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CEEC <br />F NVIIMN NlfE N I AI <br />orders, standard procedures, etc.) and data (e.g., line cleaning history, staff training <br />records, etc.), as well as comprehensive interviews with City staff and field observation <br />of key staff activities. <br />3. Use the audit findings to develop practical and defensible recommendations for program <br />improvement. EEC will prepare a report summarizing the audit findings that will include <br />classification of any identified nonconformances (i.e., major or minor nonconformance). <br />The report will also contain recommendations for program improvements based on <br />EEC's experience with successful aspects of similar programs and input received during <br />the staff interview process. <br />Analyzing the SSMP and identifying deficiencies in this <br />manner will allow the City to maintain control of the <br />definition and implementation of its programs rather than <br />putting that control in the hands of a regulator. For <br />example, in evaluating the City's SSO emergency response <br />plan, EEC will not only confirm that current practices are in <br />place and followed, but will also assess the defensibility of <br />key response procedures, such as SSO volume estimating <br />techniques. This approach parallels a regulator's approach <br />and allows the City to stay ahead in the process. <br />SSMP Audit Staff Interview <br />EEC is located close to Santa Ana and will work around the City staff members' schedules to <br />ensure the audit process is not intrusive but is thorough enough to satisfy the WDR <br />requirements and improve the City's SSMP programs. <br />B. Prepare the 2019 SSMP update using information obtained from the previous SSMP audits. <br />Pursuant to the SSS WDR, enrollees must update their SSMP once every 5 years to reflect the <br />enrollee's current SSMP - related practices and the changes recommended during internal SSMP <br />audits. Having audited the City's SSMP in 2013 and 2015 and having updated the City's SSMP <br />in 2014, EEC knows the City's SSMP thoroughly and will ensure it stays current and accurate. <br />C. Provide quarterly WDR training and advising City staff on emerging issues, revisions, and <br />additions to the SSS WDR. <br />EEC has provided previous similar training to City staff regarding SSO emergency response <br />procedures and general WDR requirements. Training topics will include, but not be limited to, <br />SSO emergency response, EML evaluation procedures, and FOG program management. <br />D. Develop SSO contingency plans for the two City sewage lift stations. <br />The risk of large SSOs is greater in the event of sewage lift station failures. Understanding this, <br />EEC will work with the sewage lift station staff to develop SSO contingency plans that will <br />include, but not be limited to, procedures for electrical operations, bypass, and cleaning of the <br />lift stations. <br />E. Develop a sewer system maintenance (cleaning) program and schedule. <br />As part of the SSMP and the City's asset management endeavor, EEC will develop a sewer <br />system maintenance and cleaning program and schedule. The program and schedule will <br />Proposal to Provide WDR Compliance Services, City of Santa Ana, RFP 15 -072 21 August 13, 2015 <br />25G -42 <br />