Preparing for CMOM; Challenges, Opportunities and New Approaches?

In order to improve water quality from point source discharges, the United States Environmental Protection Agency (EPA) is proposing comprehensive strategies in the new Sanitary Sewer Overflow (SSO) rule. The SSO rule will require owners of the sanitary collection system to exercise decision-making skills so that the utility, agency or municipality will be in the best position possible to comply with the rule. These strategies will have significant impacts in regards to resources required from the local, state and federal governments and citizens. This paper will address the various aspects of the SSO rule as it affects Metropolitan St Louis Sewer District (MSD) and possibly other agencies, operators and municipalities. Another paper in the US Congress will focus on a new tool for estimating rainfall dependent inflow and infiltration (RDII). The method employed is a statistical model approach to predict RDII at any point in a collection system when applied to the principal sewershed characteristics. The SSO rule has four themes that will need to be a part of an owner's strategic approach: 1. A management approach for each sewershed or treatment area; 2. Public notification, reporting and record keeping requirements; 3. Prohibition provision for overflows; 4. Capacity Assurance, Management, Operations and Maintenance (CMOM) program. BACKGROUND The United States Legislative Branch enacted on October 18 1972, Public Law 92-500 to provide the nation with a comprehensive water quality policy. The passage of the Federal Water Pollution Control Act Amendments of 1972, more commonly known as the Clean Water Act (CWA), is often referred as farsighted, successful, and significant legislation. The objectives of the act are to restore and maintain the chemical, physical, and biological integrity of the nation's waters. The implementation of various programs of the Clean Water Act has made significant improvements to our nation's waters. The Clean Water Law has provided many programs to improve water quality in our nation, with the latest being the SSO rule.