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Reso - CC - 061-2025
RESOLUTION NO. 061-2025 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BURLINGAME APPROVING THE UPDATED SANITARY SEWER MANAGEMENT PLAN WHEREAS, in 2006, the State Water Resources Control Board (SWRCB) adopted the Statewide General Waste Discharge Requirements (GWDR) permit known as Order No. 2006- 0003, for wastewater collection agencies; and WHEREAS, the GWDR Permit required public agencies responsible for collection and treatment of waste water to adopt the Sanitary Sewer Management Plan (SSMP); and WHEREAS, the SSMP provides detailed guidance and protocols regarding the requirements for maintenance and operations of the sanitary sewer collection system; and WHEREAS, on December 6, 2022, the SWRCB adopted the reissued Sanitary Sewer System General Order No. 2022-0103-DWQ (WDR), which went into effect on June 5, 2023; and WHEREAS, the reissuance provided new guidance and requirements for what is required to be part of the SSMP; and WHEREAS, the Public Works Department has developed an updated and revamped SSMP document, with the technical assistance of Fischer Compliance and Sam Rose Consulting; and WHEREAS, the last update to the SSMP occurred in 2018. NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Burlingame does hereby approve the updated SSMP, attached hereto, in accordance with state regulations. ______________________________ Peter Stevenson, Mayor I, MEAGHAN HASSEL-SHEARER, City Clerk of the City of Burlingame, do hereby certify that the foregoing Resolution was introduced at a regular meeting of the City Council held on the 16th day of June 2025, and was adopted thereafter by the following vote: AYES: COUNCILMEMBERS: Brownrigg, Colson, Pappajohn. Stevenson, Thayer NOES: COUNCILMEMBERS: None ABSENT: COUNCILMEMBERS: None ______________________________ Meaghan Hassel-Shearer, City Clerk Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 Sewer System Management Plan (SSMP) City of Burlingame 2025 Update Waste Discharge ID = 2SSO10099 City Council Approval Date: Resolu�on #: REVIEWED AND APPROVED BY: Richard Horne Streets, Storm Drains and Sewer Divisions Manager Legally Responsible Official City of Burlingame Sanitary Sewer Collec�on System Date Signed Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 THIS PAGE INTENTIONALLY LEFT BLANK Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SSMP CHANGE LOG © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Yuba City use only. COPY THIS PAGE AS NEEDED Revision Date SSMP Sec�on Approval Date Descrip�on of Change/Revision Made Ini�als Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SSMP CHANGE LOG © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Yuba City use only. COPY THIS PAGE AS NEEDED Revision Date SSMP Sec�on Approval Date Descrip�on of Change/Revision Made Ini�als Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 LETTER OF COMPLIANCE © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City use only. Page i City of Burlingame Atn: Richard Horne Legally Responsible Official (LRO) 1361 N. Carolan Ave. Burlingame, CA 94010 Dear Mr. Horne, We are pleased to present the new 2025 Sewer System Management Plan (SSMP) Update developed in partnership with the City of Burlingame’s management. The 2025 Update meets and exceeds compliance with the WDR (State Water Board, Water Quality Order No. 2022-0103-DWQ, Atachment D-10 and Specifica�ons 5.4). The 2025 SSMP has been completely revised to harmonize with industry standard guidelines and incorporates the City’s latest SSMP Audit findings. The 2025 SSMP is a declara�on of what the City is doing to demonstrate full compliance with the WDR. Atachment A of the WDR (page A-4), states “A sewer system management plan is a living document an Enrollee develops and implements to effec�vely manage its sanitary sewer system(s) in accordance with this General Order.” We suggest that the City review the SSMP on a regular basis, and as required by the WDR, con�nuously document changes to its SSMP in a change log atached to the Plan. We look forward to assis�ng the City wherever necessary to fully implement the new 2025 SSMP Update. Sincerely, James Fischer, P.E. Principal, Fischer Compliance LLC Creden�aled U.S. EPA NPDES Compliance Inspector Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OVERVIEW © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City use only. Page ii TABLE OF CONTENTS INTRODUCTION ............................................................................................................................................................. 1 SSMP Organiza�on ..................................................................................................................................................................... 2 Abbrevia�ons and Acronyms...................................................................................................................................................... 3 1. GOAL AND INTRODUCTION .................................................................................................................................. 4 1.1. Regulatory Context ............................................................................................................................................................ 4 1.2. SSMP Update Schedule ...................................................................................................................................................... 5 1.3. Sewer System Asset Overview ........................................................................................................................................... 7 Specifica�ons 5.2 – SSMP Development and Implementa�on ................................................................................................ 10 Specifica�ons 5.7 – Alloca�on of Resources ............................................................................................................................ 11 Provisions 6.1 - Enforcement Provisions .................................................................................................................................. 12 Provisions 6.3 Sewer System Management Plan Availability ................................................................................................... 13 2. ORGANIZATION ................................................................................................................................................... 14 2.1. Organiza�onal Chart ........................................................................................................................................................ 17 2.2. Organiza�onal Staffing Responsibili�es ........................................................................................................................... 18 2.3. Chain of Communica�on for Repor�ng Spills .................................................................................................................. 19 3. LEGAL AUTHORITY .............................................................................................................................................. 21 4. OPERATION AND MAINTENANCE PROGRAM ..................................................................................................... 23 4.1. Updated Map of Sewer System ....................................................................................................................................... 23 4.2. Preven�ve Opera�on and Maintenance Ac�vi�es .......................................................................................................... 25 4.3. Training ............................................................................................................................................................................ 27 4.4. Equipment Inventory ....................................................................................................................................................... 29 Specifica�ons 5.19 - Opera�ons and Maintenance .................................................................................................................. 30 5. DESIGN AND PERFORMANCE PROVISIONS ......................................................................................................... 32 5.1. Updated Design Criteria/Construc�on Standards/Specifica�ons .................................................................................... 32 5.2. Procedures and Standards ............................................................................................................................................... 33 6. SPILL EMERGENCY RESPONSE PLAN ................................................................................................................... 34 7. SEWER PIPE BLOCKAGE PROGRAM .................................................................................................................... 36 8. SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS ........................................................ 39 8.1. System Evalua�on and Condi�on Assessment ................................................................................................................ 39 8.2. Capacity Assessment and Design Criteria ........................................................................................................................ 42 8.3. Priori�za�on of Correc�ve Ac�on ................................................................................................................................... 44 8.4. Capital Improvement Plan ............................................................................................................................................... 45 9. MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS ................................................................... 47 10. INTERNAL AUDITS ............................................................................................................................................... 51 11. COMMUNICATION PROGRAM ............................................................................................................................ 53 LIST OF APPENDICES ................................................................................................................................................... 55 Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OVERVIEW © 2025 Fischer Compliance, LLC. All rights reserved. SSMP licensed for City use only. Page iii LIST OF FIGURES Figure 1 - Collec�on Spill Summary: Burlingame City CS .............................................................................................. 1 Figure 2 - Sewer System Management Plan, Subsequent Update and Audit Due Dates ............................................. 5 Figure 3 - City Vicinity Map and Service Area ............................................................................................................... 8 Figure 4 - Organiza�on Chart ...................................................................................................................................... 17 Figure 5 - Organiza�onal Staffing Responsibili�es...................................................................................................... 18 Figure 6 - City Chain of Communica�on for Repor�ng Spills ...................................................................................... 19 Figure 7 - Agency, Region and State SSO Rate per 100 Miles by Year ........................................................................ 48 Figure 8 - Spill Volume By Year/Spill Volume Per Capita by Year ............................................................................... 48 Figure 9 - Spill Recovered Percent by Spill Type ......................................................................................................... 48 Figure 10 - City Spills Causes by Volume of Spills (2007-2022) .................................................................................. 49 Figure 11 - City Spills Causes by No. of Spills (2007-2022) ......................................................................................... 49 LIST OF TABLES Table 1 - Abbrevia�ons and Acronyms ......................................................................................................................... 3 Table 2 - Implementa�on Responsibili�es ................................................................................................................. 15 Table 3 - Responsible Posi�on Contact Informa�on .................................................................................................. 16 Table 4 - Key City Phone Numbers for Spill Repor�ng................................................................................................ 19 Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OVERVIEW © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 1 of 55 Introduc�on This Sewer System Management Plan (SSMP) or “Plan” has been prepared by the City of Burlingame (City) with technical assistance from Fischer Compliance LLC and Sam Rose Consul�ng for mee�ng and exceeding compliance with the State Water Resources Control Board 2022 General Waste Discharge Requirements, Order WQ 2022-0103- DWQ for Sanitary Sewer Systems, referred to throughout this document as the WDR. In addi�on, the City’s NPDES Permit (No. CA0037788) incorporates the requirements to comply with the WDR by reference in the treatment plant permit ((Order R2-2023-0010) to operate the Burlingame Wastewater Treatment Plant and City of Burlingame’s wastewater collec�on system. The SSMP has been developed to meet the size, scale and complexity of the City to serve as a “living document,” that will be used as a tool to manage and operate the collec�on system. Further, the new 2024 Sewer System Management Plan Guidance Manual published by the Bay Area Clean Water Agency (BACWA) was u�lized as a model for development of the SSMP to ensure the SSMP harmonizes with the latest available industry standard recommenda�ons for the development and upda�ng of SSMPs. A commitment to mee�ng or exceeding regulatory requirements, along with a proac�ve approach to opera�on and management of the collec�on system has led to system improvements helping the City to provide excellent service to its customers while reducing the likelihood of sewer spills or environmental and public harm. Figure 1 provides key City spill metrics including data comparing the City’s spill record with state and regional system data. The City consistently performs well when compared to both statewide and regional spill rate indices and net spill volumes for all categories of spills from its sanitary sewer collec�on system. Figure 1 - Collection Spill Summary: Burlingame City CS Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OVERVIEW © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 2 of 55 SSMP Organiza�on This SSMP is organized into 11 core elements following Atachment D of the WDR, with inclusion of applicable Specifica�ons requirements. Each individual element in the SSMP includes the following technical contents. 1. Requirements – Provides the actual descrip�on of applicable requirements in the WDR. 2. Compliance – Describes the City’s approach to complying with the WDR requirements. 3. Effec�veness – As measured by Key Performance Indicators (KPIs.) 4. Implementa�on – Demonstrates how the City will ensure the SSMP will be carried out as described. 5. Resilience – Demonstrates the resilience that is addressed in the SSMP and built-in to the City’s collec�on system and procedures. 6. Appendix Inclusions – List the items included in the Appendix for each SSMP Element, if any. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OVERVIEW © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 3 of 55 Abbrevia�ons and Acronyms ASM Administra�ve Services Manager BMP Best Management Prac�ces CCTV Closed Circuit Television CIP Capital Improvement Program CIPP Cured in Place Pipe CIWQS California Integrated Water Quality System (State Water Board Online Spill Database) CMMS Computerized Maintenance Management System EPA US Environmental Protec�on Agency FOG Fats, Oils and Grease FSE Food Service Establishment GCD Grease Control Device GIS Geographic Informa�on System GM General Manager HCFLS High Cleaning Frequency Line Segments I & I Inflow and Infiltra�on LRO Legally Responsible Official MRP Monitoring and Repor�ng Program NPDES Na�onal Pollutant Discharge Elimina�on System PLCO Property Line Clean Out RWQCB Regional Water Quality Control Board (Lahontan Region) SCADA Supervisory Control and Data Acquisi�on SERP Overflow Emergency Response Plan SOP Standard Opera�ng Procedure SSMP Sewer System Management Plan Spill Sanitary Sewer Overflow WDR Sanitary Sewer Systems General Wastewater Discharge Requirements Order issued by the State Water Board (Order No. 2022-0103-DWQ) SWRCB State Water Resources Control Board WDID Waste Discharge ID Number (CIWQS) Table 1 - Abbreviations and Acronyms Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 4 of 55 1. Goal and Introduc�on WDR REQUIREMENTS At. D-1 (pg. D-2) “The goal of the Sewer System Management Plan (Plan) is to provide a plan and schedule to: (1) properly manage, operate, and maintain all parts of the Enrollee’s sanitary sewer system(s), (2) reduce and prevent spills, and (3) contain and mitigate spills that do occur. The Plan must include a narrative Introduction section that discusses the following items:” 1.1. Regulatory Context WDR REQUIREMENTS At. D-1.1 (pg. D-2) “The Plan Introduction section must provide a general description of the local sewer system management program and discuss Plan implementation and updates”. COMPLIANCE The City is commited to fully implemen�ng the WDR which includes addressing all requirements and integra�ng a wide range of programs specifically designed for ensuring the integrity and efficiency of the City’s sanitary sewer collec�on system. The primary focus remains on reducing spills and employing targeted strategies to minimize their environmental and public health impact. Addi�onally, the City is dedicated to maintaining its collec�on system in a systema�c manner by implemen�ng various work programs, which target cri�cal areas to prevent spills, allowing for a comprehensive approach to maintenance. Work programs include, but are not limited to, CCTV inspec�ons, pipe cleaning, manhole inspec�ons, li� sta�on maintenance, root control, source control and pipe repair. By priori�zing proac�ve measures and taking a comprehensive approach, the City is well-equipped to effec�vely operate its sanitary sewer collec�on system, comply with the WDR, and reduce/eliminate sewage spills. EFFECTIVENESS N/A IMPLEMENTATION PLAN/SCHEDULE N/A Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 5 of 55 1.2. SSMP Update Schedule WDR REQUIREMENTS At. D-1.2 (pg. D-3) “The Plan Introduction section must include a schedule for the Enrollee to update the Plan, including the schedule for conducting internal audits. The schedule must include milestones for incorporation of activities addressing prevention of sewer spills.” COMPLIANCE The City u�lizes the State Water Board’s online lookup tool for ensuring all required due dates for upda�ng its SSMP and comple�ng required SSMP Audits (see Fig 2 below). Notable maintenance milestones include three-year CCTV inspec�on, gravity main and siphon cleaning cycles, daily li� sta�on inspec�ons, chemical root control is performed on iden�fied line segments every 24 months (both laterals and gravity mains). The City has a Lateral Program and is working to define the op�mal return interval. Problem lines that require accelerated maintenance have been iden�fied and are addressed on prescribed intervals. The City has a Capital Improvement Program (CIP) that includes sewer projects that are completed on a priori�zed basis. EFFECTIVENESS Key Performance Indicators: • Are SSMP Audits and SSMP Updates being performed as scheduled? • Has the Sewer System Management Plan been approved by the governing board on schedule (every six years)? • Are specific internally established sewer program milestones being monitored and met? Figure 2 - Sewer System Management Plan, Subsequent Update and Audit Due Dates Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 6 of 55 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crews 1.2.1 Prepare for next SSMP Audit Begin 8/2/2024 X X 1.2.2 Complete and Upload next SSMP Audit By 2/2/2025 X X 1.2.3 Incorporate Audit Findings, update Change Log and Update SSMP Begin 2/2/2025 X X 1.2.4 Board Approval and LRO Cer�fica�on of SSMP By 8/2/2025 X X 1.2.5 Prepare for next SSMP Audit Begin 8/2/2027 X X 1.2.6 Complete and Upload SSMP Audit By 2/2/2027 X X 1.2.7 Prepare for next SSMP Audit Begin 8/2/2029 X X 1.2.8 Complete and Upload SSMP Audit By 2/2/2029 X X 1.2.9 Board Approval and LRO Cer�fica�on of SSMP By 8/2/2031 X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 7 of 55 1.3. Sewer System Asset Overview WDR REQUIREMENTS At. D-1.3 (pg. D-3) “The Plan Introduction section must provide a description of the Enrollee-owned assets and service area, including but not limited to: • Location, including county(ies); • Service area boundary; • Population and community served; • System size, including total length in miles, length of gravity mainlines, length of pressurized (force) mains, and number of pump stations and siphons; • Structures diverting stormwater to the sewer system; • Data management systems; • Sewer system ownership and operation responsibilities between Enrollee and private entities for upper and lower sewer laterals; • Estimated number or percentage of residential, commercial, and industrial service connections; and • Unique service boundary conditions and challenge(s). Additionally, the Plan Introduction section must provide reference to the Enrollee’s up-to-date map of its sanitary sewer system, as required in section 4.1 (Updated Map of Sanitary Sewer System) of this Attachment.” COMPLIANCE Located in the San Francisco Peninsula, the City operates a sanitary sewer system that serves a popula�on of approximately 30,150 in a 4.3 square mile service area. The sewer system serves 7,576 residen�al connec�ons, 956 commercial, industrial and ins�tu�onal customers as of May 2025. The system consists of 81 miles of gravity mains, about 31 miles of lower laterals (approximately 8,532 laterals), 2,000 manholes, 6.1 miles of force mains, 8 pump sta�ons and 6 siphons. Sewer pipe diameters range from 4 inches to 51 inches. The City provides service and repair of lower lateral, described as the por�on of the lateral that extends from the sewer main in the public right-of-way to the clean out at the property line/edge of City right-of-way. The property owner is responsible for maintenance and repair of the upper lateral that extends from the clean out at the property line/edge of public right-of- way to the building sewer (Ordinance No. 1329, which became effec�ve August 7, 1986, and later modified by ordinance 1623 on March 23, 2000.) The City requires inspec�on of the upper lateral and repair of iden�fied deficiencies when the property is sold and when addi�onal water fixtures are added to the house. The City u�lizes a Geographical Informa�on System (GIS) to manage data for both its wastewater collec�on system and storm drainage system maps. See D, 4.1, Updated Map of Sewer System for details. The City will provide electronic version of the City’s maps to the State and Regional Water Boards upon request. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 8 of 55 EFFECTIVENESS Key Performance Indicators: • Are asset sta�s�cs periodically reviewed and updated as necessary? • Are correc�ons addressed in a �mely manner? • Are system maps up to date? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crews 1.3.1 Review City-owned asset sta�s�cs and element descrip�on; update as necessary At the beginning of the audit cycle and when significant changes have been made. X X 1.3.2 Update Maps As needed. Updates distributed monthly. X X Figure 3 - City Vicinity Map and Service Area Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 9 of 55 RESILIENCE Resilience is addressed in Element 1 by: • Adhering to an SOP for collec�ng and managing asset data. • Redundancy: More than one member of staff is trained and able to retrieve and manage the data. • Implemen�ng a QA/QC process to help ensure informa�on is accurate. • Using Calendar Reminders to ensure compliance deadlines are met. APPENDIX 1 INCLUSIONS: • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 10 of 55 Specifica�ons 5.2 – SSMP Development and Implementa�on WDR REQUIREMENTS Specifica�on. 5.2 (pg. 18) “To facilitate adequate local funding and management of its sanitary sewer system(s), the Enrollee shall develop and implement an updated Sewer System Management Plan. The scale and complexity of the Sewer System Management Plan, and specific elements of the Plan, must match the size, scale, and complexity of the Enrollee’s sanitary sewer system(s). The Sewer System Management Plan must address, at minimum, the required Plan elements in Attachment D (Sewer System Management Plan – Required Elements) of this General Order. To be effective, the Sewer System Management Plan must include procedures for the management, operation, and maintenance of the sanitary sewer system(s). The procedures must: (1) incorporate the prioritization of system repairs and maintenance to proactively prevent spills, and (2) address the implementation of current standard industry practices through available equipment, technologies, and strategies.” COMPLIANCE The City's current Sewer System Management Plan (SSMP) has been updated to meet the requirements of Order WQ 2022-0103-DWQ and addresses the required Elements. The SSMP addresses management, opera�ons and maintenance procedures. The City maintains ac�ve inspec�on programs, such as CCTV inspec�on for both gravity mains and laterals, manhole inspec�ons, and pump sta�ons inspec�ons. Inspec�on findings are then priori�zed for repair, replacement, rehabilita�on, or modified maintenance schedules. (See Elements 4 and 8.) The City is proac�ve in keeping up with current industry standards, technology and best prac�ces and stays abreast by reviewing industry periodicals, networking and atending industry conferences and workshops. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 11 of 55 Specifica�ons 5.7 – Alloca�on of Resources WDR REQUIREMENTS Specifica�on. 5.7 (pg. 22) “The Enrollee shall comply with the following requirements: • Establish and maintain a means to manage all necessary revenues and expenditures related to the sanitary sewer system; and • Allocate the necessary resources to its sewer system management program for: • Compliance with this General Order, • Full implementation of its updated Sewer System Management Plan, • System operation, maintenance, and repair, and • Spill responses.” COMPLIANCE The City has established revenues/expenditures for proper and effec�ve opera�ons and maintenance of the sewer system through the enterprise fund annual budge�ng process. The City allocates resources for its sewer system opera�on and maintenance through a comprehensive approach that priori�zes maintenance efforts. The city conducts regular inspec�ons and assessments to iden�fy areas of poten�al concern, allowing for preemp�ve repairs and upgrades to mi�gate future issues. Addi�onally, a por�on of the city's budget is dedicated to emergency response capabili�es, ensuring swi� ac�on in the event of unexpected sewer system failures, enabling the city to uphold high standards of public health and environmental protec�on while managing its sewer infrastructure. An addi�onal revenue stream is the Sewer Capacity charge for future system upsizing. The City recently completed its third rate increase in as many years, which commenced in January of 2022, and will con�nue to monitor expenditures to ensure proper funding is secured to operate and maintain its sewer system efficiently. The City’s vehicle and equipment inventory and workforce are adequate for opera�ng the collec�on system. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 12 of 55 Provisions 6.1 - Enforcement Provisions WDR REQUIREMENTS Provisions 6.1 (pg. 27) “The following enforcement provisions are based on existing federal and state regulations, laws and policies, including the federal Clean Water Act, the state Water Code and the State Water Board Enforcement Policy.” COMPLIANCE The City is aware of the consequences for noncompliance including associated penal�es for viola�ons. The City maintains a proac�ve stance with full implementa�on of its SSMP. Noncompliance with requirements of this General Order or discharging sewage without enrolling in this General Order cons�tutes a viola�on of the Water Code and a poten�al viola�on of the Clean Water Act and is grounds for an enforcement ac�on by the State Water Board or the applicable Regional Water Board. Failure to comply with the no�fica�on, monitoring, inspec�on, entry, repor�ng, and recordkeeping requirements may subject the City to administra�ve civil liabili�es of up to $10,000 a day per viola�on pursuant to Water Code sec�on 13385; up to $1,000 a day per viola�on pursuant to Water Code sec�on 13268; or referral to the Atorney General for judicial civil enforcement. Discharging waste not in compliance with the requirements of this General Order or the Clean Water Act may subject the City to administra�ve civil liabili�es up to $10,000 a day per viola�on and addi�onal liability up to $10 per gallon of discharge not cleaned up a�er the first 1,000 gallons of discharge; up to $5,000 a day per viola�on pursuant to Water Code sec�on 13350 or up to $20 per gallon of waste discharged; or referral to the Atorney General for judicial civil enforcement. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 GOAL AND INTRODUCTION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 13 of 55 Provisions 6.3 Sewer System Management Plan Availability WDR REQUIREMENTS Provisions 6.3 (pg. 31) “The Enrollee’s updated Sewer System Management Plan must be maintained for public inspection at the Enrollee’s offices and facilities and must be available to the public through CIWQS and/or on the Enrollee’s website, in accordance with section 3.8 (Sewer System Management Plan Reporting Requirements) of Attachment E1 (Notification, Monitoring, Reporting and Recordkeeping Requirements) of this General Order.” COMPLIANCE The City publishes its SSMP, available for public review, on its website at the Sewer Systems page and also maintains a paper copy in its offices which can be made available for inspec�on during regular business hours. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 14 of 55 2. Organiza�on WDR REQUIREMENTS Att. D-2 (pg. D-3) “The Plan must identify organizational staffing responsible and integral for implementing the local Sewer System Management Plan through an organization chart or similar narrative documentation that includes: • The name of the Legally Responsible Official as required in section 5.1 (Designation of a Legally Responsible Official) of this General Order; • The position titles, telephone numbers, and email addresses for management, administrative, and maintenance positions responsible for implementing specific Sewer System Management Plan Element;. • Organizational lines of authority; and • Chain of communication for reporting spills from receipt of complaint or other information, including the person responsible for reporting spills to the State and Regional Water Boards and other agencies, as applicable. (For example, county health officer, county environmental health agency, and State Office of emergency Services.) COMPLIANCE The requirements above are addressed in order below. The City has designated the Streets, Storm Drains & Sewer Divisions Manager, Mr. Rick Horne as its LRO. Mr. Horne is the authorized representa�ve in all wastewater collec�on system maters who is authorized to cer�fy electronic spill reports submited to CIWQS and is authorized to submit spill reports to other appropriate government agencies, as necessary. Mr. Michael Heathcote, the Deputy Director of Public Works Opera�ons, also serves as an LRO for the City, alongside Mr. Horne. Mr. Heathcote is authorized to cer�fy electronic spill reports submited to CIWQS and has the authority to submit spill reports to other relevant government agencies whenever required. Mr. Horne has over 24 years of experience and has received training from Fischer Compliance LLC on all elements of the Reissued WDR. He serves as the primary LRO and is the liaison between the different departments that support collec�on system efforts. Mr. Horne meets quarterly with engineering and every two weeks with the Deputy Director of Public Works Opera�on. Specifica�ons 5.1 lists the qualifica�ons for the Legally Responsible Official. Both Mr. Horne and Mr. Heathcote possess the necessary qualifica�ons. Both have the necessary authority over managerial decisions that govern the opera�on of the sanitary sewer system, including having the explicit or implicit duty of making major capital improvement recommenda�ons. Both have a wealth of professional training and experience. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 15 of 55 IMPLEMENTATION RESPONSIBILITIES Sewer System Management Plan Elements Responsible Posi�on 1. SSMP Plan, Goal and Introduc�on 1.1. Regulatory Context Deputy Director of Public Works Opera�ons 1.2. SSMP Update Schedule Deputy Director of Public Works Opera�ons 1.3. Sewer System Asset Overview Deputy Director of Public Works Opera�ons 2. Organiza�on Deputy Director of Public Works Opera�ons 3. Legal Authority Deputy Director of Public Works Opera�ons 4. Opera�ons and Maintenance Program 4.1. Updated maps of Sanitary Sewer System Public Works Sewer Supervisor 4.2. Preven�ve Opera�on & Maintenance Public Works Sewer Supervisor 4.3. Training Public Works Sewer Supervisor 4.4. Equipment Inventory Public Works Sewer Supervisor 5. Design/Performance 5.1. Updated Design Criteria & Construc�on Standards Assistant Public Works Director 5.2. Procedures and Standards Assistant Public Works Director 6. Spill Emergency Response Plan Streets, Storm & Sewer Divisions Manager 7. Sewer Pipe Blockage Program Streets, Storm & Sewer Divisions Manager 8. System Eval, Capacity Assurance, Capital Imp. 8.1. System Evalua�on and Condi�on Assessment Senior Engineer 8.2. Capacity Assessment and Design Criteria Senior Engineer 8.3. Priori�za�on of Correc�ve Ac�on Senior Engineer 8.4. Capital Improvement Plan Senior Engineer 9. Monitoring, Measurement & Program Modifica�ons Streets, Storm & Sewer Divisions Manager 10. Internal Audits Streets, Storm & Sewer Divisions Manager 11. Communica�on Program Deputy Director of Public Works Opera�ons Table 2 - Implementation Responsibilities Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 16 of 55 RESPONSIBLE POSITION CONTACT INFORMATION Responsible Posi�on Contact Informa�on Phone Deputy Director of Public Works Opera�ons 650-558-7670 Assistant Public Works Director 650 558-7230 Streets, Storm & Sewer Divisions Manager 650-558-7670 Public Works Sewer Supervisor 650-558-7670 Table 3 - Responsible Position Contact Information Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 17 of 55 2.1. Organiza�onal Chart Figure 4 - Organization Chart Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 18 of 55 2.2. Organiza�onal Staffing Responsibili�es Figure 5 - Organizational Staffing Responsibilities Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 19 of 55 2.3. Chain of Communica�on for Repor�ng Spills All wastewater collec�on system maters are the responsibility of the Streets, Storm Drains & Sewer Divisions Manager. The Streets, Storm Drains & Sewer Divisions Manager acts as the primary City LRO, cer�fying electronic spill reports submited to the SWRCB/CIWQS 1 system, and is also authorized to submit spill reports to other Outside Appropriate Government Agencies. The City has a chain of communica�on in place for repor�ng spills. This process involves various steps, such as public observa�on, li� sta�on alarms, and the observa�on by City or contractor staff. Once a spill is reported, the City’s Collec�ons crew a standby employee will promptly respond and follow the procedures outlined in the Sewer Spill/Backup Response Workbook. This response includes containment, rec�fying the issue, es�ma�ng spill and recovered volumes and spill start �me, documen�ng the spill, and taking the necessary ac�ons to clean up the affected area. Loca�on/Staff Telephone Number Office (Business Hours) (650) 558-7670 A�er Hours (Police Dispatch) (650) 692-0310 Streets and Sewer Supervisor (650) 558-7670 Streets, Storm Drain and Sewer Manager (650) 558-7670 1 State Water Resources Control Board/California Integrated Water Quality System, CIWQS, publicly available at: https://www.waterboards.ca.gov/water_issues/programs/ciwqs/publicreports.html Notification •The City is informed of a spill or a backup during normal business hours. The call can come from public notification (to Police Dispatch or Admin Office), lift station and Smart Cover alarms or City or Contractor staff observation. •After-hours notification will come through Police Dispatch •Notifications are forwarded to on-call staff. Response •Response staff respond, assess the spill event, and notify either the Streets and Sewer Supervisor or the Streets, Storm Drain and Sewer Manager to begin the regulatory notification, depending on the circumstances of the spill. Response activities are documented using tablets in the field and are immediately available to LROs. Data collected is verified by supervisors as a QA/QC measure. Report •The following employees are authorized to perform regulatory reporting of sewer spills: •Deputy Director of Public Works Operations •Street, Storm Drain and Sewer Divisions Manager •Streets and Sewer Division Supervisor Data Submitter Figure 6 - City Chain of Communication for Reporting Spills Table 4 - Key City Phone Numbers for Spill Reporting Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 ORGANIZATION © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 20 of 55 EFFECTIVENESS Key Performance Indicators: • Have there been any changes requiring updates to the Organiza�onal Chart? • Have there been instances when a service call for a spill was not properly routed to response personnel? • Were all spill response ac�vi�es documented and forwarded to the LRO? • Have there been any changes in assigned responsibili�es for implemen�ng the Sewer System Management Plan? • Is there a process in place to ensure all contact informa�on remains up to date? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 2.1 Review names, contact informa�on and posi�on responsibili�es. Update as necessary. Annually X 2.2 Review Chain of Communica�on outcomes for all spill responses Each Spill Event X 2.3 Review Organiza�onal Chart for any changes. Update as necessary. Annually X RESILIENCE Resilience is addressed in Element 2 by: • Ensuring that more than one person is capable and responsible for specific du�es for SSMP implementa�on, e.g., back-up personnel. • Designa�on of more than one LRO to help ensure full and con�nuous coverage of du�es. • Tes�ng the phone no�fica�on system to ensure calls are received and routed to appropriate personnel. APPENDIX 2 INCLUSIONS: • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 LEGAL AUTHORITY © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 21 of 55 3. Legal Authority WDR REQUIREMENTS At. D-3 (pg. D-4) “The Plan must include copies or an electronic link to the Enrollee’s current sewer system use ordinances, service agreements and/or other legally binding procedures to demonstrate the Enrollee possesses the necessary legal authority to: • Prevent illicit discharges into its sanitary sewer system from inflow and infiltration (I&I); unauthorized stormwater; chemical dumping; unauthorized debris; roots; fats, oils, and grease; and trash, including rags and other debris that may cause blockages; • Collaborate with storm sewer agencies to coordinate emergency spill responses, ensure access to storm sewer systems during spill events, and prevent unintentional cross connections of sanitary sewer infrastructure to storm sewer infrastructure; • Require that sewer system components and connections be properly designed and constructed; • Ensure access for maintenance, inspection, and/or repairs for portions of the service lateral owned and/or operated by the Enrollee; • Enforce any violation of its sewer ordinances, service agreements, or other legally binding procedures; and • Obtain easement accessibility agreements for locations requiring sewer system operations and maintenance, as applicable. COMPLIANCE The above items are addressed in order below: Burlingame Municipal Code 15.10.056 states: “No person shall discharge, cause or allow or permit any stormwater, roof or yard drainage, founda�on, underdrainage, or groundwater to be discharged into the sanitary sewer system without first obtaining a permit from the city to do so. In addi�on, Burlingame Municipal Code 15.12.010 and 15.12.110 offer addi�onal regula�on of I&I from private service laterals. The City’s Street, Storm Drain and Sewer divisions are responsible for the opera�on and maintenance of both the sanitary sewer system and the storm drain systems. The City has all current maps for both systems. There is some storm drain facili�es that the City shares ownership/responsibility with another agency and there is an informal agreement in place that addresses maintenance and repairs. Burlingame Municipal Code No. 15.10.024, 15.10.028 and 15.10.030 govern the City’s design and construc�on standards. Burlingame Municipal Code 15.10.024 specifies the Minimum standards for the design and construc�on of sewers within the City and that all public sewers and side sewers be planned, designed, constructed, installed and repaired in accordance with the plans and specifica�ons established by the Director of Public Works. Burlingame Municipal Code 15.10.032 governs rights of way and ensures the right to enter onto private property for the purpose of inspec�on, maintenance, repair, rehabilita�on or replacement of the por�on of the lower lateral maintained by the City. Burlingame Municipal Code 15.06.070 - The director, all employees of the water department, public works department and fire department have the duty and are authorized to enforce the provisions of this chapter Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 LEGAL AUTHORITY © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 22 of 55 and shall have all the powers and authority contained in California Penal Code Sec�on 836.5, including the power to issue writen no�ces to appear. Burlingame Municipal Code 26.24.040 governs the Dedica�on of Easements. “In the event that easements for sanitary sewers, drainage purposes or other public u�li�es are required, the city engineer shall so no�fy the person filing the map and the person shall offer to the city to dedicate the required easements before the map may be approved…” Right-of-way including sewers constructed in rights of way including in easement loca�ons for ensuring access. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Are the City ordinances and standards adequate for fulfilling the Sewer System Management Plan legal requirements? • Does the City have a process in place for periodic review and evalua�on of ordinances? • Have there been instances when the code or ordinance did not address a need or circumstance? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 3.1 Review Ordinance to confirm all documents provide necessary required legal authority Once per 6-year SSMP Update Cycle X X 3.2 Monitor and Document occasions when ordinance(s) failed to address issues as intended. Con�nuously X X X RESILIENCE Resilience is addressed in Element 3 by: • Keeping abreast of industry trends and local ordinances that may affect opera�ons. APPENDIX 3 INCLUSIONS: • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 23 of 55 4. Opera�on and Maintenance Program WDR REQUIREMENTS At. D-4 (pg. D-4) “The Plan must include the items listed below that are appropriate and applicable to the Enrollee’s system.” 4.1. Updated Map of Sewer System WDR REQUIREMENTS At. D-4.1 (pg. D-4) “An up-to-date map(s) of the sanitary sewer system, and procedures for maintaining and providing State and Regional Water Board staff access to the map(s). The map(s) must show gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities within the sewer system service area boundaries.” COMPLIANCE The City u�lizes a Geographical Informa�on System (GIS) to manage data for both its wastewater collec�on system and storm drainage system maps. Field crews use tablets to access system maps. Hard-copy maps are also available. Correc�ons submited by field personnel are updated by GIS staff which in-turn become readily available to all staff. Managing the mapping system involves regular updates to the hard copy and GIS maps, with correc�ons iden�fied by field crews and managed by the Senior Management Analyst, including incorpora�ng new facili�es and as-built informa�on form CIP projects. Upda�ng maps involves tracking of discrepancies, crea�ng work orders, resolving edits, and distribu�ng corrected map pages to the Sewer Division regularly. The City will provide electronic version of the City’s maps to the State and Regional Water Boards upon request. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Were all map updates completed in a �mely manner? • Are all staff trained in the procedure for providing map update informa�on? • Are newly installed sewer assets incorporated into the system maps? • Are there terrain features or assets that should be incorporated in future map updates (e.g. exposed pipe, siphons, ARVs, surface water, etc.) Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 24 of 55 IMPLEMENTATION PLAN/SCHEDULE No Plan Schedule Responsible Party Mgr. Sup Crew 4.1.1 Review map update procedures with all affected staff. Annually X X 4.1.2 Review/ensure all newly installed facili�es have been updated and included in the system maps. Annually X X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 25 of 55 4.2. Preven�ve Opera�on and Maintenance Ac�vi�es WDR REQUIREMENTS At. D-4.2 (pgs. D-4/D-5) ”A scheduling system and a data collection system for preventive operation and maintenance activities conducted by staff and contractors. The scheduling system must include: • Inspection and maintenance activities; • Higher-frequency inspections and maintenance of known problem areas, including areas with tree root problems; • Regular visual and closed-circuit television (CCTV) inspections of manholes and sewer pipes. The data collection system must document data from system inspection and maintenance activities, including system areas/components prone to root-intrusion potentially resulting in system backup and/or failure.” COMPLIANCE The purpose of a work order system is to program and track all required inspec�on and maintenance ac�vi�es within the collec�on system to help improve system performance and prevent blockages/opera�onal problems or spills. This includes documen�ng all inspec�on and maintenance ac�vi�es, including higher-frequency inspec�on and maintenance areas with known problems (“hot spots”), documen�ng ongoing CCTV inspec�ons and data for pipelines and manholes including areas prone to root intrusion that could cause blockages/opera�onal problems or spills. The City u�lizes OpenGov Asset Management for its CMMS (CMMS). The City schedules all inspec�on and maintenance work via tasks and work orders, which also serve as documenta�on of work ac�vi�es completed. Hot Spots are on a preven�ve maintenance schedules and work orders are automa�cally created on prescribed intervals. Work orders for produc�on work such as CCTV inspec�ons, gravity main cleaning, and repair work are also generated by workorders in the system by supervisory personnel. Work orders are completed in the field by maintenance staff and then reviewed and closed by a supervisor to ensure quality data entry. Work orders for spill response or other unscheduled ac�vi�es are completed a�er the event. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Is the agency maintenance, opera�ons, engineering work orders periodically audited for accuracy and completeness? • Does the agency monitor “planned,” “overdue,” or “in progress” work orders to ensure comple�on of tasks? • Are inspec�on and maintenance ac�vi�es reducing the number and volume of spills? • Is maintenance work being completed as scheduled? Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 26 of 55 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 4.2.1 Review work completed to date to ensure cri�cal work is being completed Quarterly X X 4.2.2 Review scheduled Preventa�ve Maintenance to ensure the prescribed schedule remains appropriate. Annually X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 27 of 55 4.3. Training WDR REQUIREMENTS At. D-4.3 (pg. D-5) “In-house and external training provided on a regular basis for sanitary sewer system operations and maintenance staff and contractors. The training must cover: • The requirements of this General Order; • The Enrollee’s Spill Emergency Response Plan procedures and practice drills; • Skilled estimation of spill volume for field operators; and • Electronic CIWQS reporting procedures for staff submitting data.” COMPLIANCE The City maintains a sound internal training program. Work Standards are used as the basis for most training. The City uses contracted services for training on Spill Emergency Response Plan, which includes review of WDR requirements, spill volume/recovered, and spill start �me es�ma�ons and prac�cal spill response drills in the field environment. The method of training ranges from classroom training, hands-on training and drills, and through hired contractors, seminars and conferences provided by California Water Environment Associa�on (CWEA.) The City requires employees to be cer�fied in Collec�on System Maintenance by CWEA. The cer�fica�on process requires employees to demonstrate that they have par�cipated in 12 hours of training every two years to renew their cer�ficates. Data Submiter training for the City repor�ng procedures includes repor�ng �melines, spill categories, QA/QC processes, spill response procedures, communica�on and coordina�on between staff and proper documenta�on and recordkeeping. The City has developed spill response procedures for Contract Service personnel who perform work for the City are required to: • Immediately no�fy the City of any sewage spill they encounter. • Make atempts to contain the spill • Cordon off the area to keep the public safe • Remain on-site un�l Burlingame staff arrives and relieves them. This language is included in service agreements and discussed during pre-job mee�ngs. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Has all training been completed as scheduled? • Have records of training and atendance been documented and maintained? • Have all staff demonstrated ability and knowledge a�er each training event? • Have contractors received, at a minimum, direc�on for repor�ng and responding to spills. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 28 of 55 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 4.3.1 Review training documenta�on to ensure all staff have received required training Annually X X 4.3.2 Review agreements with contractors and/or pre-job mee�ng minutes to ensure contract personnel have received instruc�on for responding to sewage spills Each Contract X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 29 of 55 4.4. Equipment Inventory WDR REQUIREMENTS At. D-4.4 (pg. D-5) “An inventory of sewer system equipment, including the identification of critical replacement and spare parts.” COMPLIANCE The City maintains an inventory of equipment and vehicles u�lized for the opera�on and maintenance of the collec�on system. In addi�on, the City maintains an inventory of emergency bypass equipment and related fi�ngs, hoses and pipes, as well as portable generators. Cri�cal spare parts are iden�fied and readily available for use. Examples include, SCADA PLC’s and radios, pumps, repair pipe and couplings for both gravity and force main pipes. Li� Sta�ons are equipped with bypass manifolds that can be connected to bypass pumps to manage flows for long periods of �me while repairs are being completed. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Have inventory lists been audited as scheduled? • Have any inventory deficiencies or omissions been discovered and rec�fied? • Has the City experienced any equipment failure that inhibited a spill response? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Eng Sup 4.4.1 Audit inventory lists to ensure stock is adequate Annually X X 4.4.2 Check with vendors to ensure cri�cal lead �mes for cri�cal parts are as expected. Annually X X RESILIENCE Resilience is addressed in Element 4 by: • Developing an SOP for upda�ng maps when errors are discovered. • Developing and using forms (paper or electronic) for data collec�on to help ensure all per�nent informa�on is consistently collected. • Periodically evalua�ng inspec�on cycle intervals to help ensure they are op�mized. • Requiring staff to demonstrate ability and/or knowledge for all training ac�vi�es. • Monitoring equipment and cri�cal spare parts usage for and trends. • Performing periodic audits of the Vehicle and Equipment Inventory List. APPENDIX 4 INCLUSIONS: • 4.1 Cri�cal Spare Parts List Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 30 of 55 Specifica�ons 5.19 - Opera�ons and Maintenance WDR REQUIREMENTS Specifica�on. 5.19 (pg. 27) “To prevent discharges to the environment, the Enrollee shall maintain in good working order, and operate as designed, any facility or treatment and control system designed to contain sewage and convey it to a treatment plant.” COMPLIANCE The City’s goal is to reduce the likelihood of spills by proac�vely maintaining the collec�on system in a variety of ways. Gravity Main Cleaning: The City endeavors to clean the gravity main system on a three-year cycle, by cleaning approximately 27 miles per year. This is done in a systema�c manner as crews work through maintenance basins to improve efficiency. Cleaning results of the mainlines are evaluated and reported by the cleaning crew based upon the Standard Opera�ng Procedure for Sewer Cleaning. The cleaning crew will clean mainlines before they are televised. High Frequency Cleaning: In addi�on to rou�ne produc�on cleaning, the City has a Hot Spot Program, in which lines that require a higher frequency cleaning schedule are priori�zed by monthly, quarterly, semi- annual and Annual intervals. Staff places mainline segments on these higher frequency schedules based upon past cleaning results, history of SSO events, history of cleaning results, and professional judgment. Gravity Main Inspec�on: The City inspec�ons are coordinated with gravity cleaning ac�vi�es and completed on a three-year return interval, u�lizing (NASSCO) PACP coding and IT Pipes to record the defects. CCTV work is coordinated with cleaning ac�vi�es. Root Control: The City procures a contractor to conduct annual root foaming on main lines that exhibit significant root intrusion in areas currently iden�fied by City staff. The current effort involves a 2-year return cycle for the root foaming processes. The City staff is responsible for conduc�ng root cu�ng 3 to 4 months prior to the root foaming to assure maximum effec�veness from the foaming. The City has iden�fied two separate areas where these ac�vi�es are required, and the service contractor handles one area each year. Lateral Program: The City has developed a lower lateral preven�ve maintenance program adopted by the City Council on May 5, 2003, in Resolu�on 53-2003. The maintenance program includes cleaning of all and root foaming of selected lower laterals. The City u�lizes one staff posi�on for the cleaning efforts with the lower laterals. Areas of the concern are iden�fied through CCTV inspec�ons, line cleaning, customer complaints and lateral spills. It is expected that this staff posi�on will clean an average of 2,100 laterals per year. The lateral root foaming program, up to 500 lower laterals per year, is handled each year through the City’s procurement and awarded to a contractor. In addi�on to this lateral program, the City’s Municipal Code further addresses laterals by requiring backflow preven�on for buildings with drain fixtures lower that the immediate upstream manhole and lateral tes�ng upon transfer of ownership. Municipal Code 15.12 - Lateral Test Ordinance. Whenever any property is to be transferred to or vested in any other person or en�ty and that property includes any buildings or structures constructed more than twenty-five (25) years prior to the date of transfer or ves�ng, the sewer lateral(s) to that property shall be tested for infiltra�on and all necessary repairs or replacements performed to prevent all infiltra�on. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 OPERATIONS AND MAINTENANCE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 31 of 55 Municipal Code 15.12.110 – Sewer Backwater Ordinance. This confirms the city's authority to require the property owner to install of such backwater valves and relief devices and be responsible for their maintenance; and further requires the filing of informa�on regarding fixture levels in connec�on with addi�ons of drainage fixtures and each property transfer as designated, to determine whether a valve, ejector, or relief device is required under the Municipal Code. Manhole Inspec�ons: The purpose of a manhole inspec�on program is to ensure viability of access to all collec�on system assets for preven�ve maintenance and emergency responses to proac�vely help prevent blockages/opera�onal problems or spills. Manholes are inspected using a top-Down method, without entry. Inspec�on results are documented using ITpipes and CMMS inspec�on tasks logs, which are reviewed monthly by supervisors to priori�ze any work to be completed. CCTV Crews perform the inspec�ons at all setup manholes. The remaining manholes are scheduled for inspec�on when staff is available. Pipe Repair Program – Discoveries of PACP defect scores of a 5 or 4 are scheduled in a priori�zed order. The City, in some cases, takes a reac�ve approach to pipe repairs. Informa�on from inspec�ons or blockages/spills that require immediate aten�on are deemed the highest priority. Repairs are completed by contracted services or internal staff. Pump Station Inspection & Maintenance: Pump sta�ons are inspected daily, where the pump run hours are logged and the wet well is inspected and documented. Alarms are tested semi-annually to help ensure reliability. Onsite generators and automa�c transfer switch are tested annually to ensure transfer of power during power outages. The wet wells are cleaned annually. The mechanical and electrical equipment preven�ve maintenance is scheduled quarterly. The City ini�ates annual pump sta�on condi�on assessments u�lizing the Li� Sta�on Condi�on Assessment Checklist Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 DESIGN AND PERFORMANCE PROVISIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 32 of 55 5. Design and Performance Provisions 5.1. Updated Design Criteria/Construc�on Standards/Specifica�ons WDR REQUIREMENTS Atachment D-5.1 (pg. D-5) “Updated design criteria, and construction standards and specifications, for the construction, installation, repair, and rehabilitation of existing and proposed system infrastructure components, including but not limited to pipelines, pump stations, and other system appurtenances. If existing design criteria and construction standards are deficient to address the necessary component-specific hydraulic capacity as specified in section 8 (System Evaluation, Capacity Assurance and Capital Improvements) of this Attachment, the procedures must include component-specific evaluation of the design criteria.” COMPLIANCE The City’s Municipal Code, Chapter 26, contains the physical design requirements for new development construc�on. Municipal Code 12.12.020 Standard Specifica�ons states all work shall conform with "standard specifica�ons" for the construc�on of public works as are compiled by the city engineer. Municipal Code 26.16.100 provides requirements for the installa�on of sewer facili�es. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Are plan checking QA/QC processes helping to ensure adherence to the standards? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Eng Sup 5.1.1 Ensure all project plans are approved in accordance with the City’s Standard Specifica�ons and Details. Each Project X 5.1.2 Verify design standards and hydraulic model previously completed are adequate and consistent with current standards of prac�ce. 10-year cycle X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 DESIGN AND PERFORMANCE PROVISIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 33 of 55 5.2. Procedures and Standards WDR REQUIREMENTS Atachment D-5.2 (pg. D-5) “Procedures, and standards for the inspection and testing of newly constructed, newly installed, repaired, and rehabilitated system pipelines, pumps, and other equipment and appurtenances.” COMPLIANCE The City’s Wastewater Collec�on System Inspec�on and Tes�ng Criteria are based on the State of California Standard Specifica�ons, latest edi�on, published by the Department of Transporta�on. All sewer installa�ons and sewer repairs are subject to this required tes�ng. Municipal Code 15.10.30 addresses City requirements for inspec�ons. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Were any design or installa�on deficiencies found during warranty inspec�ons? • Are devia�ons from standard procedures and/or specs, tes�ng, etc., jus�fied and documented? • Does the City stay abreast of industry design standards and technical advances in the industry? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Eng Crew 5.2.1 Verify inspec�on procedures are adequate and consistent with current standards of prac�ce 10-year cycle X X 5.2.2 Monitor development Warranty inspec�on outcomes 10-year cycle X X X RESILIENCE Resilience is addressed in Element 5 by: • Staying abreast of industry trends and standards. • Performing warranty inspec�ons of newly installed or repaired assets to evaluate design and installa�on prac�ces. • Evalua�ng as-built changes for trends and areas for design and performance improvements. APPENDIX 5 INCLUSIONS: • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SPILL EMERGENCY RESPONSE PLAN © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 34 of 55 6. Spill Emergency Response Plan WDR REQUIREMENTS Atachment D-6 (pg. D-6) “The Plan must include an up-to-date Spill Emergency Response Plan to ensure prompt detection and response to spills to reduce spill volumes and collect information for prevention of future spills. The Spill Emergency Response Plan must include procedures to: • Notify primary responders, appropriate local officials, and appropriate regulatory agencies of a spill in a timely manner; • Notify other potentially affected entities (for example, health agencies, water suppliers, etc.) of spills that potentially affect public health or reach waters of the State; • Comply with the notification, monitoring and reporting requirements of this General Order, State law and regulations, and applicable Regional Water Board Orders; • Ensure that appropriate staff and contractors implement the Spill Emergency Response Plan and are appropriately trained; • Address emergency system operations, traffic control and other necessary response activities; • Contain a spill and prevent/minimize discharge to waters of the State or any drainage conveyance system; • Minimize and remediate public health impacts and adverse impacts on beneficial uses of waters of the State; • Remove sewage from the drainage conveyance system; • Clean the spill area and drainage conveyance system in a manner that does not inadvertently impact beneficial uses in the receiving waters; • Implement technologies, practices, equipment, and interagency coordination to expedite spill containment and recovery; • Implement pre-planned coordination and collaboration with storm drain agencies and other utility agencies/departments prior, during, and after a spill event; • Conduct post-spill assessments of spill response activities; • Document and report spill events as required in this General Order; and • Annually, review and assess effectiveness of the Spill Emergency Response Plan, and update the Plan as needed.” COMPLIANCE The City’s Spill Emergency Response Plan (SERP), developed in coordina�on with DKF Solu�ons Group, LLC, was updated prior to the June 5, 2023, deadline and ini�al training to affected staff was completed at that �me. The SERP addresses all the requirements as stated in Atachment D, 6 of the WDR. The purpose of the City of Burlingame’s Spill Emergency Response Plan (SERP) is to support an orderly and effec�ve response to Sanitary Sewer spills. The SERP provides guidelines for City personnel to follow in responding to, cleaning up, and repor�ng spills that may occur within the City’s service area. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SPILL EMERGENCY RESPONSE PLAN © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 35 of 55 EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Have staff’s spill response efforts helped to prevent the discharge of sewage to surface waters? • Do post-spill assessments indicate staff are following the procedures outlined in the SERP? • Is SERP training effec�ve and are trainees demonstra�ng adequate knowledge and abili�es? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 6.1 Perform SERP training including prac�ce drills. Annually X X 6.2 Perform Post Spill Event Assessments Each spill X X 6.3 Review Post Spill Assessments to ensure adherence and to indemnify any trends that should be addressed Annually X X RESILIENCE Resilience is addressed in Element 6 by: • Mul�ple staff are trained to respond to spill events. • Post-spill assessments are conducted to evaluate staff’s adherence to the SERP and to iden�fy areas for improvement. • Data collec�on forms are used to direct staff to collect all the required data to be submited to CIWQS and are designed as a guide to a proper spill event response. • The City employees several different spill volume es�ma�on methods to account for different circumstances. APPENDIX 6 INCLUSIONS: • City of Burlingame Spill Emergency Response Plan available upon request. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SEWER PIPE BLOCKAGE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 36 of 55 7. Sewer Pipe Blockage Program WDR REQUIREMENTS Atachment D-7 (pg. D-7) “The Sewer System Management Plan must include procedures for the evaluation of the Enrollee’s service area to determine whether a sewer pipe blockage control program is needed to control fats, oils, grease, rags and debris. If the Enrollee determines that a program is not needed, the Enrollee shall provide justification in its Plan for why a program is not needed. The procedures must include, at minimum: • An implementation plan and schedule for a public education and outreach program that promotes proper disposal of pipe-blocking substances; • A plan and schedule for the disposal of pipe-blocking substances generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of substances generated within a sanitary sewer system service area; • The legal authority to prohibit discharges to the system and identify measures to prevent spills and blockages. • Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, best management practices requirements, recordkeeping and reporting requirements; • Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the fats, oils, and grease ordinance; • An identification of sanitary sewer system sections subject to fats, oils, and grease blockages and establishment of a cleaning schedule for each section; and • Implementation of source control measures for all sources of fats, oils, and grease reaching the sanitary sewer system for each section identified above.” COMPLIANCE The items above are addressed in order below. The City’s public outreach program includes efforts to educate customers on “what not to flush,’ and Kitchen Best Prac�ces. This is accomplished through flyers and pamphlets for both general and targeted outreach. The City also has Messaging on the City website Fats, Oils, & Grease Outreach, including a means for the public to Contact the City. In addi�on, the City maintains a presence at community events where it further atempts to educate the public. Pipe blocking substances collected during maintenance and repair ac�vi�es are disposed of at the Burlingame Wastewater Treatment Facility. This is done on an as-needed basis. The City’s legal authority to prevent illicit discharges is through Municipal Code 15.10.40, Municipal Code 15.10.056 which prohibits stormwaters, surface water and groundwater and 15.10.38, general prohibited wastes. The City’s authority to require grease removal devices is through Municipal Code 15.10.066. The City’s design and installa�on criteria for grease removal devices is the most recent edi�on of the Uniform Plumbing Code enforced in the Municipal Code 18.08.005 Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SEWER PIPE BLOCKAGE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 37 of 55 The City’s authority to inspect grease producing facili�es is through its FOG Source Control Program and supported by Municipal Code 15.10.102 The City has iden�fied problem areas within the collec�on system and addresses pipe blocking issues through its high frequency cleaning and root control programs, described in 4.5 of this document. The City’s FOG Source Control Program is intended to work in conjunc�on with the City’s preven�ve maintenance program to monitor and prevent FOG-related SSOs. It remains an essen�al component in mee�ng and maintaining its projected spill reduc�on performance goals mandated by the Sanitary Sewer WDR The elements of the City’s FOG Source Control Program include: • Requirement for the installa�on of grease removal devices (GRDs); • Permi�ng food service establishments (FSE); • Requirement for proper opera�on and maintenance of GRDs • Verifica�on of grease handling and disposal prac�ces • FSE inspec�ons • Public Educa�on and Outreach and • Enforcement. In addi�on to the City’s source control program, hydro-cleaning of gravity lines is performed on a rou�ne and systema�c basis to control grease and ensure con�nuity of service. New problems found through the CCTV inspec�on program are brought to a supervisor’s aten�on and evaluated to determine the best course of ac�on to mi�gate or eliminate. All problem line segments are evaluated for the best method of repair or rehabilita�on. The City’s Spill Reduc�on Performance Goal requires the City to iden�fy controllable sources of spill- genera�ng ac�vi�es through the implementa�on of a FOG Program. The overall aim is to reduce the occurrence of FOG-related mainline spills in the service area over �me. The City focused on food service establishments (FSEs) to prevent or reduce FOG-related mainline spills in an effec�ve manner. In 2008, the City modified its FOG Source Control Program to include public outreach targe�ng residen�al areas with FOG-related mainline spills. All residen�al FOG-related mainline SSO’s are categorized and mapped. This data is u�lized by City staff to assist with iden�fying areas or line segments of the sanitary sewer collec�on system prone to FOG-related stoppages. Staff establishes a priori�zed or accelerated preven�ve cleaning, inspec�on and maintenance schedule for each iden�fied area. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Have there been any blockages/spills from any iden�fied problem area? • Is the City receiving feedback on public outreach efforts? • Are the debris and other sewage solids collected during cleaning ac�vi�es being disposed of appropriately? • Have there been spills due to excessive fats, oil, grease, roots, or non-dispersible wipes discovered in the sewer system during the audit period? • Are there repeat offenders among FSEs? • Are enforcement trends decreasing? • Are Source Control and Collec�on staff included in the plan check process? Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SEWER PIPE BLOCKAGE PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 38 of 55 IMPLEMENTATION PLAN/SCHEDULE No Plan Schedule Responsible Party Mgr. Sup Crew 7.1 Review/evaluate enforcement and inspec�on findings and implement changes as necessary. Annually X 7.2 Review spill rates and causes and make changes to maintenance programs, as necessary. Annually X X X RESILIENCE Resilience is addressed in Element 7 by: • Inspec�on of select assets directly downstream of grease producing businesses to ensure source control is effec�ve. • Residen�al FOG outreach and educa�on program. • Performance of regular assessments of system assets to monitor performance. • QA/QA process for evalua�ng pipe cleaning effec�veness. • Daily disposal of pipe blocking materials retrieved during maintenance ac�vi�es. APPENDIX 7 INCLUSIONS: • 7.1 FOG Ordinance § 15.10.038 Generally prohibited wastes and § 15.10.040 Specifically prohibited wastes Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 39 of 55 8. System Evalua�on, Capacity Assurance, Capital Improvements WDR REQUIREMENTS Atachment D-8 (pg. D-) “The Plan must include procedures and activities for: • Routine evaluation and assessment of system conditions; • Capacity assessment and design criteria;. • Prioritization of corrective actions; and • A capital improvement plan.” 8.1. System Evalua�on and Condi�on Assessment WDR REQUIREMENTS Atachment D-8.1 (pgs. D-7/D-8) “The Plan must include procedures to: • Evaluate the sanitary sewer system assets utilizing the best practices and technologies available; • Identify and justify the amount (percentage) of its system for its condition to be assessed each year; • Prioritize the condition assessment of system areas that: • Hold a high level of environmental consequences if vulnerable to collapse, failure, blockage, capacity issues, or other system deficiencies; • Are located in or within the vicinity of surface waters, steep terrain, high groundwater elevations, and environmentally sensitive areas; • Are within the vicinity of a receiving water with a bacterial-related impairment on the most current Clean Water Act section 303(d) List. • Assess the system conditions using visual observations, video surveillance and/or other comparable system inspection method; • Utilize observations/evidence of system conditions that may contribute to exiting of sewage from the system which can reasonably be expected to discharge into a water of the State; • Maintain documents and recordkeeping of system evaluation and condition assessment inspections and activities; and • Identify system assets vulnerable to direct and indirect impacts of climate change, including but not limited to: sea level rise; flooding and/or erosion due to increased storm volumes, frequency, and/or intensity; wildfires; and increased power disruptions.” Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 40 of 55 COMPLIANCE The City CCTV inspects the collec�on system on a 3-year return cycle and has records on the en�re system. Defects are coded using IT Pipes and the NASSCO PACP ra�ng system, which provides consistent assessment and rankings of defects. Pump Sta�ons are inspected daily, and findings are documented. Condi�on assessments are performed, by City staff, on all sta�ons annually. The City has iden�fied and jus�fied the CCTV inspec�on three-year return interval in its current Master Plan, developed by City engineers and last updated in 2022. The City is evalua�ng this interval to determine the op�mal interval. The City’s owns 8532 lower laterals totaling approximately 31 miles. The maintenance goal for the Lateral Program is to clean 2100 laterals per year, which equates to a 4 year return cycle. This is being monitored to determine the op�mal return cycle. The City has a program to annually assesses the condi�on of its pump sta�ons, In addi�on to this, an in- depth assessment was performed and is documented in the City’s 2022 Master Plan. The intent of the visual condi�on assessment is to iden�fy and priori�ze repair and replacement needs for aging facili�es and mi�gate poten�al risks of failure. The City’s approach to priori�zing inspec�on and maintenance ac�vi�es is generally performance-based. However, the City has iden�fied system assets that hold a high level of environmental consequences, such as facili�es within a proximity of surface waters, including aerial creek crossings, and pipes located in areas where heavy rains could erode soil and possibly damage pipe. The City uses Smart Cover (flow level monitors) to monitor I&I as well as exfiltra�on, which would occur if a pipe were severely damaged. If areas are found to have significant infiltra�on, a project will be created to replace the segment. The City’s CCTV inspec�on program, for both gravity mains and laterals, manhole inspec�on program and li� sta�on inspec�on program are all used to assess condi�ons of system assets. These are on-going programs that have been in place for years. The City maintains records for CCTV, manhole, and li� sta�on inspec�ons. Supervisory staff monitor, evaluate, and document findings, which are used to determine capital improvement and repair/replace projects This is a collabora�ve effort between opera�ons and engineering. The opera�ons management staff and engineering have a monthly mee�ng where inspec�ons and assessment are discussed on an as needed basis. The City has iden�fied possible climate change impacts of the collec�on system. Drought, leading to more root intrusion, primarily in the lower lateral, Public Safety Power Shutdowns (PSPS) due to wildfires and/or overtaxed electrical grids, and intense rain events that might exceed storms used in the hydraulic model. These have not had a no�ceable impact of the collec�on system but are con�nuously being monitored so the City can react and adapt to changing condi�ons. The collec�on system experiences high levels of I&I during significant storm events and is addressing this in the current CIP. All CIP projects carried out near the San Francisco Bay are reviewed to include engineering controls against sea level rise as feasible. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 41 of 55 EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Has the City maintained its schedules for CCTV, li� sta�on, lateral and li� sta�on inspec�ons? • Are efforts being documented? • Is collected data being reviewed in a �mely manner. • Are poten�al climate change impacts being monitored? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 8.1.1 Review/evaluate enforcement and inspec�on findings and implement changes as necessary. Annually X X 8.1.2 Review spill rates and causes and make changes to maintenance programs, as necessary. Annually X X 8.1.3 Hold mee�ngs to discuss any issues that may result from climate changes. Annually X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 42 of 55 8.2. Capacity Assessment and Design Criteria WDR REQUIREMENTS Atachment D-8.2 (pgs. D-8/D-9) “The Plan must include procedures to identify system components that are experiencing or contributing to spills caused by hydraulic deficiency and/or limited capacity, including procedures to identify the appropriate hydraulic capacity of key system elements for: • Dry-weather peak flow conditions that cause or contributes to spill events; • The appropriate design storm(s) or wet weather events that causes or contributes to spill events. • The capacity of key system components; and • Identify the major sources that contribute to the peak flows associated with sewer spills. The capacity assessment must consider: • Data from existing system condition assessments, system inspections, system audits, spill history, and other available information; • Capacity of flood-prone systems subject to increased infiltration and inflow, under normal local and regional storm conditions; • Capacity of systems subject to increased infiltration and inflow due to larger and/or higher-intensity storm events as a result of climate change; • Increases of erosive forces in canyons and streams near underground and above-ground system components due to larger and/or higher-intensity storm events; • Capacity of major system elements to accommodate dry weather peak flow conditions, and updated design storm and wet weather events; and • Necessary redundancy in pumping and storage capacities. COMPLIANCE The City’s current Sewer System Master Plan includes an updated hydraulic model and includes an analysis of system component performance, during both dry weather and peak wet weather condi�ons. The exis�ng system was evaluated for capacity and projec�ons for the future system were established. In Burlingame’s service area, back-to-back storm events are a common occurrence. For this reason, the system was evaluated using a 5-year, 24-hour storm event on day one, followed by a 1- year, 24-hour storm on day two. Proposed sewer improvements required to correct exis�ng deficiencies have been iden�fied. Included in the Master Plan, was an Inflow and Infiltra�on (I&I) study performed by V&A Consul�ng Engineers. Monitoring sites includes 25 manhole loca�ons and 6 pump sta�ons covering 24 drainage basins within the City service area. Sources of I&I were iden�fied for each basin. The City’s Rehabilita�on and Replacement Program includes the rehabilita�on or replacement of 2 percent of pipelines that are not already a recommended improvement project. This equates to approximately 19 miles of pipeline R&R projects between 2021 through 2030. This includes the pipelines iden�fied in the I/I iden�fica�on and elimina�on program. The City uses exis�ng inspec�on data to priori�ze pipelines and choose the best rehabilita�on or replacement method. Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 43 of 55 EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Number of capacity-related spills or surcharge condi�on during the audit period. • Has the system responded to rain events as indicated by the hydraulic model? • Has there been any changes to zoning designa�ons (residen�al, commercial, industrial)? IMPLEMENTATION PLAN/SCHEDULE No Plan Schedule Responsible Party Mgr. Sup Crew 8.2.1 Monitor/evaluate significant rain events to see if they exceed the design storm in the hydraulic model. Each significant rain evet X X 8.2.2 Iden�fy and monitor flood-prone areas suscep�ble to erosion from rain events Each significant rain event X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 44 of 55 8.3. Priori�za�on of Correc�ve Ac�on WDR REQUIREMENTS Atachment D-8.3 (pg. D-9) “The findings of the condition assessments and capacity assessments must be used to prioritize corrective actions. Prioritization must consider the severity of the consequences of potential spills.” COMPLIANCE All defects discovered from CCTV inspec�ons of the gravity system are rated using the PACP defect coding system. Manhole and Li� Sta�on inspec�ons and findings are documented using ITpipes, checklists and CMMS task records. Collec�ons management staff evaluates and priori�zes each defect and determines the best course of ac�on to rec�fy. This is done in coordina�on with engineering. Larger, more involved work such as line replacement or rehabilita�on is recommended by collec�on staff to the engineering team. Engineering then designs the project and includes the projects in the CIP. When priori�zing work to be done, staff considers all factors such as the likelihood a defect would contribute to a service disrup�on or spill, loca�on of facility to surface water or other environmentally sensi�ve areas, difficulty of access and severity and consequence of failure or inac�on. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Has the City adhered to its system evalua�on/condi�on assessment schedule? • Has the City adhered to its priori�za�on/correc�ve procedures for sewer repair and capacity improvement projects? • Have projects been completed before deficiencies caused failures? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 8.3.1 U�lize all available data for priori�zing correc�ve ac�ons considering severity and consequences of poten�al spills. Each CIP Update X X 8.3.2 Maintain documents and recordkeeping of system evalua�on and condi�on assessment inspec�ons and ac�vi�es. A�er each significant rain event X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 45 of 55 8.4. Capital Improvement Plan WDR REQUIREMENTS Atachment D-8.4 (pg. D-9) “The capital improvement plan must include the following items: • Project schedules include completion dates for all portions of the capital improvement program; • Internal and external project funding sources for each project; and • Joint coordination between operation and maintenance staff, and engineering staff/consultants during planning, design, and construction of capital improvement projects; and Interagency coordination with other impacted utility agencies.” COMPLIANCE The City’s Capital improvement Plan (CIP) includes construc�on or renova�on projects that will allow the City to provide reliable service to its customers. The projects have been priori�zed based on reducing spills under peak wet weather flows, the type and extent of the deficiency and when the deficiency is triggered (i.e., exis�ng versus buildout) Based on these factors’ projects were assigned an implementa�on year. The capital improvements were grouped into one of the following phases: • Near Term Phase 1 (FY 2021-22 thru FY 2025-26): This phase includes projects that are targeted as the highest priority improvements. • Near Term Phase 2 (FY 2026-27 thru FY 2030-31): This phase includes projects that are targeted as high priority improvements that may be mi�gated or monitored for several years prior to being implemented. • Long Term (FY 2031-32 thru FY 2040-41): This phase generally includes medium priority improvements or improvements. Cri�cal projects were phased in the earlier phases (years) of the 20-year CIP. Less cri�cal projects were phased into later phases of the 20-year CIP. Funds for CIP projects are collected through two avenues. The two sources of revenue are customer sewer rates, large development capacity fees. While these two sources are the primary inflow of funding, the department also explores grant funding and loans to assist with large program projects. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Has the City’s capital improvement plan schedule been adhered to? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 8.4.1 Hold regular coordina�on mee�ngs, with all par�es, to help keep the projects on track and resolve issues that may arise in a �mely manner. Annually X X 8.4.2 For schedules that are not followed, jus�fy and document the reason. Each Delayed Project X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 SYSTEM EVALUATION, CAPACITY ASSURANCE, CAPITAL IMPROVEMENTS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 46 of 55 RESILIENCE Resilience is addressed in Element 7 by: • Is there an annual review of the Capital Improvement Plan by all appropriate individuals including both Engineering and Opera�ons? APPENDIX 8 INCLUSIONS • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 47 of 55 9. Monitoring, Measurement, and Program Modifica�ons WDR REQUIREMENTS Atachment D-9 (pg. D-9) “The Plan must include an Adaptive Management section that addresses Plan-implementation effectiveness and the steps for necessary Plan improvement, including: • Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities; • Monitoring the implementation and measuring the effectiveness of each Plan element; • Assessing the success of the preventive operation and maintenance activities; • Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations; and • Identifying and illustrating spill trends, including spill frequency, locations, and estimated volumes.” COMPLIANCE The City maintains accurate and relevant inspec�on and maintenance records for the collec�on system. Much of their documenta�on today is maintained electronically, which allows for ease of access and analysis. This helps City staff to make sound decisions and priori�ze ac�vi�es when dealing with the rou�ne and the unexpected. To further improve effec�veness audit findings are evaluated, priori�zed and addressed. Any findings not addressed during the three-year audit cycle will be carried over to the next audit and addressed in a priori�zed order. Audit findings that lead to upda�ng the SSMP are documented in the SSMP Change Log. The City is commited to con�nuous improvement and monitors and evaluates performance of work programs to ensure they are being implemented as intended. Data is collected and maintained on all inspec�on and maintenance ac�vi�es in the CMMS database and with minimal paper records to keep track of outcomes of the various work plans (e.g., pipe repairs, gravity cleaning, pipe inspec�ons, pump sta�on ac�vi�es, etc.) This SSMP has been designed to include key performance indicators (KPIs) for each element, which are used to measure effec�veness. KPI’s are monitored annually to help staff monitor performance against intended outcomes and adjust as necessary. The City monitors spill trends, at a minimum every three (3) years during required audits, u�lizing the data maintained in the CMMS database. These efforts are helpful in planning efforts with limited resources reduce the impact of spills. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Are SSMP Elements being periodically evaluated for effec�veness? • Are work ac�vi�es and spill events being documented? • Has a plan and schedule been established to address audit findings/deficiencies from the last audit? • Is Trend Analysis being performed on spill causes? • Have work programs been assessed and updated as necessary? Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 48 of 55 Figure 7 - Agency, Region and State SSO Rate per 100 Miles by Year Figure 8 - Spill Volume By Year/Spill Volume Per Capita by Year Figure 9 - Spill Recovered Percent by Spill Type Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 49 of 55 *Note – Spill Couse “Other” – This op�on was used when mul�ple factors were iden�fied as the cause. Figure 10 - City Spills Causes by Volume of Spills (2007-2022) Figure 11 - City Spills Causes by No. of Spills (2007-2022) Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 50 of 55 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Dir Eng Sup 9.1 Assess work programs to ensure outcomes are as intended. Annually X X 9.2 Ensure work programs and the SSMP are updated based on assessments. As Needed X X 9.3 Monitor and evaluate spill trends. Document efforts. Annually X X RESILIENCE Resilience is addressed in Element 9 by: • Development of key performance indicators to measure effec�veness of the SSMP. • Performing periodic reviews of the SSMP to help ensure it is being properly implemented. • Developing and adhering to a �meline to correct deficiencies found during the audit process. • Periodically evalua�ng work programs to help ensure effec�veness. APPENDIX 9 INCLUSIONS: • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 INTERNAL AUDITS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 51 of 55 10. Internal Audits WDR REQUIREMENTS Atachment D-10 (pg. D-10) “The Plan shall include internal audit procedures, appropriate to the size and performance of the system, for the Enrollee to comply with section 5.4 (Sewer System Management Plan Audits) of this General Order.” COMPLIANCE The City completed its last audit on February 3, 2025, and will complete audits every three (3) years moving forward. The objec�ve of the audit is to evaluate compliance, implementa�on and effec�veness of the SSMP. The SSMP includes a descrip�on of how the City will comply with the requirements of each Element. The audit review includes an evalua�on to determine if compliance has been met. Implementa�on is evaluated by determining if the agency is execu�ng the SSMP as stated. Effec�veness is evaluated by using key performance indicators, which have been developed specifically for each element. An addi�onal evalua�on is performed to comply with Specifica�ons 5.6 addressing resilience. Resilience indicators have been developed for each element, and they serve to demonstrate how resilience is built into the SSMP and inspec�on, maintenance and spill response ac�vi�es. Any deficiencies discovered through the audit process are noted and a plan and schedule to implement correc�ve measures is established. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Have audits been performed as required? • Have the audits assessed compliance, implementa�on, and effec�veness? • Have deficiencies been iden�fied? • Has a plan and schedule to rec�fy the deficiencies been established? IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 10.1 Schedule audits in advance of due dates to ensure adequate �me to complete. City has 6 months to complete the audit from the end of the audit period. Beginning at end of audit period X X 10.2 Ensure a plan and schedule is developed to address deficiencies. Once the Audit is completed X X Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 INTERNAL AUDITS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 52 of 55 RESILIENCE Resilience is addressed in Element 10 by: • Periodically evalua�ng key performance indicators during the audit period to assess effec�veness and make correc�ons, if necessary, prior to the audit. • Evalua�ng previous audits to ensure deficiencies have been rec�fied. • Scheduling the audit due dates and comple�ng the audit on �me. APPENDIX 10 INCLUSIONS: • 10.1 2021-2024 SSMP Audit Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 COMMUNICATION PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 53 of 55 11. Communica�on Program WDR REQUIREMENTS Attachment D-11 (pg. D-10) “The Plan must include procedures for the Enrollee to communicate with: • The public for: • Spills and discharges resulting in closures of public areas, or that enter a source of drinking water; and • The development, implementation, and update of its Plan, including opportunities for public input to Plan implementation and updates. • Owners/operators of systems that connect into the Enrollee’s system, including satellite systems, for: • System operation, maintenance, and capital improvement-related activities.” COMPLIANCE Should the City experience a spill that may require closure of public areas or enter a source drinking of water, signs will be immediately placed indica�ng the issue and providing contact informa�on. Staff will remain on site to provide an addi�onal safety factor un�l appropriate authori�es respond and direct otherwise. The City also has an auto-dialer system through their Police Department that can alert the public. In addi�on, the City has a social media presence on Facebook, Instagram, X (formerly twiter), Nextdoor, and an e-newsleter that can be distributed in a �mely manner. The City’s governing council will approve the SSMP every 6 years during a regular council mee�ng. As this will be an agenda item, the public will have the opportunity to comment. The SSMP is posted on the City’s website, which provides the public the opportunity to contact the City, via the “Contact Us” feature. The City lists current CIP projects. The City communicates with satellite systems, Hillsborough and Burlingame Hills, via periodic mee�ngs and on an as-needed basis to keep them abreast of City Ordinances, codes and any concerns that may arise. The City and its satellites have clearly defined the “hand-off” points between systems. EFFECTIVENESS The City u�lizes the following Key Performance Indicators for measuring effec�veness of this Element: • Does the City place all SSMP ac�on items on the agenda for regular Counsel mee�ngs? • Does the City have signage, or other means, readily available to no�fy the public of environmental or public risk factors related to a sewage spill? • Does the City perform outreach to residen�al customers? Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 COMMUNICATION PROGRAM © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 54 of 55 IMPLEMENTATION PLAN/SCHEDULE No. Plan Schedule Responsible Party Mgr. Sup Crew 11.1 Ensure the City Council approves the SSMP per schedule. Every 6 years X 11.2 Ensure the SSMP is posted on the City website and the link func�ons properly. Annually X X 11.3 Ensure Sewage Spill Warning signs are readily available to communicate with the public when necessary Annually X X RESILIENCE Resilience is addressed in Element 11 by: • Use the SSMP as a tool to communicate to the public how the City is managing the system. • Maintain a consistent presence in the service area by atending community events or issuing periodic newsleters or other communica�ons to the public. • Make it clear and easy for the public to contact the City. APPENDIX 11 INCLUSIONS • None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 APPENDICES © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 55 of 55 LIST OF APPENDICES APPENDIX 1 - None APPENDIX 2 - None APPENDIX 3 - None APPENDIX 4 4.1. Cri�cal Spare Parts List APPENDIX 5 - None APPENDIX 6 City of Burlingame Spill Emergency Response - Plan available upon request. APPENDIX 7 7.1 FOG Ordinance § 15.10.038 Generally prohibited wastes and § 15.10.040 Specifically prohibited wastes (available online) APPENDIX 8 8.1 Adopted Opera�ng and CIP Budget FY 2024-2025 (Public Works – Sewer Maintenance Division Excerpt pgs. 149 & 150)(available online) APPENDIX 9 - None APPENDIX 10 10.1. Most Recent City SSMP Audit - available upon request. APPENDIX 11 - None Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63 © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Burlingame City use only. Page 1 of 1 Appendix 4.1 Cri�cal Equipment and Parts Inventory The City of Burlingame maintains its en�re collec�on system to industry standards. All pump sta�ons have built in redundancy to provide for rou�ne pump maintenance and emergency backup in the event of power failure, pump failure, emergency or high flow. Emergency response equipment and parts include two (2) Vac-Con Combina�on Truck, a CCTV Van, Emergency Diesel Generators, Compressor, and four (4) diesel-driven Emergency Bypass Pumps, plugs, and spill containment kits. Replacement pump motors, impellers, mechanical seals and a variety of electrical parts are maintained and replaced as needed. The City of Burlingame also has numerous vendors who can be called upon to deliver necessary parts and equipment in case of an emergency. The City of Burlingame also owns a trailer-mounted backup generator that can be used to provide power should any of the on-site generators fail at Li� Sta�ons. • Pipelines/Manholes – An inventory of plugs and bypass equipment are maintained to provide for stopping, diver�ng, or bypassing flows while emergency repairs are made. The City of Burlingame relies on staff to perform most emergency repairs. Burlingame staff also maintain a substan�al inventory of cri�cal parts including pipe, pipe fi�ngs and repair couplings. In addi�on, the City of Burlingame stockpiles manhole frames and covers for emergency replacement by staff, or a contractor if needed. • Sewer li� sta�ons- An inventory of cri�cal parts, such as; repair clamps for pressurized lines, portable backup generators, submersible pumps for li� sta�on bypass procedures, and electrical supplies such as fuses, breakers, transducers and PLC’s. Cri�cal Sewer System Replacement Parts Inventory Part Descrip�on Number in Inventory Loca�on Transducer 4 Locker in S&S shop Flygt pump 5 hp 1 S&S shop Flygt pump 15 hp 2 S&S shop Flygt pump 20 hp 2 S&S shop Pump repair kits 11 S&S shop Operator Interface Terminal (OIT) 4 S&S shop Pumps 4 - Portable 6” Trash Pumps Grove Pump Sta�on and 1740 Rollins Hoses Various lengths Grove Pump Sta�on and Corpora�on Yard Plugs Various sizes S&S shop Pipe Various sizes & Lengths S&S shop Fi�ngs Various sizes S&S shop Docusign Envelope ID: DEA0D285-3AA2-4424-9CA6-538880285E63