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shall conduct a Sewer System Assessment(SSA) Study. The requirements for the SSA <br /> Study are provided in Attachment A. <br /> 52.The Sewer Collection System Alternatives Analysis shall be reviewed and updated by <br /> Respondent as needed based on findings from the CMOM (Paragraph 56)or other <br /> relevant data. <br /> �3.Respondent must provide semi-annual reports on the recommended projects chosen, as <br /> set forth in the Sewer Collection System Alternatives Analysis' implementation schedule <br /> to EPA(Paraeraph 46.d). The reports are due on January 31 and July 31 of each year, <br /> following the commencement of the Sewer Collection System Alternatives Analysis' <br /> implementation schedule. The semi-annual reports,at a minimum,must describe the <br /> status and progress of each project that is iinplemented for the previous half of the <br /> calendar year. <br /> 54.Respondent intend.s to use an asset management approach to operate and maintain the <br /> Combined Sewer Collection System and Sanitary Sewer Collection System, consistent <br /> with its Sanitary Sewer Master Plan and its CMOM Program (Paragraph 56). Within 90 <br /> days of receiving EPA approval of the CMOM Program submitted under Paragraph 56, <br /> Respondent shall submit to EPA an Asset Management Workplan, which shall include a <br /> Iist of activities Respondent intends to take to implement its asset management approach <br /> and a schedule for implementation of those activities. The submission of Respondent's <br /> Asset Management Workplan is for informational purposes only, and will not be subject <br /> to EPA approval. <br /> 55. Within 180 calendaz da3�s of the effective date of this Order,Respondent shall submit an <br /> initial Capacity,Management,Operation,and Maintenance(CMOIvn Template, <br /> containing a CMOM Program outline for review and comment by EPA.The CMOM <br /> Template shall include a status report of how the Respondent currently addresses the <br /> items(CMOM Template Items) identified in Sections I,III,N(A,E,F,and L),V(A, F, <br /> and G),and VI of the Table of Contents (attached)for Chapter 3 of the EPA's Guide for <br /> Evaluating CMOMPrograms at Sanitary Sewer Collection Systems,EPA 305-B-OS-002 <br /> (January 2005)(the Guide). The status report shall note any current deficiencies in these <br /> CMOM Template Items and shall detail how the Respondent shall improve these before <br /> the final CMOM Program submittal. The status report shall demonstrate how the other <br /> items in the Guide shall be implemented or put in place by the time of the submission of <br /> the CMOM Program. <br /> 56. VJithin 180 calendar days from the approval of the initial CMOM Template,as described <br /> in Paragraph 55,Respondent shall prepare and submit to EPA a CMOM Program <br /> designed to address all parts of its Separate Sanitary Sewer System in accordance with all <br /> listed provisions outlined in the attached Chapter 3 Table of Contents from the Guide. <br /> The submitted CMOM Program shall include all on-going,up-to-date CMOM <br /> documentation,including the checklist in Chapter 3 of the Guide. The Guide can be <br /> found online at <br /> httv'//v��n�'eaa Rovinpdes/pubs/cmom �*uide for collection svstems.vdf. The CMOM <br /> 10 <br />