cMOM Program Audits cMOM Program Audits � … NPDES permit application with audit of � … NPDES permit application with audit of your program , SSOs, compliance, your program , SSOs, compliance, deficiencies, and corrective actions deficiencies, and corrective actions
Compliance Audits Compliance Audits � Conduct and certify that an audit to evaluate a cMOM Program including SSORP � Develop an audit report based on interviews with: Staff – Field inspections of equipment – Observations of crews – Records reviews – Address findings and deficiencies – Document steps taken to respond to findings – Schedule of additional steps needed to respond – to findings � Keep two most recent compliance audits on file
Signature, Certifications and Signature, Certifications and Director’s Review Director’s Review � Required when major modifications are made � Make the SSORP and cMOM Program data available to State and EPA � Make available to downstream system and Plant Operators
Communications Communications � … with various parties � … with various parties � … how your cMOM program is working … � … how your cMOM program is working … � … with input from interested parties to � … with input from interested parties to help your cMOM program be responsive help your cMOM program be responsive � Local community stakeholders, Regional � Local community stakeholders, Regional Water Quality Control Board, County Water Quality Control Board, County Health Care Agency, and others Health Care Agency, and others
Small System Exemptions? Small System Exemptions? � Less than 1 MGD and / or less than 2.5 � Less than 1 MGD and / or less than 2.5 MGD eliminates some provisions in the MGD eliminates some provisions in the proposed program proposed program
State Issues State Issues � Permitting of satellite systems? � Permitting of satellite systems? � Oversight through Regional Boards? � Oversight through Regional Boards? � Fines for SSOs and Program non- � Fines for SSOs and Program non- compliance? compliance?
Update on EPA’s cMOM Update on EPA’s cMOM Report due to Congress on Dec. 15, 2003: Report due to Congress on Dec. 15, 2003: � Locations, constituents, volumes of SSOs � Locations, constituents, volumes of SSOs and their impacts on human health and and their impacts on human health and environment environment � Resources spent by municipalities to � Resources spent by municipalities to address these impacts address these impacts � Evaluation of technologies used by � Evaluation of technologies used by municipalities to address these impacts municipalities to address these impacts
Update on EPA’s cMOM (cont’d) Update on EPA’s cMOM (cont’d) � Currently in OMB � Currently in OMB � NRDC report “Swimming in Sewage” � NRDC report “Swimming in Sewage” www.nrdc.org www.nrdc.org � Also see: www.epa/gov/npdes/sso and � Also see: www.epa/gov/npdes/sso and see: SSO Toolbox and also search on see: SSO Toolbox and also search on cMOM cMOM � HR 2215 “The Raw Sewage Overflow” � HR 2215 “The Raw Sewage Overflow” Community Right-to-Know Act Rep. T. Community Right-to-Know Act Rep. T. Bishop (D-NY) Bishop (D-NY)
OK … How do I get Ready? OK … How do I get Ready? � Have a good design and construction � Have a good design and construction program program � Have a good documented O&M program � Have a good documented O&M program � P.M. / C/M. / Emergency Repsonse / � P.M. / C/M. / Emergency Repsonse / SSORP SSORP � Maps and data � Maps and data � Have a good rehab and CIP process � Have a good rehab and CIP process � Advise your Council / Board on $ � Advise your Council / Board on $
OK … How do I get Ready? (cont’d) OK … How do I get Ready? (cont’d) � Follow EPA through � Follow EPA through http://cfpub.epa.gov/npdes/home.cfm?program_id=4 http://cfpub.epa.gov/npdes/home.cfm?program_id=4 � Existing: discover / document / develop � Existing: discover / document / develop action plans action plans � Prepare to assist your agency during the � Prepare to assist your agency during the public comment period public comment period � Do a “gap” analysis (EPA Tool Kit) � Do a “gap” analysis (EPA Tool Kit) � Be proactive within your agency � Be proactive within your agency
OK … How do I get Ready? (cont’d) OK … How do I get Ready? (cont’d) � Collaborate with your associates � Collaborate with your associates � cMOM linkage to GASB 34 effort � cMOM linkage to GASB 34 effort � Get involved with CWEA and SCAP � Get involved with CWEA and SCAP � Live by your written program � Live by your written program � Learn how to pass audits! � Learn how to pass audits! � Form a proactive Regional cMOM Team � Form a proactive Regional cMOM Team � Invite the public to participate � Invite the public to participate
Asset Management Asset Management Fundamentals Fundamentals Nick Arhontes, P.E. Nick Arhontes, P.E. Orange County Sanitation District (OCSD) Orange County Sanitation District (OCSD) Fountain Valley, CA Fountain Valley, CA
What Do You Own? What Do You Own? � Records � Records � Lists of assets � Lists of assets � Maps and drawings � Maps and drawings � Specifications � Specifications � Vendor information � Vendor information
What Is It Worth? What Is It Worth? � Asset condition � Asset condition � Asset value � Asset value � O&M cost inputs � O&M cost inputs � Work with finance department � Work with finance department
How Do You Care For It? How Do You Care For It? � Preventive, predictive, corrective � Preventive, predictive, corrective maintenance maintenance � Trained staff and contractors � Trained staff and contractors � Records Management � Records Management
When Do You Replace It? When Do You Replace It? � Life cycle maintenance and replacement � Life cycle maintenance and replacement strategies and plans strategies and plans � Capital improvement programs (CIP) � Capital improvement programs (CIP)
How Do You Fund These Needs? How Do You Fund These Needs? � Adequate O&M revenue stream � Adequate O&M revenue stream � Adequate CIP revenue stream � Adequate CIP revenue stream � Adequate reserves � Adequate reserves
See Some Similarities to cMOM? See Some Similarities to cMOM? � Logical � Logical � Documented � Documented � Auditable � Auditable
Improved SSO Improved SSO Response Response Nick Arhontes, P.E. Nick Arhontes, P.E. Orange County Sanitation District (OCSD) Orange County Sanitation District (OCSD) Fountain Valley, CA Fountain Valley, CA
Why Do We Care? Why Do We Care? � Comply with Federal CWA and State Water � Comply with Federal CWA and State Water Code and Basin Plans Code and Basin Plans � Protect watershed from sewage overflows � Protect watershed from sewage overflows (SSO) (SSO) � Protect the public and property � Protect the public and property � Protect wildlife � Protect wildlife � Avoid fines / penalties � Avoid fines / penalties � Affirmative defense � Affirmative defense � Local economics / development � Local economics / development
What Can We Learn At A Training What Can We Learn At A Training Facility? Facility? � How to respond and notify � How to respond and notify � How to contain sewage � How to contain sewage � How to set up traffic control for worker safety � How to set up traffic control for worker safety � How to estimate flows and volumes � How to estimate flows and volumes � How to control flows � How to control flows � How to clean up � How to clean up � How to document for reporting purposes � How to document for reporting purposes
Why an SSO Training Facility? Why an SSO Training Facility? � Prepare for the real event � Prepare for the real event � Isolated from traffic hazards � Isolated from traffic hazards � Environmentally safe � Environmentally safe � Assess individual and team skills � Assess individual and team skills � Evaluate methods, equipment and � Evaluate methods, equipment and materials materials � Practice, practice, practice ! � Practice, practice, practice !
What is It? What is It? � Simulated manhole (vault with cover) � Simulated manhole (vault with cover) � Potable water supply � Potable water supply � Street surface � Street surface � Curb and gutter and catch basin � Curb and gutter and catch basin � Storm drainage to the treatment plant � Storm drainage to the treatment plant
Water Supply Valve #2 Valve #2 Valve #1 Valve #1 Water Meter
Manhole Drain Valve Manhole Vault Manhole
Street Surface and Gutter
Catch Basin
Typical Event Typical Event 6 gallons 500 gallons 6 gallons 500 gallons per minute spill per minute spill per minute spill per minute spill Flow down Flow down gutter gutter Q = A x V Q = A x V
Containment at Catch Basin Containment at Catch Basin Put containment Spill containment Put containment Spill containment in place in place Spill ponding Spill ponding
Estimating Flow Rates Estimating Flow Rates 6 gallons 6 gallons per minute spill per minute spill Flow down Flow down gutter gutter
Traffic Control
Clean Up Clean Up Combination cleaning truck Combination cleaning truck removes ponded material removes ponded material Direct flow to a Direct flow to a natural low area natural low area
Clean Up (cont’d) Clean Up (cont’d) Wash down and recover Wash down and recover Prepare field report, Prepare field report, photograph and document photograph and document
SSO Report Documentation SSO Report Documentation
Support Activities – Support Activities – Dispatch Center Dispatch Center
Closeout Activities Closeout Activities � Finish and submit the field report � Finish and submit the field report � Assemble and complete the written report � Assemble and complete the written report for RWQCB for RWQCB � Restock materials � Restock materials � Post mortem with lessons learned � Post mortem with lessons learned � Modify response procedures � Modify response procedures � More training? � More training?
What is currently What is currently happening at the happening at the SWRCB on collection SWRCB on collection systems? systems?
Statewide Electronic Statewide Electronic SSO Reporting Update SSO Reporting Update
WDRs- WDRs- what are they and where what are they and where are they being applied? are they being applied? Nick Arhontes, P.E. Nick Arhontes, P.E. Orange County Sanitation District (OCSD) Orange County Sanitation District (OCSD) Fountain Valley, CA Fountain Valley, CA
What is the Region 8 Order? What is the Region 8 Order? Santa Ana RWQCB Order R8-2002-0014 Santa Ana RWQCB Order R8-2002-0014 issued April 26, 2002 covering: issued April 26, 2002 covering: � Waste Discharge Requirements (18 pages) � Waste Discharge Requirements (18 pages) � Spill Reporting and water quality � Spill Reporting and water quality monitoring program (11 pages) monitoring program (11 pages) � Both available at: � Both available at: www.swrcb.ca.gov/rwqcb8/ www.swrcb.ca.gov/rwqcb8/ See: Orange County SSO General WDRs See: Orange County SSO General WDRs
Deliverables and Schedule Deliverables and Schedule � Apr. 26, 2002 – Reporting of all SSOs and � Apr. 26, 2002 – Reporting of all SSOs and water quality monitoring water quality monitoring � Sep. 30, 2002– Development Plan and � Sep. 30, 2002– Development Plan and schedule for Sewer System schedule for Sewer System Mgmt Plan (SSMP) – Done Mgmt Plan (SSMP) – Done � Jan. 1, 2003 – SSO Emergency Response � Jan. 1, 2003 – SSO Emergency Response Plan – Done Plan – Done
Deliverables and Schedule (cont’d) Deliverables and Schedule (cont’d) � June 15, 2003 – Preventative Maintenance � June 15, 2003 – Preventative Maintenance Program - Done Program - Done � July 30, 2004 – Legal authority � July 30, 2004 – Legal authority � Dec. 30, 2004 – Grease disposal � Dec. 30, 2004 – Grease disposal alternatives alternatives
Deliverables and Schedule (cont’d) Deliverables and Schedule (cont’d) � Dec. 30, 2004 – Grease Control Program � Dec. 30, 2004 – Grease Control Program � July 30, 2005 – Capacity evaluation � July 30, 2005 – Capacity evaluation � Sep. 30, 2005 – Sewer Rehab Plan for � Sep. 30, 2005 – Sewer Rehab Plan for entire system entire system � Sep. 30, 2005 – Final SSMP � Sep. 30, 2005 – Final SSMP
SWRCB’s Proposed SWRCB’s Proposed Statewide Model? Statewide Model?
Where does Region 8 Where does Region 8 stand on collection stand on collection system issues? system issues?
Governor’s Governor’s environmental action environmental action plan? plan?
Questions? Questions? Nick Arhontes, P.E. Nick Arhontes, P.E. Manager Manager Regional Assets and Services Divisions Regional Assets and Services Divisions (714) 593-7210 (714) 593-7210 narhontes@ocsd.com narhontes@ocsd.com Orange County Sanitation District Orange County Sanitation District Orange County Sanitation District www.ocsd.com www.ocsd.com Search: WDR – – for more info and links for more info and links Search: WDR Search: WDR – for more info and links
cMOM – Its Not Law, But A Case History
Compliance Orders Issued by EPA Region 9 • EPA Region 9 has jurisdiction over the southwestern United States including California • In 2002, Compliance Orders issued to the City of Laguna Beach, City of San Diego and Carpinteria Sanitary District • September 2003, Compliance Orders issued to Los Angeles County Sanitation Districts (LACSD) and South Coast Water District (SCWD) • April of 2004, Compliance Order issued to the City of Oakland • Reason for Compliance Orders – Excessive Sanitary Sewer Overflows (SSO)
SCWD Profile • SCWD is a water/reclamation/wastewater public agency located in southwest Orange County • Sanitary collection system is comprised of approximately 139 miles of pipelines with 14 lift stations • 49 SSOs from 1999 to 2003 – 21 reached the waters of the U.S.
SCWD Profile (Cont.) • Action started with a complaint from San Diego Water Quality Control Board – Region 9 - for failure to provide a Sanitary Sewer Overflow Prevention Plan and failing to submit complete SSO reports • District fined $136,100 and settled for a fine of $105,000 in March 2003 • EPA’s Compliance Order was issued the following September
What is in the EPA Compliance Orders? • The other compliance orders are very similar – their violations are unique – requirements and timelines for compliance are essectially the same • Primary goal – to substantially reduce the number and the volume of SSOs annually
What is in the EPA Compliance Orders? (Cont.) • Create a Sanitary Sewer Overflow Response Plan (SSORP) • Plan must: – Provide written instructions on how to respond to an SSO – Provide measures for spill containment – Establish interim method of operation – Maintain a list of spare parts and emergency equipment
What is in the EPA Compliance Orders? (Cont.) • Establish a Sewer System Cleaning and Root Control Program – Submit schedule for cleaning of entire system – Submit schedule for cleaning hot spots and describe procedures for adding or removing pipe segments from the hot spot list – Plan for comprehensive root control program including methods for controlling root intrusion into mains and private laterals and the repair, replacement or rehabilitation of root prone mains – Written procedures for cleaning, repairing and maintaining sewer lines located in easements - including schedules and instructions for gaining access to lines in easements
What is in the EPA Compliance Orders? (Cont.) • Maintenance Management System – Consider implementing computerized maintenance management system for scheduling and tracking system maintenance that should eventually be tied to a GIS mapping system • Sewer Pipe Inspection and Condition Assessment Plan – Submit a plan for periodic sewer pipeline inspection and assessment to include maintenance holes, method of inspection (i.e. CCTV), frequency of inspection, evaluation of inspection findings, and documentation of assessed condition – Submit annual report to EPA summarizing miles of pipe and number of maintenance holes inspected and their condition assessment
What is in the EPA Compliance Orders? (Cont.) • Sewer Repair, Rehabilitation and Replacement Plan – Submit a plan for the repair, rehabilitation or replacement that (1) provides the timely repair or replacement of pipelines imminently in danger of failure or blockage; (2) ensure the sustainable replacement of obsolete assets; (3) reduce spills caused by pipe defects
Sewer Repair, Rehabilitation and Replacement Plan (Cont.) • The plan must include: – Estimate of how many sewer pipes will annually require emergency repair or replacement – Estimate of how many miles of pipeline will be rehabilitated or replaced over the next 5 and 10-year periods – Submit a 10-year financial plan for the short and long term rehabilitation or replacement of the sewer pipes – Annually submit a report to the EPA documenting the repair, rehabilitation or replacement history for the previous year including an update to the 10-year capital improvement plan
What is in the EPA Compliance Orders? (Cont.) • Capacity Assessment and Capacity Assurance – Requires the agency to assess the capacity of the collection system to ensure sufficient capacity during wet weather including the control of all I/I that could pose a risk of exceeding the collection system’s capacity and to submit a report to the EPA on capacity limitations and the plan for assuring adequate capacity • Pump Station Maintenance and Inventory – Complete a condition assessment for each lift station and associated force mains, identifying potential problems, provide recommendations for standby generators, and submit a plan to the EPA of the assessment findings and for the repair, renovations or upgrades necessary to ensure the continuous operation of each lift station
What is in the EPA Compliance Orders? (Cont.) • Create a Fats, Oils, and Grease (FOG) Control Program • The program shall be sufficient to eliminate or significantly reduce sewage spills caused by FOG including: – Line cleaning of lines prone to FOG blockage – In conjunction with the cities, implement necessary best management practices (BMP) for food service establishments – Require the installation of grease interceptors for new or remodeled food service establishments – Require food service establishments that cause FOG related blockages to install grease interceptors
FOG Control Program (Cont.) – Establish FOG inspection program for food service establishments – Establish FOG educational outreach program for food service establishments and homeowners – Submit annual report to EPA documenting the FOG program activities carried out, including inspections and enforcement actions, the previous year
What is in the EPA Compliance Orders? (Cont.) • Plan Review and Approval – EPA requires submission of the plan for EPA’s review, comment and approval • Quarterly Spill Reports – As per EPA’s schedule, quarterly spill reports must be submitted summarizing all sewage spills occurring the previous quarter • Annual Progress Reports – Must submit an annual progress report to the EPA for review and approval summarizing all aspects of the spill reduction plan and its effectiveness including the annual budget for the current year
Timeframe for Compliance • The South Coast Water District compliance order was issued in September 2003. Most of the required programs were to be completed by the following March, six months after the issuance of the order with reports due the following September, twelve months after the order • Annual reports are due each September • Quarterly reports are due each quarter • No sunset
Penalty for Non - Compliance Failure to respond, or any other violation of the terms of this Order could subject (Agency) to a civil action…… negligent violations may be punished by a fine of not less than $2,500 per day or more than $25,000 per day of violation, or imprisonment for not more than one year, or both…… knowing violations may be punished by a fine of not less than $5,000 per day or more than $50,000 per day of violation, or imprisonment for not more than three years, or both…… penalties for knowingly making false statements.
The Other Boogie Man • Third party lawsuits brought by environmental groups and others under the Clean Water Act – Ecological Rights Foundation v. City of Pacific Grove, in 2004 – Divers Environmental Conservation Organization v. Fallbrook Public Utilities District in 2003
The Other Boogie Man (Cont.) • Ecological Rights Foundation v. City of Pacific Grove – Approximately 58 miles of collection pipelines – Worst spill year, 2000 (8 spills or a rate of 13.7 spills per 100 miles of pipe) – Worst spill – 70,000 gallons – FOG Program - as of July 2002, 14 grease interceptors and 86 grease traps had been installed – Budget of $1,895,065 (2002-2003) up from $620,442 (2000-2001)
The Other Boogie Man (Cont.) Ecological Rights Foundation v. City of Pacific Grove • The Settlement – $300,000 for plaintiff’s legal fees plus the City’s legal expenses – Pay $50,000 to the Save Our Shores environmental organization – $200,000 to establish a lateral replacement program for businesses and homeowners – $500,000 in improvement projects (1 st year) increased by $50,000 in successive years to $1,000,000 per year – Reduce the number of spills to 4 annually by 2013 through increased maintenance and system improvements
The Other Boogie Man (Cont.) • Divers Environmental Conservation Organization v. Fallbrook Public Utilities District – Fallbrook is located east of Camp Pendleton, not a coastal community – Approximately 72 miles of collection pipelines – In 2003, there were 10 SSOs spilling approximately 6,100 total gallons of sewage – Roots and FOG account for 99% of all SSOs in Fallbrook
The Other Boogie Man (Cont.) • The Settlement – FPUD settled out of court – Settlement was for $135,000 • Included – $60,000 in plaintiff’s legal fees – $65,000 to the San Diego Oceans Foundation – $10,000 to the Mission Resource Conservation District • Estimate for FPUD to defend itself in court - $2,000,000 • Additionally, FPUD to establish a mandatory FOG program and initiate a $65,000 public outreach campaign
The Other Boogie Man (Cont.) • The City of San Diego Metropolitan Wastewater Department compliance order was issued in April 2002. Prior to this, in October 2000, the City was notified by San Diego Bay Keeper and Surfrider Foundation of their intent to sue under the Clean Water Act
So What’s the Point? • EPA is getting actively involved with those it feels are not complying with the Clean Water Act • When cMOM is adopted, it could be enforceable on the day of adoption • Environmental groups are using third party lawsuits to ensure compliance with the Clean Water Act • Get ahead of the curve, don’t wait to be forced to manage your collection system asset
CALIFORNIA CMOM IN
SAN DIEGO REGION WDRs SANTA ANA REGION WDRs SAN FRANCISCO BAY REGION, RESOLUTION/MOA STATE WATER RESOURCES CONTROL BOARD EFFORTS, GUIDANCE, WDRs, POLICY?
WILL YOUR NEXT PERMIT, AN ENFORCEMENT ACTION, LAWSUIT, OR NEW WASTE DISCHARGE REQUIREMENTS, REQUIRE A CMOM PROGRAM � Numerous sewage collection systems in California have chronic sewage spills � Many sewage spills are caused by neglect and poor operations and maintenance, and can be prevented � CMOM only requires the basic minimum operation and maintenance for sewage collection systems, as recommended by WEF, ASCE, AMSA and other industry groups � Current Implementation of CMOM is through enforcement actions, consent decrees, or 3 rd Party Lawsuits
WHY CMOM? BECAUSE IT REDUCES SEWAGE SPILLS � The basic sewage collection system maintenance and operation guidelines, recommended by WEF, ASCE, etc., have been proven to reduce sewage spills � Those sewage collection systems that use video to identify maintenance problems and regularly clean their sewers have fewer spills than those who neglect these basic maintenance tasks � FOG Control Programs reduce sewage spills � I & I Control Reduces Sewage Discharges
SWRCB’s STATEWIDE EFFORT TO REDUCE SEWAGE SPILLS 1. The Discharge of Sewage to any Surface Water Body of the State is a Violation of the CWA, CWC, and Basin Plan 2. SWRCB’s Enforcement Policy Requires staff to notify their Respective RBs of all Sewage Spills, and Recommend Appropriate Enforcement Action 3. Enforcement Actions address Correction of the Cause of the Sewage Discharge (by requiring implementation of a CMOM program), as well as impose Penalties for the Discharge
SWRCB’s STATEWIDE EFFORT TO REDUCE SEWAGE SPILLS 4. Enforcement Options Include: 1) Informal Notice to Discharger of Violation and Voluntary Correction of the Violation, 2) Cease and Desist Order for Permitted Dischargers, 3) Cleanup and Abatement Order for Systems not currently under permit, 4) Administrative Civil Liability up to $10,000 for each day of discharge and $10 per gallons over 1,000 gallons not cleaned up, 5) Referral to the Attorney General or District Attorney for Civil or Criminal Prosecution
SWRCB’s STATEWIDE EFFORT TO REDUCE SEWAGE SPILLS SWRCB’s staff has set up a Sewage Spill Prevention Committee to evaluate alternative approaches to reduce sewage spills, and make recommendations to the SWRCB by November 2004. Alternatives to be considered include Statewide General Waste Discharge Requirements for all sewage collection systems in California, a guidance document for dischargers on implementing CMOM, guidance for Regional Board staff on enforcement actions for sewage discharges, and any other alternatives that may be proposed by stakeholders that will result in a reduction of sewage discharges to waters of the State
1. Provide a floor level of O and M that minimizes the chance of spills within some affordability limits 2. Have effective contingency capability 3. Have adequate capacity 4. Have a very high level of O and M and contingency capability at high risk sites 5. Consistent and accurate Tracking and reporting on performance 6. Develop opportunities for grants and low interest loans
WHY CMOM?: SEWAGE SPILLS IN CALIFORNIA Sewage Spills to Waters Reported to the Office of Emergency Services 600 500 s nt e id 400 c f In o 300 r e b m u N 200 100 0 1999 2000 1997 1998 2001 2002
BEACH CLOSURES IMPACTS OF SEWAGE SPILLS- NAME State Wide 100 120 140 160 20 40 60 80 0 Jan uar y Sum of BMDS F eb ruar y M arc h A pril M a y 1999 Jun e July A ug ust S ep tem be r O ctobe r N ov em be r D e cem be r Jan uar y F eb ruar y M arc h A pril M a y 2000 Jun e July A ug ust S ep tem be r O ctobe r N ov em be r D e cem be r Jan uar y F eb ruar y M arc h A pril Year Month M a y 2001 Jun e Total July A ug ust S ep tem be r O ctobe r N ov em be r D e cem be r Jan uar y F eb ruar y M arc h A pril M a y 2002 Jun e July A ug ust S ep tem be r O ctobe r N ov em be r D e cem be r Jan uar y F eb ruar y M arc h A pril M a y 2003 Jun e July A ug ust S ep tem be r O ctobe r N ov em be r D e cem be r Total
CONCLUSION 1. Discharges of Sewage are illegal under current law and regulation 2. Alternative enforcement actions available to correct these violations are informal enforcement, enforcement orders, waste discharge requirements, civil liability, and civil and criminal prosecution 3. SWRCB will be considering alternatives to reduce sewage discharges to waters of the State in November 2004 4. CMOM is coming to your sewage collection system in one form or another, whether it is guidance, General WDRs, enforcement actions, or penalties, because CMOM only requires basic operations and maintenance recommended by the wastewater collection industry to prevent and minimize sewage discharges
What’s Next? What’s Next?
Who is SCAP? Who is SCAP? � History of SCAP – Originally formed in 1992 to meet the needs of the POTWs – Structured by Committees � Air Quality � Water Issues � Biosolids � Collection Systems
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