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File Number: 25-342 <br />Water Board Basin Plans) and policies; <br />·Proactively operate and maintain resilient sanitary sewer systems to prevent spills; <br />·Eliminate discharges of sewage to waters of the State through effective <br />implementation of a Sewer System Management Plan (SSMP); <br />·Monitor, track, and analyze spills for ongoing system-specific performance <br />improvements; and <br />·Report noncompliance with the General Order per reporting requirements . <br /> <br />As part of the requirement to implement an SSMP, City Staff performed an internal audit; Fischer <br />Compliance LLC was hired to prepare the SSMP Update. The 2025 Update meets and exceeds <br />compliance with the WDR. <br /> <br />Analysis <br /> <br />The items highlighted below are major elements of the 2022 Order, which have been completed <br />by the City’s Water Pollution Control Division to ensure that the City is in compliance: <br /> <br />·Regulatory Coverage - Prepared and electronically certified the “Continuation of <br />Existing Regulatory Coverage” form in CIWQS to continue coverage from the 2006 <br />Order under the 2022 Order. <br /> <br />·Spill Emergency Response Plan (SERP) Update - Updated the SERP in March 2025, <br />which includes measures to protect public health and the environment by preventing <br />Sanitary Sewer Overflows (SSOs). <br /> <br />·Annual Reports - Prepared and electronically certified Annual Reports in CIWQS to <br />provide information on the population served and service area; years of experience <br />and certifications held by sewer operations and maintenance workers; overall system <br />condition and performance, causes of SSOs, and any actions taken to investigate and <br />address system deficiencies. The annual reports were completed in March 2024 and <br />March 2025. <br /> <br />·SSMP Audit - City staff audited the implementation and effectiveness of the SSMP, <br />assessed compliance with the 2022 Order, identified deficiencies in addressing SSOs <br />and any discharges to waters of the State, and to determine any modifications needed <br />to correct deficiencies. The SSMP Audit (Attachment B) was completed in February <br />2025 and includes Audit Findings and Recommended Corrective Actions. <br /> <br />·SSMP Update - Ficher Compliance Inc. was retained to assist the City with the <br />preparation of the SSMP Update, which includes eleven chapters covering the <br />procedures for the management, operation, and maintenance of the sanitary sewer <br />system, evaluation of existing and future conditions and system needs, and the <br />prioritization of repairs and maintenance work as described in the 2022 Order. In <br />addition, the SSMP Update incorporates the Findings and Recommended Corrective <br />Actions from the SSMP Audit. This SSMP Update is materially consistent with the <br />statewide WDRs for Sanitary Sewer Systems and incorporates the latest requirements <br />Page 2 City of San Leandro Printed on 9/4/2025