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EEC ENVIRONMENTAL 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 Headquartered in Orange, CA, 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. EEC anticipates conducting one SSMP audit over the next two years. B. Prepare the 2024 SSMP update using information obtained from the 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 2017 and 2019 and having updated the City's SSMP in 2019, EEC is intimately familiar with the City's SSMP and can readily ensure it stays current and accurate. EEC anticipates performing one SSMP update by 2024. C. 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. EEC will coordinate with City personnel to establish a training schedule and determination of requested training topics. Training topics may include gravity and lift station SSO/emergency response, WDR and SSMP requirements and contents, FOG program management, drinking water system permitting requirements, water treatment processes. This core services task will be performed as an element of As -Assigned Training and Support services. "EEC's expertise and responsiveness was instrumental in helping our city meet new stringent sewer regulations." Ray Burk, Former Principal Civil Engineer City of Santa Ana Proposal to Provide WDR Compliance Services - City of Santa Ana, RFP 20-089 12 August 4, 2020