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Regulatory - Alert (RA 99-22)

Member Pipeline - Regulatory - Alert (RA 99-22)

To:

Members & Affiliates, AMSA Pretreatment & Hazardous Waste Committee

From:

National Office

Date:

November 8, 1999

Subject:

AMSA/WEF Pretreatment Streamlining White Paper

Reference:

RA 99-22

Action Please By: November 19, 1999

Attached please find a copy of the WEF/AMSA white paper on pretreatment streamlining. The paper provides recommendations to the U.S. Environmental Protection Agency (EPA) on ways to further reduce regulatory burden in its July 22, 1999 proposed regulatory and administrative changes to the national pretreatment program (see AMSA Regulatory Alert RA 99-15). AMSA's Pretreatment & Hazardous Waste Committee leadership, along with the Water Environment Federation's (WEF's) Pretreatment Committee developed the white paper as a joint effort.

The paper focuses on six issues from the EPA streamlining proposal including: 1) significant non- compliance (SNC), 2) specific prohibition regarding pH, 3) POTW oversight of categorical industrial users, 4) sampling for pollutants not present, 5) removal credits, and 6) general permits. Additionally, AMSA and WEF have noted agreement with EPA's proposed amendments where appropriate. The paper is designed to assist AMSA and WEF members, as well as industry trade groups in developing comments to the proposal.

AMSA members are encouraged to attach the white paper or use portions of the paper in submitting their comments to EPA. A copy of this White Paper is also available in electronic format at the AMSA web site http://www.amsa-cleanwater.org. It is imperative that EPA receive numerous comments (by November 19, 1999) from member agencies in support of the recommendations. EACH AGENCY'S SUBMISSION COUNTS AS A SEPARATE SET OF COMMENTS, EVEN IF THE SUBSTANCE OF THE COMMENTS ARE IDENTICAL. In order to track the number of comments being submitted, AMSA is requesting that you complete the form on the following page (also available on the AMSA homepage) once you submit your comments to EPA and fax or email it back to the AMSA National Office c/o Robin Davis, 202/833-4657. If you have any further questions, or require assistance, please call Mark Hoeke at the AMSA Office 202/833-9106 or mhoeke@amsa-cleanwater.org.

Attachments:

  • Pretreatment Streamlining White Paper Fax Back Page
    For this downloadable file, you must have the Acrobat Reader. If you don't have the Acrobat Reader, click on the icon below to download a copy. After you download and install a copy, return to this page and click on the link above for the downloadable files.

  • AMSA/WEF Pretreatment Streamlining White Paper
  • AMSA/WEF Pretreatment Streamlining White Paper (WordPerfect Format)
  • Sample Comment Letter Cover Page (WordPerfect Format)