SAN ANTONIO WATER SYSTEM (SAWS) CAPACITY, MANAGEMENT, OPERATIONS, AND MAINTENANCE (CMOM) AUDIT

In October 2002, the San Antonio Water System (SAWS) decided to undertake an evaluation of its wastewater collection system business practices using a criteria established by the U.S.Environmental Protection Agency's (EPA) proposed Sanitary Sewer Overflow (SSO) Rule. The capacity, management, operations, and maintenance (CMOM) requirements are at the heart of EPA's proposed SSO rule. All those with National Pollutant Discharge Elimination System (NPDES) permits, including satellite collection systems with SSOs, would be required to develop and implement a comprehensive CMOM program. The key elements of a sound CMOM program include:Planning to ensure adequate capacity during both dry and wet weather,Effective system management, including mapping, maintenance tracking, training, and supervision, andEfficient operations, as measured in spending, equipment performance, and efficiencySAWS' CMOM program was also a requirement of an administrative order (AO) issued by the (EPA on September 23, 1997. SAWS was issued the AO citing overflows in its collection system, and required to implement repairs and a maintenance program to eliminate the overflows.This paper describes the performance standards developed by SAWS to meet the needs of its collection system.