Gilroy City Council
November 3, 2025

November 3, 2025 | 6:00 PM Page 1 of 7 City Council
Regular Meeting

CITY COUNCIL

REGULAR MEETING
AGENDA

CITY CHAMBERS, CITY HALL
7351 ROSANNA STREET, GILROY, CA
95020
MONDAY, NOVEMBER 3, 2025 | 6:00 PM
MAYOR
Greg Bozzo

COUNCIL MEMBERS
Dion Bracco
Tom Cline
Terence Fugazzi
Zach Hilton
Carol Marques
Kelly Ramirez
CITY COUNCIL PACKET MATERIALS ARE AVAILABLE ONLINE AT www.cityofgilroy.org AGENDA CLOSING TIME IS 5:00 P.M. THE TUESDAY PRIOR TO THE MEETING

COMMENTS BY THE PUBLIC WILL BE TAKEN ON AGENDA ITEMS BEFORE ACTION IS TAKEN BY THE CITY COUNCIL. Public testimony is subject to reasonable regulations, including but not limited to time restrictions for each individual speaker. **Please limit your comments to 3 minutes.** The amount of time allowed per speaker may vary at the Mayor’s discretion depending on the number of speakers and length of the agenda.

Written comments on any agenda item may be emailed to the City Clerk’s Office at [email protected] or mailed to the Gilroy City Clerk’s Office at City Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the City Clerk’s Office by 1 p.m. on the day of a Council meeting will be distributed to the City Council prior to or at the meeting and available for public inspection with the agenda packet located in the lobby of Administration at City Hall, 7351 Rosanna Street prior to the meeting. Any correspondence received will be incorporated into the meeting record. Items received after the 1 p.m. deadline will be provided to the City Council as soon as practicable. Written comments are also available on the City’s Public Records Portal at bit.ly/3NuS1IN.

In compliance with the Americans with Disabilities Act, the City will make reasonable arrangements to ensure accessibility to this meeting. If you need special assistance to participate in this meeting, please contact the City Clerk’s Office at least 72 hours prior to the meeting at (408) 846-0204 or [email protected] to help ensure that reasonable arrangements can be made.

If you challenge any planning or land use decision made at this meeting in court, you may be limited to raising only those issues you or someone else raised at the public hearing held at this meeting, or in written correspondence delivered to the City Council at, or prior to, the public hearing. Please take notice that the time within which to seek judicial review of any final administrative determination reached at this meeting is governed by Section 1094.6 of the California Code of Civil Procedure.

A Closed Session may be called during this meeting pursuant to Government Code Section 54956.9 (d)(2) if a point has been reached where, in the opinion of the legislative body of the City on the advice of its legal counsel, based on existing facts and circumstances, there is a significant exposure to litigation against the City.

Materials related to an item on this agenda submitted to the City Council after distribution of the agenda packet are available with the agenda packet on the City website at www.cityofgilroy.org subject to the Staff’s ability to

November 3, 2025 | 6:00 PM Page 2 of 7 City Council
Regular Meeting
post the documents before the meeting.

KNOW YOUR RIGHTS UNDER THE GILROY OPEN GOVERNMENT ORDINANCE Government's duty is to serve the public, reaching its decisions in full view of the public.

Commissions, task forces, councils and other agencies of the City exist to conduct the people's business. This ordinance assures that deliberations are conducted before the people and that City operations are open to the people's review.

FOR MORE INFORMATION ON YOUR RIGHTS UNDER THE OPEN GOVERNMENT

ORDINANCE, TO RECEIVE A FREE COPY OF THE ORDINANCE OR TO REPORT A

VIOLATION OF THE ORDINANCE, CONTACT THE OPEN GOVERNMENT COMMISSION STAFF AT (408) 846-0204.

If you need assistance with translation and would like to speak during public comment, please contact the City Clerk a minimum of 72 hours prior to the meeting at 408-846-0204 or e-mail the City Clerk’s Office at [email protected].

Si necesita un intérprete durante la junta y gustaría dar un comentario público, comuníquese con el Secretario de la Ciudad un mínimo de 72 horas antes de la junta al 408- 846-0204 o envíe un correo electrónico a la Oficina del Secretario de la Ciudad a [email protected].

To access written translation during the meeting, please scan the QR Code or click this link:

Para acceder a la traducción durante la reunión, por favor escanee el código QR o haga clic en el enlace:
bit.ly/3FBiGA0
Choose Language and Click Attend | Seleccione su lenguaje y haga clic en asistir
Use a headset on your phone for audio or read the transcript on your device.

Use sus auriculares para escuchar el audio o leer la transcripción en el dispositivo.

The agenda for this regular meeting is outlined as follows:

1. OPENING

1.1. Call to Order

1.2. Roll Call

1.3. City Clerk's Report on Posting the Agenda

1.4. Pledge of Allegiance

November 3, 2025 | 6:00 PM Page 3 of 7 City Council
Regular Meeting

1.5. Invocation

1.6. Orders of the Day

1.7. Employee Introductions

2. CEREMONIAL ITEMS - Proclamations and Awards

2.1. Arbor Day Proclamation

3. PRESENTATIONS TO THE COUNCIL

3.1. PUBLIC COMMENT BY MEMBERS OF THE PUBLIC ON ITEMS NOT ON THE

AGENDA BUT WITHIN THE SUBJECT MATTER JURISDICTION OF THE CITY

COUNCIL
This portion of the meeting is reserved for persons desiring to address the Council on matters within the Gilroy City Council’s jurisdiction but not on the agenda. Persons wishing to address the Council are requested to complete a Speaker’s Card located at the entrances and handed to the City Clerk. Speakers are limited to 1 to 3 minutes each, varying at the Mayor’s discretion depending on the number of speakers and length of the agenda. The law does not permit Council action or extended discussion of any item not on the agenda except under special circumstances. If Council action is requested, the Council may place the matter on a future agenda.

Written comments to address the Council on matters not on this agenda may be e-mailed to the City Clerk’s Office at [email protected] or mailed to the Gilroy City Clerk’s Office at City Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the City Clerk’s Office by 1:00 pm on the day of a Council meeting will be distributed to the City Council prior to or at the meeting and available for public inspection with the agenda packet located in the lobby of Administration at City Hall, 7351 Rosanna Street, prior to the meeting. Any correspondence received will be incorporated into the meeting record. Items received after the 1:00pm deadline will be provided to the City Council as soon as practicable. Written material provided by public members under this section of the agenda will be limited to 10 pages in hard copy. An unlimited amount of material may be provided electronically.

4. REPORTS OF COUNCIL MEMBERS
Council Member Bracco – Downtown Committee, Santa Clara County Library Joint Powers Authority, Santa Clara Water Commission, Santa Clara Valley Water Joint Water Resources Committee, SCRWA
Council Member Fugazzi – Santa Clara Water Commission (alternate), Silicon Valley Regional Interoperability Authority Board (alternate), SCRWA, Visit Gilroy California Welcome Center, VTA Mobility Partnership Committee
Council Member Marques – ABAG, Downtown Committee, Santa Clara County Library Joint

November 3, 2025 | 6:00 PM Page 4 of 7 City Council
Regular Meeting
Powers Authority (alternate), Santa Clara Valley Habitat Agency Governing Board, Santa Clara Valley Habitat Agency Implementation Board, SCRWA (alternate) Council Member Hilton – CalTrain Policy Group, Santa Clara County Expressway Plan 2040 Advisory Board (alternate), Silicon Valley Clean Energy Authority JPA Board, South County Youth Task Force Policy Team, VTA Policy Advisory Committee Council Member Ramirez – ABAG (alternate), Gilroy Gardens Board of Directors (alternate), Gilroy Sister Cities, Gilroy Youth Task Force (alternate), SCRWA, Santa Clara Housing and Community Development Advisory Committee
Council Member Cline – CalTrain Policy Group (alternate), Gilroy Sister Cities (alternate), Gilroy Youth Task Force, Santa Clara County Expressway Plan 2040 Advisory Board, Silicon Valley Clean Energy Authority JPA Board (alternate), Silicon Valley Regional Interoperability Authority Board, Visit Gilroy California Welcome Center (alternate), VTA Mobility Partnership Committee, VTA Policy Advisory Committee (alternate)
Mayor Bozzo – Gilroy Gardens Board of Directors, Santa Clara Valley Water Joint Water Resources Committee, South County Youth Task Force Policy Team, VTA Board of Directors (alternate), Santa Clara Housing and Community Development Advisory Committee (alternate)

5. CONSENT CALENDAR
All matters listed under the Consent Calendar are considered by the City Council to be routine and will be enacted by one motion. There will be no separate discussion of these items unless a request is made by a member of the City Council or a member of the public. Any person desiring to speak on any item on the consent calendar should ask to have that item removed from the consent calendar prior to the time the City Council votes to approve. If removed, the item will be discussed in the order in which it appears.

5.1. Approved the October 20, 2025 City Council Regular Meeting Minutes

5.2. Approve the 2025 Update to the City of Gilroy's Sewer System Management Plan (SSMP) in Compliance with State Water Resources Control Board Order WQ 2022-0103-DWQ

5.3. Award a Contract to Catholic Charities of Santa Clara County for $103,448 for South County Youth Task Force Community-Based Services for Youth

5.4. Authorize the City Administrator to Enter into a Ten-Year Master Service and Purchasing Agreement with Axon Enterprises, Inc., to Purchase the Axon Interview Room Recording System for $243,621

6. BIDS AND PROPOSALS

6.1. Award a Contract to FBD Vanguard Construction, Inc. for the FY26 CDBG Sidewalk and Curb Ramp Project No. 26-PW-303 in the amount of $156,820.00, approve a project contingency of $19,370.14, and approve a total project expenditure of $176,190.14 for Construction

November 3, 2025 | 6:00 PM Page 5 of 7 City Council
Regular Meeting

1. Staff Report:

John Doughty, Public Works Director

2. Public Comment

3. Possible Action:

Award a contract to FBD Vanguard Construction, Inc. in the amount of $156,820.00, approve a project contingency of $19,370.14, approve a total project expenditure of $176,190.14 for the construction of the FY26 CDBG Sidewalk and Curb Ramp Project (No. 26-PW-303), and authorize the Interim City Administrator to execute the contract and associated documents.

7. PUBLIC HEARINGS

7.1. Introduction and First Reading of an Ordinance Amending Chapter 30, Article LIV of the Gilroy City Code Relating to Accessory Dwelling Units (Z 25-02)

1. Disclosure of Ex-Parte Communications

2. Staff Report:

Sharon Goei, Community Development Director

3. Open Public Hearing

4. Close Public Hearing

5. Possible Action:

1. Determine the proposed ordinance is statutorily exempt from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines Section 15282(h) for the adoption of an ordinance regarding second units in a single-family or multifamily residential zone by a city or county to implement the provisions of Section 66314 and 66333 of the Government Code as set forth in Section 21080.17 of the Public Resources Code;

2. Motion to read the ordinance by title only and waive further reading of the ordinance; and

3. Introduce the ordinance of the City Council of the City of Gilroy amending Chapter 30, Article LIV of the Gilroy City Code relating to accessory dwelling units.

7.2. Consider Adopting an Urgency Interim Ordinance Prohibiting the Issuance of Tobacco Retailer Permits for a Period Not to Exceed Forty-Five (45) Days within the Downtown Specific Plan Area (M 25-13)

1. Disclosure of Ex-Parte Communications

2. Staff Report:

Sharon Goei, Community Development Director

3. Open Public Hearing

November 3, 2025 | 6:00 PM Page 6 of 7 City Council
Regular Meeting

4. Close Public Hearing

5. Possible Action:

1. Adopt an Urgency Interim Ordinance establishing a temporary prohibition on the issuance or approval of any new Tobacco Retailer Permits within the Downtown Specific Plan area within the City of Gilroy pursuant to Government Code Section 65858; and

2. Make findings, as incorporated in the ordinance, that adoption of the ordinance is necessary for the immediate preservation of the public health, safety, and welfare, particularly regarding the protection of minors within the Downtown Specific Plan area.

8. INTRODUCTION OF NEW BUSINESS

8.1. Update on Downtown Plywood Storefront Ordinance and Downtown Vacancy Ordinance Proposal

1. Staff Report:

Sharon Goei, Community Development Director

2. Public Comment

3. Possible Action:

Receive the update from staff and direct staff to revive, update, and strengthen Gilroy City Code Chapter 5D, "Vacant Commercial Space in the Downtown Historic and Downtown Expansion Districts," which is currently expired, without a vacancy tax at this time.

9. FUTURE COUNCIL INITIATED AGENDA ITEMS

10. CITY ADMINISTRATOR'S REPORTS

11. CITY ATTORNEY'S REPORTS

12. CLOSED SESSION

12.1. CONFERENCE WITH LEGAL COUNSEL - ANTICIPATED LITIGATION – Significant exposure to litigation pursuant to Paragraph (2) of Subdivision (d) of Government Code Section 54956.9 and Gilroy City Code Section 17A.11 Subdivision (3): One Case.

13. ADJOURN TO OPEN SESSION
Report of any action taken in Closed Session and vote or abstention of each Council Member if required by Government Code Section 54957.1 and GCC Section 17A.13(b); Public Report of the vote to continue in closed session if required under GCC Section 17A.11(5).

14. ADJOURNMENT

November 3, 2025 | 6:00 PM Page 7 of 7 City Council
Regular Meeting

FUTURE MEETING DATES
November 2025
17 City Council Regular Meeting - 6:00 p.m.

December 2025
08 City Council Regular Meeting - 6:00 p.m.

January 2026
05 26
City Council Regular Meeting - 6:00 p.m.

City Council Regular Meeting - 6:00 p.m.

Meetings are webstreamed on the City of Gilroy’s website at gilroy.city/meetings.

October 20, 2025 | 6:00 PM

1. OPENING

1. Call to Order
City of Gilroy
DRAFT
City Council
Minutes
Monday, October 20, 2025 | 6:00 PM
The meeting was called to order by Mayor Bozzo at 6:00 PM.

2. Roll Call
Attendance Attendee Name
Present Council Member Dion Bracco
Council Member Tom Cline
Council Member Terence Fugazzi
Council Member Zach Hilton
Council Member Carol Marques
Council Member Kelly Ramirez
Mayor Greg Bozzo

3. City Clerk's Report on Posting the Agenda
City Clerk Kim Mancera reported on the Posting of the Agenda.

4. Pledge of Allegiance
Council Member Hilton led the Pledge of Allegiance.

5. Invocation
None.

6. Orders of the Day
Mayor Bozzo announced that item 7.3 Environmental Services Update and Statewide Trash Provisions will be continued without a date certain.

7. Employee Introductions
Public Works Director John Doughty introduced City Engineer Nisha Patel.

Utilities Director Heath McMahon introduced Water Department Maintenance Workers Lance Malatka, Luis Castro, Daniel Ramirez, Anthony Valdivia, and Antonio Rodriguez, and Engineer I in Utilities CIP Guilianna Laurenzano.

2. CEREMONIAL ITEMS - Proclamations and Awards

1. Stand United Against Hate Week Proclamation

3. PRESENTATIONS TO THE COUNCIL

1. PUBLIC COMMENT BY MEMBERS OF THE PUBLIC ON ITEMS NOT ON THE

October 20, 2025 | 6:00 PM

AGENDA BUT WITHIN THE SUBJECT MATTER JURISDICTION OF THE CITY

COUNCIL
Mayor Bozzo opened public comment at 6:15 P.M.

Donald Perino - commented on the Gilroy Garlic Festival in 1979 and thanked all those involved.

Greg Felios - commented on the November 4, 2025 Special Election and Measure A.

Ron Kirkish - commented on the drug issue and DA Jeff Rosen.

Jodi Barr - commented on the American Association of University Women (AAUW) of Gilroy and the organization.

Dan Donovan - commented on the November 4, 2025 Special Election vote centers.

With no further speakers, Mayor Bozzo closed public comment.

4. REPORTS OF COUNCIL MEMBERS

1. Council Member Bracco – Downtown Committee, Santa Clara County Library Joint Powers Authority, Santa Clara Water Commission, Santa Clara Valley Water Joint Water Resources Committee, SCRWA
Council Member Fugazzi – Santa Clara Water Commission (alternate), Silicon Valley Regional Interoperability Authority Board (alternate), SCRWA, Visit Gilroy California Welcome Center, VTA Mobility Partnership Committee Council Member Marques – ABAG, Downtown Committee, Santa Clara County Library Joint Powers Authority (alternate), Santa Clara Valley Habitat Agency Governing Board, Santa Clara Valley Habitat Agency Implementation Board, SCRWA (alternate)
Council Member Hilton – CalTrain Policy Group, Santa Clara County Expressway Plan 2040 Advisory Board (alternate), Silicon Valley Clean Energy Authority JPA Board, South County Youth Task Force Policy Team, VTA Policy Advisory Committee
Council Member Ramirez – ABAG (alternate), Gilroy Gardens Board of Directors (alternate), Gilroy Sister Cities, Gilroy Youth Task Force (alternate), SCRWA, Santa Clara Housing and Community Development Advisory Committee
Council Member Cline – CalTrain Policy Group (alternate), Gilroy Sister Cities (alternate), Gilroy Youth Task Force, Santa Clara County Expressway Plan 2040 Advisory Board, Silicon Valley Clean Energy Authority JPA Board (alternate), Silicon Valley Regional Interoperability Authority Board, Visit

October 20, 2025 | 6:00 PM

Gilroy California Welcome Center (alternate), VTA Mobility Partnership Committee, VTA Policy Advisory Committee (alternate)
Mayor Bozzo – Gilroy Gardens Board of Directors, Santa Clara Valley Water Joint Water Resources Committee, South County Youth Task Force Policy Team, VTA Board of Directors (alternate), Santa Clara Housing and Community Development Advisory Committee (alternate)
Council Member Bracco - no report
Council Member Fugazzi - no report
Council Member Marques - thanked Gilroy Fire for her shirt and hat in support of October Breast Cancer Awareness Month.

Council Member Hilton - reported from Santa Clara County LAFCO is working on a draft RFP for a county-wide water and wastewater service review. He joined Gilroy Unified School District (GUSD) last week to discuss Pathways to Success. This is a new partnership with San Jose State University that guarantees admission to any CSU eligible GUSD graduate to the university.

Council Member Ramirez - thanked Gilroy Fire for her shirt and reported that Sister Cities has a group of students arriving from Japan next week.

Council Member Klein - no report
Mayor Bozzo - no report

5. CONSENT CALENDAR
Mayor Bozzo opened public comment at 6:27 P.M.

With no speakers, Mayor Bozzo closed public comment.

Motion
Approve the consent calendar.

RESULT: Passed
MOVER: Council Member Terence Fugazzi
SECONDER: Council Member Carol Marques
AYES: Council Member Dion Bracco, Council Member Tom Cline, Council Member Terence Fugazzi, Council Member Zach Hilton, Council Member Carol Marques, Council Member Kelly Ramirez, Mayor Greg Bozzo NAYS: None

1. Approve the minutes of the October 4, 2025 Coffee with the Mayor and October 6, 2025 City Council Regular Meeting

6. BIDS AND PROPOSALS

1. Old City Hall HVAC System's Replacement of Two Air Conditioning Units for

October 20, 2025 | 6:00 PM

$70,000 and Adopt a Related Budget Amendment Resolution to Appropriate the Funds
Human Resources Director/Risk Manager LeeAnn McPhillips provided a report and presentation.

Mayor Bozzo opened public comment at 6:48 P.M.

Dan Donovan - commented in favor of the HVAC repairs.

With no further speakers, Mayor Bozzo closed public comment.

Council instructed staff to proceed with the HVAC repairs, continue to honor the existing month-to-month lease, including maintenance requirements of the City as the landlord, and defer additional actions on the Old City Hall lease or lease renewal until the Economic Development Director is in place to provide further guidance.

Motion
Adopt a budget amendment resolution to increase the FY26 Facilities budget by $70,000 to cover the cost to replace the two HVAC units and complete associated installation and repairs.

RESULT: Passed
MOVER: Council Member Dion Bracco
SECONDER: Council Member Carol Marques
AYES: Council Member Dion Bracco, Council Member Tom Cline, Council Member Terence Fugazzi, Council Member Zach Hilton, Council Member Carol Marques, Council Member Kelly Ramirez, Mayor Greg Bozzo
NAYS: None

2. Award a contract to McKim Corporation for $1,009,759 construction costs and $100,976 contingency, for a total project cost of $1,110,735, for the FY26 Sidewalk Replacement Program Project
Public Works Director John Doughty provided a report and presentation.

Mayor Bozzo opened public comment at 7:11 P.M.

Rebecca Aviles - commented on the bidding process and did not understand why Villalobos was disqualified.

Tranquilino Villalobos - commented on CIP projects that they have completed in Gilroy and that Villalobos was the lowest bidder but was disqualified.

Janeth Zapata - commented on the development happening in the city and wants to understand what the justification to spend that amount of money is.

Ron Kirkish - thanked the first public speakers and would like to know why Villalobos was not chosen.

October 20, 2025 | 6:00 PM

With no further speakers, Mayor Bozzo closed public comment.

Motion
Award a contract to McKim Corporation in the amount of $1,009,759, approve a project contingency of $100,976, approve expenditure of $1,110,735 for the construction of the FY26 Sidewalk Replacement Program Project (No.26-PW-299), and authorize the Interim City Administrator to execute the contract and associated documents.

RESULT: Passed
MOVER: Council Member Zach Hilton
SECONDER: Council Member Dion Bracco
AYES: Council Member Dion Bracco, Council Member Tom Cline, Council Member Terence Fugazzi, Council Member Zach Hilton, Council Member Carol Marques, Council Member Kelly Ramirez, Mayor Greg Bozzo
NAYS: None

7. INTRODUCTION OF NEW BUSINESS

1. Receive Preliminary Fiscal Year 2024-25 Year-end Financial Report and Adopt a Budget Amendment Resolution
Finance Director Harjot Sangha provided a report and presentation.

Mayor Bozzo opened public comment at 8:02 P.M.

With no speakers, Mayor Bozzo closed public comment.

Motion
Receive preliminary Fiscal Year 2024-25 (FY25) year-end financial report, approve the Pension and Other Post-Employment Benefits (OPEB) Section 115 Trust contributions pursuant to the Council Adopted policies and adopt a budget amendment resolution.

RESULT: Passed
MOVER: Council Member Tom Cline
SECONDER: Council Member Terence Fugazzi
AYES: Council Member Dion Bracco, Council Member Tom Cline, Council Member Terence Fugazzi, Council Member Zach Hilton, Council Member Carol Marques, Council Member Kelly Ramirez, Mayor Greg Bozzo
NAYS: None
The meeting recessed at 8:04 P.M. and reconvened at 8:16 P.M.

4. Provide Policy Direction on a Proposed Zoning Ordinance Text Amendment to Allow Electronic Billboards along State Route 101

October 20, 2025 | 6:00 PM

Mayor Bozzo moved Item 7.4 to be heard after Item 7.1.

Community Development Planner Melissa Durkin provided a report and presentation.

Mayor Bozzo opened public comment at 8:46 P.M.

Mike Conrotto - commented on the benefit of electronic billboards along the freeway.

Connie Rogers - commented on the image that electronic billboards may project on the City of Gilroy.

Joe Giacalone - commented on the benefit of electronic billboards and is in support of it.

Ron Kirkish - commented on electronic billboards and staying up with the times.

George Renz - commented on his support for electronic billboards for various reasons.

Greg Bumb - commented on his support for electronic billboards which will bring more customers to his motorcycle shop.

Michelle Carlen - commented on the benefits of electronic billboards and provided some examples from other cities.

With no further speakers, Mayor Bozzo closed public comment.

Council directed staff to thoroughly research the issue of electronic billboards in conjunction with the Economic Development Department, and to bring back options that the City Council would consider at a future date. Council further directed that research focus on best practices for the City, and that it not be project-driven.

2. Discussion and Direction Regarding Establishing a Reserve Policy to Fund Parks Infrastructure
Finance Director Harjot Sangha provided a report and presentation.

Mayor Bozzo opened public comment at 9:40 P.M.

With no speakers, Mayor Bozzo closed public comment.

Council directed staff to:

1. Draft a policy to establish and fund a Capital Infrastructure Reserve to set aside monies for park infrastructure and other capital improvements via an initial $310,000 one-time contribution from the remaining Fiscal Year 2024-25 (FY25) year-end budgetary savings in the General Fund expenditures to occur at policy adoption, and up to 25% of all future year-end budgetary

October 20, 2025 | 6:00 PM

savings in the General Fund expenditures to be transferred to the said Capital Infrastructure Reserve, subject to Council approval.

2. Conduct a study session at the beginning of a regularly scheduled upcoming City Council meeting to receive updates and provide direction on the Parks and Trails Master Plan workplan item, including the request for proposal (RFP) scope, and to review the draft Capital Infrastructure Reserve and Funding Policy.

3. Environmental Services Update and Statewide Trash Provisions This item was continued without a date certain.

8. FUTURE COUNCIL INITIATED AGENDA ITEMS
Mayor Bozzo informed the Council that due to significant concerns raised by members of the community, he has asked staff to place on the November 3, 2025 meeting for Council consideration and urgency ordinance to prohibit new smoke shops in the downtown area.

The ordinance would be in effect for a limited time to allow staff to further study the issue.

9. CITY ADMINISTRATOR'S REPORTS
No report.

10. CITY ATTORNEY'S REPORTS
No report.

11. ADJOURNMENT
With no additional business before the Council, the meeting was adjourned at 9:51 P.M I HEREBY CERTIFY that the foregoing minutes were duly and regularly adopted at a regular meeting of the City Council of the City of Gilroy on XXXXXXX, 20XX.

Kim Mancera
City Clerk

City of Gilroy

STAFF REPORT
Agenda Item Title: Approve the 2025 Update to the City of Gilroy's Sewer System Management Plan (SSMP) in Compliance with State
Water Resources Control Board Order WQ 2022-0103-DWQ
Meeting Date: November 3, 2025
From: Brad Kilger, Interim City Administrator
Department: Public Utilities
Submitted by: Heath McMahon, Public Utilities Director
Prepared by: Izabela Cirloganu, Management Analyst
STRATEGIC PLAN GOALS: Maintain and Improve City Infrastructure

RECOMMENDATION
Approve the 2025 Update to the City of Gilroy's Sewer System Management Plan (SSMP) in Compliance with State Water Resources Control Board Order WQ 2022- 0103-DWQ.

EXECUTIVE SUMMARY
The Statewide Waste Discharge Requirements (WDR) adopted on December 6, 2022 by the State Water Resources Control Board (SWRCB) requires that all owners and operators of sanitary sewer collection systems over one mile in length develop and implement a Sewer System Management Plan (SSMP) pursuant to State Water Resources Control Board Order WQ 2022-0103-DWQ. As an owner and operator of a collection system, the City must implement a comprehensive plan for inspection, condition assessment, cleaning, rehabilitation, capacity assessment, and capital upgrades to mitigate Sanitary Sewer Overflows (SSOs).

The state requires the SSMP to be updated every six years. The City Council adopted the current plan in 2019. Staff recommends the City Council approve the 2025 Update to the SSMP.

BACKGROUND
All federal and state agencies, municipalities, counties, districts, and other public entities that own or operate sanitary sewer systems greater than one mile in length that collect and/or convey untreated or partially treated wastewater to a publicly owned treatment facility in the State of California are required to comply with the terms of State Water Resources Control Board Order WQ 2022-0103-DWQ.

Sanitary Sewer Overflows (SSOs) are discharges from sanitary sewer systems that may be of domestic, industrial, and/or commercial wastewater. SSOs may contain high levels of suspended solids, toxic pollutants, pathogenic organisms (such as bacteria and viruses that cause diseases), oil and grease, and other pollutants. SSOs may cause a public nuisance, particularly when raw untreated wastewater is discharged to areas with high public exposure, such as streets or surface waters used for fishing or body contact recreation. SSOs may pollute surface or ground waters, threaten public health, adversely affect aquatic life, and impair the recreational use and aesthetic enjoyment of surface waters.

Sanitary sewer systems experience periodic failures that increase the likelihood of an SSO. Factors may include geological shifts, design deficiencies, construction methods and materials, age, and deterioration of the system. Major causes of SSOs also include:
grease blockages, root blockages, flood damage, structural failures, vandalism, pump station mechanical failures, power outages, excessive storm or ground water inflow/infiltration, debris blockages, lack of proper operation and maintenance, insufficient capacity, and contractor-caused damages.

Preparation of the Sewer System Management Plan (SSMP) is a proactive approach to ensure a system-wide operation, maintenance, and management plan is in place to reduce the frequency and size of SSOs. The SSMP has the following goals:

1. Proper management and operation. Effectively manage, operate, and maintain all parts of the wastewater collection system, including sewer lines, manholes, and pump stations.

2. Capacity management. Ensure the sewer system has adequate capacity to convey peak wastewater flows, including those that occur during rainstorms.

3. Prevent SSOs. Minimize the frequency and impact of sanitary sewer overflows by implementing preventative maintenance and operational programs. Identify, prioritize and continuously renew and replace sewer collection system assets to maintain functionality.

4. Mitigate SSO impacts. Respond to and mitigate the impacts of SSOs. This includes containing spills and cleaning up affected areas.

5. Collection System Staff Training. Provide regular training for City staff and contractors in collection system maintenance, operations, and emergency response.

6. Compliance with regulations. Meet all applicable regulatory requirements for

notification and reporting to the State and Regional Water Boards

ANALYSIS
The City’s wastewater collection system serves approximately 61,000 residents, plus numerous visitors and businesses. The system consists of 172 miles of gravity sewers,

0.2 miles of force main, one lift station, and 4,030 manholes. Most of the pipelines are 8"-12" in diameter and were constructed between 1960 and 2000. Sewage is conveyed to and treated at the South County Regional Wastewater Authority (SCRWA) Wastewater Treatment Plant (WWTP).

Gilroy’s Wastewater Collection Section is responsible for the safe and efficient maintenance of the City’s sanitary sewer collection system. Its mission is to ensure the continuous flow of wastewater to the WWTP and to prevent sanitary sewer overflows.

A review of data from July 2020 to July 2025 shows that the City consistently performed better than the statewide and regional spill rate indices, reflecting the Wastewater Collection team's strong commitment to the wellbeing of its citizenry. Their proactive management of the collection system has set it apart from other agencies in the region and the state.

The Wastewater Collection Section organizes pipe cleaning work into two schedules:
high-priority cleaning and system-wide cleaning. The core responsibilities of the Wastewater Collection Section include line cleaning, closed-circuit television (CCTV) inspections, pipeline locating, structural repairs, preventative maintenance, spill response, and preparing detailed operational reports.

City staff is working to develop additional standard operating procedures (SOPs) to ensure cleaning methods are effective and work assignments are efficient. CCTV inspections will facilitate a better understanding of the requirements for high-priority activities, and may lead to additional repairs or pipe rehabilitation, and better tracking of fats, oils, and grease (FOG) generation.

ALTERNATIVES
Updating the Sewer System Management Plan is a regulatory requirement; therefore, no legal alternatives have been identified.

FISCAL IMPACT/FUNDING SOURCE
Approval of the SSMP does not have an immediate financial impact. However, implementation of the SSMP may result in increased capital project expenditures as deficiencies in the sewer infrastructure are discovered through monthly, quarterly, and yearly pipeline inspections.

PUBLIC OUTREACH

NEXT STEPS
Attachments:

1. Gilroy 2025 SSMP Final Draft

Sewer System Management Plan (SSMP)
2025 Update
Sanitary Sewer Collection System for
Waste Discharge ID (WDID): #3SSO10340
REVIEWED AND APPROVED BY:

Matt Jones, Public Works Deputy Director
Legally Responsible Official
City of Gilroy
Sanitary Sewer Collection System
Date Signed

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SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page i SSMP Action Items Checklist (Implementation Plans and Schedules) The purpose of this table is to track and document the required SSMP Implementation Plans and Schedules for each Element. Additional details are found in the discussions within each section of the SSMP. Abbreviations and acronyms are found on page 4.

Section Plan Schedule Responsible Staff

1.2.1 Incorporate 2021-2024 Audit Findings,
update Change Log, Update SSMP 12/31/2025 UT Ops Mgr. WW Sup

1.2.2 Prepare for next SSMP Audit Begin 5/2/2027 UT Ops Mgr. WW Sup

1.2.3 Complete and Upload SSMP audit. By 11/2/2027 UT Ops Mgr. WW Sup

1.2.4 Incorporate Audit Findings, update Change
Log and Update SSMP
Within one month of
completing audit UT Ops Mgr. WW Sup

1.2.5 Prepare for next SSMP Audit Begin 5/2/2030 UT Ops Mgr. WW Sup

1.2.6 Complete and Upload next SSMP Audit By 11/2/2030 UT Ops Mgr. WW Sup

1.2.7 Incorporate Audit Findings, update Change
Log and Update SSMP
Within one month of
completing audit UT Ops Mgr. WW Sup

1.2.8 Prepare for next SSMP Update Begin 2/2/2031 UT Ops Mgr. WW Sup

1.3.1 At the beginning of the audit cycle and
when significant changes have been made
Review City-owned asset
statistics and element
description; update as
necessary
UT Ops Mgr. WW Sup Eng

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page ii Section Plan Schedule Responsible Staff

1.3.2 Within 30 days of submittal of completion
of development project Update maps Eng

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

Semi-annually UT Ops Mgr. WW Sup

2.2 Review Chain of Communication outcomes
for all spill responses Each Spill Event UT Ops Mgr. WW Sup

2.3 Review Organizational Chart for any
changes. Update as necessary. Semi-Annually UT Ops Mgr. WW Sup

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

Once per 6-year SSMP
Update Cycle UT Ops Mgr. Legal Eng

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

Continuously UT Ops Mgr. WW Sup Legal

3.4 Contact Santa Clara County and Caltrans to
discuss a mutual aid agreement to allow
the City to respond to any wastewater
spills which enter a County or Caltrans
storm drain.

By 6/1/2026 UT Ops Mgr. Legal

3.5 Update the Municipal Code to specify that
the property owner is responsible for
maintenance and repair of the upper
lateral.

By 6/1/2026 UT Ops Mgr. Legal

3.6 Maintain a database of easements that the
City becomes aware of. Immediately UT Ops Mgr. WW Sup Eng

4.1.1 Review map update procedures with all
affected staff. Annually UT Ops Mgr. WW Sup

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page iii Section Plan Schedule Responsible Staff

4.1.2 Review/ensure all newly installed facilities
have been updated and included in the
system maps
Annually UT Ops Mgr. WW Sup

4.1.3 Create and use a Sewer Map Update form
when corrections are needed to the sewer
map.

By June 1, 2026 UT Ops Mgr. WW Sup

4.1.4 Enter all asset data into Cityworks and
subsequently use Cityworks to track all
inspections, work orders, and service
requests.

By June 1, 2027 UT Ops Mgr. WW Sup

4.2.1 Monitor “Past Due” work orders to ensure
critical work is being completed Quarterly UT Ops Mgr. WW Sup

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

Annually UT Ops Mgr. WW Sup

4.2.3 Begin using Cityworks to generate
inspections, maintenance, repairs, CCTV,
etc.

Beginning fourth quarter
2025 UT Ops Mgr. WW Sup

4.3.1 Review training documentation to ensure
all staff have received required training Quarterly UT Ops Mgr. WW Sup

4.3.2 Complete a training record after each
training event, using a form like that found
in Appendix 4.1
Ongoing UT Ops Mgr. WW Sup

4.3.3 Review agreements with contractors
and/or Pre-Job meeting minutes to ensure
contract personnel have received
instruction for responding to sewage spills
Each Contract UT Ops Mgr. WW Sup Eng

4.3.4 Train the new LRO on CIWQS data entry
procedures. Fourth quarter 2025 UT Ops Mgr. WW Sup

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page iv Section Plan Schedule Responsible Staff

4.3.5 Train staff on how to implement the
revised SERP. Fourth quarter 2025 WW Sup

4.4.1 Audit inventory lists to ensure stock is
adequate. Annually WW Sup

4.4.2 Check with vendors to ensure critical parts
lead times are as expected. Annually WW Sup

4.4.3 Ensure contracts with emergency support
services are current Annually WW Sup

5.19.1 Record the results of line cleaning in
Cityworks.

Beginning 4th quarter
2025 WW Sup

5.19.2 Develop standard operating procedures
for the addition and removal of lines from
the hot spot program.

Beginning 1st quarter
2026 WW Sup

5.19.3 Evaluate the need for maintenance of
large (11” diameter or greater) lines.

Beginning 1st quarter
2026 WW Sup Eng

5.19.4 Define and implement a formal manhole
inspection program based upon the
NASSCO Manhole Assessment Certification
Program (MACP) rating system
Beginning 1st quarter
2026 WW Sup

5.19.5 Evaluate cleaning results using the City’s
“Standard Measures of Observed Results
for Collection System Line Cleaning”,
Beginning 1st quarter
2026 WW Sup

5.19.6 Begin inspecting force main at potential
discharge locations. Determine
appropriate inspection schedule.

Beginning 1st quarter
2026 WW Sup

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page v Section Plan Schedule Responsible Staff

5.19.7 Determine which line segments should
receive root treatment and the
appropriate frequency of treatment for
each of these segments.

Prior to issuance of
contract WW Sup

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

Each Project Eng

5.2.1 Verify inspection procedures are adequate
and consistent with current standards of
practice.

Annually Eng

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

Annually Eng

6.1 Perform SERP training including practice
drills. Annually UT Ops Mgr. WW Sup

6.2 Review Post Spill Assessments to ensure
adherence and to indemnify any trends
that should be addressed
Annually UT Ops Mgr. WW Sup

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

Annually UT Ops Mgr. WW Sup Fire

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

Annually UT Ops Mgr. WW Sup Fire

7.3 Evaluate overall FOG Control Program and
make any improvements needed to
comply with WDR.

Beginning first half 2026 UT Ops Mgr. WW Sup Fire

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

Annually UT Ops Mgr. WW Sup

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page vi Section Plan Schedule Responsible Staff

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

Annually UT Ops Mgr. WW Sup

8.1.3 Hold meeting to discuss any issues that
may result from climate changes Annually UT Ops Mgr. WW Sup Eng

8.1.4 Determine optimal cleaning and inspection
interval for the collection system. Prior to the 2030 Audit UT Ops Mgr. WW Sup

8.1.5 Prioritize condition assessments based on
environmental risk.

Beginning first quarter
2026 UT Ops Mgr. WW Sup Eng

8.1.6 Evaluate assets that may be affected by
climate change and update the SSMP as
necessary.

First quarter 2026 UT Ops Mgr. WW Sup Eng

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

Each CIP Update UT Ops Mgr. WW Sup Eng

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

Continuously WW Sup Eng

8.3.3 Prioritize CIP projects based, in part, on
the potential for spills and document how
projects were selected for funding.

Beginning in 2026 UT Ops Mgr. WW Sup Eng

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

Annually UT Ops Mgr. WW Sup Eng

8.4.2 For schedules that are not followed, justify
and document the reason. Each Delayed Project Eng

SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page vii Section Plan Schedule Responsible Staff

9.1 Assess work programs to ensure outcomes
are as intended Annually UT Ops Mgr. WW Sup

9.2 Ensure updates to work programs and the
SSMP based on assessments. As Needed UT Ops Mgr. WW Sup

9.3 Monitor and evaluate spill trends.

Document efforts. Annually UT Ops Mgr. WW Sup

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

Begin end of audit period UT Ops Mgr. WW Sup

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

Once the Audit is
completed UT Ops Mgr. WW Sup

10.3 Complete the August 2021-August 2024
Audit, upload to CIWQS, and place on City
website.

By 30 December 2025 UT Ops Mgr. WW Sup

11.1 Ensure the City Council approves the SSMP
per schedule Every 6 years UT Ops Mgr. WW Sup

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

Fourth quarter 2025 and
then Annually UT Ops Mgr. WW Sup

11.3 Ensure Sewage Spill Warning signs are
readily available to communicate with the
public when necessary
Annually WW Sup
Table 1 – Summary of SSMP Compliance Implementation Plans and Schedules

SSMP CHANGE LOG OF REVISIONS AND COMPLETED ACTION ITEMS © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page viii SSMP Change Log of Revisions and Completed Action Items1 Revision
Date
SSMP
Section
Approval
Date Description of Change/Revision/Activity Initials
To add a row,
select this
text and hit
TAB2
1 Use this Change Log to document any edits/changes or action items as they are identified and document when they are completed. 2 To add additional table rows, insert your curser into the bottom right cell of the table and hit the tab button. The table will continue on the next page.

LETTER OF COMPLIANCE
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page ix City of Gilroy
Attn: Matt Jones
Legally Responsible Official (LRO)
613 Old Gilroy St.

Gilroy, CA 95020
Dear Mr. Jones,
We are pleased to present the new 2025 Sewer System Management Plan (SSMP) Update developed in partnership with the City of Gilroy’s management. The 2025 Update meets and exceeds compliance with the WDR (State Water Board, Water Quality Order No. 2022-0103-DWQ, Attachment D-10 and Specifications 5.4). The 2025 SSMP has been completely revised to harmonize with industry standard guidelines and incorporates the City’s latest SSMP Audit findings.

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

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

Sincerely,
James Fischer, P.E.

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

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page x

TABLE OF CONTENTS
SSMP ACTION ITEMS CHECKLIST (IMPLEMENTATION PLANS AND SCHEDULES) ..........................................................I SSMP CHANGE LOG OF REVISIONS AND COMPLETED ACTION ITEMS ......................................................................VIII INTRODUCTION.............................................................................................................................................................1 SSMP Organization ..................................................................................................................................................................... 3 Abbreviations and Acronyms...................................................................................................................................................... 4

1. GOAL AND INTRODUCTION ......................................................................................................................................5

1.1. Regulatory Context.............................................................................................................................................................. 5

1.2. SSMP Update Schedule ....................................................................................................................................................... 6

1.3. Sewer System Asset Overview............................................................................................................................................. 7 Specifications 5.2 – SSMP Development and Implementation ................................................................................................ 12 Specifications 5.7 – Allocation of Resources ............................................................................................................................ 13 Provisions 6.1 – Enforcement Provisions ................................................................................................................................. 15 Provisions 6.3 – Sewer System Management Plan Availability ................................................................................................ 16

2. ORGANIZATION.......................................................................................................................................................17

2.1. Organizational Chart.......................................................................................................................................................... 22

2.2. Organizational Staffing Responsibilities ............................................................................................................................ 23

2.3. Chain of Communication for Reporting Spills.................................................................................................................... 25

3. LEGAL AUTHORITY ..................................................................................................................................................27

4. OPERATION AND MAINTENANCE PROGRAM.........................................................................................................30

4.1. Updated Map of Sewer System......................................................................................................................................... 30

4.2. Preventive Operation and Maintenance Activities............................................................................................................ 32

4.3. Training.............................................................................................................................................................................. 34

4.4. Equipment Inventory......................................................................................................................................................... 35 Specifications 5.19 – Operations and Maintenance................................................................................................................. 38

5. DESIGN AND PERFORMANCE PROVISIONS.............................................................................................................44

5.1. Updated Design Criteria/Construction Standards/Specifications ..................................................................................... 44

5.2. Procedures and Standards................................................................................................................................................. 45

6. SPILL EMERGENCY RESPONSE PLAN .......................................................................................................................46

7. SEWER PIPE BLOCKAGE PROGRAM ........................................................................................................................48

8. SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS............................................................51

8.1. System Evaluation and Condition Assessment.................................................................................................................. 51

8.2. Capacity Assessment and Design Criteria.......................................................................................................................... 54

8.3. Prioritization of Corrective Action ..................................................................................................................................... 56

8.4. Capital Improvement Plan................................................................................................................................................. 57

9. MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS.......................................................................59

10. INTERNAL AUDITS .................................................................................................................................................61

11. COMMUNICATION PROGRAM..............................................................................................................................63 LIST OF APPENDICES ...................................................................................................................................................65

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Gilroy use only. Page xi

LIST OF FIGURES
Figure 1 – Collection Spill Summary: Operational Indices for City with State and Regional Data................................2 Figure 2 – Sewer System Management Plan, Subsequent Update and Audit Due Dates............................................6 Figure 3 – City Vicinity Map and Service Area ..............................................................................................................9 Figure 4 – Sewer Collection System (from 2023 Master Plan) ...................................................................................10 Figure 5 – City Utilities Department Organization Chart............................................................................................22

LIST OF TABLES
Table 1 – Summary of SSMP Compliance Implementation Plans and Schedules....................................................... vii Table 2 – Abbreviations and Acronyms........................................................................................................................4 Table 3 – City Sewer Connection Flow Classifications and Connections Data............................................................10 Table 4 – Sewer Enterprise Fund Revenue.................................................................................................................13 Table 5 – Sewer Enterprise Fund Expenditures..........................................................................................................14 Table 6 – Implementation Responsibilities.................................................................................................................20 Table 7 – Responsible Position Contact Information..................................................................................................21 Table 8 – Major Equipment Inventory........................................................................................................................35 Table 9 – Critical Replacement Parts Inventory..........................................................................................................36 Table 10 – System Wide Cleaning Results..................................................................................................................38 Table 11 – Problem Line Cleaning List........................................................................................................................40 Table 12 – Problem Line Cleaning Results..................................................................................................................40 Table 13 – Standard Measures of Observed Results for Collection System Line Cleaning ........................................41 Table 14 – Gravity Sewer System Siphons..................................................................................................................43

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 1 of 65 Introduction
This Sewer System Management Plan (SSMP) or “Plan” has been prepared for the City of Gilroy (City) with technical assistance from Fischer Compliance LLC with the goal of meeting and exceeding compliance with the State Water Resources Control Board 2022 General Waste Discharge Requirements, Order No. WQ 2022-0103-DWQ for Sanitary Sewer Systems (referred to throughout this document as the WDR). The City provided all details, information and institutional insights for preparation of the SSMP. The document has been developed to meet the size, scale, and complexity of the City, serving as a “living document” used as a tool for managing and operating the City's sanitary sewer collection system. Additionally, the latest 2024 Sewer System Management Plan Guidance Manual published by the Bay Area Clean Water Agencies (BACWA) was utilized as a model for development of the document to harmonize formatting/content and incorporate recommended suggested guidance wherever possible.

The City’s Wastewater Collections Section operates the sanitary sewer system. Wastewater Collection Section staff are currently transitioning from the Public Works Department to the newly created Utilities Department. When the transition is completed, Wastewater Collection Section staff will operate under the Operations Division of the Utilities Department. The Wastewater Collection Section works to prevent sanitary sewer overflows and ensure wastewater flows smoothly to the South County Regional Wastewater Authority (SCRWA) treatment plant, in full compliance with state and federal regulations.

The City’s commitment to meeting regulatory requirements, along with its proactive approach to operation and management of the collection system, has served it well, as evidenced by the system’s performance relative to other agencies in the region and the state.

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 2 of 65 Figure 1 – Collection Spill Summary: Operational Indices for City with State and Regional Data

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 3 of 65 Figure 1 provides key spill metrics, including data comparing the City’s spill record with state and regional system data for the five-year period of July 2020 through July 2025. The City consistently performs better than both statewide and regional spill rate indices and net spill volumes for all categories of spills from its sanitary sewer collection system. For reference, Category 1, 2, and 3 spills are defined on the Sanitary Sewer Systems General Order homepage.

SSMP Organization
This SSMP is organized into 11 core elements following Attachment D of the WDR, with inclusion of applicable Specifications requirements.

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

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

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

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

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

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

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

© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 4 of 65 Abbreviations and Acronyms
BMP Best Management Practices
CCTV Closed Circuit Television
CIP Capital Improvement Program
CIPP Cured in Place Pipe
CIWQS California Integrated Water Quality System (State Water Board Online Spill Database) CMMS Computerized Maintenance Management System
Eng
EPA US Environmental Protection Agency
FOG Fats, Oils and Grease
FSE Food Service Establishment
GCD Grease Control Device
GIS Geographic Information System
I & I Inflow and Infiltration
Legal City legal staff
LRO Legally Responsible Official
RWQCB Regional Water Quality Control Board
SCADA Supervisory Control and Data Acquisition
SCRWA South County Regional Wastewater Authority
SERP Spill Emergency Response Plan
SOP Standard Operating Procedure
SSMP Sewer System Management Plan
Spill Sanitary Sewer Spill
SWRCB State Water Resources Control Board
UT Ops Mgr. Utilities Operations Manager
WDID Waste Discharge ID Number (CIWQS)
WDR Sanitary Sewer Systems General Wastewater Discharge Requirements Order issued by the State Water Board (Order No. 2022-0103-DWQ)
WW Sup Wastewater Superintendent/Sewer Operations Supervisor Table 2 – Abbreviations and Acronyms

GOAL AND INTRODUCTION
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1. Goal and Introduction

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

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

1.1. Regulatory Context

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

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

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

EFFECTIVENESS
N/A

IMPLEMENTATION PLAN/SCHEDULE
N/A

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 6 of 65

1.2. SSMP Update Schedule

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

COMPLIANCE
The City utilizes the State Water Board’s online lookup tool to ensure compliance with all required due dates for updating its SSMP and completing its required SSMP Audits (see chart below).

The City has contracted with FCL Compliance to complete the Audit covering August 2021 through August 2024. It is anticipated that the audit will be complete by the end of 2025, at which time it will be uploaded to CIWQS and this SSMP will be revised to reflect the Audit’s findings.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

GOAL AND INTRODUCTION
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1.3. Sewer System Asset Overview

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

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

COMPLIANCE
The City of Gilroy is in Santa Clara County and encompasses approximately 16.5 square miles. The City’s wastewater collection system serves approximately 61,000 people in the service area shown in Figure 3, below. The sewer system consists of approximately 172 miles of gravity sewers, 0.2 miles of force main, one lift station, and 4,030 manholes, as shown in Figure 4. Most of the pipelines are 8-12” in diameter and were constructed between 1960 and 2000. Specific details regarding the gravity sewer system (i.e., size, materials, and age) are found in Appendix 1.

The City’s collection system includes 13 siphons and no stormwater diversion structures.

Sewage from the City sewer system is conveyed to and treated at the South County Regional Wastewater Authority (SCRWA) Wastewater Treatment Plant (WWTP). The WWTP’s average daily capacity rating is 8.5 million gallons per day (mgd). To allow for the long-term growth in the City of Gilroy and Morgan Hill, the SCRWA plant expansion project broke ground in 2021. When completed and operational, the facility will be able to treat 11 mgd, allowing SCRWA to provide adequate service to its customers and the demands associated with future growth in both cities.

The City maintains most inspections, maintenance, and system evaluations in Excel databases, with some data captured in CMMS and GIS programs. The City currently assigns work schedules manually based on maps and a predetermined cleaning schedule for different zones within the City. However, the City is in the process of transitioning to the Cityworks CMMS software, which will pre-populate daily work assignments for improved efficiency and tracking. Cityworks will also be used to maintain maps of the collection system.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 8 of 65 There are approximately 15,759 upper and lower service laterals connected to the system. The City owns 22 of these laterals (i.e., on City-owned property). Other than those on City-owned property, the City is not responsible for cleaning laterals. As described in the City’s 1999 Sewer Lateral Maintenance Policy (Appendix 1), the property owner is fully responsible for cleaning laterals between the building and the main. City is responsible for repairs of the lower service lateral within the street right-of-way.

The percentage of residential, commercial, and industrial service connections is shown in Table 3, below.

The City is in a good position to maintain its collection system. The City does not have any unique challenges, other than the need to coordinate with the City of Morgan Hill regarding the SCRWA WWTP. Gilroy’s collection system discharges into the joint Morgan Hill – Gilroy sewer trunk (Joint Trunk) for transport to the SCRWA WWTP. The Joint Trunk is maintained by a Joint Exercise of Powers Agreement between the City of Gilroy and the City of Morgan Hill dated May 19th, 1992, which is included in Appendix 1. Per the agreement, the City of Morgan Hill is responsible for all maintenance of the Joint Trunk up to Highland Avenue in San Martin. Additional maintenance costs incurred south of Highland Avenue are shared with Gilroy. The WWTP is overseen by a Board of Directors with representatives from both cities.

The City maintains up to date maps of its collection system.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 9 of 65 Figure 3 – City Vicinity Map and Service Area

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 10 of 65 Use Type Number or % of Connections
Residential 14,226
Commercial/ Industrial 1510
Institutional 33
Total 15,759
Table 3 – City Sewer Connection Flow Classifications and Connections Data Figure 4 – Sewer Collection System (from 2023 Master Plan)

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 11 of 65

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

RESILIENCE
Resilience is addressed in Element 1 by:
• Implement a system for collecting and managing asset data. • Redundancy: More than one member of staff is trained and able to retrieve and manage the data. • Implementing a QA/QC process to help ensure information is accurate. • Using an Excel database to ensure that timely compliance with deadlines is met.

APPENDIX 1 INCLUSIONS:
• 1.1 Gravity Sewer System Specific Details (size, materials, age) • 1.2 1999 Sewer Lateral Maintenance Policy
• 1.3 1992 Joint Exercise of Powers Agreement Creating the South County Regional Wastewater Authority

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 12 of 65 Specifications 5.2 – SSMP Development and Implementation

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

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

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

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 13 of 65 Specifications 5.7 – Allocation of Resources

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

COMPLIANCE
Maintenance and operation of the sanitary sewer collection system is funded through user fees based on rate structures approved by the City Council. Every five years, the City reviews water and sewer rates through a cost-of-service rate study. The City Council approved the most recent rate study recommendations on October 16, 2023, and the updated rates took effect on January 1, 2024. The rate study recommended annual increases from 2024 through 2028.

Fees assessed to utility customers are collected in an Enterprise Fund, which funds the ongoing operations, maintenance, and planning and implementation of capital improvements to the wastewater infrastructure.

For FY26 and FY27 combined, the Wastewater Collections budget includes $240,000 for heavy equipment, $173,000 for vehicles, $150,000 for root control, $80,000 for Smart Covers, $510,000 for emergency services, and $385,000 for equipment and improvements.

The table below, from the City’s FY26 and FY 27 Recommended Operating and Capital Budget, shows the Sewer Enterprise Fund’s actual and projected revenue.

Table 4 – Sewer Enterprise Fund Revenue

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 14 of 65 The table below shows how the City expects to allocate its Sewer Enterprise Funds by type of expense:

A secondary source of revenue is from development fees that fund the installation of the collection system to areas not yet served and to upsize pipes to ensure adequate capacity and other capital needs.

The Wastewater Collections team is generally adequately staffed, although there is one collection system vacancy as of mid-2025.

Table 5 – Sewer Enterprise Fund Expenditures

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 15 of 65 Provisions 6.1 – Enforcement Provisions

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

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

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

Failure to comply with the notification, monitoring, inspection, entry, reporting, and recordkeeping requirements may subject the City to administrative civil liabilities of up to $10,000 a day per violation pursuant to Water Code section 13385; up to $1,000 a day per violation pursuant to Water Code section 13268; or referral to the Attorney General for judicial civil enforcement. Discharging waste not in compliance with the requirements of this General Order or the Clean Water Act may subject the City to administrative civil liabilities up to $10,000 a day per violation and additional liability up to $10 per gallon of discharge not cleaned up after the first 1,000 gallons of discharge; up to $5,000 a day per violation pursuant to Water Code section 13350 or up to $20 per gallon of waste discharged; or referral to the Attorney General for judicial civil enforcement.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 16 of 65 Provisions 6.3 – Sewer System Management Plan Availability

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

COMPLIANCE
The City maintains a paper copy of the SSMP in its offices which can be made available for inspection during regular business hours. The City also published its 2019 SSMP on the City of Gilroy’s website at the StreetsTrees-Sewers page. After City Council approval, the City will upload the 2025 SSMP to its website. The City may update its website because of the reorganization described in the Introduction section; if this occurs, the 2025 SSMP will be moved to a different location.

ORGANIZATION
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2. Organization

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

COMPLIANCE
The City’s sanitary sewer collection system is operated and maintained by the Wastewater Collections Section of the Operations Division with the assistance of the Engineering Division for long range planning and capital program management. The Operations Division is also supported by the City’s Risk Management, Building, and Environmental Services Divisions.

As described in the Introduction section, Wastewater Collection Section staff are currently transitioning from the Public Works Department to the newly created Utilities Department. After the transition, Wastewater Collections Section staff will operate under the Operations Division of the Utilities Department.

SCRWA provides funding for the Pretreatment Program, which includes FOG control, permitting, inspections, and enforcement for all regulated dischargers within the cities of Gilroy and Morgan Hill.

The above items are addressed in order below:

The City’s current Legally Responsible Official is Matt Jones, the Public Works Deputy Director overseeing the Wastewater Collections Section. The City is in the process of hiring a new Operations Manager for the Utilities Department who will become the new LRO. Mr. Jones meetsthe requirements set forth in Specifications 5.1 of the WDR.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 18 of 65 Implementation Responsibilities

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 19 of 65 Sewer System Management Plan Elements Responsible Position

1. SSMP Plan, Goal and Introduction Utilities Operation Manager and Public Works Deputy Director

1.1. Regulatory Context Same as above

1.2. SSMP Update Schedule Same as above

1.3. Sewer System Asset Overview Same as above

2. Organization Utilities Department Director

3. Legal Authority Utilities Department Director

4. Operations and Maintenance Program Wastewater Collection Section Supervisor

4.1. Updated maps of Sanitary Sewer System Wastewater Collection Section Supervisor

4.2. Preventive Operation & Maintenance Wastewater Collection Section Supervisor

4.3. Training Wastewater Collection Section Supervisor

4.4. Equipment Inventory Wastewater Collection Section Supervisor

5. Design/Performance Engineering (Utilities Capital Improvement Engineer and Public Works Land Development)

5.1. Updated Design Criteria & Construction
Standards
Engineering (Utilities Capital Improvement Engineer
and Public Works Land Development)

5.2. Procedures and Standards Engineering (Utilities Capital Improvement Engineer and Public Works Land Development)

6. Spill Emergency Response Plan Wastewater Collection Section Supervisor

7. Sewer Pipe Blockage Program Wastewater Collection Section Supervisor

8. System Eval, Capacity Assurance, Capital Imp.

Utilities Operation Manager & Engineering (Utilities
Capital Improvement Engineer and Public Works
Land Development)

8.1. System Evaluation and Condition Assessment Engineering (Utilities Capital Improvement Engineer and Public Works Land Development)

8.2. Capacity Assessment and Design Criteria Engineering (Utilities Capital Improvement Engineer and Public Works Land Development)

8.3. Prioritization of Corrective Action Utilities Operation Manager

8.4. Capital Improvement Plan Engineering (Utilities Capital Improvement Engineer and Public Works Land Development)

9. Monitoring, Measurement & Program Modifications Utilities Operation Manager

10. Internal Audits Utilities Operation Manager

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 20 of 65

11. Communication Program Utilities Operation Manager & Community Engagement Manager
Table 6 – Implementation Responsibilities

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 21 of 65 Responsible Position Contact Information
Responsible Position Contact Information Phone Email
Public Works Deputy Director 408-846-0275 [email protected] Utilities Department Director 408-846-0229 [email protected] Utilities Operations Manager N/A New position - currently vacant City Engineer 408-846-0531 [email protected] Land Developer Engineer 408-846-0226 [email protected] Wastewater Collection Section Supervisor 408-846-0423 [email protected] Community Engagement Manager 408-846-0443 [email protected] Table 7 – Responsible Position Contact Information

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 22 of 65

2.1. Organizational Chart
The following chart depicts the overall organization of the Utilities Department and shows how SCRWA and the pre-treatment program are connected.

Figure 5 – City Utilities Department Organization Chart

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 23 of 65

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

City Administrator
Under general guidance from the Gilroy City Council, the City Administrator serves as the chief executive officer with responsibility for all City Functions
City Attorney
Serves as legal counsel for the City and is responsible for maintaining the City Administrative and Municipal Codes.

Utilities Department Director
Under direct supervision of the City Administrator, organizes and administers the operations of City Utilities Department (Water, Wastewater, and Wastewater Treatment Plant); directs the activities and execution of short and long-term goals and projects for the Department to best serve the needs of the City.

Utilities Operation Manager
Administers, plans, and directs the varied operations of the water distribution and wastewater collection systems, including their operation, maintenance, and repair to ensure public health, safety, and welfare. Is responsible for establishing and maintaining safe work practices and ensure compliance with all safety, environmental, and OSHA related laws and regulations. Provide leadership, training, and mentoring to ensure that each operational section is meeting established goals, objectives, work plans, and deadlines.

Wastewater Collections Supervisor
Operations Services Supervisor leads and supervises the staff of the Wastewater Collections Section and is responsible for all aspects of operation and maintenance of the City’s sewer collection system and facilities; supervises, evaluates, and occasionally assists in the work of maintenance staff; responsible for review, evaluation, and problem solving of difficult and complex operation and maintenance challenges; reviews and evaluates operation and maintenance performance, implementation of regulatory or process changes, and assists the Utilities Operations Manager in the development and management of the department budget; demonstrates a thorough understanding of all applicable regulatory requirements, policies, procedures, and work methods associated with assigned duties; coordinates activities with other Departments and interacts with outside agencies, organizations, and the public; performs other related duties as required.

Wastewater Collection System Senior Maintenance Worker
Lead, monitor, and perform work for the Wastewater Section, including inspecting, cleaning, maintaining, and repairing sanitary sewer lines; investigate and resolve service requests and customer complaints, operate and provide necessary daily maintenance on equipment, vehicles, hand and power tools as assigned, assist with preparation and administration of Section budget, prepare reports and analyses; keep records; maintain files.

Senior Hazardous Materials Inspector (Industrial Pretreatment Program) Under the supervision of the Hazardous Materials Supervisor/ Fire Marshal, enforce the requirements of Federal, State and Local regulations and ordinances related to industrial/commercial wastewater, hazardous material, underground storage tanks and other similar requirements. The Inspector I level is an entry/training level for the Hazardous Materials Inspector job series. The Inspector I level is expected to

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 24 of 65 have the educational level of the Inspector II but may have only limited experience in one or more of the program areas.

ORGANIZATION
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2.3. Chain of Communication for Reporting Spills
The City is notified of a spill in multiple ways: observation by the public, receipt of an alarm, or observation by City staff during the normal course of their work.

Public Observation
Public observation isthe most common way that the City is notified of blockages and spills. Contact numbers and information for reporting sewer spills and backups are on the City’s website at Report Sewer Spills. The City’s telephone number for reporting sewer problems during business hoursis(408) 846-0223.

The City’s telephone number for reporting sewer problems after business hours is (408) 846-0350.

The Home Page of the City’s website also has a “Report a Concern” link. Clicking on this link directs the public to “GilroyConnect”, an online service request portal, which allows the public to input information related to the spill. There is a companion mobile app which has the same feature. • Normal Work Hours: Business hours calls are received by Public Works Admin Staff, and they will record the caller’s name, address of the problem and contact information in Cityworks to begin a Service Request. They will call the Operations Services Supervisor, and they will dispatch an available Sewer crew. They will perform an investigation and note findings and actions taken, if any, either on paper or on the tablet in Cityworks. The information is transferred into Cityworks (if not entered in the filed on the tablet) and the Sr. Maintenance Works or Supervisor will close out the Service Request. If the service request involved a spill, the Spill Response Workbook will also be completed. • After Hours: After hours calls are received by City non-emergency dispatch, and they will call the Standby Employee. They will perform an investigation and note findings and actions taken, if any, either on paper or on the tablet in Cityworks. The information is transferred into Cityworks (if not entered in the filed on the tablet) and the Sr. Maintenance Worker or Supervisor will close out the Service Request the next business day in Cityworks. If the service request involved a spill, the Spill Response Workbook will also be completed.

When calls are received, either during normal work hours or after hours, the individual receiving the call will collect and include in the spill event file, at a minimum, the following information to record the complaint:
• Date, time, and method of notification,
• Date and time the complainant first noticed the spill, if available, • Narrative description of the complaint, including any information the caller provided regarding whether the spill has reached surface waters or a drainage conveyance system, if available, • Complainant’s contact information, if available, and
• Final resolution of the complaint.

If the spill or backup is not in the City’s service area the individual receiving the call provides the customer with the contact information for the responsible agency and then notifies that agency.

Lift Station
The City operates one wastewater lift station. In the event of a station failure the SCADA alarm system is activated and the City is contacted. To prevent spills, wastewater from the wet well can either be pumped into a vacuum truck for disposal to a nearby sanitary sewer manhole or bypassed around the station into the sanitary sewer system.

City Staff Observation

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 26 of 65 City staff conducts periodic inspections of its sewer system facilities as part of their routine activities. Any problems noted with the sewersystem facilities are reported to appropriate City staff that, in turn, respond to emergency situations. Work orders are issued to correct non-emergency conditions.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 2 INCLUSIONS:
• None

LEGAL AUTHORITY
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3. Legal Authority

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

COMPLIANCE
The Gilroy Municipal Code describes the City’s legal authority required for compliance with the WDR. That authority is specifically contained within Chapter 19 “Sewers and Sewage Disposal” of the Municipal Code.

All FOG related authorities are included in the SCRWA Sewer Use Ordinance No. 2024-01.

The above items are addressed in order below:

Authority to prevent illicit discharges into the City’s wastewater collection system.

The City’s Municipal Code, Section 19.100, prohibits the discharge of stormwater, surface waters, roof runoff, and subsurface drainage to the sewer system. Section 19.102 prohibits the discharge of certain wastes, including gasoline or fuels, hot waste, garbage that has not been shredded, low or high pH waste, noxious gas, garbage, fats, oils, grease, sludges, and toxic materials. Section 2.1 of the SCRWA Sewer Use Ordinance contains similar prohibitions on discharges that will pass through or cause interference with the operation or performance of the WWTP.

The City’s pre-planned collaboration and coordination with storm drain agencies.

The City owns and operates most of the storm drains within its boundaries and has a de facto legal authority to ensure access to these storm drains in the event of a wastewater spill. With the recent department restructuring, Utilities Department staff will maintain the wastewater collection system and Public Works Department staff will continue the responsibility for maintaining the storm drain system.

In addition, both Santa Clara County and Caltrans own and operate storm drains within the City limits. The City has historically had good communications with the County, and the City is permitted to do work within their drains as necessary. If a spill were to occur within a County storm drain, the City would clean up the spill. To comply with the WDR requirement, the City will contact the County and Caltrans to discuss a mutual

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 28 of 65 aid agreement to allow the City to respond to any wastewater spills which enter a County or Caltrans storm drain.

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

Section 19.9 of the City’s Municipal Code states, in part, “Plans for sewerage construction shall meet all design requirements of the Standard Details, Public Works Department Manual and shall also meet the design requirements as established from time to time by the director of public works. Inspection of all sewerage construction shall be made by the city in the manner described in Standard Specifications for Public Works Construction (commonly referred to as the “Green Book”).” Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee.

The City’s 1999 Sewer Lateral Maintenance Policy (found in Appendix 1) states that the City will repair and clean lower laterals, which are located within the public right-of-way. However, the property owner is responsible for maintenance and repair of the upper laterals, which extends from the house or business up to the right of way point of connection.

Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures.

Sections 19.111 through 19.114 of the City’s Municipal Code contain enforcement provisions, including monetary civil penalties, ability to abate, discontinuation of service, and the ability to seek injunctive relief.

The SCRWA Sewer Use Ordinance also contains enforcement provisions in Section 8, including violation notices, consent orders, compliance orders, cease and desist orders, fines, and termination of discharge.

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

The City understands that previous easement agreements have been recorded with property records and that the only way to document existing easements is to review each individual property record.

Unfortunately, the City does not have the staff to review all property records. However, moving forward, the City will maintain a database that lists the easements the City becomes aware of.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

LEGAL AUTHORITY
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 29 of 65 APPENDIX 3 INCLUSIONS
• None

OPERATIONS AND MAINTENANCE PROGRAM
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4. Operation and Maintenance Program

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

4.1. Updated Map of Sewer System

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

COMPLIANCE
The City is in the process of using the Cityworks software program to maintain up-to-date maps of its collection system. Cityworks software holds coordinates and symbology of the City assets in the map layers already uploaded from ARC GIS layers. Any new infrastructure not captured (or missed) at the point the layers were created will need to be added. Staff’s inspections, work orders and service requests add information that can then be tracked in the system, as they are applied to the assets. The data is currently held on log sheets (hardcopy) and/or excel spreadsheets. However, this can easily be entered into Cityworks to set the baseline, and the City will do so soon.

The GIS maps will include all gravity lines and manholes, pump stations, pressure pipe, siphons and other appurtenances, as well as basic asset information regarding size, material and flow direction, specific asset identification numbers for each asset and operational elevations.

The City has hired a new GIS Analyst who will maintain both sewer and storm drain maps. If staff find a problem with the map, they email the Analyst and ask for an update. It is anticipated that updates will be completed within 30 days. The City will create a form to document the need for updates.

The City will provide the system maps to State and Regional Water Board staff upon request.

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

OPERATIONS AND MAINTENANCE PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

OPERATIONS AND MAINTENANCE PROGRAM
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4.2. Preventive Operation and Maintenance Activities

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

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

COMPLIANCE
The City assigns work schedules manually based on maps and a predetermined cleaning schedule for different zones within the City. However, the City is in the process of transitioning to Cityworks software, a computerized maintenance management system (CMMS), which will pre-populate daily work assignments for improved efficiency and tracking.

Gilroy’s collection system is divided into 18 maintenance zones. Six of the zones are considered “hot spots”, based on age of pipe and/or FOG buildup. The cleaning schedule is established considering the condition of pipes, conditions found in the field, and institutional knowledge.

The City’s 13 siphons are cleaned monthly, and the high-priority lines are also cleaned on a monthly schedule, as outlined in Section 5.19.

The City has two Vactor combo trucks and one CCTV vehicle. The two Vactor trucks are operated every day, with a focus on cleaning and line repairs.

The City uses CCTV to inspect a line after a spill event, on a problem line, or after a repair. The City does not routinely CCTV the entire collection system; approximately 5% of the system has been CCTV’ed to date. With the establishment of the new Utilities department and planned staff additions, the City intends to increase the frequency of CCTV inspections.

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

OPERATIONS AND MAINTENANCE PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

OPERATIONS AND MAINTENANCE PROGRAM
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4.3. Training

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

COMPLIANCE
The City trains its staff with a combination of in-house classes, safety tailgate sessions, field exercises, on the job training, conferences, seminars, OSHA classes and other training opportunities. The City will use a form like that found in Appendix 4.1 to document training sessions.

The City contracted with DKF Solutions to prepare a revised Spill Emergency Response Plan (SERP) and to complete training regarding the document on October 3-4, 2023. Staff who respond to sewage spills received training regarding how to implement the revised SERP, including how to estimate spill volume, and the requirements of the WDR. The training included an on-site practice drill with training on emergency response procedures with flow estimation using the holes in manhole covers. The training also included determining spill start times, recovery estimation, and CIWQS reporting procedures.

The City’s standard service and construction contract language requires all contractors working in the wastewater collection system to provide training for their employees on the City’s Sanitary Sewer Overflow Emergency Response Plan or demonstrate they have been trained on an equivalent emergency response plan of their own. Alternatively, City staff will instruct contractors on the process to follow in the event of a spill and will provide contractors with a spill response form such as the one found in Appendix 4.2.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

OPERATIONS AND MAINTENANCE PROGRAM
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4.4. Equipment Inventory

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

COMPLIANCE
The major equipment used by the City for the operation and maintenance of its sewer system is listed below:

Major Equipment Inventory
Equipment Description
3747 Vactor Combo Sewer Line Cleaner 2017
3749 Vactor Combo Sewer Line Cleaner 2023
2725 Ford Crew Cab Pick-up Truck 2017
N/A 3-Inch Godwin Trash Pump 2017
3020 Freightliner/CCTV Van 2019
2725 Ford Crew Cab Pick-up Truck 2017
2441 Chevy/2500 Utility Truck 2024
2439 Chevy/2500 Utility Truck 2024
2415 Ford/F-350 Utility Truck 2025
2416 Ford/F-250 Utility Truck 2025
Not Designated Yet Chevy/2500 Utility Truck FY 26
Not Designated Yet Concrete Saw with Trailer Diamond Walk behind saw core cut FY 25 The City also has keeps multiple 4” pipes, 6” pipes, 8” pipes, and rubber couplings on hand and ready for use.

An additional piece of heavy machinery (a John Deere Backhoe – Model 320 P-Tier) has been approved and is planned to be purchased in FY 26.

The City’s criticalreplacement parts list is shown in the table below; this inventory is kept on hand and stored at the SCRWA. In addition, replacement parts for the sewer lift station are stored at SCRWA.

Critical Replacement Parts Inventory
Qty Description Mfg Part#
1 Standby Generator Detroit Diesel 50DS
2 Submersible Sewage pump Flygt 3140.09
1 Facility Alarm Dialer Raco Verbatium
Table 8 – Major Equipment Inventory

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 36 of 65 Critical Replacement Parts Inventory
Qty Description Mfg Part#
1 6" Mag flow meter Elsag Bailey Process Automation 10DX4311 1 Emergency Breaker Square D FAL34100
2 Motor Breaker Square D FAL34040
1 Control Breaker Square D FAL12015
1 Main Circuit Breaker Square D FAL12030
2 Motor Starter (size 2) Square D 8536-SDO1V02S
1 Control Power Transformer Square D 9070-T3000D1
1 Control Transformer Square D 9070-TF75D23S12
2 Fuse Gould OTM-5/250
2 Fuse Gould ATQR-10/600V
3 Fuse Gould ATM-1/600V
7 Fuse Holder Littlefuse L60030M1PQ
2 (NO,NC) Contact Square D 9001KA3
16 Contact Relay (120Vac) Potter B. KRPA14AN-120
18 11 Pin Socket IDEC SR3P-05
1 Auto Alternator (13SP) Flygt 14-40 31 86
3 Time Delay Flygt 14-40 31 91
1 Time Delay Square D JCK13V20
1 Phase Monitor Flygt 14-40 31 88
1 Telephone Jack Allen Tel
5 Basin Float Switch (40') Grainger 5828859
2 Submersible sewage pump Fylgt 3153.090.151
1 Submersible sewage pump Flygt 3153.095 (spare part)
1 Submersible sewage pump repair
kit Flygt 3153.090.180 (spare part)
1 Submersible sewage pump repair
kit Flygt 3153.090.181 (spare part)
1 SCADA/My DRO 850 Mission Communications M852L (new)
Table 9 – Critical Replacement Parts Inventory

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 4 INCLUSIONS:
• 4.1 Example Training Record
• 4.2 Example Contractor Spill Response Form
• 4.3 Example Manhole Inspection Form

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 38 of 65 Specifications 5.19 – Operations and Maintenance

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

COMPLIANCE
The City’s sewer system O&M program includes:
• Proactive, preventive, and corrective maintenance of gravity sewers; • Periodic inspection and preventive maintenance of the pump station; • Rehabilitation and replacement of sewers that are in poor condition; and • Proper training for City employees and contractors to assure proper operations and maintenance of the collection system facilities.

The City’s Wastewater Collections section is responsible for the normal maintenance and operations of the City’s sanitary sewer collection system.

Gravity Sewer Maintenance
The City’s collection system is divided into 18 sewer maintenance zones with a cleaning schedule established considering the condition of pipes, conditions found in the field, and institutional knowledge.

The City currently employs two cleaning crews, one for high priority cleaning and one assigned to systemwide cleaning within the 18 sewer maintenance zones. Cleaning results are currently recorded in Excel but will be transitioned to Cityworks. The following table documents the City’s system-wide cleaning results (excluding the high priority areas).

Calendar Year Total Feet Total Miles
2018 242,549 46
2019 450,910 85
2020 273,457 52
2021 No cleaning- Covid 0
2022 318,245 60
2023 65,950 13
2024 179,734 34
The large diameter pipelines (12” inch diameter or larger) are currently not maintained except as needed.

The City intends to evaluate the need for maintenance of these large lines, including how and when maintenance should be done either by City staff or service contractors.

Table 10 – System Wide Cleaning Results

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 39 of 65 High Priority
High Priority lines (“hot spots”) are cleaned monthly, during the first few days of each month. After that, staff clean other areas of the system, with the goal to clean the entire system yearly. The current High Priority lines are listed below. Currently there are 88 pipe segments on the high frequency program totaling 20,178 linear feet.

City staff will be working to develop standard operating procedures for the addition and removal of lines from the high frequency program. This will assure proper cleaning efficiencies and will assist with a better understanding of the requirements for high frequency maintenance activities and may lead to repair or pipe rehabilitations or more aggressive enforcement from the discharge of fats, oils and grease.

District Location
District 1 Juniper
District 2 3rd St & Santa Theresa Dr.
4th St & Santa Thereas Dr.
3rd St between Miller/Rea
6th & Princevalle, MH near SW corner
District 3 3rd St between Church/Eigleberry
4th St between Church/Eigleberry
Between Eigleberry and Church
5th St between Hanna/Rosanna
7th St between Monterey/Eigleberry
9th St between Hanna/Rosanna
9th St between Church/Rosanna
District 4 Rosanna & 11th
6700 Rosanna
6941 Church St
Church St & 11th St
Church St N of London Dr
Garden Court, S/end
130 London Pl
District 5 N end of Wayland
Willard Ct & Wren
Sherwood & Hanna
Pierce & Monterey

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 40 of 65 District Location
8000 Church St
District 6 Murray Lft Trn (8” line) by Chevron
Swanston & Forest
Leavesley MH next to median E of RR
Monterey MH in front of trans shop
MH at midblock btwn Hornlein next to RR
9th & Alexander MH near SE corner
Old Gilroy (btwn Chestnut/Forest) S 430’ LP
Old Gilroy (btwn Chestnut/Forest) N 210’
The following table documents the City’s High Priority cleaning results. It is noted that while system-wide cleaning was not completed in 2021 due to COVID, the City did clean its High Priority lines. In addition, although the number of lines should remain constant each year, and therefore the total feet/miles cleaned should remain the same each year, City staff did not accurately report the feet of lines that were cleaned.

For example, if line cleaning was completed mid-day, the cleaning team would then complete system-wide cleaning in the afternoon. Instead of reporting the feet of high-priority cleaned of lines and the feet cleaned of system-wide lines, the cleaning team would report the total number of feet cleaned for the day. The City intends to create a database to capture accurate values for line cleaning versus system wide cleaning.

Calendar Year Total Feet Total Miles
2018 648,597 123
2019 663,082 126
2020 608,912 115
2021 579,854 110
2022 479,076 91
2023 640,375 121
2024 760,614 144
In the future, line cleaning crews will evaluate cleaning results using the City’s “Standard Measures of Observed Results for Collection System Line Cleaning”, found in shown in the table below. The use of these new Standard Measures in conjunction with enhanced CCTV inspections will allow the City to develop new need-based cleaning schedules. Staff will place line segments on a higher or lower frequency schedule based upon past cleaning results, history of blockages, spill events, history of cleaning results, video Table 11 – Problem Line Cleaning List
Table 12 – Problem Line Cleaning Results

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 41 of 65 inspections and professional judgment. The current high frequency maintenance schedule only adds lines and very seldom removes line segments.

Standard Measures of Observed Results for Collection System Line Cleaning Joint Trunk Maintenance
The City shares the operations and maintenance responsibilities of the joint trunk sewer line to the SCRWA Treatment Plant with the City of Morgan Hill. Responsibilities are assigned according to the capacity ratios defined in the 1992 Joint Powers Agreement (found as Attachment 1.3).

Manhole Inspection Program
As pipelines are cleaned, City staff monitor and inspect a select list of manholes that have historically created potential operations and maintenance issues. If the manhole is not found to be flowing freely during an inspection, then additional maintenance in and around the pipe segments connected to the manhole is conducted to assure that these manholes do not create spills or operational problems. The City will begin documenting manhole inspections using a form similar to that found in Appendix 4.3.

Table 13 – Standard Measures of Observed Results for Collection System Line Cleaning

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 42 of 65 The City would like to define and implement a formal manhole inspection program based upon the NASSCO Manhole Assessment Certification Program (MACP) rating system. The inspection program would be conducted in conjunction with regular CCTV inspections. All problem conditions noticed during cleaning would be reported and appropriate repairs initiated.

Smart Covers
The City completed installation of three Smart Covers in 2024. Smart Covers provide increased ability to monitor overflows and optimize collection system cleaning methods and intervals. The Smart Covers were installed at:
• Mesa Rd and Nicole Way
• Ranco Real and Wellburn Ave
• Christmas Hill Park Ranch site
Additional Smart Cover installations are planned as part of the recently approved budgets for Fiscal Years 2026 and 2027 at the following locations:
• Wellburn siphon
• 9th Street between Monterey St/Eigleberry St
• Mesa Rd and Thomas Rd
• Monterey St and I.O.O.F
Lift Station Maintenance
The City owns one sewer lift station which is currently operated and maintained via a service agreement with Jacobs Engineering. The City plans to transfer responsibility for operation and maintenance of the sewer lift station to the Utilities Wastewater Collection Section.

The lift station is checked once a week, and emergency power transfer check is completed once a month.

The lift station includes a SCADA monitoring system. If unusual conditions or alarms are registered, an oncall operator will receive an alert. An emergency response plan has been placed at the pump station and is available at SCRWA.

Force Main
The City maintains the force main from the lift station to the City collection system. The City will begin inspecting the force main at potential discharge locations and will determine an appropriate inspection schedule.

Siphons
The City collection system includes 13 siphons, which are listed in the table below. All siphon pipelines are cleaned monthly.
# Siphon Title / Name Cross Street / Location Length, each pipe
Length,
Total Size Inches Single / Double
1 Santa Teresa Blvd
(Bridge) Longmeadow Dr 75 150 10 Double
2 Wren Ave Uvas Park Dr 432 432 18 Single
3 Luchessa Ave (Bridge) Next to Levee trail /
driveway NE side 340 680 12 Double

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 43 of 65 # Siphon Title / Name Cross Street / Location Length, each pipe
Length,
Total Size Inches Single / Double
4 Princevalle Channel Princevalle St MH S bank to
Johnson 40 80 8 Double
5 Princevalle Channel Monterey Rd S. bank, MH
315; frin 50 100 6 Double
6 Princevalle Channel Auto Mall Prkwy, next to
6475 old Granite Rock 30 60 10 Double
7 Church St (Bridge) Woodworth Way 140 280 18 Double
8 Welburn Ave (Bridge) 8383 Church (Village Car
Wash) 85 170 10 Double
9 IOOF Ave (Bridge) East of bridge 95 190 10 Double
10 Murray Ave (Bridge) East end of bridge by
Lincoln Court 120 240 15 Double
11 Forest St (Bridge) Fortunata Place 75 150 10 Double
12 Rogers Lane (Miller
Slough)
Below 6th St (overpass) on
N. Side 45 90 27 Double
13 Gilroy Gardens East bank of Uvas Creek
gravel road 400 1200 6, 8 and 10 Triple
Root Foaming
As part of the biennial budget development for FY 26 and FY 27, funds have been allocated to reinstate the City’s root control treatment program. The City will determine which line segments should receive root treatment, and the appropriate frequency of treatment, based on institutional knowledge.

An effective root control program emphasizes proactive and routine maintenance to reduce system damage and long-term operational costs. These treatments are designed to be translocated within the root structure upon application, preventing regrowth and intrusion. When performed regularly as part of a preventive maintenance strategy, root control treatments help prolong the life of sewer pipes and yield substantial cost savings over time.

Private Sewer Laterals
The City’s 1999 Sewer Lateral Maintenance Policy (found in Appendix 1) states that the City will repair and, which are located within the public right-of-way. However, the property owner is responsible for maintenance and repair of the upper laterals, which extends from the house or business up to the right of way point of connection. City intends to update its Municipal Code to include this policy.

The City may voluntarily report spills from private sewer laterals into the CIWQS database as the City becomes aware of the overflows.

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

Table 14 – Gravity Sewer System Siphons

DESIGN AND PERFORMANCE PROVISIONS
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5. Design and Performance Provisions

5.1. Updated Design Criteria/Construction Standards/Specifications

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

COMPLIANCE
The City’s Standard Details and Specifications are found on the Public Works web page. The City’s Standard Details and Specifications are updated on an ongoing basis to reflect current minimum and uniform requirements to be used by all developers, contractors, and engineers for the preparation of plans and the construction of public improvements. The Standard Details and Specifications are to be used in conjunction with the latest revision of all federal, state, Santa Clara County, Santa Clara Valley Transportation Authority, and the Santa Clara Valley Water District standards, specifications, and guidelines.

The City has established standards for both new construction and renewal and replacement work associated with the collection system infrastructure. These standards include design standards for pipes, manholes, laterals, materials and placement of pipes and manholes into the City system. These standards are supported by the sewer section of the standards details. The standards are regularly reviewed and modified as new and innovative construction techniques and materials are approved for use in the City.

The General Guidelines require that engineering calculations be submitted to the City Engineer, and contain standards for design flow, vertical alignment, horizontal alignment, slope, pipes, building laterals, and manholes.

The Technical Specifications include standards for pipes, fitting, excavation and backfill, existing manholes, pipe laying, sewer structures, and testing of sewers.

The Standard Details and Specifications do not include standards for lift stations. This is because there are too many variables to consider; each lift station design must be site-specific. Instead, the Engineering Department works with the developer’s registered engineer to determine the appropriate design for the location that the lift station will be installed.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

DESIGN AND PERFORMANCE PROVISIONS
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5.2. Procedures and Standards

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

COMPLIANCE
With respect to the wastewater collection system, the City’s Engineering Division is responsible for overseeing engineering standards, permitting, design and on-going improvements within the city rights-ofway. The Engineering Division also reviews permit applications and provides inspections for all residential, commercial and industrial developments.

The City’s Technical Specifications include standards for testing of sewers, which includes an exfiltration or infiltration test and a CCTV inspection.

The City’s Engineering Department has full-time Construction Inspectors who inspect both new construction and repairs. The inspector insures all construction meets the City’s standard specifications and other applicable codes. Permits are required for all work on wastewater facilities in the City, and no facility is accepted unless it is permitted, inspected, and tested in accordance with the standard specifications.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 5 INCLUSIONS:
• None

SPILL EMERGENCY RESPONSE PLAN
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6. Spill Emergency Response Plan

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

COMPLIANCE
The City’s Spill Emergency Response Plan (SERP) is a stand-alone document that contains all the key elements necessary for an appropriate spill response: notification, emergency incident response, reporting, and impact mitigation. The current plan, prepared by DKF Solutions Group, LLC, meets the requirements of the WDR.

The plan was drafted in 2023 and signed by the LRO in 2025. Initial training was provided to staff in 2023, and refresher training will be conducted annually. The SERP is found as an appendix to this document.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 6 INCLUSIONS:
• 2023 Spill Emergency Response Plan

SEWER PIPE BLOCKAGE PROGRAM
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7. Sewer Pipe Blockage Program

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

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

COMPLIANCE
The City’s Industrial Wastewater Pretreatment Program, which includes FOG control, is a sub-program of the South County Regional Wastewater Authority (SCRWA). The program is implemented by Gilroy’s Community Development Department Fire Prevention Division and serves the cities of Gilroy and Morgan Hill. The Pretreatment Program responsibilities include review and issuance of construction and operational permits for businesses that discharge industrial wastewater to SCRWA, periodic inspections of industries and businesses that discharge industrial wastewater to private and public sewer pipes, and protection of the public's investment in the SCRWA system.

The WDR’s requirements above are addressed below:

Public Outreach
The City’s webpage includes a Fats Oils Grease Disposal link that asks residents to dispose of FOG by pouring it into a container, scraping pots before washing, and putting all FOG into the trash. The City has a Best Management Practices for Restaurants webpage which includes information on how to manage grease.

The City has produced a YouTube PSA in coordination with the local children’s actors’ guild.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 49 of 65 The Pre-treatment team provides public information and outreach for the FOG Control Program. The City enhances this team's effort by providing utility bill stuffers regarding FOG and FOG controls and posting information on social media. For example, the City’s Utility bills have included a flier on Fat-Oil-Grease which is sent out near the end of year holidays. Gilroy Email Express is opened by ~11,500 subscribers. Additional outreach through Facebook and Instagram posts during the holiday season extends visibility to even more people.

Disposal
FOG generated by Food Service Establishments (FSEs) is collected in grease interceptors or grease traps which are maintained by the FSEs. The accumulated FOG is pumped out by licensed haulers hired by the FSE and taken to the haulers’ own facilities. City staff remove FOG from the collection system during routine pipe maintenance. This grease is disposed of at the SCRWA WWTP on an as-needed basis.

Legal authority to prohibit discharges.

The City’s Municipal Code Sections 19.100 and 19.102 prohibits the discharge of certain wastes. In addition, Section 2.1 of the SCRWA Sewer Use Ordinance contains similar prohibitions on discharges that will pass through or cause interference with the operation or performance of the WWTP.

Requirement to install grease interceptors, design standards, etc.

Section 3.2 of SCRWA’s Sewer Use Ordinance #2024-01 requires that grease interceptors be installed at any establishment where grease or other objectionable materials may be discharged to the collection system.

The Ordinance states, “Interceptors shall be constructed in accordance with applicable standards approved by the Authority.” These standards are found as Attachment 7.1. In addition, the City has adopted the 2016 California Plumbing Code which also provides authority for grease removal devices.

Authority to inspect and enforce.

Section 6.1 of SCRWA’s Sewer Use Ordinance states that “The Authority Manager shall have the right to enter the premises of any user to ascertain whether the user is complying with all requirements of this ordinance and any wastewater discharge permit or order issued hereunder. Users shall allow the Authority Manager ready access to all parts of the premises for the purposes of inspection, sampling, records examination and copying, and the performance of any additional duties.” Enforcement options are described in Section 8 of the Sewer Use Ordinance, and include violation notices, consent orders, compliance orders, cease and desist orders, administrative fines, and suspension or revocation of the wastewater discharge permit.

FOG-related problem areas.

The City has identified and maintains many collection system lines and siphons on a high frequency line maintenance list (details found in Section 5.19). These lines have experienced grease accumulation in the past and are cleaned on varying frequencies based upon severity. The single largest area for high frequency maintenance is the downtown area with a high concentration of restaurants.

Source control measures.

SCRWA and the City have identified and permitted 152 food service establishments (FSE) in the City of Gilroy and 121 in the City of Morgan Hill. In 2024, inspectors completed 116 inspections. An example inspection form is found as Attachment 7.2. During each inspection, a form reviewed by the State and Federal auditors is completed and educational materials are provided.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 50 of 65 The City’s Fire Prevention Division administers the Industrial Wastewater Pretreatment Program and conducts inspections of FSEs. A Grease Trap Maintenance Log (Attachment 7.3) is to be kept by FSEs. Three years of grease removal records are required to be kept at the facility and be available for inspection.

Operations and Maintenance crews report issues to the Fire Prevention Division when they find substantial amounts of grease in lines close to FSEs. Maintenance crews will also notify the Fire Prevention Division if they find a discharge from a grease trap.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 7 INCLUSIONS:
• 7.1 Grease Interceptor Requirements
• 7.2 Industrial Waste Pretreatment Inspection Form
• 7.3 Grease Trap Maintenance Log

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8. System Evaluation, Capacity Assurance, Capital Improvements

WDR REQUIREMENTS
Attachment D-8 (pg. D-7/D-8)
“The Plan must include procedures and activities for:
• Routine evaluation and assessment of system conditions; • Capacity assessment and design criteria;
• Prioritization of corrective actions; and
• A capital improvement plan.”

8.1. System Evaluation and Condition Assessment

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

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COMPLIANCE
The above requirements are addressed below:

System Evaluation:

The City’s collection system evaluation involves every component of the City collection system, including pipelines, manholes, and siphons. It is of key importance to regularly perform pipeline condition assessments to initially establish a baseline condition and to monitor changes over time. The City uses visual inspections, CCTV inspections, and spill data to evaluate the performance of system assets and adjust, as necessary.

Justify the amount of system assessed each year:

The City has diligently maintained its collection system, which has resulted in a very low spill rate. It's goal is to clean the entire system at least yearly, and high priority lines multiple times per year. The City has not yet determined the optimal cleaning interval or CCTV inspection interval for all segments. Once a CCTV inspection has been completed for the entire system, staff will evaluate the findings to determine the optimal cleaning and inspection frequency.

Prioritize condition assessment areas:

The City does not currently prioritize condition assessments based on environmental consequences or proximity to surface waters, but intends to do so in the future.

Assess system using visual observations, etc.:

The City mainly assesses its system conditions using visual observation. Video surveillance is used after a line repair or a spill.

Evidence of flow exiting from system:

The City is currently not aware of any sewage that exits the collection system. The City actively inspects and maintains its collection system to prevent sewage from exiting and impacting the environment.

Maintain documents:

The City maintains most inspections, maintenance, and system evaluations in Excel databases, with some data captured in CMMS and GIS programs. These records are currently stored at the City offices or within the CMMS program.

Climate change:

The City has not yet evaluated whether any of its assets are vulnerable to climate change, but will do so.

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

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 53 of 65 • Are maintenance and inspection activities being properly documented?

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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8.2. Capacity Assessment and Design Criteria

WDR REQUIREMENTS
Attachment D-8.2 (pgs. D-8/D-9)
“The Plan must include procedures to identify system components that are experiencing or contributing to spills caused by hydraulic deficiency and/or limited capacity, including procedures to identify the appropriate hydraulic capacity of key system elements for:
• Dry-weather peak flow conditions that cause or contributes to spill events; • The appropriate design storm(s) or wet weather events that causes or contributes to spill events. • The capacity of key system components; and
• Identify the major sources that contribute to the peak flows associated with sewer spills. • The capacity assessment must consider:
• Data from existing system condition assessments, system inspections, system audits, spill history, and other available information;
• Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions;
• Capacity of systems subject to increased infiltration and inflow due to larger and/or higherintensity storm events as a result of climate change; • Increases of erosive forces in canyons and streams near underground and above-ground system components due to larger and/or higher-intensity storm events; • Capacity of major system elements to accommodate dry weather peak flow conditions, and updated design storm and wet weather events; and
• Necessary redundancy in pumping and storage capacities.”

COMPLIANCE
The City completed a Sanitary Sewer Master Plan in 2023. The Master Plan evaluates the City’s sewer collection system and recommends capacity improvements necessary to service the needs of existing users and for servicing the future growth of the City. The Master Plan is intended to serve as a tool for planning and phasing the construction of future sewer collection system infrastructure for the projected buildout of the City’s service area. The area and horizon for this master plan is based on the City’s General Plan. The Master Plan includes the following tasks: (a) summarizing the City’s existing sewer collection system facilities, (b) documenting growth planning assumptions and known future developments, (c) summarizing the sewer system performance criteria and design storm event, (d) projecting future sewer flows, (e) updating and validating the City’s hydraulic model based on the City’s Geographic Information Systems (GIS), (f) evaluating the adequacy of capacity for the sewer collection system facilities to meet existing and projected peak dry weather flows and peak wet weather flows, (g) recommending a capital improvement program (CIP) with an opinion of probable construction costs, and (h) performing a capacity allocation analysis for cost sharing purposes.

In general, the Master Plan’s hydraulic model indicated that the sewer collection system exhibited acceptable performance to service the existing customers during peak dry weather flows, with three exceptions (two segments on Welburn Ave and one segment on Loof Ave). The wet weather flow analysis for existing customers indicated that the sewer collection system exhibited acceptable performance to service the existing customers during peak wet weather flows with six exceptions (Loof Ave, Welburn Ave, Forest St, Old

SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 55 of 65 Gilroy St, Third St, and Santa Theresa Dr). Future flows were then added to the hydraulic model, and the existing system was expanded to serve these future customers. The Master Plan lists the additional improvements needed for growth.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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8.3. Prioritization of Corrective Action

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

COMPLIANCE
The 2023 Master Plan identifies areas that may need capacity increases. However, it did not prioritize these based on the consequences of potential spills. Moving forward, the City intends to prioritize its CIP projects based, in part, on the potential for spills and will document how projects were selected for funding.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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8.4. Capital Improvement Plan

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

COMPLIANCE
The 2023 Sanitary Sewer Master Plan includes a recommended Capital Improvement Program (CIP), designed to address current issues and to provide adequate sewer capacity for future flows. The City’s Capital Improvement Program for FY 2024 through FY 2028 includes recommended projects for both the collection system and the Joint Truck line. Most of the funded projects were identified in the Master Plan.

The City re-evaluates its CIP project list biennially. The City adopted budget for FY 26 and FY 27 includes the allocated amounts for the Wastewater CIP Projects. Further details about the projects are provided below:

Master Plan Projects (CIP# 800970) includes 15 individual projects within six system areas that are recommended. The purpose of these projects is to mitigate existing deficiencies in the City’s sewer system and implement improvements to service anticipated future growth throughout the City. The projects include pipeline replacements as well as new pipeline improvements. The projects in each sub-trunk system area are:
• Santa Teresa - Long Meadow Sub-trunk – 1 Replacement
• Welburn Sub-trunk – 2 Replacements
• Forest-Swanston Sub-trunk – 2 Replacements
• Old Gilroy Sub-trunk – 2 Replacements
• Uvas Park Sub-trunk – 5 Replacements and 1 New
• Thomas Sub-trunk – 2 Replacements
Annual Citywide Sewer Repair and Rehabilitation Program (CIP#800490). For FY 26 and FY 27, the total amount allocated to this CIP project is $535,000. This annual project will include sewer main repairs that are beyond the capability of City maintenance crews who perform spot repairs. The project would include various locationsidentified through regular video inspection activities, maintenance, and operational activities. Work may also include engineering design, construction, construction management, and inspection. The work will include various diameters of pipe in locations throughout the City. In addition, areas with frequent customer concerns or service requests may be included in this program.

Carmel-Dowdy Alley-Sixth to Seventh Sewer Replacement (CIP#800520). Funded at $85,000 for FY 27. This project will replace and upgrade approximately 600 linear feet of existing 8” sewer pipe to a 10” sewer pipe in the alley between Carmel Street and Dowdy Street from Sixth Street to Seventh Street.

Large Diameter Sewer Rehab Citywide (CIP#800530). Funded at $1,410,000 for FY26 and FY27., this project would repair sewer mains 10” and larger throughout the City that were inspected and assessed in 2009. The

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Construction will be completed in subsequent years.

Monterey and Princevalle Sewer Network. (CIP#800540) Funded at $935,000 for FY 27. This project will replace and upgrade approximately 4,500 linear feet of existing sewer lines between the intersections of Princevalle Street/Catherine Court and Monterey Road/Luchessa Avenue. This replacement will consist of upsizing the current 18” sewer pipes to 21”.

Old Gilroy – Chestnut to Forest Sewer Upgrade (CIP#800550). Funded at $325,000 for FY26 and FY27. This project will redesign and modify a sewer manhole that has two sewer lines running through it, including the higher as a PVC pipe with the crown removed, and the lower being an older line that may now be abandoned.

Investigation into the actual extent of the deeper, apparently abandoned line will allow for proper design of how best to remove this potential overflow location from being a concern.

Seventh St -Carmel Dowdy to Hanna Sewer Replacement (CIP#800560). Funded at $64,000 for FY27. This project will replace and upgrade approximately 739 linear feet of existing 8” sewer pipe to a 10” sewer pipe on Seventh Street from the alley between Carmel Street and Dowdy Street to the alley between Hanna Street and Rosanna Street. This project is part of three segments to be replaced in this subtrunk.

Joint Morgan Hill-Gilroy Trunk Line Repairs. Funded at $3,357,000 for FY 26 and FY 27. The Joint Trunk Sewer Improvements Project includes 8 projects in the Joint Trunk Pipeline between the Cities of Gilroy and Morgan Hill. The purpose of these projects is to mitigate existing deficiencies in the City’s sewer system joint trunk pipeline. The projects include emergency to intermediate pipeline and manhole repairs.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS
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9. Monitoring, Measurement, and Program Modifications

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

COMPLIANCE
The above requirements are addressed below:

Maintaining Information:

The City maintains accurate and relevant inspection and maintenance records for the collection system, including field data such as pipe cleaning and inspection frequencies, FSE inspections, and information regarding spills. Much of the documentation is maintained electronically, which allows for ease of access and analysis. This helps City staff to make sound decisions and prioritize activities when dealing with the routine and the unexpected.

Monitoring SSMP elements:

Monitoring of the City’s SSMP focuses on each element in terms of its implementation and effectiveness.

The SSMP has been designed to include key performance indicators for each element, which are used to measure effectiveness. In addition, implementation responsibilities are included for each element to help ensure the SSMP is being implemented as intended.

Assessing Preventative Operations:

The City assesses the success of maintenance and operation activities by ensuing activities are being performed as expected, by monitoring results compared to intended outcomes, as well as monitoring spill trends.

Updating the SSMP:

The City is committed to continuous improvement and monitors and evaluates performance of work programs and SSMP elements to ensure intended outcomes are achieved while looking for areas of improvement. Although the SWRCB requires that the SSMP be updated every six years, the SSMP is considered a dynamic document that may require updating on a more frequent basis. Routine changes to administrative information, notwithstanding, minor changes will likely be required to address improvements identified through the SSMP Audit or as conditions change.

MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 60 of 65 Identifying Spill Trends:

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

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 9 INCLUSIONS:
• None

INTERNAL AUDITS
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10. Internal Audits

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

COMPLIANCE
The City has not yet completed the Audit for the period of August 2021 through August 2024 but has contracted with Fischer Compliance LLC to prepare it. It is anticipated that the audit will be completed by December 2025, at which time it will be uploaded to CIWQS and placed on the City’s website.

In the future, the City will complete audits every three years following the WDR schedule. The objective of the audit is to evaluate compliance, implementation and effectiveness of the SSMP. Additionally, the SSMP includes a description of how the City will comply with the requirements of each Element.

The audit review includes an evaluation to determine if compliance has been met. A list of priority improvement opportunities will be prepared and updated as part of the audit program. Improvement opportunities will be used to prioritize and develop program modifications and will be initiated based on the priority and the available funding. An overview of SSMP related work completed between audits will be included in the program audits.

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

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

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

Any deficiencies discovered through the audit process are noted and a plan and schedule to implement corrective measures are established. All audit reports will be certified by the City’s LRO. All changes or modifications of the SSMP resulting from the Audit shall be listed in the SSMP Change Log.

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

IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 10 INCLUSIONS:
• None

COMMUNICATION PROGRAM
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11. Communication Program

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

COMPLIANCE
Spills:

When a spill is identified, standard procedure is to secure the affected area. This is generally done using barricades, cones, and caution 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 indicating the issue and providing contact information. Staff will remain on site to provide an additional safety factor until appropriate authorities respond and direct otherwise. In all cases, the City will follow the advice of higher authorities, such as the local environmental health department and other regulatory authorities.

Public Participation:

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

Satellite Systems:

The City shares the Joint Trunk line to the SCRWA with the City of Morgan Hill. Representatives from both cities are on SCRWA’s Board of Directors, allowing direct and timely communication.

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

COMMUNICATION PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
See “SSMP Action Items Checklist (Implementation Plans and Schedules)” at the beginning of this document.

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

APPENDIX 11 INCLUSIONS
• None

APPENDICES
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Gilroy use only Page 65 of 65 List of Appendices
APPENDIX 1
• 1.1 Gravity Sewer System Specific Details (size, materials, age) • 1.2 1999 Sewer Lateral Maintenance Policy
• 1.3 1992 Joint Exercise of Powers Agreement Creating the South County Regional Wastewater Authority
APPENDIX 2 • None
APPENDIX 3 • None
APPENDIX 4
• 4.1 Example Training Record
• 4.2 Example Contractor Spill Response Form
• 4.3 Example Manhole Inspection Form
APPENDIX 5 • None
APPENDIX 6 • 2023 Spill Emergency Response Plan
APPENDIX 7
• 7.1 Grease Interceptor Requirements
• 7.2 Industrial Waste Pretreatment Inspection Form
• 7.3 Grease Trap Maintenance Log
APPENDIX 8 • None
APPENDIX 9 • None
APPENDIX 10 • None
APPENDIX 11 • None

Appendix 1

Diameter, inches
Number of Line
Segments Pipe Length, linear feet % of Sewer System
Unknown and Less then 3 inches 124 24,404.18 2.70
4" 34 3,573.88 0.39
6" 686 134,583.53 14.86
8" 2,732 479,231.48 52.92
10" 418 84,534.58 9.34
12" 260 58,409.34 6.45
14" 3 327.26 0.04
15" 64 21,443.18 2.37
16" 2 135.56 0.01
18" 183 43,388.82 4.79
24" 55 13,753.76 1.52
27" 46 12,542.07 1.39
30" 9 3,428.74 0.38
33" 52 19,562.94 2.16
42" 15 5,809.50 0.64
48" 5 375.08 0.04
Total 4,688 905,503.89 100
Total, miles 171.50
Gravity Sewer System Size Distribution

Material
Number of Line
Segments Pipe Length, LF % of Sewer System
Unknown 5 Unknown
Requiring Field Check 728 173,255.39 19.13
ACP 5 1,064.90 0.12
DIP 58 10,656.15 1.18
PVC 1,054 145,306.35 16.05
RCP 4 674.62 0.07
VCP 2,834 574,546.48 63.45
Total 4,688 905,503.89 100
Total, miles 171.50
Age in Years Construction Period
Linear Feet of Gravity
Sewers
Miles of Gravity
Sewers % of System
0-15 2010-current 109,036.02 20.65 12.04
16-35 1990-2009 239,960.87 45.45 26.50
36-55 1970-1989 188,678.24 35.73 20.84
56-75 1950-1969 39,403.32 7.46 4.35
76-95 1930-1949 6,040.48 1.14 0.67
96-115 1910-1929 - 0.00 0.00
>115 Before 1910 - 0.00 0.00
Unknown 322,384.96 61.06 35.60
Total Miles 171.50
Gravity Sewer System Materials of Construction
Gravity Sewer System Inventory of Sewer Lines by Pipe Age

Appendix 4

Appendix 4.1: Example Training Record
Topic: __________________________________________ Training Date: ______/______/______ 1 of 2
Trainer: _____________________________ Trainer Position/Company: ________________________ Training Location/Environment: __________________________________________________________ Basis for Training & Materials Used:

1. __________________________________ 2. ___________________________________

3. __________________________________ 4. ___________________________________

5. __________________________________ 6. ___________________________________ Comments: ____________________________________________________________________ ______________________________________________________________________________ (Basis Examples: SOP, Power Point, Manufacturer’s Recommendations, on-the-job-training. Reference Title when applicable) Attachments ☐
Training Description: ____________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ (Describe in detail what training entailed) Training Method: (Check all that apply)
☐ Classroom/Instructor ☐ Breakout Sessions ☐ Tabletop Exercise ☐ Drill ☐ Hands-on ☐ Coaching/Mentoring ☐ Role Playing ☐ Computerized/on-line Training ☐ Other: ____________________________________________________________________ Attachments ☐
Method to Qualify Trainees: (Check all that apply)
☐ Exam/Quiz ☐ Assessment of Ability ☐ Attendance/Participation ☐ Other: ______________________________________________________________________ (Maintain Qualifying Records with Training Records)
Trainer Signature: ___________________________________ Date: ______/______/______ Length of Training (Time) _____________ hours

Appendix 4.1: Example Training Record
Topic: __________________________________________ Training Date: ______/______/______ 2 of 2
Signature Sheet
Trainee Name
(Print)
Signature Qualified Qualified
By
(initials)
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No
☐ Yes ☐ No

This document shall be always maintained on site while work is being performed on City facilities Appendix 4.2: Spill Response Requirements for Contracted Services Contracted services personnel performing work on the City sewer system who cause or otherwise discover a sewage blockage or spill are required, at a minimum, to respond as detailed below.

1. Immediately notify the City of any sewer problem encountered. Call (408) 846-0424 during business hours or (408) 846-0350 after hours.
 Spill
 Surcharging pipe
 Obstruction

2. Make attempts to contain the spill or prevent sewage from reaching surface water or drainage system.
 Absorbent
 Dirt
 Sandbags

3. Cordon off the area to keep the public safe
 Traffic cones
 Barricades
 Caution Tape

4. Provide photo/video documentation
 Take Photo(s) of the spill appearance point
 Take 10 second video of the active spill (from approximately 10 feet away)  Take photo of the affected area

5. Remain onsite until Agency staff arrives and provide:
 The time problem was discovered
 The time the spill was discovered (if different from discovered time) This was discussed/Reviewed with Date: _______/_______/_______ Contractor Representative: ___________________________________, ________________________________ Print Name Signature
Contractor Representative: ___________________________________, ________________________________ Print Name Signature
City Representative: ___________________________________, ________________________________ Print Name Signature

: EXAMPLE MANHOLE INSPECTION FORM
Manhole # _______________ Depth _________ Inspection Date _______/_______/_______ By: _____, ______ (Rim to Invert) Lid Type: Bolt down Standard 26” Standard 36” Other: _________________ Needs Manhole Marker Access: Accessible Restricted Seasonal Access Notes: _______________________________________________ Comments: _______________________________________________________________________________________________ ________________________________________________________ Evidence of: High Water Vermin Frame & Cover OK
Broken/Cracked Offset Wrong Lid Type Improper Grade Bolts Missing Damaged Threads Other Problem:

Comments:

Action Taken:

Grade Rings OK
Broken/Cracked Offset I & I / Rate _____ H2S Damage / Rate _____ Roots / Rate _____ Other Problem:

Comments:

Action Taken:

Cone OK
Broken/Cracked Offset I & I / Rate _____ H2S Damage / Rate _____ Roots / Rate _____ Other Problem:

Comments:

Action Taken:

Barrel OK
Broken/Cracked I & I / Rate _____ H2S Damage / Rate _____ Roots / Rate _____ Other Problem:

Comments:

Action Taken:

Bench OK
Broken/Cracked Debris I & I / Rate _____ H2S Damage / Rate _____ Roots / Rate _____ Other Problem:

Comments:

Action Taken:

Channel OK
Channel Problem Debris I & I / Rate _____ H2S Damage / Rate _____ Roots / Rate _____ Other Problem: Camera Entry Issues:

Comments:

Action Taken:

: EXAMPLE MANHOLE INSPECTION FORM
Indicate Problem, Rating and Location by drawing on Diagram(s) below.

Flow
Out
9 3
6 Cover
Frame
9 3
Grade Rings
Cone
Barrel
Bench
Channel
Barrel

Appendix 6

City of Gilroy
Sewer Spill Emergency
Response Plan
Effective Date:

Revised Date:

Approved by:

Signature:

Date:

Prepared by: David Patzer
DKF Solutions Group, LLC
[email protected]
© 2004-2023 DKF Solutions Group, LLC. All rights reserved.

This Spill Emergency Response Plan (SERP) is licensed to the City of Gilroy for internal use only beginning on the effective date listed above. All right, title and interest in the SERP, including without limitation, any copyright, shall remain with DKF Solutions Group, LLC. The City of Gilroy is granted a non-exclusive right to copy the SERP for use by City of Gilroy personnel only. The SERP as customized for the City of Gilroy is a public document and may be posted on the City’s website or otherwise presented in a non-editable format for public view. The SERP may not, in whole or in part, be shared in an editable format with another entity other than the City of Gilroy including, but not limited to, contractors, vendors, private companies, or other public agencies. In no case can the SERP be shared or posted online in an editable format. This document should not be construed as legal advice to any individual or agency that may use it.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5 Matt Jones
9/29/2025
Deputy Public Works Director

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 2 of 47

TABLE OF CONTENTS

1. Purpose

2. Policy

3. Definitions as used in this Spill Emergency Response Plan

4. State Regulatory Requirements for Element 6, Spill Emergency Response Plan

5. Spill Emergency Response Plan Objectives

6. Spill Detection and Notification

7. Spill Response Procedures

8. Recovery and Cleanup

9. Water Quality

10. Notification, Reporting, Monitoring and Recordkeeping Requirements

11. Post-Spill Assessments of Spill Response Activities

12. Spill Response Training

13. Sewer Backup Into/Onto Private Property Claims Handling Policy

14. Authority

15. Appendices
A. Appendix A: Reporting Requirements by Spill Category B. Appendix B: Door Hanger
C. Appendix C: Sanitary Sewer Spill Response Instructions for Contractors D. Appendix D: Sanitary Sewer Spill/Backup Response Workbook Section 1:
o Workbook Instructions...................................................................A-1 o Contact Information .........................................................................-2 o Key Definitions and Category Determination...................................-3 o Spill Event Checklist..........................................................................-4 Section 2: Regulatory Reporting
o Regulatory Reporting Guide..................................................B-1 o Regulatory Reporting Log .......................................................-2 Section 3: Flowchart ...................................................................................C-1 Section 4: Sanitary Sewer Spill Field Report ...............................................D-1 Section 5: Volume Estimation
o Volume Estimation Computations and Examples................. E-1 o Eyeball Estimation Method.....................................................-2 o Duration and Flow Rate Comparison Method ........................-3 Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 3 of 47 o Area/Volume Method.............................................................-4 o Upstream Connections Method..............................................-5 o Drawing Worksheet ................................................................-6 Section 6: Backup Forms
o Backup Forms Checklist ....................................................... F-1 o First Responder Form..............................................................-2 o Customer Information Letter..................................................-5 o Your Responsibilities as a Private Property Owner.................-6 Section 7: Surface Water Sampling Standard Operating Procedure (SOP) o Table of Contents................................................................G-1 o Specifications & Requirements ............................................-2 o Introduction & Overview ......................................................-3 o Equipment & Safety ..............................................................-4 o Before Sampling ...................................................................-5 o Surface Water Sampling .......................................................-6 o After Sampling ......................................................................-7 o Attachment E1 Summary .....................................................-8 o Quick-Reference Guide ........................................................-9 o Surface Water Sampling Worksheet ...................................-10 o Surface Water Sample Chain of Custody Record ................-11 Section 8: Post Event
o Post-Spill Assessment ...........................................................H-1 o Collection System Failure Analysis..........................................-2 Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 4 of 47

1. PURPOSE
The purpose of the City of Gilroy Spill Emergency Response Plan (SERP) is to support a prompt, orderly and effective response to spills (sanitary), reduce spill volumes, and collect information for prevention of future spills. A “spill” in this document is defined, by State Water Board Order No. WQ 2022-0103-DWQ as a discharge of sewage from any portion of a sanitary sewer system due to a sanitary sewer system overflow, operational failure, and/or infrastructure failure.

The SERP provides guidelines for City personnel to follow in responding to, cleaning up, reporting, and properly documenting spills that may occur within the City’s service area. This SERP satisfies the State Water Board Order No. WQ 2022-0103-DWQ, which require wastewater collection agencies to have a Spill Emergency Response Plan.

Additionally, the SERP outlines procedures for responding to sanitary sewer spill backups into structures as required by the City’s insurer. “Backup” is a term typically used by insurers to describe property damage resulting from exposure and contact to untreated or partially treated sewage.

2. POLICY
The City’s employees are required to report all spills from agency owned sewer mains and publicly owned laterals found and to take the appropriate action to secure the spill area, properly report to the appropriate regulatory agencies, relieve the cause of the spill, and ensure that the affected area is cleaned as soon as possible to minimize health hazards to the public and protect the environment. The City’s goal is to respond to sewer system spills as soon as possible following notification. The City will follow reporting procedures regarding sewer spills as set forth by the Central Coast Regional Water Quality Control Board and the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR).

3. DEFINITIONS AS USED IN THIS SERP
ANNUAL REPORT: An Annual Report (previously termed as Collection System Questionnaire in previous State Water Board Order No. 2006-0003-DWQ) is a mandatory report in which the City provides a calendar-year update of its efforts to prevent spills.

BASIN PLAN: A Basin Plan is a water quality control plan specific to a Regional Water Quality Control Board (Regional Water Board), that serves as regulations to: (1) define and designate beneficial uses of surface and groundwaters, (2) establish water quality objectives for protection of beneficial uses, and (3) provide implementation measures.

BENEFICIAL USES: The term “Beneficial Uses” is a Water Code term, defined as the uses of the waters of the State that may be protected against water quality degradation. Examples of beneficial uses include but are not limited to, municipal, domestic, agricultural, and industrial supply; power generation; recreation; aesthetic enjoyment; navigation; and preservation and enhancement of fish, wildlife, and other aquatic resources or preserves.

CALIFORNIA INTEGRATED WATER QUALITY SYSTEM (CIWQS): CIWQS is the statewide database that provides for mandatory electronic reporting as required in State and Regional Water Board-issued waste discharge requirements.

DATA SUBMITTER: A Data Submitter is an individual designated and authorized by the City’s Legally Responsible Official to enter spill data into the online CIWQS Sanitary Sewer System Database. A Data Submitter does not have the authority of a Legally Responsible Official to certify reporting entered into the online CIWQS Sanitary Sewer System Database.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 5 of 47 DRAINAGECONVEYANCE SYSTEM: A drainage conveyance system is a publicly- or privately-owned separate storm sewer system, including but not limited to drainage canals, channels, pipelines, pump stations, detention basins, infiltration basins/facilities, or other facilities constructed to transport stormwater and non-stormwater flows.

ENVIRONMENTALLY SENSITIVE AREA: An environmentally sensitive area is a designated agricultural and/or wildlife area identified to need special natural landscape protection due to its wildlife or historical value.

EXFILTRATION: Exfiltration is the underground exiting of sewage from a sanitary sewer system through cracks, offset or separated joints, or failed infrastructure due to corrosion or other factors.

FOG – Fats, Oils, and Grease: Refers to fats, oils, and grease typically associated with food preparation and cooking activities that can cause blockages in the sanitary sewer system.

HYDROLOGICALLY CONNECTED: Two waterbodies are hydrologically connected when one waterbody flows, or hasthe potential to flow, into the other waterbody. For the purpose of the SWRCB Order, groundwater is hydrologically connected to a surface water when the groundwater feeds into the surface water. See image, right. The surface waterbody in this example is termed a gaining stream as it gains flow from surrounding groundwater.

LATERAL (INCLUDING LOWER AND UPPER LATERAL): A lateral is an underground segment of smaller diameter pipe that transports sewage from a customer’s building or property (residential, commercial, or industrial) to the City’s main sewer line in a street or easement. Upper and lower lateral boundary definitions are subject to local jurisdictional codes and ordinances, or private system ownership. A lower lateral is the portion of the lateral located between the sanitary sewer system main, and either the property line, sewer clean out, curb line, established utility easement boundary, or other jurisdictional locations. An upper lateral is the portion of the lateral from the property line, sewer clean out, curb line, established utility easement boundary, or other jurisdictional locations, to the building or property.

LEGALLY RESPONSIBLE OFFICIAL: A Legally Responsible Official is an official representative, designated by the City, with authority to sign and certify submitted information and documents required by State Water Board Order No. WQ 2022- 0103-DWQ (SSSWDR).

MAINLINE SEWER: Refers to City wastewater collection system piping downstream of the sewer laterals that is not a private sewer lateral connection to a building.

MAINTENANCE HOLE OR MANHOLE: Refers to an engineered structure that is intended to provide access to a sanitary sewer for maintenance and inspection
NOTIFICATION OF A SPILL: Refers to the time at which the City becomes aware of a spill event through observation or notification by the public or other source.

NUISANCE: For the purpose of the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), a nuisance, as defined in Water Code section 13050(m), is anything that meets all of the following requirements:
• Is injurious to health, or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property; • Affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal; and Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 6 of 47 • Occurs during, or as a result of, the treatment or disposal of wastes.

PREVENTATIVE MAINTENANCE: Refers to maintenance activities intended to prevent failures of the wastewater collection system facilities (e.g. cleaning, CCTV, inspection).

PRIVATE LATERAL SEWAGE SPILL – Spills that are caused by blockages or other problems within a privately-owned lateral.

PRIVATE SANITARY SEWER SYSTEM: A private sanitary sewer system is a sanitary sewer system of any size that is owned and/or operated by a private individual, company, corporation, or organization. A private sanitary sewer system may or may not connect into a publicly owned sanitary sewer system.

PRIVATE SEWER LATERAL: A private sewer lateral is the privately-owned lateral that transports sewage from private property(ies) into a sanitary sewer system.

POTENTIAL TO DISCHARGE, POTENTIAL DISCHARGE: Potential to Discharge, or Potential Discharge, means any exiting of sewage from a sanitary sewer system which can reasonably be expected to discharge into a water of the State based on the size of the sewage spill, proximity to a drainage conveyance system, and the nature of the surrounding environment.

RECEIVING WATER: A receiving water is a water of the State that receives a discharge of waste.

SANITARY SEWER SYSTEM: A sanitary sewer system is a system that is designed to convey sewage, including but not limited to, pipes, manholes, pump stations, siphons, wet wells, diversion structures and/or other pertinentinfrastructure, upstream of a wastewater treatment plant headworks, including:
• Laterals owned and/or operated by the City;
• Satellite sewer systems; and/or
• Temporary conveyance and storage facilities, including but not limited to temporary piping, vaults, construction trenches, wet wells, impoundments, tanks, and diversion structures.

For purpose of the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), sanitary sewer systems include only systems owned and/or operated by the City.

SATELLITE SEWER SYSTEM: A satellite sewer system is a portion of a sanitary sewer system owned or operated by a different owner than the owner of the downstream wastewater treatment facility ultimately treating the sewage.

SEWAGE: Sewage, and its associated wastewater, is untreated or partially treated domestic, municipal, commercial and/or industrial waste (including sewage sludge), and any mixture of these wastes with inflow or infiltration of stormwater or groundwater, conveyed in a sanitary sewer system.

SEWER BACKUP A sanitary sewer spill resulting from a sanitary sewer system overflow, operational failure, and/or infrastructure failure in a publicly owned sewer system, with an appearance point and subsequent discharge into a structure.

SPILL: A spill is a discharge of sewage from any portion of a sanitary sewer system due to a sanitary sewer system overflow, operational failure, and/or infrastructure failure. Exfiltration of sewage is not considered to be a spill under the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) if the exfiltrated sewage remains in the subsurface and does not reach a surface water of the State.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 7 of 47 • Category 1 Spill:

A Category 1 spill is a spill of any volume of sewage from or caused by a sanitary sewer system regulated under the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) that results in a discharge to:
o A surface water, including a surface water body that contains no flow or volume of water; or o A drainage conveyance system that discharges to surface waters when the sewage is not fully captured and returned to the sanitary sewer system or disposed of properly.

Any spill volume not recovered from a drainage conveyance system is considered a discharge to surface water, unless the drainage conveyance system discharges to a dedicated stormwater infiltration basin or facility.

A spill from a City-owned and/or operated lateral that discharges to a surface water is a Category 1 spill; the City shall report all Category 1 spills per section 3.1 of Attachment E1 (Notification, Monitoring, Reporting and Recordkeeping Requirements) of State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR).
• Category 2 Spill
A Category 2 spill is a spill of 1,000 gallons or greater, from or caused by a sanitary sewer system regulated under the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) that does not discharge to a surface water.

A spill of 1,000 gallons or greater that spills out of a lateral and is caused by a failure or blockage in the sanitary sewer system, is a Category 2 spill.
• Category 3 Spill
A Category 3 spill is a spill of equal to or greater than 50 gallons and less than 1,000 gallons, from or caused by a sanitary sewer system regulated under the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) that does not discharge to a surface water. A spill of equal to or greater than 50 gallons and less than 1,000 gallons, that spills out of a lateral and is caused by a failure or blockage in the sanitary sewer system is a Category 3 spill. • Category 4 Spill
A Category 4 spill is a spill of less than 50 gallons, from or caused by a sanitary sewer system regulated under the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) that does not discharge to a surface water. A spill of less than 50 gallons that spills out of a lateral and is caused by a failure or blockage in the sanitary sewer system is a Category 4 spill.

TRAINING: Training is in-house or external education and guidance needed that provides the knowledge, skills, and abilities to comply with the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR).

WASH DOWN WATER: Wash down water is water used to clean a spill area.

WASTE: Waste, as defined in Water Code section 13050(d), includes sewage and any and all other waste substances, liquid, solid, gaseous, or radioactive, associated with human habitation, or of human or animal origin, or from any producing, manufacturing, or processing operation, including waste placed within containers of whatever nature prior to, and for purposes of, disposal.

WATERS OF THE STATE: Waters of the State are surface waters or groundwater within boundaries of the state as defined in Water Code section 13050(e), in which the State and Regional Water Boards have authority to protect beneficial uses. Waters of the State include, but are not limited to, groundwater aquifers, surface Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 8 of 47 waters, saline waters, natural washes and pools, wetlands, sloughs, and estuaries, regardless of flow or whether water exists during dry conditions. Waters of the State include waters of the United States.

WATERS OF THE UNITED STATES: Waters of the United States are surface waters or waterbodies that are subject to federal jurisdiction in accordance with the Clean Water Act.

WATER QUALITY OBJECTIVE: A water quality objective is the limit or maximum amount of pollutant, waste constituent or characteristic, or parameter level established in statewide water quality control plans and Regional Water Boards’ Basin Plans, for the reasonable protection of beneficial uses of surface waters and groundwater and the prevention of nuisance.

4. STATE REGULATORY REQUIREMENTS FOR ELEMENT 6, SPILL EMERGENCY RESPONSE PLAN The Sewer System Management Plan (SSMP) must include an up to date Spill Emergency Response Plan (SERP) to ensure prompt detection of and response to spills to reduce spill volumes and collect information for prevention of future spills.

The SERP must include procedures to:
• Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill in a timely manner;
• Notify other potentially affected entities (for example, health agencies, water suppliers, etc.) of spills that potentially affect public health or reach waters of the State; • Comply with the notification, monitoring and reporting requirements of State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), State law and regulations, and applicable Regional Water Board Orders; • Ensure that appropriate staff and contractors implement the SERP and are appropriately trained; • Address emergency system operations, traffic control and other necessary response activities; • Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system; • Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of the State; • Remove sewage from the drainage conveyance system;
• Clean the spill area and drainage conveyance system in a manner that does not inadvertently impact beneficial uses in the receiving waters; • Implement technologies, practices, equipment, and interagency coordination to expedite spill containment and recovery;
• Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event; • Conduct post-spill assessments of spill response activities; • Document and report spill events as required in State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR); and • Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update it as needed.

The Sewer System Management Plan is available to the public at https://www.cityofgilroy.org/347/Streets-Trees-Sewers.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 9 of 47

5. SPILL EMERGENCY RESPONSE PLAN OBJECTIVES
The Spill Emergency Response Plan includes measures to protect public health and the environment. The City willrespond to spills from its system(s) in a timely manner that minimizes water quality impacts and nuisance by:
• Immediately stopping the spill and preventing/minimizing a discharge to waters of the State; • Intercepting sewage flows to prevent/minimize spill volume discharged into waters of the State; • Thoroughly recovering, cleaning up and disposing of sewage and wash down water; and • Cleaning publicly accessible areas while preventing discharges to waters of the State.

Additionally, City Staff will:
• Work safely;
• Properly document each spill event in a separate file including photos and/or video where applicable; • Collect information for prevention of future spills;
• Minimize public contact with the spilled wastewater;
• Mitigate the impact of the spill;
• Meet the regulatory reporting requirements;
• Evaluate the causes of failure related to spills;
• Perform post-spill response evaluation for adherence to procedures and effectiveness of response; and • Revise response procedures, modify maintenance practices or provide additional training based on the results from the debrief and failure analysis of spills, if needed.

6. SPILL DETECTION AND NOTIFICATION
ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), ATTACHMENT D, Element 6, Page D-6 The processes that are employed to notify the City of the occurrence of a spill include: observation by the public, receipt of an alarm, or observation by City staff during the normal course of their work.

6.1 LIFT STATION ALARMS
The City operates 1 wastewater lift station. In the event of a station failure the SCADA alarm system is activated and the City is contacted. To prevent spills, wastewater from the wet well can either be pumped into a vacuum truck for disposal to a nearby sanitary sewer manhole or bypassed around the station into the sanitary sewer system.

6.2 PUBLIC OBSERVATION
Public observation is the most common way that the City is notified of blockages and spills. Contact numbers and information for reporting sewer spills and backups are on the City’s website: https://www.cityofgilroy.org/347/Streets-Trees-Sewers. The City’s telephone number for reporting sewer problems during business hours is (408) 846-0223. The City’s telephone number for reporting sewer problems after business hours is (408) 846-0350.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 10 of 47 • Normal Work Hours: Business hours calls are received by Public Works Admin Staff and they will record the caller’s name, address of the problem and contact info in Cityworks to begin a Service Request. They will call the Operations Services Supervisor and they will dispatch an available Sewer crew. They will perform an investigation and note findings and actions taken, if any, either on paper or the tablet in Cityworks. The information is transferred into Cityworks (if not entered in the filed on the tablet) and the Sr. Maintenance Works or Supervisor will close out the Service Request in CItyworks. If the service request involved a spill, the Spill Response Workbook will also be completed. • After Hours: After hours calls are received by City non-emergency dispatch and they will call the Standby Employee. They will perform an investigation and note findings and actions taken, if any, either on paper or the tablet in Cityworks. The information is transferred into Cityworks (if not entered in the filed on the tablet) and the Sr. Maintenance Worker or Supervisor will close out the Service Request the next business day in CItyworks. If the service request involved a spill, the Spill Response Workbook will also be completed.

When calls are received, either during normal work hours or after hours, the individual receiving the call will collect and include in the spill event file, at a minimum, the following information to record the complaint:
• Date, time, and method of notification,
• Date and time the complainant first noticed the spill, if available, • Narrative description of the complaint, including any information the caller provided regarding whether the spill has reached surface waters or a drainage conveyance system, if available, • Complainant’s contact information, if available, and
• Final resolution of the complaint.

If the spill or backup is not in the City’s service area the individual receiving the call provides the customer with the contact information for the responsible agency, and then notifies that agency.

6.3 CITY STAFF OBSERVATION
City staff conducts periodic inspections of its sewer system facilities as part of their routine activities. Any problems noted with the sewer system facilities are reported to appropriate City staff that, in turn, responds to emergency situations. Work orders are issued to correct non-emergency conditions.

6.4 CONTRACTOR OBSERVATION
Contractors working on the City sewer system will be informed of contractor spill response procedures. Contractors working on behalf of property owners will be provided spill response information by Engineering Counter when they pull a permit. The following procedures are to be followed in the event that a contractor/plumber causes or witnesses a sanitary sewer spill. If the contractor/plumber causes or witnesses a spill they should:

1. Immediately notify the City at (408) 846-0223 and provide the following information if available:
a. Date, time contractor first noticed the spill
b. Description of the contractor’s observation, including any information regarding whether the spill has reached surface waters or a drainage conveyance system c. Contractor’s contact information

2. Protect storm drains.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 11 of 47

3. Protect the public.

4. Direct ALL media and public relations requests to the Communication and Engagement Manager.

6.5 NO OBSERVATION
If there are no witnesses or no call was received for a spill, the City staff will contact nearby residences or business owners in the vicinity of the spill, in an attempt to obtain information that brackets a given start time that the spill began. This information will be collected and documented on the Sanitary Sewer Spill Report in the Sanitary Sewer Spill/Backup Response Workbook.

7. SPILL RESPONSE PROCEDURES (Ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), ATTACHMENT D Element 6 page D-6)

7.1 SEWER SPILL/BACKUP RESPONSE SUMMARY
The City will respond to spills as soon as feasible following notification of a spill/backup.

If it is not possible that the spill/backup is due to a failure in the City-owned/maintained sewer lines the Sewer Crew performs the following:
• Follows the instructions in the Sanitary Sewer Spill/Backup Response Workbook. • If the customer is not home the Sewer Crew completes the Door Hanger and leaves it on the customer’s door.
• If the customer is home the Sewer Crew:
o Explains that the blockage is in the customer’s lateral and the City does not have legal authority to maintain or perform work on privately owned laterals. o Recommends to the customer that they hire a licensed contractor to clear their line. o Gives the customer the Your Responsibilities as a Private Property Owner pages from the Sanitary Sewer Spill/Backup Response Workbook.

If it is possible that the spill/backup is due to a failure in the City-owned/maintained sewer lines the Sewer Crew:
• Follows the instructions in the Sanitary Sewer Spill/Backup Response Workbook. • Notifies Streets, Sewer, and Forestry Supervisor of the incident. • Relieves blockage and cleans impacted areas.
• Forwards the completed Sanitary Sewer Spill/Backup Response Workbook to the Streets, Sewer, and Forestry Supervisor.

The Streets, Sewer, and Forestry Supervisor, Deputy Director of Public Works and Utilities, and/or the Senior Maintenance Workers performs required regulatory reporting in accordance with the Sanitary Sewer Spill/Backup Response Workbook’s Regulatory Reporting section.

If the overflow has impacted private property, the Sewer Crew:
• Follows the instructions in the Sanitary Sewer Spill/Backup Response Workbook.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 12 of 47 • Provides the customer with forms and information as indicated in the Sanitary Sewer Spill/Backup Response Workbook. • Forwards the completed Sanitary Sewer Spill/Backup Response Workbook to the Streets, Sewer, and Forestry Supervisor.

The Streets, Sewer, and Forestry Supervisor notifies the Human Resources Director/Risk Manager of incident.

The Human Resources Director/Risk Manager or designee:
• Reviews incident reports, claim form and other incident information. • Communicates with claimant as appropriate.
• Properly documents in writing all activities and communications before approving the final event file.

7.2 FIRST RESPONDER PRIORITIES
The first responder’s priorities are:
• Prompt response to spills.
• To follow safe work practices.
• To respond promptly with the appropriate and necessary equipment. • To reduce spill volume and contain the spill wherever feasible. • To restore the flow as soon as practicable.
• To minimize public access to and/or contact with the spilled sewage. • To promptly notify the Streets, Sewer, and Forestry Supervisor in event of a spill needing additional resources, and/or impacting environmentally sensitive areas. • To return the spilled sewage to the sewer system.
• To restore the area to its original condition (or as close as possible). Collect information for the prevention of future spills. • Properly document the spill and response activities on the forms provided in the Sanitary Sewer Spill/Backup Response Workbook, including photos and/or video where practicable.

7.3 SAFETY
The first responder is responsible for following safety procedures at all times. Special safety precautions must be observed when performing sewer work. There may be times when City personnel responding to a sewer system event are not familiar with potential safety hazards peculiar to sewer work. In such cases it is appropriate to take the time to discuss safety issues, consider the order of work, and check safety equipment before beginning response activities.

If the first responders encounter access restrictions or unsafe conditions that prevent its compliance with spill response requirements or monitoring requirements in State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), the City provides written documentation of access restrictions and/or safety hazards in the corresponding required report.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 13 of 47

7.4 INITIAL RESPONSE
The first responder must respond to the site of the spill/backup and visually check for potential sewer stoppages.

The first responder will:
• Note arrival time at the site of the spill/backup.
• Verify the existence of a public sewer system spill or backup. • Identify and assess the affected area and extent of spill. • Assess the spill location(s) and spread using photography, global positioning system (GPS), and other best available tools.
• Contact caller if time permits.
• Document the spill according to the requirements described in Section 10 of this SERP, including taking photos and/or videos of overflowing manhole(s)/cleanout(s). • Take steps to contain, recover, and return the spill to the sanitary sewer as feasible. For procedures refer to the Sanitary Sewer Spill/Backup Response Workbook.
• Protect surface waters to the extent practicable. For procedures refer to the Sanitary Sewer Spill/Backup Response Workbook.
• Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event.

7.5 INITIATE SPILL CONTAINMENT MEASURES
The first responder will attempt to contain as much of the spilled sewage as possible using the following steps:
• Determine the immediate destination of the overflowing sewage. • Plug storm drains using air plugs, sandbags, and/or plastic mats to contain the spill, whenever appropriate.

If spilled sewage has made contact with the storm drainage system, attempt to contain the spilled sewage by plugging downstream storm drainage facilities.
• Contain/direct the spilled sewage using dike/dam or sandbags. • Vacuum retrieve sewage whenever practicable.
• Pump around the blockage/pipe failure.

Containment efforts will be documented. For procedures refer to the Sanitary Sewer Spill/Backup Response Workbook.

7.6 RESTORE FLOW
Using the appropriate cleaning equipment, set up downstream of the blockage and hydro-clean upstream from a clear manhole. Attempt to remove the blockage from the system and observe the flows to ensure that the blockage does not reoccur downstream. If the blockage cannot be cleared within a reasonable time from arrival, or sewer requires construction repairs to restore flow, then initiate containment and/or bypass pumping. If other Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 14 of 47 assistance is required, immediately contact the Streets, Sewer, and Forestry Supervisor. For procedures refer to the Sanitary Sewer Spill/Backup Response Workbook.

7.7 EQUIPMENT
This section provides a list of specialized equipment that may be used to support this Spill Emergency Response Plan.
• Closed Circuit Television (CCTV) Inspection Unit – A CCTV Inspection Unit is required to determine the root cause for all spills from gravity sewers.
• Camera -- A digital or disposable camera (photo, video or phone) is required to record the conditions upon arrival, during clean up, and upon departure.
• Emergency Response Trucks -- A utility body pickup truck, or open bed is required to store and transport the equipment needed to effectively respond to sewer emergencies. The equipment and tools will include containment and clean up materials.
• Portable Generators, Portable Pumps, Piping, and Hoses – Equipment used to bypass pump, divert, or power equipment to mitigate a spill.
• Combination Sewer Cleaning Trucks -- Combination high velocity sewer cleaning trucks with vacuum tanks are required to clear blockages in gravity sewers, vacuum spilled sewage, and wash down the impacted area following the spill event.
• Air plugs, sandbags and plastic mats
• Spill Sampling Kits
• Portable Lights
Standard operating procedures for equipment that may be necessary in the event of a sanitary sewer overflow or backup can be found in the Corp Yard.

8. RECOVERY AND CLEANUP (Ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6, ATTACHMENT D, Page D-6) The recovery and cleanup phase begins immediately after the flow has been restored and the spilled sewage has been contained to the extent possible. The spill recovery and cleanup procedures are described in the following sections.

8.1 ESTIMATE THE FLOW AND VOLUME OF SPILLED SEWAGE
A variety of approaches exist for estimating the volume of a sanitary sewer spill. The Sewer Crew members should use the method most appropriate to the sewer overflow in question and reference the Sanitary Sewer Spill/Backup Response Workbook which provides four (4) methods:
• Eyeball Estimation Method
• Duration and Flow Rate Calculation Method
Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 15 of 47 • Area/Volume Method
• Upstream Connections Method
In addition, the following will be documented on the Sewer Spill Report form:

1. Description, photographs, and GPS coordinates of the system location where the spill originated. If a single spill event results in multiple appearance points, provide GPS coordinates for the appearance point closest to the failure point and describe each additional appearance point in the spill appearance point explanation field;

2. Estimated total spill volume exiting the system;

3. Description and photographs of the extent of the spill and spill boundaries;

4. Did the spill reach a drainage conveyance system? If yes:
• Description of the drainage conveyance system transporting the spill; • Photographs of the drainage conveyance system entry location(s); • Estimated spill volume that reached the drainage conveyance system; • Estimated spill volume fully recovered from the drainage conveyance system; • Estimated spill volume remaining within the drainage conveyance system • Estimated spill volume discharged to a groundwater infiltration basin or facility, if applicable; • Estimated spill travel time from the point of entry into the drainage conveyance system to the point of discharge into the receiving water.

5. Estimated total spill volume recovered.

8.2 RECOVERY OF SPILLED SEWAGE
Vacuum up and/or pump the spilled sewage and wash down water and discharge it back into the sanitary sewer system. Thoroughly recover and dispose of sewage and wash down water.

8.3 CLEAN-UP AND DISINFECTION
Clean up procedures will be implemented to reduce the potential for human health issues and adverse environmental impacts associated with a spill event. The procedures described are for dry weather conditions and will be modified as required for wet weather conditions. Where cleanup is beyond the capabilities of City staff, a cleanup contractor will be used.

Private Property
City crews are responsible for the cleanup when the property damage is minor in nature and is outside of private building dwellings, such as in front, side and backyards, easements, etc. In all other cases, affected property owners can call a water damage restoration contractor to complete the cleanup and restoration. If the overflow into property is the definite cause of City system failure, the property owner can call out a water damage restoration contractor to complete the cleanup and restoration. In both cases, property owners may submit a claim form.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 16 of 47 Hard Surface Areas
Collect all signs of sewage solids and sewage-related material either by protected hand or with the use of rakes and brooms. Wash down the affected area with clean water and/or deozyme or similar nontoxic biodegradable surface disinfectant until the water runs clear. The flushing volume will be approximately three times the estimated volume of the spill. Take steps to contain and vacuum up the wastewater. Allow area to dry. Repeat the process if additional cleaning is required.

Landscaped and Unimproved Natural Vegetation
Collect all signs of sewage solids and sewage-related material either by protected hand or with the use of rakes and brooms. Wash down the affected area with clean water until the water runs clear. The flushing volume will be approximately three times the estimated volume of the spill. Either contain or vacuum up the wash water so that none is released. Allow the area to dry. Repeat the process if additional cleaning is required.

Natural Waterways
The Department of Fish and Wildlife will be notified by CalOES for spills greater than or equal to 1,000 gallons. For spills less than 1,000 gallons, contact Santa Clara Environmental Health for direction.

Wet Weather Modifications
Collect all signs of sewage solids and sewage-related material either by protected hand or with the use of rakes and brooms. Omit flushing and sampling during heavy storm events (i.e., sheet of rainwater across paved surfaces) with heavy runoff where flushing is not required and sampling would not provide meaningful results.

8.4 PUBLIC NOTIFICATION
Signs will be posted and barricades put in place to keep vehicles and pedestrians away from contact with spilled sewage. Santa Clara Environmental Health instructions and directions regarding placement and language of public warnings will be followed. Additionally, the Streets, Sewer, and Forestry Supervisor will use their best judgment regarding supplemental sign placement in order to protect the public and local environment. Signs will not be removed until directed by Santa Clara Environmental Health or the Streets, Sewer, and Forestry Supervisor.

Creeks, streams and beaches that have been contaminated as a result of a spill will be posted at visible access locations until the risk of contamination has subsided to acceptable background bacteria levels. Document the number and location of posted signs. The area and warning signs, once posted, will be checked every day to ensure that they are still in place. Photographs of sign placement will be taken.

In the event that an overflow occurs at night, the location will be inspected first thing the following day. The field crew will look for any signs of sewage solids and sewage-related material that may warrant additional cleanup activities.

When contact with the local media is deemed necessary, the Communication and Engagement Manager or their designee will provide the media with all relevant information.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 17 of 47

9. WATER QUALITY (Ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6, Attachment A - DEFINITIONs page A-5, Attachment E1 2.3 through 2.4 pages E1-5 through E1-8)

9.1 SURFACE WATERS OF CONCERN
The following waters of the State are in the City’s service area:
• Miller Slough
• Uvas Creek

9.2 WATER QUALITY SAMPLING AND TESTING
For sewage spills in which an estimated 50,000 gallons or greater are discharged into a surface water, the City will conduct the following water quality sampling as soon as possible but no later than 18 hours after the City’s knowledge of a potential discharge to a surface water. Collect one water sample, each day of the duration of the spill, at:
• The DCS-001 location as described in section 9.5 (Receiving Water Sampling Locations) below, if sewage discharges to a surface water via a drainage conveyance system; and/or • Each of the three receiving water sampling locations in section 9.5 (Receiving Water Sampling Locations) below;
If the receiving water has no flow during the duration of the spill, the City must report “No Sampling Due To No Flow” for its receiving water sampling locations.

The Sewer Crew will collect water quality samples in accordance with State Water Board Order No. WQ 2022- 0103-DWQ (SSSWDR).

The Sewer Crew collecting the samples will complete the Chain of Custody prior to transferring ownership of the samples to Monterey Analytics Lab.

The Monterey Analytics Lab shall analyze the collected receiving water samples for the following constituents:
• Ammonia, and
• Indicator Organisms: Fecal coliform and E. coli
Use the table below for the various surface waters in Region 3 to determine whether the impacted surface water exceeded Water Quality Objectives as a result of the spill for the surface waters sampled. If so, continue collecting samples daily until the either the upstream and downstream sample results are similar or if the downstream sample results are below the Water Quality Objective or the County Environmental Health Dept indicates continued sampling is no longer necessary. • Watsonville Slough
o Fecal coliform concentration, based on a minimum of five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100mL, nor shall more than ten percent of total samples collected during any 30-day period exceed 400 MPN per 100mL
• San Lorenzo Estuary and River
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 18 of 47 more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Soquel Lagoon, Soquel Creek, and Noble Gulch
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Aptos Creek, Valencia Creek, and Trout Gulch
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Pajaro River Watershed
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Corralitos and Salsipuedes Creeks
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Lower Salinas River Watershed
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
• Santa Maria River Watershed
o Fecal coliform concentration, based on a minimum of not less than five samples for any 30-day period, shall not exceed a log mean of 200 MPN per 100 mL, nor shall more than 10 percent of samples collected during any 30-day period exceed 400 MPN per 100 mL.
o Based on a statistically sufficient number of samples (generally not less than five samples equally spaced over a 30-day period), the geometric mean of E. coli densities shall not exceed 126 per 100mL, and no sample shall exceed a one-sided confidence limit (C.L.) calculated using the following as guidance: lightly used for contact recreation (90% C.L.) = 409 per 100mL.

Dependent on the receiving water(s), sampling of bacterial indicators shall be sufficient to determine post-spill (after the spill) compliance with the water quality objectives and bacterial standards of the California Ocean Plan or the California Inland Surface Water Enclosed Bays, and Estuaries Plan, including the frequency and/or number of post-spill receiving water samples as may be specified in the applicable plans.

The City shall collect and analyze additional samples as required by the applicable Regional Water Board Executive Officer or designee.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 19 of 47

9.3 LAB SELECTION
Analytical Lab
Samples collected for spill response and background monitoring purposes will be analyzed at Monterey Analytics Lab, which is accredited through the California State Water Resources Control Board Environmental Laboratory Accreditation Program (ELAP). ELAP provides evaluation and accreditation of environmental testing laboratories to ensure the quality of analytical data used for regulatory purposes to meet the requirements of the State's drinking water, wastewater, shellfish, food, and hazardous waste programs. The State agencies that monitor the environment use the analytical data from these accredited labs. The ELAP-accredited laboratories have demonstrated capability to analyze environmental samples using approved methods.

Getting Samples to the Lab
At all times, sample hold times identified below will be observed in accordance with the following:

Analytical
Parameter
Maximum
Holding Time
Required
Container
Type
Required Preservative
Minimum
Amount
Ammonia (NH3 as N);
SM 4500NH3 B/C or B/G
28 days Plastic / Glass H2SO4 pH <2 +0-6°C 200 mL
Coliform, Total / Fecal;
SM 9221 B/E
8 hours –
wastewater/stormwater
30 hours – drinking
water
Plastic (sterile) Na2S2O3 + 0-10°C;
No regulatory temp.
req. for drinking water)
100 mL
Coliform, Total / E.Coli;
SM 9223 B (Present/Absent or Quantitray)
8 hours Plastic (sterile) Na2S2O3 + 0-10°C;
No regulatory temp.
req. for DW
100 mL
Once samples are collected, they will be transported by the Sewer Crew to the lab to be processed.

9.4 WATER QUALITY ANALYSIS SPECIFICATIONS
Spill monitoring must be representative of the monitored activity (40 Code of Federal Regulations section 122.41(j)(1)).

Sufficiently Sensitive Methods
Sample analysis must be conducted according to sufficiently sensitive test methods approved under 40 Code of Federal Regulations Part 136 for the sample analysis of pollutants. For the purposes of State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), a method is sufficiently sensitive when the minimum level of the analytical method approved under 40 Code of Federal Regulations Part 136 is at or below the receiving water pollutant criteria.

Environmental Laboratory Accreditation Program-Accredited Laboratories The analysis of water quality samples required per State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) must be performed by a laboratory that has accreditation pursuant to Article 3(commencing with section 100825) of Chapter 4 of Part 1 of Division 101 of the Health and Safety Code. (Water Code section 13176(a).) The State Water Board accredits laboratories through its Environmental Laboratory Accreditation Program (ELAP).

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City of Gilroy
Spill Emergency Response Plan 7-28-23
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9.5 RECEIVING WATER SAMPLING LOCATIONS
Receiving water samples shall be collected at the following locations.

Sampling of Flow in Drainage Conveyance System (DCS) Prior to Discharge Sampling Location Sampling Location Description
DCS-001 A point in a drainage conveyance system before the drainage conveyance system flow discharges into a receiving water.

Receiving Surface Water Sampling (RSW)1
Sampling Location Sampling Location Description
RSW-001:

Point of Discharge
A point in the receiving water where sewage initially enters the receiving water.

RSW-001U:

Upstreamof Point of
Discharge
A point in the receiving water, upstream of the point of sewage discharge, to capture ambient conditions absent of sewage discharge impacts.

RSW-001D:

Downstream of
Point ofDischarge
A point in the receiving water, downstream of the point of sewage discharge, where the spill material is fully mixed with the receiving water.

9.6 STREAM VELOCITY MEASUREMENTS
If sampling is performed after the spill has stopped, the velocity of the impacted surface water must be determined to estimate spill travel time and select an accurate Downstream sample location. One way to measure the spill travel time is to use a velocity probe (such as a Global Water FP111-S Flow Probe) to determine the rate of flow in the water body. In cases where a water velocity probe is used, the manufacturer’s instructions will be followed.

9.7 SAMPLE TYPES
Grab Samples
Grab samples are appropriate for the characterization of surface waters at a particular time and place, to provide information about minimum and maximum concentrations, and to allow for the collection of variable sample volume.

Grab samples may be collected directly into the sample container, or a clean decontaminated intermediate container may be used if a wading sample is not possible or safe. If an intermediate container is used, when in the field, double rinse the sampling device (bucket, automatic sampler) with sample water prior to collecting the sample and be sure to discard rinse water downstream of where sample will be collected. If samples are collected in a bucket and distributed into a consolidation collection container, swirl the contents of the bucket as it is being 1 The City must use its best professional judgment to determine the upstream and downstream distances based on receiving water flow, accessibility to upstream/downstream waterbody banks, and size of visible sewage plume.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 21 of 47 poured into the consolidation collection container to avoid settling of solids (and pour in back-and-forth pattern – e.g., 1-2-3-3-2-1).
• Grab Sample: A grab sample is defined as an individual sample collected at a given time. Grab samples represent only the condition that exists at the time the sample is collected (US EPA 1977). • Surface Grab Sample: A sample collected at the water surface (i.e., skimming) directly into the sample container or into an intermediate container such as a clean bucket. A single or discrete sample collected at a single location.

Field Blanks
Field Blanks are used to evaluate the potential for contamination of a sample by site contaminants from a source not associated with the sample collected (e.g., airborne dust, etc.). Sterile, deionized water is taken into the field in a sealed container. This is the stock water. The stock water is then poured into the sample container. The containers and sample submission forms are labeled as “Field Blank.” The same template selected for the test samples should be used. Field blanks are subject to the same holding time limitations as samples. The appropriate FIELD QC box on the sample Chain of Custody form should be checked.

9.8 SAMPLE LABELING AND CHAIN OF CUSTODY PROCEDURES
At a minimum, the following grab samples will be collected:
• Field Blank: See Section 9.7 for discussion.
• Upstream: A point in the receiving water, upstream of the point of sewage discharge, to capture ambient conditions absent of sewage discharge impacts. • Source: A point in the receiving water where sewage initially enters the receiving water. See Section 9.6 for information on determining velocity of the surface water in order to determine the Source sample location.
• “Downstream” of spill: A point in the receiving water, downstream of the point of sewage discharge, where the spill material is fully mixed with the receiving water. This location will vary with the velocity of the surface water to be sampled (see Section 9.6). • A point in a drainage conveyance system before the drainage conveyance system flow discharges into a receiving water.

Photos or video of each sample location will be taken, properly labeled with date, time, and view direction and a map of the photo locations completed. Photos and videos shall include relevant landmarks to identify sampling locations and their surroundings.

Due to the evidentiary nature of samples collected during enforcement investigations, possession must be traceable from the time the samples are collected until they are analyzed. To maintain and document sample possession, a Surface Water Sample Chain of Custody Record (see Sewer Spill/Backup Response Workbook) must be completed. A sample is under custody if:
• It is in your possession, or
• It is in your view, after being in your possession, or Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 22 of 47 • It was in your possession and under your control to prevent tampering, or • It is in a designated secure area.

As few people as possible should handle samples. The person taking the samples is personally responsible for the care and custody of the samples collected until they are transferred or dispatched properly.

Samples are accompanied by a chain of custody record. When transferring the possession of samples, the individuals relinquishing and receiving will sign, date, and note the time on the record. This record documents sample custody transfer from the sampler, often through another person, to the analyst at the laboratory. The samples are typically transferred to the sample-receiving custodian at the laboratory.

9.9 SAMPLING EQUIPMENT
The following are examples of sampling equipment used by the City:
• Sampling pole with fixed container
• Sampling pole with removable container
• Sampling pail and rope
• Stream velocity meter
• Grab-n-Go Sample Kit

9.10 GRAB-N-GO SAMPLING KIT
The City maintains a Grab-n-Go sampling kit located at the Corp Yard Shop. The kit is inspected quarterly by the Streets, Sewer, and Forestry Supervisor. Additionally, any City employee utilizing the kit is responsible for decontaminating sampling equipment and field monitoring devices and replenishing the kit.

Spill Sample Collection Kit Inventory:
• Cooler
• Surface Water Sampling SOP (in Sewer Spill/Backup Response Workbook) • Ice Pack
• 5 Ammonia sample bottles
• 12 Bacti sample bottles
• Minimum of 20 blank sample bottle labels
• Digital camera or smart phone camera
• Latex gloves
• Safety glasses/goggles
• Waterproof Pen
• Surface Water Sampling Worksheet (in Sewer Spill/Backup Response Workbook) • Chain of Custody form (in Sewer Spill/Backup Response Workbook)

9.11 DECONTAMINATION PROCEDURES
Removing or neutralizing contaminants from sampling equipment minimizes the likelihood of sample cross contamination, reduces or eliminates transfer of contaminants to clean areas, and prevents the mixing of Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 23 of 47 incompatible substances.

Gross contamination can be removed by physical decontamination procedures. These abrasive and non-abrasive methods include the use of brushes, air and wet blasting, and high- and low- pressure water cleaning.

The decontamination procedures for the sample types and sampling equipment (other than sample bottles, which are provided to Sewer Crew in a “ready to be used” condition by the lab) used at the City may be summarized as follows:

1. Physical removal

2. Tap water rinse

3. Air dry

9.12 SAMPLING PROCEDURES

9.12.1 Sample Location and Identification Procedures
Samples will be collected by the Sewer Crew. It is impossible to establish hard and fast rules concerning sampling locations. However, the following general guidelinesshould be applied whenever surface waters are sampled:
• The sampling location should be far enough upstream or downstream of confluences or point sources so that the surface water and spill volume is well mixed. Natural turbulence can be used to provide a good mixture.
• Samples should be collected at a location where the velocity is sufficient to prevent deposition of solids, and to the extent practical, should be in straight reach having uniform flow. All flow in the reach should be represented, so divided flow areas should be avoided, and samples should be taken towards the middle of the reach where feasible.
• Sampler must always stand downstream of the collection vessel, and sample “into the current.” Care must be taken to avoid introducing re-suspended sediment into the sample.

9.12.2 Surface Water Sampling Standard Operating Procedure (SOP) The Surface Water Sampling SOP, Section G in the Sewer Spill/Backup Response Workbook, provides step-by-step procedures to collect samples and deliver them for analysis in accordance with State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6.

9.12.3 Follow Up Sampling
Sampling will be repeated every 24 hours, or as directed by the RWQCB or the Santa Clara Environmental Health, until such time as one of the following criteria have been met:
• The Santa Clara Environmental Health or the RWQCB indicates follow up sampling is no longer required, or
• Both the ammonia and bacteria levels downstream are approximately equal to or less than the upstream levels.

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City of Gilroy
Spill Emergency Response Plan 7-28-23
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9.13 SAFETY AND ACCESS EXCEPTIONS
If the City encounters access restrictions or unsafe conditions that prevents its compliance with spill response requirements or monitoring requirements in State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), the City shall provide documentation of access restrictions and/or safety hazards in the corresponding required report.

Personal safety of staff engaged in any fieldwork activity (e.g. in transit, walking or hiking, and any field activities while at the sample site) is of primary importance. Staff should never place themselves in dangerous or risky situations. Any hazards that are known by field personnel should be communicated to other members of the field crew.

Fieldwork should be postponed if there is indication that engagement in the field activity could cause bodily harm.

Working during lightning storms, in heavy vegetation or poison oak, near aggressive wildlife or domestic animals, traversing steep or rugged terrain, unstable slopes or creek banks, near swiftly moving water or potential flash flood conditions, or during snowy weather is not considered "normal risk." If any member of the field crew is uncomfortable with a reasonable self-determined hazardous field condition, it is that person’s responsibility to bring this to the attention of the onsite field supervisor or their supervisor. A “reasonable self-determined hazardous field condition” is defined as other than normal risk. Supervisors shall not dismiss any person’s spoken concerns that field conditions are too hazardous to complete the work assignment.

The person taking the samples must have adequate protection, including protective clothing. They must wear gloves, as protection against chemical and/or bacteriological hazards, while they are sampling or handling samples that are known or suspected to be hazardous (e.g. visible solids or sheens, downstream from sewage spills, etc.), or if hands have open wounds. The type of gloves worn shall be determined by the sampling circumstance and type of pollutants expected – for instance longer gloves are needed when samples must be taken well below the surface.

When in a boat or wading in a stream and where the danger of drowning exists, a personal floatation device shall be worn at all times in addition to following the other requirements of Title 8 CCR 1602 Working Over or Near Water. Other protective measures shall be taken in accordance with City safety procedures.

Upon arrival at a sampling site, safety equipment such as signs, cones, lights, etc. shall be set out as appropriate.

Vehicles shall be parked in locations and directions to minimize traffic disruption and avoid sample contamination.

Photos should be ultimately taken of the placement of all safety equipment and signage.

The following guidelines apply to all fieldwork by City staff. • No sample or measurement is worth the risk of injury. • All staff shall use proper personnel protective gear as appropriate for the incident (e.g., life preservers, gloves, goggles, etc.)
• Field sampling crews should consist of at least two members unless otherwise approved by a supervisor. • Be conscious of the whereabouts of rattlesnakes, mountain lions, and other dangerous animals. • Open body wounds are entry sites for infection; take the necessary precautions for self-protection. • If there is storm activity in the work area, wait for safer conditions to develop or postpone the sampling. • Do not sample at night without approval from your supervisor.

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City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 25 of 47 • Do not trespass on private property or posted restricted public lands without prior permission and written approval from property owner or administrator.
• If strange or suspicious looking people are in the work area, either wait for them to leave or postpone the work to a later time. Do not force confrontations with strangers and back away from any confrontations with the public. Be courteous and understanding of public concerns of the situation. • Take the necessary precautions against exposure to harmful weather conditions such as heat, wind, snow, cold, rain, etc.
• Carefully evaluate a given on-site situation to determine if the task can be performed safely. • Streams will not be entered unless the responding employees have the necessary protective footwear (e.g. rubber boots, waders) and the footwear does not pose an additional risk to worker safety (e.g. waders filling with water if the employee slips in the stream). • Streams will not be entered if deemed unsafe to so by the most senior employee on the responding crew and if entered, will only be done so in accordance with Title 8 CCR Section 1602 Work Over or Near Water.

9.14 SPILL TECHNICAL REPORT: Spill Technical Report for Individual Category 1 Spill in which 50,000 Gallons or Greater Discharged into a Surface Water
For any spill in which 50,000 gallons or greater discharged into a surface water, within 45 calendar days of the spill end date, the Deputy Director of Public Works and Utilities shall submit a Spill Technical Report to the online CIWQS Sanitary Sewer System Database. The Spill Technical Report, at minimum, must include the following information:

1. Spill causes and circumstances, including at minimum:
• Complete and detailed explanation of how and when the spill was discovered; • Photographs illustrating the spill origin, the extent and reach of the spill, drainage conveyance system entrance and exit, receiving water, and post-cleanup site conditions; • Diagram showing the spill failure point, appearance point(s), the spill flow path, and ultimate destinations;
• Detailed description of the methodology employed, and available data used to calculate the discharge volume and, if applicable, the recovered spill volume; • Detailed description of the spill cause(s);
• Description of the pipe material, and estimated age of the pipe material, at the failure location; • Description of the impact of the spill;
• Copy of original field crew records used to document the spill; and • Historical maintenance records for the failure location.

2. City’s response to the spill:
• Chronological narrative description of all actions taken by the City to terminate the spill; • Explanation of how the Sewer System Management Plan Spill Emergency Response Plan was implemented to respond to and mitigate the spill; and
• Final corrective action(s) completed and a schedule for planned corrective actions, including:

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 26 of 47 o Local regulatory enforcement action taken against an illicit discharge in response to this spill, as applicable,
o Identifiable system modifications, and operation and maintenance program modifications needed to prevent repeated spill occurrences, and o Necessary modifications to the Emergency Spill Response Plan to incorporate lessons learned in responding to and mitigating the spill.

3. Water Quality Monitoring, including at minimum:
• Description of all water quality sampling activities conducted; • List of pollutant and parameters monitored, sampled and analyzed; as required in Section 9.2. • Laboratory results, including laboratory reports;
• Detailed location map illustrating all water quality sampling points; and • Other regulatory agencies receiving sample results (if applicable).

5. Evaluation of spill impact(s), including a description of short-term and long-term impact(s) to beneficial uses of the surface water.

9.15 TRAINING
Training will be provided in accordance with the table below:

Surface Water Sampling Training Program
Who Is Trained to Collect Surface Water Samples?Sewer Crew Training Curriculum At a minimum, training shall include:
• The City of Gilroy Water Quality Monitoring Plan
• Sampling technique, including hands on practice
• Sampling equipment calibration, use and decontamination procedures, including hands on practice • Sampling safety
• Completion of the Sampling Equipment Calibration/Maintenance Log, Surface Water Sampling Report and Chain of Custody Training Documentation Attendees shall be required to sign-in to all training on the appropriate forms used by the City.

Refresher Training Frequency Annual
Who is Responsible for Ensuring Training Occurs?Streets, Sewer, and Forestry Supervisor Required Training Records Employee training sign in log Who is Responsible for Maintaining Records?Streets, Sewer, and Forestry Supervisor Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
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10. NOTIFICATION, REPORTING, MONITORING AND RECORDKEEPING REQUIREMENTS ref. ORDER WQ 2022-0103-DWQ Attachment E-1 and E-2

10.1 REPORTING REQUIREMENTS
All reporting required in State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR) must be submitted electronically to the online CIWQS Sanitary Sewer System Database (https://ciwqs.waterboards.ca.gov), unless specified otherwise in State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR). Electronic reporting may solely be conducted by a Legally Responsible Official or Data Submitter(s) previously designated by the Legally Responsible Official, as required in section 5.8 (Designation of Data Submitters) of the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR).

The City shall report any information that is protected by the Homeland Security Act, by email to [email protected], with a brief explanation of the protection provided by the Homeland Security Act for the subject report to be protected from unauthorized disclosure and/or public access, and for official Water Board regulatory purposes only.

Refer to APPENDIX A for detailed reporting requirements by spill category.

10.2 REGULATOR REQUIRED NOTIFICATIONS

10.2.1 Spill Category 1: Spills to Surface Waters
Spill Requirement Due Method
Notification Within two (2) hours of the City’s
knowledge of a Category 1 spill of 1,000 gallons or greater, discharging or threatening to discharge to surface waters notify the
California Office of Emergency Services and
obtain a notification control number.

CaliforniaOffice of Emergency
Services at: (800) 852-7550
(Section 1 of Attachment E1
of the State Water Board Order No. WQ 2022-0103-DWQ
(SSSWDR))
Monitoring • Conduct spill-specific monitoring;
• Conduct water quality sampling of the
receiving water within 18 hours of initial
knowledge of spill of 50,000 gallons or
greater to surface waters.
(Section 2 of Attachment E1
of the State Water Board Order No. WQ 2022-0103-DWQ
(SSSWDR))
Reporting • Submit Draft Spill Report within three
(3) business days ofthe City’s knowledge
of the spill;
• Submit Certified Spill Report within 15
calendar days of the spill end date;
• Submit Technical Report within 45 calendar days after the spill end date for a Category 1 spill in which 50,000 gallons
or greater discharged to surface waters;
and
• Submit Amended Spill Report within 90
calendar days after the spill end date.
(Section 3.1 of Attachment E1
of the State Water Board Order No. WQ 2022-0103-DWQ
(SSSWDR))
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10.2.2 Spill Category 2: Spills of 1,000 Gallons or Greater That Do Not Discharge to Surface Waters Spill Requirements Due Method
Notification Within two (2) hours of the City’s
knowledge of a Category 2 spill of 1,000 gallons or greater threatening to discharge to waters of the State: Notify California Office
of Emergency Services and obtain a notification control number.

CaliforniaOffice of Emergency Services at: (800) 852-
7550
(Section 1 of Attachment E1
of the State Water Board Order No. WQ 2022-0103-

DWQ (SSSWDR))
Monitoring Conductspill-specific monitoring. (Section 2 of Attachment E1 of the State Water Board Order No. WQ 2022-0103-

DWQ (SSSWDR))
Reporting • Submit Draft Spill Report within three
(3) business days of the City’s
knowledge of the spill;
• Submit Certified Spill Report within 15
calendar days of the spill end date; and
• Submit Amended Spill Report within 90
calendar days after the spill end date.
(Section 3.2 of Attachment
E1 of the State Water Board
Order No. WQ 2022-0103-

DWQ (SSSWDR))

10.2.3 Spill Category 3: Spills of Equal or Greater than 50 Gallons and Less than 1,000 Gallons That Does Not Discharge to Surface Waters
Spill Requirements Due Method
Notification Not Applicable Not Applicable
Monitoring Conduct spill-specific monitoring. (Section 2 of Attachment E1 of the State Water Board Order No. WQ 2022-0103-DWQ
(SSSWDR))
Reporting • Submit monthly Certified Spill Report
to the online CIWQS Sanitary Sewer
System Database within 30 calendars
days after the end of the month in
which the spills occur; and
• Submit Amended Spill Reports within 90
calendar days after the Certified Spill
Report due date.
(Section 3.3 and 3.5 of Attachment E1 of the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR))

10.2.4 Spill Category 4: Spills Less Than 50 Gallons That Do Not Discharge to Surface Waters Spill Requirements Due Method
Notification Not Applicable Not Applicable
Monitoring Conductspill-specific monitoring. (Section 2 of Attachment E1 Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 29 of 47 of the State Water Board Order No. WQ 2022-0103-DWQ
(SSSWDR))
Reporting • If, during any calendar month, Category 4 spills occur, certify monthly, the estimated total spill volume exiting the
sanitary sewer system, and the total
number of all Category 4 spills into the
online CIWQS Sanitary Sewer System
Database, within 30 days after the end
of the calendar month in which the
spills occurred.
• Upload and certify a report, in an acceptable digital format, of all Category 4 spills to the online CIWQS Sanitary
Sewer System Database, by February
1st after the end of the calendar year
in which the spills occur.
(Section 3.4, 3.6, 3.7 and 4.4
of Attachment E1 of the State
Water Board Order No. WQ
2022-0103-DWQ (SSSWDR))

10.2.5 City Owned and/or Operated Lateral Spills That Do Not Discharge to Surface Waters Spill Requirements Due Method
Notification Within two (2) hours of the City’s
knowledge of a spill of 1,000 gallons or
greater, from an City- owned and/or operated lateral, discharging or threatening to discharge to waters of the State:

Notify California Office of Emergency Services and obtain a notification control number.

Not applicable to a spill of less than 1,000
gallons.

California Office of Emergency Services at: (800) 852- 7550
(Section 1 of Attachment E1
of the State Water Board Order No. WQ 2022-0103-

DWQ (SSSWDR))
Monitoring Conduct visual monitoring. (Section 2 of Attachment E1 of the State Water Board ORDER WQ 2022-0103-DWQ)
Reporting • Upload and certify a report, in an acceptable digital format, of all lateral spills (that do not discharge to a surface water) to the online CIWQS Sanitary Sewer System Database, by February 1st after the end of the calendar year in which the spills occur.
• Report a lateral spill of any volume
that discharges to a surface water as a
Category 1 spill.
(Sections 3.6, 3.7 and 4.4 of
Attachment E1 of the State
Water Board Order No. WQ
2022-0103-DWQ (SSSWDR))
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Spill Emergency Response Plan 7-28-23
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10.3 COMPLAINT RECORDS
The City maintains records of all complaints received whether or not they result in sanitary sewer overflows.

These complaint records include, but are not limited to, records documenting how the City responded to notifications of spills. Each complaint record must, at a minimum, include the following information:
• Date, time, and method of notification,
• Date and time the complainant first noticed the spill, if available, • Narrative description of the complaint, including any information the caller provided regarding whether the spill has reached surface waters or a drainage conveyance system, if available, • Complainant’s contact information, if available, and
• Final resolution of the complaint;
All complaint records will be maintained in Cityworks for a minimum of five years whether or not they result in a spill. Spill files (field notes, spill/Backup Response Workbook) are kept in the Streets, Sewer, and Forestry Supervisor's office.

11. POST-SPILL ASSESSMENTS OF SPILL RESPONSE ACTIVITIES (ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6, ATTACHMENT D, Page D-6) Every spill event is an opportunity to evaluate the City adherence to response and reporting procedures and effectiveness of the response. Each spill event is unique, with its own elements and challenges including volume, cause, location, terrain, climate, and other parameters.

As soon as possible after spill events all the participants, from the person who received the call to the last person to leave the site, will meet to review the procedures used and to discuss what worked and where improvements could be made in responding to and mitigating future spill events. The results of the debriefing will be documented and tracked to ensure the action items are completed as scheduled.

11.1 FAILURE ANALYSIS INVESTIGATION
The objective of the failure analysis investigation is to determine the “root cause” of the spill and to identify corrective action(s) needed that will reduce or eliminate future potential for the spill to recur or for other spills to occur.

The investigation will include reviewing all relevant data to determine appropriate corrective action(s) for the line segment. The investigation may include:
• Reviewing and completing the Sanitary Sewer Spill Report and any other documents related to the incident • Reviewing the incident timeline and other documentation regarding the incident • Reviewing communications with the reporting party and witness • Reviewing volume estimate, volume recovered estimate, volume estimation assumptions and associated drawings
• Reviewing available photographs
Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 31 of 47 • Interviewing staff that responded to the spill
• Reviewing past maintenance records
• Reviewing past CCTV records,
• Conducting a CCTV inspection to determine the condition of all line segments immediately following the spill and reviewing the video and logs,
• Reviewing any Fats, Oils, Roots and Grease (FROG) related information or results • Post spill debrief records
• Interviews with the public at the spill location
The product of the failure analysis investigation will be the determination of the root cause and the identification and scheduling of the corrective actions. The Collection System Failure Analysis Form (in Sanitary Sewer Spill/Backup Response Workbook) will be used to document the investigation.

12. SPILL RESPONSE TRAINING
(ref. State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6, Attachment D 4.3 page D-5 and Element 6 page D-6
This section provides information on the training that is required to support this Spill Emergency Response Plan.

12.1 INITIAL AND ANNUAL REFRESHER TRAINING
All City personnel who may have a role in responding to, reporting, and/or mitigating a sewer system spill will receive training on the contents of this SERP. All new employees will receive training before they are placed in a position where they may have to respond. Current employees will receive annual refresher training on this SERP and the procedures to be followed. The City will document all training.

Affected employees will receive annual training on the following topics by knowledgeable trainers:
• The requirements of State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6 • The City’s Spill Emergency Response Plan procedures and practice drills • Containment and cleanup methods
• Researching and documenting Sanitary Sewer Spill Start Times • Skilled estimation of spill volume for field operators • Impacted Surface Waters: Sample location selection, sampling, and documentation procedures • Electronic CIWQS reporting procedures for staff submitting data • State Water Resources Control Board Employee Knowledge Expectations Through SWRCB Employee Knowledge Expectations training, the employee will be able to answer the following:

1. Please briefly describe your name and job title.

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2. Please describe for us approximately when you started in this field and how long you have worked for your agency.

3. Please expand on your current position duties and role in responding in the field to any spill complaints.

4. Please describe your SOPs used to respond/mitigate spills when they occur.

5. Describe any training your agency provides or sends you to for conducting spill volume estimates.

6. We are interested in learning more about how your historical spill response activities have worked in the field. We understand from discussions with management earlier that you use the SERP from the SSMP. Please elaborate on how you implement and utilize the procedures in the plan.

7. Historically, before any recent changes, can you please walk us through how you would typically receive and respond to any spill complaints in the field?

8. Can you tell us who is responsible for estimating spill volumes discharged? If it is you, please describe how you go about estimating the spill volume that you record on the work order/service request forms?

9. What other information do you collect or record other than what is written on the work order form?

10. Describe if and when you ever talk with people that call in spills (either onsite or via telephone) to further check out when the spill might have occurred based on what they or others know? If you do this, can you tell us where this information is recorded?

11. We understand you may be instructed to take pictures of some sewer spills/backups into structures. Other than these spills, when else would you typically take any pictures of a spill?

12. Please walk us through anything else you’d like to add to help us better understand how your field crews respond and mitigate spill complaints.

12.2 SPILL RESPONSE DRILLS
Periodic training drills or field exercises will be held to ensure that employees are up to date on these procedures, equipment is in working order, and the required materials are readily available. The training drills will cover scenarios typically observed during sewer related emergencies (e.g. mainline blockage, mainline failure, and lateral blockage). The results and the observations during the drills will be recorded and action items will be tracked to ensure completion.

12.3 SPILL TRAINING RECORD KEEPING
Records will be kept of all training that is provided in support of this SERP for 5 years. The records for all scheduled training courses and for each overflow emergency response training event will include date, time, place, content, name of trainer(s), names and titles of attendees, brief narrative description of the training, including training method(s) and training materials and/or equipment used.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

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Spill Emergency Response Plan 7-28-23
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12.4 CONTRACTORS WORKING ON CITY SEWER FACILITIES
All contractors working on City sewer facilities will be required to follow the spill response instructions on the Sanitary Sewer Spill Response Instructions for Contractors (Appendix C). Additional training may be required depending on the nature of the work on any or all of the following:
• The requirements of State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR), Element 6 • Communication procedures to City in the event a spill is caused or witnessed • The City’s Spill Emergency Response Plan procedures and practice drills • Skilled estimation of spill volume for field operators • Electronic CIWQS reporting procedures for staff submitting data

13. SEWER BACKUP INTO/ONTO PRIVATE PROPERTY CLAIMS HANDLING POLICY It is the policy of the City that a claims form shall be offered to anyone wishing to file a claim. The following procedures will be observed for all sewer overflows/backups into/onto private property:
• City staff will offer a City claim form irrespective of fault whenever it is possible that the sanitary sewer backup may have resulted from an apparent blockage in the City-owned sewer lines or whenever a City customer requests a claim form. The claim may later be rejected if subsequent investigations into the cause of the loss indicate the City was not at fault. • It is the responsibility of the Sewer Crew to gather information regarding the incident and notify the Streets, Sewer, and Forestry Supervisor or their designee.
• It is the responsibility of the Human Resources Director/Risk Manager or their designee to review all claims and to oversee the adjustment and administration of the claim to closure.

14. AUTHORITY
This SERP is written in accordance with the State Water Board Order No. WQ 2022-0103-DWQ (SSSWDR).

15. APPENDICES
A. Reporting Requirements by Spill Category
B. Door Hanger
C. Sanitary Sewer Spill Response Instructions for Contractors D. Sanitary Sewer Spill/Backup Response Workbook
Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

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Reporting Requirements by Spill Category
Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 35 of 47 REPORTING REQUIREMENTS FOR INDIVIDUAL CATEGORY 1 SPILL REPORTING Draft Spill Report
Within three (3) business days of the City’s knowledge of a Category 1 spill, the City shall submit a Draft Spill Report to the online CIWQS Sanitary Sewer System Database.

The Draft Spill Report must, at minimum, include the following items:

1. Contact information: Name and telephone number of City contact person to respond to spill-specific questions;

2. Spill location name;

3. Date and time the City was notified of, or self-discovered, the spill;

4. Operator arrival time;

5. Estimated spill start date and time;

6. Date and time the City notified the CaliforniaOffice of Emergency Services, and the assigned control number;

7. Description, photographs, and GPS coordinates of the system location where the spill originated; If a single spill event results in multiple appearance points, provide GPS coordinates for the appearance point closest to the failure point and describe each additional appearance point in the spill appearance point explanation field;

8. Estimated total spill volume exiting the system;

9. Description and photographs of the extent of the spill and spill boundaries;

10. Did the spill reach a drainage conveyance system? If Yes:
a. Description of the drainage conveyance system transporting the spill; b. Photographs of the drainage conveyance system entry location(s); c. Estimated spill volume fully recovered from the drainage conveyance system; d. Estimated spill volume remaining within the drainage conveyance system; e. Description and photographs of all discharge point(s) into the surface water; f. Estimated spill volume that discharged to surface waters; and g. Estimated total spill volume recovered.

Certified Spill Report
Within 15 calendar days of the spill end date, the City shall submit a Certified Spill Report for Category 1 spills, to the online CIWQS Sanitary Sewer System Database.

Upon completion of the Certified Spill Report, the online CIWQS Sanitary Sewer System Database will issue a final spill event identification number.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

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The Certified Spill Report must, at minimum, include the following mandatory information in addition to all information in the Draft Spill Report:

1. Description of the spill event destination(s), including GPS coordinates if available, that represent the full spread and reach of the spill;

2. Spill end date and time;

3. Description of how the spill volume estimations were calculated, including at a minimum:
a. The methodology, assumptions and type of data relied upon, such as supervisory control and data acquisition (SCADA) records, flow monitoring or other telemetry information used to estimate the volume of the spill discharged, and the volume of the spill recovered (if any volume of the spill was recovered), and
b. The methodology(ies), assumptions and type of data relied upon for estimations of the spill start time and the spill end time;

4. Spill cause(s) (for example, root intrusion, grease deposition, etc.);

5. System failure location (for example, main, lateral, pump station, etc.);

6. Description of the pipe material, and estimated age of the pipe material, at the failure location;

7. Description of the impact of the spill;

8. Whether or not the spill was associated with a storm event;

9. Description ofspillresponse activitiesincluding description of immediate spill containment and cleanup efforts;

10. Description of spill corrective action, including steps planned or taken to reduce, eliminate, and prevent reoccurrence of the spill, and a schedule of major milestones for those steps;

11. Spill response completion date;

12. Detailed narrative of investigation and investigation findings of cause of spill;

13. Reasons for an ongoing investigation (as applicable) and the expected date of completion;

14. Name and type of receiving water body(s);

15. Description of the water body(s), including but not limited to:
a. Observed impacts on aquatic life,
b. Public closure, restricted public access, temporary restricted use, and/or posted health warnings due to spill,
c. Responsible entity for closing/restricting use of water body, and d. Number of days closed/restricted as a result of the spill.

16. Whether or not the spill was located within 1,000 feet of a municipal surface water intake; and

17. If water quality samples were collected, identify sample locations and the parametersthe water quality samples were analyzed for. If no samples were taken, Not Applicable shall be selected.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

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Spill Emergency Response Plan 7-28-23
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Amended Certified Spill Reports
The City shall update or add additional information to a Certified Spill Report within 90 calendar days of the spill end date by amending the report or by adding an attachment to the Spill Report in the online CIWQS Sanitary Sewer System Database. The City shall certify the amended report.

After 90 calendar days, the City shall contact the State Water Board at [email protected] to request to amend a Spill Report. The Legally Responsible Official shall submit justification for why the additional information was not reported within the Amended Spill Report due date.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 38 of 47 REPORTING REQUIREMENTS FOR INDIVIDUAL CATEGORY 2 SPILL REPORTING Draft Spill Report
Within three (3) business days of the City’s knowledge of a Category 2 spill, the City shall submit a Draft Spill Report to the online CIWQS Sanitary Sewer System Database.

The Draft Spill Report must, at minimum, include the following items:

1. Contact information: Name and telephone number of City contact person to respond to spill-specific questions;

2. Spill location name;

3. Date and time the City was notified of, or self-discovered, the spill;

4. Operator arrival time;

5. Estimated spill start date and time;

6. Date and time the City notified the California Office of Emergency Services, and the assigned control number;

7. Description, photographs, and GPS coordinates of the system location where the spill originated; If a single spill event resultsin multiple appearance points, provide GPS coordinates for the appearance point closest to the failure point and describe each additional appearance point in the spill appearance point explanation field;

8. Estimated total spill volume exiting the system;

9. Description and photographs of the extent of the spill and spill boundaries;

10. Did the spill reach a drainage conveyance system? If Yes:
• Description of the drainage conveyance system transporting the spill; • Photographs of the drainage conveyance system entry location(s); • Estimated spill volume fully recovered from the drainage conveyance system; • Estimated spill volume remaining within the drainage conveyance system;

11. Estimated spill volume discharged to a groundwater infiltration basin or facility, if applicable; and

12. Estimated total spill volume recovered.

Certified Spill Report
Within 15 calendar days of the spill end date, the City shall submit a Certified Spill Report for the Category 2 spill, to the online CIWQS Sanitary Sewer System Database (https://ciwqs.waterboards.ca.gov). Upon completion of the Certified Spill Report, the online CIWQS Sanitary Sewer System Database will issue a final spill event identification number.

The Certified Spill Report must, at minimum, include the following mandatory information in addition to all information in the Draft Spill Report:

1. Description of the spill event destination(s), including GPS coordinates if available, that represent the full spread and reach of the spill;
Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

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Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 39 of 47 (Category 2 continued)

2. Spill end date and time;

3. Description of how the spill volume estimations were calculated, including at a minimum:
• The methodology, assumptions and type of data relied upon, such as supervisory control and data acquisition (SCADA) records, flow monitoring or other telemetry information used to estimate the volume of the spill discharged, and the volume of the spill recovered (if any volume of the spill was recovered), and
• The methodology(ies), assumptions and type of data relied upon for estimations of the spill start time and the spill end time;

4. Spill cause(s) (for example, root intrusion, grease deposition, etc.);

5. System failure location (for example, main, pump station, etc.);

6. Description of the pipe/infrastructure material, and estimated age of the pipe material, at the failure location;

7. Description of the impact of the spill;

8. Whether or not the spill was associated with a storm event;

9. Description ofspill response activitiesincluding description of immediate spill containment and cleanup efforts;

10. Description of spill corrective action, including steps planned or taken to reduce, eliminate, and prevent reoccurrence of the spill, and a schedule of major milestones for those steps;

11. Spill response completion date;

12. Detailed narrative of investigation and investigation findings of cause of spill;

13. Reasons for an ongoing investigation (as applicable) and the expected date of completion; and

14. Whether or not the spill was located within 1,000 feet of a municipal surface water intake.

Amended Certified Spill Reports
The City shall update or add additional information to a Certified Spill Report within 90 calendar days of the spill end date by amending the report or by adding an attachment to the Spill Report in the online CIWQS Sanitary Sewer System Database. The City shall certify the amended report.

After 90 calendar days, the City shall contact the State Water Board at [email protected] to request to amend a Spill Report. The Legally Responsible Official shall submit justification for why the additional information was not reported within the Amended Spill Report due date.

Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5

City of Gilroy
Spill Emergency Response Plan 7-28-23
© 2004-2023 DKF Solutions Group, LLC. All rights reserved. Page 40 of 47 REPORTING REQUIREMENTS FOR INDIVIDUAL CATEGORY 3 SPILL REPORTING Monthly Certified Spill Reporting
The City shall report and certify all Category 3 spills to the online CIWQS Sanitary Sewer System Database within 30 calendar days after the end of the month in which the spills occurred. (For example, all Category 3 spills occurring in the month of February shall be reported and certified by March 30th). After the Legally Responsible Official certifies the spills, the online CIWQS Sanitary Sewer System Database will issue a spill event identification number for each spill.

The monthly reporting of all Category 3 spills must include the following items for each spill:

1. Contact information: Name and telephone number of City contact person to respond to spill-specific questions;

2. Spill location name;

3. Date and time the City was notified of, or self-discovered, the spill;

4. Operator arrival time;

5. Estimated spill start date and time;

6. Description, photographs, and GPS coordinates where the spill originated. If a single spill event results in multiple appearance points, provide GPS coordinatesforthe appearance point closest to the failure point and describe each additional appearance point in the spill appearance point explanation field;

7. Estimated total spill volume exiting the system;

8. Description and photographs of the extent of the spill and spill boundaries;

9. Did the spill reach a drainage conveyance system? If Yes:
a. Description of the drainage conveyance system transporting the spill; b. Photographs of the drainage conveyance system entry locations(s); c. Estimated spill volume fully recovered from the drainage conveyance system; and d. Estimated spill volume discharged to a groundwater infiltration basin or facility, if applicable.

10. Estimated total spill volume recovered;

11. Description of the spill event destination(s), including GPS coordinates, if available, that represent the full spread and reaches of the spill;

12. Spill end date and time;

13. Description of how the spill volume estimations were calculated, including, at minimum:
a. The methodology and type of data relied upon, including supervisory control and data acquisition (SCADA) records, flow monitoring or other telemetry information used to estimate the volume of the spill discharged, and the volume of the spill recovered (if any volume of the spill was recovered), and b. The methodology and type of data relied upon to estimate the spill start time, on-going spill rate at time of arrival (if applicable), and the spill end time;

14. Spill cause(s) (for example, root intrusion, grease deposition, etc.); Docusign Envelope ID: B7C6A99E-C479-47F2-B2EA-13BE70CE4EC5