IMPLEMENTING A CMOM PROGRAM THROUGH A RELIABILITY CENTERED MAINTENANCE AND ASSET MANAGEMENT PROGRAM

The Environmental Protection Agency (EPA) has proposed regulations that would include standard NPDES permit requirements or conditions for municipal sanitary sewer collection systems. The permit conditions include Capacity, Management, Operations Maintenance (CMOM) requirements, a prohibition on discharges, and reporting, public notification, and recordkeeping requirements. The proposed CMOM requirements are intended to encourage the efficient management of collection systems, so that environmental impacts to receiving waters are minimized.Stege Sanitary District (District) recognized that it had serious problems associated with deferred maintenance and replacement of portions of its collection system. Stoppages, overflows and unplanned repairs were becoming a costly, weekly occurrence. Consequently, in 1991 the District initiated measures to implement a different approach to its business of operating and maintaining its collection system of approximately 150 miles of sewers. A “System Rehabilitation Plan” was fully implemented in 1996 after entire system had been digitally mapped and a capacity model was completed. This plan was begun prior to publication of the proposed CMOM requirements, but contains the same basic elements included in EPA's CMOM requirements. The District decided to implement its plan because it was convinced that it was “good business”; it is the most cost efficient way to manage its assets and protect the environment, and the District did not want or need to wait until this type of plan was required by regulations.The Stege System Rehabilitation Plan is a management information system linked with mapping and condition assessment tools that enable management and operations staff improve system performance and reliability. A reliability centered maintenance program is a core element of the system. The management information system allows for the management of assets in a way that minimizes the total cost of owning and operating them while continuously providing desired service levels to District customers. The most remarkable aspect of the District's plan is the involvement of the District staff, which designed, developed, implemented and continues to maintain the entire system of databases.