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09.D Attachment 2 2026 Pismo SSMP 2026-04-21 ONLINE ONLY

Pismo Beach City Council
April 21, 2026

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09.D Attachment 2 2026 Pismo SSMP 2026-04-21 ONLINE ONLY
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City of Pismo Beach

Sewer System Management Plan

Revision 2 – May 2026

WDID: 3SSO10307

Prepared By:

Attachment 2
Council Agenda 4-21-2026 Item 9.D

Sewer System Management Plan – Revision 02
City of Pismo Beach
May 2026
Page i
City of Pismo Beach

SEWER SYSTEM MANAGEMENT PLAN
Revision 2
WDID: 3SSO10307
May 2026
The Sewer System Management Plan, Revision 2 was created with the assistance of the following City of Pismo Beach and Wallace Group Staff:

City of Pismo Beach Staff
Eric Eldridge, City Engineer: Public Works
Jake Smith, Utilities Manager
Jack Armtrong, Regulatory Compliance Coordinator
Sean Campbell, Wastewater Systems Supervisor
Ryan Provost, Engineer
Wallace Group Staff
Bill Callahan, Senior Environmental Compliance Specialist

Sewer System Management Plan – Revision 02
Certification Statement

City of Pismo Beach
May 2026
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CERTIFICATION STATEMENT
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

______________________________________
Jake Smith
Utilities Manager / LRO

Sewer System Management Plan – Revision 02

City of Pismo Beach
May 2026
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SSMP – REVISION RECORD
The City of Pismo Beach SSMP has undergone the following revisions:

Revision
No.

Revision
Date Description of Revisions
Revision
Completed
By
Revision
Approved By
0 May 2010 Initial SSMP Development City Staff
City Utilities
Manager and
City Council
1 June 2020
Updates based on
findings of SSMP Audit
Report
Cannon
Engineering &
City Staff
City Utilities
Manager and
City Council
2 May 2026
The SSMP was updated
based on the findings of
the 2024 SSMP Audit and
based on regulatory
requirements in the 2022
WDRs.

Wallace Group
& City Staff
City Utilities
Manager and
City Council

Sewer System Management Plan – Revision 02
Table of Contents

City of Pismo Beach
May 2026
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TABLE OF CONTENTS
Acronyms and Abbreviations
SSMP Update and Adoption Record
Introduction
▪ Section 0.1 – Requirement Background
▪ Section 0.2 – Introduction & Executive Summary
Element 1 – Goals, Regulatory Context, Asset Overview and Schedule ▪ Section 1.1 – Regulatory Requirement
▪ Section 1.2 – Sanitary Sewer System Goals
▪ Section 1.3 – Regulatory Context and Schedule for Audits and Updates ▪ Section 1.4 – System Asset Overview and Service Area
Element 2 – Organization
▪ Section 2.1 – Regulatory Requirements
▪ Section 2.2 – Responsible and Authorized Representatives ▪ Section 2.3 – SSMP Program Implementation
▪ Section 2.4 – Chain of Communication for Responding to Sewer Spills Element 3 – Legal Authority
▪ Section 3.1 – Regulatory Requirements
▪ Section 3.2 – SSMP Sanitary Sewer System Legal Authority Element 4 – Operation and Maintenance Program
▪ Section 4.1 – Regulatory Requirements
▪ Section 4.2 – Collection System and Storm Water Maps
▪ Section 4.3 – Preventative Maintenance Program
▪ Section 4.4 – Training

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Table of Contents

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TABLE OF CONTENTS
▪ Section 4.5 – Equipment and Replacement Parts Inventory Element 5 – Design and Performance Provisions
▪ Section 5.1 – Regulatory Requirements
▪ Section 5.2 – Design and Construction Standards and Specifications ▪ Section 5.3 – Inspection and Testing Procedures and Standards Element 6 – Spill Emergency Response Plan
▪ Section 6.1 – Regulatory Requirements
▪ Section 6.2 – Initial Spill Notification Procedures
▪ Section 6.3 – Spill Response Program
▪ Section 6.4 – Spill Notification and Reporting Procedures ▪ Section 6.5 – SERP Training
▪ Section 6.6 – Spill Impact Mitigation Program
▪ Section 6.7 – Spill Coordination with Stormwater Management Agencies and Public Water Systems
▪ Section 6.8 – Post Spill Investigations
Element 7 – Pipe Blockage Control Program
▪ Section 7.1 – Regulatory Requirements
▪ Section 7.2 – Pipe Blockage Control Program Public Education and Outreach ▪ Section 7.3 – FOG Disposal Facilities
▪ Section 7.4 – Discharge Prohibition Legal Authority and Spill Prevention Measures ▪ Section 7.5 – Requirements to Install Grease Removal Devices ▪ Section 7.6 – FOG Control Program Inspection, Enforcement, and Staffing ▪ Section 7.7 – Problem Areas Identification and Sewer Cleaning ▪ Section 7.8 – Other Source Control Measures

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Table of Contents

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TABLE OF CONTENTS
Element 8 – System Evaluation, Capacity Assurance and Capital Improvement Plan ▪ Section 8.1 – Regulatory Requirements
▪ Section 8.2 – System Evaluation and Condition Assessment ▪ Section 8.3 – Capacity Evaluation Design Criteria
▪ Section 8.4 – Prioritization of Corrective Actions
▪ Section 8.5 – Capital Improvement Plan
Element 9 – Monitoring, Measurement, and Program Modifications ▪ Section 9.1 – Regulatory Requirements
▪ Section 9.2 – Data Management
▪ Section 9.3 – Establishing and Prioritizing SSMP Activities ▪ Section 9.4 – Preventative Maintenance Program Assessment ▪ Section 9.5 – SSMP Updates
▪ Section 9.6 – Sewer Spill Trends
Element 10 – Sewer System Management Plan Program Audits ▪ Section 10.1 – Regulatory Requirements
▪ Section 10.2 – SSMP Program Audits
Element 11 – Communication Program
▪ Section 11.1 – Regulatory Requirements
▪ Section 11.2 – Communication Program
▪ Section 11.3 – Satellite & Tributary Systems

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Table of Contents

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May 2026
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TABLE OF CONTENTS
Appendices
▪ Appendix 2A – City Organization Chart
▪ Appendix 7A – Toilets are not Trashcans Flyer
▪ Appendix 7B – Roots, Wipes, and FOG Outreach
▪ Appendix 10A – SSMP Audit and Data Request Template

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Acronyms and Abbreviations

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May 2026
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ACRONYMS AND ABBREVIATIONS
BMP Best Management Practices
CAP Capacity Assessment Plan
Cal OES California Office of Emergency Services
Cal/OSHA California Division of Occupational Health and Safety CCR California Code of Regulations
CCTV Closed Circuit Television
CDFW California Department of Fish and Wildlife
CFR Code of Federal Regulations
CIP Capital Improvement Plan
CITY City of Pismo Beach
CIWQS California Integrated Water Quality System
CMMS Computerized Maintenance Management System
CWEA California Water Environment Association
EHS Environmental Health Services
ELAP Environmental Laboratory Accreditation Program
EOP Emergency Operating Procedure
ENROLLEE City of Pismo Beach
EPA Environmental Protection Agency
FOG Fats, Oil, and Grease
FSE Food Services Establishment
HMA High Maintenance Area
I/I Inflow & Infiltration
IIPP Injury and Illness Prevention Program
IWF Industrial Waste Facility
LRO Legally Responsible Official
mgd Million Gallons per Day
MRP Monitoring and Reporting Program (Used in this SSMP to reference MRP Order No. 2022-0103-DWQ.)
SERP Spill Emergency Response Plan
OES Office of Emergency Services
O&M Operation and Maintenance
OSHA Occupational Safety and Health Administration

Sewer System Management Plan – Revision 02
Acronyms and Abbreviations

City of Pismo Beach
May 2026
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ACRONYMS AND ABBREVIATIONS
PLSD Private Lateral Sewage Discharge
PM Preventative Maintenance
PPE Personal Protective Equipment
R&R Rehabilitation and Replacement
RWQCB Central Coast Regional Water Quality Control Board SCADA Supervisory Control and Data Acquisition
SECACIP Sewer Evaluation, Capacity Assurance and Capital Improvement Plan SMP Sewer Master Plan
SOP Standard Operating Procedure
SSMP Sewer System Management Plan
SPILL Sanitary Sewer Spill
SSS Sanitary Sewer System
SWRCB State Water Resources Control Board
WDR Waste Discharge Requirements (Used in this SSMP to reference WDR Order No. 2022-0103-DWQ, the Statewide General WDR for SSSs.)

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Introduction

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INTRODUCTION
This Sewer System Management Plan (SSMP) six (6) year update was performed in compliance with the requirements of the State Water Resources Control Board (SWRCB) Statewide General Waste Discharge Requirements (WDR), Order No. 2022-0103-DWQ, which are available at the City Public Works Office and on the State Water Resources Control Board website: https://www.waterboards.ca.gov/water_issues/programs/sso/ .

0.1 Requirement Background
The WDRs require all public wastewater collection system agencies in California that own and operate sanitary sewer systems greater than one mile in length, which collect or convey untreated or partially treated wastewater to a publicly owned treatment facility, to develop, implement, and maintain a SSMP and report sanitary sewer spills(Spills) using the State’s electronic reporting system, California Integrated Water Quality System (CIWQS).

The City of Pismo Beach (City) SSMP includes the following eleven (11) Elements:

1. Goal

2. Organization

3. Legal Authority

4. Operation and Maintenance Program

5. Design and Performance Provisions

6. Spill Emergency Response Plan

7. Pipe Blockage Control Program

8. System Evaluation, Capacity Assurance and Capital Improvement Plan

9. Monitoring, Measurement, and Program Modifications

10. Sewer System Management Plan Program Audits

11. Communication Program
Each SSMP Element is prefaced with the associated WDR section and narrated with the City’s policies and procedures, which address the respective SWRCB requirement.

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EXECUTIVE SUMMARY
The State Water Resources Control Board’s (SWRCB’s) Statewide General Waste Discharge Requirements (WDR) for Sanitary Sewer Systems, Order No. 2022-0103-DWQ require the City of Pismo Beach (City) to have and maintain a Sewer System Management Plan (SSMP), which provides a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system in order to help reduce and prevent sanitary sewer spills (Spills), as well as mitigate any Spills that do occur.

The SSMP includes the following eleven (11) Elements:

Goal
City goals, which are included in the SSMP, are:
• To properly manage, operate, and maintain all aspects and components of the City’s wastewater collection system.
• To provide the wastewater collection system with adequate capacity to convey peak wastewater flows.
• To minimize the occurrence of sewer spills to the extent possible. • To mitigate the impacts that are associated with any sewer spill that may occur. • To meet all regulatory requirements related to the SSMP and sewer spill reporting system.

Organization
The Organization Element of the SSMP identifies City and Contract Staff, who are responsible for implementing the SSMP, responding to sewer spills, and meeting sewer spill reporting requirements, and identifies the lines of authority of SSMP responsibilities and chains of communication for sewer spill response and reporting. The Legally Responsible Officials (LRO) are also designated in this SSMP Element in order to meet the SWRCB requirements for completing and certifying sewer spill reports in the SWRCB’s online regulatory information database and tracking system, California Integrated Water Quality System (CIWQS).

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Legal Authority
This SSMP Element outlines the City Municipal Code Chapters and Ordinances that provide the City with the legal authority to:
a. 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;
b. 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;
c. Require that sewer system components and connections be properly designed and constructed;
d. Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee;
e. Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and
f. Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable.

Operation and Maintenance Program
City operation and maintenance of its collection system ensures that the system is kept in good working condition, and this SSMP Element outlines the work that is conducted to accomplish the optimal operation and maintenance of the City collection and conveyance system. This SSMP Element details the following:
a. Up-to-date maps of the sanitary sewer system, and procedures for maintaining and providing State and Regional Water Board staff access to the maps. The maps must show gravity line segments and maintenance holes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities within the sewer system service area boundaries.; b. A scheduling system and a data collection system for preventive operation and maintenance activities conducted by staff and contractors. a. The scheduling system includes:
i. Inspection and maintenance activities;
ii. Higher-frequency inspections and maintenance of known problem areas, including areas with tree root problems;
iii. Regular visual and closed-circuit television (CCTV) inspections of maintenance holes and sewer pipes.

The data collection system documents data from system inspection and

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Introduction

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maintenance activities, including system areas/components prone to root- intrusion potentially resulting in system backup and/or failure. c. In-house and external training provided on a regular basis for sanitary sewer system operations and maintenance staff and contractors. The training covers:
i. The requirements of this General Order;
ii. The Enrollee’s Spill Emergency Response Plan procedures and practice drills;
iii. Skilled estimation of spill volume for field operators; and iv. Electronic CIWQS reporting procedures for staff submitting data. d. An inventory of sewer system equipment, including the identification of critical replacement and spare parts.

Design and Performance Provisions
The Design and Performance Provisions Element describes the standards and specifications for new construction, repair of the existing sanitary sewer system, and the inspection and testing of these items.

Spill Emergency Response Plan
The Spill Emergency Response Plan (SERP) contains the following information in order to protect public health and the environment in the event of a sewer spill:
a. Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill in a timely manner;
b. 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;
c. Comply with the notification, monitoring and reporting requirements of this General Order, State law and regulations, and applicable Regional Water Board Orders;
d. Ensure that appropriate staff and contractors implement the Spill Emergency Response Plan and are appropriately trained;
e. Address emergency system operations, traffic control and other necessary response activities;
f. Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system;
g. Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of the State;
h. Remove sewage from the drainage conveyance system;

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i. Clean the spill area and drainage conveyance system in a manner that does not inadvertently impact beneficial uses in the receiving waters; j. Implement technologies, practices, equipment, and interagency coordination to expedite spill containment and recovery;
k. Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event; l. Conduct post-spill assessments of spill response activities; m. Document and report spill events as required in this General Order; and n. Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update the Plan as needed.

Pipe Blockage Control Program
The goal of the Pipe Blockage Control Program is to reduce and/or eliminate the amount of pipe blocking materials such as fats, oils and grease wipes, roots, etc., that may be discharged to the sanitary sewer system. This is implemented through public outreach, operations and maintenance activities, investigations and FOG Program inspections.

System Evaluation, Capacity Assurance, and Capital Improvement Plan The City completed a Wastewater Collection System Master Plan, in 2000. The 2000 Master Plan recommended improvements to address the City’s system deficiencies at that time and to recommend improvements to plan for future development. Some of the projects identified in Section 8.5: Capital Improvements are a result of this analysis.

The City recently started the development of an updated Sewer Master Plan that was initiated in 2025. The System Evaluation and Condition Assessment is planned to identify areas that are capacity deficient and/or structurally deficient under existing and future conditions. Recommended capital improvement projects will be prioritized as a result of this analysis. The scope of work includes required criteria identified in the 2022 WDRs.

Monitoring, Measurement, and Program Modifications
The City monitors the implementation of the SSMP Elements in order to measure the effectiveness of the City SSMP program in reducing sewer spills. This SSMP Element outlines the manner in which each SSMP Element is monitored and evaluated and the schedule with which the City completes this monitoring and evaluation.

Sewer System Management Plan Program Audits
The SSMP Program Audits Element outlines the audit process and identifies City Staff responsible for conducting or participating in SSMP Program Audits and generating the required SSMP Program Audit Report. SSMP Program Audits must occur at a minimum of every three (3) years and are required to evaluate the City SSMP Program, identify program deficiencies, and provide an improvement schedule based on the audit findings.

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Introduction

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Communication Program
This SSMP Element describes the manner in which the City communicates the development, implementation, and performance of its SSMP with the public in order to provide them with the opportunity to provide input as the SSMP program is developed and implemented.

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Element 1 – Goal

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ELEMENT 1 - GOALS, REGULATORY CONTEXT, ASSET OVERVIEW AND

SCHEDULE
The City of Pismo Beach (City) has the following goals for the management and maintenance of the sanitary sewer collection system. These goals provide focus for City Staff to continue high- quality work to operate and maintain City facilities and to implement improvements for management of the collection system to prevent sanitary sewer spills (Spills). The role of the SSMP in supporting these goals is discussed below.

These goals will be evaluated annually in Element 9: Monitoring, Measurement and Program Modification to assess the City’s success in implementing and meeting the objectives of these goals.

1.1 Regulatory Requirement
WDR Order No. 2022-0103-DWQ Attachment D1 states:

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.

1.2 Sanitary Sewer System Goals
The City seeks to provide high quality and reliable wastewater collection and conveyance for its residents and businesses.

City SSMP Goals to:
• Properly manage, operate, and maintain all aspects and components of the City’s wastewater collection system.
• Provide the wastewater collection system with adequate capacity to convey peak wastewater flows.
• Minimize the occurrence of sewer spills to the extent possible. • Mitigate the impacts that are associated with any sewer spill that may occur. • Meet all regulatory requirements related to the SSMP and sewer spill reporting system.

1.3 Regulatory Context and Schedule for Audits and Updates As required by Statewide Sanitary Sewer Systems General Order 2022-0103-DWQ, the SSMP contains several elements which are referenced in the table of contents that will help the City accomplish the goals mentioned in this element. The City is dedicated to implementing each Element of the SSMP and tracking any revisions that may be necessary as program implementation progresses. The current 2025 SSMP update was completed prior to the due date of May 2, 2026.

The City will begin their next SSMP Audit after May 2, 2028, Audit Period End Date with an identified Audit period of May 2, 2025, through May 2, 2028, for completion by November 2, 2028. The Audit will evaluate how the SSMP meets regulatory requirements, implementation of the SSMP, success of preventative maintenance program, and sewer spill trends. A plan and

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Element 1 – Goal

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schedule will be developed for the correction of any deficiencies identified in the audit and any necessary updates or general plan changes that may be required.

The City will annually review and evaluate the SSMP, Preventative Maintenance Program, and Spill Trends to identify areas of their sewer operations that may need to be modified to comply with existing regulatory requirements and reduce the number of sewer spills occurring in a calendar year.

The SSMP 6-Year Update will begin on or before January 2, 2032 for completion, adoption and recertification by May 2, 2032.

In addition to the SSMP Update and SSMP Audit discussed above, the City has identified additional near-term compliance dates as required by General Order WQ-2022-0103-DWQ:
• Annual Report of Category 4 Non-Lateral Spills: February 1st of each calendar year • Annual Report: April 1st of each calendar year

1.4 System Asset Overview and Service Area
The City of Pismo Beach is a public agency providing services to residential and commercial establishments and visitors. The City maintains the sewer collection and conveyance system.

This system is connected to a trunk sewer system and Wastewater Treatment Plant owned and operated by the City.

The City sewer collection and conveyance system is located in San Luis Obispo County with a three and a half (3.5) square mile service area and consists of approximately 40 miles of gravity pipelines, which vary in diameter from 4-inch to 18-inches, twelve (12) City-owned lift stations, and approximately 8.5 miles of force mains. Approximately 64% of the City’s collection system was constructed before 1980 and is primarily Vitrified Clay Pipe (VCP). The remaining 36% of the system was constructed from 1980 to present and is primarily Polyvinyl Chloride Pipe (PVC).

There are 1001 manholes throughout the system. The sewer system is restricted to providing sanitary sewer flows only with no diversion of stormwater into the sewer system.

The following table shows the various gravity pipeline sizes:

Pipe Diameter (Inches) Gravity Pipe
Length (Miles)
Force Main Pipe
Length (Miles)
Total
Miles
Percent of
Sewer System
3” 0 0.05 0.05 1%
4” 0.33 0.53 0.86 1%
6” 11.84 0.48 12.32 25%
8” 23.71 1.55 25.26 51%
10” 1.94 1.46 3.4 6%
12” 1.97 3.94 5.91 13%
15” 0.36 0 0.36 1%
16” 0 0.46 0.46 1%
18” 0.20 0 0.20 1%
TOTAL 40.35 8.47 48.82 100%
Table 4-1: Sewer Pipe Sizes

Table 4-2 illustrates the current age of sewer lines in the system.

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Sewer Line Age Percent of Sewer System
Year 2000 to Present 3%
1980 to 1999 33%
1960 to 1979 32%
1940 to 1959 32%
1900 to 1939 0%
Table 4-2: Sewer Pipeline Age
The City serves a population of approximately 11,114 people¹. The City system includes approximately 3,000 sewer laterals. Sewer system customers are broken down as follows:

Type of Connection % of Total Connections
Residential 90%
Commercial 10%
Industrial 0%
Total 100%
Table 4-3: Sewer Connection Types
A general overview showing the service area boundaries is provided below.

Figure 4-1: Sewer System Overview

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Element 1 – Goal

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¹ US Census Population Data, 2024
Data management for the operations and maintenance of the sewer systems is provided utilizing the “City Wide” computer-based maintenance program.

Sewer laterals are owned, operated and maintained by individual property owners from the wye connection at the sewer main, back to each building. The City does not own or maintain any sewer laterals within the service area other than laterals on City owned property.

The City utilizes the following 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 (every six years)?
• Are specific internally established sewer program milestones being monitored? • Are asset statistics periodically reviewed and updated as necessary? • Are system sewer and stormdrain maps up to date?
System Resilience is addressed in Element 1 by:
• Redundancy: More than one member of staff is trained and able to retrieve and manage SSMP data.
• Implementing a QA/QC process to help ensure information is accurate. • Continuous improvement with input from the field (ex: map updates). • Using Outlook calendar reminders or work orders to ensure compliance deadlines are met.

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ELEMENT 2 - ORGANIZATION
The Organization Element of the SSMP identifies City of Pismo Beach (City) staff that are responsible for the management and implementation of this SSMP. This Element identifies staff’s responsibilities responding to sewer spill events, and meeting sewer spill reporting requirements. The Legally Responsible Officials (LRO) are designated below to meet SWRCB requirements for completing and certifying sewer spill reports in the California Integrated Water Quality System (CIWQS).

This SSMP Element outlines the City organization, SSMP responsibilities of personnel, authorized representatives, and chains of communication for sewer spill response and reporting.

2.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Attachment D 2 states:

The collection system agency’s SSMP must identify:
a) The name of the Legally Responsible Official defined in this Order; b) The position titles, telephone numbers, and email addresses for management, administrative, and maintenance positions responsible for implementing specific Sewer System Management Plan elements;
c) Organizational lines of authority; and
d) Chain of communication for reporting spills from receipt of complaint or other information, including the person responsible for reporting spills to the State and Regional Water Boards and other agencies, as applicable. (For example, county health officer, county environmental health agency, and State Office of Emergency Services.) WDR Order No. 2022-0103-DWQ Section 5.1 states:

The Enrollee shall designate a Legally Responsible Official that has authority to ensure the enrolled sanitary sewer system(s) complies with this Order and is authorized to serve as a duly authorized representative. The Legally Responsible Official must have responsibility over management of the Enrollee’s entire sanitary sewer system and must be authorized to make managerial decisions that govern the operation of the sanitary sewer system, including having the explicit or implicit duty of making major capital improvement recommendations to ensure long-term environmental compliance. The Legally Responsible Official must have or have direct authority over individuals that:
• Possess a recognized degree or certificate related to operations and maintenance of sanitary sewer systems, and/or

• Have professional training and experience related to the management of sanitary sewer systems, demonstrated through extensive knowledge, training and experience.

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2.2 Responsible and Authorized Representatives
The name of the authorized representatives described in WDR Section 5.1 above is listed in Table 2-1:

Table 2-1: City of Pismo Beach Authorized Representatives Name Title CIWQS Database
Jake Smith Utilities Manager Legally Responsible Official Sean Campbell Wastewater Systems Supervisor Legally Responsible Official Jack Armstrong Regulatory Compliance
Coordinator Legally Responsible Official

2.3 SSMP Program Implementation
An organization table showing the lines of authority for the City is described below in Table 2-2 and updated City Organization Chart which show lines of authority and Staff Contact List can be found in Appendix 2A.

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Table 2-2: City of Pismo Beach SSMP Responsibilities and Contact Information Name and Title SSMP Responsibilities Contact Information City Council
Ed Waage
Mayor

Mary Ann Reiss
Mayor Pro Tem

Marcia Guthrie
Councilmember

Stacy Inman
Councilmember

Scott Newton
Councilmember

The City Council annually adopts a
budget in which funding would be
allocated for SSMP related tasks.

The City Council is also responsible
for considering and approving
updates to the City’s SSMP.

(805) 550-3345
[email protected]

(805) 709-6296
[email protected]

(805) 709-0500
[email protected]

(661) 699-0914
[email protected]

(805) 419-3448
[email protected]

Jorge Garcia

City Manager
The City Manager coordinates and
directs all departments of the City.

Office: (805) 773-7007
[email protected]
Dean Pucci

City Attorney
The City Attorney assists in the
management of Element 3, Legal
Authority.

Office: (916) 771-0635
[email protected]
Rosemarie Gaglione
P.E.

Public Works
Director
The Public Works Director oversees
City staff in the implementation of all
eleven (11) SSMP Elements.

Office: (805) 773-7037
[email protected]
Jake Smith

Utilities Manager

The Utilities Manger is responsible for
the overall management of the SSMP
and specifically directs the
implementation of:
• Element 1 – Goal;
• Element 2 – Organization;
• Element 3 – Legal Authority;
Office: (805) 773-7075
[email protected]

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Name and Title SSMP Responsibilities Contact Information • Element 4 - Operation and
Maintenance Program;
• Element 5 – Design and
Performance Provisions;
• Element 6 – Spill Emergency
Response Plan;
• Element 7 – Pipe Blockage
Control Program;
• Element 8 – System
Evaluation, Capacity
Assurance and Capital
Improvement Plan;
• Element 9 – Monitoring,
Measurement, and Program
Modifications;
• Element 10 – SSMP Audits;
and
• Element 11 – Communication
Program

The Utilities Manager is assisted by
the Regulatory Compliance
Coordinator, Wastewater Systems
Supervisor, and Sewer System
Operators to manage and implement
these Elements.

2.4 Chain of Communication for Responding to Sewer Spills Collections System:

Notifications of possible spills are received via telephone calls. All telephone calls or complaints for actual or potential spills are routed directly to the City’s Public Works Office (805) 773-4656 and then to the On Call Operator or Utilities Manager via City office personnel. During non- business hours, the City’s Dispatch (805) 773-2208 (or 911) will receive the call and notify the City’s On-Call Operator.

Lift Stations:

The City’s On-Call Operator, Operations staff and Utilities Manager are responsible for responding to alarm notifications for lift station failures. The City operates and maintains 12 lift stations which are monitored continuously via supervisory control and data acquisition (SCADA). The SCADA system provides operators real time pump station monitoring. Staff is required to respond to all alarms within 30 minutes of a call out. If the first responding Operator requires assistance, they will contact the Utilities Manager (805) 904-8362 or Lead Operator (949) 374-6621 and/or other City Operations staff.

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The City of Pismo Beach procedure is to report all Category 1, 2, 3, & 4 spills as required by the Statewide General Order.

In the event of a report of a possible wastewater spill, or when Staff is contacted concerning odors, standing water or an overflowing manhole, the following steps are taken to verify the report and ensure the safety of the public.

1. The receiver of the call (City Staff or after-hours Dispatch) will obtain the location from the caller and any description they may have of the problem. Staff will fill in a Sewer Incident Report Form (Spill Response Checklist) and obtain caller name and phone number for follow-up information if necessary.

2. The call receiver will contact the Utilities Manager or On Call Staff by phone immediately who will direct Maintenance Staff to the described location.

3. Maintenance Staff will proceed to the location to verify report.

4. If warranted the Utilities Manger or their designee may request further support. If a Maintenance Staff member is dispatched they will keep management informed of progress as necessary.

5. The first responder or his delegate will notify Utilities Manager.

6. The Utilities Manager will notify all appropriate public agencies as described in Element 6 Spill Emergency Response Plan.

Upon completion of containment and clean-up, Utilities Manager will use the Spill Reporting Form to complete the final spill reports to the CIWQS database, RWQCB, , and the SLO County Environmental Health Department as needed. The following flowchart shows the current spill response chain of command. This Chain of Command is updated as necessary to reflect

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changes in staffing as warranted.

Figure 2-1: Sewer Spill Response Chain of Command
SSMP Element 6 – Spill Emergency Response Plan contains a chain of communication for reporting Spills for use in the field by the Operations Staff in Figure 6—1 which is the same as Figure 2-1 above.

Sewer Spill notification is outlined in the City’s – Spill Emergency Response Plan. The contact information and notification requirements associated with notifying Cal OES and other applicable agencies, such as SLO County Environmental Health Division, are included in that SSMP Element.

Upon completion of containment and clean-up, the Utilities Manager initiates the Draft Sewer Spill Report in CIWQS.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
• Have there been any changes requiring updates to the Organizational Chart? • 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? Resilience is addressed in Element 2 by:

After-hours
Contacts
Observer
Notifies City Office
(805) 773-4656
After Hours
Observer directed
to Call 911

Emergency Phone #
911 or (805) 773-
2208

Wastewater Staff
Responds

On Call Staff is
contacted

Wastewater Staff
Mitigates Spill
Utilities Manager
(805) 779-0627 or
(949) 374-6621

Compile CIWQS
Data:

On Call Staff and
Utilities Manager
Spill Notification & Reporting to
Appropriate Agencies

If additional
resources are
necessary

If no
additional
resources
are
necessary

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• Ensuring that more than one person is capable and responsible for specific duties for Sewer System Management Plan 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.

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ELEMENT 3 - LEGAL AUTHORITY
The City of Pismo Beach (City) maintains the legal authority for the sanitary sewer system in the City Municipal Code sections listed below. These Codes are on file at the City Office and can also be located on the City Website: https://www.pismobeach.org/149/Municipal-Code .

3.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Attachment D 3 states:

The wastewater collection system agency must include copies or an electronic link to the Enrollee’s current sewer system use ordinances, service agreements and/or other legally binding procedures to demonstrate the Enrollee possesses the necessary legal authority to:
a) Prevent illicit discharges into its sanitary sewer system from inflow and 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;

b) 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;

c) Require that sewer system components and connections be properly designed and constructed;

d) Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee;

e) Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and

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

3.2 SSMP Sanitary Sewer System Legal Authority [WDR D 3 (a) – (f)] Table 3-1 below provides the mechanisms by which the City maintains the legal authorities required by the WDRs for public and private sewer systems. Theses Codes and Ordinances can be found in the link identified above.

Table 3-1: City Legal Authority References
WDR Requirement City Code
D 3 (a) Prevent illicit
discharges into its sanitary
sewer system (examples
may include Inflow &
Infiltration (I/I), storm water,
chemical dumping,
unauthorized debris and cut
• Chapter 13, Section 13.14.221: prohibits the discharge of materials that will adversely affect humans or the
environment, including wastes that cause, threaten to
cause, or capable of causing, either alone or by
interaction with other substances.
• Chapter 13, Section 13.14.222 prohibits the discharge

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WDR Requirement City Code
roots, etc.). of any rainwater, stormwater, groundwater, street drainage, subsurface drainage, or yard drainage into
any pipe that is in any way connected to the City’s
sanitary sewer collection facilities.
• Chapter 13, Section 13.14.223 specifies that the use of diluting waters is prohibited.
• Chapter 13, Section 13.14.224 specifies that the
discharge of unpolluted water, such as cooling water,
process water, or blowdown from cooling towers or
evaporative coolers, into the City’s sanitary sewer
system is prohibited unless authorized by the City.
• Chapter 13, Section 13.14.225 prohibits the discharge of radioactive wastes into the sanitary sewer system,
unless approved by persons authorized to use
radioactive materials by the State Department of Health or other appropriate governmental agencies.
• Chapter 13, Section 13.14.227 specifies that wastes
that have been collected and held in tanks or
containers may not be discharged into the system,
unless prior approval has been obtained in writing from the Director of Public Works and payment of processing
charges has been paid. Stored liquid waste refers to
septic tank pumping’s, chemical toilet wastes, pleasure boat wastes, industrial wastes collected in containers or tanks, oils and greases, and any other material
classified as domestic waste.
•
D 3 (b) Collaborate with
storm sewer agencies to
coordinate emergency spill
responses, ensure access to
storm sewer systems during
spill events, and prevent
unintentional cross
connections of sanitary
sewer infrastructure to storm
sewer infrastructure
The City is responsible for the storm drain system within the City service area. Coordination occurs internally.

D 3 (c) Require that sewers
and connections be properly
designed and constructed;
Chapter 13: Public Services
▪ Sections 13.14.140 through 13.14.150 establish the
requirements for the design and construction of
sanitary sewers and connections.
▪ Section 13.14.141 requires an independent building

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WDR Requirement City Code
sewer for every building and parcel in the City.
▪ Section 13.14.142 specifies that the size, slope,
alignment, materials of construction, and methods
used to excavate, place pipe, joint, test, and backfill trenches for building sewer must conform to the
building code requirements, plumbing code, or other
applicable City regulations.
▪ Section 13.14.145 specifies inspection and testing of new connections is required to be made in the
presence of the Director of Public Works or their
representative.

D 3 (d) Ensure access for
maintenance, inspection, or
repairs for portions of the
lateral owned or maintained
by the Public Agency;
The City does not own any portion of private sewer laterals in the service area however the following code give them access to sewer laterals.

The Cities Municipal Code does provide access to all areas of the sewer system in Section 13.14.228 which provides
provisions to provide maintenance, inspection, and repair access for the City’s sanitary sewer facilities. This section specifies that the Director of Public Works, the County health officer, or any authorized representative of the public works department or health department is authorized to make
inspections as such department may deem necessary at any reasonable time in any building, premises, or lot.

D 3 (e) Enforce any violation
of its sewer ordinances.

City has the authority to enforce violation of its sewer ordinances, service agreements, or other legally binding procedures in the sanitary sewer system in the following Municipal Code sections:
▪ Sections 13.14.410 through 13.14.440 of the City’s
Municipal Code establish the City’s enforcement
requirements, citation authority, and violation
penalties.
▪ Section 13.14.410 states it is the responsibility of the Director of Public Works to enforce the provisions of
Chapter 13.14 of the City’s Municipal Code.
▪ Section 13.14.420 of the City’s Municipal Code
establishes the City’s authority, as provided in Section 836.5(a) of the California Penal Code, to issue
citations and make arrests for violations of the City’s sanitary sewer system ordinances.

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WDR Requirement City Code
▪ Section 13.14.440 establishes penalties for violations.

D 3 (f) Obtain easement
accessibility agreements for
locations requiring sewer
system operations and
maintenance, as applicable
• Title 16 Subdivisions, Chapter 16.40 Standards and
Requirements, Section 16.40.120 states that utility
easements may be required not less than 8 feet in
width.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
• Are the City ordinances and standards adequate for fulfilling the Sewer System Management 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?
Resilience is addressed in Element 3 by:
• Tracking industry trends and local ordinances that may affect operations as appicable.

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ELEMENT 4 - OPERATION AND MAINTENANCE PROGRAM
The City’s operation and maintenance of its collection system ensures that the system is kept in good working condition. Sewer lift station operations and maintenance work and sewer line operations and maintenance is primarily conducted by City of Pismo Beach staff with the support of some additional contract services. This SSMP Element 4 outlines the work that is conducted to accomplish the optimal operation and maintenance of the City’s collection system.

A general overview of the City Sewer System is provided in Figure 4-1: Collection System Overview Map. Indexed pages to this map are located at City Public Works Office, City Yard and in Service Trucks.

Figure 4-1: Sewer System Overview

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4.1 Regulatory Requirements
Attachment D 4. states:

The SSMP must include those sections listed below that are appropriate and applicable to the Enrollee’s system:
(a) 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 maintenance holes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities within the sewer system service area boundaries.;
(b) A scheduling system and a data collection system for preventive operation and maintenance activities conducted by staff and contractors. a. The scheduling system must include:
i. Inspection and maintenance activities;
ii. Higher-frequency inspections and maintenance of known problem areas, including areas with tree root problems;
iii. Regular visual and closed-circuit television (CCTV) inspections of maintenance holes 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.
(c) In-house and external training provided on a regular basis for sanitary sewer system operations and maintenance staff and contractors. The training must cover:
i. The requirements of this General Order;
ii. The Enrollee’s Spill Emergency Response Plan procedures and practice drills;
iii. Skilled estimation of spill volume for field operators; and iv. Electronic CIWQS reporting procedures for staff submitting data. (d) An inventory of sewer system equipment, including the identification of critical replacement and spare parts.

4.2 Collection System and Storm Water Maps

4.2.1 Sewer Collection and Conveyance
The City of Pismo Beach maintains collection system maps that outlines the following features:
location of the sewer lines, maintenance holes, cleanouts, pipe sizes and pipe materials, and direction of flow. Pump stations and other special structures are also identified.

Corrections for Atlas Maps are noted and submitted to GIS staff. Engineering staff maintains a “Master” Atlas Map and will show corrections here. Updated maps are re-distributed to maintenance staff and will display a date identifying the latest version of the Atlas Map. The City also maintains a GIS map layer of the sewer system. As-built plans and construction drawings are also maintained as the collection system is improved and new systems are added or altered. As-built drawings are required by the City as a condition of construction.

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The City’s sewer system mapping and maintenance tracking is a collaborative effort by the City’s Engineering, GIS, and Public Works.

4.2.2 Storm Water Conveyance Map
The City owns and operates storm water conveyance facilities within the service area. Storm water maps are maintained at the City Public Works Office as hard copy maps and as a GIS layer. This map can be printed as hard copy maps to be utilized by City maintenance staff in the event of a Sanitary Sewer Spill (Spill) to identify storm water inlets and outlets and isolate/capture wastewater that may enter the storm drain system. A general overview map of the City stormdrain system is provided in Figure 4-2 below:

Figure 4-2 Stromdrain System Overview

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4.3 Preventative Maintenance Program
The City manages, schedules, and tracks preventative maintenance activities utilizing a City Wide based scheduling and tracking system. The system covers the following:
o CCTV Inspections
o Manhole Inspections and Maintenance
o High Priority Area Cleaning and Inspections
o Lift Station Inspection and Maintenance
o Force main and Air Relief Valve Inspection and Maintenance o Customer Complaints
o Work Orders

Routine maintenance that requires follow-up is flagged in the City Wide system. The Wastewater Systems Supervisor assigns appropriate staff to follow up on flagged tasks.

4.3.1. CCTV Inspection
The City conducts CCTV inspections utilizing two (2) methods:
1) City Staff conducts CCTV investigations on an ongoing basis as an investigative tool to identify problems identified in the field such as flow restriction, customer complaints, or as a result of line cleaning follow-up investigations utilizing a City owned push camera. 2) System wide CCTV investigations are planned to be initiated in Fiscal Year 2026/2027 as part of an initial phase for a system wide condition assessment. CCTV for the entire service area is anticipated to be completed in the next five (5) years. The City anticipates completing approximately 36,000 linear feet of CCTV annually to accomplish this five- year schedule.

Contractor CCTV information will be one of the primary methods to identify sewer line rehabilitation and replacement projects in the future. Data will be evaluated on an ongoing basis to help identify and prioritize City Capital Projects.

As CCTV investigations are complete they will be analyzed to identify, rank and prioritize areas of the sewer system that require rehabilitation and replacement. A summary of these CCTV investigations will be on file at the Public Works office when completed. A decision tree informing CCTV inspections conducted after the system wide inspection project is provided below in Figure 4-2 to help establish the need for future CCTV inspections:

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Figure 4-2 CCTV Grades above based on NASSCO defect ranking codes

4.3.2 Line Cleaning
The City implements a two (2) year schedule to clean the entire system which consists of multiple distinct sewer cleaning routes. Staff cleans and documents line cleaning conditions on a Routine Sewer Line Cleaning and Manhole Inspection form.

The City evaluates the frequency at which the entire system is cleaned based on the results of sewer line cleaning logs, sewer spill history and the results of CCTV data. Changes in sewer line cleaning and prioritization of sewer repairs based on sewer line cleaning observations follow the following protocol in Figure 4-3 below:

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Figure 4-3: Sewer Line Cleaning Flow Chart

4.3.3 Manhole Inspection
City manholes and cleanouts / lampholes are inspected in conjunction with routine sewer line cleaning activities and as part of the High Priority List inspections. The City utilizes the Line Cleaning & Manhole Inspection Form for routine documentation of manhole conditions. When

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significant issues are observed during these routine manhole inspections, a more detailed inspection and assessment is conducted by maintenance staff. Relevant information from these sheets is maintained in the Public Works City Wide system for consideration in future rehabilitation and/or CIP.

4.3.4 High Priority Areas
High priority areas in the system are identified and cleaned on a monthly, quarterly, and annual basis based on the severity of pipeline defects and flow conditions for specific line segments.

These cleaning activities are performed at historical problem areas (Hot Spots: referenced in Section 7.7) based on field crew experience. The City also participates in an active FOG Program and root treatment program. The current lists are dynamic and revised as needed. This list is maintained at the City Public Works office. The City currently has the following number of high maintenance areas with associated cleaning frequencies:
o Monthly: 4 areas
o Quarterly: 16 areas
o Annually: 22 areas

4.3.5 Lift Station Operation and Maintenance
The City of Pismo Beach operates and maintains twelve (12) lift stations. Weekly inspections are performed on City lift stations. Inspections include electrical equipment, instrumentation, wet well condition, pump operation and general housekeeping. Weekly lift station and wet well inspections are performed by field crews. Lift Station wet wells are cleaned quarterly. Staff utilizes the City’s Lift Station Log when completing weekly lift station inspections to document observed conditions. A copy of this log is on file at the City’s Public Works office at 570 Frady Lane.

A summary of Lift Station descriptions is included in Table 4-3 below:

Lift Station
Name
Operating
Point
Wet Well
Dimensions
Pump Type
& Model
Motor
Size (hp)
# of
Pumps
Emergency
Power
Vista Del
Mar Lift
Station #1
365 gpm @
153 TDH,
1,500 lf of
8” force
main
15 feet
deep, 6-foot
diameter
Baldor
Motor,
Cornell
Pump
4NHDH-V1
50 2 Permanent
Unit
Indio Drive
(Sunset
Palisades)
Lift Station
#2
460 gom @
208 TDH,
7000 lf of
8” force
main
20 feet deep
with 6-foot
diameter
Vertical
Solid Shaft
Motor,
Cornell
Pump
4414TF18
60 2
Portable
Power
Receptacle
(MQ
Whisperwatt
125
Portable
Generator)
St.

Andrew’s
(Sea Cliff)
Lift Station
#3
40 gpm @
80 TDH,
300 lf of 6 “
diameter
force main
13 feet deep
with 6-foot
diameter
Myers
3MW30M4-
21 Submersible
Pump
3 2
No backup
power,
requires
pumper
trucks or
vacuum
truck to

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“bypass” lift
station
Spyglass
Park Lift
Station #4
385 gpm @
121 TDH,
2,000 lf of
8” force
main
22 feet deep
with 6-foot
diameter
Yeomans
Pump
(Grundfos)
4312C-3D
30 2 Permanent
Unit
Freeway
Foothills
Lift Station
275 gpm @
70 TDH,
660 lf force
main 10”
diameter
15 feet
deep, 6-foot
diameter
Hydromatic
H Series
Non-clog
Sewage
Pump
20 2
Portable
Power 60
kw
generator
Harloe Lift
Station
125 gpm @
13ft TDH
@ 1200
rpm, 4”
force main
12 feet deep
with 4 ft
diameter
fiberglass
basin , STL
ANTI-Float
wet well
WEMCO
Model
13X4S2R

TOURQUE-
FLOW
submersible
2 2
Service with
Vactor Truck
during
power
outage. Low
flow station.

Service ~ 10
homes.

Ira Lease
Lift Station
185 gpm @
46ft TDH,
3450 rpm,
3” force
main
5 ft deep, 3ft
diameter
BJM SK
1500C 2 1
Serves 2
restrooms in
public park.

Restroom
closed
during
power
outage.

Addie Lift
Station
950 gpm @
85ft TDH, 2
force
mains(170
0 lf)
13 feet
deep,
rectangular
structure 26
ft x 18 ft
Wemco /
Hidrostal
6x5 ESK-S-
EE4S4
50 4
Cummins -
Permanent
Unit
PG&E Lift
Station
100 gpm @
29 TDH, 6
inch force
main, 1000
lf
15 feet
deep, 6-foot
diameter
Smith &
Loveless 3 2 Portable
Power
Price
Canyon
(Historic
Park) Lift
Station
100 gpm @
32 TDH, 4
inch force
main, 2250
lf
15 feet
deep, 6-foot
diameter
Baldor
Motor,
Wemco
Pump 3x4
S2R

7.5 2 Permanent
Unit
Pismo
Oaks Lift
Station
681 gpm @
60 ft TDH,
1,000 lf of
force main
15 feet
deep, 6-foot
diameter
WEMCO-

HIDRSTAL

IMMERSIBL
E, Model #
E4K-S-

18.8 2
Cummins -
Permanent
Unit

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EEXW5-19,
1710 rpm
Five Cities
Lift Station
900 gpm @
52 TDH, 8”
PVC force
main, ~
2,200
linear feet
20 ft deep,
8ft diameter

HIDRSTAL
MOTOR-
EEXW4-
MYAK+XD1
A7MM-25,
Pump- E5K-
M4R
25 2
Cummins
Permanent
Unit
Table 4-3 Lift Station Summary

Air Relief Valves (ARV) associated with lift station force mains are inspected weekly and maintenance is performed on an as needed basis based on weekly observation of each unit’s operation. Inspections are documented on the Lift Station Log for the ARV associated with that lift station.

4.3.6 Customer Requests/Complaints
The City utilizes the Pismo Pulse system on the City’s website to collect and track information regarding customer complaints and concerns ( https://www.pismobeach.org/104/Complaint- Process). A service request form is used to record complaints from the public. This report becomes a permanent record and is subject to review at a later time. Operations staff documents each identified issue / complaint and the results of investigations and corrective actions. The City makes every effort to respond in a timely manner to all sewer-related complaints followed by prompt corrections to address each identified condition.

4.4 Training
Training programs include formal classroom, informal on-the-job and hands-on training. Training is conducted by both City staff and by outside training workshops. On-the-job cross training is pursued to ensure staff has a proficient working knowledge of the sewer system. City staff are also cross trained so that critical tasks can be performed without interruption even when the crew members change. Task proficiency is a requirement for all job positions and promotions.

Training records are maintained to monitor completed classes and for scheduling.

Crews are initially trained in the proper operation and maintenance of all new major mobile equipment and facilities by the contractor or manufacturer. Written operation and maintenance manuals are used as resource material for initial start-up training as well as new staff training.

Safety training is an integral part of the City’s program. Every staff member receives formal training. Staff is trained in confined space entry and in hazardous materials management, as required.

The City also plans to conduct regular training in the following areas on an annual basis:
o The requirements of General Order WQ 2022-0103-DWQ;
o Spill Emergency Response Plan procedures and practice drills; o Estimation of spill volume and spill response/mitigation; and o Electronic CIWQS reporting procedures for staff submitting data.

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Training records are maintained at the Public Works Office.

4.5 Equipment and Replacement Parts Inventory
Equipment and replacement parts inventories are provided as discussed below.

4.5.1 Critical Parts and Equipment
The City maintains an inventory of critical parts and equipment which are utilized for both routine and emergency operations. Operations Staff maintain City lift stations but do not perform larger projects to repair or replace underground pipelines. Repair and replacement of underground pipelines are contracted out to licensed contractors who have the equipment, materials and personnel to complete the work. The City maintains an electronic inventory of equipment, replacement parts, and supplies and follows a structured process to ensure an up- to-date accounting and complete inventory of equipment and replacement parts. Parts required for preventive maintenance are identified ahead of time for each specific maintenance task.

The City maintains equipment such as portable pumps, portable generators, traffic control and other equipment for emergency response. These items are maintained in a ready state for immediate deployment. This is a dynamic list of parts and equipment that fluctuates throughout each fiscal year. The City maintains this list at the Public Works Office.

The City’s lift stations are equipped with emergency generator connections, permanent generators, and smaller stations have a wet well storage and utilize pumper trucks to “bypass” wastewater in the event of a prolonged power outage.

As a backup, managers have credit authority to purchase needed materials and supplies from local vendors of non-stock items when they are critically needed. In the event of an emergency, local retailers are available to supply additional needed equipment and parts on short notice.

The City has a history of purchasing wastewater related products and services from the contractors/vendors listed below. This list is dynamic and the list below is provided as an example. A master list is maintained at the City Public Works office. Contact information for contractor and vendor contacts is provided below:

Retailer/Contractor Contact Service
Clays Septic & Jetting (805) 481-1116
Pumping Contractors
Al’s Septic Services (805) 528-0432
Speeds Oil & Tools Services (805) 925-1369
Pacific Petroleum (805) 925-1947
Fluid Resource Management (805) 597-7100 Emergency Repairs and Pump Repairs Mainline Utility (805) 434-5015 Sewer System Contractor Spice Integration (805) 464-4111 Instrumentation and Automation Systems Alpha Electrical Service (805) 595-2720 Electrical Contractor

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R. Baker Inc (805) 489-8711
General Engineering Contractor
Joseph Engineering (805) 928-3703
Brough Construction (805) 489-7779
R. Burke Corporation (805) 543-8568
JNE Construction (805) 668-2059
Perrys Electric Motors (805) 925-8761
Pumps and Motor Repair
DXP Enterprises (713) 996-3700
San Luis Powerhouse (805) 543-4643
Generator Repairs
Alltech Services Inc. (805) 239-0300
Sunbelt Rentals (800) 736-2504
Generator Rentals Herc Rentals (888) 202-7658
United Rentals (805) 543-7297
OEC (805) 922-4722 Laboratory & Compliance
Table 4-6: Vendors and Contractors
The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
• Were all map updates completed in a timely manner?
• Are all staff aware of procedures 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.) • Are the City’s maintenance and operations work orders periodically reviewed 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 sewer spills?
• Is maintenance work being completed as scheduled?
• Has all training been completed as scheduled?
• Have records of training and attendance been documented and maintained? • Have contractors received, at a minimum, direction for reporting and responding to spills?
• Has the City experienced any equipment failure that inhibited a spill response? Resilience is addressed in Element 4 by:
• Developing and using forms (paper or electronic) for data collection to help ensure all pertinent information is consistently collected.

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• Periodically evaluating inspection cycle intervals to help ensure they are optimized. • Requiring staff to demonstrate ability and/or knowledge for all training activities. • Periodic review of the Vendor and Equipment Inventory List.

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ELEMENT 5 - DESIGN AND PERFORMANCE PROVISIONS
The standards and specifications for new construction and repair of the existing sanitary sewer system described in this SSMP Element are utilized to ensure a high quality, well designed, and functioning sanitary sewer system.

5.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Section D 5 states that the SSMP must identify:
(a) Updated design criteria, and construction standards and specifications, for the construction, installation, repair, and rehabilitation of existing and proposed system infrastructure components, including but not limited to pipelines, pump stations, and other system appurtenances. If existing design criteria and construction standards are deficient to address the necessary component- specific hydraulic capacity as specified in section 8 (System Evaluation, Capacity Assurance and Capital Improvements), the procedures must include component- specific evaluation of the design criteria.;
(b) Procedures, and standards for the inspection and testing of newly constructed, newly installed, repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances

5.2 Design and Construction Standards and Specifications The purpose of the Standards and Specifications is to provide minimum standards for the design, types and uses of materials, and the preparation of plans for construction, repair, or alteration of City sewer and water facilities. The following sections, from the City Public Works Engineering Standards and SLO County Design Standards, address the standards expected by the City for conducting repairs or new construction related to the sewer system.

City of Pismo Beach Standards & Specifications
SSMP Requirement Standard
WDR D5 (a) Design and construction
standards of new sanitary systems, pump
stations, and other appurtenances; and for
the rehabilitation and repair of existing
sanitary sewer systems
City 2020 Engineering Standards
o Trench Backfill Requirements
o Trench Repair
o Sewer Lateral
o Sewer Manhole
o Sewer Drop Manhole
o Sewer Cleanout
o Water Sewer Separation
o Utility Covers

Section 7 - San Luis Obispo County
Standards 2022: Wastewater Disposal
o Depth to Diameter
o Minimum & Maximum Velocity
o Changes in Pipe Size and Angle
o Acceptable Materials

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o Manhole Spacing
o Pump Stations and Force Mains
o Installation Requirements

https://www.pismobeach.org/441/Engineering-
Documents

5.3 Inspection and Testing Procedures and Standards
The City’s standard public works procedure requires work to be placed into service only after it is accepted by the Utilities Supervisor following satisfactory inspection and testing. The City provides continuous inspection during the construction of sewer facilities and believes that proper installation is the key to ensuring proper operation and maximum life expectancy. The City’s inspection standards are referenced below:

County of San Luis Obispo Public Improvement Standards
SSMP Requirement Standard
WDR D5 (b) Procedures and standards
for inspecting and testing the
installation of new sewers, pumps, and
other appurtenances and for
rehabilitation, and repair projects.

The City sites the following testing procedures in the
SSMP which utilize 2022 San Luis Obispo County
procedures for testing and inspection of sewer assets:

Section 7: Wastewater Disposal – 7.2.4 Testing
o Sewer Line Cleaning and Mandrel Testing
o Hydrostatic Testing for Manholes and Sewer
Lines
o Air Testing for Manholes and Sewer Lines
o Deflection Testing
o CCTV Inspection
o Force Main Pressure Testing

https://www.slocounty.ca.gov/departments/public-
works/forms-documents/development-
services/public-improvements/public-
improvement-standards

These standards provide for design standards, construction standards, specifications and testing requirements for the installation or reconstruction of sanitary sewer systems. City sewer lift stations are designed by professional engineers and include design and inspection requirements specific to each individual lift station project.

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

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• Were any design or installation deficiencies found during warranty inspections? • Are deviations from standard procedures and/or specifications, testing, etc., justified and documented?

Resilience is addressed in Element 5 by:
• Staying current with 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.

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ELEMENT 6 - SPILL EMERGENCY RESPONSE PLAN
Sanitary Sewer Spills (Spills), or spills, can occur due to unforeseen accidents, unusual equipment failures, or other events not controllable by the City. A Spill Emergency Response Plan is maintained by the City Public Works Office for City maintenance personnel to use as guidance in responding to Spills. The Spill response plan defines procedures to:
▪ protect public health and the environment
▪ comply with local, state, and federal regulatory agency requirements ▪ protect City personnel, the wastewater collection system, and private and public properties

The SERP is summarized in this SSMP Element.

The City has developed a stand-alone SERP to address emergency response and follow up activities for Spills experienced in the City’s collection and conveyance system. This plan is located at the City Public Works office and on maintenance staff trucks. This document is the primary references for staff to use during all Spills.

6.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Attachment D 6 states:

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:
a) Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill in a timely manner;
b) 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;
c) Comply with the notification, monitoring and reporting requirements of this General Order, State law and regulations, and applicable Regional Water Board Orders;
d) Ensure that appropriate staff and contractors implement the Spill Emergency Response Plan and are appropriately trained;
e) Address emergency system operations, traffic control and other necessary response activities;
f) Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system;
g) Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of the State;
h) Remove sewage from the drainage conveyance system;
i) Clean the spill area and drainage conveyance system in a manner that does not inadvertently impact beneficial uses in the receiving waters;

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j) Implement technologies, practices, equipment, and interagency coordination to expedite spill containment and recovery;

k) Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event;

l) Conduct post-spill assessments of spill response activities;

m) Document and report spill events as required in this General Order; and

n) Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update the Plan as needed.

6.2 Initial Spill Notification Procedures
If a member of the public witnesses a Spill, they contact City On Call Staff by way of the City Office at (805) 773-4656 during normal business hours. Calls to the City after hours or on weekends and holidays are directed to the City Dispatch at (805) 773-2208 which contacts staff responsible for “On-Call” duty. The City Staff as the First Responder If City Staff is contacted during normal business hours Monday through Friday, excluding legal holidays, administrative staff at the City Office, calls the Supervisor or the next available Wastewater Staff to investigate the situation utilizing the contact information found in the SERP.

If City Staff needs assistance responding to the Spill, the first responder calls additional Wastewater staff utilizing the information found in Table 6-1.

Table 6-1: Maintenance Staff Contact Information
City Office Phone Number for Normal Working Hours: (805) 773-4656 After Hours Calls to City Dispatch: (805) 773-2208 or 911 On-Call Operator
Cell: (805) 441-
7687
Wastewater System
Supervisor
Sean Campbell
Office: (805) 770-1462
Cell: (949) 374-6621
Radio: Call Sign 45
Utilities Manager
Jake Smith
Office: (805) 773-7075
Cell: (805) 904-8362, or
Radio: call sign 46

If City staff are contacted after normal business hours, on a holiday, or during the weekend, On-Call maintenance staff are contacted by dialing the Dispatch line or 911 line. The call will be routed to the City On-Call phone, and staff responds accordingly.

After normal operating hours, one member of Maintenance Staff is on-call as a primary on-call wastewater emergency responder.

The Sewer Spill Reporting Chain of Command follows the flowchart shown in the City Spill Response Chain of Command in the complete City SERP. The reporting process and responsibilities are described in detail in the Spill Emergency Response Plan.

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6.3 Spill Response Program
The City SERP documents provide a comprehensive Emergency Response Program consisting of the following:
o Spill Detection and Notification
o Regulatory Agency Contacts
o Spill Response Procedures
o Spill Recovery and Cleanup
o Traffic Control
o Pump Station and Force Main Failure
o Contingency Data for Lift Stations
o Water Quality Monitoring/Sampling & Water Body Closures o Notification, Reporting and Record Keeping Requirements o Post Spill Debriefing / Failure Analysis Investigation o Spill Response Training (training records maintained at City office) o Spill Response Field Checklist

6.4 Spill Notification and Reporting Procedures
This section of the SERP ensures proper notification and reporting of Spills, which occur in the City’s sanitary sewer system, to protect public and environmental health.

An overview of the notification and reporting process is illustrated on the following page in Table 6-1. This overview is not inclusive of all the notification and reporting requirements and procedures. The following section of this SSMP Element corresponding to each Spill category for notifications and reporting must be referenced and followed.

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Spill Category 1:

Spills to Surface Waters and/or SW Conveyance System
Spill
Requirement Schedule Method
Notification

Within two (2) hours of the Enrollee’s knowledge of a
Category 1 spill of 1,000 gallons or greater, discharging or threatening to discharge to surface waters:

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

California
Office of
Emergency
Services at:
(800) 852-
7550

Reporting
• Submit Draft Spill Report within three (3) business
days of the Enrollee’s knowledge of the spill;
• Submit Certified Spill Report within 15 calendar
days of the spill end date;
• Submit Technical Report within 45 calendar days after the spill end date for a Category 1 spill in which 50,000 gallons or greater discharged to surface waters; and
• Submit Amended Spill Report within 90 calendar days after the spill end date.

CIWQS
Spill Category 2:

Spills of 1,000 Gallons of Greater That Do Not Discharge to Surface Waters Spill
Requirement Schedule Method
Notification

Within two (2) hours of the Enrollee’s knowledge of a
Category 2 spill of 1,000 gallons or greater, discharging or threatening to discharge to waters of the State:

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

California Office
of Emergency
Services at:
(800) 852-7550

Reporting
• Submit Draft Spill Report within three (3) business
days of the Enrollee’s knowledge of the spill;
• Submit Certified Spill Report within 15 calendar
days of the spill end date; and
• Submit Amended Spill Report within 90 calendar
days after the spill end date.

CIWQS

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Spill Category 3:

Spills of Equal or Greater than 50 Gallons and Less than 1,000 Gallons That Does Not Discharge to Surface Waters

Spill
Requirement Schedule Method

Notification

Not Applicable

Not Applicable
Reporting
• Submit monthly Certified Spill Report to the online
CIWQS Sanitary Sewer System Database within 30
calendars days after the end of the month in which
the spills occur; and
• Submit Amended Spill Reports within 90 calendar
days after the Certified Spill Report due date.

CIWQS
Spill Category 4:

Spills Less Than 50 Gallons That Do Not Discharge to Surface Waters Spill
Requirement Schedule Method

Notification

Not Applicable

Not Applicable
Reporting
• If, during any calendar month, Category 4 spills occur, certify monthly, the estimated total spill volume exiting the sanitary sewer system, and the total number of all
Category 4 spills into the online CIWQS Sanitary
Sewer System Database, within 30 days after the end
of the calendar month in which the spills occurred.

• Upload and certify a report, in an acceptable digital format, of all Category 4 spills to the online CIWQS
Sanitary Sewer System Database, by February 1st
after the end of the calendar year in which the spills
occur.

CIWQS

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Enrollee Owned and/or Operated Lateral Spills That Do Not Discharge to Surface Waters Spill
Requirement Schedule Method

Notification
Within two (2) hours of the Enrollee’s knowledge of a spill of 1,000 gallons or greater, from an enrollee- owned and/or operated lateral, discharging or threatening to discharge to waters of the State:

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

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

California
Office of
Emergency
Services at:
(800) 852-
7550

Reporting
• Upload and certify a report, in an acceptable digital format, of all lateral spills (that do not discharge to a surface water) to the online CIWQS Sanitary Sewer
System Database, by February 1st after the end of the
calendar year in which the spills occur.
• Report a lateral spill of any volume that discharges to a surface water as a Category 1 spill.

CIWQS
Table 6-1: Spill Notification and Reporting Overview

6.4.1 Spill Notification Procedure
Spill notification procedures vary based on whether the Spill is classified as a Category 1, Category 2, Category 3, Category 4 or Enrollee Owned Lateral and are the SERP: Spill Notification section.

Notification of Spills of 1,000 Gallons or Greater to the California Office of Emergency Services
Per Water Code section 13271, for a spill that discharges in or on any waters of the State, or discharges or is deposited where it is, or probably will be, discharged in or on any waters of the State, the City shall notify the California Office of Emergency Services and obtain a California Office of Emergency Services Control Number as soon as possible but no later than two (2) hours after:
• The City has knowledge of the spill; and
• Notification can be provided without substantially impeding cleanup or other emergency measures.

The notification requirements in this section apply to individual spills of 1,000 gallons or greater, from an Enrollee-owned and/or operated laterals, to a water of the State.

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Spill Notification Information
The Enrollee shall provide the following spill information to the California Office of Emergency Services before receiving a Control Number, as applicable:
• Name and phone number of the person notifying the California Office of Emergency Services;
• Estimated spill volume (gallons);
• Estimated spill rate from the system (gallons per minute); • Estimated discharge rate (gallons per minute) directly into waters of the State or indirectly into a drainage conveyance system; • Spill incident description:
o Brief narrative of the spill event, and
o Spill incident location (address, city, and zip code) and closest cross streets and/or landmarks;
• Name and phone number of contact person on-scene;
• Date and time the Enrollee was informed of the spill event; • Name of sanitary sewer system causing the spill;
• Spill cause or suspected cause (if known);
• Amount of spill contained;
• Name of receiving water body receiving or potentially receiving discharge; and
• Description of water body impact and/ or potential impact to beneficial uses.

Notification of Spill Report Updates
Following the initial notification to the California Office of Emergency Services and until such time that the Enrollee certifies the spill report in the online CIWQS Sanitary Sewer System Database, the Enrollee shall provide updates to the California Office of Emergency Services regarding substantial changes to:
• Estimated spill volume (increase or decrease in gallons initially estimated);
• Estimated discharge volume discharged directly into waters of the State or indirectly into a drainage conveyance system (increase or decrease in gallons initially estimated); and
• Additional impact(s) to the receiving water(s) and beneficial uses.

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

Table 6-2: Regulatory Agency Notification Information for a Spill to Surface Water

Regulatory Agency Contacts
California Office of
Emergency
Services (Cal OES)
Within two (2) hours of the City’s knowledge of a Category 1 spill of 1,000 gallons or greater, discharging or threatening to discharge to surface waters notify the California Office of Emergency Services and obtain a notification control number at (800) 852-7550 Regional Water
Quality Control
Board (RWQCB)
Optional – If spill is over 1,000 gallons, reaches waterway, or occurred in area with likely public contact, call (805) 549-3147 or (805) 542-4638.

SLO County
Environmental
Health
Optional- If spill reaches waterway, call (805) 781-5544. Give the spill information.

California
Department of Fish
and Wildlife
Optional -If spill reaches waterway, call state office (916) 445-0045.

6.4.1.2 Category 2 Spills
(Spills of 1,000 Gallons or Greater That Do Not Discharge to Surface Waters) Within two (2) hours of the City’s knowledge of a Category 2 spill of 1,000 gallons or greater, discharging or threatening to discharge to waters of the State:
o Notify California Office of Emergency Services and obtain a notification control number.

6.4.1.3 Category 3 Spills
(Spills of Equal or Greater than 50 Gallons and Less than 1,000 Gallons That Does Not Discharge to Surface Waters)
o Not Applicable

6.4.1.4 Category 4 Spills
(Spills Less Than 50 Gallons That Do Not Discharge to Surface Waters) o Not Applicable

6.4.1.5 Enrollee Owned and or Operated Lateral Spills that do not Discharge to Surface Waters
Within two (2) hours of the City’s knowledge of a spill of 1,000 gallons or greater, from an enrollee- owned and/or operated lateral, discharging or threatening to discharge to waters of the State:
o Notify California Office of Emergency Services and obtain a notification

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

6.4.2 Spill Reporting Procedure
Spill reporting procedures vary based on whether the Spill is classified as Category 1, Category 2, Category 3, Category 4 or City Owned Lateral. A full description of Spill reporting requirements is found in the City SERP.

Category 1 Spills
• Submit Draft Spill Report in CIWQS within three (3) business days of the City’s knowledge of the spill;
• Submit Certified Spill Report within 15 calendar days of the spill end date; • Submit Technical Report within 45 calendar days after the spill end date for a Category 1 spill in which 50,000 gallons or greater discharged to surface waters; and • Submit Amended Spill Report within 90 calendar days after the spill end date.

Spill Technical Report
Category 2 Spills
• Submit Draft Spill Report within three (3) business days of the City’s knowledge of the spill;
• Submit Certified Spill Report within 15 calendar days of the spill end date; and • Submit Amended Spill Report within 90 calendar days after the spill end date.

Category 3 Spills
• Submit monthly Certified Spill Report to the online CIWQS Sanitary Sewer System Database within 30 calendars days after the end of the month in which the spills occur; and
• Submit Amended Spill Reports within 90 calendar days after the Certified Spill Report due date.

Category 4 Spills
• If, during any calendar month, Category 4 spills occur, certify monthly, the estimated total spill volume exiting the sanitary sewer system, and the total number of all Category 4 spills into the online CIWQS Sanitary Sewer System Database, within 30 days after the end of the calendar month in which the spills occurred. • Upload and certify a report, in an acceptable digital format, of all Category 4 spills to the online CIWQS Sanitary Sewer System Database, by February 1st after the end of the calendar year in which the spills occur.

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Enrollee Owned and/or Operated Lateral Spills That Do Not Discharge to Surface Waters
• Upload and certify a report, in an acceptable digital format, of all lateral spills (that do not discharge to a surface water) to the online CIWQS Sanitary Sewer System Database, by February 1st after the end of the calendar year in which the spills occur. • Report a lateral spill of any volume that discharges to a surface water as a Category 1 spill.

6.5 SERP Training
The City implements a formal training program which will include annual training of City Staff on this SSMP Element and SERP. The City will also require contractor personnel to train on and follow SERP through their contracts. The City will maintain a log of SERP Training as training is completed.

6.6 Spill Impact Mitigation Program
The Spill Mitigation Program is comprised of the mitigation practices contained in the SERP, which is on file at the City Public Works Office.

The SERP includes Water Quality Monitoring, Beneficial Uses identification and Spill Impact Mitigation section providing information to post water body warning and closure signs in the event that a spill reaches a surface water, and City Public Works coordinates with the SLO County Environmental Health Department to conduct water quality sampling for any spill impact assessment that may be required.

6.7 Spill Coordination with Stormwater Management Agencies and Public Water Systems
City Public Works manages the MS4 Stormwater Program which includes the entire City service area. Maps of the stormwater collection and conveyance system are available to City staff which allows them to isolate any areas impacted by a sewer spill, recover this wastewater and return it to the sewer system. Municipal water system contacts are identified for notification of spills that may occur within 1000 ft of a surface water intake in the City SERP.

6.8 Post Spill Investigations
The City conducts Post Spill Investigations for Cat 1, 2, 3, and 4 spills as warranted per instructions in Section 11 of the 2023 SERP.

The City utilizes the following 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 staff demonstrating adequate knowledge and abilities?

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Resilience is addressed in Element 6 by:
• All staff with sewer response duties 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 (Spill Response Field Checklists) 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.

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ELEMENT 7 – PIPE BLOCKAGE CONTROL PROGRAM
The City of Pismo Beach has identified a significant number of commercial facilities that contribute fats, oils and grease (FOG) into the City’s sewer system. FOG has been a contributing factor in sanitary sewer spills and requires the City to conduct additional maintenance. Roots and disposable wipes have also been identified as pipe blocking sources.

7.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Attachment D 7 states:

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:
a) An implementation plan and schedule for a public education outreach program that promotes proper disposal of pipe blocking substances;
b) A plan and schedule for the disposal of FOG 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 FOG generated within a sanitary sewer system service area;
c) The legal authority to prohibit discharges to the system and identify measures to prevent spills and blockages;
d) Requirements to install grease removal devices (such as traps or interceptors) and the development of design standards for such devices, maintenance requirements, BMP requirements, record keeping and reporting requirements; e) Authority to inspect grease producing facilities, enforcement authorities, and whether the City has sufficient staff to inspect and enforce the FOG ordinance; f) An identification of sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and g) Implementation of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each section identified above

7.2 Pipe Blockage Control Program Public Education and Outreach The City currently has approximately 49 miles of sanitary sewer pipelines. The service area includes a variety of residential and commercial facilities. The focus of an effective Pipe Blockage Control Program includes residential customers, commercial facilities and commercial food service/preparation facilities.

The City utilizes personal contact with business owners for the proper disposal of FOG and other sewer spill prevention measures. The City’s website posts information for FSEs regarding recommended Best Management Practices (BMPs) for FOG control, requirements for grease interceptors, and inspections and educational information for FOG related issues in the sewer system.

The City provides guidance for Food Service Establishments (FSEs) and other FOG producing users in the City to conform to BMPs for FOG control. These BMPs are practices and procedures that should be performed by FSEs to reduce the quantity of FOG discharged into

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the sanitary sewer system. Not all BMPs may be applicable to all users; therefore, the following should be used as a starting point for the development of individualized BMPs. A list of BMPs is provided below:
o Employee Training and Awareness
o Garbage Disposal Limitations
o Spill Cleanup
o Equipment Cleaning & Maintenance
o Grease Handling & Disposal
o Grease Trap Installation & Maintenance
o Residential and Private Dwellings
Residential outreach is also an important element for reducing the amount of FOG entering the collection system. While requiring grease traps and interceptors is not possible to the residential community, education is.

In addition to the City’s FOG Control Program outreach, the City has independently developed outreach materials for other pipe blocking materials such as “disposable” wipes and any other consumer items that do not belong in the sewer through a flyer labeled “Toilets Are Not Trashcans”.

The City provides the following outreach and education materials that consist of the following:
• Residential and commercial outreach on proper Disposal of Wipes - “Toilets are not Trashcans” flyer,
• Residential Outreach Page: “Don’t Let Roots, Wipes, and FOG Cause Sewer Problems”

Copies of educational outreach documents for food service establishments are available on the City’s Public Works Office.

The City refers the appropriate businesses to the available information, to assist them with FOG compliance. Examples of these outreach materials are also found in Appendix 7A and 7B.

The City provides additional Safe Sewer Practices on the City website:
https://www.pismobeach.org/452/Safe-Sewer-Practices

7.3 FOG Disposal Facilities
The City does not own nor operate a FOG disposal facility; however, licensed FOG hauling contractors are identified as part of the City’s FOG Pipe Blockage Control Program, and the City provides a list of these licensed haulers to each food service establishment (FSE).

A list of grease trap and interceptor vendors, pumping and waste hauling contractors in San Luis Obispo County that haul FOG for disposal is available in the City’s Sanitary Sewer website link identified above and is also provided below:

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Table 7-1: SLO County Grease Haulers

7.4 Discharge Prohibition Legal Authority and Spill Prevention Measures The City FOG Program is governed by the City’s Pretreatment Ordinance found in Title 13:

Public Services of the City Municipal Code. A link to this Code is provided below:
https://codelibrary.amlegal.com/codes/pismobeach/latest/pismo_ca/0-0-0-30194

The FOG Ordinance includes:
▪ Establishment of enforcement authority,
▪ Limits on types of wastes discharged to public sewers, ▪ Requirements for specific design and construction of grease interceptors and/or traps, ▪ Best Management Practice requirements,
▪ Requirements for the installation of grease interceptors, ▪ Requirements for maintenance of grease interceptors,
▪ Enforcement, and
▪ Implementation measures, as appropriate.

Additionally, the City of Pismo Beach Municipal Code prohibits pipe blocking materials in the following code sections:
• Chapter 13.12.050 Prohibited Discharge Standards

7.5 Requirements to Install Grease Removal Devices
See Section 7.4 above.

Grease Haulers in San Luis Obispo County
R. P. Environmental (805) 929-5509
Clay’s Septic and Jetting (800) 928-2529
Salinas Tallow (800) 621-9000
Central Grease Inc. (559) 846-9393
Liquid Environmental Solutions (866) 694-7327
Marborg Industries (805) 963-1852
Valley Septic (805) 928-1414
Triple J Grease Removal (805) 878-4854

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7.6 FOG Control Program Inspection, Enforcement, and Staffing The City Fog Control Program provides provisions for the inspection of FOG producing facilities and the enforcement actions that should be taken by the City in the event of a violation of the provisions of the plan. The City currently performs inspections of all FSEs located within City boundaries. Each Food Service Establishment (FSE) receives an annual inspection, with some facilities receiving biannual inspection based on compliance history. By conducting these inspections, the City identifies which FSEs conform to the City’s existing Fog Control Program requirements and set dates for compliance for those which do not conform with City requirements.

The City currently has a procedure in place for the enforcement of its existing FOG Control Program. Through the City’s annual or biannual FSE inspections, violators of City standards are identified. A “Notice of Violation” is then issued to the violator. The violator is then given a timeframe for which they are to comply with the corrective actions identified in the notice of violation. Should the violator choose not to comply, then a non-compliance fine of an amount not to exceed $250 for each day the violation is not corrected is issued.

The goals of the FOG Control Program are to reduce the amount of fat, oils, and grease entering the sewer system, inspect all food service establishments for FOG violations, provide education to FSEs and reduce maintenance costs from grease related problems. Doing so should reduce the risk of sewer spills and increase the longevity of the sewer collection lines.

7.7 Problem Area Identification and Sewer Cleaning
One objective of a FOG control program is the identification of trouble spots, or “Hot Spots”, that are likely or prove to have grease accumulation. The City identifies potential grease problem areas by tracking locations and causes of dry weather blockages and sewer spills. FOG accumulation is also documented when seen in the sewer system during a visual inspection by Closed Circuit Television (CCTV). If the specific trouble spots occur in close proximity to several restaurants or grease-producing facilities the FSEs will be considered a potential source of the FOG in the sewer and increased inspections will take place. Additionally, the identified locations will be noted in the O&M program and will be monitored for cleaning frequency requirements.

The City has compiled a list of Hot Spots within the sewer service area. These areas of concern have been put on an increased cleaning schedule and will be monitored annually for individual required cleaning frequency. The list is dynamic and changes based on staffs’ findings in the field during scheduled maintenance and in response to sewer blockages and/or spills. The City cleans these areas on a monthly, quarterly and annual basis. This Hot Spot list is maintained at the Public Works office. An example of the current annual hot spots is provided below:

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City of Pismo Beach Sewer Hot Spots
Street Location Upstream MH Downstream MH Pipe Diameter Footage Solar Way P-21 P-22 6 72
Bello Street AS-086 AS-091 6 250
Crest Drive P-042 P-043 8 58
Ema Way P-068 P-069 8 450
Price Street AS-115 AS-114 8 205
Summit Drive P-041 P-042 8 422
Terry Court P-052 P-057 8 179
Wadsworth Avenue AS-607 AS-066 8 45
Wadsworth Avenue AS-069 AS-067 6 360
Morro Avenue V-202 V-021 6 340
Morro Avenue V-021 V-022 6 300
Morro Avenue V-19 V-020 6 185
Morro Avenue V-022 V-023 6 300
Lemore Avenue AS-051 AS-050 6 312
Stratford Street AS-040 AS-042 6 130
Longview Avenue AS-046 AS-052 6 220
Fresno Street AS-038 AS-040 6 145
Tulare Street AS-015 AS-016 6 172
Bello Street AS-086 AS-091 6 272
Price Street AS-118 AS-117 6 195
Dolliver Street PO-248 PO-249 6 186
Capanna Lane PO-249 PO-250 6 145
Table 7-2: Sewer System Hot Spots

Additional information about cleaning and maintenance is included in Element 4: Operations and Maintenance Program.

7.8 Other Source Control Measures
The City’s source control efforts to reduce or eliminate pipe blocking materials and related problems in the pipeline sections identified in the hot spot maintenance list are addressed through the actions previously described in this Element. Additionally, the City provides outreach and education to residential customers through the City website previously referenced in this Element.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
• Have there been any blockages/spills from any identified problem areas? • 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 serial violators among FSEs?

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• Are enforcement trends decreasing?
• Are Source Control and Collection staff included in the plan check process? Resilience is addressed in Element 7 by:
• Inspection of select manholes and pipelines directly downstream of grease producing businesses to ensure source control is effective.
• Residential Pipe Blocking Materials outreach and education program. • Performance of regular assessments of system assets to monitor program performance. • QA/QC process for evaluating pipe cleaning effectiveness.

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ELEMENT 8 SYSTEM EVALUATION, CAPACITY ASSURANCE AND

CAPITAL IMPROVEMENT PLAN

8.1 Regulatory Requirements
Attachment D 8 states:

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.
(a). System Evaluation & Condition Assessment: The Plan must include procedures to:
o Evaluate the sanitary sewer system assets utilizing the best practices and technologies available;
o Identify and justify the amount (percentage) of its system for its condition to be assessed each year;
o 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; o Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act section 303(d) List;
o Assess the system conditions using visual observations, video surveillance and/or other comparable system inspection methods;
o 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;
o Maintain documents and recordkeeping of system evaluation and condition assessment inspections and activities; and
o 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.
(b). Capacity Assessment & Design Criteria: 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:
o Dry-weather peak flow conditions that cause or contributes to spill events;

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o The appropriate design storm(s) or wet weather events that causes or contributes to spill events;
o The capacity of key system components; and
o Identify the major sources that contribute to the peak flows associated with sewer spills.
o The capacity assessment must consider:
▪ Data from existing system condition assessments, system inspections, system audits, spill history, and other available information; ▪ Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions;
▪ Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-intensity storm events as a result of climate change; ▪ Increases of erosive forces in canyons and streams near underground and above- ground system components due to larger and/or higher-intensity storm events;
▪ Capacity of major system elements to accommodate dry weather peak flow conditions, and updated design storm and wet weather events; and ▪ Necessary redundancy in pumping and storage capacities. (c). Prioritization of Corrective Action: The findings of the condition assessments and capacity assessments must be used to prioritize corrective actions. Prioritization must consider the severity of the consequences of potential spills. (d). Capital Improvement Plan: The capital improvement plan must include the following items:
o Project schedules including completion dates for all portions of the capital improvement program;
o Internal and external project funding sources for each project; and o Joint coordination between operation and maintenance staff, and engineering staff/consultants during planning, design, and construction of capital improvement projects; and Interagency coordination with other impacted utility agencies.

8.2 System Evaluation & Condition Assessment
The City completed a Wastewater Collection System Master Plan, in 2000. The 2000 Master Plan recommended improvements to address the City’s system deficiencies at that time and to recommend improvements to plan for future development. Some of the projects identified in Section 8.5: Capital Improvements are a result of this analysis.

The City recently started a new Sewer Master Plan Update that started in 2026. The System Evaluation and Condition Assessment. The criteria for this Master Plan includes procedures to:
o Evaluate the sanitary sewer system assets utilizing the best practices and technologies available;

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o Identify and justify the amount (percentage) of its system for its condition to be assessed each year;
o 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; o Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act section 303(d) List;
o Assess the system conditions using visual observations, video surveillance and/or other comparable system inspection methods;
o 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;
o Maintain documents and recordkeeping of system evaluation and condition assessment inspections and activities; and
o 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.

8.3 Capacity Evaluation & Design Criteria
The 2026 Master Plan scope includes identification of 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:
o Dry-weather peak flow conditions that cause or contributes to spill events; o The appropriate design storm(s) or wet weather events that causes or contributes to spill events;
o The capacity of key system components; and
o Identify the major sources that contribute to the peak flows associated with sewer spills.
o The capacity assessment must consider:
▪ Data from existing system condition assessments, system inspections, system audits, spill history, and other available information; ▪ Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions;
▪ Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-intensity storm events as a result of climate change; ▪ Increases of erosive forces in canyons and streams near underground and above- ground system components due to larger and/or higher-intensity storm events;

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▪ 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.

8.4 Prioritization of Corrective Actions
The 2026 Master Plan anticipates including the findings of the condition assessments and capacity assessments to prioritize corrective actions. Prioritization will consider the severity of the consequences of potential spills.

8.5 Capital Improvement Plan
The City developed Capital Improvement List and schedule which is included below in Table 8-1.

Table 8-1: Capital Projects
Project Fiscal
Year 2026
Fiscal
Year 2027
Fiscal
Year 2028
Fiscal
Year 2029
Fiscal
Year 2030
Fiscal
Year 2031
Toal
Budget
Sunset Palisades Lift
Station Rehabilitation
& Force Main
Relocation
$2,000,000 0 0 0 0 0 $2,000,000
CCTV Gravity Sewer
Mains 0 0 0 $500,000 $500,000 0 $1,000,000
Lift Station
Maintenance 0 0 0 0 $820,000 0 $820,000
Manhole
Rehabilitation $60,000 $60,000 $60,000 $60,000 $60,000 $60,000 $360,000 Pismo Oaks Lift
Station Rehabilitation 0 $600,000 0 0 0 0 $600,000
PG&E Lift Station 0 0 0 0 $500,000 0 $500,000
Wastewater System
Pump Replacement 0 0 $62,000 $62,000 $62,000 $62,000 $248,000 Freeway Foothills Lift
Station 0 0 0 $300,000 0 0 $300,000
Toucan Terrace Pipe
Relining $250,000 0 0 0 0 0 $250,000
Air Vac Replacements $20,000 $20,000 $20,000 $20,000 $20,000 $20,000 $120,000

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Additional Capital Projects are anticipated as a result of the Sewer Master Plan Update which is anticipated for completion in 2027. These Capital Projects will be ranked and prioritized. An updated project list will be maintained at the City Public Works office when complete. The City will include Engineering, Operations and Management staff to evaluate and prioritize these projects
Funding
City sewer projects are funded by sewer user fees and sewer connection fees. The City completed a Wastewater Rate Study and associated rate increase in 2024 to fund future sewer projects.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
o Has the City maintained its schedule for routine O&M and is data being reviewed in a timely manner?
 CCTV Gravity Mains
 Laterals
 Manholes
 Lift Stations
o Are inspection efforts discovering deficiencies in a timely manner? o Are maintenance and inspection activities properly documented? o Number of capacity-related spills or surcharge condition during the audit period. o Has the City followed its system evaluation/condition assessment schedule? o Has the City followed its prioritization/corrective procedures for sewer repair and capacity improvement projects?
o Have projects been completed before deficiencies caused failures? o Has the City’s capital improvement plan schedule been followed?

Resilience is addressed in Element 8 by:
o Annual review of the Capital Improvement Plan by all appropriate individuals including Management, Engineering, and Operations during budget preparation.

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ELEMENT 9 - MONITORING, MEASUREMENT & PROGRAM MODIFICATIONS The City monitors the implementation of the SSMP elements in order to measure the effectiveness of the City’s SSMP in reducing sewer spills. The manner in which each SSMP element is monitored and evaluated and the schedule the City utilizes to complete this monitoring and evaluation is described in this SSMP Element.

9.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Section D 9 states:

The Plan must include an Adaptive Management section that addresses Plan- implementation effectiveness and the steps for necessary Plan improvement, including:
(a). Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities;
(b). Monitoring the implementation and measuring the effectiveness of each Plan Element;
(c). Assess the success of the preventative maintenance activities; (d). Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations; and
(e). Identifying and illustrating spill trends, including spill frequency, locations and estimated volumes.

9.2 Data Management
The City uses the “City Wide” computer-based maintenance system to maintain accurate and relevant inspection and maintenance records for the collection system, including field data such as, CCTV inspections, manhole inspections, pipeline cleaning and inspection frequencies, lift station inspections, and information regarding spills. Much of the documentation is maintained electronically, which allows for ease of access and analysis. This helps City staff to make informed decisions and prioritize activities when encountering routine and unexpected tasks.

9.3 Monitoring SSMP Elements
Monitoring the City’s SSMP focuses on each element in terms of its implementation and effectiveness. The SSMP includes performance indicators for each element, which are intended to measure effectiveness by City staff. In addition, implementation schedules are included for specific elements to help ensure the SSMP is managed and implemented as intended.

9.4 Preventative Maintenance Program Assessment
The City’s Preventative Maintenance Program includes CCTV inspection, line cleaning, visual manhole inspection, lift station maintenance, high priority area identification and maintenance.

The City will review these operation and maintenance practices annually and compare them with annual Spill records. Use of City maintenance tracking systems allow for inspections and maintenance following identified schedules and for progress to be tracked. Regular operations and maintenance meetings are a forum for communicating the status of work tasks following identified schedules and those that may need additional attention. O&M meetings are also an opportunity to discuss any problems which may have been identified. Changes are made to regularly planned work as needed to address higher priorities in the collection system.

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9.5 SSMP Updates
The City is committed to continuous improvement and monitors and evaluates performance of work programs and SSMP elements to ensure goals and objectives are achieved while identifying areas for improvement. Although the SWRCB requires that the SSMP be updated every six years, the SSMP is considered a living document and may require administrative updates on a more frequent basis.

At a minimum, the City will review and revise the SSMP annually as warranted. The Utilities Manager is responsible for revising and maintaining the SSMP. A revision record will be maintained to track changes.

9.6 Sewer Spill Trends
The City monitors spill trends during required annual CIWQS Reports (Annual Reports), and at a minimum every three years during required audits, utilizing its maintenance database, inspection records and CIWQS data. These resources are helpful in planning and programing work, and adjusting as needed, enabling the City to adapt and to adjust based on a review of system data.

The City will continue to plan and adjust operation and maintenance practices so that the number of Spills experienced on an annual basis remains low.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
o Are SSMP Elements periodically evaluated for effectiveness? o Are work activities and spill events being documented? o Has a plan and schedule been established to address audit findings/deficiencies from the last audit?
o Is a Trend Analysis being performed on spill causes?
o Have work programs been assessed and updated as necessary? Resilience is addressed in Element 9 by:
o Development of performance indicators to measure effectiveness of the SSMP. o Performing periodic reviews of the SSMP to help ensure it is being properly implemented.
o Developing and implementation of a timeline to correct deficiencies found during the audit process.
o Periodically evaluating work programs to help ensure effectiveness.

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ELEMENT 10 - SEWER SYSTEM MANAGEMENT PLAN PROGRAM AUDITS SSMP audits are required to identify and correct deficiencies in the most current revision of the City’s SSMP and provide a schedule to correct identified deficiencies. This SSMP Element outlines the audit process and identifies staff responsible for conducting or participating in SSMP audits and generating the required SSMP Audit Report.

10.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Section D 10 requires:

The Plan shall include internal audit procedures, appropriate to the size and performance of the system. Additionally, the General Order requires;
The internal audit shall be appropriately scaled to the size of the system(s) and the number of spills. The Enrollee’s sewer system operators must be involved in completing the audit. At minimum, the audit must:
o Evaluate the implementation and effectiveness of the Enrollee’s Sewer System Management Plan in preventing spills;
o Evaluate the Enrollee’s compliance with this General Order; o Identify Sewer System Management Plan deficiencies in addressing ongoing spills and discharges to waters of the State; and
o Identify necessary modifications to the Sewer System Management Plan to correct deficiencies.

The Enrollee shall submit a complete audit report that includes:
o Audit findings and recommended corrective actions;
o A statement that sewer system operators’ input on the audit findings has been considered; and
o A proposed schedule for the Enrollee to address the identified deficiencies.

10.2 SSMP Program Audits
The Utilities Manager is the Legally Responsible Official (LRO). The LRO or their designee is responsible for assuring the SSMP audit is conducted and complete based on the schedule outlined on the SWRCB lookup website which requires audits to be conducted at a three-year interval from the prior audit. Audits should be conducted with the cooperation of the City staff responsible for sewer system operations and maintenance, administrative staff, and engineering staff. When conducting the SSMP audit, City staff must evaluate the effectiveness of each SSMP Element. A comprehensive, effective review of the City’s SSMP must be documented in a SSMP Audit Report.

10.2.1 Summary of Procedure:

1. Gather appropriate documents using the SSMP Audit Data & Records Request, which is provided in Appendix 10A.

2. Interview City staff responsible for the administration, operations, maintenance and engineering associated with system performance information.

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3. Develop Audit Report and reference all documents reviewed and used as evidence of compliance with the WDR. Create a plan and schedule for updates to the SSMP based on changes in operational strategies or deficiencies found in the SSMP.

4. Evaluate the effectiveness of the City’s SSMP and compliance with each WDR requirement using the ranking methodology outlined in Table 10-1.

Table 10-1: SSMP Audit Ranking Criteria
Ranking Ranking Basis
In Compliance All requirements specified in the element are met.

Substantial Compliance The majority of requirements in the element are met.

Partial Compliance Half of the requirements in the element are met.

Marginal Compliance Less than half of the requirements in the element are met.

Out of Compliance None of the requirements in the element are met.

The SSMP Audit Report must be signed and certified by the Legally Responsible Official (LRO).

The SSMP Audit Report must be certified using the language provided below:
“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”
Subsequent SSMP audits must be conducted continuously on a three-year interval following the schedule outlined below which is based on the dates required by the 2022 WDR:
• SSMP Audit Period: May 2, 2024 - May 2, 2027 (Audit report due 11/2/28) • SSMP Update: Update due 5/2/31.

Additional SSMP Audit and SSMP Update regulatory schedules required after the dates shown above should be identified in the following link:
https://www.waterboards.ca.gov/water_issues/programs/sso/lookup/ To assist in the audit process, the City should consider quarterly or semiannual reviews and revisions to specific SSMP Elements and associated supporting documents. These reviews and revisions will help ensure current operational practices and procedures are reflected in the

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SSMP and documentation of these activities is readily available during an audit by the Regional Water Quality Control Board, and/or State Water Resources Control Board.

SSMP Audit Reports must be kept on file and submitted to the online CIWQS Sanitary Sewer Database within six (6) months after the end of the 3-year audit period.

The City utilizes the following 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?

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.

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ELEMENT 11 - COMMUNICATION PROGRAM
Communicating the objectives of the SSMP and the importance of sanitary sewer system management practices to the public is essential. An informed public can assist and support the City by reducing customer caused blockages, which will potentially decrease sewer spills.

11.1 Regulatory Requirements
WDR Order No. 2022-0103-DWQ Section D 11 states:

The Plan must include procedures for the Enrollee to communicate with:
o The public for:

▪ Spills and discharges resulting in closures of public areas, or that enter a source of drinking water, and
▪ The development, implementation, and update of its Plan, including opportunities for public input to Plan implementation and updates.

o Owners/operators of systems that connect into the Enrollee’s system, including satellite systems, for:

▪ System operation, maintenance, and capital improvement-related activities.

11.2 Communication Program
The purpose of the City sanitary sewer system communication program is to educate stakeholders, which include residential and commercial users of the collection system, about the SSMP. Public awareness of different components of the SSMP is accomplished through different mediums and may reach different audiences. The following are activities that the City practices to increase awareness and education about the importance of having a properly constructed, maintained, and operated sewer collection system.

Table 11-1: City Communication Program Overview
Activity Frequency Stakeholders
City Website:
https://pismobeach.org/1 Year-round All
City Council Meetings First and Third Tuesday of
each month @ 5:30 pm All
Social Media – Facebook,
Instagram, Twitter, Youtube Year-round All
City Office Year-round All

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11.2.1 City Website
Information is posted on the City website, https://pismobeach.org/1 and includes reports, documents, maps, links, City meeting minutes and agendas, educational material, and public service announcements. The City SSMP can be found on the City website. Sewer spill emergency contact information is also provided on the City website.

Updates and revisions to the SSMP will be posted and maintained on the City website when completed.

11.2.2 City Council Meetings
City Council Meetings are generally held on the first and third Tuesday of each month at Council Chamber at City Hall, 760 Mattie Road. Utility sewer operation, Sewer Spill Reports, SSMP updates, significant revisions, audits and SSMP status reports are presented at the Council meetings to receive input.

11.2.3 Social Media
The City uses social media (Facebook, Instagram, Twitter, & YouTube) to post information about utility projects, public education and outreach, and highlight items on the Council agenda.

11.2.4 City Public Works Office
The City Office located at 760 Mattie Road, has copies of educational material, public service announcements, and staff that provide assistance and education to the public. Office hours are Monday- Friday from 7:00am to 4:00pm.

11.2.5 Public Notices for Spills – Public Areas
The public is notified of spills and discharges that result in closures of public areas (including streets and surface waters) by erecting cones and barricades, and by posting warning signs in accordance with the Spill Emergency Response Plan. The necessary equipment and signage are kept in the City’s emergency response vehicles.

11.2.6 Public Notices for Spills – Public Water Systems The City has not identified water purveyors, other than the City itself that would need be notified in the event of a sewer spill if one occurred within the vicinity of a source of drinking water. If systems are identified in the future their contact information will be listed in the is section of the SSMP so that City staff may contact them in the event of a sewer spill in their vicinity.

11.3 Satellite Systems
There are no satellite sewer systems that discharge to the City of Pismo Beach.

The City utilizes the following Performance Indicators for measuring effectiveness of this Element:
o Does the City place all SSMP action items on the agenda for regular counsel/board meetings?
o 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? o Does the City perform outreach to residential customers?

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

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Element 2 – Organization

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APPENDIX 2
2A Organization Chart and Contact Information

Public Works

Public Works
Director
City Engineer
Senior Engineer /
Engineer
Capital Projects
Manager
Senior Management
Analyst Permit Technician
Utilities
Manager
Water System
Supervisor
Water System Operator
(3)
Wastewater Supervisor
WW Plant Operator (4)
PT Office Assistant Regulatory Compliance
Coordinator
Facilities
Manager
Streets Supervisor
Maintenance Worker
(4)
PT Maintenance
Worker (2)
Parks Supervisor
Maintenance Worker
(Parks) (4)
Maintenance Worker
(Sanitation) (2)
PT Maintenance
Worker (3)
Facility and Fleet
Supervisor
Maintenance Worker
(Facilities) (2)
Fleet Mechanic (1)
PT Maintenance
Worker (1)
GIS AnalystAdministrative
Secretary

City Of Pismo Beach Wastewater Operators

Utility Manager- Jacob Smith 805-773-7075 [email protected] Wasewater Systems Supervisor- Sean Campbell 805-770-1462 [email protected]
Regulatory Compliance Coordinator- Jack Armstrong 805-773-7067 [email protected]
Wastewater Plant Operator 1- Luis Castaneda 805-441-9054 [email protected] Wastewater Plant Operator 1- Richard Blessing 805-441-9162 [email protected] Wastewater Plant Operator 1- Jesus Navarro 805-441-9215 [email protected] Wastewater Plant Operator 1- Luke Gaalswyk 805-441-9329 [email protected]

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Element 7 – Pipe Blockage Control Program

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APPENDIX 7
7A What Not to Flush Flyer
7B Roots, Wipes and FOG Outreach

Many household
cleaning products are
labeled and marketed
as disposable; many
baby hygiene prod-
ucts are labeled both
disposable and flush-
able. And while these
products may be mar-
keted as a conven-
ience item in this
way, the truth is that
these household wipes and cleaning towelettes have the ability to clog and stop up not only the sewer line on your property, but also can cause blockage and service problems in the public sew- er system and pump stations. Unlike toilet paper, these products don’t break down once they are flushed. They can cause block- ages in your private sewer lateral, especially older pipelines that may have grease, roots, or other obstructions already existing.

A repair of the private
sewer lateral can leave the
homeowner with an ex-
pensive repair bill. On a
larger scale when these
products make their way
into the public sewer system they col-
lect together and cause clogs in the
sewer main lines and get tangled in
pump stations requiring repair or re-
placement of equipment.

The following items
should never be flushed
into the sewer system:
• Disinfecting wipes, Baby
wipes.
• Q-tips.
• Toilet cleaning pads.
• Mop or “Swiffer” type
refills.
• Paper towels.
• Moist towelettes.
• “Disposable” Kitty Litter
• Dental Floss
• Any consumer item that
is not toilet paper.

Public Works Department
(805) 773- 4656

City of Pismo Beach Pipe Blockage Control Program
Don’t Let Roots, Wipes, and FOG Cause Sewer Problems

Your home’s plumbing is connected to the public wastewater system through an underground pipe called a “private sewer lateral.” As the property owner, you own this pipe and are responsible for keeping it flowing freely and repairing cracks and breaks. Laterals do not necessarily end at the curb or property line but extend all the way to the public sewer main, which often is located in the middle of the street. The City of Pismo Beach maintains the public sewer.

Preventing Sewer Spills
These steps can help you avoid the unpleasant and usually costly experience of a sewage backup in your home.
• Do not pour Fats, Oils or Grease (FOG) down drains. After soaking a greasy pan, place a paper towel over the drain basket to catch grease and food particles as you slowly pour the water down the drain. Put the paper towel in your green waste cart. Collect waste cooking oil and grease in a container with a tight-fitting lid and bring it to a hazardous waste collection center or dispose of into the trash. • Do not flush wipes, diapers or feminine hygiene products, even if they are labeled “flushable.” As homes age, roots often infiltrate sewer laterals. So-called flushable products catch on these intrusions, or on grease build-up, and form clogs and sewer backups.
• Don’t plant trees and large shrubs near sewer lines. Roots grow toward sewer line cracks in search of water, often forming root balls that clog the line. • When buying a home, consider having the sewer lateral inspected. A licensed plumber’s video inspection may reveal cracks, breaks, offsets, and root intrusion. The pipe may need to be cleaned, repaired, or replaced.

A Simple Device Can Protect Your Home
An overflow protection device or sewer backwater valve can prevent sewage from backing up into your home. If a clog occurs in the public sewer main or in your private lateral downstream of the device, an overflow protection device keeps the spill outside. While still not desirable, an outside spill avoids property damage, substantially reduces health risks, and can be cleaned up much more quickly and easily.

If you have an overflow protection device (backwater valve/backflow preventer), inspect it periodically to make sure it is working correctly and not inadvertently covered with dirt. If an overflow occurs and the device is not operating properly, your insurance might not fully cover the cost of property damage.

If you don’t have an overflow protection device, consider installing one. We recommend that a licensed plumber install the device, since elevation and location are critical for it to function properly.

Tree Roots
Roots thrive in the warm, moist, nutrient-rich atmosphere above the water level inside sanitary sewers. The flow of warm water inside the sewer pipe causes water vapor to escape to the cold and/or dry soil surrounding the pipe. Tree roots are attracted to the water vapor leaving the pipe and they follow the vapor trail to the source of the moisture, which is usually from cracks or loose joints in the sewer pipe. Tree roots will penetrate the opening to reach the nutrients and moisture inside the pipe. This continues in winter even though trees appear to be dormant. Once inside the pipe, roots will continue to grow and if not disturbed, they will completely fill the pipe with many hairy root masses at each point of entry. The network of roots grows, forming a root ball inside the pipe, trapping grease, tissue paper, and other debris discharged from the residence or business.

Homeowners will notice the first signs of a slow flowing drainage system by hearing gurgling noises from toilet bowls or drains become slower when emptying their tubs. A complete blockage will occur if no remedial action is taken to remove the roots and resulting blockage.

As roots continue to grow, they exert considerable pressure at the crack or joint where they entered the pipe. The force exerted by the root growth can break the pipe and may result in total collapse of the pipe. Severe root intrusion and structurally damaged pipes will require replacement. Tree roots growing inside sewer pipes are generally the most expensive sewer

maintenance item experienced by City residents. Roots from trees growing on private property throughout the City sewer areas are responsible for many of the sanitary sewer backups and damaged sewer pipes. Homeowners should be aware of the location of their building sewer and refrain from planting trees, bushes, and hedges near the building sewers. You may want to consult tree experts and ask their advice. The replacement cost of a building sewer line as a result of damage from tree roots can be very expensive.

If your home was built before 1980, you may have clay or iron pipes. These pipes are more likely to have cracks or joint problems caused by ground settling or freeze/thaw cycles than PVC pipes. Look at your yard and walk above the area where your building sewer is located. Walk with a person on each side of you, holding hands with your arms stretched out wide. If anyone bumps into a tree or large bush before you get to the street or sewer main, your sewer lateral may be subject to root intrusion.

Other than removing the trees or replacing the building sewers with PVC pipe, there isn’t any permanent solution. If the blockage is bad, the roots have to be cut and flushed away. The foam-type aquatic herbicide can be added a couple weeks later. The foaming herbicide fills the pipe, killing the roots on the top of the pipe as well as the sides. Annual use usually will keep them from returning. Please do not use any copper sulfate type root-killer. The copper crystals will only affect roots on the bottom of the pipe, and since roots are found in the top of the pipe, above the water level, only a tiny part of the root problem will be affected. Also, the copper will end up at the wastewater treatment plant and may adversely affect the sludge treatment process and cost the municipality and you more money.

If your plumber has to cut out roots from your building sewer, please call (805) 773-4656 and the Public Works Department know. We will send a crew to make sure that the roots the plumber cut out do not cause problems for your neighbors downstream.

Sewer System Management Plan – Revision 02
Element 10 – SSMP Audits

City of Pismo Beach
May 2026

Page 10 ends

APPENDIX 10
10A Audit Data and Records Request

SSMP AUDIT DATA & RECORDS REQUEST
A. SSMP ADMINISTRATIVE YES LOCATED
WHERE?NO N/A COMMENTS
A1 a.Has your agency enrolled in the State-wide GWDR and designated the responsible or authorized representative (LRO)?
b.Provide a copy of the SSMP Certification in CIWQS.
c.Provide a copy of the CIWQS print-out for all LROs and Data Submitters.
d.Provide a copy of your Operational Report(s) from CIWQS. e.

Does the SSMP include a narrative that discusses; summary of plan and associated schedules, sewer system asset overview, updated maps?
A2 a.Has your agency adopted a SSMP?
b.Provide a copy of the SSMP.
c.

Provide a copy of the Meeting Minutes for the agency
governing body's meeting during which the SSMP was
adopted.

A3 a.Does your agency have a copy of the GWDRs available to agency staff? Where is it kept?
A4 a.

How does agency ensure revenues and expenditures related to sanitary sewer system are available to; comply with General Order, fully implement the SSMP, conduct O&M and necessary repairs, ensure proper spill response?
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SSMP AUDIT DATA & RECORDS REQUEST
B. GOALS YES LOCATED
WHERE?NO N/A COMMENTS
B1 a.Has your agency developed SSMP and Spill reduction goals? b.

Provide documentation that your agency has made progress toward meeting these goals.

C. ORGANIZATION YES LOCATED
WHERE?NO N/A COMMENTS
C1 a.Does your SSMP clearly identify the names and job titles the LROs?
C2 a.

Does your SSMP have an organizational chart or table showing individual roles and responsibilities for implementation of the SSMP?
b.Are names, titles, and telephone numbers provided in this chart or table?
C3 a.Is the chain of communication for reporting Spills included in the SSMP?
b.Are names, titles, and telephone numbers provided in this chain of communication?
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SSMP AUDIT DATA & RECORDS REQUEST
D. LEGAL AUTHORITY YES LOCATED
WHERE?NO N/A COMMENTS
D1 a.

Provide the sanitary sewer system use ordinances, service agreements, or other legally binding procedures or documents, which demonstrates the agency's legal authority:
b.Prohibit illicit discharges
c.

Collaborate w/ Stormwater Agencies for sewer spill response and prevent cross connections of sanitary sewer and storm sewer infrastructure.
c.Require that sewers and connections be properly designed and constructed
d.

Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency
e.Enforce any violation of its sewer ordinances
f.

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

E. OPERATIONS AND MAINTENANCE (O&M)YES LOCATED
WHERE?NO N/A COMMENTS
E1 a.Provide the following documents:
b.An updated map of the agency's sanitary sewer system and storm drain system.
c.A schedule for maintenance and cleaning of the sanitary sewer system.

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SSMP AUDIT DATA & RECORDS REQUEST
d.How do O&M and R&R schedules enhance System Resilience? e.Documentation for maintenance and cleaning of the sanitary sewer system.
f.Documentation for scheduled and conducted activities, such as work orders and/or reports and invoices from contractors. g.The O&M contract if the agency's collection system is operated and maintained by a contract operations firm.
h.The agency's Rehabilitation and Replacement Plan
i.» Summary of the agency's CCTV program and schedule.

Include samples of inspections and summary of findings. j.» List of current and planned projects
k.» Time schedule for planned projects
l.» Schedule for developing the funds needed for
rehabilitation and replacement projects
m.Standard Operating Procedures for Sewer System Operations and Maintenance activities.
n.

Training records for staff operations and maintenance
activities and contractor operations and maintenance
activities. Training records for CIWQS reporting, Spill volume estimation, Spill response training.

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SSMP AUDIT DATA & RECORDS REQUEST
o.
» All applicable licenses and certifications required for agency or contract staff. Provide documents stating this requirement.
p.Assessment of O&M Staff "Core Competencies" (Skills,
Knowledge and Abilities)
q.Equipment and replacement part inventories, including identification of critical replacement parts.
r.
» If critical replacement parts are not kept in stock, identify and provide method in which these parts are
acquired when needed (List of emergency contractors
and/or suppliers).
s.» If critical replacement parts are not kept in stock, provide applicable mutual aid agreements.
q.Equipment and replacement part inventories, including identification of critical replacement parts.
r.
» If critical replacement parts are not kept in stock, identify and provide method in which these parts are
acquired when needed (List of emergency contractors
and/or suppliers).
s.» If critical replacement parts are not kept in stock, provide applicable mutual aid agreements.

F. DESIGN & PERFORMANCE PROVISIONS YES LOCATED
WHERE?NO N/A COMMENTS
F1 a.Provide the following documents:
b.Design and construction standards and specifications for:
c.» the installation of new sanitary sewer systems
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d.» pump stations and other appurtenances specific to the agency's collection and conveyance system
e.» the rehabilitation and repair of existing sanitary sewer systems
f.

Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances specific to the agency's collection and conveyance system and for rehabilitation and repair projects.

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SSMP AUDIT DATA & RECORDS REQUEST
G. SPILL EMERGENCY RESPONSE PLAN YES LOCATED
WHERE?NO N/A COMMENTS
G1 a.Provide the agency's Spill Emergency Response Plan b.

Notification procedures ensuring that the primary responders, regulatory agencies, and potentially affected entities are informed of all Spills in accordance with the Monitoring and Reporting Program, Order No. 2022-0103.
c.A program to ensure an appropriate response to all spills. d.

Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Spill Emergency
Response Plan and are appropriately trained.
e.Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities. f.Procedures to address spill volume estimation.
g.

A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States.
h.

A program to ensure that all reasonable steps are taken to minimize or correct any adverse impact on the environment resulting from the Spills, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge.
i.

Plan to coordinate with storm drain agencies and other
impacted utilities in the event of a Spill. Plan to conduct Post Spill Assessments.

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H. SEWER PIPE BLOCKAGE CONTROL PROGRAM YES LOCATED
WHERE?NO N/A COMMENTS
H1 a.Public Education and Outreach Program for pipe blocking substances.
b.Disposal facilities for pipe blocking substances.
c.

Ordinance demonstrating the agency's legal authority to prohibit discharges to the sewer system and prevent spills and blockages.
d.

Requirements to install grease removal devices, design
standards for these devices, maintenance requirements, BMPs, recordkeeping and reporting requirements.
e.

Ordinance demonstrating the agency's legal authority to prohibit FOG discharges to the system and inspect FOG
producing facilities.
f.Evidence of FOG Control Program inspection and enforcement activities.
g.Documentation of hot spots in the collection system, which are caused by FOG.

I. SYSTEM EVALUATION, CAPACITY ASSURANCE, AND CIP YES LOCATED WHERE?NO N/A COMMENTS
I1 a.Provide procedures to evaluate the sanitary sewer system assets. b.Percentage of system assessed annually and rationale for this frequency.

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SSMP AUDIT DATA & RECORDS REQUEST
c.

Provide information that demonstrates condition assessment prioritizes areas that: 1) Have high level of environmental consequences if vulnerable to failure or are deficient for any reason; 2) Are located in or within the vicinity of surface waters, steep terrain, high groundwater elevations, and environmentally sensitive areas; 3) Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act section 303(d) List
d.

Provide information demonstrating system is assessed using visual observations, video surveillance and/or other
comparable system inspection methods.
e.

Provide information demonstrating corrective actions for areas that may contribute to exiting of sewage from the system which can reasonably be expected to discharge into a water of the State.
f.

Provide information that demonstrates you have identified 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
g.

Provide analysis and 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.

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h.

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

Demonstrate how corrective actions are prioritized based on these condition assessments based on the severity of the consequences of potential spills.
j.

Capital Improvement Plans: based on the results of these condition assessments provide the following:
1) project schedules, including completion dates for all rehabilitation and replacement projects or CIP;
2) Internal and External project funding sources for each project; 3) Information demonstrating coordination between operations and maintenance staff, engineering staff, and consultants during the planning, design and construction of CIP. If other utility agencies are impacted, document coordination efforts.

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J. MONITORING, MEASUREMENT & PROGRAM MODIFICATIONS YES LOCATED WHERE?NO N/A COMMENTS
J1 a.Adaptive Management strategies
b.· Provide relevant information, including audit findings, to establish and prioritize appropriate Plan activities;
c.
· Provide relevant information demonstrating the
implementation and measuring the effectiveness of each Plan Element;
d.· Provide relevant information demonstrating the success of the preventive operation and maintenance activities;
e.
· Provide relevant information demonstrating update of plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations;
f.Identification of SSO trends.

K. SSMP PROGRAM AUDITS YES LOCATED
WHERE?NO N/A COMMENTS
K1 a.Provide historical SSMP Program Audit Reports.

L. COMMUNICATION PROGRAM YES LOCATED
WHERE?NO N/A COMMENTS
L1 a.Provide the agency's Communication Program and evidence of its implementation.

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