Sewer System Management Plan
City of Pomona
Water Resources Department
752 W Commercial Street
Pomona, California 91768
WDID #4SSO10418
Updated Adoption: April 21, 2025
Updated Adoption: October 15, 2018
Updated Adoption: October 21, 2013
Original Adoption: October 20, 2008
Agency Revision Team
Julie Carver
Environmental Compliance Supervisor
Romell Eutsey
Wastewater System Supervisor
Mike Moody
Wastewater Collection System Crew Chief
Nichole Horton
Principal Water Engineer
Jorge Anaya
Senior Water Resources Engineer
Certified by: Legal Responsible Official (LRO)
“I certify under penalty of perjury under the laws of the State of California that the electronically submitted information was prepared under my direction or supervision. Based on my inquiry of the person(s) directly responsible for gathering the information, to the best of my knowledge and belief, the information submitted is true, accurate, and complete, and complies with the Statewide Sanitary Sewer Systems General Order. I am aware that there are significant penalties for submitting false information.” Name of LRO
Position
Signature
Chris Diggs
Water Resources Director
Date Approved: _____________________
Table of Contents
Acronyms 5
Element 1: Sewer System Management Plan Goal and Introduction 6
1.1 Order Regulatory Context 6
1.2 Sewer System Management Plan Update Schedule 7
1.3 Sewer System Asset Overview 8
Element 2: Organization 10
2.1 Order Requirements Summary 10
2.2 Agency Organization 10
2.2.2 Agency Organizational line of authority and chain of communication for reporting spills to the State, regional boards, and other agencies. 11 Element 3: Legal Authority 15
3.1 Order Requirement Summary 15
3.2 Summary of City’s Existing Legal Authority 16
3.2.1 Prevention of Illicit Discharges 16
3.2.2 Domestic Discharges 17
3.2.3 Industrial Discharges 18
3.2.4 Proper Connections and Construction 18
3.2.5 Accessibility for Maintenance, Inspection and Repair 19
3.2.6 Limit of fats, oils, grease and debris discharges 20
3.2.7 Enforcement 21
Element 4: Operations and Maintenance Program 23
4.1 Order Requirements 23
4.2 Updated Map of Sanitary Sewer System 23
4.2.1 Preventive Operations and Maintenance Activities 23
4.2.2 Training 26
4.2.3 Equipment Inventory 27
Element 5: Design and Performance Provisions 28
5.1 Order Requirement Summary 28
5.2 Updated Design Criteria and Construction Standards and Specifications 28
5.2.1 Standards for Design, Construction, Inspection, Rehabilitation, 28 and Repair 28
5.2.2 Standards for Inspection, Records, and Testing 30 Element 6: Spill Emergency Response Plan 32
6.1 Order Requirements Summary 32
Element 7: Sewer Pipe Blockage Control Program 33
7.1 Order Requirements Summary 33
7.2 Sewer Pipe Blockage Control Program Plan 33
Element 8: System Evaluation, Capacity Assurance and Capital Improvements 35
8.1 Order Requirements 35
8.2 System Evaluation and Condition Assessment 36
8.3 Capacity Assessment and Design Criteria 39
8.4 Prioritization of Corrective Actions 46
8.5 Capital Improvement Plan 46
Element 9: Monitoring, Measurement, and Program Modifications 48
9.1 WDR Requirements Summary 48
9.2 Discussion on Monitoring, Measurement, and Program Modifications 48
9.3 SSMP Modifications 51
Element 10: Internal Audits 52
10.1 WDR Requirements Summary 52
10.2 Discussion of SSMP Program Audits 52
10.3 SSMP Program Audits 53
Element 11: Communication Program 55
11.1 WDR Requirements Summary 55
11.2 Regulatory Requirements for Communication Program 55
11.3 Discussion of Communication Program 55
11.4 Public Education and Outreach Media 57
11.5 Satellite Agencies 58
Acronyms
BMP
Best Management Practices
CCTV
Closed Circuit Television
CSA
Compliance Schedule Agreement
CIP
Capital Improvement Program
CIWQS
California Integrated Water Quality System
CMMS
Computerized Maintenance Management System
CAMOM
Capacity Assurance, Management, Operations, and Maintenance COD
Chemical Oxygen Demand
CSM
Collection System Maintenance
CWA
Clean Water Act
CWEA
California Water Environment Association
DEH
Department of Environmental Health
EPA
Environmental Protection Agency
FOG
Fats, Oils, and Grease
FSE
Food Service Establishment
GIS
Geographical Information System
I/I
Inflow and Infiltration
KPI
Key Performance Indicator
LACSD
Los Angeles County Sanitation Districts
LACP
Lateral Assessment Certification Program
LARWQCB
Los Angeles Regional Water Quality Control Board
LRO
Legally Responsible Official
MACP
Manhole Assessment Certification
MRP
Monitoring and Reporting Program
NASSCO
National Association of Sewer Service Companies
NPDES
National Pollutant Discharge Elimination System
O&M
Operations and Maintenance
OES
Office of Emergency Services
PACP
Pipeline Assessment Certification Program
PIO
Public Information Officer
PWRP
Pomona Wastewater Reclamation Plant
SCAG
Southern California Association of Governments
SWRCB
State Water Resources Control Board
SSMP
Sewer System Management Plan
SERP
Spill Emergency Response Plan
WDR
Waste Discharge Requirements
Element 1: Sewer System Management Plan Goal and Introduction
1.1 Order Regulatory Context
The goal of the Sewer System Management Plan (SSMP) is to provide a plan and schedule to: (1) properly manage, operate and maintain all parts of the sanitary sewer system; (2) reduce and prevent spills, and (3) contain and mitigate spills that do occur.
The City of Pomona is located in Los Angeles County approximately 35 miles east of downtown Los Angeles, borders San Bernardino County’s western boundary and is just 5 miles north of Orange County. The City encompasses approximately 23 square miles and serves approximately 152,939 residents. The City incorporated in January 1888, became a Charter City in March 1911, and is currently the seventh largest city in Los Angeles County.
The sewer collection service area includes incorporated areas within the City limits and a limited area outside the City limits. The City collects and conveys sewer from the service area for treatment by the Los Angeles County Sanitation Districts (LACSD). Local City sewer mains discharge to several trunk sewers owned and maintained by the LACSD that run through the City.
The City’s Wastewater Division is responsible for the operation and maintenance of an extensive sewer collection system and is tasked with ensuring proper and efficient operation of the system. The City provides sewer service throughout the City and to a limited area outside the City limits. The City’s sewer collection system consists of approximately 317 miles of gravity sewer, four (4) pump stations (maintained by LACSD), 1.4 miles of force mains, and 6,360 manholes, and three ((3) siphons. The sewer lift stations are monitored by LACSD’s SCADA system.
Sewage collected by the City’s sewer collection system is conveyed to the Pomona Water Reclamation Plant (PWRP) for treatment and disposal under the authority of the LACSD. There are four pump stations located in the City and owned by the LACSD. In 2012 the City agreed to turn the pump stations over to the LACSD.
LACSD Pumping Plant #
Site Address
1 2394 S. San Antonio Ave.
2 2070 S. Garey Ave.
3 1026 W. Lexington Ave.
4 2800 Ficus St.
The four pump stations are owned, maintained, and operated by the LACSD under the terms of a new contract that was signed in 2012. The corresponding force mains are all owned and managed by the City except the one associated with plant number 4. LACSD owns and manages the other force main.
The City is dedicated to improving the condition and performance of its sewer collection system and reducing the occurrences of spills. Implementation of a sewer collection system operations and maintenance (O&M) program serves to ensure that the sewer collection system is routinely and properly maintained in a manner that minimizes failures and extends the longevity of the system. The City has updated the map of its system per Section 4.1 of the Order and established key performance indicators (KPIs) to measure compliance.
1.2 Sewer System Management Plan Update Schedule
Below is the schedule for plan update due dates for Pomona City, CS WDID Number 4SSO10418:
Plan
Schedule
Responsible Party
WW Sup
Eng
Ops
Prepare for next SSMP Audit
Begin in early 2027
X
X
X
Complete and Upload SSMP Audit
By 05/02/2027
X
X
Incorporate Audit Findings, Update Change Log, and Update SSMP 05/02/2031
X
X
Board Approval and LRO Certification of SSMP
By 05/02/2031
X
X
Additional Due Dates:
SSMP Plan Due Dates
05/02/2025
05/02/2031
05/02/2037
05/02/2043
Below is the schedule for Program Audit Due Dates:
Program Audit Due Dates
05/02/2024
05/02/2027
05/02/2030
05/02/2033
The city has established key KPIs to measure compliance.
Four (4) spills per 100-mile of collection systems.
Establishing a response time of 20-minutes during working hours, and 45 minutes during after-hours and weekends.
Taking reasonable steps and attempt to provide feasible alternatives to the reduction and mitigation of spills, including:
The First Street facility will have a designated area for temporary storage or retention of untreated sewer.
Reduction of inflow and infiltration. In an upcoming red flags construction contract, a bid option will address rehabilitation and/or replace specific manholes in the Phillips Ranch area wherein water is suspected to be infiltrating.
Use of adequate backup equipment. Collecting and hauling of untreated sewer to a treatment facility or an increase in the capacity of the system as necessary to contain the design storm event identified in the SSMP Leverage the City’s data from GIS and cleaning records to optimize gravity main cleaning frequencies as necessary to maintain KPI performance with available resources
1.3 Sewer System Asset Overview
This section must include a description of owned assets and service area, including the following:
• Unique service boundary conditions and challenge(s).
The City of Pomona is located in Los Angeles County approximately 35 miles east of downtown Los Angeles, borders San Bernardino County’s western boundary and is just 5 miles north of Orange County. The City encompasses approximately 23 square miles and serves approximately 145,502 residents. There are a total of 30,372 residential, commercial, and industrial service connections included in the system. In January 1888, the City became incorporated and became a Charter City in March 1911. The City is currently the seventh-largest city in Los Angeles County.
The sewer collection service area includes incorporated areas within the City limits and limited areas outside the City limits. The City collects and conveys wastewater from the service area for treatment by the Los Angeles County Sanitation Districts (LACSD). Local sewer mains discharge to several trunk sewers owned and maintained by the LACSD that run through the City.
The City’s Wastewater Division (Wastewater) is responsible for the operation and maintenance of an extensive wastewater collection system and is tasked with ensuring proper and efficient operation of the system. The City provides sewer service throughout the City and to limited areas outside the City limits. The City’s sewer collection system consists of approximately 317 miles of gravity sewer, four (4) pump stations (owned, maintained, and operated by LACSD), 1.4 miles of force mains, and 6,360 manholes, and two (4) siphons. The Wastewater division works closely with the Environmental division to ensure proper stormwater compliance, and support communication with all parties in case of a spill that may lead to receiving waters. The Engineering division works with Wastwater to ensure compliance with NASSCO inspection, construction specifications, and GIS reporting and data analytics. All staff have access to the sewer and stormwater infrastructure information using GIS, hydraulic modeling, and data reports.
Sewage collected by the City’s sewer collection system is conveyed to the Pomona Water Reclamation Plant (PWRP) for treatment and disposal under the authority of the LACSD. The four pump stations are owned, maintained, and operated by the LACSD since 2012. Currently the dual force main and pump station at location 4 is owned and operated by LACSD. The remaining force mains serving the other three pump stations are owned by the City until all four pump stations are improved an accepted by LACSD.
The City is dedicated to improving the condition and performance of its sewer collection system and reducing the occurrences of spills. Development and implementation of a sewer collection system operations and maintenance (O&M) program serves to ensure that the sewer collection system is routinely and properly maintained in a manner that minimizes failures and extends the longevity of the system. To support this program the City uses GIS enabled reporting, real-time field maintenance communication, and regular hydraulic modeling tools.
Element 2: Organization
2.1 Order Requirements Summary
Identify organizational staffing responsibility and integral for implementing the plan through an organization chart or narrative.
2.2 Agency Organization
An organizational chart for the City’s Water Resources Department serves to identify the administrative, maintenance, and management positions responsible for implementing, managing, and updating the overall measures in this SSMP Program. The organizational chart presented in Figure 2.2-1 shows the positions and sections within the City’s current organization responsible for concurrently implementing and managing various plans and procedures required to satisfy the elements of the SSMP, including responding, reporting, and certification of spills and this SSMP. Outlined below is the organizational staffing responsible and integral for implementation of the SSMP.
Figure 2.2.1
Name
Title
Phone Number
Email
CIWQS
Chris Diggs
Water Resources Director
(909) 802-7412
[email protected]
LRO
Romell Eutsey
Wastewater Operations Supervisor
(909) 802-7426
[email protected]
LRO
Mike Moody
Wastewater Collection System Crew Chief
(909) 802-7433
[email protected]
Data Submitter
Julie Carver
Environmental Compliance Supervisor
(909) 620-3628
[email protected]
Data Submitter
Nichole Horton
Principal Water Engineer
(909) 620-2212
[email protected]
N/A
Carlos Velarde
*WWMTII
(909) 802-7433
[email protected]
N/A
Richard Gutierrez
WWMTI
(909) 802-7433
[email protected]
N/A
Marcos Garcia
WWMTII
(909) 802-7433
[email protected]
N/A
Eric Saucedo
WWMTII
(909) 802-7433
[email protected]
N/A
Darrel Castro
WWMTII
(909) 802-7433
[email protected]
N/A
Jesus DeHaro
WWMTI
(909) 802-7433
[email protected]
N/A
WWMT
Vacant
Alex Curry
Stormwater Crew Chief
(909) 322-4811
[email protected]
N/A
* Wastewater Maintenance Technicians
2.2.2 Agency Organizational line of authority and chain of communication for reporting spills to the State, regional boards, and other agencies.
The City operates under the Council-City Manager form of government as shown in Figure 2.2.2. The City’s elected governing body consists of a Mayor and six (6) district council members. The Mayor is the presiding officer of the City Council and is elected at-large. Each council member is nominated by, and represents, the district in which he or she lives. The City Manager serves as the chief administrative officer of the City and is directly responsible to the Mayor and City council for the efficient and effective administration and daily operations of all City functions. The Council must certify the completed SSMP and ultimately share the responsibility that the sewer collection system is managed efficiently.
City CouncilCity ManagerCity AttorneyWater Resources Director(LRO)Environmental Crew Chief and FSE InspectorsCity ClerkEnvironmental Maintenance Workers I/IICode Compliance(Administration Dept.)Wastewater Collection System Crew ChiefCustomer Service Representative(Finance Dept.)Wastewater Maintenance Workers I/II/IIEnvironmental Compliance SupervisorWastewater System SupervisorPrincipal Water EngineerCity CouncilCity ManagerCity AttorneyWater Resources Director(LRO)Environmental Crew Chief and FSE InspectorsCity ClerkEnvironmental Maintenance Workers I/IICode Compliance(Administration Dept.)Wastewater Collection System Crew ChiefCustomer Service Representative(Finance Dept.)Wastewater Maintenance Workers I/II/IIEnvironmental Compliance SupervisorWastewater System SupervisorPrincipal Water Engineer City Council
City Manager
City Attorney
Water Resources Director
(LRO)
Environmental Crew Chief and FSE Inspectors
City Clerk
Environmental Maintenance Workers I/II
Code Compliance
(Administration Dept.)
Wastewater Collection System Crew Chief
Customer Service Representative
(Finance Dept.)
Wastewater Maintenance Workers I/II/II
Environmental Compliance Supervisor
Wastewater System Supervisor
Principal Water Engineer
City Council
City Manager
City Attorney
Water Resources Director
(LRO)
Environmental Crew Chief and FSE Inspectors
City Clerk
Environmental Maintenance Workers I/II
Code Compliance
(Administration Dept.)
Wastewater Collection System Crew Chief
Customer Service Representative
(Finance Dept.)
Wastewater Maintenance Workers I/II/II
Environmental Compliance Supervisor
Wastewater System Supervisor
Principal Water Engineer
Figure 2.2.2
Sewer Utility Organization
The Water Resources Director reports directly to the City Manager. The Wastewater System Supervisor, who reports to the Water Resources Director, oversees the Wastewater division. All nine (9) full time positions identified are necessary for the maintenance and operation of the sewer collection system. In addition to the Wastewater staff, other divisions such as Engineering, Environmental, Water Quality, and continual administrative support, provide support to the Wastewater division.
The organizational chart presented in Figure 2.2.3 shows the positions and divisions within the City’s current organization responsible for concurrently implementing and managing various plans and procedures required to satisfy the elements of the SSMP, including responding, reporting, and certification of spills.
Highlighted on the organizational chart are the current fiscal year’s budgeted positions in the Wastewater division, the division that is primarily responsible for operating and maintaining the sewer collection system. Examples of other divisions support includes Engineering for system mapping assistance, capital improvement, and GIS support. Environmental division assists with FSE inspections and assists the division when needed. Equipment maintenance and contract services are examples of other services paid for by the Wastewater division.
Figure 2.2.3 (on next page)
Wastewater Collection System Crew ChiefWastewater MaintenanceTechnician I (4)Wastewater Maintenance Technician III (2)Engineering Division: Principal Engineer, Senior Engineers (3), Assistant EngineersWater Resources DirectorCity ManagerMayor &City Council Members (6)Sr. Administrative Assistant Environmental DivisionSr. Management Analyst Wastewater MaintenanceTechnician II Wastewater MaintenanceSectionEnvironmental Crew Chief, Stormwater Maintenance Workers and Inspector for FSEsWastewater System SupervisorProgram Assistants (3) and Management Analyst Primarily responsible for the sewer collection systemCurrently providing support servicesProduction, Treatment, Water Quality, and Distribution Divisions Wastewater Collection System Crew ChiefWastewater MaintenanceTechnician I (4)Wastewater Maintenance Technician III (2)Engineering Division: Principal Engineer, Senior Engineers (3), Assistant EngineersWater Resources DirectorCity ManagerMayor &City Council Members (6)Sr. Administrative Assistant Environmental DivisionSr. Management Analyst Wastewater MaintenanceTechnician II Wastewater MaintenanceSectionEnvironmental Crew Chief, Stormwater Maintenance Workers and Inspector for FSEsWastewater System SupervisorProgram Assistants (3) and Management Analyst Primarily responsible for the sewer collection systemCurrently providing support servicesProduction, Treatment, Water Quality, and Distribution Divisions Wastewater Collection
System Crew Chief
Wastewater Maintenance
Technician I (4)
Wastewater Maintenance
Technician III (2)
Engineering Division: Principal Engineer, Senior Engineers (3), Assistant Engineers Water Resources Director
City Manager
Mayor &
City Council Members (6)
Sr. Administrative Assistant
Environmental Division
Sr. Management Analyst
Wastewater Maintenance
Technician II
Wastewater Maintenance
Section
Environmental Crew Chief, Stormwater Maintenance Workers and Inspector for FSEs Wastewater System Supervisor
Program Assistants (3) and Management Analyst
Primarily responsible for the sewer collection system
Currently providing support services
Production, Treatment, Water Quality, and
Distribution Divisions
Wastewater Collection
System Crew Chief
Wastewater Maintenance
Technician I (4)
Wastewater Maintenance
Technician III (2)
Engineering Division: Principal Engineer, Senior Engineers (3), Assistant Engineers Water Resources Director
City Manager
Mayor &
City Council Members (6)
Sr. Administrative Assistant
Environmental Division
Sr. Management Analyst
Wastewater Maintenance
Technician II
Wastewater Maintenance
Section
Environmental Crew Chief, Stormwater Maintenance Workers and Inspector for FSEs Wastewater System Supervisor
Program Assistants (3) and Management Analyst
Primarily responsible for the sewer collection system
Currently providing support services
Production, Treatment, Water Quality, and
Distribution Divisions
Spill Communication Structure
Historically, sanitary sewer overflow events were identified as SSOs. Currently the City manages these events as sewer spills. The communication structure for responding to a spill is also in the Spill Emergency Response Plan (SERP) Chapter 2(See Element 6). Also included in the SERP are the communication protocol, names, and telephone numbers for City staff required to respond, and a general description of the responsibilities for City staff responding to identified spill locations.
Element 3: Legal Authority
3.1 Order Requirement Summary
This element includes a discussion of the City’s legal authority, including its city code and agreements with cities and agencies for the conveyance, treatment, and disposal of sewer. The city possesses the necessary legal authority to:
Prevent illicit discharges into its sanitary sewer system from inflow and infiltration (I&I); unauthorized stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including rags and other debris that may cause blockages illicit discharges Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to storm sewer systems during spill events, and prevent unintentional cross connections of sanitary sewer infrastructure to storm sewer infrastructure.
Require that sewer system components and connections be properly designed and constructed.
Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee.
Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable The City’s current legal authority is established through existing codes, regulations, ordinances, and permitting procedures that allows the City to require and enforce various measures for ensuring the proper and efficient operation, management, and maintenance of the City’s sewer collection system.
These mechanisms include, but are not limited to, limiting the types of substances allowed to be discharged into the City’s sewer collection system, establishing requirements for the proper design, construction and connections to the City’s sewer collection system, ensuring access to City sewer pipelines for maintaining, inspecting and repairing the system, limiting the discharge of fats, oils, grease, and other types of debris that cause blockages, and enforcing violations of its sewer related ordinances, codes, and laws.
A vital component in preventing spills requires that the City have comprehensive policies and procedures that encompass, but are not limited to, the permitting, design, construction, inspection, monitoring, and enforcement of policies as they pertain to the City’s sewer collection system. To implement the various elements required to prevent spills to the maximum extent possible and meet state and federal requirements, the City must ensure that its existing codes, policies and procedures are such that the requirements necessary to require, implement, and fulfill the specific City needs are encompassed.
The City has codified several ordinances related to the sewer collection system in the Pomona City codes in Chapter 62, titled Utilities, under Article V, titled Sewage Disposal and Chapter 18, titled Stormwater Management, under Article X. In addition, the City has executed various agreements with cities and agencies adjacent to the City for the conveyance, treatment, and disposal of sewer. These agreements are approved by the City Council. Examples of these agreements include the agreement with Los Angeles County Sanitation District No. 21 to operate and maintain the four (4) pump stations within the City’s boundaries, agreements to accept sewer from adjacent communities, and agreements to send small amounts of sewer to other agencies for conveyance and disposal.
Additionally, the California Water Code Section 13271 of the California Code of Regulations, the Clean Water Act, Section 1251 of Chapter 33 of the United States Code, and the California Waste Discharge Requirements serve to ensure the City establishes the necessary codes, agreements, policies, and procedures to provide the City the legal authority to require and enforce the necessary requirements.
The city code sections currently governing the City’s sewer collection system are included at the following link:
Chapter 64, Article V Sewage Disposal
Chapter 18, Article X Stormwater Management
3.2 Summary of City’s Existing Legal Authority
The City’s legal authority and powers are established in the City’s code and provide the necessary measures to facilitate the control of inflow and infiltration (I/I); require proper design, construction, installation, testing, and inspection of new and rehabilitated sewers and laterals; control the discharge of fats, oils, grease and debris; and enforce violation of ordinances. Additionally, it allows the City to promote and protect the health, safety, and general welfare of all of the citizens of the City. The existing ordinances identify the City’s Public Works Director and/or City Engineer as the person responsible for approving and managing permit requirements with respect to the City’s sewer collection system.
The following sections include a summary of the City’s existing codes and ordinances as they apply to its wastewater collection system. As of April 2025, the ordinance is in review for update.
3.2.1 Prevention of Illicit Discharges
The City is required to prevent discharges of illicit and undesirable substances from entering the sewer collection system. Illicit discharges include, but are not limited to, the release of I/I, storm water, chemical dumping, unauthorized debris and constituents, and cut roots. Properly drafted ordinances provide the City the tools to identify and enforce penalties to prevent illicit discharges. The City’s current ordinances prohibiting illicit discharges to control both domestic and industrial discharges are discussed in the following sections.
3.2.2 Domestic Discharges
Chapter 62, Article V, Section 62-396, Dumping in Manholes, states that “it shall be unlawful for any person to dump anything in a sewer manhole unless the person has been issued, by the Public Works Director and/or City Engineer, a permit to dump into the manhole. This permit must be issued for specific discharge and states what is permitted to be dumped.” While this section controls discharges into the system via manholes, the type of substances allowed is discretionary. It is imperative that the City Engineer coordinate with the City’s Wastewater staff to ensure that substances that may be detrimental to the operation and maintenance of the system are not allowed into the system. The intent of this section is to prevent discharges via manholes and to allow the City to track and control the type and number of discharges. Often these discharges come from portable comfort stations or sewer cleanings.
Additionally, Chapter 62, Article V, Section 62-401, Compliance with Other Sewage Discharge Restrictions and Requirements, restricts what users can generally discharge into the collection system. This section requires that all persons “shall comply with all sewage discharge restrictions and other requirements of the LACSD and the United States, the state, and the city.” The Wastewater Ordinance for the Sanitation Districts of Los Angeles County, Part I, Section 103, Liquid Waste Disposal Policy, states:
“Wastewater originating within the Districts' boundaries will generally be accepted into the Districts’ sewerage systems, provided the wastewater will not, directly or indirectly: (1) damage structures; (2) create nuisances such as odors; (3) threaten public health; (4) impose excessive collection, treatment or disposal costs on the Districts; (5) interfere with wastewater treatment or residue disposal processes; (6) violate quality and pretreatment requirements set by the Districts or federal or state agencies; (7) detrimentally affect the environment or (8) cause the Districts to violate any terms or conditions of their facilities' permits or any other waste discharge or air quality requirements.” This statement, incorporated by reference into the City’s code, provides the City the authority to determine the extent of substances permitted to be discharged into the sewer collection system.
3.2.3 Industrial Discharges
City Code Chapter 62, Article V, Division 4, Industrial Wastes, describes limitations on industrial waste discharges and special permit requirements. Section 62-546 requires that the discharge of industrial wastes into a sanitary sewer shall be governed as follows:
(1) All wastes, however harmless, shall be reduced to a minimum in volume and strength, and fluctuations of temperature and flow shall be evened out by adequate storage before discharge. (2) All wastes, when necessary, shall be pretreated by screening, sedimentation, neutralization, or other approved methods to produce a quality and character of waste that shall conform to Section 62-504 of the City Ordinance. (3) Pretreatment of industrial wastes shall be at the source and at the expense of the agency producing such.
For both the domestic and industrial waste discharges, the City has included and delineated restrictions on what may be deposited into its sewer system.
3.2.4 Proper Connections and Construction
The requirements for the design and construction of new, rehabilitated, and replaced sewer system facilities, including mains, tie-ins, service laterals, cleanouts, manholes, and other system appurtenances, are necessary to ensure the proper operation of the sewer system. City Code Chapter 62, Article V, Division 1, from Section 62-392 to Section 62-401 includes the general design and construction requirements for the City’s sewer collection system. The sections include the requirements for sewer connection locations, pipe size, minimum grades, manholes, and construction requirements. City Code Chapter 62, Article V, Division 1, Section 62-397 provides the Public Director and/or City Engineer the authority to establish the requirements and approve the provisions of specifications for construction of any sewer built in the City.
Additionally, Section 62-504, approval of disposal requirements prerequisite to issuance of building permit, in the Industrial Wastes Division of the Code, requires every person applying for a building permit for construction of a new industrial building or industrial structure, or for an addition or alteration to an existing building or structure, to obtain a signed statement from the Public Works Director and/or City Engineer allowing the discharge into the sewer collection system. Although this requirement applies specifically to industrial facilities, it describes a process for the review and approval of construction plans, allowing the City the opportunity to ensure the safety of the sewer collection system.
The City prepared the City of Pomona Sewer Design Policy and Standard Drawings to supplement the City’s existing codes and provide additional information for the planning and design of sewer collection facilities within the City of Pomona. The policy has not been adopted as of the development of this document, outline and describe in one succinct document, the relevant City policies, applicable codes, engineering and operation practices, and procedures to plan, design, and build a cost-effective, reliable, and safe sewer collection system. The policy includes minimum design standards for sewer mains, sewer manholes, sewer laterals, and general guidelines for common sewer rehabilitation options. Also included are standard drawings, specifications and industry requirements for the planning and design of sewer infrastructure. In contrast to the City’s existing ordinances, the proposed sewer design policy designates the Public Works Director as the person with the authority to review and approve plans and construction related to the sewer collection system. The City of Pomona Sewer Design Policy and Standard Drawings link is included and are further discussed in Chapter 8 of this SSMP.
3.2.5 Accessibility for Maintenance, Inspection and Repair The City codes do not expressly document access requirements for maintenance, inspection, or repair of the wastewater collection system. Instead, accessibility requirements are managed through the plan reviews for new sewer service where City staff ensures that sewer system facilities are constructed to specific standards within the public right-of-way or within adequate, permanent easements.
However, Section 62-398, Sewer Construction Permit, Connection Permit and Inspection Fees, in Chapter 62, Article V of the City code implies that the City may have some accessibility rights in that it requires the Public Works Director and/or City Engineer to issue a permit before a sewer line may be constructed. As such, the Public Works Director and/or City Engineer has the opportunity to ensure that new sewer lines are accessible. Since this is not an explicit requirement, and it is based on the city engineer’s best engineering abilities, not all new sewer pipes may be designed with proper access to the facilities for maintenance, repair, replacement and/or rehabilitation purposes. Plus, City crews and authorized representatives may not have the right to access existing City sewer lines located on private property.
The City of Pomona Sewer Design Policy and Standard Drawings includes general procedures for ensuring proper access to the City’s sewer collection system is properly addressed in the planning and design phases of sewer projects. The policy includes information pertaining to the placement of sewer mains within the public right-of-way. It includes the requirement for easements and encroachments where public sewer mains are located outside of the public right-of-way and that permanent access easements will be provided with adequate widths to allow maintenance vehicles and necessary equipment proper access to all appurtenances and isolated reaches of sewer main. The policy also includes a summary of prohibited locations for installation of sewer mains and manholes without prior approval by the Water Resources Director and/or designee.
3.2.6 Limit of fats, oils, grease and debris discharges Chapter 62, Article V, Division 3, from the adopted ordinance Section 62-471 to Section 62-477 addresses sand and grease traps. With the update to Chapter 62 (Pending), Article V, Division 3, substantial changes were made to rename the section to “Sewer Pipe Blockage Control Program” for permit compliance per the Order. These sections clearly outline the intent and purpose of this section to establish regulations for the disposal of fats, oils, grease, rags, and other insoluble waste discharges from food service establishments (FSE) within the city and to allow the city to inspect FSE facilities and practices to ensure compliance with the Order. These appurtenances are required in all packing plants and other establishments that may be a source of food fats and greases with respect to grease interceptors, and in establishments equipped with wash racks, floor drains, or wash tanks for cleaning machined parts or other materials. Specifically, Sections 62-472, 62-473, and 62-474 address the requirements for the installation, minimum capacity and flow rate, and inspection and cleaning frequency of grease interceptors respectively. Sections 62-475, 62-476, and 62-477 respectively address the requirements for grease trap installation, inspection and cleaning frequencies. Staff or consultant have been inspecting FSEs on an annual basis and reviewing their maintenance logs, and issue violations if not compliant. This is being conducted with the NPDES Permit for Municipal Stormwater and Urban Runoff Discharges requirements, and the newly organic regulations. The FSEs pay an annual fee for inspections as part of their business license renewals and/or obtaining a new business license.
The City recently updated the Fats, Oils, and Grease (FOG) Control Program in Element 7. The FOG Control Program establishes the formal procedures City staff will implement to effectively reduce the direct or indirect discharge of all wastewater or waste containing FOG into the City’s sewer collection system. It includes several components necessary to reduce the quantity of FOG discharged into the City’s sewer collection system to achieve the goal of minimizing spills due to excessive FOG. The elements of the FOG Control Program include:
Kitchen Best Management Practices
Grease Trap Installation, Operation and Maintenance Requirements Grease Interceptor Installation, Operation and Maintenance Requirements Notification Requirements
Record Keeping and Reporting Requirements
Permits, Inspection, and Enforcement
Drawing Submittals
Public Education
With the implementation of the FOG Control Program, the City will continue to implement and enforce actions against FSEs of the sewer collection system that violate the prohibition of discharging FOG into the sewer collection system. The City will initiate enforcement actions for non-compliance, and it will be possible for other regulatory agencies, including the EPA or the State to initiate their own enforcement actions.
3.2.7 Enforcement
The authority for the City to enforce violations of the codes or other adopted policies is proposed in the updated Sewer Ordinance to be in Sec. 62-478 to Sec. 62-480, and Sec. 62-489. In addition, Chapter 1, General Provisions, Section 1-7 describes the general penalties for violating sections of the code and for continuing violations. Individuals convicted of a violation of the City Code that is not specifically declared to be an infraction shall be considered guilty of a misdemeanor and punished with a fine of not more than $1,000.00, imprisonment in the city or county jail for not more than six (6) months or both such fine and imprisonment.
Chapter 2, Article X, Code Enforcement includes information regarding the City’s authority to enforce penalties for violations of the City’s ordinances and City Code. Division 1, Section 2-1161, Authority to Cite Persons in Violation, provides the City Council the power to authorize its officers and employees the ability to enforce the provisions of the City ordinances and the City Municipal Code. Specifically, it states:
(a) The city council hereby authorizes all officers and employees of the city who have the duty to enforce city ordinances and this Code to cite persons for violation of such ordinances and this Code, pursuant to Penal Code § 836.5, provided such officers and employees have reasonable cause to believe that the persons to be cited have committed misdemeanors and infractions in their presence which are violations of the ordinance or section of this Code which such officers and employees have the duty to enforce and further provided that such officers and employees have satisfactorily completed the peace officers standards and training course provided for in Penal Code § 832.
Division 2, Administrative Citations, summarizes the City’s administrative citation program as an alternative method of enforcing violations of the City’s code. Section 2-1182 recognizes the police chief as the “enforcement official” and gives the police chief the authority to administer and enforce violations of the municipal ordinance that are determined to be infractions. Enforcement of violations shall be in accordance with Sections 2-1183 through 2-1190.
Element 4: Operations and Maintenance Program
4.1 Order Requirements
This element discusses the City’s operation, maintenance and other related measures and activities as they pertain to its sewer collection system.
The Order requires that the SSMP contain descriptive measures of the City’s Operations and Maintenance (O&M) Program that are implemented by the City to facilitate proper and efficient management and maintenance of the sewer collection system and affected appurtenances. The Order requires that the SSMP include a description of each of the following components as they apply to the City’s sewer collection system:
Updated map of the sanitary sewer system showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities within the boundary.
Routine preventive operations and maintenance activities by staff and contractors; including a data driven system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known or predicted problem areas. The preventive maintenance program has a system to document scheduled and conducted activities, such as work orders.
Provide training on a regular basis that covers the order requirements, SERP, estimation of spill volume for field operators, and CIWQS reporting procedures for staff submitting data.
Provide equipment inventory that includes the ID of critical replacement and spare parts.
4.2 Updated Map of Sanitary Sewer System
The City effectively manages and maintains information pertaining to the sewer infrastructure by means of GIS using ESRI’s ArcGIS software. The Wastewater Supervisor and Wastewater Crew Chief can access real time data through a dashboard that includes sewer and stormwater conveyance facilities within the entire system. The current map can be located here.
4.2.1 Preventive Operations and Maintenance Activities
The City has a comprehensive Operation and Maintenance Program, which includes a summary of the current procedures and practices as they pertain to the O&M activities related to sewer collection system. All data collected is stored on GIS and a dashboard has been created for quick real time overview.
The City’s sewer collection system requires frequent maintenance due to age, extended use, debris accumulation, and tree root intrusion. To minimize and prevent system blockages and extend the useful life of the sewer collection system, the City’s preventive maintenance program primarily includes the routine cleaning of all sewer pipelines. The preventive maintenance program also includes schedules focused and cyclic cleaning, root control, and response to customer complaints. The following paragraphs describe the City’s current preventive maintenance procedures as they apply to the sewer collection system.
Mechanical Cleaning
The City’s Sewer Maintenance Staff continually cleans the sanitary sewer system. In this manner, they can clean the entire system approximately once every 1 ½ years. They utilize three (3) combination jetter/Vactor vehicles. The sewers are typically cleaned by putting high-pressure water jetting nozzles in the pipe and manually removing debris from the downstream manhole. Purchased equipment or staff-made appurtenances are inserted at the downstream manhole to capture and remove debris, debris, roots, and FOG. The material is stored in a 10 yard roll away bin and disposed of properly by contractor. Progress ranges from 3,000 to 18,000 lineal feet per day, depending on the existing conditions, staffing available, and other assigned duties.
The City’s cleaning efforts focus on one (1) drainage area at a time. Although the map varies slightly year to year. Wastewater crews work daily to eliminate potential pipe and manhole blockages. There are currently two (2) crews, consisting of two (2) staff members each that are assigned to perform daily routine cleaning tasks with the jetter/Vactor. Additionally, crews clean high frequency maintenance locations monthly, quarterly, and bi-annually which have identified on a GIS map. These locations include areas identified as having excessive amounts of grease accumulation and concentration of roots. Staff primarily uses the combination jetter/Vactor vehicles for cleaning, and the trailer mounted jetter.
Root Treatment
The City’s root treatment program is performed by the City’s Wastewater staff utilizing Root X and Dukes Root Control by contractor. Pipelines identified as locations with root intrusion problems are treated and evaluated on a yearly basis. Target sites are in the older developed areas with large mature trees as well as locations identified via the CCTV inspection efforts that identify high concentration of roots. As locations are identified as requiring chemical treatment for root control, location information is recorded in the CCTV database, assessed, and evaluated for inclusion in the root control program.
Manhole Treatment Program
To control infestations of insects and to maintain adequate access to the system, the City’s sewer collection system manholes are systematically treated for the removal of roaches. The annual roach treatment is performed by an independent contractor retained by the City. Staff budgets for this treatment annually. Each chemical application can treat approximately 500 to 800 manholes per year. This contractor can apply the chemical at a rate of about 150 to 200 manholes per day. The manholes selected for treatment are identified by areas known to be prone to insect infestation, and observations made during the annual cleaning. After application, infestation is controlled in most cases is typically for two years (this is the company’s guarantee).
Although we know the chemical treatment is effective, the roach infestation moves around. One way in which we locate the infestation is through field observation while cleaning the sewer line. Another method of discovery comes from our experience. Staff has a good sense of how the population moves so we use that knowledge in determining where to apple the chemical along with using data from our customer callouts pertaining to roaches.
Response to Customer Notifications
City service calls are currently handled manually. All customer calls are routed to the Wastewater System Supervisor, Wastewater Collection System Crew Chief or designee from either the City’s Customer Services Section or the Pomona Police Dispatch Center. Customer notifications may also be received via the City’s GOVQA notification system currently in place. The GOVQA is Customer Relationship Management/Request Tracking software that allows internal and external notification of various issues via an email system. City staff is required to respond to issues received via the GOVQA system in a timely manner.
Response to customer notifications is performed by the Wastewater Collection System staff during business hours, and by the standby staff during non-business hours. The staff’s responsibility primarily includes assessing the complaint and resolving the potential problem.
Management of Operations and Maintenance Activities
In 2024, the City hired V & A Consulting Engineers to leverage the city’s data from GIS and cleaning records to optimize gravity main cleaning frequencies as necessary to maintain KPI performance with available resources. This is a valuable tool for the wastewater staff.
Tracking and reporting are done electronically using ESRI GIS system. The map serves to provide wastewater crews with a real-time comprehensive view of the progress of the preventive maintenance efforts by area.
Maintenance Data Management
Since the beginning of 2024, staff is working with engineering firm V&A Consulting Engineers to leverage data science to validate and quality check GIS and gravity main cleaning records. This effort also enables predictive modeling to fine-tune cleaning frequencies of individual gravity main segments while also identifying anomalies in observations made by cleaning crews that could be early indicators of emerging risks for potential spills.
The current CCTV data storage and management process, in place since October 2017, includes transferring the recorded data onto the City’s WinCan Web database server for future reference as needed. As of January 2025, WinCan Enterprise has been added to the City’s WinCan CCTV suite. WinCan Enterprise can create enhanced work orders specified for the CCTV truck, create advanced mapping and visualizations with all archived CCTV data, and lastly it has a comprehensive dashboard displaying CCTV inspections which have been integrated to our GIS server.
The City continues to work toward identification, integration, and utilization of a full-featured computerized maintenance management system (CMMS) to facilitate management of sewer facilities and resources. A versatile CMMS will allow staff to properly and efficiently organize, plan, and schedule the appropriate resources for routine preventive maintenance activities, coordinate and prioritize urgent and/or unique maintenance activities, and ensure uniformity and consistency in processing and tracking facility related information.
4.2.2 Training
Prior to performing any work in the City of Pomona, City Wastewater maintenance staff are trained on the existence and the provisions of the sewer operations system and maintenance policies, procedures, safety policies, and the equipment used. Additionally, these staff members are required to receive Collection System Maintenance (CSM) training and certification through CWEA. Training for operation of City equipment includes primarily “on-the-job” training in conjunction with weekly “tailgate” meetings to discuss safety issues. All new employees are required to watch new hire orientation videos regarding job safety, and Vactor/ combo unit safety.
The City requires maintenance staff to become CWEA certified and provides training opportunities to enable its maintenance staff to become and remain certified. The City assists with certifications by sponsoring preparation courses, certification exams, and requiring continuing education. Minimal certification is required for maintenance staff. However, the City will institute additional certification requirements if deemed necessary by governing authorities.
Each year in January, wastewater maintenance staff undergo spill scenario training to demonstrate the proper procedure for establishing manhole to manhole bypass system in the field.
The City also ensures that contractors for the City have appropriate training. The City has incorporated language in its various programs to require contractors working on City facilities to be adequately trained and provide proof for sewer collection system work. The contract specifications list Special Technical Provisions, in Section 1170, Paragraph 1.5, which states the contractor must maintain sewage flows and sewage bypass if necessary.
The city is currently a member of the DFK Solutions SERP Services. This service offers up to date training for staff that include consulting services, classes for spill volume and start time determination, CIWQS for the data submitters and LRO, surface water-sampling, classes on submittal of annual reports, and also offers safety tailgate trainings.
Lastly, to stay abreast of current technologies and ensure that the report is developed and maintained over the course of time, environmental/engineering staff has been developing its own familiarity with the SSMP and associated regulations. Hence, environmental/engineering staff is expected to attend and access CWEA technical meetings, regulations updates, seminars, such as Tri-State, and web site information for other agencies, to sustain an informed staff
4.2.3 Equipment Inventory
The wastewater division maintains an inventory of vehicles and sanitary sewer system replacement parts. The inventory of vehicles includes the vehicle type currently utilized to perform the necessary operation and maintenance activities of the City’s sewer collection system. A listing of the vehicles and replacement parts are in the O & M Plan, Chapter 2.
The vehicles and sanitary sewer system replacement parts are made readily accessible to staff. The replacement parts maintained in the City Water yard are for the specific types of repairs performed by Wastewater Maintenance staff. As necessary, maintenance staff solicits the utilization of resources, including equipment and staff, from other divisions of the Water Resources Department. For implementation of repairs that extend beyond the City’s internal resource capabilities, the City retains the services of professional contractors.
Element 5: Design and Performance Provisions
5.1 Order Requirement Summary
This chapter of the SSMP discusses the City’s design and construction standards and serves to fulfill the Design and Construction Standards SSMP requirement of this Orders. The City of Pomona Sewer Design Policy and Standard Drawings is included here for reference.
Updated design criteria and construction standards and specifications for the construction, installation, repair, and rehabilitation of existing and proposed system infrastructure components, including but not limited to pipelines, pump stations, and other system appurtenances. If existing design criteria and construction standards are deficient to address the necessary component-specific hydraulic capacity as specified in Section 8 (System Evaluation, Capacity, Assurance and Capital Improvements) of the Order, the procedures must include component-specific evaluation of the design criteria.; and Procedures and standards for inspecting and testing the installation of newly constructed, newly installed and rehabilitated system pipelines, pumps, and other equipment and appurtenances.
5.2 Updated Design Criteria and Construction Standards and Specifications The City’s current design and performance standards are addressed in the existing codes, regulations, ordinances, and permitting procedures that allow the City to require and enforce the proper design, construction, and connections to the City’s collection system, and ensure access to City sewer pipelines for maintenance, inspection, and repair for the system. The City of Pomona Sewer Design Policy and Standard Drawings were developed to supplement the City’s existing codes and sewer design policy, and to provide additional information for the planning and design of sewer collection facilities within the City of Pomona. The document outlines and describes the relevant City policies, applicable codes, engineering and operation practices, and procedures to plan, design, and construct a cost-effective, reliable, robust, and safe sewer collection system.
5.2.1 Standards for Design, Construction, Inspection, Rehabilitation, and Repair
Procedures and standards for the construction, inspection, and testing of newly constructed, installed, repaired, and rehabilitated system pipelines, pumps, and other infrastructure and appurtenances.
To address the components listed above in Section 5.1 and as required by the Order, the following subsections provide a summary of the applicable procedures that are currently being evaluated for implementation.
Design and Construction Standards and Specifications
The requirements for the design and construction of new, rehabilitated, and replaced sewer system facilities, including mains, tie-ins, service laterals, cleanout, manholes, and other system appurtenances, are necessary to ensure the proper operation of the sewer system. City Code Chapter 62, Article V, Division 1, from Section 62-391 to Section 62-396 includes the general design and construction requirements for the City’s sewer collection system. The sections include the requirements for sewer connection locations, pipe size, minimum grades, manholes, and construction requirements. All public sewer mains and associated infrastructure within the City are constructed by the City, under contract to the City, or by a private developer. The City has used the “Standard Plans for Public Works Construction” (Greenbook) written by the Public Works Standards, Inc. corporation and published by BNI Publications, Inc., the City of Pomona “Public Works Department Standard Drawings”, and City generated written specifications for sewer infrastructure. The City plans to develop and/or incorporate by reference a complete set of design and construction standards and specifications before 2030. The City’s Water Resources Director will review and update these standards and specifications annually and as updates are developed.
The City of Pomona Sewer Design Policy and Standard Drawings include minimum design standards for sewer mains, sewer manholes, sewer laterals, sewer saddles, and general guidelines for common sewer rehabilitation options. Also included are updated standard drawings, specifications, and industry requirements for the planning and design of sewer infrastructure. The City designs and manages force mains, inverted siphons, complete abandonment of infrastructure, and/or flow measurement devices. Design considerations for sewer facilities that the City considers non-standard, such as treatment plants, outfall sewers, energy dissipaters, regulating devices, and regulating devices, are not included in the City’s design policy, construction manual, and standard drawings. If these non-standard improvements are proposed they require prior review, approval, and testing from the City before design may proceed to construction.
Inspecting and Testing
Compliance with the sewer design policy requires the contractor performing work on the City’s sewer infrastructure to be responsible for conducting a CCTV inspection for all new and rehabilitated sanitary sewer systems and other appurtenances. The sewer contractor must submit a copy of the CCTV report and inspection documentation to the City’s Wastewater Supervisor at least thirty (30) working days prior to the anticipated date of final construction acceptance. The information provided by the contractor is subsequently reviewed by the City’s designated inspector and/or engineer for compliance with City design and construction policies.
5.2.2 Standards for Inspection, Records, and Testing
Inspection
Additional standards for the sewer system infrastructure inspection, records, and testing are provided by the City. In general, the NASSCO manhole, pipeline, and lateral defect descriptions are used during CCTV inspections for categorizing details. The defect descriptions are defined by the following code characterization types; structural, operation & maintenance, construction features, and miscellaneous features. NASSCO categorization and coding enables staff to quickly identify the highest observed severity grade, number of occurrences of severity items, and standard system of cataloging infrastructure. Pipe, manhole, and lateral assessment certification programs are referred to respectively as with the acronyms PACP, MACP, and LACP. The City requires all CCTV WinCan inspections to be completed with this standardized method.
Records
Each sewer asset in the City has digital, physical, or video record associated with it. Every report associated with an asset is documented catalogued and digitally saved. The City is committed to compiling accurate data and saving it to a virtual database. Physical data (plans, photos, and reports) that are generated and captured are archived in a physical vault in City Hall. For all constructed new infrastructure physical and virtual NASSCO, video, reports, and plans must be produced.
Testing
SWRCB requires that the City’s procedures, testing, design, construction standards, and construction specifications match their standards. This applies for the installation of new sewer systems, pump stations, appurtenances, rehabilitation, and repair of existing sanitary sewer systems. Staff requires construction acceptance testing for all sewer gravity and force mains.
All acceptance testing for gravity sewers is performed in the presence of the City’s inspectors or contractors. The construction project will not be accepted until all results of the exfiltration, infiltration, deflection, leak, air pressure, joint testing, water pressure, and final CCTV NASSCO assessments conform to City standards. The testing of sewers must meet the requirements of the project plans, specifications, and/or the established City standards. If the acceptance testing fails, the City must require the contractor to submit a repair plan and conduct the repair per the City’s approval. Acceptance testing is performed again until the testing results meet the City’s requirements.
Element 6: Spill Emergency Response Plan
6.1 Order Requirements Summary
This element of the SSMP provides a summary of the City’s Spill Emergency Response Plan (SERP). Complete documents and procedures for the City’s SERP are included here.
The SERP was updated in May 2024 and includes formal procedures for staff to contain, correct, and clean up spills. The intent of the Plan is to provide comprehensive document that includes components necessary for minimizing the effects of spills on the environment while protecting the public’s health and safety.
The SERP includes a strategy for the wastewater division to mobilize labor, material, tools, and equipment to contain, mitigate, and clean-up residuals from a spill and correct or repair any condition, which may cause or contribute to an un-permitted sewage discharge. The document provides the necessary guidelines for City staff to respond to a spill event and contains the following elements:
Introduction and Regulatory Requirements
Spill Emergency Response Procedures
Public Advisory of Sewage Contamination Procedures
Spill Reporting Requirements
Training Requirements
SERP Updating Requirements
Element 7: Sewer Pipe Blockage Control Program
7.1 Order Requirements Summary
This element discusses the City’s Sewer Pipe Blockage Control Program including identification of high frequency maintenance locations and source control.
The Plan must include procedures for the evaluation of the city’s service area to determine whether a sewer pipe blockage control program is needed to control fats, oils, grease, rags and debris.
Based on the history since the 2008 Order, the city has implemented a program for the control of fats, oils, grease, rags, and debris. The 2022 Order changed the name of the program, but the program elements remain the same. The program includes the legal authority, inspections, education, requirements to install devices, and compliance. The procedures must include, at a minimum:
An implementation plan and schedule for a public education and outreach program that promotes proper disposal of pipe-blocking substances.
A plan and schedule for the disposal of pipe-blocking substances generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of substances generated within a sanitary sewer system service area.
The legal authority to prohibit discharges to the system and identify measures to prevent spills and blockages.
Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, best management practices requirements, recordkeeping and reporting requirements.
Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the fats, oils, and grease ordinance.
An identification of sanitary sewer system sections subject to fats, oils, and grease blockages and establishment of a cleaning schedule for each section; and Implementation of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each section identified above.
7.2 Sewer Pipe Blockage Control Program Plan
The City has revamped the Sewer Pipe Blockage Control Program Plan to facilitate the maximum beneficial public use for the City’s sewer collection system. The plan outlines the procedures to prevent blockages of the sewer lines and pump stations.
The City’s Sewer Pipe Blockage Control Program documents the processes and procedures intended to provide the City with a comprehensive document that includes components necessary to reduce the quantity of FOG discharged into the city’s sewer collection system to achieve the goal of minimizing spills due to excessive FOG. Elements of the FOG Control Program include the following.
Kitchen Best Management Practices
Grease Trap Installation, Operation and Maintenance Requirements Grease Interceptor Installation, Operation and Maintenance Requirements Notification Requirements
Record Keeping and Reporting Requirements
Permits and Enforcement
Drawing Submittals
Public Education Outreach Program
The Plan has been updated to include the required procedures per the Order. The Plan can be located here.
Element 8: System Evaluation, Capacity Assurance and Capital Improvements
8.1 Order Requirements
This element will discuss the City’s capacity management measures to address the current and future capacity requirements of its collection system and the recommended capacity improvement projects.
The Order requires that the City prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate design storm or wet weather event. At a minimum, the plan must include:
a) System Evaluation and Condition Assessment
Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to a spill caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from spills that escape from the system) associated with conditions like those causing overflow events, estimates for the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events. b) Capacity Assessment and Design Criteria
Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and the steps needed to establish a short- and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. c) Prioritization of Corrective Actions
The findings of the condition assessments and capacity assessments must be used to prioritize corrective actions. The city will consider the severity of the consequences of potential spills. d) Capital Improvement Plan
The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding.
8.2 System Evaluation and Condition Assessment
The City has developed a sewer hydraulic model under the guise of the 2018 Strategic Plan by calibrating and conducting capacity analysis using InfoWorks ICM (by Innovyze).
The 2019 hydraulic sewer model is based upon the updated GIS sewer database and is includes sewer mains eight inches (8”) and larger. Additional components of the sewer system were analyzed under the current conditions and included the following:
514,542 feet or 97.5 miles of sewer pipelines
1,630 manholes (includes 6 “outfall” manholes)
4 pump stations
A full assessment of the model was completed in 2019. An assessment of the hydraulic capacity of major sewers and pump stations were performed using both dry and wet weather. The system evaluation was performed to identify improvements necessary to meet the requirements of the Capacity Assurance, Management, Operations, and Maintenance (cMOM) Plan. The 2019 the Sewer Master Plan included a summary of the findings and recommendations to meet the cMOM program assessment requirements and anticipated state or federal regulations.
The model will be used to determine if there are hydraulic capacity deficiencies. To ensure an approach, consistent with industry practices, it is necessary to apply capacity triggers to each model for analysis. Listed below are some of the triggers to be used in Pomona’s sewer hydraulic model:
Hydraulic water freeboard must be less than 5 feet
No pipelines surcharging or flowing full under Dry or Wet Weather conditions (when Hydraulic Grade Line is greater than 2 feet)
Don’t want the HGL elevation to exceed the ground surface elevation of manholes and inlets; this would indicate that flow exist the system at undesirable locations Peak weather flow conditions are identified as an rain event that occurs every ten years; this event size was used as a standard approach to evaluate and calibrate the model The following subsections provide a summary of the modeled system, flow estimates, and evaluation criteria used for the City’s sewer system capacity evaluation to address the components listed above.
Evaluation
The capacity assessment completed as part of the City’s 2019 Sewer Master Plan was based on hydraulic modeling of the City’s collection system under current and future design flows. The overall objective of the City’s capacity assessment is to avoid capacity related spills. The 2019 sewer hydraulic model helped to identify potential capacity problems in the City’s sewer system, identify projects to address potential capacity problems, and determine an approximate completion schedule necessary for implementing the projects.
The Plan included procedures to:
Evaluate the sanitary sewer system assets utilizing the best practices and technologies available.
Identify and justify the amount (percentage) of its system for its condition to be assessed each year.
Prioritize the condition assessment of system areas that:
Hold a high level of environmental consequences if vulnerable to collapse, failure, blockage, capacity issues, or other system deficiencies.
Are located in or within the vicinity of surface waters, steep terrain, high groundwater elevations, and environmentally sensitive areas.
Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act section 303(d) List.
Assess the system conditions using visual observations, video surveillance and/or other comparable system inspection methods.
Utilize observations/evidence of system conditions that may contribute to exiting of sewage from the system which can reasonably be expected to discharge into a water of the State.
Maintain documents and recordkeeping of system evaluation and condition assessment inspections and activities; and Identify system assets vulnerable to direct and indirect impacts of climate change, including but not limited to sea level rise; flooding and/or erosion due to increased storm volumes, frequency, and/or intensity; wildfires; and increased power disruptions.
A rehabilitation and replacement plan serves to identify and prioritize system deficiencies and establish short and long-term rehabilitation actions to address each deficiency. The City’s program includes regular visual and CCTV inspections, and assessment of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation.
Design Criteria
In keeping with the development of the City’s 2019 hydraulic model sewage flow estimates and system capacity, analysis will be evaluated for conformance with industry standard practices as well as for compliance with the WDRs. The evaluation will include a review of dry weather peak flow conditions and identify areas of the model that may require modification and/or expansion. Recommendations for assessing current and future capacity requirements as well as a schedule to complete the modeling scenario simulations will also be included.
The new sewer model will involve a comprehensive evaluation of available flow monitoring and water use data to develop realistic factors for estimating base wastewater flow (BWF), groundwater infiltration (GWI), rainfall-dependent infiltration/inflow (RDI/I), and peak dry and wet weather flows. The Consultant will:
Utilize the temporary meters placed in various areas of the collection system. Winter water consumption data will also be compared to measure wastewater flows. Analysis of dry weather data will focus on refining flow factors for BWF, developing appropriate values for Dwelling Unit Equivalent (DUE) and per capita flows, and incorporating the anticipated long-term effects of water conservation.
Build upon previous analyses of wet weather flows to develop RDI/I rates (R-values and hydrograph shapes) for various areas of the City collection system and the anticipated RDI/I contributions from future development.
Make recommendations for appropriate design criteria for evaluating collection system capacity requirements such as:
Type of design storm; in this case, a 10-year rain event is typical The flow in the pipe should be at least 2 feet per second or greater; that is, the flushing velocity must be at least 2 ft/sec or greater to avoid sediment buildup in the pipe The depth to diameter ratio should not exceed 0.75; if the pipe is flowing full, it could create a whole host of problems System Inspection and Assessment
The City’s CCTV truck was equipped with WINCAN software in 2017. The inspection codes incorporated into the WINCAN software are National Association of Sewer Service Companies (NASSCO) certified and comply with the Pipeline Assessment and Certification Program (PACP). The defect codes also include codes developed and incorporated by the City. The information obtained and recorded from the CCTV inspections is reviewed, recorded, and assigned a severity rating according to a rating scale developed by City staff. Permanent records of the inspections are made by capturing still images of the information on the TV screen and recording the information to the City’s database. The City’s CCTV inspection capability extends to various pipe sizes.
Inspections are performed by a one person and are typically performed after the cleaning of the pipeline sections to be televised. Daily progress is recorded and uploaded to the WINCAN database and utilized for recording, tracking, and reporting purposes. As the necessity to televise a particular location or portion of the wastewater collection system arises, staff assignments are reorganized, and resources are reallocated to accommodate the requirement. Although the City’s goal includes televising the sewer from north to south and east to west, many of the staff resources are currently devoted to performing routine cleaning and maintenance tasks.
Inspection information is recorded and rated according to the City’s procedures summarized in the City of Pomona Operations and Maintenance Program.
Repair and Rehabilitation Projects
The City’s Wastewater Operations Section is responsible for performing various types of wastewater facility repairs and rehabilitation improvements. Repair and rehabilitation work performed by crews may include point repairs at cracks, joints, and service interfaces, repairing collapsing or broken sewer pipe, removing obstructions in the sewers that hinder cleaning operations, manhole rehabilitation, video inspection, and other related work. Repairs that require resources beyond those available within the Wastewater Maintenance Section, including staff and equipment, are coordinated and scheduled with other sections including the Water Distribution/Treatment and Environmental/Engineering Section. In conjunction with the City’s Water Distribution Section’s staff and equipment, the Wastewater Maintenance staff is responsible and able to implement mitigation efforts and perform repairs for pipeline up to 12 inches in diameter to restore or replace failing wastewater collection sewer lines. Repairs for pipelines greater than 12 inches in diameter or that require an extensive construction effort are performed by independent contractors retained by the City.
CIP Development
Based on field data from cleanings the CIPs are created and included in the annual CIP plans.
8.3 Capacity Assessment and 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:
Dry-weather peak flow conditions that cause or contributes to spill events.
The appropriate design storm(s) or wet weather events that causes or contributes to spill events.
The capacity of key system components; and
Identify the major sources that contribute to the peak flows associated with sewer spills.
The capacity assessment must consider:
Data from existing system condition assessments, system inspections, system audits, spill history, and other available information.
Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions.
Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-intensity storm events because 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.
In keeping with the development of the City’s 2019 hydraulic model sewage flow estimates and system capacity, analysis will be evaluated for conformance with industry standard practices as well as for compliance with the WDRs. The evaluation will include a review of dry weather peak flow conditions and identify areas of the model that may require modification and/or expansion. Recommendations for assessing current and future capacity requirements as well as a schedule to complete the modeling scenario simulations will also be included.
The new sewer model will involve a comprehensive evaluation of available flow monitoring and water use data to develop realistic factors for estimating base wastewater flow (BWF), groundwater infiltration (GWI), rainfall-dependent infiltration/inflow (RDI/I), and peak dry and wet weather flows. The Consultant will:
Utilize the temporary meters placed in various areas of the collection system. Winter water consumption data will also be compared to measure wastewater flows. Analysis of dry weather data will focus on refining flow factors for BWF, developing appropriate values for Dwelling Unit Equivalent (DUE) and per capita flows, and incorporating the anticipated long-term effects of water conservation.
Build upon previous analyses of wet weather flows to develop RDI/I rates (R-values and hydrograph shapes) for various areas of the City collection system and the anticipated RDI/I contributions from future development.
Make recommendations for appropriate design criteria for evaluating collection system capacity requirements such as:
Type of design storm; in this case, a 10-year rain event is typical The flow in the pipe should be at least 2 feet per second or greater; that is, the flushing velocity must be at least 2 ft/sec or greater to avoid sediment buildup in the pipe The depth to diameter ratio should not exceed .75; if the pipe is flowing full, it could create a whole host of problems Hydraulic Model Development
Using existing data in the City’s updated GIS database, atlas maps, record drawings, and pump station details, the current model of the sewer collection system was constructed. Some of the steps used in the development of the new sewer hydraulic model are listed below:
Imported pipe and manhole data from the City’s GIS database (e.g. spatial coordinates, manhole identifiers, manhole rim elevations, pipe inverts, diameters, and lengths).
Inclusion of all pipelines that were eight inches (8”) in diameter or greater. However, some 8-inch pipes that served relatively large areas (i.e. effectively acting as trunk sewers), were downstream of trunk sewer mains, or serve as system flow splits were also included in the modeled network.
Validated the network to correct incomplete or erroneous data values. Profiles for pipe segments in the modeled network were reviewed to visually check for suspect data. Refer to the attached record of sewer geodatabase changes.
Delineated sewer system sub-basins. These represent the un-modeled sewers that discharge flow to the modeled network. Sub-basins were created by creating sewer discharge load allocations to the appropriate area manhole. Each sub-basin therefore discharges to a load manhole, representing the point where base wastewater flow (BWF) and infiltration/inflow (I/I) flows originating from the sub-basin enter the modeled trunk sewer network.
Loaded average base wastewater flows to each sub-basin to compute based on a sum of the flows from the parcels contained within the sub-basin. Base wastewater flows are comprised of residential and non-residential (e.g. commercial/industrial) flows.
Assigned diurnal curves and rainfall-dependent infiltration/inflow (RDI/I) parameters to each sub-basin in the model based on its land use characteristics and associated flow meter area.
Added GWI to each sub-basin during model calibration by comparing the modeled dry weather flow to actual observed flows at the flow meter sites.
Populated missing GIS data with the best information found in record drawings, sewer atlas maps, and field notes.
Estimated Sewer Generation Rates
Estimates for sewer generation rates are typically prepared using population and land use data. Residential population and non-residential square footage estimates were developed for the existing and build out conditions for the year 2040. For the 2019 model existing conditions, residential population and non-residential square footage were estimated based upon 2010 Census block data, Southern California Association of Governments (SCAG) 2001 estimates, and existing City land use data. Estimates for the build out condition were based upon SCAG growth projections and City planning input. The existing condition residential population and non-residential square footage estimates were compared to temporary flow meter data, collected at 10 locations, to determine unit generation rate factors. Table 8.3-1 summarizes the unit generation rate factors that were developed in the 2019 Master Plan. These factors are within typical values for cities in Southern California.
Table 8.3-1
Unit Generation Rates
Land Use
Unit Generation Rate
Residential
70 gallons per day per capita
Light Industrial & Institutional
0.04 gallons per day/square feet
Other Non-Residential
0.08 gallons per day/square feet
The unit generation rates were then applied to the estimated residential population and non-residential square footage to develop sewage flow estimates for the build-out condition. Large domestic water users were also identified and point loads were developed as inputs into the model.
The 2019 sewer model incorporated sewer mains eight inches (8”) and greater to calculate the City's current and projected sewer flows through year 2040 and at build out. It also includes the following sewer collection projection methods: 1) land use based; and 2) population based. The model developed by comparing the results of the two methods and reconcile them to the City's historic sewer flow data, and data from neighboring cities and sewer districts. The City currently uses a percentage of all potable water usage for sewer discharge projection.
For purposes of creating a hydraulic model and forecasting future sewer flows by development, the model will:
Develop sewer unit flow coefficients and peak hour factors.
Develop a sewage unit flow coefficients for each category of land use in the City's General Plan or best available information at the time.
Develop average day and peak hour unit flow coefficient factors for the different categories of land use.
Validate the developed factors by comparing them to observed customer sewer flow patterns.
System Capacity Analysis
The 2019 model was able to provide the following capacity data:
Verify the City’s existing GIS database of collection system information for missing data and physical inconsistencies (connectivity; reverse pipe slopes; missing pipe diameters, slopes, upstream/downstream invert/rim elevations; significant discontinuities in pipe sizes or slopes). The data validation will utilize GIS routines that display the pipe profile to enable graphical review of the data.
Utilize the sewer modeling areas to estimate flow to support detailed hydraulic modeling and engineering analysis.
Recommend the optimal number and size of sewer boundaries before delineating sewer modeling areas.
Estimate sewage flows from the land use data and criteria developed above, with flow monitoring, and with water demands.
Identify those portions of the sewage system that are overloaded under existing conditions and provide a database that will permit the identification of those portions of sewer system that will become overloaded as additional development occurs.
The 2019 model was calibrated in the following manner:
For a 7-day dry weather flow (DWF) period (starting on January 29th), the calibration periods included both weekdays and weekends.
For a 7-day wet weather flow (WWF) period (starting on January 18th), the calibration periods included both weekdays and weekends.
The WWF calibration period included two main rainfall events (Jan. 19th and Jan. 22nd). 10 flow meters were used for a 6-week flow monitoring period (mid Jan through end of Feb 2017). Flow data provided in 15-min intervals (flow/depth/velocity).
Also used 3 rain gauges were used to capture 4 main rainfall events Jan 13th
Jan 19th through Jan. 21st
Jan. 22nd through Jan. 23rd
Feb. 17th through Feb. 19th
Prior to running a calibrated model, scenarios are developed to get a better sense of how Pomona’s sewer system will respond. Four scenarios would then be applied to the calibrated model to evaluate the impacts to the system. At the writing of this text, not all of the scenarios have been run using the model. The scenarios to be run were as follows and are listed below in order of greater loading:
#1 - Existing Infrastructure under Dry Weather Conditions #2 - Existing Infrastructure under Peak Wet Weather Conditions #3 - Future (2040) Infrastructure under Dry Weather Conditions #4 - Future (2040) Infrastructure under Peak Wet Weather Conditions Of the various scenarios mentioned, scenario #4 represents the greatest wastewater loading case for the model. The initial model run, using scenario #4, appeared to reveal that the system has adequate load carrying capacity as it currently exists. Although this is good news, it does not mean that the system cannot be made to operate more efficiently. Closed Circuit Television Video has uncovered a variety of locations wherein system pipelines have been subjected offsets, breaks, or even sags. Sewer lines that have reached to their useful life need to be replaced. There may be legacy sewer lines that are placed under building or structure that needs to be relocated to ease maintenance efforts.
Capacity Enhancement Measures
The new model will be used to identify system deficiencies, generate operations and emergency scenarios, and analyze the impacts from new developments. Given the expected use from the model, the City is motivated to keep it calibrated as things change in the field.
To date, the City has not experienced a hydraulic capacity related spill. However, there have been several spills resulting from decreased maintenance efforts and illegal manhole dumping’s. Given that the model has not run all the scenarios, there can be no finding that there exists sewer system no capacity deficiencies at this time. Therefore, no projects have been identified at this time to repair or address systems capacity deficiencies.
Schedule
Since the model was recently developed, coupled with the lack of scenario runs simulations, no new projects were preliminarily identified as deficient under dry or wet weather conditions. Therefore, no final conclusions can be made can be made at this time. Despite this, several projects were completed since the 2005 Sewer Master Plan. These projects were either based upon leaks, joint offsets, or line sags discovered during CCTV filming and were known as Red Flags. A list of those completed projects is shown below:
Project Name
Main Replacement
Construction Number
Towne Avenue
8" VCP
FB 1312B
Dawson Street
8" VCP
FB 1312C
Hardwood Drive
8" VCP
FB 1312D
Leather Oak Lane
8" VCP & 8" PVC
FB 1312E
Rancho Camino Drive
4" PVC
FB 1313
Rio Rancho Road
8" VCP
FB 1327
Ganesha Hills (Phase III)
8" VCP
FB 1321A
S/O Dudley
8" VCP
FB 1321D
Fairplex Parking Lot
8" VCP
FB 1321E
Paige Drive
8" VCP
FB 1321F
Paige Drive
8" VCP
FB 1321G
North Hill Road
8" VCP
FB 1321H
Holt Avenue
15" VCP
FB 1356
Fairplex Drive
8" & 15" VCP
FB 1355
As we continue to move forward with technology, we have added a new tool to help with the development of future CIP projects. WinCan Web’s VX inspection software is being used to identify and plan for future CIP and understanding the comprehensive sewer inspection program, by integrating its software with the City’s GIS system and the sewer hydraulic model. WinCan uses a dashboard concept to access information from the GIS database, the sewer hydraulic model analysis, and is much more user friendly.
WinCan enables Wastewater and Engineering staff to produce potential projects by using the City’s hydraulic model analysis feature. Staff bases its project selection on Likelihood of Failure, Likelihood of Risk, age, hydraulic capacity deficiencies and the like. From this extraction, a project list will emerge and can then be prioritized. The cost and implementation will then be developed to ensure that the project implementation schedule will be spread over the future years so as not to create a financial burden in any given year. Any financial plan developed will include both internally produced funds and external sources of income. Internal funds may include reserved funds from previous operations or from the sale of revenue bonds. External funds include Federal grants or state loans.
8.4 Prioritization of Corrective Actions
The findings of the condition assessments and capacity assessments must be used to prioritize correction actions. Prioritization must consider the severity of the consequences of potential spills.
The 2019 sewer model was constructed in such a manner to ensure that key segments of the sewer collection system were being properly evaluated and for compliance with the WDRs. The model will analyze the City’s system of pipelines of 8-inch diameter and larger and considered the following actions:
Populate the Model with main line invert data to create a more robust GIS database and allow the pipes to be modeled in the future.
Obtain and incorporate existing and projected hydraulic flow data for the LACSD trunk sewers to evaluate whether the trunk sewers produce backwater effects into the City’s system.
Include the 8-inch diameter pipelines and the LACSD trunk sewer data and project peak dry weather and wet weather (10-year storm event) flows.
Apply industry standard trigger criteria and re-evaluate: (1) recommended projects; (2) potential capacity constraints within the sewer collection system; and (3) the estimated required completion dates (to avoid capacity related spills).
Evaluate funding sources on an annual basis for potential sewer projects. This review is part of the City’s annual budgeting process as we are required to submit both and operating and CIP budget for the Water Resources Department.
Attend and investigate new external funding sources for CIP projects. Events such as the California Financing Coordinating Committee, 2019 Funding Fair Partners workshop may offer some opportunities to grants, for example.
8.5 Capital Improvement Plan
The capital improvement plan must include the following items:
Project schedules including completion dates for all portions of the capital improvement program.
Internal and external project funding sources for each project; and Joint coordination between operation and maintenance staff, and engineering staff/consultants during planning, design, and construction of capital improvement projects; and Interagency coordination with other impacted utility agencies Each year the city engineering staff, and maintenance staff review and update as necessary the CIPs for sewer. The current and past CIP documents are stored on the city website under Finance, Budget section located here. The current adopted CIP for FY 2024-25 sewer projects show a five-year plan and budget.
Element 9: Monitoring, Measurement, and Program Modifications
9.1 WDR Requirements Summary
This element of the SSMP discusses the parameters the City will utilize to track and monitor the progress of implementing elements of the SSMP, the effectiveness of the SSMP, and how the City intends to update and revise the SSMP to keep it current.
The Plan requires the City to:
Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities.
Monitoring the implementation and measuring the effectiveness of each Plan element.
Assessing the success of the preventive operation and maintenance activities.
Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations; and Identifying and illustrating spill trends, including spill frequency, locations and estimated volumes.
Adaptive Management that addresses Plan-implementation effectiveness and the steps for necessary Plan improvement
9.2 Discussion on Monitoring, Measurement, and Program Modifications The preventive maintenance activities and documenting notifications received regarding potential and actual spill occurrences are now inputted electronically in our GIS System. This process allows staff to reduce the paper storage issue, allows them the ability to query data, and make the information more easily transferable. The City has tracked performance measures through logs and reports including, but not limited to, the length of pipe cleaned and televised, the quantity, cause and location of stoppages, spills, and the scheduled maintenance of high frequency maintenance locations. The City will continue to monitor the performance measures it currently tracks.
The following subsections provide a summary of the procedures to be implemented to properly monitor program progress and implement necessary modifications. (a) Maintain information to establish and prioritize SSMP activities The City’s primary designee will be the Water Resources Director or his designee, responsible to continually monitor the SSMP provisions to ensure that the system is maintained in conformance with the document. As improvements or modifications are identified, the City will implement the necessary adjustments to the program at the earliest practical time. (b) Monitor the implementation and measure the effectiveness of each SSMP element As the SSMP elements are implemented and evolve, the City will modify the elements due to new technology, equipment, code changes, specific program enhancements, and the collection system’s rehabilitation through implementation of the CIP. The Water Resources Director or designee should identify and recommend updates to this SSMP as part of the City’s regular performance measurement assessments.
The following performance parameters may be utilized along with typical industry and EPA performance indicators for the City’s system:
1. Pipe age
2. O & M cost/mile/year
3. O & M staff/100 miles
4. Percent of system each year
5. Total annual percent cleaned
6. System cleaning cycle frequency
7. FOG program activities
8. Percent CCTV per year
9. I & I monitoring
10. Planning goals status
(c) Assess the success of the preventative maintenance program The City developed the “City of Pomona Operation and Maintenance Program” that includes a summary of the City’s current procedures and practices as they pertain to the O&M activities and includes recommended changes to augment the City’s current activities to facilitate compliance with the Order. A comprehensive evaluation of the elements affecting the O&M of the City’s sewer collection system including, but not limited to, system inventory and mapping, the work order process, inspection and assessment of the system including objective standards, CIP project identification process, preventative maintenance procedures, repair and rehabilitation procedures, and training programs is included. Additional details relevant to the preventative maintenance efforts are included in the City of Pomona Operation and Maintenance Program and can be located here.
Computerized Maintenance Management System
A key component involved in integrating workflow and data flow between the various divisions is the integration of Computerized Maintenance Management System (CMMS)-related technology. It is the desire of the Department to integrate work order systems and asset management systems around GIS.
Currently, there are three software solutions in use throughout City departments that provide functionality of CMMS. One is used by the Finance Department to manage customer billing data, respond to service requests, and issue service orders. Another is used by the Water Distribution Section to issue work orders and store historical work order information. The last one is used by the Wastewater Collections Division to assist in performing closed circuit television (CCTV) inspections and to generate CCTV inspection reports.
The Water Resources Department uses WinCan Enterprise for electronic work orders and electronic historical documentation. The City is working to select and deploy a GIS enabled CMMS system for the entire city implementation. The date for launch is being generated by the City.
One important commonality between the three existing systems is that they all can integrate with a GIS enabled systems and tools. For this reason, it is recommended that the main integration between the three systems be accomplished at the enterprise geodatabase level, using the ESRI ArcGIS Pro system as the common asset database. Once that database is generated, integrations must be synchronized develop efficient work order processing between the three systems and to expand asset management systems beyond the Water Resources Department. (d) Update program elements based on monitoring or performance evaluations The City will review this SSMP and its elements on a regular basis and update the document with any significant changes. The SSMP must be reviewed, updated, and re-certified at least once every six (6) years as this update stems from the 2018 SSMP. The City’s process should include distributing the SSMP to appropriate City staff for review to ensure the most current legal authority, response plans, organizational charts, equipment lists, and contact/notification information is included. Once the City makes operational, maintenance, management, and administrative changes, the City may consider distributing the SSMP to other agencies to perform a peer review of the document. Once recommendations are incorporated into the document, the SSMP will be ready for public dissemination and ultimately for recertification by the Council. The City is responsible for maintaining the SSMP program as required by the Los Angeles RWQCB and will make the SSMP accessible to the public via the City’s web site in PDF form. (e) Identify and illustrate spill trends, including frequency, location, and volume The City currently maintains a spreadsheet with information as to the emergency calls received reporting potential and/or actual spills. The City will continue to document spill trends. Additional information to be included in the documentation process is the frequency and approximate volume of the spill. The City is efficiently and effectively implementing the measures to properly document and report any spills as required by the Order.
On a monthly basis, the City is required to certify via CIWQS system that there are no spills.
9.3 SSMP Modifications
The City must update the SSMP periodically to maintain current information and modify the programs as necessary to ensure program effectiveness and continual compliance with the Order. Information that will be routinely updated includes, but is not limited to, contact names and phone numbers for City staff responsible for implementation of specific SSMP programs, staff on stand-by for spill response, and approved contractors and vendors. From a practical standpoint, the current SSMP version will be marked up by staff, using track changes, and then reviewed by the necessary people: Environmental, Engineering, and Wastewater supervisors, and wastewater field staff will participate in the review and approval of SSMP updates.
As modifications to elements of this SSMP are deemed necessary, the City will implement them at the earliest practical time. However, changes will be officially made to this updated SSMP during the annual or bi-annual update to the document. Changes will be logged on the change form. A comprehensive SSMP update, and recertification will occur every six (6) years as necessary and will include any significant program changes. The next re-certification of the SSMP will take place in May 2031.
Element 10: Internal Audits
10.1 WDR Requirements Summary
The Plan shall include internal audit procedures, appropriate to the size and performance of the system, for the City to comply with the Order.
The City will conduct an internal audit of its SSMP, and implementation of its Plan, at a minimum frequency of once every three (3) years. The audit must be conducted for the period after the end of the City’s last required audit period. Within six months after the end of the required 3-year audit period, the Legally Responsible Official shall submit an audit report into the online CIWQS Sanitary Sewer System Database per the Order.
Audit reports submitted to the CIWQS Sanitary Sewer System Database will be viewable only to Water Boards staff.
The internal audit shall be appropriately scaled to the size of the system(s) and the number of spills. The City’s sewer system operators must be involved in completing the audit. At minimum, the audit must:
Evaluate the implementation and effectiveness of the City’s Sewer System Management Plan in preventing spills Evaluate the City’s compliance with the Order
Identify Sewer System Management Plan deficiencies in addressing ongoing spills and discharges to waters of the State; and Identify necessary modifications to the Sewer System Management Plan to correct deficiencies.
The City will submit a complete audit report that includes Audit findings and recommended corrective actions.
A statement that sewer system operators’ input on the audit findings has been considered; and A proposed schedule for the Enrollee to address the identified deficiencies.
This element discusses the City’s SSMP Auditing Program.
10.2 Discussion of SSMP Program Audits
The City will conduct periodic internal audits, appropriate to the size of the system and the number of spills. These audits will occur every three (3) years and a report will be prepared and kept on file and uploaded in CIWQS Sanitary Sewer System Database. Any modifications identified while monitoring the implementation of this SSMP will be officially noted during the SSMP audit to ensure this SSMP is up to date. The audit will be completed internally, and the City may elect to have the audit performed by an appropriate third-party auditor or a neighboring agency. The audit may include, but not be limited to:
Reviewing the progress made on the development of SSMP elements Reviewing the status of the SSMP programs implemented
Identifying the success of various SSMP programs implemented Identifying the deficiencies in addressing ongoing spills and discharged to waters of the State improvements necessary to various SSMP programs
Describing system improvements within the three (3) year audit period Describing system improvements planned for the upcoming three (3) years Reviewing data related to spill occurrences
10.3 SSMP Program Audits
Since the 2018 SSMP update, there have been three (3) audits performed by the Environmental Compliance Supervisor within the Water Resources Department. The internal audits of the SSMP and implementation of its Plan is conducted for the period after the end of the last required audit period. The audit includes:
Evaluation of the implementation and effectiveness of the SSMP in preventing spills Evaluation of compliance with the Order
Identifies SSMP deficiencies
And identifies modifications
Copies of the all audits performed and plan updates can be located on the City website here.
During the audit process, staff is interviewed on the eleven (11) SSMP elements. Once completed, the elements are ranked, and recommendations for improvement, if needed, is noted. All changes made to the SSMP are kept on a Change Log, and at the next SSMP annual plan update, will incorporate the changes.
The State Water Resources Control Board provided the schedule for City of Pomona’s audits and plan updates. This can be found here and the schedule is shown below. * Per Section 5.5 and Attachment E1, Section 3.11 of the General Order, Plan updates are due within six years after the required due date of the Enrollee’s last Plan Update. ** Per Section 5.4 and Attachment E1, Section 3.10 of the General Order, the Audit Report is due within six months after the end of the required 3-year audit period.
Element 11: Communication Program
11.1 WDR Requirements Summary
The Plan must include procedures for the City to communicate with:
The public for:
Spills and discharges resulting in closures of public areas, or that enter a source of drinking water, and The development, implementation and update of its plan, including opportunities for public input to plan implementation and updates.
Owners/Operators of systems that connect into the City’s system, including systems for:
System operations, maintenance, and capital improvement related activities The primary objective of a Communication Program is to increase public awareness of sewer collection system issues and to promote a sense of stewardship for the City’s system and facilitate its efforts towards the effective and efficient management, operation, and maintenance of the sewer collection system. This element of the SSMP discusses the City’s efforts to educate and inform the public and affected agencies regarding the proper use of the City’s sewer collection system.
11.2 Regulatory Requirements for Communication Program
The Order requires the City to communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the City as the program is developed and implemented.
11.3 Discussion of Communication Program
The City’s Communication Program’s efforts to comply with the Order and address the development and implementation of this SSMP will serve to educate, inform, and engage key stakeholders, such as agencies served by the City’s sewer collection system or that may be affected by a spill, and businesses, developers, contractors, vendors, and plumber’s whose business could be impacted by specific requirements or elements of this SSMP.
As a result of changes in the City’s organization, the duties of the City’s Public Information Office (PIO) are handled by the Assistant City Manager and/or designee. He/she will work to coordinate external communications between the City and the public regarding the development and implementation of this SSMP and the various elements. Additionally, the PIO will work closely with the City Council, City departments, news media, the public and affected agencies to assist in promoting an open and frequent exchange of information necessary for the systematic and effective implementation of the various SSMP elements.
The following includes a summary of the City’s efforts to educate, inform and engage the public’s support and participation in the proper utilization of the City’s sewer collection system and comply with the Order’s requirements.
City of Pomona Official Website
The City’s current outreach efforts include maintaining a website (www.pomonaca.gov) to inform the public about City activities. The City’s website is an effective communication channel for providing alerts and news to the public. The main page of the website provides access to various City departments including the Public Information Office, and links to diverse information, important announcements, agendas and minutes for City Council meetings, and other key information for City residents. City staff can utilize the website to publish its SSMP to provide the public the opportunity to view and offer input to the City as the SSMP elements are implemented. As well, the City can utilize the website to notify the public of important upcoming activities related to sewer system management. This information is located on the Water Resources Department home page with links to other programs.
City of Pomona FOG Control Program also known as the Sewer Pipe Blockage Control Program The public outreach element included in the City of Pomona FOG Control Program includes educating the public on the negative impacts of putting FOG into the sewer collection system. Providing information via various forms of media is an effective way to engage the public in recognizing the importance of reducing the quantity of FOG introduced to the sewer collection system and the threat of excessive quantities to the potential and actual occurrence of spill. Examples of educational campaigns are included in the FOG Control Program, which includes a flyer advertising that the drain is not a dump for FOG, a door hanger, presented in both English and Spanish, that can be left with residents, and best kitchen practices for businesses. Additionally, an example of text that may be included on a postcard and mailed to residents soon after a FOG related spill has occurred to alert people to the effort required to clear a blockage and to reinforce not to put FOG down the drain.
City of Pomona Spill Emergency Response Plan
The SERP, located here, includes a Public Advisory of Sewage Contamination Procedures which includes a description of the action that City staff must take to limit public access to surface waters and other areas that may have been impacted by a spill as well as notify the public of potentially hazardous conditions. Examples of signs that may be posted to provide a warning of potential public health risk are included in Attachment H of the SERP. Additionally, pre-scripted notices are included in Attachment I of the SERP which may be modified to accurately reflect the conditions at the time of publication and/or airing.
Should additional notification of sewage contamination be deemed necessary, City staff is required to, in cooperation with the City’s PIO, provide further notices using the pre-scripted notices made available to the printed or electronic news media for immediate publication or airing, or by other measures, such as door hangers.
In addition, Wastewater staff will work with other divisions of the Water Resources Department, and Public Works to cross train in the basic of spillage containment. Acknowledging that these crews do not have the required equipment to clean up a spill, they would be able to reduce the spillage area if they came across the spillage first.
Public Meetings
Public meetings to discuss the City related issues are held regularly in the City Council Chambers. The City encourages residents to attend City council meetings to become better informed about how the City works and various issues. The council meetings provide the residents and concern citizens a forum to provide the council with input on particular programs through the Public Hearing process, and through the Citizen Participation portion of each City Council meeting. During Citizen Participation, each person who wishes to address the City Council on an item not on the agenda may do so. Certification of the completed SSMP will be required by the City Council during a public city council meeting.
Copies of the Council Agenda are made readily available to the public at the City Clerk's Office located here, and in the lobby of the Council Chambers during the meeting. A complete agenda packet is also available for review in the Special Collections section of the Pomona Public Library and at the Council meeting. The City currently is offering live streaming of council meetings, and provides a link to recorded meetings.
Project specific meetings may also be convened with community leaders and other citizens to discuss the impacts, schedule and criteria of sewer related projects and efforts. These meetings give citizens a forum to learn about the City’s activities, voice their concerns, and receive clarification on a variety of issues. Often the project managers will arrange these meetings.
11.4 Public Education and Outreach Media
A variety of means exist to educate and inform the public regarding impacts to the City’s sewer collection system facilities. The following list identifies several forms of media available for the City to use to educate and inform the public:
Bi-annual inserts in water and/or sewer bills.
Press releases.
Direct mailers.
Door hangers.
Brochures distributed at City locations and kiosks.
Posters and flyers displayed prominently in public areas, such as in libraries, and recreational centers.
Announcements and notices placed on the City’s web site, and social media.
Advertisements placed in the City’s recreation guide,
Public service announcements on the City’s cable television channel; and Specific co-sponsored events hosted by the City to educate the public on the effects of spills to the public and environment such as at an earth day fair, open house events, and other appropriate venues. Below is an idea what staff includes at such events:
Manned a booth to discuss the sewer system with the public attendees Illustrations the sewer system and goals of grease free traps placed on poster boards o Handouts from the Water Environment Federation in English and Spanish o Future ideas will include having a lap top run a CCTV video All messages that are communicated to the public should be prepared in English, and, where appropriate, in Spanish and any other dominant language spoken by the target audience. Translation services may be required and anticipated during any educational campaign. Educational activities should occur regularly throughout the year, but the City may consider enhancing education campaigns near holidays when many residents increase their cooking activities, and consequently generate more FOG.
The City will communicate on a regular basis with interested parties on the implementation and performance of this SSMP. The Public Education and Outreach program will allow interested parties to provide input as the SSMP and its elements are developed and implemented.
11.5 Satellite Agencies
Satellite Agencies, as mentioned in this report, refer to those neighboring agencies that convey wastewater into Pomona’s collection system. As it stands today, the following agencies are the satellite systems for Pomona:
California State Polytechnic University, Pomona
City of Claremont
City of La Verne
City of Chino Hills
City of Chino
City of Diamond Bar
LA County Department of Public Works (Foxpark District and Fairplex) A copy the existing agreements are provided here.
For communication with other satellite agencies, staff will consider regular coordination meetings, annual surveys for changes in their system, and/or web pages devoted to satellite agency issues. As of this point, Water Resources Director or his designee will be responsible for satellite agency coordination. This person will ensure that the program is sustained, and that our efforts to get the program up and running aren’t wasted once the updated SSMP is completed.
Sewer System Management Plan
Rev. April 21, 2025
Page | 45
Attachment 1