Sanitary Sewer Management Planning— A Better Way to Manage Sewer Collection Systems

INTRODUCTION AND BACKGROUND

Treatment plants, including pretreatment programs, have been regulated for some time along with several other networks such as potable water, natural gas, electricity, and liquid fuels, among others.  Sanitary collection systems are the last major component of the wastewater management system yet to be regulated.  In 1995, the US Environmental Protection Agency (EPA) convened an Urban Wet Weather Flows Advisory Committee and a Sewer System Overflow (SSO) Subcommittee.  Both the Committee and the Subcommittee included municipal representatives, advocacy groups, states, and representatives from the EPA.

On May 29, 1999, President Clinton directed EPA to “improve the protection of public health at our Nation’s beaches by developing, within one year, strong national regulations to prevent the over 40,000 annual sanitary sewer overflows from contaminating our nation’s beaches and jeopardizing the health of our nation’s families.  EPA Administrator Carol Browner signed a proposed SSO rule in January 2001.  The incoming Bush Administration withdrew the signed rule proposal for further review before it could be officially published in the Federal Register for public comment and it has not been put forward since.  As a result, there are still no clear, consistent national guidelines or regulations leaving many agencies and wastewater collection system managers to formulate individual plans and go it alone.

In 2006, the California State Water Resources Board became the first public entity to implement waste discharge requirements to regulate sanitary sewer systems.  To effectively manage a wastewater collection system, it is expected that each collection system agency should develop and implement a Sewer System Management Plan also called an SSMP.  Other agencies around the country have followed in the intervening years to the present, although there is still no federal requirement for an SSMP by the EPA.

SEWER SYSTEM MANAGEMENT DEFINED

The SSMP is a living document to describe the activities necessary for a utility agency to manage its wastewater collection system and to keep the system up to date and running efficiently.  For the SSMP to be effective for the agency, there are a few specific components that must be implemented.  These include:

1. Maintaining or improving the condition of the collection system infrastructure to provide reliable service into the future.
2. Cost-effectively minimizing infiltration/inflow (I/I) and providing adequate sewer capacity to accommodate existing and future design flows; and
3. Minimizing the number and impact of wastewater sewer system overflows (SSOs) that occur.

With some exceptions, the current performance of many collection systems can be considered as poor due to minimal maintenance compounded over many years.  Many collection systems are maintained by a public works department or other governmental entity charged with overseeing a variety of functions, such as streets, sidewalks, storm drains, and sometimes water utility maintenance in addition to the sanitary collection system.  Money is usually spent where the ratepayer or the public can see the results.

Consequently, one of the key concepts that should come to mind when thinking about the SSMP is the idea of “Planning”.  Alan Lakein, a well-known author on personal time management has said: “Planning is bringing the future into the present so that you can do something about it now”.  This is a very reasonable consideration of what the SSMP and the concept of planning have in common.  By using the planning aspect, the frequency and severity of SSO’s and I/I problems can be reduced and the corresponding cost associated with running the wastewater collection system should also be reduced.

The SSMP as a document may be comprised of several individual plans linked under a single umbrella.  The SSMP represents a consistent and singular document to enable a unified approach to help plan the management of a wastewater collection system for the governing agency.

CORE COMPONENTS

Each wastewater collection system is different, and some of the differences that affect the content of an SSMP include geographical terrain (hilly or flat), number and type of connections (residential, commercial, industrial), soil types, weather patterns, age of sewers, condition of sewers, materials of sewers, history of sewer management practices, number of SSOs, affordability of sewer rates, type of agency (municipal government or special district), among other factors.

In summary, the required elements of an SSMP for the efficient management of a wastewater collection system should include most, if not all, of the following elements:

1. Collection system management goals,
2. Personel Organization, including the chain of command and communications,
3. The legal authority for permitting flows into the system,
4. Overflow emergency response plan,
5. Fats, oils, and grease (FOG) control program,
6. Monitoring, measures, and program activities to maintain the system,
7. Design and construction standards,
8. Capacity management,
9. Monitoring plan for SSMP program effectiveness,
10. Periodic SSMP Audits,
11. Communication Program to disseminate information on updates and program improvements.

ELEMENTS OF THE SSMP

Goals – The SSMP is a plan and schedule to properly manage, operate, and maintain all parts of the wastewater collection system.  While a variety of goals can be formulated for any given system, the one or ones selected must be realistic, attainable and effective.  It is unlikely that a single goal will achieve the desired outcome.  Several goals should be formulated and considered for implementation as related to such ideas as performance, safety, levels of service, resource use, economics, public outreach, and other considerations.

Personnel Organization – The SSMP will contain a list of responsible staff or other authorized representatives to implement, manage and update the SSMP over time.  An important designation is a responsible or authorized representative, also designated as the Legally Responsible Official or LRO.  It should further detail the chain of communication for implementing the SSMP, responding to SSO events and meeting SSO reporting requirements, and personnel names and telephone numbers for management, maintenance, and administration.  This can be accomplished by including an organizational chart similar to the shown in Figure 1 below.

Figure 1.  Example SSMP Organization Chart

A narrative in the form of brief statements on the role of each person named in the chart can be included or it can be summarized in a tabular format organized by the SSMP element, responsible party (by position and name), and contact information (telephone numbers and/or emails).

Legal Authority – The SSMP document itself does not give one the legal authority but it will help outline what the level of authority is and assist with making sure there is progress toward covering options in the future.  The discussion in the SSMP helps demonstrate that each agency possesses the necessary legal authority for enforcement through sewer use ordinances, service agreements, discharge permits, or other means to:

1. Prevent illicit discharges into the wastewater sewer collection system,
2. Require sewers and connections to be properly designed and constructed according to proper design, installation, and testing standards,
3. Ensure access for maintenance, inspection, or repairs,
4. Limit the discharge of fats, oils, and grease (FOG) and other debris,
5. Control infiltration and inflow (I/I) into the collection system,
6. Enforce action against any violation of its sewer ordinances.

Documentation of the specific items granting the legal authority can be done by a table detailing the specific codes or ordinance sections, and/or inclusion of the cited items in the plan.

Overflow Emergency Response Plan – Emergency response plans should include the protocols and an indication of the resources available to handle a wastewater sewer overflow.  The response plan should be developed as a stand-alone document summarized in the SSMP and updated as needed to reflect staffing or notification requirements, including contact numbers.  The plan does not need to be organized specifically into the following sections, but it must include written procedures to address emergency operations including:

1. Notification: procedures to ensure staff and contractor personnel follow the Emergency Response Plan and are adequately trained to handle the problem;
2. Response Planning and Training: program to ensure an appropriate response to all overflows, including the emergency response procedures, requirements for orientation and refresher courses over time to stay current, and for maintaining the emergency equipment;
3. Reporting: procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities, with current and up-to-date information on contacts and officials;
4. Impact Mitigation: program to contain and prevent the discharge of untreated and partially treated wastewaters and minimize adverse impacts.

Fats, oils, and grease (FOG) control program – The first step for any collection system is determining whether FOG is a problem in the system.  The SSMP can refer to any existing documentation if a wastewater collection system FOG program is already in place.  If it is the initial development to address a demonstrable problem, then the FOG control program is designed to reduce the amount of these substances discharged to the wastewater sewer system.  The planned development can consult external resources and/or neighboring agencies with existing programs as examples for consideration in developing a program that meets the specific needs of the wastewater system agency.

A FOG control program normally includes any of the following elements that are deemed as appropriate or necessary for the plan implementation.  The elements include:

1. Outreach – Plan and schedule for a public education outreach program to residential and commercial customers to keep FOG out of the sewer system. This could include such methods as direct mail or utility bill inserts, radio or newspaper ads, use of the internet and social media, door hangers, and participation in community events, among others.
2. Disposal Method – A planned method and location for disposal, including names, addresses, and telephone numbers. Sewer sections subject to FOG blockages should be cataloged for reference and prioritized based upon the past evidence of problems.
3. Legal Authority – A stand-alone sewer use ordinance or other municipal code provision that can be used to prohibit discharges and identify measures to prevent SSOs and blockages, and requirements for installation of grease removal devices (GRD) with design standards or a reference to building/plumbing codes. There should also be guidelines for maintenance and record-keeping, facility inspection programs and reporting requirements, along with a process for identifying and disseminating best management practices (BMPs) for food service establishments (FSE) of all types.
4. Requirements to Install GRDs – The SSMP should discuss what are acceptable GRD devices, acceptable design standards, necessary cleaning or maintenance frequencies, and record-keeping requirements, and required storage and disposal methods for accumulated FOG prevented from entering the wastewater collection system.
5. Inspection and Enforcement Authority – The description of the inspection and enforcement program including resources available, inspection checklists, staff training requirements and documentation on FSEs with problems and FOG hot spots in the local sewers.
6. Collection System Maintenance – Process descriptions for the utility workers to maintain the collection system and remove FOG buildups, procedures to investigate FOG sources and causes of blockages, effective means of removal, and the means to check/confirm the effective removal of FOG such as by CCTV use.
7. Source Control Program – Development of effective means of minimizing or preventing FOG from entering the system including a survey program to identify the types of sources, problem areas, education to customers on wastewater related issues, inspection programs to gauge compliance, and use of tracking systems or documentation to ensure program success.

Operation and Maintenance Program – The SSMP must include an up-to-date map of the sanitary sewer system showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities.  There should be a prioritized schedule and log of regular maintenance and cleaning activities, a developed short term and long term rehabilitation and replacement plan keyed to the prioritized system deficiencies, provision for staff training regularly, and provision for equipment and replacement part inventories including identification of critical replacement parts to keep the system functioning.  This may necessitate an asset management plan (AMP) to be developed to ensure can define adequate funding to do what is needed for the system.

Design and Performance Provisions – The SSMP should include the description of an effective program to ensure that new sewers are properly designed and installed to minimize system deficiencies that create or contribute to future overflows or operations and maintenance problems.  Also, the description of inspection and testing of new facilities is important, to ensure that the standards are implemented in the field should be included.  Acceptance testing for gravity sewers can include low-pressure air test or water test to identify leakage, mandrel test to identify deflection in a flexible pipe, water or vacuum test of manholes to identify leakage, and television inspection to identify grade variations or other construction defects.  The design and performance standards should be reviewed and updated regularly and can include looking at new and emerging technologies.

Capacity Management – The SSMP should discuss the process to assess current and future hydraulic capacity of the key wastewater sewer system elements to handle dry weather flows as well as the storm or wet weather events.  This should include actions or modeling needed to evaluate SSO discharges caused by hydraulic deficiency, an evaluation process identified to establish appropriate design criteria with the use of enough flow monitoring so all downstream portions of a system can handle new flows.  There should be an implementation schedule and discussion of provisions for regular evaluation and updating of planning.

Capital Improvement Plan – Coincident with the capacity management, the SSMP should include the preparation and implementation of a Capital Improvement Plan (CIP).  The CIP should include the steps needed to establish short- and long-term plans to address hydraulic or structural deficiencies.  There needs to be a schedule of prioritized completion dates for all portions of the CIP and plans to update the schedule regularly.

Monitoring, Measurement, and Modifications – The SSMP should establish the procedures needed to maintain relevant information to establish and prioritize implementation of SSMP activities, to identify and illustrate SSO trends including frequency, location, and volume, pursue regular monitoring and implementation of the effectiveness of each element of the SSMP, and assess the success of a preventative maintenance program.  Program elements should be regularly updated based on monitoring or performance evaluations and the effect of significant changes should be evaluated as they may relate to policy or funding implications requiring input from the governing board or council.

SSMP Audits – The agency should conduct periodic internal audits appropriate to the size of the system and the number of SSOs.  It is recommended that his occur at a minimum every two years with reports kept on file to track the history of the SSMP.  The audit focus should be on evaluating the effectiveness of SSMP and the Agency’s compliance with SSMP requirements identified.  The audit can also demonstrate its successes in achieving goals or other measurable benchmarks that may be established.  The audit should identify any deficiencies in the SSMP and provide a summary of plan revisions needed to improve the implementation and attainment of identified goals.

Communication Program – The agency should create a plan to communicate regularly with the public on the development, implementation, and performance of its SSMP, including with systems that are tributary and/or satellite to the agency’s wastewater sewer system.  The communication within the jurisdiction the plan covers must be to keep them informed of problems, issues, and successes.  The degree of communication with other tributary systems is dependent upon the system size and the likelihood of their being satellite contributions to the system.  The methodologies and frequencies of communication should consider the best means of reaching the public and how best to relay the necessary information.

FINAL THOUGHTS

The SSMP is a guidance document not part of a regulatory requirement.  Failure to strictly comply with the SSMP requirements is not a failure of the program’s effectiveness.  Developing an SSMP is an iterative process over time; not a one and done proposition.  Documentation failures are intended to be identified during system self-audits and should be addressed as training opportunities.  Most agencies make their SSMP’s publically available by uploading an electronic copy to the web.  Reviewing what others have done provides a ready source of information and assistance for developing an SSMP suitable for your efforts.