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MONITORING, MEASUREMENT, AND PROGRAM MODIFICATIONS © 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Redwood City use only Page 53 of 59 9. Monitoring, Measurement, and Program Modifications WDR REQUIREMENTS Attachment D-9 (pg. D-9) “The Plan must include an Adaptive Management section that addresses Plan-implementation effectiveness and the steps for necessary Plan improvement, including: • Maintaining relevant information, including audit findings, to establish and prioritize appropriate Plan activities; • Monitoring the implementation and measuring the effectiveness of each Plan element; • Assessing the success of the preventive operation and maintenance activities; • Updating Plan procedures and activities, as appropriate, based on results of monitoring and performance evaluations; and • Identifying and illustrating spill trends, including spill frequency, locations, and estimated volumes.” COMPLIANCE The above requirements are addressed below: a. The City maintains accurate and relevant inspection and maintenance records for the collection system as required by the City’s retention schedule. Much of the documentation is maintained electronically, which allows for ease of access and analysis. This helps City staff to make sound decisions and prioritize activities when dealing with the routine and the unexpected. b. Monitoring of the City’s SSMP focuses on each element in terms of its implementation and effectiveness. The SSMP has been designed to include key performance indicators for each element, which are used to measure effectiveness. In addition, implementation responsibilities are included for each element to help ensure the SSMP is being implemented as intended. c. The City assesses the success of maintenance and operation activities by ensuing activities are being performed as expected, by monitoring actual outcomes compared to intended outcomes, as well as monitoring spill trends. d. The City is committed to continuous improvement and monitors and evaluates performance of work programs and SSMP elements to ensure intended outcomes are achieved while looking for areas for improvement. Although the State Water Board requires that the SSMP be updated every six years, the City recognizes that SSMP is considered a dynamic document and may require updating on a more frequent basis. Routine changes to administrative information, notwithstanding, minor changes will likely be required to address improvements identified through the SSMP Audit or through modifications required as conditions change. e. The City monitors spill trends, at a minimum every three years during required audits, utilizing the Hiperweb database, inspection records and CIWQS data. These resources are helpful in planning and programing work, and adjusting as needed, enabling the City to be adaptive and capitalize on lessons learned. EFFECTIVENESS The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element: • Are SSMP Elements being periodically evaluated for effectiveness? ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A REV: 07-14-25 LF Page 60 of 317