Sanitary Sewer System Management Plan

Transcription

1 Sanitary Sewer System Management Plan Prepared by: Environment, Health and Safety Division Environmental Services Group October 2009 Ernest Orlando Berkeley, CA This work was supported by the Director, Office of Science, U.S. Department of Energy under Contract Number DE- AC02-05CH11231

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3 LBNL SSMP TABLE OF CONTENTS SSMP Section Tab / Page # Section 0: Introduction 0 Section i: Goals i Section ii: Organization ii ii-a: Authorized representative ii-2 ii-b: Organizational chart ii-3 ii-c: SSO reporting chain of communication ii-6 Section iii: Legal Authority iii iii-a: Authority to prevent illicit discharges iii-2 iii-b: Authority to properly design and construct sewer iii-6 iii-c: Authority to ensure access iii-8 iii-d: Authority to limit FOG iii-9 iii-e: Authority to enforce any violation iii-10 Section iv: Operation and Maintenance Program iv iv-a: System mapping iv-2 iv-b: Routine preventative O&M activities iv-6 iv-c: Prioritization program for impaired sewer assets iv-10 iv-d: Training iv-17 iv-e: Equipment and critical replacement parts iv-20 Section v: Design and Performance Provisions v v-a: Design and construction standards and specifications v-2 v-b: Procedures and standards for inspecting and testing v-6 Section vi: Overflow Emergency Response Plan vi vi-a: Proper notification procedures vi-2 vi-b: Program to ensure appropriate response vi-4 vi-c: Notification of regulatory agencies vi-6 vi-d: SSO response plan distribution and training vi-7 vi-e: Procedures for emergency operations vi-9 vi-f: Program to minimize effects of sewage discharge to waters of the U.S. vi-10 Section vii: FOG Control Program vii vii-a: FOG public outreach program vii-2 vii-b: FOG disposal vii-4 vii-c: Legal authority vii-5 vii-d: Requirements for grease removal devices vii-6 vii-e: Inspection vii-9 vii-f: Identification of FOG problem areas vii-11 vii-g: FOG source control measures vii-12 Section viii: System Evaluation and Capacity Assurance viii viii-a: Identification of areas of hydraulic deficiency viii-2 viii-b: Hydraulic design criteria viii-7 viii-c: Capacity enhancement capital improvement program viii-10 viii-d: Schedule of completion dates for capital improvement projects viii-13

4 TABLE OF CONTENTS (CONTINUED) SSMP Section Tab / Page # Section ix: Monitoring, Measurement, and Program Modifications Ix ix-a: Information maintained to prioritize SSMP activities ix-2 ix-b: Monitoring and measurement of SSMP element effectiveness ix-5 ix-c: Assessment of success of preventative maintenance program ix-9 ix-d: SSMP program updates based on performance evaluations ix-11 ix-e: SSO trend analysis ix-12 Section x: SSMP Audits X Section xi: Communication Program Xi xi-a: Plan of communication with public xi-2 xi-b: Plan of communication with satellite collection systems xi-4

5 LIST OF ATTACHMENTS Section 0: Introduction Attachment 0-1: LBNL CIWQS Sewer System Questionnaire Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map Section i: Goals None Section ii: Organization Attachment ii-1: LBNL Notice of Intent for GWDR Coverage Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel Attachment ii-4: Sanitary Sewer Overflow Off-Hours Notification Procedure Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows Section iii: Legal Authority None Section iv: Operation and Maintenance Program Attachment iv-1: Example Sewer Asset Database Format Section v: Design and Performance Provisions None Section vi: Overflow Emergency Response Plan None Section vii: FOG Control Program Attachment vii-1: Cafeteria FOG Control Inspection Form Section viii: System Evaluation and Capacity Assurance Attachment viii-1: I/I Analysis Spreadsheet Example Section ix: Monitoring, Measurement, and Program Modifications None Section x: SSMP Audits None Section xi: Communication Program None

6 0 Introduction / Document Use SSMP Requirement Background This Sanitary (SSMP) has been prepared by the Lawrence Berkeley National Laboratory (LBNL) in compliance with the requirements of California State Water Resources Control Board (SWRCB) Order No , dated May 2, The order consists of general waste discharge requirements (GWDRs) which prohibit the discharge of untreated wastewater which may reach waters of the United States or cause a public nuisance as defined in California Water Code Section 13050(m). The order requires that all publicly owned wastewater collection system utilities owning more than one mile of pipe prepare a written SSMP to address the proper operation, maintenance, and funding of the system to ensure the prevention of sanitary sewer overflows (SSOs). The LBNL sanitary sewer collection system consists of approximately 5.5 miles of gravity sewer pipe; therefore LBNL is required to develop an SSMP. In addition to the GWDRs, the SWRCB order established a monitoring and reporting program (MRP No DWQ) for all SSOs. The purpose of this program is to characterize and track SSO occurrence for the purpose of future prevention. The MRP defines specific information which must be included with each SSO report that is entered into the online SSO reporting system (California Integrated Water Quality System, or CIWQS). The MRP defines three categories of SSOs: A Category 1 SSO is any sewage spill in excess of 1,000 gallons or that is discharged to a drainage channel, surface water, or storm water pipe (if not captured and returned to the sanitary sewer system). Category 1 SSOs must be reported within 2 hours to the State Office of Emergency Services (OES), Regional Water Quality Control Board (RWQCB), and Local Department of Public Health, accompanied by a 24 hour certification to the RWQCB that all 2- hour notifications have been made. Category 1 SSOs must be reported using the online CIWQS system initially within three business days of occurrence. A final SSO report is submitted within 15 days using the CIWQS system when all response and follow-up activities for the SSO event have been closed-out. A Category 2 SSO is any sewage spill from the publicly owned portion of the collection system that is not a Category 1 SSO and must be reported through the online CIWQS system within 30 days after the end of the calendar month in which the SSO occurred. The final category encompasses SSOs originating from private laterals, which may be reported at the discretion of the agency. LBNL was enrolled in the San Francisco Bay RWQCB online SSO ereporting Program following its inception in December 2004, and switched over to the SWRCB s CIWQS system in compliance with MRP No DWQ at the time it was implemented. The RWQCB ereporting program is still used to submit 2-hour notification / 24-hour certifications of SSOs to Last Revision: Page 0-1

7 Element 0. Introduction / Document Use the RWQCB. A completed online Collection System Questionnaire for LBNL is included in Attachment 0-1. The questionnaire displays the information provided by LBNL to the SWRCB during registration in the MRP through the CIWQS system, and must be updated annually. Purpose of the SSMP Any prohibited SSO originating from a publicly owned sanitary sewer collection system constitutes a violation of the California Water Code and is subject to enforcement action. The purpose of this document is to ensure that the LBNL has a plan in place to reduce or eliminate SSOs and protect public health. The SSMP accomplishes this purpose by defining specific procedures and programs in 11 categories defined by the SWRCB GWDRs. The SSMP procedures and programs are specifically designed to maximize the functionality of LBNL s capital and human resources to manage the sanitary sewer collection system in a way that minimizes SSOs, and to ensure that LBNL is in compliance with the GWDRs. The SSMP also helps to advance LBNL s broad-based environmental policies with respect to the sanitary sewer collection system as stated in the LBNL Environmental Management System Plan (EMS Plan): 1. Comply with applicable environmental, public health, and resource conservation laws and regulations. 2. Prevent pollution, minimize waste, and conserve natural resources. 3. Correct environmental hazards and clean up existing environmental problems. 4. Continually improve the Laboratory s environmental performance while maintaining operational capability and sustaining the overall mission of the Laboratory. Document Organization The SWRCB GWDRs require that the SSMP address 11 specific aspects of the agency s responsibility regarding its management, operation and maintenance of the sanitary sewer collection system. These sections address the following: i. Goals ii. Organization iii. Legal Authority iv. Operation and Maintenance v. Design and Performance Provisions vi. Overflow Emergency Response vii. Fats, Oils, and Grease (FOG) Control viii. System Evaluation and Capacity Assurance ix. Monitoring, Measurement, and Program Modifications x. SSMP Program Audits xi. Public Communication Page 0-2

8 Element 0. Introduction / Document Use The SSMP describes the actions of LBNL pertaining to all 11 required sections. Each section of the SSMP begins with the presentation of the specific requirements of that section per the SWCRB GWDRs as well as a narrative providing additional background on the section. Following that, a sub-section exists for each sub-requirement within the section. Each subsection presents the following: a. The exact language of the SWRCB sub-requirement. b. A discussion of specific actions performed by LBNL which satisfy the requirement. c. A list of related documents in support of the discussion. d. A plan and schedule for implementing any actions that LBNL is not currently performing that are needed to meet the sub-requirement, or that are planned to be completed in the future to implement any programs described in the SSMP subsection. An appendix is included at the end of each main SSMP section that contains all attached related documents for that section. Sanitary Sewer Collection System Overview The LBNL is a member of the national laboratory system supported by the U.S. Department of Energy (DOE) through its Office of Science. Unclassified research across a wide range of scientific disciplines is conducted at LBNL. The LBNL facility is located on a 200 acre site in the hills above the University of California (UC) Berkeley campus and currently employs approximately 4,000 scientists, engineers, support staff and students. The LBNL facility property is owned by UC and leased to the DOE. All LBNL facilities, equipment, and supporting infrastructure (including the on-site sanitary sewer collection system) is owned and funded by the DOE. However, day-to-day operation and management of the LBNL is conducted by UC through a contract with DOE (Contract No. DE-AC02-05CH11231, also referred to as Contract 31). The East Bay Municipal Utility District (EBMUD), through the City of Berkeley, provides wastewater collection service to the LBNL. All wastewater discharged to the LBNL sanitary sewer collection system exits the facility at two outfall locations that connect to the EBMUD (via Hearst Monitoring Station) or UC sanitary sewer collection systems (via Strawberry Monitoring Station). Each of the perimeter outfall locations has a monitoring facility, which is used for continuous flow monitoring and for extraction of samples for chemical and radioisotope analysis as required by the EBMUD and the DOE (refer to SSMP section iii-a). The average wastewater flow from the LBNL site is approximately 135,000 gallons per day. The LBNL sanitary sewer collection system consists of approximately 29,000 feet of pipeline (5.5 miles), ranging in size from 3-inches to 10-inches in diameter. Presently, there are 68 occupied structures at LBNL that discharge to the system. In addition, the Strawberry system Page 0-3

9 Element 0. Introduction / Document Use carries wastewater from the University of California s Lawrence Hall of Science, Botanical Gardens, Space Science Laboratory, and Mathematical Sciences Research Institute. The sanitary sewer collection system is completely dependent upon gravity flow; no pumping stations exist at LBNL. An overview map of the LBNL facility, sanitary sewer collection system, and sewage outfall locations is provided in Attachment 0-2. Responsibilities of the Authorized Representative The representative(s) of LBNL responsible for the maintenance and implementation of this SSMP will be required to perform the following tasks: I. Submission and endorsement of all reports required by SWRCB Order No II. Management of the LBNL CIWQS SSO reporting system account III. Completion of the certification portion of the CIWQS SSO Database Questionnaire IV. Completion of bi-annual program audits V. Completion of 5-year SSMP re-certifications It should be noted that the LBNL representatives authorized to perform the tasks described above (as identified through the LBNL CIWQS system account) are not the only individuals responsible for the overall implementation of the SSMP. SSMP implementation is a shared responsibility between the LBNL Facilities Division and Environmental Health and Safety (EH&S) Division, as described in SSMP section ii-b. The LBNL authorized representatives are identified in SSMP section ii-a. Governing Body SSMP Certification and Re-Certification Requirements In order to certify the SSMP, the LBNL s governing body, the DOE, must review the document and ensure that it fully meets all of the requirements of the GWDR and includes actions and procedures to be taken by LBNL that are generally feasible and acceptable to DOE. Prior to certification, an overview of the programs proposed in the SSMP and any potential budgetary impact will be presented to the LBNL Chief Operating Officer (COO). Every 5 years, the SSMP must be reviewed by DOE and re-certified, to ensure that it remains up-to-date with changing management, operation, and maintenance programs and objectives. Related Documents o Refer to UC-DOE Prime Contract No. DE-AC02-05CH o Refer to LBNL Environmental Management System Plan (Latest Revision) o Attachment 0-1: LBNL CIWQS Collection System Questionnaire o Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map Page 0-4

10 Element 0. Introduction / Document Use Glossary The following is a list of abbreviations and acronyms used in this document: Abbreviation ADWF ASTM BACWA BMP CCR CCTV CDFG CEQA CFR CIP CIWQS CSI COO CUPA DOE EBMUD ECAAP EH&S EMS FOG gpm GWI/I GWDR I/I ID ISDHH ISM LBNL MGD MRP NEPA NOI NPDES OCA OERP OES O&M OSHA PDWF Meaning Average Dry Weather Flow American Society for Testing and Materials Bay Area Clean Water Agencies Best Management Practices California Code of Regulations Closed Circuit Television California Department of Fish and Game California Environmental Quality Act Code of Federal Regulations Capital Improvement Plan California Integrated Water Quality System Construction Specifications Institute Chief Operating Officer Certified Unified Program Agency Department of Energy East Bay Municipal Utility District Environmental Compliance Audit and Assessment Plan Environmental Health and Safety Environmental Management System Fats, Oils and Grease Gallons Per Minute Groundwater Infiltration and Inflow General Waste Discharge Requirements Infiltration and Inflow Identification Imminent and Substantial Danger to Human Health Integrated Safety Management Lawrence Berkeley National Lab Million Gallons per Day Monitoring and Reporting Program National Environmental Policy Act Notice of Intent National Pollution Discharge Elimination System Office of Contract Assurance Overflow Emergency Response Plan Office of Emergency Services Operation and Maintenance Occupational Safety and Health Administration Peak Dry Weather Flow Page 0-5

11 Element 0. Introduction / Document Use Abbreviation PI PMT POSM POTW PWWF RDI/I RP RWQCB SECAP SIU SOP SSMP SSO SWRCB TM UC UM UPC WDR Meaning Performance Indicators Plant Maintenance Technician Pipeline Observation System Management Publicly Owned Treatment Works Peak Wet Weather Flow Rainfall-Dependent Infiltration and Inflow Responsible Person Regional Water Quality Control Board System Evaluation and Capacity Assurance Plan Significant Industrial User Standard Operating Procedure Sanitary Sewer Overflow State Water Resources Control Board Technical Memorandum University of California Utilities Manager Uniform Plumbing Code Waste Discharge Requirements Page 0-6

12 Attachment 0-1: LBNL CIWQS Collection System Questionnaire

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14 Attachment 0-2: LBNL Facility Sanitary Sewer Collection System Overview Map

15 Sanitary Sewer Collection System Overview Map

16 i Goals SWRCB Requirement: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. Taken from SWRCB GWDR Order No adopted May 2, Background This SSMP section describes the goals of the LBNL for the management, operation, and maintenance of the sanitary sewer collection system. These broad goals help to shape programs developed within the SSMP and executed by the LBNL to meet the objectives of the GWDR. This section fulfills the requirements of the GWDR SSMP mandatory element i. Last Revision: Page i-1

17 Element i. Goals i. Goals Requirement: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. Discussion The SSMP will guide the LBNL Facilities Division and EH&S Division in accomplishing the following 3 goals: 1. Identify, prioritize, and continuously renew and replace sewer system facilities to maintain reliable service now and in the future. 2. Cost-effectively minimize infiltration and inflow. 3. Properly manage and operate the Laboratory s facilities to minimize the number and impact of SSOs. Related Documents o None Plan & Schedule No further efforts are projected for this element at the present time. Page i-2

18 ii Organization SWRCB Requirement: The SSMP must identify: (a) The name of the responsible or authorized representative as described in Section J of this Order. (b) The names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation; and (c) The chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services (OES)). Taken from SWRCB GWDR Order No adopted May 2, Background This section of the SSMP identifies the individuals responsible for implementation of the SSMP and for signing and certifying all reports and documents required by the GWDRs. The organizational structure for the LBNL employees that have responsibility for implementing the SSMP is clearly presented along with essential job functions and contact information for each employee. The chain of command for the identification, reporting, and mitigation of SSOs is established. This section fulfills the requirements of the GWDR SSMP mandatory element ii. Last Revision: Page ii-1

19 Element ii. Organization ii-a. Authorized representative Requirement: The SSMP must identify the name of the responsible or authorized representative as described in Section J of the GWDR s. Discussion The EH&S Division Environmental Manager and SSO Program Manager are LBNL s authorized representatives registered with the SWRCB through the CIWQS system to submit, sign, and certify all reports required by SWRCB Order No and MRP No DWQ. The Environmental Manager and SSO Program Manager may also submit SSO reports (i.e. 2- hour notification / 24-hour certification) to the RWQCB through the ereporting Program. The original Notice of Intent (NOI) for LBNL s coverage under the Statewide GWDR is included in Attachment ii-1. It should be noted that the LBNL authorized representatives identified above are not the only individuals responsible for the overall implementation of the SSMP. SSMP implementation is a shared responsibility between the LBNL Facilities Division and EH&S Division, as described in SSMP section ii-b. Related Documents o Attachment ii-1: LBNL Notice of Intent for GWDR Coverage Plan & Schedule No further efforts are projected for this element at the present time. Page ii-2

20 Element ii. Organization ii-b. Organizational chart Requirement: Identify the names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation. Discussion Compliance with the GWDR is a shared responsibility between two LBNL organizations: 1. The LBNL Facilities Division is responsible for sanitary sewer collection system operation, repairs, improvements, and modifications. In addition, it manages the operating budget, secures funding for improvement/repair/survey projects, and maintains records of the underground sanitary sewer collection system infrastructure. 2. The LBNL EH&S Division is responsible for environmental programs, site security, and emergency operations. Activities include SSO compliance, sampling, testing, and reporting sanitary sewer overflow volume and content as required by the EBMUD wastewater discharge permit for the LBNL site. In the event of a sanitary sewer overflow, the EH&S Division manages site access and emergency response activities and emergency notifications to all regulatory agencies per MRP No DWQ. The organization chart for employees responsible for implementation of the SSMP is included in Attachment ii-2. Roles and responsibilities specific to responsible positions are described below: Utilities Manager (UM): Reporting to the Facilities Operations Department Head, the Utilities Manager (UM) operates a comprehensive operation and maintenance plan to ensure a sufficient and dependable sanitary sewer collection system, minimizing SSOs and meeting the requirements of the DOE. The UM organizes multiple maintenance efforts including: periodic high-pressure water jetting, root control, grease interceptor maintenance, CCTV inspections, condition assessments, and capital improvement projects. The UM oversees the maintenance of a detailed sanitary sewer collection system Asset Database which includes pertinent asset physical data, historical maintenance records, and condition assessment data. The UM is also responsible for overseeing hydraulic analysis of the sanitary sewer collection system to ensure that adequate capacity is provided as described in the System Evaluation and Capacity Assurance Plan (see SSMP section viii). The UM secures funding, allocates expenditures, and develops and plans infrastructure projects. The UM annually updates (typically April 1st) the Collection System Questionnaire and provides responses to the Wastewater Discharge Program Manager for input into the on-line CIWQS database. The UM is involved with monitoring and measuring the performance of specific SSMP programs, and recommending updates to the SSMP as needed as part of the audit process. Page ii-3

21 Element ii. Organization Cafeteria Manager: Reporting to the Facilities Operations Department Head, manages the cafeteria support subcontract and subcontractor activities. Business Manager: Under general direction of the Facilities Division Director, the Business Manager is responsible for the planning and supervision of LBNL s accounting and financial record keeping activities. Inspector: Under general supervision of the Project Support Services, the Inspector personally performs a variety of inspection activities relating to sanitary sewer collection system facility construction to ensure compliance with approved plans and enforcement of LBNL s design and construction standards and specifications relating to construction of the system. The Inspector may be an employee contracted on a project-specific basis. Civil Engineer (Infrastructure): Under general direction of the UM, the Civil Engineer plans, organizes, administers and directs the maintenance, repair, installation and upgrading of LBNL s sanitary sewer collection system infrastructure and is involved with the maintenance of the sanitary sewer collection system Asset Database. The Civil Engineer is responsible for maintaining and periodically updating the LBNL design and construction standards and specifications. Plant Maintenance Technician (PMT): Under supervision of the Maintenance Superintendent, the Plant Maintenance Technician (PMT) performs a variety of tasks related to the maintenance, cleaning, and repair of LBNL s sanitary sewer collection system, Fixed Treatment Units, and related appurtenances. The PMT is a primary responder to any SSO events that may occur. Environmental Manager: Plans, directs and manages the environmental protection programs within the LBNL facility. Performs accidental release (SSO) notifications and prepares reports to Federal, State, and local agencies. Monitors and reviews LBNL activities for compliance with environmental laws and regulations. The Environmental Manager is involved with monitoring and measuring the performance of specific SSMP programs, and recommending updates to the SSMP as needed as part of the audit process. Security Manager: Plans, directs and manages site access and emergency response activities. Sanitary Sewer Overflow Program Manager: Designs and coordinates the sanitary sewer overflow (SSO) compliance program for LBNL. Assists Facilities Division management in interpreting and applying SSO requirements at the Page ii-4

22 Element ii. Organization LBNL site. Performs accidental release SSO notifications and reporting to Federal, State, and local agencies. Submits monthly no spill report through the on-line CIWQS database. The LBNL Division responsible for implementing each SSMP section is included in Attachment ii-3. Names and contact information for key staff responsible for GWDR compliance is also included in Attachment ii-3. Related Documents o Refer to Overall LBNL Organizational Chart o Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities o Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel Plan & Schedule No further efforts are projected for this element at the present time. Page ii-5

23 Element ii. Organization ii-c. SSO reporting chain of communication Requirement: Identify the chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services). Discussion Chain of Communication for Responding to SSOs The SSO chain of communication usually begins when the PMT responds to a reported release, assesses the situation, and determines that a SSO has occurred. Within the first 2 hours, the PMT will notify both his supervisor and EH&S Security and provide the following information: Description of what happened Location of release and of threatened or involved waterway(s) or storm drains Date and time the unauthorized discharge is known to have started Estimated quantity and duration of the unauthorized discharge Identity of person reporting the unauthorized discharge Facilities PMT personnel will use the emergency contact list to notify a Plumbing Shop employee to respond to the SSO. If unable to contact a Plumbing Shop employee, the secondary resource shall be a sewer maintenance contractor currently under blanket purchase order. Depending on the severity of the SSO, the PMT Supervisor may also notify the Utilities Manager, Facilities Director, Operations Department Head, and the Chief Operations Officer. The SSO Off Hours Notification Procedure flowchart can be found in Attachment ii-4. Chain of Communication for Reporting SSOs The initial notification of SSOs to the various regulatory agencies is conducted by the EH&S Environmental Services Group (normal business hours) or Security Group (off hours). The following information should be provided to the State OES, RWQCB, and City of Berkeley as soon as possible but within the first 2 hours of discovering an SSO that impacts a drainage channel or surface water (per SWRCB Order No. WQ EXEC): Description of what happened Location of threatened or involved waterway(s) or storm drains Date and time the unauthorized discharge is known to have started Estimated quantity and duration of the unauthorized discharge Identity of person reporting the unauthorized discharge Page ii-6

24 Element ii. Organization As soon as possible but within 24 hours, the EH&S Environmental Services Group will provide a certification report to the RWQCB that the State OES and the City of Berkeley have been notified. If the SSO meets the SWRCB s Category 1 reporting requirement, then the Environmental Services Group will submit a report via CIWQS within 3 business days. If the SSO meets the Category 2 reporting requirement, then a report will be submitted within 30 calendar days after the end of the calendar month in which the SSO occurs. A summary of SSO reporting requirements is included in Attachment ii-5. Related Documents o Attachment ii-4: Sanitary Sewer Overflow Off-Hours Notification Procedure o Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows Plan & Schedule No further efforts are projected for this element at the present time. Page ii-7

25 Attachment ii-1: LBNL Notice of Intent for GWDR Coverage

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31 Attachment ii-2: Organization Chart for SSMP Implementation Responsibilities

32 Facilities Division and Environmental Health and Safety Division Organization Chart for SSMP Implementation Responsibilities Chief Operating Officer Facilities Division Director Business Manager EH&S Director Operations Department Head Environmental Manager Security Manager Utilities Manager Wastewater Discharge Program Manager Inspector Plant Maintenance Technician Civil Engineer

33 Attachment ii-3: SSMP Implementation Responsibilities by Division and Contact Information for Key Personnel

34 SSMP Implementation Responsibility By Division and Contact Information for Key Personnel SSMP Section i Goals ii Organization iii Legal Authority iv Operation and Maintenance Program v Design and Performance Provisions vi Overflow Emergency Response Plan vii FOG Control Program viii System Evaluation and Capacity Assurance ix Monitoring, Measurement and Program Modifications x SSMP Audits xi Communication Plan Responsible Division(s) Facilities Facilities/EH&S EH&S Facilities Facilities Facilities Facilities Facilities Facilities/EH&S Facilities/EH&S EH&S OFFICE PHONE NUMBER CELL PHONE NUMBER POSITION NAME FACILITIES DIVISION: Operations Department Head Ken Fletcher (510) (510) Utilities Manager Mike Dong (510) (510) EH&S DIVISION: Environmental Manager Ron Pauer (510) (510) Wastewater Program Manager Robert Fox (510) (510) (pager)

35 Attachment ii-4: Sanitary Sewer Overflow Off- Hours Notification Procedure

36 Sanitary Sewer Overflow Off-Hours Notification Procedure

37 Attachment ii-5: Reporting Requirements for Sanitary Sewer Overflows

38 Reporting Requirements for Sanitary Sewer Overflows

39 iii Legal Authority SWRCB Requirement: Each Enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to: (a) Prevent illicit discharges into its sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc.); (b) Require that sewers and connections be properly designed and constructed; (c) Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency; (d) Limit the discharge of fats, oils, and grease and other debris that may cause blockages, and (e) Enforce any violation of its sewer ordinances. Taken from SWRCB GWDR Order No adopted May 2, Background LBNL s legal authority to perform all of the necessary management, operation, and maintenance functions for the sanitary sewer collection system is derived from the DOE s Prime Contract with the University of California, Contract No. DE- AC02-05CH11231, also referred to as Contract 31, as discussed in section 0 of the SSMP. Section C of Contract 31 states that the Consultant (LBNL) shall manage and operate the Laboratory through best-in-class management practices designed to foster world-class research while assuring the protection and proper maintenance of DOE research and information assets, the health and safety of Laboratory staff and the public, and the environment. The Contractor is expected to operate the Laboratory so as to meet all applicable laws, regulations, and requirements. LBNL does not experience many of the legal authority issues that most municipal utility agencies typically experience, because a majority of the sewage discharged to a municipal sanitary sewer collection system is contributed from private property not owned or operated by the municipality. Therefore, the municipal utility must develop a sanitary sewer system use ordinance to control discharges from private property to the public system to ensure that the utility can comply with applicable regulations. However, all property, facilities, and equipment located at LBNL are managed and operated under the authority of LBNL staff who are able to maintain full control over all discharges to the sanitary sewer collection system at all times. Therefore, LBNL is not in need of a sanitary sewer system use ordinance, but has instead established various management plans and operating procedures to ensure compliance with applicable regulations. This section fulfills the requirements of the GWDR SSMP mandatory element iii. Last Revision: Page iii-1

40 Element iii. Legal Authority iii-a. Authority to prevent illicit discharges Requirement: Possess the necessary legal authority to prevent illicit discharges into the sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc.) Discussion Regulations Applicable to the LBNL Sewer Collection System Appendix I of Contract 31 includes an attachment entitled Environment, Safety, and Health Standards Set for LBNL. This attachment includes a list of all Federal, State, and Local regulations that govern activities at LBNL. The key regulations specifically applicable to sewage discharges are: i. 10 CFR 20, Subpart K, Section regulates the discharge of radioactive wastes; ii. 40 CFR 403, Subpart N - establishes sewage discharge pretreatment requirements; iii. EBMUD Ordinance NO. 311A-13 - governs sewage discharge to the EBMUD sewage collection and treatment systems. LBNL Policy Documents LBNL has established an Integrated Safety Management (ISM) Plan, which is the core policy governing environmental, safety, and health processes, and is required to be implemented per Section C.4.d.2 of Contract 31, and per DOE Order 450.1A. Compliance with the regulations applicable to the discharge of sewage listed above is monitored primarily by the LBNL under the Environmental Management System (EMS) Plan, which is established under the ISM Plan. The EMS Plan describes the LBNL s overarching strategy for protecting environmental resources and complying with all applicable laws and regulations in a cost-effective manner. EMS Plan Section 2.2 establishes two specific areas of environmental compliance that may be affected by the operation and maintenance of the sewer collection system, which are surface water protection, and environmental and effluent monitoring. To help ensure compliance in these areas, an Environmental Monitoring Plan was established, which specifically describes sewage effluent pretreatment and monitoring programs (chapter 4) executed by LBNL. LBNL has also established a Health and Safety Manual under the ISM Plan in order to achieve the goal of performing all work safely and in a manner that strives for protection for employees, participating guests, visitors, subcontractors, the public, and the environment, commensurate with the nature and scale of work. Chapter 11 of the Health and Safety Manual (Environmental Protection) also describes LBNL policies and programs designed to reduce environmental Page iii-2

41 Element iii. Legal Authority impacts and ensure regulatory compliance, which includes sewage effluent monitoring and spill prevention / response policies. Sewage Discharge Permits LBNL has in place three sewage discharge permits, issued under EBMUD s Industrial Waste Pretreatment Program per 40 CFR 403, Subpart N and EBMUD Ordinance NO. 311A-13, which establish local pollutant discharge concentrations and prohibit illicit discharges. Permits have been issued for the following discharges from the LBNL: Site-wide sewage discharges from the Hearst and Strawberry outfall sites to the City of Berkeley and EBMUD sanitary sewer collection systems: Wastewater Discharge Permit No Site-specific discharge permits from Building 25 (Photo Fabrication Facility) and Building 77 (Ultra High Vacuum Cleaning Facility): Wastewater Discharge Permit No Site-specific discharge permit for treated groundwater from 5 sites at LBNL: Wastewater Discharge Permit No LBNL is classified by EBMUD as a Significant Industrial User (SIU) according to Ordinance NO. 311A-13 Title I Section 3-ee because LBNL discharges in excess of 25,000 gallons per day of sewage from the Hearst and Strawberry outfall sites combined (total daily average discharge of 135,000 gallons). All SIUs require a site-specific discharge permit per Title IV Section 1 of the Ordinance. The LBNL site-wide discharge permit (No ) establishes local discharge limits and a self monitoring and reporting program. LBNL is required to deliver monitoring reports to EBMUD within 30 days of the required sampling dates as specified in the permit. The LBNL has 6 buildings where hazardous wastes are handled or treated, which are regulated by the California Department of Toxic Substances Control (DTSC) under the Wright-Polanco- Lempert Hazardous Waste Treatment Permit Reform Act of 1992, which establishes a 5-tiered permitting system for the treatment or storage of hazardous wastes. Enforcement of the Hazardous Waste Treatment Permit Reform Act and permitting authority has been delegated to the City of Berkeley as a Certified Unified Program Agency (CUPA) by DTSC. The processes at Buildings 25 and 77 operate under the Permit-by-Rule tier, which is the third priority tier that allows on-site treatment of wastes in compliance with CCR Title 22, Chapter 12. The general practice across the LBNL is to prevent the discharge of hazardous materials to the sanitary sewer collection system by isolating and storing spent wastes as part of the applicable process, and removing and disposing of those wastes off-site at a hazardous waste disposal facility. However, at Buildings 25 and 77, process rinse water may become acidic and contaminated with metals, and thus wastewater discharge is regulated under the Metal Finishing Point Source Category per 40 CFR Part 433. Fixed Treatment Units (FTUs) are in place at these facilities to pre-treat Page iii-3

42 Element iii. Legal Authority wastewater prior to discharge from the building to comply with EBMUD s local limits. The EBMUD site-specific discharge permit for these facilities (No ) requires self monitoring and reporting of wastewater prior to discharge to the LBNL sanitary sewer collection system. The other 4 buildings which handle hazardous waste at LBNL are permitted under the Conditional Authorization tier (fourth priority), and may discharge wastewater that is acidic, but not contaminated with metals. These facilities are not regulated under 40 CFR Part 403, but have FTUs in place to meet EBMUD local limits. Additional documentation and reporting is required by the City of Berkeley for all 6 buildings regulated under the Hazardous Waste Treatment Permit Reform Act as described in Section of LBNL s Health and Safety Manual. LBNL is permitted as a Hazardous Waste Handling Facility under the Resource Conservation and Recovery Act (RCRA) by the DTSC. This permit requires that LBNL undergo a facility assessment to determine if any previous releases of hazardous wastes have occurred, and if any corrective measures are required to remediate those releases. LBNL has an Environmental Restoration Program in place, which includes monitoring and treatment of contaminated soil and groundwater at 5 locations at LBNL due to releases that have occurred over the life of the research facility. LBNL is permitted (No ) by EBMUD to discharge treated groundwater to the sanitary sewer collection system from these 5 locations. This permit also requires specific monitoring and reporting to EBMUD. Although none of the EBMUD discharge permits described above contain limits specific to radioactive wastes, LBNL monitors wastewater radioactivity to comply with 10 CFR 20, Subpart K, Section , the results of which are regularly reported to the DOE. Related Documents o Refer to LBNL Contract 31 Appendix I o Refer to EBMUD Wastewater Control Ordinance NO. 311A-13 er_control_ordinance/default.htm o Refer to DOE Order 450.1A o Refer to LBNL Integrated Safety Management Plan (Latest Revision) o Refer to LBNL Environmental Management System Plan (Latest Revision) o Refer to LBNL Environmental Monitoring Plan (Latest Revision) Page iii-4

43 Element iii. Legal Authority o Refer to LBNL Health and Safety Manual (Latest Revision) o Refer to LBNL Environmental Restoration Program Documents o Refer to EBMUD LBNL Site-Wide Discharge Permit No o Refer to EBMUD LBNL Building 25 and 77 Discharge Permit No o Refer to EBMUD LBNL Treated Groundwater Discharge Permit No Plan & Schedule No further efforts are projected for this element at the present time. Page iii-5

44 Element iii. Legal Authority iii-b. Authority to properly design and construct sewer Requirement: Possess the necessary legal authority to require that sewers and connections be properly designed and constructed. Discussion Established Design and Construction Standards The LBNL has the authority to establish design and construction standards for sanitary sewer collection system infrastructure owned by the DOE as the "Prime Contractor" in control of the LBNL property and infrastructure per Contract 31 with the DOE. Because the Laboratory is owned by DOE, a Federal entity, it is not subject to local design and construction standards or ordinances. LBNL has established a list of applicable State and National infrastructure design and construction standards and codes within the LBNL Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements, which are adhered to by LBNL employees and hired subcontractors (refer to Section 1 General Codes). Additionally, LBNL has established site-specific design requirements within the Construction Standards and Design Requirements - Volume 1 Part 2 Design Requirements, Standard Project Specifications, and Standard Construction Details, which are adhered to where applicable. The Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements describes in detail LBNL's rigorous infrastructure design review and approval process, which includes design review milestones and LBNL employees who must review and approve plans. Specific submittal content and format requirements are described for preliminary design phase, final design phase, construction document phase, and bidding and construction phase plans, specifications, and estimates for any infrastructure project. All infrastructure projects for the LBNL are either completed in-house by Facilities Division Engineers, or under the direction of a Project Manager from the LBNL Facilities Division who ensures that LBNL's established design requirements are adhered to through contract management and the review and approval of all project submittals. Construction Completed by Licensed Contractors Per LBNL Standard Specification Section 0101 General Requirements, Section 1.12, contractors are required to hold general licenses, or specialty licenses applicable to the specific work to be completed in compliance with the California Business and Professions Code. LBNL Facilities Division Project Managers confirm appropriate contractor licenses during the bidding and contract award phases of each project. Page iii-6

45 Element iii. Legal Authority All New Infrastructure Inspected and Approved Per Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements Section 6: Construction Phase, a Project Inspector is assigned by LBNL to each project to verify that construction of the project complies with the contract documents, applicable codes, and LBNL design and construction standards. The Project Inspector is responsible for documenting inspections, and bringing any instances of non-compliance to the attention of the LBNL Project Manager, so that those issues may be resolved prior to completion of the project. LBNL typically contracts with third party testing laboratories to complete any materials testing that is recommended or required in the contract documents. Record Drawing Submittal Per Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements Section 6: Construction Phase, record drawings must be prepared by the Project Engineer based on changes noted during construction by the Contractor and Project Inspector. All record drawings are submitted in AutoCAD format to the Facilities Division, which are used to update the site-wide infrastructure mapping system. Related Documents o Refer to LBNL Construction Details and Design Guidelines Home o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 1: Administrative Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements% pdf o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 2: Design Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Design%20requirements_ pdf o Refer to LBNL Standard Project Specifications Construction_Guidelines/Standard_Project_Specifications.html o Refer to LBNL Standard Construction Details Plan & Schedule No further efforts are projected for this element at the present time. Page iii-7

46 Element iii. Legal Authority iii-c. Authority to ensure access Requirement: Possess the necessary legal authority to ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency. Discussion LBNL Facilities Division Staff have full access to all on-site infrastructure, including the sanitary sewer collection system and wastewater pre-treatment works located at various research facility buildings. There is no publicly or privately owned infrastructure at LBNL which could present an access issue. All infrastructure is owned by the DOE, and operated by LBNL Facilities Division Staff. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page iii-8

47 Element iii. Legal Authority iii-d. Authority to limit FOG Requirement: Possess the necessary legal authority to limit the discharge of fats, oils, and grease (FOG) and other debris that may cause blockages. Discussion LBNL is required to comply with EBMUD Ordinance No. 311A-03 Title II Section 3a, which limits the discharge concentration of oil and grease to 100 mg/l to the sanitary sewer collection system. There is one food handling facility at LBNL, which is the on-site cafeteria. The cafeteria has a grease interceptor installed to control the discharge of FOG to the sanitary sewer collection system. This facility has not been required to obtain an EBMUD "Food Handling Facility Wastewater Discharge Permit", as these permits apply only to newly constructed facilities, remodeled facilities, or facilities which have caused or contributed to the cause of sewer blockages or SSOs related to FOG discharge. Currently, LBNL's site-wide discharge permit, as described in SSMP section iii-a, addresses FOG discharges from the cafeteria and other on-site grease producing facilities as a whole. It is possible that LBNL may be required by EBMUD to obtain a Food Handling Facility Wastewater Discharge Permit in the future if a new food handling facility is constructed, if the existing cafeteria is significantly remodeled, or if the existing cafeteria discharges excessive amounts of FOG to the sanitary sewer collection system that are determined to have caused a blockage or SSO, per subsequent EBMUD investigations. Additionally, there is a vehicle fueling (motor pool) facility at LBNL, which is served by two oil/ water separators which has been installed to comply with EBMUD's Pollution Prevention Program for automotive facilities, and the LBNL General Industrial Permit for stormwater discharges. One device discharges into the storm drain system, and the other discharges into the sanitary sewer collection system. The motor pool area is used only for vehicle refueling, and all vehicle maintenance is conducted off-site. All oil and fuel accumulated in the oil / water separators is regularly removed and disposed of by Facilities Division staff off-site. LBNL ensures that any new or modified automotive service or food handling facilities are served by Oil and Flammable Liquid Interceptors or Grease Interceptors conforming to the requirements of the California Plumbing Code (or Uniform Plumbing Code), Chapter 10. Related Documents o Refer to EBMUD Pollution Prevention Program Website _prevention_program/ Plan & Schedule No further efforts are projected for this element at the present time. Page iii-9

48 Element iii. Legal Authority iii-e. Authority to enforce any violation Requirement: Possess the necessary legal authority to enforce any violation of its sewer ordinances. Discussion Self Monitoring and Corrective Action The LBNL EH&S Division has established training requirements and standard operating procedures (see SSMP section iv-d) pertinent to sanitary sewer collection system waste disposal for all employees and researchers to ensure that Federal, State, and Local (EBMUD) discharge requirements are satisfied. The EH&S Division is charged with ensuring compliance of the LBNL with environmental regulatory requirements, and has the authority to make any modifications to infrastructure operation or lab policies or procedures that are necessary to ensure compliance. Compliance with the discharge permits and regulations described in SSMP section iii-a is self monitored through LBNL s Environmental Compliance Audit and Assessment Program, which requires internal audits of LBNL s key environmental programs, including the Wastewater Discharge Program, at least every three years to determine if the following activities are being implemented: EBMUD monitoring and permitting reports completed and submitted Verify wastewater controls and regular promotion of wastewater discharge awareness among LBNL personnel Completion of required discharge sampling collection, and adequate documentation Review / auditing of sample analysis performed by contracted labs The Environmental Compliance Audit and Assessment Program is required under DOE Order 450.1A to identify compliance deficiencies and root causes of non-compliance. LBNL personnel are directed to use the online Corrective Action Tracking System to report instances of non-compliance, for which appropriate corrective actions are developed, implemented, and documented by LBNL. Annually, LBNL compiles and publishes a Site Environmental Report which summarizes the performance of LBNL s significant environmental management programs and success in achieving regulatory compliance, per DOE Order 231.1A. Page iii-10

49 Element iii. Legal Authority External Enforcement LBNL does not have an established sewer use ordinance, and therefore does not conduct enforcement action. Instead, corrective measures are addressed internally when cases of noncompliance are identified. Enforcement actions by EBMUD (per Ordinance No. 311A-13 Title VI, and Wastewater Discharge Permit Standard Terms and Conditions), RWQCB, or SWQCB may be taken if LBNL fails to comply with sanitary sewer collection system discharge or operation and maintenance regulatory requirements. Related Documents o Refer to LBNL Environmental Compliance Audit and Assessment Program (Latest Revision) o Refer to the LBNL Corrective Action Tracking System (CATS) Primer / Database o Refer to DOE Order 231.1A o Refer to LBNL Annual Site Environmental Reports Plan & Schedule No further efforts are projected for this element at the present time. Page iii-11

50 iv Operation and Maintenance Program SWRCB Requirement: The SSMP must include those elements listed below that are appropriate and applicable to the Enrollee s system: (a) Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities; (b) Describe routine preventive operation and maintenance activities by staff and contractors, including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The Preventative Maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders; (c) Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed for the capital improvement plan; (d) Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained; and (e) Provide equipment and replacement part inventories, including identification of critical replacement parts. Taken from SWRCB GWDR Order No adopted May 2, Background This SSMP section describes various aspects of LBNL s operation and maintenance (O&M) program for the sanitary sewer collection system, which is designed to reduce the occurrence of SSOs. LBNL s approach to implementing an effective O&M program is to plan for condition assessment of the entire sanitary sewer collection system, and strategically plan both preventative maintenance work and capital improvement projects based on analysis of welldocumented field data. This section fulfills the requirements of the GWDR SSMP mandatory element iv. Last Revision: Page iv-1

51 Element iv. Operation and Maintenance Program iv-a. Maintain an up-to-date system map Requirement: Maintain an up-to-date map of the sanitary sewer system showing all gravity segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities. Discussion Utility Mapping In 1995, the LBNL Facilities Division had a facility-wide utility survey conducted for the purpose of generating accurate utility maps and a database of utility infrastructure assets. The utility survey resulted in the creation of an AutoCAD Master Sanitary Sewer Map, which includes (but is not limited to) the sanitary sewer collection system, the storm drain pipe network, potable water system, high pressure gas system, compressed air system, and electrical network. The Master Sanitary Sewer Map contains layers for each separate utility. LBNL has divided its Master Sanitary Sewer Map into equally sized rectangular quadrants which have been given unique identification codes and may be printed individually for a more detailed view of existing utilities in a given area of the LBNL. The Master Sanitary Sewer Map also includes physical features such as topography, buildings, streets, and vegetated areas. The sanitary sewer collection system mapping layer includes the following typical information: Plan view locations of all gravity sewer pipelines, manholes, cleanouts, and sewer outfall monitoring stations Unique identifiers for all sewer manholes Sewer pipeline size and material Sewer manhole rim and flow line (invert) elevations The storm drain system mapping layer includes the following typical information: Plan view locations of all storm drain pipelines, manholes, catch basins, cleanouts, and storm drain outfall structure locations Storm drain pipeline size Storm drain catch basin and manhole rim and flow line (invert) elevations The Master Sanitary Sewer Map includes a layer which is used to store callouts and notes for utility assets, such as unique identifiers, size, material, and other pertinent information which provides the LBNL Facilities Division an effective way to track issues that arise within each system. The utility notes layer may be used as a way to document institutional knowledge. Page iv-2

52 Element iv. Operation and Maintenance Program Availability of Utility System Mapping The Master Sanitary Sewer Map AutoCAD file is available for all Facilities Division and EH&S Division Staff to use for reference or for making updates. The following hard copy maps have been printed and made available to PMTs and other LBNL Staff for use in the field who may be involved with maintenance of the sanitary sewer collection system, or response to potential SSO events: Overall facility map of the sanitary sewer collection system Overall facility map of the storm drain system Individual grid maps showing all mapped utilities and notes Utility System Asset Database The 1995 LBNL utility survey also resulted in the creation of a utility Asset Database, in the form of an Excel spreadsheet, which documents the size, material, and length of each pipeline asset for each utility type. The number of sewer manholes and cleanouts, and storm drain manholes and catch basins are also documented. The information contained in the database helps LBNL comply with the requirements of DOE Order 430.1B Real Property Asset Management. The LBNL Facilities Division also plans to use this database in the future to perform tasks such as keeping records of maintenance activities, storing condition assessment data, and calculating pipeline hydraulic capacity, as described in SSMP section iv-b. Updating of Utility Mapping The Facilities Division Utilities Manager is responsible for updating the Master Sanitary Sewer Map. Notes and additional asset data collected by LBNL Staff or maintenance contractors are added continuously as information is collected. Contractors and Architects / Engineers are required to submit as-built AutoCAD files upon the completion of infrastructure projects, as specified in LBNL s CAD Policies, Procedures and Standards requirements. The Utilities Manager is responsible for integrating the key elements of new utility infrastructure as-built drawings into the Master Sanitary Sewer Map upon reception from the Contractor, Architect, or Engineer, and filing the original as-built drawings using LBNL s standard electronic drawing file structure. Planned Improvements to Utility Mapping System The LBNL Facilities Division plans to make several improvements to the Master Sanitary Sewer Mapping and Asset Database system so that they may be used as effective tools for sanitary sewer collection system operation and maintenance planning, work order documentation, and capacity assessment. Those improvements include the following tasks: Include the unique identifier assigned to each pipeline in the Asset Database as a call-out on the Master Sanitary Sewer Map to allow for easier linkage. Include the upstream and downstream manhole unique identifier as shown on the Master Page iv-3

53 Element iv. Operation and Maintenance Program Sanitary Sewer Map in the Asset Database for each pipeline. Include the invert or flow line of the upstream and downstream manhole for each pipeline asset from the Master Sanitary Sewer Map in the Asset Database for each pipeline. Calculate the pipe slope based on length and change in invert elevation. Calculate the maximum full flow hydraulic capacity of the pipe using Manning s Equation. Create a table for sewer manholes, including the unique identifier, rim elevation, invert elevation, depth, and diameter. Include the approximate asset installation date in the Asset Database (may be estimated). After completing the improvements to the Master Sanitary Sewer Map and Asset Database described above, both will be reviewed for missing information such as pipe sizes, materials, or manhole rim / invert information. LBNL Facilities Division Staff will collect this data in the field if it is needed for immediate analysis of system hydraulic capacity. Missing data may also be collected by CCTV inspection contractors during condition assessments and included in the Master Sanitary Sewer Map and Asset Database as it becomes available. Any errors in the horizontal alignment of the sewer system mapping (i.e. missing pipe sections, missing manholes, inaccurate locations of assets) will be noted by CCTV inspection contractors as they use the existing maps to conduct their work, or by Facilities Division Staff during the normal course of their work. When errors are discovered, the Utilities Manager will determine how best to collect the necessary data to update the Master Sanitary Sewer Map, which could include field investigations by Facilities Division Staff, additional data collection by CCTV inspection contractors, or ordering a utility survey in a particular location. A Master Sanitary Sewer Map grid revision layer is maintained by the Facilities Division to denote updates to the system mapping. A revision block reference is maintained for each grid of the Master Sanitary Sewer Map, and all changes to the map are documented, including the individual making the changes, the date, approvals, and a description of the changes made. Related Documents o Refer to LBNL s Master Sanitary Sewer Mapping AutoCAD File: Site Utilities.DWG o Refer to LBNL s Sewer Asset Database File: Sewer_Asset_Database.xls o Refer to LBNL s CAD Policies, Procedures, and Standards Admin_&_Design_Guidelines/Procedures_Standards_AE_CAD_Reqs_ pdf o Refer to DOE Order 430.1B Real Property Asset Management Page iv-4

54 Element iv. Operation and Maintenance Program Plan & Schedule Task Responsible Party Scheduled Date Print and make available to maintenance staff all sewer system / storm drain system overall facility maps and utility grid maps. Utilities Manager October 2009 Include sewer pipeline unique identifiers from Asset Database on Master Sanitary Sewer Map. Include upstream / downstream manhole identification, invert, slope, and estimated installation date in Asset Database. Identify data missing from Master Sanitary Sewer Map and Asset Database and determine most costeffective way to obtain that data.. Make updates based on necessary corrections noted in the field, and improvements made in the system as documented in as-built plans. Document drawing updates. Utilities Manager May 2010 Utilities Manager May 2010 Utilities Manager As Needed Page iv-5

55 Element iv. Operation and Maintenance Program iv-b. Routine preventative O&M activities Requirement: Describe routine preventive operation and maintenance activities by staff and contractors, including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The preventative maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders. Discussion Regular System-Wide Hydroflushing The LBNL Facilities Division has established a schedule to conduct system-wide hydroflushing of the sanitary sewer collection system at a minimum frequency of once every 5 years as a preventative maintenance activity to reduce the probability of an SSO due to a debris blockage. Periodic cleaning of the sanitary sewer collection system helps the system operate at or near its designed hydraulic capacity. The Facilities Division typically uses a contractor to complete scheduled work, and may complete hydroflushing of the entire system at one time under a single contract, or may complete smaller portions of the system over consecutive years based on available year-to-year funding in the operating budget. The Utilities Manager uses the sewer Asset Database to document hydroflushing work completed for each pipeline asset, so that no single asset goes more than 5 years without scheduled maintenance. Additionally, LBNL conducts annual cleaning and maintenance of both the Hearst and Strawberry discharge monitoring stations, also typically through a contractor. Targeted Increased Frequency Hydroflushing LBNL identifies specific sections of the sanitary sewer collection system which are observed to accumulate debris at rate which requires hydroflushing at a frequency less than the standard 5- years to prevent the occurrence of an SSO. If a partial blockage or an SSO occurs, LBNL conducts a post-event CCTV inspection of the area to determine the conditions that caused the event. If a significant amount of debris is observed in the area, the affected area is scheduled for hydroflushing at a frequency greater than every 5 years. The following general guidelines are used to select an appropriate hydroflushing frequency for assets subject to debris accumulation. However, the ultimate selection of the appropriate frequency is subject to the discretion of the Utilities Manager: Most severe loss of pipe cross sectional area > 30% - At least Annually Most severe loss of pipe cross sectional area > 20% - At least Biannually Most severe loss of pipe cross section area > 10% - At least Triannually Page iv-6

56 Element iv. Operation and Maintenance Program The hydroflushing frequency selected for each asset is documented in the Utility Asset Database. System-Wide Closed Circuit Television (CCTV) Inspection The LBNL Facilities Division has established a schedule to conduct system-wide closed circuit television (CCTV) inspections of the sanitary sewer collection system at a frequency of approximately every 10 years in order to maintain an accurate and up-to-date assessment of the condition of the infrastructure. The typical serviceable life of a sewer pipeline can vary widely depending upon the material of installation, quality of installation, and local conditions, however a typical range is between 50 to 100 years before rehabilitation or replacement is necessary. Therefore, LBNL schedules pipes with a current age over 20 years to be inspected every 10 years. Pipes over 20 years old that are found to be in excellent or good condition based on the most recent condition assessment may have the next inspection scheduled for between years. Pipes over 20 years old that are in fair or poor condition for which no immediate rehabilitation or replacement action was deemed necessary, but for which more rapid deterioration may be possible may be scheduled for future inspections more frequently than every 10 years to monitor the situation. LBNL requires CCTV inspection contractors to employ the National Association of Sewer Service Companies (NASSCO) Pipeline Assessment and Certification Program (PACP) protocol for pipeline condition assessment data collection, as described in SSMP section iv-c. Manhole Inspection and Repair Sewer manholes are visually inspected at the time adjacent pipelines are CCTV inspected. LBNL requires CCTV inspection contractors to employ the NASSCO Manhole Assessment and Certification Program (MACP) protocol for manhole condition assessment data collection, as described in SSMP section iv-c. Root Control Program When roots penetrate into sanitary sewer collection system pipelines through the joint or sidewalls, they provide a pathway for groundwater infiltration and compromise the structural integrity of the pipe. Additionally, roots may grow rapidly within sewer piping because of the optimal high-nutrient, warm temperature conditions and cause blockages in the system. Root intrusion is a common cause of SSOs. CCTV inspection results are reviewed for the occurrence of observations of roots, which is documented in the Asset Database. The Facilities Division has established a program to conduct regularly scheduled chemical treatment of pipelines affected by root intrusion, typically performed by a contractor. The contractor is consulted, and CCTV pictures or video may be reviewed to determine the appropriate treatment method and frequency. Work Order Scheduling and Documentation LBNL requires that contractors performing maintenance activities for the sanitary sewer collection system provide work order invoices that list each asset maintained or serviced using the unique identifier provided on the Master Sanitary Sewer Map, the specific maintenance activity performed for each asset, the date of completion, and any notes or observations particular to the work performed on each asset. Page iv-7

57 Element iv. Operation and Maintenance Program The Facilities Division Utilities Manager uses the sewer Asset Database to document maintenance frequencies and work completed for each asset which is submitted by contractors as invoices, or completed internally by Facilities Division Staff. An example of the format of the sewer Asset Database is included in Attachment iv-1. The regular maintenance activities that are tracked in the Asset Database are CCTV inspection, hydroflushing, and root control. The average maintenance frequency set by the Facilities Division, and last completion date for each of these three activities is listed for each pipeline asset. Conditional formatting is used to alert the user when a particular regularly scheduled maintenance activity is overdue. The Asset Database is used to document the completion of each preventative maintenance work order group, and can be used to quickly review the maintenance history of any given sewer system asset. A column is entered in the database of each work order group. The maintenance activity type, date, and contractor is listed for each work order group. The column for each work order group is aligned with the list of sanitary sewer collection system assets so that a comment may be entered for each asset that was serviced in the work order group. For assets where maintenance was performed routinely with no significant observations, the word complete is entered. If the contractor observed unusual circumstances, notes can be entered, which document the issue and alert the Utilities Manager that follow-up may be required. Un-planned activities such as blockages, SSOs, or repairs can also be entered as work orders. The Utilities Manager periodically reviews the Asset Database and schedules maintenance for assets which are either overdue, or are nearing the required due date. Data from work order invoices is entered into the Asset Database upon receipt. Documentation of Un-planned Sanitary Sewer Collection System Maintenance / Repairs The Asset Database will also be used to document any observations of sanitary sewer collection system deficiencies by Facilities Division Staff, other LBNL personnel, or maintenance contractors, and associated un-planned maintenance or repairs by asset that are required as a result of those observations. Observations and associated un-planned repairs or maintenance activity will be documented in the Asset Database similar to a regularly planned work order group, and adequate comments will be entered to describe the deficiency and the repairs or additional actions that were taken to mitigate the deficiency, as stipulated by the record keeping requirements of MRP No DWQ. A separate memorandum or other acceptable form of documentation may be required for more complex issues that cannot be adequately documented within the Asset Database as cell entries or comments to comply with the requirements of the MRP. Preventative Maintenance Program Budgeting The Asset Database is configured to calculate the average annual planned maintenance cost of each asset, based on a standardized cost per foot of pipe for each maintenance activity. The Utilities Manger uses the estimated average annual cost in the budgeting process to ensure that adequate funding is available to support the program as planned. The Utilities Manager may conduct cost-to-benefit analysis as deemed necessary, and adjust maintenance frequencies so that Page iv-8

58 Element iv. Operation and Maintenance Program maintenance expenditures are in line with available budget and LBNL risk tolerances. Related Documents o Refer to LBNL s Sewer Asset Database File: Sewer_Asset_Database.xls o Attachment iv-1: Example Sewer Asset Database Format Plan & Schedule Task Responsible Party Scheduled Date Assign maintenance frequencies in Asset Database for hydroflushing, CCTV inspection, and root treatment (only for assets with known root growth) to each sewer pipeline. Assign higher hydroflushing frequencies to assets in areas where blockages have occurred previously or other areas of concern Utilities Manager June 2010 Review Asset Database and schedule contracted maintenance for assets for which regular maintenance is due. Record data from maintenance work order invoices provided by contractors, and document unscheduled maintenance or event response activities in the Asset Database. Utilities Manager Utilities Manager Annually As Needed Page iv-9

59 Element iv. Operation and Maintenance Program iv-c. Prioritization program for impaired sewer assets Requirement: Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement (R/R) should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the R/R plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the shortand long-term plans plus a schedule for developing the funds needed for the capital improvement plan. Discussion LBNL conducts regular CCTV inspection of the sanitary sewer collection system to gather condition assessment data for all gravity main and manhole assets, which is used to identify capital improvement projects. LBNL establishes parameters related to asset condition that are used to prioritize capital improvement projects and establish a project schedule. CCTV Inspection Procedures LBNL requires that CCTV condition assessment data is collected and documented using the National Association of Sewer Service Companies (NASSCO) Pipeline Assessment and Certification Program (PACP) method, which is a nationally recognized sewer pipeline condition rating system for CCTV inspections. The NASSCO PACP method provides quantitative standardized results that allow for straight-forward prioritization of system deficiencies. The NASSCO Manhole Assessment and Certification Program (MACP) method is used to collect condition assessment data for manholes. LBNL s standard procedure is to hydroflush all sanitary sewer lines prior to inspection, to maximize the operator s ability to capture structural defects. In some instances where debris or root intrusion is a concern, crews may choose to CCTV without pre-cleaning to see the true operating condition of pipe. By requiring the NASSCO method and report format, LBNL can ensure that the results of condition assessments are uniform if various contractors are used to perform work. Condition Assessment Data Analysis CCTV inspections conducted using the NASSCO PACP / MACP coding interface result in the creation of a standardized report that documents the locations within the pipe at which observations were made. A still picture of each observation is taken, and a live video for the entire inspection is also provided. Every observation made using a PACP / MACP code is classified as either a structural defect (i.e. cracks, offsets, corrosion, etc.), maintenance defect (i.e. debris, grease, roots, etc.), or a miscellaneous observation (i.e. tap, manhole, end of survey, etc.). Appendix D of the PACP Manual includes a condition grading system that rates the Page iv-10

60 Element iv. Operation and Maintenance Program severity of each structural and maintenance defect on a scale from 1-5. Standard NASSCO PACP reports can be configured to automatically record the associated maintenance grade and structural grade for each observation made during an inspection. As a general guideline, defect severity levels 1-5 may cause failure of the asset on a timeline as described below. The failure timelines described in Appendix D of the NASSCO PACP manual for severity 3-5 defects has been condensed somewhat to provide an additional factor of safety: Severity 5 asset has failed or will likely fail within next two years (asset requires immediate attention, very poor condition) Severity 4 asset will probably fail in 2 to 5 years (asset is in poor condition) Severity 3 asset may fail in 5 to 20 years (asset is in fair condition) Severity 2 asset unlikely to fail for at least 20 years (asset is in good condition) Severity 1 asset failure unlikely in the foreseeable future (asset is in excellent condition) NASSCO has developed an overall asset condition rating system, known as the PACP quick rating, which is described in Appendix D of the PACP Manual. The Quick Rating is a four digit code, with the following characteristics: First digit is the highest severity observation noted (1-5) Second digit is the number of observations of the highest severity o If there are observations of this severity, the letter A is used o If there are observations of this severity, the letter B is used o If there are observations of this severity, the letter C is used Third digit is the second highest severity observation noted Fourth digit is the number of observations of the second highest severity o If there are observations of this severity, the letter A is used o If there are observations of this severity, the letter B is used o If there are observations of this severity, the letter C is used The quick rating provides a quantitative assessment of asset condition. A quick rating can be generated for either structural observations only, maintenance observations only, or for both types of observations combined. The quick rating system prioritizes assets first by the highest severity observation (the first digit), and second by the quantity of defects. It only takes one severity 5 defect, which may indicate that the asset has already failed, to cause an SSO. A single severity 5 defect is considered more serious than many severity 4 defects. Page iv-11

61 Element iv. Operation and Maintenance Program The Utilities Manager is responsible for review of condition assessment data, development of rehabilitation / replacement (R/R) recommendations, and prioritization of short and long term R/R as capital improvement projects that will be scheduled for completion over a 10-year horizon in compliance with DOE Order No B Real Property Asset Management, which governs the methodology used to analyze asset condition and plan for renewal of assets owned by DOE. DOE Order No B Section 4.d.3 states that condition assessments result in a determination of the current condition of real property assets, their estimated time to failure, the optimal period to accomplish maintenance actions based on engineering/maintenance analysis, and the estimated cost to correct identified deficiencies. Use of the NASSCO PACP quick rating condition assessment system meets this requirement by providing an estimated time to failure for each asset. The estimated time to failure is not based on a detailed structural analysis of the asset, but on average prevailing conditions. Typically, the cost to conduct detailed structural analysis of pipes in poor or very poor condition is not an economically favorable method of determining the appropriate timing for R/R actions, and rules of thumb such as the NASSCO recommendations provide a less costly way to make asset renewal decisions. Pipeline & Manhole Capital Improvement Project Identification and Prioritization The Utilities Manager uses the sewer Asset Database to store the NASSCO PACP structural and maintenance quick ratings obtained from CCTV inspections. The basic process for determining the need for R/R projects is described below: 1. Sort the Asset Database (pipelines and manholes) by PACP structural quick rating to identify all new (previously un-reviewed) inspections for which severity 5 structural defects were noted. Repairs associated with these defects are Priority 1 repairs. A relative priority ranking for assets in this category may be assigned in the Asset Database, such as 1-1, 1-2, 1-3, etc. These relative priority rankings may need to be integrated with priority rankings that have already been assigned to assets that were previously inspected and analyzed within the Asset Database (including priorities assigned to assets based on hydraulic capacity deficiencies as described in SSMP section viii-c). It should be noted that if during a routine CCTV inspection, an operator finds that a pipe or manhole has already failed (i.e. crush, collapse, etc.) or is substantially blocked due to a severe maintenance defect that cannot be remedied without excavation, the condition is reported to the Utilities Manager and an emergency repair or maintenance activity is always completed immediately to prevent an imminent SSO. 2. Sort the Asset Database by maintenance quick score to identify all new inspections for which severity 5 maintenance defects were noted. Repairs associated with these defects are Priority 2 repairs. A relative priority ranking for assets in this category may be assigned in the Asset Database, such as 2-1, 2-2, 2-3, etc. Page iv-12

62 Element iv. Operation and Maintenance Program 3. Sort the Asset Database by overall quick score to identify all new inspections for which severity 4 structural or maintenance defects were noted. Repairs associated with these defects are Priority 3 repairs. A relative priority ranking for assets in this category may be assigned in the Asset Database, such as 3-1, 3-2, 3-3, etc. 4. Identify all new inspections for which severity 3 structural or maintenance defects were noted. Repairs associated with these defects are Priority 4 repairs. A relative priority ranking for assets in this category may be assigned in the Asset Database, such as 4-1, 4-2, 4-3, etc. 5. After assigning an R/R priority ranking to the assets identified above, the CCTV inspection reports, pictures, and videos for each are reviewed in order of the R/R priority ranking to determine an appropriate R/R action for each deficiency. Any defects that can be remedied by a standard maintenance activity (i.e. non-structural repair) are immediately scheduled as work orders. Pipelines that exhibit accumulated debris or roots that result in a severity 3 or greater observation may be placed on increased frequency PM schedules that are set by the Utility Manager through field review and review of the video inspection. It should be noted that in some cases, severity 3 defects do not present a significant risk of near-term asset failure. The need to schedule an R/R action on the 10-year planning horizon, or mitigate the issue through an applicable preventative maintenance activity is at the discretion of the Utilities Manager based on the specific defect. In some cases, no action may be necessary. 6. Bundle identified R/R actions into preliminary Project Call List. 7. Estimate the construction cost of each identified R/R action. 8. Schedule tentative completion dates for identified project groups. Creation of LBNL Project Call List The result of updating the sewer Asset Database following completion of CCTV inspection work is the assignment of an R/R priority ranking for every asset. Using assigned priority rankings, the Utilities Manager begins the process of developing a Project Call List that includes groups of assets to be repaired or replaced. Steps 5 through 7 above should be performed under the oversight of a Civil Engineer licensed in the State of California. These tasks may be completed by LBNL Staff, or the services of a contracted Engineer may be procured to select the appropriate R/R method (i.e. typical excavation or trenchless construction methods) for each deficiency. Projects may be assembled according to priority ranking alone, selected construction methodology, coordination with other LBNL infrastructure projects, or other factors deemed appropriate by the Utilities Manager. Within the Asset Database, the Utilities Manager ensures that every asset with a severity 4 or 5 structural or O&M defect is assigned to a project. Typically, the upstream and downstream manholes for a rehabilitated or replaced pipeline are also rehabilitated (i.e. manhole lining or patching) or replaced at the same time. When a pipeline is placed into a Project Call List, the associated upstream and downstream manholes are also placed into that project if any severity 3 or greater defects have been noted. If Page iv-13

63 Element iv. Operation and Maintenance Program there are any manholes with severity 4 or 5 defects (i.e. R/R priority ranking 1-3) that are not adjacent to pipelines with similar defects, a separate manhole rehabilitation project may be scheduled to ensure these assets are adequately repaired or replaced. Preliminary Scheduling of Capital Improvement Projects When the Utilities Manager has finished assigning assets to a Project Call List, preliminary cost estimates are determined. Per DOE Order No B Section 4.d.4, the repair costs for deficiencies identified during the condition assessments must be estimated using the DOE Condition Assessment Information System (CAIS) or another nationally recognized cost estimating system. Costs must include overhead/burden. The Utilities Manager is responsible for ensuring that cost estimates for identified R/R actions are prepared in accordance with acceptable DOE standards. LBNL uses the following general timelines to schedule sanitary sewer improvement projects: * Table iv-1: Sanitary Sewer Improvement Project Scheduling Guidelines Highest Priority LBNL Action Severity 5 Schedule for immediate emergency repair / replacement, or within 1 (Structural) next 1-2 years if appropriate. * 5 Schedule for immediate emergency repair / replacement, or within 2 (O&M) next 2-3 years if appropriate. * 4 3 Schedule for repair / replacement within next 2-5 years. * (any) 3 Schedule as likely for repair / replacement within next 10 years, 4 (any) and/or schedule increased PM or CCTV inspection. * May require interim increased frequency O&M activity to mitigate risk prior to R&R. Sanitary Sewer Collection System Project Call List The sanitary sewer collection system Project Call List consists of two project types, which are repairs or replacements for pipelines and manholes in poor condition, and capacity-related improvement projects (i.e. pipe diameter increase by dig and replace, pipe bursting, parallel construction, refer to SSMP section viii-c). The sanitary sewer collection system Project Call List is based on the prioritized project schedule and associated cost estimates developed within the sewer Asset Database. Pipeline and manhole R/R projects identified through the condition assessment process are prioritized and scheduled using the parameters described above. Capacity-related improvements that are required in order to mitigate the possibility of an SSO due to a lack of hydraulic capacity to convey peak design wet weather flows are assigned priority rankings as described in SSMP section viii-c and integrated into the prioritization process. Capacity-related improvement projects that are required to provide adequate hydraulic capacity for future Page iv-14

64 Element iv. Operation and Maintenance Program improvements at the LBNL are scheduled concurrently with the expected timing for the related improvements. The Project Call List will consider the following: NASSCO PACP / MACP CCTV inspection reports / condition assessment data Sewer Asset Database with assigned R/R Priority Rankings Grouped sanitary sewer collection system improvement project bid packages with estimated construction costs and construction dates Hydraulic capacity analysis of LBNL sanitary sewer main lines, and list of identified deficiencies for existing conditions and future facility build-out Analysis of required improvements to address hydraulic capacity deficiencies, including construction methodology, cost, and required construction date Each year, the Facilities Division (typically the Utilities Manager, and Operations Department Head and / or Facilities Division Director) will present Project Call List items to the Chief Operating Officer (COO) in the form of Project Funding Requests. The COO is responsible for reviewing the Project Funding Requests submitted, and prioritizing those needs versus the need for other LBNL projects that are integrated into the Institutional General Plant Project (IGGP) process. If the COO decides that adequate funding to support the current proposals in the sanitary sewer collection system project list is not currently available, the Utilities Manager will discuss the potential risks of deferring identified improvement projects (which may be based on research of enforcement actions and consequences of SSO events for similarly sized systems), and work with the COO to adjust the proposed project schedule. The Utilities Manager maintains copies of the original Project Call Lists (prior to any scheduling modifications due to funding limitations) submitted to the COO. Once the items on the Project Call List have been approved and funding becomes available, LBNL typically establishes external contracts with registered Civil Engineering Consultants to prepare bid documents for projects scheduled to be constructed in the next two years. Bid document preparation may also be completed internally by licensed LBNL Staff, where appropriate. Related Documents o Refer to NASSCO PACP User s Manual (Latest Edition) o Refer to DOE Order 430.1B Real Property Asset Management o Refer to LBNL s Sewer Asset Database File: Sewer_Asset_Database.xls Page iv-15

65 Element iv. Operation and Maintenance Program Plan & Schedule Task Responsible Party Scheduled Date Collect CCTV inspection condition assessment data from contractors following completion of scheduled work, enter pertinent data from inspection reports into sewer Asset Database, and file inspection reports, pictures, and video for later reference. Prioritize the repair of identified deficiencies in Asset Database using the NASSCO quick rating methodology for all severity 3, 4, and 5 defects. Utilities Manager As Needed Review CCTV inspection video, pictures, and reports for severity 3, 4, and 5 defects and determine appropriate rehabilitation / repair methods, or appropriate preventative maintenance activities to address deficiencies. Assemble sanitary sewer collection system improvement project bid packages, estimate cost, and assign preliminary construction date. Update LBNL Project Call List and present changes to LBNL Chief Operating Officer. Maintain documentation of Project Call Lists Initiate design / construction of approved sewer system capital improvement projects. Utilities Manager Utilities Manager Utilities Manager As Needed Annually in May As Needed Page iv-16

66 Element iv. Operation and Maintenance Program iv-d. Training Requirement: Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained. Discussion Job Hazard Assessment Procedure and Required Training The LBNL EH&S Division is responsible for administering a safety and training program for all LBNL employees and researchers per the ISM Plan. Each employee or researcher is required to complete a Job Hazard Analysis (JHA) survey, which is intended to identify health or safety hazards each individual would normally encounter during their work at LBNL. The JHA is designed to address the five core functions of Integrated Safety Management: 1. Plan the Work by identifying the tasks to be performed; 2. Analyze the Hazards of the Work; 3. Determine the Controls necessary to safely perform work; 4. Perform the work utilizing the prescribed Controls; and 5. Provide feedback and continuous improvement to enhance safety by periodically reviewing the JHA. Based on the JHA, specific requirements in the form of a Training Profile are established for each individual. Training classes are regularly conducted by EH&S staff and the completion of this training is documented for each individual. Each employee s or researcher s JHA and training profile is accessible through the EH&S website, where training is tracked and documented. Required SSO Response Training LBNL employees do not conduct regular operation and maintenance of the sanitary sewer collection system, which includes hydroflushing, CCTV inspection, and root control. This work is contracted out. LBNL employee positions responsible for direct SSO response are the Facilities Division Plant Maintenance Technicians, Plumbing Shop employees, and EH&S Environmental Services Group employees. LBNL has four standard operating procedure (SOP) documents which govern responses to and reporting of SSO events, which are: LBNL Emergency Response Protocol for Sewage and Potable Water Releases EMRG Sewage Spill Cleanup: Interior Emergency Procedure EMRG Sewage Spill Cleanup: Exterior Emergency Procedure OPER-75 Interior Sanitary Sewer Clearing Safety Operating Procedure Page iv-17

67 Element iv. Operation and Maintenance Program The LBNL EH&S Division includes training on SSO response into the existing Stormwater Management training course (EHS 690), which is a required training course for Plant Maintenance Technicians, Plumbing Shop employees, and EH&S Environmental Services Group employees (among other attendees), and is based around requirements and procedures described in LBNL s Stormwater Pollution Prevention Plan. Other LBNL training courses applicable to work which may be performed with respect to the sanitary sewer collection system include: EHS0256, EHS0267, EHS0258, EHS0357 LockOut / TagOut Training EHS0270 Gas Detection Instrumentation EHS0274 Confined Space Hazards EHS0276 Fall Protection EHS0277 Confined Space Permit Writer EHS0298 Construction Industry Outreach Training Required Contractor Training LBNL s Standard Specification No Environment, Safety, and Health General Requirements provides a list of applicable codes and standards for work performed at LBNL for contractors. The California Code or Regulations (CCR) governs a majority of the basic safety and training requirements for contractors: Requirement to develop and submit Illness and Injury Prevention Program: LNBL Standard Specification No Section 1.04 CCR Title 8, Chapter 4, Subchapter 7, Group 1, 3203 Traffic Control Flagger Training Requirements: CCR Title 8, Chapter 4, Subchapter 4, Article 11, Construction Safety Orders: CCR Title 8, Chapter 4, Subchapter 4, Article 6 Confined Space Entry: CCR Title 8, Chapter 4, Subchapter 7, Group 16, Article 108 Emergency Medical Procedures: CCR Title 8, Chapter 4, Subchapter 4, Article 3, 1512 Standard Specification No Section 1.05 states that all hired contractors must complete a subcontractor JHA to identify specific job hazards they will encounter during contracted work. Ultimately, hired contractors are required to adhere to the same regulations and policies LBNL employees are subjected to when considering job hazards. Section 1.05-D requires that, Each employee scheduled to work in the activities identified above (within the JHA) shall receive safety training in those activities prior to working on them. The Subcontractor shall maintain Page iv-18

68 Element iv. Operation and Maintenance Program proof of employee training at the work site and make it available to the LBNL Project Manager upon request. LBNL Project Managers review all contractor safety submittals required by Standard Specification No , and conduct a Work Site Safety Orientation prior to the start of construction projects. For construction projects affecting the sanitary sewer collection system, SSO response procedures are discussed with the subcontractor so that they are aware of the proper procedures and contact information in the event of an SSO. Related Documents o Refer to LBNL Integrated Safety Management Plan (Latest Revision) o Refer to LBNL Monthly Training Schedules and Training Course List o Refer to LBNL Job Hazard Analysis Website o Refer to LBNL Stormwater Pollution Prevention Plan (Latest Revision) o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf o Refer to EMRG-050: Interior Emergency Procedure (Latest Revision) o Refer to EMRG-051: Exterior Emergency Procedure (Latest Revision) o Refer to OPER-075: Interior Sanitary Sewer Clearing Safety Operating Procedure o Refer to LBNL Standard Specification No EH&S General Requirements Construction_Guidelines/Standard_Project_Specifications.html Plan & Schedule No further efforts are projected for this element at the present time. Page iv-19

69 Element iv. Operation and Maintenance Program iv-e. Identify equipment and critical replacement parts Requirement: Provide equipment and replacement part inventories, including identification of critical replacement parts. Discussion LBNL maintenance staff (i.e. PMTs, Plumbing Shop employees) conduct limited operation, maintenance, and SSO response activities for the sanitary sewer collection system. LBNL holds blanket contracts with sewer maintenance contractors for regular preventative maintenance activities, inspections, and emergency response to sanitary sewer overflows, and therefore does not have a need to maintain an extensive inventory of maintenance equipment. The LBNL has a limited inventory of equipment used to respond to SSOs, which includes a plumber's snake, sandbags and containment booms, personal protective equipment, and supplies needed to conduct surface water quality sampling. SSO response supplies and equipment are replaced as they are used or as required following the close-out of any SSO response. Bypass pumping is available from UC Berkeley's Facilities Division, as described in Section D of the UC Berkeley Emergency Response Program: Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek, and may be used to divert sewage flow in the event of a blockage. Additionally, for most Category 1 SSOs, an on-call contractor or the LBNL Fire Department will be contacted to respond, and will provide the equipment and materials necessary to appropriately address the situation. The LBNL sanitary sewer collection system does not have any lift stations or other mechanical / electrical controls that would require immediate backup replacement parts in the case of a failure to prevent the occurrence of an SSO. Any mechanical or electrical failures within the Hearst and Strawberry Outfall monitoring stations may result in a temporary loss of functionality in the monitoring station in terms of data collection, but would not impeded the flow of sewage that could result in a blockage or SSO. Therefore, the tracking of equipment and replacement parts associated with the outfall monitoring stations is not addressed within the SSMP. Any mechanical or electrical failures associated with FTUs for the facilities which require sewage pretreatment would result in an alarm to which the Facilities Division would respond. In the case of an alarm or malfunction in an FTU process, activities within the facility would be suspended until the appropriate repairs are made. Similarly, the tracking of equipment and replacement parts associated with FTUs is not addressed within the SSMP. Page iv-20

70 Element iv. Operation and Maintenance Program Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases otocol%20-%20sewage%20and%20water.pdf o Refer to UC Berkeley Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek Plan & Schedule No further efforts are projected for this element at the present time. Page iv-21

71 Attachment iv-1: Example Sewer Asset Database Format

72 Today's Date 10/1/2009 Pipe Section ID Length (ft) Dia. (in) Pipe Material Install Year Upstream Manhole ID Sewer Pipe Asset Database Upstream Invert Elevation (ft) Downstream Manhole ID Downstream Invert Elevation (ft) Pipe Slope (%) Pipe Maximum Capacity (gpm) CCTV Cost per Foot CCTV Inspection Freq. (mo) $3.50 Date Last CCTV Inspected Hydroflush Cost per Foot Hydroflushing Freq. (mo) $1.00 Date Last Cleaned Root Control Freq. (mo) Last Root Treatment Total Average Average Average $3, Schedule With 2 Years Schedule Within 2-3 Years Schedule Within 2-5 Years Schedule Within 5-10 Years Avg. Annual Maint. Cost NASSCO PACP Structural Quick Rating NASSCO PACP Maintenance Quick Rating NASSCO PACP Overall Quick Rating Rehabilitation / Replacement Priority Planned Rehabilitation/ Replacement Action Planned Rehabilitation/ Replacement Project Date SS PVC 1970 SSMH5N11E-# SSMH5N10E % /15/ /1/ #N/A $ Dig and Replace 6/1/2010 $$$ SS CI 1970 SSMH15S39E SSMH13S33E % /15/ /1/ #N/A $ Liner - Cured In Place Pipe 6/1/2010 $$$ SS CI 1970 SSMH13S33E SSMH12S30E % /1/ /1/ /28/2007 $ Liner - Cured In Place Pipe 6/1/2010 $$$ SS CI 1970 SSMH12S30E PLUGGED % /1/ /1/ /5/2009 $ Liner - Cured In Place Pipe 6/1/2010 $$$ SS CI 1970 SSMH3S33E SSMH7S33E % /3/ /1/ /1/2009 $ Liner - Cured In Place Pipe 6/1/2010 $$$ SS CI 1970 SSMH10S33E SSMH12S30E % /1/ /1/ /11/2009 $ No Repair Necessary SS CI 1970 SSMH11S30E SSMH13S30E % /1/ /1/ /2/2008 $ No Repair Necessary SS CI 1970 SSMH1S35E SSMH3S33E % /5/ /1/ /1/2009 $ No Repair Necessary SS CI 1970 CO SSMH5N14E % /22/ /1/ /11/2009 $ No Repair Necessary SS HDPE 1970 CO SSMH5N11E-# % /22/ /1/ #N/A $ No Repair Necessary SS CI 1970 SSMH5N11E-# SSMH5N11E-# % /1/ /1/ /14/2008 $ No Repair Necessary SS CI 1970 SSMH7S33E SSMH10S33E % /1/ /1/ #N/A $ No Repair Necessary SS CI 1970 ABANDONED SSMH13S33E % /8/ /1/ #N/A $ No Repair Necessary SS CI 1970 SSMH12S30E SSMH11S30E % /8/ /1/ #N/A $ No Repair Necessary SS PVC 1970 SSMH2S33E SSMH3S33E % /5/ /1/ /2/2008 $ No Repair Necessary SS CI 1970 SSMH5N15E SSMH5N14E % /1/ /1/ /22/2006 $ No Repair Necessary SS PVC 1970 SSMH5N14E SSMH5N11E-# % /3/ /1/ #N/A $ No Repair Necessary Root Control Cost per Foot $1.50 Estimated Rehabilitation/ Replacement Cost Note: Data shown is only an example, and does not represent actual LBNL data.

73 v Design and Performance Provisions SWRCB Requirement: The SSMP must identify: (a) Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems; and (b) Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects. Taken from SWRCB GWDR Order No adopted May 2, Background LBNL has developed and maintains its own design and construction standards, specifications, and details in accordance with Department of Energy (DOE) standards and requirements, which allow the Facilities Division to accomplish the following objectives: New and rehabilitated sanitary sewer collection system infrastructure is designed and installed in compliance with the latest Federal and State regulations, and in line with general industry standards. New and rehabilitated sanitary sewer collection system infrastructure is inspected to ensure high quality and compliance with LBNL standards, which will maximize the operating life of the asset. This section fulfills the requirements of the GWDR SSMP mandatory element v. Last Revision: Page v-1

74 Element v. Design and Performance Provisions v-a. Design and construction standards and specifications Requirement: Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems. Discussion The LBNL is operated by the University of California under Contract 31 with the DOE. It is the responsibility of the LBNL to manage the facility, which includes ensuring that the sanitary sewer collection system is properly designed, constructed, maintained, and improved when necessary. As part of this responsibility, the LBNL maintains established design and construction standards, specifications, and details to ensure infrastructure projects are completed properly and at a high level of quality. LBNL has established a list of applicable State and National infrastructure design and construction standards and codes within the LBNL Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements, which are adhered to by LBNL employees and hired subcontractors (refer to Section 1 General Codes). All LBNL infrastructure project designs are either completed in-house by licensed Facilities Division Civil Engineers or outsourced to contracted Design Professionals. A Project Manager from the Facilities Division is assigned to each sanitary sewer collection system expansion or improvement project to ensure that LBNL-specific design requirements and other applicable regulations are adhered to throughout the project s duration. The LBNL standards consist of the following three major components, which are described below: Volume 1: Project Administration and Design Requirements Volume 2: Standard Specifications Volume 3: Standard Details Project Administration and Design Requirements The LBNL maintains project administration and design requirements for all infrastructure projects as published on the Facilities Division s Construction Details & Design Guidelines webpage. The LBNL Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements describes required design plan and construction document bid package submittal content and formats, and establishes review / approval milestones by specific LBNL staff. The LBNL Construction Standards and Design Requirements - Volume 1 Part 2 Design Requirements lists specific design criteria applicable to each engineering discipline. Specific sections that pertain to LBNL s sanitary sewer collection system reside within the Page v-2

75 Element v. Design and Performance Provisions General Civil Requirements, General Mechanical Requirements, and General Plumbing Requirements. LBNL has also developed a document entitled CAD Policies, Procedures and Standards for sub-contracted Design Professionals to ensure that electronic files a prepared uniformly and can be used efficiently by the Facilities Division when required for subsequent review or integration into site-wide utility mapping. Standard Project Specifications The LBNL maintains standard project specifications (Volume 2) for infrastructure projects at the LBNL site. LBNL s standard specifications have been prepared using the standard Construction Specifications Institute (CSI) MasterFormat divisions. Standard specifications have been developed to control product submittals, quality of materials, construction and installation methods, and testing requirements. LBNL has a developed a specification entitled "Site Sanitary Sewer Systems" (Section 02732) which specifies sewer system pipe material, product delivery and storage, pipe joint type, trenching, pipe installation, manhole and cleanout connection, construction site maintenance, and testing requirements for gravity sewer pipelines. There is also a "Sanitary Sewer Manholes" specification (Section 02607) which provides similar requirements for manholes. LBNL also maintains other typical specifications applicable to the sanitary sewer collection system such as site preparation, excavation, trenching, shoring, backfilling, coatings and linings, etc. LBNL does not currently have standard specifications pertaining to sewer pumping stations, as none currently exist and none are planned in the near future given the topography of the LBNL facility. Standard Construction Details The LBNL maintains standard construction details (Volume 3) for six specific infrastructure categories: Part I Civil / Site Details Part II Landscape Details Part III Architectural Details Part IV Structural Details Part V Mechanical Details Part VI Electrical Details Standard details specific to the sanitary sewer collection system reside within Part I Civil / Site Details. Details addressing items including pipe trenching, pipe bedding, manholes, cleanouts, sewer main crossings of other utility types, and tie-in of new sewer lines are established to ensure uniformity in the construction of the sanitary sewer collection system. Page v-3

76 Element v. Design and Performance Provisions Trenchless Rehabilitation and Replacement Specifications pertaining to trenchless rehabilitation and construction methods are typically developed by Design Professionals and tailored as needed to each specific project application due to the wide variety of available methods and fast pace with which trenchless rehabilitation technologies are developing. LBNL does have a specification entitled "Protective Coatings for New & Existing Manholes" (Section 02608) that is used for the rehabilitation of corroded or damaged manholes. Design and Construction Standard, Specification, and Details Update Process The LBNL maintains continuity with regard to the standard design requirements, specifications, and details used for sanitary sewer collection system improvement projects by using the same standards from project to project, with modifications made as needed for project-specific conditions. To keep the standards up-to-date, post construction reviews may be conducted following the completion of sanitary sewer collection system improvement projects by subcontracted Design Professionals. Any modifications to existing standards, or new standards developed by the Design Professionals throughout the project process may be incorporated or adopted by the LBNL into the published set of standards where appropriate. Modifications or new standards that were developed to address project or situation specific circumstances are maintained by the Facilities Division, and may be referenced on future projects where similar circumstances are encountered, but are typically not published as part of the official standards set. The Utilities Manager or Civil Engineer also periodically compares the LBNL standards to industry standard specifications developed by nationally recognized organizations to ensure that appropriate materials, installation methods, quality control, and environmental protection practices are being employed at LBNL. Page v-4

77 Element v. Design and Performance Provisions Related Documents o Refer to LBNL Construction Details and Design Guidelines Home o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 1: Administrative Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements% pdf o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 2: Design Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Design%20requirements_ pdf o Refer to LBNL Standard Project Specifications Construction_Guidelines/Standard_Project_Specifications.html o Refer to LBNL Standard Construction Details Plan & Schedule Task Responsible Party Scheduled Date Lead post-construction reviews of specifications and details used for sanitary sewer collection system infrastructure projects. Conduct general review of standard design requirements, specifications, and details by comparison with nationally recognized industry standards. Utilities Manager As Needed Page v-5

78 Element v. Design and Performance Provisions v-b. Procedures and standards for inspecting and testing Requirement: Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects. Discussion LBNL employs a detailed infrastructure project design and bid package preparation review procedure that ensures all applicable design and construction requirements are adhered to, including those established by LBNL within standard design requirements, specifications, and details, and those adopted by LBNL as described in the LBNL Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements. An overview of the processes described in this document is provided below. Reviews & Approvals A breakdown of the deliverables that are expected to be submitted at each milestone of the project design process is provided. At each milestone, excluding the final 100% submittal, the sub-contracted Design Professional will receive comments and mark-ups of drawings for inclusion into the next submittal. All plans and specifications deemed incomplete or incorrect shall be returned to the sub-contracted Design Professional with a request to improve the documents up to compliance with the LBNL standards. Internal LBNL Design Reviews are performed by: Facilities D&C Department, A/E Group Team Members Subject Matter Experts Project Manager Client/User Fire Marshal Environmental Health and Safety Team Members Plant Operations/M&O Department Quality Assurance Procurement Page v-6

79 Element v. Design and Performance Provisions External reviews may be required by: CEQA NEPA DOE/External Independent Review contracted by DOE Office of the President The Regents Third Party for Hazardous Materials Third Party for Structural Value Engineering Third Party for Cost Estimates Preliminary Design, Final Design, and Construction Document Phase Submittals For the Preliminary Design Phase, the LBNL has specific format requirements for Civil, Structural, Architectural, Mechanical, and Electrical discipline drawings and specifications. These requirements are available on the LBNL Facilities Division website and are intended to inform Design Professionals of submittal content and formatting requirements. The Final Design Phase plans and specifications should show in greater detail all of the items discussed and shown within the Preliminary Design Phase submittals. A detailed list of items required to be included in the final set of Construction Documents for each discipline is also provided. Bidding & Construction Phase LBNL has established protocols for bidding, contractor selection, and construction management that include contractor pre-qualification, pre-bid site visits, construction meetings, and preparation of record documents. The Construction Phase of infrastructure projects is monitored primarily by an LBNL Project Inspector. The Project Inspector is responsible for conducting periodic spot check inspections to verify compliance with established contract documents and standards, documenting those inspections, reporting instances of noncompliance, assisting the Design Professional in analyzing laboratory results from required materials testing (per project specifications), and monitoring the project for any unsafe practices. Inspection and Testing of New or Rehabilitated Sanitary Sewer Collection System Infrastructure LBNL ensures that a Project Inspector is appropriately appointed for every sanitary sewer collection system improvement project, and that they issue a certificate of approval based on the results of their inspections as required by the project specifications and contract documents for all work before final payment is made by LBNL. Inspection and testing requirements for sanitary sewer collection system infrastructure are included within the technical specifications, within a dedicated section based on the CSI MasterFormat. Currently, LBNL standard specifications applicable to the sanitary sewer collection system require deflection testing, air pressure testing, and CCTV inspection for sewer pipeline installation where appropriate. Page v-7

80 Element v. Design and Performance Provisions For sewer manholes, vacuum testing and water exfiltration testing may be required. For manhole coatings and linings, spark testing may be required to verify adequate installation. Testing and inspection requirements for trenchless rehabilitation, replacement, or installation of sewer pipelines and manholes are developed on a project by project basis and included within the technical specifications as appropriate for the construction methods and technologies selected. The inspection and testing procedures are typically developed by the sub-contracted Design Professional to verify the integrity of the product. Related Documents o Refer to LBNL Construction Details and Design Guidelines Home o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 1: Administrative Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements% pdf o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 2: Design Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Design%20requirements_ pdf o Refer to LBNL Standard Project Specifications Construction_Guidelines/Standard_Project_Specifications.html o Refer to LBNL Standard Construction Details Plan & Schedule No further efforts are projected for this element at the present time. Page v-8

81 vi Overflow Emergency Response Plan SWRCB Requirement: Each Enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, this plan must include the following: (a) Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner; (b) A program to ensure an appropriate response to all overflows; (c) Procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP. All SSOs shall be reported in accordance with this MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP should identify the officials who will receive immediate notification; (d) Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Emergency Response Plan and are appropriately trained; (e) Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and (f) A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge. Taken from SWRCB GWDR Order No adopted May 2, Background This section of the SSMP outlines the elements of the LBNL s SSO Emergency Response Plan. LBNL currently has a documented protocol for procedures that are followed in the event of an SSO at the LBNL facility. This document, the LBNL Emergency Response Protocol for Sewage and Potable Water Releases, (referred to as the Emergency Response Protocol), was prepared by LBNL s Environmental Services Group in October of This section fulfills the requirements of the GWDR SSMP mandatory element vi. Last Revision: Page vi-1

82 Element vi. Overflow Emergency Response Plan vi-a. Proper notification procedures Requirement: Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner Discussion LBNL s Emergency Response Protocol is used to guide LBNL responders through SSO response procedures. This protocol includes the following: General information about the LBNL sanitary sewer collection system, storm drain system, and surrounding landscape (Section 1.0) Defines individual staff responsibilities in the event of an SSO to ensure appropriate measures are taken by each individual (Section 2.0) List of phone numbers for internal offices and divisions as well as regulatory agencies that must be contacted in the event of an SSO (Section 3.0) Instructions for first responders, information on which agencies to contact, and testing procedures for analyzing the environmental impact of a spill (Section 4.0) Information on which regulatory agencies must be contacted, what information to supply them with, and due dates for report submittals (Section 5.0) During regular working hours, SSOs may be discovered by LBNL PMTs, or may be reported to the Facilities or EH&S Division by other LBNL personnel. All personnel at LBNL, through basic required training, are aware that the Facilities and EH&S Divisions are the appropriate groups to contact in the event of equipment / system malfunctions or spills. Facilities Division and EH&S Division contact information is available on the LBNL website, and key emergency contact information is available in the widely distributed Emergency Preparedness Employee Pocket Guide. Once Facilities or EH&S has been notified of an SSO, an investigation of the incident is initiated by a PMT or Plumbing Shop employee, and the event is reported as described in the Emergency Response Protocol. After-hours SSOs are typically discovered by LBNL Security, who initiate a response as detailed in the Sanitary Sewer Overflow Off-Hours Notification Procedure (see Attachment ii-4). Section 5.0 of the Emergency Response Protocol explains LBNL s sewage release notification and reporting requirements, which correspond with the Communication Requirements for Sanitary Sewer Overflows (see Attachment ii-5). These reporting requirements are in compliance with MRP No DWQ and SWRCB Order No. WQ EXEC, which govern the reporting of SSOs. Page vi-2

83 Element vi. Overflow Emergency Response Plan Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf o Refer to LBNL Emergency Preparedness Employee Pocket Guide Plan & Schedule No further efforts are projected for this element at the present time. Page vi-3

84 Element vi. Overflow Emergency Response Plan vi-b. A program to ensure appropriate response Requirement: A program to ensure an appropriate response to all overflows. Discussion The specific responsibilities of EH&S Division and Facilities Division Staff involved in the Emergency Response Protocol are described in Section 2.0 of the document. LBNL maintenance staff responding to the report of an SSO adhere to the procedures described in Section 4.0 of the Emergency Response Protocol. Upon receiving a report of an SSO, the main objectives of the response are to: Determine the cause of the spill Contain spilled sewage and return to the sewer system if possible Isolate the area affected by the spill Mitigate the cause of the spill Clean up the spill Adequately document the spill (may include surface water sampling) In the event of an SSO, the Facilities Division has the ability to suspend water usage in facilities upstream of a sanitary sewer collection system blockage. This strategy is commonly used to prevent the further release of sewage in the event that a blockage cannot be rapidly cleared. Facilities Division Staff are typically capable of mitigating and cleaning up Category 2 spills without the support of additional responders. The Facilities Division keeps up-to-date standard operating procedures (SOPs) for sewage spill mitigation and cleanup for both exterior and interior releases. These SOPs describe special equipment required, work steps to safely clean up the spill, and references to other SOPs for further information. Facilities Division Staff have three SOPs available, depending on whether the spill occurs indoors or outdoors, which are documents EMRG-050, and EMRG 051, and OPER-075. Sewage blockages causing SSOs are typically cleared by maintenance staff using a plumber's snake, if possible. For SSOs caused by blockages or other problems within the sanitary sewer collection system that cannot be addressed by Facilities Division Staff, an on-call contractor is called to clear the blockage and determine the cause of the blockage using CCTV inspection if necessary. LBNL maintains blanket contracts with sewer maintenance contractors capable of responding to SSOs 24/7. LBNL ensures that on-call contractors have the capabilities and equipment to appropriately mitigate the most severe possible spills that could occur at LBNL. Page vi-4

85 Element vi. Overflow Emergency Response Plan On-call sewer maintenance contractors are required to provide, at a minimum, the following equipment and capabilities: Hydro-jet equipment Vacuum pump truck equipment CCTV inspection equipment Excavation equipment for emergency open-cut repairs of buried infrastructure Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf o Refer to EMRG-050: Interior Emergency Procedure (Latest Revision) o Refer to EMRG-051: Exterior Emergency Procedure (Latest Revision) o Refer to OPER-075: Interior Sanitary Sewer Clearing Safety Operating Procedure Plan & Schedule No further efforts are projected for this element at the present time. Page vi-5

86 Element vi. Overflow Emergency Response Plan vi-c. Procedures to ensure prompt notification to regulatory agencies and other potentially affected entities Requirement: The OERP must include procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP. All SSOs shall be reported in accordance with the MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP should identify the officials who will receive immediate notification. Discussion SSO reporting to regulatory agencies as required by MRP No DWQ and SWRCB Order No. WQ EXEC is completed as described in SSMP sections ii-c and vi-a. Other agencies that may be notified as deemed necessary by the Environmental Manager, Stormwater Program Manager, or SSO Program Manager, in addition to those required to be notified per the MRP (per Emergency Response Protocol section 3.0) include: California Department of Fish and Game (in the event of a fish kill) City of Berkeley Department of Energy UC Berkeley EH&S Any SSO that affects a waterway or enters the LBNL storm drain system is likely to affect Strawberry Creek, which is the main drainage for the LBNL facility and the UC Berkeley Campus, as described in Section 1.0 of the Emergency Response Protocol. Any SSO affecting a waterway or the storm drain system is immediately reported to the UC Berkeley EH&S office as described in Section 5.0 so that SSO response activities can be coordinated between LBNL and UC Berkeley, where appropriate, to most effectively mitigate a spill. Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf Plan & Schedule No further efforts are projected for this element at the present time. Page vi-6

87 Element vi. Overflow Emergency Response Plan vi-d. Distribute OERP to all likely users and train Requirement: The OERP must include procedures to ensure that appropriate staff and contractor personnel are made aware of proper procedures and are appropriately trained. Discussion SSO Response Protocol Training All LBNL Staff involved with SSO response and notification are properly trained to follow established operating procedures as described in SSMP section iv-d. All LBNL Staff with SSO event management, communication, or reporting responsibilities as described in Emergency Response Protocol Section 2.0 are required to understand fully the procedures outlined in the document. The most recent copy of the Emergency Response Protocol is always available through the LBNL website to the agencies listed below that may also be involved with SSO response for the LBNL: UC Berkeley EH&S / Physical Plant Campus Services LBNL Fire Department LBNL Security On-Call Sewer Maintenance Contractors Post SSO Event Review Meetings Following an SSO event, the Environmental Manager, Stormwater Program Leader, SSO Program Leader, and any support staff involved with the response effort may hold a meeting to discuss the effectiveness of the response and determine if any modifications to the procedures outlined in the Emergency Response Protocol, or other SSO response SOPs would be beneficial. If the SSO event under discussion significantly affected the UC Berkeley campus or involved the response of UC Berkeley Staff (EH&S or Physical Plant Campus Services), appropriate UC Berkeley Staff will be invited to attend the meeting. A key topic of the discussion will be if any additional or ongoing actions in terms of operation and maintenance should be implemented to prevent an SSO from recurring in a similar location due to a similar cause, per the MRP No DWQ Record Keeping Requirements. The Environmental Manager ensures that the MRP Record Keeping Requirements are satisfied through documentation of the event through CIWQS reporting and standard LBNL Occurrence Reports (including identification of root cause and corrective action, if applicable, for SSOs). The Environmental Manager may subsequently update the Emergency Response Protocol if deemed necessary based on the success of any SSO response effort. UC Berkeley Staff may choose to incorporate changes to the UC Berkeley Emergency Response Program: Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek as a result of the meeting. Page vi-7

88 Element vi. Overflow Emergency Response Plan If any significant changes to the SSO Response Plan are made, a notification is made to the agencies listed above, as well as key LBNL personnel so that they may download and print the most up-to-date version of the document. Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf o Refer to UC Berkeley Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek Plan & Schedule Task Responsible Party Scheduled Date Hold a SSO response evaluation meeting with all staffed involved in response to an SSO (including UC Berkeley Staff if applicable). Implement any necessary additional or ongoing operation and maintenance activities to prevent future SSOs in the same location. Update the Emergency Response Protocol or SSO response SOPs as needed based on results of SSO response procedure evaluations, and notify key LBNL Staff involved with SSO response of the update. Environmental Manager Environmental Manager As Needed As Needed Page vi-8

89 Element vi. Overflow Emergency Response Plan vi-e. Procedures for emergency operations Requirement: Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities. Discussion LBNL has contracted 24/7 on-site emergency response capabilities available through the LBNL Fire Department (in association with the Alameda County Fire Department), and LBNL Security Services. The LBNL Fire Department staffs a minimum of 1 captain and 3 firefighters at all times at LBNL who serve as dispatchers for emergency calls. The LBNL Fire Department is the primary responder for all emergency events, including medical, fire, chemical, biological, and radiological releases. The LBNL Fire Department typically consults with the EH&S or Facilities Division in the case of an SSO that may involve the release of dangerous or hazardous materials. At least 3 fire fighters must be on duty at all times who are certified hazardous material technicians or specialists. The LBNL Fire Department has a Haz-Mat specific response vehicle on-site. If necessary, the LBNL Fire Department is capable of calling Berkeley Automatic Aid and/or Alameda Mutual Aid to respond to situations that require additional resources. The LBNL Security Service performs nighttime patrols of the LBNL facility, and would likely notice an SSO if one were to occur after hours. Additionally, the Security Service is trained to perform traffic control, crowd control, and first responder assistance. If necessary, the Security Service completes the 2-hour notification of regulatory agencies required for SSOs affecting waterways per SWRCB Order No. WQ EXEC. If necessary, the Security Service can request additional support from the UC Berkeley Police Department. Related Documents o Refer to LBNL Fire Department Technical Scope of Work o Refer to LBNL Security Services Scope of Work o Refer to LBNL Fire Department Website: o Refer to LBNL Emergency Preparedness Website: Plan & Schedule No further efforts are projected for this element at the present time. Page vi-9

90 Element vi. Overflow Emergency Response Plan vi-f. Program to ensure steps are taken to contain/prevent and/or minimize/correct effects from discharge to waters of the US Requirement: A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge. Discussion LBNL and UC Berkeley have established several strategies for minimizing the effect of potential sewage spills to surface waters. All drainage from the LBNL facility enters either the North Fork of Strawberry Creek, or the South Fork of Strawberry Creek, which are perennial streams that flow west through the UC Berkeley Campus. The North and South Fork join at the west end of the UC Berkeley Campus, and flow through a series of culverts into the San Francisco Bay. Strawberry Creek is not a source of drinking water. UC Berkeley maintains real-time water quality monitoring stations on the North and South Fork of Strawberry Creek that may detect the effects of SSOs, which could be identified due to spikes in stream temperature or conductivity. The UC Berkeley EH&S Division may notify the LBNL EH&S Division if spikes in water quality data are observed, so that an investigation of possible SSOs can be undertaken. The LBNL EH&S Division notifies the UC Berkeley EH&S Division in the case of any SSOs that reach surface waters, the drainage system, or any drainage channels since all creeks and streams on the LBNL site eventually drain through UC Berkeley and to Strawberry Creek. To prevent the migration of creek water that is contaminated with sewage downstream into the City of Berkeley and into the San Francisco Bay, UC Berkeley Staff may attempt to pump contaminated creek flows back into the sanitary sewer system (with EBMUD approval) if the event does not occur during wet weather and flow in the affected area of the creek is not too great (per Section I of the UC Berkeley Emergency Response Program: Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek). When SSOs affect surface waters, LBNL Staff coordinate with UC Berkeley EH&S and with the City of Berkeley to post water quality warnings on the UC Berkeley campus or within the City of Berkeley as directed by UC Berkeley's posting procedures as described in Section K of the UC Berkeley Emergency Response Program. Page vi-10

91 Element vi. Overflow Emergency Response Plan LBNL's Emergency Response Protocol, Section includes detailed procedures for water quality sampling following an SSO to a surface water to quantify the impacts of the spill. Specific sampling locations are identified depending on the watershed affected by an SSO. A map of the appropriate sampling locations is provided in Appendix A of the Emergency Response Protocol. Related Documents o Refer to LBNL Emergency Response Protocol for Sewage and Potable Water Releases (Latest Revision) otocol%20-%20sewage%20and%20water.pdf o Refer to UC Berkeley Sewage Spill Response Procedures for Releases or Threatened Releases to Central Campus Storm Drains or Strawberry Creek o UC Berkeley Strawberry Creek Real-Time Hydrologic Monitoring Data Plan & Schedule No further efforts are projected for this element at the present time. Page vi-11

92 vii FOG Control Program SWRCB Requirement: Each Enrollee shall evaluate its service area to determine whether a FOG control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate: a) An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG; b) A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of FOG generated within a sanitary sewer system service area; c) The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG; d) Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, BMP requirements, record keeping and reporting requirements; e) Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance; f) An identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and g) Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above. Taken from SWRCB GWDR Order No adopted May 2, Background The only facility at LBNL with the potential to introduce a significant level of fats, oils, and grease (FOG) to the sanitary sewer collection system is the LBNL cafeteria. The cafeteria is served by a grease interceptor located within the building that is serviced by Facilities Division Staff. There is also a vehicle fueling area (Building 76) at LBNL that is served by two fuel spill containment basins, which are essentially oil / water separators. Accumulated fuel and oil are regularly removed from the containment basins, and is not discharged to the sanitary sewer collection system. LBNL will benefit from the implementation of some aspects of a FOG control program as discussed below. This section fulfills the requirements of the GWDR SSMP mandatory element vii. Last Revision: Page vii-1

93 Element vii. FOG Control Program vii-a. FOG public outreach program Requirement: An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG. Discussion The possible sources of FOG discharge to the LBNL sanitary sewer collection system include the on-site cafeteria (food preparation area) and incidental discharges from other facilities. The Facilities Division Cafeteria Manager will discuss the implementation of FOG control practices with cafeteria management subcontractors. As discussed in SSMP section vii-c, the cafeteria has not been required to have an EBMUD Food Handling Facility Wastewater Discharge Permit. However, the Facilities Division s goal is to have the cafeteria operate in compliance with typical EBMUD maintenance and best management practice (BMP) standards (see SSMP section vii-d) as a measure to prevent FOG blockages in the LBNL sanitary sewer collection system or in the UC Berkeley / EBMUD systems downstream. The FOG control practices meeting between the Cafeteria Manager and cafeteria management subcontractors will include a discussion of the following topics: Review how the discharge of FOG material to the sanitary sewer collection system can cause blockages, SSOs, and compliance issues for LBNL. Review the current use of the cafeteria grease interceptor device. Provide EBMUD FOG control program materials: o EBMUD FOG control program brochure for food handling facilities o EBMUD grease interceptor maintenance fact sheet o EBMUD FOG BMP chart o EBMUD maintenance documentation log Discuss the need to implement a regular grease interceptor pumping schedule. Additionally, the SSO Program Manager periodically conducts the following activities (typically annually) to help ensure compliance with waste discharge regulations and requirements applicable to LBNL: Ensuring that labels and appropriate discharge controls are in place at all sinks and wastewater discharge areas in all LBNL facilities that prohibit the discharge of hazardous wastes and viscous / FOG materials through cyclical inspections and communication with the Cafeteria Manager. Page vii-2

94 Element vii. FOG Control Program These public outreach activities are in place to ensure that hazardous wastes or FOG materials are isolated and stored for later off-site disposal rather than discharged into the sanitary sewer collection system where they can cause blockages or compliance problems. Related Documents o Refer to EBMUD FOG Control Program Website _prevention_program/fog/default.htm Plan & Schedule Task Responsible Party Scheduled Date Discuss FOG control practices and provide EBMUD FOG control guidance documents to cafeteria managerial staff. Cafeteria Manager January 2010 Complete cafeteria sink labeling inspections and label sinks appropriately SSO Program Manager January 2010 Page vii-3

95 Element vii. FOG Control Program vii-b. FOG disposal Requirement: The FOG control program shall include a plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. Discussion Grease interceptors should be pumped regularly to remove accumulated grease. If grease is not regularly removed, the internal compartment designed to capture grease fills to maximum capacity, and additional grease is washed downstream into the sanitary sewer collection system. The LBNL Cafeteria Manager will establish a schedule for regular maintenance and grease removal for the cafeteria grease interceptor through its blanket contract for sewer maintenance services. Facilities operating grease interceptors are required to have waste removed by grease haulers licensed by the California Department of Food and Agriculture (CDFA) in accordance with Sections of the Food and Agricultural Code. Grease haulers are required to transport grease only to renderers also licensed by the CDFA according to Section of the Food and Agricultural Code. LBNL will ensure that the grease interceptor maintenance contractor is appropriately licensed as described above, and is on EBMUD s list of approved grease haulers. Related Documents o Refer to EBMUD FOG Control Program Website _prevention_program/fog/default.htm Plan & Schedule Task Responsible Party Scheduled Date Procure services for regularly scheduled maintenance and grease removal for LBNL cafeteria grease interceptor by licensed grease hauler. Cafeteria Manager February 2010 Page vii-4

96 Element vii. FOG Control Program vii-c. Legal authority Requirement: The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG. Discussion With respect to facilities other than the on-site cafeteria, LBNL Facilities Division and EH&S Division staff have full control over the operation of all processes and devices at LBNL which have the possibility of impacting the environment, and are responsible for ensuring those devices are operating properly so as to comply with all applicable regulations and LBNL environmental plans. The goal of the EH&S Division and Facilities Division is to prevent sewer blockages due to FOG in the LBNL sanitary sewer collection system and systems downstream, as well as to comply with EBMUD's discharge concentration limit for oil and grease of 100 mg/l, as stated in Ordinance No. 311A-03 Title II Section 3a and enforced through LBNL's site-wide sewage discharge permits. At this time, EBMUD has determined that the site-wide sewage discharge permit for LBNL is an adequate means to ensure that excessive levels of FOG are not discharged to the City of Berkeley and EBMUD sanitary sewer collection systems, and that a site-specific Food Handling Wastewater Discharge Permit is not required for the LBNL cafeteria. Management and operation of the LBNL cafeteria is conducted under subcontract. The LBNL Cafeteria Manager will review the existing contract and determine if amendments to the scope of work are necessary to ensure that typical EBMUD FOG control BMPs are implemented, BMP implementation is documented, and cafeteria food preparation workers are trained by management to follow published EBMUD FOG disposal BMPs to prevent the discharge of FOG to the LBNL sanitary sewer collection system. Related Documents o Refer to Cafeteria Operation Services Contract Scope of Work o Refer to EBMUD FOG Control Program Website _prevention_program/fog/default.htm Plan & Schedule Task Responsible Party Scheduled Date Review existing cafeteria operation services contract and determine if a revision to the scope of work is necessary for FOG control BMP efforts. Utilities Manager February 2010 Page vii-5

97 Element vii. FOG Control Program vii-d. Grease removal devices Requirement: The FOG Program shall include requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, BMP requirements, record keeping and reporting requirements. Discussion Grease Interceptor & Grease Trap Installation, Design, and Construction Standards LBNL has established a list of applicable State and National infrastructure design and construction standards and codes within LBNL s Construction Standards and Design Requirements - Volume 1 Part 1 Administrative Requirements. The California Plumbing Code and the American Society for Testing and Materials (ASTM) Standard are referenced within this document as applicable standards. The California Plumbing Code (which is based on the Uniform Plumbing Code) includes design and sizing requirements for gravity grease interceptors and hydromechanical grease traps within a chapter specifically dedicated to these devices (UPC Chapter 10). There are two ASTM standards which apply to gravity grease interceptors, which are: (1) ASTM C Standard Specification for Precast Concrete Grease Interceptor Tanks; (2) ASTM F Standard Specification for Corrugated High Density Polyethylene (HDPE) Grease Interceptor Tanks. An ASTM standard applicable to grease traps is currently under development. Section of the Uniform Plumbing Code (UPC) states that, An approved type of grease interceptor complying with the provisions of this section shall be correctly sized and properly installed in grease waste lines(s) leading from sinks and drains, such as floor drains and floor sinks and other fixtures or equipment in serving establishments such as restaurants, cafes, lunch counters, cafeterias, etc. where grease may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal. If any significant expansion to the existing cafeteria was undertaken, or if a new food handling facility was built at LBNL in the future, the requirement to install a grease interceptor or grease trap in accordance with the California / Uniform Plumbing Code to isolate FOG discharged from all fixtures where FOG may be present in the wastewater would be adhered to. The Facilities Division is responsible for maintaining copies of mechanical plans, plumbing plans, and device operation and maintenance manuals incase assistance with the operation or maintenance of a grease trap or interceptor is required. Page vii-6

98 Element vii. FOG Control Program Grease Interceptor & Grease Trap Maintenance, BMP, and Record Keeping Requirements To ensure that FOG discharges from the LBNL cafeteria are adequately controlled, the Facilities Division will require that cafeteria management conduct and document regular inspections (see SSMP section vii-e) to determine if proper grease interceptor maintenance is being performed, and BMPs are being implemented, following the implementation of FOG control BMPs in accordance with modifications to the cafeteria operation services contract (refer to SSMP section vii-c). The LBNL cafeteria does not operate under an EBMUD Food Handling Wastewater Discharge Permit, however the Facilities Division intends for grease interceptor maintenance and FOG control BMPs to be implemented equivalent to the requirements of the typical EBMUD permits to prevent FOG blockages in the LBNL sanitary sewer collection system. The basic operation, maintenance, and record keeping requirements for grease interceptors as stated in the EBMUD permit standard terms and conditions include: Operation and maintenance so as to comply with 100 mg/l local discharge limit for oil and grease at all times. Minimum quarterly grease pumping frequency, at which time all contents of interceptor are removed. For each grease interceptor maintenance activity, document the following: o Date of service o Volume pumped (gallons) o Name of approved food handling facility waste grease hauler o Approved waste grease disposal location o Maintain receipt / manifest from contractor Initially, the Facilities Division will schedule periodic grease interceptor maintenance through its blanket contract for sewer maintenance services. The contractor will be consulted to determine if the service frequency is either too long or too short, based on the observed accumulation of grease at the time of service. The service frequency may be adjusted based on the recommendations of the contractor, as deemed necessary by the Facilities Division. The Facilities Division will maintain documentation of grease interceptor maintenance by retaining work orders and invoices provided by the contractor, which must include identification of the data typically required to be kept by EBMUD listed above. In addition to implementing a schedule to regularly service the grease interceptor, the implementation of general FOG disposal BMPs in the kitchen area can help reduce the amount of FOG discharged through fixtures that may not be served by a grease interceptor. FOG disposal BMPs help to isolate and remove FOG prior to mixing with water or emulsification during the dish and ware cleaning process. Page vii-7

99 Element vii. FOG Control Program EBMUD publishes a BMP guide for food preparation, which includes activities such as: Training staff on implementation of the BMPs. Posting signs above sinks that prohibit the discharge of FOG. Collection and recycling or off-site removal (by licensed grease haulers) of waste cooking oil / fryer grease. o A receipt for the removal of stored grease by a licensed grease hauler should be maintained by the Facilities Division, similar to that maintained for grease interceptor pumping. Dry wiping grease and food solids from dishes prior to dishwashing. Regular grease interceptor / trap maintenance and inspection. Grease spill cleanup procedures. Cafeteria management subcontractors will be responsible for training staff who work in the food preparation or dishwashing area on the general implementation of the BMPs promoted by EBMUD, and ensuring that the BMPs are implemented on an ongoing and regular basis. Related Documents o Refer to LBNL Construction Standards and Design Requirements Volume 1 Part 1: Administrative Requirements (Latest Revision) Admin_&_Design_Guidelines/LBNL%20CS&DR%20- %20Admin%20Requirements% pdf o Refer to EBMUD FOG Control Program Website _prevention_program/fog/default.htm Plan & Schedule Task Responsible Party Scheduled Date Oversee initial FOG disposal BMP training for cafeteria food preparation / dishwashing staff by cafeteria management subcontractors. Cafeteria Manager April 2010 Maintain documentation of grease interceptor maintenance and grease removal, including receipts / manifests from grease hauling contractors. Cafeteria Manager Annually Page vii-8

100 Element vii. FOG Control Program vii-e. Inspection Requirement: Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance. Discussion LBNL cafeteria management subcontractors conduct annual inspections of the food preparation / dishwashing area to determine the success with which regular grease interceptor maintenance and FOG disposal BMPs are being implemented. The following items will be reviewed during the inspection / site visit: Use of cooking oil / grease storage or recycling bins for removal and off-site disposal. Posting of sink FOG disposal posters and BMP posters. General staff knowledge of FOG-related issues. Description of any unscheduled grease interceptor maintenance required, grease spills, accidental grease discharges, or other unusual grease-related events, including corrective action taken, if applicable. New staff sign-off for FOG control BMP implementation training. LBNL cafeteria management subcontractors document the results of the inspection using the form shown in Attachment vii-1, and delivers the completed form to the Facilities Division upon completion. Assessment of the grease interceptor maintenance requirements and for implementation of FOG disposal BMPs by LBNL cafeteria staff shall be conducted informally by either Facilities Division or EH&S Division Staff through the cafeteria operation services contract or during site visits. Related Documents o Attachment vii-1: Cafeteria FOG Control Inspection Form Page vii-9

101 Element vii. FOG Control Program Plan & Schedule Task Responsible Party Scheduled Date Oversee inspection of cafeteria food preparation facility by cafeteria management subcontractors to determine success of grease interceptor maintenance and FOG disposal BMPs activities. Cafeteria Manager Semi-Annually Page vii-10

102 Element vii. FOG Control Program vii-f. Identification of FOG problem areas Requirement: The FOG control program shall include an identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section. Discussion Currently, FOG blockages have not been documented as a problem within LBNL's sanitary sewer collection system. However, if FOG blockages occur in the future, or are discovered through CCTV inspections, Facilities Division and EH&S Division Staff plan to identify likely sources of FOG discharges through analysis of upstream operations and processes, and implement source control measures to prevent further discharges of FOG. The EH&S and Facilities Divisions will use their ability and authority to control discharge sources through process modifications or additional training of LBNL personnel in facilities that may act as a source of FOG to prevent any identified FOG issues rather than expend financial resources on sub-contractor services to mitigate FOG discharges that are affecting the sanitary sewer collection system. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page vii-11

103 Element vii. FOG Control Program vii-g. Source control measures Requirement: Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above. Discussion As discussed in SSMP section vii-f, any identified FOG problems in the sanitary sewer collection system will be analyzed to determine the potential sources that are contributing to the problem. EH&S Division and Facilities Division Staff will implement methods for source control as necessary to prevent future FOG discharges, which may include modifying the use of chemicals or materials in upstream processes, or installing additional pretreatment to capture FOG prior to discharge to the sanitary sewer collection system. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page vii-12

104 Attachment vii-1: Cafeteria FOG Control Inspection Form

105

106

107 viii System Evaluation and Capacity Assurance Plan SWRCB Requirement: The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate design storm or wet weather event. At a minimum, the plan must include: (a) Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events; (b) Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and (c) Capacity Enhancement Measures: The steps needed to establish a short- and longterm CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding. (d) Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D. 14. Taken from SWRCB GWDR Order No adopted May 2, Background LBNL conducts hydraulic analysis of its sanitary sewer collection system to ensure that it has adequate capacity to convey peak wet weather flow without resulting in capacity-related SSOs. The LBNL identifies existing hydraulic capacity deficiencies, develops capital improvement projects, and works to obtain funding for enhancements from the DOE. The LBNL also analyzes the existing system s capability to accommodate all future campus expansions outlined within the LBNL Long Range Development Plan (LRDP) and determines what enhancements must be made to maintain sufficient sanitary sewer collection system hydraulic capacity. The LBNL has established procedures for monitoring and evaluating infiltration and inflow (I/I), including guidelines for taking action to limit I/I. This section fulfills the requirements of the GWDR SSMP mandatory element viii. Last Revision: Page viii-1

108 Element viii. System Evaluation and Capacity Assurance Plan viii-a. Identify areas of hydraulic deficiency Requirement: Describe actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events. Discussion Previous Sewer System Hydraulic Capacity Assessments In 2005, Winzler & Kelly Consulting Engineers completed a technical memorandum entitled East Canyon Sanitary Sewer System Study Report, which presents alternatives aimed at eliminating surcharging occurring intermittently at manhole locations within the City of Berkeley s (City) sanitary sewer collection system along Dwight Avenue between Prospect Street and Telegraph Avenue. The surcharges are believed to result from a combination of sewer flows originating within the Strawberry section of the LBNL sanitary sewer collection system (including UC Berkeley Hill area buildings tributary to the Strawberry system) and private residences within the Panoramic Hill area. The three alternatives proposed by the consultant for addressing surcharging in the City s system were developed on the basis of re-routing flow from LBNL s 8-inch sewer main in Centennial Drive to a different location in an effort to avoid the bottleneck along Dwight Avenue. One proposed alternative includes diverting flow from the sewer main in Centennial Drive upstream of the Strawberry monitoring station into the Hearst portion of the LBNL sanitary sewer collection system through a series of pump stations to reduce the flow to the affected portion of the City s system downstream of the Strawberry monitoring station. The other two alternatives propose to redirect flow from the Centennial Drive sewer main to different locations within either the UC Berkeley system or City system to avoid the Dwight Avenue area. These two alternatives require construction of a new pipeline from LBNL SSMH 14S18E (east of Memorial Stadium) to the alternative points of delivery to divert the flow from its current path of delivery to the City system on Dwight Avenue. These two alternatives do not affect the hydraulic capacity of the existing LBNL sanitary sewer collection system, but only redirect the delivery location of the flow to the City s system. The East Canyon Sanitary Sewer System Study Report analyzed sewage flow in the Strawberry portion of LBNL s sanitary sewer collection system by gathering flow data from the Strawberry outfall monitoring station, estimating future campus expansion (per the LRDP) design flow demands, and quantifying both existing and future peak wet weather sewage flows. Page viii-2

109 Element viii. System Evaluation and Capacity Assurance Plan Flow monitoring data from the Strawberry monitoring station was used in the East Canyon Sanitary Sewer System Study Report to determine the average dry weather flow (ADWF) and peak dry weather flow (PDFW) rates. The total infiltration and inflow (I/I), which results from groundwater infiltration (GWI/I) and rain dependent infiltration (RDI/I) into the sanitary sewer collection system through manholes and pipe joints or pipe defects was assumed at a rate of twice the calculated PDWF. The maximum flow that the existing sanitary sewer collection system would experience is referred to as the peak wet weather flow (PWWF) and is calculated by summing the PDWF and the total I/I rate. To determine sewage flows that could be expected in the Strawberry portion of the LBNL sanitary sewer collection system in the future, a consultant analyzed LBNL s LRDP, which details planned LBNL campus facility improvements and anticipated population growth through the year The EPA Onsite Wastewater Treatment Systems Manual, which contains typical wastewater flows for various facility types, was used to estimate future PDWF from new or expanded facilities identified in the LRDP that are served by the Strawberry system. Additional PDWF due to an anticipated 25% population growth at LBNL was also quantified. The future PWWF was determined by adding the additional PDWF due facility expansions and population growth to the existing calculated PWWF. Following completion of the East Canyon Sanitary Sewer System Study Report by Winzler and Kelley, a hydraulic capacity analysis of the Centennial Drive sewer main was conducted by G.T Kunzt in a report entitled Strawberry Canyon Sewer Study to determine if it has adequate capacity to convey the existing and future PWWF identified. The report analyzed the Centennial Drive sewer main from LBNL SSMH 6S51E (at intersection of Lawrence Road and Centennial Drive) to LBNL SSMH 14S18E (east of Memorial Stadium). Flow line data was available for most of the sewer main from SSMH 6S51E down to the Strawberry monitoring station. Flow line data from the monitoring station to SSMH 14S18E was not available, and the existing ground slope was assumed to represent the sewer main slope. On average, the Centennial Drive sewer main follows the existing ground slope, at a burial depth of approximately 3 to 5 feet. From SSMH 6S51E to the Strawberry monitoring station, the flattest section of pipe is 3.4%, with a calculated hydraulic capacity in excess of the estimated future PWWF. However, downstream of the Strawberry monitoring station, the slope flattens to a minimum of 1.6%, with a calculated hydraulic capacity less than the future PWWF, but slightly above the existing PWWF. The capacity analysis was only conducted for the Centennial Drive sewer main within the Strawberry system because the hydraulic capacity analysis of the sewer main with respect to future PWWF was proven adequate up to the Strawberry monitoring station. The collector sewers tributary to the Centennial Drive sewer main were not analyzed because they have steep slopes similar to the Centennial Drive sewer main, are generally 6-inch diameter, and any single collector serves less than half of the total tributary area that delivers flow to the Strawberry monitoring station. Additionally, LBNL has never had a capacity-related SSO or observed surcharging in the sanitary sewer collection system during a rainfall event that would warrant additional analysis of collector pipes tributary to the Centennial Drive sewer main. Page viii-3

110 Element viii. System Evaluation and Capacity Assurance Plan A hydraulic capacity analysis of the Hearst portion of the LBNL sanitary sewer collection system has never been completed. However, at this time an analysis is not warranted because a capacity-related SSO has never occurred in the Hearst system, and no surcharging has been observed during rainfall events. Additionally, the system consists mainly of 6-inch and 8-inch diameter sewer lines with steep slopes, and the ADWF of the Hearst system is approximately one third of the ADWF measured in the Strawberry System. Identified Capacity Enhancement Measures The Strawberry Canyon Sewer Study recommended CCTV inspection of the Centennial Drive sewer main to determine if replacement or rehabilitation of the pipe was necessary upstream of the Strawberry monitoring station. Inspections that were completed in September of 2009 documented only light to moderate (severity 1-2) defects. The Strawberry Canyon Sewer Study hydraulic analysis indicated that lining of this portion of the sewer main could marginally increase hydraulic capacity by reducing the roughness of the pipe, and could extend the asset service life. Based on the results of the CCTV inspection, lining of Centennial Drive sewer main from the Strawberry monitoring station to SSMH 6S51E is considered a low priority project. The Strawberry Canyon Sewer Study recommended pipe bursting the existing 8 sewer main from the Strawberry monitoring station down to SSMH 14S18E, and installing a new 10 line with adequate capacity for future PWWF. This is considered a high priority project because the existing capacity of this 8 section of the sewer main is only slightly greater than the existing PWWF. Future System Capacity Analysis Measures The Facilities Division uses the sewer Asset Database to store manhole rim and invert elevation data, as well as pipeline upstream and downstream invert / flowline information. The Asset Database may be used to calculate the maximum full flow capacity of various gravity sewer assets. The hydraulic capacities of key pipelines in the Asset Database will be periodically compared to flow monitoring results obtained at the Strawberry and Hearst monitoring stations to determine if any areas of the system may be at or near maximum hydraulic capacity. Additionally, LBNL maintenance staff will conduct periodic observations of flow conditions in key areas of the sanitary sewer collection system during periods of heavy rainfall to identify any areas where surcharging may be occurring. Additional hydraulic analysis will be conducted for specific areas of the LBNL sewer collection system under the following circumstances: The percentage of the total estimated PWWF flow (as calculated separately for the Strawberry and Hearst systems) likely to be attributed to a given pipeline shows that an asset may be at or near maximum hydraulic capacity. Surcharging is observed in the sanitary sewer collection system where debris accumulation or line blockages were not involved. Expansions or improvements to existing LBNL facilities are anticipated that are likely to contribute additional sewage flow to a portion of the sanitary sewer collection system that has not had a hydraulic analysis completed to determine the extent of the potential impacts. Page viii-4

111 Element viii. System Evaluation and Capacity Assurance Plan The LBNL Facilities Division uses the sewer Asset Database to calculate maximum hydraulic capacities that are compared to flow monitoring data results for the six key sewer main lines described below: Strawberry sanitary sewer collection system: o SSMH 6S51E to SSMH 13S30E: Centennial Drive from Lawrence Road to Strawberry monitoring station (6-inch / 8-inch Centennial Drive main line) Assumed to carry 50% of total Strawberry PWWF o SSMH 1N33E to SSMH 12S30E: McMillan Road South to Strawberry monitoring station (6-inch line tributary to Centennial Drive main line) Assumed to carry 50% of total Strawberry PWWF o SSMH 13S30E to SSMH 14S18E: Centennial Drive from Strawberry monitoring station to Stadium Rimway (8-inch / future 10-inch Centennial Drive main line) Carries 100% of total Strawberry PWWF Hearst sanitary sewer collection system: o SSMH 10N18E to SSMH 5N12E: Cyclotron Road from Lawrence Road South (6-inch line tributary to Hearst main line) Assumed to carry 40% of total Hearst PWWF o SSMH 2N25E to SSMH 5N12E: Hearst sewer main line from Advanced Light Source Building to Cyclotron Road (8-inch Hearst main line) Assumed to carry 60% of total Hearst PWWF o SSMH 5N12E to SSMH 5N9E: Cyclotron Road to Hearst monitoring station (8-inch Hearst main line) Assumed to carry 100% of total Hearst PWWF The preliminary hydraulic analysis of other gravity sewer assets within the LBNL system may be warranted and conducted by the Facilities Division using the Asset Database based on the results of the analysis for the key sections listed above, and at the discretion of the Utilities Manager. Related Documents o Refer to the University of California Berkeley Lab 2006 Long Range Development Plan o Refer to East Canyon Sanitary Sewer System Study Report for the Lawrence Berkeley National Laboratory, Winzler & Kelly Consulting Engineers, August 2005 o Refer to Strawberry Canyon Sanitary Sewer Study for the Lawrence Berkeley National Laboratory, G.T. Kuntz Consulting Engineer, October 2008 o Refer to EPA Onsite Wastewater Treatment Systems Manual (Latest Revision) Page viii-5

112 Element viii. System Evaluation and Capacity Assurance Plan Plan & Schedule Task Responsible Party Scheduled Date Compare calculated maximum hydraulic capacities of the six key sewer main lines to estimated PWWF to identify potential hydraulic capacity deficiencies. Measure and record flow conditions in the sanitary sewer collection system during periods of high rainfall to identify areas of surcharging. Provide information to Utilities Manager. Utilities Manager SSO Manager Initially - August 2010 Periodically Thereafter Initially - August 2010 Periodically Thereafter Page viii-6

113 Element viii. System Evaluation and Capacity Assurance Plan viii-b. Establish appropriate design criteria Requirement: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria. Discussion Sanitary Sewer Collection System Hydraulic Analysis Criteria The LBNL Facilities Division employs the following basic design criteria when performing hydraulic analysis of the sanitary sewer collection system: Existing ADWF and PDWF rates determined by analysis of flow monitoring data from Hearst and Strawberry monitoring stations. Future sewage flow determined using EPA Onsite Wastewater Treatment Systems Manual for new or modified facilities. Hydraulic capacity determined using Manning s Equation with appropriate n values for various pipe material types. Surcharging of gravity sewer pipelines under PWWF typically not permitted. Maximum total design I/I rate is equal to PDWF, or 5-year 24-hour I/I rate if known PWWF = PDWF + I/I If a potential hydraulic deficiency is identified through the process of comparing estimated PWWF rates to maximum hydraulic capacities of specific gravity sewer main assets (as described in SSMP section viii-a), a more detailed analysis may be conducted to refine the results of the analysis. Depending on the extent of the potential deficiency identified using the Asset Database, the following additional analysis may be conducted: Determine in finer detail total ADWF, PDWF, and PWWF in specific gravity sewer assets due to tributary facilities according to one of the following methods: o Calculations of ADWF and PDWF for each tributary facility based on the EPA Onsite Wastewater Treatment Systems Manual. o Calculations of ADWF and PWDF for each tributary facility based on water use records. o Additional flow monitoring at area of concern. Analyze hydraulic capacity of specific assets using updated ADWF, PDWF, and PWWF using one or both of the following methods: o Hand calculations or spreadsheets using Manning s Equation (similar to analysis conducted in Strawberry Canyon Sewer Study). o Static / dynamic analysis using computer hydraulic modeling software. Page viii-7

114 Element viii. System Evaluation and Capacity Assurance Plan Selection of the appropriate method for determining the PWWF experienced by a specific gravity sewer asset will be made at the discretion of the Utilities Manager or consultant. A hydraulic deficiency is defined as surcharging within a gravity sewer asset, where the full flow capacity (open-channel) is exceeded at PWWF. Due to the relatively shallow burial depth of most sewer lines within the LBNL sanitary sewer collection system, surcharging is not typically permitted in design or within a hydraulic analysis. Typically, hand calculations or spreadsheet analysis are sufficient to determine if surcharging will occur, which if confirmed, will be addressed through an appropriate system improvement project. However, static or dynamic computer hydraulic modeling software may be employed to demonstrate through a sensitivity analysis the relative risk of an SSO that minor levels of surcharging present to support either the need for an improvement, or justify that no improvement is needed due to a low risk. I/I Monitoring LBNL conducts an analysis of flow monitoring data collected at the Strawberry and Hearst monitoring stations to determine system I/I rates. LBNL monitors I/I to ensure that the hydraulic capacity of the sanitary sewer collection system is not exceeded and to determine if I/I reduction projects should be initiated. Quantifying groundwater infiltration and inflow (GWI/I) and raindependent infiltration and inflow (RDI/I) is accomplished as described below: I. Groundwater infiltration is typically at its peak towards the end of the winter season in the months of March and April when groundwater tables and soil saturation are high. Average daily flow for days in these months without rainfall is compared to average daily flow for days in the months of August and September, when groundwater tables are typically lowest and soil saturation is low. The difference between the average daily flow for rainless days in March and April and the average daily flow in August and September represents the estimated average GWI/I rate for each system. II. 24-hour rainfall totals are collected for selected rainfall events throughout the winter from an on-site meteorological tower. The estimated total daily I/I at the monitoring station for each day where rainfall is recorded is calculated as the total daily flow minus the average day flow in the dry months of August and September. The estimated RDI/I for each day with rainfall is calculated as the total I/I minus the average GWI/I rate calculated as described above. III. The RDI/I is determined for each day included in the analysis versus the 24-hour rainfall depth. The system response in terms of total versus the 24-hour rainfall event can then be quantified. Historically, LBNL has designed the sewer collection system for a peak I/I rate equivalent to the PDWF. The analysis described above is used to determined the total peak I/I rate corresponding to the 5-year 24-hour return period rainfall event, which is then compared to the PDWF at the monitoring station. If the 5-year 24-hour I/I is found to be in excess of the PDWF, the LBNL Facilities Division may conduct an investigation to determine sources of excess I/I, as described in SSMP section viii-c. Page viii-8

115 Element viii. System Evaluation and Capacity Assurance Plan An example of the spreadsheet used to analyze I/I at sewer outfall monitoring stations is included in Attachment viii-1. Related Documents o Refer to East Canyon Sanitary Sewer System Study Report for the Lawrence Berkeley National Laboratory, Winzler & Kelly Consulting Engineers, August 2005 o Refer to Strawberry Canyon Sanitary Sewer Study for the Lawrence Berkeley National Laboratory, G.T. Kuntz Consulting Engineer, October 2008 o Refer to EPA Onsite Wastewater Treatment Systems Manual (Latest Revision) o Refer to East Canyon Sanitary Sewer System Study Report for the Lawrence Berkeley National Laboratory, Winzler & Kelly Consulting Engineers, August 2005 o Attachment viii-1: I/I Analysis Spreadsheet Example Plan & Schedule Task Responsible Party Scheduled Date Arrange for additional hydraulic analysis to be conducted when necessary due to comparison of flow monitoring data to Asset Database hydraulic capacity data, field observations, or impacts due to campus facility expansion that have not been analyzed previously. Utilities Manager As Needed Conduct I/I analysis of Hearst and Strawberry monitoring station flow data and quantify total I/I versus rainfall event. SSO Manager Annually Page viii-9

116 Element viii. System Evaluation and Capacity Assurance Plan viii-c. Capacity Enhancement Measures: Steps needed to establish short and long-term CIP for identified hydraulic deficiencies Requirement: Define the steps needed to establish a short and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding. Discussion I/I Source Identification CCTV inspection results can be used to identify I/I sources within the LBNL sanitary sewer collection system, including sources of system infiltration or previously unknown drainage connections. Significant I/I sources are documented using the AutoCAD Master Utility Map notes layer, or the sewer Asset Database. Actions necessary to stop I/I at identified sources are completed based on the severity of I/I and the hydraulic capacity of the downstream system. Other methods of I/I source identification may include smoke testing, dye testing, or additional targeted flow monitoring. The last LBNL sanitary sewer collection system I/I source identification project was conducted in the early 1990 s and included CCTV inspection and dye testing. The outcome of the investigation prompted the removal of several stormwater drainage connections and resulted in several sanitary sewer collection system manholes being sealed by maintenance personnel to reduce the overall system I/I rate. Capital Improvement Program for Sanitary Sewer Collection System Hydraulic Deficiencies Capital improvement projects associated with sanitary sewer collection system assets that cannot convey estimated existing PWWF flow are prioritized within the Asset Database in comparison to other identified capital improvement projects required to repair assets in poor physical condition based on the results of CCTV inspections. The following priorities are assigned to capacity-related capital improvement projects for existing hydraulic deficiencies: Priority 1: Asset cannot convey PDWF + 3-year 24-hour I/I. Priority 2: Asset cannot convey PDWF + 5-year 24-hour I/I or 2 x PDWF. Priority 3: Asset maximum hydraulic capacity only marginally greater than PDWF + 5-year 24-hour I/I or 2 x PDWF. Priority 4: Other low priority I/I reduction measures or capacity enhancement measures not needed to provide necessary design hydraulic capacity. Page viii-10

117 Element viii. System Evaluation and Capacity Assurance Plan The pipe bursting project for the Centennial Drive sewer main from the Strawberry monitoring station to LBNL SSMH 14S18E identified by G.T. Kunst within the Strawberry Canyon Sanitary Sewer Study is a Priority 3 project. The pipe lining project identified for the Centennial Drive sewer main upstream of the Strawberry monitoring station is a Priority 4 project that may be tentatively scheduled for completion within the next 10 years. Upon identifying a hydraulic deficiency within the sanitary sewer collection system, an improvement method alternatives analysis is conducted either internally within the Facilities Division or by consulting engineers. Alternatives to consider typically include: I/I reduction activities: o In certain cases, it may be possible to initiate I/I source identification and reduction activities to reduce PWWF to accommodate future capacity demands. The feasibility of cost effectively identifying and removing enough I/I to preclude the need for capacity improvement measures such as pipe upsizing or parallel construction will be evaluated on a case-specific basis. Pipe upsizing: o In cases where I/I reduction activities will not economically or sufficiently accommodate existing capacity demands, upsizing assets within the sanitary sewer collection system may be the only viable option. The asset s current condition may be a factor in determining if the LBNL should upsize or conduct parallel construction activities. Depending on the physical surroundings, open-cut construction or trenchless construction (i.e. pipe bursting) will be selected. Parallel construction or diversion: o In cases where I/I reduction activities will not economically or sufficiently accommodate existing capacity demands, constructing a new pipeline in parallel to a pipeline that has insufficient hydraulic capacity may be more cost effective and less disruptive than open-cut replacement or pipe bursting of the existing pipe. Additionally, options for diverting flow from one area of the system to another may also be viable. Funding for Capacity-Related Capital Improvement Projects and I/I Reduction Activities Small scale projects such as I/I source identification or reduction activities may be funded within the annual utility operating budget. Other capacity-related capital improvement projects are integrated into the LBNL Project Call List using the prioritization process described in SSMP section iv-c, conducted within the sewer Asset Database. The Project Call List for the sewer collection system is presented to the COO for approval and funding. Related Documents o Refer to Strawberry Canyon Sanitary Sewer Study for the Lawrence Berkeley National Laboratory, G.T. Kuntz Consulting Engineer, October 2008 Page viii-11

118 Element viii. System Evaluation and Capacity Assurance Plan Plan & Schedule Task Responsible Party Scheduled Date Prepare project descriptions and estimates for capacity-related capital improvement projects, and integrate into the overall sanitary sewer collection system capital improvement plan prioritization within the Asset Database. Utilities Manager As Needed Page viii-12

119 Element viii. System Evaluation and Capacity Assurance Plan viii-d. Schedule: Develop a schedule of completion dates for CIP Requirement: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D. 14. Discussion Scheduling of Near-Term Capacity Related Capital Improvement Projects Capacity-related capital improvement projects required to be completed within the next 5 years due to hydraulic deficiencies under existing PWWF are scheduled for completion based on the prioritization process described in SSMP section viii-c and iv-c. Scheduling and Funding for Capacity-Related Capital Improvement Projects Required to Support the LRDP If hydraulic capacity deficiencies are identified with regard to the existing sanitary sewer collection system s ability to convey PWWF due to additional flow contributed by new facilities, expanded facilities, or population increase based on the LRDP, the timing for construction of necessary sanitary sewer collection system improvements is determined according to the construction schedule for the facilities that create the impact to the existing system. The Facilities Division presents the required sanitary sewer collection system improvements, including project descriptions and cost estimates required to support LRDP projects to COO as part of the overall Project Call List. The cost to construct the identified capital improvement projects are typically included in the overall facility construction project cost (for the project creating the impact) to ensure that improvements in the sanitary sewer collection system required to support LBNL campus improvements are constructed prior to operation of the new or improved facilities. Related Documents o Refer to the University of California Berkeley Lab 2006 Long Range Development Plan Plan & Schedule No further efforts are projected for this element at the present time. Page viii-13

120 Attachment viii-1: I/I Analysis Spreadsheet Example

121 LBNL Sanitary Sewer Collection System Infiltration and Inflow Analysis Strawberry Monitoring Station / 2009 Date Scenario 24-Hour Flow (gpd) 24 Hour Rainfall (in) Dry Weather Flow (gpd) GWI/I Flow (gpd) RDI/I Flow (gpd) 2/11/09 Rainfall /5/09 Rainfall /24/09 High GW /30/09 High GW /12/08 Dry /20/08 Dry /3/08 Rainfall /20/08 Rainfall /12/08 Rainfall Avg. DWF (gpd) Avg. GWI/I (gpd) Scenario Types Rainfall High GW Dry RDI/I Data Analysis 5-Year 24-Hour Rainfall (in) 2 Total 5-Year 24-Hour (gpd) I/I to ADWF Ratio Year 24-Hour Storm (gpd) Note: This is only an example of the I/I analysis conducted by LBNL, and does not represent actual data collected by LBNL. RDI/I (gpd) Strawberry System RDI/I y = 52538x Hour Rainfall (in)

122 ix Monitoring, Measurement and Program Modifications SWRCB Requirement: The Enrollee shall: (a) Maintain relevant information that can be used to establish and prioritize appropriate SSMP activities; (b) Monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP; (c) Assess the success of the preventative maintenance program; (d) Update program elements, as appropriate, based on monitoring or performance evaluations; and (e) Identify and illustrate SSO trends, including: frequency, location, and volume. Taken from SWRCB GWDR Order No adopted May 2, Background This section of the SSMP describes the LBNL s current system for monitoring, scoring, and evaluating the effectiveness of SSMP programs executed by LBNL through the use of performance criteria. Performance criteria are regulatory requirements and quantifiable goals established by the LBNL, within the Environmental Compliance Audit and Assessment Program (ECAAP), and are used to define varying levels of service for specific SSMP programs. Comparing the actual performance of LBNL SSMP programs against criteria established in the ECAAP helps to identify programs or activities that may require more resources or changes to program implementation methodology in order to achieve an acceptable level of service. This section fulfills the requirements of the GWDR SSMP mandatory element ix. Last Revision: Page ix-1

123 Element ix. Monitoring, Measurement and Program Modifications ix-a. Maintain relevant information to prioritize SSMP activities Requirement: The Enrollee shall maintain relevant information that can be used to establish and prioritize appropriate SSMP activities. Discussion The LBNL Facilities Division and EH&S Division maintain records and documentation of sanitary sewer collection system management, operation, and maintenance activities in various forms for the purpose of SSMP program performance evaluation and SSMP auditing. A summary of the documentation maintained for the SSMP is provided below. Policy Document Updates A record of revisions is maintained for all major policy documents, to keep track of changes to LBNL and DOE policies and procedures, as well as changes to regulatory requirements which are addressed by the documents. Mapping System Updates As discussed in SSMP section iv-a, the Facilities Division maintains a map revision block for each utility grid map that is used to document map updates resulting from additions or revisions based on observations by LBNL staff or contracted utility surveys. Sanitary Sewer Collection System Operation and Maintenance Activity Tracking and Documentation As discussed in SSMP section iv-b, the Facilities Division uses a sewer system Asset Database to document the completion of regular preventative maintenance work such as hydroflushing, CCTV inspection, and root control. The Asset Database is also used to document SSOs, blockages, system repairs, or other notable occurrences. The Asset Database can be used to review the maintenance history of any individual asset, and set and track maintenance frequencies. In addition to the Asset Database, the Facilities Division maintains a hard copy file of all invoices and work orders provided by contractors who perform sanitary sewer collection system maintenance activities. CCTV Inspection Data The Facilities Division receives standard NASSCO PACP and MACP reports from contractors performing condition assessment of the sanitary sewer collection system, as well as digital pictures and videos for each inspection. The Facilities Division enters quick rating information into the Asset Database for the initial prioritization of potential capital improvement projects, and maintains an electronic file structure to store the condition assessment data which is reviewed in detail to determine appropriate asset repair or replacement methods. Page ix-2

124 Element ix. Monitoring, Measurement and Program Modifications Sanitary Sewer Collection System Project Call List The Asset Database is used to store a summary of condition assessment results (in the form of NASSCO quick ratings), and is a platform for planning sanitary sewer collection system capital improvement projects. The Asset Database stores priority rankings for identified repair or replacement projects, and is used to identify potential Project Call List items, which are presented by the Facilities Division to the Chief Operating Officer for approval. Training LBNL uses its JHA program to establish EH&S training schedules and document completed training using an online database for all LNBL personnel. SSO Response LBNL maintains records of all SSO events in compliance with the requirements of MRP No DWQ, which include: a. All Certified SSO reports, as submitted through CIWQS b. All original recordings for continuous monitoring instrumentation: o Any available records from the Strawberry and Hearst sewer outfall monitoring stations, as well as information available from UC Berkeley Strawberry Creek water quality monitoring stations is obtained and documented in the event of an SSO. c. Service call records and complaint logs: o All un-planned work in response to identified sanitary sewer collection system deficiencies is documented in the Asset Database. d. SSO calls (as documented in standard Occurrence Reports) e. SSO records (as documented in standard Occurrence Reports) f. Steps that have been and will be taken to prevent the SSO from recurring and a schedule to implement those steps (as documented in standard Occurrence Reports) g. Work Orders, work completed, and any other maintenance records from the previous 5 years which are associated with responses and investigations of system problems related to SSOs: o Documented within the Asset Database h. A list and description of complaints from the previous 5 years: o Documented within the Asset Database i. Documentation of performance and implementation measures for the previous 5 years o Documented through the PI tracking process FOG Control Program The Facilities Division tracks and maintains records of maintenance activities for the LBNL cafeteria grease interceptor by subcontractors (in the form of invoices and work orders) to ensure that excessive amounts of FOG are not discharged to the LBNL sanitary sewer collection system. Page ix-3

125 Element ix. Monitoring, Measurement and Program Modifications Additionally, the results of regular inspections of the food preparation facility by cafeteria management to ensure the implementation of FOG disposal BMPs are documented using inspection checklists, and are kept by the Facilities Division. Sanitary Sewer Collection System Capacity Assessments The results of sanitary sewer collection system capacity assessments are documented within the analysis and technical reports produced either internally by Facilities Division staff or engineering contractors. Performance Evaluations and SSMP Audits The results of performance criteria reviews are published in official ECAAP reports, which are made available and maintained for a minimum of 5 years. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page ix-4

126 Element ix. Monitoring, Measurement and Program Modifications ix-b. Monitor and measure effectiveness of SSMP elements Requirement: The Enrollee shall monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP. Discussion The LBNL Facilities Division and EH&S Division are responsible for assessing the success of sanitary sewer collection system management, operation, and maintenance activities, and refining those activities if they are not successful in minimizing the occurrence of SSOs. LBNL Performance Evaluation Process and Procedures Clause H.14 of Contract 31 requires that the LBNL implement a performance-based management approach which will include the use of objective performance goals and indicators, agreed to in advance of each evaluation period, as standards against which the LBNL s overall performance of the scientific and technical mission obligations under this contract will be assessed. LBNL already has in place several documents that describe how specific performance measures and goals are established and how performance against the measures and goals is assessed. The major documents governing the process of performance evaluation and auditing include the following: Performance Evaluation and Measurement Plan (PEMP) EH&S Self-Assessment Program EH&S Division Self-Assessment Manual Environmental Compliance Audit & Assessment Program (ECAAP) Manual Performance Evaluation and Measurement Plan The Performance Evaluation and Measurement Plan (PEMP) is the key metric by which the effectiveness of LBNL s performance-based management approach is evaluated. The PEMP measures performance according to 8 core goals which have been established by the DOE Office of Sciences, which are applied to all other DOE national laboratories as well. Goals 1-3 relate to the accomplishment of overall research and technological missions, and performance measures specific to those goals are established by DOE. Core goals 4-8 relate to management and operation of LBNL facilities in support of goals 1-3, and performance measures specific to those goals are established cooperatively by UC, DOE, and LBNL functional managers. Proper execution of the SSMP could be related to goals 5 and 7, as stated below: Goal 5: Sustain excellence and enhance effectiveness of integrated safety, health, and environmental protection. (This goal evaluates EH&S procedures) Goal 7: Sustain excellence in operating, maintaining, and renewing the facility and infrastructure portfolio to meet Laboratory needs. (This goal evaluates Facility Management Procedures) Page ix-5

127 Element ix. Monitoring, Measurement and Program Modifications For each of the 8 main goals, several more specific subordinate goals are established which relate to accomplishment of the main goal. The subordinate goals may change from year to year based on the collaboration of UC, DOE, and LBNL functional managers. A quantifiable grading metric is developed for each separate subordinate goal to establish a letter grade. The subordinate goals are individually weighted to allow for the calculation of a single letter grade for each of the main goals. The main goals are also weighted to allow for an overall LBNL performance grade to be calculated. With respect to the 8 main PEMP goals, goal 5 relates to environmental compliance (i.e. prevention of SSOs), which is a responsibility of the EH&S Division, and goal 7 relates to infrastructure management (i.e. sanitary sewer collection system operation, maintenance, and capital improvements). It is unlikely that performance measurement and evaluation of SSMP programs would be directly incorporated into the PEMP as subordinate goals to main goals 5 and 7, and more likely that the completion of SSMP objectives would be incorporated into more overarching measurements such as: the completion percentage of an established list of new key environmental management programs, or integration of sanitary sewer collection system maintenance and capital costs into measurements of overall infrastructure cost trends (examples only). Often, subordinate goals and grading metrics for those goals are established based on key issues identified in Division Self Assessment Programs. Self Assessment Programs Each LBNL division is responsible for developing and implementing their own Integrated Safety Management (ISM) Plan which details the work and research that is to be completed by the division and defines hazards and safety practices that must be followed to reduce the risk to employees, the public, and the environment. The Self Assessment Program was implemented as a way for each division to evaluate the work that is being completed, make continuous improvements to processes and procedures, and evaluated work practices set forth in each division s ISM Plan. The Environment, Safety, and Health Self-Assessment Program was developed by the DOE Office of Contract Assurance (OCA) to define the methods by which performance of EH&S activities and operations are measured. Three methods are established, which include: 1. Division Self Assessment 2. Environmental Compliance and Audit Assessment 3. Contract 31 Appendix B Self Assessments (PEMP) The Division EH&S Self Assessment Manual is a guide for conducting the self assessment referred to in item 1 above. OCA typically works with functional managers to establish performance measures for the Division Self Assessment. The performance measures typically focus on the implementation of programs designed to ensure safe work practices and compliance with applicable Federal, State, and local regulatory requirements. The Division Self Assessment Page ix-6

128 Element ix. Monitoring, Measurement and Program Modifications is conducted annually, and a report is made to OCA. The annual EH&S Self Assessment Report may address significant elements identified under the Environmental Compliance Audit and Assessment Plan (ECAAP). The ECAAP focuses on ensuring that environmental programs and processes comply with guiding regulations. The EH&S Division, working with OCA, establishes a 3-year rotating schedule to evaluate significant EH&S programs that are identified using a risk-based analysis conducted by OCA. Currently, the ECAAP has established 9 categories that are audited, one of which includes wastewater discharges. At least one of the 9 categories will be reviewed each quarter, and each category will be audited a minimum of once every 3 years. As part of the 2009 ECAAP program, wastewater discharges are slated for auditing in the fourth quarter of 2009, and will be audited again within 3 years. ECAAP audits are performed by a subject matter expert, an LBNL peer, or an environmental consultant who is knowledgeable about the environmental regulations and requirements that are being audited. The purpose of ECAAP audits is to ensure that environmental issues, risks, and impacts are being properly identified, controlled, and corrected. The results of ECAAP or other EH&S program assessments may be tracked in the Corrective Action Tracking System (CATS) Database. The CATS database is used to track compliance issues and corrective actions that have been identified to address those issues. Integration of Performance Indicator Tracking for the SSMP The requirement to monitor the implementation and measure the effectiveness of each element of the SSMP will be integrated into the existing LBNL performance-based management approach described above. Compliance with the GWDRs (SWRCB Order No ) is tied closely to the Wastewater Discharge Program, since the primary objective of the SSMP is to minimize the occurrence of prohibited SSOs. Therefore, the tracking of SSMP performance criteria will be accomplished in conjunction with the Wastewater Discharge Program assessment conducted in accordance with the ECAAP. A performance criteria worksheet will be developed which includes metrics by which the performance of SSMP programs can be measured, similar to the methodology used in the PEMP. The performance criteria worksheet will be included with ECAAP assessments of the Wastewater Discharge Program. Description of SSMP Performance Criteria Tracking Methods The LBNL EH&S Division has assigned the SSO Program Manager as the responsible person (RP) for tracking performance against the established measures by periodically reviewing the applicable data maintained by LBNL with regard to the sanitary sewer collection system. An ECAAP tracking worksheet has been developed for elements of the SSMP for which both the Facilities Division and EH&S Division have responsibilities. Page ix-7

129 Element ix. Monitoring, Measurement and Program Modifications The ECAAP worksheet describes various criteria that will be tracked and evaluated relative to a specific SSMP program. The responsible person for the assessment is identified. A description of the criteria used in the analysis, including where the information is stored and how to use the information to rate performance compared to established performance criteria, is given. The SSO Program Manager then makes SSMP program modification recommendations within the ECAAP report, which are intended to increase future ratings to at least acceptable levels, if applicable. Any significant deficiencies in performance that are identified may be entered into the CATS database for corrective action and tracking purposes. Frequency of ECAAP Completion The SSO Program Manager will prepare the ECAAP worksheet, and it will be integrated into the Wastewater Discharge Program ECAAP assessment at the time it is conducted. An ECAAP report will be completed and submitted to the Environmental Manager and the Utilities Manager. Related Documents o Refer to LBNL Performance Evaluation and Measurement Plan FY2008 Self Assessment Report o Refer to LBNL EH&S Self-Assessment Program (Latest Revision) %20draft% _%20FINAL.pdf o Refer to LBNL EH&S Self-Assessment Manual (Latest Revision) o Refer to LBNL Environmental Compliance Audit & Assessment Program Manual (Latest Revision) o Refer to the LBNL Corrective Action Tracking System (CATS) Primer / Database Plan & Schedule Task Responsible Party Scheduled Date Incorporate SSMP performance criteria into the ECAAP wastewater program assessment worksheet. Prepare ECAAP report; provide information to Environmental Manager and Utilities Manager. SSO Program Manager SSO Program Manager As Scheduled Under the ECAAP As Scheduled Under the ECAAP Page ix-8

130 Element ix. Monitoring, Measurement and Program Modifications ix-c. Assess success of preventative maintenance program Requirement: The Enrollee shall assess the success of the preventative maintenance program. Discussion Specific performance criteria will be developed for key SSMP programs and elements for which ongoing activities are occurring. Performance objectives and the metrics used to evaluate performance against those objectives may be changed by the Utilities Manager and Environmental Manager. The performance indicators established for the first year of SSMP implementation are listed below: Table ix-1: SSMP Performance Indicators SSMP Element Responsible Person Performance Indicator Establishment of sewer system pipeline asset entries in the new Asset Database. iv Mapping iv- O&M Program iv Capital Improvement Program Utilities Manager Utilities Manager Utilities Manager Establishment of sewer system manhole asset entries in the new Asset Database. Entry of critical asset data in the new Asset Database. Completion of AutoCAD map quality assurance. Establishment of asset-specific maintenance frequencies. Success of establishing an average annual sewer system maintenance cost within budget. Percentage of sewer pipe assets with overdue regular maintenance. Percentage of sewer collection system that has been CCTV inspected within the last 10 years. Average overall NASSCO quick rating for the sewer collection system. Prioritization and planning for future capital improvement projects. Page ix-9

131 Element ix. Monitoring, Measurement and Program Modifications Table ix-1: SSMP Performance Indicators (Continued) SSMP Element Responsible Person Performance Indicator Number of sewer system blockages or un-planned maintenance activities (non-sso). vi SSO Response vii FOG Control Program viii System Evaluation and Capacity Assurance Environmental Manager Utilities Manager Utilities Manager Number of Category 2 SSOs. Number of Category 1 SSOs. Average response time for SSOs during normal business hours. Average response time for SSOs after normal business hours. Initial FOG control practices implementation meeting held. Review and modification of cafeteria operation services contract for FOG control BMP implementation. Success of implementation of FOG disposal BMPs by cafeteria staff. Determination of maximum hydraulic capacity in key sewer trunk lines. Determination of existing peak flow in key sewer main lines. Identification of necessary hydraulic capacity improvements. Determination of existing GWI/I and RDI/I levels in the system. Related Documents o Refer to Waste Water Discharge Program ECAAP worksheet. Plan & Schedule Task Responsible Party Scheduled Date Review and update evaluation criteria within ECAAP, based on past performance and changing SSMP goals or requirements. SSO Manager Annually Page ix-10

132 Element ix. Monitoring, Measurement and Program Modifications ix-d. Update SSMP program elements based on performance evaluations Requirement: The Enrollee shall update program elements, as appropriate, based on monitoring or performance evaluations. Discussion The Facilities Division and EH&S Division are responsible for updating the SSMP based on the results of program performance evaluations using the ECAAP process. The process for updating the SSMP generally follows the subsequent procedure that is completed as part of the SSMP audit process (refer to SSMP section x): 1. Responsible persons annually review the performance criteria they have charge over, assess the success of the elements of the SSMP relative to established benchmark or level of service goals (i.e. metrics), and make recommendations to change SSMP elements or the implementation methods for those elements so that the established goals are reached. 2. The Utilities Manager and Environmental Manager review the completed ECAAP reports. 3. The Utilities Manager and Environmental Manager assess the recommendations from the ECAAP reports, comments received from LBNL employees, CATS database entries, and feedback received from other LBNL divisions. 4. The Utilities Manager and Environmental Manager draft updates to various elements of the SSMP based on their review of the performance of the SSMP and recommendations received by various parties. 5. The Utilities Manager and Environmental Manager will incorporate the updates into the official version of the SSMP and present it before the Facilities Division Director, EH&S Division Director, and/or Chief Operating Officer (if changes are significant or have budgetary impacts) to obtain Department of Energy approval for recertification as required by the GWDR, and described in SSMP section x. The SSMP must be recertified by the Department of Energy at least every 5 years. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page ix-11

133 Element ix. Monitoring, Measurement and Program Modifications ix-e. Identify and illustrate SSO trends Requirement: The Enrollee shall identify and illustrate SSO trends, including: frequency, location, and volume. Discussion The SSO Program Manager will investigate SSO trends during the ECAAP process utilizing SSO event documentation maintained by LBNL as described in SSMP section ix-a, and data available through the CIWQS website. Any trends will be noted on the ECAAP report. Strategies for preventing repeat or recurring SSOs are developed during post SSO event review meetings as discussed in SSMP section vi-d. Related Documents None. Plan & Schedule No further efforts are projected for this element at the present time. Page ix-12

134 x SSMP Program Audits SWRCB Requirement: As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee s compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them. Taken from SWRCB GWDR Order No adopted May 2, Background The internal audit of the SSMP is based on the SSMP element performance evaluations conducted using the ECAAP process described in SSMP section ix. By conducting an internal audit of the SSMP, the LBNL can determine if compliance with the GWDRs is being achieved, and the overall goals of the SSMP as defined in SSMP section i are being fulfilled. This section fulfills the requirements of the GWDR SSMP mandatory element x. Last Revision: Page x-1

135 Element x. SSMP Program Audits x. SSMP program audits Requirement: As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum the audits must occur every two years and a report must be prepared and kept on file. Discussion SSMP Audit Procedure The SSO Program Manager is responsible conducting the internal audit of the SSMP. The purpose of the SSMP audit is to evaluate the LBNL s effort to meet the requirements of the GWDRs and implement sewer system management, operation, and maintenance programs as stated in the SSMP. The LBNL operates a relatively small sanitary sewer collection system, therefore conducting an audit every two years is sufficient. Evaluation of established performance criteria, described in SSMP section ix, forms the basis for the audit process. The criteria are used to determine if programs are being implemented as planned. The evaluation process can be used to determine if the necessary resources are in place for successful execution of key programs and activities. The results are reviewed by the SSO Program Manager, with input from the Utilities Manager as described in SSMP section ix-d. The results are intended to be used by the Environmental Manager and Utilities Manager to guide decision making regarding modifications and updates to SSMP programs that are necessary. Consisting of two components, the SSMP internal audit is designed to highlight the performance results and to document recommended changes. The body of the ECAAP report is made up of the performance worksheets, which will be completed during the course of the two year audit period by the SSO Program Manager. The SSO Program Manager generates an ECAAP report which includes the following information: SSO history, describing the number and nature of SSOs over the past five years. Summary of progress made implementing SSMP elements which have a plan and schedule for full implementation. Summary of the effectiveness of the implemented SSMP elements based on performance indicator (PI) evaluation. Specific identification of performance areas in need of improvement, including a summary of proposed modifications to SSMP elements and programs over the next audit period to address all identified areas of past poor performance. Page x-2

136 Element x. SSMP Program Audits Summary of proposed SSMP modifications (i.e. new programs, new performance indicators, etc.) not tied to poor performance, but tied to a desire to change or increase the scope of management, operations, and maintenance activities. The SSO Program Manager also reviews the entire SSMP as part of the audit, makes any necessary minor text revisions to reflect current activities, updates reference document hyperlinks, and updates applicable implementation schedules for each SSMP element to reflect completed tasks, extended time schedules, or new tasks. The SSO Program Manager must also review the performance criteria to determine if changes to metrics are warranted, if any goals should be retired based on previous completion, and if new goals should be developed to tracking additional areas of SSMP program performance or ongoing compliance efforts. SSMP Update and Re-certification Procedure As the scope and activities of the SSMP evolve over time, the text of the SSMP is modified as needed to reflect those changes. At a minimum, the SSMP is officially updated once every 5 years if changes are not made during consecutive SSMP audit periods. For each major SSMP update, the document is re-certified by the DOE as required by GWDR section D.14. Related Documents o none Plan & Schedule Task Responsible Party Scheduled Date Collect and review performance tracking worksheet, and any CATS database entries applicable to the sanitary sewer collection system. Evaluate the results of performance tracking, recommendations provided, and any applicable corrective actions recently taken to generate changes to SSMP programs, procedures, and text as needed. Present significant SSMP modifications to the DOE and obtain approval / re-certification of the SSMP. SSO Program Manager Environmental Manager Annually As Needed / Every 5 Years Minimum Page x-3

137 xi Communication Program SWRCB Requirement: The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented. The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee s sanitary sewer system. Taken from SWRCB GWDR Order No adopted May 2, Background This section of the SSMP outlines the elements of the LBNL plan of communication with LBNL personnel on the development, implementation, and performance of the SSMP. Additionally, action taken by LBNL to communicate with the entities that manage the sanitary sewer collection systems to which LBNL s system is tributary is discussed. This section fulfills the requirements of the GWDR SSMP mandatory element xi. Last Revision: Page xi-1

138 Element xi. Communication Program xi-a. Plan of communication with public Requirement: The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented. Discussion Communication with LBNL Personnel The LBNL sanitary sewer collection system only services the LBNL facility, therefore the only users of the system are LBNL personnel. Ensuring that LBNL personnel are aware of issues pertinent to sewage waste disposal and regulatory compliance requirements is key to the successful implementation of the SSMP. Specific procedures that aid open communication between the Facilities Division, EH&S Division, and LBNL personnel that are currently in place include: Lessons Learned: After each sanitary sewer collection system related incident, the LBNL EH&S Division considers the development of a Lessons Learned document to analyze the source of the problem and the responding tactics used. This communication provides LBNL personnel an opportunity to analyze the steps taken to resolve an incident and change any response techniques to better handle a similar situation in the future. Corrective Action Tracking System: The LBNL Corrective Action Tracking System (CATS) is a forum where any sanitary sewer collection system deficiencies or compliance issues can be brought to the attention of the EH&S Division by LBNL personnel. The CATS database is a system used to record issues that could potentially jeopardize human or environmental health and safety. All LBNL personnel have access to the CATS website and are encouraged to note any and all concerns that they feel should be investigated. The CATS database is an effective communication medium for LBNL personnel to provide observations and information to those responsible for managing the sanitary sewer collection system. Sink Labeling: All sinks within the LBNL are required to be properly labeled to reduce the risk of processed or hazardous waste dumping. These sink labels communicate certain restrictions to help ensure specific wastes are disposed of properly and are not dumped into the sanitary sewer collection system. FOG control program: LBNL cafeteria management is required to conduct periodic inspections of the food preparation and dishwashing area to ensure that proper FOG disposal BMP procedures are being implemented at the cafeteria. Cafeteria management provides inspection reports to the Facilities Division semi-annually, which functions as a Page xi-2

139 Element xi. Communication Program communication mechanism to ensure that FOG is prevented from being discharged to the sanitary sewer collection system. Site Environmental Reports: Each year, a Site Environmental Report is issued by the EH&S Division, which provides a summary of environmental protection and regulatory compliance efforts, which includes a discussion of wastewater discharges. Information included in the Site Environmental Report may include a brief description of activities implemented under the SSMP, and performance of SSMP related programs, which is made available to all LBNL personnel. ECAAP: The ECAAP process (refer to SSMP section ix-a) allows for oversight and assessment of SSMP programs and practices by other LBNL subject matter experts and facility managers who may provide input on the further development of the SSMP and its implementation. Information Available to the General Public The LBNL makes a wide variety of documents available through the internet via LBNL s website. Documents that are made available to the public include (but are not limited to): Published LBNL Policy Documents: ISM, EMS, ECAAP, PEMP, etc. SSMP and SSMP Audits Standard Infrastructure Design Requirements, Specifications, and Details Standard Facility Operating Procedures Site Environmental Reports Related Documents o Refer to the EH&S Lessons Learned Website o Refer to the LBNL Corrective Action Tracking System (CATS) Primer / Database o EH&S Site Environmental Reports o Refer to LBNL Environmental Compliance Audit & Assessment Program Manual (Latest Revision) Plan and Schedule Task Responsible Party Scheduled Date Make SER SSMP documents available on the EH&S Division website. Environmental Manager As Needed Page xi-3

140 Element xi. Communication Program xi-b. Plan of communication with satellite collection systems Requirement: The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee s sanitary sewer system. Discussion The LBNL sanitary sewer collection system is a satellite system to both UC Berkeley and the City of Berkeley sanitary sewer collection systems, which ultimately discharge to treatment facilities operated by EBMUD. EBMUD is the lead agency for a Technical Advisory Board composed of representatives from all tributary system agencies serviced by EBMUD. The Technical Advisory Board meets periodically to discuss flow management, flow monitoring, SSMP issues, and various system improvement activities. The East Canyon Sanitary Sewer System Study Report, conducted in 2005 to determine alternatives for rerouting sewage flow from the LBNL campus to prevent observed surcharging within the City of Berkeley sanitary sewer collection system, is an example of a collaborated effort between multiple agencies. The LBNL Facilities Division and EH&S Division communicate with UC Berkeley, the City of Berkeley, and EBMUD regarding significant key issues, which may include the following: SSO Event Communication: As required due to the nature and extent of the event. Hydraulic Capacity Evaluations: Upon completion of studies to provide information such as existing flow monitoring results and projections of future sewage flows based on planned facility development. System Improvements: During the project planning phase. SSMP Performance Evaluations and Audits: Made available upon completion. Related Documents o Refer to East Canyon Sanitary Sewer System Study Report for the Lawrence Berkeley National Laboratory, Winzler & Kelly Consulting Engineers, August 2005 o Refer to the EBMUD SSMP Communication Section Communication%20Plan.pdf Page xi-4

141 Element xi. Communication Program Plan & Schedule Task Responsible Party Scheduled Date Maintain pertinent documentation of communications conducted with UC Berkeley, City of Berkeley, and EBMUD such as meeting notes, memorandums, and s. Utilities Manager / Environmental Manager / Wastewater Discharge Program Manager As Needed Page xi-5