Capacity, Management, Operation and Maintenance CMOM - Kentucky Energy and Environment Cabinet

What is CMOM?

“CMOM” stands for Capacity, Management, Operation, and Maintenance. A CMOM program is a framework of self-assessment and practices that help a sewer system manage, operate, and maintain their collection systems; investigate and provide adequate collection system and treatment plant capacities; and respond to and prevent unauthorized discharges such as sanitary sewer overflows (SSOs) and other non-compliance. The CMOM program should incorporate many of the standard operation and maintenance activities that are routinely implemented by Publicly Owned Treatment Works (POTWs). An effective CMOM program should not add significant additional burden on a POTW but, by implementing a CMOM program, the POTW can move from a reactive approach to a proactive approach that results in fewer SSOs, improved wastewater treatment, and less expense.

The goals of a comprehensive CMOM program are:

To better manage, operate, and maintain the collection system;
Investigate capacity constrained areas of the collection system and treatment plant;
Proactively prevent or minimize unauthorized discharges;
Respond to overflow events and other non-compliance; and
Proactively prevent or minimize the potential for the release of pollutants from associated activities through treatment plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from storage areas.

Specific CMOM programs may address budgeting, staffing, training, public education, inventory, preventive maintenance and cleaning, rehabilitation, overflow response, fats, oils and grease, backup power, root control, and system capacity. POTWs can conduct a self-assessment to determine which specific CMOM programs are appropriate for their sewer system, and determine the status of programs that may already exist or will need to be developed.

What are the KPDES permit requirements for cities with CSOs?

For more information contact:

Mark Absher,

Environmental Section Supervisor

502-782-4469

CMOM Self-Assessment

The KPDES permit requires that POTWs complete a CMOM self-assessment using the checklist in the “Guide for Evaluating Capacity, Management, Operation, and Maintenance (CMOM) Programs at Sanitary Sewer Collection Systems,” EPA 305-B-05-002 to determine the appropriate CMOM programs for the POTW. Once the checklist is completed, the POTW can develop a proposed Plan of Action. Completion of the self-assessment checklist and implementation of appropriate CMOM programs shall be as soon as possible, but no later than one year from the effective date of the permit.

CMOM Plan of Action

At a minimum the CMOM Plan of Action shall include the following:

Self-Assessment summary (including recommended improvements and schedules):
Collection System Diagram;
Sewer Overflow Response Protocol (SORP);
Best Management Practices (BMPs); and
Any other constituent programs necessary to achieve the goals of the CMOM program.

A copy of the CMOM Plan of Action and all applicable CMOM program documents should be maintained at the POTW and made available to DOW upon request.

Collection System Diagram

The collection system diagram shall include the following:

Scale;
North arrow;
Date the map was drafted and most recent revision;
Street names;
Surface waters;
Service area boundaries;
Manholes and other access points (including structure IDs);
Sewer lines;
Pump stations (including structure IDs);
Wastewater treatment plants;
Permitted discharge points or outfalls (including CSO outfalls);
CSO regulators, for combined sewer systems; and
Locations of recurring SSOs that occurred within the last five (5) years prior to the effective date of the KDPES permit.

Sewer Overflow Response Protocol (SORP)

At a minimum the SORP shall include the following elements:

An overflow response procedure including designated responders for the POTW, response times, and cleanup methods;
A public advisory procedure;
A regulatory agency notification procedure;
A manhole and pump station inspection schedule;
A procedure for addressing discharges to buildings caused by blockage, flow condition, or other malfunction in sewer infrastructure owned or operationally-controlled by the POTW; and
A requirement to include the structure ID for reported incidents.

Best Management Practices (BMPs)

BMPs are schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to implement the prohibitions listed in the KDPES permit for POTWs. BMPs also include treatment requirements, operating procedures, and practices to control treatment plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw materials storage.

Modifications of CMOM Programs and Documentation

The CMOM Plan of Action and associated CMOM programs documentation should be updated whenever there are changes in the collection systems or treatment plants which materially affect the information specified in applicable documents. If any of the CMOM programs prove to be ineffective in achieving the general objective of preventing and eliminating unauthorized discharges such as SSOs, the permit and/or specific CMOM programs may be modified to address deficiencies. If at any time following the issuance of the permit any of the CMOM programs are found to be inadequate pursuant to a state or federal site inspection or review, affected CMOM programs and documentation may need to be modified to incorporate appropriated changes necessary to resolve regulatory concerns.