|
|
|
|
|
|
AMSA Special Committees Address Top Issues
At the Association's 2000 Summer Conference, TMDLs . . . Obstacles or Opportunities?, AMSA Special Committees took up a host of issues that are currently impacting the nation's POTWs. Municipal wet weather flows, Clean Water Act legal issues, total maximum daily loads, mercury, wastewater infrastructure funding and public utility asset management emerged as the leading topics of discussion.
AMSA's Special Committee structure allows public wastewater utility professionals to collaborate with their colleagues from across the country and participate in the formation of AMSA policy on major issues. The following summaries highlight the topics covered by AMSA's Special Committees:
Air Quality Committee
Co-Chairs
Ed Torres
County Sanitation Districts of Orange County, Calif.
Prakasam Tata
Metropolitan Water Reclamation District of Greater Chicago, Ill.
After working successfully last year to ensure workable publicly owned treatment works maximum achievable control technology air quality standards, AMSA's Air Quality Committee is now closely monitoring the U.S. Environmental Protection Agency (EPA) Office of Air and Radiation's activities as the Agency gathers health effects and exposure information on hydrogen sulfide (H2S). The committee discussed EPA's two-year effort to determine whether the gas should be defined as a hazardous air pollutant under the Clean Air Act. EPA now is gathering information from the public as well as federal, state and local agencies. A joint EPA-industry symposium is planned for this fall to bring together exposure and health effects scientists. Further information on EPA's H2S activities is available online www.api.org/h2s.Upon their publication later this year, EPA's proposal to develop national emission standards for hazardous air pollutants and new source performance standards for internal combustion engines, combustion turbines, boilers, flares and process heaters will be reviewed by the Committee.
The Committee also discussed other activities, which include participation on AMSA's Mercury Workgroup and review of pertinent documents associated with EPA's Integrated Urban Air Toxics Control Strategy.
Biosolids Management Committee
Co-Chairs
Bob Dominak
Northeast Ohio Regional Sewer District, Ohio
Ray Kearney
City of Los Angeles, Department of Public Works, Calif.
The Biosolids Management Committee discussed the status of EPA's round II amendments to the Part 503 rule limiting dioxin and dioxin like compounds in biosolids reuse/disposal. AMSA has progressed in its efforts to perform a voluntary dioxin survey of the AMSA membership to help confirm and assume declining trends in levels of dioxin in biosolids. The committee has developed a questionnaire and identified a laboratory that would perform the analytical work for the survey; however, details regarding appropriate methods, detection levels, and use of the survey in the development in the final regulation are still being discussed with EPA officials.The Committee also discussed the status of a survey being conducted by the Inter-agency Steering Committee on Radiation Standards (ISCORS) to assess the levels of radionuclides in biosolids. The survey is over half way complete with a final release date of fall 2001. ISCORS has also issued a draft guidance on radioactivity for POTWs which the committee plans to review and provide input back to ISCORS (see related article).
Another issue receiving attention by the committee was the release of the National Institute for Occupational Safety and Health (NIOSH) document intended to provide guidance to workers handling Class B biosolids. The committee questioned the need for the document given the health record of POTW workers over the past 30 years, urged clarification of several draft NIOSH recommendations and challenged the limited basis for establishing recommended engineering controls (see related article).
Competitive Management Committee
Chair, Ralph Charlton
Alexandria Sanitation Authority, Va.
Vice Chair, Paul Causey
Delta Diablo Sanitation District, Calif.
AMSA's Competitive Management Committee discussed several public agency competitiveness issues and the development and progress of new and ongoing AMSA activities when it met on July 20. The Committee discussed the schedule, RFP development, and stakeholder involvement required to launch the U.S. Environmental Protection Agency/AMSA cooperative agreement to promote POTW asset management called Managing Public Utility Assets to Minimize Cost & Maximize Performance. Please see the Finance & Information Services Committee meeting summary for the project's schedule.Members and leadership of both the Competitive Management Committee and the Finance & Information Services Committee have formed a working group to guide the project, and in late July, AMSA held an organizational meeting of representatives of the Association of Metropolitan Water Agencies (AMWA), Water Environment Federation and the American Water Works Association to identify public water and wastewater utility needs with regard to asset management. Asset management will figure prominently in the program of AMSA's 2001 Winter Conference in San Diego, Calif — Managing Utility Assets. . . Securing Your Financial Future from January 30 through February 2, 2001.
Committee members also heard a status report on the marketing outreach efforts to interest national organizations representing local elected and appointed officials and various business services in both the AMSA/AMWA On-Site Workshops, Creating High Performance Business Services and Thinking, Getting & Staying Competitive.
In a discussion on the AMSA/Water & Wastewater Equipment Manufacturers Association Procurement Dialogue, Committee members noted the trend toward “Electronic Procurement,” which has been the subject of increasing attention for AMSA staff and members. The Committee members also discussed the development schedule and review of curriculum materials for the Leadership Center for Public Water & Wastewater Utilities.
Finance & Information Services Committee
Chair, Brian Crewdson
Anchorage Water & Wastewater Utility, Alaska
Vice Chair, Charles Etwert
Metropolitan St. Louis Sewer District, Mo.
The Committee received an update on the status of the AMSA/EPA Cooperative Agreement — Managing Public Utility Assets to Minimize Cost & Maximize Performance — to study asset management in the water and wastewater community. The two-year project began in July with a meeting of WEF, AMWA and AWWA representatives to identify the needs of water and wastewater agencies. The first year of the project will include developing and distributing a Request for Proposals. It is anticipated that a contractor for the project will be chosen before the start of the 2001 calendar year. The project schedule includes development of a handbook and workshops. The handbook and workshops are tentatively scheduled for release in late-2001.The AMSA Awards Committee has asked the Finance and Information Services Committee to develop criteria for a new AMSA E-Media Award. The committee plans to develop selection guidelines for discussion at the next committee meeting.
AMSA member agencies have been forwarded the survey form for the 2000 AMSA Index, a comparison of household sewer service charges. AMSA members are encouraged to complete this one page survey.
Legislative Policy Committee
Chair, Buddy Morgan
Montgomery Water Works & Sanitary Sewer Board, Ala.
Vice Chair, William B. Schatz
Northeast Ohio Regional Sewer District, Ohio
The Legislative Policy Committee met on July 19 to brief members on the status of key AMSA initiatives and to discuss strategy. The Executive Director provided a forecast for the remainder of the 106th Congress, focusing on the impacts of the election year campaigns, the movement of environmental legislation and the future effects of the budget surplus.Committee Chair Buddy Morgan opened the discussion on the importance of AMSA's leadership in the debate over the fate of the TMDL rule. Staff provided an overview of the legislative atmosphere which culminated in the budget rider prohibiting EPA from spending FY 2000 and 2001 dollars on TMDL rule implementation. A draft AMSA resolution on TMDLs was distributed to Committee members for consideration and comment. The Committee agreed to make several changes to the resolution prior to its approval. Among the concerns expressed by the Committee about the final rule was the issue of the Region IX guidance, the uncertain commitment by EPA to conduct designated use reviews in conjunction with TMDL development, and the need to greatly expand funding mechanisms to help States conduct TMDLs (see related article).
AMSA staff next provided an update on the prospects of H.R. 3570, the AMSA-supported wet weather bill, amid continued discussion within the House Water Resources & Environment Subcommittee. Although the majority committee staff's development of a draft wet weather package similar to H.R. 3570 — the Wet Weather Water Quality Act of 2000 — provided a major boost to the bill's prospects, the minority leadership has not yet indicated its support for moving forward without attaching additional environmental issues. Committee members also heard a general overview of the current and future activities of the Water Infrastructure Network (WIN). This fall, WIN will be convening three facilitated work sessions in order to come to agreement on a White Paper on funding mechanisms. WIN will continue to meet regularly with members of Congress to ask them to join the Water Infrastructure Caucus (WIC) and will be taking advantage of other legislative opportunities to put the case for expanded funding resources for clean water before lawmakers. Both the Bush and Gore presidential campaigns have received the WIN report and staff are planning to meet with campaign officials.
AMSA staff was pleased to announce favorable prospects for Phase III funding for the National Biosolids Partnership. The House FY 2001 budget for EPA included $1 million for the Partnership, an increase from the $900,000 of the past two years, and AMSA is hopeful that similar results will take place after the Senate has completed its budget debates. Staff also summarized and updated the status of other relevant environmental legislation, including bills addressing the Clean Water State Revolving Fund (SRF), biological monitoring, cleanup of abandoned mines, and coastal water quality. In order to identify and develop AMSA's strategy for the 107th Congress, the National Office announced plans to host a post-election strategy session on priority legislative issues.
Pretreatment and Hazardous Waste Committee
Chair, Guy Aydlett
Hampton Roads Sanitation District, Va.
Vice Chair, Kevin Aiello
Middlesex County Utilities Authority, N.J.
The Pretreatment Committee discussed AMSA's efforts to gain EPA approval of an alternative analytical method for mercury — draft Method 245.7. After initial support from EPA's Office of Science and Technology in 1998-99, efforts to approve the method had been dropped due to lack of Agency funding. Method 245.7 is significantly less expensive to perform than EPA's approved Method 1631, and would save POTWs an estimated $17 million per year in analytical costs. The Committee recommended that AMSA continue to push the Agency for approval of Method 245.7, which subsequently led to a meeting with EPA Assistant Administrator for Water, Chuck Fox (see related article).The Committee discussed concerns about the use of lindane-containing products for head lice and scabies treatment having the potential to cause or contribute to violations of water quality standards for lindane in California and in other parts of the country. The National Toxics Rule and the recently promulgated California Toxics Rule contain very stringent limits for lindane. The allowable concentration for discharges into water bodies that are drinking water sources or potential drinking water sources is 19 parts per trillion (ppt). POTWs in California cited discharges in the range of 30 to 40 ppt lindane, and in many cases, discharge to effluent-dominated water bodies. In these cases, no dilution credit is allowed and the 19 ppt limit must be met directly in the discharged water. California members have been active in developing a public outreach campaign on the impacts of lindane-containing products and initiating efforts to ban the sale of lindane-containing products in California.
The Committee also discussed the status of the Metal Finishing Strategic Goals Program, and the status of effluent guidelines, including an update on EPA's upcoming proposed Metal Products & Machinery (MP&M) rulemaking which is expected to be released in October 2000. AMSA is currently working with industry trade groups in developing a response to the upcoming proposal.
Water Quality Committee
Chair, Norm LeBlanc
Hampton Roads Sanitation Districts, Va.
Vice Chair, Peter Ruffier
City of Eugene, Ore.
Director of EPA's Assessment And Watershed Protection Division Elizabeth Fellows briefed the committee on the status of EPA's new Consolidated Assessment and Listing Methodology (CALM) initiative. The CALM initiative is intended to result in guidance to states on developing methodologies to determine water body listings and use attainment status under section 303(d) and 305(b) of the Clean Water Act. Under the new TMDL rule, states will be required to develop methodologies, with public input, for listing water bodies not attaining standards. Committee members encouraged EPA to ensure that adequate monitoring is conducted by states, highlighting the need for minimum quality assurance, quality control requirements and the identification of appropriate water quality parameters to be monitored. Committee members also discussed concerns regarding naturally caused impairments, measuring biological health, bacterial indicators, and how fish advisories would be assessed. EPA has conducted one set of public meetings with point source interests, including AMSA, states, nonpoint sources, and environmental groups, and plans to convene additional meetings this fall as draft of the guidance are developed. A final guidance is expected to be completed by July 2001. The committee was also updated on the status of nutrient criteria development, endocrine disrupter research, and the status of TMDL regulation and related legislation and the electronic data reporting rule.Wet Weather Issues Committee
Chair, James Murray
Wayne County Department of Environment & Public Works, Mich.
Vice Chair, David Williams
East Bay Municipal Utility District, Calif.
The Wet Weather Issues Committee meeting on July 18 focused predominantly on issues surrounding the release of the proposed sanitary sewer overflow (SSO) regulations, and provided updates on EPA's combined sewer overflow (CSO) water quality standards guidance as well as potential AMSA litigation over numerical limits in stormwater permits. Michael Cook, Director of EPA's Office of Wastewater Management, was on hand to discuss the proposed rule and field member questions. According to Cook, the Office of Management & Budget's (OMB) extended review of the proposed SSO rule, which has exceeded the allotted 90-day schedule, has focused primarily on concerns about the cost-benefit analysis in the preamble, especially EPA's assumptions about baseline costs for compliance with the rule. Originally set for release in late May 2000, EPA now estimates that a September proposal is more realistic. EPA has categorized the SSO rule as a “major rule” because it is expected to impose costs of over $100 million.OMB has directed EPA to consider several alternative options for public comment in the preamble including whether to reformat the entire rule package to more closely mirror EPA's National CSO Control Policy and whether to amend the secondary treatment standards to define allowable SSO discharges. Cook clarified that the aspects of the CSO Policy that would be most comparable to the SSO regulations are the nine minimum controls. When asked by Northeast Ohio Regional Sewer District's Assistant General Counsel Lisa Hollander whether EPA might consider delaying the release of the rule further to pursue reformatting the rule based on the CSO Policy, Cook replied that the Agency is only considering changes to the preamble, not to the regulatory language itself.
Cook noted that EPA's Office of Enforcement & Compliance Assurance (OECA) is moving forward with its enforcement strategy for priority SSO and CSO discharges and mentioned that Region IV's capacity, management, operation, and maintenance checklist is a good model for Regions to use in soliciting plans from municipalities. He also mentioned the likelihood that OECA's enforcement initiative would evolve into the national permit approach. In response to a question by Committee Chair James Murray about national design standards for the collection system, Cook replied that the lack of scientific literature defining what to expect from aging sewers has prevented EPA from considering any national approach. Chris Westhoff, Assistant City Attorney for the City of Los Angeles' Department of Public Works, outlined his concerns about the current proposed language for permitting satellite collection systems, and suggested that the POTW be given the discretion to decide between some type of joint or separate permit. Lisa Hollander and James Murray are heading up AMSA's SSO Workgroup which will be focusing on the development of Association comments on the proposed rule (see related article).