Pacifica City Council
June 23, 2025

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SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only. COPY THIS PAGE AS NEEDED Revision
Date
SSMP
Section
Approval
Date
Description of Change/Revision Made Initials

SSMP CHANGE LOG
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only. COPY THIS PAGE AS NEEDED Revision
Date
SSMP
Section
Approval
Date
Description of Change/Revision Made Initials

LETTER OF COMPLIANCE
© 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City of Pacifica use only. Page i City of Pacifica
Eddie Pastrano, Legally Responsible Official (LRO)
700 Coast Highway
Pacifica, CA 94044
Dear Eddie,
We are pleased to present the new 2025 Sewer System Management Plan (SSMP) Update developed in partnership with City management. The 2025 Update meets and exceeds compliance with the Reissued WDR (State Water Board, Water Quality Order No. 2022-0103-DWQ, Attachment D-10 and Specifications 5.4). The 2025 SSMP has been completely revised to harmonize with industry standard guidelines and incorporates the City’s latest SSMP Audit findings.

The 2025 SSMP is a declaration of what the City is doing to demonstrate full compliance with the Reissued WDR. Attachment A of the Reissued WDR (page A-4), states “A sewer system management plan is a living document an Enrollee develops and implements to effectively manage its sanitary sewer system(s) in accordance with this General Order.” As required, the City will review and update the SSMP as necessary until its next 6-year SSMP Update is completed.

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

Sincerely,
James Fischer, P.E.

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

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

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

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

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

1.3. Sewer System Asset Overview........................................................................................................................................... 8 Specifications 5.2 – SSMP Development and Implementation ................................................................................................ 11 Specifications 5.7 – Allocation of Resources ............................................................................................................................ 12 Provisions 6.1 - Enforcement Provisions.................................................................................................................................. 13 Provisions 6.3 Sewer System Management Plan Availability ................................................................................................... 14

2. ORGANIZATION ......................................................................................................................................15 ......................................................................................................................................................................................... 18

2.1. Organizational Chart........................................................................................................................................................ 18

2.2. Organizational Staffing Responsibilities........................................................................................................................... 19 Chain of Communication for Reporting Spills.................................................................................................................. 21

3. LEGAL AUTHORITY ..................................................................................................................................23

4. OPERATION AND MAINTENANCE PROGRAM ...........................................................................................25

4.1. Updated Map of Sewer System....................................................................................................................................... 25

4.2. Preventive Operation and Maintenance Activities.......................................................................................................... 27

4.3. Training............................................................................................................................................................................ 29

4.4. Equipment Inventory....................................................................................................................................................... 31 Specifications 5.19 - Operations and Maintenance.................................................................................................................. 32

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

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

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

6. SPILL EMERGENCY RESPONSE PLAN.........................................................................................................37

7. SEWER PIPE BLOCKAGE PROGRAM..........................................................................................................39

8. SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS ................................................43

8.1. System Evaluation and Condition Assessment................................................................................................................ 43

8.2. Capacity Assessment and Design Criteria........................................................................................................................ 46

8.3. Prioritization of Corrective Action ................................................................................................................................... 48

8.4. Capital Improvement Plan ............................................................................................................................................... 50

9. MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ...........................................................52

10. INTERNAL AUDITS...................................................................................................................................55

11. COMMUNICATION PROGRAM.................................................................................................................57 LIST OF APPENDICIES......................................................................................................................................59

TABLE OF CONTENTS
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LIST OF FIGURES
Figure 1 - Collection System Operational Report – SWRCB CIWQS.............................................................................. 1 Figure 1-2– Sewer System Management Plan, Subsequent Update and Audit Due Dates..........................................6 Figure 1-3 – City Vicinity Map and Service Area...........................................................................................................9 Figure 5 - City Vicinity Map and Service Area...............................................................................................................9 Figure 6 – City of Pacifica – Department of Public Works/ Wastewater Division - Organizational Chart..................18 Figure 2-2 – .................................................................................................................................................................21 Figure 8 - Chain of Communication for Reporting Spills.............................................................................................21 Figure 9 - City Annual Budget (CEI FY 2024-2029)......................................................................................................50 Figure 8-2 – .................................................................................................................................................................50

LIST OF TABLES
Table 1 - Abbreviations and Acronyms......................................................................................................................... 3 Table 2 - City sewer connection flow classifications and connections data...............................................................10 Table 3 - Implementation Responsibilities .................................................................................................................16 Table 4 - Responsible Position Contact Information ..................................................................................................17

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 1 of 59 Introduction
This Sewer System Management Plan (SSMP) or “Plan” has been prepared for the City of Pacific (City) with technical assistance from Fischer Compliance LLC with the goal of meeting and exceeding compliance with the State Water Resources Control Board 2022 General Waste Discharge Requirements, Order WQ 2022-0103-DWQ for Sanitary Sewer Systems (referred to throughout this document as the WDR). The City provided all details, information and institutional insights for preparation of the SSMP. The document has been developed to meet the size, scale, and complexity of the City, serving as a “living document” used as a tool for managing and operating the City's sanitary sewer collection system. Additionally, the latest 2024 Sewer System Management Plan Guidance Manual published by the Bay Area Clean Water Agencies (BACWA) was utilized as a model for development of the document to harmonize formatting/content and incorporate recommended suggested guidance wherever possible.

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

Figure 1 provides key spill metrics, including data comparing the City’s spill record with state and regional system data. The City consistently performs below both statewide and regional spill rate indices and net spill volumes for all categories of spills from its sanitary sewer collection system.

Figure 1 - Collection System Operational Report – SWRCB CIWQS

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 2 of 59 SSMP Organization
This SSMP is organized into 11 core elements following Attachment D of the WDR, with inclusion of applicable Specifications requirements.

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

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

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

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

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

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

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

OVERVIEW
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 3 of 59 Abbreviations and Acronyms1
BMP Best Management Practices
CCTV Closed Circuit Television
CIP Capital Improvement Program
CIPP Cured in Place Pipe
CIWQS California Integrated Water Quality System (State Water Board Online Spill Database) CMMS Computerized Maintenance Management System
EPA US Environmental Protection City
FOG Fats, Oils and Grease
FSE Food Service Establishment
GCD Grease Control Device
GIS Geographic Information System
I & I Inflow and Infiltration
LRO Legally Responsible Official
NPDES
PM
National Pollutant Discharge Elimination System
Planned Maintenance
RWQCB Regional Water Quality Control Board (Lahontan Region) SCADA Supervisory Control and Data Acquisition
SERP Spill Emergency Response Plan
SOP Standard Operating Procedure
SSMP Sewer System Management Plan
Spill Sanitary Sewer Spill
WDR Sanitary Sewer Systems General Wastewater Discharge Requirements Order issued by the State Water Board (Order No. 2022-0103-DWQ)
SWRCB State Water Resources Control Board
WDID Waste Discharge ID Number (CIWQS)
Table 1 - Abbreviations and Acronyms

GOAL AND INTRODUCTION
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1. Goal and Introduction

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

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

1.1. Regulatory Context

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

COMPLIANCE
The above requirements are addressed below:

The City is committed to fully implementing the WDR2 which includes addressing all requirements by integrating a wide range of programs specifically designed for ensuring the integrity and efficiency of the City’s sanitary sewer collection system. Moreover, the City is dedicated to maintaining its collection system in a systematic manner by implementing various work programs, with a focus on critical areas, to prevent spills, allowing for a comprehensive approach to maintenance. Work programs include CCTV inspections, pipe cleaning, manhole inspections, lift station maintenance, root control, source control and pipe repair, just to name a few. Work programs are described in more detail in Section 4.5 “Specifications 5.19- Operation and Maintenance” of this SSMP.

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

EFFECTIVENESS
The City Collections System has maintained a low spill incidence rate in the past 5 years. The crew is well trained and effective at every level from cleaning to CCTV to Spill response. Collections partnership with engineering and Source Control is seamless and effective. 2 State Water Resources Control Board, Statewide Waster Discharge requirements, General Order for Sanitary Sewer Systems

GOAL AND INTRODUCTION
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IMPLEMENTATION PLAN/SCHEDULE
The City has fully modernized their operation utilizing an effective CMMS to track progress in daily operations, planned maintenance and schedule all aspects of their operation. The New CMMS is a big upgrade from their previous system and will take some time to fully realize the potential with a goal of one year to fully reach optimal utilization. The Collections personnel meet regularly with other key departments and supervisors to ensure they have an effective CIP program.

No. Plan Schedule Responsible Party
Dir Eng Sup

1.1.1 1.1.2

1.1.3 GOAL AND INTRODUCTION
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1.2. SSMP Update Schedule

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

COMPLIANCE
The above items are addressed below:

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

The City’s most recent SSMP audit was completed for the period August 2021 through August 2024.

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

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

1.2.1 Prepare for next SSMP Audit Begin 5/2/2027 X X X

1.2.2 Complete and Upload SSMP audit. By 11/2/2027 X X

1.2.3 Incorporate Audit Findings, update Change
Log and Update SSMP 5/2/2025 X

1.2.4 Board Approval and LRO Certification of
SSMP By 8/2/2031 X X

GOAL AND INTRODUCTION
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1.3. Sewer System Asset Overview

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

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

COMPLIANCE
The above requirements are addressed below:

The City provides collection wastewater services to a 13 square mile service area that includes the City of Pacifica, and no intervening unincorporated areas See Figure 5 below), with an approximate total population in 2023 of 40,000. The City owns 2,592 (waiting for actual number from City) gravity main segments totaling 97.4 miles (with diameters ranging from 6 to 30 inches), 4.2 miles of force main, approximately 12,000 sewer service laterals totaling 227 miles (with diameters ranging from 4 to 6 inches), 5 pump stations, and no sewer mainline siphons. The City does not have any stormwater diversion structures. The City does not own the service laterals.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 9 of 59 The City has a fully effective CMMS system that functions from a GIS backbone. The CMMS system is used to track all maintenance and maintain a material history of all components of the collection system. Due to a recent conversion to a new CMMS not all the material history converted smoothly and will take approximately a year to go through manually to update the system. The City has a fully functional GIS system that is updated when operators discover errors while in the field. The operators will report discrepancies to their supervisor that are submitted to the GIS person to update. Most updates occur within a week of the request.

The City does not own any of the private laterals, the customer is responsible for the entire lateral up to the connection joint to the City system.

Estimated customer connection flow classifications and connection data are presented in Table 2, below, for residential, commercial industrial, and institutional data.

Figure 4 - City Vicinity Map and Service Area

GOAL AND INTRODUCTION
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Residential 98%
Commercial 1%
Industrial/Institutional 1%
Overall, the City is in a good position to maintain its collection system and does not have operation and maintenance challenges due the service area with the exception of extreme King Tides along Beach Blvd.

The City manages the rare tidal events by locking down manholes in the affected area and monitoring flows for Intrusion of tide water.

The City maintains up to date system maps. See Element 4.1 - Updated Map of Sanitary Sewer System for more detail.

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

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

1.3.1 Review City-owned asset
statistics and element
description; update as necessary
At the beginning of the audit cycle and
when significant changes have been made. X X

1.3.2 Update Maps Within 30 Days of Correction Submittal of Completion of Development Project X

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

APPENDIX 1 INCLUSIONS:
• None
Table 2 - City sewer connection flow classifications and connections data

GOAL AND INTRODUCTION
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WDR REQUIREMENTS
Specification. 5.2 (pg. 18)
“To facilitate adequate local funding and management of its sanitary sewer system(s), the Enrollee shall develop and implement an updated Sewer System Management Plan. The scale and complexity of the Sewer System Management Plan, and specific elements of the Plan, must match the size, scale, and complexity of the Enrollee’s sanitary sewer system(s). The Sewer System Management Plan must address, at minimum, the required Plan elements in Attachment D (Sewer System Management Plan – Required Elements) of this General Order. To be effective, the Sewer System Management Plan must include procedures for the management, operation, and maintenance of the sanitary sewer system(s). The procedures must: (1) incorporate the prioritization of system repairs and maintenance to proactively prevent spills, and (2) address the implementation of current standard industry practices through available equipment, technologies, and strategies.”

COMPLIANCE
The above items are addressed below:

This SSMP has been completed updated to meet the requirements of Order WQ 2022-0103-DWQ and address all required Elements and Specifications required by the Order. . The SSMP addresses management, operations and maintenance procedures specific to the City’s collection system. The City maintains a proactive O&M program to operate its system and identify defects, which are then prioritized for repair, replacement, rehabilitation, or placed on modified maintenance schedules. (See Elements 4 and 8 and Specifications 5.19 of this SSMP for more detail).

The City keeps up with current industry standards, technology and best practices by reviewing industry periodicals, networking, vendor visits and attending industry conferences and workshops.

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

COMPLIANCE
The above items are addressed below:

The City maintains various revenue sources to maintain financial stability, meet its operational needs and manage all necessary expenditures to operate its sewer system. Sources of revenue include:
• Revenue 1 Sewer rate charges primarily earmarked for operation and maintenance as well as CIP activities.
• Revenue 2 Connection fees are used for Collection System capacity improvements and Treatment Plant capacity improvements.
• Revenue 3 Permit Fees for connection of ADUs Construction and FSE are used for inspections and management of these programs.

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 13 of 59 Provisions 6.1 - Enforcement Provisions

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

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

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

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

GOAL AND INTRODUCTION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 14 of 59 Provisions 6.3 Sewer System Management Plan Availability

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

COMPLIANCE
The City has loaded this SSMP to the CIWQS database and published it on its website. In addition, the SSMP is available for public review at City offices, by appointment, during regular business hours. The SSMP is also available for revue by the public when posted as part of the Board agenda for approval.

ORGANIZATION
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2. Organization

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

COMPLIANCE
The above items are addressed below:

City’s Legally Responsible Officials (LRO) are listed below:
• LRO 1 – Louis Sun, Deputy Director PW-WW
• LRO 2 – Eddie Pastrano, Collection System Manager
• LRO 3 – Rey Mendez, Assistant Collection System Manager All meet the requirements set forth in Specifications 5.1 of the WDR.

ORGANIZATION
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IMPLEMENTATION RESPONSIBILITIES
Sewer System Management Plan Elements Responsible Position

1. SSMP Plan, Goal and Introduction

1.1. Regulatory Context Collection System Manager

1.2. SSMP Update Schedule Collection System Manager

1.3. Sewer System Asset Overview Collection System Manager

2. Organization Collection System Manager

3. Legal Authority Collection System Manager

4. Operations and Maintenance Program

4.1. Updated maps of Sanitary Sewer System Assistant Collection System Manager

4.2. Preventive Operation & Maintenance Assistant Collection System Manager

4.3. Training Assistant Collection System Manager

4.4. Equipment Inventory Assistant Collection System Manager

5. Design/Performance

5.1. Updated Design Criteria & Construction
Standards
Engineering

5.2. Procedures and Standards Engineering

6. Spill Emergency Response Plan Assistant Collection System Manager

7. Sewer Pipe Blockage Program Assistant Collection System Manager

8. System Eval, Capacity Assurance, Capital Imp.

8.1. System Evaluation and Condition Assessment Engineering

8.2. Capacity Assessment and Design Criteria Engineering

8.3. Prioritization of Corrective Action Engineering

8.4. Capital Improvement Plan Engineering

9. Monitoring, Measurement & Program Modifications Collection System Manager

10. Internal Audits Collection System Manager

11. Communication Program Collection System Manager
Table 3 - Implementation Responsibilities

ORGANIZATION
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RESPONSIBLE POSITION CONTACT INFORMATION
Responsible Position Contact Information Phone Email
Collection System Manager (650) 738-4669 [email protected] Assistant Collection System Manager (650) 738-7475 [email protected] Wastewater Engineering (650) 922-7248 [email protected] Program Coordinator (650) 738-4660 [email protected]
Table 4 - Responsible Position Contact Information

ORGANIZATION
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2.1. Organizational Chart
Figure 5 – City of Pacifica – Department of Public Works/ Wastewater Division - Organizational Chart

ORGANIZATION
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2.2. Organizational Staffing Responsibilities
Director of Public Works:

Under direction, manages the Public Works Department encompassing the Wastewater, Public Works, and Engineering Divisions, performs professional engineering work in connection with the operation of the Wastewater Treatment Plant, and design and construction of streets, storm drainage facilities, solid waste systems, sewers, and other public works; to do related work as required.

Deputy Director of Public Works- WW/CPO:

Under general direction of the Director of Public Works, the Deputy Director of Public Works - Wastewater plans, organizes and directs the activities of the Calera Creek Water Recycling Plant (Plant), the Collection System, and the storm water pump stations; works effectively in a team-based environment, carrying out management, technical, coaching, supervisory, project management, and administrative responsibilities.

Collection System Manager- LRO:

Under the direction of the Director of Wastewater Collections and Plant Operations, plans, organizes, directs, coordinates, supervises and reviews the construction, maintenance, repair and operation of the wastewater collections system, the mechanical equipment and structures used within the wastewater collection system, inflow-infiltration elimination activities, city generators and performs other duties as assigned.

Assistant Collection System Manager:

Under general direction, assist with planning, organizing and supervising the operation, maintenance and repair of the City’s wastewater collections system, supervises, and coordinates assigned City wide programs and operations activities with other departments, divisions and outside agencies. Act as the Collections System Manager as assigned.

WW Engineering Manager:

Under direction of the Director of Public Works, to assist in the administration and supervision of the Engineering Division; to perform professional engineering work; to supervise and review the work of professional and technical staff engaged in the preparation and/or review of plans, specifications, maps, designs, estimates, and inspections of capital improvement, construction, development and maintenance projects; coordinate the work of Engineering Division with the rest of Public Works WWTP Plant Manager:

Plan, organize and manage the activities of the Wastewater Treatment Plant Operation, and coordinate assigned City-wide programs and operations activities with other departments, divisions and outside agencies. Act as the Designated Chief Plant Operator as assigned; perform related duties as required.

Lab Supervisor:

Under general direction and supervision of the Calera Creek Water Recycling Plant Manager, supervises, plan, organizes, directs, and participates in laboratory operations, the Calera Creek Water Recycling Plant (CCWRP) monitoring program, source control programs, storm water and water reclamation, and NPDES compliance. The lab will be full accredited with Environmental Laboratory Accreditation Program (ELAP) and provides service for a designed 3.6 MGD tertiary wastewater treatment plant.

ORGANIZATION
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 20 of 59 Waste Water Treatment Plant Operator III—Programs Coordinator:

Under general supervision, coordinates, implements, and monitors all wastewater collection system programs including but not limited to: private lateral replacement, supplemental environmental projects, smoke testing, fats-oils and grease collection and disposal, lateral compliance certification; coordinates and performs construction inspections on the City’s wastewater collection system; supervises source control inspector; coordinates and performs inspections and sampling of industrial, commercial and residential sources of discharge to the wastewater and storm water systems to ensure compliance with Federal, State and local regulations; performs laboratory analyses to ensure compliance with Federal, State, and local regulations, reviews building plans for compliance with building code regulations; performs data entry, maintenance tasks and related work as required.

Eddie—need a table of SSMP responsibilities completed (see example below)

ORGANIZATION
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2.3. Chain of Communication for Reporting Spills
Service Calls during business hours are received by PWCS Admin Forwarded to Asst. CS Manager
Service Calls after business hours are received by Police Department Non-Emergency Forwarded to the On Call CS Operator
Alarm Calls are received by TP Lead Pump Mechanic
City Receives Call for Service
Response staff respond to all calls, assess the spill event, and take appropriate actions to mitigate the spill. All spill events are mitigated in accordance with the City's Spill Emergency Response Plan (SERP) and are documented in adherence to the WDR Notification, Monitoring, Reporting and Recordkeeping requirements.

City’s Response to Spill Event
The responding field staff submit the field report(s) to Asst. CS Manager who reviews for completeness and accuracy and then confers with CS Manager as a layer of quality control.

Once all information is verified, Data Submitter or LRO submits it to CIWQS.

The City's Legally Responsible Official certifies all spill reports.

City Reports Spill Event
Figure 7 - Chain of Communication for Reporting Spills

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

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

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

Semi-Annually X X

2.2 Review Chain of Communication outcomes for all
spill responses
Each Spill Event X X

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

Semi-Annually X X

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

APPENDIX 2 INCLUSIONS:
• None

LEGAL AUTHORITY
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3. Legal Authority

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

COMPLIANCE
The above items are addressed below:
a. Authority to prevent illicit discharges into the City’s sanitary sewer collection system is provided by Ordinance 181-C.S. Sec 6-10.404
b. The City's pre-planned collaboration and coordination with storm drain agencies. Both divisions are part of the City of Pacifica Public Works Utilities and Operations Department. Both Divisions fall under the same department head and have a seamless collaboration. c. Require that sewer system components and connections be properly designed and constructed.

Controls and guidance are found in City Ordinances, Ord 181-C.S. d. Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee. The City controls Access through Ord 181-C.S. and City owned easements for mainline access through yards and alleyways. e. Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures. Ord 784-C.S. Sections 6-10.803 and 6-10.804. f. Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable. Ord 181-C.S. delineates the requirements of access for maintenance and inspection.

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

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

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

Once per 6-year SSMP
Update Cycle X X

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

Annually X

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

Continuously X X X

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

APPENDIX 3 INCLUSIONS:
• None

OPERATIONS AND MAINTENANCE PROGRAM
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4. Operation and Maintenance Program
WDR Requirements
Att. D-4 (pg. D-4)
“The Plan must include the items listed below that are appropriate and applicable to the Enrollee’s system.”

4.1. Updated Map of Sewer System

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

COMPLIANCE
The above items are addressed below:

System maps include gravity mains, force mains, manholes, pump stations, property boundaries and addresses, creek locations, and storm drain mapping, and pipe asset information (ID number, diameter, flow direction, segment length, material type, and age).

The GIS and system are updated by engineering staff upon request from the Collection System Manager and Asst CS Manager. Once the GIS is corrected these changes are submitted to the CMMS provider and they make changes to the system.

When errors or omissions are discovered by field staff, they report the discrepanciesto the supervisory staff through annotating the workorder, during crew meetings or CCTV feedback.

New facilities accepted by the City are incorporated by the engineering staff upon completion of As-Builts and acceptance CCTV inspection.

The City will make maps available to Water Board Staff upon request, the City will provide State and Regional Water Board staff a link to system maps.

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

OPERATIONS AND MAINTENANCE PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
No Plan Schedule Responsible Party
Dir Eng Sup

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

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

OPERATIONS AND MAINTENANCE PROGRAM
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4.2. Preventive Operation and Maintenance Activities

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

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

COMPLIANCE
The above items are addressed below:

The purpose of a work order system is to program and track all required inspection and maintenance activities within the collection system to help proactively prevent blockages/operational problems or spills.

The City utilizes the MobileMMS Computerized Maintenance Management System (CMMS), which allows the City to make informed decisions regarding its assets and infrastructure by using the collected data from field work orders and documented inspections.

The City’s CMMS maintains historical data for all maintenance activities and provides a basis for critical analysis and data-driven planning and decision-making today and into the future. This allows for prioritizing and planning routine activities such as CCTV inspections, pipe cleaning and pump station maintenance activities.

In addition, the CMMS is used to plan and schedule higher-frequency inspection and maintenance activities such as Enhanced Maintenance (formally known as Hot Spot) cleaning and selective root control activities.

Emergency and other reactive activities are documented in work orders as well to maintain an accurate material history.

The scheduling system allows staff to put certain activities on a preventive schedule where the CMMS automatically create work orders on a prescribed interval. Work orders for other activities are generated by supervisory personnel on an as-needed basis.

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

OPERATIONS AND MAINTENANCE PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

4.2.1 Monitor “Past Due” work orders to ensure critical work is being completed Quarterly X X

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

OPERATIONS AND MAINTENANCE PROGRAM
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4.3. Training

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

COMPLIANCE
The City’s training program covers numerous areas involving or associated with wastewater collection systems and serves to develop and maintain highly qualified, knowledgeable, and capable staff. This training is provided through a variety of modes (self-study, seminars, conferences, on-the-job, etc.) and begins from the first day on the job and continues regularly thereafter.

Staff involved in responding to customer service calls, including sewage spills, receive annual training on the City’s Spill Emergency Response Plan. This training is part classroom and part hands-on exercises and drills for responding to spill events and includes containment, restoring flow, spill volume, volume recovered, spill start time estimations, clean up and completing the spill event data collection forms.

The City trains on their SOPs for bypass pumping, portable generating training and traffic control in addition to an annual review of SOPs with the field crews.

The City provides training to contracted services supervisory staff and provides them with applicable procedures to train their staff.

The City has developed spill response procedures for Contract Service personnel who perform work for the City. The Contract Service personnel are required to:
• Immediately notify the City of any sewage spill they encounter; • Make attempts to contain the spill;
• Cordon off the area to keep the public safe; and
• Remain onsite until City staff arrives and relieves them.

This language is included in service agreements and discussed during pre-job meetings.

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

OPERATIONS AND MAINTENANCE PROGRAM
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IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
Dir Eng Sup

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

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

OPERATIONS AND MAINTENANCE PROGRAM
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4.4. Equipment Inventory

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

COMPLIANCE
The City maintains a host of equipment for both routine maintenance and for contingency or emergency operations. Included in this inventory are all pump station critical repair parts not readily available on short notice that would cause the station to be inoperable. The City maintains a ready on hand supply of emergency line repair parts such as couplings and a variety of piping materials.

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

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

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

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

4.2.3 Ensure contracts with emergency support
services are current Annually X

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

APPENDIX 4 INCLUSIONS:
• None

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

COMPLIANCE
Gravity Main Cleaning:

Collections crews proactively clean all pipes 4 inches to 30 inches in diameter. The core area of the system is scheduled and performed in clusters based on known conditions. All lines are cleaned including easement areas on a one-to-two-year basis, at an average of approximately 90 miles per year.

In general, hydro jetting is utilized for cleaning and maintenance,supplemented by rodding and root cutting where required. The downtown core area has a high concentration of food service establishments (FSEs) that generate significant amounts of FOG and is consequently cleaned quarterly. Easement lines are scheduled for cleaning in clusters in the same manner as the rest of the gravity system.

The City also provides reactive maintenance, which are typically the result of service calls from staff or the public. Quick response from Collections staff often prevent potential spills from occurring, since staff can sometimes clear blockages before a spill occurs. Collections staff can also minimize the impact of spills that do occur by containing and recovering the spill volume as quickly as possible.

Gravity Main Inspection (CCTV):

The City uses CCTV camera units to visually inspect portions of the sanitary sewer system. Currently, CCTV inspection is generally performed on lines subsequent to spill events or problem maintenance areas. The City has completed inspections of their entire system, with a goal to complete an inspection cycle every seven years. Results of this CCTV work sometimes lead to main line and lateral repairs. The City uses a CCTV vehicle to assess system cleaning, repairs and replacements. The vehicle allows for the condition rating of lines. The City utilizes the standard NASSCO scoring system to assess maintenance issues and structural defects. These scores aid in CIP planning as well as emergent repairs. Currently the City is adequately staffed with NASSCO qualified inspectors to perform CCTV and review CCTV for planning purposes. The City has budgeted and is committed to maintaining this staffing.

Manhole Inspections:

The City inspects manholes at the time of cleaning operations. All problem conditions found are then either repaired by Collections staff or contracted for repairs by service contractors. Once the Mobile MMS system is fully functional separate manhole inspection workorders can be issued to expedite complete evaluation of the system. The City has a goal of implementing a formal inspection form and schedule through the CMMS.

Pump Station Inspections/Maintenance:

The City conducts regular maintenance inspections of its five pump stations weekly. Regular mechanical, electrical and/or controls maintenance is performed at the stations on a quarterly basis by collection staff.

OPERATIONS AND MAINTENANCE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 33 of 59 Easement Maintenance:

Easement maintenance is scheduled on an annual basis through the CMMS workorder process. The inspections focus on access and potential damage to the system from vandalism and possible weather conditions causing erosion.

Pipe Repair/Rehabilitation:

The City has an annualsewer rehabilitation and replacement program to rehabilitate orreplace the portions of its wastewater collection system and pump station assets where and when conditions warrant. The annual budgets for all lift station and sewer projects that are included in the City’s Annual Capital Improvement Budget.

In addition to the CIP budget, the collection system staff allocates funds every year to conduct in-house or small project repairs of the wastewater collection system.

Lateral Program:

The City has no responsibility for the installation, maintenance, operation, repair or replacement of private sewer laterals. Beginning on July 1, 2024, the City of Pacifica the City inspects qualifying residents’ sewer laterals for defects, leaks and failures, and provide reimbursement grants for the replacement of qualifying laterals that are leaking due to root infiltration, breaks, cracks, failed pipe, “Orangeburg” pipe, and alignment problems at $2,000. The program will expire on June 30, 2025, or when 100 laterals are replaced, whichever comes first. These inspections will be done on a first come first serve basis and are limited to the first 100 applicants.

DESIGN AND PERFORMANCE PROVISIONS
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5. Design and Performance Provisions

5.1. Updated Design Criteria/Construction Standards/Specifications

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

COMPLIANCE
The City has complete standard specifications and drawings that are maintained by the City Public Works Engineering Division, which meet or exceed industry standards. These standards are used for guidance to all developers, design engineers, contractors, and City departments. The City’s current design and performance standards are addressed in its municipal codes and permitting procedures that allow the City to require and enforce the proper design, construction, and connections to the City’s collection system, and ensure access to the City sewer pipelines for maintaining, inspecting, and repairing the system.

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

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

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

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

DESIGN AND PERFORMANCE PROVISIONS
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5.2. Procedures and Standards

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

COMPLIANCE
Inspecting and Testing
Compliance with the sewer Greenbook requires the contractor performing work on the City’s sewer facilities to be responsible for conducting a CCTV inspection for all new and rehabilitated sanitary sewer systems and other appurtenances. The Greenbook includes procedures and standards for inspecting and testing the installation of sewer mains and related appurtenances and for the rehabilitation and repair of existing sanitary sewer systems. Compliance with the Greenbook specifications requires air tests to be performed in accordance with Section 306-1.1.4. Also, it includes inspection and testing criteria for various pipe materials and installation methods. Sec on 500-1.2.6 requires the Engineer to review pipeline inspection video submitted by the Contractor to verity the pipeline point repair or replacement when retained for construction and installation of wastewater pipelines and manholes prior to backfilling.

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

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

5.2.1 Verify inspection procedures are adequate and
consistent with current standards of practice 2027 (10-year cycle) X

5.2.2 Verify design standards and hydraulic model
previously completed are adequate and
consistent with current standards of practice.
2027 (10-year cycle) X

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

DESIGN AND PERFORMANCE PROVISIONS
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• None

SPILL EMERGENCY RESPONSE PLAN
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6. Spill Emergency Response Plan

WDR REQUIREMENTS
Attachment D-6 (pg. D-6)
“The Plan must include an up-to-date Spill Emergency Response Plan to ensure prompt detection and response to spills to reduce spill volumes and collect information for prevention of future spills.

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

COMPLIANCE
The City’s Spill Emergency Response Plan (SERP) is a stand-alone document that contains all the key elements necessary for an appropriate spill response: notification, emergency incident response, reporting, and impact mitigation. The current plan, prepared by Fischer Compliance, LLC, meets the requirements of the WDR, which became effective on June 5, 2023. Initial training has been provided to affected staff and refresher training is conducted annually. A copy of the SERP is available for viewing at the City office upon request and is found as an appendix to this SSMP.

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

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

6.1 Perform SERP training including practice drills. Annually X X

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

Annually X X

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

APPENDIX 6 INCLUSIONS:
• None

SEWER PIPE BLOCKAGE PROGRAM
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7. Sewer Pipe Blockage Program

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

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

COMPLIANCE
The City has a fully functioning FOG Program that identifies, monitors, and regulates sources of FOG so that spills that result from FOG are minimized. The primary purpose of the program is to reduce the occurrence of FOG-related mainline spills in the service area, although the current level of FOG-related SSOs is extremely low. The City focuses on FSEs to effectively prevent or reduce FOG-related mainline spills. The City currently maintains a list of about 120 FSEs that are regularly inspected and monitored for compliance with the City Municipal Code, in particular Sec 6-1.105 and Sec 6-10.406 regarding grease interceptor requirements for FSEs. The City plans to update the Sewer and Sewage Disposal Code again in the next year for updating local limits. During this update there may also be some updates to the FOG sections and FSE requirements.

The City’s FOG Source Control Program is intended to work in conjunction with the City’s PM program to prevent FOG-related spills. It remains an essential component in meeting and maintaining its projected spill reduction performance goals. The City’s program includes FSE reviews and inspections, enforcement of the City’s Municipal Code sections regarding FOG, and is managed by City staff, an Environmental Program Specialist.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 40 of 59 The elements of the City’s FOG Source Control Program include:
• Requirement for the installation of grease removal devices (GRDs); • Requirement for proper operation and maintenance of GRDs; • Verification of grease handling and disposal practices; • FSE reviews and inspections;
• Public Education and Outreach; and
• Enforcement.

The Source Control Inspector typically conducts at least one review of each FSE per year. The reviews are done on a random basis or grouped by location A review letter is transmitted to the facility or discharger prior to the review with information regarding the review, such as the date and time of the review and what is to be inspected or reviewed. The results of the review are then sent to the FSE in a letter, generally within two weeks following the review. The City is also looking into performing unscheduled inspections at heavy FOG generators or FSEs with multiple corrective actions.

Public education and outreach remain an integral element of the FOG Program. Outreach is provided to FSE staff and management during routine reviews and inspections, as well as through multiple items of correspondence throughout the year. The City has written communication with FSEs at least four times per year in addition to the two site visits or reviews.

The Source Control Inspector checks GRDs as part of the review process and works with FSE staffs in an ongoing, collaborative relationship to stress the importance the City places on review and inspection items.

Frequent contact and meetings with FSEs and their manager/owners have helped to decrease the need for corrective actions in the last five years.

City staff offers assistance to managers and owners of FSEs with demonstrations and education to FSE employees regarding the cleaning and maintenance of under counter GRDs. City staff also offers FSEs a consultation and inspection of a review of grease interceptors to determine the need for their cleaning. If City staff is asked to check a facility's GRD, there is no charge for this service by City staff and no regulatory liability if it is determined there is a need for immediate cleaning.

Any item that needs corrective action as a result of the City's review and inspections are summarized in the review follow-up letter to FSEs. Such a letter lists the review findings and corrections to be made. Each type of correction has a standard follow up date to have the correction completed. The City may send a specific enforcement letter with milestone dates if the conditions discovered at the review or follow up warrant such an action.

The City has begun using MobileMMS, a web-based data management system, to document inspections, follow-ups, corrective actions, and violations. The data management system is a work in progress to back log previous recordsfor FSE’s and enter new information. This system allows for the follow up letters to be generated directly from the inspection data entered. It will also allow for tracking of an individual FSE, analyzing any repetitive corrective actions so that city staff may investigate, follow up and educate those FSE’s more frequently.

The City is currently managing its FOG with a FOG Source Control Program and an aggressive and focused PM program (sewer cleaning). The "downtown" area has a large concentration of FSEs, and this entire area is cleaned quarterly by field crews. There have been no spills caused by FOG in the last year. Public education outreach materials are regularly provided to FSEs as well as the general public.

The City's Municipal Code provides the legal basis and authority for the City’s FOG Control Program; specifically, Sec.6-10.406 regarding requirements grease interceptors for FSEs.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 41 of 59 The City’s FOG Control Program described above in currently meets these requirements Ord 784 C.S. of the Municipal Code, Sewers and Sewage Disposal). Staff also works with FSEs to convey standards, BMPs, maintenance and recordkeeping requirements.

The City’s FOG Control Program involves regular inspections or reviews by the City's Source Control Inspector and enforcement by the City (based upon review findings). The authority to inspect or review is granted by the Municipal Code, as previously stated.

The City’s FOG Source Control Program and its PM program are currently focused on problematic grease dischargers and "high frequency" maintenance or cleaning in the area with the greatest concentration of FSEs. The City adapts to FOG-related problems and issues, if and when they occur. a. Public Outreach: The City makes ligature available on their website for both business and residential customers. The City participates in local festivals distributing best practices literature. The City has several outreach videos available on their website under their Wastewater Division banner and videos. Currently they have videos available for residential FOG, Flushable Wipes, Prescription medicines and commercial FOG.
b. The City disposes of FOG and other blockage materials in two specially marked drying bins at the treatment plant. When these bins are full and dry the material is combined with grit chamber waste and transported to the land fill.
c. City Ord. 181-C.S. Sec. 6-10.403. - Materials prohibited in sewers. No person shall discharge or cause to be discharged any of the following described waters or wastes to any public sewer: (a)Any gasoline, benzene, naphtha, fuel oil, or other flammable or explosive liquid, solid, or gas;(b)Any waters or wastes containing toxic or poisonous solids, liquids, or gases in sufficient quantity (either singly or by interaction with other wastes) to injure or interfere with any sewage treatment process, constitute a hazard to humans or animals, create a public nuisance, or create any hazard in the receiving waters of the sewage treatment plant, including, but not limited to, cyanides in excess of two (2) mg/l as CN in the wastes as discharged to the public sewer;(c)Any waters or wastes having a pH lower than five and five-tenths (5.5) or having any other corrosive property capable of causing damage or hazard to the structures, equipment, or personnel of the sewage works; and(d)Solid or viscous substances in quantities or of such size capable of causing obstruction to the flow in sewers or other interference with the proper operation of the sewage works, such as, but not limited to, ashes, cinders, sand, mud, straw, shavings, metal, glass, rags, feathers, tar, plastics, wood, unground garbage, whole blood, paunch manure, hair, and whole or ground paper, dishes, cups, milk containers, and the like.
d. City Ord. 181 C.S. Sec. 6-10.406. - Grease traps required. Grease, oil, and sand interceptors shall be provided when, in the opinion of the Director, they are necessary for the proper handling of liquid wastes containing grease in excess amounts, or any flammable wastes, sand, or other harmful ingredients, except that such interceptors shall not be required for private living quarters or dwelling units. All interceptors shall be of a type and capacity approved by the Director and shall be located so as to be readily and easily accessible for cleaning and inspection. Failure by the owner to properly clean and maintain such interceptors shall be considered sufficient cause for the disconnection of the premises from the public sewer or punitive action as provided for in this chapter.
e. City Ord. 181-C.S., eff. September 13, 1976) Article 7. - Powers and Authority of Inspectors Sec. 6-

10.701. - Inspections of premises. The Director and other duly authorized employees of the City bearing proper credentials and identification shall be permitted to enter all properties for the purposes of inspection, observation, measurement, sampling, and testing in accordance with the provisions of this chapter.

SEWER PIPE BLOCKAGE PROGRAM
© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for City of Pacifica use only Page 42 of 59 f. The City has developed a list of lines requiring Enhanced Maintenance cleaning due to FOG through observation of field cleaning crews and CCTV Inspections. These lines are scheduled as Enhanced Maintenance areas in the CMMS PM program.
g. The City has an effective Source Control program. FSE’s and Industrial Dischargers are permitted following an initial inspection. Once permitted they are informed both by Source Control Personnel and in writing what their requirements are. The FSE or Industrial Discharger is then placed into a PM program to be periodically inspected. During the inspections the premises are inspected for compliance and records are reviewed to ensure all activities are properly documented.

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

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

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

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

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

APPENDIX 7 INCLUSIONS:
• None

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8. System Evaluation, Capacity Assurance, Capital Improvements

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

8.1. System Evaluation and Condition Assessment

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

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COMPLIANCE
The above requirements are addressed below:
a. The assessment of a collection system involves every component of the City collection system, including pipelines, manholes, and pump stations. The assessment of pipeline condition is the most significant condition assessment responsibility the City has. It is of key importance to regularly perform pipeline condition assessments to initially establish a condition baseline and to monitor condition changes over time.
g. The City currently is converting to the MobileMMS system allowing them to gather data from Cleaning workorder scoring, CCTV Inspections and pump station inspections. This data is assessed by the management staff creating a good current state of material maintenance of the entire system. b. The CS staff is fully NASSCO trained and certified. Utilizing this industry standard system, they are able to assess and target their maintenance and repair efforts to the maximum extent possible. c. Utilizing the data collected in the CMMS and CCTV scoring system the City maintains an effective system.
d. The NASSCO scoring system is an international recognized standard that allows operators and supervisors to gain a good profile of the systems maintenance and repair needs. e. The City is sensitive to the need to locate, assess and mitigate any exfiltration from their system. When the CCTV operators identify infiltration, they assess the possibility of exfiltration when the ground water level drops below the system piping. They are most sensitive to conditions near water bodies and drainage systems.
f. With the utilization of the CMMS system the City is able to maintain an effective and comprehensive documentation system. For special occurrences like spills comprehensive digital and hardcopy records are kept of all field notes, drawing, photographs, videos and after-action assessments. g. The City conducts an annual assessment to identify system assets vulnerable to direct and indirect impacts of climate change, including but not limited to: (a) sea level rise, (b) flooding and/or erosion due to increased storm volumes, frequency, and/or intensity; (c) wildfires; and increased power disruptions. These assessments are reviewed and if needed, incorporated into the City’s CIP program.

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

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

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

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

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

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8.2. Capacity Assessment and Design Criteria

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

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

COMPLIANCE
In 2019 The City contracted Woodard and Curran to conduct and complete system assessment and create a Master Plan that was completed and accepted in August 2021.

Capacity Assessment:

The capacity of the collection system was assessed using a hydraulic model. The assessment focused on the trunk sewer network, the system of pipes that convey flow generated throughout the system to the major pump stations and CCWRP. The modeled network includes all gravity sewers 10 inches in diameter and larger and additional 6- and 8-inch pipes, totaling about 30 percent of the length of sewers in the collection system, plus four of the system’s pump stations and their associated force mains.

Flow loads to the model were developed from customer water use data provided by the City, estimates of additional flows from potential future development (fairly minimal for Pacifica, as the city is largely built out), and from a flow monitoring program conducted for this study. Winter water use data typically provides a very accurate estimate of base wastewater flow (BWF), as outside water use is minimal during that time of year.

Flow monitoring was conducted at 21 sites in the collection system during the winter 2019/20, with rainfall data also collected by three temporary rain gauges. The purpose of the monitoring was to obtain data to confirm base wastewater flows and to quantify the I&I response of the system to rainfall. The flow monitoring data was used to estimate the amount of groundwater infiltration (GWI) and rainfall dependent I&I (RDI&I) for various areas of the system and to confirm, through model calibration, that the hydraulic

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A comprehensive list of recommendations and plan of action schedule can be found in the 2021 Master Plan.

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

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

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

Each significant rain evet
X X

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

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

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8.3. Prioritization of Corrective Action

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

COMPLIANCE
The City prepares an annual list of capital improvement projects that includes projects to address recently identified wastewater collection system capacity issues, and the recommendations found in the Master Plan. Engineering staff prioritize and select the projects to be included on the annual list:

Fiscal Year 2023/2024
• Pump Stations SCADA Communications Project- Provide modern communication hardware and connections with the Calera Creek Water Recycling Plant SCADA system. • Juanita Easement Project – Replacement of approximately 390 linear feet of sewer main along a public utility easement which required significant operations and maintenance resources. Approximately $40,000 construction value.
• Heathcliff Drive / Manor Drive Sewer Replacement – Replacement of a manhole and approximately 125 linear feet of sewer piping.

Fiscal Year 2024 / 2025
• Linda Mar Pump Station Project – Replacement of electrical equipment and engine pump upgrades.

This project has a construction value of approximately $1.1 million. • Lower Linda Mar Rehabilitation and Repair Project – The Lower Linda Mar R&R project includes replacing approximately 30,000 LF of sewer main in the Lower Linda Mar neighborhood to reduce I&I and improve system reliability. This project has a construction value of approximately $8.5 million. • Rockaway Pump Station Rehabilitation and Repair Project – Replacement of the emergency backup generator with a portable generator and associated electrical improvements. $488,000 construction value.

Fiscal Year 25/26
• Linda Mar Peralta Project – Improvements along Linda Mar and Peralta Blvds, including pipe bursting approximately 1000' and open trench replacement (approximately 500 feet) of sanitary sewers.

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

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

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

Each CIP Update
X X

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

Continuously
X X

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8.4. Capital Improvement Plan

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

COMPLIANCE
Refer to previous SSMP and City CIP

EFFECTIVENESS
The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element:
• Has the City’s capital improvement plan schedule been adhered to? Figure 8 - City Annual Budget (CEI FY 2024-2029)

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IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party
GM CSM Coach

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

Annually
X X

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

Each Delayed
Project X

RESILIENCE
Resilience is addressed in Element 7 by:
• Is there an annual review of the Capital Improvement Plan by all appropriate individuals including both Engineering and Operations?
APPENDIX 8 INCLUSIONS
• None

MONITORING, MEASURING, AND PROGRAM MODIFICATION
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9. Monitoring, Measurement, and Program Modifications

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

COMPLIANCE
The above requirements are addressed below:
a. The City maintains accurate and relevant inspection and maintenance records for the collection system. Much of the documentation today is maintained electronically, which allows for ease of access and analysis. This aids City staff to make sound decisions and prioritize activities when dealing with the routine and the unexpected.
b. Monitoring of the City’s SSMP focuses on each element in terms of its implementation and effectiveness. The SSMP has been designed to include key performance indicators for each element, which are used to measure effectiveness. In addition, implementation responsibilities are included for each element to help ensure the SSMP is being implemented as intended. c. The City assesses the success of maintenance and operation activities by ensuing activities are being performed as expected, by monitoring actual outcomes compared to intended outcomes, as well as monitoring spill trends.
d. The City is committed to continuous improvement and monitors and evaluates performance of work programs and SSMP elements to ensure intended outcomes are achieved while looking for areas for improvement. Although the SWRCB requires that the SSMP be updated every six years, the SSMP should be considered as a dynamic document and may require updating on a more frequent basis.

Routine changes to administrative information, notwithstanding, minor changes will likely be required to address improvements identified through the SSMP Audit or through modifications required as conditions change.
e. The City monitors spill trends, at a minimum every three years during required audits, utilizing the CMMS database, inspection records and CIWQS data. These resources are helpful in planning and programing work, and adjusting as needed, enabling the City to be adaptive and capitalize on lessons learned.

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

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

9.1 Assess work programs to ensure
outcomes are as intended.

Annually
X X

9.2 Prepare updates to work programs
and the SSMP based on assessments.

As Needed
X X

9.3 Monitor and evaluate spill trends.

Document efforts.

Annually
X X

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

APPENDIX 9 INCLUSIONS:
• None

INTERNAL AUDITS
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10. Internal Audits

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

COMPLIANCE
The City completed its last audit in Month/Year and will complete audits every three (3) years moving forward. The objective of the audit is to evaluate compliance, implementation and effectiveness of the SSMP. Additionally, the SSMP includes a description of how the City will comply with the requirements of each Element. The audit review includes an evaluation to determine if compliance has been met. • Implementation is evaluated by determining if the City is executing the SSMP as stated. • Effectiveness is evaluated by using key performance indicators, which have been developed specifically for each element. An additional evaluation is performed to comply with Specifications 5.6 addressing resilience.
• Resilience indicators have been developed for each element. These indicators serve to demonstrate how resilience is built into the SSMP and inspection, maintenance and spill response activities.

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

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

INTERNAL AUDITS
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IMPLEMENTATION PLAN/SCHEDULE
No. Plan Schedule Responsible Party

DIR ENG SUP

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

Beginning at end of
audit period X X

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

Once the Audit is
completed X X

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

APPENDIX 10 INCLUSIONS:
• 10.1. 2021-2024 SSMP Audit

COMMUNICATION PROGRAM
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11. Communication Program

WDR REQUIREMENTS
Attachment D-11 (pg. D-10)
“The Plan must include procedures for the Enrollee to communicate with:
• The public for:
o Spills and discharges resulting in closures of public areas, or that enter a source of drinking water; and
o 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:
o System operation, maintenance, and capital improvement-related activities.”

COMPLIANCE
a. When the City experiences a spill, it is standard procedure to secure the affected area and keep the public away. This is generally done using barricades, cones and caution tape. Should the City experience a spill that may require closure of public areas or enter a source drinking of water, signs will be immediately placed indicating the issue and providing contact information. Staff will remain on site to provide an additional safety factor until appropriate authorities respond and direct otherwise. In all cases, the City will follow the advice of higher authorities, such as the local environmental health department and other regulatory authorities.

There are several opportunities for stakeholders and the public to participate and provide input into the development and update of the City SSMP. During its initial development stage, as with each SSMP Audit and update of the SSMP, the SSMP and related documents are presented to the City Board for review and acceptance. As previously noted, SSMP Audits are now performed every three years and re-certification and acceptance of updated SSMPs is now required every six years. In addition to the extensive initial development process, to date there have been five updates and recertifications of the SSMP that have been presented to the Board.

Prior to each Board Meeting, these documents are included in Board Agenda packet which are readily available for review on the City’s website. The SSMP is posted on the City’s website, which provides the public several ways to contact the City, via the “Contact Us” feature. b. The City does not currently have satellite systems.

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

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

11.1 Ensure the Board of Directors
approves the SSMP per schedule.

Every 6 years
X X

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

Annually
X X

11.3 Ensure Sewage Spill Warning signs are
readily available to communicate with
the public when necessary
Annually
X

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

APPENDIX 11 INCLUSIONS
• None

APPENDICIES
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LIST OF APPENDICIES
APPENDIX 1
• None
APPENDIX 2
• None
APPENDIX 3
• None
APPENDIX 4
• None
APPENDIX 5
• None
APPENDIX 6
• None
APPENDIX 7
• None
APPENDIX 8
• 8.1 Capital Improvement Program
APPENDIX 9
• None
APPENDIX 10
• 10.1 2021-2024 SSMP Audit
APPENDIX 11
• None
APPENDIX 12
• None