and operating the sanitary sewer system, Foster City also owns and operates all storm drains within the City limits. Therefore, City staff can coordinate internally to respond to spills, ensure access to storm drains, and prevent cross connections. There are no County -owned storm drains within the City.

Require that sewer system components and connections be properly designed and constructed.

Section 8.32.010 states that “Design and construction of public sewers, building sewers and sewer laterals shall be in accordance with the standards established by the director of public works.” Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee.

The City is not responsible for any sewer laterals. Section 8.32.100 states that “… sewer laterals shall be maintained by the owner of the property served.”
Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures.

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 23 of 57 Section 8.04.130 states that a customer’s service may be disconnected for failure to comply with the City’s ordinances. S ections 8.12.230 through 8.12.280 provide escalating enforcement options for failure to comply the City’s ordinances. Section s 8.37.440 through 8.37.470 also describe escalating enforcement options.

Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable.

Foster City is a master planned community and is completely built out. Therefore, there is no need for the Municipal Code to contain a reference for future easement accessibility agreements. There are a few existing easement agreements which are maintained by the City’s Engineering Department.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are the City ordinances and standards adequate for fulfilling the SSMP legal requirements? • Does the City have a process in place for periodic review and evaluation of ordinances? • Have there been instances when the code or ordinance did not address a need or circumstance?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

3.1 Review Ordinance(s) to confirm all documents provide necessary required legal authority.

Once per 6-year SSMP
Update Cycle X X

3.2 Confer with storm drain owners to ensure current
practices and contact information are up to date.

Annually
X X

3.3 Monitor and document occasions when Ordinance(s)
failed to address issues as intended.

Continuously
X X X

RESILIENCE
Resilience is addressed in Element 3 by:
• Keeping abreast of industry trends and local ordinances that may affect operations.

APPENDIX 3 INCLUSIONS:
• None

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 24 of 57

4. Operation and Maintenance Program

WDR REQUIREMENTS
Att. D-4 (pg. D-4)
“The Plan must include the items listed below that are appropriate and applicable to the Enrollee’s system.”

4.1. Updated Map of Sewer System

WDR REQUIREMENTS
Att. D-4.1 (pg. D-4)
“An up-to-date map(s) of the sanitary sewer system, and procedures for maintaining and providing State and Regional Water Board staff access to the map(s). The map(s) must show gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities within the sewer system service area boundaries.”

COMPLIANCE
The City maintains paper maps of its system, as well as computerized maps (ArcGIS) of all mainlines, manholes, and other facilities within the City. The GIS database stores data and enables staff to retrieve information such as pipe type and diameter, the approximate manhole and cleanout locations, the location of drop manholes, pumping facilities, and the length of pipe between manholes.

Field staff have access to the GIS database through their phones or tablets. I f field staff find an error in a map, they will redline the map and refer the error to management. After internal review and verification, management will send the information to the City’s IT Department to make the correction. If a map needs to be changed due to development, the Engineering Department will provide the information to the IT Department.

High priority corrections are completed within 30 days. High priority corrections refer to mapping information that could cause the field crews to act in a manner that could cause a spill. Low priority corrections are completed once a year.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Were all map updates completed in a timely manner?
• Are all staff trained in the procedure for providing map update information? • Are newly installed sewer assets incorporated into the system maps? • Are there terrain features or assets that should be incorporated in future map updates (e.g. exposed pipe, siphons, ARVs, surface water, etc.)

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 25 of 57

IMPLEMENTATION PLAN/SCHEDULE
No Plan Schedule Responsible Party
Dir Eng Sup

4.1.1 Review map update procedures with all affected staff. Annually X X

4.1.2 Review/ensure all newly installed facilities have been updated and included in the system maps.

Annually X X

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 26 of 57

4.2. Preventive Operation and Maintenance Activities

WDR REQUIREMENTS
Att. D-4.2 (pgs. D-4/D-5)
”A scheduling system and a data collection system for preventive operation and maintenance activities conducted by staff and contractors. The scheduling system must include:
• Inspection and maintenance activities;
• Higher-frequency inspections and maintenance of known problem areas, including areas with tree root problems;
• Regular visual and closed-circuit television (CCTV) inspections of manholes and sewer pipes.

The data collection system must document data from system inspection and maintenance activities, including system areas/components prone to root -intrusion potentially resulting in system backup and/or failure.”

COMPLIANCE
The City currently uses Excel spreadsheets to program and track all required inspection and maintenance activities within the collection system. However, the City intends to transition to the Cartegraph CMMS software by 2026. Use of this software will allow the District to make informed decisions regarding its assets and infrastructure by using the data collected from field work orders and documented inspections.

Sewer maintenance is currently scheduled using paperwork orders. The work orders cover preventive maintenance program and annual routine cleaning, based on the City’s 48 sewer basins. Completed gravity sewer maintenance is recorded using Excel spread sheets. When problems are found, they are listed on a white board.

City staff clean 85-100% of the gravity system each year, working from the top lines to the bottom lines.

Staff log their work into Excel each day. Operators inspect manholes as they clean and if something unusual is noted, will send a crew out. Most pipe repairs are completed in-house by City staff. Manhole inspections are not currently documented but will be in the future using a form similar to that in Appendix 4.1.

When the City transitions to Cartegraph, the software will issue preventative maintenance, hot spot, and line repair work orders automatically.

The City has not had a CCTV program since the COVID pandemic; however, the City plans to hire a contractor by the end of 2025 and to resume the CCTV program in 2026. It is anticipated that work orders for CCTV inspections will be generated by Cartegraph.

Lift stations are inspected monthly, with results noted on logs maintained at each lift station and on work order request logged into GIS.

The City does not need to implement a root control program due to the high groundwater table.

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 27 of 57

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are the City’s maintenance operations w ork orders periodically audited for accuracy and completeness?
• Does the City monitor “open,” “overdue,” or “not yet completed” work orders to ensure completion of tasks?
• Are inspection and maintenance activities reducing the number and volume of spills? • Is maintenance work being completed as scheduled?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

4.2.1 Review work completed to date to ensure critical work is being completed. Quarterly X X

4.2.2 Review scheduled Preventative Maintenance to ensure the prescribed schedule remains appropriate. Annually X X

4.2.3 Transition from Excel spreadsheets to Cartegraph
CMMS.

Beginning first
half 2026 X X

4.2.4 Hire a contractor to CCTV the sewer lines. January 1, 2026 X X

4.2.4 Resume CCTV program. Early 2026 X

4.2.5 Begin documenting manhole inspections and retain
records.

January 1,
2026 X X X

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 28 of 57

4.3. Training

WDR REQUIREMENTS
Att. D-4.3 (pg. D-5)
“In-house and external training provided on a regular basis for sanitary sewer system operations and maintenance staff and contractors. The training must cover:
• The requirements of this General Order;
• The Enrollee’s Spill Emergency Response Plan procedures and practice drills; • Skilled estimation of spill volume for field operators; and • Electronic CIWQS reporting procedures for staff submitting data.”

COMPLIANCE
The City currently uses a combination of in-house classes, on-the-job training, conferences, seminars, and other opportunities to train its collection system staff.

Staff who respond to sewage spills receive annual training to review implementation of the SERP and the requirements of the WDR and this SSMP. The training includes an on -site practice drill with training on emergency response procedures with flow estimati on, as well as determining spill start times, volume estimation, recovery estimation, emergency operating procedures training for lift stations, and manhole to manhole bypass.

The City will soon designate a second LRO and a Data Submitter and will train these individuals on the City’s procedures for reporting spills from receipt of call to report submittals and certification.

The City has not formally documented training in the past but will begin to do so utilizing a document similar to that found in Appendix 4.2.

Contractors who work on the sewer collection system are instructed by City staff on the process to follow in the event of a spill and are provided with a spill response form such as the one found in Appendix 4.3.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Has all training been completed as scheduled?
• Have records of training and attendance been documented and maintained? • Have all staff demonstrated ability and knowledge after each training event? • Have contractors received, at a minimum, direction for reporting and responding to spills?

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 29 of 57

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

4.3.1 Review training documentation to ensure all staff
have received required training. Quarterly X X

4.3.2 Review agreements with contractors and/or pre-job meeting minutes to ensure contract personnel have
received instruction for responding to sewage spills.

Each Contract X X

4.3.3 Train the second LRO and the data submitter on
CIWQS data entry procedures.

By end of third
quarter 2025 X

4.3.4 Complete a training record after each training event. Immediately X

4.3.5 Provide each contractor with a spill response form. Immediately X

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 30 of 57

4.4. Equipment Inventory

WDR REQUIREMENTS
Att. D-4.4 (pg. D-5)
“An inventory of sewer system equipment, including the identification of critical replacement and spare parts.”

COMPLIANCE
The City keeps an inventory of critical replacement and spare pares, which includes, among other items, pipes, fittings, valves, check valves, and manhole rings. A list of this equipment is available upon request.

The City maintains an inventory of replacement pumps for its various lift stations , as shown in the table below.

Model Serial Number V oltage HP Discription Price 3085 2020049 208 3 Tag # 03211 7,758.94 3085 2020046 208 3 Tag # 03212 7,758.93 3085 1920028 208 3 Tag # 00000 3,769.13 3085 2480045 208 3 Tag # 03274 10,906.88 3085 2430093 230 Tag # 03273 10,906.88 3085 2170193 230 3 Tag # 03241 10,155.47 3085 970001 230 3 Tag # 00000 3,769.13 3085 1570028 460 3 Tag # 03051 6,742.50 3085 1570029 460 3 Tag # 03052 6,742.50 3085 920048 460 3 Tag # 00000 3,769.13 3102 2480093 208 3 Tag # 03276 13,094.38 3102 2350091 208 5 T ag # 03262 12,468.75 3102 2350092 208 5 Tag # 03263 12,468.75 3102 2350093 208 5 Tag # 03264 12,468.75 3102 2350094 208 5 Tag # 03265 12,468.75 3102 2470019 230 3 Tag # 03275 13,094.38 3102 1740017 230 5 T ag # 03111 7,193.81
3102 1570098 230 5 Tag # 03056 6,590.68
3102 2170016 230 5 Tag # 03228 10,105.16
3102 2170017 230 5 Tag # 03229 10,105.15 3102 110018 460 5 old black pump 4,643.13
3102 110038 460 5 old black pump 4,643.13
3102 110037 460 5 old black pump (used from ls # 26) 4,643.13 3102 8001 460 5 old black pump (Bad do not use) 4,643.13 3127 187 460 10 Old Black pump 6,664.25
3171 1120016 208 30 Rebuild for LS # 10 5,072.10
3127 1460048 240v Rebuild for Ls #12
3127 2480119 230v T ag # 3277 18,656.09 Table 5 - Lift Station Pump Inventory

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 31 of 57

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Have inventory lists been audited as scheduled?
• Have any inventory deficiencies or omissions been discovered and rectified? • Has the City experienced any equipment failure that inhibited a spill response?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

4.4.1 Audit inventory lists to ensure stock is
adequate. Annually X

4.4.2 Check with vendors to ensure lead times for
critical parts are as expected. Annually X X

4.2.3 Ensure contracts with emergency support
services are current. Annually X

RESILIENCE
Resilience is addressed in Element 4 by:
• Developing an SOP for updating maps when errors are discovered. • Developing and using forms (paper or electronic) for data collection to help ensure all pertinent information is consistently collected.
• Periodically evaluating inspection cycle intervals to help ensure they are optimized. • Requiring staff to demonstrate ability and/or knowledge for all training activities. • Monitoring equipment and critical spare parts usage for and trends. • Performing periodic audits of the vehicle and equipment inventory List.

APPENDIX 4 INCLUSIONS:
• 4.1 Example Manhole Inspection Form
• 4.2 Example Training Record
• 4.3 Example Spill Response Requirements for Contractors • 4.4 Example SOP for Sewer Cleaning
• 4.5 Example Annual Lift Station Inspection Form

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 32 of 57 Specifications 5.19 - Operations and Maintenance

WDR REQUIREMENTS
Specification. 5.19 (pg. 27)
“To prevent discharges to the environment, the Enrollee shall maintain in good working order, and operate as designed, any facility or treatment and control system designed to contain sewage and convey it to a treatment plant.”

COMPLIANCE
The City’s sewer system O&M program include:
• Proactive, preventive, and corrective maintenance of gravity sewers; • Rehabilitation and replacement of collection system facilities that are in poor condition; • Periodic inspection and preventive maintenance for lift station and force main facilities; and • Resumption of a CCTV program to determine the condition of the gravity sewers.

Gravity Sewers
The City cleans 85-100% of its sewer system every year, and it preventively cleans sewers with a history of problems (hot spots) every month. One collection system cleaning crew is assigned to these activities. The District’s standard operating procedure for collection system cleaning is similar to that found in Appendix

4.4. Gravity sewer maintenance is currently scheduled using paper work orders. The work orders cover preventive maintenance program and annual routine cleaning, based on the City’s 48 sewer basins.

Completed gravity sewer maintenance is recorded using Excel spread sheets . The City has established monthly and annual goals for production. Actual production is tracked, and corrective actions are implemented when production falls behind the goals. The City has a Hot Spots program, with lines cleaned on a weekly, monthly, and six-month schedule. The Hot Spots list is available upon request.

Prior to the Covid pandemic, the City used CCTV to determine the cause of its gravity sewer blockages and spills. Post COVID, the City lost staffing and expertise; therefore, the City intends to hire a CCTV contractor and resume CCTV inspections in 2026.

The City completes emergency repairs and non -emergency repairs using its field crews . Repairs are identified by the sewer cleaning crew and repairs are completed in priority order.

The Collection System staff maintains a list of known structural problems for use in providing input to Public Works Engineering on the Capital Improvement Program.

Manholes
Previously, the City’s CCTV crew inspected manholes. The City intends to contract out the CCTV program in 2026 and the CCTV crew will once again do the inspecting. Until the contractor is hired , the sewer cleaning crew visually inspects the manhole. If a problem is found, a paper work order form is completed and given to the Maintenance Superintendent for follow-up.

Lift Stations
Lift stations are inspected monthly, during the first two weeks of each calendar month. Pump current draw is measured during the operational inspection and is used as a diagnostic tool to identify pump operating problems. Facility or equipment problems observed during the operational inspecti ons are noted on logs

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 33 of 57 maintained at the lift stations and on work order reports for follow -up action. Observed facility or equipment problems are also recorded on the whiteboard in the maintenance shop. All observations are transcribed onto the Lift Station Task spreadsheet. Th e completed corrective maintenance activities are also noted on the spreadsheet.

Preventive maintenance activities are completed during the second half of each month. Checklists are used to ensure that all required preventive maintenance tasks are completed.

Emergency generators are exercised monthly.

The results of the operational inspections, preventive maintenance tasks, and any corrective maintenance are recorded on paper work order forms. The completed work orders are recorded by asset in the District’s GIS system. The GIS system maintains a history of completed maintenance by asset.

The City formally inspects the condition of its lift stations annually. The inspection process is used to identify major maintenance and rehabilitation needs. The facility inspection is completed by a team that includes collection system field staff and other City employees as appropriate to the size and complexity of the facility and uses a checklist similar to that found in Appendix 4.5. The completed inspection checklists are reviewed by the Superintendent to determine whether repairs, major maintenance, or rehabilitation/replacement are warranted. Repairs and major maintenance are completed by City staff.

Specialty repairs, maintenance, or rehabilitation/replacement are completed by contract.

Force Mains
Force main right-of-ways are inspected yearly to identify leakage and potential incursions associated with nearby construction. Air relief valves are inspected and maintained annually. The City is a member of Underground Service Alert and marks the location of its force mains to prevent damage by others during underground construction.

Non-Routine Maintenance
Non-routine maintenance activities include investigation and response to any complaints regarding a manhole overflow, missing or shifted manhole covers, manhole covers that are excessively noisy, residential plumbing troubles, pump station malfunction, une xpected sewer odor, etc. Sewer complaints are investigated, and appropriate actions are taken to resolve the source of the problem.

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 34 of 57

5. Design and Performance Provisions

5.1. Updated Design Criteria/Construction Standards/Specifications

WDR REQUIREMENTS
Attachment D-5.1 (pg. D-5)
“Updated design criteria, and construction standards and specifications, for the construction, installation, repair, and rehabilitation of existing and proposed system infrastructure components, including but not limited to pipelines, pump stations, and other system appurtenances. If existing design criteria and construction standards are deficient to address the necessary component-specific hydraulic capacity as specified in section 8 (System Evaluation, Capacity Assurance and Capital Improvements) of this Attachment, the procedures must include component-specific evaluation of the design criteria.”

COMPLIANCE
Sections 13.040202-13.04.040 of the Foster City Municipal Code states that a permit must be obtained prior to construction of a sewer system, and that the city engineer will review the application for compliance with appropriate standard and ordinances. For smaller buildings, the Code states that the applicant shall follow the California Plumbing Code (as referenced in Section 15.16 of the Municipal Code).

The City’s Sewer Standard Details describe the required design criteria for among other items, manholes, manhole frames and cover, sewer laterals, sewer lateral repairs, and grease interceptors.

The City’s 2015 Standard Specifications, Section 02730, pertains to sanitary sewers. The document references ANSI, ASTM, and AWWA publications and standards, lists the items that must be submitted to the City and permits which must be obtained prior to construction, describes the type of material to be used for each element of the sewer system (including pipelines, manholes, air release valves, and lift stations), describes how the system shall be constructed, and references the City’s Sewer Standard Details.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are plan checking QA/QC processes helping to ensure adherence to the standards?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

5.1.1 Ensure all project plans are approved in accordance with the City’s Standard Specifications and Details. Each project X X X

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 35 of 57

5.2. Procedures and Standards

WDR REQUIREMENTS
Attachment D-5.2 (pg. D-5)
“Procedures, and standards for the inspection and testing of newly constructed, newly installed, repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances.”

COMPLIANCE
Section 8.40.050 of the Foster City Municipal Code states “ All sewer construction work, building sewers, plumbing and drainage systems shall be inspected by the inspector acting for the District to ensure compliance with all requirements of the District. No sewer shall be covered at any point until it has been inspected and passed for acceptance. No sewer shall be connected to the D istrict’s public sewer until the work covered by the permit has been completed, inspected and approved by the inspector. If the test proves satisfactory and the sewer has been cleaned of all debris accumulated from construction operations, the inspector shall issue a certificate of satisfactory completion. (Ord. 126 § 1 (part), 2009)”

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Were any design or installation deficiencies found during warranty inspections? • Are deviations from standard procedures and/or specs, testing, etc., justified and documented? • Does the City stay abreast of industry design standards and technical advances in the industry?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

5.2.1 Verify inspection procedures are adequate and
consistent with current standards of practice Each project X X

5.2.2 Verify design standards and hydraulic model
previously completed are adequate and
consistent with current standards of practice.

Each project X

RESILIENCE
Resilience is addressed in Element 5 by:
• Staying abreast of industry trends and standards.
• Performing warranty inspections of newly installed or repaired assets to evaluate design and installation practices.
• Evaluating as-built changes for trends and areas for design and performance improvements.

APPENDIX 5 INCLUSIONS:
• None

SPILL EMERGENCY RESPONSE PLAN
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 36 of 57

6. Spill Emergency Response Plan

WDR REQUIREMENTS
Attachment D-6 (pg. D-6)
“The Plan must include an up- to-date Spill Emergency Response Plan to ensure prompt detection and response to spills to reduce spill volumes and collect information for prevention of future spills. The Spill Emergency Response Plan must include procedures to:
• Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill in a timely manner;
• Notify other potentially affected entities (for example, health agencies, water suppliers, etc.) of spills that potentially affect public health or reach waters of the State; • Comply with the notification, monitoring and reporting requirements of this General Order, State law and regulations, and applicable Regional Water Board Orders; • Ensure that appropriate staff and contractors implement the Spill Emergency Response Plan and are appropriately trained;
• Address emergency system operations, traffic control and other necessary response activities; • Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system;
• Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of the State;
• Remove sewage from the drainage conveyance system;
• Clean the spill area and drainage conveyance system in a manner that does not inadvertently impact beneficial uses in the receiving waters;
• Implement technologies, practices, equipment, and interagency coordination to expedite spill containment and recovery;
• Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event; • Conduct post-spill assessments of spill response activities; • Document and report spill events as required in this General Order; and • Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update the Plan as needed.”

COMPLIANCE
The City’s Spill Emergency Response Plan (SERP) is a stand- alone document that contains all the key elements necessary for an appropriate spill response: notification, emergency incident response, reporting, and impact mitigation. The current plan, prepared by DKF Solutions Group, LLC, meets the requirements of the WDR. The plan was fully updated in 2023. Initial training has been provided to affected staff and refresher training is conducted annually. The Spill Emergency Response Plan is available on the City’s website at the Wastewater Management Plan page and is available for viewing at the City office upon request.

SPILL EMERGENCY RESPONSE PLAN
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 37 of 57

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Have staff’s spill response efforts helped to prevent the discharge of sewage to surface waters? • Do post-spill assessments indicate staff are following the procedures outlined in the SERP? • Is SERP training effective and are trainees demonstrating adequate knowledge and abilities?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

6.1 Perform SERP training including practice drills. Annually X X

6.2 Review Post Spill Assessments to ensure
adherence with the SERP and to identify any
trends that should be addressed.

Annually X X

RESILIENCE
Resilience is addressed in Element 6 by:
• Multiple staff are trained to respond to spill events. • Post-spill assessments are conducted to evaluate staff’s adherence to the SERP and to identify areas for improvement.
• Data collection forms are used to direct staff to collect all the required data to be submitted to CIWQS and are designed as a guide to a proper spill event response. • The District employees several different spill volume estimation methods to account for different circumstances.

APPENDIX 6 INCLUSIONS:
• None

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 38 of 57

7. Sewer Pipe Blockage Program

WDR REQUIREMENTS
Attachment D-7 (pg. D-7)
“The Sewer System Management Plan must include procedures for the evaluation of the Enrollee’s service area to determine whether a sewer pipe blockage control program is needed to control fats, oils, grease, rags and debris. If the Enrollee determines that a program is not needed, the Enrollee shall provide justification in its Plan for why a program is not needed.

The procedures must include, at minimum:
• An implementation plan and schedule for a public education and outreach program that promotes proper disposal of pipe-blocking substances;
• A plan and schedule for the disposal of pipe-blocking substances 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 substances generated within a sanitary sewer system service area;
• The legal authority to prohibit discharges to the system and identify measures to prevent spills and blockages.
• Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, best management practices requirements, recordkeeping and reporting requirements;
• Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the fats, oils, and grease ordinance; • An identification of sanitary sewer system sections subject to fats, oils, and grease blockages and establishment of a cleaning schedule for each section; and • Implementation of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each section identified above.”

COMPLIANCE
The City’s FOG Control Program is provided under contract by the City of San Mateo. San Mateo’s FOG Control Program is described in detail in San Mateo's 2021 SSMP. San Mateo ’s Environmental Services Division, Source Control Section administers the FOG source control program while Building Departments of both San Mateo and Foster City issue permits for installation of grease control devices in conformance to requirements of Uniform Plumbing Code.

Foster City will ask San Mateo to provide quarterly updates regarding the work completed under the FOG Control Program.

The WDR’s requirements above are addressed below:

Public Outreach. The City of San Mateo conducts public outreach on behalf of the City of Foster City. San Mateo’s Environmental Compliance Inspectors distribute outreach materials , if necessary , during each commercial FSE inspection; they encourage managers of food service facilities to use the information to train employees upon hire and at least annually thereafter. San Mateo inspectors typically distribute a San Mateo-produced brochure titled Required Best Management Practices for Food Service Facilities that contains information on BMPs for the FOG and Stormwater programs. On the backside is Municipal Code Applicable to Food Service Establishments for reference. The brochure is provided in English, Spanish, and Chinese.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 39 of 57 San Mateo inspectors also distribute a one -page handout provided by the San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) titled Best Management Practices for Food Service Facilities. This is available in English, Spanish and Chinese.

A laminated poster for proper grease disposal titled No Grease Down the Drain – Keep Drains Flowing is provided during initial inspections for posting in the dishwash area of the kitchen. The poster is available in English, Spanish, Chinese, Korean and Vietnamese.

Residential outreach materials are on display at San Mateo City Hall and are distributed at the San Mateo Services Academy and other venues. Public service announcements may be published prior to major holidays to remind San Mateo residents of prudent food waste handling practices. A FOG BMP poster and the WEF “Fat Free Sewers” brochure is mailed to apartment complexes as needed, and after finding a FOG buildup in the sewer at or immediately downstream of an apartment connection. If necessary, the FOG brochure is distributed to all homes upstream of a recurring blockage.

Foster City occasionally attends community events and has door hangars and fliers available to educate the community and local businesses on how to properly maintain their private sewer laterals. The City intends to add FOG control information to its website.

Disposal. FOG which is generated by FSEs is collected in grease interceptors or grease traps which are maintained by the FSEs. The accumulated FOG is pumped out by licensed haulers hired by the FSEs and taken to the haulers’ own facilities. The City’s sewer maintenance crew also removes FOG in the collection system during their routine maintenance activities. This grease is disposed of in drying beds at the City’s Corporation Yard and then taken to the Recology landfill, on an as-needed basis.

Legal authority to prohibit discharges. The Estero Municipal Improvement District Code, a component of the Foster City Municipal Code, regulates discharges to the sewer system. Section 8.37.120(E) prohibits the discharge of solids, including FOG, which could obstruct flow within the sewer. Section 8.37.120(H) prohibits the discharge of oil and grease that exceeds specific concentrations.

Requirement to install grease interceptors, design standards, etc . Section 8.36.040 of the Foster City Municipal Code states that “Grease, oil and sand interceptors shall be provided in accordance to the FOG (fats, oil, and grease) control program and/or when in the opinion of the public works department are necessary…” Section 8.36.050 states that grease interceptors shall be maintained by the owner and shall be “in continuously efficient operation.” Section 8.37.100 states that FSEs shall have a pretreatment system for grease removal and provides design criteria. S ection 8.37.160 reiterates the need for FSEs to install a grease removal system, provides sizing criteria, and states that if there is a grease buildup in the sewer, then additional grease control measures will be required. Section 8.37.340 states that records shall be kept for at least three years.

Authority to inspect and enforce. Section 8.37.350 of the Foster City Municipal Code describes the authority to inspect and monitor, including that an authorized City representative may “conduct all inspection, surveillance and monitoring procedures necessary to assure compliance with these rules and regulations.” FOG-related problem areas. The City has limited FSEs in its collection system. If staff find more grease than expected as they clean a line, they will report the location to San Mateo. San Mateo maintains the list of FSEs within Foster City.

Source control measures. San Mateo’s FOG Control Program, which is also implemented in Foster City, emphasizes six BMPs that should be followed by FSEs and other FOG generators within the service area.

These BMPs are summarized as follows:
• Employee Training and Awareness: This BMP recommends that all employees and FOG -producing establishments be adequately trained in activities to reduce FOG disposal into the sanitary sewer system.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 40 of 57 • Garbage Grinder Elimination/Limitation: This BMP recommends that FOG generators eliminate garbage grinders or limit their use to the greatest extent possible, thereby reducing the amount of food particles that enter the sanitary sewer system with the potential to clog the system. Additionally, the use of drain screens is recommended by this BMP to capture food and other particles in order to prevent them from being discharged into the sanitary sewer system. These screens should be cleaned frequently and emptied into the trash.
• Spill Cleanup: This BMP emphasizes the use of dry -cleaning methods for cleaning up spills. If dry methods are insufficient, water use and discharge to the sanitary sewer should be limited as much as possible.
• Equipment Cleaning and Maintenance: This BMP recommends that FOG generators limit the discharge of FOG to the sanitary sewer system to the greatest extent possible in the regular cleaning and maintenance of equipment.
• Grease Handling and Disposal: This BMP requires that oils, grease or other oily liquids (such as salad dressing) should not be discharged in large quantities to the sanitary sewer system. These materials should be recycled, if possible.
• Grease Removal Devices: This BMP requires that FOG generators install and maintain grease removal devices.

Because not all FOG problems are caused by food service facilities, residential and private dwelling customers are also urged to adopt the aforementioned BMPs, as applicable.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Have there been any blockages/spills from any identified problem area? • Is the City receiving feedback on public outreach efforts? • Are the debris and other sewage solids collected during cleaning activities being disposed of appropriately?
• Have there been spills due to excessive fats, oil, grease, roots, or non-dispersible wipes discovered in the sewer system during the audit period?
• Are there repeat offenders among FSEs?
• Are enforcement trends decreasing?
• Are Source Control and Collection staff included in the plan check process?

IMPLEMENTATION PLAN/SCHEDULE
No Plan Schedule Responsible Party
Dir Eng Sup

7.1 Review/evaluate enforcement and inspection
findings and implement changes as necessary. Annually X X X

7.2 Review spill rates and causes and make changes to
maintenance programs, as necessary. Annually X

7.3 Ask San Mateo to provide quarterly updates
regarding the FOG Control Program.

By September 1,
2025 X

7.4 Add FOG control information to the City website. Second half 2025 X

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 41 of 57

RESILIENCE
Resilience is addressed in Element 7 by:
• Inspection of select assets directly downstream of grease producing businesses to ensure source control is effective.
• Residential FOG outreach and education program.
• Performance of regular assessments of system assets to monitor performance. • QA/QC process for evaluating pipe cleaning effectiveness. • Daily disposal of pipe blocking materials retrieved during maintenance activities.

APPENDIX 7 INCLUSIONS:
• None

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 42 of 57

8. System Evaluation, Capacity Assurance, Capital Improvements

WDR REQUIREMENTS
Attachment D-8 (pg. D-)
“The Plan must include procedures and activities for:
• Routine evaluation and assessment of system conditions; • Capacity assessment and design criteria;
• Prioritization of corrective actions; and
• A capital improvement plan.”

8.1. System Evaluation and Condition Assessment

WDR REQUIREMENTS
Attachment D-8.1 (pgs. D-7/D-8)
“The Plan must include procedures to:
• Evaluate the sanitary sewer system assets utilizing the best practices and technologies available; • Identify and justify the amount (percentage) of its system for its condition to be assessed each year;
• Prioritize the condition assessment of system areas that:
• Hold a high level of environmental consequences if vulnerable to collapse, failure, blockage, capacity issues, or other system deficiencies;
• Are located in or within the vicinity of surface waters, steep terrain, high groundwater elevations, and environmentally sensitive areas;
• Are within the vicinity of a receiving water with a bacterial -related impairment on the most current Clean Water Act section 303(d) List.
• Assess the system conditions using visual observations, video surveillance and/or other comparable system inspection method;
• Utilize observations/evidence of system conditions that may contribute to exiting of sewage from the system which can reasonably be expected to discharge into a water of the State; • Maintain documents and recordkeeping of system evaluation and condition assessment inspections and activities; and
• Identify system assets vulnerable to direct and indirect impacts of climate change, including but not limited to: sea level rise; flooding and/or erosion due to increased storm volumes, frequency, and/or intensity; wildfires; and increased power disruptions.”

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 43 of 57

COMPLIANCE
The above requirements are addressed below:

System Evaluation: The City assesses its system as it cleans the pipelines yearly and inspects its lift stations monthly. The City previously conducted CCTV inspections but has not done so since COVID. The City intends to hire a contractor and to resume CCTV inspections in 2026.

Justify amount of system assessed each year: The City has averaged two spills per year since 2020. The City cleans 85-100% of its lines yearly. The City intends to hire a CCTV contractor to inspect the system beginning in 2026, after which the City will evaluate the findings to determine an optimal inspection interval.

Prioritize condition assessment areas : There is a 5-mile-long lagoon running through the City. The City inspects all its lift stations monthly and inspects its larger lift stations (e.g., 22 and 29) more frequently.

Assess system using visual observations, etc.: The City assesses system conditions using visual observation of manholes and lift stations. The City intends to resume assessing the system using CCTV in 2026.

Evidence of flow exiting from system: The City is not aware of any exfiltration from its system. However, due to the high groundwater table, infiltration is possible. If the groundwater table drops below the sewer pipe, then there is the potential for exfiltration. The City will continuously monitor for evidence of exfiltration and if found, will address the issue.

Maintain documents: The City currently maintains paper and electronic (Excel) records. The City intends to transition to Cartegraph, which will allow all data to be tracked and readily available to all City staff. The City intends to have its CCTV contractor use the PACP defect coding for the gravity lines and MACP inspections for the manholes. The contractor will provide video and inspection logs to the City.

Climate change: The City has considered the potential effects of climate change on its collection system.

Given the City’s location along the edge of San Francisco Bay, sea level rise is a major concern. However, in 2024 the City completed a capital improvement project to raise and strengthen its entire levee system which should protect the City from sea level rise for the foreseeable future. Upgrades to the lagoon pumphouse are currently in the design phase. This will include the addition of up to two pumps to the existing 2 pumps, in order to increase the City’s resiliency to Sea Level Rise and heavy storm events . The City has also considered the impact of power outages and has installed permanent emergency generators at 14 lift stations and has two newer and two older portable generators available for the other lift stations. The City has previously experienced power outages and has been able to keep its entire collection system functioning using the permanent and portable generators. The City should not have issues with erosion or wildfire.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Has the City maintained its schedule for inspecting the sewer assets listed below and is data being reviewed in a timely manner?
o CCTV Gravity
o Laterals
o Manholes
o Pump Stations
• Are inspection efforts discovering deficiencies in a timely manner? • Are maintenance and inspection activities being properly documented?

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 44 of 57

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

8.1.1 Review/evaluate enforcement and inspection findings and implement changes as necessary. Annually X X

8.1.2 Review spill rates and causes and make changes to maintenance programs, as necessary. Annually X

8.1.3 Hold meetings to discuss any issues that may result from climate changes. Annually X X X

8.1.4 Complete CCTV inspection of system in 2026 and then determine optimal inspection interval.

First half
2027 x x x

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 45 of 57

8.2. Capacity Assessment and Design Criteria

WDR REQUIREMENTS
Attachment D-8.2 (pgs. D-8/D-9)
“The Plan must include procedures to identify system components that are experiencing or contributing to spills caused by hydraulic deficiency and/or limited capacity, including procedures to identify the appropriate hydraulic capacity of key system elements for:
• Dry-weather peak flow conditions that cause or contributes to spill events; • The appropriate design storm(s) or wet weather events that causes or contributes to spill events. • The capacity of key system components; and
• Identify the major sources that contribute to the peak flows associated with sewer spills.

The capacity assessment must consider:
• Data from existing system condition assessments, system inspections, system audits, spill history, and other available information;
• Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions;
• Capacity of systems subject to increased infiltration and inflow due to larger and/or higher - intensity storm events as a result of climate change;
• Increases of erosive forces in canyons and streams near underground and above-ground system components due to larger and/or higher-intensity storm events; • Capacity of major system elements to accommodate dry weather peak flow conditions, and updated design storm and wet weather events; and
• Necessary redundancy in pumping and storage capacities.”

COMPLIANCE
The City completed a Wastewater Collection System Master Plan in 2019. Among other items, the Master Plan addresses both dry weather and wet weather flow monitoring, field inspections, appropriate design capacity, existing data, impacts of inflow/infiltration on the system, and redundancy in pumping for an existing lagoon crossing.

The Master Plan identifies and prioritizes capacity and rehabilitation improvement projects and recommends a phased capital improvement program, including budget estimates, for implementing the needed capacity improvements to the wastewater collection system.

The Master Plan includes a n assessment to determine the condition of 20 City lift stations, recommend improvements, and prioritize future lift station CIP projects. These 20 lift stations have exhibited operational problems, shown signs of deterioration, or have other deficiencies that need to be corrected.

In addition, the City identified a list of 20 collection system hot spots that require monthly maintenance to sustain standard operations. The result of the assessment was a comprehensive list of impro vement projects needed to address the deficiencies at the lift stations and collection system hot spots.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Number of capacity-related spills or surcharge condition during the audit period. • Has the system responded to rain events as indicated by the hydraulic model? • Has there been any changes to zoning designations (residential, commercial, industrial)?

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 46 of 57

IMPLEMENTATION PLAN/SCHEDULE
No Plan Schedule Responsible Party
Dir Eng Sup

8.2.1 Monitor/evaluate significant rain
events to see if they exceed the
design storm in the hydraulic model.

Each significant rain evet
X X

8.2.2 Identify and monitor flood-prone
areas susceptible to erosion from
rain events
After each significant rain event
X X

8.2.3 Monitor flows in each basin and
update the hydraulic model
Per Engineering Department
schedule X X

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 47 of 57

8.3. Prioritization of Corrective Action

WDR REQUIREMENTS
Attachment D-8.3 (pg. D-9)
“The findings of the condition assessments and capacity assessments must be used to prioritize corrective actions. Prioritization must consider the severity of the consequences of potential spills.”

COMPLIANCE
The City’s 2019 Master Plan includes a “Non -Economic Project Analysis” intended to score projects to ensure that the most critical and effective projects are prioritized. Screening criteria included enhancing worker safety, improving system redundancy, risk of failure, e nhancement to public safety, time to implement or construct, criticality, and reduction in maintenance frequency. Each of the lift station and collection system hot spot improvement projects were scored and ranked to determine each projec t’s respective viability.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Has the City adhered to its system evaluation/condition assessment schedule? • Has the City adhered to its prioritization/corrective procedures for sewer repair and capacity improvement projects?
• Have projects been completed before deficiencies caused failures?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

8.3.1 Utilize all available data for prioritizing corrective actions considering severity and consequences of
potential spills.

Each CIP Update
X X

8.3.2 Maintain documents and recordkeeping of system
evaluation and condition assessment inspections
and activities.

Continuously
X X

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 48 of 57

8.4. Capital Improvement Plan

WDR REQUIREMENTS
Attachment D-8.4 (pg. D-9)
“The capital improvement plan must include the following items:
• Project schedules include completion dates for all portions of the capital improvement program; • Internal and external project funding sources for each project; and • Joint coordination between operation and maintenance staff, and engineering staff/consultants during planning, design, and construction of capital improvement projects; and Interagency coordination with other impacted utility agencies.”

COMPLIANCE
The City prepares an annual capital budget with a 5 -year Capital Improvement Program (CIP). The City’s program is intended to provide safe, reliable sewer collection and treatment services to its customers. The program priorities, per the City’s 2019-2024 Capital Improvement Program are to: (a) Maintain and enhance the City/District’s infrastructure for the benefit of the community; and (b) Develop and implement projects to ensure continued and reliable service to meet the City/District’s needs.

The 2019 Master Plan includes CIP projects proposed to address the District’s most critical lift station and collection system “hot spot” infrastructure rehabilitation needs within the next 20-year period.

For 2017-2022, the 2019 Master Plan proposed the following list of projects. However, these projects were delayed by the COVID pandemic and are included in the FY 25-26, 5-year CIP.. The projects identified in the 2019 Master Plan were reprioritized and regrouped based on discussions with Maintenance staff. A project to address rehabilitation of manholes 29-07, 18-01, 16-17, 14-02, 22-18, 22-19, 37-11, 29-31, 10-01, and 12-

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 49 of 57 02 is included in the City’s FY25 -26 budget for design and construction in FY26-27 and FY27-28. CIP 455 - 719, Lift Station Improvements Project Phase 6, addresses the rehabilitation of Lift Stations 6, 9, 11, 13, 22, 29, 42, and 43 and is scheduled to start design in FY25-26.

For 2022-2027, the 2019 Master Plan proposed the following project (now part of CIP 455-719):

For 2027-2032, the 2019 Master Plan proposed the following project (now part of CIP 455-719 and NEW CIP for FY26-27 -Sewer rehabilitation):

For 2032 -2037, the 2019 Master Plan proposed the following projects: This project is identified in the Budget as Sanitary Sewer Lift Stations Improvements Project – Phase 7 (FY28-29).

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 50 of 57

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Has the City’s capital improvement plan schedule been adhered to?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

8.4.1 Hold regular coordination meetings, with all
parties, to help keep the projects on track and
resolve issues that may arise in a timely manner.

Annually
X X

8.4.2 For schedules that are not followed, justify and
document the reason.

Each Delayed
Project X X

RESILIENCE
Resilience is addressed in Element 8 by:
• Is there an annual review of the Capital Improvement Plan by all appropriate individuals including both Engineering and Operations?
APPENDIX 8 INCLUSIONS
• None

MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 51 of 57

9. Monitoring, Measurement, and Program Modifications

WDR REQUIREMENTS
Attachment D-9 (pg. D-9)
“The Plan must include an Adaptive Management section that addresses Plan- implementation effectiveness and the steps for necessary Plan improvement, including:
• Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities;
• Monitoring the implementation and measuring the effectiveness of each Plan element; • Assessing the success of the preventive operation and maintenance activities; • Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations; and
• Identifying and illustrating spill trends, including spill frequency, locations, and estimated volumes.”

COMPLIANCE
The above requirements are addressed below:

Maintaining information. The City currently uses paper documents and Excel spreadsheets to maintain accurate and relevant inspection and maintenance records for the collection system , including field data such as pipe cleaning and inspection frequencies . The City intends to begin using the Cartegraph CMMS software by 2026.

Monitoring SSMP elements. Monitoring of the City ’s SSMP focuses on each element in terms of its implementation and effectiveness. The SSMP has been designed to include key performance indicators for each element, which are used to measure effectiveness. In addition, implementation responsibilities are included for each element to help ensure the SSMP is being implemented as intended.

Assessing preventative operations. The City assesses the success of maintenance and operation activities by ensu ring activities are being performed as expected, by monitoring actual outcomes compared to intended outcomes, as well as monitoring spill trends.

Updating SSMP . The City is committed to continuous improvement and monitors and evaluates performance of work programs and SSMP elements to ensure intended outcomes are achieved while looking for areas for improvement. Although the SWRCB (State Water Resources Control Board) requires that the SSMP be updated every six years, the SSMP is considered a dynamic document and may require updating on a more frequent basis.

Identifying spill trends. The City monitors spill trends, at a minimum every three years during required audits, utilizing inspection records and CIWQS data. These resources are helpful in planning and programing work, and adjusting as needed, enabling the City to be adaptive and to capitalize on lessons learned.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Are SSMP Elements being periodically evaluated for effectiveness? • Are work activities and spill events being documented? • Has a plan and schedule been established to address audit findings/deficiencies from the last audit? • Is Trend Analysis being performed on spill causes?

MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 52 of 57 • Have work programs been assessed and updated as necessary?

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

9.1 Assess work programs to ensure
outcomes are as intended.

Annually
X

9.2 Ensure work programs and the SSMP
are updated based on assessments.

As Needed
X

9.3 Monitor and evaluate spill trends.

Document efforts.

Annually
X

RESILIENCE
Resilience is addressed in Element 9 by:
• Development of key performance indicators to measure effectiveness of the SSMP. • Performing periodic reviews of the SSMP to help ensure it is being properly implemented. • Developing and adhering to a timeline to correct deficiencies found during the audit process. • Periodically evaluating work programs to help ensure effectiveness.

APPENDIX 9 INCLUSIONS:
• None

INTERNAL AUDITS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 53 of 57

10. Internal Audits

WDR REQUIREMENTS
Attachment D-10 (pg. D-10)
“The Plan shall include internal audit procedures, appropriate to the size and performance of the system, for the Enrollee to comply with section 5.4 (Sewer System Management Plan Audits) of this General Order.”

COMPLIANCE
The City completed its most recent audit for the period ending August 2024 and will complete audits every three years moving forward. The objective of the audit is to evaluate compliance, implementation and effectiveness of the SSMP . Additionally, the SSMP includes a description of how the City will comply with the requirements of each Element. The audit review includes an evaluation to determine if compliance has been met. A list of priority improvement opportunities will be prepared and updated as part of the audit program. Improvement opportunities will be used to prioritize and develop program modifications and will be initiated based on the priority and the available funding. An overview of SSMP related work completed between audits will be included in the program audits.

The City has already addressed some of the items highlighted in the recent Audit and intends to continue address others in combination with implementation of this SSMP, as outlined in Appendix 10.2.

Implementation is evaluated by determining if the City is executing the SSMP as stated.

Effectiveness is evaluated by using key performance indicators, which have been developed specifically for each element. An additional evaluation is performed to comply with Specifications 5.6 addressing resilience.

Resilience indicators have been developed for each element . These indicators serve to demonstrate how resilience is built into the SSMP and inspection, maintenance and spill response activities.

Any deficiencies discovered through the audit process are noted and a plan and schedule to implement corrective measures are established.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Have audits been performed as required?
• Have the audits assessed compliance, implementation, and effectiveness? • Have deficiencies been identified?
• Has a plan and schedule to rectify the deficiencies been established?

INTERNAL AUDITS
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 54 of 57

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

10.1 Schedule audits in advance of due dates to ensure
adequate time to complete. District has 6 months to
complete the audit from the end of the audit period.

Beginning at
end of audit
period
X

10.2 Ensure a plan and schedule is developed to address deficiencies.

Once the
Audit is
completed
X X

10.3 Address the items identified in the 2024 Audit. See Appendix 10 X X X

RESILIENCE
Resilience is addressed in Element 10 by:
• Periodically evaluating key performance indicators during the audit period to assess effectiveness and make corrections, if necessary, prior to the audit.
• Evaluating previous audits to ensure deficiencies have been rectified. • Scheduling the audit due dates and completing the audit on time.

APPENDIX 10 INCLUSIONS:
• 10.1 2021-2024 SSMP Audit
• Plan and Schedule to Address 2024 Audit Findings

COMMUNICATION PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 55 of 57

11. Communication Program

WDR REQUIREMENTS
Attachment D-11 (pg. D-10)
“The Plan must include procedures for the Enrollee to communicate with:
• The public for:
• Spills and discharges resulting in closures of public areas, or that enter a source of drinking water; and
• The development, implementation, and update of its Plan, including opportunities for public input to Plan implementation and updates.
• Owners/operators of systems that connect into the Enrollee’s system, including satellite systems, for:
• System operation, maintenance, and capital improvement-related activities.”

COMPLIANCE
Spills. When the City experiences a spill, it implements its SERP which includes taking measures to prevent the public from accessing the spill location. Staff will put out barricades and caution tape and remain on site to provide an additional safety factor until appropriate authorities respond and direct otherwise. The City also has the ability to turn off the force main to stop the spill. The City’s communication team are able to send a “blast” email and make calls to notify residents.

Public participation. There are several opportunities for stakeholders and the public to participate and provide input into the development and update of the City’s SSMP. During its initial development stage, as with each SSMP Audit and update of the SSMP, the SSMP and related documents are presented to the City Council for review and acceptance. Prior to each City Council Meeting, these documents are included in an Agenda packet which are readily available for review on the City’s website.

The City publishes its SSMP, available for public review, on its website on the Public Works wastewater management plan page. The City also maintains a paper copy of the SSMP in its offices which can be made available for inspection during regular business hours.

Satellite systems. The City does not have any satellite system.

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Does the City place all SSMP action items on the agenda for regular council/board meetings? • Does the City have signage, or other means, readily available to notify the public of environmental or public risk factors related to a sewage spill?
• Does the City perform outreach to residential customers?

COMMUNICATION PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 56 of 57

IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

11.1 Ensure the City Council approves the
SSMP per schedule.

Every 6 years
X X

11.2 Ensure the SSMP is posted on the
City website and the link functions
properly.

Beginning September 2025
X X X

RESILIENCE
Resilience is addressed in Element 11 by:
• Use the SSMP as a tool to communicate to the public how the City is managing the system. • Maintain a consistent presence in the service area by attending community events or issuing periodic newsletters or other communications to the public.
• Make it clear and easy for the public to contact the City.

APPENDIX 11 INCLUSIONS
• None

APPENDICES
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for Foster City and Estero MID use only. Page 57 of 57

LIST OF APPENDICES
APPENDIX 1 • None
APPENDIX 2 • None
APPENDIX 3 • None
APPENDIX 4
• 4.1 Example Manhole Inspection Form
• 4.2 Example Training Record
• 4.3 Example Spill Response Requirements for Contractors • 4.4 Example SOP for Sewer Cleaning
• 4.5 Example Annual Lift Station Inspection Form
APPENDIX 5 • None
APPENDIX 6 • None
APPENDIX 7 • None
APPENDIX 8 • None
APPENDIX 9 • None
APPENDIX 10 • 10.1 2021-2024 SSMP Audit
• 10.2 Plan and Schedule to Address 2024 Audit Findings APPENDIX 11 • None

← All documents from this meeting