TO:
Honorable Mayor and Members of the City Council
THROUGH:
Talyn Mirzakhanian, City Manager
FROM:
Ted Semaan, Interim Public Works Director
Jeff Page, Utilities Manager
SUBJECT:Title
Consideration of Formal Approval of the 2025 Sewer System Management Plan (SSMP) Update as Required by the State Water Resources Control Board (SWRCB) Order No. 2022-0103-DWQ (No Budget Impact) (Interim Public Works Director Semaan).
APPROVE
Body
_________________________________________________________
RECOMMENDATION:
Staff recommends that the City Council formally approve the 2025 Sewer System Management Plan (SSMP) Update as required by the State Water Resources Control Board (SWRCB) Order No. 2022-0103-DWQ.
FISCAL IMPLICATIONS:
Projects identified in the SSMP will be incorporated into future Capital Improvement Program and operational budgets. The SSMP will also be used as a basis for the upcoming Sewer Rate Study. There are no immediate fiscal implications at this time.
BACKGROUND:
The City operates and maintains a sewer system that serves the community through a comprehensive collection network comprised of 81.6 miles of pipe, 2,086 manholes and cleanouts, eight pump stations, and 5,114 feet of associated force mains.
On May 2, 2006, the SWRCB adopted Statewide General Waste Discharge Requirements (WDR), which requires a Monitoring and Reporting Program for sanitary sewer systems by the issuance of Order No. 2006-0003-DWQ. The regulations in the Order were in response to growing public concern about the water quality impacts of Sanitary Sewer Overflows (SSO), particularly those that cause beach closures, adverse effects to other bodies of water, or pose serious health and safety or nuisance problems. The SSMP was then prepared and approved by City Council in October 2007 and submitted to the SWRCB. Subsequent SSMP updates were developed and approved in 2010, 2017, and 2022.
On December 6, 2022, the SWRCB adopted the WDR to regulate wastewater collection system management on General Order No. 2022-0103-DWQ (2022 Order). It became effective on June 5, 2023 and superseded the previous State Water Resources Control Board (State Water Board) Order No. 2006-0003-DWQ. All sections and attachments of this 2022 Order are enforceable by the SWRCB and Regional Water Quality Control Boards. Through this 2022 Order, the SWRCB requires the City to:
• Comply with Federal and State prohibitions of discharge of sewage to Waters of the State, including Federal Waters of the United States;
• Comply with specifications and notifications, monitoring, reporting, and recordkeeping requirements in this General Order that implement the Federal Clean Water Act, the California Water Code, water quality control plans (including Regional Water Board Basin Plans), and policies;
• Proactively operate and maintain resilient sanitary sewer systems to prevent spills;
• Eliminate discharges of sewage to Waters of the State through effective implementation of a Sewer System Management Plan;
• Monitor, track and analyze spills for ongoing system-specific performance improvements; and
• Report non-compliance with this General Order per reporting requirements.
DISCUSSION:
The SSMP is divided into 11 chapters, which are mandatory and address the respective provisions contained in the 2022 Order, and were reviewed for this update:
• SSMP Goals
• Organization Structure
• Legal Authority
• Operation and Maintenance Program
• Design and Performance Provisions
• Spill Emergency Response Plan
• Sewer Pipe Blockage Control Plan
• System Evaluation, Capacity Assurance and Capital Improvements
• Monitoring, Measurement, and Program Modifications
• Internal Audits
• Communication Program
The SSMP is intended to be a living document in which the City is required to update it every six years to reflect current conditions and knowledge of the system. The Public Works Department’s Utilities Division provides operation and maintenance services and follows the SSMP in servicing the City’s sewer facilities. This update was guided by internal program audits, conducted every three years as required by the Order. On February 4, 2025, the City completed its internal self-audit. No adverse results from the City’s sewer activities were found.
The SSMP included herein updates the document to the requirements of the 2022 Order, incorporates recent spill reports, and updates associated programs and procedures, including but not limited to:
• Definitions, terminology, abbreviations, and references have been updated per the 2022 Order;
• The minimum requirements of the 2022 Order are noted in each section, and the language has been adjusted for consistency with the new requirements;
• Appendices, figures, and tables have been revised;
• Updated City procedures, staffing, and contact information;
• The Legal Authority was updated to included subsection reference to the Municipal Code Section 5.38.120 to address the City’s access to easement accessibility agreements in the event of a spill;
• The Operation and Maintenance Program was updated to include the Monitoring and Reporting Program requirements of the 2022 Order;
• References to the 2008 to 2012 condition assessment and the 2026-2030 Capital Improvement Program (CIP) were added to the System Evaluation and Condition Assessment; and
• The Order, self audit report, CIP list, extra attention lines, hot spot list, and spill maps and reports were updated in the appendices.
The 2022 Order requires the SSMP Update to be approved by a governing body prior to submittal to the SWRCB. Upon approval of the SSMP Update by City Council, the document will be submitted to California Integrated Water Quality System (CIWQS) by the City’s Legally Responsible Officer by the August 2, 2025, deadline.
PUBLIC OUTREACH:
No public outreach was conducted in preparation for recommending this approval. Public outreach will occur at the appropriate time on a project-by-project basis.
ENVIRONMENTAL REVIEW:
The City has reviewed the proposed activity for compliance with the California Environmental Quality Act (CEQA) and has determined that the activity is not a “Project” as defined under Section 15378 of the State CEQA Guidelines; therefore, pursuant to Section 15060(c)(3) of the State CEQA Guidelines the activity is not subject to CEQA. Thus, no environmental review is necessary.
LEGAL REVIEW:
The City Attorney has reviewed this report and determined that no additional legal analysis is necessary.
ATTACHMENTS:
1. SWRCB Order No. 2022-0103-DWQ
2. 2025 Sewer System Management Plan Update