Transcript cMOM

cMOM
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
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
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
What is the SSO
Policy
Development?
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EPA began the process in 1994 because of inconsistent enforcement
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Draft notice of proposed rulemaking signed January 2001
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Published in the Federal Register on January 24, 2001
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Withdrawn from the Federal Register due to Administration change
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Agency is revising the analysis and preamble of proposed rule
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EPA plans to publish this proposal in the Federal Register in the
Spring of 2003
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
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
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Some EPA regions are already implementing using the Region 4
model (1, 4, 9)
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Regions 5 and 6 are ramping up ……….the states will follow……….
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
What are the
Consequences?
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Consent Agreements
Cincinnati Consent Decree -msdgc.org
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Administrative Orders
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Fines………both criminal and civil
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
What are the
levels of
Enforcement?
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No Order
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Review, evaluate and revise program, but don’t submit
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Submit for review and comment
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Litigation, negotiation and mandated program
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
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
cMOM
Requires…………
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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
You must….
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Take steps to stop and mitigate SSOs
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Provide notification to anyone with potential exposure
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Develop written summary of cMOM program
• Show staff responsibilities and chain of command
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Capacity: the
“c” in
cMOM……
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Existing and future collection system components
 Base and peak flow adequacy
 If deficient
• Identify components
• Measures for implementing new capacity or flow
reductions
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Existing and future treatment facility components
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
Base and peak flow adequacy for compliance
Add capacity or flow reduction plan
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Management
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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
Management
Information
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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
Operation

Develop and implement an SSO response
plan
• Respond and investigate all calls
• Coordinate with state and local agencies
• Notify and report this process
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Stop and mitigate impacts ASAP
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Operation
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Plan distribution and maintenance
• Inform and implement with staff
• Provide training
• Provide for review and update
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Operation
Notification procedure to limit exposure:
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Public Notification Program
• Limit access
• Post at SSO outfall locations
• Provide media/public notifications
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Immediate notification of Health Officials and
NPDES Authority
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Maintenance

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Perform adequate preventive maintenance on
collection system
Program to identify and prioritize:
• Structural deficiencies
• I/I
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
How do you
start?

Compliance Audits (Gap Analysis)
• Conduct an audit of the cMOM program and submit with
NPDES
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Base this upon:
•
•
•
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Interview with staff
Field inspections of equipment
Observations of crews
Review of records
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
What is next?
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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
Solutions
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Establish communications
Develop information/education programs
Evaluate alternative solutions:
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•
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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
So who is doing this now?
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City Water and Wastewater Utilities Division
• Oklahoma City, Oklahoma
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Greenwood Metropolitan Authority
• Greenwood County, South Carolina
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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
Resources
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www.CMOM.net
Water Environment Federation (WEF)
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University of Wisconsin, Madison
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•
www.wef.org
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October and February courses
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April and May courses
University of Nevada, Las Vegas
Member Associations
State Collection Systems Committees
State Environmental Regulators
Peers
EPA and EPA regions
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Questions?
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Use this next set of slides if
needed
Water Environment Federation Collection Systems Committee –cMOM Subcommittee
Municipal Satellite
Collection Systems
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What 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
Municipal Satellite Collection
Systems
The Director of the NPDES
Authority must:
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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
Municipal Satellite Collection
Systems
What does this mean?
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If you are a satellite system
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Issues
• Permit under Regional agency that has NPDES permit
• New NPDES permit for satellite agency
• Willingness of Regional agency to cover under their permit:
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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