NPDES Permit Issues
NPDES Streamlining - Proposed Rule
Background: In response to President Clinton’s February 21, 1995 Reinventing Government directive, EPA proposed revisions to NPDES requirements in 40 CFR Parts 122, 123, and 124 to eliminate redundant regulations, provide clarification, and remove or streamline unnecessary procedures which do not provide environmental benefits (Round II). Proposed revisions for Round II, as published by EPA on December 11, 1996, include:
- allowing general permits to cover multiple categories of discharges, thus, increasing the ability of general permits to cover currently unregulated sources, and streamline reissuance procedures of general permits where no changes in permit conditions are anticipated;
- allowing permit writers not to require permit limits for all effluent guideline listed pollutants under certain circumstances;
- removal of stormwater group application requirements;
- streamlining permit terminations procedures; and,
- revising Part 124 evidentiary hearing procedures.
Status: A second draft of the final regulation preamble language for Round II is currently undergoing internal EPA review. EPA plans to publish a final rule in April 1998. Work has begun on Round III streamlining and may include (1) additional permit modifications that can be considered minor, and (2) changes to requirements concerning EPA’s review of State permits. Other NPDES streamlining efforts are described in more detail in other sections of this Update. CONTACT: Thomas Charlton, EPA 202/260-6960.
NPDES Permit Application Requirements for POTWs, Form 2A and 2S - Proposed Rule
Background: On December 6, 1995, EPA published a proposed regulation which will amend NPDES permit application requirements and application forms for POTWs and will replace existing Standard Form A and Short Form A to account for changes in the NPDES program since the forms were issued in 1973. The proposal consolidates POTW application requirements, including information regarding toxics monitoring, whole effluent toxicity (WET) testing, pretreatment facility and hazardous waste contributions, and combined sewer overflows (CSOs). The most significant proposed revisions according to EPA, would require toxic and WET monitoring by major and pretreatment POTWs. The proposed rule allows waivers where information is already available to the permitting authority.
Status: AMSA submitted comments to EPA on March 28, 1996. EPA expects to publish a final rule in late spring 1998. CONTACTS: Sam Hadeed, AMSA 202/833-4655, or Robin Danesi, EPA 202/260-2991.
The next NPDES Permit Writers’ Training Course is scheduled for May 11-15 in Portsmouth, NH. Courses are also scheduled for July 27-31 in Austin, TX, and September 21-25 in Seattle, WA. For more information, contact Daniel Weese, EPA 202/260-6809.