Developing a Strategy for Implementing Mandated “MOM” Plans: A City of Atlanta Perspective

In late 1999, the United States EPA (EPA) and the Georgia Environmental Protection Division (EPD) completed settlement negotiations with the City of Atlanta requiring, in part, the implementation of a management, operations and maintenance (“MOM”) program for the City's wastewater collection and transmission systems in order to help control sanitary sewer overflows (SSOs).With one exception, all other MOM program component plans of which there are a total of ten, are under implementation including the Grease Management Program and the Collection & Transmission Systems Contingency and Emergency Response Plan. The Long-Term Operation Plan will be prepared only after the construction of capital improvements to remediate SSOs are completed over the next 10 years. Several of the program components including the aforementioned have been under implementation since mid-1999 so the City is particularly experienced in the MOM “business”.Each MOM plan was prepared as a stand-alone document that helps demonstrate irrefutable compliance with each provision of the consent decree addressing the MOM program. While collectively these plans should comprise the City's comprehensive operations and maintenance management plan, something was decisively missing. Specifically, a strategic “how to” approach was needed to guide implementation of the MOM program as an integrated management system with established goals, objectives and schedules for the entire sanitary sewer utility, and reflective of the reality of available resources and resolution of any conflicting priorities.This paper focuses on the challenges of implementing a consent decree-mandated MOM program and how they are being met by:Reviewing the impacts on maintenance operations of selected MOM program components;Presenting “lessons learned” upon implementation of the approved MOM program;Providing recommendations on performance indicators for measuring implementation success;Offering possible mitigation of MOM program impacts on human and material resources;Noting the pitfalls of the tendency to develop multiple (stand-alone or “island”) databases; and,Identifying benefits of periodic internal reviews of maintenance operations and the MOM program.