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

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 Draft notice of proposed rulemaking signed January 2001  Published in the Federal Register on January 24, 2001  Withdrawn from the Federal Register due to Administration change  Agency is revising the analysis and preamble of proposed rule  EPA plans to publish this proposal in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

 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………. So What? Water Environment Federation Collection Systems Committee –cMOM Subcommittee

Prohibits any discharge prior to the WWTP  Provides consideration for severe natural causes No feasible alternativesNo feasible alternatives Does not exclude if reasonable alternatives existDoes not exclude if reasonable alternatives exist Reported within 10 days under this provisionReported within 10 days under this provision Prohibition Water Environment Federation Collection Systems Committee –cMOM Subcommittee

Demonstrate and document that cause was exceptional  Beyond the control of the agency  Could not have been prevented  Reported within 10 days under this provision  Reasonable steps taken to stop and mitigate Prohibition…also provides for affirmative defense Water Environment Federation Collection Systems Committee –cMOM Subcommittee

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

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

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

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

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 commandShow staff responsibilities and chain of command Water Environment Federation Collection Systems Committee –cMOM Subcommittee

Capacity: the “c” in cMOM……  Existing and future collection system components  Base and peak flow adequacy  If deficient Identify componentsIdentify components Measures for implementing new capacity or flow reductionsMeasures 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

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

Management Information  Map of collection system  Identify trends in overflows  Maintain three years of: work order history, work order history, complaints, complaints, performance and implementation measuresperformance 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 appurtenancesNew sewers, pumps and appurtenances Repair and rehabilitation projectsRepair and rehabilitation projects Water Environment Federation Collection Systems Committee –cMOM Subcommittee

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

Operation  Plan distribution and maintenance Inform and implement with staffInform and implement with staff Provide trainingProvide training Provide for review and updateProvide for review and update Water Environment Federation Collection Systems Committee –cMOM Subcommittee

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

Maintenance  Perform adequate preventive maintenance on collection system  Program to identify and prioritize: Structural deficienciesStructural deficiencies I/II/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 NPDESConduct an audit of the cMOM program and submit with NPDES  Base this upon: Interview with staffInterview with staff Field inspections of equipmentField inspections of equipment Observations of crewsObservations of crews Review of recordsReview of records Water Environment Federation Collection Systems Committee –cMOM Subcommittee

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

Solutions  Establish communications  Develop information/education programs  Evaluate alternative solutions: RisksRisks Financial ImplicationsFinancial Implications Capital Improvements, short term and long termCapital Improvements, short term and long term Operation and MaintenanceOperation 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?  City Water and Wastewater Utilities Division Oklahoma City, OklahomaOklahoma City, Oklahoma  Greenwood Metropolitan Authority Greenwood County, South CarolinaGreenwood County, South Carolina  Public Utilities, Clearwater Florida  Fairfax County Wastewater Collection Division Fairfax County, VirginiaFairfax County, Virginia See details about these case studies at: Water Environment Federation Collection Systems Committee –cMOM Subcommittee

Resources   Water Environment Federation (WEF)  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

Questions?

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

Municipal Satellite Collection Systems 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:  Issue a permit to the owner/operator of the satellite system that: Requires the implementation of standard permit conditions throughout the satellite system ORRequires 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 systemWhere 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?  If you are a satellite system Permit under Regional agency that has NPDES permitPermit under Regional agency that has NPDES permit New NPDES permit for satellite agencyNew NPDES permit for satellite agency  Issues Willingness of Regional agency to cover under their permit: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