Management, Operations, and Maintenance (MOM) Program

National Information

The Management, Operation and Maintenance (MOM) Programs Project is a pilot enforcement approach developed by EPA Region 4 to bring municipal sewer systems into full compliance with the Clean Water Act by eliminating sanitary sewer overflows (SSOs) from municipal sewer systems. A SSO is a release of untreated wastewater before the flow reaches a treatment plant. SSOs pose a significant threat to public health and water quality.

Municipality Self-Assessment

Under the MOM Programs Project, Region 4 invites municipalities to undertake a detailed self-assessment of their MOM programs. The municipalities submit this self-assessment along with recommendations for improvements to the MOM programs and/or remedial measures to correct sewer infrastructure problems.

In consideration for undertaking the self-assessment, the municipality is able to establish its own reasonable goals and schedules and the Region may use its discretion to significantly reduce penalties related to SSOs. Where an enforcement action is necessary, the Region works with the municipality to identify necessary remedial measures and to establish schedules. The Region will likely defer any penalty decision until after the completion of the necessary improvements.

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Project Initiation

In 1998, Region 4 began the Mom Programs Project by identifying priority watersheds and geographical areas in each of the eight States in the Region. These included areas where SSOs could cause significant public health concerns, such as beaches, shellfish harvesting areas and drinking water supplies. In addition, watersheds already listed as impaired by collection system overflows or bacterial contamination were identified.

Region 4, working with the States, selected a watershed (or geographical area) in each State. All municipal sewer systems in each watershed were identified and invited to participate in the Project and to attend a kickoff meeting held at a location in the watershed. Those municipalities wanting to participate in the MOM Project undertake the self-assessment using the guidance materials provided and submit the self-assessment to the Region within seven months of the kickoff. Municipalities that don’t participate are inspected by the Region and/or State and are subject to traditional enforcement actions, including penalties where appropriate.

In the Project’s first cycle (PDF) (4 pp, 20K), a total of eighty-one (81) utilities, in the eight Region 4 States, were invited and seventy-three (73) participated by submitting self-assessment reports. The first cycle is substantially complete and a second cycle (PDF) (2 pp, 18K) was started in 2003.

The Region 4 MOM Programs Project is related to certain other Capacity, Management, Operation and Maintenance (CMOM) projects and activities around the country. Region 4's program and guidance material are the basis for the development of CMOM programs nationwide.

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Resources

Region 4 has developed an internal guide for conducting collection system inspections which has since been revised and updated. In addition, Region 4 has developed other guidance material including a list of references and a guide to MOM programs. These resources, along with a copy of the kickoff presentation, are provided to each municipality at the kickoff meeting.