Title
Adopt a Resolution to Approve the City’s Sewer System Management Plan (SSMP) Update and Authorize the City Manager or Her Designee or the City’s Legally Responsible Official to Certify and Submit the SSMP to the California State Water Resources Control Board (SWRCB)
Staffreport
COUNCIL PRIORITY
• Infrastructure
SUMMARY
The SWRCB program requires collection agencies to present the SSMP to the agency’s governing board for approval and re-approval every 6 years. The updated SSMP has been completed and requires adoption by the City Council prior to submitting to the SWRCB.
RECOMMENDATIONS
Staff recommends that City Council approve the SSMP Update so that it can be certified and submitted to the SWRCB as required by the SWRCB.
BACKGROUND
The State Water Resources Control Board (SWRCB) adopted Order No. 2006-0003- DWQ, Statewide General Waste Discharge Requirements for Sanitary Sewer Systems in May 2006. The order requires public agencies that own or operate sanitary sewer systems to develop and implement Sewer System Management Plans (SSMPs). An SSMP is used to facilitate proper funding and management of sanitary sewer systems with the goal to reduce/eliminate spills. It must contain a spill response plan designed to minimize water quality impacts and potential nuisance conditions.
On December 6, 2022, the SWRCB adopted Order No. 2022-103-DWQ, Statewide Waste Discharge Requirements (WDRs) - General Order for Sanitary Sewer Systems (2022 Order), which became effective on June 5, 2023 and superseded the 2006 Order and amendments thereafter. Through the General Order, the SWRCB requires an enrollee (the City) to:
• Comply with federal and state prohibitions of discharge of sewage to waters of the State, including federal waters of the United States;
• Comply with specifications, and notification, monitoring, reporting and recordkeeping requirements in the General Order that implement the federal Clean Water Act, the California Water Code (Water Code), water quality control plans (including Regional Water Board Basin Plans) and policies;
• Proactively operate and maintain resilient sanitary sewer systems to prevent spills;
• Eliminate discharges of sewage to waters of the State through effective implementation of a Sewer System Management Plan (SSMP);
• Monitor, track, and analyze spills for ongoing system-specific performance improvements; and
• Report noncompliance with the General Order per reporting requirements.
As part of the requirement to implement an SSMP, City Staff performed an internal audit; Fischer Compliance LLC was hired to prepare the SSMP Update. The 2025 Update meets and exceeds compliance with the WDR.
Analysis
The items highlighted below are major elements of the 2022 Order, which have been completed by the City’s Water Pollution Control Division to ensure that the City is in compliance:
• Regulatory Coverage - Prepared and electronically certified the “Continuation of Existing Regulatory Coverage” form in CIWQS to continue coverage from the 2006 Order under the 2022 Order.
• Spill Emergency Response Plan (SERP) Update - Updated the SERP in March 2025, which includes measures to protect public health and the environment by preventing Sanitary Sewer Overflows (SSOs).
• Annual Reports - Prepared and electronically certified Annual Reports in CIWQS to provide information on the population served and service area; years of experience and certifications held by sewer operations and maintenance workers; overall system condition and performance, causes of SSOs, and any actions taken to investigate and address system deficiencies. The annual reports were completed in March 2024 and March 2025.
• SSMP Audit - City staff audited the implementation and effectiveness of the SSMP, assessed compliance with the 2022 Order, identified deficiencies in addressing SSOs and any discharges to waters of the State, and to determine any modifications needed to correct deficiencies. The SSMP Audit (Attachment B) was completed in February 2025 and includes Audit Findings and Recommended Corrective Actions.
• SSMP Update - Ficher Compliance Inc. was retained to assist the City with the preparation of the SSMP Update, which includes eleven chapters covering the procedures for the management, operation, and maintenance of the sanitary sewer system, evaluation of existing and future conditions and system needs, and the prioritization of repairs and maintenance work as described in the 2022 Order. In addition, the SSMP Update incorporates the Findings and Recommended Corrective Actions from the SSMP Audit. This SSMP Update is materially consistent with the statewide WDRs for Sanitary Sewer Systems and incorporates the latest requirements from the SWRCB related to the WDRs - General Order for Sanitary Sewer Systems
The 2025 Update meets and exceeds compliance with the WDR. Upon adoption of the SSMP, Staff will submit the document to the SWRCB, perform audits at the mandated intervals, update the document to reflect findings, and/or comply with the latest State Order. The SSMP will require recertification on a 6-year cycle.
Applicable General Plan Policies
Policy CSF-6.4 Wastewater Collection and Treatment. Maintain efficient, environmentally sound, and cost-effective wastewater collection and treatment services in San Leandro.
Financial Impacts
Certification and submittal of the SSMP Update Plan is a requirement of the SWCRB. Any cost implications from the Update have been accounted for in the adopted budget.
ATTACHMENTS
A: Resolution to Approve SSMP Update
B: SSMP Audit
C: SSMP Update
PREPARED BY: Ramya Sankar, Management Analyst II, Water Pollution Control Division