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Innovative Use of Administrative Order

Authority

Management, Operation and Maintenance (MOM) Program

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What is an SSO?

Release of raw sewage from a sanitary collection system prior to a treatment plant

Spills out of manholes, into homes, businesses, property, and waters of the U.S.

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What Causes SSOs?

Source: U.S. Environmental Protection Agency

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How Serious is the Problem?

19,500 municipal sanitary sewer systems in the U.S.

More than half of all systems have peak flow problems at the treatment plant.

Reporting of SSO events is incompletePermit requirements are inconsistent.

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Why are SSOs Prohibited?

Protect public healthPrevent public and private

property damagePrevent resource damage

Surface watersFish/shellfish bedsGroundwater

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Benefits of SSO Control

Improved collection system performance.Reduced long-term rehabilitation costs.Reduced risk for public exposure to

untreated sewage.Improved recreational opportunities in

areas previously impacted by SSOs.Framework for prioritizing repair and

rehabilitation efforts.

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Costs of SSO Control

$90 billion in rehabilitation needs *

Rehabilitation needs are a small fraction of value of existing infrastructure.$1-2 trillion to replace existing infrastructure.

Increased preventative and predictive maintenance costs.

Personnel hours required to implement MOM requirements.

* U.S. Environmental Protection Agency, 1996 Clean Water Needs Survey

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MOM Approach to SSOs

Concentrate on the causes of SSOs rather than the individual discharges.

SSOs are the result of inadequate or nonexistent Management, Operation, and Maintenance (MOM) Programs.

For all utilities to have in place an adequate MOM Program.

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MOM Program

The Clean Water Act and the NPDES permits require the permittee to properly operate and maintain their waste treatment systems which includes the collection system.

SSOs are an indication of improper operation and maintenance.

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MOM Program

MOM programs include:Overflow response (contingency) plan,Grease control program,Sewer cleaning program,Sewer system assessment and

rehabilitation programsCapacity certification program

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MOM Program

MOM programs continued:Pump station inspection, operation and

maintenance programs,Information management systemSewer mapping program

For an expanded listing see the FAQs and Links at www.epa.gov/region4/water/wpeb/momproject/index.html

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MOM Program

Every proper MOM Program should contain the following seven elements :

Must be POTW specific.Must have a purpose.Must have a defined goal.Must be in writing.

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MOM Program

Seven MOM Program elements, continued:Must be implement by trained personnel.Must have performance measures.Must be subject to periodic evaluation.

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MOM Program

Under the MOM Programs Project, EPA asks permitted wastewater utilities, and any associated satellite utilities, to perform a detailed audit of the MOM Programs associated with their wastewater infrastructure.

Participants provide a report which includes the audit results, any improvements that can be made, and any schedules necessary to make those improvements.

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MOM Program

By self-disclosing any needed improvements, the participants can work with the permitting agency to develop a self assessment schedule.

Ultimately, program fixes may be incorporated in a permit or order.

Order would have no or significantly reduced penalty.