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PART 1 – EXECUTIVE SUMMARY Sewer System Management Plan Audit (8/2/21 to 8/2/24) Page 3 of 47 SSMP AUDITING PROCEDURES A comprehensive SSMP Audit was completed in partnership with managers responsible for providing the audi[ng team with all data requests and informa[on evaluated in the project. The following key elements were reviewed for comple[on of the Audit: • Assessment of the City’s exis[ng SSMP • Detailed interviews with City collec[on management and field staff operators • Comple[on of a Compliance Evalua[on Inspec[on (CEI) mirroring procedures established and implemented by U.S. EPA and the Water Board staff assessing compliance and taking enforcement for noncompliance with the California Water Code, Federal Clean Water Act, and the Reissued WDR (see Appendix 1) • Review of City spill reports, system data, and other documenta[on • Guidelines and recommenda[ons for SSMPs (see Appendix 3, incorporated throughout the Audit Report for thoroughness) prepared and published by the Bay Area Clean Water Agencies (BACWA) posted on the SWRCB’s website. COLLECTION SYSTEM INFORMATION The City owns and operates sanitary sewer collec[on system (collec[on system) serving a popula[on of 80,500 and includes a total of 184 miles of gravity sewers and 10 miles of force main sewers. Figure 1 below provides a “Facility-At-A-Glance report providing publicly-available informa[on from the SWRCB’s database for the sytem. The purpose of the report is to convey current staffing and present the official regulatory measures informa[on for the system including iden[fica[on of historic viola[ons determined by the RWQCB, list inspec[on data and any past enforcement ac[ons. The report notes a 2019 inspec[on completed by the RWQCB as shown at the boIom of the figure. ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A REV: 07-14-25 LF Page 173 of 317