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Appendix 1 - Compliance Evaluation Inspection Report(WDID=#2SSO10168 Page 24/24 <br /> <br />Table 17 – Inspection Findings (Violations/Areas of Concern) <br /> <br />Findings Element Description Details <br />Area of Concern D-1 Goals & Intro None <br />Area of Concern D-2 Organization Limited staff resources for both O/M and emergency operations. <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 parts/equipment <br />including having "shelf-ready" components such as ultrasonic transducers, <br />fuses, capacitors, etc. to ensure readiness for spills. <br />Area of Concern D-4 O/M Program Improve auditing and Q/A of work orders in system to ensure no open work <br />orders not addressed for extended time periods. <br />Area of Concern D-5 Design/Perf None <br />Area of Concern D-6 SERP Improve SERP implementation including emergency response operations <br />documentation and coordination with outside agencies including Silicon <br />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 of <br />the Reissue WDR such as: <br />Area of Concern D-9 Monitoring None <br />Area of Concern D-10 Audits None <br />Area of Concern D-11 Communication None <br />Area of Concern E-1 NMRR (MRP) None <br />Violations Specs. 5.1-5.15 see Audit Report <br /> <br /> <br />APPENDIX 1 (Page 24) <br />ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A <br />REV: 07-14-25 LF <br /> <br />Page 242 of 317