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February 19, 1999
AMSA Urges Improvements to EPA Toxics Reduction Strategy
AMSA is calling on the U.S. Environmental Protection Agency (EPA) to focus on risk-based approaches to address pollutants such as mercury and dioxin while developing specific strategies to reduce levels persistent bioaccumulative toxic (PBT) pollutants in the environment. In comments submitted to EPA this week on its Multimedia Strategy for Priority PBT Pollutants and Draft Mercury Action Plan, AMSA urged EPA to take several steps to ensure that the most significant risks and sources of PBTs are addressed first, thereby avoiding the potential for expensive pollution control measures that will reap marginal environmental benefits.While applauding EPA for recognizing the need for a multimedia approach to reduce the risks to human health and the environment from existing and future exposure to PBTs, AMSA recommended that EPA identify and promote statutory changes needed to effectively implement the strategy. AMSA advised EPA that without statutory changes, the type of inter-office integration and prioritization required to effectively address PBTs may be impossible. AMSA also cautioned EPA that pollution prevention alone may not feasibly achieve PBT reduction goals. For many PBTs such as banned pesticides or pollutants that originate primarily from air deposition, pollution prevention is simply not an option, and EPA should calculate the true costs of compliance in case pollution prevention measures fail to achieve adequate reductions.
AMSA also urged EPA not to use the Toxics Release Inventory (TRI) as a tool to track the strategy's performance because the current TRI reporting and tracking system does not accurately represent direct releases to the environment.
AMSA also commented on EPA's Draft Mercury Action Plan, the agency's model approach for addressing other PBTs under the strategy. AMSA urged EPA to prioritize actions to control mercury in order to achieve the greatest reduction in risks to human health and the environment. Because EPA will soon apply very stringent mercury water quality criteria across the country and new sampling methods can detect mercury at less than one part per trillion, publicly owned treatment works (POTWs) are facing very low mercury effluent limits. To address this situation, AMSA has encouraged EPA to undertake a national compliance strategy for mercury that might involve variances in conjunction with pollutant minimization measures as an alternative to adherence to unattainable numeric limits, which would require expensive advanced treatment processes that may not have much impact on solving mercury water quality issues. Both the PBT strategy and the mercury action plan appeared in the Nov. 17, 1998 Federal Register. AMSA's comments are available online at http://www.amsa-cleanwater.org .
Plan To Attend the AMSA/SETAC WET Workshop . . . The deadline for registering to attend the March 25-26 whole effluent toxicity (WET) workshop in Arlington, Va. is rapidly approaching. Hotel reservations must be received by March 2, and with limited space available, the sooner you register the better. AMSA and SETAC will host the two-day seminar, A WET Tale: Toxicity of Complex Effluents, which will present critical information on EPA WET test requirements, technical aspects of implementing the WET program for determining the toxicity of discharges and WET issues that pertain to discharge permits. Course participants will receive valuable materials for use at their wastewater treatment agency. Further information and an online registration form can be found on AMSA's web site
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