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ELEMENT 9 – MONITORING, MEASUREMENT, PROGRAM MODIFICATIONS <br /> <br />Sewer System Management Plan Audit (8/2/21 to 8/2/24) Page 37 of 47 <br />ELEMENT 9 – MONITORING, MEASUREMENT, PROGRAM MODIFICATIONS <br />REQUIREMENTS 12 <br />“The Plan must include an Adap<ve Management sec<on that addresses Plan-implementa<on effec<veness and <br />the steps for necessary Plan improvement, including: <br />• Maintaining relevant informa<on, including audit findings, to establish and priori<ze appropriate Plan <br />ac<vi<es. <br />• Monitoring the implementa<on and measuring the effec<veness of each Plan Element. <br />• Assessing the success of the preven<ve opera<on and maintenance ac<vi<es. <br />• Upda<ng Plan procedures and ac<vi<es, as appropriate, based on results of monitoring and performance <br />evalua<ons; and <br />• Iden<fying and illustra<ng spill trends, including spill frequency, loca<ons, and es<mated volumes.” <br />FINDINGS (Element 9: Analysis) <br />SSMP Element - AT. D-9 <br />COMPLIANCE <br />q Assess element narra[ve and improve as necessary for 2025 SSMP Update. <br /> <br />IMPLEMENTATION <br />q None <br />EFFECTIVENESS <br />WDR RECOMMENDATION <br />To measure effec[veness and ensure alignment with available industry standard guidance, the City <br />should check/verify the following data for inclusion in its next required SSMP update: <br />q Are trends being monitored and correc[ve ac[on taken as necessary? <br />q Have Key Performance Indicators been developed to measure the effec[veness of each <br />Sewer System Management Plan element? <br />q Has a plan and schedule been established to address audit findings/deficiencies? <br />q Have changes been made to work programs and procedures because of monitoring efforts? <br /> <br /> <br /> <br />12 See Attachment D-9 of Reissued WDR (page D-9) <br />ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A <br />REV: 07-14-25 LF <br /> <br />Page 207 of 317