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May 15, 2001
Action Please By:
May 23, 2001AMSA Seeking Your Input on MP&M Proposal
AMSA is requesting member input for our comments due July 2, 2001 on EPA’s proposed Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the Metal Products & Machinery (MP&M) Point Source Category. 66 Fed. Reg. 424 (Jan. 3, 2001); deadline extension 66 Fed. Reg. 21,111 (April 27, 2001). The proposal would establish technology-based effluent limitations for MP&M direct discharges to receiving waters under NPDES permits, and pretreatment standards for the indirect discharge of pollutants by MP&M facilities through Publicly Owned Treatment Works (POTWs).In 1996, EPA selected 150 POTWs to receive a survey on the burden and impact of the MP&M rule on permitting authorities. EPA used survey responses when performing the economic analysis and pollutant reduction calculations that support the proposed rule. In the preamble to the proposed rule, EPA concludes that implementation of the proposed standards will result in reduced inhibition of wastewater treatment operations and improved sludge quality due to reduced MP&M facility discharges.
During AMSA’s review of the proposed MP&M rule, AMSA found that the Agency’s calculation of administrative burden resulting from rule implementation was vastly underestimated and that many of the critical factors important for implementation were not considered. AMSA is concerned that the data collected in the 1996 EPA survey and the corresponding data analysis did not accurately characterize actual conditions. Accordingly, AMSA is conducting our own survey of the same 150 POTWs to collect additional data and to formulate AMSA comments on the proposed rulemaking.
We would like to hear from all AMSA members, beyond the 150 POTWs targeted in the survey, to fully measure the impact this rule will have if implemented as proposed. If you are not among the 150 POTWs already receiving a survey, we would appreciate it if you would take the time to complete the survey to provide us with additional information for AMSA’s comments.
Please forward this survey to your Pretreatment Coordinators. If your agency intends to complete the survey, please call or email Chris Hornback at AMSA’s National Office, 202/833-9106 or chornback@amsa-cleanwater.org and provide the name of the individual who will complete the survey so we can provide assistance as necessary. We anticipate the survey will take approximately 16 hours to complete.
The surveys must be returned to AMSA’s contractor on this effort by Wednesday, May 23, 2001 to:
Gary Martin
URS Corporation
263 Seaboard Lane, Suite 200
Franklin, TN 37067
Phone 615-771-2480 Fax 615-771-2459The survey can be printed from the AMSA Member Pipeline at:
http://www.amsa-cleanwater.org/private/legreg/outreach/5-15-01survey.pdf.We appreciate your contribution under this relatively short time frame. Thank you for your efforts.