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Friday, June 6, 1997

EPA Issues Review Draft of Pretreatment Streamlining Proposal
Earlier this week, EPA issued for external review its draft proposed regulatory and administrative changes to streamline the national industrial pretreatment program. The effort is designed to provide administrative changes to reduce the burden on entities regulated under the pretreatment program. In May 1996, the Agency developed a series of informal issue papers for stakeholder review/comment on certain technical and administrative requirements under consideration in this initiative. Based on that input, and the results of the AMSA-WEF Pretreatment Streamlining Workshop held in Aug. 1996, EPA produced the draft for stakeholder input prior to a formal proposed rulemaking planned for Dec. 1997. Highlights of the 13 specific issues under the proposed pretreatment program changes include:

Specific Prohibition Regarding pH: POTWs could accept discharges with a pH below 5.0 to the extent that they can document that the discharges will not damage their systems.
Equivalent Mass Limits for Concentration Limits: Control Authorities (CAs) could set mass limits as an alternative to concentration limits due to reduced water use by an industrial user.
Equivalent Concentration Limits for Flow-Based Standards: CAs could set limits on industrial users by applying the concentration numbers in a flow-based standard directly as equivalent concentration limits if the flow from a facility is so variable that the development of mass limits is impractical.
POTW Oversight of Significant Industrial Users: CAs could exempt de minimis Categorical Industrial Users from the definition of SIU.
Slug Control Plans: POTWs would not be required to evaluate the need for a slug control plan for each SIU every two years
Sampling for Pollutants Not Present: CAs could waive IU sampling for pollutants that have been determined not to be present.
De Minimus Categorical Industrial Users: If the CA decides to sample a de minimis facility annually, it could also allow the facility to self-monitor only once per year.
Use of Grab and Composite Samples: This would allow compositing of grab samples for cyanide, volatile organic compounds, and other parameters unaffected by the compositing process.
Removal Credits: Removal credits would be available for those pollutants that are not controlled by a standard for the use or disposal of biosolids.
Electronic Filing and Storage of Reports: Definitions of "signed", "in writing", and "written submission" would include electronic submissions to ensure appropriate security and data integrity.
General Permits:
CAs could use general permits to regulate significant industrial users if they are covered by concentration-based standards or best management practices.
Best Management Practices:
BMPs developed by POTWs could serve as local limits.
Modifications of Significant Noncompliance Criteria: SNC criteria would only be required to apply to SIUs. SNC criteria would be changed to address violations of pretreatment standards or requirements rather than just violations of daily maximum or longer-term average limits.

Copies of the draft pretreatment streamlining package were sent to the AMSA membership via RA 97-13. Members are strongly urged to comment, particularly on SNC issues. Comments are due back to the National Office by July 1. Please contact Sam Hadeed, AMSA at (202) 833-4655 for any additional information.


Summer Conference Update ... Attendees please note that the Water Quality and Biosolids Management Committees will meet on Tuesday, July 15 from 3:30 - 5:00 p.m. instead of 4:00 - 5:30 p.m. The Financing & Management Committee will meet on Thursday, July 17 from 7:30 - 9:00 a.m. instead of 8:00 - 9:00 a.m.