Who will be affected by CMOM?
Every collection system owner (whether they have wastewater treatment facilities or not) will be required to obtain an NPDES permit. They owner must provide adequate capacity to convey base and peak flows, develop a plan to eliminate sanitary sewer overflows, and develop a preventative maintenance management program for the collection system. A formal CMOM compliance audit will assure participation, which may be self-administered by the utility.

What does CMOM mean to Collection System Owners?
The resulting health and environmental risks from poorly performing collection systems give need to increased regulatory oversight of the management, operation, and maintenance of these systems. CMOM is intended to provide a more efficient approach to controlling SSOs through an increased focus on system planning. The proposed rule would establish standard permit conditions for inclusion in existing NPDES permits and a means of regulating satellite systems. The conditions would include:

• Capacity, management, operation and maintenance requirements
• A prohibition on discharges
• Reporting, public notice, and record keeping for discharges.

Collection system owners should anticipate investment costs to manage and implement the CMOM program, both in terms of additional resources and capital improvements. It is believed that this increased investment will lower O&M costs, reduce the occurrence of sewer overflows and provide a health benefit to the public community.

What happens in the event of an Overflow?
If an overflow occurs, the Owner will be required to:

• Implement a documented overflow response plan which includes public and regulatory notification
• Notify the public that could be affected
• Make available a summary of their CMOM program, related audit activities, and results to interested parties.

What steps should Collection System Owners take?
CMOM programs are developed, managed, maintained, and administered by collection system owners. The first step is to perform an internal CMOM audit to identify the strengths and deficiencies of the organization. Depending on these results, owners may need to modify their O&M procedures, or implement condition assessment and hydraulic analysis programs restore or improve capacity.

Where can Owners find more information?

• A site was established by the WEF at www.CMOM.net. It is intended to be a clearing house for information related to the CMOM initiative.
• The EPA provides a checklist for assessing sewer system programs.
• A copy of the SSO proposed rule may be found on the EPA’s web site at www.epa.gov/npdes.
• The draft regulation is 40 CFR 122.42(f) and may be found on the EPA’s web site at the link above.
• Of course, you can always contact RJN Group for the latest information – please go to www.rjn.com to find the office closest to your location.

What is the estimated cost to implement CMOM? What is the source for the funding?
The EPA estimates that the costs to address SSOs caused by wet weather conditions and maintenance issues would result in an average household expenditure of between $75 and $160 per year. There are waivers available for systems that serve less than 2.5 mgd.

The CWA established a State Revolving to provide low interest loans for major, and some minor, replacements of sanitary sewer system components.

How can RJN Group help collection system owners fulfill the CMOM requirements?
RJN’s comprehensive CMOM services include:

• Regulatory assistance with CMOM Plan development, administration, and auditing
• Sewer evaluation and field inspection services using proven I/I source identification techniques.
• Hydraulic analysis through flow monitoring and hydraulic computer modeling to determine capacity deficiencies
• Engineering and rehabilitation design with consideration to product application, construction methods, quality assurance, and trenchless technologies
• Infrastructure management software (CASS WORKS®) to optimize O&M activities and to efficiently track and report CMOM program objectives and performance.
• Assistance in identifying fiscal needs through state revolving loans and grants.

RJN Group is your total CMOM Solution Provider, with more than 32 years of collection system experience. We have completed over 800 collection system I/I reduction projects nationwide.