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