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ME <br />♦• • -• <br />IOMM <br />Waste Discharge Requirements (WDR) and Sewer System Management Plans <br />(SSMP) <br />The EEC team has conducted a wide range of program audits, including SSMP audits, that has <br />provided EEC with a unique insight to both a regulator's view on conducting audits and a <br />regulated entity's view on being audited. EEC will provide the City with the following WDR and <br />SSMP support services under this task: <br />A. Perform the 2 -year internal audit due in 2017. The audit will include a report of the findings <br />and recommendations identified during the audit. <br />The cornerstones of EEC's expertise in SSMP program audits are extensive knowledge of key <br />SSMP program elements in line with regulatory requirements and a breadth of experience that <br />informs a complete, candid assessment of an agency's conformance or deficiency. Pursuant to <br />the WDR requirements for SSMPs, EEC's focuses on evaluating the key elements of the SSMP: <br />1. Legal authority <br />2. Operation and maintenance program <br />3. Design and performance provisions <br />4. Overflow emergency response plan <br />5. FOG control program <br />6. System evaluation and capacity assurance plan <br />7. Monitoring, measurement, and program modifications <br />Often, the SSMP internal audit is conducted merely as a formality to satisfy the minimum <br />requirements of the WDR. EEC takes a somewhat different approach and views the audit from <br />the perspective of a regulator. A regulator is looking for an honest assessment and program <br />modification that brings about true improvement in program performance (where needed). <br />Therefore, the key objectives of EEC's SSMP audit is to candidly evaluate how implemented <br />programs are impacting the reduction of SSOs and evaluate the proper ongoing management, <br />operation, and maintenance of sewer system assets, <br />EEC's general approach to SSMP internal audits is threefold: <br />1. Evaluate the level of conformance of the City's SSMP to the WDR. This is accomplished <br />primarily through a desktop review of the SSMP and supporting documentation. EEC is <br />thoroughly familiar with recent changes to the Monitoring and Reporting element of the <br />WDR and will ensure the City's SSMP appropriately addresses these changes. <br />2. Assess the level of conformance of the City's field practices with SSMP policies and <br />procedures. This includes a detailed review of program - related documents (e.g., work <br />"EEC's expertise and responsiveness was instrumental in helping <br />our city meet new stringent sewer regulations." <br />Ray Burk, Former Principal Civil Engineer <br />City of Santa Ana <br />Proposal to Provide WDR Compliance Services, City of Santa Ana, RFP 15 -072 20 August 13, 2015 <br />25G -41 <br />