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33-Public Services
CITY OF SAN BERNARDINO -REQUEST FOR COUNCIL ACTION From: Ken Fischer, Director Subject: Appfove the preparation schedule for the Sewer System Dept: Public Services Management Plan (SSMP) as required by the State Water Resources Control Date: August 13,.2008 Board. Meeting Date: August 18, 2008 Synopsis of Previous Council Action: Recommended Motion: That the preparation schedule for the Sewer System Management Plan (SSMP) be approved. Signature Contact person: Ken Fischer, Director Phone: 5140 Supporting data attached: Ward: All Staff Report, Attachment "1 and 2" FUNDING REQUIREMENTS: Amount: none Source: Finance: Council Notes: Agenda Item No. Repluceme„~ ~~~~s ~'3 3 CITY OF SAN BERNARDINO -REQUEST FOR COUNCIL ACTION Staff Report Subject: Approve the preparation schedule for the Sewer System Management Plan (SSMP) as required by the State Water Resources Control Board. Background: The State Water Resources Control Board (State Water Board) adopted Statewide General Waste Discharge Requirements (WDRs) for Sanitary Sewer Systems, Water Quality Order No. 2006-0003 (Sanitary Sewer Order) on May 2, 2006 (See Attachment "1") The Sanitary Sewer Order requires public agencies that own or operate sanitary sewer systems to develop and implement sewer system management plans (SSMP) and report all sanitary sewer overflows (SSOs) to the State Water Board's online SSO database. The initial step of the SSMP process is the approval by the governing body of the proposed schedule for completion of all of the elements of the required SSMP. The SSMP is a document that describes the activities an agency uses to manage the wastewater collection system effectively. Features of an effectively managed system include: 1. Maintaining and improving the condition of the collection system infrastructure in order to provide reliable service into the future. 2. Cost-effectively minimizing infiltration/inflow and providing adequate sewer capacity to accommodate design flows. 3. Minimize the number and impact of sanitary sewer overflows or (SSOs). SSOs are overflows from sanitary sewer systems of domestic wastewater, as well as industrial and commercial wastewater. S$Os often contain high levels of suspended solids, pathogenic organisms, toxic pollutants, nutrients, oxygen-demanding organic compounds, oil and grease and other pollutants. SSOs cause a public nuisance, particularly when raw untreated wastewater is discharged to areas with high public exposure, such as streets. In order to achieve the above goals the State of California expects that each wastewater collection system agency develop and implement an SSMP. The required SSMP is intended to assure that all agencies are adequately managed to achieve the goals of the WDR. The WDR adopted a time schedule for the SSMP to be completed by agencies. The time schedules vary based on size of the agency. The City of San Bernardino falls into the "Population Served Greater Than 100,000" category. The completion dates given are dates by which the City is required under the WDR to have individual items completed. 1 CITY OF SAN BERNARDINO -REQUEST FOR COUNCIL ACTION Staff Report- Continued The items in the below listed schedule will be completed on or before the State mandated deadline. Final approval of all the elements of the SSMP will be requested from Council at the time of completion of all the work, prior to May 2, 2009. The required elements of the SSMP are as follows: Element Descri tion 1. SSMP Develo ment Plan and Schedule 2. 3. Collection S stem Goals Or anization of ersonnel, includin chain of command and communications 4. Le al Authorit 5. O eration and Maintenance Pro ram 6. Overflow Emer enc Res onse Plan 7. Fats, Oils, and Grease ro ram FOG Control Pro ram 8. Desi nand Performance Provisions 9. S stem Evaluation and Ca aci Assurance Plan 10. Monitorin ,Measurement, and Pro ram Mod cations 11. SSMP Pro ram Audits 12. SSMP Communication Pro ram 13. Final SSMP Im lementation These thirteen (13) elements shall be completed on or before the following dates: Element Number Com letion Date 1 Au ust 2, 2007 2-3 November 2, 2007 4-7 November 2, 2008 8-13 Ma 2, 2009 Elements 1-3 are already completed. Staff recommends approval of the remaining SSMP Plan and Schedule (See Attachment "2"). Public Services staff will continue preparation of the SSMP as an ongoing program. The Water Department may be involved in regards to element number 7 since the Water Department already implemented a FOG program through the existing pretreatment program under the regulations outlined in SBMC Chapter 13.32. Financial Impact: There is no financial impact at this time. The WDR and the SSMP are intended to guide agencies in the best practices of managing a sewer collection system. Recommendation: That the preparation schedule for the Sewer System Management Plan (SSMP) be ® approved. ATTACHMENT nl~~ ~, STATE WATER RESOURCES CONTROL BOARD ORDER NO. 2006-0003-DWQ STATEWIDE GENERAL WASTE DISCHARGE REQUIREMENTS FOR SANITARY SEWER SYSTEMS The State Water Resources Control Board, hereinafter referred to as "State Water Board", finds that: All federal and state agencies, municipalities, counties, districts, and other public entities that own or operate sanitary sewer systems greater than one mile in length that collect and/or convey untreated or partially treated wastewater to a publicly owned treatment facility in the State of California are required to comply with the terms of this Order. -Such entities are hereinafter referred to as "Enrollees'. 2. Sanitary sewer overflows (SSOs) are overflows from sanitary sewer systems of domestic wastewater, as well as industrial and commercial wastewater, depending on the pattern of land uses in the area served by the sanitary sewer system. SSOs often contain high levels of suspended solids, pathogenic organisms, toxic pollutants, nutrients, oxygen-demanding organic compounds, oil and grease and other pollutants. SSOs may cause a public nuisance, particularly when raw untreated wastewater is discharged to areas with high public exposure, such as streets or surface waters used for drinking, fishing, or body contact recreation. SSOs may pollute surface or ground waters, threaten public health, adversely affect aquatic life, and impair the recreational use and aesthetic enjoyment of surface waters. 3. Sanitary sewer systems experience periodic failures resulting in discharges that may affect waters of the state. There are many factors (including factors related to geology, design, construction methods and materials, age of the system, population growth, and system operation and maintenance), which affect the likelihood of an SSO. A proactive approach that requires Enrollees to ensure a system-wide operation, maintenance, and management plan is in place will reduce the number and frequency of SSOs within the state. This approach will in turn decrease the risk to human health and the environment caused by SSOs. 4. Major causes of SSOs include: grease blockages, root blockages, sewer line flood damage, manhole structure failures, vandalism, pump station mechanical failures, power outages, excessive storm or ground water inflow/infiltration, debris blockages, sanitary sewer system age and construction material failures, lack of proper operation and maintenance, insufficient capacity and contractor- caused damages. Many SSOs are preventable with adequate and appropriate facilities, source control measures and operation and maintenance of the sanitary sewer system. State Water Resources Control Board Order No. 2006-0003-DWQ Page 2 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 SEWER SYSTEM MANAGEMENT PLANS 5. To facilitate proper funding and management of sanitary sewer systems, each Enrollee must develop and implement asystem-specific Sewer System Management Plan (SSMP). To be effective, SSMPs must include provisions to provide proper and efficient management, operation, and maintenance of sanitary sewer systems, while taking into consideration risk management and cost benefit analysis. Additionally, an SSMP must contain a spill response plan that establishes standard procedures for immediate response to an SSO in a manner designed to minimize water quality impacts and potential nuisance conditions. 6. Many local public agencies in California have already developed SSMPs and implemented measures to reduce SSOs. These entities can build upon their existing efforts to establish a comprehensive SSMP consistent with this Order. Others, however, still require technical assistance and, in some cases, funding to improve sanitary sewer system operation and maintenance in order to reduce SSOs. 7. SSMP certification by technically qualified and experienced persons can provide a useful and cost-effective means for ensuring that SSMPs are developed and implemented appropriately. ~J 8. It is the State Water Board's intent to gather additional information on the causes and sources of SSOs to augment existing information and to determine the full extent of SSOs and consequent public health and/or environmental impacts occurring in the State. 9. Both uniform SSO reporting and a centralized statewide electronic database are needed to collect information to allow the State Water Board and Regional Water Quality Control Boards (Regional Water Boards) to effectively analyze the extent of SSOs statewide and their potential impacts on beneficial uses and public health. The monitoring and reporting program required by this Order and the attached Monitoring and Reporting Program No. 2006-0003-DWQ, are necessary to assure compliance with these waste discharge requirements (WDRs). 10. Information regarding SSOs must be provided to Regional Water Boards and other regulatory agencies in a timely manner and be made available to the public in a complete, concise, and timely fashion. 11. Some Regional Water Boards have issued WDRs or WDRs that serve as National Pollution Discharge Elimination System (NPDES) permits to sanitary sewer system owners/operators within their jurisdictions. This Order establishes minimum requirements to prevent SSOs. Although it is the State Water Board's intent that this Order be the primary regulatory mechanism for sanitary sewer systems statewide, Regional Water Boards may issue more stringent or more State Water Resources Control Board Order No. 2006-0003-DWQ Page 3 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 prescriptive WDRs for sanitary sewer systems. Upon issuance or reissuance of a Regional Water Board's WDRs for a system subject to this Order, the Regional Water Board shall coordinate its requirements with stated requirements within this Order, to identify requirements that are more stringent, to remove requirements that are less stringent than this Order, and to provide consistency in reporting. REGULATORY CONSIDERATIONS 12. California Water Code section 13263 provides that the State Water Board may prescribe general WDRs for a category of discharges if the State Water Board finds or determines that: The discharges are produced by the same or similar operations; The discharges involve the same or similar types of waste; • The discharges require the same or similar treatment standards; and • The discharges are more appropriately regulated under general discharge requirements than individual discharge requirements. This Order establishes requirements for a class of operations, facilities, and discharges that are similar throughout the state. ~" 13. The issuance of general WDRs to the Enrollees will: a) Reduce the administrative burden of issuing individual WDRs to each Enrollee; b) Provide for a unified statewide approach for the reporting and database tracking of SSOs; c) Establish consistent and uniform requirements for SSMP development and implementation; d) Provide statewide consistency in reporting; and e) Facilitate consistent enforcement for violations. 14.The beneficial uses of surface waters that can be impaired by SSOs include, but are not limited to, aquatic life, drinking water supply, body contact and non- contact recreation, and aesthetics. The beneficial uses of ground water that can be impaired include, but are not limited to, drinking water and agricultural supply. Surface and ground waters throughout the state support these uses to varying degrees. 15. The implementation of requirements set forth in this Order will ensure the reasonable protection of past, present, and probable future beneficial uses of water and the prevention of nuisance. The requirements implement the water quality control plans (Basin Plans) for each region and take into account the environmental characteristics of hydrographic units within the state. Additionally, the State Water Board has considered water quality conditions that could reasonably be achieved through the coordinated control of all factors that affect State Water Resources Control Board Order No. 2006-0003-D WO Page 4 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 water quality in the area, costs associated with compliance with these requirements, the need for developing housing within Califomia, and the need io develop and use recycled water. 16.The Federal Clean Water Act largely prohibits any discharge of pollutants from a point source to waters of the United States except as authorized under an NPDES permit. In general, any point source discharge of sewage effluent to waters of the United States must comply with technology-based, secondary treatment standards, at a minimum, and any more stringent requirements necessary to meet applicable water quality standards and other requirements. Hence, the unpermitted discharge of wastewater from a sanitary sewer system to waters of the United States is illegal under the Clean Water Act. In addition, many Basin Plans adopted by the Regional Water Boards contain discharge prohibitions that apply to the discharge of untreated or partially treated wastewater. Finally, the Califomia Water Code generally prohibits the discharge of waste to land prior to the filing of any required report of waste discharge and the subsequent issuance of either WDRs or a waiver of WDRs. 17. California Water Code section 13263 requires a water board to, after any necessary hearing, prescribe requirements as to the nature of any proposed discharge, existing discharge, or material change in an existing discharge. The requirements shall, among other things, take into consideration the need to prevent nuisance. 18. California Water Code section 13050, subdivision (m), defines nuisance as anything which meets all of the fo{lowing requirements: a. Is injurious to health, or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property. b. Affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal. c. Occurs during, or as a result of, the treatment or disposal of wastes. 19. This Order is consistent with State Water Board Resolution No. 68-16 (Statement of Policy with Respect to Maintaining High Quality of Waters in Califomia) in that the Order imposes conditions to prevent impacts to water quality, does not allow the degradation of water quality, will not unreasonably affect beneficial uses of water, and will not result in water quality less than prescribed in State Water Board or Regional Water Board plans and policies. 20. The action to adopt this General Order is exempt from the California Environmental Quality Act (Public Resources Code §21000 et seq.) because it is an action taken by a regulatory agency to assure the protection of the environment and the regulatory process involves procedures for protection of the environment. (Cal. Code Regs., tit. 14, §15308). In addition, the action to adopt State Water Resources Control Board Order No. 2006-0003-DWO Page 5 of 20 Statewide General WDR For Wastewater Collection Agencies 5!2106 this Order is exempt from CEQA pursuant to Cal.Code Regs., title 14, §15301 to the extent that it applies to existing sanitary sewer collection systems that constitute "existing facilities" as that term is used in Section 15301, and §15302, to the extent that it results in the repair or replacement of existing systems involving negligible or no expansion of capacity. 21. The Fact Sheet, which is incorporated by reference in the Order, contains supplemental information that was also considered in establishing these requirements. 22. The State Water Board has notified all affected public agencies and all known interested persons of the intent to prescribe general WDRs that require Enrollees to develop SSMPs and to report all SSOs. 23.The State Water Buard conducted a public hearing on February 8, 2006, to receive oral and written comments on the draft order. The State Water Board received and considered, at its May 2, 2006, meeting, additional public comments on substantial changes made to the proposed general WDRs following the February 8, 2006, public hearing. The State Water Board has considered all comments pertaining to the proposed general WDRs. IT IS HEREBY ORDERED, that pursuant to California Water Code section 13263, the Enrollees, their agents, successors, and assigns, in order to meet the provisions contained in Division 7 of the California Water Code and regulations adopted hereunder, shall comply with the following: A. .DEFINITIONS Sanitary sewer overflow (SSO) -Any overflow, spill, release, discharge or diversion of untreated or partially treated wastewater from a sanitary sewer system. SSOs include: (i) Overflows or releases of untreated or partially treated wastewater that reach waters of the United States; (ii) Overflows or releases of untreated or partially treated wastewater that do not reach waters of the United States; and (iii) Wastewater backups into buildings and on private property that are caused by blockages or flow conditions within the publicly owned portion of a sanitary sewer system. 2. Sanitary sewer system -Any system of pipes, pump stations, sewer lines, or other conveyances, upstream of a wastewater treatment plant headworks used to collect and convey wastewater to the publicly owned treatment facility. Temporary storage and conveyance facilities (such as vaults, temporary piping, construction trenches, wet wells, impoundments, tanks, etc.) are considered to be part of the sanitary sewer system, and discharges into these temporary storage facilities are not considered to be SSOs. State Water Resources Control Board Order No. 2006-0003-DWO Page 6 of 20 Statewide General WDR For Wastewater Collection Agencies 5!2106 For purposes of this Order, sanitary sewer systems include only those Systems owned by public agencies that are comprised of more than one mile of pipes or sewer lines. 3. Enrollee - A federal or state agency, municipality, county, district, and other public entity that owns or operates a sanitary sewer system, as defined in the general WDRs, and that has submitted a complete and approved application for coverage under this Order. 4. SSO Reporting System -Online spill reporting system that is hosted, controlled, and maintained by the State Water Board. The web address for this site is http://ciwgs.waterboards.ca.gov. This online database is maintained on a secure site and is controlled by unique usernames and passwords. 5. Untreated or partially treated wastewater -Any volume of waste discharged from the sanitary sewer system upstream of a wastewater treatment plant headworks. 6. Satellite collection system -The portion, if any, of a sanitary sewer system owned or operated by a different public agency than the agency that owns and operates the wastewater treatment facility to which the sanitary sewer system is ~` tributary. ~.r' 7. Nuisance -California Water Code section 13050, subdivision (m), defines nuisance as anything which meets all of the following requirements: a. Is injurious to health, or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property. b. Affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individuals may be unequal. c. Occurs during, or as a result of, the treatment or disposal of wastes. B. APPLICATION REQUIREMENTS Deadlines for Application -All public agencies that currently own or operate sanitary sewer systems within the State of California must apply for coverage under the general WDRs within six (6) months of the date of adoption of the general WDRs. Additionally, public agencies that acquire or assume responsibility for operating sanitary sewer systems after the date of adoption of this Order must apply for coverage under the general WDRs at least three (3) months prior to operation of those facilities. 2. Applications under the general WDRs - In order to apply for coverage pursuant to the general WDRs, a legally authorized representative for each agency must submit a complete application package. Within sixty (60) days of adoption of the ® general WDRs, State Water Board staff will send specific instructions on how to State Water Resources Control Board Order No. 2006-0003-DWO Page 7 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 apply for coverage under the general WDRs to all known public agencies that own sanitary sewer systems. Agencies that do not receive notice may obtain applications and instructions online on the Water Board's website. 3. Coverage under the general WDRs -Permit coverage will be in effect once a complete application package has been submitted and approved by the State Water Board's Division of Water Quality. C. PROHIBITIONS 1. Any SSO that results in a discharge of untreated or partially treated wastewater to waters of the United States is prohibited. 2. Any SSO that results in a discharge of untreated or partially treated wastewater that creates a nuisance as defined in California Water Code Section 13050(m) is prohibited. D. PROVISIONS 1. The Enrollee must comply with all conditions of this Order. Any noncompliance with this Order constitutes a violation of the California Water Code and is grounds for enforcement action. Q 2. It is the intent of the State Water Board that sanitary sewer systems be regulated in a manner consistent with the general WDRs. Nothing in the general WDRs shall be: (i) Interpreted or applied in a manner inconsistent with the Federal Clean Water Act, or supersede a more specific or more stringent state or federal requirement in an existing permit, regulation, or administrativefudicial order or Consent Decree; (ii) Interpreted or applied to authorize an SSO that is illegal under either the Clean Water Act, an applicable Basin Plan prohibition or water quality standard, or the California Water Code; (iii) Interpreted or applied to prohibit a Regional Water Board from issuing an individual NPDES permit or WDR, superseding this general WDR, for a sanitary sewer system, authorized under the Clean Water Act or California Water Code; or (iv) Interpreted or applied to supersede any more specific or more stringent WDRs or enforcement order issued by a Regional Water Board. 3. The Enrollee shall take all feasible steps to eliminate SSOs. In the event that an SSO does occur, the Enrollee shall take all feasible steps to contain and mitigate the impacts of an SSO. 4. In the event of an SSO, the Enrollee shall take all feasible steps to prevent untreated or partially treated wastewater from discharging from storm drains into State Water Resources Control Board Order No. 2006-0003-DWO Page 8 of 20 Statewide General WDR For Wastewater Collection Agencies 512106 flood control channels or waters of the United States by blocking the storm drainage system and by removing the wastewater from the storm drains. 5. All SSOs must be reported in accordance with Section G of the general WDRs. 6. In any enforcement action, the State and/or Regional Water Boards will consider the appropriate factors under the duly adopted State Water Board Enforcement Policy. And, consistent with the Enforcement Policy, the State and/or Regional Water Boards must consider the Enrollee's efforts to contain, control, and mitigate SSOs when considering the California Water Code Section 13327 factors. In assessing these factors, the State and/or Regional Water Boards will also consider whether: (i) The Enrollee has complied with the requirements of this Order, including requirements for reporting and developing and implementing a SSMP; (ii) The Enrollee can identify the cause or likely cause of the discharge event; (iii) There were no feasible alternatives to the discharge, such as temporary storage or retention of untreated wastewater, reduction of inflow and infiltration, use of adequate backup equipment, collecting and hauling of untreated wastewater to a treatment facility, or an increase in the capacity of the system as necessary to contain the design storm event /'"~ identified in the SSMP. It is inappropriate to consider the lack of feasible fir/ alternatives, if the Entollee does not implement a periodic or continuing process to identify and correct problems. (iv)The discharge was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of the Enrollee; (v) The discharge could have been prevented by the exercise of reasonable control described in a certified SSMP for: • Proper management, operation and maintenance; • Adequate treatment facilities, sanitary sewer system facilities, and/or components with an appropriate design capacity, to reasonably prevent SSOs (e.g., adequately enlarging treatment or collection facilities to accommodate growth, infiltration and inflow (Ill), etc.); Preventive maintenance (including cleaning and fats, oils, and grease (FOG) control); Installation of adequate backup equipment; and • Inflow and infiltration prevention and control to the extent practicable. (vi)The sanitary sewer system design capacity is appropriate to reasonably prevent SSOs. State Water Resources Control Board Order No. 2006-0003-DWO Page 9 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 (vii) The Enrollee took all reasonable steps to stop and mitigate the impact of the discharge as soon as possible. 7. When a sanitary sewer overFlow occurs, the Enrollee shall take all feasible steps and necessary remedial actions to 1) control or limit the volume of untreated or partially treated wastewater discharged, 2) terminate the discharge, and 3) recover as much of the wastewater discharged as possible for proper disposal, including any wash down water. The Enrollee shall implement all remedial actions to the extent they may. be applicable to the discharge and not inconsistent with an emergency response plan, including the following: (i) Interception and rerouting of untreated or partially treated wastewater flows around the wastewater line failure; (ii) Vacuum truck recovery of sanitary sewer overflows and wash down water; (iii) Cleanup of debris at the overflow site; (iv) System modifications to prevent another SSO at the same location; (v) Adequate sampling to determine the nature and impact of the release; and (vi) Adequate public notification to protect the public from exposure to the SSO. 8. The Enrollee shall properly, manage, operate, and maintain all parts of the sanitary sewer system owned or operated by the Enrollee, and shall ensure that the system operators (including employees, contractors, or other agents) are adequately trained and possess adequate knowledge, skills, and abilities. 9. The Enrollee shall allocate adequate resources for the operation, maintenance, and repair of its sanitary sewer system, by establishing a proper rate structure, accounting mechanisms, and auditing procedures to ensure an adequate measure of revenues and expenditures. These procedures must be in compliance with applicable laws and regulations and comply with generally acceptable accounting practices. 10.The Enrollee shall provide adequate capacity to convey base Flows and peak flows, including flows related to wet weather events. Capacity shall meet or exceed the design criteria as defined in the Enrollee's System Evaluation and Capacity Assurance Plan for all parts of the sanitary sewer system owned or operated by the Enrollee. 11.The Enrollee shall develop and implement a written Sewer System Management Plan (SSMP) and make it available to the State and/or Regional Water Board upon request. A copy of this document must be publicly available at the Enrollee's office and/or available on the Internet. This SSMP must be approved by the Enrollee's governing board at a public meeting. State Water Resources Control Board Order No. 2006-0003-DWQ Page 10 of 20 Statewide General WOR For Wastewater Collection Agencies 5!2/06 12. In accordance with the California Business and Professions Code sections 6735, 7835, and 7835.1, all engineering and geologic evaluations and judgments shall be performed by or under the direction of registered professionals competent and proficient in the fields pertinent to the required activities. Specific elements of the SSMP that require professional evaluation and judgments shall be prepared by or under the direction of appropriately qual~ed professionals, and shall bear the professional(s)' signature and stamp. 13.The mandatory elements of the SSMP are specified below. However, if the Enrollee believes that any element of this section is not appropriate or applicable to the Enrollee's sanitary sewer system, the SSMP program does not need to address that element. The Enrollee must justify why that element is not applicable. The SSMP must be approved by the deadlines listed in the SSMP Time Schedule below. Sewer System Management Plan (SSMP) (i) Goal: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent SSOs, as well as mitigate any SSOs that do occur. ~j (ii) Organization: The SSMP must identify: 7/ (a) The name of the responsible or authorized representative as described in Section J of this Order. (b) The names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program. The SSMP must identify lines of authority through an organization chart or similar document with a narrative explanation; and (c) The chain of communication for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services (OES)). (iii) Legal Authority: Each Enrollee must demonstrate, through sanitary sewer system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to: (a) Prevent illicit discharges into its sanitary sewer system (examples may include Ill, stormwater, chemical dumping, unauthorized debris and cut roots, etc.); State Water Resources Control Board Order No. 2006-0003-DWO Page 11 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2/06 (b) Require that sewers and connections be properly designed and constructed; (c) Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency; (d) Limit the discharge of fats, oils, and grease and other debris that may cause blockages, and (e) Enforce any violation of its sewer ordinances. (iv) Operation and Maintenance Program. The SSMP must include those elements listed below that are appropriate and applicable to the Enrollee's system: (a) Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities; (b) Describe routine preventive operation and maintenance activities by staff and contractors, including a system for scheduling regular ~`'~ maintenance and cleaning of the sanitary sewer system with more ~.,J frequent cleaning and maintenance targeted at known problem areas. The Preventative Maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders; (c) Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long- term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed for the capital improvement plan; (d) Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained; and State Water Resources Control Board Order No. 2006-0003-DWO Page 12 of 20 /""1 Statewide General WOR For Wastewater Collection Agencies 5/2/06 ,ys,•~+ (e) Provide equipment and replacement part inventories, including identification of critical replacement parts. (v) Design and Performance Provisions: (a) Design and construction standards and specifications for the installation of new sanitary sewer systems, pump stations and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems; and (b) Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects. (vi) Overflow Emergency Response Plan -Each Enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, this plan must include the following: (a) Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner; (~", (b) A program to ensure an appropriate response to all overflows; ~./ (c) Procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with the MRP. All SSOs shall be reported in accordance with this MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP should identify the officials who will receive immediate notification; (d) Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Emergency Response Plan and are appropriately trained; (e) Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and (f) A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge. State Water Resources Control Board Order No. 2006-0003-DWQ Page 13 of 20 Statewide General WDR For Wastewater Collection Agencies 512106 (vii) FOG Control Program: Each Enrollee shall evaluate its service area to determine whether a FOG control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate: (a) An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG; (b) A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities and/or additional facilities needed to adequately dispose of FOG generated within a sanitary sewer system service area; (c) The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG; (d) Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, Q maintenance requirements, BMP requirements, record keeping and reporting requirements; (e) Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance; (f) An identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and (g) Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above. (viii) System Evaluation and Capacity Assurance Plan: The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriaie design storm or wet weather event. At a minimum, the plan must include: (a) Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs State Water Resources Control Board Order No. 2006-0003-DWQ Page 14 of 20 ~j Statewide General WDR For Wastewater Collection Agencies 5/2/06 ~y° that escape from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events; (b) Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and (c) Capacity Enhancement Measures: The steps needed to establish ashort- and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding. (d) Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c} above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D. 14. ~~ (ix) Monitoring, Measurement, and Program Modifications: The Enrollee shall: (a} Maintain relevant information that can be used to establish and prioritize appropriate SSMP activities; (b) Monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP; (c) Assess the success of the preventative maintenance program; (d) Update program elements, as appropriate, based on monitoring or performance evaluations; and (e) Identify and illustrate SSO trends, including: frequency, location, and volume. (x) SSMP Program Audits - As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit Q shall focus on evaluating the effectiveness of the SSMP and the State Water Resources Control Board Order No. 2006-0003-DWO Page 15 of 20 Statewide Genera! WDR For Wastewater Collection Agencies 5/2!06 Enrollee's compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them. (xi) Communication Program -The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented. The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee's sanitary sewer system. 14. Both the SSMP and the Enrollee's program to implement the SSMP must be certified by the Enrollee to be in compliance with the requirements set forth above and must be presented to the Enrollee's governing board for approval at a public meeting. The Enrollee shall certify that the SSMP, and subparts thereof, are in compliance with the general WDRs within the time frames identffied in the time schedule provided in subsection D.15, below. In order to complete this certification, the Enrollee's authorized representative must complete the certification portion in the Online SSO Database Questionnaire by checking the appropriate milestone box, printing and signinc the automated form, and sending the form to: State Water Resources Control Board Division of Water Quality Attn: SSO Program Manager P.O. Box 100 Sacramento, CA 95812 The SSMP must be updated every five (5) years, and must include any significant program changes. Re-certification by the governing board of the Enrollee is required in accordance with D.14 when significant updates to the SSMP are made. To complete the re-certification process, the Enrollee shall enter the data in the Online SSO Database and mail the form to the State Water Board, as described above. 15.The Enrollee shall comply with these requirements according to the following schedule. This time schedule does not supersede existing requirements or time schedules associated with other permits or regulatory requirements. ~J State Water Resources Control Board Order No. 2006-0003-DWQ Statewide General WDR For Wastewater Collection Agencies Sewer System Management Plan Time Schedule Page 16 of 20 5/2/06 Task and Completion Date Associated Section Population > Population Population Population < 100,000 between 100,000 between 10,000 2,500 and 10,000 and 2,500 Application for Permit Coverage 6 months after WDRs Adoption Section C Reporting Program 6 months after WDRs Adoption Section G SSMP Development g months after 12 months after 15 months after WDRs 18 months after WDRs Plan and Schedule WDRs Adoption2 WDRs Adoption2 2 Ado lion 2 Ado lion Nos ecitrc Section Goals and Organization Structure 12 months after WDRs Adoption2 18 months after WDRs Adoption2 Section D 13 i & ii OverFlow Emergency Response Program Section D 13 vi Legal Authority Section D 13 (iii) _ 24 months after 30 months after 36 months after 39 months after Operation and 2 WDRs Adoption 2 WDRs Adoption AdopRon2 Adoption2 Maintenance Program Section D 13 iv Grease Control Program Section D 13 vii Design and Performance Section D 13 v System Evaluation and Capacity Assurance 36 months after 39 months after 48 months after 51 months after Plan WDRs Adoption WDRs Adoption WDRs Adoption WDRs Adoption Section D 13 viii Final SSMP, incorporating all of the SSMP requirements Section D 13 State Water Resources Control Board Order No. 2006-0003-DWO Page 17 of 20 /~,~~+~,i Statewide General WDR For Wastewater Collection Agencies 512106 "'~ 1. In the event that by July 1, 2006 the Executive Director is able to execute a memorandum of agreement (MOA) with the California Water Environment Association (CWEA) or discharger representatives outlining a strategy and time schedule for CWEA or another entity to provide statewide training on the adopted monitoring program, SSO database electronic reporting, and SSMP development, consistent with this Order, then the schedule of Reporting Program Section G shall be replaced with the following schedule: Reporting Program Section G Regional Boards 4, 8, 8 months after WDRs Adoption and 9 Regional Boards 1, 2, 12 months after WDRs Adoption and 3 Regional Boards 5, 6, 16 months after WDRs Adoption and 7 If this MOU is not executed by July 1, 2006, the reporting program time schedule will remain six (6) months for all regions and agency size categories. 2. In the event that the Executive Director executes the MOA identified in note 1 by July 1, 2006, then the deadline for this task shall be extended by six (6) months. The time schedule identified in the MOA must be consistent with the extended time schedule provided by this note. If the MOA is not executed by July 1, 2006, the six (6) month time extension will not be granted. E. WDRs and SSMP AVAILABILITY 1. A copy of the general WDRs and the certified SSMP shall be maintained at appropriate locations (such as the Enrollee's offices, facilities, and/or Internet homepage) and shall be available to sanitary sewer system operating and maintenance personnel at all times. F. ENTRY AND INSPECTION 1. The Enrollee shall allow the State or Regional Water Boards or their authorized representative, upon presentation of credentials and other documents as may be required by law, to: a. Enter upon the Enrollee's premises where a regulated facility or activity is located or conducted, or where records are kept under the conditions of this Order; b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this Order; State Water Resources Control Board Order No. 2006-0003-DWQ Page 18 of 20 Statewide General WDR For Wastewater Collection Agencies 512106 c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this Order; and d. Sample or monitor at reasonable times, for the purposes of assuring compliance with this Order or as otherwise authorized by the California Water Code, any substances or parameters at any location. G. GENERAL MONITORING AND REPORTING REQUIREMENTS The Enrollee shall furnish to the State or Regional Water Board, within a reasonable time, any information that the State or Regional Water Board may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this Order. The Errollee shall also furnish to the Executive Director of the State Water Board or Executive Officer of the applicable Regional Water Board, upon request, copies of records required to be kept by this Order. 2. The Enrollee shall comply with the attached Monitoring and Reporting Program No. 2006-0003 and future revisions thereto, as specified by the Executive Director. Monitoring results shall be reported at the intervals specified in Monitoring and Reporting Program No. 2006-0003. Unless superseded by a specific enforcement Order for a specific Enrollee, these reporting requirements are intended to replace other mandatory routine written reports associated with SSOs. 3. All Enrollees must obtain SSO Database accounts and receive a "Username" and "Password" by registering through the California Integrated Water Quality System (CIWQS). These accounts will allow controlled and secure entry into the SSO Database. Additionally, within 30days of receiving an account and prior to recording spills into the SSO Database, all Enrollees must complete the "Collection System Questionnaire", which collects pertinent information regarding a Enrollee's collection system. The "Collection System Questionnaire" must be updated at least every 12 months. 4. Pursuant to Health and Safety Code section 5411.5, any person who, without regard to intent or negligence, causes or permits any untreated wastewater or other waste to be discharged in or on any waters of the State, or discharged in or deposited where it is, or probably will be, discharged in or on any surface waters of the State, as soon as that person has knowledge of the discharge, shall immediately notify the local health officer of the discharge. Discharges of untreated or partially treated wastewater to storm drains and drainage channels, whether man-made or natural or concrete-lined, shall be reported as required above. Any SSO greater than 1,000 gallons discharged in or on any waters of the State, or discharged in or deposited where it is, or probably will be, discharged in or on any surface waters of the State shall also be reported to the Office of Emergency /~"~ Services pursuant to California Water Code section 13271. State Water Resources Control Board Order No. 2006-0003-DWQ Page 19 of 20 Q Statewide General WDR For Wastewater Collection Agencies 5/2/06 H. CHANGE 1N OWNERSHIP This Order is not transferable to any person or party, except after notice to the Executive Director. The Enrollee shall submit this notice in writing at least 30 days in advance of any proposed transfer. The notice must include a written agreement between the existing and new Enrollee containing a specific date for the transfer of this Order's responsibility and coverage between the existing Enrollee and the new Enrollee. This agreement shall include an acknowledgement that the existing Enrollee is liable for violations up to the transfer date and that the new Enrollee is liable from the transfer date forward. INCOMPLETE REPORTS 1. If an Enrollee becomes aware that it failed to submit any relevant facts in any report required under this Order, the Enrollee shall promptly submit such facts or information by formally amending the report in the Online SSO Database. J. REPORT DECLARATION 1. All applications, reports, or information shall be signed and certified as follows: (i) All reports required by this Order and other information required by the ~"; State or Regional Water Board shall be signed and certified by a person ~r•~ designated, for a municipality, state, federal or other public agency, as either a principal executive officer or ranking elected official, or by a duly authorized representative of that person, as described in paragraph (ii) of this provision. (For purposes of electronic reporting, an electronic signature and accompanying certification, which is in compliance with the Online SSO database procedures, meet this certification requirement.) (ii) An individual is a duly authorized representative only if: (a) The authorization is made in writing by a person described in paragraph (i) of this provision; and (b) The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity. K. CIVIL MONETARY REMEDIES FOR DISCHARGE VIOLATIONS 1. The California Water Code provides various enforcement options, including civil monetary remedies, for violations of this Order. 2. The California Water Code also provides that any person failing or refusing to furnish technical or monitoring program reports, as required under this Order, or State Water Resources Contra! Board Order No. 2006-0003-DWQ Page 20 of 20 Statewide General WDR For Wastewater Collection Agencies 5/2!06 falsifying any information provided in the technical or monitoring reports is subject to civil monetary penalties. L. SEVERABILITY 1. The provisions of this Order are severable, and if any provision of this Order, or the application of any provision of this Order to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this Order, shall not be affected thereby. 2. This order does not convey any property rights of any sort or any exclusive privileges. The requirements prescribed herein do not authorize the commission of any act causing injury to persons or property, nor protect the Enrollee from liability under federal, state or local laws, nor create a vested right for the Enrollee to continue the waste discharge. CERTIFICATION The undersigned Clerk to the State Water Board does hereby certify that the foregoing is a full, true, and correct copy of general WDRs duly and regularly adopted at a meeting of the State Water Resources Control Board held on May 2, 2006. AYE: Tam M. Doduc Gerald D. Secundy NO: Arthur G. Baggett ABSENT: None ABSTAIN: None _v_ ___ _____ Song Her Clerk to the Board ATTACHMENT „Z~~ SSMP DEVELOPMENT PLAN AND SCHEDULE Main Task/Sub-Task Comments Status/Due Date Date Completed Responsible Party Application of Submit Notice of Intent Complete- 10/25/06 Deputy Director coverage (NOI) to the State 11/2/06 /Maintenance Services indetifying the agency's authorized representative including re uired ermit fee. SSO Electronic Agency must report all Continuous Sewer Maintenance reporting program SSOs to the statewide Supervisor and Lead SSO database via the Sewer Maintenance intemet. Worker 1. SSMP Development Initial plan on how the Complete- 11/02/07 Deputy Director Plan and Schedule agency intends to 11/2/07 /Maintenance Services develop and implement and Administrative the SSMP. Analyst II 2. SSMP Goals Stated goals for the Complete- 11/2/07 Deputy Director SSMP. 11/2/07 /Maintenance Services and Administrative Anal t II 3.Organizational Names and Staff Complete- 11/2/07 Administrative Structure positions responsible for 11/2/07 Analyst II/ Deputy developing and Director /Maintenance implementing the SSMP Services including the chain of communications for re ortin SSOs. 4. Legal Authority Agency's legal authority In TBD Legal CounseU to operate and maintain progress- Administrative its sewage collection 11/2/08 Analyst II/ Deputy system. Director /Maintenance Services 5. Operation and Maintain up-to-date In TBD Deputy Director Maintenance maps of its wastewater progress- /Maintenance Services collection system, etc. 11/2/08 and Sewer Maintenance Su ervisor Mapping Up to date mapping of In TBD Deputy Director the sewage collection progress- /Maintenance Services system facilities 11/2/08 and Sewer including appropriate Maintenance storm water systems. Supervisor Preventive Written description of In TBD Deputy Director Maintenance Program the preventative progress- /Maintenance Services maintenance activities 11/2/08 and Sewer the agency employs. Maintenance Su ervisor Rehabilitation and Short and long term plan In TBD Deputy Director Replacement Program for the rehabilitation or progress- /Maintenance Services replacement due to 11/2/08 and Sewer system deficiencies Maintenance including funding (CIP). Supervisor Inspection Program Program for the regulaz In TBD Deputy Director visual and CCTC progress- /Maintenance Services inspection of the system. 11/2/08 and Sewer Maintenance Su ervisor Staff Training Staff O&M training and In TBD Deputy Director assurance that progress- /Maintenance Services contractors aze 11/2/08 and Sewer adequately trained. Maintenance Su ervisor Equipment and Pazts Equipment and pazts In TBD Deputy Director Inventory inventory including the progress- /Maintenance Services identification of critical 11/2/08 and Sewer replacement parts. Maintenance Su ervisor 6.Overflow Written procedures In TBD Deputy Director Emergency Response defining how the agency progress- /Maintenance Services Plan responds to SSOs. 11/2/08 and Sewer Maintenance Su ervisor 7. Fats, Oils & Grease In TBD Administrative Control Program progress- Analyst IU Deputy 11/2/08 Director/Maintenance Services FOG Ordinance Legal authority to In TBD Administrative prevent the discharge of progress- Analyst II/ Deputy FOG into the system. 11/2/08 Director /Maintenance Services 2 FOG Program Program to reduce or In TBD Administrative eliminate FOG related progress- Analyst II/ Deputy SSOs. 11/2/08 Director /Maintenance Services 8. Design and Design and construction 5/2/09 TBD Deputy Director Performance standards and /Maintenance Services specifications for the and Sewer installation of new Maintenance sanit sewers terns. Su ervisor Design standazds Design standazds for 5/2/09 TBD Deputy Director new and rehabilitated /Maintenance Services systems and Sewer Maintenance Su ervisor Inspection and testing Inspection and testing 5/2/09 TBD Deputy Director standazds standazds for new and /Maintenance Services rehabilitated systems. and Sewer Maintenance Su ervisor 9. System Evaluation Evaluate those portions 5/2/09 TBD Deputy Director and Capacity of the system that aze /Maintenance Services Assurance Plan experiencing capacity and Sewer related overflows. Maintenance Establish steps to Supervisor eliminate capacity related overflows including I&I program, and short and long term CIP for ca aci issues. 10. Monitoring, Maintain records, 5/2/09 TBD Deputy Director Measurement, and monitor and assess the /Maintenance Program effectiveness of the Services, Sewer Modifications program and update as Maintenance necessary. Supervisor and Administrative Anal st II 11. SSMP Audits Conduct periodic audits, 5/2/09 Continuous Deputy Director at least every two years, /Maintenance on the SSMP Services, Sewer Maintenance Supervisor and Administrative Analyst II 12. SSMP Public communication 5/2/09 TBD Deputy Director Communications /Maintenance Services Program and Administrative Analyst II Communications with Develop a public 5/2/09 TBD Deputy Director the public communication program /Maintenance Services with customers'and and Administrative potential customers that Analyst II includes the opportunity to provide input during the development, implementation, and performance of its SSMP. Communications with If there is a satellite 5/2/09 TBD Deputy Director satellite agency agency connected to the /Maintenance Services collection system, and Administrative develop a plan of Analyst II re lar communication 13. Final SSMP Final the SSMP 5/2/09 TBD Deputy Director Implementation document after all /Maintenance Services elements have been and Administrative developed and Analyst II im lemented. 4 Business Plan for the Integrated Waste Management Division Submitted to: City of San Bernardino Public Services Department May Zoos Consulting Group. Inc. ~~ Pry o;~rces Respec~ RFspons~b~l~h City of San Bernardino IWM Cover TABLE OF CONTENTS .......................................................................................i Division Business 1.0 BACKGROUND .............................................................................1 flan 2.0 APPROACH .................................................................................. 2 I 3.0 LIMITATATIONS ........................................................................... 2 4.0 FINDINGS AND RECOMMENDATIONS ....................................... 3 4.1 Findings ................................................................................. 3 4.2 Recommendations ................................................................. 4 5.0 FINANCIAL PLAN ....................................................................... 14 5.1 Budget Projections ............................................................... 14 5.2 Example FY 2008/09 Rates .................................................. 17 5.3 Potential Revenue Enhancements and Cost Reductions ........................................................................... 18 5.4 Financial Model Assumptions ............................................... 19 6.0 EXAMPLE IMPLEMENTATION STEPS ....................................... 21 LIST OF TABLES ~ Table 1 Projected Capital Needs For FY 08/09 - FY 12/13 ................ 14 Table 2 Cost for Additional Staff For FY 08/09 .................................... 15 Table 3 Cost of Implementing Recommendations ............................... 15 Table 4 Projected Costs, Revenue and Rate Increases For FY 08/09 - FY 12/13 .............................................................. 16 Table 5 Example FY 2008/09 Monthly Rates ...................................... 17 Table 6 Cost Decreases and Revenue Increases From ~ Implementing Recommendations ........................................... 18 I Table 7 Line Of Business (LOB) Allocation Factors ............................ 20 ~ '123 Page i City of San Bernardino I W NI This page intentionally left blank. Business Plan fZ3 I o Page ii City of San Bernardino 1.0 Background IWM ~IVISIOn The City of San Bernardino Integrated Waste Management Division (Division) provides collection services to approximately 43,500 residential customers and Business 3,500 commercial customers within the City. Residential solid waste, recycling and yard waste collection services are provided weekly on a 4-day per week 10- flan hour per day schedule. Residential collection operates on a three-pass system, where separate route drivers collect garbage, recyclables and green waste materials (Separate Commodity Routes). Commercial collection services are provided six days per week to provide service to commercial accounts. The City also provides a small amount of Commercial recycling and green waste collection services. The Division had an annual budget of $24,600,000 for FY 07/08. The annual expenditures are split between residential and commercial services with approximately 52 percent of the costs going for residential services and 48 percent of the cost going to the commercial services. The City of San Bernardino has approximately 100 employees that provide residential, commercial, and roll-off collection services. Over the past two years, the Division has begun the process of addressing current operational challenges, including: • Purchased 20 new vehicles in FY 2006-07, • Purchasing 17 additional vehicles in FY 2007-08; • Tracking and improving the following items: o Department overtime; o Sick Time hours used by employees; o Workers compensation claims; and o Liability claims. • Constructed a liquefied natural gas (LNG) and compressed natural gas (CNG) fueling station; • Focusing resources on route efficiencies, accuracy of account information, and establishing improved enforcement of the Division's policies and procedures related to waste collection; and • Revising the City's Refuse and Solid Waste Division Code. At the same time, the Division is facing several longer term issues: • Arranging for disposal of approximately 200,000 tons of solid waste currently disposed at the Colton Landfill after December 31, 2012, when the San Bernardino County Waste Delivery Agreement (WDA) expires. • Providing for all temporary bin services after the expiration of the agreements with the two franchise waste haulers that compete with the ~ 2 City for temporary bin services; J7 Page 1 IWM Business Plan IZ3 City of San Bernardino • Addressing the need for customer rate increases or restructuring, given that customer rates have not been increased in four years; • Addressing recommendations contained in the March of 2007, aCity-wide Organizational Review: o Preparing detailed business plan and rate study; o Identifying enterprise costs and potential cost savings of contracting out; and o Preparing bid specifications for residential and commercial services, and conducting a managed competition process. To address these current and future challenges, the City retained R3 Consulting Inc. (R3) to prepare a Business Plan that addresses five major areas: i) rate structures, 2) equipment needs, 3) staffing levels, 4) long range planning, and 5) the impact of mariaged competition. 2.0 Approach The Business Plan is intended to present a 5-Year work plan to guide the Division in its efforts to deliver high quality services in acost-effective manner and to successfully compete with comparable utilities, both publicly and privately operated, in terms of efficiency, productivity, customer service and customer rates, and net financial impact on the City. Our study involved a review of the Division's collection operations and support functions. As part of that review, we met with management, reviewed operational information including productivity and vehicle availability data, observed collection activities in the field, conducted residential route time and motion analyses, audited commercial accounts, and performed an analysis of current and projected residential solid waste collection productivity. While our review covered a range of issues, it was not intended to be a detailed review of any of those specific issues, and we relied in part on management's representations of the Division's operations and results in developing our findings and recommendations. 3.0 Limitations In determining if further action on our recommendations is warranted, the City should consider the following limitations of our review: • A comprehensive management review of the City's solid waste operations was not conducted; • Field observations were limited to three days; Page 2 City of San Bernardino • A detailed financial analysis and/or cost-of-service study of the City's solid IWM waste operations was not performed; • R3 was not able to independently verify the customer account data, off Business route travel time, and container set-out data provided by the City; Plan • The projections used in this analysis are based on limited operational and financial data received from the City. Because events and circumstances may not occur as expected, there will usually be differences between projected and actual results, and those differences may be material. 4.0 Findings and Recommendations Our review of the Division's operations identified a number of management and operational issues that impact the Division's ability to provide consistent high quality solid waste collection services to the City's residents and businesses. There is a combination of system and operational changes that will need to be addressed by the Division to maintain ongoing operations. The major findings and recommendations to address these issues are listed below. 4.1 Findings The findings fall in three (3) major areas: 1. The Division operates as a "garbage" collection department with the diversion of material through collection of recyclables and green waste as a secondary function. a. Total residential, commercial, and C&D recycling diversion is 6.6% of collected material. b. Total residential, commercial, and C&D green waste diversion is 12.0% of collected material. c. Contamination of recyclables is between 40 - 50% of collected material. d. The Division has the potential to reduce annual cost through reductions in equipment, staffing adjustments, and technology improvements. e. The Division can realize additional revenue through expanded recycling programs, decreased recycling contamination, and increased recovery of materials now lost in landfill loads. 2. The Division does not have proper management systems in place to accurately identify service levels and bill customers, timely implement service changes, and proactively manage its operations. a. The Division can not provide an accurate accounting of current customers and service levels. ~ 2 Page 3 City of San Bernardino ' b. The Division s customer service and billing system is not tied to I W M daily operations, service and billing changes are done on a "paper" basis with limited ability to confirm if changes were made, Business service inquiries are not tracked and tied back to route operations. Plan c. Without an inventory of bins, carts and containers the Division cannot manage its equipment properly; and the billing system cannot accurately bill for actual service. d. Routes are unbalanced, with the number of stops/route/day ranging from 800 to 1,400, and no accurate tracking of accounts and service levels. e. Approximately 30% of residential and commercial vehicles deliver loads that are over 11 tons and potentially over the legal street limit. f. Onboard truck scale systems and onboard vehicle tracking systems (GPS) are not used to monitor daily operations. 3. The Division is significantly underfunded, in terms of capital replacement, operating reserves, and operating revenue for residential cart services. a. The Division has no capital or operating reserves. b. The Division needs capital expenditures of approximately $21 million over the next five years to replace old equipment and bring the Division up to service levels seen by other municipal or privately run solid waste operations. c. Residential cart services is running a deficit of approximately $3.4 million/year. d. It is unclear if temporary services is covering its costs due to inaccurate revenue and operations tracking. e. There is no established procedure to collect delinquent account payment, and budgeted revenues do not reflect delinquency experience. The Division does not use property tax liens for delinquent payment collection. 4.2 Recommendations There are recommendations that the City of San Bernardino should consider that will result in improving the operational and financial environment of the Division. The recommendations are broken down by the following areas: • Expenditure and Revenue Accounting; • Customer Service; • General Operations; ~~ Residential Services; Page 4 City of San Bernardino ~' • Commercial Services; IWM • Temporary Services; Business • FY 2008/09 Budgets and Rates; and Plan • Privatization/Managed Competition. Expenditure and Revenue Accounting The Division should consider the following steps to improve the expenditures and revenue accounting: 1. Establish all budgets on a Line-of-Business basis (LOB) - 1) residential, 2) commercial, 3) temporary services, 4) street sweeping. 5) City Services. 2. Account for all revenue and expenses on a LOB basis. 3. Account for lease payments, capital purchases and capital reserve amounts on separate line items by LOB. 4. Record tip fees by function (disposal, green waste, recycling, C&D). 5. Establish a capital acquisition reserve account of 10% for planned future needs. O 6. Establish an operating reserve account of 10% for unanticipated operating changes. 7. Adopt rate structures to generate revenue and cover expenses for each LOB. 8. Audit 100% of residential, commercial, and on-call accounts to verify/identify service levels. 9. Accept over the phone or on-line credit /debit card payments, and automatic payments. 10. Require advance payment for temporary drop boxes via the CSRs (no payment to drivers). 11. Establish a debt collection procedure, including tax liens -for delinquent accounts. Customer Service The Division should consider the following steps to improve the overall accuracy and efficiency of the Customer Information Service system: 1. Purchase an integrated Customer Information System (software and hardware) for the Residential, Commercial, and Temporary services that would handle the following: ement; Account mana a g . ~~ Page 5 City of San Bernardino b. Billing; I W M c. Routing; Bu$Ine$$ d. Dispatching; and Plan e. Reporting. A sam ple list of companies that offer "off-the-shelf" solid waste software systems include RouteWare, Soft-Pak, Trux, Encore, Waste Works and Desert Micro. 2. Establish separate Customer Service Representatives (CSR) teams to handle residential customers separately from Commercial and Temporary Customers. 3. Hire one (1) additional CSR to reduce the number of customers to CRSs to a ratio of 6,000:1 4. Hire two (2) Commercial Account Supervisor that will be responsible for all commercial accounts. 5. Establish a procedure to formally track all calls and service requests. 6. Hire Dispatchers (a.m. and p.m.) that receives and coordinates all Roll-off and Commercial service request orders (SROs). 7. Implement a "ride along" program for CRS to observe on-route operations. 8. Introduce real-time GIS/GPS vehicle monitoring, interfaced with radio frequency identification in all new bins, containers, and carts. General Ooerations 1. Establish Best Management target productivity metrics: a. Residential 700 - 800 accounts per day (23 - 27 seconds per stop); b. Commercial 80 - 100 lifts per day; c. Temporary bin services 17 - 20 pulls per day; d. Temporary roll-off services 6 - 10 pulls per day; e. Bin or roll-off drop/pull within one (1) business day; f. 30 seconds wait time on customer calls; g. Call by 3:00 pm for the same day correction of missed collections; h. Closing work orders within two days (container repair or replacement, billing error, property damage); and i. A maximum 2% delinquent accounts; ~~ Page 6 City of San Bernardino ~' 2. Establish diversion standards I W IVI a. Residential recyclables diversion of 30% of total residential waste Business stream; Plan b. Residential green waste diversion of 40% of total residential waste stream; c. Commercial recyclables diversion of 30% of total commercial waste stream; and d. C&D diversion of 50% of the C&D waste stream (temporary services). 3. Supervisors and drivers should review and monitor all current routes to determine maximum load points and eliminate vehicle overweight's. 4. Current accurate sequenced route sheets and maps are needed, with all new stops verified. 5. All trucks that currently have "on-board scales" should be calibrated and operational. 6. All drivers should be trained in the operation of the "on-board-scales" 7. ~} Establish and enforce a formal overweight policy.. i h ' 8. t s should be reviewed w All driver paper work, dump tickets, and SRO the drivers at the end of the day by the assigned supervisor or dispatcher. 9. Reconcile all driver tickets with tip fee tickets on a daily basis. 10. Unaccounted or lost tickets should be "recovered" the following day. 11. Overvveight loads should be documented daily by the supervisor and driver to determine the cause and method of prevention. 12. Implement on-board scale house readers. Residential Services The residential operations will benefit immediately from the better. balancing routes , emphasizing recycling and green waste services, and the use of a new software system. The Division should take the following actions: 1. Purchase and install GPS software and tracking devises for all residential collection vehicles. This should be directly tied to an integrated Customer Information System. 2. Audit aH residential accounts to verify account information, and reconciled to accurate route sheets. 3. Re-balanced residential routes based on 8 hour work day, 5 days of collection and with established productivity requirements, and evenly ~~ Page 7 City of San Bernardino IWM Business Plan balanced between garbage, recycling and green waste collection (650 - 800 accounts/route). 4. Provide route books and daily route logs to drivers to verify account data and any requested changes. 5. Reassign "Extra" commercial drivers to residential recycling and green waste routes. 6. Route residential routes to the closest disposal facility. 7. Reassign residential supervisors to be responsible for geographic areas rather than lines of business. 8. Drivers should be held accountable for overweight loads, missed collection, and driver caused damages. ~~ 9. Focus on .reducing recyclables and green waste contamination through on-route "cart" checks, increased public education efforts, "tagging" contaminated carts, and pulling recycling and green waste carts from habitual offenders. a. The Division should consider conducting a recycling characterization study to determine contamination levels and evaluate opportunities for improvement. The characterization should include landfill loads as well as recycling loads, to determine extent of lost recyclable and green materials. b. The Division should consider renegotiating the current residential recycling processing agreement as contamination is reduced. 10. Increase outreach and education for the recycling and green waste programs, using social marketing techniques. 11. Provide continual training on collection techniques to reduce unintentional damage to carts. 12. Provide continual training on established procedures for issuing non- collection notices, Service Request Orders ("SRO"), completing their daily logs. 13. Reduce vehicle spare ratios to 15%. Commercial Services 1. Purchase and install GPS software and tracking devises for all commercial collection vehicles. 2. Enter all current customer information into new software system. IZ3 3. Audit all commercial routes to verify account information, and reconciled with the customer account system. Page 8 City of San Bernardino 4. Include a complete bin inventory assessment as part of the route audit, with procedures established to assure ongoing accuracy. 5. Conduct commercial waste audits for all commercial accounts, identifying recycling and organics rich accounts. Priority should be given to the 20% largest commercial accounts in the first year (up to 500 total). 6. Establish "select' commercial recycling and organics collection routes to accommodate high concentrations of recyclable and organics material. 7. Focus on reducing recyclables and green waste contamination through on-route "bin" checks, increased public education efforts, "tagging" contaminated bins, and pulling recycling bins from habitual offenders. 8. Coordinate drivers, supervisors, and transfer station personnel to work together to assure that select routes maintain high levels of diversion. 9. Rebalance commercial routes with specific productivity standards established, i. e., each route should be managed as a "profit center". (80 -120/lifts/route). 10. Minimize the number of two-man commercial routes and reassign the "extra" drivers to residential collection (est. 5 - 6 drivers). 11. Drivers should not collect overloaded bins, or from locations that require ~+ the driver to leave the truck to clear a path to the bin or place items in the bin prior to collection. 12. All bin enclosures should be inspected to ensure access and safety. 13. Develop new bin enclosure standards to assure adequate collection space for recycling, organics, and refuse; and to assure that new and remodeled commercial developments provide adequate collection space. 14. Target "clean" recycling loads, aggressively target contaminated recyclables for non collection, and conduct waste audits to increase commercial recycling. 15. Identify opportunities and arrange for commercial food composting. 16. Establish and enforce additional charges for rejected recycling loads. 17. Direct drivers not to collect contaminated commercial recycling bins. 18. Hold drivers accountable for overweight loads, missed collection, and driver caused damages. 19. Retrain drivers to follow established procedures on issuing non-collection notices, SROs, completing their daily logs. 20. Reduce vehicle spare ratios should 10%. IWM Business Plan 23 Page 9 City of San Bernardino IWM Business Plan 23 Page 10 Temporary Services The temporary account operations will benefit immediately from the use of the new account supervisor, software system, and dispatcher. The Division should take the following actions: 1. Purchase and install GPS software and tracking devises for all temporary collection vehicles (both roll-off and front loaders). 2. Require all customers requesting temporary services to the CSR's to request service. 3. Restrict Temporary Services to construction and demolition materials, and clean-ups. Temporary services should not be provided for regular scheduled collection of garbage. 4. Base Temporary Services on a one (1) week service period. One (1) additional week "bin" rental can be requested at a set fee. All temporary drops must be pulled weekly, unless the customer requests a one time one (1) week extra bin rental. 5. Track all activity by drivers by SROs and account number on a daily driver activity log. 6. Enter all temporary services into the new software system. 7. Audit all permanent accounts and accounts serviced on a short term (over seven days) and on-call basis by the Commercial Account Supervisor and Roll-off Supervisor to verify customer information, bins onsite, and identify diversion opportunities. Permanent scheduled accounts should be allocated on a regular route basis, so that temporary services do not conflict with permanent collections. 8. Establish a procedure for monitoring compactor loads with high concentrations of recycling and organics material, including a transfer station floor sort procedure and accounting. 9. Work with local recycling facilities to receive additional material that current drivers or supervisors think are "contaminated" and must go to the landfill. 10. Require the Roll-off supervisor and/or Commercial Account Supervisor to review any loads dispatched as "recycling" loads that the driver feels are contaminated before the material is hauled to the landfill. 11. Reduce vehicle spare ratios to 10%. ~J 0 City of San Bernardino FY 2008/09 Budgets and Customer Rates ~ W M 1. The FY 2008/09 budget should incorporate the cost to purchase and BUSIne$S install an Integrated Customer Information and Billing System (ICSBS), including: Plan a. The cost to complete the residential and commercial customer account audits, including identification of select recycling and organics accounts. b. Software for account management, billing routing; dispatching, and reporting. c. Collection vehicle on-board GPS route and account tracking. 2. The FY 2008/09 budget should incorporate capital replacement for: c. Residential containers, in full 3-color imprinted with "recycling", "organics" and "refuse" identification and descriptions. d. Residential collection vehicles. e. Commercial containers. f. Commercial collection vehicles. g. Temporary collection vehicles. h. Street sweepers. 3. The FY 2008/09 budget should incorporate a 5% capital reserve and increase to 10% by FY 2013/14. 4. The FY 2008/09 budget should incorporate a 5% operating reserve and increase to 10% by FY 2013/14. 5. The 2008/09 budget should incorporate the cost to begin a feasibility study for Corporation Yard/MRF(fransfer Station. 6. The 2008/09 budget should incorporate the cost to implement aggressive public outreach programs and enforcement. 7. The 2008/09 budget should incorporate the cost to conduct a detailed cost of service study to establish accurate rates on LOB starting in FY 2009/10. 8. Customers Rates should be revised to: a. Incorporate items 1 - 7 above. b. Discontinue bin/box rental beyond 1 week. c. Adopt "flat" tonnage limits of 2 tons for temporary bins. d. Adopt "free" recycling for residential and commercial ~~ ~,j customers. Page 11 City of San Bernardino " " e. Reassign five extra commercial drivers to residential I W M services. Business f. Hire two (2) outside sales representatives (commercial and temporary services). Plan g, Discount commercial green waste by 50% from standard garbage bin rates. h. Charge full garbage rates for contaminated recycling or green waste loads. i. Implement separate street sweeping charges on residential and commercial customers. j. Increase rates for residential, commercial, and temporary services on an "across the board" basis for Y 2006/09. 9. For FY 2009/10 and beyond: a. Adopt "pay-as-you-throw" rates for residential and commercial customers to provide incentives for recycling. b. Transition to full LOB rates. Privatization/Manaaed Competition ' R3 does not believe it is in the City s best interest to consider privatization of the Division functions at this time for the following reasons: 1. It is not possible to accurately determine costs, revenue, number of accounts, billing errors by LOB and any private hauling company would want an accurate accounting to customer levels to determine a reasonable "value" of the contract. 2. The City would need to receive approximately $4.7 - $6.0 Million in annual franchise fee payments to account for lost revenue to the General Fund, Water, and Fleet Services, and to provide for Street Sweeping Services: a. Currently the City provides approximately $400,000 in '9ree" City Services that is not accounted for or tracked in the Division budget. b. Currently, approximately $2.7 million is transferred from Division to the City General Fund. c. Currently the direct cost of providing Street Sweeping services is approximately $1.6 million/year (including capital and operating reserves). ~~ d. Currently the Division pays approximately $90,000 to the Water Department for billing services. The cost for Water Page 12 City of San Bernardino ® billing approximately 39,500 solid waste accounts that I W M receive City water services would not be eliminated. Business e. Currently the Division pays approximately $1.8 million to Fleet Services for vehicle maintenance (excludes fuel). Plan Some, but not all of this cost would be eliminated. 3. The City's rolling stock has little or no value: a. Of the City's fleet of 98 vehicles, 19 are less than 2 years old; most are over 5 years old, are not CARB compliant and have minimal or no market value. b. Residential carts have no market value due to age and condition and will need to be replaced. c. The City's commercial bins have low market value due to age and condition, and bins that have not been replaced or refurbished will need to be replaced or refurbished. d. The City's roll-off containers have little or no market value due to age and condition and will need to be replaced'. 4. A private hauler would likely have to increase the City's current customer rates: a. Similar to the City, a private hauler will need to capitalize containers and vehicles at an estimated cost of $25 million. b. Similar to the City, a private hauler will need to conduct a billing audit of all accounts and implement a new Customer Information System. c. A private hauler would likely incorporate up-front cash payments to the City into its customer rates. d. A private hauler would need to make annual franchise fee payments to the City as discussed in No. 3 above. e. A private hauler would need to operate on a 10+% operating ratio to meet corporate profit requirements. ® 'The City has begun a program to refurbish existing commercial bins and is targeting ~~ approximately 100 per month to be refurbished. Page 13 City of San Bernardino IWM Business Plan 5.0 Financial Plan 5.1 Budget Projections R3 developed financial model fora 5-Year Financial Plan on a Line of Business basis as follows: 1. Residential Cart Services. 2. Commercial Bin and Roll-off Services (regular accounts serviced on a set schedule). 3. Temporary Bin and Temporary Roll-Off Services. 4. Street Sweeping Services. The model incorporates the City's FY 2007/08 budget, the Division's projected capital and operating needs, the operational recommendations discussed above, operating and financial practices used by other public agencies, and discussions with City staff. Changes to the capital requirements and new staff requirements for FY 08/09 - FY 12/13 are listed in Tables 1 and 2 below. Table 3 shows the additional one time costs for implementing the recommendations in FY 2008/09. Table 1 Projected Capital Needs For FY 08/09 - FY 12/13 Commercial Vehicle Replacement $3,847,000 Residential Vehicle Replacement $8,781,197 Street Sweeper Vehicle Replacement $789,000 Residential Carts $8,987,090 Commercial & Roll-off Containers $2,10,000 Integrated Customer Service/Billing/Route Management System $1,075,00 TOTAL CAPITAL NEEDS $20,415,364 \_J Page 14 IWM Business Plan Page 15 City of San Bernardino City of San Bernardino IWM Business Plan Revenue Adwatmem Percanteas Residential Commercial•Regular Commerdal-Temporary CommerciaFRegular Revenue & Transfers I n Commercia4Tempaay Revenue & Transfers In Revenue & Transfers In E>menses & Translers~0ut Net klpome/(LpssJ_ _ _ al All IJnss of Service Beginning Fund Balance Revenue&Transfers In Emenses & Transfers Out IZ3 Page 16 Table 3 Cost of Implementing Recommendations FY (18/09 Ongoing /One Cost Tlme Cost of Service Study $100,000 One time MRFlTransfer Station Feasibility $150,000 $500,000 over next 4 years Capital Reserve-Initially set at 5% $1,125,214 Increase to 10% over 5-year period Operating Reserve-Initially set at 5% $1,164,662 Increase to 10% over 5-year period Table 4 below shows the projected impact of adopting the above recommendations, including the projected rate increases. Table 4 Projected Costs, Revenue and Rate Increases For FY 08/09 - FY 12/1; u I:.J CumulAive Bitlgetetl Prd acted Net Inmme 07-OB OBa9 09-10 10-71 11-12 12-13 Loss 10,398,233 I 12,577,594 I 12,954,922 I 13,343,570 I 13,743,877 14,156,194 __ _. - ~ _ 4,202,667 5,082,606 5.235,084 5,392,137 5,553,901 5.720,518 4,946 I 1,673,5191 1,723,725 1 1,775,436 1 1,82$699 1,883,560 24,749,700 I 31,611,150 I 32,567,367 I 33,552, 913 I 34, 56$ 720 I 35,615,752 City of San Bernardino As can be seen by Table 4 above, for FY 2007/08 the City will need to increase I W NI residential, commercial, and temporary rates by 21.0%, adopt 3% annual CPI increases, and adopt a new street sweeping rates of $1.69 per residential Business accounUmonth, and $13.53 per commercial accounUmonth. The result of the i h h plan t e t rate increases and new street sweeping rates will provide the Division w necessary funding to improve services to a level provided by other publicly run solid waste operations and effectively.compete with private waste haulers. However, rate increases in FY 2008/09 are "across the board" increases and 3% do not move the Division to LOB based rates. This "across the board" approach is recommended for the following primary reasons: • Avoid a one time residential rate increase of 61.5%. • Avoid a one time commercial rate decrease of 12.0%. • Allow the Division to conduct a detailed cost of service study. • Complete the customer service level audits. • Track revenue and expenses by LOB (commercial and temporary services) and to adopt residential variable container size rates. • Incorporate disposal cost reductions and increased recyclables revenue from increased residential and commercial recycling. • Incorporate operational efficiencies due to more efficient routing, and more accurate customer billing. Also, as can be seen in Table 4 above, residential services will run a cumulative 5-year deficit of approximately $19 million unless additional rate increases are adopted. Accordingly, R3 recommends the Division should phase in residential rates on a LOB basis over a three (3) year period in conjunction with the customer service audit, cart replacement program, and adoption of variable rates. 5.2 Example FY 2008/09 Rates The following table provides a list of rates if the Division adopts the recommended rate increases: Table 5 Example FY 20013/09 Morrthly Rates Category FY 2007/08 Rate FY 2008/09 Rate Residential 96 Gallon Trash $19.86 $24.03 Residential Street Sweeping -0- $1.69 Commercial - 1 Yard - (1 x weekly) $95.00 $114.95 ~~ Page 17 IWM Business Plan 0 0 Page 18 City of San Bernardino City of San Bernardino Table 6 Cost Decreases and Revenue Increases From Implementing Recommendations Cost Decreases Revenue Increases Increase Residential Green Waste Tonnages (target of 40% of residential waste stream) 0 0 Increase Commercial Recycling Tonnages (target 30% of commercial waste stream) 0 $1,160,00 Decrease Commercial Tonnage Disposal ($1,826,000) 0 TOTALS ($2,426,000) $3,079,000 5.4 Financial Model Assumptions A significant number of assumptions were incorporated into the financial model: • Annual growth of 3%. • Assumed annual operating cost increases of 3% (salaries, benefits, tip fees, etc). • Interest rate of 6.0%. • Cart and bin depreciation over 10 years. • Collection vehicle depreciation over 7 years. • Retire all payments for lease-purchased vehicles at the end of FY 2013/14. • Debt finance new purchases of vehicles and containers. • FY 2008/09 one time cost of $450,000 for moving Division staff to the corporation yard. • $25 million capital cost for a new Corporation Yard/Material Recovery Facilitylfransfer Station beginning in FY 2012/13. • No revenue increases or operating cost decreases due to improved recyclables and green waste diversion. In order to develop the model on a LOB basis, it was necessary to reassign and allocate FY 2007/08 expenditures and revenue categories to specific LOBS as follows: IWM Business Plan IZ3 Page 19 IWM Business Plan 23 Page 20 City of San Bernardino City of San Bernardino Q Table 7 Line Of Business (LOB) Allocation Factors Hem/ Method Rasldentlal Commercial - R uler Tem ore Street Swee In BY drivers Commercial Equipment Within com 0.0% 69.6% 30.4% 0.0% Allocation perm-temp s lit Transfers By drivers 42.4% 34.8% 15.2% 7.6% 6.0 Example Implementation Steps 1. Billing System Year 1 Problem: The current customer service and billing systems (H.T.E.) does not have the ability accurately identify customer accounts, service levels, or rates charged to customers. The lack of accurate customer information greatly reduces the ability of the Division to identify cost and revenue requirements for all customers and department functions. The current H.T.E. system does not have the ability to track and bill all customers for services provided by the Division; • The Division must manually enter commercial and roll-off information to update billing at the end of the month; • H.T.E. does not have the ability to generate route sheets or management reports to assist staff with daily operations; • The current system relies heavily on handwritten notes, faxed work orders, or phone calls directly to drivers or supervisors; • Work orders are not issued for all service requests; and • There is not a system in place to track and all close work orders. V Years The Division should procure and install an industry standard "off-the-shelf" Integrated Customer Service and Billing System (ICSBS). A sample list of IWM Business Plan IZ3 Page 21 City of San Bernardino companies that offer "off-the-shelf" solid waste software systems include IINIVI Routeware, Soft-Pak, Trux, Encore, Waste Works and Desert Micro. BUSIneSS The Division should consolidate all billing and customer service functions into Plan one system that has the ability to do the following functions: • Identify all customers by service type, level of service, and rates charged; • Identify all customer calls and requests; • Processing billing and accounting functions; • Identify customers by day and routes; • Track container usage and inventory; and • Provide management reports. Year 2 • Begin full use of new Integrated Customer Service and Billing Systems (ICSBS) for all customer and billing activity; and • Implement new variable can rate structure for residential customers. Year 3 -Year 5 During Year 3, the IWD should begin the process of conducting annual compliance audits of customers to verify billing and routing information. Begin annual compliance audits of 20 percent of all commercial and residential customers. Compliance Audits should include confirmation of the following: • Address; • Container size; • Service IeveUfrequency; and • Confirm correct rate. 2. Finance and Accounting Problem: The current financial and accounting system tracks costs by five section codes, (411- Administration, 412- Automated Residential Collection, 413 -Subscription Refuse, 414, Street Sweeping, and 415 - Recycling/Environmental). Revenue is tracked by two section codes (412 -Automated Residential Collection, and 413 -Subscription Refuse). This caused a "disconnect' between cost and revenue ~~ tracking, and does not accurately reflect the costs associated with the 4 services provided by the Division. Page 22 City of San Bernardino Year 1 Conduct a cost of service analysis by Line Of Business (LOB) to determine costs that can be used to determine future rate increases; Expand the current accounting systems to track costs and revenue by the following LOBS and functions: o Residential • Solid Waste Collection • Residential Collection • Green Waste Collection o Commercial • Solid Waste Collection • Recycling Collection • Temporary Bin Collection o Roll-off • Permanent Collection Accounts `' Temporary Collection Accounts ~/~ o Street Sweeping • Residential • Commercial • Revise the current procedure for Permanent and Temporary Roll-off accounts to: o Define permanent accounts as customer with regularly scheduled service or with established bin rental charges and minimum collection frequencies established; o Establish rates that include a fixed hauling charge and apass- through of actual tipping fees; o Eliminate the use of "temporary 90-day roll-off boxes"; and o Establish all Temporary accounts to have weekly collection that is paid in advance. Year 2 • Adopt new rate structure to cover costs by LOB (may be necessary to phase in residential rates over three years); • Establish new commercial rates to "include" recycling to provide an Q incentive for commercial businesses to recycle and divert material. • Begin tracking costs and revenue by LOB; and IWM Business Plan IZ3 Page 23 City of San Bernardino IWM Business Plan • Adopt new residential 'Variable can rate"; Year 3 • Implement variable rate system for all residential customers. Year 4 • Conduct a cost of service analysis by LOB to determine costs that can be used to determine future rate increases; 3. Collection Operations Problem: Current collection operations is under staffed with the current number of supervisors that cover several functions. This understaffing and cross utilization reduces the amount of time the supervisors have to monitor the quality of service provided and limits their ability to improve performance and reduce costs. Management and customer service functions do not have the ability to effectively monitor route operations productivity or collection efficiencies. The current collection and routing system has resulted in overweight vehicles that deliver overweight loads in excess of 30 percent of the total loads delivered to the landfill. The potential financial issues related to overweight vehicles may include excessive wear and reduced life span of vehicles, excessive road wear, and potential financial penalties by local enforcement offices. Year 1 • Hire two (2) Collection Route Dispatchers to: o Assist supervisors monitor daily routes; o Communicate and schedule customer service request; and o Check-in drivers at the end of the day to ensure the completeness of daily activity. • Procure, install, and activate GPS units with "real-time" monitoring of vehicles that tie to ICSBS system; • Adopt a formal "overweight" policy program to identify and eliminate overweight vehicles; and • Adopt and implement a daily "check-in" program with the drivers and Dispatcher. IZ3 1-::J ~~ Page 24 City of San Bernardino I W M Year 2 Business • Develop a monitoring program to record and improve customer service and route operations through daily use of GPS systems; Plan • Establish benchmark system to track customer service calls and route performance; • Include Radio Frequency Identification (RFID) on all new collection carts and bins; • Install RFID systems on all new collection vehicles; and • Establish procedure to monitor and balance routes to eliminate overweight loads. Year 3 -Year 5 • Use GPS and monitoring system to establish goals to improve customer service and improve route efficiencies; and • Install RFID systems on all existing collection vehicles. 4. Commercial Accounts Problem: The current commercial collection system has several areas that can show significant improvement and result in positive financial returns to the Division. The current commercial collection system does not have the ability to accurately identify commercial customers by day, route, or service levels. The current routing system allows for frequent overweight vehicles and drivers to collect from customers that are paying for lower service levels. The Division does not have an established routing or billing audit system in place to monitor routing performance and customer service levels. The current Commercial Recycling Collection program has approximately 200 customers that are collected by routes that operate five (5) days per week. Due to random contamination, drivers will determine entire loads are contaminated, resulting in loads of contaminated recyclables that end up delivered directly to the landfill. Year 1 • Audit 100% of current commercial accounts to document the following: o Service location; o Container size and bin number; o Days of service; Q o Customer specific issues (locks, dismount, 2 staff person service, etc.); and ~~ Page 25 City of San Bernardino IWM Business Plan o Opportunities to increase diversion. • Identify current size of commercial routes; • Present options to re-balance routes to increase efficiency; • Re-route commercial accounts to reduce the number of two-man collection routes by five (5); • Design routes with sequenced stops; • Implement container inventory tracking system through ICSBS; • Conduct a waste audit of top 500 generators; • "Re-introduce" Commercial Recycling Collection; • Meet with local recyclers to evaluate additional processing capabilities to increase recycling diversion; and • Replace 20% of commercial bins. Year 2 • Implement new ICSBS; • Re-route commercial accounts; • Reduce two-staff person routes to four (4) routes per day; • Expand commercial recycling to new bundled rates; • Identify and implement the collection of select commercial loads; • Develop commercial organics collection program; • Begin to conduct waste audits on top 20% of the largest generators; and • Replace 20% of commercial bins. Year 3 -Year 5 • Implement commercial organics collection program; • Continue waste audits on 20% of the largest generators; • Begin annual compliance billing audits on 20% of all commercial customers; • Replace 20% of commercial bins (each year); • Establish procedure to monitor facility diversion of select commercial loads, C&D material, and bulky waste material; and • Continue to expand commercial recycling and select load collection programs. 0 `.I Page 26 City of San Bernardino 5. Roil-off Accounts IWM Problem: The current roll-off system has several accepted practices that BuSlneSs provide service to customers not typically found in private sector i l Pl n p ace to roll-off operations. The system does not have systems an accurately identity the quantity or location of containers. "Temporary" customers have the ability to use aroll-off bin for up to 90 days while generatirig only one (1) revenue producing load for the Division. The current system of charging for weight, while typical for permanent accounts, is burdensome for temporary bin accounts. Additionally, with permanent accounts, the overvveight limits and charges should be reviewed to reduce the administrative burden and increase the penalty for overloading the bins. Roll-off and Construction and Demolition diversion has the potential to generate a high amount of diversion with the proper outreach to customers. Currently, opportunities for diversion are missed due to quality standards accepted at local recycling and C&D facilities. Years • Audit 100% of Roll-off accounts; • Conduct bin inventory; • Implement bin inventory tracking system; • Negotiate material quality standards with local Recycling and C&D facilities; • Evaluate and establish permanent roll-off routes; • Conduct waste audit of top 50 generators; • Adopt new permanent and temporary roll-off customer policy; and • Conduct site visits with all new permanent or temporary C&D customers. Year 2 • Evaluate and establish permanent roll-off routes; • Conduct waste audit of top 51-100 generators; and • Implement new permanent and temporary roll-off customer policy. Year 3 • Conduct waste audit of top 101-150 generators. Year 4 © Conduct waste audit of top 50 generators. ~~ Page 27 City of San Bernardino - Year 5 I W M Conduct waste audit of top 51-100 generators. Business 6. Residential Accounts Plan- Problem: The current residential system operates four (4) days per week with unbalanced routes and lacks basic routing information including customer service level information or sequenced route maps. Year 1 • Audit 100% of Residential accounts; • Evaluate current route time saving options; and • Implement new customer start-up program with new bins and recycling outreach; • Replace 33% of solid waste carts; • Replace 33% of recycling carts; • Replace 33% of green waste carts; and • Begin re-route residential collection routes to five (5) day collection schedules (Mon-Fri) routes. Year 2 • Replace 33% of solid waste carts; • Replace 33% of recycling carts; • Replace 33% of green waste carts; and • Complete re-route residential collection routes to five (5) day collection schedules (Mon-Fri) routes. Year 3 • Begin annual compliance billing audits of 20% of all residential customers; • Replace 33% of solid waste carts; • Replace 33% of recycling carts; and • Replace 33% of green waste carts. Year 4 -Year 5 • Continue annual compliance billing audits of 20% of all residential customers. 123 Page 28 City of San Bernardino IWM 7. Customer Service Problem: The current Customer Service Department is limited by the H.T.E. BU$Ine$s system. The current system relies heavily on hand-written notes, Plan faxed work orders, or phone calls directly to drivers or supervisors. Customer Service Representatives (CSRs) are burdened by a slow and inefficient system that does not allow them to effectively provide customer service and participate in the delivery of high quality customer service and expand recycling and diversion programs. Work orders are not issued for all service requests and there are no formal systems in place to track and close work orders. Year 1 • Hire Commercial/Industrial Account Managers; • Hire Recycling Diversion Analysts; • Establish Residential and Commercial CSR teams; • Begin training CSRs on new ICSBS system; and • Implement CSR ride-along program for CSR's to observe on route activity. Year 2 • Implement new ICSBS system; • Implement new customer start up procedure for residential and commercial accounts including new bins and recycling outreach; and • Incorporate results of annual compliance audits. Year3-5 • Incorporate results of annual compliance billing audits. 8. Public Education and Outreach Problem: The current Public Education and Outreach programs have not achieved the goals of increasing recycling activity while informing residents and businesses on the proper procedures for separating recyclables from the solid waste to maintain acceptable levels of contamination. Current contamination levels for the residential program are estimated to be above 40 percent. Commercial recyclables are contaminated on a regular basis that results in a majority of the material being landfilled. ~~ Page 29 City of San Bernardino Year 1 I W M Develop and expand the Public Education and Outreach Programs to BUSIne$$ inform all residents and businesses the reasons to recycle and the proper methods; and Plan Contract with a social marketing firm to: o Conduct phone surveys to identify method to improve the program; o Conduct focus groups to get community involvement in the programs; and o Develop and implement pilot programs to improve the collection programs. Year 2 • Begin annual site visits of top 20% of the largest commercial accounts without recycling; • Re-introduce residential recycling program; • Continue with social marketing surveys and focus groups; and • Introduce variable can rate to provide a financial incentive for customers to increase recycling. Year 3 • Implement Commercial Recycling Recognition Program; • Implement Residential Recycling Recognition Program; • Introduce special item collection programs; • Continue with social marketing surveys and focus groups; and • Continue with social marketing surveys and focus groups. Year 4 • Implement residential food waste collection program; and • Continue with social marketing surveys and focus groups. Year 5 • Evaluate and measure the progress made through improved Public Education and Outreach programs and social marketing surveys; and • Develop new five-year plan for Public Outreach and Education Program. 9. Disposal and Processing Facilities Problem: The Division's disposal and processing capacity will expire in 2012 ~~ when the Waste Disposal Agreement (WDA) with San Bernardino r C t th R l bl P i A t ith B k b oun y, e ecyc a e rocess ng g eemen w ur an Page 30 City of San Bernardino Recycling Inc. (BRI), and the Green Waste Processing Agreement with Republic Services expire. The Ciry does not have facility options for the processing and diversion of material from select commercial loads, commercial organics, or the material collected from the bulky waste collection programs. Year 1 • Negotiate an extension of current disposal agreement with San Bernardino County; • Identify facility options to process commercial dry waste (mixed dry garbage and recyclables); • tdent'rfy facility options to process commercial food waste; and • Identify and arrange for faciliry(ies) to handle and process bulky waste collection material. Year 2 • Conduct a Corporation Yard/MRF/Transfer Station Study; • Enter into contract(s) for processing commercial dry waste and commercial food waste; and • Enter into processing agreement for the handling and diversion of bulky waste material. Year 3 • Implement action plan for long term Corp Yard/MRF/Disposal facility; and ^ Conduct material characterization per agreement with BRI. 10. Recycling Programs Problem: Current recycling programs are not achieving the goals of increasing and maintaining participation by residents and providing recyclables with acceptable levels of contamination (under 15%). The Division will need to develop and expand the current outreach programs and address these issues with all Division employees. Year 1 • Develop an expanded Outreach program for Residential and Commercial Recycling Program, using social marketing techniques; ^ Adopt a Cart and Bin Contamination Policy and Procedure; • Conduct driver training to monitor and tag carts and bins with unacceptable levels of contamination in the recyclables; IWM Business Plan Page 31 City of San Bernardino IWM Business Plan • Identify recycling-rich commercial accounts, for inclusion on source- separated or select routing collection programs; • Develop new bin enclosure standards, assuring adequate collection space for recycling, organics, and refuse containers; and ^ Assure that new and remodeled commercial developments provide adequate collection space for recycling, organics, and refuse containers. Year 2 0 • Conduct recyclables material characterization for residential and commercial recyclables per the agreement with BRI; • Begin tagging and enforcing contaminated bins through the new bin/cart contamination policy; • Begin delivery of new recycling carts with full color imprinted recycling information; • Expand commercial recycling collection; • Initiate routing and collection of select commercial accounts with high levels of recyclables; and • Continue social marketing surveys, focus groups, and outreach programs. Year 3 • Initiate process to develop, .induce, or contract for long term facility options including disposal, transfer station and material processing facility; and • Continue social marketing surveys, focus groups, and outreach programs. Year 4 • Conduct recyclables material characterization for residential and commercial recyclables per the agreement with BRI; • Contract for transfer station and materials processing facility services; and • Initiate transfer station and materials processing facilities construction and expansion. Year 5 • Conduct five (5) year review of Collection Operations and Recycling Programs. IZ3 11. Bulky Waste Collection Programs u Problem: The Division would like to provide bulky waste collection programs for all residential customers to help increase diversion, reduce the impact on the neighborhood clean up events, and reduce the impact on potential illegal dumping of material. Page 32 City of San Bernardino V Year 1 Design and plan bulky waste collection programs; Procure equipment for bulky waste collection; • Identify and adopt rates structure for bulky waste collection; and • Notify public of new bulky waste collection. Year 2 • Implement on-call bulky waste collection program; and Phase out neighborhood collection events. Year 3 Expand bulky item collection program to include universal waste and household hazardous waste material as part of the bulky waste collection program. IWM Business Plan Page 33 IWM Business Plan 23 4 Page 34 City of San Bernardino