Lawrence Berkeley National Laboratory
P a g e | ix-2 Sewer System Management Plan
ix-a. Maintain relevant information to prioritize SSMP activities
Requirement: The Enrollee shall maintain relevant information that can be used to establish and prioritize appropriate SSMP activities.
Discussion
The LBNL Facilities Division and EH&S Division maintain records and documentation of sanitary sewer collection system management, operation, and maintenance activities in various forms for the purpose of SSMP program performance evaluation and SSMP auditing. A summary of the documentation maintained for the SSMP is provided below.
Policy Document Updates
A record of revisions is maintained for all major policy documents, to keep track of changes to LBNL and DOE policies and procedures, as well as changes to regulatory requirements which are addressed by the documents.
Mapping System Updates
As discussed in SSMP section iv-a, the Facilities Division maintains a map revision block for each utility grid map that is used to document map updates resulting from additions or revisions based on observations by LBNL staff or contracted utility surveys.
Sanitary Sewer Collection System Operation and Maintenance Activity Tracking and Documentation
As discussed in SSMP section iv-b, the Facilities Division uses a sewer system Asset Database to document the completion of regular preventative maintenance work such as hydroflushing, CCTV inspection, and root control. The Asset Database is also used to document SSOs, blockages, system repairs, or other notable occurrences. The Asset Database can be used to review the maintenance history of any individual asset, and set and track maintenance
frequencies. In addition to the Asset Database, the Facilities Division maintains a hard copy file of all invoices and work orders provided by contractors who perform sanitary sewer collection system maintenance activities.
CCTV Inspection Data
The Facilities Division receives standard NASSCO PACP and MACP reports from contractors performing condition assessment of the sanitary sewer collection system, as well as digital pictures and videos for each inspection. The Facilities Division enters quick rating information into the Asset Database for the initial prioritization of potential capital improvement projects, and maintains an electronic file structure to store the condition assessment data which is reviewed in detail to determine appropriate asset repair or replacement methods.
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-3 Sewer System Management Plan
Sanitary Sewer Collection System Project Call List
The Asset Database is used to store a summary of condition assessment results (in the form of NASSCO quick ratings), and is a platform for planning sanitary sewer collection system capital improvement projects. The Asset Database stores priority rankings for identified repair or replacement projects, and is used to identify potential Project Call List items, which are presented by the Facilities Division to the Chief Operating Officer for approval.
Training
LBNL uses its JHA program to establish EH&S training schedules and document completed training using an online database for all LNBL personnel.
SSO Response
LBNL maintains records of all SSO events in compliance with the requirements of MRP No. 2006-0003-DWQ, which include:
a. All Certified SSO reports, as submitted through CIWQS
b. All original recordings for continuous monitoring instrumentation:
o Any available records from the Strawberry and Hearst sewer outfall monitoring
stations, as well as information available from UC Berkeley Strawberry Creek water quality monitoring stations is obtained and documented in the event of an SSO.
c. Service call records and complaint logs:
o All un-planned work in response to identified sanitary sewer collection system
deficiencies is documented in the Asset Database.
d. SSO calls (as documented in standard Occurrence Reports)
e. SSO records (as documented in standard Occurrence Reports)
f. Steps that have been and will be taken to prevent the SSO from recurring and a schedule
to implement those steps (as documented in standard Occurrence Reports)
g. Work Orders, work completed, and any other maintenance records from the previous 5
years which are associated with responses and investigations of system problems related to SSOs:
o Documented within the Asset Database
h. A list and description of complaints from the previous 5 years:
o Documented within the Asset Database
i. Documentation of performance and implementation measures for the previous 5 years
o Documented through the PI tracking process
FOG Control Program
The Facilities Division tracks and maintains records of maintenance activities for the LBNL cafeteria grease interceptor by subcontractors (in the form of invoices and work orders) to ensure that excessive amounts of FOG are not discharged to the LBNL sanitary sewer collection system.
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-4 Sewer System Management Plan Additionally, the results of regular inspections of the food preparation facility by cafeteria management to ensure the implementation of FOG disposal BMPs are documented using inspection checklists, and are kept by the Facilities Division.
Sanitary Sewer Collection System Capacity Assessments
The results of sanitary sewer collection system capacity assessments are documented within the analysis and technical reports produced either internally by Facilities Division staff or
engineering contractors.
Performance Evaluations and SSMP Audits
The results of performance criteria reviews are published in official ECAAP reports, which are
made available and maintained for a minimum of 5 years.
Related Documents
None.
Plan & Schedule
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-5 Sewer System Management Plan
ix-b. Monitor and measure effectiveness of SSMP elements
Requirement: The Enrollee shall monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP.
Discussion
The LBNL Facilities Division and EH&S Division are responsible for assessing the success of sanitary sewer collection system management, operation, and maintenance activities, and refining those activities if they are not successful in minimizing the occurrence of SSOs.
LBNL Performance Evaluation Process and Procedures
Clause H.14 of Contract 31 requires that the LBNL implement a “performance-based
management approach which will include the use of objective performance goals and indicators, agreed to in advance of each evaluation period, as standards against which the LBNL’s overall performance of the scientific and technical mission obligations under this contract will be
assessed”. LBNL already has in place several documents that describe how specific performance measures and goals are established and how performance against the measures and goals is assessed. The major documents governing the process of performance evaluation and auditing include the following:
Performance Evaluation and Measurement Plan (PEMP)
EH&S Self-Assessment Program
EH&S Division Self-Assessment Manual
Environmental Compliance Audit & Assessment Program (ECAAP) Manual
Performance Evaluation and Measurement Plan
The Performance Evaluation and Measurement Plan (PEMP) is the key metric by which the
effectiveness of LBNL’s “performance-based management approach” is evaluated. The PEMP
measures performance according to 8 core goals which have been established by the DOE Office of Sciences, which are applied to all other DOE national laboratories as well. Goals 1-3 relate to the accomplishment of overall research and technological missions, and performance measures specific to those goals are established by DOE. Core goals 4-8 relate to management and
operation of LBNL facilities in support of goals 1-3, and performance measures specific to those goals are established cooperatively by UC, DOE, and LBNL functional managers. Proper execution of the SSMP could be related to goals 5 and 7, as stated below:
Goal 5: Sustain excellence and enhance effectiveness of integrated safety, health, and
environmental protection. (This goal evaluates EH&S procedures)
Goal 7: Sustain excellence in operating, maintaining, and renewing the facility and
infrastructure portfolio to meet Laboratory needs. (This goal evaluates Facility Management Procedures)
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-6 Sewer System Management Plan For each of the 8 main goals, several more specific subordinate goals are established which relate to accomplishment of the main goal. The subordinate goals may change from year to year based on the collaboration of UC, DOE, and LBNL functional managers. A quantifiable grading metric is developed for each separate subordinate goal to establish a letter grade. The
subordinate goals are individually weighted to allow for the calculation of a single letter grade for each of the main goals. The main goals are also weighted to allow for an overall LBNL performance grade to be calculated.
With respect to the 8 main PEMP goals, goal 5 relates to environmental compliance (i.e. prevention of SSOs), which is a responsibility of the EH&S Division, and goal 7 relates to infrastructure management (i.e. sanitary sewer collection system operation, maintenance, and capital improvements). It is unlikely that performance measurement and evaluation of SSMP programs would be directly incorporated into the PEMP as subordinate goals to main goals 5 and 7, and more likely that the completion of SSMP objectives would be incorporated into more overarching measurements such as: the completion percentage of an established list of new key environmental management programs, or integration of sanitary sewer collection system
maintenance and capital costs into measurements of overall infrastructure cost trends (examples only). Often, subordinate goals and grading metrics for those goals are established based on key issues identified in Division Self Assessment Programs.
Self Assessment Programs
Each LBNL division is responsible for developing and implementing their own Integrated Safety
Management (ISM) Plan which details the work and research that is to be completed by the division and defines hazards and safety practices that must be followed to reduce the risk to employees, the public, and the environment. The Self Assessment Program was implemented as a way for each division to evaluate the work that is being completed, make continuous
improvements to processes and procedures, and evaluated work practices set forth in each
division’s ISM Plan.
The Environment, Safety, and Health Self-Assessment Program was developed by the DOE Office of Contract Assurance (OCA) to define the methods by which performance of EH&S activities and operations are measured. Three methods are established, which include:
1.Division Self Assessment
2.Environmental Compliance and Audit Assessment
3.Contract 31 Appendix B Self Assessments (PEMP)
The Division EH&S Self Assessment Manual is a guide for conducting the self assessment referred to in item 1 above. OCA typically works with functional managers to establish performance measures for the Division Self Assessment. The performance measures typically focus on the implementation of programs designed to ensure safe work practices and compliance with applicable Federal, State, and local regulatory requirements. The Division Self Assessment
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-7 Sewer System Management Plan is conducted annually, and a report is made to OCA. The annual EH&S Self Assessment Report
may address significant elements identified under the Environmental Compliance Audit and
Assessment Plan (ECAAP).
The ECAAP focuses on ensuring that environmental programs and processes comply with guiding regulations. The EH&S Division, working with OCA, establishes a 3-year rotating schedule to evaluate significant EH&S programs that are identified using a risk-based analysis
conducted by OCA. Currently, the ECAAP has established 9 categories that are audited, one of
which includes wastewater discharges. At least one of the 9 categories will be reviewed each quarter, and each category will be audited a minimum of once every 3 years. As part of the 2009 ECAAP program, wastewater discharges are slated for auditing in the fourth quarter of 2009, and will be audited again within 3 years. ECAAP audits are performed by a subject matter expert, an LBNL peer, or an environmental consultant who is knowledgeable about the environmental regulations and requirements that are being audited. The purpose of ECAAP audits is to ensure that environmental issues, risks, and impacts are being properly identified, controlled, and corrected.
The results of ECAAP or other EH&S program assessments may be tracked in the Corrective
Action Tracking System (CATS) Database. The CATS database is used to track compliance issues and corrective actions that have been identified to address those issues.
Integration of Performance Indicator Tracking for the SSMP
The requirement to monitor the implementation and measure the effectiveness of each element of the SSMP will be integrated into the existing LBNL performance-based management approach described above.
Compliance with the GWDRs (SWRCB Order No. 2006-0003) is tied closely to the Wastewater Discharge Program, since the primary objective of the SSMP is to minimize the occurrence of prohibited SSOs. Therefore, the tracking of SSMP performance criteria will be accomplished in conjunction with the Wastewater Discharge Program assessment conducted in accordance with the ECAAP. A performance criteria worksheet will be developed which includes metrics by which the performance of SSMP programs can be measured, similar to the methodology used in
the PEMP. The performance criteria worksheet will be included with ECAAP assessments of the
Wastewater Discharge Program.
Description of SSMP Performance Criteria Tracking Methods
The LBNL EH&S Division has assigned the SSO Program Manager as the “responsible person” (RP) for tracking performance against the established measures by periodically reviewing the applicable data maintained by LBNL with regard to the sanitary sewer collection system. An ECAAP tracking worksheet has been developed for elements of the SSMP for which both the Facilities Division and EH&S Division have responsibilities.
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-8 Sewer System Management Plan The ECAAP worksheet describes various criteria that will be tracked and evaluated relative to a specific SSMP program. The responsible person for the assessment is identified. A description of the criteria used in the analysis, including where the information is stored and how to use the information to rate performance compared to established performance criteria, is given. The SSO Program Manager then makes SSMP program modification recommendations within the
ECAAP report, which are intended to increase future ratings to at least acceptable levels, if applicable. Any significant deficiencies in performance that are identified may be entered into
the CATS database for corrective action and tracking purposes.
Frequency of ECAAP Completion
The SSO Program Manager will prepare the ECAAP worksheet, and it will be integrated into the
Wastewater Discharge Program ECAAP assessment at the time it is conducted. An ECAAP
report will be completed and submitted to the Environmental Manager and the Utilities Manager.
Related Documents
o Refer to LBNL Performance Evaluation and Measurement Plan FY2008 Self Assessment
Report
http://www.lbl.gov/DIR/OIA/OCA/contract-performance/index.html
o Refer to LBNL EH&S Self-Assessment Program (Latest Revision)
http://www.lbl.gov/DIR/OIA/assets/docs/OCA/OCA_ESH/PUB%205344%20Rev%207 %20draft%201.16.09_%20FINAL.pdf
o Refer to LBNL EH&S Self-Assessment Manual (Latest Revision)
http://www.lbl.gov/DIR/OIA/assets/docs/OCA/OCA_ESH/SA%20manual3105Rev5final .pdf
o Refer to LBNL Environmental Compliance Audit & Assessment Program Manual
(Latest Revision)
http://www.lbl.gov/ehs/esg/EMS%20Plan/assets/ECAAP_0309.pdf
o Refer to the LBNL Corrective Action Tracking System (CATS) Primer / Database
http://eetd.lbl.gov/ehs/docs/cats-primer-eetd.pdf
Plan & Schedule
Task Responsible Party Scheduled Date
Incorporate SSMP performance criteria into the ECAAP wastewater program assessment worksheet.
SSO Program Manager As Scheduled
Under the ECAAP
Prepare ECAAP report; provide information to
Environmental Manager and Utilities Manager.
SSO Program Manager As Scheduled
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-9 Sewer System Management Plan
ix-c. Assess success of preventative maintenance program
Requirement: The Enrollee shall assess the success of the preventative maintenance program.
Discussion
Specific performance criteria will be developed for key SSMP programs and elements for which ongoing activities are occurring. Performance objectives and the metrics used to evaluate performance against those objectives may be changed by the Utilities Manager and
Environmental Manager. The performance indicators established for the first year of SSMP implementation are listed below:
Table ix-1: SSMP Performance Indicators
SSMP Element Responsible Person Performance Indicator
Establishment of sewer system pipeline asset entries in the new Asset Database.
Establishment of sewer system manhole asset entries in the new Asset Database.
Entry of critical asset data in the new Asset Database.
iv – Mapping Utilities Manager
Completion of AutoCAD map quality assurance. Establishment of asset-specific maintenance frequencies.
Success of establishing an average annual sewer system maintenance cost within budget.
iv- O&M Program Utilities Manager
Percentage of sewer pipe assets with overdue regular maintenance.
Percentage of sewer collection system that has been CCTV inspected within the last 10 years. Average overall NASSCO quick rating for the sewer collection system.
iv– Capital Improvement
Program Utilities Manager
Prioritization and planning for future capital improvement projects.
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-10 Sewer System Management Plan
Table ix-1: SSMP Performance Indicators (Continued)
SSMP Element Responsible Person Performance Indicator
Number of sewer system blockages or un-planned maintenance activities (non-SSO).
Number of Category 2 SSOs. Number of Category 1 SSOs.
Average response time for SSOs during normal business hours.
vi – SSO Response Environmental Manager
Average response time for SSOs after normal business hours.
Initial FOG control practices implementation meeting held.
Review and modification of cafeteria operation services contract for FOG control BMP implementation.
vii – FOG Control Program
Utilities Manager
Success of implementation of FOG disposal BMPs by cafeteria staff.
Determination of maximum hydraulic capacity in key sewer trunk lines.
Determination of existing peak flow in key sewer main lines.
Identification of necessary hydraulic capacity improvements.
viii – System Evaluation
and Capacity Assurance Utilities Manager
Determination of existing GWI/I and RDI/I levels in the system.
Related Documents
o Refer to Waste Water Discharge Program ECAAP worksheet.
Plan & Schedule
Task Responsible Party Scheduled Date
Review and update evaluation criteria within
ECAAP, based on past performance and changing SSMP goals or requirements.
Element ix. Monitoring, Measurement and Program Modifications
Lawrence Berkeley National Laboratory
P a g e | ix-11 Sewer System Management Plan
ix-d. Update SSMP program elements based on performance evaluations
Requirement: The Enrollee shall update program elements, as appropriate, based on monitoring or performance evaluations.
Discussion
The Facilities Division and EH&S Division are responsible for updating the SSMP based on the
results of program performance evaluations using the ECAAP process. The process for updating
the SSMP generally follows the subsequent procedure that is completed as part of the SSMP audit process (refer to SSMP section x):
1. Responsible persons annually review the performance criteria they have charge over,