CITY OF CLEARWATER, FLORIDA – CMOM SELF-AUDIT FROM INCEPTION TO IMPLEMENTATION

Since 1994, there have been discussions about the development of a national policy for sanitary sewer overflows (SSOs). While dialogue on this issue was underway, Region 4 of the United States Environmental Protection Agency (EPA) introduced the Management, Operation and Maintenance (MOM) program.The MOM program is a self-audit process. Region 4 invites a municipality to analyze its wastewater collection system's management, operation and maintenance program. The municipality reviews all aspects of its system's operations and maintenance (O&M) program, documents all elements, identifies deficiencies, and develops a corrective action plan and schedule for making needed improvements. The goal of the self-audit program is to achieve environmental improvements and regulatory compliance more quickly and in a less adversarial setting than with the traditional enforcement approach.The Region 4 MOM program is the model for the federal CMOM (Capacity, Management, Operation and Maintenance) regulations. These new rules, although not yet in effect, will have great significance to all communities with centralized wastewater collection and treatment facilities.In November 1998, the City of Clearwater, Florida, received a letter from the EPA's Region 4 inviting them to participate in the new MOM program. The invitation arose from the concern over possible water quality stress from pollutant loadings in the Tampa Bay Estuary watershed. The Tampa Bay Estuary is Florida's largest open water estuary, encompassing almost 400 square miles. The primary goal of the City of Clearwater's MOM program is to obtain water quality improvements in this local watershed as soon as possible by eliminating SSOs.As a result of its participation in the MOM program, the City of Clearwater has shifted from a reactive to a proactive approach in managing its sanitary sewer collection system. Furthermore, a sewer system evaluation survey and a flow model are currently underway to help the City identify and remedy any sewer capacity problems. The planning and development of both MOM and capacity programs have allowed the City to create an effective plan for future system capital improvements. The comprehensive plan has persuaded the City's leaders to grant the necessary rate increase to achieve the targeted improvements.