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August 18, 2000
AMSA Members Meet with EPA HQ on TMDL Permitting Guidance
As the U.S. Environmental Protection Agency (EPA) develops national total maximum daily loads (TMDLs) permitting guidance, AMSA is weighing in early with the Agency to ensure it does not take an unreasonable approach. The finalization last month of EPA's TMDL rule left many TMDL/permitting coordination issues to be resolved with national clarifying guidance for states and other Clean Water Act permitting authorities. AMSA members in EPA Region IX met this week in California with EPA headquarters officials to express major concerns with Region IX's current interim permitting approach. Under its interim guidance, Region IX assigns stringent interim limits prior to a TMDL's completion — which may take up to 15 years. AMSA maintains that this approach is unsuitable for use on any basis, either nationally or regionally. Despite the problems with this approach, Region IX's approach is under consideration as EPA drafts the national permitting guidance.AMSA members pointed out that this approach puts publicly owned treatment works (POTWs) in an impossible situation. In some cases, POTWs may be unable to secure offsets from sources of impairment and could be required to make huge capital investments in treatments that would result in no water quality improvement. EPA is currently outlining a number of options for the national permitting guidance for TMDLs, which will be issued for comment in the coming months. AMSA will continue to meet with EPA throughout the development of this guidance to ensure a realistic approach. AMSA will review a draft of the guidance and keep members apprised of developments as they occur.
AMSA Helps Gain BMP Approach for TEC Effluent Guidelines
AMSA has helped gain a voluntary best management practice (BMP) pretreatment option for transportation equipment cleaning (TEC) facilities that discharge to POTWs under EPA's latest effluent Guidelines, issued this week. Based on AMSA's June comments that supported the BMPs concept, EPA adopted an approach similar that in the industrial laundries effluent guidelines. TEC facilities may opt for the “pollutant management plan” in lieu of numeric pretreatment standards in the truck chemical/petroleum and rail chemical/petroleum categories. The preamble also clarifies that POTWs are not captured under this rule. The rule can be accessed on line at www.epa.gov/fedrgstr/EPA-WATER/2000/August/Day-14.Plan Now to Attend Upcoming Pretreatment, Law Conferences ...
It's not too early to make arrangements for two upcoming AMSA conferences. The AMSA/Association of Metropolitan Water Agencies 2000 Legal Seminar — Developments in Water & Wastewater Law — is scheduled for November 1-3, 2000 in Phoenix, Ariz. Special Clean Water Act and Safe Drinking Water Act primers will be offered on Nov. 1, and the seminar will take place on Nov. 2-3. Make your hotel reservations today to ensure the special conference rate of $159 single/double. Call the Sheraton Crescent Hotel at 602/943-8200 by October 11, 2000.The AMSA/EPA Pretreatment Coordinators Workshop will take place November 15-17, 2000 at the DoubleTree Hotel at Reid Park in Tucson, Ariz. Call the DoubleTree Hotel at 520/881-4200 by October 25, 2000 to reserve your hotel room at the special conference rate of $99/night for this one-of-a-kind workshop.