HomeMy Public PortalAboutApproval Modification of Capacity, Management, Operations and Maintenance (CMOM) Program PlanUNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 7
11201 Renner Boulevard
Lenexa, Kansas 66219
02 DEC 2016
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Article No.: 7014 1200 0000 6126 0662
Mr. Brian Hoelscher
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103-2555
RE: Approval Modification of Capacity, Management, Operations and Maintenance (CMOM)
Program Plan 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 Line
Cleaning Performance Standards contained in the CMOM Plan submitted by the Metropolitan St. Louis
Sewer District on November 9, 2016. The EPA is accepting the revisions to the plan in accordance with
Paragraph V.G.33 of the Consent Decree.
The modifications to the line cleaning performance standards will be based on the condition rating given
during the time of acoustic inspection for the pipe less than 15" in diameter in the Separate System. The
previous standard was a fixed annual requirement to clean Non-PCV pipe less than 21" every five years
and PVC pipe less than 21" every 10 years. In the Separate System, MSD will use acoustic inspections
of PVC and Non -PVC pipe less than 15" every six years to determine if cleaning is necessary. All pipe
rated 0 to 5 based on the acoustic inspection will be cleaned, In the Separate System, MSD will also
clean PVC and Non -PVC pipe greater than 15" and less than 21" every six years. In the Combined
System, MSD will clean PCV and Non -PVC pipe less than 21" every five years. This change to the
Performance Standards will ensure the collection system is cleaned in a cost effective manner.
If you have any questions, please contact me at 913-551-7782, or Jodi Bruno of my staff at 913-551-
7810, or at Bruno.jodi@ epa.gov.
Sincerely,
Karen A. Flournoy
Director
Water, Wetlands and Pesticides Division
Printed on Recycled Paper
(Sent via hard copy):
Chief, Environmental Enforcement Section
Environment and Natural Resources Division
U.S. Department of Justice
Box 7611 Ben Franklin Station
Washington, D.C. 20044-7611
Re: DOJ No. 90-5-1-1-081 1 1
Chief Counsel
Agriculture and Environment Division
State of Missouri Office of Attorney General
207 W. High Street
Jefferson City, Missouri 65102
Chief, Water Pollution Compliance and Enforcement Section
Missouri Department of Natural Resources
P.O. Box 176
1101 Riverside Drive
Jefferson City, Missouri 65101
Director, St. Louis Regional Office
Missouri Department of Natural Resources
7523 South Lindbergh Blvd.
St. Louis, Missouri 63125
Heather Navarro
Director
Missouri Coalition for the Environment
3115 S. Grand Blvd., Ste. 650
St. Louis, MO 63118
Maxine I. Lipeles
Elizabeth J. Hubertz
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive. Campus Box 1120
St. Louis, Missouri 63130
"General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103-2555
Director of Engineering
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103-2555
2