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EEC ENVIRONMENTAL orders, standard procedures, etc.) and data (e.g., line cleaning history, staff training records, etc.), as well as comprehensive interviews with City staff and field observation of key staff activities. 3. Use the audit findings to develop practical and defensible recommendations for program improvement. EEC will prepare a report summarizing the audit findings that will include classification of any identified nonconformances (i.e., major or minor nonconformance). The report will also contain recommendations for program improvements based on EEC's experience with successful aspects of similar programs and input received during the staff interview process. Analyzing the SSMP and identifying deficiencies in this manner will allow the City to maintain control of the definition and implementation of its programs rather than putting that control in the hands of a regulator. For example, in evaluating the City's SSO emergency response plan, EEC will not only confirm that current practices are in place and followed, but will also assess the defensibility of key response procedures, such as SSO volume estimating techniques. This approach parallels a regulator's approach and allows the City to stay ahead in the process. SSMP Audit Staff Interview EEC is located close to Santa Ana and will work around the City staff members' schedules to ensure the audit process is not intrusive but is thorough enough to satisfy the WDR requirements and improve the City's SSMP programs. On -going: SSMP update using information obtained from the previous SSMP audits. Pursuant to the SSS WDR, enrollees must update their SSMP once every 5 years to reflect the enrollee's current SSMP-related practices and the changes recommended during internal SSMP audits. Having audited the City's SSMP in 2013 and 2015 and having updated the City's SSMP in 2014, EEC knows the City's SSMP thoroughly and will ensure it stays current and accurate. Provide quarterly WDR training and advising City staff on emerging issues, revisions, and additions to the SSS WDR. EEC has provided previous similar training to City staff regarding SSO emergency response procedures and general WDR requirements. Training topics will include, but not be limited to, SSO emergency response, EML evaluation procedures, and FOG program management. Develop SSO contingency plans for the two City sewage lift stations. The risk of large SSOs is greater in the event of sewage lift station failures. Understanding this, EEC will work with the sewage lift station staff to develop SSO contingency plans that will include, but not be limited to, procedures for electrical operations, bypass, and cleaning of the lift stations. Develop a sewer system maintenance (cleaning) program and schedule. As part of the SSMP and the City's asset management endeavor, EEC will develop a sewer system maintenance and cleaning program and schedule. The program and schedule will Proposal to Provide WDR Compliance Services, City of Santa Ana, RFP 15-072 21 August 13, 2015