To: Members, Affiliates & Pretreatment & Hazardous Waste Committee From: National Office Date: June 23, 1998 Re: RA 98-11 Pretreatment Program Reinvention Pilot Projects Under Project XL
On June 23, EPA published the attached Federal Register notice (63 FR 34170) requesting proposals from POTWs interested in implementing alternative local pretreatment programs. EPA is not proposing a change to the regulations at this time. Instead, in response to the findings of stakeholder studies initiated by AMSA regarding measures of performance, EPA is requesting POTWs interested in implementing environmental performance-based programs to submit Project XL proposals explaining how they would change their pretreatment program implementation. AMSA member agency contacts are requested to forward this Regulatory Alert to your pretreatment coordinator for review and consideration.
To qualify for this Project XL program a POTW must: currently administer an approved pretreatment program; have a solid record of compliance; and have five years of influent, effluent, and sludge quality data, as well as three years of ambient water quality measurements for its receiving water or be able to demonstrate the ability to collect ambient data. The project proposed by the POTW must then meet the Project XL criteria as explained in the Federal Register notice. POTW agencies interested in participating in this Project XL solicitation have until September 21, 1998 to submit a preliminary proposal for consideration. EPA’s Project XL program is discussed further in the attached Federal Register notice (63 FR 34161).
The intent of this proposal is to allow programs that have demonstrated a strong compliance record and an ability to measure environmental performance to investigate alternative ways of implementing local pretreatment programs that will produce superior environmental performance. The alternate program would use specific measures to determine whether or not implementation procedures are achieving their desired results.
POTWs which have mastered the programmatic aspects of the pretreatment program (identifying industrial users, permitting, monitoring, etc.), may want to move into more environmental performance-based processes. AMSA has been actively promoting pretreatment streamlining/reinvention activities over the past several years, including its participation in three cooperative agreements with EPA in support of these approaches. Several POTWs have already expressed an interest in being allowed flexibility to focus their resources on procedures that they believe will provide greater environmental benefit. These POTWs want to be able to make decisions to allocate resources based on the risk associated with industrial contributions they receive or other factors. Several AMSA POTWs want to be able to apply resources to ambient monitoring in their receiving waters and/or to integrate their pretreatment programs with their storm water monitoring programs. Since they have limited resources, some POTWs may need the flexibility to drop some of the prescribed programmatic elements and redirect these resources.
Given all of these considerations, the pilot program is being limited to POTWs that have mastered the programmatic elements and have available a significant amount of environmental performance data (or a demonstrated ability to collect the necessary data). These conditions can form the basis for creative alternative approaches that best allocate limited resources. It is expected that by providing this discretion to the POTWs, they will be able to focus their limited resources on activities that produce superior environmental performance.
For local POTW Pretreatment Programs, superior environmental performance may include:
- Reducing pollutant loadings to the environment or achieving some other environmental benefit beyond that currently achieved through the existing pretreatment program (including collecting environmental performance data and data related to environmental impacts in order to measure the environmental benefit. Such information would include data on pollutant loadings to the environment, ambient environmental conditions and measures of the impact of these conditions on the health of ecosystems. The data should be able to support decisions concerning the future use of pretreatment program resources);
- Reducing or optimizing costs related to implementation of the pretreatment program with the savings used to attain environmental benefits elsewhere in the watershed in any media; and,
- Other environmental benefits gained by allowing pretreatment program flexibility.
AMSA members should submit formal proposals to: Michael B. Cook, Director, Office of Wastewater Management (MC 4201), U.S. Environmental Protection Agency, 401 M Street, SW, Washington, DC 20460. Duplicate copies of your proposal should be sent concurrently to the appropriate regional EPA pretreatment coordinator and the state pretreatment program coordinator providing oversight of your pretreatment program.
If you have any questions or if you would like additional clarification please contact Patrick Bradley, EPA, at 202/260-6963. AMSA members interested in participating in this pretreatment Project XL activity should contact Sam Hadeed, AMSA’s director of regulatory affairs and technical services at 202/833-4655 or shadeed@amsa-cleanwater.org. AMSA’s National Office wants to track member agency interest and facilitate your application process with EPA. Copies of application should also be sent to Sam Hadeed at the National Office.
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