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HomeMy WebLinkAboutItem 6 and 7 PPP Operations Committee 6-7-17 �vio fob Xi imk SSMP Audit aowl te ?. Sewer System Management Plan (SSMP ) • SSMPs document Spill Reporting, Response and Comprehensive Prevention efforts undertaken by Collection System Owners and Operators • An audit of the SSMP must be conducted every 2 years as required by the Waste Discharge Requirements for Sanitary Sewer Systems (WDR for SSSs) by the State Water Resources Control Board • Audits focus on evaluating the effectiveness of the SSMP and compliance with SSMP requirements Auditor Statements • "The overall program for managing, operating, and maintaining the sewer system has continued to improve and operate at a high level of performance:' • OCSD's SSMP was used by regulators in presentations to Collection System Operators as a positive example to follow. Audit Findings • Audit covered the period between January 2015 through December 2016 • No non-compliance findings or deficiencies • 4 major non-conformances were identified . These represent a mode rate-to-h igh likelihood of impact to the success of the program performance • 13 minor non-conformances. These are less likely to impact on the success of the program • 10 Opportunities for Improvement not impacting compliance or conformance 4 Major Non -Conformances • Spill contingency plans for pump stations need to be added to the SSMP (Currently located in Emergency Response Plan ) • Inspections of Force Mains are not conducted on a routine schedule as done with the gravity system • OCSD's Design and Construction Requirements for Sanitary Sewers are not consistent with the SSMP • Work order data collection is not uniformly recorded between different collection crews and locations 13 Minor Non -Conformances • Groups of Issues identified include : • Improve identification of positions responsible for different roles within the SSMP • Improve use of Maximo to implement SSMP • Update collection system risk as new CCTV data is recorded • Update training documentation i Opportunities for Improvement • Develop standardized approach to evaluate CCTV and maintenance data • Improve solicitation by public on SSMP • Incorporate findings of ongoing sewer assessment into SSMP when completed • Review frequency of Environmental Compliance Assurance Program ( ECAP) notifications SSMP Changes Since Prior Audit (2015) • Major change : • Procedure established for documenting changes made to the SSMP since the last certification. • Minor changes : • Organization chart in the SSMP document was updated to reflect changes in OCSD structure as well as staff moves and promotions. • Transfer of local sewers to EOCWD was noted. This impacted the length of sewers under the jurisdiction of OCSD. estion s ?