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Approval 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