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
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