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Articles Received in:
September 2000
(
Printed Issue:  October 2000)

Contents
Atmospheric Mercury Sampling, By The City & County of San Francisco
CMOM and Your Future
News, Announcements, Upcoming Events  - Go to Home Page

Atmospheric Mercury Sampling, By The City & County of San Francisco

Agencies and stakeholders in the San Francisco Bay area are focusing efforts on determining sources and loading of mercury to San Francisco Bay. In June of 1999, the City and County of San Francisco, in collaboration with the San Francisco Estuary Institute, began sampling atmospheric deposition of mercury at Treasure Island as part of the San Francisco Bay Atmospheric Deposition Pilot Study. The pilot study conducts monitoring at three stations: Central Bay Site at Treasure Island; North Bay Site at Martinez and South Bay Site at the NASA/Ames Research Center. The pilot study will provide information for estimating the magnitude and seasonal variability of contribution from atmospheric deposition as a pathway to the total loading of mercury to San Francisco Bay.

If I go into great detail about the talk, you won’t want to attend. My part is one half of the talk and relates Hg data interpretation to compliance determinations. But to wet your appetite, I've provided the summary above.

Guy Kumar and Susan Glendening will both speak at the Waterworks 2000 Conference, Sacramento on Thursday, September 28, 2000.

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CMOM and Your Future

by John Larson

The times are changing. President Clinton issued an Executive Order last April that directed the Environmental Protection Agency (EPA) to move forward on the elimination of sanitary sewer overflows (SSO) because of the public health and water quality issues they create. In response, the EPA is working on NPDES Permit requirements for collection systems, developing an inventory of agencies with SSO violations, and preparing plans for taking enforcement action. The EPA favors a program it calls CMOM. CMOM is an acronym for Capacity, Management, Operations, and Maintenance - the four cornerstones of a well run collection system. The rules requiring CMOM are currently being reviewed by the Office of Management and Budget and they are expected to be promulgated in the next month or two. It is my understanding from the State Water Resources Control Board Staff that California will adopt the EPA requirements.

What does this mean for us? Over the next two years we will need to become familiar with and either meet or exceed the CMOM requirements. The basic requirements are:

- Overflow Response Plan

CMOM requires a written plan to respond to and mitigate any collection system overflow that may occur. The plan must include provisions for public notification of the health hazards (posting signs, notifying media) and notifying appropriate regulatory agencies. CMOM requires periodic training to support the plan.

- Management Program

CMOM requires a comprehensive management program. There are two areas where the requirements go beyond current best practices. They are:

Asset Management System

An asset management system tracks the location, condition, cost and performance history for each line segment.

This system provides documentation of our performance. It is also the foundation for future decision making regarding preventive maintenance, inspection, repair, rehabilitation, or replacement.

Programmed Follow-up for SSOs

Each SSO should have a programmed follow-up. The follow-up actions must include evaluating the condition and capacity of the line segment. In cases where the capacity is deficient, the capacity must be upgraded in a timely manner. In cases where the condition is deficient, repair or replacement must be completed in a timely manner.

- Periodic Reports and Audits

CMOM requires periodic reports showing changes in key performance indicators, documented management review of the reports, and periodic audits to verify compliance with the program requirements.

What is the benefit of CMOM? The potential benefit of CMOM to the public will be a reduction in the number of SSOs. The potential benefit to the collection system operators are twofold: CMOM provides an integrated program that will hopefully improve our access to the resources needed to correct recurring problems and it will hopefully provide some level of consideration during enforcement actions (the quality and implementation of the CMOM Program will be taken into account during enforcement actions).

For more information on CMOM, go the the following web addresses: http://www.epa.gov/owm/ and http://www.epa.gov/region4/water/wpeb/momdocs.htm

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