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To: Members & Subscribers, and 1996 AMSA/EPA Pretreatment Coordinators' Workshop Participants
From:National Office
Date:May 14, 1997
Re:RA 97-11

Measuring Progress - Case Studies In The Application Of Performance For Potw Pretreatment Programs"

The enclosed report, Measuring Progress - Case Studies in the Application of Performance for POTW Pretreatment Programs, builds on the results of AMSA's 1994 project and publication, Performance Measurement and the National Industrial Pretreatment Program, and demonstrates AMSA's commitment to assisting EPA's efforts for reinvention. The study found that greater program flexibility could result in enhanced environmental protection and reduced program costs. According to the program managers at the study sites, flexibility would result in shifts of resources to the highest priority problems resulting in less cost, greater certainty and enhanced pollution prevention programs. While the local flexibility could result in certain risks to water quality that are different from the risks presented under current policies, very few current program requirements would be eliminated entirely.

To help offset these risks, the report recommends that pilot programs be used to help phase-in and promote reinvention efforts. Under this strategy, only those agencies that can demonstrate readiness to manage locally directed program will be eligible. Once eligible, the exact dimensions of each local program can be negotiated with the public and EPA. The pilot project approach will be the focus of the next steps in AMSA's reinvention efforts. A concept paper, Reinventing the National Industrial Wastewater Pretreatment Program: A Pilot Project Approach, which explores reinvention of the national pretreatment program through voluntary, local pilot projects, is currently under review by EPA Headquarters, EPA Regions, state pretreatment coordinators, AMSA's Pretreatment & Hazardous Waste Committee, AMSA-WEF Pretreatment Streamlining Workshop Attendees and the Clean Water Coalition.

Following the review of the concept paper, AMSA plans on scheduling a meeting for late June to develop a white paper and continuing to play an active role in the reinvention and streamlining efforts. AMSA's National Office expects to receive an interim draft of EPA's pretreatment streamlining proposal for review in late May. A 30-day comment period is anticipated. Copies will be forwarded to the membership at that time. For more information contact Sam Hadeed at the National Office (202/833-4655).

ATTACHMENT:

  • Full Report