CONDUCTING A MOM SELF-AUDIT AT THE CITY OF GASTONIA, NC

The U.S. Environmental Protection Agency (EPA) considers sanitary sewer overflows (SSOs) to be a violation of the Clean Water Act. The EPA further considers SSOs to be an indication of improper management, operations and maintenance by the utility. To address these issues, EPA Region 4 implemented a Management, Operations and Maintenance (MOM) audit program.During the last three years, EPA Region 4 has invited several utilities in each of Region 4 states, including the City of Gastonia in North Carolina, to participate in the program. This paper will discuss the City's initial reaction to this perceived “unfunded mandate” as well as the City's modified opinion following the conclusion of the self-audit.Some examples from the Gastonia Self-Audit will be provided to help the audience conduct a better self-audit should you be “invited to join the party.” Some of those lessons learned during the Gastonia Self-Audit process include:Present your performance measures in “benchmark measure” terms.Don't be shy about reporting your successes.Take the opportunity to take a fresh look at your procedures.Document, document, document.Track your results and make improvements as necessary.Subsequent to the Region 4 initiative, EPA has, on a national level, developed CMOM regulations adding the “C” for Capacity assurance. CMOM regulations were issued by the Clinton Administration in January 2001, but put on hold by the Bush Administration. It is not currently known when the CMOM regulations might be re-activated.