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EEC ENVIRONMENTAL Scope of Services & Schedule Core Requirements Waste Discharge Requirements (WDR) and Sewer System Management Plans (SSMP) The EEC team has conducted a wide range of program audits, including SSMP audits, that has provided EEC with a unique insight to both a regulator's view on conducting audits and a regulated entity's view on being audited. EEC will provide the City with the following WDR and SSMP support services under this task: A. Perform the 2-year internal audit due in 2021. The audit will include a report of the findings and recommendations identified during the audit. The cornerstones of EEC's expertise in SSMP program audits are extensive knowledge of key SSMP program elements in line with regulatory requirements and a breadth of experience that informs a complete, candid assessment of an agency's conformance or deficiency. Pursuant to the WDR requirements for SSMPs, EEC's focuses on evaluating the key elements of the SSMP: 1. Goals and metrics 2. Organization and staff 3. Legal authority 4. Operation and maintenance program 5. Design and performance provisions 6. Overflow emergency response plan 7. FOG control program 8. System evaluation and capacity assurance plan 9. Monitoring, measurement, and program modifications Often, the SSMP internal audit is conducted merely as a formality to satisfy the minimum requirements of the WDR. EEC takes a somewhat different approach and views the audit from the perspective of a regulator. A regulator is looking for an honest assessment and program modification that brings about true improvement in program performance (where needed). Therefore, the key objectives of EEC's SSMP audit is to candidly evaluate how implemented programs are impacting the reduction of SSOs and evaluate the proper ongoing management, operation, and maintenance of sewer system assets. EEC's general approach to SSMP internal audits is threefold: 1. Evaluate the level of conformance of the City's SSMP to the WDR. This is accomplished primarily through a desktop review of the SSMP and supporting documentation. EEC is thoroughly familiar with recent changes to the Monitoring and Reporting element of the WDR and will ensure the City's SSMP appropriately addresses these changes. 2. Assess the level of conformance of the City's field practices with SSMP policies and procedures. This includes a detailed review of program -related documents (e.g., work orders, standard procedures, etc.) and data (e.g., line cleaning history, staff training records, Proposal to Provide WDR Compliance Services - City of Santa Ana, RFP 20-089 11 August 4, 2020