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extensive negotiations between the City and the US EPA resulted in the US EPA's issuance of an <br /> ACO that was greatly limited in scope compared to the initial Order. This was in large measure <br /> due to the City's ongoing commitment to improving its sanitary sewer systems, and its good faith <br /> efforts to negotiate a reasonable ACO with the US EPA. <br /> The Administrative Consent Order's major requirements included: <br /> 1. A Development of a Capacity Management, Operations, and Maintenance (CMOM) <br /> program. The CMOM program provides a comprehensive review of the City's sewer <br /> collection system asset, including system management, maintenance, and capital <br /> improvement funding. The CMOM was approved by the USEPA on May 1, 2018 and <br /> the City has implemented the program. <br /> 2. Preparation of a Sewer Collection System Alternatives Analysis (SCSAA) for areas <br /> identified as experiencing Sanitary Sewer Overflows (SSOs) and sewer back-ups during <br /> storm events. The analysis focused on efforts to keep storm water from entering into the <br /> separate sanitary sewer system and better manage stormwater entering the combined <br /> sewer system. <br /> US EPA Administrative Consent Order Status <br /> The City submitted a third revision to the required Sanitary Sewer Collection System Analysis <br /> (SCSAA) on November 30, 2017. The _ <br /> revised SCSAA identified four major areas of <br /> t, <br /> concern. <br /> m <br /> _� <br /> 1. North Lost Bridge Area ( I <br /> 2. Florian Avenue Area <br /> 3. Basin 5/6 Area(Grand/Rt.48) T"eEll.8°"a°" —r <br /> 4. Ellen/Division Area <br /> �TABFIaianAw <br /> Bash 5 BArae � <br /> The Ellen/Division Area was identified as an 1 <br /> additional <br /> thatoccurred duringarea <br /> theduring e aTA <br /> preparation of thee rainfall �.,;�� .� n � �I.ade� <br /> revised SCSAA. Rainwater induced sanitary <br /> sewer overflows persisted in the area despite <br /> increased sewer system maintenance. These <br /> persistent overflows required that an Inflow <br /> and Infiltration(I&I) study be completed, and <br /> the system be added to the list of priority areas <br /> to be addressed by the City as identified in the <br /> SCSAA. <br /> The City has not received any correspondence regarding the SCSAA from the USEPA since the <br /> November 30, 2017 revision was submitted. The table below provides the project status of each <br /> area. The Consent Order originally required that all work be completed by December 31, 2020. <br /> The final I&I reduction design for each area was put on hold until the City received USEPA <br /> approval of the SCSAA and the preliminary design studies. <br />