Member Pipeline - Regulatory - Alert (RA 99-3)
To:
Members & Affiliates
From:
National Office
Date:
March 2, 1999
Subject:
National SSO Policy Dialogue Status
Reference:
RA 99-3
On December 23, 1998, the Office of Water and the Office of Enforcement and Compliance Assurance jointly circulated a memorandum concerning draft policy and regulations clarifying NPDES permit requirements for municipal sanitary sewer collection systems and SSOs to EPA Regional Water Directors, and States for review. A meeting of regional and state representatives was held in early February to discuss EPA's draft approach and regulations. Attached for your information is a February 17, 1999 two-page EPA outline on the current status of the policy/regulation development.
As many of you know, EPA is crafting a national framework to guide the Agency in revising regulations and guidance to address SSO permitting and enforcement issues. A federal advisory committee, made up of municipal (including AMSA), environmental, EPA, and state interests met from November 1994 to December 1996 to discuss framework and implementation issues. The Office of Wastewater Management (OWM) is currently developing a draft Federal Register notice that will include:
- An interim policy statement addressing NPDES permit requirements for municipal sanitary sewer collection systems (the policy will clarify how existing “generic” standard NPDES permit conditions apply to municipal sanitary sewer collection systems); and
- Proposed modifications to the NPDES regulations which would establish standard permit conditions specifically for municipal sanitary sewer collection systems. These standard permit conditions will address: reporting requirements for sanitary sewer overflows (SSOs); and a prohibition on discharges from municipal sanitary sewer collection systems.
It is expected that a subset of regional/state meeting participants will consider alternative approaches and analyze options during the next two months. A follow up regional/state meeting is scheduled for April 28 in Washington, DC. EPA plans to begin sharing its draft approach with the SSO Federal Advisory Committee at the end of May 1999, and plans to reconvene the federal advisory committee at the end of July 1999.
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