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August 21, 1998
National Office Staff Meets with Chuck Fox on Water Issues
On Monday, August 17 AMSA’s National Office staff met with Chuck Fox, the new acting assistant administrator for EPA’s Office of Water to discuss priority issues affecting the AMSA membership. From the discussions it was clear that Fox does not plan to drastically alter current water office priorities or activities. Fox was very interested in hearing AMSA concerns regarding the control of nonpoint source pollution, Clean Water Act reauthorization, wet weather regulation, mercury control efforts, and proposed changes to the water quality standards regulation. Fox relayed his support for holistic watershed management concepts and the Clean Water Action Plan. He also indicated strong support for the concept of effluent trading among point and nonpoint sources, and suggested that EPA would make small grants available for fledgling effluent trading efforts. Fox also supported an AMSA suggestion that EPA make grants available for pilot unified wet weather permits or permitting programs. Fox is scheduled to meet with the AMSA leadership during the Fall Leadership Meeting on Sept. 24-25.
AMSA Meets with OMB to Reinforce SNC Changes in Pretreatment Streamlining Proposal
AMSA’s National Office staff and Pretreatment & Hazardous Waste Committee Chair Guy Aydlett met with the Office of Management & Budget this week to press the Association’s proposed changes to the definition of significant noncompliance (SNC) in EPA’s pretreatment streamlining proposal. While AMSA has met with EPA’s Office of Enforcement & Compliance Assurance (OECA) to address SNC issues, OECA has resisted taking any further steps on this issue. OMB, however, is a proponent of streamlining, was very receptive to AMSA’s concerns, and is interested in ensuring that the rule will not create unnecessary burdens on POTWs.
AMSA is recommending the following modifications of SNC criteria: 1) provide POTWs more flexibility to determine if reporting violations should be classified as SNC; 2) apply SNC only to significant industrial users; 3) base SNC determinations on six calender months of data and not on rolling quarters; and 4) revise the technical review criteria related to pretreatment program implementation. The proposal will be distributed to the membership via a Regulatory Alert following its fall publication in the Federal Register.
EPA Publishes Draft Human Health Criteria Methodology
On August 14, EPA’s Draft Revisions to the Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health (AWQC Methodology Revisions) appeared in the Federal Register. Changes presented in the proposal from the 1980 AWQC National Guidelines include: replacing bioconcentration factors (BCFs) with bioaccumulation factors (BAFs); replacing the default fish intake rate of 6.5 grams/day to 17.8 grams/day (for protection of the general adult population and sport anglers) and 86.3 grams/day (for protection of subsistence fishers), and the addition of an incidental exposure rate of 0.01/liters/day to account for long-term incidental recreational ingestion where recreational waters are not used as drinking water sources.
In addition to the draft Federal Register notice, EPA has developed a Technical Support Document (TSD). The TSD includes more technical detail and is supplemented by three proposed criteria. AMSA will be distributing the AWQC Methodology Revisions to the membership next week via a Regulatory Alert.