The KY Division of Water has added new management requirements to KPDES permits for municipal wastewater plants with design flows above 1 MGD. The new requirement is to implement a Sewer Overflow Response Protocol, or SORP. Components of the SORP shall include: 1) an overflow response procedure, 2) a public advisory procedure, 3) a regulatory agency notification procedure, and 4) a manhole and pump station inspection schedule. If municipalities haven’t already received the requirement, they will see this requirement on their next issuance of their 5-year permit renewal. Deadline for submittal of the SORP is one year after the permit effective date. More importantly, the SORP requirement is paired with the requirement to develop a Capacity, Management, Operation, and Maintenance (CMOM) program. Deadlines for the CMOM are either one year or two years following the permit effective date of the permit reissuance. The SORP and CMOM requirements are not new to communities with combined sewers as they were the first to institute wet weather and capacity management programs as required by the Division of Water.
A CMOM Self-Assessment is an existing tool that has been helpful for wastewater utilities to evaluate the performance of the sanitary collection system and reduce the occurrence of sanitary sewer overflows. CMOM stands for Capacity, Management, Operation, and Maintenance. Overflows that occur in separate sanitary sewers are considered bypasses of the collection system and are not authorized. Causes of sanitary sewer overflows (SSOs) may include any of the following: blockages, structural, mechanical, or electrical failures, collapsed or broken sewer pipes, insufficient conveyance capacity, or vandalism. Eliminating sanitary sewer overflows is a key component for gauging the performance of wastewater collection systems. Tracking the causes of sanitary sewer overflows can provide utility managers with the necessary data to properly manage assets more effectively. Contact Daniel Hardin for help with conducting your CMOM Self-Assessment.