Attch. 20 SOUTH BAY SPILL PREVENTION AND RESPONSE PLAN October 2024.pdf

Spill and Transboundary Flow Event Prevention & Response Plan

United States International Boundary and Water Commission

South Bay International Wastewater Treatment Plant

Prepared by:

Veolia &

USIBWC

October 1, 2024

Table of Contents

I. INTRODUCTION

a. GOALS AND DESIRED OUTCOMES

b. DEFINITIONS

c. AREA PHOTOGRAPH

d. ROLES AND RESPONSIBILITIES

e. COMMUNICATIONS AND COORDINATION WITH STAKEHOLDERS

II. PREVENTION PLAN

a. SBIWTP

1. INSPECTIONS OF SBIWTP

2. PREVENTATIVE MAINTENANCE OF SBIWTP

b. CANYON COLLECTORS

1. DAILY INSPECTIONS OF CANYON COLLECTORS

2. PREVENTATIVE MAINTENANCE OF CANYON COLLECTORS

3. INSPECTIONS OF CANYON COLLECTORS DURING EMERGENCY CONDITIONS

i. RAIN EVENT

ii. DRY WEATHER TRANBOUNDARY FLOW

4. MAINTENANCE OF COLLECTORS AFTER WET WEATHER

5. OTHER PREVENTION MEASURES:

i. EQUIPMENT

ii. SANDBAGS

iii. TRASH NOTIFICATION PROTOCOL

c. TRAINING

III. RESPONSE PLAN

A. INITIAL RESPONSE PROCEDURES

B. AFTER SPILL ENDS

C. SPILL CLEANUP

D. STEWART’S DRAIN

E. NOTIFICATION AND REPORTING

IV. PLAN IMPLEMENTATION

1. PLAN AMENDMENT

2. POSTING

3. RECORD KEEPING – LOG MAINTENANCE AND RETENTION OF RECORDS

APPENDICES

Appendix A Plan Points of Contact

Appendix B SBIWTP Flow Diagram and Design Capacities

Appendix C Canyon Collectors Description

Appendix D Canyon Collectors Daily Inspection Checklist and SOP

Appendix E Trash Accumulation Communications Protocol

Appendix F Stewart’s Drain Prevention and Response Plan

Appendix G Spill & Transboundary Flow Report and SOP

I. INTRODUCTION

The South Bay International Wastewater Treatment Plant (“SBIWTP”) is a 25‐million gallon per day (“MGD”) secondary treatment plant that treats wastewater collected within the City of Tijuana, Mexico and discharges the treated wastewater to the Pacific Ocean through the South Bay Ocean Outfall. The sewer collection system, located in Mexico, is maintained by the Comisión Estatal de Servicios Públicos (CESPT) de Tijuana in the City of Tijuana (“City”).

Wastewater collected within Tijuana is received by Sewer Pump Stations #1A B, located within the Cit of Tijuanay. By US/Mexico treaty conditions, a 30-day average of 25 MGD is sent to the SBIWTP, with the remainder being conveyed by Pump Station 1A and 1B to San Antonio de los Buenos, located approximately six (6) Miles south of the US/Mexico border. Conveyance is through a force main and gravity pipeline.

Surface releases of wastewater within Mexico are considered potential sources for contamination of waterways and land areas within the United States. By design, canyon collector structures were erected on the United States side of the US/Mexico border to capture low volume flows in dry weather. During wet weather events, canyon collectors do not operate resulting in transboundary flows leading to the Tijuana River channel and estuary. Canyon collectors are referred to by name as Stewart’s Drain, Silva Drain, Canyon Del Sol, Smuggler’s Gulch Collector, and Goat Canyon collector.

Per California Regional Water Quality Control Board – San Diego Region (“RWQCB”), Order No. R9-2021-0001 as amended by R9-2023-0009 (“Permit”), Section 6.3.2.1.2, this Spill and Transboundary Flow Event Prevention and Response Plan (“Plan”) is required as a comprehensive approach to the reduction, elimination, and prevention of the recurrence of spill and transboundary flows events, the protection of public health and safety, and the prevention of adverse impacts to the environment from spill and transboundary flow events, including but not limited to, adverse impacts to waters of the U.S. and/or State.

This Plan is specifically focused on spills originating from the SBIWTP and certain transboundary flows through the canyon collectors that could potentially reach the Tijuana River facilities.

a. GOALS AND DESIRED OUTCOMES

Pursuant to Permit Section 6.3.2.1.2.1, the goals of the Plan are to:

• Reduce, eliminate, prevent the recurrence of spill and transboundary flow events;

• Protect public health and safety; and

• Prevent adverse impacts to the environment from Spill and Transboundary Flow Events, including but not limited to, adverse impact to waters of the United States and/or State of California.

Pursuant to Permit Section 6.3.2.1.2.2, the desired outcomes of the Plan are to:

• Provide for prompt notification and reporting of Spill Events and Tijuana River Transboundary Flow Events to appropriate regulatory agencies, municipalities, and other potentially affected Stakeholder entities;

• Provide effective implementation measures to prevent, reduce, and eliminate Spill and dry weather canyon collector Transboundary Flow Events;

• Provide effective remedial measures for implementation to (a) control or limit Spill Events,

(b) Terminate Spill Events, and (c) recover as much Spill volume as possible for proper disposal, including any wash down water; and

• Provide a framework for achieving and implementing the goals and desired outcomes of the Plan.

b. DEFINITIONS

Canyon collector. A canyon collector is a concrete structure designed to detain the low-volume, dry-weather flow from surface runoff and spilled wastewater flows in Mexico. The flow is redirected to an intake and through gravity flow or a force main pipeline to the headworks of the SBIWTP.

Discharger. The Discharger as it pertains to the Permit is the Owner of the SBIWTP, which is the International Boundary and Water Commission United States Section (“USIBWC”).

However, there are several functional roles within the Permit, which the Operator of the facility, USIBWC’s designee, has the responsibility to complete via contract. The Operator at the time this Plan was finalized is Veolia Water West Operating Services, Inc (“Veolia”). This Plan will distinguish between the responsibilities of the “Owner” or “ USIBWC” and of the contracted “Operator” or “Veolia.”

Facility. The formal definition of Facility is located at page A-9 of the Permit. For practical purposes, “Facility” means:

- SBIWTP

- Five canyon collectors

- Hollister Street Pump Station

- Goat Canyon Pump Station

- Junction Box 1

- Junction Box 2

- South Bay Land Outfall (“SBLO”)

- South Bay Ocean Outfall (“SBOO”)

- Other associated infrastructure such as the pipes and conveyances between the canyon collectors, pump stations, and the SBIWTP.

International Boundary and Water Commission (“IBWC”). IBWC is an international organization comprised of a Mexican section (CILA) and a United States section (USIBWC).

Operator. Veolia Water West Operating Services, Inc. is the contracted Operator of the Facility.

San Antonio de los Buenos Wastewater Treatment Plant (“SABWWTP”). The wastewater treatment plant located in Tijuana, Mexico.

South Bay International Wastewater Treatment Plant. SBIWTP is a 25 million gallon per day secondary wastewater treatment facility located in San Diego, California which treats wastewater originating in Tijuana, Mexico.

Spill Event. A discharge, or any other type of emission or release, of waste from the Facility due to system overflow, flow stoppage, system leaks and breaks, operational failure and/or infrastructure failure. The discharge of waste from the Facility, after it was initially captured or is under the control of the Facility, is a Spill Event. The definition of a Spill Event includes dry weather transboundary flows that are less than or equal to the maximum design capacity of a canyon collector but that are not diverted for the treatment by the canyon collector. A Spill Event does not include (1) wet weather flows that bypass the canyon collectors or (2) any portion of dry weather flows which exceed the maximum design capacity of the canyon collector and are not diverted by the canyon collector.

Tijuana River Transboundary Flow Event. Any flow across the U.S./Mexico international border, under dry or wet weather conditions, into the Tijuana River. This Plan does not address prevention or response to Tijuana River transboundary flow events.

Canyon collector Transboundary Flow Event. Any flow across the U.S./Mexico international border under dry or wet weather conditions to any one of the five canyons equipped with a canyon collector system, including Smuggler’s Gulch, Goat Canyon, Canyon del Sol, Stewart’s Drain, or Silva Drain, that is not captured by the canyon collector system for treatment at the

SBIWTP.

Other Canyon Transboundary Flow Event. Any flow across the U.S./Mexico international border, under dry or wet weather conditions, at any transboundary canyon in the Tijuana River Valley that is not equipped with a canyon collector system, including but not limited to Yogurt Canyon. This Plan does not address prevention or response to Other Canyon Transboundary Flow Events. To the extent that USIBWC becomes aware of other canyon transboundary flow events while operating and maintaining its facilities, it may in its discretion employ the procedures outlined in this Plan in response to those events.

Additional definitions. Additional definitions can be found within Attachment A – Abbreviation and Definitions of the California Regional Water Quality Control Board – San Diego Region, Order No. R9-2021-0001 as amended by R9-2023-0009.

c. AREA PHOTOGRAPH

d. ROLES AND RESPONSIBILITIES

The roles and responsibilities for the development and implementation of the Plan and lines of authority, as well as points of contact and position descriptions, are clearly defined and are listed within Appendix A of this Plan.

e. COMMUNICATION AND COORDINATION WITH INTERESTED STAKEHOLDERS

USIBWC will coordinate and communicate with interested stakeholders through regular meetings and written and/or oral communication to:

• Develop procedures for reducing, eliminating, and preventing recurrence of Spill Events resulting from emergency or unanticipated outages of wastewater infrastructure;

• Develop emergency response and notification procedures for loss of wastewater infrastructure capacity;

• Review existing plans, specifications, and reports of key wastewater infrastructure; and

• Maintain Stakeholder awareness of overall water quality status and issues.

Communications framework and protocols include:

• Disseminate Spill and Transboundary Flow Reports upon initiation and conclusion of events for stakeholder awareness and implementation of appropriate prevention and response measures. Stakeholders include RWQCB, U.S. Customs and Border Protection, federal, state and local government officials, and community members.

• Provide Twitter notifications to supplement dissemination of Spill and Transboundary Flow

Reports and reach additional interested stakeholders.

• Conduct Citizens’ Forum meetings three times per year to inform stakeholders of initiatives, actions, and technical issues related to water quality.

• Conduct regular bi-national meetings between USIBWC, CILA, CESPT, and Veolia to discuss the status of wastewater system operations and conditions to include planned maintenance, upgrades, and repairs as necessary to maintain safe and efficient operations.

• Veolia and CESPT operators communicate directly via WhatsApp to ensure the smooth day-to-day operations between the SBIWTP, PBCILA, and PB1.

• USIBWC and CILA communicate almost daily by telephone, email, and WhatsApp for awareness and to ensure all operations and actions are coordinated.

• For ongoing transboundary flows events, USIBWC will request from CILA information on sources of transboundary flows, anticipated duration of flows, and estimated flow rates and volumes as well as efforts to divert or contain flows within Mexico.

• CILA provides regular CESPT Tijuana River survey and inspection results to USIBWC for monitoring purposes and to direct follow up investigations and corrective actions to eliminate dry-weather sources as appropriate.

II. PREVENTION PLAN

a. SBIWTP

1. INSPECTIONS OF SBIWTP:

i. Condition Assessment: Assessing the condition of all SBIWTP facilities is an integral component of facility performance assurance. This assessment is conducted and updated annually. Upcoming repairs and maintenance are highlighted in the annual Condition Assessment Report that is developed. The report provides a rolling 5‐year projection of likely repair and maintenance work.

Factors including equipment/system criticality, results of predictive maintenance analyses, etc. are utilized to provide a priority ranking for identified work. Once recommended repairs are reviewed, funding is pursued to perform the work. If funding limitations preclude performance of some repairs or improvements, then these projects will automatically be included in the following year’s assessment.

ii. The SBIWTP is in 24/7 operation and is monitored continuously through alarms via a Supervisory Control and Data Acquisition (“SCADA”) computer system.

The plant is also regularly checked each shift for conditions of potential failures in pumps, piping, and tanks which may result in a spill event.

iii. All wastewater facilities are inspected visually on a daily basis by operators through round sheet checklists.

iv. Veolia maintains a list of planned maintenance for all structures and equipment through a computer program, the Veolia Asset Management System (“VAMS”), which schedules planned and unplanned maintenance throughout the plant.

2. PREVENTATIVE MAINTENANCE AT SBIWTP:

i. A program for routine and regular inspections and preventative maintenance, as well as schedules for rehabilitation and replacement of wastewater system components, including canyon collectors, is established and documented in Veolia’s existing and current Asset Management Plan, Annual Condition Assessment Reports, and the VAMS Maintenance Program.

• Asset Management Plan – This Plan shall identify and prioritize upcoming asset rehabilitation and replacement projects valued at greater than $5,000 including schedules for completion; identify maintenance activities and frequencies performed;

identify requirements and recommendations for critical spare components and inventory of those components; and provide a SBIWTP system map identifying piping, pump stations, sewer lines, or other conveyances associated with the SBIWTP to identify maintenance and rehabilitation priorities.

• Annual Condition Assessment – This assessment allows identification, warranty repairs, and maintenance/replacement prioritization of facility assets based on assets’ condition. The assessment provides a condition rating that facilitates prioritizing corrective work orders, long-range planning, Capital and Maintenance Budget planning, and contracts’ renewal.

• VAMS Maintenance Program - VAMS is a web-based maintenance management system that provides cost and workflow tracking, physical and financial condition of assets, identification of critical assets and schedules for preventative maintenance, life-cycle costs for costs control and budgeting, and capital planning.

See Appendix B for flow diagrams and design capacities for the SBIWTP.

b. CANYON COLLECTORS

1. DAILY INSPECTIONS OF CANYON COLLECTORS: Canyon collectors are inspected at least once daily, or more if necessary. The inspections are to identify flows, trash accumulation, needs for routine maintenance, and vandalism. The collectors are designed to divert transboundary flows up to certain capacities. The intent of the daily inspections is to ensure that the canyon collectors are operating properly and capable of functioning at their design capacity. The collectors are described in Appendix C and identified as follows:

• Stewart’s Drain

• Silva Drain

• Canyon del Sol

• Smugglers Gulch

• Goat Canyon

Daily inspections of each canyon collector are required. Each inspection is documented by completion of the daily inspection form for that specific collector using the MobileMMS smartphone app. The daily inspection form and standard procedures for completion are included as Appendix D. A monthly summary report of the daily inspection reports are provided to Regional Water Quality Control Board (“RWQCB”) through the California Integrated Water Quality System (“CIWQS”). Daily inspection reports are made available upon request.

Daily inspection reports from MobileMMS are emailed daily to Veolia and USIBWC staff for monitoring and further prevention and response plans and actions as necessary. The USIBWC submits these reports to the CIWQS database on a monthly basis for reference with specific daily reports available upon request. See Attachment D for the canyon collector Daily Inspection Form and instructions on filling out the form.

The collector standard operating procedures are reviewed annually and updated as needed.

The most current versions are provided for ready reference in the Operator’s Administration Building Operations’ Control Room. As of the writing of this Plan, the most current procedure was updated on September 24, 2024 and is included as Appendix D.

2. PREVENTATIVE MAINTENANCE OF CANYON COLLECTORS:

i. During the dry weather months of April through October, the canyon collector structures shall be cleaned of debris as necessary to ensure that dry weather sewage flows are captured. During the wet weather months of November through March, the canyon collector structures shall be cleaned and put back into service within forty-eight (48) hours of the end of each rainfall event provided that it is safe and reasonably practical. In addition, the sand/grit interceptors at the canyon collectors shall be cleaned as necessary to ensure proper operation.

ii. During or immediately prior to rain events, the isolation valve at the Goat and Smuggler’s Gulch canyon collectors are shut to prevent storm water from entering. The other three canyon collectors do not have isolation valves.

iii. In response to observations during a daily inspection, the following maintenance should be performed as necessary, conditions permitting, to ensure that canyon collectors are capable of processing design flows:

1. Removal of trash and debris. Debris and trash should be removed from the collector as necessary such that the collector intake screen is capable of receiving volumes up to its design capacity. If moderate levels of trash are noted during a daily inspection, the collector should be cleaned within 1 week of the daily inspection report noting moderate trash levels. Collection of accumulated trash, garbage, sand, rocks and miscellaneous debris shall be removed from the collector within 7 calendar days of each cleaning event, provided that it is safe and reasonably practical.

2. Removal of sediment. Sediment accumulated within the collector structure that reduces the containment capacity of the collector shall be moved to a location in the collector’s footprint that does not interfere with collector operation and shall be allowed to dry for a period of up to 7 days. Sediment shall be removed from the collector area within 7 days.

3. Upstream Trash. Upon notification of trash buildup upstream of the canyon collectors, either by daily inspection reports or direct notification by Veolia staff or others, USIBWC shall notify Mexican authorities and/or U.S. Customs and Border Protection to coordinate the trash removal. USIBWC’s communications regarding upstream trash build-up should follow the protocol attached as Appendix E.

4. Sandbags. The Operator will maintain sandbags on the canyon collector weirs during the dry season to increase containment capacity and will replace sandbags as soon as reasonably practicable after they wash out or are damaged.

3. INSPECTIONS OF CANYON COLLECTORS DURING EMERGENCY CONDITIONS:

a. DRY WEATHER TRANSBOUNDARY FLOW: If a large dry weather transboundary flow is anticipated or if water flows past a collector’s terminal weir during dry weather conditions, the operator shall make hourly trips out to the collector and complete an inspection form for each visit. During each visit, the intake screen shall be cleaned to prevent any overflow, but only if it is safe and reasonably practicable. If high flows or high amounts of debris are being experienced, additional Veolia staff or contractor assistance may be needed.

Example. An operator makes the Collector Rounds at 08:00. At approximately 09:00, the inspection rounds have been completed. At 13:00, USIBWC receives a call from Mexico stating they have a problem and will be sending flow to Goat Canyon. USIBWC will notify Veolia and the Operator shall then take another canyon collector daily inspection form using the MobileMMS smartphone app to the Goat Canyon collector and record their findings.

If a dry-weather transboundary flow crests a collector’s terminal weir, samples should be taken from the catch basins and sent for assessment consistent with the water quality parameters outlined in the Permit.

4. MAINTENANCE OF CANYON COLLECTOR AFTER WET WEATHER:

Following Wet Weather Events, open the collector and put it back in service. Ensure the lift stations (Goat and Hollister lift station) are operational. Clear debris blockages and remove accumulated sediment in the canyon collector aprons to restore canyon collector capacity and reinstitute canyon collector operations as soon safe and reasonably practicable.

To restore the collector to maximum capacity after a wet-weather event, the canyon collector intake must be cleared of debris and accumulated sand/silt and blockages within 48 hours of a storm event, but no later than 96 hours after a storm event provided it is safe and reasonably practicable. If such debris or sediment clearing is not possible due to conditions in the collector (i.e., conditions that make it dangerous to clean the collector), such conditions must be noted on the daily canyon collector inspection report, along with photos. If this is the case, the collector must be cleaned/cleared as soon as it is safe and reasonably practicable.

5. OTHER PREVENTION MEASURES

Interior chambers of the collectors must be cleaned of sand and debris as needed. These structures are cleaned to remove any obstructions as soon as safe and reasonably practicable after a wet-weather event or after a routine inspection identifies possible obstructions. Under unusual circumstances, gravity pipelines have also been blocked by material. Pipelines are inspected when there is reason to suspect that they are obstructed based on collector performance.

Cleaning activities are performed with the following:

i. Equipment. The Operator will maintain equipment in a state of operational readiness and will deploy the equipment to mitigate, contain, and/or prevent dry weather canyon collector transboundary flows to the extent practicable.

Equipment includes front‐end loaders, backhoes, vacuum trucks, sandbag fillers, and hand tools. Additional Operations and Maintenance staff will provide supplementary support as needed.

It is within the discretion of the Operator and USIBWC regarding whether to deploy equipment. However, potential uses of equipment following a Spill or Transboundary Flow Event are as follows:

• Front End Loaders: Remove sediment buildup in collectors, construct temporary sediment berms or flow containment, remove stockpiled trash and sediment.

• Mobile Pumps: Provide additional pumping capacity and ability to contain and divert potential and actual transboundary flows.

• Generators: Provide remote power to mobile pumps and other tools.

• Sandbags: Provide sandbags at collector weirs and other locations to provide added containment of flows.

• Velocity Meter: Provides approximate flow rates for determination of transboundary flow volumes and urgency of response actions.

• Vactor Truck: Provides capture and containment of small volumes of spills and flows.

ii. Training The Operator ensures comprehensive response to Spill & Transboundary Flow Events through multilevel training. The Operator provides new hires with intensive training and familiarization and also provided periodic refresher reviews to reinforce initial instruction.

Further details follow.

New Operations and Maintenance Staff. Upon commencement of employment, new operations and maintenance staff are trained on a wide variety of treatment processes and procedures. Included in this training is training specific to the operation of the Facility’s canyon collectors/drains and pump stations. A portion of this training includes:

Review of the following standard operating procedures (“SOPs”):

• Canyon collector Rounds

• Requirements of Spill and Transboundary Prevention and Response Plan

• Spill & Transboundary Flow Event Reporting

• Spill & Transboundary Flow Event Prevention Inspection

• Canyon collector Daily Inspection Form using the MobileMMS smartphone App

• Fork‐Lift Training in the event it may be needed during an event

• On site review of canyon collector/drain and pump station locations, preferred operational methodology, and operational practices and procedures

• Proper completion of inspection logs

• Review of spill notification procedures

Existing Staff. Although staff are initially trained in facility operation/spill response procedures, review and renewal of previous knowledge is essential. Documented annual review of SOPs and other written documentation is required of all staff involved in facility operations and maintenance. Routine reports and inspection logs completed by staff are assessed to ensure that all data entered is accurate and complete. As individual staff may desire, additional training will be repeated upon request.

SOPs and other documents are reviewed annually and updated as necessary to ensure that these critical reference documents are up‐to‐date and reflect the most recent regulatory requirements. Where updates are significant, out of sequence refresher training is conducted.

III. RESPONSE PLAN

Procedures in this Section III should be applied to spills and to dry-weather canyon collector transboundary flow events if the transboundary flow is equal or less than the canyon collector’s maximum design capacity and is not captured by the canyon collector. The Operator and USIBWC should take all feasible steps to 1) prevent the potential for spill and transboundary flow events by adhering to maintenance requirements in this Plan, 2) control or contain the spill or transboundary flow volume, 3) terminate the spill or transboundary flow event, and 4) recover as much of the spill and transboundary flow volume as possible for proper disposal.

A. INITIAL RESPONSE PROCEDURES:

1. Initial Notification: Whether the overflow or spill is within the treatment plant or at one of the canyon collectors, pump stations, or conveyance piping, it is likely the person discovering the overflow will be alone. Therefore, it is extremely important that the person who discovers the overflow is capable of identifying the spill or the transboundary flow past the canyon collectors and notifies their immediate supervisor, or the operator in‐charge at the treatment plant, of the spill or transboundary flow and its location. Notification is the first action that should be taken, regardless of the size, volume, cause, or corrective actions that could be taken. By communicating to other operators that a problem exists, additional support and aid can be sent to the scene. If spill or transboundary flow events are not reported promptly and the operator decides to attempt to halt the overflow, the operator may become injured or incapacitated, resulting in potential continued spill or transboundary flow without aid and assistance from other plant operators. In any emergency event, including a spill and transboundary flow event, the initial response should always be notification by the on-scene Operator to the plant supervisor and USIBWC. For spills or transboundary flows greater than 1000 gallons, initial notification will include Operator contacting CA OES to report the event. For spills or transboundary flows that pose a health risk to the public, post signs or placards warning of hazardous conditions.

2. Investigation & Assessment: After initial notification, an investigation and assessment of the event must be done. An investigation and assessment shall be conducted for all spill and transboundary flow events. USIBWC and the Operator will coordinate in performing all investigations and assessments. The Operator will provide the initial reports, which include flow and volume estimations and times of events. USIBWC will determine the nature and impact of the event, identify the receiving waters, call for additional backup support if needed and notify the appropriate agencies as required under section 6.3.2.1.2.8.1 of the Permit.

This investigation and assessment includes:

o Operator estimates flow rate and volume of the spill or flow and reports estimates to USIBWC through a Draft Spill and Transboundary Flow Report.

o USIBWC, with Operator input, determines the nature/cause of the spill or transboundary flow event, if possible.

o USIBWC monitors impact of the event, including identification of receiving waters that are impacted.

o USIBWC notifies appropriate agencies and stakeholders, as set-forth below.

3. Containment: If the person discovering the spill or transboundary flow has made their initial notification, investigation, and assessment, and they believe it is safe to take further actions, they should attempt to contain the spill or flow. For example, if possible, the spill or flows should be captured and/or directed by ensuring the screens are kept clear to allow flow to the Facility for containment. Operator should establish a means of preventing other people from entering the area of the spill or flow.

As may be determined based on the information presented in the spill and transboundary flow report, the USIBWC or Operator may commission additional sandbags for the weirs at the drain/collectors. In addition, the use of sandbags or containment barriers, alteration of the containment in the downstream storm drains, and plugging the downstream storm drains outlets to capture the spill and/or transboundary flows, will be considered. Lastly, the USIBWC and/or Operator may request excavation of contaminated soils.

4. Halting Overflow: If the operator is not exposed to a hazardous situation and the overflow can be halted by turning on and off a pump (opening or closing a valve or similar operator action), then the operator should take the appropriate action to halt the overflow.

5. Senior Operator/Manager Assume Control: Once assistance has arrived on the scene, the senior operator assumes responsibility and directs all further responses. For example, the response actions may include, but are not limited to: attempting to contain or halt overflow by contacting Mexico and requesting remedial action and maintaining control of access to the scene; estimating volume of overflow and/or flow rate; collecting samples when appropriate; and obtaining any other assistance and/or support as needed. Access restriction and hazard warnings should be posted to inform the general of public of the hazard.

B. AFTER SPILL ENDS: Once the overflow has stopped, the facility component that caused or experienced the spill or transboundary flow should be made operational as soon as reasonably practicable. If the spill or transboundary flow is at a canyon collector, the collector needs to be made operational as soon as reasonably practicable.

C. SPILL CLEAN UP: The Operator coordinates the cleanup of the spill or transboundary flow which may include the following actions:

• Collection of trash, sediment, rocks, and other liquid or solids debris;

• Vacuum truck recovery of wastewater or polluted water and washdown water;

• Cleanup of the impacted storm drains in accordance with NPDES storm water permit;

• The Operator leads the cleanup efforts within the drain/collectors of spill and transboundary flow events.

Whether and how to initiate a cleanup action will be based on an assessment of the following factors:

• Impact on operability:

o Are there cleanup measures necessary to restore the plant or related facilities, including canyon collectors, to normal operations?

• Accessibility:

o Is a spill reachable by equipment such as vacuum truck?

o Is a spill located on USIBWC property or on property accessible to the public without special permission?

• Safety:

o Do conditions permit staff to safely access pooled water or debris?

• Composition of spill:

o Does spill contain, or is it likely to contain, raw wastewater or chemicals that pose an immediate threat to public safety?

D. STEWART’S DRAIN: With added wastewater infrastructure risk at Stewart’s Drain and greater potential for transboundary flows, this Plan incorporates a specific plan for responding to and/or preventing transboundary flows at Stewart’s Drain which is included as Appendix E.

E. NOTIFICATION and REPORTING:

1. Documentation

The Preliminary and Certified Spill and Transboundary Flow Report shall include all required information as shown and specified on the sample Report included within Appendix G. Appendix G also includes instructions for filling out the Spill and Transboundary Flow Report form.

2. Notification and reporting of Spill Event and Dry Weather Canyon Collector Transboundary Flow Events

a. Prompt reporting of Spill and Transboundary Flow Events:

The operator that takes control of the scene of a spill or transboundary flow event is responsible for the reporting of the event, unless senior management assumes the reporting responsibilities. The communications, notifications, and reporting requirements as outlined in this Plan will be followed and the appropriate verbal and written reports made as specified. A copy of the Spill and Transboundary Flow Report completion and submittal procedures can be found in Appendix G and is available in the Operations Control Room at the SBIWTP.

Spills greater than 1000 gallons must be reported within 2 hours to the CAL OES and to USIBWC, who then report the event to the stakeholders. First notification of a spill should be made to California Office of Emergency Services in Sacramento. Information MUST be phoned in to the Duty Officer at 800‐852‐7550 and all data requested should be provided.

b. Permit-required reporting:

This section of the Plan shall apply to Spill Events and Dry Weather Canyon Collector Transboundary Flow Events. The Operator and/or USIBWC will promptly notify the appropriate parties. Please see Appendix F. Distribution list for Transboundary Flow and Spill Reports is maintained by the operations manager and is available to the Regional Board upon request. USIBWC will regularly update the notification and reporting list (emails and phone numbers) to conduct adequate public notification to protect the public from exposure to spills and/or transboundary wastewater flows. The written notifications and reports will be provided to appropriate regulatory agencies, municipalities and other potentially affected entities to the extent required by the Permit, other permits and licenses, state and Federal laws, local ordinances or as otherwise described in the Plan.

Adequate notification is satisfied with an email or other written notification to the reporting contact list.

c. Notification and reporting of Tijuana River Transboundary Flow Events:

Although the Tijuana River Flood Control Project is not part of the Facilities, this section of the Plan shall apply to Tijuana River Transboundary Flow Events. These events should be reported within 3 business days of the time the Operator and/or USIBWC becomes aware of the event with a final report within 15 calendar days. USIBWC shall provide for notification and reporting of such events to governmental agencies, municipalities, and other organizations as described in section 6.3.2.1.2.9 in the Permit.

The event will be recorded on the reporting form, entitled Spill & Transboundary Flow Report. Please see Appendix F for example forms.

d. Twitter Notification Requirements

USIBWC shall provide notification via Twitter within eight business hours of becoming aware of:

(1) Dry Weather Tijuana River Transboundary Flow Events and Dry Weather Canyon Collector Transboundary Flows at Stewart’s Drain, Silva Drain, or Canyon del Sol, when flows reach as far as Dairy Mart Road Bridge; and (2) Dry Weather Canyon Collector Transboundary Flows at Goat Canyon and/or Smuggler’s Gulch when flows reach as far as Monument Road. Business hours are defined as 7:00 a.m.–5:00 p.m., Monday through Friday (other than federal holidays).

IV. PLAN IMPLEMENTATION

1. Plan Amendment

Responses to spills within the treatment facilities caused by the Operator are fully the responsibility of the Operator. Upon request by USIBWC, the Operator shall implement the plan for additional investigation and cleanup. These tasks include conducting regular review and assessment of the Plan to identify improvements and modify it as necessary to reduce, eliminate, and prevent the recurrence of spills and/or transboundary wastewater flows. The Owner shall keep the Plan in an up‐to‐date condition and shall amend the Plan whenever there is a change (e.g., in the design, construction, operation, or maintenance of the Facilities) which materially affects the potential for a spill and/or transboundary wastewater flow events; or which materially affects the response required for each event. The Owner shall include any modifications as an amendment to the Plan and submit it to CIWQS within 30 days of making the amendment.

2. Posting

A copy of the most current version of the Plan shall be posted at a prominent location at or near the Facility and shall be readily available to Owner’s and Operator’s employees, contractors, and other representatives at all times. The Owner shall also post a publicly available internet accessible copy of the most current Plan on the Owner’s website.

3. Recordkeeping ‐ Log maintenance and retention of records

The Operator maintains records and documents that the Operator creates at the SBIWTP for five years. USIBWC maintains records and documents, which are created by USIBWC and other agencies and documents received from the Operator, at its offices for five years.

T

Appendix A

Appendix A - Spill Plan Roles and Responsibilities and Points of Contact

ROLE

PARTY

DESIGNATED

INDIVIDUAL

TITLE

RESPONSIBILITY

EMAIL ADDRESS

TELEPHONE

NUMBER

Overall Plan Ownership USIBWC

Morgan Rogers

Area Operations Manager

Develop, implement, & update the Plan morgan.rogers@ibwc.gov 619-662-7600

Coordinating Agency

USIBWC Morgan Rogers

Area Operations Manager

Communications with

CILA & CESPT

management morgan.rogers@ibwc.gov 619-662-7600

SBIWTP

Operator

Veolia

Mark Wippler

Plant

Superintendent

Responsible for all Plant and collectors’ operations & maintenance;

contractor to USIBWC.

mark.wippler@veolia.com

619-662-7687

Operations

Jacob Schmidt

Operations Manager

Responsible for Plant & collectors’ operations;

reports to Plant Supervisor .

Communications with CILA and CESPT operational staff jacob.schmidt@veolia.com

Maintenance

Randy Freund

Maintenance

Responsible for Plant & collectors’ maintenance; reports to Plant Supervisor randy.freund@veolia.com

Notes:

(1) While USIBWC has overall responsibility for the development and implementation of Plan, development and implementation responsibility is delegated to Veolia as USIBWC’s contracted Operator.

(2) Veolia Operations division operators are responsible for the canyon collectors’ daily inspections, cleanups, and reporting.

(3) USIBWC management will initiate communications with CESPT management through

CILA.

(4) Veolia, CILA, and CESPT Operators will make contact as necessary to ensure the coordinated operation of the wastewater infrastructure.

mailto:morgan.rogers@ibwc.gov mailto:morgan.rogers@ibwc.gov mailto:mark.wippler@veolia.com mailto:jacob.schmidt@veolia.com mailto:randy.freund@veolia.com

USIBWC/San Diego Field Office

ORGANIZATION CHART

Area Operations

Morgan Rogers

Civil Engineer Robert Kerns

Civil Engineer Tech Lonnie Conners

Civil Engineer Tech Samuel

Katzenstein

Supply Technician Vacant

VEOLIA/SBIWTP

MAINTENANCE

Project Manager

Maintenance Manager

Randy Freund

Maintenance James Caldwell

Maintenance Mike Plasterer

Maintenance Logan Babler

Maintenance Robert Murillo

Maintenance Manuel Galinato

Maintenance Ricardo Navarro

Maintenance Kevin Carter

Maintenance Josh Nunez

I&C Technician Clayton Burns

I&C Technician Jimmy Page

Electricians Jesse Donoho

Electrician Neil Young

Heavy Equipment Robby Mueller

Heavy Equipment Vacant

Planner/ Scheduler

Sangvourn Thong

Systems Analyst Luis Olivas

Operations Manager

Jacob Schmidt

Office Manager Irma Robles

VEOLIA/SBIWTP

OPERATIONS

Project Manager

Maintenance Manager

Randy Freund

Systems Analyst Luis Olivas

Operations Manager

Jacob Schmidt

Shift Supervisor Roberto Marquez

Operator Cory Thornton

Shift Supervisor Carlos Calderon

Operator Raymond Vallido

Shift Supervisor Lorenzo Yelder

Shift Supervisor Abel Alba

Shift Supervisor Troy Prewett

Operator Hal VanHorn

Shift Supervisor Nasser Georges

Operator Cesar Quezada-

Prewett

Shift Supervisor Steven Bates

Operator Rawath Yim

Office Manager Irma Robles

Appendix B

South Bay International Wastewater Treatment Plant

Description:

• 72 inch Gravity influent line from Tijuana

• 96 inch Gravity effluent line to Headworks

Headworks Description:

• Three Mechanical Bar Screens and Three Manual Bar Screens. Peak Flow per Screen

34.7 MGD

• 5 Vertical turbine solids handling pumps. Rated at 25 MGD each.

Grit Chamber/Primary Sedimentation Tanks Description:

• Annual Average Flow: 25 MGD

• Peak Flow 75MGD

• Hydraulic Capacity 100 MGD

Aeration/Secondary Sedimentation Tanks Description:

• Annual Average Flow: 25 MGD

• Peak Flow: 48.75 MGD

Appendix C

Stewart’s Drain Collector Description:

• Collector gravity flows through a buried pipe to plant

• Footprint approx. 50 ft W x 150 ft L

• Inlet has barrier fence/grate

Screen:

• Number of Screens: 1

• Dimension: 5 ft x 1.5 ft

• Height off Floor: 2 ft

Drain Type: Drain Tile

Silva Drain Collector Description:

• Collector gravity flows through a buried pipe to the plant

• Footprint approx. 20 ft W x 25 ft L

• Inlet has no barrier fence/grate

Screen:

• Number of Screens: 1

• Dimension: 4 ft x 1.5 ft

OVERFLOW

Canyon Del Sol Collector

• Collector gravity flows through a buried pipe to plant

• Footprint approx. 20 ft W x 15 ft L

• Inlet has no barrier fence/grate

Screen:

• Number of Screens: 1

• Dimension: 1.5 ft x 4 ft

Smuggler’s Gulch Collector

• Collector gravity flows through buried pipe to Hollister pump station and is pumped to the plant

• Footprint approx. 50 ft W x 80 ft L

• Inlet has no barrier fence/grate

Screen:

• Number of Screens: 4

• Dimension: 2 ft x 5 ft

• Height of Floor: 2.5 ft

Drain Type: One 4-inch hole core drilled at bottom of diversion box

Goat Canyon collector

• Collector gravity flows through buried pipe to Goat Canyon Pump Station, is pumped to Hollister Pump Station, and is pumped to the plant

• Footprint approx. 75 ft W x 80 ft L

• Inlet has barrier fence/grate

Screen:

• Number of Screens: 4

• Dimension: 2 ft x 5 ft

• Height off Floor: 2.5 ft

Drain Type: Two 4-inch holes core drilled at bottom of diversion box

Appendix D

CANYON COLLECTORS’ DAILY INSPECTIONS STANDARD OPERATING PROCEDURES

Sample Daily Inspection Form

Daily Inspection Location Stewart's Drain

Date 6/13/2022

Inspector John Smith

Inspection Time 3:33 PM

Weather Condition Partly Cloudy

Goat Canyon Rain Gauge (Inches)

Total Visits Today 3

Is the Collector in Service Yes If "No" enter reason in remarks section (ie: Rain Event)

Are there any indications of sewage overflow, over the weir, wet ground, standing water etc.

No

Do Border Grates Need Cleaning No If "Yes" notify IBWC and CBP by email, or if urgent by telephone.

Is flow coming from Mexico NOW Yes

Mexico Width (Feet) 2

Mexico Depth (Inches) 0.25

Mexico Feet per Second 1

Flow From Mexico (CFS) 0.04

Transboundary Spill Event No

Bypass Width (Feet)

Bypass Depth (Inches)

Bypass Feet per Second

Overflow Bypassing Collector (CFS)

How much debris is on the Screen to the collector

None

Is there a buildup of trash in Mexico upstream No If "Yes" Notify IBWC by email, or if urgent by telephone.

Is there a buildup of sediment requiring No If "Yes" Notify IBWC by email, or if urgent by telephone.

cleaning and removal

Remarks (Include steps taken to clean and remove trash and sediment)

Picture IMG_1655162011069.jpg

Canyon Collector Daily Inspection Form (MobileMMS) Instructions

For each canyon collector daily inspection, the inspecting Operator shall fill out the top section of the form with general information to include inspection location, date, and time, inspector name, and weather conditions.

Further inspection instructions:

Goat Canyon Rain Gauge – if rain occurred since the previous inspection or is ongoing, note rain accumulation utilizing the Goat Canyon rain gauge.

Is the Collector in Service? Check YES if the entire collector is operational, which includes the area outside of the intake vault, the condition of the screen, and the interior of the vault. Check NO if the vault is sanded in, the screen is completely plugged, and the area outside the collector is likely to be full of debris which prohibits the flow from entering the vault.

Are there any indications of sewage overflow in the last 24 hrs? Check YES if there are signs of overflow and record your observations in the REMARKS section. Overflow is when any flow leaves the collector site and travels down the pathway leading to the TJ River. Check NO if there are no obvious signs.

Do Border Grates Need Cleaning? Notify USIBWC and CBP by email or telephone if urgent.

Is flow coming from Mexico NOW? Check YES if ANY flow is coming from Mexico; check NO if there is not. If NO is checked, then proceed to the “How much debris is on the collector” area.

If Yes, how much? To calculate the flow, do the following:

Pick an area that accounts for all of the flow and measure the width in feet. Check the floor of the area and count the lines to give an estimate of the area wetted. Use these widths and these lengths over which the water is flowing.

Each yellow line is 1 foot apart and the red lines are 5 feet apart. The red lines will be numbered moving out from the center.

Record the depth in feet (each ¼” = 0.021 ft.; each 1” = 0.083 ft.) and measure the velocity in feet per second (this can be accomplished with a radar gun or by timing a floatable object).

Now multiply and record the CFS result. Example:

o A flow of 2 feet per second that is 2 feet wide and ~ ½” deep o 2ft/s x 2ft x .042ft = 0.168 CFS (multiply this by 7.48 Gals /CFS times 60 Seconds/Minute to give you gallons per minute 0.168 CFS X 7.48 X 60 = 75.398 GPM

Is there a Spill or Transboundary Flow? Check NO if ALL of the flow is being contained, with zero overflowing. Check YES if ANY of the flow is overflowing.

If YES, How much is bypassing the Collector? To calculate this number, measure the amount of flow going over the overflow, the same way you calculated the flow from Mexico. Also note color, odor, turbidity and trash quantity and describe in Remarks section.

How much debris is on the screen to the collector?

o None: the screen is clean and free of all debris o Light: the screen has some debris on it, but does not restrict any flow o Moderate: the screen has debris on it; schedule cleaning within one week o Heavy: the screen must be cleaned promptly

Is there a buildup of trash in Mexico downstream? If YES, notify USIBWC for follow-up with CILA and clearance of trash.

Is there a buildup of sediment requiring cleaning and removal? If YES, notify USIBWC and take appropriate action to remove the sediment.

Remarks: Use this area to notate any observations that are out of the norm. Items such as condition of the collector, water quality, excessive debris, sanded in, or anything else noteworthy would go in this section. If a flow is not wholly captured by the collector, the Operator should note color, odor, and turbidity of flows, and whether the flows appear to contain sewage or trash. This section should note whether and what cleaning occurred.

Photos: During each inspection of each collector, Operator will take photos of the collector and its intake and upload the photos using the MobileMMS smartphone app. The Owner can then access the daily canyon collector inspections via the MobileMMS website.

When inspecting each collector, take the time and open the hatches to the vaults and run a pole down the vault to check for sand build‐up in the vault. There needs to be adequate space between the outlet piping and the level of sand to keep the collector operational. If excessive sand is discovered, put in a work order to have the vault cleaned out.

INSPECTIONS OF CANYON COLLECTORS DURING EMERGENCY CONDITIONS:

DRY WEATHER TRANSBOUNDARY FLOW: If a large dry weather transboundary flow is anticipated or if water flows past a collector’s terminal weir is occurring during dry weather conditions, the operator shall make hourly trips out to the collector and complete an inspection form for each visit. During each visit, the intake screen shall be cleaned to prevent any overflow, but only if it is safe to do so. If high flows or high amounts of debris are being experienced, it may require a call out for additional Veolia staff or contractor assistance.

Example. :

An operator makes the Collector Rounds at 08:00. At approximately., 09:00, the inspection rounds have been completed. At 13:00 we receive a call from Mexico stating that they are having a problem and will be sending flow to Goat Canyon. The operator shall then take another canyon collector daily inspection form using the MobileMMS smartphone app to the Goat Canyon collector and record their findings.

If a dry-weather transboundary flow crests a collector’s terminal weir, samples should be taken from the catch basins and sent for assessment consistent with the water quality parameters outlined in the Permit.

Appendix E

COMMUNICATIONS PROTOCOL – Trash Accumulation Upstream of Canyon Collectors

Purpose:

Establish protocol for communications between USIBWC, CILA, CBP, and Veolia for the removal of accumulated trash upstream of the canyon collectors.

Background:

Excessive trash accumulation upstream of the canyon collectors in Mexico poses a solid waste risk with potential for trash washing further downstream into the US and to the Tijuana River Valley and Pacific Ocean.

Flow of trash also increases the risk of transboundary flows and structural damage to the canyon collectors.

Trash accumulated in Mexico upstream of…