o Title 3 Chapter 3: 3-3-5 Sewer Connection and Use Fees o 10-6-11 Subdivision Sewer and Drainage Standards
Conclusion: The section above is in compliance with Section D.13(iii)(b).
Finding: Section D.13(iii)(c): City currently does not own and therefore does not require access to maintain or repair any portion of a Lateral Sewer, House Sewer or House Drain.
City ensures access for inspection for portions of the lateral owned or maintained by a “Person” in:
City Municipal Code Section Referenced in SSMP:
o Title 3 Chapter 3: 3-3-2 (F) Inspection.
Conclusion: The section above is in compliance with Section D.13(iii)(c).
Finding: Section D.13(iii)(d): City has the authority to limit the discharge of FOG and other debris that may cause blockages into the system in the sections of code specified below:
City Municipal Code Section Referenced in SSMP:
o Title 3 Chapter 3: 3-3-3-1 Fats Oils and Grease (FOG) Control Program Conclusion: The section above is in compliance with Section D.13(iii)(d).
Finding: Section D.13(iii)(e): City has the authority to enforce any violation of its sewer ordinances in the sections of the Municipal Code specified below:
City Municipal Code Sections Referenced in SSMP:
o Title 3 Chapter 3: 3-3-2 General Provisions
Conclusion: The section above is in compliance with Section D.13(iii)(e).
Element 3.0 Sufficiency: In Compliance
Reference: City SSMP, Revision 1 April 28, 2015 Pages 3-1 to 3-3, City of Taft Municipal Code Title 3 Chapter 3.
Deficiencies: None.
Recommendation: None.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
4.0 Operation and Maintenance Program [SSSWDR D.13(iv)] SSSWDR D.13(iv) states:
The SSMP must include those sections listed below that are appropriate and applicable to the Enrollee’s system:
(a).Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable storm water conveyance facilities;
(b).Describe routine preventive and operation and maintenance activities by staff and contractors, including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The Preventative Maintenance (PM) Program should have a system to document scheduled and conducted activities, such as work orders; (c). Develop a rehabilitation and replacement plan to identity and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally the rehabilitation and replacement plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed to the capital improvement plan;
(d).Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained; and (e).Provide equipment and replacement part inventories, including identification of critical replacement parts.
Finding: Section D.13(iv)(a): All major sewer assets and appurtenances are identified in the City’s GIS Sewer Atlas Map referenced in the April 2015 SSMP. An example of the sewer atlas is included in Figure 4-1 on page 4-1 of the SSMP. The City does not currently maintain a storm water collection conveyance map for storm water assets that may be impacted by a SSO. A list of storm water subsurface drainage areas are provided on page 4-3 of the SSMP as a reference for operations staff in the event of a SSO. The SSMP commits to including these areas into a storm water GIS layer by February 2016. There was no evidence of this storm water map update at the time of this audit. Sewer system maps are updated by KSA staff as improvements are made and specific sewer assets such as missing manhole locations are discovered. This information is documented on paper copies of the existing sewer atlas and submitted for formal annual updates to the sewer system atlas.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Conclusion: The section above is in partial compliance with Section D.13(iv)(a). See recommendations section below.
Finding: Section D.13(iv)(b): The April 2015 City SSMP summarizes goals and Routine Preventative Operation and Maintenance (O&M) for Pipelines, Manholes, Lift Stations, and Complaint Investigations.
Sewer line cleaning and routine visual inspections are contracted and performed by Kern Sanitation Authority (KSA) operations staff. Sewer cleaning and visual observations are documented in the field on a KSA Sewer Line Cleaning Log and Report. This information is additionally summarized and entered into an Annual Sewer Line Cleaning Log Report database managed by KSA. The City SSMP discusses Quarterly sewer line cleaning by the City’s former contractor, Severn Trent (this should be updated to reflect contracted services with KSA).
Quarterly cleaning is conducted to address “Hot Spots” or High Maintenance areas in the collection system. The City also schedules the entire system to be cleaned annually as a goal.
The City’s contract with KSA requires Quarterly Hot Spot cleaning and annual cleaning of the entire system. CCTV is used to provide Quality Control and Quality Assurance for annual and hot spot cleanings. These practices and information should be integrated into the next update of the City’s SSMP.
The City’s SSMP reports that CCTV investigations are completed on an as needed basis. Under the recently executed contract with KSA, CCTV will be conducted annually on 20% of the system. When the entire system is complete this data will be analyzed for potential rehabilitation and replacement projects. The City is currently planning to complete additional CCTV investigations after 100% of the system is televised and assessed, inspecting 20% of the system annually.
Operation and Maintenance for the one (1) City Lift Station is also contracted to KSA. This lift station is inspected daily with observations logged in a daily lift station log. The City SSMP states that a work order is generated monthly for this lift station which requires operators to check for; proper pump performance, proper flow from discharge, and leaks from the associated discharge hose. The formal process of developing a work order to; test pump performance, flow rate and leaks has not been continued by the current contract operator. Formal methods of inspection, regular maintenance and documentation of these activities at this lift station should be clarified in the next update to the City’s SSMP. Operations staff reports that mechanical or electrical issues with this station are repaired by mechanical/electrical contractors hired by the City, listed in Table 4-1 on page 4-7 of the City’s SSMP.
The City SSMP states that Manholes are visually inspected on a routine basis by contracted field crews during routine sewer line cleaning. Any damage is reported and the repair or replacement of the manhole is either done immediately or added to the Capital Improvement Plan (CIP) depending on whether it is a major project or a simple repair. City manholes are treated with a residual pesticide for roaches. The residual spraying for roaches has had a significant impact on reducing customer calls. While staff reports these manhole inspections take place during line cleaning activities, there was no documented evidence of these inspection activities or CIP documentation occurring.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
The results of future sewer line cleaning and manhole inspections should be tracked and summarized. This summary should include noted flow conditions, cleaning activities and their effectiveness and any observed conditions that would warrant manhole rehabilitation or replacement. A summary of; visual and CCTV investigations, sewer line cleaning, and manhole inspection records should be included in the SSMP annually to assist in the development of future rehabilitation and replacement projects within the collection system.
Conclusion: The section above is in substantial compliance with Section D.13(iv)(b). See recommendations section below.
Finding: Section D.13(iv)(c): The City SSMP states that the City budgets $50,000 annually for rehabilitation and replacement of the sewer system. These projects are funded through the City’s sewer enterprise fund and capital budget. The 2015 SSMP does not identify a process for the identification of sewer deficiencies other than reactionary projects which are completed when discovered in the field through visual observations or unscheduled CCTV inspection. KSA has started to implement a program of CCTV inspection, reporting and evaluation in an effort to identify portions of the collection and conveyance system that require rehabilitation or replacement or that may be considered for inclusion on a longer range Capital Improvement Plan. KSA is planning to conduct CCTV on 20% of the system annually for a system wide evaluation which should be completed by 2021. This new CCTV plan and schedule should be included in the next update to the SSMP along with the results of CCTV evaluations and a plan and schedule for rehabilitation and replacement and CIP projects.
Conclusion: The section above is in substantial compliance with Section D.13(iv)(c). See recommendations section below.
Finding: Section D.13(iv)(d): The April 2015 SSMP states that all Collections Staff are certified Grade I CWEA Collection System Maintenance Workers. While these licenses are not mandatory, certification is identified in the SSMP as a method of training and demonstrating job proficiency. Currently only 2 of 5 maintenance staff are licensed. The SSMP also states that training activities will be organized in a training binder beginning in September 2015. While KSA staff report operations and maintenance training does occur for new and existing staff, no documentation of these training activities was available at the time of this audit.
Conclusion: The section above is in marginal compliance with Section D.13(iv)(d). See recommendations section below.
Finding: Section D.13(iv)(e): A list of collection system critical equipment is found in Appendix 4-I of the SSMP. A list of contractors and vendors who may be contacted for emergency parts and equipment during an emergency or during routine operations and maintenance activities is also include in Appendix 4-I. A list including additional emergency parts and equipment supplied by KSA was presented during the audit. This information should be integrated into Appendix 4-I of the SSMP.
Conclusion: The section above is in compliance with Section D.13(iv)(e). See recommendations section below.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Sufficiency: Substantial Compliance
Reference: City SSMP Rev 1: April 28, 2015 – Element 4 & Appendices, KSA Hot Spot List and Hot Spot Tracking Spreadsheet, KSA Sewer Line Cleaning Field Report, KSA Sewer Line Cleaning Tracking Spreadsheet, POSM CCTV Report and KSA CCTV Tracking Spreadsheet, KSA Updates to Critical Parts and Equipment List, KSA Staff CWEA Collection System Maintenance Certifications (Evans and Aguilar), Contract for O&M Services for City Sewer System with Kern Sanitation Authority dated June 16, 2015, 2016: Lift Station daily log.
Deficiencies: A storm water atlas is not included in the City’s SSMP. A storm water atlas would allow operations staff to quickly identify portions of the storm water system that may be impacted by a SSO. An updated program documenting the KSA O&M program and the development of Rehabilitation and Replacement Projects needs to be included in the SSMP. A critical parts and equipment list has not been updated for City including KSA critical parts and equipment. An updated formal training program and training records are not available reflecting the City’s current SSMP and O&M staff training efforts. A formal method of tracking lift station performance and scheduling preventative maintenance is not currently being implemented.
Recommendation: Sections of the O&M Program to be created and documented in the next SSMP revision include:
• Future updates to the City’s GIS Mapping System should be referenced and integrated into revisions to this SSMP. This update should include a map of the City’s storm water system.
• Update the SSMP to document the KSA program for implementing a CCTV and pipeline assessment program. Include documentation and a summary of CCTV inspection results as they occur over the course of future Fiscal Years.
• Develop a formal Rehabilitation and Replacement (R&R) plan that incorporates CCTV sewer line condition assessments and future manhole inspection data. Develop a shortand long-term CIP completion schedule based on the results of these inspections. • The results of future sewer line cleaning and manhole inspections should be tracked and included in the SSMP on an annual basis.
• Develop a maintenance and inspection schedule utilized by KSA for lift station maintenance and include in the next update to the SSMP. • The FY 2015/16 and future Budgets should be included or referenced in future revisions of the SSMP to identify pending sewer projects for this Fiscal Year. • Integrate critical parts and equipment necessary for the operation and maintenance of City assets for items provided by KSA. If mutual aid agreements exist for assistance with emergency response, they should be included in the SSMP. • Develop training procedures specific to City O&M activities and train on these procedures annually. Maintain documentation of this training. • The City must update this section to reflect the; staff, operational practices, maintenance schedules and forms of documentation utilized by Kern Sanitation Authority (KSA) in the next update to the SSMP.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
5.0 Design and Performance Provisions [SSSWDR D.13(v)]
SSSWDR D.13(v) states:
(a).Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations, and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems; and
(b).Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects.
Finding: Section D.13(v)(a-b): The City identifies applicable sections of their Municipal Code and Subdivision and Engineering Design Manual to address the requirements stated in SSWDR Section D.13(v)(a-b) in the table below:
SSMP Requirement City Code or Standard
[WDR D.13(v)(a)] Design and construction standards
of new sanitary systems, pump stations, and other
appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems
California Plumbing Code, 2010 ed. adopted by
reference
The Green Book of Standard Public Works
Construction, adopted by reference
City of Taft Municipal Code
• Chapter 3 Sewerage Construction And Use
o 3.3.3 Sewerage Construction And
Sewer Use
2011 City of Taft Subdivision & Engineering Design
Manual
• Division Two – Standards For Sanitary
Sewer
• Sec. 2.1 General
• Sec. 2.2 Design Standards
• Sec. 2.3 Material Standards
• Sec. 2.4 Construction Standards
• Sec. 2.6 Sewer Construction Plans
• Sec 2.7 Requirements For Design &
Construction Of Sanitary Sewer Lift
Stations
[WDR D.13(v)(b)] Procedures and standards for
inspecting and testing the installation of new sewers,
pumps, and other appurtenances and for
rehabilitation, and repair projects.
2011 City of Taft Subdivision & Engineering Design
Manual
• Division Two – Standards For Sanitary
Sewer
• Sec. 2.5 Final Acceptance
o 2.5.3 Testing
Table 5.1 Design and Performance Provisions
Applicable sections of the City’s Municipal Code as referenced in Table 5.1 can be found on the City of Taft website; www.cityoftaft.org
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Conclusion: The section above is in compliance with Section D.13(v)(a-b).
Element 5.0 Sufficiency: In Compliance
Reference: City SSMP, Revision 1 April 28, 2015, City of Taft Municipal Code Chapter 3, 2011 City of Taft Subdivision and Engineering Design Manual: Division 2 – Standards for Sanitary Sewer, SSMP Appendix 5-A.
Deficiencies: N/A
Recommendation: N/A
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
6.0 Overflow Emergency Response Plan (OERP) [SSSWDR D.13(vi)] SSSWDR D.13(vi) states:
Each Enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, the plan must include the following:
(a).Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner;
(b).A program to ensure appropriate response to all overflows; (c). Procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP. All SSOs shall be reported in accordance with this MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP identifies the officials who will receive immediate notification; (d).Procedures to ensure that appropriate staff and contract personnel are aware of and follow the Emergency Response Plan and are appropriately trained; (e).Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and
(f). A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated or partially treated wastewater to waters of the United States and minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge.
Finding: Section D.13 (vi)(a): The City’s SSMP provides an overview of how notification procedures are followed to ensure primary responders and regulatory agencies are informed of a SSO in a timely manner. Specific procedures related to primary response and regulatory notifications are also identified in the SSMP. The staff members/contractors identified in the SSMP that are responsible for emergency response/notification activities are out of date and should be updated to reflect current staff responsibilities and contacts. The local RWQCB contact in the event of a SSO has changed and should be updated.
Finding: Section D.13 (vi)(b): A description of the City’s SSO response Program is included in the 2015 SSMP on pages 6-2 through 6-3 which includes a flow chart identifying key personnel and their responsibilities in responding to a SSO. The information requires an update to include new staff and their responsibilities in responding to SSOs.
Finding: Section D.13 (vi)(c): A description of the current notification process is included in this section of the SSMP on pages 6-3 through 6-7. Specific procedures to ensure prompt Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
notification to appropriate regulatory agencies and other potentially affected entities are included in the body of this section of the SSMP. An additional procedure for reporting SSOs is included in Appendix 6-B however it is no longer utilized due to a change in contract operations staff. The City and KSA should establish a formal set of response procedures and integrate them into the next update to the SSMP.
Finding: Section D.13 (vi)(d): The SSMP does include specific procedures to ensure appropriate staff and contractor personnel are trained on the OERP and does discuss contract operations staff providing some emergency response training, SSO response procedures and reporting. A formal program consisting of specific emergency response procedures was not complete at the time of this the Audit. The City SSMP commits to the development of a formal SSO Emergency Response and training program by October 2015. Due to changes in contract staff over the past year this program was not developed or implemented. KSA did provide an example of SSO Emergency Response and Notification procedures that are utilized by KSA for other agencies during the City’s audit.
Finding: Section D.13 (vi)(e-f): Procedures to address emergency operations, such as emergency traffic and crowd control, surface water quality monitoring, and other necessary response activities are discussed in the 2015 SSMP. Some examples of procedures were provided by KSA contract operations staff however a formal program consisting of specific emergency response procedures was not identified during the Audit. Formal procedures that are specific to the City of Taft should be developed, adopted, and incorporated into the City’s Emergency Response Program and referenced in the SSMP. Examples of these procedures are as follows:
SS-EOP: SSO Traffic and Crowd Control
SS-EOP: SSO Volume Estimation (Reviewed during Audit) SS-EOP: SSO Mitigation and Cleanup
SS-EOP: SSO Response Documentation and Records
SS-EOP: Water Quality Monitoring Program
The City may also consider the development of additional procedures specific to the collection and conveyance system to assist in SSO response and staff training.
It is important to note that KSA staff submitted an Emergency Response Plan which is used by their agency in sewer systems throughout Kern County. Existing procedures currently in the SSMP should be reviewed by KSA staff and compared to Emergency Response procedures utilized by KSA. A final set of procedures should be developed and integrated into the City’s SSMP.
Conclusions: The sections above are in partial compliance with Sections D.13 (vi)(a-f). See recommendations below.
Element 6.0 Sufficiency: Partial Compliance
Reference: City April 28, 2015 SSMP Revision 1, Contactor (KSA) SOPs for Emergency Response to SSOs.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Deficiencies: The City committed to the development of Emergency Response Procedures and a formal training Program which was not completed and implemented at the time of this audit. A complete emergency response program with associated procedures should be developed and included as part of the SSMP. Contact information in the emergency response chain of command and notification procedures require updates to reflect current staff responsibilities and contact information. The notification and reporting overview requires updating to reflect current RWQCB staff contacts.
Recommendation: Develop a formal emergency response program with supporting SSO response procedures for incorporation into the SSMP. The combination of City (Severn Trent) and KSA Emergency Response Procedures provides much of the information required for compliance with this section. A formal set of procedures should be developed for the City’s SSMP to establish a set of uniform procedures to be utilized for SSO response in the City of Taft and for future training activities.
Train staff annually on this OERP and the associated procedures. Document all staff training.
Update each procedure and the OERP as conditions warrant.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
7.0 Fats, Oils, and Grease (FOG) Control Program [SSSWDR D.13(vii)] SSSWDR D.13(vii) states:
Each Enrollee shall evaluate its service area to determine whether a FOG control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate:
(a).An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG;
(b).A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of FOG generated within a sanitary sewer system service area;
(c). The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG;
(d).Requirements to install grease removal devices (such as traps or interceptors) and the development of design standards for such devices, maintenance requirements, BMP requirements, record keeping and reporting requirements; (e).Authority to inspect grease producing facilities, enforcement authorities, and whether the City has sufficient staff to inspect and enforce the FOG ordinance; (f). An identification of sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and (g).Development and implementation of source control measures for all sources of FOG discharged to the sewer system for each section identified in (f) above.
After the issuance of the Statewide General WDRs in 2006, the City determined that FOG is an on-going problem in the sewer collection system and a FOG Program was needed. The City identified over Fifty (50) Food Service Establishments in its service area and developed a FOG Control Program in 2010.
Finding: Section D.13(vii)(a): The City SSMP Revision 1, April 2015, page 7-2 through 7-3, presents a plan to conduct a FOG control outreach program to businesses and the residents of the City. While the City did develop the outreach materials (included as Appendix 7-A of the SSMP) there was no evidence of outreach efforts occurring at the time of this audit.
Conclusion: The section above is out of compliance with Section D.13(vii)(a). See recommendations below.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Finding: Section D.13(vii)(b): The City SSMP Revision 1, April 2015, Appendix 7-A, provides a list for Food Service Establishments (FSEs) a list of recommended FOG waste haulers for FOG generated within the City’s service area. There was no evidence provided at time of this audit to demonstrate this information was delivered to Food Service Establishments within the City limits or provided through the Public Works Department.
Conclusion: The section above is in marginal compliance with Section D.13(vii)(b).
Finding: Section D.13(vii)(c): The legal authority to prohibit discharges to the collection system and identify measures to prevent FOG-caused SSOs is located in Chapter 3 of the City Municipal Code.
Conclusion: The section above is in compliance with Section D.13(vii)(c).
Finding: Section D.13(vii)(d): The City has developed; a FOG permit application, cleaning log, Best Management Practice Manual, Inspection Form, etc. which is referred to in SSMP Revision 1, April 2015, Appendix 7-A. Grease Control Device Design, Installation, and Maintenance Requirements can be found in the City’s Municipal Code Chapter 3-3-3-1 Fats, Oils, and Grease (FOG) Control. There was no evidence at the time of this audit, to demonstrate these FOG Control Program components have been implemented or required.
Conclusion: The section above is in partial compliance with Section D.13(vii)(d).
Finding: Section D.13(vii)(e): The City Municipal Code Section 3-3-3-1,F and 3-3-2,B give the City the authority to inspect and enforce violations of its FOG Program. The City SSMP Revision 1, April 2015 on page 7-6 states that the initial roll out of a FOG Program will be limited to public outreach and education with an evaluation after the first 12 months occurring to assess effectiveness. Additional program development is proposed to take place if necessary. There was no evidence to suggest this evaluation took place in the 1st year of outreach as discussed in the SSMP. Additionally, on page 7-5 states that a FOG Permitting Program will be developed “over the next 2 years” and include permitting and inspections. There was no evidence at the time of this audit that measures to develop this program have occurred in the first year of this 2 year time schedule.
Conclusion: The section above is out of compliance with Section D.13(vii)(e).
Finding: Section D.13(vii)(f): The City SSMP, Revision 1, April 2015 identifies sections of the collection system which are subject to grease blockages. Appendix C provides a list of High Maintenance Areas (HMAs) which are cleaned quarterly as a result of FOG and other hydraulic issues.
Conclusion: The section above is in compliance with Section D.13(vii)(f).
Finding: Section D.13(vii)(g): The City SSMP Revision 1, April 2015, provides information regarding the development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each FOG induced HMA. The City provided information to demonstrate that these areas were cleaned/inspected as part of quarterly HMA cleaning however there was no evidence provided at the time of this audit demonstrating these Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
HMAs are addressed through; public outreach and education, and a commercial FOG Control Program.
Conclusion: The section above is in partial compliance with Section D.13(vii)(g).
Sufficiency: Marginal Compliance
Reference:
• SSMP Revision 1, April 28, 2015 p. 7-1 through 7-6 and Appendix 7-A; • City Municipal Code Chapter 3
• CIWQS SSO Public Report – City of Taft: Detail Page
Deficiencies: The April 2015 SSMP does not include the following:
• Examples of public outreach conducted by the City of Taft, • An assessment of initial FOG Program effectiveness which was required to occur in April 2016 to determine if a FOG Permitting and Inspection Program is warranted, • Information regarding the development and implementation of source control measures for all sources of FOG discharged into the sewer system for each FOG induced HMA, • Evidence that demonstrates sections of the City’s Municipal Code have been enforced and or source control measures have been implemented when FOG related SSOs or heavy FOG discoveries have occurred in the collection system.
Recommendation: Current CIWQS data shows that FOG has contributed to approximately 20% of the SSOs experienced by the City between 2010 and 2016. It should be noted that additional SSOs have been recorded as being caused by “debris” which may include FOG as part of the contributing factor in a SSO. The City should evaluate the current program outlined in the 2015 SSMP and determine how to address FOG Control in the future. Additional factors to consider should be; HMAs the City may experience due to FOG, PSLDs related to FOG, and other complaints from the public (if any) related to FOG. An updated FOG Control Program should be included in the next update to the SSMP.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
8.0 System Evaluation and Capacity Assurance Plan [SSSWDR D.13(viii)] SSSWDR D.13(viii) states:
The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system sections 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).Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to a SSO discharge deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, estimates of 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).Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and (c). Capacity Enhancement Measures: The steps needed to establish a short- and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. 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.
(d).Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D.14.
Findings: Section D.13(viii)(a-d): The City SSMP states the City has not experienced a dry or wet weather capacity related SSO between 2006 and 2015. Additionally, operations staff has not reported any areas of the collection system observed as capacity deficient during routine and emergency operations and maintenance activities. A review of CIWQS records and historic sewer maintenance records through March 2016 confirms there have been no capacity related SSOs or evidence of observed capacity related concerns in the system.
Additionally, the City SSMP states a plan and schedule to rehabilitate or replace areas of the collection and conveyance system will be developed for areas that are hydraulically deficient if the City begins to encounter capacity related SSOs or staff observes capacity related restrictions that may lead to a SSO.
Conclusion: The section above is in compliance with Section D.13(viii)(a-d). See recommendations below.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Sufficiency: In Compliance
Reference: City 2015 SSMP Rev 1 - April 2015, CIWQS Facility At-A Glance & Operational Reports – March 2016.
Deficiencies: None at this time.
Recommendation: Continue to monitor for areas of the sewer system that may develop capacity issues due to pipeline defects or bottlenecks which could result or contribute to SSOs.
If these areas are identified, update the SSMP to include a plan and schedule to address areas that are hydraulically restricted.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
9.0 Monitoring, Measurement, and Program Modifications [SSSWDR D.13(ix)]
SSSWDR D.13(ix) states:
The Enrollee shall:
(a).Maintain relevant information that can be used to establish and prioritize appropriate SSMP activities;
(b).Monitoring the implementation and, where appropriate, measure the effectiveness of each section of the SSMP;
(c). Assess the success of the preventative maintenance program; (d).Update program sections, as appropriate, based on monitoring or performance evaluations; and
(e).Identify and illustrate SSO trends, including: frequency, location and volume.
Finding: Section D.13(ix)(a): The City does maintain relevant information necessary to establish and prioritized SSMP activities in the SSMP and does maintain records associated with O&M activities, such as sewer cleaning records, emergency callout records, and emergency work reports. The City should implement the plan and schedule identified in this section of the SSMP to further assess the condition of the collection system and to help evaluate the effectiveness of sewer line cleaning and other maintenance activities.
Conclusion: The section above is in partial compliance with Section D.13(ix)(a). See recommendations below.
Finding: Section D.13(ix)(b) and (c): The City does not formally evaluate on an annual basis the implementation or effectiveness of each section of the SSMP or preventative maintenance activities.
Conclusion: The section above is out of compliance with Section D.13(ix)(b) and (c). See recommendations below.
Finding: Section D.13 (ix)(d): The City SSMP was revised and updated in 2015 based on the results of the 2014 SSMP Audit and for compliance with the 5-Year Update requirement identified in the SSSWDRs. There have been no formal annual monitoring or performance evaluation of each SSMP section and supporting programs as discussed in this section of the City’s SSMP.
Conclusion: The section above is in partial compliance with Section D.13 (ix)(d). See recommendations below.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Finding: Section D.13(ix)(e): The City SSMP has a framework to track the frequency, location, and cause, found in Table 9-2 on page 9-6 of the City’s SSMP. This table was not updated with information from 2015. There was no evidence that SSO trends were evaluated in these reports.
Conclusion: The section above is in partial compliance with Section D.13(ix)(e). See recommendations below.
Sufficiency: Partial Compliance
Reference: City SSMP April 2015 Revision 1, Page 8-1 to 8-2 & Appendix 9-A.
Deficiencies: The City did not implement the plan identified in their 2015 SSMP to formally evaluate and update their SSMP based on cleaning and SSO data. Additionally this section requires enrollees to evaluate the implementation or effectiveness of each SSMP Section.
Recommendation: Implement the written program to schedule, track, and evaluate the effectiveness of preventative maintenance for the sanitary sewer system. Implement the plan and schedule to review and asses the effectiveness of each SSMP section annually. Update written record of SSO trend evaluation and identification at the end of each calendar year.
Report progress in the implementation of the SSMP to the City Council as stated in the commitments found in this section of the SSMP. Complete these plans and activities and incorporate supporting documentation into the next update of this SSMP Section.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
10.0 Sewer System Management Plan Program Audit [SSSWDR D.13(x)] SSSWDR D.13(x) states:
As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee’s compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them.
Sufficiency: In Compliance
Reference: City SSMP April 28, 2015 Revision 1, Page 10-1 to 10-3 & Appendix 10-B.
Finding: The Cities 3rd SSMP Audit was due for completion on or before May 2, 2016. The City scheduled and conducted this Audit in April 2016.
Deficiencies: N/A
Recommendation: The next bi-annual audit is due prior to May 2, 2018. Schedule future SSMP Audits prior to the bi-annual date to ensure compliance with this section utilizing a format that meets the requirements found in Section D. 13 of the SSSWDRs.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
11.0 Communication Program [SSSWDR D.13(xi)]
SSSWDR D.13(i) states:
The Enrollee shall 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 Enrollee as the program is developed and implemented.
The Enrollee shall also create a plan of communications with systems that are tributary and/or satellite to the Enrollee’s sanitary sewer system.
Section D.13 (xi): The City SSMP states on page 11-1 the following communication program commitments:
o Development of outreach materials to inform the public on the “dos and don’ts of the sewer system;
o Posting of the City SSMP on the City Website www.cityoftaft.org; o Discussion of relevant SSMP activities at City Council Meetings such as SSMP Updates and SSMP Audits;
o Distribution of outreach and educational materials by November 2015 at the City Public Works Office.
At the time of this audit there was no evidence of the above mentioned communication plan efforts occurring with the exception of certification of the SSMP 5-Year Update. The City did not post the SSMP on the City website and no outreach materials were developed or distributed.
The City commits to conducting quarterly coordination meetings with the Ford City-Taft Heights Sanitation District which is satellite to the City of Taft collection system. Agendas and minutes are discussed as being provided as a record of these meetings and to identify action items from these meetings.
At the time of this audit there was no evidence of the above mentioned communication plan efforts occurring.
Sufficiency: Out of Compliance
Reference: City SSMP April 28, 2015 Revision 1, Page 11-1 to 11-2, City of Taft Regular Meeting Minutes May 5, 2015, City of Taft website: www.cityoftaft.org.
Deficiencies: City has identified satellite systems that discharge to the City sewer system and developed a plan for documenting communication that occurs with these satellite systems, however the plan was not implemented as of the date of this audit. Communication Program examples from City Council meetings for 2015 were not available during this audit. The City did not post its SSMP on the City website as is required in the State’s 2013 Monitoring and Reporting Requirements and committed to in the SSMP.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Recommendation: Develop a schedule to implement the current Communication Program that involves the City Council and members of the public in the next update to the SSMP. Keep a record of all outreach efforts and coordination as supporting documentation for this section of the SSMP. Implement the current plan in the City SSMP to communicate with satellite agencies and maintain documentation from these meetings and communications. Post the City’s SSMP and supporting documents on the City’s web site.
Sewer System Management Plan – Revision 1
Audit Report by Wallace Group
City of Taft
April 29, 2016
Records List by SSMP Section
1.0 Goals – See Records under Sections 3 - 11
2.0 Organization
a. SWRCB CIWQS Facility at a Glance City of Taft: March 13, 2016
3.0 Legal Authority
a. City of Taft Municipal Code Title 3, Chapter 3.
4.0 Operation and Maintenance Program
a. KSA Hot Spot List and Hot Spot Tracking Spreadsheet
b. KSA Sewer Line Cleaning Field Report
c. KSA Sewer Line Cleaning Tracking Spreadsheet
d. POSM CCTV Report and KSA CCTV Tracking Spreadsheet
e. KSA Updates to Critical Parts and Equipment List
f. KSA Staff CWEA Collection System Maintenance Certifications (Evans and Aguilar)
g. Contract for O&M Services for City Sewer System with Kern Sanitation Authority dated June 16, 2015
5.0 Design and Performance Standards
a. 2009 Subdivision and Engineering Standards,
b. City Municipal Code Title 3, Chapter 3
6.0 Overflow Emergency Response Plan
a. Kern Sanitation Authority Overflow Emergency Response Plan, b. Appendix 6-A through 6-B3: Contractor SOPs for Emergency Response (Severn Trent): Spill Notification/Reporting Procedure, Lift Station Emergency Procedure, SSO Volume Estimation Procedure.
7.0 Fats, Oils, and Grease Control Program
a. Appendix 7-A: List of FSEs, Permit Applications, FOG Inspection Forms, Residential Outreach Materials, FSE Outreach Materials, Grease Hauler List, b. City Municipal Code: Chapter 3,
c. CIWQS SSO Public report – City of Taft Detail Page
8.0 System Evaluation and Capacity Assurance Plan (SECAP) a. CIWQS Operational and Facility At-A Glance Reports – March 13, 2016
9.0 Monitoring, Measurement, and Program Modifications
a. SWRCB CIWQS Facility at a Glance and City Operational Report: March 13, 2016
10.0 SSMP Audits
a. 2014 City of Taft SSMP Audit and 2015 SSMP
11.0 Communication Program
a. City of Taft Website: www.cityoftaft.org
b. City of Taft Regular Meeting Minutes: May 5, 2015
Sewer System Management Plan – Revision 03
Element 11 – Communication Program
City of Taft
May 2023
APPENDIX 11-A
City of Taft
Outreach and Education Materials:
o Residential FOG Flyer
o Toilets are not Trashcans Flyer
City of Taft: Fats, Oils, and Grease Control
Program
FATS, OILS & GREASE (FOG)
What is FOG?
FOG stands for Fats, Oils, and Grease. Did you know that pouring fats, oils, and grease down the drain or garbage disposal creates obstructions in underground pipes and creates serious problems like blockages and sewer overflows? In fact, FOG is one of the leading causes of sewer overflows and blockages in the United States.
When washed down the sink, grease sticks to the insides of your sewer pipes (both on your property and in the streets). Over time, grease buildup can clog an entire pipeline, causing sewer overflows in your home and neighborhood. The damage from overflows could cost you thousands of dollars!
Here are some simple tips on how to prevent sewer
overflows.
• Do not pour cooking oil, greasy food, dairy products, or salad dressing down the drain. • Use strainers in the sink drains to catch food scraps and other solids. • Do not use hot water and soap to try to wash grease down the drain. It will eventually cool and harden in the sewer lines.
• Pour cooled grease into a disposable container, cover with a tight fitting lid and place in you r freezer. Once contents are frozen, toss in the garbage. • Mix cooking oils with absorbent material such as coffee grounds or cat litter. Place in tight lidded container and dispose of it in garbage.
• Wipe or scrape food particles from pots, pans and dishes into the trash can prior to placing them in the sink for washing.
• Wipe excess fats and grease from pans with a dry paper towel and toss it in the garbage.
Clogged Sewer Line Caused by FOG
Many household
cleaning products are
labeled and marketed
as disposable; many
baby hygiene products are labeled both
disposable and flushable. And while these
products may be marketed as a convenience item in this way, the truth is that these
household wipes and cleaning towelettes have the ability to clog and stop up not only the sewer line on your property, but also can cause blockage and service
problems in the public sewer system and pump stations. Unlike toilet paper, these products don’t break down once they are flushed. They can cause blockages in your private service lateral, especially older pipelines that may have
grease, roots, or other obstructions already existing.
A repair of the private service lateral can leave the
homeowner with a nasty
repair bill. On a larger
scale when these products make their
way into the public sewer system they
collect together and cause clogs in the
sewer main lines and get tangled in
pump stations requiring repair or replacement of equipment.
The following items
should never be
flushed into the sewer
system:
• Disinfecting wipes,
Baby wipes.
• Q-tips.
• Toilet cleaning pads.
• Mop or “Swiffer” type
refills.
• Paper towels.
• Moist towelettes.
• Any consumer item
that is not toilet paper.
City of Taft
209 E. Kern Street
Taft, CA 93268
Phone: (661) 765-4136