HomeMy WebLinkAbout2007-05-07 Packet - Sewer WorkshopCITY OF UKIAH
CITY COUNCIL AGENDA
Special Meeting
Civic Center Council Chambers
SEWER LATERALWORKSHOP
300 Seminary Avenue
Ukiah, CA 95482
May 7, 2007
5:00 PM
ROLL CALL
2.
4. ADJOURNMENT
Please be advised that the City needs to be notified 72 hours in advance of a meeting if any specific
accommodations or interpreter services are needed in order for you to attend. The City complies with
ADA requirements and will attempt to reasonably accommodate individuals with disabilities upon request.
hereby certify under penalty of perjury under the laws of the State of California that the foregoing agenda
was posted on the bulletin board at the main entrance of the City of Ukiah City Hall, located at 300
Seminary Avenue, Ukiah, Cal'rfornia, not less than 72 hours prior to the meeting set forth on this agenda.
Dated this 4th day of May, 2007.
Gail Petersen, City Clerk
ITEM NO: Sewer Lateral Workshop
MEETING DATE: Mav 7. 2007
AGENDA SUMMARY REPORT
SUBJECT: DISCUSSION AND DIRECTION TO STAFF REGARDING VARIOUS
SEWER LATERAL PROGRAM TOPICS
SUMMARY: The City Council had requested staff to return with information on several
sewer lateral program topics that needed further discussion. Attached are reports from
consultant Mary Grace Pawson and from Rick Kennedy on several key issues that
require Council discussion and direction.
RECOMMENDED ACTION: Discuss and provide direction.
ALTERNATIVE COUNCIL POLICY OPTIONS: N/A
Citizens Advised: Yes
Requested by: City Council
Prepared by: Mary Grace Pawson
Coordinated with: Candace Horsley, C
Attachments: Reports--3
and Rick Kennedy
:y Manager and Dave Rapport, City Attorney
Approved:
Candace Horsley, Cit Manager
CITY OF UKIAH
REPORT ON
SEWER LATERAL ASSISTANCE PROGRAM
May 2, 2007
Prepared by:
WINZLER & KELLY CONSULTING ENGINEERS
495 Tesconi Circle
Santa Rosa, CA 95404
(707)523-1010
TABLE OF CONTENTS
1.0 INTRODUCTION &PURPOSE .....................................................................................1-1
2.0 EXISTING CONDITION INFORMATION ...................................................................2-1
2.1 Existing City-Owned Sewer Collection System ..................................................2-1
2.2 Private Laterals .................................................................................................... 2-1
2.3 General Waste Discharge Requirements for Sanitary Sewer Systems .................2-2
2.4 City's Sewer Rate Structure and Available Budgets ........................................... 2-3
3.0 ALTERNATIVE ASSISTANCE PROGRAMS ................................................ .............3-1
3.1 Alternative 1 -Increase Public Education .............................................. .............3-1
3.2 Alternative 2 -Grants For Lateral Repairs ............................................. ............. 3-1
3.3 Alternative 3 -Loans For Lateral Repairs ............................................... ............. 3-2
3.4 Alternative 4 -City Crew Repair of Street Laterals ............................... ............. 3-2
3.5 Alternative 5 -Accept Repaired Laterals in the Right of Way .............. ............. 3-2
3.6 Summary ....... .......................................................................................... .............3-4
4.0 RECOMMENDATIONS .................................................................................................4-1
5.0 REFERENCES .......................................:........................................................................ 5-2
`Tbi,r is a draft report and is not intended to be a ftna! reprerentation of the work done or recommendations made by Bmwn and Caldwc!!.
It should not be relied upon; cansulL the final report. "
City of Ukiah
Report on Sewer Lateral Assistance Program
Page 1-1
1.O INTRODUCTION & PURPOSE
The City of Ukiah (City) owns and operates a sanitary sewer collection system and a sewer
treatment plant to serve the residents and businesses within its limits. The City regulates its
sewer system under Division 4, Chapter 2 of the Municipal Code (the "Sewer Use Ordinance").
The City recently amended portions of its Sewer Use Ordinance to require inspection and repair
of privately owned sewer laterals upon a number of triggers, including point-of--sale of a
property. These amendments were made in order to comply with a Consent Decree and Order
between the City and North Coast River Watch. As the City developed these amendments to its
Sewer Use Ordinance, it received substantial public comment related to the burden these
requirements would place on private property owners. Comments fell into two major categories:
1. The City should consider providing financial assistance to owners;
2. The City should consider relieving the private property owner of responsibility for the
portion of the sewer lateral that is located in the public street.
In addition to the requirements of the Consent Decree, the City, like all agencies operating sewer
collection systems, is subject to the requirements of the State Water Resources Control Board
Order No. 2006-0003 DWQ (Statewide General Waste Dischazge Requirements for Sanitary
Sewer Systems or GWDRs).
The GWDRs set new standards for collection system maintenance and management. These new
standards emphasize the importance of reducing overflows of untreated sewage from the
collection system. Historically agencies that operate treatment plants, like the City, have focused
on treating peak wastewater flows rather than reducing these flows because investing in
centralized treatment is less expensive than investing in miles of collection system repair. The
new requirements have changed this perspective. Because collections system performance is now
regulated, improving that performance by reducing seasonal infiltration and inflow will reduce
the City's exposure to regulatory enforcement actions.
The GWDRs require that the City prepare a Sanitary Sewer Management. Plan by July 2009. As
part of this Plan, the City needs to develop goals for the management of its sewer collection
system. The GWDR requirements provide the City with an opportunity to consider the
comments it received on its sewer lateral program in the context of its lazger goals for managing
the collection system.
The purpose of this report is to provide the City's decision makers with options that would help
them address the comments received on the sewer lateral inspection and repair program. The
options are presented in light of the overall collection system management needs so that decision
makers can develop a balanced strategy for infrastructure investment that makes the most of
available budgets.
City of Ukiah
Report on Sewer Lateral Assistance Program
Page 2-1
2.0 EXISTING CONDITION INFORMATION
This section provides information on the City's collection system and on its sewer rate structure
and budget. This existing condition information provides the background against which the City
will develop alternative sewer lateral inspection and repair programs and evaluate their
effectiveness.
2.1 Existing City-Owned Sewer Collection System
Under current City policy, the City owns and is responsible for the maintenance of the sewer
mains located in public rights of way. The City-owned sewer collection system is approximately
43.5 miles in length and varies in diameter from 6-inches to 42-inches.
In order to provide the City with an approximate value of this asset (and the investment that is
needed to preserve it), Winzler & Kelly used an estimate of $200/linear foot of system. With this
estimate, the present value of the City's system is approximately $46 million dollars.
If the City managed this asset fora 100-year life (i.e. replaces 1% per year), the required
investment is $460,000/year in current dollars.
If the City managed this asset fora 50-year life (i.e. replaces 2% per year), the required
investment is $920,000/year in current dollars.
2.2 Private Laterals
Under current City policy, private property owners are responsible for the maintenance of the
sewer lateral from the building face to the sewer main. The City's Sewer Use Ordinance
describes two pieces of the lateral: the building lateral (which is located between the building
face and the property line) and the street lateral (which is located between the property line and
the sewer main}. There are approximately 5,700 lateral connections to the City-owned sewer
collection system.
In order to provide the City with an approximate value of this asset (and the investment that is
needed to preserve it), Winzler & Kelly used the following simplifying assumptions:
• Each lateral is approximately 50 feet long and evenly divided between building lateral
and the street lateral;
• The value of the building lateral is estimated at $65/linear foot;
• The value of the street lateral is estimated at $120/linear foot.
Using these estimates, privately-owned laterals may actually be longer than the City-owned
collection system and could contribute another 54 miles of length to the collection system (50
feet x 5,700 connections). The laterals have an estimated asset value of $26.5 million or
approximately 60% of the value of the City-owned collection system.
City of Ukiah
Report on Sewer Lateral Assistance Program
Page 2-2
Managing these assets fora 100-yeaz life (i.e. replacing 1% per year), requires an investment of
$265,000/year in current dollars.
Managing these assets fora 50-yeaz life (i.e. replacing 2% per year), requires an investment of
$530,000/year in current dollars.
2.3 General Waste Discharge Requirements for Sanitary Sewer Systems
In May 2006, the State Water Resources Control Board (State Boazd) adopted its GDWRs for
collection systems. The City is subject to these new requirements because it owns and operates
more that one mile of collection system infrastructure. The City has enrolled for coverage under
the GWDR program. The GWDRs require that the City participate in a centralized reporting
system for sanitary sewer overflows (SSOs) and also require that the City develop and
implement a Sewer System Management Plan (SSMP). The SSMP has eight required elements,
outlined in Section D.13 of the GWDRs including:
• A description of the City's organization
• A description of the City's legal authority to manage its system. This is to be
accomplished through the Sewer Use Ordinance or service agreements and must
demonstrate that the City has the authority to:
o Prevent illicit discharges into its sanitary sewer system (including I/I. stormwater,
roots etc);
o Require that sewers and connections be properly designed and constructed
o Ensure access for maintenance, inspection or repairs for portions of the lateral
owned or maintained by the public agency
o Limit the discharge of fats, oils and grease and other debris that may cause
blockages; and
o Enforce any violation of its sewer ordinances
• A description of the City's Operation and Maintenance Program. This is to include a
rehabilitation and replacement plan to identify and prioritize system deficiencies and
implement actions to address each deficiency.
• A description of the City's Design and Performance Provisions
• A description of the City's Overflow and Emergency Response Plan
• A description of the City's Fat, Oil & Grease Control Program
Ciry of Ukiah
Report on Sewer Lateral Assistance Program
Page 2-3
• A description of the City's System Evaluation and Capacity Assurance Plan. This is to
include a short and long-term Capital Improvement Program (CIP) to address identified
deficiencies.
• A description of the City's Monitoring and Measurement Program for SSOs
As part of developing its SSMP the City will need to review its Sewer Use Ordinance to assure
that it has clearly articulated the authority required by the GWDRs and it will need to review its
CIP to assure that it has clearly articulated and budgeted for repairs consistent with technical
information on the condition of the system.
2.4 City's Sewer Rate Structure and Available Budgets
In late 2005, the City and the Ukiah Valley Sanitation District approved aphased-in sewer rate
increase to manage the capital and operational needs of their collection systems and their shazed
treatment plant. While the primary driver for the sewer rate increase was the need to finance
upgrades to the sewer treatment plant, the rates also support an ongoing Capital Improvement
Program that includes components for Sewer Line Replacements, Sewer Main Replacements and
Inflow and Infiltration. Table 2-1 below summazizes the 5-year budgetazy numbers that were
included in the City's rate study. The table also converts these to an annual budgetary amount
and allocates that budget between the City and the Ukiah Valley Sanitation District.
These tables represent the fully budgeted revenues. Because of the rate increases are phased-in,
fully budgeted revenues, from the rate increase, will not become available until Fiscal Year
2009/10.
Table 2-2 below compares these annual budgetary amounts to the asset management budgets
developed above for the City-owned Sewer Collection System.
Table 2-1 Five Year Capital Improvement Budgets in Rate Structure
Project Description 5-Year CIP Equivalent Annual Annual
Budget' Annual Budget Budget Budget
' Allocation Allocation
to City to District
(53%) (47%)
Line Replacements
$1,500,000 $300,000 $159,000 $141,000
Main Replacement
$1,625,000 $325,000 $172,250 $152,750
Subtotal Line 8 Main Replacement
$3,125,000 $625,000 $331,250 $293,750
Inflow/Infiltration
$1,301,000 $260,200 $137,906 $122,294
Totals $4,426,000 $885,200 $469,156 416,044
'Note: Full Budget Allowance is not available until Fiscal Year 09/70.
City of Uklah
Report on Sewer Lateral Assistance Program
Pate 2-4
Table 2-2 Equivalent Annual Budget Compared to Estimated Asset Management Needs
1 % per Year 2% per Year
Replacement Replacement
Schedule Schedule
(100-year life) (50-year life)
City Line 8: Main Replacement Budget Only ,
Annual City Line & Main Replacement Budget $331,250 $331,250
Estimated Investment in City-Owned Sewer System <$460,000> <$920,000>
Difference (Budget less Estimated Investment) <$128,750> <588,750>
City Line, Main I/I Budget
Annual City Line & Main Replacement Budget $469,156 $469,156
Estimated Investment in City-Owned Sewer System <$460,000> <$920,000>
Difference (Budget less Estimated Investment) $9,156 <450,844>
Table 2-2 indicates the following key points:
• The City's available budget from its rate base does not allow it to accomplish a 2% per
year replacement schedule;
The City's available budget from its rate base does allow it to accomplish a 1 % per year
replacement schedule within its collection system. However, in this case it would have
little available revenue for property owner assistance;
• The City could preserve its Infiltration and Inflow budget for property owner assistance
and accomplish a replacement of its collection system at 0.75% per year.
City of Ukiah
Report on Sewer Lateral Assistance Program
Paze 3-/
3.O ALTERNATIVE ASSISTANCE PROGRAMS
This section describes five (5) alternatives programs for assisting property owners with the costs
of inspecting, repairing and maintaining the private sewer laterals that are tributary to the City's
collection system. Three of these options build on model programs developed by other agencies.
The fourth program is an option that has been discussed by the City Council
3.1 Alternative 1 -Increase Public Education
This alternative involves providing the public with easy access to information and resources that
will help them maintain their private sewer lateral and minimize the risk of overflows or damage.
The alternative can be very easily implemented by utilizing resources developed through the
Association of Bay Area Government's (ABAG's) "Sewer Smart Program". Resources are easily
accessed on-line at www.sewersmart.ora.
This alternative would require minimal staff time and minimal financial commitment to
implement. The City can elect to implement this alternative in combination with others described
below.
3.2 Alternative 2 -Grants For Lateral Repairs
Some public agencies do make grants to property owners who repair/replace their sewer lateral.
These programs are similar in concept to water conservation rebate programs. The property
owner contracts for the repair work and provides the City with documentation of costs. The City
would then issue a check for a portion of the costs.
Lateral grant programs are administered by the City of Petaluma, the Castro Valley Sanitary
District, and the West County Sanitary District (covers the cities of Pinole, El Sobrante, East
Richmond Heights, Tara Hills, Rollingwood and Bayview). Each of these programs offer grants
for 50% of the cost of repairs up to $2,000.
When the City conducted public outreach, during the development of its Sewer Lateral
Inspection and Repair requirements, it learned that approximately 100 real estate transactions
occur annually in the City. If the City set a maximum grant amount of $2,000 and each
transaction qualified for the maximum grant, the City would need a budget of approximately
$200,000 annually to administer the program. As illustrated in Table 2-1, the City's share of the
adopted Infiltration/Inflow budget ($137,000) would likely allow it to fund this type of a
program.
This alternative would require financial commitment to implement. Administratively, sewer
lateral grants could be issued in conjunction with the Certificate of Sewer Lateral Compliance.
City of Ukiah
Report nn Sewer Lateral Assistance Program
Page 3-2
3.3 Alternative 3 -Loans For Lateral Repairs
The City of Pacific Grove administers a loan program for property owners who repair or replace
their sewer laterals. As is the case in Ukiah, property owners are responsible for the lateral to the
public sewer main. Pacific Grove's loan program offers a maximum of $10,000 in loan funds to
owners who undertake the work.
In Ukiah, a program like this with a maximum loan of $10,000 could require up to $1,000,000 in
annual capitalization costs in the early years. As the program matured, the City could fund new
loans with the repayment stream, which would minimize the ongoing program costs.
Table 2-1 illustrates that the City's rate base can be expected to generate approximately
$885,000 in revenue for collection system upgrade programs. This indicates that the City would
need to capitalize a loan program over several years and may need to prioritize the manner in
which it gave loans in order to manage available funds. A loan program does require
substantially more administrative effort than a grant program because of the need to administer
the repayment process.
3.4 Alternative 4 -City Crew Repair of Street Laterals
Since the City adopted its lateral inspection and repair program, City crews have made repairs to
the portion of the sewer lateral in the street upon request of the property owner. The owner has
then reimbursed the City for the actual cost of City time and materials. This program is cost-
neutral to the City, because it recovers its costs from benefiting property owners. The program
does produce additional administrative demands on staff related to scheduling work and billing
for services.
Anecdotal reports suggest that the City's cost is lower than quotes from private contractors;
hence City crew repair is a form of assistance to property owners. The single largest limitation to
offering this assistance to all owners is the availability of City workers. The City may wish to
consider combining this program with direct financial assistance (i.e. a grant or loan) so that
property owners can access either a lower cost repair or receive direct assistance for the more
expensive repair.
3.5 Alternative 5 -Accept Repaired Laterals in the Right of Way
This alternative involves City acceptance of the street lateral once an owner has replaced the
lateral to current City standards.
This alternative has no immediate costs to the City but brings with it long term considerations
related to asset management and future liability.
There are two major types of liability that the City could potentially incur if it accepts portions of
the private sewer lateral. These are liability from blockages and overflows and liability for future
costs of repair and replacement.
City oJUkiah
Report on Sewer Lateral Assistance Program
Paee 3-3
Liability from blockages and overflows. Under current policy, the owner is responsible for the
sewer lateral. The City is not required to prevent blockages in the lateral; it is not required to
report overflows that occur as result of these blockages and its rate base is not liable for any fines
or administrative liabilities that result from lateral overflows.
if the City modified its ownership policy, it could be accepting some responsibility for keeping
the street lateral clear of blockages and reporting overflows that result from these blockages. The
City may be able to tailor its lateral acceptance contract and policy to leave the responsibility for
lateral maintenance with the private property owner, even if the City chose to accept
responsibility for the costs of street lateral repairs. This concept would require careful review by
the City Attorney and the North Coast Regional Water Quality Control Board to assure that the
City is protected.
Liability for future costs of repair and replacement. As outlined in Section 2, there aze
approximately 5,700 lateral connections to the City's sewer system. Using the assumptions
developed in Section 2, the street portion of the laterals has an approximate value of $17.1
million or nearly 40% of the value of the City-owned sewer collection system.
If it accepted the street lateral assets, the City should budget for the eventual need to replace or
repair these at some time in the future, or it will compromise its ability to effectively manage its
other assets including the main collection system and the treatment plant.
Managing the laterals fora 100-year life (i.e. replacing 1 % per year), requires an investment of
$171,000/year in current dollars.
Managing the laterals fora 50-yeaz life (i.e. replacing 2% per yeaz), requires an investment of
$342,000/yeaz in current dollazs.
Table 3-1 below illustrates the impact of this additional liability on the City's revenue stream.
Table 3-1 Equivalent Annual Budget Compared to Estimated Asset Management Needs
1%per Year 2% per Year
Replacement Replacement
Schedule Schedule
Equivalent Annual CIP Budget $469,000 $469,000
Estimated Investment in City-Owned Sewer System <$460,000> <$920,000>
Estimated Investment in Street Laterals <171,000> <$342,000>
Difference (Budget less Estimated Investment) <$762,000> <$793,000>
This preliminazy analysis indicates that the City's rate base could not adequately support the
ongoing investment in both collection system and street lateral repair. Accepting responsibility
for additional infrastmcture assets will not only result in an "unfunded" liability for the City but
would also limit the City's ability to invest in other aspects of its collection system and would
limit the City's ability to provide other forms of property owner assistance.
City of Ukiah
Report on Sewer Lateral Assistance Program
Page 3-4
Administrative Concerns. While accepting fully repaired street laterals could provide an
incentive to property owners, the piece-meal nature of the acceptance process will create new
administrative concerns. Staff would need to carefully track which laterals the City owned and
didn't own and there would clearly be a need for additional public outreach to assist the public in
understanding repair policies that appeared inconsistent.
Again, while the City may be able to effectively limit its liability for blockages and overflows, it
can expect to be challenged at times on these liability limitations.
3.6 Summary
Table 3-2 provides a summary of the various alternatives evaluated against a range of cost and
liability criteria. This analysis is intended to assist the City in clarifying its goals for the program
and is not a conclusive set of recommendations.
Table 3-2 Summary of Alternative Evaluation
Low First Low Long Can Be Maintains Minimizes
Cost Term Cost Supported the City's Liability
by Existing on the
Existing Asset Sewer
Rate Base Base Enterprise
Fund
Alternative 1
Increase Public Education X X X X X
Alternative 2
Provide Grant Assistance ? ? X
Alternative 3
Provide Loan Assistance X ? ? X
Alternative 4
Provide City Crew Assistance X X X X X
Alternative 5
City Acceptance of Replaced Public Laterals X
? Indicates that the City would need to selectively prioritize between investments in city-owned infrastructure
and privately-owned infrastructure.
Ciry of Ukiah
Report on Sewer Lateral Assistance Program
Page 4-!
4.0 RECOMMENDATIONS
The City is considering major policy revisions which potentially have significant financial
impacts upon its sewer enterprise fund well into the future. The GWDRs provide the City with a
framework for making these decisions, because they require that the City develop goals for its
collection system management program.
We recommend that the City develop its Sanitary Sewer Management Plan goals and work to
implement policy changes consistent with goals. Example goals that the City could consider
include:
1. The City's collection system management strategy will include a repair and rehabilitation
plan that identifies and prioritizes system deficiencies and actions to address those
deficiencies (GWDRs D.13(iv)(c)).
2. The City's collection system management strategy will include proactive implementation
of Capacity Enhancement Measures (GWDRs D.13(viii)(c)).
3. The City's collection system management strategy will minimize the risk of regulatory
enforcement actions being taken against the City and its rate payers.
4. The City's collection system management strategy will preserve the value of the City's
infrastructure assets
5. The City's collection system management strategy will be supported by the existing rate
structure.
6. The City will implement a property owner assistance program for sewer lateral repairs
that is based on need/priority.
City of Ukiah
Report on .Sewer Lateral Assistance Program
Paee 5-2
5.0 REFERENCES
Ukiah and Ukiah Valley Sanitation District Sewer Rate Study and Financing Plan,
October 2008.
2. City of Ukiah, Municiual Code Division 4, Chapter 2 (the "Sewer Use Ordinance).
3. State Water Resources Control Board Order No. 2006-003 DWO Statewide General
Waste Discharge Requirements for Sanitary Sewer S std, May 2006.
APPROVAL OF FORMS AND STANDARDS
CITY COUNCIL WORKSHOP
SEWER LATERAL INSPECTION AND TESTING PROGRAM
MAY 7. 2007
Discussion Item
Approval of Forms and Standards Developed for the Sewer Lateral Inspection
and Testing Program-Rick Kennedy
Atlssue
Staff has developed draft forms and standards (Program Standards) to facilitate
the enforcement of the City of Ukiah's Sewer Lateral Inspection and Testing
Program. Although the provisions of Ordinance No 1091 provides the authority to
the Public Utility Director to prepare and promulgate the public administrative
guidelines within 90 days of the adoption of the ordinance, staff is recommending
that the provisions of the Program Standards be discussed by the City Council
for the purpose of determining if said provisions serve the public interest and
accomplishes the goals intended by the City Council.
Discussion
As committed by staff, the development of the Program Standards has been
accomplished with appropriate public review. Two program stakeholder meetings
were held for the purpose of receiving comment to the proposed Program
Standards from the professionals who will be directly involved in the program
process. Program stakeholders are realtors, mortgage lenders, title company
officers, escrow officers and contractors who will be offering inspection, testing,
and repair/replacement services. As directed by the Ukiah Valley Sanitation
Board of Directors, a second stakeholder meeting was noticed in the Daily
Journal and the proposed Program Standards were posted on the City's web site
along with a the notice of the meeting. Independent consultations with title
officers and the County Recorder/Assessor were conducted to ensure that the
Certificates of Compliance were recordable and that the Security Agreements
and the corresponding certificates were sufficient and addressed the needs of
the Title Companies. Staff also attended a NorBar breakfast meeting with the
City Mayor to discuss the sewer lateral programs adopted by the City of Ukiah
and the Ukiah Valley Sanitation District.
The majority of the stakeholder comments pertained to the requirements of the
Ordinances and the point of sale requirements. The point of sale requirement has
not received favorable comment and all comments were taken from the seller's
perspective. Most individuals opined that the geographical approach to the sewer
1
lateral inspections was the most practical approach. However, it was not evident
to the participants that the geographical approach did not currently involve
financial participation by the City and that the requirement to inspect, test, and
repair/replace the sewer lateral if necessary could arise without offering the
property owner the opportunity to plan for the expense of making the repair. Staff
received considerable comment regarding the responsibility for the repair of the
street lateral and all participants believed that the street lateral was the City's
responsibility. Some participants opined that the City should issue bonds to
finance the lateral repairs. Several participants felt that the sale price exemption
provided in the District's ordinance was unfair when compared to the
requirements of the City's ordinance.
Staff did receive some comments pertaining to the Program Standards. During
the first stakeholder meeting it was suggested that the air test was not applicable
to sewer laterals that have been in service over several years and that the air test
was not equivalent to the water pressure test. Staff agreed and the requirement
for the air test was omitted from the Standards. The allowable leakage contained
in the standards was changed to 85 gallons per day per lateral which represents
the average daily discharge per individual. During the second stakeholder
meeting, a participant took exception to the requirement that a copy of the
escrow instructions be provided with the application for a sewer lateral certificate
of compliance for the purpose of verifying that the sale price was under or over
the sale price exemption provided in the District's ordinance and that the
information contained in the instructions is confidential even though the sale price
becomes public record after the recording of the deed of transfer. Since the
applicant signs the application under penalty of perjury and that the sale price
can be confirmed after deed recordation, staff agreed to eliminate the
requirement for providing a copy of the escrow instructions. One participant
requested that the application for the testing permit include the construction of a
cleanout should a cleanout become necessary to facilitate the inspection or test;
for work within the District, this request can be accommodated since the District
staff inspects the sewer lateral on private property. One participant opined that
the presence of some roots within a lateral does not necessarily mean that the
lateral is leaking; the individual further opined that pressure testing does not
necessarily determine if the sewer lateral is significantly contributing to I/I. Staff
does not agree with this opinion. One participant inquired about the provisions for
providing security and the provisions of the security agreement were briefly
discussed. Many participants opined that the public needed to be informed about
the process and staff replied that after the forms and standards had been
finalized, information pertaining to the sewer lateral testing and inspection
program would be provided with the utility bills.
The Program Standards were presented to the Ukiah Valley Sanitation District
Board for approval on April 25, 2007. As a result of objections from two public
speakers, the Board took exception to the repair methods and materials specified
as approved in the Standards of Repair and Replacement. The Board also took
2
exception to the provisions setting forth what existing sewer lateral conditions
were repair would not be accepted for the purpose of obtaining a certificate of
compliance. Staff explained that the purpose of the Standards was to clarify and
provide specificity as to what type of repair and material would be acceptable.
Staff also stated that the Codes do not address Certificates of Compliance or the
testing and inspection of existing sewer laterals. However, the Board opined that
the provisions of the Plumbing Code were sufficient.
The City of Ukiah has adopted the State of California model codes and the
current Plumbing Code is the 2001 California Plumbing Code (the Code).
Chapter 7 of the Code addresses sanitary drainage and Part 2 of Chapter 7,
beginning with Section 713.0, deals with building sewers. Section 715, Building
Sewer Materials, states that "the building sewer, beginning two (2) feet. from any
building or structure, shall be of such materials as maybe approved by the
Administrative Authority under the approval procedures set forth in Chapter 3 of
the Code. Joining methods and materials shall be as prescribed in the Code".
Section 701, Materials, of the Code states that "drainage piping shall be cast
iron, galvanized steel, galvanized wrought iron, lead, copper, brass, schedule 40
ABS DWV, schedule 40 PVC DWV, extra strength vitrified clay pipe or other
approved materials having a smooth and uniform bore",with certain exceptions.
Not all the pipe so specified is acceptable for underground installations but are to
be used in the building plumbing. Section 705.1, Types of Joints, permits caulked
joints for cast iron bell and spigot with oakum or hemp filled with molten lead. The
section also permits cement mortarjoints where repairs and connections to
existing lines constructed with such joints are made. Staff does not believe these
types of joints are appropriate for the purpose of reducing I/I.
Appendix I of the Code addresses installation standards and under Section
IAPPMO IS 1-91 of this Appendix non metallic building sewer materials and
approved jointing are specified. This appendix allows the use of concrete sewer
pipe and asbestos cement sewer pipe: Concrete products are susceptible to
deterioration from sewer gases created under anaerobic conditions. The use of
asbestos cement pipe has safety issues and most Public Agencies do not specify
its use in public work contracts.
As is specified in the Draft Standards for Repair and Replacement, the following
pipe joints and connections are prohibited because of their potential to leak under
aging and ground movement conditions:
1. Cement, cement mortar; or concrete joints
2. Mastic or hot pour bituminous joints
3. Caulked joints
4. Oakum or hemp joints filled with lead
5. Lead joints
6. Joints made with fittings not approved for the specific installation
7. Joints between different diameter pipes made with elastomeric rolling o-
rings
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8. Solvent cement joints between different types of plastic pipe
The Draft Standards for Repair and Replacement specify what existing
conditions where pipe repairs. will not be accepted for the purpose of obtaining a
Certificate of Sewer Lateral Compliance. Repairs to Orangeburg pipe, hubless
concrete or vitrified clay pipe or pipes without gasketed or glued bell and spigot
joints excepting asbestos cement pipe gasketed couplings, ABS glued or
gasketed couplings or gasketed couplings for grey iron drainage pipe are not
acceptable and sewer laterals constructed of the pipe materials and jointing so
described must be replaced in their entirety from the wye in the sewer main to a
cleanout located near the footing of the structure being served.
Staff believes that the Program Standards as submitted contain appropriate
measures whereby the City can achieve its goal in reducing I/I to its sewer
collection system in accordance with the requirements and objectives of the
Consent Decree. Continued implementation of the Program Standards will
reduce sanitary sewer overflows as is required by the General Statewide Waste
Discharge Requirements for Sewer Collection Systems. Staff encourages the
City Council to accept the Program Standards as written and submitted.
The Program Standards are attached and consist of the following
1. Application for Sewer Lateral Testing
2. Application for Sewer Lateral Certificate of Compliance
3. Sewer Lateral certificate of Compliance
4. CCTV Sewer Lateral Inspection Report
5. Sewer Lateral Repair/Replacement Agreement
6. Certificate of Compliance Bond
7. Sewer Lateral Notice of Repair
8. Requirements and Standards for Closed Circuit Television Sewer Lateral
Inspections
9. Standards for Obtaining a Sewer Lateral Certificate of Compliance Based
on Repair or Replacement of the Sewer Lateral
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RE-DEFINING SEWER MAIN REPAIR
CITY COUNCIL WORKSHOP
SEWER LATERAL INSPECTION AND TESTING PROGRAM
MAY 7, 2007
Discussion Item
Re-defining Sewer Main Repair-Rick Kennedy
At Issue
Pursuant to the provisions of Ordinance No. 1091, a repair to the sewer main will
trigger the requirement that all sewer laterals connected to the repaired sewer
main must be inspected and tested and subsequently repaired should the laterals
fail the test. Since re-lining of sewer mains is a common repair method, a public
work project involving the re-lining of public sewer mains will cause the
necessary cleaning and testing of all sewer laterals connected to the sewer main
to be re-lined. This requirement will cause an unexpected financial burden on the
property owners that are connected to the repaired main. It has been questioned
if this requirement was intended when the ordinance was drafted for
consideration by the City Council and staff recommends that the City Council
consider modifying the provisions of Ordinance No. 1091 to specifically exclude
re-lining of sewer mains from the Sewer Main Repair trigger for lateral testing
and repair if permitted by the Consent Decree or as may be re-negotiated with
River Watch.
Discussion
The adoption of Ordinance No. 1091 created the City of Ukiah's Sewer Lateral
Testing and Inspection Program. The provisions of this ordinance requires that all
sewer laterals connected to the public sewer shall be cleaned and tested in
accordance with the provisions of the ordinance upon the occurrence of any one
of seven specific events which are as follows:
1. Application for a new connection to the sewer collection system; or
2. Application for a building permit for a remodel on the property served
where the cost of the improvements exceeds $50,000 in 2007 dollars and
adjusted every yaer for inflation, the inflation adjustment to be prescribed
by resolution of the City Council; or
3. Application for a building permit or plumbing permit to install additional
toilet facilities on the property served; or
4. Application for a change of use on the property served from residential to
commercial, or from non-restaurant commercial to restaurant commercial;
or
5. In conjunction with a change of ownership of property served and prior to
the recordation of any deed or other conveyance document; or
6. In conjunction with any repair or replacement of the main sewer to which
the sewer lateral is connected; or
7. The determination of the Director of Public Utilities that the cleaning and
testing is required for the protection of the public health, safety, and
welfare.
This discussion item pertains to the requirements for sewer lateral cleaning and
inspection when the sewer main to which the lateral is connected is repaired or
replaced.
Section 3799.6 of Section 18, Division 4, Chapter 2 of the Ukiah Municipal Code
created by Ordinance No. 1091, sets forth the testing procedures and
requirements for repair for sewer laterals upon the repair or replacement of the
public sewer main or upon the determination of the Director of Public Utilities if
the public welfare and safety requires the testing. Should the lateral fail the test,
the property owner is responsible for the repair or replacement of the sewer
lateral and the work must be completed within six (6) months from the date of the
test unless an extension of time, not exceeding 90 days, is granted for good
cause. If the repair is not completed within the required time limit including any
authorized time extensions, the City shall complete the required repairs at the
owner's expense. Reimbursement to the City may be accomplished through the
addition of a surcharge to the monthly utility bill until the repair costs are
recovered in not more than five (5) years. The City Council may by Resolution
prescribe alternative procedures by which the repair or replacement work shall
be performed including the degree to which the City shall offer to perform all or a
portion of the work or contribute towards the cost of the sewer lateral work.
The term repair is not defined within the ordinance and what constitutes repair
has been debated by staff. There is a general consensus that re-lining the sewer
main constitutes repair and all laterals connected to that portion of the sewer
main so repaired would be required to be cleaned and tested. However, it has
been questioned if this was the intent of the authors of the provisions of the
ordinance. Some staff members have opined that the repair trigger was intended
to apply to the situation where the sewer wye within the main is repaired.
The consequences arising from the requirement that sewer laterals connected to
a sewer main which is being repaired or rehabilitated under a public works
contract must be cleaned and tested is similar to the consequences that would
result under a geographical approach to the testing and inspection of sewer
laterals. Both occurrences are beyond the control of the affected property
owners. The cost to clean and inspect the sewer lateral and the cost of any
required repair is to be-borne by the property owner. The cost to clean and
inspect is ranging from $400 to $600 for most cases and a potential sewer lateral
repair/replacement can cost between $4,000 to $8,000 depending upon the
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extent of the repair/replacement and the amount of site and public improvements
to be replaced. Upon the failure of a sewer lateral test, the repairs of the sewer
lateral to be completed within 6 months from the date of inspection and there is
concern that this requirement may place an unanticipated financial burden on
many property owners.
The City has budgeted $225,000 for fiscal year 06/07 for sewer system
improvements and repair under account 612-3510-810. Technical Specifications
for the re-lining of the sewer main in Clay Street from State Street to Highland
Ave have been prepared and posted for public review. Staff has delayed
submitting the contemplated public works project to the City Council for approval
to advertise for bids because of the resulting consequences in regards to the
requirement that all sewer laterals connected to the repaired sewer main must be
cleaned and tested. Staff is recommending that the sewer main repair provisions
of Ordinance No. 1091 be discussed and consideration be given to re-defining
sewer main repair that best serves the public interest or, pursuant to the
provisions of said Section 3799.6 of the Ukiah Municipal Code, consider the
adoption of a Resolution setting forth the City's participation in the cost to test
and repair the sewer lateral connected to the sewer main scheduled for repair.
At their regular meeting of April 25, 2007, the Ukiah Valley Sanitation District
Board of Directors approved the establishment of a test area within which the
sewer laterals connected to the District's sewer main would be inspected and
tested for the purpose of identifying issues and for quantifying potential repairs
and associated costs for repair that may arise if a geographical approach to the
enforcement of the inspection and testing provisions of the District's Sewer
Lateral Inspection and Testing Ordinance were implemented. The testing and
inspection of the sewer laterals and main will be accomplished under a public
work contract. Staff will develop the Technical Specifications and bid documents.
The Board approved an expenditure level not to exceed $26,000 and directed
staff to select two locations within the District for possible selection. The public
work project will potentially be completed the month of June. The resulting test
information will be shared with the City of Ukiah.
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