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SSOs & FOG ControlAdvanced 26 min read

SSOs & FOG Control: Advanced SSO Regulatory Framework & CMOM

In-depth treatment of the Clean Water Act/NPDES foundation for SSO reporting, EPA's withdrawn 2001 SSO rule and the resulting CMOM framework, Colorado's CDPHE-administered reporting requirements, public notification obligations, and coordination with NPDES permits and consent decrees.

There is no single federal rule that tells you exactly when and how to report a sanitary sewer overflow — the national SSO rule EPA drafted in 2001 was withdrawn before it ever took effect, and it has never been replaced. That gap means the actual reporting obligations a Class 4 operator has to navigate come from a patchwork: general NPDES permit conditions, your utility's specific state permit, and — if your system is under a consent decree — negotiated terms that can be far more demanding than any baseline rule. This guide works through that regulatory landscape in depth, including what could and could not be verified about Colorado's specific requirements, so you know exactly where to go for the authoritative answer.
The Clean Water Act Foundation: Why SSOs Are Unlawful Discharges
The Clean Water Act prohibits the discharge of pollutants to waters of the United States except as a

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