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January 8, 1999
AMSA Submits Comment on Water Quality Standards ANPRM
On January 4, AMSA submitted comments on EPA's Advanced Notice of Proposed Rulemaking (ANPRM) for revising the national water quality standards regulation. In its comments, AMSA discusses the need for regulatory change. AMSA supports EPA's overall vision that the water quality standards program needs to better promote watershed-based approaches, and emphasizes that changes need to provide flexibility to EPA, states, and the regulated community to target resources. Also, AMSA urges EPA to ensure that regulatory modifications and efforts to encourage involvement of unregulated nonpoint source dischargers do not unfairly lead to a disproportionate increase in requirements on permitted dischargers, due to lack of EPA and state authorities to control nonpoint source pollution.
EPA published the ANPRM on July 7, 1998 (Regulatory Alert RA 98-15) and requested public comment on possible regulation and policy changes to strengthen and modernize the water quality standards regulation, including facilitating a watershed approach. Comments were solicited on five core areas, including: beneficial uses, criteria, anti-degradation, mixing zones, and independent application policies.
In the comments, AMSA affirms that many problems associated with attainment of water quality standards, as well as permitting issues, are associated with inappropriate use designations. AMSA urges that States have the latitude to refine use categories to differentiate between diverse uses, such as swimming vs. wading, which could be protected by very different criteria. AMSA goes further to recommend that States be mandated to refine uses where appropriate, and to perform use attainability analyses for those waters that have been inappropriately designated. AMSA also calls on EPA to establish a stakeholder discussion process as an appropriate way to resolve difficult issues within major topic areas, especially beneficial uses. Copies of AMSA comments can be obtained on AMSA's website or by contacting the National Office.
AMSA/SETAC to Hold WET Training Course in March 1999
AMSA and the Society of Environmental Toxicologists and Chemists (SETAC) will co-host a two-day training course designed to assist publicly owned treatment works (POTWs) with implementation of EPA's whole effluent toxicity (WET) program. A WET Tale… Toxicity of Complex Effluents will take place on March 25-26, 1999 and cover standards, regulations, policy, guidance and technical aspects of the WET program.
The training course, which will be held in Arlington, Virginia, will incorporate rationale and information on WET test requirements as contained in EPA materials such as the Technical Support Document for Water Quality-Based Toxics Control, toxicity reduction evaluation/toxicity identification evaluation (TRE/TIE) manuals, and acute and short-term chronic toxicity testing manuals. Instructors from EPA, states, and municipalities will provide balanced information on the WET program and cover such topics as WET implementation based on statutory, regulatory and policy publications; test methods; quality assurance; statistical evaluation techniques; NPDES permit development; compliance and enforcement; and TRE/TIE procedures and TIE case studies.
Flyers, including a registration form will be forwarded to the membership and other interested parties next week. Additional training course information and an on-line registration form will also be available on AMSA's Clean Water on the Web. Persons planning to attend the training course are urged to register early as space is limited.
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