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Appendix 1 - Compliance Evaluation Inspection Report(WDID=#2SSO10168 Page 8/24 <br /> <br />A list of Violations (V) and Areas of Concern (AOC) identified during Task B of the Inspection is presented in Table 7 below. <br />Table 7 – City Violations and Areas of Concern (Task B1) <br /> <br />Findings Element Description Details <br />Area of Concern D-1 Goals & Intro None <br />None D-2 Organization Limited staff resources for both O/M and emergency operations for <br />covering water, sewer, and storm drain systems. <br />Area of Concern D-3 Legal Authority The City should ensure its available legal authority addresses illicit <br />discharge prohibitions, enforcement authority, ability for adequate <br />stormwater collaboration and access to easement areas for spill <br />response and required maintenance; relevant codes, ordinances, and/or <br />standards should be updated to ensure proper legal authority as <br />required to comply with the Reissued WDR. <br />Area of Concern D-3 Legal Authority The City should periodically review its illicit discharge <br />prohibitions/enforcement authority for satellite sewers and update as <br />necessary. <br />Area of Concern D-4 O/M Program Underdeveloped lower sewer lateral maintenance program. <br />Area of Concern D-4 O/M Program Improve force main cleaning program. <br />Area of Concern D-4 O/M Program Improve maintenance in downtown area including smaller pipes. <br />Area of Concern D-4 O/M Program Improve identification of all critical/spare parts and backup <br />parts/equipment including having "shelf-ready" components such as <br />ultrasonic transducers, fuses, capacitors, etc. to ensure readiness for <br />spills. <br />Area of Concern D-4 O/M Program Improve auditing and Q/A of work orders in system to ensure no open <br />work orders not addressed for extended time periods. <br />None D-5 Design/Perf None <br />Area of Concern D-6 SERP Improve SERP implementation including emergency response <br />operations documentation and coordination with outside agencies <br />including Silicon Valley Clean Water. <br />Area of Concern D-6 SERP Improve more frequent bypassing trainings to ensure adequate <br />emergency readiness. <br />Area of Concern D-6 SERP Improve signage at stations. <br />Area of Concern D-7 Pipe Blockage Improve FOG program oversight/implementation. <br />Area of Concern D-8 SECAP Limited/low CCTV inspection annual return frequency covering entire <br />system; prepare annual production justification narrative for SSMP <br />Update. <br />Area of Concern D-8 SECAP Improve capital attention in downtown area including smaller pipes. <br />Area of Concern D-8 SECAP Develop a system-specific Climate Resilience Plan for the SSMP Update <br />including but not limited addressing the factors listed in Findings 3.2.3 <br />of the Reissue WDR such as: <br />None D-9 Monitoring None <br />None D-10 Audits None <br />None of Concern D-11 Communication None <br />None E-1 NMRR (MRP) None <br />see Audit Report Specs. 5.1-5.15 see Audit Report <br /> <br /> <br />APPENDIX 1 (Page 8) <br />ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A <br />REV: 07-14-25 LF <br /> <br />Page 226 of 317