CMOM in california – the race to implement waste discharge requirements for sanitary sewer collection systems
On May 2, 2006, the California State Water Resources Control Board adopted Order Number 2006-0003, the statewide General Waste Discharge Requirements (WDRs). The WDRs establish minimum operation, maintenance and management standards to significantly reduce sanitary sewer overflows (SSOs) from publicly owned collection systems greater than one mile in length. The agencies that own or operate collection systems with these criteria are required to develop and implement a Sewer System Management Plan (SSMP) within an aggressive schedule. An SSMP provides details on items such as: cost effective management practices; proper wastewater collection system operations; effective maintenance of wastewater collection systems; and public education on related programs and projects. Essentially, the WDRs mandate Capacity, Management, Operations and Maintenance (CMOM) requirements on every public sewer collection system in California.
While many agencies within California are scrambling to comply with the WDRs, several have completed an SSMP or have a large portion of the work completed, because of either aggressive regional requirements or proactive agencies. The experiences of these agencies offer excellent insight into the planning, development, and implementation of an SSMP. Using the City of Pomona’s experience, this paper describes the requirements of the WDRs, offers suggestions to streamline the SSMP development process, describes challenges encountered during its development, and provides a proven roadmap to guide agencies struggling with this endeavor.