City of Sebastopol
Water Quality Monitoring Program Plan
© 2014 DKF Solutions Group, LLC Page 5 of 44
SOP Standard Operating procedure
SSC Sewer Service Charge
SSMP Sanitary Sewer Management Plan
SSO Sanitary Sewer Overflow
SSO GWDR Sanitary Sewer Overflow General Waste Discharge Requirements
SURFACE WATER
All waters whose surface is naturally exposed to the atmosphere; for example, rivers, lakes, reservoirs, ponds, streams, seas, estuaries, etc., and all springs, wells, or other collectors directly influenced by surface water.
SWRCB State Water Resources Control Board
WQMP Water Quality Monitoring Program Plan
WQ Water Quality
WDR Waste Discharge Requirements
VOC Volatile Organic Compound
3. RESPONSIBILITY
The City shall designate responsibility for all WQMP roles to appropriate classifications within the City to ensure conformance with all activities related to water quality monitoring associated with sanitary sewer overflows (SSOs) that may affect waters of the State, protect public health and the environment, and ensure that personnel responsible for implementing this Plan are properly trained in their roles, responsibilities, and applicable protocols. It is further recognized that the proper implementation of this Plan will help ensure that all monitoring activities withstand regulatory or legal scrutiny by the State Water Resources Control Board, the Regional Water Quality Control Board, or other legal proceedings. These roles and responsibilities are intended to comply with the requirements of the State Water Resources Control Board Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems (Order WQ 2022-0103-DWQ) and the associated Monitoring and Reporting Program (MRP).
The following table contains the roles and responsibilities as assigned by the City to individual classifications or service contractors of the City:
Roles and Responsibility Responsible Classification
Provide and document regular training on WQMP
for all City classifications that have a role or
responsibility in the WQMP and identified herein
Sebastopol Public Works Department
-Safety Representative
Identification and assessment of potential impacts
to local areas with surface waters that may require
WQMP (i.e. aerial crossings, creeks, waterways,
rivers, bays, estuaries, etc.)
Sebastopol Public Works and Engineering
Departments
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Determination of specific sampling protocols and
analytic methods to be used for the City-required
testing
Sebastopol Public Works Department
-Public Works Operation Supervisor
Determination of appropriate bacterial indicators for
sampling
Sebastopol Public Works Department
- Public Works Operation Supervisor
Annual review of all standard operating procedures
related to this WQMP especially the Sample
Collection procedures
Sebastopol Public Works Department
- Public Works Operation Supervisor
Decision to invoke a WQMP and direct the
monitoring program to conclusion
City of Sebastopol
-City Manager
Selection of sampling locations Sebastopol Public Works Department - Public Works Operation Supervisor
Coordination of field sampling Sebastopol Public Works Department - Public Works Operation Supervisor
Conduct field sampling per City protocols Sebastopol Public Works Department -Public Works Maintenance Staff
Authorization and direction for placement of public
notifications and signage
Sebastopol Public Works Department
-Public Works Director
Photographs of sampling and signage placed to
protect public health and safety
Sebastopol Public Works Department
-Public Works Maintenance Staff
Preparation of Chain of Custody for all samples
taken including proper labeling
Sebastopol Public Works Department
-Public Works Maintenance Staff
Determination of spill travel time, if applicable. Sebastopol Public Works Department -Public Works Maintenance Staff
Review and evaluate lab results for termination of
sampling and to determine the nature and impact of
the release
Sebastopol Public Works Department
- Public Works Operation Supervisor
Decision to terminate sampling Sebastopol Public Works Department -Public Works Director
Preparation of detailed sampling location map Sebastopol Public Works Department -Public Works Assistant Superintendent
Conduct sample analysis Laguna Environmental Laboratory, ELAP Cert #1126
4300 Llano Rd, Santa Rosa, CA 95407
707 543-3365
Preparation of water quality sampling activities
narrative for Technical Report
Sebastopol Public Works Department
- Public Works Operation Supervisor
Review and Approval of Technical Report Sebastopol Public Works Department -Public Works Director
Certification and placement of Technical report in
the CIWQS spill reporting system.
Sebastopol Public Works Department
- Public Works Operation Supervisor
Failure Analysis Investigation of all water quality
monitoring from the SSO event to determine all
necessary changes or modifications to the WQMP
Sebastopol Public Works Department
- Public Works Director
Audits of the WQMP as required by City SSMP
Element 10, Audit.
Sebastopol Public Works Department
-Public Works Director
Management of Change responsibilities for the
WQMP and all associated forms and documents
required for use during an incident
Sebastopol Public Works Department
-Public Works Director
It is recommended that this list of responsibilities be placed on a laminated card and kept in the Sampling Kit for easy access during an SSO sampling incident.
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4. AUTHORITY AND REFERENCES
The authority for the monitoring and sampling of sanitary sewer overflows are contained in the following regulations:
1. State Water Resources Control Board, Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems, Order WQ 2022-0103-DWQ, adopted December 6, 2022, effective June 5, 2023.
2. State Water Resources Control Board, Monitoring and Reporting Program (MRP) for the Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems, Order WQ 2022-0103- DWQ.
3. Standard Methods for the Examination of Water and Wastewater, latest edition, American Public Health Association (APHA), American Water Works Association (AWWA), and Water Environment Federation (WEF).
4. Federal Water Pollution Control Act (Clean Water Act), as amended, including Sections 301(a), 304(h), and 501(a).
5. Code of Federal Regulations, Title 40, Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants, as amended.
A. There are a number of applicable references that are available to assist with the a proper Water Quality Monitoring Program as follows:
B. Water Quality Control Plan for the North Coast Region (Basin Plan), California Regional Water Quality Control Board, North Coast Region, as amended.
C. California State Water Resources Control Board, Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems (Order WQ 2022-0103-DWQ) and associated Monitoring and Reporting Program (MRP).
D. City of Sebastopol Spill Emergency Response Plan (SERP), Element VI of the Sewer System Management Plan (SSMP).
E. Standard Methods for the Examination of Water and Wastewater, latest edition, American Public Health Association (APHA), American Water Works Association (AWWA), and Water Environment Federation (WEF).
F. U.S. Environmental Protection Agency (EPA), National Recommended Water Quality Criteria, as amended.
G. U.S. Environmental Protection Agency (EPA), Surface Water Sampling Guidance, Standard Operating Procedures, and applicable quality assurance/quality control (QA/QC) guidance, as amended.
5. IDENTIFICATION OF LOCAL SURFACE WATERS AND CHARACTERISTICS An important element of any water quality monitoring program is the proper and thorough understanding of the service area and the various challenges the geography and sanitary sewer infrastructure of the service area present for the potential of wastewater reaching surface waters or storm water facilities. By evaluating the areas of concern in a service area such as lakes, rivers, dry creeks, aerial pipeline crossings over water ways and all storm water related infrastructure, the City can be better prepared to timely respond to any SSO reaching surface waters and to minimize the impacts of an SSO in or around local surface waters and storm water infrastructure.
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A. Surface Waters of Concern
For the purposes of this Plan, surface waters are defined as all waters whose surface is naturally exposed to the atmosphere, for example, rivers, lakes, reservoirs, ponds, streams, seas, estuaries, etc., and all springs, wells, or other collectors directly influenced by surface water. In addition, the City will also identify and evaluate areas where collection system pipelines and force mains cross over or under waterways as these crossings can require additional resources and equipment to properly address any SSO from these collection system assets.
Surface waters of concern are those surface waters with the City’s service area that may be impacted by a sanitary sewer overflow from the City’s sanitary sewer collection system. Prior planning, review and evaluation of potential failure mechanisms can help minimize any potential impacts to surface waters or storm water infrastructure when and if the WQMP must be invoked.
Any review of these important areas of potential surface water contamination in advance of an SSO should allow the City to be better prepared to respond to an SSO with the proper equipment and a better understanding of the procedures that may need to be invoked during the SSO such as flow rate of a creek or stream, and potential areas of significant environmental concern such as shell fish beds or fish habitats. In addition, having all storm water infrastructure located on the collection system field maps will help the City’s responders quickly determine if SSOs may flow into storm drains reach and impact surface waters.
The following (Table 5.1) are the surface waters of concern within the City’s jurisdiction:
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Bog: Freshwater wetlands that are poorly drained and characterized by a buildup of peat.
Brackish Water: Generally, water containing dissolved minerals in amounts that exceed normally acceptable standards for municipal, domestic, and irrigation uses. Considerably less saline than sea water. Also, Marine and Estuarine waters with Mixohaline salinity (0.5 to 30 due to ocean salts). Water containing between 1,000-4,000 parts per million (PPM) Total Dissolved Solids TDS). The term brackish water is frequently interchangeable with Saline Water. The term should not be applied to inland waters.
Brook: A natural stream of water, smaller than a river or creek; especially a small stream or rivulet which breaks directly out of the ground, as from a spring or seep; also, a stream or torrent of similar size, produced by copious rainfall, melting snow and ice, etc.; a primary stream not formed by tributaries, though often fed below its source, as by rills or runlets; one of the smallest branches or ultimate ramifications of a drainage system.
Canal: A constructed open channel for transporting water.
Channel: An area that contains continuously or periodically flowing water that is confined by banks and a stream bed.
Culvert: A buried pipe that allows streams, rivers, or runoff to pass under a road.
Ditch: A long narrow trench or furrow dug in the ground, as for irrigation, drainage, or a boundary line.
Diversion channel: (1) An artificial channel constructed around a town or other point of high potential flood damages to divert floodwater from the main channel to minimize flood damages. (2) A channel carrying water from a diversion dam.
Drainage Channel: For the purposes of complying with the Statewide Sanitary Sewer Order, (1) a man-made canal used to transport storm water as part of a municipal separate storm sewer system, or (2) an intermittent or perennial stream bed.
Dry Wash: A streambed that carries water only during and immediately following rainstorms.
Ephemeral Streams: Streams which flow only in direct response to precipitation and whose channel is at all times above the water table.
Freshwater marsh: Open wetlands that occur along rivers and lakes.
Intermittent stream: Any nonpermanent flowing drainage feature having a definable channel and evidence of scour or deposition. This includes what are sometimes referred to as ephemeral streams if they meet these two criteria.
Perennial streams: Streams which flow continuously.
Pipe crossing: Crossing of a pipe or force main over or under a surface water body.
Riverine: Relating to, formed by, or resembling a river including tributaries, streams, brooks, etc.
Slough: A shallow backwater inlet that is commonly exposed at low tide.
Stream: A general term for a body of flowing water; natural water course containing water at least part of the year. In Hydrology, the term is generally applied to the water flowing in a natural channel as distinct from a canal. More generally, as in the term Stream Gaging, it is applied to the water flowing in any channel, natural or artificial.
For additional definitions refer to the glossary at http://www.streamnet.org/glossarystream.html.
Table 5.1: Surface Waters of Concern
Name Type
(see legend, below) Map Location Background
Monitoring?
Access
Considerations
Safety
Considerations
Laguna de’ Santa
Rosa Stream
See Maps in
Attachment (Att.) F No No special
considerations
Exercise caution,
may be slippery in
wet weather
Calder Creek Brook See Maps in Att. F No " "
Zimpher Creek Brook See Maps in Att. F No " "
Atascadero Creek Brook See Maps in Att. F No " "
Witter Creek Brook See Maps in Att. F No " "
Morris Outfall Culvert See Maps in Att. F No " "
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6. LAB SELECTION
A. Analytical Lab
Samples collected for SSO response and background monitoring purposes pursuant to Section 5.0 will be analyzed at the Laguna Environmental Laboratory in Santa Rosa. This lab is accredited through California’s Department of Public Health Environmental Laboratory Accreditation Program (ELAP). ELAP provides evaluation and accreditation of environmental testing laboratories to ensure the quality of analytical data used for regulatory purposes to meet the requirements of the State's drinking water, wastewater, shellfish, food, and hazardous waste programs. The State agencies that monitor the environment use the analytical data from these accredited labs. The ELAP-accredited laboratories have demonstrated capability to analyze environmental samples using approved methods.
B. Getting Samples to the Lab
At all times, sample hold times identified below will be observed in accordance with Section 7.0.
Once samples are collected, they will be transported to the lab as follows:
1. During Business Hours: Public Works Maintenance staff taking samples will deliver to Lab. 707-543-3350, 8-5 M-F
2. After Hours: Public Works Maintenance staff taking samples will deliver to Lab.
C. Lab Contact Info
Name: Laguna Environmental Lab
Address: 4300 Llano Road, Santa Rosa
Hours Samples Are Accepted: 24 hours
Phone: 707-543-4369, Shirley Johnson (normal hours Supervisor) Alternate or After Hours Phone: 707-543-3364 (need to call ahead if after hours) Emergency contact information: 707-543-3364
7. SAMPLING PARAMETERS
A. Required Sampling Parameters
The RWQCB Basin Plan and/or NPDES permit set the water quality standards against which one can judge the levels of impacts of an SSO on surface waters.
In accordance with the State Water Resources Control Board Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems (Order WQ 2022-0103-DWQ) and the associated Monitoring and Reporting Program (MRP), water quality monitoring shall be conducted as required based on the characteristics of the sanitary sewer overflow, receiving water, and applicable regulatory requirements. The following parameters may be sampled, as appropriate:
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1. Ammonia
Ammonia-N is a key indicator of the extent of wastewater contamination in the receiving water following a sanitary sewer overflow (SSO). Untreated or partially treated wastewater typically contains elevated concentrations of ammonia-N (generally 20–30 mg/L), while natural background concentrations in surface waters are typically less than 0.5 mg/L. Therefore, elevated ammonia concentrations measured downstream or at the location of the SSO, when compared to upstream background concentrations, provide a reasonable indication of the extent of wastewater contamination.
2. Bacteriological Indicators
Bacteriological indicators, including E. coli, enterococci, total coliform, and other parameters specified by the applicable Basin Plan or regulatory agency, are used to evaluate the potential public health impacts of an SSO on receiving waters. If concentrations exceed natural background levels or applicable Basin Plan water quality objectives, additional public health notifications, warning signs, or other response actions may be necessary.
It should be recognized that elevated bacteria concentrations may result from sources unrelated to an SSO, including wildlife, domestic animals, agricultural runoff, urban stormwater runoff, or other non-point source discharges. Upstream and background samples help distinguish SSO-related impacts from existing ambient water quality conditions. In some cases, particularly where sampling occurs after the SSO has ceased or where receiving waters are influenced by stormwater or other sources, it may not be possible to definitively distinguish SSO-related impacts from background conditions.
Generally, if bacteriological concentrations at downstream or impacted locations are comparable to upstream or background conditions, or are consistent with historical ambient monitoring data, the water quality impacts attributable to the SSO are considered minimal.
The applicable surface water quality objectives for bacteriological indicators are provided in Tables 7.1 and 7.2.
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Table 7.1: Water Quality Objectives for Coliform Bacteriaa Beneficial Use Indicator Water Quality Objective
Water Contact Recreation
(REC-1) – Fresh Water E. coli
Six-week rolling geometric mean ≤ 100
cfu/100 mL; Statistical Threshold Value
(STV) ≤ 320 cfu/100 mL (not to be
exceeded by more than 10% of samples
collected in a calendar month)
Water Contact Recreation
(REC-1) – Marine/Estuarine
Water
Enterococci
Six-week rolling geometric mean ≤ 30
cfu/100 mL; Statistical Threshold Value
(STV) ≤ 110 cfu/100 mL (not to be
exceeded by more than 10% of samples
collected in a calendar month)
Shellfish Harvesting (SHELL) Fecal Coliform ≤ 43/100 mL (5-tube decimal dilution) or ≤ 49/100 mL (3-tube decimal dilution)
Municipal Supply – Surface
Water Total Coliform Geometric Mean < 20/100 mL
NOTES:
a. Recreational water quality objectives for freshwater are based on a six-week rolling geometric mean and a Statistical Threshold Value (STV) for E. coli.
b. Recreational water quality objectives for marine and estuarine waters are based on a six-week rolling geometric mean and a Statistical Threshold Value (STV) for enterococci. c. Shellfish harvesting objectives are based on the National Shellfish Sanitation Program. d. Municipal supply objectives are based on the applicable California Regional Water Quality Control Board Basin Plan and the Safe Drinking Water Act.
e. Equivalent analytical methods approved under 40 CFR Part 136 or other approved methods may be used for compliance monitoring.
Source: North Coast Region Basin Plan (Region 1)
Water Quality Control Plan (Basin Plan)
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California RWQCB, North Coast Region adopted 6/13/2025
Table 7.2 – U.S. EPA Bacteriological Criteria for Water Contact Recreation1, 2 (in colonies per 100 ml)
Fresh Water Salt Water
Steady State (all areas) Enterococci E. Coli Enterococci 33 126 35
Maximum at:
Designated beach 61 235 104
Moderately used area 89 298 124
Lightly used area 108 406 276
Infrequently used area 151 576 500
NOTES:
1. The criteria were published in the Federal Register, Vol. 51, No. 45 / Friday, March 7, 1986 / 8012- 8016. The criteria are based on:
a. Cabelli, V.J. 1983. Health Effects Criteria for Marine Recreational Waters, U.S. EPA, EPA 600/1-80-031, Cincinnati, Ohio, and
b. Dufour, A.P. 1984, Health Effects Criteria for Fresh Recreational Waters, U.S. EPA, EPA 600/1- 84-004, Cincinnati, Ohio.
2. The U.S. EPA criteria apply to water contact recreation only. The criteria provide for a level of production based on the frequency of usage of a given water contact recreation area. The criteria may be employed in special studies within this region to differentiate between pollution sources or to supplement the current coliform objectives for water contact recreation.
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B. Sampling Parameters for City of Sebastopol
1. Ammonia
Discussion: See Section 7A
Sample Container: Plastic/glass
Sample Type: Grab
Sample Volume Required: 200 ml. minimum
Hold Time: 28 days
Preservative: Sulfuric acid
Analytical Method: Method 4500-XX R and C, Standard Methods for the Examination of Water or Wastewater, 21st Edition
2. Total Coliform/Fecal
Discussion: See Section 7A.2
Sample Container: Plastic (sterile)
Sample Type: Grab
Sample Volume Required: 100 ml. minimum
Hold Time: 8 hours
Preservative: None if waters are not chlorinated
Analytical Method: Method 9221 B, C and E, Standard Methods for the Examination of Water or Wastewater, 21st Edition
3. Enterococcus (not currently used by City)
Discussion: See Section 7A.2
Sample Container: Plastic (sterile)
Sample Type: Grab
Sample Volume Required: 100 ml. minimum
Hold Time: 48 hours
Preservative: None if waters are not chlorinated
Analytical Method: Method 9230D, Standard Methods for the Examination of Water or Wastewater, 21st Edition
4. Biological Oxygen Demand (BOD)
Discussion: Added 2020 (settlement agreement with Riverwatch) Sample Container: Plastic (sterile)
Sample Type: Grab
Sample Volume Required: 100 ml. minimum
Hold Time: 8 hours
Preservative: None if waters are not chlorinated
Analytical Method: Method 5210-B 5-day test, Standard Methods for the Examination of Water or Wastewater, 21st Edition
5. Dissolved Oxygen
Discussion: Added 2020 (settlement agreement with Riverwatch) Sample Container: Plastic (sterile)
Sample Type: Grab
Sample Volume Required: 100 ml. minimum
Hold Time: NA
Preservative: None if waters are not chlorinated
Analytical Method: Method 4500-O Membrane electrode, Standard Methods for the Examination of Water or Wastewater, 21st Edition
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8. SAMPLING EQUIPMENT AND CALIBRATION
A. Sampling Equipment Used At City of Sebastopol
The following are the sampling equipment used by the City Sampling pole with fixed container
Sampling pole with removable container
Sampling pail and rope
Grab-n-Go Sample Kit containing:
o Ice pack
o Waterproof pen
o Sample labels
o Camera
o Sample bottles
o Dissolved oxygen meter
B. Calibration and Record Keeping (Informational only, Sebastopol currently has no equipment that requires calibration)
Each piece of equipment is required to have an up-to-date calibration and maintenance logbook.
The logbook will be maintained to have consecutively numbered pages and shall contain at least the following:
Date
Calibration Results
Calibration comments
Initials of the individual calibrating the instrument Each instrument must be clearly identified (e. g., the make, model, serial and/or ID number) to differentiate among multiple meters.
The appropriate calibration procedure must be followed pursuant to City standard calibration operating procedure and if the instrumentation does not have an electronic program that maintains a running calibration log, then the results must be recorded in the logbook each time a piece of field equipment is used, along with the date and name/initials of the person performing the calibration.
If difficulty is encountered in calibrating an instrument, or if the instrument will not hold calibration, this information must also be recorded. Malfunctioning equipment should not be used to collect data. Steps should be taken to correct the problem as soon as possible. All equipment maintenance should be recorded in the logbook indicating what was done to correct the problem, along with the date and signature/initials of the staff person that corrected the problem.
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9. Sampling Procedures
A. Sample Location and Identification Procedures:
Samples will be collected by the City of Sebastopol Maintenance Staff. The most precise and accurate analytical measurements are worthless and even detrimental if performed on a sample that was improperly collected and stored, or was contaminated in the process. The purpose of sampling and analysis is to provide data that can be used to interpret the quality or condition of the water under investigation.
Unfortunately, water quality characteristics are not spatially or temporally uniform from one effluent to another. A sampling program must recognize such variations and provide a basis for compensations for their effects. The sample must be:
1. Representative of the material being examined;
2. Uncontaminated by the sampling technique or container;
3. Of adequate size for all laboratory examinations;
4. Properly and completely identified;
5. Properly preserved, and
6. Delivered and analyzed within established holding times.
These six requirements are absolutely necessary for a proper assessment of water quality.
It is impossible to establish hard and fast rules concerning sampling locations. However, the following general guidelines should be applied whenever City personnel conduct surface water sampling:
1. The sampling location should be far enough upstream or downstream of confluences or point sources so that the surface water and SSO volume is well mixed. Natural turbulence can be used to provide a good mixture.
2. Samples should be collected at a location where the velocity is sufficient to prevent deposition of solids, and to the extent practical, should be in straight reach having uniform flow. All flow in the reach should be represented, so divided flow areas should be avoided and samples should be taken towards the middle of the reach where feasible.
3. Sampler must always stand downstream of the collection vessel, and sample “into the current”. Care must be taken to avoid introducing re-suspended sediment into the sample.
B. Sample Types:
Grab samples are appropriate for the characterization of surface waters at a particular time and place, to provide information about minimum and maximum concentrations, to allow for the collection of variable sample volume.
Grab samples may be collected directly into the sample container, or a clean decontaminated intermediate container may be used if a wading sample is not possible or safe. If an intermediate container is used, when in the field, double rinse the sampling device (bucket, automatic sampler) with sample water prior to collecting the sample and be sure to discard rinse water downstream of where sample will be collected. If samples are collected in a bucket and Agenda Item Number 7
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distributed a consolidation collection container, swirl the contents of the bucket as it is being poured into the consolidation collection container to avoid settling of solids (and pour in back and forth pattern – e.g., 1-2-3-3-2-1).
Grab Sample: A grab sample is defined as an individual sample collected at a given time. Grab samples represent only the condition that exists at the time the sample is collected (US EPA 1977).
Surface Grab Sample: A sample collected at the water surface (i.e. skimming) directly into the sample container or into an intermediate container such as a clean bucket. A single or discrete sample collected at a single location.
Field Blanks are used to evaluate the potential for contamination of a sample by site contaminants from a source not associated with the sample collected (e.g., airborne dust, etc.).
Sterile, deionized water is taken into the field in a sealed container. This is the stock water.
The stock water is then poured into the sample container. The containers and sample submission forms are labeled as “Field Blank“. The same template selected for the test samples should be used. Field blanks are subject to the same holding time limitations as samples. The appropriate FIELD QC box on the sample Chain of Custody form should be checked.
C. Decontamination Procedures
Removing or neutralizing contaminants from sampling equipment minimizes the likelihood of sample cross contamination, reduces or eliminates transfer of contaminants to clean areas, and prevents the mixing of incompatible substances.
Gross contamination can be removed by physical decontamination procedures. These abrasive and non-abrasive methods include the use of brushes, air and wet blasting, and high and low pressure water cleaning.
The decontamination procedure described above may be summarized as follows:
1. Physical removal
2. Non-phosphate detergent wash
3. Tap water rinse
4. Distilled/deionized water rinse
5. 10% nitric acid rinse
6. Distilled/deionized water rinse
7. Solvent rinse (pesticide grade)
8. Air dry
9. Distilled/deionized water rinse
D. Sample Labeling and Chain of Custody Procedures
A sample is a physical evidence of a facility or the environment. An essential part of all enforcement investigations is that evidence gathered be properly documented. To accomplish this, the following sample identification and chain of custody procedures are established.
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performed. When in-situ measurements are made, the data are recorded directly in Field Data Worksheets with identifying information, field observations, and remarks. Examples of in-situ measurements are:
pH
Temperature
Dissolved Oxygen
Stream Flow Measurement
Samples other than in situ measurements must be identified by a sample label. These samples are removed from the sample location and transported to a laboratory for analyses. Before removal, however, a sample is often separated into portions depending upon the analyses to be performed. Each portion is preserved in accordance with applicable procedures and each sample container is identified by a sample label.
2. At a minimum, the following grab samples will be collected, in duplicate:
Field Blank: See Section 9.B for discussion.
Upstream: This sample will be collected far enough upstream of the SSO’s point of entry into the surface water as to be free of contaminants from the SSO. Typically, 50- feet is sufficient, but this may vary on circumstances of the spill. Source: Immediate vicinity where the SSO entered the surface water. This point will actually be downstream of the actual SSO entry point for SSO’s that have stopped entering the surface water to be sampled. If the SSO has stopped, calculate the approximate downstream distance from the original SSO location by dividing the time since the SSO occurred by the estimated velocity. This is the approximate downstream distance from the SSO discharge point to the “source” sampling location. o Due to possible tidal action in the surface water or other factors, another method may be used to determine the “source” location at the discretion of any of the following LROs:
City Manager, Mary Gourley-LRO
Oriana Hart, Public Works Director/Data Submitter
Erik Billing, Public Works Operation Supervisor-LRO/Data Submitter “Downstream” of SSO: This sample will be collected far enough downstream to be representative of the water quality of the surface water after adequate mixing of the surface water and the SSO have occurred. Typically, this location will be 50-feet downstream of the Source sample, but this may vary on the size and velocity of the surface water to be sampled.
o NOTE: The terms “upstream” and “downstream” may depend on the tidal cycle if the water body is tidally influenced. Check the tide chart(s) and table at the following link:
http://tidesandcurrents.noaa.gov/noaatidepredictions/NOAATidesFacade.jsp?S tationid=9415623.
3. Sample labels shall be completed for each sample, using waterproof ink. The information recorded on the sample tag/label includes:
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Time: a four-digit number indicating military time of collection (e.g., 0954) Sample Location: sampling location description as either Upstream, Source, or Downstream
Samplers: each sampler is identified
Parameter/preservative: the analysis to be conducted for the sample /sample preservation
4. Photos or video of each sample location will be taken, properly labeled with date, time, and view direction and a map of the photo locations completed. Photos and videos shall include relevant landmarks to identify sampling locations and their surroundings.
Due to the evidentiary nature of samples collected during enforcement investigations, possession must be traceable from the time the samples are collected until they are analyzed. To maintain and document sample possession, a Surface Water Sample Chain of Custody Record (Attachment C) must be completed. A sample is under your custody if:
It is in your possession, or
It is in your view, after being in your possession, or It was in your possession and under your control to prevent tampering, or It is in a designated secure area.
5. As few people as possible should handle samples. The person taking the samples is personally responsible for the care and custody of the samples collected until they are transferred or dispatched properly.
6. Samples are accompanied by a chain of custody record. When transferring the possession of samples, the individuals relinquishing and receiving will sign, date, and note the time on the record. This record documents sample custody transfer from the sampler, often through another person, to the analyst at the laboratory. The samples are typically transferred to the sample-receiving custodian at the laboratory.
E. Safety Considerations
Personal safety of staff engaged in any fieldwork activity (e.g., in transit, walking or hiking, and any field activities while at the sample site) is of primary importance. Staff should never place themselves in dangerous or risky situations. Any hazards that are known by field personnel should be communicated to other members of the field crew.
Fieldwork should be postponed if there is indication that engagement in the field activity could cause bodily harm. Working during lightning storms, at night, in heavy vegetation or poison oak, near aggressive wildlife or domestic animals, traversing steep or rugged terrain, unstable slopes or creek banks, near swiftly moving water or potential flash flood conditions, or during snowy weather is not considered "normal risk". If any member of the field crew is uncomfortable with a reasonable self-determined hazardous field condition, it is that person’s responsibility to bring this to the attention of the on site field supervisor or their supervisor. A “reasonable selfdetermined hazardous field condition” is defined as other than normal risk. Supervisors shall Agenda Item Number 7
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not dismiss any person’s spoken concerns that field conditions are too hazardous to complete the work assignment.
The person taking the samples must have adequate protection, including protective clothing.
They must wear gloves, as protection against chemical and/or bacteriological hazards, while they are sampling or handling samples that are known or suspected to be hazardous (e.g. visible solids or sheens, downstream from sewage spills, etc.), or if hands have open wounds.
The type of gloves worn shall be determined by the sampling circumstance and type of pollutants expected – for instance longer gloves are needed when samples must be taken well below the surface.
When in a boat or wading in a stream, a personal floatation device shall be worn at all times.
Other protective measures shall be taken in accordance with Sebastopol safety procedures.
Upon arrival at a sampling site, safety equipment such as signs, cones, lights, etc. shall be set out as appropriate. Vehicles shall be parked in locations and directions to minimize traffic disruption and avoid sample contamination. Photos should be ultimately taken of the placement of all safety equipment and signage
The following guidelines apply to all fieldwork by City staff. No sample or measurement is worth the risk of injury. All staff shall use proper personnel protective gear as appropriate for the incident (e.g., life preservers, gloves, goggles, etc.)
Field sampling crews should consist of at least two members unless otherwise approved by a supervisor.
Be conscious of the whereabouts of rattlesnakes, mountain lions, and other dangerous animals.
Open body wounds are entry sites for infection; take the necessary precautions for self-protection.
If there is storm activity in the work area, wait for safer conditions to develop or postpone the sampling.
Do not sample at night without approval from your supervisor. Do not trespass on private property, or posted restricted public lands without prior permission and written approval from property owner or administrator. If strange or suspicious looking people are in the work area, either wait for them to leave or postpone the work to a later time. Do not force confrontations with strangers and back away from any confrontations with the public. Be courteous and understanding of public concerns of the situation.
Take the necessary precautions against exposure to harmful weather conditions such as heat, wind, snow, cold, rain, etc.
Carefully evaluate a given on-site situation to determine if the task can be performed safely. Wear protective footwear when entering streams.
Do not enter the stream if the water is flowing too fast.
F. Stream Velocity Measurements
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If sampling is performed after the SSO has stopped, the velocity of the impacted surface water should be determined in order to estimate SSO travel time and select an accurate Source sample location. One way to measure the SSO travel time is to use a velocity probe (such as a Global Water FP111-S Flow Probe) to determine the rate of flow in the water body. The City doesn't have one currently, but if a water velocity probe is used in the future, the manufacturer’s instructions will be followed.
G. Grab-n-Go Sampling Kit
The City maintains a Grab-n-Go sampling kit located at the Public Works Corporation Yard.
The kit is inspected quarterly by the Public Works Wastewater Treatment Operator.
Additionally, any City staff utilizing the kit is responsible for decontaminating sampling equipment and field monitoring devices and replenishing the kit.
SSO Sample Collection Kit Inventory:
Cooler
Surface Water Sampling SOP (Attachment B)
Ice Pack (stored in freezer)
5 Ammonia sample bottles, preserved (3 for samples, 1 for Field Blanks and 1 extra in the event of contamination, spillage of the preservative or other contingency) 5 sample bottles (3 for samples, 1 for Field Blanks and 1 extra in the event of contamination, or other contingency)
Digital camera, with extra batteries
Disposable nitrile gloves
Safety glasses/goggles
Surface Water Sampling Worksheet (Attachment D)
Sampling Pole
Field Lights
Waterproof Pen
Minimum of 20 blank sample bottle labels
Chain of Custody form (Attachment C)
Boat and personal floatation device (if applicable)
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H. Surface Water Maps
Maps of surface waters in the Sebastopol service area that may be impacted by an SSO are located in Attachment F.
I. Follow Up Sampling
1. Sampling will be repeated every 24 hours, or as directed by the RWQCB or Sonoma County Environmental Health Department, until such time as one of the following criteria have been met:
The County Environmental Health Department or the RWQCB indicates follow up sampling is no longer required, or
Both the ammonia and bacteria levels downstream are approximately equal to or less than the upstream levels; or
The concentration of ammonia is at or below that of the upstream sample, or the unionized ammonia is below 0.16 mg/L as N; and The concentration of fecal coliform levels is below the applicable water quality objective levels for fecal coliform shown in Table 9.1 below for the appropriate beneficial use.
Beneficial Use Fecal Coliform
(MPN/100 mL)
Total Coliform
(MPN/100 mL)
Enterococci
(CFU/100 mL) E. coli (CFU/100 mL)
Water Contact Recreation
(REC-1) – Fresh Water — — —
Geometric Mean ≤
100STV ≤ 320
Water Contact Recreation
(REC-1) – Marine/Estuarine
Water
— —
Geometric Mean
≤ 30STV ≤ 110 —
Shellfish Harvesting (SHELL) 90th Percentile
≤ 43
90th Percentile
≤ 230 — —
Non-Contact Water Recreation
(REC-2) — — —
No specific
bacteriological objective
established
*Water Quality Control Plan (Basin Plan) for the North Coast Region, California Regional Water Quality Control Board, as amended.
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J. Surface Water Sampling SOP
The Surface Water Sampling SOP, Attachment B, provides step-by-step procedures to collect samples and deliver them for analysis in accordance with Sections 6, 7 and 9.
10. NOTIFICATIONS OF SENSITIVE RECEPTORS AND REGULATORY AGENCIES Table 10.1 describes regulatory and other notifications that must be made in accordance with the triggers indicated:
Table 10.1 Notifications of Sensitive Receptors and Regulatory Agencies Contact Trigger Deadline How Person(s)
Responsible
CalOES Category 1 SSO of
1,000 gallons or
greater that reaches
surface water or a
drainage conveyance
that discharges to
surface water.
2 hours after
awareness of
SSO
Call CalOES at
(800) 852-7550.
County
Environmental
Health
Notify when an SSO
may pose a threat to
public health
As soon as
practicable
(707) 565-6565
SWRCB Category 1: Draft
report within 3
business days; certify
within 15 calendar
days of SSO end
date. Category 2:
Same reporting
timeline. Category 3:
Certified report
within 30 calendar
days after the end
of the month in
which the SSO
occurred.
CIWQS*
RWQCB
Public Works
Director
Any reportable spill With 24 hours Phone Call Public Works Staff
City Manager Any reportable spill 3 Business days email Public Works Superintendent
Sonoma County
Water Agency
If Spill Reaches the
Russian River
2 Hours Bus.Hrs.
707-526-5370
Aftr. Hrs
707-523-1070
Russian River
Utility
If Spill Reaches the
Russian River
2 Hours 707-887-7735
Sweet Water
Springs
If Spill Reaches the
Russian River
2 Hours 707-869-4000
* In the event that the CIWQS online SSO database is not available, notify the State Water Resources Control Board (SWRCB) by phone or email and provide required information until the CIWQS online SSO database becomes available.
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11. TECHNICAL REPORT
The Monitoring and Reporting Program (MRP) requires that, in the event of a Category 1 SSO in which 50,000 gallons or greater are discharged to surface waters, the City shall prepare and submit an SSO Technical Report. The Technical Report shall include a description of all water quality monitoring activities conducted, a map showing all sampling locations, analytical results, and an evaluation of the monitoring data in accordance with the requirements of the MRP. The Technical Report shall be submitted through the CIWQS Online SSO Database within 45 calendar days following the end of the SSO and shall be certified by the City's Legally Responsible Official (LRO).
City Manager, Mary Gourley-LRO
Oriana Hart, Public Works Director-LRO/Data Submitter
Erik Billing, Public Works Supervisor-LRO/Data Submitter
12. RECORDKEEPING
All sampling related records associated with this WQMP should be contained in the appropriate SSO Incident file designated with a specific locator record number. These records shall include at least the following documents related to the WQMP:
• A narrative description of water quality sampling activities associated with the event. • Timeline of the sampling activities until sampling is terminated. • All surface water sampling worksheets.
• Computations of spill travel time in surface waters, if appropriate. • Chain of Custody for all samples.
• Sampling Map of all sample locations.
• All photos or video showing sampling activities.
• Final analytical results from the certified laboratory conducting the sample analysis along with an Agency evaluation of the results to determine the nature and impact of the release. • Failure analysis reviews of the WQMP including recommendations for changes and modifications.
• Calibration records for specific equipment used in the sampling processes. • Notification documentation for all public and private agencies involved with or requiring monitoring related to final sample results.
The City shall maintain all records including records from service contractors associated with this WQMP as part of the file records for an SSO as required by the WDR and MRP. These records shall be maintained for a minimum period of five-years from the end date of the SSO unless required by regulatory enforcement action, request of the State or Regional Board or as support for claims litigation resulting from the SSO. All records associated with the SSO shall be destroyed upon reaching the end of the file retention period or as otherwise required by the Regional or State Board.
Samples of all City forms and records used in this WQMP are included as attachments.
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13. TRAINING
Training will be provided in accordance with Table 13.1.
Table 13.1 Sebastopol surface water sampling training program Who Is Trained To Collect Surface Water
Samples?
PUBLIC WORKS MAINTENANCE STAFF
Trainer Qualifications The trainer shall, by virtue of training, experience, education or a combination thereof
demonstrate expertise in surface water
sampling science, techniques and
documentation.
Training Curriculum at a minimum, training shall include:
The Sebastopol Water Quality
Monitoring Plan
Sampling technique, including hands on
practice
Sampling equipment calibration, use
and decontamination procedures,
including hands on practice
Sampling safety
Completion of the Sampling Equipment
Calibration/Maintenance Log, Surface
Water Sampling Report and Chain of
Custody
Training Documentation Attendees shall be required to sign-in to all training on the appropriate forms used by
AGENCY.
Refresher Training Frequency Annual
Who is Responsible for Ensuring Training
Occurs?
PUBLIC WORKS OPERATIONS
SUPERVISOR
Required Training Records Employee training sign in log Who is Responsible for Maintaining Records? PUBLIC WORKS OPERATIONS
SUPERVISOR
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14. INTERNAL REVIEW AND UPDATE OF THE WQMP
The WQMP is a requirement of the WDR and MRP regulations and therefore the WQMP must be adopted by the City governing board when completed and thereafter at the same time as the new adoption of the SSMP every five years or when major changes to the SSMP are required. Internal reviews of the WQMP should be conducted at a minimum with City SSMP audits or with a failure analysis following a SSO event requiring the use of this WQMP. This latter evaluation should be used to determine if any procedures or program changes would improve the WQMP.
The internal review of the WQMP must include a thorough review of the then existing WQMP against actual performance by the agency staff and testing laboratory during and after the event.
All documents associated with the water quality sampling should be reviewed and included in the SSO file and compared to the requirements in this Plan. Particular attention should be given to all dates and times associated with the monitoring, proper tests in support of the Regional Board Basin Plan, proper completion of the Chain of Custody, equipment calibration documentation of all equipment used for sampling and available photographs or video of the sampling processes, review and sign-offs by all responsible parties, review of the sampling locations map, final lab results and the certification report that the Technical Report was submitted within 45 calendar days of the end of the SSO to the CIWQS system.
In addition, the City should also conduct regular reviews of the WQMP at least annually or along with the tri-annual SSMP Audit required by the WDR. The review should be undertaken to determine that all information in the Program is current, that all classification responsibilities have not changed, that all forms are still appropriate and that all contract relationships with testing laboratories, if not associated with the agency, are still current and available 24 hours per day and 7 days per week. The review should also include a review of the Regional Board Basin Plan to assure continuing conformance with the Basin Plan.
This internal review should be conducted by senior management of the collection systems personnel, laboratory management and any outside contract laboratory services subsequent to any event or once per year if the WQMP has not had to be invoked during the preceding year.
Finally, a schedule and assignment of responsibility for completion of the recommended changes should be prepared along with additions to the SSMP Change Log for these changes and modifications of the WQMP.
CHANGE LOG
The new MRP, Section E.3 requires that all changes to the Sanitary Sewer Management Plan be recorded and documented using an SSMP Change Log indicating what section is being change, a description of the changes, and the person or persons authorizing the changes. Because the WQMP is required by the WDR and MRP, it is also necessary that changes to the WQMP be included in the documentation of changes to the SSMP. Any changes resulting from Section 14 above should be added to the Change Log of the SSMP upon implementation and adoption of the changes as required by the WDR.
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ATTACHMENT A
Water Quality Monitoring Plan Change Log
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Water Quality Monitoring Plan Change Log
Date Section(s) Changed Summary of Change Approved
8/25/20 7
Added BOD and dissolved oxygen
to testing parameters as a result of
settlement agreement with
Riverwatch
7/23/26 Various Updated Staffing Oriana Hart
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ATTACHMENT B
Surface Water Sampling SOP
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Surface Water Sampling Standard Operating Procedure
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ATTACHMENT C
Sample Collection Chain of Custody Record
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City of Sebastopol Water Quality Monitoring Program Plan Surface Water Sample Collection Chain of Custody Record © 2014 DKF Solutions Group, LLC Page 33 of 44
Customer Name Hazardous Waste PO#
Customer Address Unknown Material WO#
Customer Telephone Mail Code CONTRACT LAB INFORMATION Turnaround Requirement Program Name Ship to: Normal (21 days)
Rush:
Other:
Lab Program
Coordinator
Phone # Ship Date:
Sampled By Courier:
LIMS#
(Issued by Lab)
SAMPLE COLLECTION INFORMATION # Containers Matrix*
Analysis Requested QA/QC Requirements
Date Time
Type
Sample Location Field pH Field Temp Ammonia Enterococcus Lab Standard
Special (see attached) Composite Grab Remarks/Notes
Upstream 2 A
Entry Point 2 A
Downstream 2 A
2
2
2
2
*Matrix: P = Potable Water, W = Wastewater, A = Ambient Water, G = Groundwater, S = Soil, B = Biosolids, I = Industrial, O = Other (specify in remarks) Relinquished Date Time Relinquished to Date Time Transport/Shipping Information USPS UPS FedEx
Tracing #:
Other:
Sample Receiving Documentation
Container intact? Yes No Correct container? Yes No Field preserved? Yes No Custody tape intact? Yes No Cooled? Yes No Temp. Blank? Yes No ( °C) Comments:
Sample distribution: Lab bench Ice chest Walk-in cooler shelf # Disposal Date: Disposed by: (inits.) Agenda Item Number 7
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C-O-C Distribution Date: By: Lab Admin File Prog/proj Mgr. Lab Prog. Coord. Delivery courier Pick-up courier
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ATTACHMENT D
Surface Water Sampling Worksheet
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Surface Water Sampling Worksheet City of Sebastopol
Water Quality Monitoring Program Plan
© 2014 DKF Solutions Group, LLC Page 36 of 44
Sample Date: Sample Time: ☐AM ☐PM Sample Location:
Sampler(s)’ Name(s):
Sampler(s)’ Signature(s):
What is being sampled?
☐Stream ☐Pond ☐Lake ☐Lagoon
☐Bay/Estuary ☐Ocean ☐River ☐Other:
If the SSO was not actively entering the surface water during sampling:
A. Stream Velocity: CFS
B. How Long Has the SSO NOT Been Entering the Surface Water? minutes X 60sec/min = seconds
C. How Far Downstream Did You Travel To Collect The SOURCE Sample? (A X C = Feet): feet
D. Explain why you travelled a different distance, if you did, to collect the source sample:
Weather at time of sampling: ☐Sunny ☐Overcast
☐Sprinkling ☐Raining ☐Snowing
Was the SSO actively entering the surface water during
Sampling? ☐YES ☐NO
If no, complete A-D in the gray box to the right
NOTE: Calibrate equipment prior to use and record in the Equipment Calibration/Maintenance Log Sample
Location
# of
Samples* pH Temp.
(°C)
DO
(mg/l)
Photo ID# of
Sample Location Visual Observations and/or Interferences Upstream
Source
Downstream
Field Blank
* Minimum of 2 per location
FINISH CHECKLIST NOTES / OBSERVATIONS
All Samples Labeled with:
Date: a six-digit number indicating the year, month, day of collection Time: a four-digit number indicating military time of collection. e.g. 0954 Sample Location: Upstream, Source, or Downstream
Samplers: each sampler is identified
Parameter/preservative: analysis to be conducted for sample preservation Chain of Custody Completed
Samples on Ice in Cooler
Pictures Taken of Each Sample Location and the Photo ID/# Noted Above All Sampling Equipment Collected
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ATTACHMENT E
Technical Report
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Technical Report
Outline
1. Introduction
Agency/system description
2. SSO Technical Report - Contents and Responses
a. Causes and Circumstances of the SSO
i. Detailed explanation of how and when SSO was discovered ii. Diagram indicating SSO "Cause point", appearance point, and final destination (use attachments, maps and diagrams as needed)
iii. Detailed description of methodology employed and available data used to calculate the SSO volume and any volume recovered
iv. Detailed description of the cause(s) of the SSO
v. Copies of the original field crew records used to document the SSO (attachment) vi. Historical maintenance records for the lines involved in the cause of the SSO (attachment) b. Agency's Response to the SSO
i. Chronological narrative description of actions taken by agency to terminate the SSO ii. Description of how the OERP was implemented to respond to and mitigate any impacts of the SSO
iii. Final corrective action(s) completed and/or planned, including a schedule for actions not yet completed
c. Water Quality Monitoring
i. Description of all water quality sampling activities conducted, including analytical results and evaluation of the results
ii. Detailed location map illustrating all water quality sampling points
3. Conclusions
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ATTACHMENT F
SURFACE WATER MAPS
Zimpher Creek
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Witter Creek
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Atascadero Creek
Calder Creek
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Laguna de Santa Rosa
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Morris Outfall
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Appendix C: Sewer System Management Audit Checklist
Appendix C: Sewer System Management Audit Checklist (2026) City of Sebastopol 2026
SSMP Audit Checklist
Report Form
The purpose of the SSMP Audit is to evaluate the effectiveness of the City SSMP and sanitary sewer program and to identify any needed for improvement. The information identified here will be used to inform the possible findings and necessary information to be evaluated during the biannual Internal Audit of the City SSMP.
Directions: Please rank each item below utilizing the following sufficiency ranking system and add any comments to explain the ranking to the Comment Section of each SSMP Element:
• Complies (C) - complies with all WDR objectives
• Substantially Complies (SC) - complies mostly with all WDR objectives • Partially Complies (PC) - complies with basic WDR objectives • Marginal Compliance (MC) - complies minimally with basic objectives of the WDR • Does Not Comply - does not comply with WDR objectives • Not applicable (NA) – does not need to be included in this Audit Element O - Introduction/Executive Summary
A. NA
B. NA
C. NA
D. NA
Element I- Goals Rating
A. Are the goals stated in the SSMP Element I still appropriate and accurate? Discussion:
Element II - Organization Rating
A. Is the List of Staff Responsible for SSMP Elements current? B. Is the Sanitary Sewer Overflow Responder List current? C. Is the Organization Chart current?
D. Are the Staff position descriptions an accurate portrayal of staff responsibilities? Are the LRO and DSs properly identified in the position descriptions?
C
C
C
C
C
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Appendix C: Sewer System Management Audit Checklist
E. Is the Chain of Communication for Reporting and Responding to SSOs section/flow chart accurate and up to date?
Discussion: There have been several staff changes and those changes will be noted in the revised Public Works organization chart and the Responder List has been updated as of beginning of fiscal year 2026/27
Element III - Legal Authority Rating
Does the SSMP contain current references to the Sebastopol Municipal Code documenting City's legal authority to:
A. Prevent illicit discharges?
B. Require proper design and construction of sewers and connections? C. Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the City?
D. Limit discharges of fats, oils, and grease?
E. Enforce any violation of its sewer ordinances?
F. Were any changes or modifications made in the past year to Sewer Ordinances, Regulations, or standards?
Discussion:
I Element IV - Operations & Maintenance
Collection System Maps Rating
A. Does the SSMP reference the current process and procedures for maintaining City's wastewater collection system maps?
B. Are the wastewater collection system maps complete, current, and sufficiently detailed?
C. Are storm drainage facilities of the City and County identified in the City service area on the collection system maps? If not, are SSO responders able to determine locations of storm drainage inlets and pipes for possible discharge to waters of the state?
Prioritized Preventive Maintenance Rating
D. Does the SSMP describe current preventive maintenance activities and the system for prioritizing the cleaning of sewers?
E. Based upon information in the Annual SSO Report, are the City's preventive maintenance activities sufficient and effective in minimizing SSOs and blockages?
C
C
C
C
C
C
NA
C
C
C
C
C
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Appendix C: Sewer System Management Audit Checklist
Scheduled Inspections and Condition Assessments Rating
F. Is there an ongoing condition assessment program sufficient to develop a capital improvement plan addressing the proper management and protection of infrastructure assets? Are the current components of this program documented in the SSMP?
Contingency Equipment and Replacement Inventory Rating
G. Does the SSMP list the major equipment currently used in the operation and maintenance of the collection system and documents the procedures of inventory management?
H. Are contingency and replacement parts sufficient to respond to emergencies and properly conduct regular maintenance?
Training Rating
I. Does the SSMP document current training expectations and programs for staff and contractors?
Outreach to Plumbers and Building Contractors Rating
J. Does the SSMP document current outreach efforts to plumbers and building contractors?
Element V - Design and Performance Standards Rating
A. Does the SSMP reference current design and construction standards for the installation for new sanitary sewer systems, pump stations and other appurtenances and for the rehabilitation and repair of existing sanitary sewer systems?
B. Does the SSMP document current procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and the rehabilitation and repair of existing sewer lines?
Discussion: The City Standards do not include construction inspection requirements but are included in the Construction Notes and Details in sewer improvement plans and/or City encroachment permit requirements. Construction inspection requirements will be included in a future update to the City Standards.
Element VI - Overflow and Emergency Response Plan Rating A. Does the City Sanitary Sewer Overflow Emergency Response Plan establish procedures for the emergency response, notification, and reporting of SSOs? B. Are staff and contractor personnel appropriately trained on the procedures of the Sanitary Sewer Overflow Emergency Response Plan?
C
C
C
C
C
MC
C
C
C
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Appendix C: Sewer System Management Audit Checklist
C. Considering SSO performance data, is the Sanitary Sewer Overflow Emergency Response Plan effective in handling SSOs in order to safeguard public health and the environment?
D. Are all SSO and claims reporting forms current or do they require revisions or additions?
E. Does all SSO event recordkeeping meet the SSS GWDR and MRP requirements? Are all SSO event files complete and certified in the CIWQS system?
F. Is all information in the CIWQS system current and correct? Have periodic reviews of the data been made during the year to assure compliance with SSS GWDR?
Have all Technical Report and Water Quality Sampling requirements been met and uploaded to the CIWQS data management system?
Discussion:
Element VII - Fats, Oils and Grease (FROG) Control Program Rating A. Does the FROG Control Program include efforts to educate the public on proper handling and disposal of FROG?
B. Does the FROG Control Program identify sections of the collection system subject to FROG blockages, establish a cleaning schedule and address source control measures to minimize these blockages?
C. Are requirements for grease removal devices, best management practices (BMP), record keeping, and reporting established in the FROG Control Program?
D. Does City have sufficient legal authority to implement and enforce the FROG Control Program?
E. Is the current FROG program effective in minimizing blockages of sewer lines resulting from discharges of FROG to the system
F. Was required training on SSMP and OERP completed and documented? Were field exercises with field staff on SSO volume estimation conducted and documented?
G. Did all public improvement plans and specifications that could impact collection system operations include requirements for OERP training or were contractor OERP programs at least as stringent as the City OERP? Were regular items included in project meeting agendas to discuss emergency response procedures and communications?
Discussion: The City of Sebastopol contracts with the City of Santa Rosa to manage, implement, and enforce Sebastopol’s FROG and pretreatment program. Although the City is in compliance, program effectiveness will be further evaluated with City of Santa Rosa inspection staff.
C
C
C
C
C
C
C
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C
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Agenda Item Number 7
Agenda Item Number 7
City Council Meeting Packet for September 15, 2026
Appendix C: Sewer System Management Audit Checklist
Element VIII - System Evaluation and Capacity Assurance Plan Rating A. Does the City Sewer System Master Plan evaluate hydraulic deficiencies in the system, establish sufficient design criteria and recommend both short and long-term capacity enhancement and improvement projects? B. Does the City Capital Improvement Plan (CIP) establish a schedule of approximate completion dates for both short and long- term capacity improvements and isthe schedule reviewed and updated to reflect current budgetary capabilities and activity completed?
Discussion: The City is currently updating its Sewer Master Plan, which will evaluate the hydraulic capacity and condition of the sewer system and provide recommendations to inform the FY 2027/28 Capital Improvement Program (CIP). An update to the SSMP will include the finalized list.
Element IX - Monitoring, Measurement and Program Modifications Rating A. Does the SSMP accurately portray the methods of tracking and reporting selected performance indicators?
B. Is City able to sufficiently evaluate the effectiveness of the SSMP elements based on relevant information?
C. Do the performance metrics properly support the Goals in Element 1? Discussion: The Public Works Department prepares an Annual Report to the City Council each year in August and the Report is presented at a regularly scheduled City Council meeting.
Element X - SSMP Audits Rating
A. Will the SSMP Audit be completed, reviewed and filed in Appendix B based upon the required time intervals since the original SSMP adoption date? B. Was the last Audit Report certified by the City LRO as required? C. Was the final Audit Report presented to the governing body at a publicly noticed meeting?
D. Was the last Audit Report placed in the SSMP Appendix and added to the SCWD SSMP webpage.
Discussion:
Element XI-Community Program Rating
A. Does City effectively communicate with the public and other agencies about the implementation of the SSMP and continue to address any feedback? B. Did the City receive and review the Annual Sewer System Report? MC
MC
C
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Agenda Item Number 7
Agenda Item Number 7
City Council Meeting Packet for September 15, 2026
Appendix C: Sewer System Management Audit Checklist
C. Was the annual report uploaded to the City Sewer Section website and added to Appendix C?
D. Did staff conduct and document meetings with the Pebble Beach Community Services City's satellite collection systems? N/A
E. Are all agreements with satellite systems current or are changes necessary to these agreements? N/A
Discussion: The City presented the 2020 SSMP at a City Council meeting that was publicly noticed and the 2022 Audit Report is also publicly noticed. Any comments and feedback are taken and recorded in City Council meeting minutes.
Change Log Rating
A. Is the SSMP Change Log current and up to date? C
Discussion: The Change Log is current and up to date (Appendix D). The Public Works Department will mark up the 2026 SSMP to reflect the Change Log.
Audit Team: Date:
Prepared By: Date:
Reviewed By: Date:
Certified By: Date:
Approved for Filing On Date:
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Agenda Item Number 7
Agenda Item Number 7
City Council Meeting Packet for September 15, 2026
Sanitary Sewer (SSO) Data for Calendar Year 2025
Calendar
Year
Gravity Sewer
SSOs
Pump Station
SSOs
Force Main
SSOs
Total Volume Spilled
(Gallons)
Portion Contained
and Returned to Sewers
(Gallons)
Total Volume
Entering Surface Waters
(Gallons)
2014 2 0 0 826 1 825
2015 6 0 0 28,341 12 28,329
2016 5 0 0 1,310 328 982
2017 1 1 0 2,039 0 2,039
2018 4 0 0 1,926 271 1,655
2019 0 0 0 0 0 0
2020 1 0 0 19 19 0
2021 2 0 0 5,710 257 5,453
2022 1 0 0 22 22 0
2023 0 0 0 0 0 0
2024 3 0 0 71 50 21
2025 1 0 0 133 133 0
CY Roots Debris Grease Cap./
Infil. Vndl. PipeFailure
PS
Failure
Force
Main
Failure
Other Total
2014 2 0 0 0 0 0 0 0 0 2
2015 2 3 0 0 0 0 1 0 0 6
2016 3 1 1 0 0 0 0 0 0 5
2017 1 0 0 0 0 0 1 0 0 2
2018 2 2 0 0 0 0 0 0 0 4
2019 0 0 0 0 0 0 0 0 0 0
2020 0 1 0 0 0 0 0 0 0 1
2021 0 2 0 0 0 0 0 0 0 2
2022 0 1 0 0 0 0 0 0 0 1
2023 0 0 0 0 0 0 0 0 0 0
2024 3 0 0 0 0 0 0 0 0 3
2025 0 1 0 0 0 0 0 0 0 1
Total 13 11 1 0 0 0 2 0 0 27
2 6
5 2
4 0
1 2
1 0
3 1
0 1
2 3
4 5
6 7
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 SSOs Sanitary Sewer Overflows by Calendar Year
Agenda Item Number 7
Agenda Item Number 7
City Council Meeting Packet for September 15, 2026