Cities Index.
Updated Sewer System Management Plan without appendices

Orange City Council
April 22, 2025

Document
Updated Sewer System Management Plan without appendices
Meeting
April 22, 2025
Body
Orange City Council
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Text extracted from the city's file for reading and search. Open the original on cityoforange.legistar1.com. That file is the official record.

Sewer System Management Plan
Prepared by the City of Orange

Prepared for
State Water Resources Control Board Order 2022-0103-DWQ Updated May 2025

Sewer System Management Plan Update Log Sheet

Date Rev. # By Revisions
January 2012 1 G. Estrada Title change, update org chart, sewer maps, other minor changes May 2013 2 G. Estrada Update text, Overflow Emergency Response Plan, org charts, ordinances, maps, sewer master plan, May 2014 3 G. Estrada Updated org charts and maps, City Council Certification November 2017 4 G. Estrada Update Public Works Organization, maps, spill guide May 2020 5 Frank Sun Update Public Works Organization, add definitions, update Operations and Maintenance Program, update Overflow Emergency Response Plan June 2023 6 Frank Sun Updated the Spill (formerly Overflow) Emergency Response Plan to comply with Order 2022-0103-DWQ May 2025 7 Frank Sun General updates to comply with Order 2022-0103-DWQ. Also changed the Plan’s name from Sanitary Sewer Management Plan to Sewer System Management Plan to align with the Order.

SSMP City of Orange Updated 2025
Table of Contents
I. Goal and Introduction .............................................................................................................. 1 Goal ......................................................................................................................................... 1 Introduction .............................................................................................................................. 1 II. Organization ............................................................................................................................. 3 III. Legal Authority ....................................................................................................................... 4 IV. Operation and Maintenance Program ................................................................................... 7 V. Design and Performance Provisions ..................................................................................... 9 VI. Spill Emergency Response Plan ......................................................................................... 10 VII. Sewer Pipe Blockage Program ........................................................................................... 11 VIII. System Evaluation, Capacity Assurance and Capital Improvements ........................... 13 IX. Monitoring, Measurement and Program Modifications .................................................... 21 X. Internal Audits ....................................................................................................................... 22 XI. Communication Program .................................................................................................... 23 Appendices

Appendix A. Organization charts and Legally Responsible Official Appendix B. Spill Emergency Response Plan (SERP)
Appendix C. Hot spot list
Appendix D. Sewer Collection System Master Plan Update Appendix E. Sanitary Sewer Rehabilitation and Replacement Plan Appendix F. 5-year Capital Improvement Plan for the Sanitary Sewer System

SSMP City of Orange Updated 2025
I. Goal and Introduction
Goal
Requirement
The goal of the Sewer System Management Plan (SSMP or 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 goal of the City’s 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.

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

Requirement: Regulatory Context
The Plan Introduction section must provide a general description of the local sewer system management program and discuss Plan implementation and updates.

The City’s sewer system management program aims to manage, operate, and maintain the sanitary

sewer

system,

reduce

and

prevent

spills,

and

mitigate

the

impact

of

spills.

The

Public

Works

Department

is

responsible

for

implementing

the

Plan.

The

city

evaluates

its

activities

annually

to

minimize

sewer

spills

by

reviewing

spill

locations

and

causes,

cleaning

and

videoing

frequency,

capital

improvement

programs,

and

deficiency

locations.

The

City

also

implements

a

Sewer

Pipe

Blockage

Control

Program,

cleans

hot

spots

regularly,

and

updates

its

Sewer

Master

Plan

(SMP)

as-needed.

Plan updates and self-audits will occur at the frequencies required by the Statewide Sanitary Sewer

Systems

General

Order

(Order).

Plan

updates

may

also

occur

as

needed.

Plan

updates

will

be

logged

in

the

Plan

and

will

include

a

summary

of

revisions.

Requirement: Sewer System Management Plan Update Schedule 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. 1 SSMP City of Orange Updated 2025
Plan updates and self-audits will occur at the frequencies required by the Order. So future Plan updates

will

be

every

6 years

starting

from

5/2/2025

(e.g.,

5/2/2031,

5/2/2036)

and

future

self-audit

periods

will

cover

every

3 years

starting

from

5/2/2024

(e.g.,

5/3/2024

-

5/2/2027,

5/3/2027

-

5/30/2030),

with

the

audit

reports

due

six

months

after

the

end

of

the

audit

period

(e.g.,

11/2/2027,

11/2/2030).

Plan

updates

may

also

occur

as

needed.

Plan

updates

will

be

logged

in

the

Plan

and

will

include

a

summary

of

revisions.

Milestones for the incorporation of activities addressing prevention of sewer spills include the development

of

the

City’s

Sewer

Collection

System

Master

Plan

Update

in

2012

(SMP,

Appendix

D),

the

development

of

the

City’s

Sanitary

Sewer

Rehabilitation

and

Replacement

Plan

in

2015

(SSRRP,

Appendix

E),

the

update

to

the

Spill

Emergency

Response

Plan

(SERP)

in

2023,

the

latest

update

to

this

Plan

(2025),

the

continued

implementation

of

an

annual

Capital

Improvement

Plan

for

the

sanitary

sewer

system

that

is

based

off

of

the

SMP/SSRRP

(2023-24

to

2027-28,

Appendix

F),

and

the

continued

implementation

of

ongoing

programmatic

activities

detailed

in

this

Plan,

such

as

sewer

system

maintenance,

sewer

blockage

prevention,

and

spill

response.

Plan updates will include the incorporation of any new activities addressing prevention of sewer spills.

Requirement: Sewer System Asset Overview
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 percent 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.

Description of assets and service area:
● Location, including county(ies): City of Orange, County of Orange. 2 SSMP City of Orange Updated 2025
● Service area boundary: Jurisdictional boundaries of the City of Orange. ● Population and community served: 136,718 residents (as of 2022) of the City of Orange. ● System size, including total length in miles, length of gravity mainlines, length of pressurized

(force)

mains,

and

number

of

pump

stations

and

siphons:

313

miles

of

gravity

mainlines,

0.1 miles

of

pressurized

(force)

mains,

2 pump

stations,

and

14 siphons.
● Structures diverting stormwater to the sewer system: None. ● Data management systems: MaintStar Asset Management System manages sanitary sewer

system

data

and

an

MS

Access

database

(and

CIWQS)

is

used

for

spill

data.
● Sewer system ownership and operation responsibilities between the City and private entities

for

upper

and

lower

sewer

laterals:

The

City

does

not

own

or

operate

upper

and

lower

sewer

laterals.

Lateral

operation

is

the

responsibility

of

the

owners.
● Estimated number or percent of residential, commercial, and industrial service connections:

Approximately

30,278

residential,

2,524

commercial,

and

260

industrial.
● Unique service boundary conditions and challenge(s): The City of Villa Park’s and parts of

unincorporated

county’s

sanitary

sewer

systems

in

part

connect

to

the

City’s

system.

II. Organization
Requirement: Sewer System Management Plan Update Schedule 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:

1. The name of the Legally Responsible Official as required in section 5.1 (Designation of a Legally Responsible Official) of the Order; 2. The position titles, telephone numbers, and email addresses for management, administrative, and maintenance positions responsible for implementing specific Sewer System Management Plan elements; 3. Organizational lines of authority; and 4. 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.) Legally Responsible Official
See Appendix A.

Position titles, telephone numbers, and email addresses for management, administrative, and maintenance

positions

responsible

for

implementing

specific

Plan

elements,

as

well

as

organizational

lines

of

authority.

3 SSMP City of Orange Updated 2025
The City of Orange Public Works Department is responsible for implementing the Plan. A set of organization

charts

that

includes

position

titles,

telephone

numbers,

and

email

addresses

for

management,

administrative,

and

maintenance

positions

responsible

for

implementing

specific

Plan

elements

is

in

Appendix

A.

The

charts

also

outline

the

lines

of

authority

for

administrative

and

field

staff.

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.

The Public Works Engineering Division’s Surface Water Quality Section is responsible for oversight

of

the

reporting

process.

Depending

on

the

time

of

day

in

which

spills

occur,

calls

for

the

reporting

of

spills

occur

in

two

ways

as

reported

in

the

Sewer

Emergency

Response

Plan

included

in

Appendix

B.

During

normal

working

office

hours,

calls

of

spills

are

reported

to

the

Public

Works

Maintenance

Division

at

(714)

532-6480.

After

normal

working

hours

including

weekends

and

holidays

the

24 hour

hotline

number

(714)

538-1961,

Water

Plant

Operator

and/or

call

center,

receives

calls

and

takes

all

information

and

forwards

the

information

to

the

on-call

Public

Works

supervisor.

At

that

point

City

work

crews

are

dispatched

to

the

site

along

with

an

Environmental

Compliance

Specialist,

who

provides

reports.

III. Legal Authority
Requirement
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.

The City’s legal authority for these items is established by the following:
4 SSMP City of Orange Updated 2025
Legal Authority Requirement 1 of 6. 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.

Orange County Sanitation District Ord. 53, which covers the City of Orange, is a general ordinance

for

the

Orange

County

Sanitary

District

which

treats

all

of

the

wastewater

from

the

City.

The

ordinance

contains

requirements

on

what

can

be

disposed

of

in

the

sewers,

prohibited

discharges,

authority

to

carry

out

the

ordinance,

and

enforcement.

The

City

also

uses

Municipal

Code

Sections

13.66 (FOG

requirements)

and

13.64 (Industrial

Waste)

to

prohibit

the

discharge

of

waste

that

may

be

harmful

or

obstruct

flow

within

the

sewer

system.

Links: https://records.ocsan.gov/WebLink/DocView.aspx?id=205719&dbid=0&repo=OrangeCountySanitationDistrict https://ecode360.com/43564751
https://ecode360.com/43564689
Legal Authority Requirement 2 of 6. Legal authority to 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.

The City is party to a Water Quality Ordinance Implementation Agreement with the Orange County

Flood

Control

District.

This

Agreement,

along

with

the

similar

Water

Quality

Ordinances

of

the

City

and

its

adjoining

storm

sewer

agencies,

provides

the

legal

authority

to

collaborate

with

and

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.

Legal Authority Requirement 3 of 6. Legal authority to require that sewer system components and connections be properly designed and constructed.

Design of sewers in the City’s collection system is based on the requirements contained in Design

and

Construction

Requirements

of

Sanitary

Sewers

by

the

Orange

County

Sanitation

District.

It

contains

design

requirements

such

as

maximum

peak

flow

allowed,

minimum

velocity,

depth

of

cover,

land

use

density,

manhole

spacing,

materials

and

other

criteria

used

in

designing

sewers

within

the

City.

While

not

formally

incorporated

into

the

City’s

municipal

code,

it

is

used

by

the

various

divisions

involved

in

the

design

of

sewers.

Link: https://www.ocsan.gov/wp-content/uploads/2024/08/2022-OC-SAN-Design-and-Con.pdf 5 SSMP City of Orange Updated 2025
The City of Orange Standard Plans Series 200 provides information on constructing sewer manholes

and

other

elements

related

to

sanitary

sewers.

Link: https://www.cityoforange.org/our-city/departments/public-works/engineering-division/engineering-standards Through its municipal code, the City has adopted the Standard Specifications for Public Works Construction

more

commonly

known

as

the

Green

Book.

This

document,

particularly

sections

306

and

500

are

used

in

the

construction

of

City

sewers.

Section

306

Underground

Conduit

Construction

covers

sewer

pipe

construction

and

includes

information

on

excavation,

trenching,

bedding,

joints,

backfill,

air

pressure

tests,

water

pressure

tests

and

other

items

related

to

the

installation

and

acceptance

of

underground

pipes.

Section

500,

Pipeline

Rehabilitation,

includes

information

on

various

lining

methods

that

can

be

used

to

rehabilitate

underground

pipes.

Link: https://citydocs.cityoforange.org/WebLink/DocView.aspx?id=244347704&dbid=0&repo=CityofOrange Legal Authority Requirement 4 of 6. Legal authority to ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the City.

Most laterals in the City are privately owned. It is the responsibility of the owner to maintain the private

lateral

in

good

working

condition

free

of

obstructions

(OMC

13.56.050).

In

cases

where

a

sewer

lateral

is

required

to

be

maintained

by

the

City,

an

easement

is

recorded

that

contains

provisions

for

access,

maintenance

and

inspection

by

the

City.

Link: https://ecode360.com/43564654
Legal Authority Requirement 5 of 6. Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures.

Chapter 1.08 of the Municipal Code provides the legal authority to enforce the City’s sewer ordinances.

The

City

Attorney

ensures

that

service

agreements

and

other

legally

binding

procedures

include

the

legal

authority

to

enforce

violations.

Link: https://ecode360.com/43545657
Legal Authority Requirement 6 of 6. Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable. 6 SSMP City of Orange Updated 2025
In cases where a sewer lateral is required to be maintained by the City, an easement is recorded

that

contains

provisions

for

access,

maintenance

and

inspection

by

the

City.

IV. Operation and Maintenance Program
The Plan must include the items listed below that are appropriate and applicable to the Enrollee’s

system.

Requirement: Updated Map of Sanitary Sewer System 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.

The City collection system has been mapped including all gravity lines and manholes, pump facilities

and

storm

water

conveyance

systems.

These

maps

are

stored

within

the

City’s

geographic

information

system

(GIS)

and

are

maintained

and

updated

as

needed.

Attributes

available

for

viewing

within

the

GIS

system

include

pipe

size,

material,

year

built,

pipe

identifier,

slope,

invert,

manhole

number

and

other

attributes.

Storm

water

conveyance

facilities

are

also

stored

in

a

GIS

database

and

include

information

such

as

pip

size,

material,

catch

basin

and

their

identifier

and

other

information.

A copy of these up-to-date maps is accessible to the public at the following link: https://experience.arcgis.com/experience/d5b47f56c689474bafa6e0070af1217d/ Requirement: Preventive Operation and Maintenance Activities 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.

The City has historically had a Preventive Maintenance Plan, which included cleaning of the City’s

collection

system.

To

provide

increased

and

dedicated

resources

to

the

sewer

system,

the

City

contracts

out

a

vast

majority

of

the

cleaning

and

inspection.

This

includes

routine

cleaning

and

inspection

as

well

as

the

more

frequent

“hot

spots”

cleaning.

The

city

is

divided

into

5 7
SSMP City of Orange Updated 2025
sections based on their primary servicing requirements where areas of greater need would be emphasized

such

as

industrial/commercial

areas

and

areas

where

sewer

pipe

grades

were

minimal.

The

oldest

sections

of

the

City

will

be

inspected

annually.

Residential

areas

and

areas

where

sewer

pipe

grades

are

in

excess

of

minimal

scour

velocity

will

be

cleaned

less

frequently

(every

two

to

three

years)

and

other

areas

inspected

every

five

years.

Until

a

specific

cause

is

identified

and

eliminated,

hot

spots

will

be

monitored

and

cleaned

as

needed,

typically

every

three

or

six

months

depending

on

suspected

cause

and

buildup

in

the

pipe.

The City will implement mechanical root control methods when roots are determined to be the cause

of

buildup

in

the

pipe.

Chemical

root

control

is

not

allowed.

The City will continue to monitor and adjust schedules to facilitate optimal operation of the collection

system

and

proper

allocation

of

limited

resources.

Cleaning

and

CCTV

inspection

will

be

on

the

schedule

identified

in

Attachment

B

of

the

Sanitary

Sewer

Rehabilitation

and

Replacement

(SSRRP,

Appendix

E).

A

listing

of

the

existing

hot

spots

can

be

found

in

Appendix

C.

In addition, the City has two sewer pump stations, which are serviced and inspected monthly under

a

contract.

Manhole inspections are conducted during field visits and documented using a form.

The City will utilize the CCTV inspection program as outlined above. This program identifies structural

deficiencies

in

the

City’s

collection

system.

Prioritization

along

with

short

and

long

term

strategies

for

rehabilitation

of

any

structural

deficiencies

found

through

the

inspection

program

will

be

addressed

in

the

City’s

capital

improvement

program.

This

is

a

comprehensive

budgeting

program,

which

looks

forward

seven

years

and

is

updated

annually.

Items

related

to

deficiencies

identified

in

the

City’s

Master

Plan

of

Sewers

are

discussed

in

Section

6 of

the

latest

plan

dated

August

2012.

By February 2025, for all sewer lines in the Collection System located within two hundred (200) feet

of

Surface

Waters,

the

City:

1. Repaired or replaced all gravity sewer lines previously found to be Significantly Defective;

2. Began a Surface Water Assessment to prioritize the review, rating, and repairs of gravity sewer

lines

located

within

200

feet

of

surface

water.

3. Sewer pipe segments containing defects with a PACP rating of 3 that are not repaired or replaced

within

five

(5)

years

after

completion

of

the

Surface

Water

Condition

Assessment

are

to

be

re-CCTV'd

every

ten

(10)

years

to

ascertain

their

condition.

If

the

City

determined

the

sewer

pipe

segment

had

deteriorated

and

needed

to

be

repaired

or

replaced,

the

City

completed

such

repair

or

replacement

within

five

(5)

years

after

the

last

CCTV

cycle.

For the remainder of the Collection System, the City will implement the Condition Assessment Cycle

and

re-inspect

all

gravity

sewer

lines,

manholes,

pump/lift

stations,

and

pipe

segments

at

8 SSMP City of Orange Updated 2025
least every ten (10) years. This program of re-inspection will begin one (1) year following completion

of

the

Full

Condition

Assessment.

Requirement: Training
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 the 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.

Administrative and Field Staff are regularly trained in the above elements. California Water Environment

Association

(CWEA)

certification

training

for

Field

staff

is

conducted

on

a

regular

basis.

Attainment

of

the

following

“Collections”

certification

grades

will

be

the

goal

of

the

City.

Position Grade level
Maintenance Division Manager 4
Assistant Field Services Manager 3
General/Sanitation Supervisor 2
All Field support staff 1
Environmental Compliance Specialist 1
Environmental Scientist 3
Environmental Program Manager (NPDES) 3
Contract personnel are trained on an as-needed basis Requirement: Equipment Inventory
An inventory of sewer system equipment, including the identification of critical replacement and spare parts.

The City has or has on order general maintenance equipment necessary to perform minor sewer

construction,

maintenance,

and

inspection

work.

The

City

maintains

a

limited

supply

of

sewer

pipe,

clamps,

manhole

covers

and

emergency

pumps

and

hoses

stored

at

the

City’s

Corporation

Yard.

In

addition,

as

part

of

an

emergency

response

cooperative,

the

City

is

able

to

contact

other

local

wastewater

agencies

to

obtain

emergency

repair

parts.

V. Design and Performance Provisions
9 SSMP City of Orange Updated 2025
The Plan includes the following items as appropriate and applicable to the City’s system:

Requirement: Updated Design Criteria and Construction Standards and Specifications 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.

As noted in Section III, design of the City’s sewer collection system is based on the Orange County

Sanitation

District’s

document

Design

and

Construction

Requirements

of

Sanitary

Sewers.

The

document

contains

design

requirements

such

as

maximum

peak

flow

allowed,

minimum

velocity,

depth

of

cover,

land

use

density,

manhole

spacing,

materials

and

other

criteria

used

in

designing

sewers

within

the

City.

Construction specifications for construction and performance of its new sewer lines and the rehabilitation

of

existing

sewer

lines

are

through

the

Standard

Specifications

for

Public

Works

Construction

(Green

book)

as

modified

internally

to

meet

City

requirements.

The

Green

Book

sections

most

commonly

used

in

the

construction

of

City

sewers

are

sections

306

and

500.

Section 306 Underground Conduit Construction covers sewer pipe construction and includes information

on

excavation,

trenching,

bedding,

joints,

backfill,

air

pressure

tests,

water

pressure

tests

and

other

items

related

to

the

installation

and

acceptance

of

underground

pipes.

Section

500,

Pipeline

Rehabilitation,

includes

information

on

various

lining

methods

that

can

be

used

to

rehabilitate

underground

pipes.

Existing design criteria and construction standards are sufficient to address the necessary component-specific

hydraulic

capacity

as

specified

in

Section

8 of

Attachment

D

of

the

Order.

Requirement: Procedures and Standards
Procedures, and standards for the inspection and testing of newly constructed, newly installed, repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances.

Inspection and testing standards of new sewers and rehabilitation of existing sewers are in accordance

with

Section

306

of

the

Green

Book

as

noted

above.

VI. Spill Emergency Response Plan
Requirement
10 SSMP City of Orange Updated 2025
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 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.

The City’s Spill Emergency Response Plan (SERP) is in Appendix B. Annually, the City will review

and

assess

effectiveness

of

the

SERP,

and

update

it

as

needed.

VII. Sewer Pipe Blockage Program
Core Requirement
The Plan must include procedures for the evaluation of the City’s service area to determine whether a sewer pipe blockage control program (SPBP) is needed to control fats, oils, grease, rags and debris. If the City determines that a program is not needed, the City shall provide justification in its Plan for why a program is not needed.

Spill causes reported through the SERP indicated that an SPBP is needed to control FOG, rags, and

debris.

The

SPBP

procedures

required

by

the

Order

are

as

follows:

11 SSMP City of Orange Updated 2025
SPBP Procedures Requirement 1 of 7: An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG.

At the on-set of the FOG program, the City provided a poster and two informational DVDs to all inventoried

City

restaurants

on

the

proper

disposal

of

FOG

and

kitchen

best

management

practices.

When

a

new

restaurant

opens

in

the

City

an

Environmental

Compliance

Specialist

will

conduct

an

introductory

meeting/informal

training

during

which

the

restaurant

receives

a

poster

and

brochures

containing

appropriate

best

management

practices

for

kitchen

procedures

to

ensure

it

adheres

to

proper

FOG

disposal.

In

addition,

the

City

currently

uses

its

local

newsletter

Our

Orange

and

website

to

reach

residents

and

inform

them

of

the

need

for

proper

FOG

disposal.

FOG

brochures

are

also

available

at

the

City’s

Public

Works

counter.

SPBP Procedures Requirement 2 of 7: 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.

Each restaurant within the City is responsible for the proper disposal of pipe-blocking substances

generated

within

its

facility.

If

necessary

and

requested

by

the

facility,

the

City

provides

a

list

of

acceptable

disposal

operators.

SPBP Procedures Requirement 3 of 7: The legal authority to prohibit discharges to the system and identify measures to prevent spills and blockages.

The City of Orange adopted Ordinance 17-04 its Fats, Oils and Grease Control Regulations Applicable

to

Food

Service

Establishments

on

November

9,

2004

to

control

the

discharge

of

FOG

into

the

City’s

sanitary

sewer

system.

The

ordinance

was

codified

into

its

municipal

code

in

Chapter

13.66. The

ordinance

contains

information

on

how

to

reduce

the

impact

of

FOG

on

the

sewer

system

through

the

use

of

kitchen

best

management

practices.

In

addition,

Orange

County

Sanitation

District

Ord.

53,

which

covers

the

City

of

Orange,

is

a

general

ordinance

for

the

Orange

County

Sanitary

District

which

treats

all

of

the

wastewater

from

the

City.

The

ordinance

contains

requirements

on

what

can

be

disposed

of

in

the

sewers,

prohibited

discharges,

authority

to

carry

out

ordinance

and

enforcement.

SPBP Procedures Requirement 4 of 7: 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.

Ordinance 17-04 requires all new food service facilities (FSEs) to install grease interceptors or grease

traps

as

necessary

to

control

the

discharge

of

FOG

into

the

sanitary

sewer

system.

FSEs

that

are

upgraded

or

have

operational

changes

may

also

be

required

to

install

grease

interceptors

or

grease

traps

if

they

trigger

certain

requirements

in

the

ordinance.

In

addition,

existing

FSE

may

be

required

to

install

new

grease

control

devices

if

it

is

determined

that

they

12 SSMP City of Orange Updated 2025
are discharging an excessive amount of grease and it is contributing to sanitary sewer overflows.

The

ordinance

also

contains

BMP,

recordkeeping,

and

reporting

requirements.

SPBP Procedures Requirement 5 of 7: Authority to inspect grease producing facilities, enforcement authorities, and whether the City has sufficient staff to inspect and enforce the fats, oils, and grease ordinance.

Ordinance 17-04 provides authority to inspect grease producing facilities and contains enforcement

provisions

that

include

Civil

and

Criminal

penalties

to

ensure

those

discharging

FOG

into

the

sanitary

sewer

system

can

be

prosecuted.

The

City

of

Orange

currently

contracts

with

the

Orange

County

Health

Care

Agency

to

inspect

all

of

the

City’s

restaurants

to

ensure

proper

best

management

practices

are

being

implemented

and

FOG

is

not

being

discharged.

City

staff

are

used

to

inspect

grease

interceptors

and

grease

traps

every

3 to

6 months

as

needed

based

on

the

amount

of

FOG

generated.

SPBP Procedures Requirement 6 of 7: An identification of sanitary sewer system sections subject to fats, oils, and grease blockages and establishment of a cleaning schedule for each section.

The City regularly produces a list of hot spots associated with FOG discharges. Hot spots are cleaned

regularly

every

3 to

6 months

to

minimize

spills.

SPBP Procedures 7 of 7: Implementation of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each section identified above.

As noted above, all grease producing facilities are provided with education and training material on

the

proper

disposal

of

FOG.

Where

specific

sources

have

been

identified,

attempts

are

made

to

remove

the

FOG

source

through

education,

additional

BMP

training

or

installation

of

grease

capturing

devices.

Where

the

source

cannot

be

identified,

the

area

is

targeted

for

outreach

through

flier

distribution

of

door

hangers

or

educational

letters.

The

area

may

also

be

added

for

frequent

cleaning.

All

of

this

is

considered

instrumental

in

reducing

spills

from

hot

spot

areas.

Based

on

the

frequency

of

sewer

spills

the

previous

years,

the

program

seems

to

be

successful.

VIII. System Evaluation, Capacity Assurance and Capital Improvements

Core Requirement
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. 13 SSMP City of Orange Updated 2025
The required procedures and activities are as follows:

Requirement: System Evaluation and Condition Assessment 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 methods; ● 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.

The City evaluates its sanitary sewer system assets through a combination of master planning, hydraulic

modeling,

flow

monitoring,

and

physical

condition

assessments.

The

Sewer

System

Master

Plan

(SMP,

included

as

Appendix

D)

is

a

key

planning

tool

that

is

updated

periodically

(most

recently

in

2012)

to

analyze

the

existing

system

capacity

and

identify

required

upgrades

based

on

both

existing

and

ultimate

(build-out)

conditions

outlined

in

the

City's

General

Plan.

This

evaluation

involves

creating

a

computer

model

using

GIS

data

of

the

sewer

infrastructure,

including

pipe

and

manhole

information,

and

calibrating

it

with

field

flow

monitoring

data.

Hydraulic

modeling

is

used

to

assess

the

capacity

of

the

pipelines

under

both

dry

and

estimated

wet

weather

flows,

identifying

hydraulically

deficient

segments

based

on

d/D

ratios

exceeding

established

criteria.

The

City

also

utilizes

flow

monitoring

investigations

at

key

locations

to

verify

flow

characteristics

and

calibrate

the

hydraulic

model,

contributing

to

the

development

of

flow

generation

factors

for

different

land

uses.

In

addition,

the

City

conducts

video

inspection

(CCTV)

of

the

sewer

lines

as

a

primary

method

for

assessing

their

physical

condition.

This

allows

for

the

identification

of

structural

deficiencies

such

as

broken

pipes

and

severe

offsets.

The

City

uses

the

PACP

(Pipeline

Assessment

Certification

Program)

developed

by

NASSCO

to

grade

the

condition

of

the

sewer

line

segments

based

on

these

inspections.

14 SSMP City of Orange Updated 2025
In 2015 the City developed a Sanitary Sewer Rehabilitation and Replacement Plan (SSRRP, included

in

Appendix

E).

Although

the

SSRRP

does

not

state

a

target

annual

percentage

for

condition

assessment,

it

details

a

cyclical

and

risk-based

approach

that

indicates

that

a

significant

portion

of

the

system

is

evaluated

regularly.

The

SSRRP

states

that

the

entire

sewer

system

is

cleaned

over

a

five-year

cycle,

meaning

approximately

20%

of

the

system

is

cleaned

annually.

This

cleaning

process,

while

not

a

detailed

condition

assessment,

allows

for

visual

observations

and

can

help

identify

areas

needing

further

inspection.

For

more

detailed

condition

assessment

using

CCTV,

the

City

aims

to

CCTV

each

gravity

sewer

line

at

least

every

ten

years

on

a

rolling

basis.

This

suggests

an

average

annual

assessment

rate

of

approximately

10%

of

the

sewer

lines

through

CCTV

inspection.

This

ten-year

cycle,

along

with

the

more

frequent

cleaning

in

older

areas

like

Old

Towne

(annually)

and

known

hot

spots

(quarterly),

demonstrates

a

justified

approach

based

on

the

age

of

pipelines

and

known

problem

areas.

The

Maintenance

Division

adjusts

inspection

frequencies

as

necessary

based

on

these

factors.

The

City

conducts

condition

assessment

for

about

20%

of

the

City’s

sewer

system

with

a

combination

of

both

programmed

annual

video

inspection

and

targeted

inspection

as

needed.

The

amount

of

the

annual

assessment

is

what

the

City’s

sewer

fee

can

support

and

the

City’s

sewer

capital

improvement

funding

can

implement.

This

plan

has

been

effective

in

addressing

both

the

sewer

maintenance

need

and

the

structural

deficient

sewer

main

improvement

need.

The prioritization of the condition assessment is based on historical data and identified deficiencies:
● The SMP focuses on mitigating potential cumulative impacts to the sewer collection system, which

inherently

considers

the

consequences

of

system

deficiencies.

Identifying

hydraulically

deficient

pipes,

especially

those

exceeding

d/D

criteria

under

both

dry

and

wet

weather

conditions,

prioritizes

areas

vulnerable

to

capacity

issues,

which

could

lead

to

overflows

with

environmental

consequences.
● The SSRRP highlights "sewer hot spots" known for past spills and identifies "Sewer Repair Areas"

with

existing

defects

(broken

pipes,

offsets)

based

on

video

inspections.

These

areas,

with

a

demonstrated

history

or

high

potential

for

sewage

exiting

the

system,

are

implicitly

prioritized

for

assessment

and

repair.

The

more

frequent

cleaning

cycle

in

Old

Towne,

with

its

older

infrastructure,

also

indicates

a

prioritization

based

on

the

potential

for

failure.
● The recommendation to investigate the Hart Park Lift Station due to concerns about capacity and

operation

in

preventing

sewer

spills

indicates

a

prioritization

of

assets

near

surface

waters

(Santiago

Creek)

to

mitigate

potential

environmental

impacts.

While the SMP and SSRRP do not explicitly state a prioritization based on steep terrain and high groundwater

elevations,

the

overall

approach

of

addressing

known

problem

areas,

aging

infrastructure,

and

hydraulically

deficient

segments

inherently

targets

vulnerabilities

that

could

be

exacerbated

by

such

conditions.

The

City’s

sewer

system

located

within

the

vicinity

of

surface

waters,

steep

terrain,

high

groundwater

elevations,

and

environmentally

sensitive

areas

is

limited

and

can

be

prioritized

within

the

City’s

programmed

annual

inspection

activities.

According to the California proposed 2020-2022 Integrated Report 303(d) Map, there are no impaired

waterbodies

within

the

City

limits,

or

within

approximately

3.5 miles

downstream

of

the

City.

Most

of

the

City

falls

within

the

Santa

Ana

River

Watershed,

for

which

there

are

no

impairments

listed.

(A

small

southwestern

portion

of

the

City

drains

about

3.5 miles

to

the

East

Garden

Grove

Wintersburg

Channel,

which

is

impaired

for

Ammonia.

A

relatively

small

southeastern

portion

of

the

15 SSMP City of Orange Updated 2025
City drains about 5 miles to Peters Canyon Channel, which is impaired for pH, Toxaphene, Benthic Community

Effects,

Malathion,

Selenium,

Toxicity,

DDT,

and

Indicator

Bacteria.

Peters

Canyon

Channel

drains

to

the

San

Diego

Creek

and

the

Newport

Bay,

both

of

which

are

listed

for

Indicator

Bacteria,

in

addition

to

other

listings.)

The SSRRP outlines the methods used to assess system conditions:
● Visual Observations: These occur during the cleaning process, where maintenance crews can

identify

obvious

issues.
● Video Surveillance (CCTV): The Maintenance Division utilizes vans equipped with video cameras

and

cleaning

equipment

to

conduct

internal

inspections

of

sewer

lines.

Pipe

hunters

are

also

used

for

inspection.
● PACP Grading: The video inspections result in a condition grade (1 to 5) based on the PACP standards,

providing

a

systematic

way

to

categorize

the

severity

of

observed

defects.

The City’s condition assessment practices directly target observations and evidence of system conditions

that

could

lead

to

sewage

exiting

the

system.

The

identification

of

hydraulically

deficient

pipes

through

modeling

points

to

areas

susceptible

to

backups

and

overflows,

particularly

during

peak

flows,

which

could

result

in

sewage

discharge.

Similarly,

the

video

inspections

identify

physical

defects

such

as

broken

pipes,

severe

offsets,

cracks,

and

holes

that

can

directly

cause

leaks

and

exfiltration

of

sewage

into

the

surrounding

environment,

potentially

reaching

waters

of

the

State.

The

"Sewer

Repair

Areas"

list

explicitly

documents

these

conditions.

The

focus

on

"hot

spots"

with

a

history

of

sewer

spills

further

demonstrates

the

utilization

of

evidence

of

past

sewage

exiting

the

system

to

inform

ongoing

assessment

and

maintenance

efforts.

The SSRRP and the development of the SMP demonstrate a commitment to maintaining documents and

recordkeeping.

● The Maintenance Division maintains records of sewer line videos and forwards them to the City’s

GIS

group

to

be

attached

to

the

appropriate

line

segment.
● Segments with deficiencies identified through video inspection are documented and forwarded

to

the

Maintenance

Manager.

The

SSRRP

lists

deficient

sewer

segments.
● The Sewer System Master Plan itself is a comprehensive document detailing the system evaluation,

modeling

results,

and

recommendations.

Updates

to

the

SMP

(e.g.,

the

2012

update)

are

also

documented.
● The Capital Improvement Program (CIP) lists proposed sewer projects derived from the identified

deficiencies,

indicating

a

record

of

planned

improvements

based

on

assessment

findings.
● The existence of a GIS-based sewer system with plans indicates a centralized system for maintaining

data

about

the

sewer

assets.

The City’s sewer system has vulnerability to sea level rise and increased storm volumes, frequency, and/or

intensity

due

to

their

potential

impacts

to

the

Orange

County

Sanitation

District’s

trunk

line

that

the

city’s

system

convenes

flow

to.

Requirement: Capacity Assessment and Design Criteria 16 SSMP City of Orange Updated 2025
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 contribute to spill events; ● The appropriate design storm(s) or wet weather events that causes or contributes to spill events; ● The capacity of key system components; and ● Identify the major sources that contribute to the peak flows associated with sewer spills.

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

The following are City procedures to identify system components that are experiencing or contributing

to

spills

caused

by

hydraulic

deficiency

and/or

limited

capacity:

● Hydraulic Modeling: The City develops and updates a comprehensive hydraulic computer model

of

its

sewer

collection

system

using

GIS-based

software.

This

model

simulates

flow

under

various

conditions

to

identify

pipe

segments

where

capacity

is

exceeded

based

on

the

ratio

of

water

depth

to

pipe

diameter

(d/D).
● Flow Monitoring: Field flow monitoring investigations are conducted at key locations within the

system

to

measure

actual

flow

characteristics.

This

data

is

crucial

for

calibrating

the

hydraulic

model

and

verifying

previously

identified

deficiencies.
● Master Plan Analysis: The SMP includes a systematic analysis of the City's sewer system capacity.

This

analysis

identifies

deficient

segments

based

on

criteria

derived

from

the

Orange

County

Sanitation

District

(OCSD)

and

the

City’s

General

Plan,

considering

both

existing

and

ultimate

build-out

conditions.

The following are City procedures to identify the appropriate hydraulic capacity of key system elements

for:

● Dry-weather peak flow conditions that cause or contribute to spill events: The hydraulic model

is

run

for

peak

dry

weather

flows,

which

are

determined

using

flow

monitoring

data

to

establish

diurnal

flow

patterns

and

peaking

factors.

The

OCSD

peaking

formula

is

also

17 SSMP City of Orange Updated 2025
utilized for analysis outside of monitored areas. System components exceeding defined d/D criteria

(0.50

for

pipes

<

18 inches,

0.75 for

pipes

≥

18 inches)

under

peak

dry

weather

flow

are

identified

as

potentially

deficient.
● The appropriate design storm(s) or wet weather events that causes or contributes to spill events:

Peak

wet

weather

flows

are

estimated

by

increasing

peak

dry

weather

flows

by

a

factor

to

account

for

rainfall

dependent

inflow

and

infiltration

(I/I).

Estimates

are

based

on

previous

OCSD

studies

and

adjacent

agency

criteria.

Pipes

exceeding

a

d/D

ratio

of

0.90 during

these

estimated

peak

wet

weather

flow

conditions

are

considered

deficient.
● The capacity of key system components: The hydraulic model analyzes the carrying capacity of

individual

pipelines

based

on

factors

like

diameter,

slope,

and

roughness

coefficient

(Manning's

n).

The

capacity

is

evaluated

against

peak

dry

and

wet

weather

flow

estimates

to

determine

if

the

component

can

adequately

convey

the

flow

without

surcharging.

The following are City procedures to identify the major sources that contribute to the peak flows associated

with

sewer

spills:

● Land Use and Population: The SMP utilizes land use data and projected population from the City's

General

Plan

to

estimate

both

existing

and

ultimate

system

flows.

Changes

in

land

use

intensity

and

population

density

are

considered

major

drivers

of

increased

flows.
● Inflow and Infiltration (I/I): Wet weather peak flows are directly influenced by inflow (surface water

entering

through

manholes)

and

infiltration

(groundwater

entering

through

pipe

defects).

Estimates

for

I/I

are

incorporated

into

wet

weather

flow

analyses.

The capacity assessment considers the following:
● Data from existing system condition assessments, system inspections, system audits, spill history,

and

other

available

information:

The

SMP

utilizes

information

on

known

O&M

problem

areas

identified

by

the

Public

Works

Maintenance

Division.

Sewer

Repair

Areas

with

documented

defects

from

video

inspections

(as

noted

in

the

SSRRP)

and

the

history

of

sewer

spill

locations

and

causes

(as

tracked

for

the

SSMP)

inform

the

prioritization

of

capacity

assessments

in

areas

with

a

higher

likelihood

of

hydraulic

deficiencies

contributing

to

spills.
● Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local

and

regional

storm

conditions:

The

estimation

of

wet

weather

flows

in

the

SMP

attempts

to

account

for

increased

I/I

during

storm

events.

● Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-intensity

storm

events

as

a

result

of

climate

change:

The

current

wet

weather

flow

estimation

methodology

in

the

SMP

is

based

on

historical

data

and

does

not

explicitly

model

the

impact

of

larger

or

higher-intensity

storm

events

resulting

from

climate

change.

The

SMP

recommends

a

more

extensive

wet

weather

flow

monitoring

program

for

a

better

understanding

of

I/I

impacts.

As

noted

above,

the

estimation

of

wet

weather

flows

in

the

SMP

attempts

to

account

for

increased

I/I

during

storm

events.
● Increases of erosive forces in canyons and streams near underground and above-ground system

components

due

to

larger

and/or

higher-intensity

storm

events:

.

As

noted

above,

the

estimation

of

wet

weather

flows

in

the

SMP

attempts

to

account

for

increased

I/I

during

storm

events.

18 SSMP City of Orange Updated 2025
● Capacity of major system elements to accommodate dry weather peak flow conditions, and updated

design

storm

and

wet

weather

events:

The

hydraulic

modeling

within

the

SMP

assesses

the

capacity

of

sewer

pipelines

against

calculated

peak

dry

weather

flows

and

estimated

peak

wet

weather

flows

using

established

design

criteria

for

d/D

ratios

and

velocities.

The

SMP

aims

to

provide

a

planning

tool

to

ensure

the

collection

system

can

operate

effectively

under

these

flow

conditions.
● Necessary redundancy in pumping and storage capacities: The SSMP identified the need to replace

aging

pumps

at

the

Hart

Park

and

Stacey

Lee

Lift

Stations,

which

the

SSRRP

notes

as

being

replaced

in

2014.

Requirement: Prioritization of Corrective Action
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.

Condition assessment data is used for prioritization:
● The SSRRP states that a committee comprised of the Public Works Director, City Engineer, and

Maintenance

Manager

will

review

a

list

of

sewer

segments

with

deficiencies

annually

and

prioritize

segments

for

rehabilitation

and

replacement.

This

prioritization

is

based

on

several

factors,

including

the

severity

of

the

deficiency.
● The SSRRP uses the PACP (Pipeline Assessment and Certification Program) rating system to

grade

the

condition

of

sewer

line

segments

from

1 (Excellent)

to

5 (Immediate

Attention).

Segments

receiving

a

grade

of

4 or

5 are

considered

Significantly

Defective.

The

rehabilitation

replacement

focuses

on

sewer

pipes

that

are

at

risk

of

collapse

or

prone

to

more

frequent

blockages

due

to

pipe

defects,

which

correlate

with

higher

PACP

ratings.
● The City will repair or replace all gravity sewer lines previously found to be significantly defective.

This

demonstrates

a

prioritization

based

on

the

potential

consequence

of

a

spill

reaching

sensitive

environmental

areas.

Capacity assessment data is used for prioritization:
● The SMP provides a detailed capacity analysis of the sewer system, identifying hydraulically deficient

pipes

based

on

the

ratio

of

the

depth

of

water

to

the

diameter

of

the

pipeline

(d/D

ratio)

under

both

dry

and

wet

weather

conditions.
● The SMP establishes priority level criteria for deficient pipelines based on the d/D ratio: ○ Critical Priority: d/D > 0.90 in all conditions. This signifies a severe deficiency with a high

potential

for

overflow.
○ High Priority: Dry weather d/D exceeded, wet weather d/D > 0.90. These segments are

also

at

high

risk

of

spilling,

especially

during

wet

weather

events.

○ Low Priority: Dry weather d/D exceeded, wet weather d/D < 0.90. These may be addressed

in

the

longer

term.
● The SRP states that pipelines with a critical priority are to be considered as the City’s top priority

projects

for

capital

improvement.

This

links

the

severity

of

the

hydraulic

deficiency

to

the

urgency

of

corrective

action.

19 SSMP City of Orange Updated 2025
Prioritization considers the severity of consequences of potential spills:
● This Plan emphasizes an annual evaluation of activities to ensure resources are used effectively

and

targeted

to

minimize

sewer

spills.

This

includes

reviewing

sewer

spill

locations,

causes

of

spills,

cleaning

and

videoing

frequency,

the

capital

improvement

program,

and

hot

spot

and

sewer

deficiency

locations.

This

holistic

review

integrates

findings

from

condition

and

capacity

assessments

with

spill

history

to

inform

prioritization.
● The SSRRP notes that prioritization considers "public risk". This implies that deficiencies in areas

with

higher

population

density,

proximity

to

critical

infrastructure,

or

a

history

of

spills

impacting

the

public

health

or

environment

would

likely

be

given

higher

priority.
● The Plan’s SERP details procedures for responding to and reporting spills, including categorization

based

on

whether

the

spill

reaches

surface

waters

or

the

MS4.

This

focus

on

the

potential

for

spills

to

impact

receiving

waters

indicates

that

deficiencies

that

could

lead

to

such

spills

are

prioritized

for

corrective

action.

Requirement: Capital Improvement Plan
The capital improvement plan must include the following items:
● Project schedules including 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.

The SMP, created in 2012, identified existing and future needs for the sewer system and proposed a Capital

Improvement

Program

(CIP)

to

address

these

deficiencies.

This

included

recommendations

for

sewer

main

replacements,

lift

station

upgrades,

and

pipeline

capacity

improvements,

along

with

preliminary

cost

estimations

and

potential

funding

strategies.

The SSRRP further detailed the CIP and its processes: The SSRRP outlines the responsible divisions

within

the

Public

Works

Department

for

carrying

out

the

CIP,

with

the

Maintenance

Division

handling

inspections

and

videoing,

and

the

Engineering

Division

overseeing

updates

to

the

Master

Plan

and

CIP

implementation.

It

also

describes

the

process

for

assessing

sewer

deficiencies

using

CCTV

inspections

and

the

PACP

rating

system,

which

helps

prioritize

rehabilitation

and

replacement

projects.

The

SSRRP

emphasizes

the

need

for

a

capital

improvement

plan

that

addresses

infrastructure

needs

with

a

time

schedule

and

funding

development

plan.

The City’s 2023-24 Five-Year Capital Improvement Plan for the City’s sewer system is in Appendix F.

The

Capital

Improvement

Plan

provides

evidence

of

the

sanitary

sewer

CIP

in

action,

meeting

key

requirements:

It

showcases

specific

ongoing

sewer

projects

and

their

financial

planning,

demonstrating

the

implementation

of

the

recommendations

and

processes

outlined

in

the

earlier

plans.

20 SSMP City of Orange Updated 2025
● Project Schedules and Completion Dates: The Sewer Cleaning & Video project is an ongoing project

with

budget

allocations

from

2023-24

through

2027-28.

This

reflects

the

ongoing

condition

assessment

cycle.

Similarly,

the

Sewer

Line

Maintenance

&

Replacement

project

is

also

ongoing

with

$2.4

million

allocated

in

FY

23-24,

indicating

a

scheduled

annual

program

for

necessary

upgrades.
● Internal and External Funding Sources: The Sewer Cleaning & Video project is funded through

the

"Sewer"

Enterprise

Fund,

an

internal

funding

source

as

discussed

in

our

previous

turn.

The

Sewer

Line

Maintenance

&

Replacement

project

is

also

funded

by

Sewer

funds,

resulting

from

the

2023

Sanitation

Fee

study,

again

representing

an

internal

funding

source.
● Joint Coordination Between Operation and Maintenance, and Engineering Staff: The Sewer Cleaning

&

Video

project

directly

involves

operation

and

maintenance

staff

in

the

initial

assessment.

The

findings

from

these

activities

would

then

inform

the

Sewer

Line

Maintenance

&

Replacement

project,

which

would

be

planned

and

overseen

by

engineering

staff.

This

demonstrates

the

coordination

highlighted

in

the

SSRRP,

where

the

Maintenance

Division

conducts

inspections

and

the

Engineering

Division

manages

the

CIP.
● Interagency Coordination with Other Impacted Utility Agencies: The City coordinates with impacted

utility

agencies,

for

example

the

Irvine

Ranch

Water

District,

regarding

sewer

service

areas.

IX. Monitoring, Measurement and Program Modifications Requirement
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.

The following is the Adaptive Management section that addresses Plan-implementation effectiveness

and

the

steps

for

necessary

Plan

improvement.

Adaptive Management Requirement 1 of 5: Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities.

The City will evaluate its activities annually to ensure that its resources are used effectively and targeted

to

minimize

sewer

spills.

This

includes

the

review

of

sewer

spill

locations,

causes

of

spills,

cleaning

and

videoing

frequency

of

its

sewer

system,

capital

improvement

program

and

21 SSMP City of Orange Updated 2025
hot spot and sewer deficiency locations. This information will be contained in its GIS system for rapid

visual

assessment

or

contained

in

spread

sheets

where

information

can

be

tracked

accurately.

Once

compiled,

the

information

will

be

reviewed

annually

with

the

goal

of

reducing

sewer

spills

and

future

work

will

be

prioritized

accordingly.

Adaptive Management Requirement 2 of 5: Monitoring the implementation and measuring the effectiveness of each Plan Element.

The Plan will be reviewed annually and each program element assessed. Where changes are needed,

the

Plan

will

be

revised.

In

addition,

where

resources

or

changes

are

deemed

more

crucial

to

a

particular

part

of

the

program,

those

changes

will

be

implemented

following

the

annual

review

noted

above.

Adaptive Management Requirement 3 of 5: Assessing the success of the preventive operation and maintenance activities.

The maintenance program will be evaluated on an annual basis to ensure resources are applied where

deemed

necessary.

This

includes

the

review

of

all

relevant

factors

noted

above.

Adaptive Management Requirement 4 of 5: Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations.

The City will review and update the program elements of the Plan annually as noted above to assess

and

measure

their

effectiveness

and

update

as

necessary.

Adaptive Management Requirement 5 of 5: Identifying and illustrating spill trends, including spill frequency, locations and estimated volumes.

As part of the annual review of the Plan program elements, the City will look for trends, frequency,

locations

and

volumes

to

assess

changes

to

its

maintenance

program.

X. Internal Audits
Requirement
The Plan shall include internal audit procedures, appropriate to the size and performance of the system, to comply with section 5.4 (Sewer System Management Plan Audits) of the Order.

The City will undertake the audits of the Plan as specified in Section 5.4. That is, the City will:
● Conduct an internal audit of its Plan, and implementation of its Plan, at a minimum frequency

of

once

every

three

years.
● Conduct each audit for the period after the end of the last required audit period. 22 SSMP City of Orange Updated 2025
● Within six months after the end of the required 3-year audit period, have the Legally Responsible

Official

submit

an

audit

report

into

the

online

CIWQS

Sanitary

Sewer

System

Database

per

the

requirements

in

section

3.10 of

Attachment

E1

of

the

Order.
● Appropriately scale the audit to the size of the system(s) and the number of spills. ● Involve the City’s sewer system operators in completing the audit. ● Evaluate the implementation and effectiveness of the Plan in preventing spills. ● Evaluate compliance with the Order. ● Identify Plan deficiencies in addressing ongoing spills and discharges to waters of the State.
● Identify necessary modifications to the Plan to correct deficiencies. ● Submit a complete audit report that includes: ○ Audit findings and recommended corrective actions. ○ A statement that sewer system operators’ input on the audit findings has been considered.
○ A proposed schedule to address the identified deficiencies.

XI. Communication Program
Requirement
The Plan must include procedures 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.

The City has established a website that describes the Plan and posted companion documents.

Input

from

interested

parties

is

solicited

via

the

website.

23

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