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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, and

Efficient operations, as measured in spending, equipment performance, and efficiency

SAWS' 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 two primary training components at SAWS. General training on work practices and equipment associated with a wastewater collection system and safety training practices. These training programs are described and exceed the basic requirements of the Capacity, Management, Operations and Maintenance (CMOM) Rule and can be used as a model in the wastewater industry.

Document Type: Research Article


Publication date: January 1, 2006

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  • Proceedings of the Water Environment Federation is an archive of papers published in the proceedings of the annual Water Environment Federation® Technical Exhibition and Conference (WEFTEC® ) and specialty conferences held since the year 2000. These proceedings are not peer reviewed.

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