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INTERNAL AUDITS <br />© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for Redwood City use only Page 55 of 59 <br />10. Internal Audits <br />WDR REQUIREMENTS <br />Attachment D-10 (pg. D-10) <br />“The Plan shall include internal audit procedures, appropriate to the size and performance of the system, <br />for the Enrollee to comply with section 5.4 (Sewer System Management Plan Audits) of this General <br />Order.” <br />COMPLIANCE <br />The City completed its last audit in August 2024 and will complete audits every three (3) years moving <br />forward. The Public Works Superintendent is responsible for ensuring the SSMP audit is completed on <br />schedule. The objective of the audit is to evaluate compliance, implementation and effectiveness of the <br />SSMP. Additionally, the SSMP includes a description of how the City will comply with the requirements of <br />each Element. The audit review includes an evaluation to determine if compliance has been met. <br />Implementation is evaluated by determining if the City is executing the SSMP as stated. <br />Effectiveness is evaluated by using key performance indicators, which have been developed specifically for <br />each element. An additional evaluation is performed to comply with Specifications 5.6 addressing resilience. <br />Resilience indicators have been developed for each element. These indicators serve to demonstrate how <br />resilience is built into the SSMP and inspection, maintenance and spill response activities. <br />Any deficiencies discovered through the audit process are noted and a plan and schedule to implement <br />corrective measures are established. All audit reports will be certified by the City’s LRO. All changes or <br />modifications of the SSMP resulting from the Audit shall be listed in the SSMP Change Log. <br /> EFFECTIVENESS <br />The City utilizes the following Key Performance Indicators for measuring effectiveness of this Element: <br />• Have audits been performed as required? <br />• Have the audits assessed compliance, implementation, and effectiveness? <br />• Have deficiencies been identified? <br />• Has a plan and schedule to rectify the deficiencies been established? <br />IMPLEMENTATION PLAN/SCHEDULE <br />No. Plan Schedule Responsible Party <br /> E&T PWS <br />10.1 <br />Schedule audits in advance of due dates to ensure <br />adequate time to complete. City has 6 months to <br />complete the audit from the end of the audit period. <br />5/2/2027 <br />(See Section 1.2) X <br />10.2 Ensure a plan and schedule is developed to address any <br />deficiencies. <br />Once the Audit is <br />completed X X <br /> <br />RESILIENCE <br />Resilience is addressed in Element 10 by: <br />ATTY/RESO.0077/CC RESO SEWER SYSTEM MANAGEMENT PLAN - EXHIBIT A <br />REV: 07-14-25 LF <br /> <br />Page 62 of 317