Regulatory & Indices

The US frameworks that govern a water and sewer utility, and what prevention contributes to each.

NAPOT is the binding constraint for this deployment — Miami-Dade Code Sec. 24-42.3

Nominal Average Pump Operating Time caps every sewage pump station at 10.0 hours per day. Exceed it and the station goes under moratorium — no new building permits upstream until a Remedial Action Plan is certified. Because the rule counts run hours rather than sanitary volume, infiltration and recirculation count against the ceiling exactly like real sewage, so a false water movement can freeze development across an entire basin.

Open NAPOT Compliance

Frameworks Tracked

Federal, state, index, safety

Scored Indices

Produce a grade or ratio

Primary Jurisdiction

FL DEP

62-604 FAC for WASD

Governing Exposure

NPDES

Every SSO is a violation

Federal Statutes & Rules

The legal exposure. These are obligations, not scores — you either comply or you are in violation.

Code	Framework	Authority	Scale	What it measures	Our contribution
CWA §402	NPDES Permit — Clean Water Act	US EPA / delegated state	Rule — not scored	Any SSO is an unauthorized discharge. Permit compliance is the core legal exposure.	Time-to-surcharge ranking creates the documented intervention record before a discharge occurs.
CMOM	Capacity, Management, Operation & Maintenance	US EPA	Rule — not scored	Whether the utility runs an adequate O&M program: mapping, cleaning, condition assessment.	Continuous level + condition telemetry is the evidence base a CMOM audit asks for.
40 CFR 127	NPDES Electronic Reporting Rule	US EPA (NeT / ICIS)	Rule — not scored	Mandatory electronic submission of DMRs and noncompliance reports.	Structured, timestamped event records export instead of being reconstructed by hand.
40 CFR 403	National Pretreatment Program	US EPA / POTW	Rule — not scored	Industrial and FOG discharge limits enforced against contributing users.	FOG fluorescence correlated to a downstream rise attributes the event to a specific discharger.
AWIA §2013	Risk & Resilience Assessment + ERP	US EPA	Rule — not scored	Recurring all-hazards risk assessment and emergency response plan certification.	Live asset criticality and gallons-at-risk feed the consequence side of the assessment.
Consent Decree	EPA / DOJ Enforcement Action	US EPA, DOJ, state AG	Stipulated penalties per event	Court-ordered SSO reduction milestones after a pattern of violations.	Prevented-overflow and gallons-averted counts are the milestone reporting currency.

Scoring Indices

The graded instruments a regulator, rate case or bond review will actually ask for. Each produces a number.

Code	Framework	Authority	Scale	What it measures	Our contribution
PACP 1–5	Pipeline Assessment Certification Program	NASSCO	Structural & O&M grades 1–5	Standardized defect coding per pipe segment; drives rehab prioritization.	Correlated blockage and surcharge history sharpens which segments get inspected first.
MACP / LACP	Manhole & Lateral Assessment Certification	NASSCO	Condition grades 1–5	Manhole and service-lateral condition, a primary I&I entry point.	SmartCover units sit in manholes — telemetry pairs directly to the graded asset.
ILI	Infrastructure Leakage Index	AWWA / IWA (M36)	CARL ÷ UARL (ratio, 1.0 = optimal)	Real physical leakage against the technical minimum for that system.	Continuous flow and pressure data raises audit data-validity scores feeding ILI.
AWWA M36	Water Audit — Real vs Apparent Losses	AWWA	Data validity score 0–100	Splits non-revenue water into real leakage vs apparent (paper) losses.	Directly addresses false water movement — see the apparent-loss panel below.
NRW %	Non-Revenue Water	AWWA / state PUC	% of system input volume	Water produced but not billed; commonly rate-case reportable.	Metered reconciliation separates true loss from measurement artifact.
BRE	Business Risk Exposure	ISO 55000 / industry practice	Likelihood × Consequence	Asset-management scoring that ranks capital spend by risk retired.	Gallons-at-risk per site supplies a defensible consequence term.
AWWA G480	Water Conservation Program Operation	AWWA	Conformance criteria	Standard for a conforming utility conservation program.	Loss reduction evidence supports conformance.

Worker Safety Thresholds

H₂S is the governing sewer atmosphere hazard, and the limits are numeric and enforceable.

Code	Framework	Authority	Scale	What it measures	Our contribution
29 CFR 1910.146	Permit-Required Confined Spaces	OSHA	H₂S PEL 20 ppm ceiling	Atmospheric testing before entry; H₂S is the governing sewer hazard.	Continuous H₂S holds entry automatically instead of relying on a spot reading.
NIOSH IDLH	Immediately Dangerous to Life or Health	NIOSH	H₂S IDLH 100 ppm	Concentration requiring immediate evacuation.	Headworks array trips the hold at the threshold, logged with the reading.

State & Financial Reporting

Jurisdiction-specific programs. Florida is primary for a WASD deployment; others shown for contrast.

Code	Framework	Authority	Scale	What it measures	Our contribution
Sec. 24-42.3	NAPOT — Nominal Average Pump Operating Time	Miami-Dade County / WASD	10.0 hr/day ceiling	Daily average pump run hours per station. Above 10.0 hr the station is placed under moratorium and no new building permits may be issued upstream.	Separates true sanitary run time from infiltration and recirculation so a station is not derated by phantom hours.
62-604 FAC	Collection Systems & Transmission Facilities	Florida DEP	Rule — not scored	Florida permitting and abnormal-event reporting for collection systems.	Primary jurisdiction for a WASD deployment; event timeline exports on request.
2022-0103-DWQ	Statewide Sanitary Sewer Systems WDR	CA State Water Board (CIWQS)	Spill Category 1–3	Spill reporting to CIWQS, Sewer System Management Plan, LRO certification.	Category assignment needs volume and receiving-water reach — both captured at event time.
GASB 34	Infrastructure Asset Condition Reporting	GASB	Condition level vs asserted target	Modified-approach financial reporting requires documented condition assessment.	Condition records tie to the audited financial statement.

False Water Movements — NAPOT Run Hours & Apparent Losses

A false water movement is volume or flow that appears in the data but never physically happened. AWWA M36 calls these apparent losses. They inflate non-revenue water, distort ILI, send crews to sites that were never at risk — and because Sec. 24-42.3 counts pump run hours, they push stations toward a moratorium the real sanitary load never justified.

Cause	Inflates	Why the data lies	Control
Rainfall-derived infiltration	NAPOT hrs	Storm water entering through failed seals and cracked laterals runs the pump on water that is not sewage.	Correlate run hours against rainfall and groundwater to separate wet-weather hours from base sanitary flow.
Check-valve recirculation	NAPOT hrs	Discharge leaking back into the wet well is pumped twice, doubling run time for one volume.	Compare pumped volume against downstream flow — a persistent gap is recirculation, not load.
Float hysteresis / short-cycling	NAPOT hrs	A mis-set or fouled float restarts the pump above true draw-down, adding starts without moving sewage.	Watch cycle count against volume per cycle; rising starts at falling volume is a control fault.
Run-signal held on	NAPOT hrs	A welded contactor or stuck relay reports run time the pump never performed.	Cross-check the run signal against motor current — hours without current are reporting artifacts.
Meter under/over-registration	NRW / ILI	Worn or wrongly sized meters misreport real volume.	Cross-check registered volume against independent flow and pressure series.
Stuck or drifting level sensor	NRW / ILI	A frozen reading looks like a stable level; drift looks like a slow rise.	Flag any series whose variance collapses or that diverges from basin peers.
Surcharge false positive	NRW / ILI	Debris on a sensor face reads as rising water.	Require a corroborating signal — velocity, pump current or a peer site — before dispatch.
Unauthorized consumption	NRW / ILI	Hydrant and bypass draw that never reaches a meter.	Reconcile district-metered input against the sum of downstream reads.
Data-handling error	NRW / ILI	Unit mix-ups, timezone shifts and double-counted imports.	Single ingestion namespace with typed units and one timestamp convention.
Systematic estimation error	NRW / ILI	Billing estimates substituted for absent reads.	Track estimated-read share as its own reported figure.

This is why a corroborated reading matters: one sensor asserting a rise is a hypothesis, while a rise confirmed against velocity, pump behaviour and a neighbouring site is an event. Under Sec. 24-42.3 the same discipline decides whether a basin is open to development.