SR 05-23-2022 5C
City Council
Report
City Council Meeting: May 23, 2023
Agenda Item: 5.C
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To: Mayor and City Council
From: Rick Valte, Public Works Director, Public Works, Water Resources
Subject: Adoption of a Resolution Approving the City's Sewer System Management
Plan Update
Recommended Action
Staff recommends that the City Council:
1. Adopt the attached resolution approving the City’s Sewer System Management
Plan (SSMP) Update and Certifying it is consistent with Statewide General Waste
Discharge Requirements (WDRs) for Sanitary Sewer Systems.
2. Adopt a finding of Categorical Exemption pursuant to Section 15308 (Actions for
Protection of the Environment), of the California Environmental Quality Act
(CEQA) Guidelines.
Summary
The City of Santa Monica’s Water Resources Division within the Public Works
Department operates and maintains the City’s sanitary sewer system, which consists of
approximately 150 miles of sewer main, a sanitary sewer lift station (Moss Avenue
Pump Station), and 2,800 maintenance utility holes. The City is required to update its
Sewer System Management Plan (SSMP) periodically to comply with statewide Waste
Discharge Requirements (WDR) administered by the California State Water Resources
Control Board. The WDR permit requires the City to operate and maintain sanitary
sewer systems to prevent spills and to eliminate discharge of sewage into waters of the
State through effective implementation of the SSMP, among other requirements. The
Water Resources Division recently updated the City’s SSMP, which requires
recertification by City Council prior to submittal to the California State Water Resources
Control Board. Staff recommends that City Council recertify the City’s revised SSMP. By
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recertifying the SSMP, the City would reinforce its commitment to managing the sanitary
sewer system in a manner that protects public health and natural resources.
Discussion
On May 2, 2006, the California State Water Resources Control Board announced
requirements for a statewide waste discharge requirements permit (Order NO. 2006-
0003-DWQ) to regulate sanitary sewer systems. The California State Water Resources
Control Board requires public entities that own and/or operate one or more sanitary
sewer systems greater than one (1) mile in length to obtain a WDR permit for sanitary
sewer systems. The City currently holds a WDR permit for its sanitary sewer system
and the first SSMP was approved by City Council on September 8, 2009. The City’s
recently completed Sustainable Water Infrastructure Project (SWIP) is regulated under
its own WDR permit (Order No. R4-2021-0044) to produce advanced treated recycled
water for non-potable uses (e.g., irrigation and dual-plumbed buildings) and
groundwater recharge. Thus, discussion of the SWIP is not included in the SSMP.
The purpose of the SSMP is to identify necessary administrative elements to properly
schedule, manage, operate, and maintain all parts of the City’s sanitary sewer system,
to reduce and prevent sanitary sewer overflows, and to mitigate any overflow events
that do occur. In October 2022, The Water Resources Division commenced efforts to
update the City’s Sanitary Sewer Master Plan and key proposed updates include a
chain of communications for reporting sanitary sewer overflows, addition of pertinent
sections of the City’s Municipal Code (SMCC 5.20, 7.04, 7.68) to establish legal
authority for WDR compliance, response actions to overflow events, routine
maintenance activities performed by the City, and updated historical information on
overflow events in the City.
The updated SSMP must be recertified by City Council prior to it being submitted to the
California State Water Resources Control Board in May 2023.
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Environmental Review
Updating the City’s Sewer System Management Plan is categorically exempt from
CEQA pursuant to Section 15308 (Class 8 - Actions for Protection of the Environment)
of the CEQA Guidelines. Section 15308 exempts actions taken by regulatory agencies
for protection of the environment. The SSMP establishes the administrative elements
and guidelines to prevent and mitigate sewer overflow events in an effort to protect the
environment.
Past Council Actions
Meeting Date Description
09/08/09 (Attachment A) Approval of initial Sewer System Management Plan
07/26/22 (Attachment B) Award contract for Sanitary Sewer Master Plan Update
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of this
recommended action.
Prepared By: Thomas Poon, Senior Administrative Analyst
Approved
Forwarded to Council
Attachments:
A. July 26, 2022 Staff Report (Web Link)
B. September 8, 2009 Staff Report
C. Draft Sewer System Management Plan Update 2023
D. Resolution
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2023
CITY OF SANTA MONICA
SEWER SYSTEM MANAGEMENT PLAN
WDID: 4SSO10431
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CSMWRD SSMP Table of Contents
Table of Contents
Introduction .................................................................................................................................................. 1
List of Abbreviations and Acronyms ......................................................................................................... 4
Element 1 – SSMP Goals............................................................................................................................ 1-1
Element 2 – Organization .......................................................................................................................... 2-1
2.1 Organizational Structure ................................................................................................................. 2-1
Element 3 – Legal Authority ...................................................................................................................... 3-1
3.1 City of Santa Monica Municipal Code ............................................................................................. 3-1
3.2 Agreement with Satellite Agency .................................................................................................... 3-3
Element 4 – Operations and Maintenance ............................................................................................... 4-1
4.1 Collections System Maps ................................................................................................................. 4-1
4.2 Preventive Maintenance ................................................................................................................. 4-2
4.3 Rehabilitation and Repair Program ................................................................................................. 4-3
4.4 Training ............................................................................................................................................ 4-3
4.5 Equipment and Replacement Parts ................................................................................................. 4-4
Element 5 – Design and Performance ...................................................................................................... 5-1
5.1 Design Criteria for Replacement and Repair ................................................................................... 5-1
5.2 Inspection and Testing Criteria ........................................................................................................ 5-2
Element 6 – Spill Emergency Response Plan ............................................................................................ 6-1
6.1 Purpose ............................................................................................................................................ 6-1
6.2 SSO Emergency Response Plan........................................................................................................ 6-1
6.3 Goals ................................................................................................................................................ 6-5
Element 7 – Spill Emergency Response Plan ............................................................................................ 7-1
7.1 FOG Control Elements ..................................................................................................................... 7-1
7.2 Scope and Scale of FOG Problem .................................................................................................... 7-2
7.3 FOG Control Program ...................................................................................................................... 7-2
7.4 GWRD Requirements Response ...................................................................................................... 7-3
Element 8 – Capacity Assurance Plan ....................................................................................................... 8-1
8.1 System Capacity Evaluation ............................................................................................................. 8-1
8.2 Design Criteria ................................................................................................................................. 8-3
8.3 Capital Improvement Goals and Schedules ..................................................................................... 7-1
Element 9 – Monitoring, Measurement, and Program Modifications .................................................... 9-1
9.1 Performance Measures ................................................................................................................... 9-1
9.2 Monitoring and Measurement ........................................................................................................ 9-2
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CSMWRD SSMP Table of Contents
Element 10 – SSMP Program Audit ......................................................................................................... 10-1
Element 11 – Communication Program .................................................................................................. 11-1
11.1 Communication Program Discussion ........................................................................................... 11-1
11.2 Communication with Satellite Wastewater Collection Systems ................................................. 11-1
Appendix A ................................................................................................................................................A-1
Appendix B................................................................................................................................................. B-1
Appendix C ................................................................................................................................................. C-1
Appendix D ............................................................................................................................................... D-1
Appendix E ................................................................................................................................................. E-1
Appendix F ................................................................................................................................................. F-1
Appendix G ............................................................................................................................................... G-1
Appendix H ............................................................................................................................................... H-1
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Introduction
The California State Water Resources Control Board (“SWRCB”) promulgated a waste discharge
requirement (“WDR”) permit on May 2, 2006 to regulate sanitary sewer systems. This permit is known
as SWRCB Order No. 2006-0003, Statewide General Waste Discharge Requirements for Sanitary Sewer
Systems. On July 30, 2013, Attachment A to the Order was promulgated and became effective on
September 9, 2013 and is known as Attachment A, SWRCB Order No. WQO 2013-0058-EXEC, amending
the Monitoring and Reporting Program for Statewide General Waste Discharge Requirements for
Sanitary Sewer Systems (together these documents constitute the “SSS WDR”). Recently, a reissuance of
the General Order occurred to update the 16-year-old Order. Order 2022-0103-DWQ will be in effect
as of June 5, 2023. This Sewer System Management Plan (SSMP) is intended to update the City’s
existing SSMP, in continued compliance with the WDR.
System Overview
The City of Santa Monica, Department of Public Works – Water Resources Division (WRD) provides
wastewater collection services over 8.25 square miles in area and servces a resident population of
approximately 91,105 (2021). In addition to collecting sewage from parcels within its corporate
boundaries, the WRD also collects pass-through flow from the City of Los Angeles, via the Coastal
Interceptor System (CIS) and unmetered locations, and conveys (via pumps and/or gravity collection) the
sewage to the City of Los Angeles Hyperion Water Reclamation Plant for treatment and disposal.
The WRD is responsible for wastewater collection and pumping in the City, which consists of
approximately 154 miles of sewer pipe ranging in diameter from 6-inches to 72-inches, over 2,800
maintenance manholes, two flow-monitoring and sampling stations, and the Moss Avenue Pumping
Station (MAPS) that has a pump capacity of 26- million gallons per day (mgd). Sewage also enters Santa
Monica from the City of Los Angeles through one metered location and from three unmetered locations
and leaves Santa Monica for treatment at the City of Los Angeles Hyperion Water Reclamation Plant
through one metered and six unmetered locations. The City of Santa Monica’s 72-inch CIS connection to
the City of Los Angeles was designed for the development sunset year of 2090 and has a capacity of
approximately 52 mgd. The CIS is owned and maintained by the City of Los Angeles. Presently, the
maximum peak instantaneous flow approaches 32.67 mgd and the annual daily averages flow is
approximately 14.54 mgd. This flow rate includes all dry weather runoff diversions into the sanitary
sewer systems. Long-term build out (e.g., 2020 Regional Housing Needs Assessment) and populaion
density increases is evaluated through the City’s WAter and Wastewater Master Plans that is updated
every four to five years. Asthe City recognizes the importance of planning for all aspects of future
development, water and sewer capacity and demand forecasts are reviewed regularly and updated as
needed to keep abreast of changing conditions.
The WRD is also responsible for all water-related assets that support the safe treatment and distribution
of potable and recycle water within the City, as well as the collection and conveyance of all sanitary and
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stormwater, urban runoff to protect the community from sewer system overflows (SSOs), local flooding,
and protect overall water quality in Santa Monica Bay. A overview of the City’s wastewater collection
system is provided in Figure 1.
Figure 1 CSMWRD Wastewater System
Figure 1 - Overview of City of Santa Monica’s Wastewater System
A summary of the City’s wastewater collection, by size and material of construction is provided in
Table 1 and 2, respectively.
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Table 1: Gravity Sewer Size Distribution
Diameter (in)* Length (ft)* Percentage of Total Length
6 41,253.89 5.03
8 518,875.06 63.30
10 72,054.33 8.79
12 38,133.43 4.65
14 2,818.07 0.34
15 32,107.62 3.92
18 28,503.67 3.48
20 2,624.18 0.32
21 12,456.51 1.52
24 18,159.43 2.22
27 6,653.15 0.81
30 15,565.15 1.90
33 1,634.32 0.20
36 6,269.00 0.76
39 5,315.01 0.65
42 467.11 0.06
48 798.99 0.10
54 6,242.00 0.76
60 7,923.00 0.97
72 172.00 0.02
Unknown 1,659.99 0.20
Total 819,685.91 100.00
Table 2: Gravity Sewer Materials of Construction
Pipe Material* Length (ft)* Percentage of Total Length
Polyvinyl chloride (C900) 4,181.69 0.51
Polyvinyl chloride (C905) 107.00 0.01
Concrete Cast 2,118.81 0.26
Ductile Iron Pipe 820.00 0.10
High Density Polyethylene 13,524.37 1.65
Polyvinyl chloride 80,324.57 9.80
Reinforced Concrete Pipe 15,711.99 1.92
S80 640.00 0.08
Vitrified Clay Pipe 684,035.32 83.45
VYLON 16,367.20 2.00
Unknown 1,854.96 0.23
Total 819,685.91 100.00
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List of Abbreviations and Acronyms
APWA American Public Works Association
ASSFC Amalgamated Sewerage System Facilities Charge
CCTV Closed Circuit Television
CIP Capital Improvement Plan/Project
CIWQS California Integrated Water Quality System
City/CSM The City of Santa Monica
CIS Coastal Interceptor Sewer System
CMMS Computer Maintenance Management System
CSI Construction Standards Institute
CSMWRD City of Santa Monica Water Resources Division
ESRI Environmental Systems Research Institute, Inc.
FEMA Federal Emergency Management Agency
FOG Fats, Oils, and Grease
GWRD General Waste Discharge Requirements
GIS Geographical Information System
LA Los Angeles
MAPS Moss Avenue Pumping Station
MGD Million Gallons per Day
NOC Notice of Correction
NOV Notice of Violation
O&M Operations and Maintenance
OERP Overflow Emergency Response Plan
OES Office of Emergency Services
POTW Publicly Owned Treatment Works
RWQCB Regional Water Quality Control Board
SGF Sewer Generation Factor
SMMC Santa Monica Municipal Code
SMURRF Santa Monica Urban Runoff Recycling Facility
SSO Sanitary Sewer Overflow
SOP Standard Operating Procedure
SCADA Supervisory Control and Data Acquisition
SWRCB State Water Resources Control Board
WDID Waste Discharger Identification
WDR Waste Discharge Requirements
WQMP Water Quality Management Plan
WRPP Water Resources Protection Program
Yards City Maintenance Yard
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Element 1 – Goals of the SSMP
State Resources Water Control Board (SWRCB) Waste Discharge Requirement:
The purpose of the SSMP is to provide the necessary administrative elements to properly schedule,
manage, operate, and maintain all parts of the City’s sanitary sewer system in order extend the functional
life of the system and to reduce and prevent Sanitary Sewer Overflows (SSOs), as well as mitigate any
SSOs that do occur. The goals listed below support the purpose of the SSMP.
1.1 Goals
In support of this SSMP, the City has developed the following goals to properly manage, operate and
maintain its sewer system:
x Protect the City’s investment in its collection systems and prolong the operational life of the
system by performing preventative maintenance.
x Prevent public health hazards.
x Meet all applicable regulatory notification, monitoring and reporting requirements.
x Minimize the frequency and magnitude of SSOs.
x Prevent damage to public and private property that could result from SSOs.
x Ensure that funds available for sewer operations are utilized in the most efficient manner.
x Convey wastewater to treatment facilities with a minimum of infiltration, inflow and exfiltration.
x Provide adequate capacity to convey peak wastewater flows.
x Control corrosion and minimize odor release
x Perform all operations in a safe manner to avoid personal injury and property damage.
1.2 Element 1 Appendix
None
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Element 2 - ORGANIZATION
SWRCB Waste Discharge Requirement:
a. The name of the responsible or authorized representative as described in Section J of this Order.
b. The names and telephone numbers for management, administrative, and maintenance positions
responsible for implementing specific measures in the SSMP program. The SSMP must identify
lines of authority through an organization chart or similar document with a narrative
explanation; and
c. The chain of communication for reporting SSOs, from receipt of a complaint or other
information, including the person responsible for reporting SSOs to the State and Regional
Water Board and other agencies if applicable (such as County Health Officer, County
Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services
(OES)).
2.1 Organizational Structure
The organization chart for the management, operation, and maintenance of the City’s wastewater
collection system is shown in Figure A-1 of Appendix A.
Authorized Representative
The City’s Water Resources Manager, or their designee, is the legally responsible individual(s) for signing
and certifying all applicable SSMP documents. The Water Resources Manager is also responsible for
assigning staff from the division to implement the SSMP and all staff in the table below report to the
Water Resources Manager. The chain of communication for responding to and reporting SSOs is
contained Figure A-2 of Appendix A.
Table 2-1: Summary of Roles and Responsibilities within the City
Position Roles and Responsibilities
City Council Enacts Ordinances.
City Manager Is responsible for the effective operation of 12
City departments and for implementing City
Council policies and priorities.
City Public Works Director Oversees more than 430 staff members in
Architecture Services, Custodial Services,
Engineering & Street Services, Fleet
Maintenance, Facilities Maintenance, Office of
Sustainability & the Environment, Promenade
Maintenance, Public Landscape, Resource
Recovery & Recycling, Santa Monica Airport,
Water Resources, and Woodlawn Cemetery.
Public Works – Engineering Division Manages the construction phase of capital
improvement projects (streets, water, sewer,
bridges, drainage, storm drain, storm water
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quality, streetlights, traffic, and pier
infrastructure).
Water Resources Manager (LRO) Plans and directs the operation, construction,
maintenance, and repair of the wastewater
collection and conveyance system; included is
also operation and maintenance of portions of
the local storm drainage system within the city,
as well as management of the Water Resources
Protection group.
Water/Wastewater Admin Administers/manages the day-to-day operation
of the water and wastewater operation and
maintenance unit. Responsible for enforcement
of the City's industrial waste ordinances.
Wastewater Supervisor Supervises and assists in the maintenance and
repair of sewers and sewage pumping stations.
Wastewater Crew Leader Leads, schedules, trains, and participates in the
work activities of a crew engaged in installing,
repairing, and maintaining the sewer lines and
storm drain system in the City’s wastewater
system; oversees the operation of closed-circuit
television video (CCTV) and related specialized
equipment.
Wastewater Collections Worker Repairs, maintains, and installs sewer lines and
storm drains in the municipal wastewater
collection system; and performs related work as
required.
Engineering Support Services Administrator Performs a variety of complex, specialized and
professional level budgetary, analytical, and
administrative duties within the Public Works
Department. Leads, organizes, and reviews the
work of assigned staff.
Water Resources Protection Programs
Coordinator (LRO)
Develops and administers water protection,
wastewater pretreatment, and pollution
prevention programs related to storm drain and
sewer systems; plans, directs, and coordinates
the implementation of policies and programs
impacting wastewater and urban runoff.
Senior Water Resources Protection Programs
Specialist (LRO)
Implements and administers water protection,
wastewater pretreatment, and pollution
prevention programs related to storm drain and
sewer systems.
Water Resources Protection Programs Specialist
(DS)
Assists in administering water protection,
wastewater pretreatment, and pollution
prevention programs related to storm drain and
sewer systems.
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Responsibilities within the SSMP
The following staff is responsible for implementing, managing, and updating the SSMP:
Table 2-2 – SSMP Implementation Roles and Responsibilities
ELEMENT PROGRAM & POSITION Name & Email Address
Goals CSMWRD Manager Sunny Wang
Sunny.wang@santamonica.gov
Overflow Emergency
Response
CSMWRD WRPP &
W/WW Administrator
George Rodriguez
George.rodriguez@santamonica.gov
Fats, roots, oils and grease CSMWRD WRPP &
W/WW Administrator
George Rodriguez
George.rodriguez@santamonica.gov
Measures & Activities: W/WW Administrator Ralph Valencia –
Ralph.valencia@santamonica.gov
Maps GIS Section Neda Peiravian
Neda.peiravian@santamonica.gov
Resources and Budgets Principal Public Works
Analyst
Thomas Poon
Thomas.poon@santamonica.gov
Preventive Operations &
Maintenance
W/WW Administrator
and Water Resources
Engineer
Ralph Valencia
Ralph.valencia@santamonica.gov
Rehabilitation and
Replacement (Inspection
and Condition Assessment)
W/WW Administrator
and Water Resources
Engineer
Ralph Valencia
Ralph.valencia@santamonica.gov
Contingency Equipment &
Replacement Parts
W/WW Administrator Ralph Valencia
Ralph.valencia@santamonica.gov
Training CSMWRD WRPP &
W/WW Administrator
George Rodriguez
George.rodriguez@santamonica.gov
Outreach CSMWRD WRPP George Rodriguez
George.rodriguez@santamonica.gov
Design and Construction
Standards
Water Resources Engineer
Capacity Management Water Resources Engineer
Monitoring Plan for SSMP CSMWRD Manager Sunny Wang
Sunny.wang@santamonica.gov
Audits for SSMP CSMWRD Manager Sunny Wang
Sunny.wang@santamonica.gov
Communications Program CSMWRD Manager Sunny Wang
Sunny.wang@santamonica.gov
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2.3 Element 2 Appendix A
Supporting information for Element 2 is included in Appendix A. This appendix includes the following
documents:
x Figure A-1 Organizational Chart of Wastewater Utility Staff
x Figure A-2 Chain of Communication for responding to and reporting SSOs.
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Element 3 – Legal Authority
SWRCB Requirements:
Each enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or
other legally binding procedures, that it possesses the necessary legal authority to:
a. Prevent illicit discharges into its sanitary sewer system (examples may include infiltration and
inflow, storm water, chemical dumping, unauthorized debris and cut roots, etc…);
b. Require that sewers and connections be properly designed and constructed;
c. Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or
maintained by the Public Agency;
d. Limit the discharge of fats, oils, and grease and other debris that may cause blockages, and
e. Enforce any violation of its sewer ordinances.
3.1 City of Santa Monica Municipal Code
The City of Santa Monica Municipal Code (SMMC) is available online
(https://library.qcode.us/lib/santa_monica_ca/pub/municipal_code) and describes the City’s current
legal authority to comply with Waste Discharge Requirements (WDRs). More specifically, authority is
contained in Article 5 Sanitation and Health and Article 7 Public Works; authority is more generally
contained in other SMMC Chapters listed in Table 3-1.
Table 3-1: Summary of Legal Authorities in Santa Monica Municipal Code
Requirement SMMC Reference
Prevent Illicit Discharges
Prevent unlawful discharges into its
sanitary sewer system.
5.20.010
Limit the discharge of fats, oils, and grease
and other debris that may cause blockages
5.20.040(a)(4)(7), 5.20.090, 5.20.110,
Control infiltration and inflow (I/I) from
private service laterals.
7.68.160 Standards for utilities.
Proper Design and Construction
Require that sewers and connections be
properly designed and constructed
7.04.480, 7.04.490, 7.04.520;
Chapter 8.12 –Building Code (California Building
Code, International Building Code )
Chapter 8.32 –Plumbing Code (California Plumbing
Code and Uniform Plumbing Code)
Ensure access for maintenance, inspection,
or repairs for portions of the lateral owned
or maintained by the Public Agency
7.04.620 Investigations on private property
Fog Source Control
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WRD SSMP Legal Authority Element 3 Page 3-2
Requirement SMMC Reference
Requirements to install grease removal
devices (such as traps and grease
interceptors)
5.20.080 Additional pretreatment measures
Design standards for the grease removal
devices
5.20.080 Additional pretreatment measures
Maintenance requirements, BMP
requirements, record keeping and
reporting requirements for grease removal
devices
5.20.310 Periodic compliance reports
Authority to inspect grease producing
facilities
5.20.430 Inspection and sampling
Enforcement
Enforce any violation of its sewer
ordinances
5.20.490 – 5.20.620
3.2 Agreement with Satellite Agency
The City of Santa Monica does not have a large enough treatment plant to treat all of the wastewater
generated in the city. For this reason, there is an agreement with the City of Los Angeles to accept
wastewater from Santa Monica. The City of Los Angeles charges Santa Monica based on the amount
and strength of flow that is sent to the Hyperion Water Reclamation Plant for final treatment and
disposal. These measurements are taken at two outfalls just at the entrance of Santa Monica city limits
and right before flow leaves the city.
The City of Los Angeles has tributary areas that combine with sewage from the City of Santa Monica.
These tributaries feed into six different locations around Santa Monica that eventually pass through
back into the LA sewer system. The largest amount of pass through comes via the Coastal Interceptor
System (CIS) which transports flow from areas upstream of Santa Monica’s service area.
3.3 Element 3 Appendix B
1. Agreement for Sewer Treatment Service with City of Los Angeles
2. Sewer Lateral Maintenance Outreach
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ELEMENT 4 - OPERATIONS AND MAINTENANCE (O & M) PROGRAM
SWRCB Requirement:
The SSMP must include those elements 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 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 rehabilitation and replacement plan to identify 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 for the capital improvement
plan;
d. Provide training on a regular basis for staff in sanitary sewer system operations, maintenance,
and require contractors to be appropriately trained; and
e. Provide equipment and replacement part inventories, including identification of critical
replacement parts.
4.1 Collection System Maps
The WRD ESRI-GIS database was initially based upon as-built record drawings and was limited to
horizontal data. As time progressed, more field information (e.g., elevation and pipe slope) is added to
the GIS database. Linear assets older than 75 years usually have limited construction data and the
record as-built drawings associated with the assets provide the best engineering data. As the WRD’s
asset management plan grows, more information is incorporated including vertical pipe invert and soffit
elevations, manhole rim elevations and pipe segment slopes. The database is continuously growing and
is also tied to the WRD’s maintenance management system.
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The City also has limited copies of its older (1960) sewer atlas, which provides some additional data, and
can be used to find appropriate as-built drawings. The last update of the sewer atlas occurred in 2000, at
which time the City switched to the current GIS system.
As-built drawings are on file at the City’s Department of Public Works – Engineering Division. The
Engineering Division is also responsible for the construction of the collection system assets. The City is
in the process of incorporating these drawings into the GIS format as funding and resources allows.
Collections system maps are revised as necessary when discrepancies are discovered in the field.
Wastewater crew relay the changes to the supervisor who then passes the information to the
Engineering division for revision in the GIS system. Field crews are equipped with hard copies of the
maps, tablets for digital access, and access to the Hansen database for work order observations.
4.2 Preventative Maintenance
The elements of the City’s sewer system operation and maintenance (O&M) program include:
x Preventative and corrective maintenance;
x Closed Circuit Television (CCTV) inspections in order to evaluate the condition of the gravity
sewers;
x Routine sewer jetting to maintain gravity flow and minimize SSOs;
x Replacement and repair of sewers that are in poor condition.
4.2.1 Computer Maintenance Management Systems (CMMS)
To plan and track O&M activities, the City utilizes a computerized maintenance management system
(CMMS). The CMMS (Hansen) is capable of tracking equipment and staff by work orders, assisting in the
planning and prioritizing of O &M work based on past activity, and maintaining accurate work order and
other maintenance documentation used in collection system analysis and reporting. The CMMS is also
GIS compatible. The CMMS is the central location for asset history, work orders, and labor hours. The
WRD is currently replacing the Hansen CMMS system with a new, modern system provided by
MentorAPM that would increase functionality, including tracking vertical assets, asset age, performance,
and criticality impacts.
4.2.2 Gravity Sewers
The Wastewater team clean all City-owned sewer pipes between 4-72 inches in diameter. The schedule
of cleaning can be every 2 months, 4 months, 6 months, yearly, and every 3-5 years, depending on the
condition of the line, operating history, and service area characteristics. The priority is to clean those
lines that have a history of blockage or SSOs. Portions of the collection system with repeated SSOs are
evaluated for immediate replacement or prioritization as part of the City’s Capital Improvement
Program (CIP), depending on the specific conditions present in the line.
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The Wastewater team utilizes a hydro jetting truck and combo unit trucks to flush and jet sewer lines.
One complete video-capable truck is available for immediate deployment 24 hours per day, and routine
main jetting is conducted 5 days a week.
High frequency cleaning occurs in those areas that are known to have many food service establishments
(FSEs) that generate FOG and those areas that are known to suffer from persistent root intrusion. These
areas are maintained every 2-4 months. Lines that are larger than 15 inches are scheduled to be cleaned
at least biennially.
Historical line cleaning results are provided in Table 4-1. Line connections and manholes are inspected at
the time of cleaning. Any issues noted during the inspection are scheduled for repair. Either the City or a
hired contractor conducts any repairs.
Table 4-1: Historical Line Cleaning Results
Year Line Cleaning, Miles Line Cleaning, Feet Total Lines Inspected, Miles
2010 195.5 1,032,240 2.1
2011 195.5 1,032,240 2.1
2012 370.2 1,954,656 15.4
2013 436.3 2,303,664 3.3
2014 436.3 2,303,664 3.3
2015 327.6 1,729,728 3.2
2016 461.1 2,434,608 9.2
2017 292.8 1,545,984 13.2
2018 292.8 1,545,984 13.2
2019 396.7 2,094,576 11.2
2020 396.7 2,094,576 11.2
2021 396.7 2,094,576 11.2
2022 415.9 2,195,952 9.04
2023 293 1,547,040 9.04
4.2.3 Closed Circuit Television (CCTV) Inspections
The City conducts system-wide routine preventative maintenance activities, including closed circuit
television (CCTV) reconnaissance of its collection system, utilizing experienced dedicated O &M staff to
ensure efficient and reliable operation of the various components of the sewer system.
One complete video-capable truck is available for immediate deployment 24 hours per day, and routine
main jetting is conducted 5 days a week. The priority is to clean those lines that have a history of
blockage or SSOs. Portions of the collection system with repeated SSOs are evaluated for immediate
replacement or prioritization as part of the City’s CIP, depending on the specific conditions present.
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The City previously utilized WinCam software for facilitating CCTV activities. Presently, Granite Net will
be the new provider for the City’s CCTV program. The City anticipates being able to CCTV every line in
the service area within 3-5 years.
4.3 Rehabilitation and Replacement Program
The City has a long-term program to rehabilitate and replace lines in the system that may be deficient.
The program has prioritized portions of the sewer system that have persistent issues, older line segments,
and upsizing lines that are 6 inches. This work is included in the City’s CIP process. CIPs are approved
biannually. On average, the City replaces 1-2 miles of sewer pipes each year.
4.4 Training
The City encourages, and requires staff, to obtain professional certifications or licenses (e.g., California
Water Environment Association). WRD staff receives training on a regular basis in sewer system O&M
developments and techniques, and in work safety topics. In addition, many WRD staff maintains various
professional certifications through related continuing education or professional participation credits.
Confined space training
4.5 Equipment and Replacement Parts
Critical equipment and replacement part inventories are maintained at the City Maintenance Yard (Yards)
Complex, located at 2500 Michigan Avenue in Santa Monica. Mechanical equipment and WRD trucks and
support vehicles are fueled, serviced and repaired at the Yards, and many of the administrative functions
related to the collection system are also housed in this central location.
4.6 Element 4 Appendix C
Supporting information for Element 4 is included in Appendix C. This appendix includes the following
documents:
1. Map of Santa Monica Sewer Service Area
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Element 5 – Design and Performance
SWRCB Waste Discharge Requirement:
a. Design and construction standards and specifications for the installation of new sanitary sewer
systems, lift 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.
5.1 Design Criteria for Installation, Replacement, and Repair
Sanitary sewer system design standards, Standard Specifications, and Standard Plans are maintained by
the Civil Engineering Division of the Public Works Department. These plans extend to sewer mainlines,
structures, structures and appurtenances like manholes, lift stations, and service laterals.
5.1.1 General
The City has standards established for new construction, replacement, and renewal regarding any work
on the collections system. There is a periodic review of these standards by the Engineering Division. The
last update was done in 2021. The most up-to-date version of Standards is available at the City website.
Please see the link below.
Specifications subject to inspection during construction are Construction Standards Institute (CSI) based
and are modified as applicable by the Standard Specifications for Public Works Construction
(GREENBOOK), latest edition, which is jointly produced by representatives of the American Public Works
Association (APWA), the Associated General Contractors of California, the Engineering Contractors
Association, the Southern California Contractors Association and BNi Publications, Inc.
Complete versions of the City’s Standards Specifications and Standard Plans are located at the City
website. Please click through to:
https://www.santamonica.gov/standard-detail-and-specifications
5.1.2 Moss Avenue Pump Station
MAPS is a sewer pump station owned by the City. MAPS is a critical component of the Coastal Interceptor
System (CIS), which moves sewage along the coast from northern Los Angeles, through Santa Monica, and
eventually to the Hyperion Treatment Plant. MAPS is the City’s single most critical sewer utility asset as it
is in very close proximity to the Santa Monica Pier.
The pump station is equipped with two discharge force mains. To-date, this pump station has
predominantly used a single force main for all discharge. Utilizing both force mains, MAPS’ firm capacity
(three duty pumps running) has been field measured at 27.6 MGD discharging through a dual force main
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configuration. The maximum capacity (four pumps running) has been field measured as 36.9 MGD
discharging through dual force mains as per the MAPS Evaluation Report 2015.
Detailed information for the MAPS, junction boxes, gauging stations and siphons was obtained from
Operations and Maintenance and As-Built Drawings.
5.1.3 Authorized Pipe Materials
The City currently requires polyvinyl chloride pipe as the standard for authorized pipe material.
Specifically, PVC SDR-26 is the type called out for usage in the City. For any pipe lining, cured-in-place-pipe
(CIPP) is required.
5.1.4 Private Sewer Systems and Laterals
All private sewer systems and private sewer laterals are required to be design, installed, inspected and
accepted per the Green Book and the City Adaptations to the Green Book. Private sewer laterals must
also conform to the requirements of the California Plumbing Code.
5.2 Inspection and Testing Criteria
Wastewater construction inspection and testing criteria is based on the Green Book. Standards and
specifications are reviewed before any job is put out to bid. Any additional technical requirements will be
called out and added to any specific construction project. This criteria applies to new and rehabilitated
gravity sewers and new and rehabilitated manholes.
These standards, which are based on Standard Specifications for Public Works Construction, are updated
as required by CSMWRD staff and are made available to the public by the Civil Engineering Division upon
request so that all engineering contractors and civil engineers are aware of the CSMWRD’s standards for
wastewater construction. Presently, City wastewater projects are designed by the Civil Engineering
Division within the City, and each project’s contract documents contain all wastewater specification
standards, construction notes and details for the project. They are modified to be site-specific on a
project-by-project basis. Contract documents are prepared in-house using consultant civil engineers for
the plans and technical specifications.
Typically, because of historic development within the City, there are unique construction challenges
presented by interfering utilities and confined rights-of-way, which require site or project specific
modifications to existing standards. In those cases, the City usually depends upon construction applicants’
private engineers to modify or design a new standard and will review and approve it for site-specific
construction.
5.3 Element 5 Appendix
None
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Element 6 Spill Emergency Response Plan
SWRCB Requirements:
a. Each Enrollee shall develop and implement an Spill Emergency Response Plan (SERP) that
identifies measures to protect public health and the environment. At a minimum, this plan must
include the following:
b. Proper notification procedures so that the primary responders and regulatory agencies are
informed of all SSOs in a timely manner;
c. A program to ensure an appropriate response to all overflows;
d. 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 Monitoring and Reporting Program (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 should identify the officials who will receive
immediate notification;
e. Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the
Emergency Response Plan and are appropriately trained;
f. Procedures to address emergency operations, such as traffic and crowd control and other
necessary response activities; and
g. A program to ensure that all reasonable steps are taken to contain and prevent the discharge of
untreated and partially treated wastewater to waters of the United States and to 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.
6.1 Purpose
The City’s SERP serves as a guide for efficiently and appropriately responding to sewer spills. The SERP
has directions for staff to follow regarding response, cleanup, and reporting of any sewer spills in the
City’s service area.
6.2 Sanitary Sewer Overflow Emergency Response Plan
An SSO is any overflow, spill, release, discharge, or uncontrolled diversion of untreated or partially treated
wastewater from a sanitary sewer. SSOs may contain high levels of suspended solids, pathogenic
organisms, toxic pollutants, nutrients and oil and grease and can adversely impact human health and the
environment. In order to minimize the potential for health and environmental impacts, the City has
developed the following plan and standard operation procedure (SOP) for responding to all SSOs.
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SSO Emergency Response Plan:
City water resources and inspection staff have been trained to respond promptly upon receiving
notification of an uncontrolled sewage discharge. An SSO can originate from residential structures,
commercial facilities, or City related devices, (e.g., broken sewer lines, and/ or manhole covers). Time is
of the essence in responding to SSO incidents to control and reduce the potential for impact to the storm
drain system and waters of the State.
The SSO plan involves two basic steps.
Step# 1- Upon notification, City Wastewater staff (both Operations and Water Resources
Protection Program (WRPP) inspector) responds and identifies the location of the overflow and
its characteristics (i.e., apparent source, volume released, extent, and whether it is on private
property etc.). They also determine the potential cause of the SSO and the responsible party. This
information is recorded on the SSO Response Form. To ensure containment, CSM Wastewater
Staff locate the nearest down gradient (down slope) storm drain and determine if the release has,
or will, reach this drain. Based on site conditions, the onsite incident manager decides if
immediate action or additional staff or equipment is needed to prevent the release from reaching
this drain. If the SSO occurred because of a blockage at a main City sewer line, the onsite incident
manager will direct CSM Wastewater Staff to immediately contain the discharge by completely
berming the storm drain inlet and to clear the blockage. Once the nature and extent of the
discharge are known, staff will begin immediate cleanup of discharges caused by a city-owned
pipeline; typically by vacuuming the discharge for lawful disposal.
Staff also ensures the release area (all public areas) are cleaned and disinfected after the normal
sewer flow is restored and the blockage relieved. If the release has reached the storm drain
system, staff will routinely check a couple of storm drain catch basins downstream from the
contaminated catch basin to verify how far the release has traveled down the storm drain line.
Depending on the severity of the release, samples may be required to be taken from those catch
basins and analyzed for pathogenic organisms. Sampling, if any, conforms to steps taken in the
City’s Water Quality Management Plan (WQMP).
If a release from a City-owned main has visibly impacted private property, the onsite staff will
photo document all such impacts identified at the time of the release response. Staff also
documents the contact information of the property owner and any notes regarding the potential
impact in their field notebook. Questions regarding repair costs are directed to the CSM Office
of Risk Management at (310) 458-8910.
Step # 2- If the SSO occurred because of a blockage or other problems within a privately owned
lateral line resulting in a discharge to the ground surface and /or into the public right-of-way such
as City streets, alleys or sidewalks, CSM Wastewater staff will contain and prevent further
discharges into the Public Right- of- Way as described in Step #1, above. This is typically done by
using a City vacuum truck. CSM staff then contact the subject property owner/manager and direct
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them to immediately contact a private plumber to relieve the sewer blockage. In instances where
there is no effective response from the property owner or manager to abate the SSO within a
reasonable time frame (less than an hour), or at the discretion of the onsite incident manger or
the WRPP Inspector, the water service may be temporarily turned off at the subject property after
proper notifications are made by calling the CSM Water Division staff and requesting a temporary
water service disruption.
Before attempting to turn off the water service, CSM Wastewater Staff will try to contact the
property owner or manager. Wastewater Operations Staff will make notification if a WRPP
Inspector is unavailable (i.e., after hours, weekends). Notification is made verbally and by posting
a large placard in a common area and a door hanger on each unit or residence/ business. Each
placard and door hanger has contact information for the CSM and the Los Angeles County DHS
Public Health. If possible, door hanger notifications are placed on each tenant’s door depending
on access.
Note: The duration, and therefore volume, of the SSO discharge is estimated from when the SSO
is first reported to the City, NOT when staff arrives to the site. Staff are required to accurately
estimate the volume of the discharge and note how the estimate was derived in their field book.
Photographs of the SSO site are also included in the incident file when damage to private property
is known to have occurred.
Other agency contact/reporting include:
- Office of Emergency Services (OES) at (800) 852-7550 to obtain an OES Control#. After
business hours including weekends, CSM Wastewater staff makes the notification to OES and
provides WRPP inspection staff with the OES Control #.
For logistics planning, staff has determined it typically takes 45-60 minutes for a private plumber
to arrive and/ or relieve the sewer blockage on private property. Prior to the arrival of the plumber
if the water is not shut down, City staff ensure that the property owner makes all efforts to contain
sewer discharges on their property and not allow any discharges onto the public right-of-way.
Any discharge that reaches the public right-of-way will be contained by City staff.
Wastewater Staff monitor the SSO site continuously to make sure the plumbing problem is
corrected and sewage at the site has been cleaned up and the release area is disinfected.
Wastewater Operations Staff will disinfect the impacted street and sidewalk (public areas)
immediately in contact with the release using chlorine/water solution. Large discharges from
private property requiring clean-up will be billed to the property owner for cost recovery of labor
and equipment use. Once the sewer blockage is cleared, and the contaminated area cleaned and
disinfected, the property owner/manager may call and request the Water Division to turn the
water service back on, if needed.
If there is an extensive damage to privately owned properties because of an overflow and release
of sewage due to a SSO, depending on the cause, staff will call or advise the property owner to
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directly contact LA County Dept. of Health Services (DHS) at 310-665-8484 to evaluate the health
hazard and recommend detailed procedures for proper clean-up. Staff will also contact the CSM
Office of Risk Management to evaluate any damages if the SSO is caused by blockages or flow
conditions within the publicly owned portion of a sanitary sewer system.
It is important to remember that spills into the City storm drain system from SSO’s typically are
captured by one of the City diversion BMP projects such as SMURFF, Wilshire Blvd., Montana Ave.,
Rose Ave., Ashland Ave., Sunset-Canyon and Centinela-Pearl projects and therefore normally do
not reach Santa Monica Bay as long as those diversion projects are operational at the time of the
incident. Staff will confirm the operational status of the subject BMP project as part of the SSO
response procedures.
Once the SSO response incident is concluded, WRPP Inspection Staff forward the required data to
the California Integrated Water Quality System (CIWQS) by visiting the agency database at:
http://ciwqs.waterboards.ca.gov and entering on-line the requested information about the SSO.
WRPP Inspection Staff also retain a copy of all completed reports about an SSO incident in a folder
designated for SSO records.
SSO Equipment and Training
Typical equipment required for response to an SSO, depending on location and size of the release,
includes, but is not limited to, personal protective gear, reporting forms, traffic control devices such as
cones or barricades, absorbent materials, sampling equipment, disinfectant solutions, pipe snake, vacuum
trucks, backhoe, replacement pipe, and street sweepers.
The City conducts regular training to familiarize staff with health and safety issues, standard response
procedures, and regulatory and technological developments. The City also encourages staff to
recommend more efficient ways of completing work tasks based on staff field experience.
Moss Avenue Pump Station (MAPS) Emergency Response
CSM staff monitors MAPS through SCADA alarm system during and after hours. Upon discovery or
notification of an SSO at the facility, staff would respond to the MAPS to make necessary SSO assessment.
Staff would check the generator, wet well operation, pumps, and force mains. For SSOs that occur because
of MAPS or force mains, notifications to proper regulatory agencies and response procedures apply that
are discussed as part of this SOP.
Specific procedures include:
Wet Well
x Observe SCADA screen and PLC panel to confirm proper wet well level
x If SCADA and PLC not operational, emergency notification to Plant Operator, Supervisor and
Senior WRD staff and SCADA technician.
x Call emergency pump contractor for emergency pump/bypass equipment set-up at facility.
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x Call emergency clean-up/truck pumping services vendor.
x Inspect upstream manholes for SSOs.
x Notify SMPD, SMFD, and Cal Trans.
Force Main Pumps
x Observe SCADA screen, PLC panel, and VFD to verify proper operation.
x Identify pumps not working.
x If plugged, remove obstruction, test and put pump back into service.
x Call emergency pump contractor for technical and operational assistance, if required.
Force Main Pipeline
x Inspect force main manifolds in pump room, above ground force mains, and in ground segments
leading Seaview Terrace terminus.
x Isolate force main if damaged; turn off pumps associated with force main.
x Call emergency clean-up/truck
6.3 Goals
x Protect public health and the environment.
x Achieve timely responses to any spills.
x Minimize and prevent any adverse impacts on the public and the environment.
x Mitigate any adverse impacts.
Emergency Contacts:
SCADA Systems Analyst – Tim Vosecky – (310)-487-3197
CSM ISD Joseph Contreras- (310) 458-2261
CSM Engineer – Vacant (310) 458-8286
CSM Engineer – Selim Erin – (310) 437-9898 (Cell)
Emergency Generator/Pump Vendor – Xylem, Godwin – Nate Warren (310)-830-3636
Emergency Cleanup/Truck Pumping Services Vendors
x Clean Earth- Shaun Russel (310)- 415-0247
Pump Contractor – Mike Woodward (Pumpman) – (626) 664-9078 (Cell), (626) 939-0300
Electrical Contractor- Darren Roesh (LEED Electric) – (626) 692-3330
Water Treatment Plant Supervisor (Arcadia) – Gary Richinick (213)709-1888 (Cell)
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Water Resources Division Standby – (310) 628-9378 (Cell)
Wastewater Supervisor – Danny Gomez – (310) 629-9436 (Cell)
Wastewater Plant Operator – Jeff Grooms – (310) 883-8350 (Cell)
Wastewater Plant Operator- Joe Felix – (310) 877-5338 (Cell)
Water Resources Manager – Sunny Wang – (424) 330-9636
WRPP Coordinator – George Rodriguez – (310) 901-7069
6.4 Element 6 Appendix D
1. City of Santa Monica Overflow Emergency Response Plan
2. City of Santa Monica Water Quality Management Plan
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WRD SSMP Fats, Oils, And Grease (FOG) Control Program Element 7 Page 7-1
Element 7 – Fats, Oils, and Grease (FOG) Control Program
SWRCB Requirements:
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), design standards
for the removal devices, maintenance requirements, BMP requirements, record keeping and
reporting requirements;
e. Authority to inspect grease producing facilities, enforcement authorities, and whether the
Enrollee has sufficient staff to inspect and enforce the FOG ordinance;
f. An identification of sanitary 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 sanitary sewer system for each section identified in (f) above.
7.1 FOG Control Elements
The City’s FOG source control program, managed by the WRD, includes the following elements:
x A public education outreach program that promotes proper disposal of FOG;
x The legal authority to issue permits, prohibit discharges to the system (article 5.20.040 (a)(16)
SMMC) and identify measures to prevent SSOs and blockages caused by FOG;
x Requirements (article 5.20.080 SMMC ) to install grease removal devices (such as traps or
interceptors) design standards for the grease removal devices, maintenance requirements, BMP
requirements, record keeping and reporting requirements;
x Authority to inspect grease producing facilities and enforce requirements (article 5.20.500
SMMC);
x Operations and Maintenance and operations (O& M) procedures which assist in the
identification of sewer system sections subject to FOG blockages, based on operational history
and inspection, and;
x Other source control measures, as appropriate, for all sources of FOG discharged to the sewer
system.
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7.2 Scope and Scale of FOG Problem
Table 7-1 lists all of the FOG-related mainline SSOs that the City had between 2007 and 2022. As of
March 2023, the City has experienced only two FOG-related SSOs in the last five year.
Table 7-1: Historical FOG-related SSOs in Mainlines
Calendar Year SSOs caused by FOG
2022 0
2021 0
2020 1
2019 0
2018 0
2017 2
2016 0
2015 0
2014 0
2013 1
2012 1
2011 3
2010 1
2009 2
2008 7
2007 0
7.3 FOG Control Program
The City has determined that a FOG control program is necessary per SSMP requirements. There are
approximately 474 food service facilities located within City limits and discharge to City sewers.
Operations and maintenance staff have also noted the tendency for grease buildup in specific sewer
lines due to proximity to sources or hydraulic conditions. This section discusses measures the City takes
to control FOG.
The City’s FOG control program consists of focused cleaning and maintenance as well as source control.
The following subsections discuss identification and cleaning of grease-prone areas, legal authority to
prohibit grease discharge or require a grease removal device, facility inspection, and public outreach.
Water Resources Protection Program and Source Control
The City of Santa Monica Water Resources Protection Program (WRPP) facilitates the FOG Source
Control Program and ensures compliance with federal, state, and local regulations for wastewater pre-
treatment standards prior to discharge into the City’s wastewater collection system. WRPP Staff
oversees all industrial and business customers that have the potential to adversely affect the CSM
wastewater system by the issuance of Industrial Wastewater permits every year, inspections, and
applicable unannounced sampling events for approximately 870 businesses requiring pre-treatment
and/or regular monitoring for toxic substances, such as inorganic toxic substances, such as acids &
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metals, fats from grease and oil producing food-related operations, and other oil and grease producing
operations, such as automotive uses, prior to connection and discharge to the wastewater system. For
FOG control, there are 474 permittees subject to inspection. For instances of non-compliance with
sewer limitations and prohibited discharge standards as specified in the Santa Monica Municipal Code,
the WRPP relies on various escalating enforcement actions such as the issuance of Notices of Correction
(NOC), Notices of Violation (NOV), administrative citations, and referral to the City Attorney’s office for
prosecution. Every permittee inspection is stored in a Hansen 8 computer database as well as a hard
copy file. WRPP is also in constant contact with CSM Wastewater staff about any significant findings in
the collections system. The WRPP also advises residential customers through outreach information and
in tandem with the City’s Household Hazardous Waste Program, the proper disposal methods for toxic
materials (such as mercury), waste cooking oil, and other household hazardous waste. In addition, the
WRPP has distributed education material on the importance of preventing FOG from entering the
sanitary sewer system and brochures on roots and how they adversely affect the wastewater system to
the residents of Santa Monica. This information is also distributed to residents at the City of Santa
Monica Festival, which is held yearly.
The City also requires the installation of pretreatment devices such as clarifier and grease interceptors
for new and remodeled facilities and requires pretreatment devices to be installed in other older
facilities that have caused SSOs.
The City also has an annual inspection and random sampling program and keeps records of all permits
with proof of regular maintenance of all pretreatment devices by the permit holder.
Wastewater Operations Program
The Wastewater Operations Staff is responsible for the cleaning, monitoring and maintenance of the
City’s wastewater collection system. Maintenance consists of four (4) full-time crews, five to six days a
week jetting and cleaning the local collection system and the CIS. Wastewater Operations also
maintains the City’s Moss Avenue Pumping Station (MAPS), end of line diversions into the sewer system.
The City completed replacing and/or lining 80% of its sewer mains and manholes in 2002. Areas of
concern based previous experience are tracked on the City GIS system and are cleaned more frequently.
Together with the CSM Civil Engineering & Architecture Division problem-prone pipelines having both
structural and flow capacity issues are prioritized for replacement to minimize the potential for serious
SSO incidents.
7.4 GWRD Requirements Response
Requirement (a): An implementation plan and schedule for a public education outreach program that
promotes proper disposal of FOG.
Response: The City regulates FOG through WRPP’s Source Control Program and with regular, proactive
sewer cleaning. Areas that have a high density of FSEs tend to have higher cleaning frequencies. FSEs are
also inspected routinely by WRPP. Finally, public outreach regarding FOG issues is provided for
businesses as well as the general public.
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Requirement (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.
Response: There are grease disposal sites available in Los Angeles County that accept spent grease from
nearby commercial disposal companies. The City provides FSEs with a vendor list of California
Registered Inedible Kitchen Grease Commercial Transporters. No vendor is recommended or preferred
by the City.
Requirement (c):The legal authority to prohibit discharges to the system and identify measures to
prevent SSOs and blockages caused by FOG
Response: Santa Monica Municipal Code provides the legal basis for the City’s Source and FOG control
program. This is noted in Element 3. More specifically, SMMC 5.20.110 provides requirements for grease
disposal and FSE BMPs. SMMC 5.20.080 provides requirements for grease interceptor installation.
Requirement (d): Requirements to install grease removal devices (such as traps or interceptors),
design standards for the removal devices, maintenance requirements, BMP requirements, record
keeping and reporting requirements.
Response: The City’s WRPP team meets this requirement as described in Requirement (c). Also, WRPP
observes FSE BMPs and record keeping during routine inspections.
Requirement (e): Authority to inspect grease producing facilities, enforcement authorities, and
whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance.
Response: WRPP conducts regular inspections of FSEs and is granted authority to inspect and enforce via
SMMC 5.20.
Requirement (f): An identification of sanitary sewer system sections subject to FOG blockages and
establishment of a cleaning maintenance schedule for each section
Response: The City’s Wastewater team prioritizes areas of high FSE concentration and areas where
there may be high FOG discharger for more frequent cleaning of connected sewer lines. Wastewater is
flexible and will tend to any area that may have become problematic.
Requirement (g): Development and implementation of source control measures for all sources of FOG
discharged to the sanitary sewer system for each section identified in (f) above.
Response: Similar to the response to (f), WRPP supports the Wastewater team and follows up on those
FSEs that are discharging significant amount of FOG.
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7.2 Element Appendix E
Supporting information for Element 7 is included in Appendix E. This appendix includes the following
documents:
1. Example Restaurant Inspection form
2. Example Public Outreach Brochure
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Element 8 –Capacity Assurance Plan
SWRCB Requirements:
The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic
capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the
appropriate design storm or wet weather event. At a minimum, the plan must include:
a) Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are
experiencing or contributing to an SSO discharge caused by hydraulic 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 capital
improvement plan (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.
8.1.1 System Capacity Evaluation
Evaluation of a sanitary sewer collection system during dry and wet weather conditions involves
evaluation of both capacity and general operational issues. The capacity of the system is primarily
controlled by population and significant commercial/industrial dischargers. Operational issues that may
lead to inadequate level of service system performance include roots, fats, oils and grease. The hydraulic
model is an important utility management tool to assist in identifying locations of capacity constraints or
velocity concerns that may exist in the existing system or are projected to arise under future dry or
weather flows.
Depth of flow in relation to pipe diameter, or depth-to-diameter (d/D) ratio is an element of the City’s
existing design criteria and is used herein to identify potential capacity problems within the system,
which may result in sewer overflows. A wet weather assessment of the sanitary sewer system is focused
on the elimination of wet weather overflows for a particular design storm event. Design storms are
primarily defined by their duration and the return period. Duration is the amount of time over which a
rain event occurs, where the return period is a measurement of the likelihood a particular event will
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occur. For example, a 5-year storm will theoretically occur once every 5 years. Since the selection of the
design storm can have a significant impact on determining the adequacy of system capacity, this design
criteria driven level of service element of the Sanitary Sewer Master Plan had careful consideration in
this planning effort. Based on discussions with City staff, the design storm selected to be incorporated in
the hydraulic model simulation is a 10-year 24-hour event. This design criterion is also used by City of
Los Angeles, the regional wastewater conveyance and treatment provider, in the assessment of its
sewer system hydraulic capacity analysis programs to contain peak wet weather flows in the sewer
design to avoid SSOs.
8.1.2 Existing Conditions Collection System Evaluation
The purpose of a sanitary sewer system is to collect sewer flow from various origins in the City and
convey these flows to a designated point of discharge. The maximum and minimum flow rates in any
given day can vary, but generally follow some typical daily diurnal patterns for residential and non-
residential customers. The sanitary sewer system should be designed to carry the maximum rate within
an acceptable range of velocity without the sewer system backing up during these peak daily flows. In
contrast, the sewer system should also have adequate flows and velocity to convey the minimum flow
without deposition of suspended solids during the minimum daily time periods, which is typically in the
middle of the night. The City’s hydraulic model was developed to effectively simulate the system’s
hydraulic behavior at specific time period and analyze its performance under various flow conditions.
The InfoSewer model uses steady-state simulations in its hydraulic analysis calculations for the analysis
of utility sewer systems. For a steady-state analysis, all flows are assumed to accumulate in the system
and discharge only at the outlets. This means that even if a pipe has a flow beyond its maximum
capacity, the flow is still carried downstream including through pumps and force mains so that
full/maximum flow conditions are carried through to all affected downstream facilities. The transition
between gravity flow and pressurized flow is also ensured by assuming that all flows are transported
through each force main, subject to the upstream hydraulic control. The hydraulic evaluation of the
City’s existing collection system was performed using the collection system model developed as
described earlier and is explained in this section.
The existing system evaluation applies current sewage flows to applicable spatial locations in the system
and incorporates current infrastructure configurations and applicable operational strategies, typically
associated with pump stations, force mains and diversion structures. A sanitary sewer collection system
has basically two main functions: to convey the designed peak discharge and to transport solids so that
deposits are kept to a minimum. It is imperative; therefore, that the sanitary sewer has adequate
capacity for the peak flow and that it functions at minimum flows without excessive maintenance and
odor generation. The existing system scenario takes into consideration the current flows in the existing
infrastructure, both under dry and wet weather conditions. The existing scenario incorporates all
facilities in the existing sanitary sewer system including gravity mains 10-inch in diameter and greater
(and all 8-inch mains directly upstream from 10-inch mains), maintenance holes, lift stations, pumps,
force mains, and the outfall station located at SM-1. For the dry weather scenario, sewer flows are
loaded to each node in the system based on the summation of account-level tributary sewer flows, as
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derived from water consumption data. To simulate wet weather conditions stemming from infiltration
and inflow, a peaking factor (PF) was applied to the dry weather loads at all nodes in the sewer system
network. This wet weather PF is calculated as the ratio between the average day flows and the flows
that occur on the day out of the year when the highest flows are recorded during a particular wet
weather event.
An understanding of the hydraulic condition of the existing system is essential to identify existing system
related capacity limitations and to help prioritize recommended system improvements resulting from
the ultimate system capacity analysis. The InfoSewer hydraulic model developed as a part of the Sewer
Master Plan was used to perform the capacity analysis of the existing collection system. The capacity
analysis was performed for various existing flow scenarios including existing average, peak dry weather,
and peak wet weather flow scenarios. Improvements are identified based on the evaluation of the
existing system during the peak hours of wet weather conditions. The capacity analysis performed
herein is consistent with generally accepted methods and is based on the consideration of the depth of
flow with respect to the diameter of the pipe. A capacity limited section along a pipeline is identified as
a potential capacity related improvement project if the depth to diameter (d/D) ratio exceeds the
criteria established to define system performance during the designated wet weather flow scenario
conditions. The hydraulic model constructed for this study was used to evaluate performance of the
collection system using the criteria for d/D ratio and velocity for gravity pipes, and surcharge depth for
maintenance holes. Under existing dry and wet weather flow conditions, a large majority of the City’s
sewer collection system pipelines have excess or reserve capacity. The existing hydraulic modeling
simulation identified approximately 1 percent of the total sanitary sewer pipeline system had d/D ratios
greater than the 0.75 criteria. This finding indicates the City’s sewer system has available capacity in
much of the local sewer system.
8.1.3 Background of InfoSewer Software Modeling
The City’s sanitary sewer collection system was modeled using the InfoSewer Version 7.6 software by
Innovyze. The InfoSewer software can simulate all aspects of the City’s sanitary sewer collection system
through a hydraulic model network. A hydraulic model network is a mathematical representation of the
collection system represented by a series of nodes and links. Nodes represent maintenance holes,
storage basins, wet wells, junction boxes, and outfalls. Links, as the name implies, represent any
hydraulic structure connecting two nodes. Sanitary sewer pipelines, force mains, lift stations, weirs, and
gates are all represented by links in this model. During the conduct of hydraulic simulations, the model
considers the available storage at these hydraulic elements (through filling and draining) and can
simulate unsteady state flow conditions under both open channel and surcharged conditions for varying
time periods. Additionally, this model allows simulation of single path and multiple path flow networks,
backwater curves, flow reversals, pumps, weirs, siphons, gates, orifices, parallel pipes, and other
diversion structures necessary to simulate a sanitary sewer system, such as the City's.
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8.2 Design Criteria
The City’s wastewater construction standards are maintained by the Engineering Division of the Public
Works Department. These standards are updated as required by City staff and are made available to the
public by the Civil Engineering Division upon request so that all engineering contractors and civil
engineers are aware of the City’s standards for wastewater construction. Presently, public wastewater
projects are designed by the Civil Engineering Division and each project’s contract documents contain all
wastewater specification standards, construction notes and details for the project. They are modified to
be site-specific on a project-by-project basis. Contract documents are prepared in-house using
consultant civil engineers for the plans and technical specifications. Specifications are Construction
Standards Institute (CSI) based and are modified as applicable by the Standard Specifications for Public
Works Construction (GREENBOOK), latest edition, which is jointly produced by representatives of the
American Public Works Association (APWA), the Associated General Contractors of California, the
Engineering Contractors Association, the Southern California Contractors Association and BNi
Publications, Inc.
8.3 Capital Improvement Goals and Schedules
As part of the City’s collection system CIP, land use and flow modeling are utilized to develop and prioritize
five-year and 30-year CIP goals and schedules for consideration and approval by the City Council. The
approved CIP projects are implemented as funds become available through a combination of Council-
adopted incremental development financing (for increases in land use), Council-approved rate increases
(for rate payers), and/or Council-approved increased Wastewater Capital Facility Fees.
The City of Santa Monica pays the City of Los Angeles an Amalgamated Sewerage System Facilities Charge
(ASSFC) for upward changes in land use by building permit. Until July 2008, Santa Monica paid Los Angeles
by utilizing the Santa Monica Wastewater Capital Facilities Fee collected at the time of permit issuance.
This has left Santa Monica’s CIP program at the same monetary level and funded through a combination
of rates collected from rate payers and wastewater capital facility fee at building permit issuance or
change of land use.
Currently, the City is on a 100-year sewer line replacement schedule and presently replaces 1 to 2 miles
of sewer per year.
8.3.1 CIP Prioritization Criteria
In addition to the individual prioritization of capacity-related projects, other key factors have been
integrated in the overall prioritization process. While some of these factors may be somewhat external to
the performance of the City’s Wastewater Enterprise, they will influence the timing and potential cost
aspects of the program’s implementation and have an influence on the level of community disruption and
overall quality of life in Santa Monica. These implementation elements include spatial demand triggers
that link to CIP requirements and associated development projects, inclusion of a broader infrastructure
management perspective by coordinating the CIP with other projects (e. g., underground utility and paving
projects) to minimize community disruption, consideration for cost segregation so that growth pays an
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appropriate share of costs, and an effort to develop a leveled CIP to match the programmed
improvements with capital budgeting and ratepayer affordability and acceptance.
8.4 Element 8 Appendix
None.
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Element 9 – Monitoring, Measurement, and Program Modifications
SWRCB Waste Discharge Requirement:
The Enrollee shall:
a. Maintain relevant information that can be used to establish and prioritize appropriate SSMP
activities;
b. Monitor the implementation and, where appropriate, measure the effectiveness of each
element of the SSMP;
c. Assess the success of the PM program;
d. Update program elements, as appropriate, based on monitoring or performance evaluations;
and
e. Identify and illustrate SSO trends, including: frequency, location, and volume.
9.1 Performance Measures
Annual performance indicators that the City will use to measure the health of the wastewater collection
system and the effectiveness of the SSMP are:
x SSOs: Total number, SSO rate, and number for each cause (e.g., roots, grease or FOG-related
blockage, debris, line failure, capacity deficiency, storm flow exceeding design, lift station
failure, or other);
x Total volume of SSOs and volume contained and returned to the system;
x Total volume and percentage of SSO volume that reached surface water; and
x Footage of main lines and percentage of system cleaned annually.
9.2 Monitoring and Measurement
Over the past three years the City’s commitment to asset management and preventative O & M
activities has resulted in fewer FOG related SSO incidents. The City regularly tracks and monitors the
general effectiveness of preventative maintenance measures through work orders/service requests,
number and location of reportable SSO reports, and required annual regulatory reports. Information
collected includes cause and location of stoppages; number, cause, location, and volume of SSOs;
stoppage response time; number and reason for customer complaints; and type of debris found. The
City has selected these certain, specific parameters because they can be documented and compared on
an annual basis in a simple format. In addition, experience has shown that these parameters are
straightforward, quantitative, and are focused on results.
In addition to the City tracking and monitoring measures, all documented SSO events are reported
through the California Integrated Water Quality System (CIWQS) database within the required
timeframe.
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9.3 Element 9 Appendix F
Supporting information for Element 9 is included in Appendix F. This appendix includes the following
documents:
1. Graph of SSO incidents
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Element 10 – SSMP Program Audit
SWRCB Waste Discharge Requirement:
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.
10.1 SSMP Audits
Internal audits will be conducted by Wastewater Division staff with assistance from WRPP on a biannual
(every 2 years) basis to determine the relevance and effectiveness of each element of the SSMP. In
addition to reviewing each element of the SSMP, the audits will also include a review of schedule
progress for measures implemented to correct any identified deficiencies from the prior version. Based
on the findings of the audit process, the SSMP will be updated or modified accordingly. A copy of the
audit report checklist and findings report will be retained in the file. The audit checklist was based on
the City’s knowledge and size of its system, and the number of FOG related SSO’s. The Audit also
incorporates the elements from example self-audits provided by the State Water Resources Control
Boards Enforcement Division.
10.3 Element 10 Appendix G
1. SSMP Audit Checklist
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Element 11 – Communication Program
SWRCB Waste Discharge Requirement:
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 communication with systems that are tributary and/or satellite to
the Enrollee’s sanitary sewer system.
11.1 Communication Program Discussion
The CSM maintains active public outreach and communication efforts with all its customers, the public-
at-large and surrounding agencies to provide timely information on City projects, improvements, and
emergency situations.
Communication outlets range from public meetings and hearings, representation at community groups,
to time-critical posting of signage in emergency situations and updates, posting to the CSM public
website (https://www.santamonica.gov/) and 24-hour telephone reporting systems. Also, part of the
CSM website are links to agenda and minutes from City Council meetings. Additionally, newsletters and
brochures are developed and distributed community-wide and staff regularly meets with other area
agencies. Informational flyers are often included with customer bills to update the rate payers on
system operations, proposed City projects and programs, and the City has public information staff and
inter-governmental management staff to maintain routine contact with news and media outlets in a
timely manner.
11.2 Communication with Satellite Wastewater Collection Systems
The City of Santa Monica communicates regularly with the City of Los Angeles which accepts and treats
flow from the City. The City of Santa Monica and other satellite agencies that have their flow treated by
Los Angeles attend quarterly contract Cities meetings at which treatment plant, collections system and
pretreatment issues are discussed and coordinated.
11.3 Communication Program Appendix H
1. Sanitary Sewer Overflow Response Contact List
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Appendix A
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Water Resources
Manager
Sunny Wang
Principal Civil
Engineer
(Vacant)
Water Resources
Protection Programs
Coordinator (WRPP)
George Rodriguez
Senior WRPP
Specialist
David Tu
WRPP Specialist
Corey Bracken
Water/Wastewater
Admin
Ralph Valencia
Wastewater
Supervisor
Danny Gomez
Wastewater Crew
Leader
Valente Guzman
Wastewater
Collections Worker
Hugo Camacho
Wastewater
Collections Worker
Luis Hernandez
Wastewater
Collections Worker
Irael Nieves
Wastewater
Collections Worker
Ismael Macias
Wastewater
Collections Worker
Omar Vizcarra
Wastewater
Collections Worker
Luis Romo
Wastewater
Collections Worker
Alfredo Bocanegra
Wastewater
Collections Worker
(VACANT)
Wastewater Crew
Leader
Joe Felix
Engineering Support
Services
Administrator
Thomas Poon
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Was there
an SSO?
Was the spill
blockage in a
private lateral?
Reporting a private lateral spill is optional.
1. Call LA County Department of Health
Services (213) 974-1234.
2. Report spill in CIWQS as a PLSD.
Did spill reach surface water or a drainage
channel that discharges to surface water or a
stormwater system which was not fully
captured and disposed of properly?
Was spill greater than 1000
gallons?
Spill is considered a Category 3 SSO.
Submit report to CIWQS within 30
calendar days of the end of the month
from when event occurred.
Spill is considered a Category 2 SSO.
Submit Draft Report into CIWQS within 3
business days and Certify within 15 days.
Spill is considered a Category 1 SSO if the
amount exceeds 1000 total gallons.
Notify Office of Emergency Services
(Cal OES) within 2 hours of becoming
aware of the spill. (800) 852-7550
Was spill over 50,000 gallons?
Water quality samples should be taken within
48 hours after spill notification.
Submit and certify spill technical report on
CIWQS within 45 days.
Yes
Yes
No
No
Yes
Yes
Yes
Yes
No
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Packet Pg. 219 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 220 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 221 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 222 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 223 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 224 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 225 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 226 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 227 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 228 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 229 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 230 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 231 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 232 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 233 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 234 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 235 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 236 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 237 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 238 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 239 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 240 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 241 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 242 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 243 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 244 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 245 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 246 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 248 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 249 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 250 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 251 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 252 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 253 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 254 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 255 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 256 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 257 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 258 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 259 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 260 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 261 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 262 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 263 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 264 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 265 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 266 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 267 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 268 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 269 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 270 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 271 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 272 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 273 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 274 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 275 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 285 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 287 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 289 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 290 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 292 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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Packet Pg. 313 Attachment: Draft Sewer System Management Plan Update 2023 (5683 : Sanitary Sewer Management Plan)
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