CMOM: How To Be Prepared

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CMOM How To Be Prepared

• Frank Johns

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What is CMOM?

• Capacity assurance
• Management
• Operation
• Maintenance

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May 29, 1999 EPA Directive

• Improve protection of public health by
  developing, within one year, a strong national
  regulation to prevent the over 40,000 annual
  sanitary sewer overflows

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Wastewater Collection Systems

• Collect domestic sewage and other wastewaters
  from homes, industries, and other buildings and
  convey it to treatment plants
• Vital role in public health
• Public expects them to function effectively at a
  reasonable cost

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Sanitary Sewer Collection Systems

• Serve 150 million people (55 of population)
• 500,000 miles of pipe in publicly owned systems
• 19,000 municipal sanitary sewer collection
  systems
• 4,800 of these are satellite collection systems

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Inflow and Infiltration (I/I)

• Caused by deterioration of structural integrity
• High levels of I/I
• Increase hydraulic load on plants
• Reduced treatment efficiency
• Process bypass
• Wash out of biological organisms

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Sanitary Sewer Overflows (SSOs)

• Result in the release of raw sewage
• Health and environmental risks vary
• Location
• Volume
• Season
• Pollutants present
• Receiving water
• SSO vs unpermitted discharge

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Types of SSOs

• Overflows or releases of wastewater that reach
  waters of the US
• Overflows or releases of wastewater that do not
  reach waters of the US
• Wastewater backups into buildings that are caused
  by blockages or flow conditions in a sanitary
  sewer (excluding privately-owned lateral)

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Impacts of SSOs

• Human health
• Areas of high risk to human exposure
• Pathogens
• Environment
• Physical characteristics
• Viability of aquatic habitats
• Fish kills

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Existing System Performance

• Sanitary sewer systems experience periodic
  failures
• Performance varies from system to system
• Significant number of systems have SSOs
• Availability of information is system specific
  and an overall picture is incomplete
• EPA estimates 40,000 SSOs per year

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Major Causes of SSOs

• Peak flows exceeding capacity
• Blockages
• Structural failures of pipes and manholes
• Mechanical and electrical failures at lift
  stations
• Third party activities
• Combination of the above

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Typical Regulatory Response

• Poor performance leads to an increase in
  regulatory oversight of
• Management
• Operation
• Maintenance
• For which they hope to
• Reduce SSOs
• Improve treatment facility performance
• Extend life of system components

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Original Proposed Rule

• Expansion of NPDES requirements
• Standard permit conditions addressing CMOM
• Prohibition on discharge to waters of the US
• Requirements for reporting, public notification,
  and recordkeeping

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Regulated Entities

• Owners or operators of POTWs and municipal
  sanitary sewer collection systems
• Owners or operators of municipal satellite
  collection systems

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Municipal Satellite Collection Systems

• Sanitary sewers owned or operated by a
  municipality that convey sewage or industrial
  wastewater to a POTW that has a treatment plant
  owned or operated by a different municipality.

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Municipal Satellite Collection Systems

• Can make up a significant percentage of the total
  sewer length in a collection system
• Poorly performing systems can be major
  contributors to peak flow problems
• Investment in maintenance, repair, and enhanced
  capacity has lagged behind regional collection
  systems

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How Municipal Satellite Collection Systems
Regulated?

• Owner or operator of municipal satellite
  collection system obtain NPDES permit coverage
  and be responsible
• or
• Where sufficient arrangements made, NPDES permit
  for regional system would hold operator of
  regional system responsible

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Five General Performance Standards

• Properly manage, operate, and maintain, at all
  times, the parts of collection system that
  permittee owns or over which it has operational
  control
• Provide adequate capacity to convey base flows
  and peak flows

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Five General Performance Standards (continued)

• Take all feasible steps to stop, and mitigate the
  impact of, SSOs
• Provide notification to parties with a reasonable
  potential for exposure to pollutants associated
  with the SSO
• Develop a written summary of CMOM program and
  make it, and audits, available to the public upon
  request

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Five Elements of Program

• Develop and implement a CMOM program
• Develop and implement an overflow emergency
  response plan
• Develop a plan for system evaluation and capacity
  assurance
• Conduct periodic program audits
• Communicate with interested parties

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Documentation Requirements

• Written summary of CMOM program
• Overflow emergency response plan
• Program audit report
• If necessary, system evaluation and capacity
  assurance plan

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CMOM Elements

• Identify program goals
• Identify administrative and maintenance functions
  and lines of communication for reporting SSOs
• Include legal authorities for implementing CMOM
• Address measures and activities to meet
  performance standards
• Provide design and performance provisions
• Monitor program implementation and measure its
  effectiveness

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Overflow Emergency Response Plan

• Standardized course of action for SSOs
• Address mechanisms to
• Identify SSOs
• Provide immediate response and emergency
  operations
• Provide appropriate immediate notification
• Ensure personnel are adequately trained to
  implement plan

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Self-Audit Program Elements

• Be POTW Specific
• Have a Defined Purpose
• Be Goal-Oriented
• Use Performance Measures
• Performed Periodically
• Be Written
• By Trained Personnel

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When CMOM condition is incorporated in permit

• Comply with general performance standards
• Develop and implement a CMOM program that will
  result in compliance with the general standards
• Develop a written summary of CMOM program

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Recommended Deadlines(time period after permit
issuance, except as noted)
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Compliance With Requirements

• NPDES compliance and enforcement authorities
  primarily would be concerned with whether a
  permittee is fulfilling the obligations
  established by its permit conditions, e.g.,
  whether reports are submitted as required and
  whether the facility is undertaking required
  activities.

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Proposed SSO Prohibition

• Clarification that discharges to waters of US
  from a collection system are prohibited
• Framework for evaluating specific circumstances
  of SSOs
• Recognize exceptional circumstances
• Severe natural conditions
• Other factors

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Public Notification and Recordkeeping

• Existing standard permit conditions
• Noncompliance reporting
• Public notification
• Recordkeeping
• Public availability

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Public Notification and Recordkeeping

• Proposed standard permit conditions
• Reporting to NPDES authority
• Immediate notification to the public and other
  affected entities
• Annual reports
• Recordkeeping
• Posting of overflow locations

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Tiered Framework for Reporting

• All SSOs would be identified in annual reports
  and subject to recordkeeping requirements
• SSOs that result in discharge to waters of US
  identified in DMRs
• SSOs that may endanger human health subject to
  noncompliance reporting and public notification
• Locations where SSOs have potential to affect
  human health subject to posting requirements

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Small Systems

• Proposed rule looks at options
• Proposal for municipal sanitary sewer
  collection systems with an average daily flow of
  1 MGD or less, may
• Omit requirements for legal authority
• Omit certain measures and activities
• Modify design provisions

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Small Systems (continued)

• Proposal for municipal sanitary sewer
  collection systems with an average daily flow of
  2.5 MGD or less, may
• Omit requirement to develop written summary of
  CMOM plan
• Omit requirement to conduct audit and prepare
  audit report unless triggered by SSO that
  discharges to waters of US

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Effective Date For Provisions

• Notice of proposed rulemaking has been put on
  hold
• 120-day public comment period after publication
• Once a final rule
• Incorporated into NPDES permit
• Immediately comply with general performance
  standards (except notification)

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Questions?