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.
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.
- EPA Region 4 Introduction to Conducting Evaluations of Municipal Wastewater Collection System Management, Operation, and Maintenance Programs, Version 1.0 (PDF) (23 pp, 158K)
- Useful References for Management, Operations, and Maintenance Programs (PDF) (2 pp, 28K)
- EPA Region 4 Guide to Collection and Transmission System Management, Operation, and Maintenance Programs Version 1.0 (PDF) (28 pp, 127K)
- January 23, 2003 Memorandum on “Pilot Enforcement Approach for MOM Cases in Region IV ” (PDF) (5 pp. 40K)
- Guide for Evaluating Capacity, Management, Operation, and Maintenance (CMOM) Programs at Sanitary Sewer Collection Systems EPA 305-B-05-002 (PDF) (126 pp, 3MB)