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HomeMy WebLinkAbout75A - PH SEWER SYSTEMREQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: AUGUST 6, 2007 TITLE: PUBLIC HEARING: SEWER SYSTEM MANAGEMENT PLAN DEVELOPMENT PLAN AND SCHEDULE ,~ ) ~ '~L (~~i- CITY MANAGER RECOMMENDED ACTION CLERK OF COUNCIL USE ONLY: APPROVED ^ As Recommended ^ As Amended ^ Ordinance on 1~` Reading ^ Ordinance on 2ntl Reading ^ Implementing Resolution ^ Set Public Hearing For CONTINUED TO FILE NUMBER Adopt the Sewer System Management Plan Development Plan and schedule. DISCIISSION The California Regional Water Quality Control Board (RWQCB) adopted Order No. 2006-0003 on May 2, 2006. The order requires proper operation and maintenance of the City's sewer collection system and regulates sanitary sewer overflows (SSOs) from the system. Waste discharge requirements are established that are intended to protect the beneficial uses of surface waters and beaches in Orange County. Order No. 2006-0003 requires the City to prepare and implement a comprehensive Sewer System Management Plan (SSMP). The main goal of this plan is to prevent sanitary sewer overflows (SSO's) and to provide a plan and schedule for measures to be implemented to prevent future SSO's. The City prepared a SSMP in September, 2005. This document contains most of the provisions required under Order No. 2006-0003. City staff will be providing updates and revisions to the SSMP as required in Order No. 2006-003. While the City's current SSMP meets the major goals of Order No. 2006- 0003, the Order requires Council adoption of a Development Plan and Schedule to revise the SSMP. The proposed Sewer System Management Plan Development Plan and Schedule will meet this requirement. All of the SSMP revisions required in Order No. 2006-0003 must be completed by May 2, 2009. Once the SSMP revisions are complete, another public hearing will be held for Council adoption of the final SSMP. 75A-1 Public Hearing - Sewer System Management Plan Development Plan and Schedule August 6, 2007 Page 2 fiNVIRONMTNTAL IMPACT There is no environmental impact associated with this action. FISCAL IMPACT There is no direct fiscal impact associated with the adoption of this development plan or the final SSMP. However, the SSMP requires a sewer main replacement program that will require significant capital expenditures. The costs for sewer main replacements will be paid out of the Sanitary Sewer Service fund. (account 56-575). APPROVED AS TO FUNDS AND ACCOUNTS: s G. Ross Francisco Gutierrez utive Director Executive Director is Works Agency Finance & Management Services Agency 75A-2 SEWER SYSTEM MANA GEMENT PLAN DEVELOPMENT PLAN AND SCHEDULE (SSMP) for the City of Santa Ana July 25, 2007 Y:\Water Opera[ions\Engineering\O[her Agencies\OCSD\Waste Discharge Requirements Order\SSMP\SSMP DEVELOPMENT PLAN AND SCHEDULE 75A-3 SEWER SYSTEM MANAGEMENT PLAN DEVELOPMENT PLAN AND SCHEDULE Introduction The City of Santa Ana has completed the Sewer System Management Plan (SSMP) Development Plan and Schedule in accordance with the requirements of the Statewide General Waste Discharge Requirements (WDR) for Sanitary Sewer Systems. Because the Santa Ana Regional Water Quality Control Board (Region 8) issued a local Sewer WDR (Order No. R8-2002-0014) to north Orange County, many of the required Plans and Programs of the General WDR have already been developed and initiated or even completed in some cases. The existing SSMP prepared in response to the Region 8 Board WDR will be revised and amended as required to comply fully with the new Statewide WDR . When completed, the SSMP will be recommended for adoption by the City Council. CiTy staff will continually update the plan and bring it back to Council at intervals as specified in the WDR for approval. 75A-4 Table of Contents Required sections of the Sewer System Management Plan are: Page INTRODUCTION ............................................................... 2 (i) Goals .................................................. .......... 4 (ii) Organization ..................................................... .......... 4 (iii) Legal Authority ..................................................... .......... 6 (iv) Operation and Maintenance Program ........................ ......... 8 (v) Design and Performance Provisions ........................... ......... 11 (vi) Overflow Emergency Response Program .................. ......... 12 (vii) FOG Control Program ........................................... ......... 13 (viii) System Evaluation and Capacity Assurance Plan .......... ........ 14 (ix) Monitoring and Program Modifications ..................... ....... 16 (x) SSMP Program Audits ............................................. ......... 17 (xi) Communications ..................................................... ........ 18 SCHEDULE ..................................................................................... ............ 18 3 75A-5 (i) Goals: The goal of the SSMP is to provide a plan and schedule to properly manage, operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent SSOs, as well as mitigate any SSOs that do occur. The City of Santa Ana recognizes the importance of protecting ocean water quality by preventing sewer spills and has tailored its existing sewer system maintenance practices to comply with the new Waste Discharge Requirements (WDR). (ii) Organization: The SSMP must identify: (a) The name of the responsible or authorized representative as described in Section J of this Order. The authorized representative for the City oi' Santa Ana is: Thom Loughran, Water Resources Manager (714)647-3318 (b) The names and telephone numbers for management, administrative, and maintenance positions responsible for implementing specific measures in the SSMP program, including lines of authority by organization chart or similar document with a narrative explanation; and The City of Santa Ana has a current organization chart showing the lines of authority of the administrative and field staff for the Water Resources Division, Sewer Maintenance Section. A copy of this organization chart is attached. Telephone numbers for all of the positions are included in the Public Works Agency after hours callout manual. This manual is used by all Water Resources Division staff, including emergency sewer responders, for assistance during emergencies. 4 75A-6 SEWER SYSTEM ORGANIZATION CHART WATER RESOURCES MANAGER (714)647-3318 PRINCIPAL CIVIL ENGINEER FOG CONTROL PROGRAM MANAGER (714)647-3317 Cesar Barrera Senior Civil Engineer (714) 647-3387 WATER MAINTENANCE SUPERVISOR (714)647-3344 Vacant WATER MAINTENANCE CREW LEADER SEWER REPAIR CREW 2 EQUIPMENT OPERATORS 2 MAINTENANCE WORKER II VIDEO SEWER CLEANING CREWS SECTION 7 OPERATORS THAT MAINTAIN SEWER LIFT STATIONS (2 CREWS) 2 EQUIPMENT OPERATORS 2 MAINTENANCE WORKER II 75A-7 (c) The chain of communications for reporting SSOs, from receipt of a complaint or other information, including the person responsible for reporting SSOs to the State and Regional Water Board and other agencies if applicable (such as County Health Officer, County Environmental Health Agency, Regional Water Board, and/or State Office of Emergency Services (OES)). The Water Resources Manager is responsible for overseeing the reporting process. The Water Maintenance Supervisor receives the spill report from the field crew and prepazes a draft report. The Water Maintenance Supervisor is also responsible for notifying other agencies, including the Regional Water Board, Orange County Health Care Agency, and OES if applicable. The draft is then reviewed with the Principal Civil Engineer and Water Resources Manager with consideration given to volume calculations, vacuum and wash down operations, cause of spill, timeliness of response, etc. After discussions/reviews are complete, the report entered into the CIWQS on-line spill reporting database. The Water Resources Manager reviews the spill report and certifies the spill in the CIWQS database. (iii) Legal Authority: Each Enrollee must demonstrate, through collection system use ordinances, service agreements, or other legally binding procedures, that it possesses the necessary legal authority to: (a) Prevent illicit discharges into its sanitary sewer system (examples may include I/I, stormwater, chemical dumping, unauthorized debris and cut roots, etc); The City of Santa Ana currently enforces Orange County Sanitation District regulations prohibiting the dischazge of rainfall to the sewer system. This is done through the City's existing development approval process. No connections from any potential source of runoff are allowed to the City's sanitary sewer system. City Ordinance NS-2670 contains provisions that prohibit the discharge of chemicals, unauthorized debris, pollutants, and any solid or viscous substances that could cause obstruction to flow in the sewer collection system. 75A-8 (b) Require that sewers and connections be properly designed and constructed. The City of Santa Ana has standard plans and specifications for the construction of sanitary sewers, which insure the sewer lines and connections are properly designed and constructed. The City's Specifications by reference incorporate the Standard Plans and Specifications for Public Works Construction (Green Book), which helps insure proper design and construction of sewer facilities. (c) Ensure access for maintenance, inspection, or repairs for portions of the lateral owned or maintained by the Public Agency: The City of Santa Ana currently does perform repairs and/or replacements of damaged sewer laterals for the portion of the lateral located within the public right of way. Current City codes provide access to all facilities located within the public right of way. (d) Limit fats, oils, and grease and other debris that may cause blockages, The City of Santa Ana recognizes the significant impacts to sewer collection system operation caused by fats, oils and greases (FOG). In November of 2004, the City adopted a comprehensive FOG control ordinance (Ordinance NS 26-70). This ordinance establishes the legal authority required to implement a comprehensive FOG control program. (e) Enforce any violation of its sewer ordinances. Santa Ana sewer ordinances are currently enforced under Administrative Citation provisions of the municipal code. Public Works Agency Sanitation Inspectors have citation authority to enforce sewer ordinance provisions. 75A-9 (iv) Operation and Maintenance Program. The SSMP must include those elements listed below that are appropriate and applicable to the Enrollee's system: (a) Maintain an up-to-date map of the sanitary sewer system, showing all gravity line segments and manholes, pumping facilities, pressure pipes and valves, and applicable stormwater conveyance facilities. The City has a Sewer Atlas that shows the location of all sewer mains, manholes and pumping stations. The City does not have any pressure pipelines in the sewer system. The Atlas also has reference numbers to the particular construction plans that were used to build each portion of the system. The map is created and maintained by the Water Engineering Section. Currently, a Senior Civil Engineer and two Assistant Engineers are responsible for creating and updating all of the sewer maps and related databases. The Senior Civil Engineer also oversees the sewer video inspection program, as well as the sewer main condition assessments. The Senior Civil Engineer reports directly to the FOG Control Program Manager. The City has completed the conversion of all 186 manually drafted map sheets into a digital sewer atlas. The locations of all the storm water conveyance facilities are shown on separate maps prepared by the Public Works Agency Design Division. City sewer maintenance staff members recognize the link between a sewer spill and its travel in a storm drain facility to the receiving waters. The City educates its staff to understand the storm drain network and capture a spill before it has entered the storm drain system. 75A-10 (b) Describe routine preventative operation and maintenance activities by staff and contractors; including a system for scheduling regular maintenance and cleaning of the sanitary sewer system with more frequent cleaning and maintenance targeted at known problem areas. The Preventative Maintenance (PM) program should have a system to document scheduled and conducted activities, such as work orders: The City of Santa Ana has prepared a Sewer System Preventative Maintenance Plan (SSPMP) as require by the previous Region 8 WDR (Order No. R8-2002-0014). This plan will be revised and included in the Operation and Maintenance Program task element due on November 2, 2008. The City of Santa Ana has historically cleaned the sewer system once a year and continues to do so today. Once a year is the industry standard for agencies with comprehensive sewer maintenance programs. Areas needing more frequent cleaning - known as hot spots -are cleaned on a monthly or weekly interval. These are the inverted siphons that run under flood control channels or commercial areas with multiple restaurants. The City has two sewer cleaning trucks, each with atwo-man crew. In addition to these four workers, the City's Water Production staff maintain the two sewer lift stations. A total of seven production operators are trained in pump maintenance. In addition to the daily cleaning of the gravity sewer lines by the two man crews, the City has a sewer lift station maintenance program. The City performs weekly inspections of the lift stations, along with periodic equipment servicing based upon the manufacturer's recommendations and industry standards. 75A-11 (c) Develop a rehabilitation and replacement plan to identify and prioritize system deficiencies and implement short-term and long-term rehabilitation actions to address each deficiency. The program should include regular visual and TV inspections of manholes and sewer pipes, and a system for ranking the condition of sewer pipes and scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes that are at risk of collapse or prone to more frequent blockages due to pipe defects. Finally, the rehabilitation and replacement plan should include a capital improvement plan that addresses proper management and protection of the infrastructure assets. The plan shall include a time schedule for implementing the short- and long-term plans plus a schedule for developing the funds needed for the capital improvement plan; The City of Santa Ana has prepared a Sewer System Infrastructure Maintenance System (SSIMS) as required by the previous Region 8 WDR (Order No. R8-2002-0014). This system is currently being revised and a new system will be included in the Operation and Maintenance Program task element due on November 2, 2008. (d) Provide training on a regular basis for staff in sanitary sewer system operations and maintenance, and require contractors to be appropriately trained; and The City of Santa Ana has purchased two vacuum trucks so that City workers can respond directly to spills without calling a contractor. This has helped expedite the response to spills and insure that spills are contained and cleaned up in the shortest time possible. City sewer maintenance staff are trained in-house to properly clean and maintain the sewer collection system, as well as respond to spill emergencies. Water production staff are trained to operate and maintain all city pumping facilities and related equipment, including the two sewer lift stations. 10 75A-12 Although not required, City maintenance staff are encouraged to obtain California Water Environment Agency (CWEA) training and certification. Several staff members have received certification through this program. (e) Provide equipment and replacement part inventories, including identification of critical replacement parts. The two sewer lift stations each have two pumps, if one pump fails, the other pump runs until repairs are made. Both lift stations were equipped in July 2001 with automatic backup emergency diesel generators. An inventory of pipe and equipment is maintained at the City yard to make repairs to small sewer mains and laterals. The City has two vacuum trucks to insure availability of this equipment at all times. (v) Design and Performance Provisions: (a) Design and construction standards and specification for the installation of new sanitary sewer systems, pump stations and other appurtenances; and for the rehabilitation and repair of existing sanitary sewer systems; and The City's standards for the proper installation and inspection of sewer lines are discussed in Section (iii) (B) above. Additionally, the City has standardized its use of equipment in the pumping stations for ease of maintenance and replacement. This includes the pumps, liquid level indicators, electrical components, valves, piping and radios. The City uses sewer lining technology where these methods are cost effective and practical. The City has adopted the American Public Works Association Standard Specifications for Public Works Construction ("Greenbook") as its standard specification 11 75A-13 for sewer projects. The Greenbook specifications for pipeline rehabilitation are used as the standard for City projects. (b) Procedures and standards for inspecting and testing the installation of new sewers, pumps, and other appurtenances and for rehabilitation and repair projects. The City of Santa Ana has developed standard plans and specifications for the construction of new sewer infrastructure. Inspection and testing of new construction is accomplished by trained City Public Works Agency construction inspectors. These inspectors insure that all sewer projects are completed in accordance with the City's standards. (vi) Overflow Emergency Response Plan -Each Enrollee shall develop and implement an overflow emergency response plan that identifies measures to protect public health and the environment. At a minimum, this plan must include the following: (a) Proper notification procedures so that the primary responders and regulatory agencies are informed of all SSOs in a timely manner; (b) A program to ensure an appropriate response to all overflows; (c) Procedures to ensure prompt notification to appropriate regulatory agencies and other potentially affected entities (e.g. health agencies, Regional Water Boards, water suppliers, etc.) of all SSOs that potentially affect public health or reach the waters of the State in accordance with this MRP. All SSOs shall be reported in accordance with this MRP, the California Water Code, other State Law, and other applicable Regional Water Board WDRs or NPDES permit requirements. The SSMP should identify the officials who will receive immediate notification; 12 75A-14 (d) Procedures to ensure that appropriate staff and contractor personnel are aware of and follow the Emergency Response Plan and are appropriately trained; (e) Procedures to address emergency operations, such as traffic and crowd control and other necessary response activities; and (f) A program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impact on the environment resulting from the SSOs, including such accelerated or additional monitoring as may be necessary to determine the nature and impact of the discharge. The City of Santa Ana currently has a Sewage Spill Procedures plan and is following the notification procedures based on the new CIWQS on-line SSO Reporting System Database. This plan will be reviewed, amended and updated to fully comply with all of the items in section (vi) of the WDR. The plan will be completed by November 2, 2008 as required in the WDR. (vii) FOG Control Program: Each Enrollee shall evaluate its service area to determine whether a FOG control program is needed. If an Enrollee determines that a FOG program is not needed, the Enrollee must provide justification for why it is not needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG source control program to reduce the amount of these substances discharged to the sanitary sewer system. This plan shall include the following as appropriate: (a) An implementation plan and schedule for a public education outreach program that promotes proper disposal of FOG; 13 75A-15 (b) A plan and schedule for the disposal of FOG generated within the sanitary sewer system service area. This may include a list of acceptable disposal facilities an/or additional facilities needed to adequately dispose of FOG generated within a sanitary sewer system service area; (c) The legal authority to prohibit discharges to the system and identify measures to prevent SSOs and blockages caused by FOG; (d) Requirements to install grease removal devices (such as traps or interceptors), design standards for the removal devices, maintenance requirements, BMP requirements, record keeping and reporting requirements; (e) Authority to inspect grease producing facilities, enforcement authorities, and whether the Enrollee has sufficient staff to inspect and enforce the FOG ordinance; (f) An identification of sanitary sewer system sections subject to FOG blockages and establishment of a cleaning maintenance schedule for each section; and (g) Development and implementation of source control measures for all sources of FOG discharged to the sanitary sewer system for each section identified in (f) above. A major collaborative effort took place in this SSMP requirement during the development of our existing SSMP. A FOG Control Program Manual was developed to specify the key elements of our ongoing FOG Control Program, and will be further discussed and updated (as necessary) by the November 2, 2008 date as required in the WDR. (viii) System evaluation and Capacity Assurance Plan: The Enrollee shall prepare and implement a capital improvement plan (CIP) that will provide hydraulic 14 75A-16 capacity of key sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate design storm or wet weather event. At a minimum, the plan must include: (a) Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that are experiencing or contributing to an SSO discharge caused by hydraulic deficiency. The evaluation must provide estimates of peak flows (including flows from SSOs that escape from the system) associated with conditions similar to those causing overflow events, estimates of the capacity of key system components, hydraulic deficiencies (including components of the system with limiting capacity) and the major sources that contribute to the peak flows associated with overflow events; (b) Design Criteria: Where design criteria do not exist or are deficient, undertake the evaluation identified in (a) above to establish appropriate design criteria; and (c) Capacity enhancement measures: The steps needed to establish ashort- and long-term CIP to address identified hydraulic deficiencies, including prioritization, alternatives analysis, and schedules. The CIP may include increases in pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and storage facilities. The CIP shall include an implementation schedule and shall identify sources of funding. (d) Schedule: The Enrollee shall develop a schedule of completion dates for all portions of the capital improvement program developed in (a)-(c) above. This schedule shall be reviewed and updated consistent with the SSMP review and update requirements as described in Section D. 14. 15 75A-17 The 2003 Sewer Master Plan Update and Infiltration and Inflow Study analyzed the capacity of larger city sewers (generally 10 inch diameter and larger) for peak flow conditions under both dry and wet weather conditions. Deficient sewer line segments are identified for prioritization in the capital replacement program. No dry -weather hydraulic capacity deficiencies exist to staffls knowledge, and recent projects have eliminated the major known wet-weather related deficiencies. We are working with OCSD on ajoint project to correct a deficiency on the Bristol Street Trunk sewer, portions of which are owned by both OCSD and the City of Santa Ana. (ix) Monitoring, Measurement, and Program Modifications: The Enrollee shall: (a) Maintain relevant information that can be used to establish and prioritize appropriate SSMP activities; The City of Santa Ana has created and uses extensive data sets to monitor SSMP related activities. Enhancements to the data collection and analysis activities are in process, including a portable digital map based system for field use. When complete, this system will be used by engineering and maintenance staff to more efficiently operate and maintain the sewer collection system. This system will enhance analysis and prioritization of SSMP activities. (b) Monitor the implementation and, where appropriate, measure the effectiveness of each element of the SSMP; The City of Santa Ana has assigned a Senior Civil Engineer to oversee the implementation of all SSMP activities. This position works closely with the sewer maintenance crews and FOG sanitation inspectors to implement all of the SSMP activities. 16 75A-18 SSMP activities aze also discussed at bi-weekly staff meetings with the Water Resources Manager and division supervisors. Additional meetings to assess the effectiveness of individual elements aze held as needed. (c) Assess the success of the preventative maintenance program; Santa Ana has for many years used two in-house crews to clean sewer collection pipelines on an annual basis. We believe this program has been very effective in reducing both the number and size of SSO's to a very low level. The Water Maintenance Supervisor is in charge of the routine preventative maintenance program. Line cleaning methods and schedules are continuously modified as needed based upon changed field conditions. This position works closely with the Senior Civil Engineer to use available technology enhancements to improve the effectiveness of the maintenance program. (d) Update program elements, as appropriate, based on monitoring or performance evaluation; and The SSMP and its elements will be updated in accordance with the results of the monitoring described herein. Revisions to the FOG program as well as the Sewer Spill Procedures have been made in the past, and additional program revisions will be made as required. (e) Identify and illustrate SSO trends, including frequency, location, and volume. The City of Santa Ana has records of all SSOs dating back to 1999. Using this data, we track SSO trends and make program adjustments as required. (x) SSMP Program Audits - 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 17 75A-19 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. The City of Santa Ana will develop an internal audit program to evaluate the effectiveness of the SSMP and our compliance with the SSMP requirements. SSMP Deficiencies identified in the audit process will be corrected with program updates as required. The program audits will be implemented by the May 2, 2009 date as required in the WDR. (xi) Communication Program -The Enrollee shall communicate on a regular basis with the public on the development, implementation, and performance of its SSMP. The communication system shall provide the public the opportunity to provide input to the Enrollee as the program is developed and implemented. The Enrollee shall also create a plan of communication with systems that are tributary and/or satellite to the Enrollee's sanitary sewer system. The City of Santa Ana is currently using it's website to convey information on the FOG control program to the public. This medium can be expanded to include other program elements. The public will also be informed during the public heazing process as the SSMP and updates are adopted. SCHEDULE The City of Santa Ana acknowledges and agrees to the WDR time schedule as outlined in the table below: 18 75A-20 _ _ ~~ Boaz. -l ~~.,,il.. Sidon ~ a 491~it98 ~ _ _ Fpp4~14t10A P.p,~utaibn 1~e4~+ean 9etween ~ ~ - ~°n ~ ~ I q pp amt 49.804 t0.9~ an6 2,60 ! 0 , _ --- SSMP Development Plan and -, '. -------- ~ '~. ~ _ '. _ r-- ~ Schedule '~, ~ August 2, 2007 '~, November 2, 2007 '~, February 2, 2008 '~.. May 2, 2008 : No Specific Section ' '~, ', ', Goal ~I j I '. Section D 13 (~) ,___._.._._.. ____ -- ~ November 2, I November 2, 2007 i --~ 2007 May 2 2008 ' ~'. May 2, 2008 ' Organization ~ '~, ', Section D 13 (ii) ~ - '. Legal Authority Section D 13 (iii) ~~ '~ ' -----. _._.......-- --. - Operation and Maintenance ' -1 i ~ I '. Program ~ ~ Section D 13 (iv) ---_--- ---...._. __ '. November 2, ' November 2 ~: y ~ Ma 2 2009 ', February 2, ~. ~ Overflow Emergency , '~, 2008 I 2009 ', 2010 Response Program Section D 13 (viJ ', I, FOG Control Program ~'~. '~.. ', Section D 13 (iivJ -~ I ~ Design and Performance ', Provisions ', ~ ~~ Section D 13 (v) -._ _' '. System Evaluation and '', , Capacity Assurance Plan j ~ ~ ' Section D 13 (viii) ---- "~~. ', ~ ', Monitoring and Program Modifications '. '. '. ~ May 2, 2009 August 2, 2009 May 2, 2010 August 2, 2010 Section D 13 (ix) ', '~, ! ' Program Audits ~ '.. Section D 13 (x) , '. '~. Communication Program ~! ' ', Section D 13 (xi) '~, , ~ '~.. Final SSMP Implementation ~I ~ ~~ ~~ End of SSMP Development Plan and Schedule 19 75A-21 75A-22