Member Pipeline - Fax Alerts - March 25, 2005
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March 25, 2005
AMSA Reviews Draft EPA
‘Fact Sheet’ on SSOs, Nears Completion of Model Rule
EPA is seeking comments from states on its March 7, 2005, draft 'fact sheet' on sanitary sewer overflows (SSOs) (http://www.amsa-cleanwater.org/private/legreg/outreach/2005-03-07draftSSOfactsheet.pdf), which could potentially be combined with the Agency’s proposed blending guidance upon finalization. The draft 'fact sheet', which reads like Agency policy, asserts that many of the requirements EPA intended to propose in its January 2001 draft SSO rule are already required in the standard conditions of National Pollutant Discharge Elimination System (NPDES) permits for wastewater treatment facilities. These requirements include: immediate reporting (as soon as practicable, but within 24 hours of an SSO); written reports within five days of an SSO; third party notice; recordkeeping; and capacity, management operation and maintenance (CMOM) programs. Also, EPA is asserting that municipal satellite collection systems that overflow, or have the potential to overflow, into the waters of the U.S. must have a NPDES permit. AMSA will discuss this draft ‘fact sheet’ during relevant committee meetings at the Association’s 35th Anniversary Annual Meeting, May 1-2, in Washington, DC (see below for more information). Also, through its Targeted Action Fund, AMSA is nearing completion of its model SSO rule project and will set up a meeting with EPA to discuss the Agency’s new 'fact sheet' and the Association’s model rule. AMSA will alert the membership as additional details become available.AMSA Provides EPA’s Office of
General Counsel with Municipal Viewpoint on Blending
AMSA met this week with EPA’s General Counsel, Ann Klee, to discuss the legal merits of blending. Karen Pallansch, Director of Environmental Services, Alexandria Sanitation Authority, Va., and Chair of AMSA’s Pathogens Workgroup, and Lisa Hollander, Chair of AMSA’s Legal Affairs Committee and Assistant General Counsel for the Northeast Ohio Regional Sewer District, Cleveland, Ohio, provided the Association’s views on the blending issue. AMSA's presentation focused on why clean water agencies need a final blending policy and outlined the Association’s support for elements of the November 2003 proposed policy. AMSA’s detailed presentation is posted on its website (http://www.amsa-cleanwater.org/private/reg_outreach.cfm) and the Association will continue its advocacy efforts to ensure that EPA finalizes its proposed blending policy.EPA Expects to Finalize Streamlining Rule by June 2005
In response to its January 14, 2005 letter to EPA regarding the Agency’s Pretreatment Streamlining Rule (http://www.amsa-cleanwater.org/advocacy/co/2005-01-14Grumblesltr.pdf), AMSA received a letter from EPA’s Assistant Administrator for Water, Benjamin Grumbles, that stated the Agency expects to finalize the rule by June 2005 (http://www.amsa-cleanwater.org/advocacy/co/2005-03-15Grumbles.pdf). The Agency continues to consider whether two key Association issues – converting concentration-based limits to mass-based limits and revised definitions of nonsignificant or de minimis categorical industrial users – will be incorporated into the rule. AMSA has worked consistently with EPA over the years to ensure the wastewater community’s position is included in this critical document and will continue to advocate for the inclusion of these two critical components in the June 2005 rule.
- Make your plans now to attend the Association’s 35th Anniversary Annual Meeting, as well as the AMSA/WEF National Clean Water Policy Forum, May 1-4, 2005, in Washington, DC. The April 8 deadline to reserve your hotel room at the special rate of $219 single double is rapidly approaching, so contact the Marriott at Metro Center at 202/737-2200 today. An up-to-date agenda and online conference registration are now available at AMSA’s Conferences & Meeting webpage (http://www.amsa-cleanwater.org/meetings/05nepf/).