HomeMy Public PortalAbout6. Approval 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.
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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