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Hillsboro County, Florida MOM Self-Assessment Results in EPA Region 4 Administratvie Order on Consent

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US EPA Region 4's Management, Operation and Maintenance (MOM) Program is an enforcement approach to control sanitary sewer overflows (SSOs) through self audits conducted by collection system owners and operators. Under the MOM Self-Audit Program, EPA Region 4 invites utilities to undertake a self-assessment of their MOM programs. Municipalities submit this self-assessment with recommendations for improvements to the MOM programs and/or remedial measures to correct system problems. In consideration for undertaking the selfassessment, the municipality establishes its own goals and schedules and EPA Region 4 defers assessment of monetary fines or penalties. When an enforcement action is necessary, EPA Region 4 works with the municipality to identify necessary remedial measures and to establish reasonable schedules.

In late 2005, Hillsborough County, Florida, was invited to participate in EPA Region 4's Cycle 2 of the MOM Self-Audit Program. In 2006, the County submitted its self-assessment to EPA Region 4 disclosing Clean Water Act and National Pollutant Discharge Elimination (NPDES) permit violations associated with SSO events. This resulted in the issue of an Administrative Order on Consent to the County by EPA Region 4 in June 2008.

This presentation will provide insight into conducting MOM self-assessments, negotiating an Administrative Order, and formulating and implementing an action plan to satisfy Administrative Order conditions to minimize or eliminate exposure to penalties.
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Keywords: Administrative Order on Consent; MOM Program Self-Audits; SSO

Document Type: Research Article

Publication date: 2009-01-01

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