HomeMy WebLinkAboutStaff Report 2301-0789CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, May 08, 2023
Council Chambers & Hybrid
5:00 PM
Agenda Item
3.Approval of the Sewer System Management Plan Update 2023 as required by the
reissued Statewide Waste Discharge Requirements General Order for Sanitary Sewer
Systems, Order 2022-0103-DWQ
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CITY COUNCIL
STAFF REPORT
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Utilities
Meeting Date: May 8, 2023
Staff Report: 2301-0789
TITLE
Approval of the Sewer System Management Plan Update 2023 as required by the reissued
Statewide Waste Discharge Requirements General Order for Sanitary Sewer Systems, Order
2022-0103-DWQ
RECOMMENDATION
Staff recommends that Council approve the revised Sanitary Sewer Management Plan (SSMP)1 ,
as required by the reissued Statewide Waste Discharge Requirements General Order for Sanitary
Sewer Systems, Order 2022-0103-DWQ.
EXECUTIVE SUMMARY
The City’s current SSMP was certified by Council per the State of California Water Resources
Control Board’s (SWRCB’s) requirements on November 5, 20182. On December 6, 2022, the
SWRCB adopted Statewide Waste Discharge Requirements General Order for Sanitary Sewer
Systems, Order 2022-0103-DWQ (2022 General Order3) affecting wastewater collection system
management. The 2022 General Order requires the City of Palo Alto to update its SSMP to
incorporate certain additional requirements of the 2022 General Order by June 5, 2023.
Remaining requirements of the 2022 General Order must be included in the SSMP and adopted
by Council prior to August 2, 2025.
BACKGROUND
The 2022 General Order applies to all California municipalities that own and/or operate a sanitary
sewer system greater than one (1) mile in length. The 2022 General Order supersedes previous
1 Sanitary Sewer Management Plan https://www.cityofpaloalto.org//files/assets/public/agendas-minutes-
reports/reports/city-manager-reports-cmrs/attachments/05-08-2023-id2301-0789-2023-ssmp.pdf
2 2018 Sanitary Sewer Management Plan https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-
reports/reports/city-manager-reports-cmrs/attachments/05-08-2023-id2301-0789-2018-ssmp.pdf
3 Order 2022-01-03DWQ (2022 General Order)
https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2022/wqo_2022-0103-dwq.pdf
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General Orders, including the 2006 Order No. 2006-0003-DWQ and the Amending Monitoring
and Reporting Program WQ 2013-0058-Exec. To decrease the impacts on human health and the
environment caused by sewage spills, the previous General Order required enrollees to develop
a rehabilitation and replacement plan that identified system deficiencies and prioritized short-
term and long-term rehabilitation actions. The previous General Order also required enrollees
to:
1. Maintain information that can be used to establish and prioritize appropriate Sewer
System Management Plan activities; and
2. Implement a proactive approach to reduce spills.
The previous General Order also required SSMP elements to document these requirements for
“the proper and efficient management, operation, and maintenance of sanitary sewer systems,
while taking into consideration risk management.” The 2022 General Order continues and
expands on the requirements of the previous General Order, including the requirement to
prepare, certify, and implement an SSMP.
Under the 2022 General Order, two (2) requirements must be completed prior to the June 5,
2023. First, the Legally Responsible Official must be designated on the online California
Integrated Water Quality System (CIWQS) Sanitary Sewer System Database and certify
continuation of existing regulatory coverage under the 2022 General Order. Certification of
existing regulatory coverage will be made available on the CIWQS website beginning April 5,
2023. Second, the Spill Emergency Response Plan (SERP) element of the SSMP must be updated
and implemented. City Staff has prepared an updated SSMP that meets the requirements of the
2022 General Order. After adoption by the City Council, the updated SSMP will be uploaded to
CIWQS prior to the June 5, 2023 deadline.
ANALYSIS
The SSMP is a planning document that describes the City’s wastewater collection system
management activities and procedures. The 2022 General Order has updated the required 11
elements of the SSMP. The structure of the SSMP required by the 2022 General Order is largely
unchanged, as shown below in the table below.
2006 General Order Elements 2022 General Order Elements
1. Goal 1. Sewer System Management Plan Goal
and Introduction
2. Organization 2. Organization
3. Legal Authority 3. Legal Authority
4. Operations and Maintenance Program 4. Operations and Maintenance Program
5. Design and Performance Goals 5. Design and Performance Provisions
6. Overflow Emergency Response Plan
(OERP)
6. Spill Emergency Response Plan (SERP)
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2006 General Order Elements 2022 General Order Elements
7. Fats, Oils, and Grease (FOG) Control
Program
7. Sewer Pipe Blockage Control Program
8. System Evaluation and Capacity
Assurance Plan
8. System Evaluation, Capacity
Assurance, and Capital Improvements
9. Monitoring, Measurement, and
Program Modifications
9. Monitoring, Measurement, and
Program Modifications
10. Sewer System Management Plan
(SSMP) Program Audits
10. Internal Audits
11. Communication Program 11. Communication Program
The specific requirements for each element of the SSMP are listed in the 2022 General Order.
Many of the updated requirements must be incorporated into the SSMP by August 2, 2025.
However, all changes related to Element 6 - “Spill Emergency Response Plan” (SERP) must be
completed prior to June 5, 2023.
2022 General Order Element 6 includes significant changes to notification, monitoring, reporting,
and recordkeeping requirements of individual spills. Individual spills are defined as Category 1,
2, 3, or 4. Category 4 is a newly defined sanitary sewer overflow (SSO). The SSO categories have
been redefined in the 2022 General Order and are shown in the table below.
Amended 2013 General Order Newly Adopted 2022 General Order
Category 1: discharges of untreated or
partially treated wastewater of any volume
that reach surface water or municipal
separate storm sewer system and are not
fully captured or returned to the sanitary
sewer system or not otherwise captured and
disposed of properly
Category 1: a spill of any volume of sewage
from or caused by a sanitary sewer system
that results in a discharge to: a) surface
water b) a drainage conveyance system that
discharges to surface water when the sewage
is not fully captured and returned to the
sanitary sewer system or disposed of
properly
Category 2: discharges of untreated or
partially treated wastewater of 1,000 gallons
or greater that do not reach surface water
Category 2: a spill of 1,000 gallons or greater
that does not discharge to a surface water
Category 3: all other discharges of untreated
or partially treated wastewater
Category 3: a spill of equal to or greater than
50 gallons and less than 1,000 gallons that
does not discharge to a surface water
Category 4 was not defined.Category 4: a spill of less than 50 gallons that
does not discharge to a surface water
Procedures on how to contain and clean up an SSO remain unchanged in the SERP, however
additional procedures have been added to meet the new notification requirements to potentially
affected entities when an SSO reaches a water of the State as well as SSO-specific monitoring and
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reporting requirements. Waters of the State include, but are not limited to, groundwater
aquifers, surface waters, saline waters, natural washes and pools, wetlands, sloughs, and
estuaries, regardless of flow or whether water exists during dry conditions. Detailed instructions
on water quality sampling analysis have also been included in the SERP and are to be
implemented if an SSO reaches surface water. The City’s 2023 SSMP update includes some
significant formatting changes, a new Element 6, and other minor changes in the rest of the
elements. These changes are recorded in Appendix N of the 2023 SSMP.
The 2022 General Order further requires internal audits of the SERP annually and the SSMP every
three years and updates as needed. The City’s Utilities Department will complete the required
audits, update the SERP and SSMP, and implement identified changes based on the audit findings.
The entire SSMP will be recertified by City Council every six (6) years as required by the 2022
General Order. Once certified by City Council, the Legally Responsible Official will upload and
certify the SSMP in the online CIWQS Sanitary Sewer System Database.
FISCAL/RESOURCE IMPACT
There are no immediate fiscal or resource impacts due to adoptions of this update to the SSMP.
Potential long-term impacts include additional, unquantifiable increases in operational and
capital costs to comply with increasingly stringent regulatory requirements.
ENVIRONMENTAL REVIEW
Council’s adoption of the updated 2023 SSMP does not meet the definition of a project under
the California Environmental Quality Act’s Regulations, 14 CCR Section 15378(b)(5), as an
organization or administrative activity of government that will not result in direct or indirect
physical changes in the environment, thus environmental review is not required.
ATTACHMENTS:
Attachment A: 2023 Sanitary Sewer Management Plan
APPROVED BY:
Dean Batchelor, Director Utilities
Staff: Venessa Fujii, WGW Project Coordinator
2023 Sewer System Management Plan
City of Palo Alto
2023 Sewer System Management Plan
2023 Sewer System Management Plan
City of Palo Alto
CITY OF PALO ALTO, CALIFORNIA
2023 Sewer System Management Plan
City of Palo Alto
3201 East Bayshore Road
Palo Alto, CA 94303
Phone 650.496.6982
Prepared by:
Venessa Fujii, Utilities Project Coordinator
Reviewed by:
Matt Zucca, Assistant Director WGW
Anthony Meneses, Manager, WGW Operations
Robert Bishop, Acting Utilities Supervisor, Wastewater
Approved by Council:
2023 Sewer System Management Plan
City of Palo Alto
Page 9 of 37
Introduction
System Overview
The Sewer System Management Plan (SSMP) is a living planning document that includes the City of Palo
Alto’s wastewater program activities, procedures, and decision making. The State Water Resources
Control Board (SWRCB) Division of Water Quality has issued statewide waste discharge requirements for
sanitary sewer systems, which include requirements for the development of an SSMP. State Water
Resources Control Board Order No. WQ 2022-0103-DWQ Statewide Waste Discharge Requirements
General Order for Sanitary Sewer Systems. State Water Resources Control Board Order No. 2006-0003-
DWQ, Statewide General Waste Discharge Requirements for Sanitary Sewer Systems. State Water
Resources Control Board Order No. WQ 2013-0058-EXEC, Amending Monitoring and Reporting Program
for Statewide General Waste Discharge Requirements for Sanitary Sewer Systems. NPDES Permit No.
CA0037834 Incorporates the requirements to comply with the SSO WDR by reference in the treatment
plant to operate Order No. R2-2014-0024 that regulates the Palo Alto Regional Water Quality Control Plan
and City of Palo Alto’s wastewater collection system.
Documentation Organization
This SSMP has been prepared by The City of Palo Alto’s Utilities Department – Wastewater Operations,
Engineering, and Public Works – Environmental Services Staff in compliance with the SWRCB. Quoted
language taken from the SSO WDR will be boxed at the beginning of each element. The SSO WDR uses the
term “Enrollee” to mean each individual municipal wastewater agency that has completed and submitted
the required application for coverage under the WDR (in this case, the Enrollee is the City of Palo Alto.
The City of Palo Alto’s waste discharger identification number (WDID) in the California Integrated Water
Quality System (CIWQS) is 2SSO10164.
The City of Palo Alto’s SSMP contains 11 elements and is designed to meet the SSO WDR requirements
and the City’s Treatment Plant NPDES Permit. The structure of this document follows the section
numbering and nomenclature specified in the SSO WDR.
SSMP Elements
This SSMP includes 11 elements that are listed below. Each element forms a section of this document.
1. Sewer System Management Plan Goal and Introduction
2. Organization
3. Legal Authority
4. Operation and Maintenance Program
5. Design and Performance Provisions
6. Spill Emergency Response Plan
7. Sewer Pipe Blockage Control Program
8. System Evaluation, Capacity Assurance and Capital Improvements
9. Monitoring, Measurement and Program Modifications
10. Internal Audits
11. Communication Program
2023 Sewer System Management Plan
City of Palo Alto
Page 10 of 37
Element 1: Sewer System Management Plan Goal and Introduction
City of Palo Alto SSMP Goals:
• Repair, rehabilitate, replace, and upgrade system components as needed;
• Properly manage, operate and maintain the wastewater collection system;
• Cost effectively minimize I/I and provide sufficient system capacity;
• Eliminate all preventable overflows in dry and wet weather;
• Maintain an effective spill response that reduces overflow impact to public health & the environment;
• Analysis and evaluation of historical spills to provide recommendations to reduce future risk;
• Identify system blockages due to fats, oil, and grease (FOG) and develop strategies to decrease
backups; and
• Provide regular training for City of Palo Alto Utility Staff and Contractors in wastewater collection
system maintenance, operations, and emergency response.
Statewide Waste Discharge Requirements
The goal of the Sewer System Management Plan (Plan) is to provide a plan and schedule to: (1) properly
manage, operate, and maintain all parts of the Enrollee’s sanitary sewer system(s), (2) reduce and
prevent spills, and (3) contain and mitigate spills that do occur. The Plan must include a narrative
Introduction section that discusses the following items:
1.1. Regulatory Context
The Plan Introduction section must provide a general description of the local sewer system
management program and discuss Plan implementation and updates.
1.2. Sewer System Management Plan Update Schedule
The Plan Introduction section must include a schedule for the Enrollee to update the Plan, including
the schedule for conducting internal audits. The schedule must include milestones for incorporation
of activities addressing prevention of sewer spills.
1.3. Sewer System Asset Overview
The Plan Introduction section must provide a description of the Enrollee-owned assets and service
area, including but not limited to:
• Location, including county(ies);
• Service area boundary;
• Population and community served;
• System size, including total length in miles, length of gravity mainlines, length of pressurized (force)
mains, and number of pump stations and siphons;
• Structures diverting stormwater to the sewer system;
• Data management systems;
• Sewer system ownership and operation responsibilities between Enrollee and private entities for
upper and lower sewer laterals;
• Estimated number or percent of residential, commercial, and industrial service connections; and
• Unique service boundary conditions and challenge(s).
Additionally, the Plan Introduction section must provide reference to the Enrollee’s up to-date map of
its sanitary sewer system, as required in section 4.1. (Updated Map of Sanitary Sewer System) of this
Attachment.
2023 Sewer System Management Plan
City of Palo Alto
Page 11 of 37
1.1 Regulatory Context
The City of Palo Alto has adopted a SSMP in accordance with the SWRCB statewide waste discharge
requirements. The first SSMP to be adopted by City Council was in July 2009. Since the first adoption of
the SSMP, the plan has been audited and updated to remain compliant with the SWRCB’s regulations.
Under the reissued General Order, 2022-0103-DWQ, the SSMP must be updated within every six (6)
years after the required due date of its last plan update.
1.2 Sewer System Management Plan Update Schedule
The SWRCB has created an online look up tool to show each System’s SSMP audit and update due dates.
https://www.waterboards.ca.gov/water_issues/programs/sso/lookup/
The City’s SSMP update schedule is shown in the Table 1 below and follows the required plan update
pattern of every six (6) years.
Table 1: SSMP Audit Due Dates
8/2/2025 8/2/2031 8/2/2037 8/2/2043
8/2/2049 8/2/2055 8/2/2061 8/2/2067
8/2/2073 8/2/2079 8/2/2085 8/2/2091
1.3 Sewer System Asset Overview
The City of Palo Alto’s sanitary sewer system serves a population of 67,937 residents in a 26 square mile
service area within Santa Clara County. The City owns and operates 206 miles of gravity wastewater
collection system pipeline that ranges from 4 to 72 inches in diameter, 3,460 manholes, 80 lamp-holes,
900 feet of 10-inch diameter force main, and 1 wastewater lift station. Of the total piping system, 12%
(25.8 miles) are located in easements. The City also owns and maintains the lower portion of 17,739
service laterals. The upper portion of the service lateral from the cleanout or property line to the
building and the entire portion of the service lateral connected to the main pipeline located in
easements are owned and maintained by the individual private property owners. Maintenance of and
responsibility for upper laterals can be found in Appendix G or Rules and Regulations 23, Section C at
the City of Palo Alto Utilities Website: http://www.cityofpaloalto.org/civicax/filebank/documents/8211
Wastewater is treated at the Regional Water Quality Control Plant (RWQCP) that is operated by the City
of Palo Alto in partnership with the City of Mountain View, City of Los Altos, East Palo Alto Sanitary District,
Town of Los Altos Hills, and Stanford University. In addition to the City of Palo Alto’s collection system,
wastewater is conveyed to the RWQCP from several wastewater collection systems operated by and
serving the Cities of Los Altos and Mountain View, the Town of Los Altos Hills, the East Palo Alto Sanitary
District. Each of the municipalities, districts, and unincorporated areas of Stanford University campus are
obligated by agreement or contract to operate, maintain, and improve its wastewater collection system
to ensure there are no adverse impacts to the RWQCP.
2023 Sewer System Management Plan
City of Palo Alto
Page 12 of 37
Table 2: Inventory of Mains by Diameter
Pipe Diameter (IN) Length (LF) Number of Segments
4” 2,352 28
4.9” 8,625 29
5.4” 39,210 130
6” 332,754 1,252
6.6” 19,464 60
7.6” 9,728 34
8” 396,690 1,300
10” 70,554 252
12” 54,960 186
14” 6,515 24
15” 51,438 176
16” 6,034 20
18” 28,359 107
21” 13,920 48
24” 10,918 41
26” 570 2
27” 24,767 72
30” 15,325 35
33” 5,809 16
36” 15,327 39
39” 5,566 13
42” 7,545 24
54” 2,180 1
60” 536 1
72 8,450 12
Unknown 4,157 29
Total 1,141,753 (216.25 Miles) 3,931
2023 Sewer System Management Plan
City of Palo Alto
Page 13 of 37
Table 3: Inventory of Mains by Age
Sewer Construction Dates Feet Miles
Sewer Constructed 2000 to Current 230,725 43.70
Sewer Constructed 1980 to 1999 88,844 16.83
Sewer Constructed 1960 to 1979 11,542 2.19
Sewer Constructed 1940 to 1959 38,225 7.24
Sewer Constructed 1920 to 1939 4,456 .84
Sewer Constructed 1900 to 1919 Unknown Unknown
Sewer Constructed Before 1900 Unknown Unknown
Unknown 767,962 145.45
Table 4: Inventory of Mains by Material
Material Feet Miles
ABS 116 .02
ACP 5,095 .96
CIP 530 .10
CIPP 19,406 3.68
DIP 136 .03
PCP 12,283 2.33
PE 301,138 57.03
PVC 42,331 8.02
RCP 29,746 5.63
Steel 248 .05
VCP 284,426 53.87
Unknown 446,659 84.59
Table 5: Inventory of Lower Laterals
Agency Number of Laterals
City of Palo Alto 18093
2023 Sewer System Management Plan
City of Palo Alto
Page 14 of 37
Table 6: Inventory of City Owned Lower Laterals by Material
Material Feet Miles
ABS 55,426 10.50
ACP 11,794 2.23
CIP 1,643 .31
DIP 16 .00
PE 115,712 21.92
PVC 17,895 3.39
Steel 114 .02
VCP 30,091 5.70
Unknown 17,637 3.34
Data Management Systems
The City is currently in contract with Sedaru, which is owned by Aquatic Informatics, as their enterprise
asset management software. The Sedaru program can be used out in the field using tablets or in the
office using a desktop computer. WGW Operations and Engineering team are working with the Sedaru
to continue improving the software system.
2023 Sewer System Management Plan
City of Palo Alto
Page 15 of 37
Element 2: Organization
2.1 Organizational Structure
An organizational chart for Water Gas Wastewater Operations (WGW) is shown in Figure 1. This
organization shows the lines of authority for administrative and field staff who are involved with
implementing the SSMP.
Statewide Waste Discharge Requirements
The Plan must identify organizational staffing responsible and integral for implementing the local
Sewer System Management Plan through an organization chart or similar narrative documentation
that includes:
• The name of the Legally Responsible Official as required in section 5.1. (Designation of a Legally
Responsible Official) of this General Order;
• The position titles, telephone numbers, and email addresses for management, administrative, and
maintenance positions responsible for implementing specific Sewer System Management Plan
elements;
• Organizational lines of authority; and
• Chain of communication for reporting spills from receipt of complaint or other information,
including the person responsible for reporting spills to the State and Regional Water Boards and
other agencies, as applicable. (For example, county health officer, county environmental health
agency, and State Office of Emergency Services.)
2023 Sewer System Management Plan
City of Palo Alto
Page 16 of 37
Figure 1: Organizational Chart
Position Descriptions
Brief descriptions of the staff positions included on the organizational chart.
Utilities Director
Oversees the overall program, communicates with City Manager, provides reports to the City Council and
designates Legally Responsible Official (LRO) to certify spill reports.
Assistant Director, WGW Operations and Engineering
Oversees the program and communicates with the media. This classification can be designated as an LRO.
Manager, Utilities Compliance
Supports the collection systems program through evaluation of service reliability inspections related to
collection system programs. Provides support and assistance with regulatory and environmental
compliance.
Manager, Utilities Communications
Disseminates urgent and pertinent information to the public in a timely manner.
Manager, WGW Operations
2023 Sewer System Management Plan
City of Palo Alto
Page 17 of 37
Manages five WGW Operations Supervisors. Has the appropriate knowledge and expertise of the City’s
wastewater infrastructure to make decisions. This classification can be designated as an LRO.
Utilities Supervisor, Wastewater Operations
Manages field operations and maintenance activities for the sanitary sewer collection system, provides
relevant information to agency management, prepares, and implements contingency plans, leads
emergency response, investigates, and reports spills, and trains field staff. This position has an account
with the State Water Board online spill database and submits spill data that is ultimately reviewed and
certified by the LRO. The State designates these persons as Data Submitter.
Business Analyst
Assist in wastewater collection system data analysis and report generation. The State designates these
persons as Data Submitters.
Installer/Repairer Lead
Leads crews in the performance of routine maintenance and inspection. Oversees and participates in the
installation and repair projects of Wastewater Operations. Responds to after hour spills if part of Standby
Operations. Referred to as a Wastewater Operator in the SSMP.
Installer/Repairer
Under direction of Wastewater Supervisor, performs routine maintenance and inspection. Participates in
the installation and repair projects of Wastewater Operations. Also responds to after hours spills if part
of the Standby Operations Team. Referred to as the Wastewater Operator in the SSMP.
Manager, WGW Engineering
Establishes policy, plans strategy, reviews the SSMP engineering related information, leads engineering
staff, allocates resources, delegates responsibility, and authorizes outside contractors to perform
services for rehabilitation and new construction of wastewater improvements.
Senior Wastewater Engineer
Manages and administers the Capital Improvement Program (CIP).
Utilities Project Coordinator
This position has an account with the State Water Board online CIWQS database and submits spill data
that is ultimately reviewed and certified by the LRO. This position is a Data Submitter for the City.
Inspector
Conducts inspections of construction projects including contract and CIP projects. Ensures that new and
rehabilitated assets meet agency standards.
Manager, Watershed Protection
Manages the development, implementation and administration of various environmental compliance
and water pollution prevention programs for the Regional Water Quality Control Plant. Maintains and
updates the City’s Sewer Use Ordinance.
Manager, Environmental Control Program
Administers the City’s Fats, Oils and Grease (FOG), Industrial Waste, and Storm Water Programs.
Environmental Compliance Division (ECD) Industrial Waste Investigator
Conducts inspections and industrial, commercial, and food service facilities.
2023 Sewer System Management Plan
City of Palo Alto
Page 18 of 37
Environmental Compliance Division (ECD) Industrial Waste Inspector, Storm Water
Investigates the illegal discharge of wastewater to the storm drains.
Environmental Compliance Division (ECD) Industrial Waste Inspector, Sampling
Collects samples and inspects discharge locations including creeks and grease removal devices.
Environmental Compliance Division (ECD) Engineering Tech III
Inspects food service facilities
2.2 Responsibility for SSMP Management, Administration, and Maintenance
The City’s Utilities Director has the ultimate responsibility for management, administration, and
maintenance of all elements of the City’s SSMP. The responsibility for day-to-day implementation and
maintenance of each of the City’s SSMP Elements has been delegated to City Staff. Table 7 lists the City
Staff involved with developing, implementing, and maintaining the City’s SSMP, along with their job titles
and contact information.
Table 7: List of City Staff Responsible for the SSMP
SSMP Element Responsible City Official Phone e-Mail
Element 1 Sewer
System Management
Plan Goal and
Introduction
Dean Batchelor, Utilities
Director
(650)496-6981 Dean.Batchelor@cityofpal
oalto.org
Element 2 Organization Anthony Meneses, WGW
Operations Manger
(650)496-6907 Anthony.Meneses@cityof
paloalto.org
Element 3
Legal Authority
Pam Boyle Rodriguez,
Manager Environmental
Control Program
Watershed Protection
(650)329-2421 Pamela.BoyleRodriguez@
cityofpaloalto.org
Element 4
Operation and
Maintenance Program
Robert Bishop, Interim
Supervisor
WGW Operations
(650)329-2218 Robert.Bishop@cityofpalo
alto.org
Element 5
Design and
Performance
Provisions
Silvia Santos, Manager
WGW Engineering
(650)566-4520 Silvia.Santos@cityofpaloal
to.org
Element 6
Spill Emergency
Response Plan
Robert Bishop, Interim
Supervisor WGW Operations
(650)496-6917 Robert.Bishop@cityofpalo
alto.org
Element 7
Sewer Pipe Blockage
Control Program
Pam Boyle Rodriguez,
Manager Environmental
Control Program Watershed
Protection
(650)329-2421 Pamela.BoyleRodriguez@
cityofpaloalto.org
Element 8
System Evaluation,
Capacity Assurance and
Capital Improvements
Silvia Santos, Manager
WGW Engineering
(650)566-4520 Silvia.Santos@cityofpaloal
to.org
2023 Sewer System Management Plan
City of Palo Alto
Page 19 of 37
2.3 Legally Responsible Official
Under Resolution No. 9380, the City Council has adopted the following City employee classifications as
potential Legally Responsible Officials (LROs):
Assistant Director of Utilities
Water Gas Wastewater Operations Manager
Utilities Compliance Manager
Wastewater Collections Supervisor
Out of these potential employee classifications, only the Assistant Director of Utilities and Water Gas
Wastewater Operations Manager maintain the qualifications that are stipulated in the reissued General
Order. Per Section 5.1 of the Order 2022-0103-DWQ, the LRO must have responsibility over the entire
sanitary sewer system and have the authority to make decisions governing operations of the sewer
system, including explicit or implicit duty of making capital improvement recommendations.
Furthermore, the LRO must have or be in direct authority over individuals that:
1. Possess a recognized degree or certificate related to operations and maintenance of the sewer
system, and/or
2. Have professional training and experience related to the management of sanitary sewer
systems, demonstrated through extensive knowledge, training and experience.
In consideration of the above criteria, the City of Palo Alto has designated Matt Zucca, Water Gas
Wastewater Operations and Engineering Assistant Director, and Anthony Meneses, WGW Operations
Manager, as the Legally Responsible Official.
2.4 Chain-of-Communication for Reporting and Responding to Spills
In response to a spill event, City of Palo Alto Utilities also known as Water, Gas, Wastewater Operations
implements its Spill Emergency Response Plan, discussed in detail in Element 6. The Spill Emergency
Response Plan provides direction for the immediate verbal and written notification of City Staff and
California Office of Emergency Service (Cal OES).
All spill-related calls from the Public and City Staff are routed to the City’s 24-hour Dispatch Center for
proper documentation and tracking. The Dispatch Center is responsible for routing the spill calls to
Wastewater Operations - Emergency Response Team (ERT) during regular business hours and to the
Standby Operations - Emergency Response Team after hours.
Element 9
Monitoring,
Measurement and
Program Modifications
Anthony Meneses, Manager
WGW Operations
(650)496-6932 Anthony.Meneses@cityof
paloalto.org
Element 10
Internal Audits
Anthony Meneses, Manager
WGW Operations
(650)496-6932 Anthony.Meneses@cityof
paloalto.org
Element 11
Communications
Program
Catherine Elvert, Manager
Utilities Communications
(650)329-2417 Catherine.Elvert@cityofpa
loalto.org
2023 Sewer System Management Plan
City of Palo Alto
Page 20 of 37
Wastewater Operations
ERT consists of Installer/Repairers (I/R). During regular business hours, the ERT arrives on site and
assesses the situation. If the event is a Category 1 or 2 Spill, ERT will call the Utilities Supervisor as soon as
possible while containing the spill, relieving the blockage/stoppage, and documenting the event. Category
3 and 4 Spills will have the same procedure stated above except notification to the Utilities Supervisor is
not necessary. The ERT is responsible for communicating the details of the event to Management,
ensuring all necessary paperwork is completed in full.
Standby Operations
ERT consists of a team of 3 which includes 2 Installer/Repairers who are designated as Primary Responder,
Secondary Responder, and a Heavy Equipment Operator (HEO) in case of major repairs. Standby
Operations ERT is an after-hours operation and uses the same process as the Wastewater Operations ERT.
The Dispatch Center records communications between the callers, the responders and any other
supporting team that is being dispatched to the spill scene. Important phone numbers for City Staff
involved in spill response are shown on Table 8.
Table 8: Phone Numbers for Spill Response
Responsible Party Name Phone Number
24hr Dispatch Center Utilities Emergency Dispatch (650) 329-2579
Police Department 24-Hour Non-Emergency Police Dispatch (650) 329-2413
Emergency/Crossbore/Radio Call
Sign 413
I/R Class, Emergency Response normal
working hours
(650)213-2633
Primary ERT I/R Class, Standby Operations after hours (650)444-6198
Secondary ERT I/R Class, Standby Operations after hours (650)444-5290
WGW Operations Office Administrative Staff (650) 496-6982
Utilities Supervisor
(Interim Wastewater Operations)
Robert Bishop (650) 329-2218
Legally Responsible Official(s) Anthony Meneses
Matt Zucca
(650)496-6907
(650) 329-2639
Data Submitters Venessa Fujii (650) 496-6994
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Element 3: Legal Authority
3.1 Legal Authority
The Palo Alto City Council has the power to enact ordinances and other legally binding instruments to regulate
usage and prevent discharges to the sewer, including but not limited to fats, oils, grease, and debris that may
cause blockages. The City has approved and adopted the Sewer Use Ordinance (Palo Alto Municipal Code
(PAMC), Title 16, Chapter 16.09 Appendix H), the Utilities Rules and Regulations (Appendix G) and the Utility
Standards (Appendix I) to govern the collection, maintenance, and construction of the wastewater facilities
within the City. In addition, the City has entered into several agreements with its partner agencies to the RWQCP
that obligates those agencies to comply with both City requirements and the WDR and NPDES permit.
The specific purpose of the City’s Sewer use Ordinance is to prevent the discharge of any pollutant into the
sewer system, the storm drain system, or surface waters, which would:
1. Obstruct or damage the collection system;
2. Interfere with, inhibit or disrupt the Palo Alto Regional Water Quality Control plant or its
treatment processes;
3. Pass through the treatment system and contribute to violations of the regulatory requirements
placed upon the plant;
4. Result in or threaten harm to or deterioration of human health or the environment.
The Utilities Rules and Regulations, approved and adopted by resolution of the City of Palo Alto City
Council, govern the business operation of the City’s utilities, including access, maintenance, and
inspection of City-owned laterals.
The Utility Standards govern the requirements for proper design, construction, and maintenance of water,
gas, and wastewater utility facilities and connections within the City of Palo Alto. Element 5 contains
Statewide Waste Discharge Requirements
The Plan must include copies or an electronic link to the Enrollee’s current sewer system use
ordinances, service agreements and/or other legally binding procedures to demonstrate the Enrollee
possesses the necessary legal authority to:
• Prevent illicit discharges into its sanitary sewer system from inflow and infiltration (I&I); unauthorized
stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including
rags and other debris that may cause blockages;
• Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to
storm sewer systems during spill events, and prevent unintentional cross connections of sanitary sewer
infrastructure to storm sewer infrastructure;
• Require that sewer system components and connections be properly designed and constructed;
• Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned
and/or operated by the Enrollee;
• Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures;
and
• Obtain easement accessibility agreements for locations requiring sewer system operations and
maintenance, as applicable.
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greater detail regarding the Utility Standards governing the design and construction of sanitary sewer
systems.
Enforcement provisions are found in Palo Alto Municipal Code (PAMC). Violations of the PAMC can be
addressed through criminal, judicial, administrative, and/or injunctive action. The City may assess
monetary fines as well.
3.2 Sewer Use Ordinance
Table 9 contains a summary of pertinent Sewer Use Ordinance provisions relevant to SSMP
implementation. Note that this summary is provided for convenience only; users should consult with the
Utilities Compliance Manager or the City Clerk’s Office to confirm that they are using the most recent
version of the City’s Sewer Use Ordinance.
(https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-71241)
Table 9: Palo Alto Municipal Code Provisions Relevant to SSMP
Provision Palo Alto Municipal Code Reference
Purpose and applicability 16.09.005
Limitations of point of discharge 16.09.030
Prohibitions 16.09.035
Standards 16.09.040
Grease disposal prohibited 16.09.050
Unpolluted water 16.09.055
Food service establishments 16.09.075
Industrial waste discharge permit 16.09.080
Requirements for construction operations 16.09.170
Root and pest control chemicals 16.09.210
Enforcement – Warning 16.09.240
Enforcement – Notice of noncompliance 16.09.245
Enforcement – Administrative compliance order 16.09.250
Enforcement – Criminal penalties 16.09.255
Enforcement – Administrative citation 16.09.260
Enforcement – Administrative civil penalties 16.09.265
Enforcement – Judicial civil penalties 16.09.270
Damage to facilities 16.09.275
City right to terminate discharge 16.09.280
3.3 Utilities Rules and Regulations
Table 10 contains a summary of pertinent Utilities Rules and Regulations relevant to SSMP
implementation. See Appendix G or check the link below for the most recent versions of the Utilities
Rules and Regulations.
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Table 10: Utilities Rules and Regulations Relevant to SSMP
Rule/Regulation Reference
Adoption of Rules RR01
Definitions and Abbreviations RR02
Description of Utility Service RR03
Application for Service RR04
Access to Premises RR08
Disconnection, Restoration & Termination of Service RR09
Billing, Adjustment & Payment of Bills RR11
Line Extensions RR16
Utility Service Connections & Facilities on Customers’ Premises RR18
Special Wastewater Utility Regulations RR23
3.4 Agreements with Other Agencies
The Regional Water Quality Control Plant administers and manages an agreement with each of the partner
agencies: City of Mountain View, City of Los Altos, East Palo Alto Sanitary District, Town of Los Altos Hills
and Stanford University. Provisions in the Partners Agreement, Appendix M, requires that the agencies
adopt companion ordinances and regulations to assure no upset or damaging conditions will affect the
RWQCP in the partner wastewater discharges. The City and partner agencies meet and discuss various
issues on a regular basis. Each partner agency is responsible for its own collection operations maintenance
and regulatory compliance.
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Element 4: Operation and Maintenance Program
4.1 Sanitary Sewer System Mapping
The City of Palo Alto uses Geographic Information System (GIS) technology to create, maintain, and
manage maps and data sets associated with its wastewater collection system facilities, storm drainage
facilities, and force mains. Location, pipe, and manhole inventory data including length, diameter,
material, rim/invert elevations, street address, and other information are maintained.
4.1.1 Mapping
Since 1995, the WGW Engineering staff has maintained and utilized the City’s GIS system for the
Wastewater Collection System. Wastewater Collection System Map Books are in all service vehicles
assigned to Wastewater Operations, Offices, and in the WGW Operations center. Wastewater Collection
Statewide Waste Discharge Requirements
The Plan must include the items listed below that are appropriate and applicable to the Enrollee’s
system.
4.1. Updated Map of Sanitary Sewer System
An up-to-date map(s) of the sanitary sewer system, and procedures for maintaining and providing
State and Regional Water Board staff access to the map(s). The map(s) must show gravity line
segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater
conveyance facilities within the sewer system service area boundaries.
4.2. Preventive Operation and Maintenance Activities
A scheduling system and a data collection system for preventive operation and maintenance activities
conducted by staff and contractors. The scheduling system must include:
• Inspection and maintenance activities,
• Higher-frequency inspections and maintenance of known problem areas,
• Regular visual and closed-circuit television (CCTV) inspections of manholes and sewer pipes. The
data collection system must document data from system inspection and maintenance activities.
The data collection system must document data from system inspection and maintenance activities,
including system areas/components prone to root-intrusion potentially resulting in system backup
and/or failure.
4.3. Training In-house and external training provided on a regular basis for sanitary sewer system
operations and maintenance staff and contractors. The training must cover:
• The requirements of this General Order;
• The Enrollee’s Spill Emergency Response Plan procedures and practice drills;
• Skilled estimation of spill volume for field operators; and
• Electronic CIWQS reporting procedures for staff submitting data.
4.4. Equipment Inventory
An inventory of sewer system equipment, including the identification of critical replacement and
spare parts.
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System Map Books are in the form of a 200-scale map book, which are in sizes of 11”x17” and 24”x16”
with a green front cover.
Updates to Existing Drawings
Corrections are made to maps in the GIS system by WGW Engineering when requested by Wastewater
Operations. Proposed corrections identified by Wastewater Operations are delivered by electronic service
orders to the WGW Engineering staff as field staff discovers corrections. Engineering staff makes map
revisions weekly based on these orders. Map books are provided to Wastewater Operations by WGW
Engineering every 18 months to 2 years. Interim changes on individual pages can be printed from GIS and
given to personnel prior to the distribution of map books.
Storm Drains
Storm drains are also shown on GIS and can be viewed by Wastewater Operations. The City’s Public Works
Engineering staff is responsible for maintaining the storm drain map. The Storm Drain System GIS is
equipped with a tool called “FLO” that can electronically trace the location of any overflow from the
source to downstream locations, including storm drains, lift station, or creeks. In addition to the GIS map,
a Map Book of the City’s Storm Drain System Map is kept in the WGW Operations Center and all service
vehicles assigned to Wastewater Operation. The system map can be used to determine the routing of
spills, to potentially block storm drains and contain the volume of overflows before they reach waters.
4.1.2 New Improvement Plan Drawings
Upon acceptance by the City Council of all new and dedicated infrastructure, record drawings are
prepared by WGW Engineering for inclusion in the GIS and sewer maps. A copy of record drawings are
scanned for map updates, catalogued, and inserted into the GIS system upon installation of newly
constructed and dedicated sewer mains, storm drains, and associated facilities. Drawings are submitted
in both hard copy and electronic format. A scanned copy of record drawings from contractors and
developers is provided to the Wastewater Operations so they have a record of improvements and facilities
on hand prior to the publication and receipt of updated system maps. The hardcopies of records are
maintained in the WGW Operations Center. As part of each rehabilitation and replacement project,
contractors provide GPS data for sewer collection facilities like cleanouts, lateral connection locations,
and manholes. Engineering uses this information in its updates of the GIS and wastewater collection
system facilities.
4.2 Preventative Maintenance
The City’s wastewater collection system Operation and Maintenance (O&M) Program includes proactive,
preventive, and corrective maintenance of gravity sewers, and regular inspection and preventive
maintenance of the lift station and force main. Figure 2 provides a map of the City’s Wastewater Collection
System service area including the Partner Agency service areas.
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Figure 2: Sewer System Service Area
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4.2.1 Staffing
The City has twelve O&M employee positions dedicated to Wastewater Operations. The 12 O&M
employees consist of the following budgeted positions:
1 Utilities Supervisor (Wastewater Operations)
2 Installer/Repairer Leads (I/R Leads)
8 Installer/Repairers (I/R)
1 Heavy Equipment Operator (HEO)
Other Wastewater Operation staff that support O&M include the Assistant Director, WGW Operations
Manager, Utilities Project Coordinator, Business Analyst, Utilities Communications Manager, and a
Program Assistant.
4.2.2 Preventative Maintenance for Gravity Sewer Mains
The City is committed to proactively cleaning its entire collection system on a frequency of at least every
36 months except for trunk lines (lines greater than 15 inches) and certain lines located in easements.
Table 11 shows the cleaning frequencies for the various categories of lines. Pipes with historical
maintenance issues like heavy FOG deposition, “hotspot” or high frequency lines, are cleaned on a
preventive maintenance schedule every 3 or 6 months. The City collects and analyzes maintenance and
other condition assessment data during its proactive and preventive cleaning of lines. The cleaning
frequency of hotspot lines may vary and be increased seasonally, during holiday periods for example, and
in areas with heavy FOG deposits. In the future, the frequency of sewer cleaning may be adjusted to
optimize efforts based on cleaning results measured by the observed results and condition assessment by
CCTV.
Table 11: Minimum Cleaning Frequencies for Line Type
Line Type Minimum Cleaning Frequency in Months
Hot Spot Lines 3 to 6 months
Easement Lines 36 months
Trunk Lines (Lines greater than 15 inches) 60 months
Siphons 12 months
All Other Lines 12 to 36 months
Figure 3 provides a map of the City’s Wastewater Collection System and cleaning frequencies. The City
uses its own staff and contractors to perform all cleaning of City wastewater collection system lines.
Gravity sewer maintenance is currently scheduled using a computerized maintenance management
system (CMMS) called Sedaru. Maintenance activities and cleaning results are recorded in Sedaru for each
segment of pipe cleaned. Work orders are generated and are used to schedule cleaning of “Hotspot” or
high frequency lines as well as for the system-wide cleaning of all other pipes and siphons. Although the
goal is to have all work orders assigned and completed within Sedaru, there are times when a paper work
order is completed instead. Wastewater Operators are to deliver completed paper work orders to the
Utilities Project Coordinator at the end of each working day so that it can be recorded into Sedaru. The
City’s work order form used for dispatching work and recording completed work is shown in Appendix A
and B.
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Figure 3: City of Palo Alto Sewer Line Cleaning Frequencies
An important aspect of the City’s sewer cleaning program is the recording of cleaning results for each
manhole-to-manhole pipe segment using code-based standard results in the Standard Measures of
Observed Results on the Mainline Work Order From, Appendix A. The results provide a basis for the
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Utilities Supervisor to modify the frequency or method of cleaning for that pipe segment to reflect current
field conditions. Follow-up video inspections and/or repairs are requested as needed by the Utilities
Supervisor to assure quality of the cleaning and for training of City employees. This process is shown in
Figure 4.
The City is currently beginning a process to define the cleaning and maintenance requirements of all
system siphons that have not had regular maintenance. This program will evaluate required equipment,
procedures, frequency of evaluation and cleaning and the possible use of contractors to conduct this
work when required.
Main cleaning is presently performed on a basin based approach utilizing twenty-seven (27) basins
defined in the City’s GIS. Basins are geographically located to reduce travel time to the basin and
maximize productivity once work in the basin is initiated. Figure 5 contains the current Wastewater
Collection System Basin Map. Work orders are prepared in routes which include about 3,500 to 5,000
linear feet of cleaning and are provided to Wastewater Operators at the start of each day. A team of 2
Operators are assigned to complete daily wastewater main cleaning per a schedule. Sometimes there
are two teams working on cleaning depending on emergency response, work load priorities, and
projects. Most cleaning is accomplished by hydroflushing wastewater mains using a combination high
velocity hydroflushing/vacuum truck. The City has two of these units assigned to Wastewater
Operations.
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Figure 4: Sewer Cleaning Scheduling Flowchart
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Figure 5: City of Palo Alto Wastewater Utility Basin Map
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4.2.3 Main Inspection
Inspections are performed by Wastewater Operations field staff with the use of a CCTV van equipped
with a camera, a computer, and Granite Basic software. Small, portable cameras are also available for
use in small diameter lines/laterals and special cases where the CCTV van system is cumbersome.
Quality Assurance/Quality Control (QA/QC)
Quality Assurance/Quality Control is used to provide feedback to Wastewater Operations on the quality
of their cleaning on approximately 2% of the footage of cleaning performed. Formal QA/QC consists of
performing CCTV inspection of selected lines within 2 weeks of their cleaning. The I/R Lead provides
feedback to support modification of cleaning processes, practices, techniques, and tool-use to improve
line cleaning quality located in the Sedaru work order. Feedback is generally given in staff meetings and
in one-on-one meetings with employees.
Pipeline Assessment Certification Program (PACP)
Pipeline Assessment Certification Program is the North American Standard for pipeline defect
identification and assessment, providing standardization and consistency to the methods in which
pipeline conditions are identified, evaluated, and managed. This program provides a framework for
ranking line segments based on severity of observed defects and conditions. The pipe ratings are based
on the number of occurrences and severity of each defect or condition. Structural and O&M defects are
calculated separately. The data obtained from these inspections are used to assist in the prioritization
of the City’s sewer rehabilitation and replacement program as well as the identification of hotspots
requiring regular flushing. Currently, work orders are generated from Sedaru for Lateral Assessment
Certification Program (LACP) and spills. These lines are inspected by an I/R Lead who holds a PACP
Certification through NASSCO. Defects in the Wastewater Collection System are identified, graded and
managed through the Granite Basic Software. PDF reports are exported and printed by Granite Basic and
stapled together with the Sedaru work order. It is then turned in at the end of the day to be entered into
Sedaru by the data submitter who must scan and attach the report to each work order form and close it
out.
Manhole Inspections
The City will assess the condition of the manholes and other structures using City field crews and visual
inspection methods during its system-wide sewer cleaning. Manhole Inspection forms should be
completed on the SEDARU app when in the field.
4.2.4 Lower Lateral Maintenance
As with mainline maintenance frequencies, problem laterals that warrant a higher cleaning frequency
due to root intrusion or structural defect are placed on a 12 month cleaning frequency scheduled in
Sedaru. If the problem lateral continues to have repeated service calls, or results in multiple backups or
spills, it is placed on the lower lateral Replacement/Repair list and its cleaning frequency is increased.
Lower lateral cleaning is performed by using 2 methods. One being an electric power rodder/snake
mostly used by the ERT during preventive maintenance (SOAP) and our new Hydrojetter Truck used for
the AJAC Program.
Sewer Overflow Alternative Program (SOAP)
SOAP is the City of Palo Alto’s preventive maintenance program. The Wastewater Operations
Department uses an electric power rodder which is a portable unit that is kept in the ERT Van. The
Wastewater Operators assigned to the ERT will respond to emergency blockages, stoppages, and spills.
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When there are no emergencies, the Operators will complete planned work in paper or digital SOAP
work orders. A tablet with the Sedaru App is given to this team to complete work orders. The
Wastewater Project Coordinator can review data that was submitted from the field, enter data, and
close work orders in Sedaru.
Advanced Jetting And Cleaning (AJAC)
AJAC is similar to the SOAP program but dedicated to hydrojetting lines. The Wastewater Operators
assigned to AJAC will focus on preventive maintenance. This team is to complete paper or digital AJAC
work orders on the Sedaru App. A Utilities Project Coordinator can review data that was submitted from
the field, enter data, and close work orders in Sedaru. Teams assigned to the Combination Truck can be
assigned AJAC if all routes have been completed and there are no emergencies.
4.2.5 Lower Lateral Inspection
Inspections are performed by Wastewater Operators by using small, portable CCTV units (Rigid See
Snakes as well as other brands). It is used to confirm cleaning frequencies, methodologies, and
determine effectiveness of a cleaning as well as finding crossbores, structural defects, and infiltration.
CCTV of New Gas Service/Crossbore Program Once a new gas service is installed/replaced by New
Construction/Gas Operations, ERT is dispatched to do a sewer lateral inspection for crossbores. ERT
must inspect the entire length of the sewer lateral, both City and Private. If there is no access for the
private sewer lateral, a contractor must be dispatched to clear for crossbore. Wastewater Operators
assigned to ERT will use a Portable CCTV Camera to complete inspections. Details of the inspection are
recorded on a Lateral Work Order form, see Appendix B, which are turned in at the end of the day or
submitted on the Sedaru App. If a crossbore is found, repairs are completed the same day.
Quality Assurance/Quality Control (QA/QC) Same as 4.2.3 Section A but for Laterals
Lateral Assessment Certification Program (LACP) Same as 4.2.3 Section B but for Laterals
4.2.6 Lift Stations
The City operates and maintains one lift station. Wastewater Operations perform routine operational
checks of the station once a month and the wet well is cleaned annually. The Water Transmission
Division of Utilities also performs weekly visual inspections of the station. Preventive maintenance for
mechanical and electrical equipment is done annually by WGW Operations General Shop. The station
has an audible alarm and is connected through a SCADA system to the Utilities Dispatch Center. The
station serves approximately 25 homes and a portable generator is available in the event of power
outages.
4.2.7 Force Mains
The City has one 10-inch diameter force main of 900 linear feet that serves the lift station in Foothill
Park. (A force main moves wastewater under pressure by using pumps located in lift stations. They carry
wastewater from lower to higher elevation). Wastewater Operations conducts annual above-ground
visual inspections for signs of problems or leakage from the force main.
4.2.8 Chemical Root and Grease Control
Lines with a history or record of significant root intrusion, or in areas that are not readily accessible such
as parks or easements, may be treated with chemicals to control root growth on an as needed basis.
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Wastewater Operations occasionally applies commonly used herbicides for this purpose as well as
grease emulsifying agents to assist with FOG control. The City also contracts a root control contractor to
apply root foaming applications to identified areas of high root intrusion throughout the City.
4.3 Rehabilitation and Replacement Plan
Since 1988, the City has had an ongoing Capital Improvement Program (CIP) to rehabilitate and replace
its sewer infrastructure. On average roughly 9,100 feet of sewer mains are replaced each year. Since
1988, approximately 64 miles of sewer mains have been rehabilitated or replaced, primarily by pipe
bursting with high-density polyethylene (HDPE) pipe. Since 2005, the sewer rehabilitation projects have
also included replacement of the associated lower laterals.
Areas of the system are targeted for rehabilitation based on the results of CCTV inspection, review of
spill records, and line cleaning maintenance records. In addition, lines may be prioritized and replaced in
selected “targeted work zones” where City Public Works has planned pavement rehabilitation and
improvement work scheduled. The wastewater CIP is overseen by WGW Engineering. Other, repair work
is conducted on an as-needed basis by Wastewater Operations to address wastewater maintenance or
structural problems identified through regular maintenance or CCTV inspection activities.
4.3.1 Gravity Sewers
The City’s Rehabilitation and Replacement Program is driven by the condition of its wastewater
collection system assets as described above. In addition to main replacement, lower lateral
replacements are done in response to maintenance problems, follow-up to spill events, and upon
discovery by SOAP or QAQC program. Lateral repairs and replacements are performed by Wastewater
Operations as well as contractors. Approximately 200 laterals are replaced annually in addition to those
replaced as part of Sanitary Sewer Replacement (SSR) projects. Similar to main lines, lower laterals are
generally replaced by pipe bursting with HDPE pipe.
4.4 Training
Training includes City-specific issues, such as operation of its key pieces of equipment, as well as general
safety and operational issues, the SSMP and Spill Emergency Response Plan (SERP). The City uses both
contracted and in-house training services and requires training or certification of conformance of
training of contractors on its SERP and spill response procedures.
4.4.1 City Staff
Wastewater Operations uses a combination of in-house classes, on-the-job training, conferences,
seminars, and other training opportunities to provide technical training for its wastewater collection
system staff. Vendors provide training for new tools or equipment. A portion of weekly meetings are
dedicated to training on various wastewater topics. These short meetings prior to the start of the day’s
field work provide the opportunity for quick discussions of short topics related to specific collection
system operations issues. The sources of technical training and training materials for the City’s
wastewater collection staff are listed in Table 12 and Table 13.
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Table 12: Training Resources (Conferences, Seminars & Courses)
Organization Event Timeframe References
California Water
Environment
Association (CWEA)
State Conference April www.cwea.org
Northern Regional Safety Conference September
Santa Clara Valley Section Meetings &
collections training events & Classes
Monthly
CWEA – San Francisco
Bay Area section
Meetings and collections training
events & classes
Monthly www.cwea.org
Bay Area Clean Water
Association (BACWA)
Collection Systems
Committee
Collection System Committee meetings Monthly www.bacwa.org
Table 13: Training Materials
Organization Materials Reference
California State University
Sacramento (CSUS)
Videos, manuals, home study
courses
www.owp.csus.edu
Other potential sources of training include the Water Environment Federation specialty conferences on
collection system operations, webinars and publications that support sewer system education and
training including the City’s risk management and insurance program pools that provide specific risk-
based training for claims and risk reduction.
Wastewater Operators receive annual training on the following topics: volume estimation, storm water
pollution prevention, confined space entry, biological and chemical hazards, Vactor safety, underground
construction, gas detector use, application of overflow control materials, back injury prevention,
overflow reporting and field documentation, and the content and procedures of the SSMP. In addition,
the City provides free training and seminars on various professional development topics including
computer applications, writing, and communication skills.
Individual training records are documented and maintained by the City’s Department of Human
Resources.
4.4.2 Contractors Working on City Sewer Projects
The City requires contractors working on its wastewater collection system to have been trained on the
City’s Sanitary Sewer Overflow Emergency Response Plan or have demonstrated they have been trained
on an equivalent emergency response plan of their own. In addition, all City projects that may impact
City wastewater collection system lines or facilities, require that the emergency procedures be discussed
regularly, and especially at the pre-construction conference at the start of a project.
4.5 Equipment and Parts Inventory
A summary of major tools and equipment used by staff to maintain the City’s wastewater collection
system is shown in Table 14. The smaller tools are kept inside the service vehicles and are easily
accessible to Wastewater Operators. The larger tools and equipment are housed inside the City’s
Municipal Service Center (MSC). The City also operates a General Store that maintains spare parts and
critical operational items used by Wastewater Operations. Access outside of regular working hours is
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limited to supervisory and senior management. City vehicles are housed at the MSC as are bypass
pumps, hoses, and other items to assist in containing and mitigating spills.
Table 14: Tools and Equipment Inventory List
Item Quantity Comments
Combination Hydroflush Truck
by Vactor
2 #8748, 2015 FREIGHTLINERS
#8747, 2015 FREIGHTLINERS
Hydrojetter Truck 1 #8791, 2017 FORD
Lead Service Truck 1 #8723, 2017 PETERBILT
Lateral Maintenance Vans 2 #7509, 2015 FORD
#7215, 2017 FORD
Supervisor Truck 1 #8721, 2010 FORD
Dump Truck 1 #8802, 2003 GMC 5 yard
Dump Truck 1 #8725, 2008 PETERBILT 10 yard
HEO Backhoe 1 #8738, 2008 CATERPILLAR
Inspection CCTV Van 1 #8793, 2004 FORD video from 6” to 24” main lines
Inspection Cameras 6 Used as an assessment and inspection tool
Emergency Trailer 1 Located in MSC
Shoring Trailer 1 Located in MSC. Used for deep trenches.
6” Pump 1 Located in MSC
2” pump 3 Located in MSC
Snake/ Rooter Machine 4 Mechanical pipe cleaner. Cuts roots and debris.
Mini Snake/ Rooter Machine 1 Mechanical pipe cleaner. Cuts roots and debris.
Smoke Machine 1 Located in MSC
Spill Control Rubber Dam 2 Placed inside wastewater service vehicles
Spill Control Rubber Mat 4 Placed inside wastewater service vehicles
Gas Detector 20 Used to detect dangerous gases
Metal Detector 5 Used to locate parts of the Wastewater Collection
System
4” to 6” Pipebursting machine 1 Used for trenchless pipe replacement
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Element 5: Design and Performance Provisions
5.1 Updated Design Criteria and Construction Standards and Specifications
The City has standard specifications for installation, rehabilitation, and repair of facilities. The City of
Palo Alto Water, Gas, and Wastewater Utility Standards (Appendix I), which is updated every year,
include standard detail design criteria, products, installation procedures and testing for wastewater
facilities. The City’s Utility Standards incorporate, by reference, other City department standards and
drawings including Public Works and Traffic, technical association standards (i.e. ASTM, AASHTO,
AWWA), and CALTRANS standards.
The current Utility Standards are posted on the City website:
https://www.cityofpaloalto.org/Departments/Utilities/Utilities-Services-Safety/Engineering-and-
Operations
A summary of the City of Palo Alto Water, Gas, and Wastewater Utility Standard Sections, relevant to
SSMP implementation and collection system design and rehabilitation are included in Table 15. As these
Utility Standards are periodically updated, please note that this summary is provided for convenience
only. Consult the website listed above for the most current version of the Utility Standards
Table 15: Relevant Sections of City of Palo Alto WGW Utility Standards
Section Title Section Number
Excavation, Backfill, and Restoration 2200
Polyethylene Pipe Installation for Water, Gas and Wastewater 2300
Wastewater Design and Construction Standards 2730
Vitrified Clay Sewer Pipe 2731
Polyvinyl Chloride Sewer Pipe 2733
Sewer Construction with Polyethylene Pipe 2735
Cured-in-Place Pipe (CIPP) 2736
Sanitary Sewer Lateral 2737
Statewide Waste Discharge Requirements
The Plan must include the following items as appropriate and applicable to the Enrollee’s system:
5.1. Updated Design Criteria and Construction Standards and Specifications
Updated design criteria, and construction standards and specifications, for the construction,
installation, repair, and rehabilitation of existing and proposed system infrastructure components,
including but not limited to pipelines, pump stations, and other system appurtenances. If existing
design criteria and construction standards are deficient to address the necessary component-specific
hydraulic capacity as specified in section 8 (System Evaluation, Capacity Assurance and Capital
Improvements) of this Attachment, the procedures must include component-specific evaluation of
the design criteria.
5.2. Procedures and Standards
Procedures, and standards for the inspection and testing of newly constructed, newly installed,
repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances.
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Section Title Section Number
Concrete Manholes 2738
Cleaning and Video Inspection of Sewer Pipe 2739
Wastewater Standard Details Appendix D
5.2 Procedures and Standards
Inspection, testing, and repair standards are included in the appropriate Section of the Utility Standards related
to the pipe material described above. All new construction plans are required to be prepared by a registered
civil engineer and submitted to the City for review and approval prior to construction. The City has five full time
inspectors to monitor the construction of CIP projects and customer service installations to ensure compliance
with the City’s specifications.
All City and private projects must be tested according to the requirements outlined in the specifications prior to
consideration for City acceptance for maintenance. In addition, record drawings of all final project elements
must be submitted and approved by WGW Engineering prior to final acceptance of any project on City
infrastructure.
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Element 6: Spill Emergency Response Plan
6.1 Introduction
The State Water Resources Control Board (SWRCB) has issued statewide waste discharge requirements
for sanitary sewer systems, which include requirements for development of an SSMP. The State Water
Board requirements are outlined in Order No. WQ 2022-0103-DWQ Statewide General Waste Discharge
Requirements General Order for Sanitary Sewer Systems, dated December 6, 2022, which supersedes the
previous Order No. 2006-0003-DWQ, dated May 2, 2006, and amended by Order No. 2013-0058-EXEC, dated
July 30, 2013. In addition, the City’s NPDES Permit, No. CA0037834 incorporates the requirements to comply
with the SSO WDR by reference in the treatment plant permit to operate Order No. R2-2014-0024 that
regulates the Palo Alto Regional Water Quality Control Plant and City of Palo Alto’s sewage collection system.
Statewide Waste Discharge Requirements
The Plan must include an up-to-date Spill Emergency Response Plan to ensure prompt detection and
response to spills to reduce spill volumes and collect information for prevention of future spills. The
Spill Emergency Response Plan must include procedures to:
• Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill
in a timely manner;
• Notify other potentially affected entities (for example, health agencies, water suppliers, etc.) of
spills that potentially affect public health or reach waters of the State;
• Comply with the notification, monitoring and reporting requirements of this General Order, State
law and regulations, and applicable Regional Water Board Orders;
• Ensure that appropriate staff and contractors implement the Spill Emergency Response Plan and are
appropriately trained;
• Address emergency system operations, traffic control and other necessary response activities;
• Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance
system;
• Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of
the State;
• Remove sewage from the drainage conveyance system;
• Clean the spill area and drainage conveyance system in a manner that does not inadvertently
impact beneficial uses in the receiving waters;
• Implement technologies, practices, equipment, and interagency coordination to expedite spill
containment and recovery;
• Implement pre-planned coordination and collaboration with storm drain agencies and other utility
agencies/departments prior, during, and after a spill event;
• Conduct post-spill assessments of spill response activities;
• Document and report spill events as required in this General Order; and
• Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update the
Plan as needed.
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Purpose
The purpose of this Spill Emergency Response Plan (SERP) is to provide City Staff task prioritization and a
reference point in effectively responding to spill events. This SERP provides guidelines for City Staff to
follow in responding to, cleaning, and reporting spills.
Table 16: Spill Categories and Definitions
Category Definition
Category 1 A spill of any volume of sewage from or caused by a sanitary sewer
system regulated under the General Order that results in a discharge
to:
• A surface water, including a surface water body that
contains no flow or volume of water; or
• A drainage conveyance system that discharges to surface
waters when sewage is not fully captured and returned to
the sanitary sewer system or disposed of properly.
Any spill volume that is not recovered from a drainage conveyance
system is considered a discharge to surface water, unless the drains
conveyance system discharges to a dedicated stormwater infiltration
basin or facility.
Category 2 A spill of 1,000 gallons or greater, from or caused by a sanitary sewer
system regulated under the General Order that does not discharge
to a surface water
Category 3 A spill of equal to or greater than 50 gallons and less than 1,000
gallons, from or caused by a sanitary sewer system regulated under
the General Order that does not discharge to a surface water.
Category 4 A spill of less than 50 gallons, from or caused by a sanitary sewer
system regulated under the General Order that does not discharge
to a surface water.
Enrollee Owned/Operated Lateral Spills A spill of any volume from an Enrollee’s owned and/or operated
lateral that is caused by a failure or blockage in the lateral and that
do not discharge to a surface water.
Private Lateral Sewage Discharge (PLSD) A spill of untreated or partially treated wastewater resulting from
blockages or other problems within a privately owned sewer lateral
connected to the Enrollee’s sanitary sewer system or from other
private sewer assets.
6.2 SERP Goals
• Prevent public health hazards by minimizing public exposure to spilled wastewater
• Protect the environment by preventing spills from entering storm drains and receiving water
• Comply with regulations
• Minimize the frequency of spills
• Mitigate the impact of spills
• Minimize disruptions in service
• Minimize complaints
• Provide quick response to minimize spill volume
• Prevent unnecessary damage to public/private property
• Provide immediate, responsive, and efficient service to all emergency calls
• Provide a safe work environment for employees, employers, and residents
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• Perform all operations in a safe manner to prevent personal injury
6.3 Spill Detection and Notification
The Dispatch Center is responsible for collecting the following information from all collection system
related incoming calls:
• Time and date of call
• Assigns an Incident Number
• Specific location of potential problem
• Nature of call
• In case of spill, estimated start time of overflow
• Reporting Party’s name and phone number
• Reporting Party’s observation (e.g., odor, duration, location on property, known impacts, indication if
surface water impacted, appearance at cleanout or manhole)
• Other relevant information
The Dispatch Center assigns a unique Incident Number which is used to track subsequent actions taken
in response to the call. The Dispatch Center immediately notifies staff on the Emergency Response
Notification Team (ERNT) of a call through a text/email notification. The list of individuals on the ERNT is
included in Table 17 below.
The Dispatch Center’s text/email notification to the ERNT consists of the following information:
• Incident number
• Location
• Reporting Party’s Name
• Reporting Party’s phone number
Table 17: Text/Email for Emergency Response Notification Team (ERNT)
Name Email Phone
Wastewater Operations ERT N/A 650-213-2633
Standby Operations Primary N/A 650-444-6198
Standby Operations Secondary N/A 650-444-5290
WGW Operations Mainline wgw.operations@cityofpaloalto.org 650-496-6982
Anthony Meneses, Manager anthony.meneses@cityofpaloalto.org 650-496-6907
Robert Bishop, Supervisor (Interim) robert.bishop@cityofpaloalto.org 650-329-2218
Abel Silva, Supervisor abel.silva@cityofpaloalto.org 650-496-6972
Todd Carlsen, Supervisor todd.carlsen@cityofpaloalto.org 650-444-6334
Eric Talley, Supervisor eric.talley@cityofpaloalto.org 650-496-6917
David Cordova, Supervisor david.cordova@cityofpaloalto.org 650-444-6967
Venessa Fujii, Utility Project Coordinator venessa.fujii@cityofpaloalto.org 650-496-6994
Within the ERNT is the Emergency Response Team (in bold italic font) who will respond to the incident.
The ERT consists of Installer-Repairer class staff who are scheduled for ERT at the beginning of the day
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and will respond during regular business hours. Standby Operations Primary and Secondary responders
will respond outside of normal business hours.
The Dispatch Center records communications between callers, responders and any other supporting
staff that is dispatched to the spill scene. Figure 6 contains a flow chart of this Spill Detection and
Dispatch process.
Depending on the time of the call, the Dispatch Center uses the schedule shown in Table 18 to dispatch
a response team.
Table 18: Schedule for Dispatching a Response Team
Days Time Spill Response Team
Weekdays* 0630 to 1600 Wastewater, Emergency Response Team (ERT)
1600 to 0630 Standby, Primary and Secondary Responder
Saturdays 24hr Response Standby, Primary and Secondary Responder
Sundays & Holidays 24hr Response Standby, Primary and Secondary Responder
*On Fridays, Standby receives sewer related calls starting at 1500 hours
6.3.1 Public Observation
The Public can report spills by calling one of the following numbers:
Palo Alto Utilities Emergency Water, Gas, and Wastewater Dispatch Center at (650)329-2579
Palo Alto Police Non-Emergency at (650)329-2413
Or the Emergency 911 number.
These phone numbers are included in monthly utility bills sent to customers and on the City’s website.
Spill related calls from the public are routed through the City’s 24-hour Dispatch Center.
6.3.2 City Staff Observation
Spill related calls that are received by other departments and/or observed by Utilities Staff during their
normal working hours are also routed to the Dispatch Center for proper documentation and tracking.
6.3.3 Alarms
The City of Palo Alto’s lift station is controlled by SCADA and maintained by the Utilities Operators. In
case of any pump failure, the high level sensor activates the SCADA alarm system and the Utilities
Communication Center (UCC) is contacted. Under this situation, the UCC serves the role of the City
Dispatch by contacting the ERNT via text.
Wastewater Operations has contracted Gierlich-Mitchell, Inc to install and activate 39 sanitary sewer
level monitoring alarms in hot spot areas throughout the City. The manhole alarm service and
equipment, Mission M84 Manhole Monitor+, is supplied by Mission Communications
(https://www.123mc.com/123mc/log_in.asp). High level alarms will send a text message to the ERNT.
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The status of each monitor can be accessed through Mission Communication’s online portal. Mission
Communications also provides technical support at (877) 993-1911.
6.3.4 Coordination with Public Works Departments
If the spill is caused by FOG or an illicit discharge the WW Project Coordinator or WW Supervisor will
notify the Public Works’ Watershed Protection Group and coordinate a joint spill response to mitigate
the spill. Once the spill has been eliminated the Wastewater Department will coordinate with Public
Works’ to implement a plan to prevent the spill from occurring again and if applicable apply fines and
fees to the responsible party.
6.4 Spill Response Procedures
The Wastewater Operations Division has created a section withing the Wastewater Standard Operating
Procedures for Emergency Response. These Wastewater Standard Operating Procedures are attached as
Appendix J.
The Responder ensures all safety procedures are strictly adhered to, including traffic control, PPE
(visibility vests, hard hats, safety glasses, gloves, etc.) as well as confined space entry procedures at all
times.
6.4.1 ERT and Standby Responder Priorities
ERT and Standby Responder priorities are:
1. To follow safe work practices;
2. To respond promptly with the appropriate equipment;
3. To minimize public access to and/or contact with the spilled sewage;
4. To contain the spill;
5. To restore the flow as soon as possible;
6. To promptly notify the Supervisor in the event of a major spill;
7. To return the spilled sewage to the sewer system and;
8. To restore the area close to its original condition.
6.4.3 Initial Response
During Regular Hours, the Emergency Response Team will:
1. Be dispatched an 868 (Overflow) by Radio from the Dispatch Center.
a. If unanswered, Dispatch will then call the ERT Phone and the Wastewater Supervisor.
2. Document the address or location, call received time from Reporting Party to Dispatch, call received
time from Dispatch to ERT, Incident Number, Reporting Party Name and number, and notes
provided by Dispatch.
3. Call the Reporting Party and ask to verify that a spill or blockage is occurring.
4. Ask the Reporting Party where the spill is occurring. (cleanout, manhole, public, private, etc.)
a. If the spill is from a cleanout, inform the Reporting Party not to use water to minimize the spill.
5. Ask the Reporting Party for the Spill Start Time.
6. Inform Reporting Party of the estimated Responder arrival time.
7. Contact/coordinate with ERT Flush Team for cleanup if the spill is a minor event, Category 3, 4.
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8. Contact/coordinate with the ERT Flush Team and Wastewater Supervisor if the spill is a major event,
Category 1 or 2. (Wastewater Supervisor must call Cal OES within 2 hours of knowledge of 1,000
gallon or greater spill threatening surface water.)
9. Notify Dispatch of their arrival once onsite.
10. Verify extent of spill, document Arrival Time and photographs scene.
11. If spill has reached Public Works’ storm drain and assistance is needed to collect the spill, the ERT
Team will call the Public Works Department at (650)496-6974.
During After Hours
(Monday – Thursday 4PM – 6:30AM, Friday 3PM – 6:30AM, Saturday and Sunday all day) Standby
Responders will:
1. Be dispatched an 868 (Overflow) by Primary Phone from the Dispatch Center.
a. If unanswered, Dispatch will call the Standby Secondary and lastly the Standby Supervisor.
2. Document the address or location, call received time from Reporting Party to Dispatch, call
received time from Dispatch to ERT, Incident Number, Reporting Party name and number, and
notes provided by Dispatch.
3. Call the Reporting Party and ask to verify that a spill or blockage is occurring.
4. Ask the Reporting Party where the spill is occurring. (cleanout, manhole, public, private, etc.)
a. If the spill is from a cleanout, inform the Reporting Party not to use water to minimize the spill.
5. Ask the Reporting Party for the Spill Start Time.
6. Inform Reporting Party of the estimated Responder arrival time.
7. Contact/coordinate with Standby Secondary for cleanup if the spill is a minor event, Category 3 or 4.
8. Contact/coordinate with Standby Secondary for cleanup and Standby Supervisor if the spill is a major
event, Category 1 or 2. (Standby Supervisor must call Cal OES within 2 hours of knowledge of 1,000 gallon
or greater spill threatening surface water.)
9. Notify Dispatch of their arrival once onsite.
10. Verify extent of spill, document Arrival Time and photographs scene.
11. If spill has reached Public Works storm drain and assistance is needed to collect the spill, the ERT
Team will call the afterhours Public Works Department at (650)329-2413.
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Figure 6: Process flow chart for the notification of a potential Spill
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6.4.4 Initiate Spill Containment Measures
Once at the scene, the Responder should attempt to contain the overflow to the best of their ability by:
1. Determining the immediate destination of the overflow.
2. Protect nearby catch basins that lead to the storm drain system and surface water by creating a dam with
sandbags, spill mats, spill shark or dirt found nearby to dam/redirect the overflow.
3. Referencing the storm drain collection system map to identify and block the downstream storm drain so
that the wastewater can be collected.
6.4.5 Restore Flow
If the blockage is in the public lower lateral, setup the electric rodder at the City cleanout to clear the
blockage, see Appendix K Electric Rodder Standard Operating Procedures.
If the blockage is in the private upper lateral, Initiate Spill Containment Measures as in Section 6.4.4 and have
Private Owner call a plumber. The ERT or Standby Responders will assist with clean-up to prevent wastewater
entering storm drain. If the overflow is greater than 1,000 gallons and has resulted or may result in a discharge
to surface water, the ERT should contact the scheduled Supervisor, who is strongly encouraged to notify the
California Office of Emergency Services.
If the blockage is in the public main, reference the Wastewater Collections System Map and check every
manhole downstream of the blockage. If sewage is “up” or overflowing at the manhole, then the blockage is
further downstream. Keep checking downstream manholes until you find a manhole that is barely flowing or
“down”. During regular hours, the ERT is responsible for locating the “down” manhole and communicating the
setup to the Flush ERT. After hours, the Standby Primary is responsible for locating the “down” manhole and
communicating the setup to the Standby Secondary. See Appendix L Flush Truck Standard Operating
Procedures.
If the blockage is in the private main, verify that ownership by referencing the Wastewater Collection System
Map (all city assets are assigned Identification Numbers). Initiate Spill Containment Measures listed in Section
6.4.4 and have the Private Owner call a plumber. The ERT or Standby Responders will assist with clean-up to
prevent wastewater from entering the storm drain. If the overflow is greater than 1,000 gallons and has resulted
or may result in a discharge to surface water, the ERT should contact the scheduled Supervisor, who is strongly
encouraged to notify the California Office of Emergency Services.
6.5 Spill-Specific Monitoring Requirements
6.5.1 Spill Location and Spread
Responders shall visually assess the spill location(s) and spread using photography, global position
system (GPS), and other best available tools. The Responders shall document the critical spill locations,
including:
1. Photography and GPS coordinates for:
a. The system location where spill originated.
i. For multiple appearance points of a single spill event, the points closest to the spill origin.
2. Photography for:
a. Drainage conveyance system entry locations,
b. The location(s) of discharge into surface waters, as applicable,
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c. Extent of spill spread, and
d. The location(s) of clean up.
6.5.3 Receiving Water Visual Observations
Through visual observations and spill volume estimating techniques the ERT shall document the
following information regarding spills to surface water:
1. Estimated spill travel time to the receiving water;
a. For spills entering a drainage conveyance system, estimated spill travel time from point of entry
into the drainage conveyance system to the point of discharge into the receiving water;
2. Estimated spill volume entering the receiving water; and
3. Photography of:
a. Waterbody bank erosion,
b. Floating matter,
c. Water surface sheen,
d. Discoloration of receiving water, and
e. Impact to the receiving water.
6.5.2 Receiving Water – Water Quality Sampling and Analysis
Water quality sampling procedures for Responders are:
1. Contact the Public Works, Environmental Services Division, Watershed Protection Group (during
business hours only) for technical assistance with water quality sampling;
2. Samples should be collected as soon as possible by the Responder after the discovery of the spill
event. Sample kits are stored in the ERT van and at the Municipal Service Center for immediate use
by responders.
3. If the spill is 50,000 gallons or greater, collect samples within 18 hours of becoming aware of the
spill.
a. Collect one water sample each day of the duration of the spill at the point a point in the
drainage conveyance system before the drainage conveyance system flow discharges into a
receiving water (if the spill is discharging via a drainage conveyance system)
b. Collect one water sample each day for the duration of the spill at the three receiving water
sampling locations:
i. Upstream: This sample will be collected far enough upstream of the spill’s point of entry
into the surface water as to be free of contaminants from the spill. Typically, 50 feet is
sufficient, but this may vary on circumstances of the spill.
ii. Source: Immediate vicinity where the spill entered the surface water. This point will be
downstream of the actual spill entry point for spills that have stopped entering the surface
water to be sampled. If the spill has stopped, calculate the approximate downstream
distance from the original spill location by dividing the time since the spill occurred by the
estimated velocity. This is the approximate downstream distance from the spill discharge
point to the “source” sampling location.
• Due to tidal action in the surface water or other factors, another method maybe used to
determine the “source” location at the discretion of the scheduled Supervisor.
iii. Downstream: This sample will be collected far enough downstream to be representative of
the water quality of the surface water after adequate mixing of the surface water and the
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spill have occurred. Typically, this location will be 50 feet downstream of the “source”
sampling, but this may vary on the size and velocity of the surface water to be sampled.
c. If there is no flow during the duration of the spill, the CIWQS report must reflect “No Sampling
Due To No Flow” for its receiving water sampling locations.
4. Samples shall be transported to the Regional Water Quality Control Plant Laboratory at 2501
Embarcadero Way, Palo Alto, CA 94303.
a. Samples are accepted 6AM – 5PM, if outside of normal business hours must make arrangements
with Lab Manager or Senior Chemists
Table 19: Contact Phone Numbers for Laboratory
Main Lab Phone Number (650)617-3169
Manager of Laboratory Services (650)329-2334
After Hours Phone Numbers (650)269-3298 or (408)666-7130
6.5.3 Water Quality Analysis Specifications
The collected samples shall be analyzed for the following constituents:
1. Ammonia, and
2. Appropriate bacterial indicator(s) per the applicable Basin Plan water quality objectives, including
one or more of the following , unless directed otherwise by the Regional Water Board:
a. Total Coliform Bacteria
b. Fecal Coliform Bacteria
c. E-coli
d. Enterococcus
Sampling of these bacterial indicators shall meet the water quality objectives and bacterial
standards of the California Ocean Plan or the California Inland Surface Water Enclosed Bays, and
Estuaries Plan.
3. Additional sampling and analysis required by the Regional Water Board Executive Office or designee
Sample analysis must be completed using a sufficiently sensitive test method that complies with 40
Code of Federal Regulations Part 136. A method is considered sufficiently sensitive when the minimum
level of the analytical method is at or below the receiving water pollutant criteria. Furthermore, water
quality samples must be conducted by a laboratory that has accreditation pursuant to Article 3, Section
100825 of Chapter 4 of Part 1 of Division 101 of the Health and Safety Code. The City’s Regional Water
Quality Control Laboratory meets these accreditations and is recognized by the State Water Board
through its Environmental Laboratory Accreditation Program (ELAP).
6.6 Recovery and Cleanup
The recovery and cleanup phase begin when the flow has been restored and the spilled sewage has
been contained to the best of the Responder’s ability. The spill recovery and cleanup procedures are:
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6.6.1 Estimate the Volume of Spilled Sewage
To estimate the volume of spilled sewage, use the methods outlined on the third page of the WGW
Operations Spill Report Form, see Appendix C. When possible, document the estimate using photos of
the spill before and during the recovery procedure.
6.6.2 Recovery of Spilled Sewage
If the spill is in a drainage conveyance system, the Operator must, to the best of their ability, recover the
total volume of the spill with minimum impact to the environment, public, and private properties.
Detailed instructions of how to recover the spill from a storm drain are in the Wastewater SOP. The
Operator should utilize the vacuum and/or pump the overflow and discharge it back into the sanitary
sewer system.
6.6.3 Cleanup and Disinfection
Cleanup and disinfection procedures should be implemented to protect public health and the
environment from a spill. The procedures described are for dry weather conditions and should be
modified as required for wet weather conditions.
Private Property
If an overflow occurs due to a blockage in a private lateral or private sewer system but has the potential to
impact public property, the Responders will take action to contain, cleanup, and disinfect the spilled sewage.
However, if it does not have a potential to impact public property and surface water – It is the Property
Owners responsibility to clean and restore the site.
If the spill was caused by the City owned lateral or sewer system and has compromised private property,
advise the Owner of the property of the City claims procedure, see
https://www.cityofpaloalto.org/civicax/filebank/documents/29341 for the Claims Form. If they are not onsite,
leave a Door Hanger with relevant information.
Paved Surface Area
Take steps to contain and vacuum the wastewater. Collect all signs of sewage by hand, broom and shovel and
push all wastewater debris toward the vacuum on the combo flush truck or position the vacuum over affected
area and collect. Wash down the affected area with clean water until the water runs clear and push all
wastewater and debris toward the vacuum on the combo flush truck. Apply disinfectant by using a bottle
sprayer and disinfect all areas that were contaminated from the overflow. Wash down and vacuum again if
additional cleaning is required.
Unpaved Surface Areas (Landscaping & Unimproved Natural Vegetation)
Take steps to contain and vacuum the wastewater. Collect all signs of sewage by hand, broom and shovel and
push all wastewater debris toward the vacuum on the combo flush truck or position the vacuum over affected
area and collect. Allow area to dry, repeat the process if additional cleaning is required.
Natural Waterways
The scheduled Supervisor is responsible for determining the proper course of action for Category 1 Spills.
They will utilize the wastewater collection system map, storm drain collection system map and other
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documentation to minimize the impact of the overflow to the environment and protect public health. If a spill
is confirmed to have entered a creek or waterway, the scheduled Supervisor and the WGW Operations
Manager are immediately notified. The scheduled Supervisor may request additional assistance, if needed,
from City staff and/or outside agencies that are the wastewater treatment plant partners (City of Mountain
View, City of Los Altos, Town of Los Altos Hills, Stanford University, and the East Palo Alto Sanitary District).
The Responders are responsible for the following when Natural Waterways are affected:
1. Determines the extent of the spill by investigating downstream until there is no evidence of sewage or
debris along the creek or water body.
2. Contact the Public Works, Environmental Services Division, Watershed Protection Group (during business
hours only) for technical assistance with water quality sampling.
3. Immediately post contaminated water sign(s) and protect the creek from public access on both sides,
Appendix F.
4. Photographs sign placement and evidence of the overflow in and around the creek to the farthest point
reached by the sewage.
5. Determines if the creek is safe to enter. During the winter storm season, cleaning the creek may not be
feasible due to high water flows.
6. If feasible, blocks the creek downstream of the affected area in a location that is safe to enter and is
accessible to set up a pump or utilize combo flush trucks.
7. To extent feasible, recover and return contaminated water to the collection system;
8. If the spill is 50,000 gallons or greater, collects water quality samples within 18 hours of becoming aware
of the spill.
9. Follow up sampling will be performed until the area shows no water quality impairment and the posted
signs can be removed. The Utilities Director ultimately determines when this happens and makes any
follow up calls to affected agencies.
6.6.4 Safety and Access Exceptions
For safety, omit sampling during heavy storm events with heavy runoff where flushing is not feasible
and sampling would not provide meaningful results. The Wastewater Supervisor or their designee, must
document the access restrictions or unsafe conditions that prevent them from completing the
appropriate spill response or water quality monitoring. This documentation should be included in the
Certified Report.
6.7 Notification Requirements
6.7.1 2 Hour Required Notification to California Office of Emergency Services
The State Water Resource Control Board Order No. 2022-0103-DWQ states that the California Office of
Emergency Services (OES) is only to be notified of a Category 1 or 2 Spill greater than or equal to 1,000
gallons discharged to waters of the State or spilled in a location where it probably will be discharged to
waters of the State. The Utilities Supervisor is responsible for reviewing field data to report to regulatory
agencies. If it is determined that the criteria for OES notification was met, the Utilities Supervisor must
notify Cal OES of the event no later than two (2) hours after:
1. The City has knowledge of the spill;
2. Notification can be proved without substantially impeding cleanup or other emergency measures.
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The Cal OES phone number is (800) 852-7550. The Utilities Supervisor is response for obtaining an OES
Control Number.
Spill Notification Information
The Utilities Supervisor shall provide the following information, as applicable, regarding the spill to Cal
OES before receiving a Control Number:
1. Name and phone number of the person notifying the Cal OES;
2. Estimated spill volume (gallons);
3. Estimated spill rate from the system (gallons per minute);
4. Estimated discharge rate (gallons per minute) directly into waters of the State or indirectly into a drainage
conveyance system;
5. Spill incident description:
6. Brief narrative of the spill event, and
7. Spill incident location (address, city, and zip code) and closest cross streets and/or landmarks;
8. Name and phone number of contact person on-scene;
9. Date and time the Enrollee was informed of the spill event;
10. Name of sanitary sewer system causing the spill;
11. Spill cause or suspected cause (if known);
12. Amount of spill contained;
13. Name of receiving water body receiving or potentially receiving discharge; and
14. Description of water body impact and/or potential impact to beneficial uses.
Notification of Spill Report Updates
Following the initial notification to Cal OES and until the spill report is certified in the CIWQS online
database, the Utilities Supervisor must provide updates to Cal OES regarding substantial changes to
estimated volume of untreated or partially treated sewage discharged and any substantial changes to:
1. Estimated spill volume (increase or decrease in gallons initially estimated);
2. Estimated volume discharged directly into waters of the State or indirectly into a drainage conveyance
system (increase or decrease in gallons initially estimated); and
3. Additional impact(s) to the receiving water(s) and beneficial uses.
6.7.3 Notification to Santa Clara County Health Department
Wastewater Supervisor or their designee, will send an email to dehweb@deh.sccgov.org or call
(408)918-3400 during working hours. Details of the spill should be included and that Cal OES was
notified. Any correspondence with the County Health Department should also include carbon copies to
the WGW Operations Manager and the Wastewater Supervisor.
6.7.4 Notification to Santa Clara Valley Water District
If the spill affects or threatens water bodies operated or maintained by the Santa Clara Valley Water
District (SCVWD) the Wastewater Supervisor or their designee will contact the SCVWD Pollution Hotline
at 1-888-510-5151 with spill details.
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6.7.5 Media Notification Procedure
When an overflow is substantial and confirmed to be a significant public health threat, the following actions
should be taken, if deemed necessary by City staff, to notify the media:
1. The scheduled Supervisor or the WGW Operations Manager will contact the Utilities Communications
Manager (UCM) and provide a spill status report.
2. The UCM is responsible for contacting and updating the media.
3. Any calls from the media should be routed to the UCM.
4. The following personnel are designated spokespersons and authorized to release information on the
incident and be interviewed by the media:
Table 20: Media Notification Personnel
Name Position Office Phone Cell Phone
Catherine Elvert Utilities Communications Manager 650-329-2417 650-833-9433
Matt Zucca Utilities WGW Assistant Director 650-566-4506
6.9 External Spill Reporting Requirements
All spill reports are to be electronically submitted to the California Integrated Water Quality System (CIWQS)
Sanitary Sewer System Database (https://ciwqs.waterboards.ca.gov/). Spill reports will be uploaded by the Data
Submitter and certified by the Legally Responsible Official within the time frames set forth in the WDR.
Any information that is protected by the Homeland Security Act can be emailed to
sanitarysewer@waterboards.ca.gov. A brief justification letter should also be included.
6.9.1 Category 1 Spill Reporting
Draft Spill Report for Category 1 Spills
Within 3 business days of being notified of the spill event -- the Water Gas Wastewater Operations Manager
(WGW Operations Manager), or their designee, will submit a Draft Spill Report using the online CIWQS Sanitary
Sewer System Database. This Draft Spill Report must include the following:
1. Contact information: Name and telephone number of City employee who can respond to spill specific
questions;
2. Spill location name;
3. Date and time the Enrollee was notified of, or self-discovered, the spill;
4. Operator arrival time;
5. Estimated spill start date and time;
6. Date and time the City notified CalOES, and the assigned control number;
7. Description, photographs, and GPS coordinates of the system location where the spill originated;
a. If there is more than one appearance point, provide GPS coordinates for the appearance point closest
to the failure point and describe the other appearances points in the explanation field;
8. Estimated spill volume exiting the system;
9. Description and photographs of the extent of the spill and spill boundaries;
10. Did the spill reach a drainage conveyance system? If Yes:
a. Description of the drainage conveyance system transporting the spill
b. Photographs of the drainage conveyance system entry location(s);
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c. Estimated spill volume fully recovered from the drainage conveyance system;
d. Estimated spill volume remaining within the drainage conveyance system;
11. Description and photographs of the all discharge point(s) into the surface water;
12. Estimated spill volume that discharged to surface waters; and
13. Estimated total spill volume recovered.
Certified Spill Reports for Category 1 Spills
Within 15 calendar days of the spill end date -- the WGW Operations Manager, or their designee, will certify the
final report using the online CIWQS Sanitary Sewer System Database. The Certified Spill Report must include
the following in addition to the Draft Spill Report:
1. Description of spill event destination(s), including GPS coordinates if available, that represent the full spread
and reach of the spill;
2. Spill end date and time;
3. Description of how the spill volume estimations were calculated, including at a minimum:
a. The methodology, assumptions and type of data relied upon, SCADA records, flow monitoring or other
telemetry information used to estimate the volume of the spill discharged, and the volume of the spill
recovered (if any volume of the spill was recovered), and
b. The methodology(ies), assumptions and type of data relied upon for estimations of the spill start time
and the spill end time;
4. Spill cause(s);
5. System failure location;
6. Description of the pipe material, and estimated age of the pipe material, at the failure location;
7. Description of the impact of the spill;
8. Whether or not the spill was associated with a storm event;
9. Description of spill response activities including description of immediate spill containment and cleanup
efforts;
10. Description of spill corrective action, including steps planed or taken to reduce, eliminate, and prevent
reoccurrence of the spill, and a schedule of major milestones for those steps;
11. Spill response completion date;
12. Detailed narrative of investigation and investigation findings of cause of spill;
13. Reasons for an ongoing investigation (as applicable) and the expected date of completion;
14. Name and type of receiving water body(s);
15. Description of the water body(s), including but not limited to:
a. Observed impacts on aquatic life,
b. Public closure, restricted public access, temporary restricted use, and/or posted health warnings due
to spill,
c. Responsible entity for closing /restricting use of water body, and
d. Number of days closed/restricted as a result of the spill.
16. Whether or not the spill was located within 1,000 feet of a municipal surface water intake; and
17. If water quality samples were collected, identify sample locations and the parameters the water quality
samples were analyzed for. If no samples were taken, Not Applicable shall be selected.
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Spill Technical Report for Individual Category 1 Spill in which 50,000 Gallons or Greater Discharged into a
Surface Water
Within 45 days calendar days of the spill end date – the WGW Operations Manager, or their designee, will
submit a Spill Technical report. If 50,000 gallons or greater from a spill reaches surface waters, an Spill Technical
Report must be prepared and submitted to the CIWQS online spill database within 45 calendar days of the spill
end date. The Spill Technical Report must include, at a minimum, the following:
1. Causes and Circumstances of the spill:
• Detailed explanation of how and when spill was discovered;
• Photographs illustrating spill origin the extent and reach of the spill, drainage conveyance system
entrance and exit, receiving water, and post cleanup site conditions;
• Diagram indicating spill failure point, appearance point, spill flow path, and final destination (use
attachments, maps and diagrams as needed);
• Detailed description of methodology employed and available data used to calculate the spill volume
and any volume recovered;
• Detailed description of the spill cause(s);
• Description of the pipe material, and estimated age of the pipe material, at the failure location;
• Description of impact of the spill;
• Copies of the original field crew records used to document the spill (attachment); and
• Historical maintenance records for the lines involved in the cause of the spill.
2. Agency’s Response to spill:
• Chronological narrative description of actions taken by agency to terminate the spill;
• Description of how the SERP was implemented to respond to and mitigate any impacts of the spill; and
• Final corrective action(s) completed, including a schedule for actions not yet completed which include:
a. Local regulatory enforcement action applied to an illicit discharge;
b. Operational and maintenance program changes to prevent the spill from occurring again; and
c. Necessary modifications to the SERP to incorporate lessons learned in.
3. Water Quality Monitoring:
• Description of all water quality sampling activities conducted, including analytical results and evaluation
of the results;
• Detailed location map illustrating all water quality sampling points.
• List of pollutant and parameters monitored, sampled, and analyzed;
• Laboratory results/reports; and
• Other regulatory agencies receiving sample results (if applicable).
4. Evaluations
• Short-term and long-term impact(s) spill impact(s) to beneficial uses of the surface water
The WGW Operations Manager or other designated LRO is responsible for the development and certification of
the Spill Technical Report.
Amended Certified Spill Reports for Individual Category 1 Spills
The WGW Operations Manager, or their designee, will update the Certified Report as new or amended
information becomes available. Reports can only be amended within 90 calendar days after spill end date.
Amended report needs to be certified by the LRO. After 90 calendar days, the WGW Ops Manager or their
designed will need to contact the State Water Board at sanitarysewer@waterboards.ca.gov to request to
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amend a Spill Report. The LRO must include justification for why the amended information was not reported
within the 90 calendar days.
6.9.2 Category 2 Spill Reporting
Draft Spill Report for Category 2 Spills
Within 3 business days of being notified of the spill event, the Wastewater Supervisor, or their designee,
will submit a Draft Spill Report using the online CIWQS Sanitary Sewer System Database. The Draft Spill
Report must include the following:
• Contact information: Name and telephone number of City employee who can respond to spill specific
questions;
• Spill location name;
• Date and time the Enrollee was notified of, or self-discovered, the spill;
• Operator arrival time;
• Estimated spill start date and time;
• Date and time the City notified Cal OES, and the assigned control number;
• Description, photographs, and GPS coordinates of the system location where the spill originated;
o If there is more than one appearance point, provide GPS coordinates for the appearance point
closest to the failure point and describe the other appearances points in the explanation field;
• Estimated spill volume exiting the system;
• Description and photographs of the extent of the spill and spill boundaries;
• Did the spill reach a drainage conveyance system? If Yes:
o Description of the drainage conveyance system transporting the spill
o Photographs of the drainage conveyance system entry location(s);
o Estimated spill volume fully recovered from the drainage conveyance system;
o Estimated spill volume remaining within the drainage conveyance system;
• Description and photographs of the all discharge point(s) into the surface water;
• Estimated spill volume that discharged to a ground water infiltration basin or facility, if applicable; and
• Estimated total spill volume recovered.
Certified Spill Report for Category 2 Spills
Within 15 calendar days of the spill end date, the WGW Operations Manager, or their designee, will
certify the final report using the online CIWQS Sanitary Sewer System Database. In addition to the Draft
Spill Report, the Certified Report must include the following:
1. Description of spill event destinations(s) including GPS coordinates if available, that represent the
full spread and reach of the spill;
2. Spill end date and time;
3. Description of how the spill volume estimations were calculated, including at a minimum:
a. The methodology, assumptions and type of data relied upon, such as SCADA records, flow
monitoring or other telemetry information used to estimated the volume of the spill discharged,
and the volume of the spill recovered (if any volume of the spill was recovered), and
b. The methodology(ies), assumptions and type of data relied upon for estimations of the spill start
time and spill end time;
4. Spill cause(s);
5. System failure location;
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6. Description of pipe/infrastructure material, and estimated age of the material, at the failure
location;
7. Description of the impact of the spill;
8. Whether or not the spill was associated with a storm event;
9. Description of spill response activities including description of immediate spill containment and
cleanup efforts;
10. Description of spill corrective action, including steps planed or taken to reduce, eliminate, and
prevent reoccurrence of the spill, and a schedule of major milestones for those steps;
11. Spill response completion date;
12. Detailed narrative of investigation and investigation findings of cause of spill;
13. Reasons for an ongoing investigation (as applicable) and the expected date of completion;
14. Whether or not the spill was located within 1,000 feet of a municipal surface water intake.
Amended Certified Spill Reports for Category 2 Spills
The WGW Operations Manager, or their designee, will update the Certified Report as new or changed
information becomes available. Reports can only be amended within 90 calendar days after spill end
date. Amended report needs to be certified by the LRO. After 90 calendar days, the LRO will need to
contact the State Water Board at sanitarysewer@waterboards.ca.gov to request to amend a Spill Report
and include justification as to why the additional information was not reported before the due date.
6.9.3 Category 3 Spill Reporting
Monthly Certified Spill Reporting for Category 3 Spills
Within 30 calendar days after the end of the calendar month in which the spill occurs, the WGW
Operations Manager, or their designee, will submit a monthly Certified Spill Report using the online
CIWQS Database. The WGW Operations Manager, or their designee, will certify the report. The report
must include the following:
1. Contact information: Name and telephone number of the City employee who can respond to spill
specific questions;
2. Spill location name;
3. Date and time the Enrollee was notified of, or self-discovered, the spill;
4. Operator arrival time;
5. Estimated spill start date and time;
6. Description, photographs, and GPS coordinates where the spill originated:
a. If there is more than one appearance point, provide GPS coordinates for the appearance point
closets to the failure point and describe the other appearance points in the explanation field;
7. Estimated total spill volume exiting the system;
8. Description and photographs of the extent of the spill and spill boundaries;
9. Did the spill reach a drainage conveyance system? If Yes:
a. Description of the drainage conveyance system transporting the spill;
b. Photographs of the drainage conveyance system entry location(s);
c. Estimated spill volume fully recovered from the drainage conveyance system; and
d. Estimated spill volume discharged to groundwater infiltration basin or facility, if applicable.
10. Estimated total spill volume recovered;
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11. Description of the spill event destination(s), including GPS coordinates, if available, that represent
the full spread and reaches of the spill;
12. Spill end date and time;
13. Description of how the spill volume estimations were calculated, including, at minimum:
a. The methodology and type of data relied upon, including SCADA records, flow monitoring, or
other telemetry information used to estimate the volume of the spill discharged, and the
volume of the spill recovered (if any volume of the spill was recovered), and
b. The methodology and type of data relied upon to estimated the spill start time, on-going spill
rate at time of arrival (if applicable), and the spill end time;
14. Spill cause(s);
15. System failure location;
16. Description of the pipe/infrastructure material and estimated age of the pipe/infrastructure
material, at the failure location;
17. Description of the impact of the spill;
18. Whether or not the spill was associated with a storm event;
19. Description of spill response activities including description of immediate spill containment and
cleanup efforts;
20. Description of spill corrective actions, including steps planned or taken to reduce, eliminate, and
prevent reoccurrence of the spill, and a schedule of the major milestones for those steps, including,
at minimum:
a. Local regulatory enforcement action taken against an illicit discharge in response to this spill, as
applicable, and
b. Identifiable system modifications, and operation and maintenance program modifications
needed to prevent repeated spill occurrences at the same spill even location including
i. Adjusted schedule/method of preventative maintenance,
ii. Planned rehabilitation or replacement of sanitary sewer asset,
iii. Inspected, repaired asset(s), or replaced defective asset(s),
iv. Capital improvements
v. Documentation verifying immediately implemented system modifications and
operating/maintenance modifications,
vi. Description of spill response activities,
vii. Spill response completion date, and
viii. Ongoing investigation efforts, and expected completion date of investigation to determine
the full cause of spill;
21. Detailed narrative of investigation and findings of cause of spill.
Amended Certified Spill Reports for Category 3 Spills
The WGW Operations Manager, or their designee, will update the Certified Report as new or changed
information becomes available. Reports can only be amended within 90 calendar days after spill end
date. Amended report needs to be certified by the LRO. After 90 calendar days, the LRO will need to
contact the State Water Board at sanitarysewer@waterboards.ca.gov to request to amend a Spill Report
and include justification as to why the additional information was not reported before the due date.
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6.9.4 Category 4 Spill Reporting
Monthly Certified Spill Reporting for Category 4 Spills
The LRO shall report and certify the estimated spill volume exiting the sanitary sewer system, and the
total number of all Category 4 Spills to the online CIWQS Sanitary Sewer System Database within 30
calendar days after the end of the month in in which the spills occurred.
Annual Certified Spill Reporting of Category 4 and/or Lateral Spills
For all Category 4 Spills and spills from the City owned and/or operated laterals that are caused by a failure or
blockage in the lateral and that do not discharge to a surface water, the Enrollee shall:
1. Maintain records per section 6.6.4 of the SSMP
2. Annually upload and certify a report, in an appropriate digital format, of all recordkeeping of spills to the
online CIWQS Sanitary Sewer System Database, by February 1st after the end of the calendar year in which
the spills occurred.
6.9.5 Monthly Certification of “No Spills”, Category 4 Spills, and/or Non-Category 1 Lateral Spills
If either (1) no spills occur during a calendar month or (2) only Category 4, and/or Enrollee-owned
and/or operated lateral spills (that do not discharge to a surface water) occur during a calendar month,
the Enroll shall certify, within 30 calendars days after the end of each calendar month, either a “No
Spill” certification statement, or a “Category 4 Spills” and/or “Non-Category 1” certification statement in
the online CIWQS Sanitary Sewer System Database, certifying that there were either no spills, or
Category 4 and/or Non-Category 1 Laterals Spills that will be reported annually for the designated
month.
6.9.6 Private Lateral Sewer Discharge (PLSD)
Discharges of untreated or partially treated wastewater resulting from blockages or other problems within a
privately owned sewer lateral connected to the enrollee’s sanitary sewer system or from other private sewer
assets that the enrollee becomes aware of may be voluntarily reported to the CIWQS Online Spill Database.
6.9.7 CIWQS Not Available
If the CIWQS online spill database is not available, the Wastewater Collection Supervisor will fax or e-mail all
required information to the RWQCB office at (510) 622-2460. In such an event, the City will submit the
appropriate reports using the CIWQS online spill database when the database becomes available. A copy of all
documents that certify the submittal in fulfillment of this section shall be retained in the Spill document file.
6.10 Internal Spill Reporting Procedures
All spills should be investigated and thoroughly documented for the use in managing the sewer system and
meeting established notification and reporting requirements. The procedures for investigating and
documenting spills are shown below.
Category 1 and 2 Spills
During regular business hours, the ERT will notify the Wastewater Supervisor immediately of a Category 1 or
2 spill. After hours, the Standby Responders will notify the Standby Supervisor of a Category 1 or 2 spill. The
Responders will fill out the Spill Form as soon as possible. Then turn it in to the Wastewater Supervisor or
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Wastewater Project Coordinator during regular hours. In the event of a Category 1 overflow in a sensitive area,
the Wastewater/Standby Supervisor will notify the WGW Manager and WGW Assistant Director.
Category 3 and 4 Spills
The ERT or Standby Responders will fill out the WGW Operations SSO Report Form, see Appendix C, and
turn it into the Wastewater Project Coordinator to begin the reporting process.
Internal Reporting of Spills related to FOG
If a spill is determined to be caused by FOG, either from one or more Food Service Establishment (FSE)
or specific residential areas, the Wastewater Project Coordinator will notify the City’s FOG Manager,
Environmental Program, located at the Regional Water Quality Control Plan (RWQCP). The work order
includes the following information, at minimum. The record should include the following information, at
minimum:
1. Location of affected laterals, manholes, and sewer main segments;
2. Date, time, address, and cause of the spill;
3. Severity of the FOG; and
4. If available, a copy of the CCTV or a statement when it will be available.
WGW Operations should receive confirmation from the Public Works Watershed Protection Department that
the FSE is integrated into the FOG Program and follow ups are completed.
6.11 Internal Spill Documentation
Category 1, 2, 3, 4, and/or Enrollee Owned/Operated Spills
The Responder will complete a Spill Report form and turn it into the Wastewater Supervisor or Wastewater
Project Coordinator. The Wastewater Supervisor or Wastewater Project Coordinator will create and maintain a
file for each individual spill. The file should include the following:
• Spill Investigative Procedures Checklist, Appendix E
• Spill Report – Draft for review
• Spill Report – Final
• Photos
• Certified CIWQS Report
The following are for Category 1 and 2 Spills.
• Appropriate maps showing the spill location
• Water quality sampling and test results, if applicable
Private Spills
The Responder will complete Spill Form and provide it to the Wastewater Supervisor or Wastewater
Project Coordinator. A separate file will be prepared for each individual spill at the Wastewater
Supervisor’s discretion. The file should include any relevant information above.
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6.12 Failure Analysis Investigation
6.12.1 Post Spill Debriefing
For each spill event greater than 250 gallons, all participants involved in the response – from the person who
received the call to the last person to leave the site – should meet, as soon as feasible, after the event to
review and evaluate the incident and the City response procedures. The objective of the Post-Spill Debrief is
to determine actions necessary, if any, to reduce the recurrence and better mitigate the effects of spills. The
results are documented and tracked on a Post-Spill Debrief form to ensure the identified action items are
implemented. The Post-Spill Debrief Form is in Appendix D. The Post-Spill Debrief documentation is filed in
the final spill file for the incident.
6.12.2 Spill Investigation and Mitigation
It is the responsibility of the Wastewater Supervisor to investigate spills and to ensure that the procedures in
the SERP are followed or modified as a result of the incident failure analysis. The Utilities Supervisor failure
analysis is intended to determine if additional maintenance, repair/replacement or other follow-up actions or
response procedures changes are needed to reduce or eliminate the likelihood of future spills.
The procedures for investigating a spill are as follows:
1. Review the SSO Report Form, Appendix C;
2. Interview the following personnel, if applicable: Dispatch, Supervisor, Primary Responder, Field Service
Representatives, Customer Service Representatives, responding crew members or any other; Agency staff
that were involved with the response;
3. Review the incident timeline and other documentation regarding the incident;
4. Review communications with the Reporting party and witnesses;
5. Review photographs of the incident;
6. Review spill volume estimate, volume recovered estimate, volume estimation assumptions and associated
drawings;
7. Review past maintenance records of affected manholes and pipe segments;
8. Review past CCTV records.
9. Conduct new CCTV inspection, if necessary.
10. If the spill is located within the designated hot spot areas, consider increasing the maintenance frequency;
11. Review any FOG related information or results from RWQCP;
12. If the spill is due to pipe failure, schedule repair or replacement as soon as feasible;
13. If the spill is due to an under-sized pipe, infiltration/inflow or other engineering defect, contact the WGW
Engineering for inclusion in the CIP work; and
14. Develop agreed upon changes and additions to the SERP and/or City Procedures resulting from the
investigation and debrief session(s).
6.13 Record Keeping Requirements
The SWDR and MRP require that individual spill records be maintained by the City for a minimum of five years
from the date of the spill. This period may be extended when requested by a Regional Water Quality Control
Board Executive Officer.
All records shall be made available for review upon SWRCB or RWQCB staff's request during on-site inspection
or through an information request.
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Spill Reports
Records shall be retained for all spills, including but not limited to the following when applicable:
1. Service call records and complaint logs of calls received by the City, documenting how the City responded
to all notifications of possible or actual spills (including complaints that do not result in spills), including:
a. Date, time, and method of notification
b. Date and time the complainant or informant first noticed the spill
c. Narrative description of the complaint, including any information the caller can provide regarding
whether or not he/she knows if the spill has reached surface waters, drainage channels, or storm
drains
d. Follow-up return contact information for complainant or informant for each complaint received, if not
reported anonymously
e. Final resolution of the complaint
2. Records documenting steps and/or remedial actions take to control and terminate the spill and recover as
much of the discharged volume as possible;
3. Records documenting how estimates of volume discharged and volume recovered were calculated; and
4. All California Office of Emergency Services notification records, as applicable.
Recordkeeping of Category 4 Spills and Non-Category 1 Lateral Spills
The City must maintain the following records for each individual Category 4 Spill and for each individual
non-Category 1 owned and/or operated lateral spill.
Recordkeeping of Individual Category 4 Spill Information
1. Contact information: Name and telephone number of the City employee who can respond to spill
specific questions;
2. Spill location name;
3. Description and GPS coordinates where the spill originated:
4. Did the spill reach a drainage conveyance system? If Yes:
a. Description of the drainage conveyance system transporting the spill;
b. Estimated spill volume fully recovered from the drainage conveyance system; and
c. Estimated spill volume remaining within the drainage conveyance system;
5. Estimated total spill volume exiting the system;
6. Spill date and start time;
7. Spill cause(s)
8. System failure location
9. Description of spill response activities including description of immediate spill containment and
cleanup efforts;
10. Description of how the volume estimation was calculated, including, at minimum:
a. The methodology and type of data relied upon, including SCADA records, flow monitoring, or
other telemetry information used to estimate the volume of the spill discharged, and the
volume of the spill recovered (if any volume of the spill was recovered), and
b. The methodology and type of data relied upon to estimated the spill start time, on-going spill
rate at time of arrival (if applicable), and the spill end time;
11. Description of implemented system modifications and operating/maintenance modifications.
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Recordkeeping of Individual Lateral Spill Information
1. Date and time the Enrollee was notified of, or self-discovered, the spill;
2. Location of individual spill;
3. Estimated individual spill volume;
4. Spill cause(s);
5. Description of how the volume estimations were calculated.
Total Annual Spill Information
1. Estimated total annual spill volume;
2. Description of spill corrective actions, including at minimum:
a. Local regulatory enforcement action taken against the sewer lateral owner in response to a spill,
as applicable, and
b. System operation, maintenance and program modifications implemented to prevent repeated
spill occurrences at the same spill location.
Sewer System Telemetry Records
Electronic monitoring records relied upon for documenting spill events and/or estimating spill volume
discharged, including:
1. Supervisory Control And Data Acquisition (SCADA) systems;
2. Alarm System(s);
3. Flow monitoring devices or other instruments used to estimate wastewater levels, flow rates, or volumes;
4. Computerized maintenance management system records; and
5. Asset management-related records.
Recordkeeping for Water Quality Sampling
If water quality samples are required by an environmental or health regulatory agency or State law or if
voluntary monitoring is conducted by the City or its agent(s) as a result of any spill, records of monitoring
information shall include:
1. The date, exact place, and time of sampling or measurements;
2. The individual(s) who performed the sampling or measurements;
3. The date(s) analyses were performed;
4. The individual(s) who performed the analyses;
5. The analytical technique or method used; and
6. The results of such analyses.
SSMP Implementation
WGW Operations shall maintain records documenting the implementation of its SSMP, including
documents that support audits, corrections, modifications, and updates to the SSMP.
Audit Records
WGW Operations shall maintain, at minimum, the following records:
• Completed audit documents and findings;
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• Name and contact information of staff and/or consultants that participated in the audit; and
• Follow-up actions based on audit findings.
Equipment
WGW Operations shall maintain a log of all owned and leased sewer system cleaning, operational,
maintenance, construction, and rehabilitation equipment.
Work Orders
WGW Operations shall maintain record of work orders for operations and maintenance projects.
6.14 Equipment
Tools and Equipment inventory:
Table 21: Equipment
Item Quantity Comments
Combination Hydroflush Truck
by Vactor
2 #8748, 2015 FREIGHTLINERS
#8747, 2015 FREIGHTLINERS
Hydrojetter Truck 1 #8791, 2017 FORD
Lead Service Truck 1 #8723, 2017 PETERBILT
Lateral Maintenance Vans 2 #7509, 2015 FORD
#7215, 2017 FORD
Supervisor Truck 1 #8721, 2010 FORD
Dump Truck 2 #8802, 2003 GMC 5 yard
#8725, 2008 PETERBILT 10 yard
HEO Backhoe 1 #8738, 2008 CATERPILLAR
Inspection CCTV Van 1 #8793, 2004 FORD video from 6” to 24” main lines
Inspection Cameras 6 Used as an assessment and inspection tool
Emergency Trailer 1 Located in MSC
Shoring Trailer 1 Located in MSC. Used for deep trenches.
6” Pump 1 Located in MSC
2”Pump 3 Located in MSC
Snake/ Rooter Machine 4 Mechanical pipe cleaner. Cuts roots and debris.
Mini Snake/ Rooter Machine 1 Mechanical pipe cleaner. Cuts roots and debris.
Smoke Machine 1 Located in MSC
Spill Control Rubber Dam 2 Placed inside wastewater service vehicles
Spill Control Rubber Mat 4 Placed inside wastewater service vehicles
Gas Detector 20 Used to detect dangerous gases
Metal Detector 5 Used to locate parts of the Wastewater Collection System
4” to 6” Pipebursting machine 1 Used for trenchless pipe replacement
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6.15 Spill Response Training
Training includes City-specific issues, such as operation of its key pieces of equipment, as well as general safety
and operational issues, the SSMP including the Spill Emergency Response Plan and spill response procedures
practice drills. The City uses both contracted and in-house training services and requires training or
certification of conformance of training of contractors on its SERP and spill response procedures.
Initial and Annual Refresher Training
The City uses a combination of in-house classes, on-the-job training, conferences, seminars, and other training
opportunities to provide technical training for its wastewater collection system staff. Vendors provide training
for new tools or equipment. A portion of bi-weekly tailgate meetings are dedicated to training on various
wastewater topics. These short meetings prior to the start of the day’s field work provide the opportunity for
quick discussions of short topics related to specific collection system operations issues. The sources of technical
training and training materials for the City’s wastewater collection staff are listed in Table 21 and Table 22.
Table 22: Training Resources (Conferences, Seminars, and Courses)
Sponsor Event Timeframe References
California Water Environment
Association (CWEA)
State Conference April
www.cwea.org Northern Regional Safety Conference September
Santa Clara Valley Section Meetings &
collections training events & classes Monthly
CWEA - San Francisco Bay Area
section
Meetings and collections training
events & classes Monthly www.cwea.org
Bay Area Clean Water Association
(BACWA) Collection Systems
Committee
Collection System Committee
meetings Monthly www.bacwa.org
Table 23: Training Resources (Materials)
Sponsor Materials Reference
California State University,
Sacramento
Videos, manuals, home study
courses www.owp.csus.edu
Other potential sources of training include the Water Environment Federation specialty conferences on
collection system operations, webinars and publications that support sewer system education and
training including the City’s risk management and insurance program pools that provide specific risk-
based training for claims and risk reduction.
City staff receives annual training on the following topics: volume estimation, storm water pollution
prevention, confined space entry, biological and chemical hazards, Vactor safety, underground
construction, gas detector use, application of overflow control materials, back injury prevention,
overflow reporting and field documentation, and the content and procedures of the SSMP. In addition,
the City provides free training and seminars on various professional development topics including
computer applications, writing, and communication skills.
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Individual training records are documented and maintained by the City’s Department of Human
Resources.
Spill Response Drills
Periodic training drills should be held to ensure that employees are up-to-date on the procedures, the
equipment is in working order, and the required materials are readily available. The training drills should cover
scenarios typically observed during sewer-related emergencies (e.g. mainline blockage, mainline failure, force
main failure, pump station failure, and lateral blockage). The results and the observations during the drills
should be recorded and action items should be tracked to ensure completion.
Spill Response Training Record Keeping
Records should be kept of all training that is provided in support of this plan. The records for all scheduled
training courses and for each overflow emergency response training event and should include date, time,
place, content, name of trainer(s), and names of attendees.
Contractors Working on City Sewer Facilities
All Contractors working on City sewer facilities will be required to develop a project-specific SERP that is
subject to City approval. All contractor personnel will be required to receive training in the contractor’s SERP
and to follow that SERP in the event that they cause or observe a spill.
6.16 Annual Review of SERP
The Wastewater Operations Manager, or designee, shall annually review and assess the effectiveness of
the Spill Emergency Response Plan. Upon completion of the review, the SERP shall be updated as soon
as reasonably practicable.
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Element 7: Sewer Pipe Blockage Control Program
7.1 FOG Program Goals
The City of Palo Alto implements a FOG Control Program due to the significant number of FOG-
generating FSEs in the City. The benefits of a FOG Control Program include FOG discharge prevention to
the sanitary sewer and storm drain systems, storm drain pollution prevention from spills and FSE
practices, reducing the number of FOG-related spills, improving public health and safety, avoidance of
overflow-related fines, minimizing property damage claims, reducing sewer maintenance costs, and
improving the FSE business environment. The primary goal of the FOG program is to reduce the number,
severity and frequency of spills linked to FOG and to reduce the environmental impacts and the costs
associated with spill cleanup.
Since 1996, the City began development a food service program to include appropriate SUO provisions,
site inspection procedures, enforcement action procedures, BMPs for FSEs, outreach and education.
The FOG Program began during the second half of 2006 with the addition of a full time FOG Program
Investigator. In 2008, the program enhanced its data management system to track inspections, follow-
up letter enforcement and storm drain program inspections as they relate to FSEs.
Statewide Waste Discharge Requirements
The Sewer System Management Plan must include procedures for the evaluation of the Enrollee’s
service area to determine whether a sewer pipe blockage control program is needed to control fats,
oils, grease, rags, and debris. If the Enrollee determines that a program is not needed, the Enrollee
shall provide justification in its Plan for why a program is not needed. The procedures must include,
at minimum:
• An implementation plan and schedule for a public education and outreach program that
promotes proper disposal of pipe-blocking substances;
• A plan and schedule for the disposal of pipe-blocking substances generated within the
sanitary sewer system service area. This may include a list of acceptable disposal facilities
and/or additional facilities needed to adequately dispose of substances generated within a
sanitary sewer system service area;
• The legal authority to prohibit discharges to the system and identify measures to prevent
spills and blockages;
• Requirements to install grease removal devices (such as traps or interceptors), design
standards for the removal devices, maintenance requirements, best management practices
requirements, recordkeeping and reporting requirements;
• Authority to inspect grease producing facilities, enforcement authorities, and whether the
Enrollee has sufficient staff to inspect and enforce the fats, oils, and grease ordinance;
• An identification of sanitary sewer system sections subject to fats, oils, and grease
blockages and establishment of a cleaning schedule for each section; and
• Implementation of source control measures for all sources of fats, oils, and grease reaching
the sanitary sewer system for each section identified above.
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7.2 Outreach
7.2.1 Regional Outreach
During 2014, the Bay Area Pollution Prevention Group (BAPPG) promoted proper disposal of kitchen
fats, oils, and grease on Bay Area Univision Spanish radio stations between Thanksgiving week and New
Year’s Day. Univision aired a total of 73.3 paid radio spots (48 – 60 second and 20 – 30 second) on radio
stations KSOL and KBRG. Additionally, Univision broadcasted 220 paid audio streaming ads on their radio
website (www.univision.org) featuring a banner directing the audience to www.baywise.org with more
than 580 thousand gross impressions. Univision also included complimentary PSAs on KSOL, KBRG and
KVVF. The campaign included a total of 288 spots making 1.74 million gross impressions at a cost of
$0.0042 per impression.
7.2.2 Residential Outreach
Outreach for residents continues to be an important component of the FOG program. In past years the
RWQCP focused on providing residents with helpful tools, such as free grease scrapers, and utility bill inserts
with disposal information of cooking oil and grease. In 2012 specific residential areas were targeted for
outreach where more multi-family residential buildings existed and older neighborhoods that had continually
high spill counts. In 2013 a seasonal utility bill insert was mailed that included information about HHW dates
and disposal of used cooking oil and grease, especially from deep fryers for turkeys. Residents are able to
dispose of their unwanted cooking oil at the weekly HHW events. Utility bill inserts continue to include HHW
information and the importance of proper grease disposal. Outreach efforts are further detailed in the City’s
annual Clean Bay Plan report.
7.3 FOG Disposal
Adequate disposal options for FOG are available in the region.
7.3.1 Acceptance at RWQCP and Maximizing Energy Recovery
During 2008, City staff investigated the FOG acceptance procedures at the RWQCP. The goal was to evaluate
the potential to receive all hauler loads associated with the Grease Waste Hauler Contract in the City of Palo
Alto and possibly other Cities in the RWQCP’s service area, which would include non-contracted haulers. At
the present time, there is limited capacity for accepting more than the current amount of approximately 6,000
gallons of grease waste hauler loads per day. The RWQCP’s acceptance of GCD waste material cannot exceed
130,000 gallons per month or 1.56 million gallons per year.
The RWQCP Long-Term Facilities Plan discussed the benefits of adding FOG to digesters, if digesters are
chosen as a biosolids handling technology. FOG addition can significantly increase energy production.
7.3.2 Coordination/Data Management
During 2008, City staff investigated the FOG acceptance procedures at the RWQCP. The goal was to evaluate
the potential to receive all hauler loads associated with the Grease Waste Hauler Contract in the City of Palo
Alto and possibly other Cities in the RWQCP’s service area, which would include non-contracted haulers. At
the present time, there is limited capacity for accepting more than the current amount of approximately 6,000
gallons of grease waste hauler loads per day. The RWQCP’s acceptance of GCD waste material cannot exceed
130,000 gallons per month or 1.56 million gallons per year.
The RWQCP Long-Term Facilities Plan discussed the benefits of adding FOG to digesters, if digesters are
chosen as a biosolids handling technology. FOG addition can significantly increase energy production.
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7.4 Legal Authority
Chapter 16.09 of the Palo Alto Municipal Code (SUO) provides the legal authority to regulate FOG discharges
to the sewer system. The SUO has specific grease control requirements for Food Service Establishments.
Table 23 contains a summary of the SUO provisions pertinent to FOG control.
Table 24: Sewer Use Ordinance Provisions for FOG Control
Provision Palo Alto Municipal Code Reference
Prohibitions 16.09.035
Standards 16.09.040
Grease Disposal Prohibited 16.09.050
Unpolluted Water 16.09.055
Standards for Other Industrial Wastes 16.09.060
Best Management Practices 16.09.065
Trucker’s Discharge Permit 16.09.070
Food Service Establishments 16.09.075
Reporting Requirements for all Permitted Dischargers 16.09.135
Requirements for Reporting Noncompliance, Increased
Loading, Slug Discharges, Accidental Discharges 16.09.140
Storm Drains – Prohibited Discharges 16.09.165
Requirements for Construction Operations 16.09.170
General Prohibitions and Practices 16.09.175
Requirements for Newly Constructed, Remodeled or
Converted Multi Residential, Commercial and Industrial
Facilities 16.09.180
Enforcement – Notice of Non-Compliance 16.09.245
Enforcement – Administrative Compliance Order 16.09.250
Enforcement: Criminal Penalties 16.09.255
Enforcement – Administrative Citation 16.09.260
Enforcement – Administrative Civil Penalties 16.09.265
Enforcement – Judicial Civil Penalties 16.09.270
Damage to Facilities 16.09.275
City Right to Terminate Discharge 16.09.280
References: Palo Alto, California Municipal Code Ordinance No. 5561, passed September 27, 2022.
7.5 Source Control
The City has several high density and high volume restaurant areas including Downtown, Midtown, and the
California Avenue Business District, which are known hotspots for collection system impacts related to FOG
discharge. There are also several smaller clusters of FSEs and individual restaurants that warrant FOG controls.
These areas and specific FSEs have been the primary targets for increased inspection, enforcement, and
preventive cleaning.
The partner cities to the RWQCP (City of Mountain View, City of Los Altos, East Palo Alto Sanitary District,
Town of Los Altos Hills, and Stanford University) remain responsible for their collection systems, SSMPs and
FOG Control Programs. The City of Palo Alto will continue to support the satellite systems as needed with
creation of outreach materials, training, and assistance with FSE inspections.
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The City’s FOG Program staff in Public Works – Environmental Services manages plan check and specifications
for newly constructed and remodeled FSEs to ensure items required by the Palo Alto Municipal Code and
Uniform Plumbing Code are completed prior to approval of building permits. Grease-generating drainage
fixtures must be connected to a grease control device (GCD). Non-grease generating drainage fixtures
including hot discharge equipment can be connected directly to the sanitary sewer system. When drainage
fixtures are properly plumbed and the GCDs are properly maintained, there should be very little to no FOG
discharging to the sanitary sewer system. Improperly plumbed pipes and drainage fixtures are generally
associated with FOG buildup downstream, and occurrences of sewer backups or spills. The SUO includes a
requirement for undesignated retail spaced, ensuring that new buildings must retrofit to meet the
requirements if an FSE is in a new building’s undesignated retail space.
New buildings constructed to house food service establishments are required to include a covered area
for trash, recycling, tallow (used oil) and compostable. The area is designed to prevent water run-on to
the area and runoff from the area. Drains that are installed within the enclosure for recycle and waste
bins, dumpsters, and tallow bins (used oil containers) serving food service facilities are optional. Any
such drains installed must be connected to a GCD and the sanitary sewer. If tallow is to be stored
outside, then an adequately sized, segregated space for a tallow bin must be included in the covered
area.
7.6 Inspections
There are over 300 FSEs in the City of Palo Alto. The FOG program includes comprehensive inspections and
enforcement. Inspections of FSEs occur on a routine basis, and the City conducts more frequent inspections
and enforcement where necessary based upon FSE performance. The Clean Bay Pollution Prevention Plan
includes the goal of inspecting at least one-third of the FSEs each year.
The City’s main goals for FSEs are to have GCDs maintained frequently enough to prevent FOG from escaping
from GCDs and entering the sanitary sewer system, ensuring drainage fixtures are correctly plumbed, keeping
a maintenance log for GCDs, not to wash kitchen equipment or discharge wastewater to the storm drain
system, and to maintain the tallow bin and trash areas free of FOG and debris.
The FSEs are categorized by their potential to contribute FOG to the sanitary sewer or storm drain system.
Facilities located in hot spots or that have otherwise been problematic are addressed first and receive more
frequent inspections. FSEs are prioritized in one of the following categories:
• Problem FSEs in hot spots
• Problem FSEs not in hot spots
• FSEs in hot spots
• FSEs that have only had minor issues in the past
• FSEs with potential to generate FOG
• FSEs without significant potential to generate FOG (juice bars, coffee shops, etc.)
Experience has shown that some facilities will frequently not meet all requirements and will need ongoing
attention. These facilities will be re-visited as necessary. Facilities that demonstrate compliance will receive
less attention. During the inspections, the FSE is ranked on a scale of 1 (worst) to 5 (best) on their compliance
with BMPs and ordinance requirements. BMPs include:
• Removing food waste from preparation and service items prior to washing and disposal in the
trash or food scrap container (dry wipe pots, pans, and dishes before washing);
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• Installing drain screens in all sinks, drains, floor drains, floor sinks, dishwashers, etc. Clean
screens frequently into the trash or food scrap container;
• Cleaning water from floors, floor mats, exhaust hoods, large kitchen equipment, trash, recycling,
tallow containers, or other dishwashing not done in a dishwasher, should be directed to the GCD
prior to discharge, including outdoor cleaning;
• Maintain exhaust hood and vent grease collections devices, including those on roofs, in hoods
and removable filters to prevent spills and overflows;
• Dispose of waste oil/grease in a tallow receptacle that is kept free of spills, and closed with a lid;
• Prevent storm water pollution by keeping waste containers and surrounding area covered, clean
and free of FOG and food residue, debris and leaks; and
• Cleaning up spills using dry methods first (sweeping, rags, absorbent material that are disposed
in the trash), then mop and bucket. Mop water is discharged through the GCD.
FSEs that cause problems in the sanitary sewer, storm drain systems or have violations of their BMPs are
rated 1 or 2 depending on their location. The problematic facilities that rank 1 or 2 have one of more of
the following issues:
• Experienced back-ups or overflows;
• Contributed to FOG build up in the sanitary sewer (identified by CCTV or cleaning records);
• Unresolved compliance issues;
• Failed to follow the proper BMPs;
• Failed to keep records;
• Had storm drain violations; and/or
• Failed to comply with verbal or written directives.
The City receives updated lists of FSEs from the County of Santa Clara, Department of Environmental Health
and the Consumer Protection Division. Not all of the facilities on the list require an inspection by the City, as
many are farmer’s markets, gas stations and general food vendors. In addition, staff attends weekly
Development Review Committee meetings and is routed building plans for buildings that include FSEs.
The program includes different inspection types including FSE storm drain system inspections, full FSE FOG
inspections, and GCD building inspections. Efforts are concentrated in areas of known problems and facilities
with historical issues or known potential to discharge grease. Enforcement actions include Verbal Warning,
Warning Letters, Notices of Non-compliance, Compliance Agreements and Administrative Citations consistent
with the Enforcement Response Plan (ERP) for either wastewater or storm water violations.
During FSE inspections, outreach materials are distributed as appropriate. The BAPPG funded CalFOG to create
a poster that is available in English, Spanish, Korean, Chinese, and Vietnamese.
In addition to the posters, BAPPG created food scrapers with the RWQCP’s insignia and local disposal contact
info from www.cleanbay.org and a phone number. These food scrapers are BMP tools to help scrape off any
remaining food and FOG waste into the trash prior to rinsing kitchen items. Food scrapers are generally
distributed to FSEs during inspections.
In 2012, FOG Program staff created a fact sheet detailing the requirements for FSEs. This fact sheet is provided
to FSEs during the permitting process to ensure that all are aware of the SUO requirements and enforcement
response plan as well as other requirements such as the ban on Expanded Polystyrene (EPS) takeout
containers and single use plastic checkout bags.
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City staff educates the FSE management and staff on ordinance requirements and BMPs to the extent
practical during inspections. If a violation is observed, the inspector issues enforcement consistent with the
Enforcement Response Plan. For FSE’s that do not achieve compliance, enforcement will be escalated
according to the appropriate Enforcement Response Plan (Pretreatment or Storm water).
During the FSE storm drain system inspections compliance with storm drain regulations is assessed.
Outdoors cleaning of kitchen equipment, dumping of mop water, and poor housekeeping around trash
compactors, trash bins and tallow bins are addressed. Outreach materials, including those developed by
the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) are distributed to FSE’s
during inspections and with follow-up Letters as appropriate.
7.7 Compliance
Inspections and enforcement are described in the City’s annual Clean Bay Plan report located on the
Public Works, Environmental Services Publications and Reports website at
https://cleanbay.org/publications-permits/.
7.8 Rags and Debris
If the Wastewater Operations Department can confirm the source of rags and debris in a sewer lateral
or sewer main, the Wastewater Operations crew will try to contact the responsible party and inform
them of the violation. If the responsible party cannot be reached, then a “Sewer Lateral Blockage
Investigation” will be filled out accordingly and left at the premise.
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Element 8: System Evaluation, Capacity Assurance and Capital
Improvements
Statewide Waste Discharge Requirements
The Plan must include procedures and activities for:
• Routine evaluation and assessment of system conditions;
• Capacity assessment and design criteria;
• Prioritization of corrective actions; and
• A capital improvement plan.
8.1 System Evaluation and Condition Assessment
The Plan must include procedures to:
• Evaluate the sanitary sewer system assets utilizing the best practices and technologies
available;
• Identify and justify the amount (percentage) of it’s system for its condition to be assessed
each year;
• Prioritize the condition assessment of system areas that:
o Hold a high level of environmental consequences if vulnerable to collapse, failure,
blockage, capacity issues, or other system deficiencies;
o Are located in or within the vicinity of surface waters, steep terrain, high
groundwater elevations, and environmentally sensitive areas;
o Are within the vicinity of a receiving water with a bacterial-related impairment on
the most current Clean Water Act section 303(d) List;
• Assess the system conditions using visual observations, video surveillance and/or other
comparable system inspection methods;
• Utilize observations/evidence of system conditions that may contribute to exiting of sewage
from the system which can reasonably be expected to discharge into a water of the State;
• Maintain documents and recordkeeping of system evaluation and condition assessment
inspections and activities; and
• Identify system assets vulnerable to direct and indirect impacts of climate change, including
but not limited to: sea level rise; flooding and/or erosion due to increased storm volumes,
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8.1 System Evaluation and Condition Assessment
The City of Palo Alto’s Sanitary Sewer CIP plan is based on the 2004 Wastewater Master Plan, CPA’s
Wastewater Operations’ identified deficiencies (repairs or replacements), and CCTV evaluation and
assessment. The WGW Engineering Department is currently in the process of procuring another contractor to
complete and updated Master Plan Study. Since the updated plan is not available currently, the Wastewater
Engineering and Operations Department is utilizing the information it currently has available to evaluate and
assess its system.
Statewide Discharge Requirements
8.2 Capacity Assessment and Design Criteria
The Plan must include procedures to identify system components that are experiencing or
contributing to spills caused by hydraulic deficiency and/or limited capacity, including procedures to
identify the appropriate hydraulic capacity of key system elements for:
• Dry-weather peak flow conditions that cause or contributes to spill events;
• The appropriate design storm(s) or wet weather events that causes or contributes to spill
events;
• The capacity of key system components; and
• Identify the major sources that contribute to the peak flows associated with sewer spills.
The capacity assessment must consider:
• Data from existing system condition assessments, system inspections, system audits, spill
history, and other available information;
• Capacity of flood-prone systems subject to increased infiltration and inflow, under normal
local and regional storm conditions;
• Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-
intensity storm events as a result of climate change;
• Increases of erosive forces in canyons and streams near underground and aboveground
system components due to larger and/or higher-intensity storm events;
• Capacity of major system elements to accommodate dry weather peak flow conditions, and
updated design storm and wet weather events; and
• Necessary redundancy in pumping and storage capacities.
8.3 Prioritization of Corrective Action
The findings of the condition assessments and capacity assessments must be used to prioritize
corrective actions. Prioritization must consider the severity of the consequences of potential spills.
8.4 Capital Improvement Plan
The capital improvement plan must include the following items:
• Project schedules including completion dates for all portions of the capital improvement
program;
• Internal and external project funding sources for each project; and
• Joint coordination between operation and maintenance staff, and engineering
staff/consultants during planning, design, and construction of capital improvement projects;
and Interagency coordination with other impacted utility agencies.
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During 2004, an update of the Master Plan was completed by MWH Americas titled, “Wastewater
Collection System Master Plan – Capacity Assessment”, March 2004 (Master Plan) and approved by the
City Council. The Master Plan evaluated the effectiveness of the previous 1988 Master Plan Study
completed by CDM. It included a model of the collection system and an evaluation of the ability for the
system to convey existing and future peak flows from a 5-year design storm, along with identification of
areas with limited capacity and the need for system improvements and rehabilitation. Collection system
improvements were designed for a 20-year design storm.
The City requires all new developments, on a case by case basis, that propose to connect to the City system, to
provide capacity evaluations to determine that the existing system can transmit the proposed flows from the
new development without exceeding the City’s design criteria from the Master Plans. If deficiencies are
found, the evaluation must provide solutions to allow the addition of these expanded flows to the collection
system without causing spills or system failures. This also includes capacity expansion evaluations for satellite
agencies Stanford University and Los Altos Hills that currently discharge directly to and utilize capacity in the
Palo Alto collection system.
8.2 Capacity Assessment and Design Criteria
The Master Plan Study was effective in identifying the capacity deficiencies and recommended
appropriate CIP projects. Between 1990 and 2004, a majority of these CIP Capacity projects were
designed and constructed. The 2004 Master Plan study further refined the previous study with more
accurate modeling and significantly reduced the number of remaining capacity projects, which allowed
us to refocus our attention on I/I CIP projects. Since 2004, the remaining CIP projects identified in the
2004 Master Plan, which addressed current capacity deficiencies, have been completed. See Section 5.1
for WW Design Standards governing design and construction methods.
8.3 Prioritization of Corrective Action
The City’s WGW Engineering Department is in the process of procuring a consultant to perform the
Master Plan Study. Upon completion of the Master Plan Study the WGW Engineering and Operations
Department will collaborate to create a plan that prioritizes corrective action throughout the sewer
system.
8.4 Capital Improvement Plan
Projects in the 2004 Master Plan Study were broken into three groups, phases ‘A’, ‘B’, or ‘C’. The ‘A’
group consists of high priority projects. The ‘B’ group corrects relatively minor deficiencies. The ‘C’
group identifies potential future deficiencies. The groups relate to surcharge levels of the hydraulic
grade line determined by the collection system model. The Master Plan identified eight locations
where capacity-related improvements were required, generally in small diameter pipelines. These eight
improvement projects have since been completed. The City is in the process of contracting a new
vendor to complete an updated Master Plan Study which will include a capacity assessment and new
recommendations for CIP.
The Wastewater Enterprise Fund, which is predominately funded by collection system sewer service charges,
is the source of revenue for the annual CIP sewer rehabilitation projects. The funding is distributed among
three operations: WGW Engineering, Customer Services and WGW Operations. Table 24 shows this
distribution.
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Table 25: Sources of Annual Funding for Sanitary Sewer Rehabilitation
Funding Source Responsible City Division
General Equipment and Tools WGW Engineering
Sewer System Extensions – new laterals and pipelines Customer Services Division
Sewer Lateral/Manhole Rehab/Replacement WGW Operations
Wastewater System Improvements WGW Operations; WGW Engineering
Annual WW Collection System Rehabilitation WGW Engineering
Annual O&M WGW Operations Contractual Line Item WGW Operations
The sewer system rehabilitation and replacement projects are included in the City’s Five Year Capital
Improvement Program (CIP). The annual expenditures for the City’s CIP, which totals an average of $3
million to $4 million annually for wastewater collection system rehabilitation and replacement, are
shown by program in Table 25.
Table 26: Five-Year Capital Improvement Plan
Program FY 2022 FY 2023 FY 2024 FY 2025 FY 2026
TOTAL
New Manholes/
Replacement
$800.000 $1,325,000 $850,000 $875,500 $900,000 $4,750,000
Pipeline Rehabilitation/
Augmentation
$4,130,000 $0 $1,650,000 $3,550,000 $1,650,000 $9,495,000
System Improvements $200,000 $500,000 $500,000 $500,000 $200,000 $1,900,000
General Equipment and
Tools
$50,000 $50,000 $50,000 $50,000 $50,000 $250,000
TOTAL $5,180,000 $1,875,000 $3,050,000 $4,975,000 $2,800,000 $17,880,500
The funds that support the Capital Improvement Program come from the City’s Sewer Fund. The Sewer
Fund is an enterprise fund that includes annual sewer service charges, connection fees and interest.
Additional funding from the Utilities Operations, operations and maintenance budget is made available
for emergency repairs and lateral replacement, which is administered by Utility Operations.
8.4.1 Schedule
The annual projects include between 15,000 and 25,000 linear feet of pipe and associated manholes and
attached lower laterals. The current capacity deficiencies identified in the 2004 Master Plan Study have
all been constructed. An on-going 5-year CIP plan addresses and other maintenance issues typically
replacing lines in place. Figure 7 from the City’s five-year Capital Improvement Program identifies
approximately 75% of the line segments that are to be rehabilitated in the next five years. The
remaining 25% are line segments that will be identified during the design phase. All projects are
currently being or will be designed and implemented by WGW Engineering on an annual CIP Project Plan
basis as detailed in Figure 7. All line segments represent sewer mains in the street blocks shown. The
project usually takes a year after the start date to complete.
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The City has rehabilitated approximately 34% of the 217 miles of sanitary sewer system to date and expects to
add an additional 20 to 25 miles of rehabilitation in the next five years. Figure 7 identifies those lines that have
been rehabilitated or replaced up to 2019.
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Figure 7: Proposed Pipeline Replacement and Rehabilitation 2015-2019.
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Element 9: Monitoring, Measurement and Program Modifications
9.1 Maintenance of Relevant Data
The City of Palo Alto Utilities staff track relevant information that is used to establish and prioritize
appropriate SSMP activities. Field data such as pipe cleaning and inspection frequencies, spills, and
lateral replacements are tracked in Sedaru and/or other systems (for example GIS). On a monthly basis,
the Business Analyst and the Operations Manager and Utilities Supervisor generate monthly reports to
monitor and evaluate the effectiveness of the City’s collection system operation. The monthly report is
also discussed with WGW Engineering staff at the regular monthly meetings.
SSMP Audit findings should also be used to determine plan modification and prioritization. Details
regarding the SSMP internal audits can be found in Element 10 of the SSMP.
9.2 Monitoring and Assessment
The City has selected certain performance indicators to assess the effectiveness of the SSMP and WGW
Operations for the sanitary sewer collection system. These indicators were selected because they are
straightforward, quantitative, and focused on results. Changes in the indicators over time can be used to
assess the overall success of the SSMP or, conversely, to identify underlying conditions that inhibit success and
necessary program revisions and changes to fully implement the SSMP. The two categories of performance
indicators are listed below:
Data Regarding Implementation of SSMP Measures
• Feet of sewer main inspected with CCTV/year
• Feet of sewer main cleaned/year
• Number of lower laterals with PM activity/year
• Feet of sewer main treated for root control
• Feet of sewer main rehabilitated
• Number of lower laterals rehabilitated
• Number of FSE inspections
Statewide Waste Discharge Requirements
The Plan must include an Adaptative Management section that addresses Plan implementation
effectiveness and the steps for necessary Plan improvement, including:
• Maintaining relevant information, including audit findings, to establish and prioritize
appropriate Plan activities;
• Monitoring the implementation and measuring the effectiveness of each Plan Element;
• Assessing the success of the preventive operation and maintenance activities;
• Updating Plan procedures and activities, as appropriate, based on results of monitoring and
performance evaluations; and
• Identifying and illustrating spill trends, including spill frequency, locations, and estimated
volumes.
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Average response time for spill event (Time between City becoming aware of potential spill and First
Responder arriving on site)
Data Regarding Success of Preventative Maintenance
Spill Rate (Spills/100 miles/year);
Number of spills for each cause (roots, grease, debris, pipe failure, capacity, lift station failures, etc);
Median spill volume (gallons)’
Percentage of spills greater than 100 gallons; and
Percentage of total spilled sewage reaching surface water.
9.3 Performance Data
Table 26 contains the specific annual performance goals associated with the collection system work.
The City’s Business Analyst produces monthly and annual performance reports, which will provide the
data to compare to the SSMP and individual Element stated goals. The reports also presents spill
performance results as certified in the State CIWQS system. This information allows the City to optimize
operations in a manner that yields favorable spill performance.
Table 27: Palo Alto Annual Performance Goals
Performance Indicator Measured Units Goal
Feet of sewer main inspected with CCTV Feet 52,800
Feet of sewer main cleaned Feet 385,440
Feet of sewer main treated for root control Feet 5,280
Feet of sewer main rehabilitated Feet 5,280
Number of lower laterals PM’ed Number 2,400
Number of lower laterals rehabilitated Number 110
Number of Food Establishment Inspections Number 200
Average response time for spill event Time 1 Hour
Sanitary Overflow Trends Performance Indicator Measured Units
Total Annual Spills Number
Spill Rate Spills/100 miles/year
Percentage of Total Spilled Sewage Reaching Surface Water Gallons
Percentage of Spills Greater Than 100 Gallons Percentage
Spills by Cause Roots
Grease
Debris
Pipe Failure
Lift Station Failure
Other
Median Spill Volume Gallons
2023 Sewer System Management Plan
City of Palo Alto
Adaptive Management
The City will evaluate the performance of its SSMP on a biennial basis using the performance indicators
noted in Section 9.2. Any operational changes that are made to improve specific performance indicators
will be documented in the SSMP Audit and reflected in the revised language of the SSMP. Element 10
discusses the SSMP Audit process in detail.
Chart Data Regarding Implementation of SSMP Measures 2012 – 2022
Figure 8: Feet of sewer main inspected with CCTV, 2012-2022
Figure 9: Feet of sewer main cleaned, 2021 – 2022
0
17370 19437
29137
54710
76811
49852 49417
71035
63752
45208
0
10000
20000
30000
40000
50000
60000
70000
80000
90000
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
Feet of Sewer Main Inspected with CCTV/Year
714959 656256
573677
729814
792032
718217 774036
915212
724987
562163 540843
0
100000
200000
300000
400000
500000
600000
700000
800000
900000
1000000
2011 2013 2015 2017 2019 2021 2023
Feet of Sewer Main Maintained
2023 Sewer System Management Plan
City of Palo Alto
Figure 10: Number of Lower Laterals PM’ed
Figure 11: Average Spill Response Time
1128
1485
809
1714
1171
2232
1838
2588
1920 1928
1687
0
500
1000
1500
2000
2500
3000
2011 2013 2015 2017 2019 2021 2023
Number of lower laterals PM'ed
118
133
103
81
121
70 64 68
46 46
55
28 26
38 30
42 44 52 46
76 75 80
0
20
40
60
80
100
120
140
2011 2013 2015 2017 2019 2021 2023
Average Spill Response Time
Number of SSOs Average Response Time Per Spill (Minutes)
2023 Sewer System Management Plan
City of Palo Alto
9.4 Spill Trends
Figure 12: Total Annual Number of Spills
Figure 13: Median Spill Volume
118
133
102
81
121
70 64 68
46 46
55
0
20
40
60
80
100
120
140
2010 2012 2014 2016 2018 2020 2022 2024
Total Annual Number of Spills Number
10 11
17
23
18
25
21.5
11.5 12.5
19
25
0
5
10
15
20
25
30
2010 2012 2014 2016 2018 2020 2022 2024
Median Spill Volume in Gallons
2023 Sewer System Management Plan
City of Palo Alto
Figure 14: Percent Reached Surface Water
Figure 15: Percent of Spills Greater than 100 Gallons
22%
7%
0%0%
4%3%
0%0%0%0%
3%
0%
5%
10%
15%
20%
25%
2010 2012 2014 2016 2018 2020 2022 2024
Percent Reached Surface Water
1.69%
9%
5%
14.81%
5%
8.57%
13%
3%4%
20%
13%
0.00%
5.00%
10.00%
15.00%
20.00%
25.00%
2010 2012 2014 2016 2018 2020 2022 2024
Percentage of Spills Greater than 100 Gallons Percentage
2023 Sewer System Management Plan
City of Palo Alto
Figure 16: Spills by Cause
0
20
40
60
80
100
120
140
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
Spill Cause
Roots Debris FOG Other Pipe Failure
2023 Sewer System Management Plan
City of Palo Alto
Element 10: Internal Audits
Internal Audits
The reissued General Order, 2022-01-03-DWQ, requires the SSMP to be audited every three years. The
audit report shall be uploaded to the online CIWQS database by six (6) months after the end of the 3-
year audit period.
If the City fails to complete the audit, justification will need to be entered into the CIWQS database and
sent to the Region 2 – San Francisco Bay Regional Water Quality Control Board. (Region 2’s contact
information: RB2SpillReports@waterboards.ca.gov or (510) 622-2639). Failure to complete the audit
within the required timeframe is not justification for non-compliance with the General Order. Therefore,
the City must submit the late audit and comply with subsequent audit requirements and due dates
corresponding to the original audit cycle.
The audit will include a systematic review of each SSMP element to ensure the SSMP contains current
information, regulatory requirements are satisfied, and programs are effective and meeting the City
goals for the operation of the collection system stated in Element 1. If updates or changes are required,
the content and timeline to complete those changes are described in the audit form.
As part of the audit process, City staff will update critical information in the SSMP, such as contact
information, names of the required Designated Officials and the spill response chain of communication,
as needed. A comprehensive SSMP update will occur every 6 years, as required by the SSS WDR.
Changes made to the SSMP will be documented in the Change Log located in Appendix N.
Statewide Waste Discharge Requirements
The Plan shall include internal audit procedures, appropriate to the size and performance of the
system, for the Enrollee to comply with section 5.4 (Sewer System Management Plan Audits) of this
General Order.
2023 Sewer System Management Plan
City of Palo Alto
Element 11: Communication Program
11.1 Public Education
Outreach and public education are an important part of the City of Palo Alto’s operations. On an annual
basis, the City utilizes various media (newspaper, utility bill inserts, website and social media) to inform
utility customers of various topics including sanitary sewer collection system issues. Periodically
throughout the year, public outreach material on sanitary sewer lateral and cleanout maintenance tips
and requirements will be published in ads in the local newspaper’s special publications, through digital
online advertisements, distributed to customers through utility bill inserts, and posted on the Utilities
website. The outreach material provides instructions for reporting sewer blockages and overflows to the
City’s dispatch center, as well as contacting the City’s dispatch center. Additional outreach on keeping
fats, oils, and greases (FOG) out of drains is distributed via these communication channels every year,
typically around the fall and winter holiday seasons. The Environmental Compliance Division distributes
public education materials on proper disposal and handling of the household and non-residential fats,
oils, and grease.
A copy of the City of Palo Alto’s 2018 SSMP is available on the City’s web site. Subsequent updates to
the SSMP will also be posted on the same website.
SSMP link: https://www.cityofpaloalto.org/Departments/Utilities/Utilities-Services-Safety/Safety
11.2 Public Notification of a Spill
In the event of a spill reaching surface water, contaminated water signs will be posted as needed. If
notification to the public is necessary, the City of Palo Alto’s Communication Manager will be the source
of information and primary point of contact for the public. Additional details and contact information
can be found in Element 6.7.5.
11.3 Connected Agencies
The City has an established communication plan with the Regional Water Quality Control Plant’s
(RWQCP) collection system tributary agencies. The partner agencies meet periodically with City staff to
discuss various topics of mutual interest. These meetings are documented and copies of the meeting
agendas are located at the WGW Operations offices.
Statewide Waste Discharge Requirements
The Plan must include procedures for the Enrollee to communicate with:
• The public for:
o Spills and discharges resulting in closures of public areas, or that enter a source of
drinking water, and
o The development, implementation, and update of its Plan, including opportunities for
public input to Plan implementation and updates.
• Owners/operators of systems that connect into the Enrollee’s system, including satellite
systems, for:
o System operation, maintenance, and capital improvement-related activities.