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INTERNAL AUDITS <br />© 2025 Fischer Compliance, LLC. All rights reserved. Sewer System Management Plan licensed for San Leandro use only. Page 53 of 57 <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 most recent audit for the period ending August 2024; this document is found as an <br />Appendix to this SSMP. The City will complete audits every three years moving forward. The objective of <br />the audit is to evaluate compliance, implementation and effectiveness of the SSMP. Additionally, the SSMP <br />includes a description of how the City will comply with the requirements of each Element. <br />The audit review includes an evaluation to determine if compliance has been met. A list of priority <br />improvement opportunities will be prepared and updated as part of the audit program. Improvement <br />opportunities will be used to prioritize and develop program modifications and will be initiated based on <br />the priority and the available funding. An overview of SSMP related work completed between audits will be <br />included in the program audits. <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 /> Mgr. Eng Sup <br />10.1 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 />Beginning at end <br />of audit period X X <br />10.2 Ensure a plan and schedule is developed to address <br />deficiencies. <br />Once the Audit is <br />completed X X