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HomeMy Public PortalAboutApproval CMOM Plan Modification - Pump Station and Force Main Inspection and Testing Modification (12/10/2020) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 7 11201 Renner Boulevard Lenexa, Kansas 66219 Printed on Recycled Paper SENT VIA ELECTRONIC MAIL RETURN RECEIPT REQUESTED Mr. Brian Hoelscher Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 bhoelscher@stlmsd.com RE: Approval of Modification of Capacity, Management, Operations, and Maintenance Program submitted pursuant to Consent Decree no. 4:07-CV-1120 Dear Mr. Hoelscher: The U.S. Environmental Protection Agency has reviewed the proposed modifications to the Sewer System Asset Management Process contained in the CMOM Plan submitted by the Metropolitan St. Louis Sewer District on September 21, 2020. The EPA is accepting the revisions to the plan in accordance with Paragraph V.G.33 of the Consent Decree. Modifications to the Sewer System Asset Management Process will make changes to the force main inspection program, and the force main non-destructive testing program. Each program will reclassify pump stations and force mains into a new risk-based matrix, replacing the current classifications as defined in the CMOM Plan with a critical or non-critical designation. Pump stations will be inspected either weekly or monthly thereby eliminating previous bi-monthly inspections. Force mains will be inspected either annually or every five years, eliminating the previous category of inspections conducted every two years. Force main non-destructive testing will be consolidated into one category and testing will be conducted every five years. This will eliminate previous testing conducted once every six years and once every three years. Changes to the inspection and testing programs will allow MSD to consolidate inspections for more efficiency, better matching of resources, and align more closely with other MSD planning processes. This proposed revision was included in the annual report that was submitted to the EPA on October 30, 2020. Details will also be included in the 2020 annual report due on October 31, 2021. MSD also seeks to make further changes to the Sewer System Asset Management Process. Additional modifications would change the mileage requirements for sewer repair, rehabilitation, and/or replacement as described in the Consent Decree but is not expected to occur until 2025. 2 The EPA is reserving final approval for this modification until is presented in the annual report pursuant to Paragraph 33 of the Consent Decree. If you have any questions, please contact Erin Kleffner at kleffner.erin@epa.gov, or Jodi Bruno at bruno.jodi@epa.gov. Sincerely, David Cozad Director Enforcement and Compliance Assurance Division cc: Kristi Savage-Clarke, Kristi.Savage-Clarke@dnr.mo.gov Lourdes Bufill, Bufill.Lourdes@epa.gov Kathryn Macdonald, kathryn.macdonald@usdoj.gov Elizabeth Hubertz, ejhubertz@wustl.edu