041525 PW Sewer System Management Plan Update Management Plan — City Council - Successor Agency

Sewer System Management Plan (SSMP) 2025 Update
Waste Discharge ID (WDID) #8SSO20044 Water Board Region 8 REVIEWED AND APPROVED BY:

Stephen Bise, Public Works Director Legally Responsible Oﬃcial City of Fullerton Sanitary Sewer CollecEon System (includes Element Development Plans & Schedules) Date Signed

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SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City use only. Page i Revision Date SSMP Sec0on Descrip0on of Change/Revision Made Ini0als

SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City use only. Page ii Revision Date SSMP Sec0on Descrip0on of Change/Revision Made Ini0als

LETTER OF COMPLIANCE
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March 7, 2025 A>: Mr. Stephen Bise, Public Works Director Legally Responsible Oﬃcial (LRO) 1580 W. Commonwealth Fullerton, CA 92833 Dear Mr. Bise, We are pleased to present the new 2025 Sewer System Management Plan (SSMP) Update developed in partnership with City management. The 2025 Update meets and exceeds compliance with the Reissued WDR (State Water Board, Water Quality Order No. 2022-0103-DWQ, A>achment D-10 and SpeciﬁcaYons 5.4). The 2025 SSMP has been completely revised to harmonize with industry standard guidelines and incorporates the latest SSMP Audit ﬁndings. The 2025 SSMP is a declaraYon of what the City is doing to demonstrate full compliance with the Reissued WDR. A>achment A of the Reissued WDR (page A-4), states “A sewer system management plan is a living document which requires the City to Enrollee develops and implements to eﬀecYvely manage its sanitary sewer system(s) in accordance with this General Order.” This requires the City to periodically review and update the SSMP as necessary unYl its next required 6-year SSMP Update is completed. We look forward to assisYng the City wherever necessary to fully implementaYon its new 2025 SSMP Update. Sincerely, James Fischer, P.E. Principal, Fischer Compliance LLC CredenYaled U.S. EPA NPDES Compliance Inspector

TABLE OF CONTENTS
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City use only. Page iv TABLE OF CONTENTS INTRODUCTION ................................................................................................................................................... 1 SSMP OrganizaEon ..................................................................................................................................................................... 2 AbbreviaEons 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 SpeciﬁcaEons 5.2 – SSMP Development and ImplementaEon ................................................................................................... 9 SpeciﬁcaEons 5.7 – AllocaEon of Resources ............................................................................................................................ 10 Provisions 6.1 - Enforcement Provisions .................................................................................................................................. 11 Provisions 6.3 Sewer System Management Plan Availability ................................................................................................... 11 2. ORGANIZATION ......................................................................................................................................... 12 OrganizaEonal Lines of Authority ............................................................................................................................................. 15 Abbreviated OrganizaEonal Chart ............................................................................................................................................ 16 Chain of CommunicaEon for ReporEng Spills ........................................................................................................................... 17 3. LEGAL AUTHORITY ..................................................................................................................................... 19 4. OPERATION AND MAINTENANCE PROGRAM ............................................................................................. 23 4.1. Updated Map of Sewer System ....................................................................................................................................... 23 4.2. PrevenEve OperaEon and Maintenance AcEviEes .......................................................................................................... 25 4.3. Training ............................................................................................................................................................................ 27 4.4. Equipment Inventory ....................................................................................................................................................... 29 SpeciﬁcaEons 5.19 - OperaEons and Maintenance .................................................................................................................. 31 5. DESIGN AND PERFORMANCE PROVISIONS ................................................................................................. 34 5.1. Updated Design Criteria/ConstrucEon Standards/SpeciﬁcaEons .................................................................................... 34 5.2. Procedures and Standards ............................................................................................................................................... 36 6. SPILL EMERGENCY RESPONSE PLAN ........................................................................................................... 38 7. SEWER PIPE BLOCKAGE PROGRAM ............................................................................................................ 40 8. SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS .................................................. 45 8.1. System EvaluaEon and CondiEon Assessment ................................................................................................................ 45 8.2. Capacity Assessment and Design Criteria ........................................................................................................................ 48 8.3. PrioriEzaEon of CorrecEve AcEon ................................................................................................................................... 50 8.4. Capital Improvement Plan ............................................................................................................................................... 51 9. MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ............................................................ 53 10. INTERNAL AUDITS ...................................................................................................................................... 55 11. COMMUNICATION PROGRAM ................................................................................................................... 57 LIST OF APPENDICIES ......................................................................................................................................... 59

SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City use only. Page v LIST OF FIGURES IntroducYon: Figure 1 (CollecYon System OperaYonal Report – SWRCB Integrated Water Quality System (CIWQS) 1 Figure 1-1 Sewer System Management Plan, Subsequent Update and Audit Due Dates ............................................ 5 Figure 2-1 OrganizaYonal Lines of Authority ............................................................................................................. 15 Figure 2-2 Abbreviated OrganizaYon Chart ............................................................................................................... 16 Figure 2-3 Chain of CommunicaYon for ReporYng Spills ........................................................................................... 17 LIST OF TABLES IntroducYon: Table 1 AbbreviaYons and Acronyms ..................................................................................................... 3 Table 2-1 ImplementaYon ResponsibiliYes ................................................................................................................ 13 Table 2-2: Responsible PosiYon Contact InformaYon ................................................................................................ 14

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 1 of 59 Introduc*on The City of Fullerton provided detail, informaYon and insYtuYonal insight in preparaYon to develop this Sewer System Management Plan (SSMP) or “Plan” and received technical assistance from Fischer Compliance LLC and Sam Rose ConsulYng for meeYng and exceeding compliance with the State Water Resources Control Board 2022 General Waste Discharge Requirements, Order WQ 2022-0103-DWQ for Sanitary Sewer Systems, referred to throughout this document as the WDR1. The SSMP has been developed to meet the size, scale, and complexity of the City to serve as a “living document” that will be used as a tool to manage and operate the collecYon system. Further, the new 2024 Sewer System Management Plan Guidance Manual published by the Bay Area Clean Water Agency (BACWA) was uYlized as a model for development of the SSMP to ensure the SSMP harmonizes with the latest available industry standard recommendaYons for the development and updaYng of SSMPs. The City’s commitment to meeYng or exceeding regulatory requirements, along with their proacYve approach to operaYon and management of the collecYon system, has served them well, as evidenced by system performance relaYve to other agencies in the region and the state. The City has experienced only three spills between January 2018 and January 2025. Figure 1 provides key City spill metrics, including data (8/2/2009 – 3/1/2025) comparing the City’s spill record with state and regional system data. The City consistently performs below (be>er than) both statewide and regional spill rate indices and net spill volumes for all categories of spills from its sanitary sewer collecYon system.

1 See Order No. 2022-0103-DWQ
Introduc7on: Figure 1 (Collec7on System Opera7onal Report – SWRCB Integrated Water Quality System (CIWQS)

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 2 of 59 SSMP OrganizaBon This SSMP is organized into 11 core elements following A>achment D of the WDR, with inclusion of applicable SpeciﬁcaYons requirements. Each individual element in the SSMP includes the following technical contents. 1. Requirements – Provides the actual descripYon of applicable requirements in the WDR. 2. Compliance – Describes the City’s approach to complying with the WDR requirements. 3. EﬀecYveness – As measured by Key Performance Indicators (KPIs.) 4. ImplementaYon – Demonstrates how the City will ensure the Plan is being carried out as described. 5. Resilience – Demonstrates the resilience that is addressed in the SSMP and built-in to the City’s collecYon 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. Sewer System Management Plan licensed for City of Fullerton use only Page 3 of 59 AbbreviaBons and Acronyms2 AGENCY Agency Name BMP Best Management PracEces CCTV Closed Circuit Television CIP Capital Improvement Program CM City Manager CIWQS California Integrated Water Quality System (State Water Board Online Spill Database) CMMS Computerized Maintenance Management System CITY City of Fullerton EPA US Environmental ProtecEon Agency FOG Fats, Oils and Grease FSE Food Service Establishment GCD Grease Control Device GIS Geographic InformaEon System HFML High Frequency Maintenance LocaEons I & I Inﬂow and InﬁltraEon LRO Legally Responsible Oﬃcial NPDES NaEonal Pollutant Discharge EliminaEon System RWQCB Regional Water Quality Control Board (Lahontan Region) SCADA Supervisory Control and Data AcquisiEon SERP Spill Emergency Response Plan SOP Standard OperaEng Procedure SSMP Sewer System Management Plan Spill Sanitary Sewer Overﬂow WDR Sanitary Sewer Systems General Wastewater Discharge Requirements, (Order No. 2022-0103-DWQ) SWRCB State Water Resources Control Board WDID Waste Discharge ID Number (CIWQS) 2 For a list of additional common acronyms for collection systems and related WDR terms, see the WDR, Attachment A (page 32) Introduc7on: Table 1 Abbrevia7ons and Acronyms

GOAL AND INTRODUCTION
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1. Goal and Introduc*on REQUIREMENTS A>. 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 miDgate spills that do occur. The Plan must include a narraDve IntroducDon secDon that discusses the following items (see below):” 1.1. Regulatory Context WDR REQUIREMENTS A>. D-1.1 (pg. D-2) “The Plan IntroducDon secDon providing a general descripDon of the local sewer system management program and discuss Plan implementaDon and updates”. COMPLIANCE The City is commi>ed to fully implemenYng the WDR3 which includes addressing all requirements by integraYng a wide range of programs speciﬁcally designed for ensuring the integrity and eﬃciency of the City’s sanitary sewer collecYon system. AddiYonally, the City is dedicated to maintaining its collecYon system in a systemaYc manner by implemenYng various work programs, with a focus on criYcal areas, to prevent spills, allowing for a comprehensive approach to maintenance. Work programs include CCTV inspecYons, pipe cleaning, manhole inspecYons and treatment, root control, just to name a few. Work programs are described in more detail in secYons SpeciﬁcaYons 5.19 OperaYon and Maintenance of this SSMP. By prioriYzing proacYve measures and taking a comprehensive approach, the City is well-equipped to eﬀecYvely operate its sanitary sewer collecYon system with the highest levels of service, complying with the WDR, and reducing/eliminaYng sewage spills. EFFECTIVENESS N/A IMPLEMENTATION PLAN/SCHEDULE N/A 3 Guidance 1.1.2

GOAL AND INTRODUCTION
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1.2. SSMP Update Schedule WDR REQUIREMENTS A>. D-1.2 (pg. D-3) “The Plan IntroducDon secDon must include a schedule for the Enrollee to update the Plan, including the schedule for conducDng internal audits. The schedule must include milestones for incorporaDon of acDviDes addressing prevenDon of sewer spills.” COMPLIANCE The City uYlizes the State Water Board’s online lookup tool for ensuring all required due dates for updaYng its SSMP and compleYng its required SSMP Audits (see chart below). The City’s most recent SSMP audit was for the period May 2021 through May 2024. Notable maintenance milestones include opYmizaYon of preventaYve measures including an 18-month gravity main cleaning cycle and a 60-month CCTV inspecYon cycle and capital improvement projects/schedules, all of which are monitored conYnuously throughout the 6-year SSMP update cycle.

EFFECTIVENESS Key Performance Indicators: 1. Are SSMP Audits and SSMP Updates being performed as scheduled? 2. Has the Sewer System Management Plan been approved by the governing board on schedule (every six years)? 3. Are speciﬁc internally established sewer program milestones being monitored? Figure 1-1 Sewer System Management Plan, Subsequent Update and Audit Due Dates

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 6 of 59 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party PWD Mgr. Sup 1.2.1 Prepare for next SSMP Audit Begin 5/2/2027 X X X 1.2.2 Complete and Upload SSMP audit. By 11/2/2027 X X

1.2.3 Incorporate Audit Findings, update Change Log and Update SSMP 5/2/2025 X 1.2.4 Board Approval and LRO CerEﬁcaEon of SSMP By 5/2/2025 X X

GOAL AND INTRODUCTION
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1.3. Sewer System Asset Overview WDR REQUIREMENTS A>. D-1.3 (pg. D-3) “The Plan IntroducDon secDon must provide a descripDon of the Enrollee-owned assets and service area, including but not limited to: a. LocaDon, including county(ies). b. Service area boundary. c. PopulaDon and community served. 111,000 d. System size, including total length in miles, length of gravity mainlines, length of pressurized (force) mains, and number of pump staDons and siphons. e. Structures diverDng stormwater to the sewer system. f. Data management systems. g. Sewer system ownership and operaDon responsibiliDes between Enrollee and private enDDes for upper and lower sewer laterals. h. EsDmated number or percentage of residenDal, commercial, and industrial service connecDons; and i. Unique service boundary condiDons and challenge(s). j. AddiDonally, the Plan IntroducDon secDon must provide reference to the Enrollee’s up-to-date map of its sanitary sewer system, as required in secDon 4.1 (Updated Map of Sanitary Sewer System) of this ATachment.” COMPLIANCE The City of Fullerton is in Orange County and provides collecYon wastewater services to a 22 square mile service area with a total populaYon of 139,461 and serves over 135,000 customers. The City is bordered by the ciYes of La Habra and Brea to the north, La Mirada to the northwest, Buena Park on the west, Anaheim on the south, and PlacenYa on the east. The collecYon system consists of 330 miles of gravity mains ranging from 6-inch to 36-inch in diameter, 36 siphons. Laterals are privately owned. The City does not own/operate any pump staYons, force mains or stormwater diversion structures. The Lucity computerized maintenance management system (CMMS) is used for work orders and maintaining inspecYon and asset data; POSM is used for sewer pipe CCTV inspecYons; and ArcGIS (ESRI) for system mapping. The City does not own any porYon of the service lateral, except for City owned buildings connected to the collecYon system. See Fullerton Municipal Code 12.08.031. The 2024 Sewer Master Plan indicates the City’s service connecYon classiﬁcaYons, residenYal, commercial industrial and insYtuYonal, are as follows: Use Type By Percentage of Total Connec@ons ResidenEal 68% Commercial 8% InsEtuEonal 11% Industrial 13%

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 8 of 59 Overall, the City has put itself in good posiYon to maintain its collecYon system. There are few service area challenges. Some easements present challenges because they are in backyards. However, all can be accessed by CCTV and hydro-cleaning equipment. During heavy rain events, access to some easement roads/manholes can someYmes be limited for short periods. This is miYgated by performing necessary maintenance in the fall to help ensure proper performance throughout the rainy season. System maps, include gravity mains, manholes, lio staYons, siphons and other collecYon system features and are complete, accurate, up-to-date and available to staﬀ. Refer to SecYon 4.1 Updated Map of Sanitary Sewer System for more detail. EFFECTIVENESS Key Performance Indicators: • Are asset staYsYcs periodically reviewed and updated as necessary? • Are omissions or errors addressed in a Ymely manner? • Are system maps up to date? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party PWD Mgr. Sup 1.3.1 Review City-owned asset staEsEcs and element descripEon; 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 CorrecEon Submijal of CompleEon of Development Project X RESILIENCE Resilience is addressed for Element 1 by: • Adhering to an SOP for collecYng and managing asset data. • Redundancy: More than one member of staﬀ is trained and able to retrieve and manage the data. • ImplemenYng a QA/QC process to help ensure informaYon is accurate. • Using Calendar Reminders to ensure compliance deadlines are met. APPENDIX 1 INCLUSIONS: • None

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 9 of 59 SpeciﬁcaBons 5.2 – SSMP Development and ImplementaBon WDR REQUIREMENTS Spec. 5.2 (pg. 18) “To facilitate adequate local funding and management of its sanitary sewer system(s), the City 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 SSMP, 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 ATachment D (Sewer System Management Plan – Required Elements) of this General Order. To be eﬀecDve, the Sewer System Management Plan must include procedures for the management, operaDon, and maintenance of the sanitary sewer system(s). The procedures must: (1) incorporate the prioriDzaDon of system repairs and maintenance to proacDvely prevent spills, and (2) address the implementaDon of current standard industry pracDces 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, operaYons and maintenance procedures speciﬁc to the City’s collecYon system. The City maintains a proacYve O&M program to operate its system and idenYfy defects, which are then prioriYzed for repair, replacement, rehabilitaYon, or placed on modiﬁed maintenance schedules. (See Elements 4, 8 and SpeciﬁcaYons 5.19 of this SSMP for more detail.) The City keeps up with current industry standards, technology and best pracYces by reviewing industry periodicals, networking and a>ending industry conferences, seminars and workshops.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 10 of 59 SpeciﬁcaBons 5.7 – AllocaBon of Resources WDR REQUIREMENTS Spec. 5.7 (pg. 22) “The City 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: (a) compliance with this General Order, (b) full implementaDon of its updated SSMP, (c) system operaDon, maintenance, and repair, and (d) spill responses.” COMPLIANCE The City maintains ﬁnancial stability and meets its operaYonal needs for managing its sewer system. The City’s Sewer Service Fee is based on the actual water usage of each Fullerton resident and business. The fee will cover the costs for operaYon and maintenance, compliance with regulatory agency requirements, capital improvement and replacement of the sewer system. All revenue collected from the sewer fee is placed in the Sewer Enterprise Fund. Sewer Enterprise Fund revenues can only be spent on sewer related maintenance, operaYons and capital improvements. The City is adequately staﬀed and owns and operates the necessary equipment to eﬀecYvely maintain its collecYon system.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 11 of 59 Provisions 6.1 - Enforcement Provisions WDR REQUIREMENTS Provisions 6.1 (pg. 27) “The following enforcement provisions are based on exisDng federal and state regulaDons, 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 penalYes for violaYons. The City maintains a proacYve stance with full implementaYon of its SSMP. Noncompliance with requirements of this General Order or discharging sewage without enrolling in this General Order consYtutes a violaYon of the Water Code and a potenYal violaYon of the Clean Water Act and is grounds for an enforcement acYon by the State Water Board or the applicable Regional Water Board. Failure to comply with the noYﬁcaYon, monitoring, inspecYon, entry, reporYng, and recordkeeping requirements may subject the Enrollee to administraYve civil liabiliYes of up to $10,000 a day per violaYon pursuant to Water Code secYon 13385; up to $1,000 a day per violaYon pursuant to Water Code secYon 13268; or referral to the A>orney 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 Enrollee to administraYve civil liabiliYes up to $10,000 a day per violaYon and addiYonal liability up to $10 per gallon of discharge not cleaned up aoer the ﬁrst 1,000 gallons of discharge; up to $5,000 a day per violaYon pursuant to Water Code secYon 13350 or up to $20 per gallon of waste discharged; or referral to the A>orney General for judicial civil enforcement. Provisions 6.3 Sewer System Management Plan Availability WDR REQUIREMENTS Provisions 6.3 “The Enrollee’s updated Sewer System Management Plan must be maintained for public inspecDon at the Enrollee’s oﬃces and faciliDes and must be available to the public through CIWQS and/or on the Enrollee’s website, in accordance with secDon 3.8 (Sewer System Management Plan ReporDng Requirements) of ATachment E1 (NoDﬁcaDon, Monitoring, ReporDng and Recordkeeping Requirements) of this General Order.” COMPLIANCE The City publishes its SSMP, available for public review, on its website and also maintains a paper copy in its oﬃces which can be made available for inspecYon during regular business hours.

ORGANIZATION
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2. Organiza*on WDR REQUIREMENTS A>. D-2 (pg. D-3) “The Plan must idenDfy organizaDonal staﬃng responsible and integral for implemenDng the local Sewer System Management Plan through an organizaDon chart or similar narraDve documentaDon that includes: • The name of the Legally Responsible Oﬃcial as required in secDon 5.1 (DesignaDon of a Legally Responsible Oﬃcial) of this General Order. • The posiDon Dtles, telephone numbers, and email addresses for management, administraDve, and maintenance posiDons responsible for implemenDng speciﬁc Sewer System Management Plan Elements. • OrganizaDonal lines of authority. • Chain of communicaDon for reporDng spills from receipt of complaint or other informaDon, including the person responsible for reporDng 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 the order below: Stephen Bise and Anthony Reynoso are designated as the City’s Legally Responsible Oﬃcials. Both meet the requirements set forth in SpeciﬁcaYons 5.1 of the re-issued Order (WQ-2022 0103-DWQ). § Stephen Bise, Public Works Director, oversees all aspects of Public Works. § Anthony Reynoso, Streets and Sewer Manager, has over 30 years of collecYon systems operaYons experience, and oversees the day-to-day maintenance and operaYons acYviYes.

ORGANIZATION
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IMPLEMENTATION RESPONSIBILITIES
Sewer System Management Plan Elements Responsible Posi@on

1. SSMP Plan, Goal and IntroducEon Streets and Sewer Manager

1.1. Regulatory Context Streets and Sewer Manager

1.2. SSMP Update Schedule Streets and Sewer Manager

1.3. Sewer System Asset Overview Streets and Sewer Manager

2. OrganizaEon Director of Public Works

3. Legal Authority Council

4. OperaEons and Maintenance Program

4.1. Updated maps of Sanitary Sewer System Asset Management Coordinator

4.2. PrevenEve OperaEon & Maintenance Streets and Sewer Manager

4.3. Training Streets and Sewer Manager

4.4. Equipment Inventory Streets and Sewer Manager

5. Design/Performance

5.1. Updated Design Criteria & ConstrucEon
Standards City Engineer/Asst. Public Works Director

5.2. Procedures and Standards Streets and Sewer Manager

6. Spill Emergency Response Plan Streets and Sewer Manager

7. Sewer Pipe Blockage Program Streets and Sewer Manager

8. System Eval, Capacity Assurance, Capital Imp.

8.1. System EvaluaEon and CondiEon Assessment Streets and Sewer Manager

8.2. Capacity Assessment and Design Criteria City Engineer/Asst. Public Works Director

8.3. PrioriEzaEon of CorrecEve AcEon Streets and Sewer Manager

8.4. Capital Improvement Plan City Engineer/Asst. Public Works Director

9. Monitoring, Measuring & Program ModiﬁcaEons Streets and Sewer Manager

10. Internal Audits Streets and Sewer Manager

11. CommunicaEon Program Streets and Sewer Manager
Table 2-1 Implementa7on Responsibili7es

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 14 of 59 RESPONSIBLE POSITION CONTACT INFORMATION Responsible Posi@on Contact Informa@on Phone Email Stephen Bise - Public Works Director 714-738-6852 Stephen.Bise@cityoﬀullerton.com Anthony Reynoso – Streets and Sewer Manager 714-738-2802 Tony.Reynoso@cityoﬀullerton.com Benjamin Perez – Sewer Supervisor 714-738-2810 Benjamin.Perez@cityoﬀullerton.com David Grantham – City Engineer 714-738-6853 David.Grantham@cityoﬀullerton.com Table 2-2: Responsible Posi7on Contact Informa7on

ORGANIZATION
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Figure 2-1 Organiza7onal Lines of Authority

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 16 of 59 Abbreviated OrganizaBonal Chart
Figure 2-2 Abbreviated Organiza7on Chart

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 17 of 59 Chain of CommunicaBon for ReporBng Spills
Figure 2-3 Chain of Communica7on for Repor7ng Spills
Calls or complaints received via telephone for actual or possible spills are routed to the Public Works Department for response. During non-business hours, weekends, and/or holidays, calls are received at the 24-hour maintenance service phone number and routed to dispatch for the police department. The calls are then forwarded to the amer hours stand by response staﬀ, the sanitaEon crew or standby crew. Response Eme goals are 10 minutes during business hours and 30 minutes amer hours.

City Receives Call for Service
Response staﬀ respond to all calls, assess the spill event, and take appropriate acEons to miEgate the spill. All spill events are miEgated in accordance with the City's Spill Emergency Response Plan (SERP) and are documented in adherence to the WDR NoEﬁcaEon, Monitoring, ReporEng and Recordkeeping requirements. In the event of a large volume spill (1000 Gallons +) Response staﬀ noEfy the Sewer Supervisor for Cal-OES noEﬁcaEon.

City’s Response to Spill Event
The responding ﬁeld staﬀ submit the ﬁeld report(s) to Supervising Lead Worker who reviews for completeness and accuracy and then confers with the Sewer Supervisor as a layer of quality control. Prior to submiqng the dram report to the CIWQS database, a spill event debrieﬁng, involving response personnel, and the Streets and Sewer Manager, is held to thoroughly vet and ﬁnalize the dram report. The City's Legally Responsible Oﬃcial cerEﬁes all spill reports.

City Reports Spill Event

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 18 of 59 EFFECTIVENESS Key Performance Indicators: 1. Have there been any changes requiring updates to the OrganizaYonal Chart? 2. Have there been instances when a service call for a spill was not properly routed to response personnel? 3. Were all spill response acYviYes documented and forwarded to the LRO? 4. Have there been any changes in assigned responsibiliYes for implemenYng the Sewer System Management Plan? 5. Is there a process in place to ensure all contact informaYon remains up to date? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 2.1 Review names, contact informaEon and posiEon responsibiliEes. Update as necessary. Semi-Annually X X 2.2 Review Chain of CommunicaEon outcomes for all spill responses Each Spill Event X X 2.3 Review OrganizaEonal Chart for any changes. Update as necessary. Semi-Annually X X RESILIENCE Resilience is addressed for Element 2 by: • Ensuring that more than one person is capable and responsible for speciﬁc duYes for the Sewer System Management Plan implementaYon, e.g., back-up personnel. • DesignaYon of more than one LRO to help ensure full and conYnuous coverage of duYes. • TesYng the phone noYﬁcaYon system to ensure calls are received and routed to appropriate personnel. APPENDIX 2 INCLUSIONS: • None

LEGAL AUTHORITY
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3. Legal Authority WDR REQUIREMENTS A>. 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: a. Prevent illicit discharges into its sanitary sewer system from inﬂow and inﬁltraDon (I&I); unauthorized stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including rags and other debris that may cause blockages. b. Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to storm sewer systems during spill events, and prevent unintenDonal cross connecDons of sanitary sewer infrastructure to storm sewer infrastructure. c. Require that sewer system components and connecDons be properly designed and constructed. d. Ensure access for maintenance, inspecDon, and/or repairs for porDons of the service lateral owned and/or operated by the Enrollee. e. Enforce any violaDon of its sewer ordinances, service agreements, or other legally binding procedures; and f. Obtain easement accessibility agreements for locaDons requiring sewer system operaDons and maintenance, as applicable. COMPLIANCE The above items are addressed in order below: a. Authority to Prevent Illicit Discharges into City’s Wastewater CollecYon System Illicit discharges include, but are not limited to, the release of I/I, storm water, chemical dumping, unauthorized debris and consYtuents, and grease. Municipal Code 12.08.070, Sewer ConnecYons, requires that all new connecYons to the public sewer system be tested speciﬁcally for potenYal inﬁltraYon. The tesYng is performed in accordance with the standards set forth in the latest ediYon of the Greenbook. Municipal Code 12.08.110, Deposit in Sewer Restricted, of Title 12, includes a general descripYon of the various types of substances restricted from being directly or indirectly discharged into the collecYon system. The restricYons are applicable to all users of the City’s system except as permi>ed by other city ordinances and the OCSD regulaYons. b. The City's pre-planned collaboraYon and coordinaYon with storm drain agencies The City owns and operates the storm drain system within the City Limits. Both the sewer and storm drain faciliYes are within the Streets and Sewer Division. Should sewage discharge to a storm drain facility, City staﬀ has full authority miYgate the impact of the spill. c. Require that sewer system components and connecYons be properly designed and constructed. Municipal Code 12.08.070 requires that any construcYon or reconstrucYon of a lateral sewer service line that is to be connected to the public sewer system within the public streets, alleys,

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 20 of 59 easements and public rights-of way of the City shall conform to the construcYon standards set forth in the applicable chapters in Title 16, Subdivisions. 16.05.080 Municipal Code 12.08.120, Sewer Design, requires that all sewer mains, laterals, manholes, and other appurtenances be designed, constructed, and inspected in accordance to the applicable chapters in of the City of Fullerton Municipal Code, including Title 16, Subdivisions, the City of Fullerton standard drawings, the latest ediYon of the Greenbook, or as approved by the City Engineer. Municipal Code 16.05.020, City Standards, requires that all public improvements, construcYon and dedicaYons required and described in Title 16, Subdivisions, conform to the latest ediYons of the State of California, Department of TransportaYon “Standard SpeciﬁcaYons” and the American Public Works AssociaYon “Standard SpeciﬁcaYons for Public Works ConstrucYon.” The chapter also provides ulYmate authority to the City Engineer to amend and change such standards and speciﬁcaYons as deemed in the best interest of the public. Municipal Code 16.05.040, Public Improvements for Sewerage FaciliYes, requires that sewer mains, manholes, and appurtenances being constructed to serve a subdivision, lot, parcel, building or structure be constructed as approved by the City Engineer and as required in City’s Master Sewerage Plan or any applicable element of the City’s General Plan. Municipal Code 16.05.080, Improvement Plans, Drawings and Related Items, includes the requirements for preparing proﬁles, descripYons, studies, calculaYons, notes, surveys and drawings for private and public improvement plans and as required by the City Engineer. Ensure access for maintenance, inspecYon, and/or repairs for porYons of the service lateral owned and/or operated by the Enrollee. The Municipal code does not expressly document access requirements for maintenance, inspecYon, or repair of the wastewater collecYon system. Instead, accessibility requirements are managed through the plan reviews for new sewer service where City staﬀ can ensure that sewer system faciliYes are constructed to speciﬁc standards within the public right-of-way or within adequate permanent easements. The following includes a summary of municipal codes. Municipal Code 12.08, Sewer ConnecYons, sYpulates the responsibility to properly maintain and repair the sewer lateral that extends from a building on a property to its point of connecYon with the main sewer, is the responsibility of the property owner or user. The code allows the City to perform maintenance, repair and upkeep on the porYon of the lateral sewer located within the public right-of-way in the event the Director of Public Works determines that to do so would miYgate City liability. Municipal 16.05.070, InspecYon of Public Improvements, provides City staﬀ the authority to access the improvements during construcYon and/or rehabilitaYon for the purpose of examining and inspecYng the construcYon or condiYon of the sewer system to ensure compliance with the City standards. This provides ulYmate authority to the City Engineer or designated staﬀ to determine whether the improvements comply with City standards and requirements. The City requires projects to be accompanied with project plan and proﬁle drawings in compliance with Municipal Code 16.05.080. The materials and methods of construcYon are reviewed and cerYﬁed by a design engineer to ensure the faciliYes will perform properly, provide the appropriate service to City, and meet or exceed industry standards. AddiYonally, all new sewer systems are required to be inspected using Closed Circuit Television (CCTV) by a ConstrucYon Inspector and a Maintenance Services Sewer UYlity staﬀ person or an acceptable CCTV/Sewer Maintenance Contractor.

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 21 of 59 Chapter 16.07, Public Works Permits, implies that the City may have some accessibility rights in that it provides the ulYmate authority to the City Engineer to issue a permit before a sewer line may be constructed. As such, the City Engineer can ensure that the new sewer lines are accessible. Since this is not an explicit requirement, and it is based on the City Engineer’s best engineering abiliYes, not all new sewer pipes may be designed with proper access to the faciliYes for maintenance, repair, replacement and/or rehabilitaYon purposes. AddiYonally, City crews and authorized representaYves may not have the right to access exisYng City sewer lines located on private property. As such, adding s speciﬁc code secYon or chapter or adopYng an ordinance that governs accessibility for maintenance, inspecYon, and repair eﬀorts will provide the appropriate legal authority for City crews to access the sewer faciliYes. d. Enforce any violaYon of its sewer ordinances, service agreements, or other legally binding procedures The authority for the City to enforce penalYes for violaYons of the City’s codes, ordinances, and other adopted policies speciﬁc to the wastewater collecYon system is not explicitly described in the municipal codes. However, it includes a descripYon of the general penalYes for violaYng secYons of the code and for conYnued violaYons. Individuals convicted of violaYng a City ordinance or provision may be charged with either an infracYon or misdemeanor unless the penalty for violaYon is speciﬁcally stated within the ordinance. Individuals convicted of a violaYon of the City code that is not speciﬁcally declared to be an infracYon shall be considered guilty of a misdemeanor and punished with a ﬁne of not more than $1,000 or imprisonment for a term not exceeding 6 months in the Orange County Jail, or by both such ﬁne and imprisonment. Municipal Code 1.10, AdministraYve CitaYons, provides the City the authority to use AdministraYve CitaYons, including imposiYon of administraYve ﬁnes or penalYes as an opYon to address violaYons and encourage voluntary and complete compliance with the provisions of the code for the protecYon and beneﬁt of the community. SubsecYon 130 of Municipal Coder 12.08, PenalYes, summarizes the general penalYes for violaYng the condiYons of Chapter 12, Sewer ConnecYons. The code speciﬁcally states that any person who violates any provision or fails to comply with any requirement of the chapter is guilty of a misdemeanor and may be punished by a ﬁne of not more than $1,000 or imprisonment for a term not to exceed 6 months in the Orange County Jail, or both. The City A>orney has the discreYon to charge a violaYon as an infracYon while the City shall have the discreYon of issuing an administraYve citaYon for violaYons of the chapter. ViolaYon enforcement provisions for the FOG Control Program are contained in Municipal Code 12.20.300 through 12.20.400. The subsecYons include a descripYon of the general penalYes for violaYng various provisions of the chapter and for conYnued violaYons. It serves to govern the discharges into the City’s system by FSEs. The code provides the FOG Control Program Manager the authority to issue a noYce of violaYon, permit suspension or revocaYon and/or establish a Compliance Schedule Agreement. Municipal Code 12.20.390, Civil PenalYes, allows the City to require reimbursement for any payment of ﬁnes or penalYes issued by regulatory or enforcement agencies based on a violaYon of law, regulaYon or its permits. Said violaYon can be established by the City as caused by the discharge by a user of the City’s wastewater collecYon system and that is in violaYon of any provision of the City’s FOG ordinance or permit. AddiYonally, the code allows the City to issue AdministraYve Civil PenalYes for violaYon of any provision of the chapter, permit condiYons, and/or suspension or revocaYon order.

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 22 of 59 SecYon 12.20.400, Criminal PenalYes, describes that any person who violates any provision of the chapter is guilty of a misdemeanor and is punishable by a ﬁne up to $1,000 or imprisonment for up to 6 months, or both. e. Obtain easement accessibility agreements for locaYons requiring sewer system operaYons and maintenance, as applicable. Municipal Code 16.05.100 addresses easement requirements for public faciliYes. EFFECTIVENESS Key Performance Indicators: 1. Are the City ordinances and standards adequate for fulﬁlling the Sewer System Management Plan legal requirements? 2. Does the City have a process in place for periodic review and evaluaYon of ordinances? 3. Have there been instances when the code or ordinance did not address a need or circumstance? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 3.1 Review Ordinance 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 pracEces and contact informaEon are up to date. Annually X 3.3 Monitor and Document occasions when ordinance(s) failed to address issues as intended. ConEnuously X X X RESILIENCE Resilience is addressed for Element 3 by: • Keeping abreast of industry trends and local ordinances that may aﬀect operaYons. APPENDIX 3 INCLUSIONS: • None

OPERATIONS AND MAINTENANCE PROGRAM
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4. Opera*on and Maintenance Program 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 A>. D-4 (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 faciliDes, pressure pipes and valves, and applicable stormwater conveyance faciliDes within the sewer system service area boundaries.” COMPLIANCE Once capital or new development projects are completed, informaYon obtained from the project speciﬁc as-built drawings is used to update the City’s GIS. InformaYon including installaYon date, pipe size, pipe material, manhole locaYon, and any addiYonal perYnent project informaYon is included into GIS and used to update the City’s wastewater collecYon system maps. AddiYonally, as pipelines are removed or abandoned, the informaYon is archived in the GIS system. Necessary revisions and/or updates to the GIS informaYon that are idenYﬁed by the maintenance crews while performing rouYne operaYon and maintenance acYviYes are documented for incorporaYon into the City’s GIS. Map updates are made on a conYnuous basis. Where discrepancies are idenYﬁed by ﬁeld crews during the rouYne maintenance inspecYons, actual ﬁeld condiYons are documented on the Sewer Maintenance ObservaYon Report. Findings are veriﬁed by supervisory personnel before being forwarded to the Asset Manager Coordinator for incorporaYon into the City’s GIS. EFFECTIVENESS Key Performance Indicators: • Were all map updates completed in a Ymely manner? • Are all staﬀ trained in the procedure for providing map update informaYon? • 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.)?

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 24 of 59 IMPLEMENTATION PLAN/SCHEDULE No Plan Schedule Responsible Party DPW Mgr. Sup 4.1.1 Review map update procedures with all aﬀected staﬀ. Annually X X 4.1.2 Review/ensure all newly installed faciliEes have been updated and included in the system maps Annually X X

OPERATIONS AND MAINTENANCE PROGRAM
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4.2. PrevenBve OperaBon and Maintenance AcBviBes WDR REQUIREMENTS A>. D-4 (pgs. D-4/D-5) A scheduling system and a data collecDon system for prevenDve operaDon and maintenance acDviDes conducted by staﬀ and contractors. The scheduling system must include: • InspecDon and maintenance acDviDes. • Higher-frequency inspecDons and maintenance of known problem areas, including areas with tree root problems. • Regular visual and closed-circuit television (CCTV) inspecDons of manholes and sewer pipes. The data collecDon system must document data from system inspecDon and maintenance acDviDes, including system areas/components prone to root-intrusion potenDally resulDng in system backup and/or failure. COMPLIANCE The purpose of a work order system is to program and track all required inspecYon and maintenance acYviYes within the collecYon system to help proacYvely prevent blockages/operaYonal problems or spills. The City uYlizes the Lucity Computerized Maintenance Management System (CMMS), which allows the City to make informed decisions regarding its assets and infrastructure by using the collected data from ﬁeld work orders and documented inspecYons. The City’s CMMS maintains historical data for all maintenance acYviYes and provides a basis for criYcal analysis and data-driven planning and decision-making today and into the future. This allows for prioriYzing and planning rouYne acYviYes such as CCTV inspecYons, manhole inspecYons, pipe repair, and pipe cleaning. In addiYon, the CMMS is used to plan and schedule higher-frequency inspecYon and maintenance acYviYes such as Hot Spot cleaning and root control acYviYes. Emergency and other reacYve acYviYes are documented in work orders as well. The City Engineering Division maintains the GIS data that facilitates management of O&M acYviYes, expedites data management and retrieval for scheduling, tracking, reporYng, and mapping purposes. AddiYonally, GIS allows the City to implement an asset management program to facilitate planning and funding for CIPs. The scheduling system allows staﬀ to put certain acYviYes on a prevenYve schedule where the CMMS automaYcally generates work orders on a prescribed interval. Work orders for other acYviYes are generated by supervisory personnel on an as-needed basis.

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 26 of 59 EFFECTIVENESS Key Performance Indicators: • Is the agency’s maintenance, operaYons, engineering work orders periodically audited for accuracy and completeness? • Does the agency monitor “open,” “overdue,” or “not yet completed” work orders to ensure compleYon of tasks? • Are inspecYon and maintenance acYviYes reducing the number and volume of spills? • Is maintenance work being completed as scheduled? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 4.2.1 Monitor “Past Due” work orders to ensure criEcal work is being completed Quarterly X X 4.2.2 Review scheduled PMs to ensure the prescribed schedule remains appropriate. Annually X X

OPERATIONS AND MAINTENANCE PROGRAM
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4.3. Training WDR REQUIREMENTS A>. D-4 (pg. D-5) In-house and external training provided on a regular basis for sanitary sewer system operaDons and maintenance staﬀ and contractors. The training must cover: • The requirements of this General Order. • The Enrollee’s Spill Emergency Response Plan procedures and pracDce drills. • Skilled esDmaDon of spill volume for ﬁeld operators; and • Electronic CIWQS reporDng procedures for staﬀ submilng data. COMPLIANCE Prior to performing any work on City FaciliYes, City Sewer Maintenance staﬀ are trained on the existence and provisions of the wastewater operaYons and maintenance policies, procedures, safety policies, and the equipment used. Training for operaYon of City equipment includes “on-the-job” training in conjuncYon with bi-weekly “tailgate” meeYngs to discuss safety issues. For regular meeYngs, topics are selected and presented. Generally, monthly meeYngs are conducted by the supervisors on topics selected by the supervisors and are typically relevant to recent acYviYes and/or events and safety issues. As well, staﬀ a>ends regional meeYngs on perYnent topics. Staﬀ involved in responding to customer service calls, including sewage spills, receive annual training on the City’s Spill Emergency Response Plan and the SSMP. This training is part classroom and part hands-on exercises and drills for responding to spill events, including volume esYmaYons and spill start Yme esYmaYons. Staﬀ designated as Data Submi>ers are trained on the City’s procedures for reporYng spills from receipt of call to drao report submi>als and cerYﬁcaYon. The City has developed spill response procedures for Contract Service personnel who perform work for the City are required to: • Immediately noYfy the City of any sewage spill they encounter. • Make a>empts to contain the spill • Cordon oﬀ the area to keep the public safe • Remain onsite unYl AGENCY staﬀ arrives and relieves them. This language is included in service agreements and discussed during pre-job meeYngs. EFFECTIVENESS Key Performance Indicators: • Has all training been completed as scheduled? • Have records of training and a>endance been documented and maintained? • Have all staﬀ demonstrated ability and knowledge aoer each training event? • Have contractors received, at a minimum, direcYon for reporYng and responding to spills.

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 28 of 59 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 4.3.1 Review training documentaEon to ensure all staﬀ have received required training Quarterly X X

4.3.2 Review agreements with contractors and/or Pre-Job meeEng minutes to ensure contract personnel have received instrucEon for responding to sewage spills Each Contract X X

OPERATIONS AND MAINTENANCE PROGRAM
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4.4. Equipment Inventory WDR REQUIREMENTS A>. D-4 (pg. D-5) An inventory of sewer system equipment, including the idenDﬁcaDon of criDcal replacement and spare parts. COMPLIANCE The Sewer Public Works Division maintains an inventory of vehicles and sanitary sewer repair and replacement parts that are maintained in the City’s corporaYon yard. The inventory of vehicles includes the vehicle type currently uYlized to perform the necessary operaYon and maintenance acYviYes of the City’s wastewater collecYon system. Each cleaning trucks is equipped with a fresh supply of high-pressure hose including a supply of repair couplings. The vehicles and replacement parts are made readily accessible to maintenance staﬀ. The replacement parts maintained in the City yard generally consist of parts necessary for speciﬁc types of repairs performed by maintenance staﬀ. AddiYonally, the City maintains a resource list of contractors and vendors who stock materials and are available for emergency and short noYce deliveries. The inventory of repair and replacement parts includes a summary of part size and type and a descripYon and applicaYon of its use. The materials and parts inventories have been integrated into the City’s CMMS and maintenance services database. The City’s Sewer Division maintains a small supply of VCP pipe and associated materials in stock for performing pipe repairs on their system. Typically, pipe materials include approximately 24 feet of 4, 6, 8, 10, and 12-inch VCP. A supply of couplings and bands are also maintained. These are idenYﬁed as criYcal spare parts. Manhole frames and lids are kept in stock to facilitate quick repairs if necessary. As the City’s wastewater collecYon system does not include lio or pump staYons, related items are not maintained in reserves. Other or addiYonal materials idenYﬁed as necessary are easily obtainable on an as needed basis. EFFECTIVENESS Key Performance Indicators: • Have inventory lists been audited as scheduled? • Have any inventory deﬁciencies or omissions been discovered and recYﬁed? • Has the agency experienced any equipment failure that inhibited a spill response?

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 30 of 59 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 4.4.1 Audit inventory lists to ensure stock is adequate Annually X X 4.4.2 Check with vendors to ensure criEcal parts lead Emes are as expected. Annually X X 4.2.3 Ensure contracts with emergency support services are current Annually X RESILIENCE Resilience is addressed for Element 4 by: • Developing an SOP for updaYng maps when errors are discovered. • Developing and using forms (paper or electronic) for data collecYon to help ensure all perYnent informaYon is consistently collected. • Periodically evaluaYng inspecYon cycle intervals to help ensure they are opYmized. • Requiring staﬀ to demonstrate ability and/or knowledge for all training acYviYes. • Monitoring equipment and criYcal spare parts usage for and trends. • Performing periodic audits of the Vehicle and Equipment Inventory List. APPENDIX 4 INCLUSIONS: • None

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 31 of 59 SpeciﬁcaBons 5.19 - OperaBons and Maintenance WDR REQUIREMENTS Spec. 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 has a very eﬀecYve prevenYve maintenance program that maintains the integrity of the sewer system and ensures conYnuous and safe conveyance of wastewater, resulYng in a reduced frequency, number, and volume of spills. The City’s prevenYve maintenance program has evolved into a very proacYve program that is designed to locate, idenYfy, and address problems that may exist in the collecYon system prior to the occurrence of a failure in the system. It is eﬃcient by establishing, where possible, standard cleaning cycles in predetermined geographic areas. By creaYng large work orders bound within a single geographic area, high producYvity is achieved by reducing travel Yme and uYlizing the same work crews for conYnuity. It should be noted that the City’s maintenance program is never staYc and conYnues to be re-examined to improve its eﬃciency and eﬀecYveness. The prioriYzaYon and scheduling of the City’s prevenYve maintenance program is enhanced by the capabiliYes of Lucity, which is used to electronically store, track, and manage all operaYons and maintenance acYviYes pertaining to the collecYon system. Maintenance history informaYon, asset informaYon, service call data, cleaning schedules, and closed-circuit television (CCTV) data are all kept and managed through the Lucity database. The linking of the City’s GIS and Lucity database is a powerful feature for ﬁeld use and provides oﬃce staﬀ the ability to graphically represent or tabulate any collecYon system asset or historical maintenance data to help facilitate its analysis. The primary components of the sewer system receiving prevenYve maintenance include main lines, lower laterals, and manholes. The City’s prevenYve maintenance program for each component is described below through a discussion of speciﬁc maintenance rouYnes, cleaning methods, and service call response procedures. Hydraulic Cleaning The City’s Public Works Sewer Division staﬀ conducts the rouYne cleaning of the enYre wastewater collecYon system once every 18 months. The City’s wastewater collecYon system is divided into three districts and 52 sub-basins. Using the three (3) combinaYon hydro-vacuum trucks, the cleaning eﬀorts are focused on cleaning each district concurrently. Each sub-basin in each of the districts is cleaned in the direcYon of ﬂow to convergence locaYons.

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 32 of 59 Three crews consisYng of two staﬀ members each are assigned to perform daily rouYne cleaning task. Cleaning eﬀorts are documented daily. DocumentaYon includes: • Street name in which the facility is located • Lineal footage cleaned • Beginning and ending manhole • Documented pipe length • Type and quanYty of debris removed • Names of staﬀ performing the cleaning, and • Any addiYonal perYnent comments Once the cleaning of a basin is completed, informaYon pertaining to the cleaning acYviYes and dates are entered into the GIS system for each speciﬁc pipeline. High Frequency Maintenance LocaYons (HFMLs) The City has idenYﬁed locaYons within the collecYon system as HFML’s. The City’s preventaYve maintenance program includes cleaning of the HFMLs on a regularly scheduled basis. Generally, the HFMLs are referred to as “special projects” are cleaned on a scheduled 1, 3, 6, or 12-month interval. These locaYons include the City’s siphons, pipelines with sags and capacity constraints, and areas idenYﬁed as having excessive amounts of grease accumulaYon and/or root concentraYons. Cleanout Lateral Program The City’s Cleanout Lateral Program is available to assist residents with root blockages that are caused in developed areas with large mature trees. The program is limited to residenYal properYes and requires an iniYal evaluaYon of the property to be performed to determine if the property qualiﬁes for the program. The evaluaYon includes: • conﬁrmaYon of an exisYng 4-inch sweep type of clean-out in the front of the property for sewer access, • veriﬁcaYon of tree root problems through video inspecYon by City crews, and • veriﬁcaYon that no private trees are near the sewer line. City crews use portable CCTV equipment to inspect laterals and conﬁrm the tree roots are the source of the problem and verify the roots originate from a City owned tree. Where it is determined a City tree is the source of the problem, City crews use mechanical rodding equipment to cut and remove the roots. Upon compleYng the clearing of the pipeline, crews record the locaYon and footage on daily work reports. The service is generally performed annually, and crews are available to respond to emergency blockages. Where it is determined that tree roots are the source causing excessive infrastructure damage at a speciﬁc locaYon, the tree may be scheduled for removal. Root Treatment A component of the City’s cleaning eﬀorts includes using the City’s hydro-vac truck to minimize root intrusion that can damage sewers, cause restricted ﬂow in sewer pipelines, and contribute to the potenYal for spills. Mechanical root cuung is used in areas where tree root intrusion is the primary cause of sewer line restricYon and potenYal blockages. As necessary, the mechanical Hydro-vac truck is used to clear roots from the wastewater collecYon system. The City has increased root-cuung eﬀorts as roots have been idenYﬁed as being a primary cause of spills. According to the City staﬀ, increasing the root cuung eﬀorts has reduced the number and risk of potenYal blockages due to roots. In addiYon, the City has an annual contract to treat sewer mains with chemicals that are in diﬃcult access areas or that have excessive root intrusions.

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 33 of 59 Manhole InspecYons Manholes are rouYnely inspected by hydro-cleaning crews and the CCTV crew. A top-down inspecYon is performed, as the covers are removed for maintenance acYviYes The crews use a “Manhole InspecYon Report” to document manhole features and overall condiYons. Based on the defects repair, rehabilitaYon, or replacement of the manhole is prioriYzed and scheduled. DefecYve manhole lids are replaced if damaged and as it is typically not cost-eﬀecYve to repair manhole lids. Manhole Treatment To control infestaYons of insects and root intrusion to maintain adequate access to the wastewater collecYon system, the system manholes are systemaYcally treated for the removal of roaches and root intrusion. A treatment program is implemented by City staﬀ as determined necessary. System InspecYon and Assessment The City employs CCTV technology for the inspecYon of pipelines. With the use of the City’s one CCTV truck, the City performs inspecYons of select sewer pipelines of the City’s wastewater collecYon system. The City’s truck is equipped with Pipeline ObservaYon System Management sooware that is cerYﬁed by NaYonal AssociaYon of Sewer Service Companies and complies with the Pipeline Assessment and CerYﬁcaYon Program (PACP). The informaYon obtained and recorded from the CCTV inspecYons is reviewed as assessed by City staﬀ. Permanent records of the inspecYons are made by capturing sYll images of defects and other perYnent observaYons. The City’s CCTV capability extends to various pipe sizes. InspecYons are performed by a two-person crew and are typically performed aoer the cleaning of the pipelines to be televised. Daily progress is recorded by the inspecYon crew and uYlized for recording, tracking, and reporYng purposes. As the necessity to televise a parYcular locaYon or porYon of the wastewater collecYon system arises, staﬀ assignments are reorganized, and resources are reallocated to accommodate the requirement. AddiYonally, the CCTV crews perform inspecYons to rouYnely monitor the eﬀecYveness of the cleaning eﬀorts crews.

DESIGN AND PERFORMANCE PROVISIONS
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5. Design and Performance Provisions 5.1. Updated Design Criteria/ConstrucBon Standards/SpeciﬁcaBons WDR REQUIREMENTS A>. D-1.1 (pg. D-5) Updated design criteria, and construcDon standards and speciﬁcaDons, for the construcDon, installaDon, repair, and rehabilitaDon of exisDng and proposed system infrastructure components, including but not limited to pipelines, pump staDons, and other system appurtenances. If exisDng design criteria and construcDon standards are deﬁcient to address the necessary component-speciﬁc hydraulic capacity as speciﬁed in secDon 8 (System EvaluaDon, Capacity Assurance and Capital Improvements) of this ATachment, the procedures must include component-speciﬁc evaluaDon of the design criteria. COMPLIANCE The City has complete standard speciﬁcaYons and drawings that are maintained by the City Engineering Division, which meet or exceed industry standards. These standards are used for guidance to all developers, design engineers, contractors, and City departments. The City’s current design and performance standards are addressed in its municipal codes and permiung procedures that allow the City to require and enforce the proper design, construcYon, and connecYons to the City’s collecYon system, and ensure access to the City sewer pipelines for maintaining, inspecYng, and repairing the system. Also referenced are the City of Fullerton standard drawings. To address the requirements as required by the WDR, the following subsecYons provide a summary of the applicable procedures that are currently being implemented. Further detailed informaYon of the design and performance standards and guidelines are included in Municipal Code of Title 12, Waters and Sewers, and Title 16 Subdivisions Design and ConstrucYon Standards and SpeciﬁcaYons Requirements for the design and construcYon of new, rehabilitated, and replaced sewer system faciliYes, including main, Ye-ins, service laterals, cleanout, manholes, and other system appurtenances, are necessary to ensure the proper operaYon of the sewer system. SecYon 12.08.120 Sewer design, of the City’s Municipal Code requires that all sewer mains, laterals, manholes, and other appurtenances be designed, constructed, and inspected in accordance with all applicable secYons of the Fullerton Municipal Code, Title 16 Subdivisions; the City of Fullerton standard drawings; the latest ediYon of the Greenbook or as required and approved by the City Engineer. The City of Fullerton Municipal Code 16.05 Public Improvements, DedicaYons, Performance Agreements, and Improvement SecuriYes, includes that serve to regulate and control the design and improvement of public works faciliYes. The City of Fullerton Municipal Code 16.05.020, requires that all wastewater improvements, construcYon, rehabilitaYon, and dedicaYons conform to the standards and speciﬁcaYons of the City and the applicable porYons of the latest ediYons of the Greenbook. The Ytle also grants the City Engineer the authority to amend and change such standards and speciﬁcaYons as deemed to be in the best public interest.

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 35 of 59 SecYon 16.05.040 Public improvements, includes the standards and criteria that shall apply for the design and construcYon of all public improvements required under Title 16. Part I, Sewerage FaciliYes, of SecYon 16.05.04 requires that sewer mains, manholes, and appurtenances be constructed to the sizes, lines, grades and design as approved by the City Engineer and as required by any Master Plan of Sewer or element of the General Plan in eﬀect. Design consideraYons for wastewater faciliYes that the City considers non-standards, such as pump or lio staYons, force mains, siphons, etc., require prior approval from the City before design can begin. EFFECTIVENESS Key Performance Indicators: • Is plan checking QA/QC processes helping to ensure adherence to the standards? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Eng 5.1.1 Ensure all project plans are approved in accordance with the City’s Standard SpeciﬁcaEons and Details. Each Project X

5.1.2 Verify design standards and hydraulic model previously completed are adequate and consistent with current standards of pracEce. 2025 X

5.2. Procedures and Standards WDR REQUIREMENTS A>. D-1.1 (pg. D-5) Procedures, and standards for the inspecDon and tesDng of newly constructed, newly installed, repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances. COMPLIANCE InspecYng and TesYng Compliance with the sewer Greenbook requires the contractor performing work on the City’s sewer faciliYes to be responsible for conducYng a CCTV inspecYon for all new and rehabilitated sanitary sewer systems and other appurtenances. The Greenbook includes procedures and standards for inspecYng and tesYng the installaYon of sewer mains and related appurtenances and for the rehabilitaYon and repair of exisYng sanitary sewer systems. Compliance with the Greenbook speciﬁcaYons requires air tests to be performed in accordance with SecYon 306-1.1.4. Also, it includes inspecYon and tesYng criteria for various pipe materials and installaYon methods. SecYon 500-1.2.6 requires the Engineer to review pipeline inspecYon video submi>ed by the Contractor to verity the pipeline point repair or replacement when retained for construcYon and installaYon of wastewater pipelines and manholes prior to backﬁlling. AddiYonally, SecYon 16.05.070, InspecYon of Public Improvements, requires that all improvements under Title 16 be subject to inspecYon and tesYng by the City Engineer or his authorized representaYves to ensure compliance with the standards and speciﬁcaYons. The secYon also requires that reasonable access to the construcYon and work be provided at all Yme to obtain full knowledge of the progress, workmanship and character of the material used in the work. EFFECTIVENESS Key Performance Indicators: • Were any design or installaYon deﬁciencies found during warranty inspecYons? • Are deviaYons from standard procedures and/or specs, tesYng, etc., jusYﬁed 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 DPW Mgr. Eng 5.2.1 Verify inspecEon procedures are adequate and consistent with current standards of pracEce 2017 (10-year cycle) X 5.2.2 Verify design standards and hydraulic model previously completed are adequate and consistent with current standards of pracEce. 2017 (10-year cycle) X

DESIGN AND PERFORMANCE PROVISIONS
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 37 of 59 RESILIENCE Resilience is addressed for Element 5 by: • Staying abreast of industry trends and standards. • Performing warranty inspecYons of newly installed or repaired assets to evaluate design and installaYon pracYces. • EvaluaYng as-built changes for trends and areas for design and performance improvements. APPENDIX 5 INCLUSIONS: • None

6. Spill Emergency Response Plan WDR REQUIREMENTS A>. D-1.1 (pg. D-6) The Plan must include an up-to-date Spill Emergency Response Plan to ensure prompt detecDon and response to spills to reduce spill volumes and collect informaDon for prevenDon of future spills. The Spill Emergency Response Plan must include procedures to: • NoDfy primary responders, appropriate local oﬃcials, and appropriate regulatory agencies of a spill in a Dmely manner; • NoDfy other potenDally aﬀected enDDes (for example, health agencies, water suppliers, etc.) of spills that potenDally aﬀect public health or reach waters of the State; • Comply with the noDﬁcaDon, monitoring and reporDng requirements of this General Order, State law and regulaDons, 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 operaDons, traﬃc control and other necessary response acDviDes; • 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, pracDces, equipment, and interagency coordinaDon to expedite spill containment and recovery; • Implement pre-planned coordinaDon and collaboraDon with storm drain agencies and other uDlity agencies/departments prior, during, and amer a spill event; • Conduct post-spill assessments of spill response acDviDes; • Document and report spill events as required in this General Order; and • Annually, review and assess eﬀecDveness 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: noYﬁcaYon, emergency incident response, reporYng, and impact miYgaYon. The current plan, prepared by Fischer Compliance, LLC, meets the requirements of the State Water Resources Control Board’s reissued Waste Discharge Requirements (Order WQ-2022-0103-DWQ), which became eﬀecYve on June 5, 2023. IniYal training has been provided to aﬀected staﬀ and refresher training is conducted annually. A copy of the SERP is available for viewing at the City oﬃce upon request.

SPILL EMERGENCY RESPONSE PLAN
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 39 of 59 EFFECTIVENESS Key Performance Indicators: • Have staﬀ 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 eﬀecYve and trainees demonstraYng adequate knowledge and abiliYes? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DPW Mgr. Sup 6.1 Perform SERP training including pracEce drills. Annually X X 6.2 Review Post Spill Assessments to ensure adherence and to indemnify any trends that should be addressed Annually X X RESILIENCE Resilience is addressed for Element 6 by: • MulYple staﬀ are trained to respond to spill events • Post-spill assessments are conducted to evaluate staﬀ adherence to the SERP and to idenYfy areas for improvement. • Data collecYon forms direct staﬀ to collect all the required data to be submi>ed to CIWQS and are designed as a guide to a proper spill event response. • The City employees several diﬀerent spill volume esYmaYon methods to account for diﬀerent circumstances. APPENDIX 6 INCLUSIONS: • None

7. Sewer Pipe Blockage Program WDR REQUIREMENTS A>. D-7 (pg. D-7) The Sewer System Management Plan must include procedures for the evaluaDon 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 jusDﬁcaDon in its Plan for why a program is not needed. The procedures must include, at minimum: a. An implementaDon plan and schedule for a public educaDon and outreach program that promotes proper disposal of pipe-blocking substances; b. 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 faciliDes and/or addiDonal faciliDes needed to adequately dispose of substances generated within a sanitary sewer system service area; c. The legal authority to prohibit discharges to the system and idenDfy measures to prevent spills and blockages. d. Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, best management pracDces requirements, recordkeeping and reporDng requirements; e. Authority to inspect grease producing faciliDes, enforcement authoriDes, and whether the Enrollee has suﬃcient staﬀ to inspect and enforce the fats, oils, and grease ordinance; f. An idenDﬁcaDon of sanitary sewer system secDons subject to fats, oils, and grease blockages and establishment of a cleaning schedule for each secDon; and g. ImplementaDon of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each secDon idenDﬁed above. COMPLIANCE City’s FOG Control Program The City is commi>ed to complying with the mandates set forth under the WDRs. To comply with the one of the eleven mandatory elements of the SSMP, the City is required to either prepare a FOG Control Program or demonstrate its exisYng preventaYve maintenance program eﬀecYvely reduces the quanYty and/or the eﬀects of FOG and other debris discharged to the wastewater collecYon system that may cause sewerage collecYon system blockages or spills. The City retained outside services to prepare the FOG CharacterizaYon Study, which was completed in 2004. The primary goal of the FOG CharacterizaYon Study was to idenYfy the source and nature of FOG within the City’s wastewater collecYon system and compile and categorize the ﬁndings. At that Yme, the study idenYﬁed over 400 FSE within the City’s service area. A map illustraYng the locaYon of the FSEs was developed and allowed the City to idenYfy potenYal HFMLs and facilitated development of a comprehensive GIS database to allow staﬀ to eﬃciently monitor FSEs, schedule and perform inspecYons, and issue permits. AddiYonally, the study included the inspecYon of approximately 50 percent of the FSEs during 2003-2004.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 41 of 59 The inspecYons were to determine pracYces related to the disposal of grease and idenYfy establishments that may discharge FOG into the wastewater collecYon system and that used the following: • Kitchen Equipment (deep fryer, wok, grill, etc.) • Kitchen Drains (sinks, garbage grinders, dishwashers, trashcan wash areas, etc.) • Grease Removal Equipment and Grease Disposal PracYces • Evidence of Kitchen BMPs • Trap Maintenance • Spill PrevenYon/Clean-up PracYces • EvaluaYon menu and FOG usage • Compliance with Uniform Plumbing Code The City developed and implemented the City of Fullerton Fats, Oils, and Grease Control Plan for the Sanitary Sewer System in 2005. The intent of the plan was to idenYfy the acYviYes necessary to facilitate the maximum beneﬁcial public use of the City’s sanitary sewer system while prevenYng blockages of the sewer lines and reducing the adverse eﬀects on sewage treatment operaYons resulYng from discharges of FOG into the system. The plan served as a basis for developing and implemenYng the City’s FOG Control Program. The City’s FOG Control Program summarizes the components of the processes and procedures intended to reduce the quanYty of FOG discharged into the City’s sanitary sewer system to achieve the goal of minimizing spills due to excessive FOG. The WDR requirements above are addressed in order below: a. Public EducaYon and Outreach The City maintains a presence at community events, such as the Farmer’s Market, Airport Days, and the City’s On the Go Program to promote best pracYces to help prevent the disposal of pipe blocking substances (Non-dispersible wipes, grease, etc.) into the collecYon system. In addiYon, has developed a ﬂyer to distribute to residents and businesses within the service area that explains responsibiliYes and promotes kitchen best pracYces and lists items that should not be disposed of in the sewer system. Field staﬀ have informaYonal doorhangers that are used for targeted outreach when called for. b. Disposal of Pipe-Blocking Substances Pipe blocking substances collected during maintenance acYviYes, primarily through hydro-cleaning acYviYes, are collected and disposed of. Each hydro-vac debris tank has the capacity to hold up to 1,200 gallons of water, which is forced through the je>er nozzle at approximately 2,000 pound of pressure per square inch. The sewer mains are typically cleaned by inserYng a high-pressure water jeung nozzles in the pipeline and removing the debris from a downstream manhole. The types of nozzles used vary based on the type of cleaning performed including rouYne cleaning, root removal, or grit removal. The debris that is removed from the sewer mains is separated into solid and liquid waste tanks as it is vacuumed into the truck. Liquids that are re-released back into the system are generally stored in special containers at Basque Yard and once ﬁlled, the waste is disposed of at the OCSD in Fountain Valley. Hydro-vac debris tanks are empYed on an as-needed basis. c. Legal Authority to Prohibit Discharges The City’s current legal authority to limit and prohibit FOG from entering the City’s wastewater collecYon system is established through its exisYng municipal codes, ordinances, and permiung procedures. SecYon Chapter 12.20 FOG Control Ordinance of the Fullerton Municipal Code includes

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 42 of 59 the requirements and prohibiYons pertaining to the use of the City’s wastewater collecYon system. Speciﬁcally, SecYon 12.20.050. ProhibiYons, of the City’s Municipal Code, includes a general descripYon of the various types of substances restricted by the City from being directly or indirectly discharged into the collecYon system. The restricYons are applicable to all users of the City’s system. FOG Ordinance No. 3051, which serves to adopt the City’s Fats, Oils, and Grease Program, also speciﬁes appropriate FOG discharge requirements, limitaYons, and prohibiYons for FSEs to prevent blockages of sewer lines resulYng from discharges of FOG. The key elements of the FOG Control Program include Waste Discharge Permit Requirements; Kitchen BMPs; the installaYon, operaYons and maintenance of approved type and adequately sized grease control device(s); and the noYﬁcaYon, monitoring, reporYng and record keeping condiYons. d. Requirements to Install Grease Removal Devices The requirement for the installaYon of a grease control devices is a key component of the City’s Municipal Code and FOG Control Program. SecYon 12.20.210. Grease Interceptor Requirements, and SecYon 12.20.220, Grease Trap Requirements, includes a descripYon of the requirements for the installaYon of grease interceptors and grease traps. The City requires sizing and installaYon of grease interceptors and grease traps to conform to the applicable secYons of the current ediYon of the California Plumbing Code (CPC) or as required by the FOG Control Manager. FOG Ordinance No 3051 included amendments to various secYons of the 2001 CPC. Speciﬁcally, SecYon 14.07.070 and 14.07.080 were added to and serve to amend SecYons 1014.1 and 1014.6 of the CPC, respecYvely. SecYon 14.07.070 modiﬁes the CPC to grant the City the administraYve authority to require all FSEs to install and operate a grease control device in conformance with Chapter Chapter 12.20 FOG Control Ordinance, of the Municipal Code. SecYon 14.07.080 establishes more speciﬁc maintenance requirements for grease interceptors in accordance with the Chapter Chapter 12.20 FOG Control Ordinance, of the Municipal Code. SecYon 12.20.250, Grease Interceptor Maintenance Requirements, of the City’s Municipal Code outlines the provisions for maintaining the grease interceptors in proper operaYonal condiYons. AddiYonally, to ensure proper operaYon and maintenance of the approved grease control devices, the FOG Control Program includes monitoring and reporYng condiYons that may require the FOG Control Program Manger to idenYfy any deﬁciencies in meeYng the requirements of the permit. e. Authority to Inspect Grease Producing FaciliYes ImplementaYon of the FOG Control Program requires all FSEs to obtain and renew a FOG Waste Discharge Permit. Although the requirements for compliance with the permit may vary among FSEs, generally each permit will require the FSE to meet the requirements for installaYon of FOG removal devices where required, comply with applicable City policies, and pay all required fees as set forth by the permit fee schedule. SecYon 12.20.270. InspecYon and Sampling CondiYons, allows the FOG Control Manager to enter the premises for purposes of inspecYng the grease control devices, reviewing manifests, records, and other applicable documents related to the cleaning, maintenance and inspecYon of the sewer

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 43 of 59 conveyance system and grease control devices to determine compliance with the condiYons of the Waste Discharge Permit, FOG Control Program, and City ordinances. SecYon 12.20.280, Right of Entry requires persons or occupants of FSE to allow the FOG Control Program Manager, or designated City representaYves, access to all parts of the wastewater generaYng and disposal faciliYes for purposes of inspecYng and sampling. AddiYonally, the secYon authorizes City representaYves a>empYng to inspect any facility involved directly or indirectly with a discharge of wastewater into the City’s sewer system, access to adjoining businesses or properYes that share a sewer conveyance system with an FSE in order to prevent or remediate an actual or imminent spill. ImplementaYon of the City’s maintenance procedures has been successful in minimizing the number of spills and addressing the high frequency maintenance locaYons, the City intends to conYnue its current FOG Control Program. f. IdenYﬁcaYon of FOG in CollecYon System The performance and scheduling of prevenYve, operaYon and maintenance acYviYes is performed by the City’s Source Control Inspectors. The PreventaYve Maintenance Program includes a cleaning cycle for the areas that have been idenYﬁed by City staﬀ as “special projects.” The City’s “special projects” include pipe segments idenYﬁed as having high FOG, root concentraYons, and siphons. The pipe segments within the wastewater collecYon system idenYﬁed as “special projects” are rouYnely cleaned on a 1, 3, 6, or 12-month intervals based on ﬁeld observaYons. g. ImplementaYon of Source Control Measures The Sewer Division has two Source Control Inspector assigned to the FOG Control Program that is responsible for conducYng the scheduled FSE inspecYons schedule, meeYng reporYng requirements, adjusYng and implemenYng addiYons/changes to the inspecYon schedule as FSEs are established, closed, or where there is a change in ownership or operaYons. While the exisYng Source Control Inspector has successfully conducted the Ymely inspecYons of restaurants, adding an addiYonal inspector would allow the City to implement the following programs: • EducaYonal component of the FOG Control Program: As the FOG Control Program is primarily concentrated on educaYng FSE staﬀ, the addiYonal inspector would be focused on performing the iniYal educaYonal site visits. • InspecYon of business that include food processing, which create packaged meals or process cooking oil, and determined that these businesses are considered FSE and are inspected for proper grease control programs. • Commercial and industrial oil/water separator program: Although oil/water separators are installed in non-food service environments such as car washes, loading docks, and service staYons, or anywhere where oil and other toxins can mix with runoﬀ water, they operate similar to grease interceptors and are part of the City’s overall NPDES compliance eﬀorts.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 44 of 59 EFFECTIVENESS Key Performance Indicators: • Have there been any blockages/spills from any idenYﬁed problem area? • Is the agency receiving feedback on public outreach eﬀorts? • Are debris and other sewage solids collected during cleaning acYviYes 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 CollecYon staﬀ included in the plan check process? IMPLEMENTATION PLAN/SCHEDULE No Plan Schedule Responsible Party DPW Mgr. Sup 7.1 Review/evaluate enforcement and inspecEon ﬁndings and implement changes as necessary. Annually X X

7.2 Review spill rates and causes and make changes to maintenance programs, as necessary. Annually X X RESILIENCE Resilience is addressed for Element 7 by: • InspecYon of select assets directly downstream of grease producing businesses to ensure source control is eﬀecYve. • ResidenYal FOG outreach and educaYon program. • Performance of regular assessments of system assets to monitor performance. • QA/QA process for evaluaYng pipe cleaning eﬀecYveness. • Daily disposal of pipe blocking materials retrieved during maintenance acYviYes. APPENDIX 7 INCLUSIONS: • None

8. System Evalua*on, Capacity Assurance, Capital Improvements WDR REQUIREMENTS A>. D-8 (pgs. D-7/D-8) The Plan must include procedures and acDviDes for: • RouDne evaluaDon and assessment of system condiDons. • Capacity assessment and design criteria. • PrioriDzaDon of correcDve acDons; and • A capital improvement plan. 8.1. System EvaluaBon and CondiBon Assessment WDR REQUIREMENTS A>. D-8 (pgs. D-7/D-8) The City SSMP must include procedures to: a. Evaluate the sanitary sewer system assets uDlizing the best pracDces and technologies available. b. IdenDfy and jusDfy the amount (percentage) of its system for its condiDon to be assessed each year. c. PrioriDze the condiDon 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 elevaDons, and environmentally sensiDve areas; • Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act secDon 303(d) List. d. Assess the system condiDons using visual observaDons, video surveillance and/or other comparable system inspecDon methods. e. UDlize observaDons/evidence of system condiDons that may contribute to exiDng of sewage from the system which can reasonably be expected to discharge into a water of the State. f. Maintain documents and recordkeeping of system evaluaDon and condiDon assessment inspecDons and acDviDes; and g. IdenDfy system assets vulnerable to direct and indirect impacts of climate change, including but not limited to: (a) sea level rise, (b) ﬂooding and/or erosion due to increased storm volumes, frequency, and/or intensity; (c) wildﬁres; and (4) increased power disrupDons.

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENT © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 46 of 59 COMPLIANCE The above requirements are addressed in order below: a. Evaluate System Using Best PracYces and Technologies The assessment of a collecYon system involves every component of the City collecYon system, including pipelines, manholes, and siphons. The assessment of pipeline condiYon is the most signiﬁcant condiYon assessment responsibility the City has. It is of key importance to regularly perform pipeline condiYon assessments to iniYally establish a condiYon baseline so condiYons can be monitored over Yme. The condiYon raYng of a pipeline is one of the key parameters used prioriYzing risk, which in turn is used to help develop the City’s CIP. The City has divided their system into three (3) Districts and 52 sub- basins, allowing for eﬃcient and systemaYc assessment of the collecYon system. and ﬁeld staﬀ inspect the system in a systemaYc manner, which improves eﬃciency, allowing to City to achieve the goal of properly maintaining the system. Field staﬀ monitors easements to help ensure access. There are occasions when acYviYes are performed on or about easements, which can create access concerns, such as the construcYon of a shed or other outbuildings, installaYon of a fences, swimming pools (above and below surface), dumping of garbage and trash that blocks drivable easements, to name a few. City has a manhole inspecYon program, and inspecYons are performed during cleaning operaYons and manholes are inspected employing a visual, top-down approach, without entry, and documented in the Lucity CMMS (every 5 years.) b. JusYfy the Amount of Yearly CondiYon Assessment Currently the City has one CCTV truck and dedicates two staﬀ to operate it. Staﬀ assesses the condiYon of the collecYon system on a ﬁve-year interval (+/- 65 miles/year). The City maintains a relaYvely low spill rate, incurring only 3 spills between 1/1/2018 and 1/1/2025. In addiYon, the City cleans the system on an 18-month interval, which means the pipes will be cleaned over three (3) Ymes between inspecYon cycles. Though the current ﬁve-year cycle seems appropriate for the City’s collecYon system, staﬀ is evaluaYng their current pracYces to help ensure an opYmal inspecYon cycle. c. PrioriYze CondiYon Assessment The City CCTV inspects all gravity mains and manholes on a ﬁve-year interval and is knowledgeable about the performance of its collecYon system. Staﬀ believes it is appropriate to address all pipe segments in the same manner as the risk and consequence of a spill from any porYon of the collecYon is essenYally the same. Field staﬀ use proﬀer skids, one size down from the pipe diameter, and monitors debris found during pipe cleaning acYviYes and would recognize if there was a signiﬁcant failure. As menYoned previously, gravity mains are cleaned every 18 months. The City performs top-down, visual inspecYons of manholes and video inspecYons of gravity mains. Level monitors and ﬂow monitoring devices are uYlized to monitor ﬂow condiYons, pipe performance and inﬁltraYon. The City is not aware of exﬁltraYon from their collecYon system. The City has idenYﬁed all sewage conveyance faciliYes near surface water. Approximately 6044 feet of gravity main runs parallel to creeks and some have been lined. Other pipes located near surface water are located within the

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENT © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 47 of 59 public right-of-way, in streets and show no evidence of defects that could lead to exﬁltraYon. The City conYnuously monitors defects such as cracks, separated joints, and inﬁltraYon. Signiﬁcant ﬁndings will be addressed in a Ymely manner. d. CCTV inspecYons are documented in the POSM sewer inspecYon sooware. The City documents all maintenance acYviYes in the Lucity CMMS. All collected data is used for the purpose of documenYng maintenance eﬀorts, evaluaYng system performance, and making maintenance and correcYve acYon decisions today and into the future. e. The City, generally its service area and has determined that ﬂooding is the one climate change impact that aﬀects the sewer system. The City has idenYﬁed areas suscepYble to ﬂooding and has implemented a program to seasonally plug the vent and pick holes in manhole covers. EFFECTIVENESS Key Performance Indicators: • Has the City maintained its schedule and is data being reviewed in a Ymely manner? • CCTV Gravity Mains • Laterals • Manholes • Are inspecYon eﬀorts discovering deﬁciencies in a Ymely manner? • Are maintenance and inspecYon acYviYes properly documented? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Mgr. Sup 8.1.1 Review/evaluate enforcement and inspecEon 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 X 8.1.3 Hold meeEng to discuss any issues that may result from climate changes Annually X X X

8.2. Capacity Assessment and Design Criteria WDR REQUIREMENTS A>. D-8 (pgs. D-7/D-8) The Plan must include procedures to idenDfy system components that are experiencing or contribuDng to spills caused by hydraulic deﬁciency and/or limited capacity, including procedures to idenDfy the appropriate hydraulic capacity of key system elements for: • Dry-weather peak ﬂow condiDons 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 • IdenDfy the major sources that contribute to the peak ﬂows associated with sewer spills. The capacity assessment must consider: • Data from exisDng system condiDon assessments, system inspecDons, system audits, spill history, and other available informaDon. • Capacity of ﬂood-prone systems subject to increased inﬁltraDon and inﬂow, under normal local and regional storm condiDons. • Capacity of systems subject to increased inﬁltraDon 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 condiDons, and updated design storm and wet weather events; and • Necessary redundancy in pumping and storage capaciDes. COMPLIANCE In October 2024, the City updated its Sewer System Master Plan. The capacity assessment completed as part of the City’s Sewer Master Plans was based on hydraulic modeling of the City’s collecYon system under current and future design ﬂows. The objecYve of the plan was to: • Update the City’s exisYng sewer model with system improvements completed since the 2009 Sewer Master Plan. • Using recent ﬂow monitoring data, allocate dry weather sewer ﬂows throughout the system and calibrate the hydraulic model to exisYng dry and wet weather ﬂow condiYons. • Evaluate the exisYng and future capacity of the City’s collecYon system under both dry and wet weather condiYons. • Perform condiYon assessment of pipelines throughout the collecYon system. • Develop a prioriYzed list of recommended Capital Improvement Program (CIP) projects, with engineer’s cost esYmates, intended to address anYcipated pipeline capacity and/or condiYon concerns. Both dry weather and wet weather capacity analyses were performed on the modeled system under ExisYng,

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENT © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 49 of 59 Near-Term (2030) and UlYmate (2045) loading condiYons. The dry weather analysis indicated that no pipeline in the modeled system is anYcipated to exceed capacity under dry weather condiYons. During peak wet weather ﬂows, which includes a 10-year storm, two deﬁciencies were idenYﬁed. The Master Plan idenYﬁes the areas with the highest inﬁltraYon and inﬂow (I/I) based on ﬂow monitoring data. Basins idenYﬁed with the highest I/I were generally sewered with pipes constructed before 1960 and therefore suggested that the pipes were potenYally deteriorated such that high levels of inﬁltraYon were entering the system through cracks and other defects. The analysis determined that the wastewater system did not experience a signiﬁcant amount of ground water inﬁltraYon and that elevated levels of inﬁltraYon did not persist during the enYre wet weather seasons. CondiYon assessment reports were reviewed to determine an appropriate rehabilitaYon or repair method intended to address observed structural and other physical defects. The reports were generated between 2008 and 2024 and used in preparaYon for this Sewer Master Plan Update. EFFECTIVENESS Key Performance Indicators: • Number of capacity-related spills or surcharge condiYons during the audit period? • Has the system responded to rain events as indicated by the hydraulic model? • Have there been any changes to zoning designaYons (residenYal, commercial, industrial)? 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 IdenEfy and monitor ﬂood-prone areas suscepEble to erosion from rain events Amer each signiﬁcant rain event X X 8.2.3 Monitor ﬂows in each basin and updates the hydraulic model Per Engineering Division schedule X

8.3. PrioriBzaBon of CorrecBve AcBon WDR REQUIREMENTS A>. D-8 (pgs. D-7/D-8) The ﬁndings of the condiDon assessments and capacity assessments must be used to prioriDze correcDve acDons. PrioriDzaDon must consider the severity of the consequences of potenDal spills. COMPLIANCE The determinaYon of repair priority for short-term repair acYviYes and long-term CIP projects can be very challenging due to the complexity in analyzing all the various factors aﬀecYng the pipeline’s risk of failure. All defects discovered from CCTV inspecYons of the gravity system are rated using the PACP defect coding system. Repairs are prioriYzed by considering the severity of defect, likelihood the defect would cause a spill and the consequence of a spill at that locaYon. CollecYons staﬀ, in coordinaYon with engineering, evaluates and prioriYzes each defect and determines which repairs will be performed in house and which will be performed by contracted services. Larger, more involved work such as install liners and line replacement or rehabilitaYon is recommended by collecYon staﬀ, and engineering designs the project and includes the projects in the CIP. When prioriYzing work to be done, staﬀ considers all factors such as locaYon of facility to surface water or other environmentally sensiYve areas, diﬃculty of access and likelihood and consequence of failure or inacYon. As a rule, for idenYﬁed capacity improvements, any potenYal capacity deﬁciencies idenYﬁed under peak dry weather ﬂows (PDWF) condiYons will be prioriYzed over those anYcipated under peak wet weather ﬂow (PWWF) condiYons. EFFECTIVENESS Key Performance Indicators: • Has the City adhered to its system evaluaYon/condiYon assessment schedule? • Has the City adhered to its prioriYzaYon/correcYve 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 Mgr Sup 8.3.1 UElize all available data for prioriEzing correcEve acEons considering severity and consequences of potenEal spills. Each CIP Update X X

8.3.2 Maintain documents and recordkeeping of system evaluaEon and condiEon assessment inspecEons and acEviEes.

ConEnuously X X

8.4. Capital Improvement Plan WDR REQUIREMENTS A>. D-8 (pgs. D-7/D-8) The capital improvement plan must include the following items: a. Project schedules include compleDon dates for all porDons of the capital improvement program. b. Internal and external project funding sources for each project; and c. Joint coordinaDon between operaDon and maintenance staﬀ, and engineering staﬀ/consultants during planning, design, and construcDon of capital improvement projects; and Interagency coordinaDon with other impacted uDlity agencies. COMPLIANCE The City’s Sewer Master Plan idenYﬁes the wastewater collecYon system CIP short and long-term projects necessary to correct idenYﬁed system deﬁciencies. A comprehensive list of Capital Improvement Program (CIP) projects, including projected costs, for the City’s exisYng collecYon system was developed based on the results of the capacity analysis and condiYon assessment. A total of two gravity main capacity improvements were idenYﬁed as hydraulically deﬁcient, as well as needing replacement due to poor condiYon, indicaYng a high priority. Repair and RehabilitaYon Projects - The City’s preventaYve maintenance program serves as a basis for idenYfying the repair, replacement, and/or rehabilitaYon improvements to the collecYon system and provides for the eliminaYon of high frequency maintenance locaYons and/or “hot spots” through capital investment in permanent repairs and replacements. For the implementaYon of repairs that extend beyond the City’s internal resource capabiliYes, the City retains the services of professional contractors. Repairs that require further prioriYzaYon and planning are coordinated and scheduled with the City’s CIP. CIP Development - Using the results of CCTV inspecYon eﬀorts, crews idenYfy pipeline secYons with structural damage, capacity issues, and/or locaYons where there is potenYal for a spill occurrence. Where structural defects are noted, numeric values are assigned and using the PISCES sooware, a risk assessment is performed. The Sewer Division’s management team works with the Engineering Division to idenYfy and prioriYze capital improvement and repair projects. The Sewer Division managers provide a report that idenYﬁes and summarizes the system deﬁciencies. The list of priority projects is rouYnely updated and evaluated by the Engineering Department and the projects are systemaYcally scheduled and incorporated into the City’s exisYng CIP. Several factors determine the priority of projects idenYﬁed during the assessment process, although the condiYon of the pipe is usually the primary factor. AddiYonal factors may include goals to reduce sanitary sewer overﬂows, providing suﬃcient system capacity, reducing I/I into pipes located below the water table, or reducing maintenance eﬀorts by improving the pipe condiYon. Other consideraYons include coordinaYng the surface and uYlity improvements with the other agencies that may be impacted by improvements

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENT © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 52 of 59 2024 Sewer Master Plan, Appendix E, provides a summary of CIP projects, while Appendix F includes project cost details. Funding for capital improvement and replacement of the sewer system is generated through the Sewer Service Fee. EFFECTIVENESS Key Performance Indicators: • Has the agency’s capital improvement plan schedule been adhered to? • Have there been any instances when a failure or service disrupYon occurred that would have been prevented if a project been completed? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Eng Sup 8.4.1 Hold regular coordinaEon meeEngs, with all parEes, to help keep the projects on track and resolve issues that may arise in a Emely manner. Annually X X

8.4.2 For schedules that are not kept, jusEfy and document the reason Each Delayed Project X RESILIENCE Resilience is addressed for Element 7 by: • Is there an annual review of the Capital Improvement Plan by all appropriate individuals including both Engineering and OperaYons? APPENDIX 8 INCLUSIONS 8.1 2024 Sewer Master Plan and Capital Improvement Program.

9. Monitoring, Measurement, and Program Modiﬁca*ons WDR REQUIREMENTS A>. D-9 (pg. D-9) The City SSMP must include an AdapDve Management secDon that addresses Plan implementaDon eﬀecDveness and the steps for necessary Plan improvement, including: a. Maintaining relevant informaDon, including audit ﬁndings, to establish and prioriDze appropriate SSMP acDviDes. b. Monitoring the implementaDon and measuring the eﬀecDveness of each element. c. Assessing the success of the prevenDve operaDon and maintenance acDviDes. d. UpdaDng SSMP procedures and acDviDes, as appropriate, based on results of monitoring and performance evaluaDons; and e. IdenDfying and illustraDng spill trends, including spill frequency, locaDons, and esDmated volumes. COMPLIANCE The above requirements are addressed in order below a. The City maintains accurate and relevant inspecYon and maintenance records for the collecYon system. Much of the documentaYon today is maintained electronically, which allows for ease of access and analysis. This helps City staﬀ to make sound decisions and prioriYze acYviYes when dealing with the rouYne and the unexpected. b. Monitoring of the City’s SSMP focuses on each element in terms of its implementaYon and eﬀecYveness. Monitoring the implementaYon of SSMP elements would achieve the following goals: • Stated objecYves of each element are valid and achievable • Tasks cited in each element leads to reaching these objecYves • Tasks are being implemented • Responsibility for implementaYon is idenYﬁed By establishing speciﬁc performance indicators for each element, an assessment can be made to determine the degree of success achieved. The SSMP has been designed to include key performance indicators (KPIs) for each element, which are used to measure eﬀecYveness. c. The City Assesses the success of maintenance and operaYon acYviYes by ensuing acYviYes are being performed as expected by performing quality assurance reviews, monitoring actual outcomes compared to intended outcomes, as well as monitoring spill trends. d. The City is commi>ed to conYnuous 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 requires that the SSMP be updated every six years, the SSMP should be considered as a dynamic document and may require updaYng on a more frequent basis. RouYne changes to administraYve informaYon, notwithstanding, minor changes will likely be required to address improvements idenYﬁed through the SSMP Audit or through modiﬁcaYons required as condiYons change.

MONITORING, MEASURING, AND PROGRAM MODIFICATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 54 of 59 e. The City monitors and analyzes spill trends, at a minimum every three (3) years during required audits, uYlizing the CMMS database, inspecYon records and CIWQS data. In addiYon, spill trends are monitored and analyzed annually, when the Annual Report is submi>ed, by reviewing the Performance Analysis graphs that are required to be produced and submi>ed in the report. These reviews and analysis are helpful in planning and programing work, and adjusYng as needed, enabling the City to be adapYve and capitalize on lessons learned. EFFECTIVENESS Key Performance Indicators: • Are SSMP Elements periodically evaluated for eﬀecYveness? • Are work acYviYes 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? • Have work programs been assessed and updated as necessary? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Mgr. Sup 9.1 Assess work programs to ensure outcomes are as intended Annually X X 9.2 Ensure updates to work programs and the SSMP based on assessments. As Needed X X 9.3 Monitor and evaluate spill trends. Document eﬀorts. Annually X X RESILIENCE Resilience is addressed for Element 9 by: • Development of key performance indicators to measure eﬀecYveness of the Sewer System Management Plan. • Performing periodic reviews of the Sewer System Management Plan to help ensure the plan is being properly implemented. • Developing and adhering to a Ymeline to correct deﬁciencies found during the audit process. • Periodically evaluaYng work programs to help ensure eﬀecYveness. APPENDIX 9 INCLUSIONS: • None

10. Internal Audits WDR REQUIREMENTS A>. D-10 (pg. D-10) The City SSMP shall include internal audit procedures, appropriate to the size and performance of the system, for the Enrollee to comply with secDon 5.4 (Sewer System Management Plan Audits) of this General Order. COMPLIANCE The above requirements are addressed in order below a. The City will complete audits every three (3) years moving forward. The objecYve of the audit is to evaluate compliance, implementaYon and eﬀecYveness of the SSMP. b. The SSMP includes a descripYon of how the City will comply with the requirements of each Element. The audit review includes an evaluaYon to determine if compliance has been met. c. ImplementaYon is evaluated by determining if the agency is execuYng the SSMP as stated. d. EﬀecYveness is evaluated by using key performance indicators, which have been developed speciﬁcally for each element. e. An addiYonal evaluaYon is performed to comply with SpeciﬁcaYons 5.6 addressing resilience. Resilience indicators have been developed for each element, and they serve to demonstrate how resilience is built into the SSMP and inspecYon, maintenance and spill response acYviYes. f. Any deﬁciencies discovered through the audit process are noted and a plan and schedule to implement correcYve measures are established. EFFECTIVENESS Key Performance Indicators: • Have audits been performed as required? • Have the audits assessed compliance, implementaYon, and eﬀecYveness? • Have deﬁciencies been idenYﬁed? • Has a plan and schedule to recYfy the deﬁciencies been established?

INTERNAL AUDITS
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 56 of 59 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party DIR Mgr SUP 10.1 Schedule audits in advance of due dates to ensure adequate Eme to complete. Agency has 6 months to complete the audit from the end of the audit period.

Begin end of audit period X X

10.2 Ensure a plan and schedule is developed to address deﬁciencies. Once the Audit is completed X X RESILIENCE Resilience is addressed for Element 10 by: • Periodically evaluate key performance indicators during the audit period to assess eﬀecYveness and make correcYons, if necessary, prior to the audit. • Evaluate previous audit to ensure deﬁciencies have been recYﬁed. • Calendar the audit due dates and complete the audit on Yme. APPENDIX 10 INCLUSIONS: • None

11. Communica*on Program WDR REQUIREMENTS A>. D-11 (pg. D-10) The Plan must include procedures for the Enrollee to communicate with: a. The public for: b. Spills and discharges resulDng in closures of public areas, or that enter a source of drinking water, and c. The development, implementaDon, and update of its Plan, including opportuniDes for public input to Plan implementaDon and updates. d. Owners/operators of systems that connect into the Enrollee’s system, including satellite systems, for: e. System operaDon, maintenance, and capital improvement-related acDviDes. COMPLIANCE a. When the City experiences a spill, it is standard procedure to secure the aﬀected area and keep the public away. This is generally done using barricades, cones and cauYon tape. Should the City experience a spill that may require closure of public areas or enter a source drinking of water, signs will be immediately placed indicaYng the issue and providing contact informaYon. Staﬀ will remain on site to provide an addiYonal safety factor unYl appropriate authoriYes respond and direct otherwise. In all cases, the City will follow the advice of higher authoriYes, such as the local environmental health department and other regulatory authoriYes. There are several opportuniYes for the public to parYcipate and provide input into the development and update of the City SSMP. During its iniYal 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. As previously noted, SSMP Audits are performed every two years and re-cerYﬁcaYon and acceptance of updated SSMPs are required every ﬁve years. In addiYon to the extensive iniYal development process, to date there have been ﬁve updates and re-cerYﬁcaYons of the SSMP that have been presented to the Board. Prior to each Council MeeYng, these documents are included in Board Agenda packet which are readily available for review on the City’s website. The SSMP is posted on the City’s website, which provides the public several ways to contact the City, via the “Contact Us” feature. b. The City does not currently have satellite systems. EFFECTIVENESS Key Performance Indicators: • Does the agency place all Sewer System Management Plan acYon items on the agenda for regular counsel/board meeYngs? • Does the agency have signage, or other means, readily available to noYfy the public of environmental or public risk factors related to a sewage spill? • Does the agency perform outreach to residenYal customers?

COMMUNICATION PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 58 of 59 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Mgr Sup 11.1 Ensure the City Counsil approves the SSMP per schedule Every 6 years X X 11.2 Ensure the SSMP is posted on the City Website and the link funcEons properly. Annually X X 11.3 Ensure Sewage Spill Warning signs are readily available to communicate with the public when necessary Annually X RESILIENCE Resilience is addressed for Element 11 by: • Use the Sewer System Management Plan as a tool to communicate to the public how the agency is managing the system. • Maintain a consistent presence in the service area by a>ending community events or issuing periodic newsle>ers or other communicaYons to the public. • Make it clear and easy for the public to contact the agency. APPENDIX 11 INCLUSIONS • None

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 59 of 59 LIST OF APPENDICIES APPENDIX 1 § None APPENDIX 2 § None APPENDIX 3 § None APPENDIX 4 § None APPENDIX 5 § None APPENDIX 6 § None APPENDIX 7 § None APPENDIX 8 § 8.1 Capital Improvement Program APPENDIX 9 § None APPENDIX 10 § None APPENDIX 11 § None APPENDIX 12 § 12.1 SSMP EﬀecYveness Worksheet

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Fullerton use only Page 61 of 61 APPENDIX 12 § 12.1 SSMP Eﬀec,veness Worksheet
APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 1 of 13 SSMP Eﬀec)veness Worksheet CONTENTS ELEMENT 1 – INTRODUCTION AND GOALS .................................................................................................... 2 ELEMENT 2 – ORGANIZATION ........................................................................................................................ 3 ELEMENT 3 – LEGAL AUTHORITY .................................................................................................................... 4 ELEMENT 4 – OPERATIONS AND MAINTENANCE ........................................................................................... 5 ELEMENT 5 – DESIGN AND PERFORMANCE PROVISIONS .............................................................................. 7 ELEMENT 6 – ELEMENT 6 – SPILL EMERGENCY RESPONSE PLAN ................................................................... 8 ELEMENT 7 – SEWER PIPE BLOCKAGE PROGRAM .......................................................................................... 9 ELEMENT 8 – SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPTIAL IMPROVEMENTS ............................ 10 ELEMENT 9 – MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ....................................... 11 ELEMENT 10 – INTERNAL AUDITS ................................................................................................................. 12 ELEMENT 11 – COMMUNICATIONS PROGRAM ............................................................................................ 13 APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 2 of 13 ELEMENT 1 – INTRODUCTION AND GOALS ELEMENT 1 No. Assessment Criteria Yes No 1.1 None ☐ ☐ 1.2 Are SSMP Audits and SSMP Updates being performed as scheduled? ☐ ☐ 1.2 Has the Sewer System Management Plan been approved by the governing board on schedule (every six years)? ☐ ☐ 1.2 Are speciﬁc internally established sewer program milestones being monitored? ☐ ☐ 1.3 Are asset staGsGcs periodically reviewed and updated as necessary? ☐ ☐ 1.3 Are correcGons addressed in a Gmely manner? ☐ ☐ 1.3 Are system maps up to date? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 3 of 13 ELEMENT 2 – ORGANIZATION ELEMENT 3 No. Assessment Criteria Yes No 2.0 Have there been any changes requiring updates to the OrganizaGonal Chart? ☐ ☐ 2.0 Have there been instances when a service call for a spill was not properly routed to response personnel? ☐ ☐ 2.0 Were all spill response acGviGes documented and forwarded to the LRO? ☐ ☐ 2.0 Have there been any changes in assigned responsibiliGes for implemenGng the Sewer System Management Plan? ☐ ☐ 2.0 Is there a process in place to ensure all contact informaGon remains up to date? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 4 of 13 ELEMENT 3 – LEGAL AUTHORITY ELEMENT 3 No. Assessment Criteria Yes No 3.0 Are the Agency ordinances and standards adequate for fulﬁlling the Sewer System Management Plan legal requirements? ☐ ☐ 3.0 Does the Agency have a process in place for periodic review and evaluaGon of ordinances? ☐ ☐ 3.0 Have there been instances when the code or ordinance did not address a need or circumstance? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 5 of 13 ELEMENT 4 – OPERATIONS AND MAINTENANCE ELEMENT 4 No. Assessment Criteria Yes No 4.1 Were all map updates completed in a Gmely manner? ☐ ☐ 4.1 Are all staﬀ trained in the procedure for providing map update informaGon? ☐ ☐ 4.1 Are newly installed sewer assets incorporated into the system maps? ☐ ☐ 4.1 Are there terrain features or assets that should be incorporated in future map updates (e.g. exposed pipe, siphons, ARVs, surface water, etc.) ☐ ☐ 4.2 Is the agency’s maintenance, operaGons, engineering work orders periodically audited for accuracy and completeness? ☐ ☐ 4.2 Does the agency monitor “open,” “overdue,” or “not yet completed” work orders to ensure compleGon of tasks? ☐ ☐ 4.2 Are inspecGon and maintenance acGviGes reducing the number and volume of spills? ☐ ☐ 4.2 Is maintenance work being completed as scheduled? ☐ ☐ 4.3 Has all training been completed as scheduled? ☐ ☐ 4.3 Have records of training and aZendance been documented and maintained? ☐ ☐ 4.3 Have all staﬀ demonstrated ability and knowledge a[er each training event? ☐ ☐ 4.3 Have contractors received, at a minimum, direcGon for reporGng and responding to spills. ☐ ☐ 4.4 Have inventory lists been audited as scheduled? ☐ ☐ 4.4 Have any inventory deﬁciencies or omissions been discovered and recGﬁed? ☐ ☐ 4.4 Has the agency experienced any equipment failure that inhibited a spill response? ☐ ☐ Comments APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 6 of 13 ELEMENT 4 Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 7 of 13 ELEMENT 5 – DESIGN AND PERFORMANCE PROVISIONS ELEMENT 5 No. Assessment Criteria Yes No 5.1 Are the Agency ordinances and standards adequate for fulﬁlling the Sewer System Management Plan legal requirements? ☐ ☐ 5.2 Were any design or installaGon deﬁciencies found during warranty inspecGons? ☐ ☐ 5.2 Are deviaGons from standard procedures and/or specs, tesGng, etc., jusGﬁed and documented? ☐ ☐ 5.2 Does the Agency stay abreast of industry design standards and technical advances in the industry? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 8 of 13 ELEMENT 6 – ELEMENT 6 – SPILL EMERGENCY RESPONSE PLAN ELEMENT 6 No. Assessment Criteria Yes No 6.0 Have staﬀ spill response eﬀorts helped to prevent the discharge of sewage to surface waters? ☐ ☐ 6.0 Do post-spill assessments indicate staﬀ are following the procedures outlined in the SERP? ☐ ☐ 6.0 Is SERP training eﬀecGve and trainees demonstraGng adequate knowledge and abiliGes? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 9 of 13 ELEMENT 7 – SEWER PIPE BLOCKAGE PROGRAM ELEMENT 7 No. Assessment Criteria Yes No 7.0 Have there been any blockages/spills from any idenGﬁed problem area? ☐ ☐ 7.0 Is the agency receiving feedback on public outreach eﬀorts? ☐ ☐ 7.0 Is the debris and other sewage solids collected during cleaning acGviGes being disposed of appropriately? ☐ ☐ 7.0 Have there been spills due to excessive fats, oil, grease, roots, or non-dispersible wipes discovered in the sewer system during the audit period? ☐ ☐ 7.0 Are there repeat oﬀenders among FSEs? ☐ ☐ 7.0 Are enforcement trends decreasing? ☐ ☐ 7.0 Are Source Control and CollecGon staﬀ included in the plan check process? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 10 of 13 ELEMENT 8 – SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPTIAL IMPROVEMENTS ELEMENT 8 No. Assessment Criteria Yes No 8.1 Has the Agency maintained its schedule for CCTV inspecGons and is data being reviewed in a Gmely manner. ☐ ☐ 8.2 Number of capacity-related spills or surcharge condiGon during the audit period? ☐ ☐ 8.2 Has the system responded to rain events as indicated by the hydraulic model? ☐ ☐ 8.2 Has there been any changes to zoning designaGons (residenGal, commercial, industrial)? ☐ ☐ 8.3 Has the Agency adhered to its system evaluaGon/condiGon assessment schedule? ☐ ☐ 8.3 Has the Agency adhered to its prioriGzaGon/correcGve procedures for sewer repair and capacity improvement projects? ☐ ☐ 8.3 Have projects been completed before deﬁciencies caused failures? ☐ ☐ 8.4 Has the agency’s capital improvement plan schedule been adhered to? ☐ ☐ 8.4 Have there been any instances when a failure or service disrupGon occurred that would have been prevented if a project been completed? ☐ ☐ Comments Correc2ons Reviewed By Approved By
APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 11 of 13 ELEMENT 9 – MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ELEMENT 9 No. Assessment Criteria Yes No 9.0 Are SSMP Elements being periodically evaluated for eﬀecGveness? ☐ ☐ 9.0 Are work acGviGes and spill events being documented? ☐ ☐ 9.0 Has a plan and schedule been established to address audit ﬁndings/deﬁciencies from the last audit? ☐ ☐ 9.0 Is Trend Analysis being performed on spill causes? ☐ ☐ 9.0 Have work programs been assessed and updated as necessary? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 12 of 13 ELEMENT 10 – INTERNAL AUDITS ELEMENT 10 No. Assessment Criteria Yes No 10.0 Have audits been performed as required? ☐ ☐ 10.0 Have the audits assessed compliance, implementaGon, and eﬀecGveness? ☐ ☐ 10.0 Have deﬁciencies been idenGﬁed? ☐ ☐ 10.0 Has a plan and schedule to recGfy the deﬁciencies been established? ☐ ☐ Comments Correc2ons Reviewed By Approved By APPENDIX 12.1: SSMP Eﬀec2veness Worksheet
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Agency use only. Page 13 of 13 ELEMENT 11 – COMMUNICATIONS PROGRAM ELEMENT 11 No. Assessment Criteria Yes No 11.0 Does the agency place all Sewer System Management Plan acGon items on the agenda for regular counsel/board meeGngs? ☐ ☐ 11.0 Does the agency have signage, or other means, readily available to noGfy the public of environmental or public risk factors related to a sewage spill? ☐ ☐ 11.0 Does the agency perform outreach to residenGal customers? ☐ ☐ Comments Correc2ons Reviewed By Approved By

City Council - Successor Agency - Housing AuthorityApril 15, 2025

City Council - Successor Agency - Housing Authority
April 15, 2025