Over the past several years, there has been a movement in the industry to a more defined management discipline, termed “cMOM” (Capacity assurance, Management, Operation, and Maintenance). This process was initiated and coined by the USEPA through Region Four, which is primarily an advanced MOM management discipline that focuses on management and operational techniques to eliminate sanitary sewer overflows (SSO) to the optimal goal of zero releases.

This can be a vast and confusing issue, as it is not considered a stand alone regulation by the USEPA, however, the language of cMOM and what it entails can be found in the NPDES permit for systems with treatment facilities. One of the reasons for the thrust of cMOM from USEPA is consideration of satellite collection systems that discharge into a regional or neighboring community and are not permitted.

There are reams of materials available to read on or about cMOM, one site is http:www.cmom.org, and though it may not ever become a USEPA regulation in and of itself, many States have adopted the tenets of this management discipline into their regulations or considerations of collection system operations. These may be invisible to a utility until there are issues of SSOs which draw the attention of regulators, who may start looking for how the utility is planning and tracking its maintenance, its short and long term repair goals, funding issues, and other determinations of critical service delivery.

The good news is, cMOM is not to be feared by anyone who is interested in being progressive and utilizing best practices in their operations. cMOM projects do not have to be expensive to deliver usable information, the only real issue with the process is time and manpower. Most utilities do not have the time or manpower to dedicate to development of this management discipline, however, once started, it can be more easily folded into daily operations.

To this end, Tilson & Associates offers several cMOM related services for our clients, from initial cMOM audits and recommendations to individual departmental audits, to personnel training on determining the success or improvements necessary to ongoing processes. We take some of the confusion out of this process along with a lot of the costs that can be associated with them, allowing our clients to benefit from the educational delivery and proceeding at their own pace based on their specific needs and concerns.

The cMOM management discipline needs a starting point. Rather than make this starting point a full blown sanitary sewer evaluation process or capacity analysis, we provide a full system overview audit at the level the utility wishes to take stock at. We can provide the “10,000 foot view” or the “2,000 foot view” depending on where the utility is or the depth they wish to go on the specific audit.

A typical audit includes a 21 category list of collection system operations and management that covers a wide range of issues. A sampling of these includes:

• Sewer Use Ordinances
• Organizational Structure
• Communications
• Budgeting
• Short and long term planning for repairs/replacement
• Training
• Safety
• Customer Service
• IT Services (Information Technology Systems)
• System Mapping
• CCTV Inspection
• Sewer Line Cleaning
• Manhole Inspection/Assessment
• Pump Stations
• Standard operation procedures (SOPs)
• Emergency Response Procedures (ERPs)

One of the advantages of an outside initial audit of these and other areas of operations and management is the utility gets an objective look at what it is doing, how it is doing it, and if it is working as desired. Once the initial audit is completed, a priority list from the audit is developed for further action.

Tilson & Associates provides a unique, low cost service in this process, incorporating training of personnel as the audit is carried out. This allows the utility to understand how information is obtained and where it comes from in the audit report, which translates to a more intimate understanding of what may be needed in terms of changes to existing programs or processes, or in new additions to operation. Our audits and resulting reports are concise and a very usable planning tool for improvements in processes, documentation, and ultimately, SSO reduction and better service to the end users.

In instances where multiple departments are heavily involved in operations, there may be need for a stand alone departmental cMOM audit. This process is more focused in nature than the system wide audit, as the topics of the audit will be more narrow in scope and limited to the department mission or charge in their area/s of operations.

Much like the full system audit, we can provide either a high overview audit very inexpensively, or an extremely detailed audit designed to interconnect with other utility departments at logical points. A sample list for this type of audit for a sewer maintenance department would likely include:

• Organizational Structure
• Communications internal to the department
• Communications with other departments in the Utility
• Budgeting
• Short and long term planning for repairs/replacement
• Training and Safety
• IT Services (Information Technology Systems) and work order management
• System Mapping
• CCTV Inspection
• Sewer Line Cleaning – rodding, flushing operations
• Large line maintenance
• Contracting services
• Manhole Inspection/Assessment
• Standard operation procedures (SOPs)
• Emergency Response Procedures (ERPs)

As with a full system audit, one of chief advantages of an outside audit is the department gets an objective look at what it is doing, how it is doing it, and if it is working as desired. Once the initial audit is completed, a priority list from the audit is developed for further action.

Tilson & Associates provides a unique, low cost service in this process, incorporating training of personnel as the audit is carried out. This allows the utility to understand how information is obtained and where it comes from in the audit report, which translates to a more intimate understanding of what may be needed in terms of changes to existing programs or processes, or in new additions to operation. Our audits and resulting reports are concise and a very usable planning tool for improvements in processes, documentation, and ultimately, SSO reduction and better service to the end users.