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MPW Gets High Marks In EPA Audit (cMOM)



Mount Pleasant Waterworks (MPW) has received an excellent rating for the way it manages, operates and maintains its wastewater system, according to a recent audit report.

The audit, known as the Capacity, Management, Operating and Maintenance Self-Audit, or cMOM, is provided to the U.S. Environmental Protection Agency. MPW volunteered to participate in the self-audit, which was conducted by an unbiased, third-party firm.

The report gave high marks to MPW’s innovative features such as state-of-the-art facilities and a SCADA system that incorporates pump station controls. MPW’s Commission, staff and Executive Team were also congratulated for motivation, professionalism and progressive attitude.

Auditors cited the utility’s annually updated formal business plan as an excellent tool to help operations run more efficiently and effectively. The report also noted that 50-percent of the MPW staff holds collection system operator’s certification and applauded the utility’s customer communication programs.



The following is an html version of a PowerPoint slideshow presented at the May 17, 2004 Commission Meeting:

EPA’s Basic Premise

  • Majority of collection systems have overflows
  • SSOs violate the Clean Water Act
  • SSOs indicate improper management, operations and maintenance (MOM)practices

Why?

  • Aging Infrastructure
  • Lack of Maintenance and Repair
  • Materials and Design
  • Institutional Arrangements

EPA Region 4's Approach

  • Enforcement via "mega" court cases
  • Enforcement via "self-audits"

What?

  • Region 4 "invitations"
    • Cycle 1 started in 1998, but last 2 states not until 2000, and hit 81 utilities
    • Cycle 2 started in late 2003 and hit 15 SC utilities
  • Offered enforcement "carrot"
    • Avoid adversarial enforcement
    • Minimize penalties
    • Allow the utility to control its own future

Who?

  • Target one watershed/Region 4 state/year
  • Cycle 2 - two watersheds in SC
Cycle One States--Number
Alabama----------------6
Florida------------------6
Georgia-----------------4
Kentucky--------------13
Mississippi-------------16
North Carolina----------5
South Carolina---------20
Tennessee--------------11

Extension of Region 4 Program

  • The SSO Rule (epa-gov/npdes/sso/ssorule)
    • cMOM requirements for public collection systems
    • Prohibit SSO discharges to waters of US
    • Reporting, public notification and recordkeeping for SSOs
    • NPDES permit modifications
  • Issued January 2001
    • Immediately put on hold
    • Currently, a "non-starter"

MPW Self-Audit Results

  • The "c" in cMOM = capacity assurance
    • 1997 Wastewater Master Plan
      • Projected flow to buildout
      • Plants to expand to 12 mgd in progress
    • Collection system
      • Hydraulic model in use
      • Customer connections tracked
      • SSES and rehabilitation performed with plans for a master plan

MPW Self-Audit Results

  • The "M" in cMOM = Management
    • Vision "to become an innovative, progressive, customer-oriented, highly professional, highly motivated organization that sets the standard for excellence in the water and wastewater industry"
      • Innovative - SCADA controls on re-pump stations to maximize collection system storage; contract O&M for grinder pump systems
      • Progressive - strategic and business planning
      • Customer-oriented - routine tracking of customer response; formalized public outreach activities
      • Professional - certification levels including voluntary collection system certification; numerous awards and recognitions
      • Motivated - written, and audited, SOPs; compensation surveys and commitment to training
  • Performance measures tracked

MPW Self-Audit Results

  • The "O" in cMOM = Operations
    • Collection System
      • Routine cleanint at 17% goal
      • Routine CCTV at 18% goal
      • CCTV of service lateral lines
      • MH inspections
      • Grinder pump inspections
  • FOG program

MPW Self-Audit Results

  • The "M" in cMOM = Maintenance
    • Preventive maintenance emphasized
      • Routine inspections
      • On-staff mechanics and electricians
      • CMMS work order tracking
      • SCADA monitoring
      • Emergency generators
  • CIP funding strong
    • Renewal and replacement projects
      • SSES, PS I&I, $10.8 million
      • Asset Management $2.3 million

MPW Self-Audit Results

  • The RESULTS of cMOM
    • SSO Tracking in MPW
      • 4-Year average of 28.5 SSOs/year
      • 7.8 SSOs/year/100 miles
  • Region 4 Survey
    • Average = 11.12/year/100 miles
    • Median = 8.53/year/100 miles

Comparison to Others . . .

So, Where Are We?

  • Submit to EPA Region 4
    • Submittal May 18, 2004
    • Anticipated review period ? ?
  • Consent order ? ?
    • EPA's general tendency is to issue a consent
    • MPW has a strong self-audit

White Waiting . . .

  • Continue to track performance measures
    • Watch contractor hit trends
    • Audit SOPs
  • Asset management
    • Keep on cleaning and CCTVing
    • Consider identifying "critical" sewers and force mains
    • Look out ofor private property I/I
    • Plan for increase in grinder pump O&M

For the Long Term . . .

  • Fund and Implement Master Plans
  • Implement the cMOM Philosophy for "Continual Improvement"
    • Monitor performance measures
    • Re-evaluate cMOM programs annually
    • Update and refine cMOM programs and performance measures as needed
Click here if you would like to visit the MPW Operations Center to see the full 90 page report.



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