R2015-109 AUTHORIZING ADMINISTRATIVE CONSENT ORDER

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shall conduct a Sewer System Assessment (SSA) Study. The requirements for the SSA Study are provided in Attachment A. 52. The Sewer Collection System Alternatives Analysis shall be reviewed and updated by Respondent as needed based on findings from the CMOM(Paragraph 56) or other relevant data. 53. Respondent must provide semi-annual reports on the recommended projects chosen, as set forth in the Sewer Collection System Alternatives Analysis' implementation schedule to EPA (Paragraph 46.d). The reports are due on January 31 and July 31 of each year, following the commencement of the Sewer Collection System Alternatives Analysis' implementation schedule. The semi-annual reports, at a minimum, must describe the status and progress of each project that is implemented for the previous half of the calendar year. 54. Respondent intends to use an asset management approach to operate and maintain the Combined Sewer Collection System and Sanitary Sewer Collection System, consistent with its Sanitary Sewer Master Plan and its CMOM Program(Paragraph 56). Within 90 days of receiving EPA approval of the CMOM Program submitted under Paragraph 56, Respondent shall submit to EPA an Asset Management Workplan, which shall include a list of activities Respondent intends to take to implement its asset management approach and a schedule for implementation of those activities. The submission of Respondent's Asset Management Workplan is for informational purposes only, and will not be subject to EPA approval. 55. Within 180 calendar days of the effective date of this Order, Respondent shall submit an initial Capacity, Management, Operation, and Maintenance (CMOM)Template, containing a CMOM Program outline for review and comment by EPA. The CMOM Template shall include a status report of how the Respondent currently addresses the items (CMOM Template Items) identified in Sections I, III, N(A, E, F, and L), V(A, F, and G), and VI of the Table of Contents (attached) for Chapter 3 of the EPA's Cncide for Evaluating CMOMPrograms at Sanitary Sewer Collection Systems, EPA 305-B-OS-002 (January 2005) (the Guide). The status report shall note any current deficiencies in these CMOM Tetnplate Items and shall detail how the Respondent shall improve these before the final CMOM Program submittal. The status report shall demonstrate how the other items in the Guide shall be implemented or put in place by the time of the submission of the CMOM Program. 56. Within 180 calendar days from the approval of the initial CMOM Template, as described in Paragraph 55, Respondent shall prepare and submit to EPA a CMOM Program designed to address all parts of its Separate Sanitary Sewer System in accordance with all listed provisions outlined in the attached Chapter 3 Table of Contents from the Guide. The submitted CMOM Program shall include all on-going, up-to-date CMOM documentation, including the checklist in Chapter 3 of the Guide. The Guide can be found online at http://www.epa.gov/npdes/pubs/cmom� ide for collection s stY ems.pdf. The CMOM 10