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City of San Leandro Sewer System Management Plan Volume I 3. The City shall take all feasible steps to eliminate SSOs. In the event that an SSO does occur, the City shall take all feasible steps to contain and mitigate the impacts of an SSO. 4. In the event of an SSO, the City shall take all feasible steps to prevent untreated or partially treated wastewater from discharging from storm drains into 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 City'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: a. The City has complied with the requirements of Order No. 2006-0003, including requirements for reporting, developing and implementing an SSMP; b. The City can identify the cause or likely cause of the discharge event; c. 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 alternatives if the City does not implement a periodic or continuing process to identify and correct problems. d. The discharge was exceptional, unintentional, temporary, and caused by factors beyond the reasonable control of The City; e. The discharge could have been prevented by the exercise of reasonable control described in a certified SSMP for: i. Proper management, operation and maintenance; ii. 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 (I/I), etc.); iii. Preventative maintenance (including cleaning and fats, oils, and grease (FOG) control); iv. Installation of adequate backup equipment; and v. Inflow and infiltration prevention and control to the extent practicable. f. The sanitary sewer system design capacity is appropriate to reasonably prevent SSOs. ~~~e ~