cMOM

1. cMOM Water Environment Federation Collection Systems Committee –cMOM Subcommittee

2. What is cMOM? C – Capacity M – Management O - Operation M - Maintenance of Municipal Sanitary Sewer Collection Systems Water Environment Federation Collection Systems Committee –cMOM Subcommittee

3. cMOM • New Provision of the Clean Water Act Regulates Sanitary Sewer Overflows (SSOs) The proposed rule would: • Reduce health/environmental risks • Improve the performance of treatment facilities • Protect the nation’s collection systems • Reduce equipment and operational failures • Extend the life of the treatment equipment Water Environment Federation Collection Systems Committee –cMOM Subcommittee

4. What is the SSO Policy Development? • EPA began the process in 1994 because of inconsistent enforcement • Draft notice of proposed rulemaking signed January 2001 • Published in the Federal Register on January 24, 2001 • Withdrawn from the Federal Register due to Administration change • Agency is revising the analysis and preamble of proposed rule • EPA plans to publish this proposal in the Federal Register in the Spring of 2003 Water Environment Federation Collection Systems Committee –cMOM Subcommittee

5. So What? • cMOM is part of the EPA’s strategy for managing SSOs • cMOM will affect every collection system in the US regardless of the size of the system • Some EPA regions are already implementing using the Region 4 model (1, 4, 9) • Regions 5 and 6 are ramping up ……….the states will follow………. Water Environment Federation Collection Systems Committee –cMOM Subcommittee

6. What are the Consequences? • Consent Agreements Cincinnati Consent Decree -msdgc.org • Administrative Orders • Fines………both criminal and civil Water Environment Federation Collection Systems Committee –cMOM Subcommittee

7. What are the levels of Enforcement? • No Order • Review, evaluate and revise program, but don’t submit • Submit for review and comment • Litigation, negotiation and mandated program Water Environment Federation Collection Systems Committee –cMOM Subcommittee

8. OK……So what do I do now? Use this window of opportunity • Get ready for cMOM • Satellite systems may get a NPDES permit • Doing a good job? Then document and improve • If you aren’t doing a good job……………………………. Water Environment Federation Collection Systems Committee –cMOM Subcommittee

9. cMOM Requires………… • Provide capacity to convey base and peak flow ………..………………….AND…………..………. • Proper management, operation and maintenance, at all times, of all parts of the collection system that you own or have operational control Water Environment Federation Collection Systems Committee –cMOM Subcommittee

10. You must…. • Take steps to stop and mitigate SSOs • Provide notification to anyone with potential exposure • Develop written summary of cMOM program • Show staff responsibilities and chain of command Water Environment Federation Collection Systems Committee –cMOM Subcommittee

11. Capacity: the “c” in cMOM…… • Existing and future collection system components • Base and peak flow adequacy • If deficient • Identify components • Measures for implementing new capacity or flow reductions • Existing and future treatment facility components • Base and peak flow adequacy for compliance • Add capacity or flow reduction plan Water Environment Federation Collection Systems Committee –cMOM Subcommittee

12. Management • Control I/I • Require proper design and construction • Ensure proper installations • Manage flows from satellite systems • Comply with Pretreatment Standards (40CFR 403.5) • Train staff on all elements of cMOM program Water Environment Federation Collection Systems Committee –cMOM Subcommittee

13. ManagementInformation • Map of collection system • Identify trends in overflows • Maintain three years of: • work order history, • complaints, • performance and implementation measures • List of components with lack of capacity • Non-compliance events due to overflows • Requirements and/or standards for • New sewers, pumps and appurtenances • Repair and rehabilitation projects Water Environment Federation Collection Systems Committee –cMOM Subcommittee

14. Operation • Develop and implement an SSO response plan • Respond and investigate all calls • Coordinate with state and local agencies • Notify and report this process • Stop and mitigate impacts ASAP Water Environment Federation Collection Systems Committee –cMOM Subcommittee

15. Operation • Plan distribution and maintenance • Inform and implement with staff • Provide training • Provide for review and update Water Environment Federation Collection Systems Committee –cMOM Subcommittee

16. Operation Notification procedure to limit exposure: • Public Notification Program • Limit access • Post at SSO outfall locations • Provide media/public notifications • Immediate notification of Health Officials and NPDES Authority Water Environment Federation Collection Systems Committee –cMOM Subcommittee

17. Maintenance • Perform adequate preventive maintenance on collection system • Program to identify and prioritize: • Structural deficiencies • I/I Water Environment Federation Collection Systems Committee –cMOM Subcommittee

18. How do you start? • Compliance Audits (Gap Analysis) • Conduct an audit of the cMOM program and submit with NPDES • Base this upon: • Interview with staff • Field inspections of equipment • Observations of crews • Review of records Water Environment Federation Collection Systems Committee –cMOM Subcommittee

19. What is next? • Address findings and deficiencies • Document steps taken to respond to findings • Schedule of additional steps needed to respond to findings Water Environment Federation Collection Systems Committee –cMOM Subcommittee

20. Solutions • Establish communications • Develop information/education programs • Evaluate alternative solutions: • Risks • Financial Implications • Capital Improvements, short term and long term • Operation and Maintenance • Minimize decisions based on political influence • Look at what is good for the regional community Water Environment Federation Collection Systems Committee –cMOM Subcommittee

21. So who is doing this now? • City Water and Wastewater Utilities Division • Oklahoma City, Oklahoma • Greenwood Metropolitan Authority • Greenwood County, South Carolina • Public Utilities, Clearwater Florida • Fairfax County Wastewater Collection Division • Fairfax County, Virginia See details about these case studies at: http://cfpub.epa.gov/npdes/sso/featuredinfo.cfm?program_id=4 Water Environment Federation Collection Systems Committee –cMOM Subcommittee

22. Resources • www.CMOM.net • Water Environment Federation (WEF) • www.wef.org • University of Wisconsin, Madison • October and February courses • University of Nevada, Las Vegas • April and May courses • Member Associations • State Collection Systems Committees • State Environmental Regulators • Peers • EPA and EPA regions Water Environment Federation Collection Systems Committee –cMOM Subcommittee

23. Questions? Water Environment Federation Collection Systems Committee –cMOM Subcommittee

24. Use this next set of slides if needed Water Environment Federation Collection Systems Committee –cMOM Subcommittee

25. Municipal Satellite Collection SystemsWhat are they? • Owned or operated by a “state” or a “municipality” • Used to convey municipal sewage or industrial waste to a POTW that has an NPDES permit or is required to apply for such permit and • The owner/operator is not the owner/operator of the POTW that has the NPDES permit or has applied for an NPDES permit Water Environment Federation Collection Systems Committee –cMOM Subcommittee

26. Municipal Satellite Collection SystemsThe Director of the NPDES Authority must: • Issue a permit to the owner/operator of the satellite system that: • Requires the implementation of standard permit conditions throughout the satellite system OR • Where the Director had legal authority, issue a permit to the operator of the POTW which receives wastewater from the satellite system Water Environment Federation Collection Systems Committee –cMOM Subcommittee

27. Municipal Satellite Collection SystemsWhat does this mean? • If you are a satellite system • Permit under Regional agency that has NPDES permit • New NPDES permit for satellite agency • Issues • Willingness of Regional agency to cover under their permit: • Base Flow/Peak Flow • I/I Control • Liability for violations • Condition of satellite collection systems • O&M program effectiveness • Financial Resources Water Environment Federation Collection Systems Committee –cMOM Subcommittee