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XI. SSMP PROGRAM AUDITS A. Introduction This section of the SSMP outlines the process that the City will follow to evaluate the effectiveness of the SSMP to identify updates that may be needed for a more effective program. B. Regulatory Requirements State GWDR Requirement As part of the SSMP, the Enrollee shall conduct periodic internal audits, appropriate to the size of the system and the number of SSOs. At a minimum, these audits must occur every two years and a report must be prepared and kept on file. This audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee's compliance with the SSMP requirements identified in this subsection (D.13), including identification of any deficiencies in the SSMP and steps to correct them. C. Audits The audit covers each of the major sections of the SSMP. An Audit Checklist, adapted from a document developed by BACWA and based on the requirements of the GWDR is used. In addition to the Yes/No response to questions,the checklist provides space for each group of related questions to document any deficiencies and steps taken or planned to correct them.The comment spaces will also be used to document qualitative evaluations related to the particular element or sub-element. In this way,the audit serves as the primary tool for documenting SSMP effectiveness as prescribed per the SWRCB. D. SSMP Updates The City conducted annual audits of the SSMP from Calendar Year 2008 through 2013. Staff intends to perform bi-annual audits (Attachment F) in the first quarter beginning in 2015. After 2015, audits will be conducted every two years in the first quarter of the year by the Legally Responsible Official (LRO). Other parties may be added to the future audit teams. The audit is retained by the Environmental Compliance Manager. As part of the audit process, City staff will update critical information in the SSMP, such as contact information, names of the key staff in the response chain of communication,or other similar data as needed. A comprehensive SSMP update will occur every 5 years, as required by the GWDR. 42IPage