and Condition Assessment Plan 4.1 Introduction 4.1.1 Purpose This addresses the requirements of Section IV.A. of the EPA Order. The plan documents the progress that each agency has made to date regarding sewer inspection, and also documents the practices and schedules that the Sewerage Agency of Southern Marin (SASM), Almonte Sanitary District, Alto Sanitary District, City of Mill Valley, Homestead Valley Sanitary District (HVSD), Richardson Bay Sanitary District (RBSD), and Tamalpais Community Services District (TCSD) will follow when they inspect sewer pipes and manholes in the future in order to assess the condition of inspected facilities. 4.1.2 Requirements of the EPA Amended Order for Compliance The EPA Order, Section IV.A. includes the following requirements: IV. COLLECTION SYSTEM ASSESSMENTS A. Sewer and Condition Assessment: 1. By April 15, 2009, SASM and the member agencies each shall submit a plan to EPA for periodic inspection and assessment of the condition of gravity sewers and maintenance holes throughout the agency s collection system. The inspection and condition assessment program shall be sufficient to evaluate the condition of pipes following blockage-related spills, identify pipes in need of emergency repair, and provide a schedule for completion of a system-wide condition assessment no later than April 15, 2010. The requirements for system-wide condition assessment may be satisfied with reliable data obtained from an inspection and assessment conducted within the last five years. The plan shall describe: a. Inspection methods to be used, including direct visual inspection, closed circuit television (CCTV) inspection, and whether SASM and the member agencies will purchase, lease or contract for CCTV inspection equipment;. b. An inspection schedule including an estimation of the miles of sewer pipe and number of maintenance holes that will be inspected each year for the next two years; and c. A system for timely evaluation of inspection findings and documentation of the assessed condition. 2. By October 15, 2008, SASM and the member agencies each shall submit a report to EPA summarizing inspections and condition assessments completed during the previous five years. The report shall include activities conducted to complete an inspection and condition assessment plan by April 15, 2009. 3. By October 15, 2009, SASM and the member agencies each shall submit an annual progress report to EPA summarizing the inspection methods and findings of sewer pipe condition assessments conducted during the previous year and the estimated miles of sewer pipe and number of maintenance holes to be inspected during the current year. August 2009 4-1
4. By October 15, 2010, SASM and the member agencies shall submit a final report summarizing the findings of the inspections and condition assessments required by Paragraph IV.A.1. This Inspection addresses the requirements of the EPA Order. August 2009 4-2
4.2 Sewerage Agency of Southern Marin 4.2.1 Recent Sewer Inspection and Condition Assessment Activities 4.2.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, SASM has collected a significant quantity of sewer inspection data. Figure 4-1 summarizes which sewers have been previously inspected. 4.2.1.2 Evaluation Methods SASM typically utilizes a defect coding system to identify the type and severity of each defect in each sewer pipe that has been inspected. The following section summarizes the defect coding system and the defect rating system that was utilized in the past. Defect Coding Systems SASM utilized a customized defect coding system utilized by several agencies in Northern California. This defect rating system identifies the type and severity of defects and also has a rating score associated with some defects. The defect coding system that will be utilized in the future is described below. Condition Rating Systems The condition rating system for sewer pipe inspections performed prior to April 10, 2008 is known as the fault ratio. The fault ratio is calculated by taking the sum of the rating scores for all defects found in one pipe segment divided by the lineal feet of pipe in the pipe segment, or: Fault Ratio = (Sum of DEFECT RATING SCORES) / (LINEAL FEET OF PIPE SEGMENT) The fault ratio system was designed to quickly determine the relative condition of each line segment that had been inspected. The following fault ratio ranges were developed to assign a condition rating: < 5 Good condition > 5 and <10 Marginal condition >10 Poor condition Utilizing this formula and these condition rating definitions, Table 4-1 summarizes the condition ratings for the pipes in the SASM service area that have previously been inspected. August 2009 4-3
Figure 4-1: SASM Pipes Inspected after April 10, 2003 and prior to April 10, 2008 August 2009 4-4
Table 4-1: SASM Condition Rating Summary Pipes Inspected April 10, 2003 to April 10, 2008 Condition Rating Rating Description # of Pipe Segments Lineal Feet of Sewer Mains Good Does not require repair or rehabilitation. 56 11,175 Marginal Some deterioration but should not require rehabilitation in the near future. 9 3,289 Poor Significant deterioration. Should be considered for rehabilitation in the Rehabilitation and Replacement Plan. 5 988 Totals 70 15,453 The condition rating system that will be utilized for inspection data collected after April 10, 2008 is described below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.2.1.3 Documentation and Recordkeeping All defects observed have been documented. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.2.2 Planned Inspection and Condition Assessment Program SASM plans to inspect the remaining gravity sewer pipes and manholes that have not been recently inspected. These remaining sewers will be inspected prior to April 15, 2010. Table 4-2 summarizes the quantity of sewers that have been inspected and the quantity of pipes in the planned inspection program. Table 4-2: SASM Inspection and Condition Assessment Program Summary SASM Sewer Mains Lineal Feet of Sewer Mains Pipes Database 61,850 Agency Force Mains (Remove) (33,767) Gravity Pipes Subtotal 28,083 Inspected between April 13, 2003 and April 10, 2008 (15,453) Total Lineal Feet to be Inspected Prior to April 15, 2010 12,630 Table 4-3 summarizes the schedule for future sewer inspections through April 15, 2010. Table 4-3: SASM Inspection Schedule through April 15, 2010 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 0 Between April 16, 2009 and April 15, 2010 12,630 Totals 12,630 Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. August 2009 4-5
4.2.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.2.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.2.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long- August 2009 4-6
term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.2.2.4 Inspection Schedule 2008 through April 15, 2010 Table 4-2 summarizes the overall status of the collection system inspection and rehabilitation program, and Figure 4-1 shows the locations of the pipes and manholes that were excluded from the current inspection program. The remaining pipes (12,630 lineal feet) and manholes in the system are scheduled for inspection before April 15, 2010, and are also shown in Figure 4-1. Table 4-3 shows that 12,630 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-7
4.3 Almonte Sanitary District 4.3.1 Recent Sewer Inspection and Condition Assessment Activities 4.3.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, Almonte collected some sewer inspection data. However, when the inspections were performed, Almonte s contractor was primarily visually inspecting the sewers to identify and repair defects. When major defects were found, a repair was performed. However, detailed defect code data and condition rating data was not collected during these inspections. Therefore, Almonte has elected to re-inspect the entire gravity sewer system after the Order was issued on April 10, 2008 and prior to the April 15, 2010 deadline for completion of the inspection program as stated in the Order. 4.3.1.2 Evaluation Methods Defect Coding Systems The defect coding system that will be utilized in the future is covered below. Condition Rating Systems The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.3.1.3 Documentation and Recordkeeping As documented above, records of past inspection of sufficient detail to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers does not exist. Future inspection will be detailed as detailed below. 4.3.2 Planned Inspection and Condition Assessment Program Almonte plans to inspect the entire gravity sewer system prior to April 15, 2010. Table 4-4 summarizes the schedule for future sewer inspections through April 15, 2010. Table 4-4: Almonte Inspection Schedule through April 15, 2010 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 34,303 Between April 16, 2009 and April 15, 2010 0 Totals 34,303 Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. 4.3.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator August 2009 4-8
to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.3.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.3.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and longterm repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.3.2.4 Inspection Schedule 2008 through April 15, 2010 Table 4-4 shows that 34,303 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-9
4.4 Alto Sanitary District 4.4.1 Recent Sewer Inspection and Condition Assessment Activities 4.4.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, Alto did not collect detailed sewer inspection data. Therefore, Alto has elected to inspect the entire system between April 10, 2008 and April 15, 2010, the deadline for completion of the inspection program as stated in the Order. 4.4.1.2 Evaluation Methods Defect Coding Systems The defect coding system that will be utilized in the future is covered below. Condition Rating Systems The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.4.1.3 Documentation and Recordkeeping As documented above, records of past inspection of sufficient detail to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers does not exist. Future inspection will be detailed as detailed below. 4.4.2 Planned Inspection and Condition Assessment Program Alto plans to inspect the entire gravity sewer system prior to April 15, 2010. Table 4-5 summarizes the schedule for future sewer inspections through April 15, 2010. Table 4-5: Alto Inspection Schedule through April 15, 2010 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 14,874 Between April 16, 2009 and April 15, 2010 0 Totals 14,874 Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. 4.4.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. August 2009 4-10
For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.4.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.4.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and longterm repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.4.2.4 Inspection Schedule 2008 through April 15, 2010 Table 4-5 shows that 14,874 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-11
4.5 City of Mill Valley 4.5.1 Recent Sewer Inspection and Condition Assessment Activities 4.5.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, Mill Valley has collected a significant quantity of sewer inspection data. Figure 4-2 summarizes which sewers have been previously inspected. 4.5.1.2 Evaluation Methods Rather than collecting defect coding data in the past, Mill Valley had each inspection video reviewed by a qualified consultant to determine the condition of each pipe segment and to recommend future action to correct the deficiencies found in each pipe segment. The recommendations are documented in the City s current Clean and CCTV Sanitary Sewer Records. The following section summarizes how these decisions have been adapted to generate sewer condition ratings. Defect Coding Systems As noted above, Mill Valley did not utilize a formal defect coding system for past sewer inspections. The defect coding system that will be utilized in the future is described below. Condition Rating Systems The condition rating system selected for sewer pipe inspections performed prior to April 10, 2008 is as follows: A (Excellent): Has been recently removed and replaced via open trench or pipe bursting, or if the pipe is newly installed. B (Good): Generally good condition but required one or more point repairs. C (Fair): Some deterioration and has been referred for cleaning, root cutting or chemical root treatment. D (Poor): Indicates that the pipe has significant deterioration and that the pipe requires further analysis to determine whether a rehabilitation project is needed. These pipes have the following comment rehabilitation to be determined in the CCTV database. Utilizing these condition rating definitions, Table 4-6 summarizes the condition ratings for the pipes in the Mill Valley service area that have previously been inspected. August 2009 4-12
and Condition Assessment Plan Figure 4-2: Mill Valley Pipes Inspected after April 10, 2003 and prior to April 10, 2008 August 2009 1. 4-13
Pipe and Maintenance Hole Inspection and Condition Assessment Plan Table 4-6: Mill Valley Condition Rating Summary Pipes Inspected April 10, 2003 to April 10, 2008 Condition Rating Rating Description # of Pipe Segments Lineal Feet of Sewer Mains A Excellent 194 24,675 B Good 31 949 C Fair 36 4,106 D Poor 12 2,465 Totals 273 32,195 The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.5.1.3 Documentation and Recordkeeping All defects observed have been documented. A copy of all future defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.5.2 Analysis and Inspection Schedule Development Section IV.A.1 of the Order requires Mill Valley to submit a schedule for completion of a system-wide condition assessment no later than April 15, 2010. Mill Valley will not be able to meet this aggressive inspection schedule due to current budget limitations. To correct this situation, the City plans to establish a new sewer rate to be able to accomplish the sewer inspection and condition assessment program and other necessary programs. However, Mill Valley needs to fully identify future operating costs, maintenance costs, capital improvement program costs (including sewer rehabilitation and replacement), and SASM treatment costs, prior to establishment of a new rate. It is estimated that a new sewer rate will take effect by July 1, 2011. In an effort to reduce the number and severity of SSOs from the Mill Valley system, it was decided to focus limited near-term resources on sewer cleaning efforts to meet the 3-year cleaning and hot spot cleaning program required by the Order. Some limited funding does remain for sewer inspection, so Mill Valley plans to inspect a minimum of 10 miles of sewers in the elevated risk zones by April 15, 2010. In order to identify which sewers should be inspected first, Mill Valley undertook a risk analysis of the system to identify areas with elevated risk of SSOs and to identify areas with lower risk of SSOs. Figure 4-3 identifies the low SSO risk zones in Mill Valley, which include areas that were constructed more recently with modern PVC sewer pipes. The low SSO risk zones also include areas with fewer households and very low flows, and the low SSO risk zones include portions of the system that have been recently rehabilitated. Due to the fact that very few SSOs have occurred in the low SSO risk zones, Mill Valley plans to begin the sewer inspection and condition assessment program with inspection all pipes in the elevated risk zones as funding becomes available. Once the sewers in the elevated SSO risk zones have been inspected, then Mill Valley will re-evaluate the low SSO risk zones. If it is determined that SSO rates are beginning to increase in the low SSO risk zones, then Mill Valley will prepare a plan to inspect the appropriate portions of the low SSO risk zones. Mill Valley asserts that this approach will meet the intent of the Order while taking the City s budget constraints into consideration. August 2009 2. 4-14
Figure 4-3: Mill Valley Low SSO Risk Zones August 2009 4-15
4.5.3 Planned Inspection and Condition Assessment Program The City of Mill Valley plans to inspect all gravity sewer pipes and manholes in the elevated risk zones prior to June 30, 2013. Some of pipes in the overall system were not scheduled for CCTV inspection because they have already been inspected, because they have already been rehabilitated or replaced, or because they fall into the low risk zones. Table 4-7 summarizes the planned inspection program: Table 4-7: Mill Valley Planned Inspection and Condition Assessment Program Summary Sewer Mains GIS Database Lineal Feet of Mains Mill Valley Pipes Database 331,778 Remove: Private Lines (9,020) Mill Valley Pipes and Pipes from Other Agencies 322,758 Remove: Owned by Others: (28,083) Mill Valley Pipes 294,675 Remove: Force Mains: (2,552) Mill Valley Gravity Pipes Subtotal: 292,123 Remove: Remove: Remove: Previously Inspected with no Rehabilitation or Replacement to Date: (24,464) Recently Rehabilitated or Replaced with Inspection Data (7,731) Recently Rehabilitated and Replaced without Inspection Data (978) Remaining Pipes in the Mill Valley System: 258,949 Remove: Pipes in Low Risk Zones: (111,008) Pipes in Elevated Risk Zones that have Not Been Inspected, Rehabilitated or Replaced: 147,941 Length of Sewers in Elevated Risk Zones to be Inspected Prior to April 15, 2010 (10 miles): 52,800 Remaining Sewers in Elevated Risk Zones to be Inspected Prior to June 30, 2013: 95,141 Table 4-8 summarizes the schedule for future sewer inspections through June 30, 2013. August 2009 4-16
Table 4-8: Mill Valley Inspection Schedule through June 30, 2013 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 0 Between April 16, 2009 and April 15, 2010 52,800 Between April 16, 2010 and April 15, 2011 31,714 Between April 16, 2011 and April 15, 2012 31,714 Between April 16, 2012 and June 30, 2013 31,713 Totals 147,941 Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. 4.5.3.1 Planned Inspection Methods CCTV data will be collected both by City crews and with CCTV contractors. CCTV data will be collected with fully equipped CCTV vehicles or with push cameras. If a CCTV contractor is utilized, the vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. City crews and inspection contractors may also utilize portable push cameras. This type of camera may not have a prehensile head, but will still be capable of viewing and identifying defects located in the pipe. 4.5.3.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an August 2009 4-17
alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.5.3.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor or by City crews. A copy of all defect code data will be retained for evaluation and to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the equipment utilized by City crews or the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and analyzed. 4.5.3.4 Inspection Schedule 2008 through April 15, 2010 The City s planned sewer inspection schedule is shown in Table 4-8. Table 4-8 shows that a minimum of 52,800 lineal feet are scheduled for inspection prior to April 15, 2010. This is due to the City s funding constraints detailed in.5.2. Table 4-8 also shows that an additional 95,141 lineal feet of sewers will be inspected prior to June 30, 2013. August 2009 4-18
4.6 Homestead Valley Sanitary District 4.6.1 Recent Sewer Inspection and Condition Assessment Activities 4.6.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, Homestead Valley collected sewer inspection data. Figure 4-4 summarizes which sewers have been previously inspected. 4.6.1.2 Evaluation Methods Homestead Valley typically utilizes a defect coding system to identify the type and severity of each defect in each sewer pipe that has been inspected. The following section summarizes the defect coding system and the defect rating system that was utilized in the past. Defect Coding Systems Homestead Valley utilized a customized defect coding system utilized by several agencies in Northern California. This defect rating system identifies the type and severity of defects and also has a rating score associated with some defects. The defect coding system that will be utilized in the future is covered below. Condition Rating Systems The condition rating system for sewer pipe inspections performed prior to April 10, 2008 is known as the fault ratio. The fault ratio is calculated by taking the sum of the rating scores for all defects found in one pipe segment divided by the lineal feet of pipe in the pipe segment, or: Fault Ratio = (Sum of DEFECT RATING SCORES) / (LINEAL FEET OF PIPE SEGMENT) The fault ratio system was designed to quickly determine the relative condition of each line segment that had been inspected. The following fault ratio ranges were developed to assign a condition rating: < 5 Good condition > 5 and <10 Marginal condition >10 Poor condition Utilizing this formula and these condition rating definitions, Table 4-9 summarizes the condition ratings for the pipes in the Homestead Valley service area that have previously been inspected. August 2009 3. 4-19
Figure 4-4: HVSD Pipes Inspected after April 10, 2003 and prior to April 10, 2008 August 2009 4. 4-20
Table 4-9: HVSD Condition Rating Summary Pipes Inspected April 10, 2003 to April 10, 2008 Condition Rating Rating Description # of Pipe Segments Lineal Feet of Sewer Mains Good Does not require repair or rehabilitation. 98 16,151 Marginal Poor Some deterioration but should not require rehabilitation in the near future. 58 11,230 Significant deterioration. Should be considered for rehabilitation in the Rehabilitation and Replacement Plan. 57 8,034 Totals 213 35,415 The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.6.1.3 Documentation and Recordkeeping All defects observed have been documented. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.6.2 Planned Inspection and Condition Assessment Program Prior to April 15, 2010, Homestead Valley Sanitary District plans to inspect the gravity sewer pipes and manholes that have not been recently inspected, rehabilitated, or replaced. Table 4-10 summarizes the quantity of sewers that have been inspected, rehabilitated or replaced, and the quantity of pipes in the planned inspection program. Table 4-10: HVSD Planned Inspection and Condition Assessment Program Summary HVSD Pipes Database Sewer Mains GIS Database Remove: Remove: Remove: Lineal Feet of Mains 66,080 a Previously Inspected with no Rehabilitation or Replacement to Date (32,684) Recently Rehabilitated or Replaced with Inspection Data (2,731) Recently Rehabilitated and Replaced without Inspection Data (1,379) HVSD Lines Planned for Inspection: 29,286 Footnotes: a. Excluding any abandoned or private lines. Table 4-11 summarizes the schedule for future sewer inspections through April 15, 2010. August 2009 4-21
Table 4-11: HVSD Inspection Schedule through April 15, 2010 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 0 Between April 16, 2009 and April 15, 2010 29,286 Totals 29,286 Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. 4.6.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.6.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade August 2009 4-22
5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.6.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and longterm repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.6.2.4 Inspection Schedule 2008 through April 15, 2010 Table 4-10 summarizes the overall status of the collection system inspection and rehabilitation program, and Figure 4-4 summarizes the pipes and manholes that were excluded from the current inspection program. The remaining pipes (29,286 lineal feet) and manholes in the system are scheduled for inspection before April 15, 2010, and are also shown in Figure 4-4. Table 4-11 shows that 29,286 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-23
4.7 Richardson Bay Sanitary District 4.7.1 Recent Sewer Inspection and Condition Assessment Activities 4.7.1.1 Previously Inspected Areas During the five years prior to issuance of the Order, Richardson Bay has collected a significant quantity of sewer inspection data. Figure 4-5 summarizes which sewers have been previously inspected. 4.7.1.2 Evaluation Methods Richardson Bay had two methods for evaluation of sewer inspection data collected during the period between April 10, 2003 and April 10, 2008. Early in the inspection program, Richardson Bay inspected pipes but did not record detailed defect code data. However, every time a serious defect was found, the defect was corrected through a sewer repair and rehabilitation program. Therefore, if a pipe was inspected during this time period and was not repaired or rehabilitated, the pipe was in generally good condition. Later in the program, Richardson Bay began to utilize a more structured defect coding system to identify the type and severity of each defect in each sewer pipe that has been inspected. The following section summarizes the defect coding system and the defect rating system that was utilized in the past. Defect Coding Systems For the inspections where defect codes were collected, Richardson Bay utilized a customized defect coding and rating system utilized by several agencies in Northern California. This defect coding and rating system identifies the type and severity of defects and also has a rating score associated with some defects. The defect coding system has been included in Appendix L, and the condition rating system that utilizes these defect codes is described below. The defect coding system and the defect rating system that will be utilized in the future is covered below. Condition Rating Systems The condition rating system for sewer pipe inspections performed prior to April 10, 2008 is known as the fault ratio. The fault ratio is calculated by taking the sum of the rating scores for all defects found in one pipe segment divided by the lineal feet of pipe in the pipe segment, or: Fault Ratio = (Sum of DEFECT RATING SCORES) / (LINEAL FEET OF PIPE SEGMENT) The fault ratio system was designed to quickly determine the relative condition of each line segment that had been inspected. The following fault ratio ranges were developed to assign a condition rating: < 5 Good condition > 5 and <10 Marginal condition >10 Poor condition Utilizing this formula and these condition rating definitions, Table 4-12 summarizes the condition ratings for the pipes in the SASM service area that have previously been inspected. August 2009 5. 4-24
and Condition Assessment Plan Figure 4-5: RBSD Pipes Inspected after April 10, 2003 and prior to April 10, 2008 August 2009 6. 4-25
Table 4-12: RBSD Condition Rating Summary Pipes Inspected April 10, 2003 to April 10, 2008 Condition Rating Rating Description # of Pipe Segments Lineal Feet of Pipe Good Does not require repair or rehabilitation. 941 160,724 Marginal Some deterioration but should not require rehabilitation in the near future. 116 20,506 Poor Significant deterioration. Should be considered for rehabilitation in the Rehabilitation and Replacement Plan. 193 33,447 Totals 1,250 214,677 The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. Also, a more detailed method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.7.1.3 Documentation and Recordkeeping All defects observed have been documented. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.7.2 Inspection and Condition Assessment Program Richardson Bay plans to inspect the remaining gravity sewer pipes and manholes that have not been recently inspected. These remaining sewers will be inspected prior to April 15, 2010. Table 4-13 summarizes the quantity of sewers that have been inspected and the quantity of pipes in the planned inspection program. Table 4-13: RBSD Inspection and Condition Assessment Program Summary Sewer Mains GIS Database Lineal Feet of Mains RBSD Pipes 242,630 a Remove: Force Mains: (18,118) RBSD Gravity Pipes Subtotal: 224,512 Remove: Previously Inspected: (214,667) RBSD Lines Planned for Inspection: 9,835 Footnotes: a. Excluding any abandoned or private lines. Table 4-14 summarizes the schedule for future sewer inspections through April 15, 2010. Table 4-14: RBSD Inspection Schedule through April 15, 2010 Planned Inspection Lineal Feet of Sewer Mains Between April 10, 2008 and April 15, 2009 0 Between April 16, 2009 and April 15, 2010 9,835 Totals 9,835 August 2009 4-26
Manholes will typically be inspected at the same time that the pipe downstream of the manhole is inspected. 4.7.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.7.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. August 2009 4-27
4.7.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and longterm repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.7.2.4 Inspection Schedule 2008 through April 15, 2010 Table 4-13 summarizes the overall status of the collection system inspection and rehabilitation program, and Figure 4-5 summarizes the pipes and manholes that were excluded from the current inspection program. The remaining pipes (9,835 lineal feet) and manholes in the system are scheduled for inspection before April 15, 2010, and are also shown in Figure 4-5. Table 4-14 shows that 9,835 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-28
4.8 Tamalpais Community Services District This section addresses collection system maintenance and management for the portion of the Tamalpais Community Services District (TCSD) that is tributary to the SASM system. The past and proposed programs and procedures described in this section apply to the entire District, but the inspection schedules presented in this section are specific to the portion of TCSD, known as the Kay Park area, that is part of SASM. 4.8.1 Recent Sewer Inspection and Condition Assessment Activities 4.8.1.1 Previously Inspected Areas During the 5-year period prior to April 10, 2008 when the original Order was issued, some inspection data had already been collected. However, the entire Kay Park sewer system has recently been replaced and is therefore not scheduled for re-inspection prior to April 15, 2010. 4.8.1.2 Evaluation Methods Defect Coding Systems The defect coding system that will be utilized in the future is covered below. Condition Rating Systems The condition rating system that will be utilized for inspection data collected after April 10, 2008 is documented below. 4.8.2 Planned Inspection and Condition Assessment Program As described above, the Kay Park sewers were recently replaced or rehabilitated and are not part of a planned inspection program. Table 4-15 summarizes the total lineal footage of sewers, the amount owned by others, and the amount of pipe that was recently replaced or rehabilitated. Table 4-15: TCSD Planned Inspection and Condition Assessment Program Summary TCSD Pipes Database Sewer Mains GIS Database Lineal Feet of Mains 13,179 a Remove: Owned by others: (5,264) TCSD Gravity Pipes Subtotal: 7,915 Remove: Recently Rehabilitated and Replaced: (7,915) TCSD Kay Park Lines Planned for Inspection: 0 Footnotes: a. Excluding any abandoned or private lines. Also does not include pipe outside of the Kay Park area. While inspections are not currently planned, future inspections are anticipated as part of the normal operation of the sewer system. Future maintenance hole inspections will typically occur at the same time that the pipe downstream of the maintenance hole is inspected. August 2009 4-29
4.8.2.1 Planned Inspection Methods The current intention is to utilize inspection contractors to collect all CCTV inspection data discussed in this Inspection. For mains with maintenance holes located in readily accessible locations, CCTV data will be collected with the use of fully equipped CCTV vehicles. The vehicles will be equipped with a digital or VHS recording device. Each vehicle will carry all of the inspection, video capture, and recording equipment needed to televise a sewer pipe. CCTV contractors will use pan and tilt cameras which allow the operator to remotely rotate the camera in the sewer pipe and focus on the object being observed. Pan and tilt cameras are preferred because they give the inspectors increased flexibility in identifying and assessing the main infrastructure as well as the service lateral connections. For mains with maintenance holes that are located in remote or difficult to access areas, inspection contractors may need to utilize a portable push camera set up. This camera may not have a prehensile head, but will still be capable of viewing, recording and identifying defects located in the pipe. 4.8.2.2 Evaluation Procedure The inspection data will be used to assign a condition grade based on the quantity and the types of defects found in each pipe section. Defect Rating System This inspection program will utilize the Pipeline Assessment and Certification Program (PACP) and the Manhole Assessment and Certification Program (MACP) defect rating systems, which was developed by the National Association of Sewer Service Companies (NASSCO). The PACP and MACP systems require CCTV operators to code defects either by structural or maintenance defect. Each defect code is assigned a grade of 1 to 5, with 1 being the least severe and 5 being the most severe defect. These grades only consider the internal pipe conditions obtained from the televised inspection. After a sewer segment or manhole has been inspected, a grading system will be applied to evaluate the overall condition of the system and to identify pipe segments and manholes with the most severe defects. Other defect rating systems may be utilized. If an alternate defect rating system is utilized, the system will be identified in the annual progress reports for the Inspection. Condition Grading System To evaluate the current condition of the system, this inspection and condition assessment program will utilize a Quick Rating for each pipe segment or manhole. The quick rating will indicate the number of occurrences for the two highest severity grades for each pipe segment for either maintenance or structural defects. A grade of 1 indicates that a pipe segment or manhole is in excellent condition with minor defects and failure is unlikely in the foreseeable future, while a grade of 5 indicates that a pipe segment may require immediate attention. An example of a quick rating may be: 5249, where there are two defects with a grade 5 rating, and 9 defects with a grade 4 rating. Other condition grading systems may be utilized. If an alternate condition grading system is utilized, the system will be identified in the annual progress reports for the Inspection. The method to identify non-emergency sewer repair, rehabilitation and replacement projects will be documented in the plan for short-term and long-term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. 4.8.2.3 Documentation and Recordkeeping All defects observed will be documented by the inspection contractor. A copy of all defect code data and the video will be retained for evaluation and to support preparation of the plan for short-term and long- August 2009 4-30
term repair, rehabilitation and replacement of sewers that will be submitted to EPA by October 15, 2010. The final format of the defect code data to be archived may vary depending on the selected contractor s documentation practices, but the data will be in the form of a written report, electronic spreadsheet or an electronic database that can be readily accessed and reviewed. 4.8.2.4 Inspection Schedule 2008 through April 15, 2010 As described above, 0 lineal feet are scheduled for inspection prior to April 15, 2010. August 2009 4-31