In January of 2014, the North Texas Municipal Water District (NTMWD) experienced a wastewater system compliance inspection by representatives of the Environmental Protection Agency (EPA). The inspection evaluated the level of NTMWD compliance with its wastewater operating permit and the Clean Water Act (CWA). All areas of wastewater operations were inspected, with emphasis on operations, maintenance, and capital investments necessary to eliminate sanitary sewer overflows (SSO). Subsequent to the NTMWD inspection, the EPA returned several times to perform similar inspections on all twelve member cities in the NTMWD Wastewater system. The most recent inspection was completed in the spring of 2015 and that last formal report was issued in August 2015.
The EPA concluded that the NTMWD and member cities should improve their respective wastewater system O&M activities beyond what currently exists under the purview of the TCEQ. This translates into EPA's documentation of suggested improvement in:
• training,
• inspection scheduling,
• maintenance of inspection records,
• mapping in Geographic Information System (GIS),
• need for an enhanced regional wastewater flow model,
• response to SSOs, and
• backup power supply at sewer lift stations and treatment plants.
Additionally, the EPA desires large systems (including Allen's) to have a very well-integrated asset management system in GIS and a very aggressive sewer system replacement program.
As part of their corrective actions, NTMWD has brought together the wastewater member cities in a workgroup to discuss EPA inspection results and corrective actions. NTMWD effectively has the "lead" on these issues because they hold the wastewater permits. NTMWD has met with officials at EPA Headquarters in Washington, DC and EPA Region 6 in Dallas several times. NTMWD is making every effort to show the EPA the progress they (and wastewater member cities) are making on correcting the inspection findings. Key to this effort has been portrayal of a regional approach to creating unified corrective actions.
The term Capacity, Management, Operations, and Maintenance (CMOM) is used to describe the detailed system of operations and maintenance activities that the EPA has an interest in seeing the NTMWD wastewater family adopt for sewer system maintenance. To answer EPA observations and request for improvement, the consensus is to develop a Regional CMOM Program. Following multiple reviews by member-city staff, the NTMWD has circulated a consensus version of the interlocal agreement (ILA) proposed between the NTMWD and all member cities, concerning development of a mutually agreeable Regional CMOM program. Establishment of a mutually agreeable Regional CMOM program is in the best interest of Allen and all member cities because it will demonstrate to the EPA the existence of a collaborative interface between member cities (Allen) and NTMWD systems.