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August 26, 2005 NACWA Fax Alert

Member Pipeline - Fax Alerts - August 26, 2005

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August 26, 2005

NACWA Participates
in EPA-Sponsored ‘Pharmaceuticals in the Environment’ Meeting

EPA held a meeting on ‘Pharmaceuticals in the Environment’ this week drawing more than 150 people, including a dozen representatives from NACWA member agencies. Much of the discussions were highly technical and involved findings from research funded by EPA through its Science to Achieve Results (STAR) grants program. Generally, research shows the presence of pharmaceuticals and personal care products (PPCPs) in influent, effluent, groundwater, and surface waters. So far, no link to human health has been established, but studies have revealed potential impacts to aquatic life, such as the feminization of fish. The discussions also addressed the degree to which the presence of PPCPs in water is actually a problem; possible solutions; and regulatory barriers to better management of PPCPs. The meeting generated an intense amount of interest among representatives from NACWA member agencies. These agencies have agreed to provide the Association with their impressions of the meeting for use in NACWA’s August Regulatory Update. Presentations from the meeting will be available in the coming weeks on EPA’s website (http://www.epa.gov/ncer). This issue – in the broader context of emerging pollutants – has become a key focus area for ongoing discussions in both NACWA’s Water Quality and Pretreatment & Hazardous Wastes Committees.

NACWA Voices
Clean Water Community Perspective in Key Meetings with EPA

NACWA met twice with key EPA officials this week to discuss sanitary sewer overflow (SSO) issues and a new study on the fate of pollutants in wastewater treatment plants. The first meeting, with officials from EPA’s Office of Wastewater Management and NACWA Committee and issue leaders, focused on the Agency’s draft ‘fact sheet’ on SSOs. NACWA noted its support for EPA’s efforts to advance the capacity, management, operation and maintenance (CMOM) concept and to address the permitting of satellite collection systems. The Association, however, expressed concern that the fact sheet and accompanying model permit language are based on a zero-overflow standard and require the development of CMOM programs, with no protection or defense for municipalities in the event of an unavoidable overflow. Additionally, NACWA believes that much of what EPA is trying to accomplish in its fact sheet should require a formal rulemaking process. In the absence of a formal rulemaking, NACWA will urge the Agency to modify the fact sheet to include a defense for unavoidable overflows, and make other changes the Association feels are necessary, within the next two weeks.

NACWA’s Pretreatment & Hazardous Waste Committee leadership also met with Office of Science and Technology officials regarding a new study to determine if an update to EPA’s 1982 study, Fate of Priority Pollutants in Publicly Owned Treatment Works (or “50 POTW Study”) is needed. NACWA has advocated for some time now that such an update is critical both for the effluent guidelines program and for the development of local limits. EPA has initiated a small-scale study to conduct sampling at up to nine clean water agencies nationwide to determine if a larger update is necessary and what the scope of that study should be. The study will examine both influent and effluent for 674 analytes, including 120 emerging compounds including some pharmaceuticals. During the meeting, NACWA expressed concern that EPA’s limited database of results from only nine facilities may be too small to draw meaningful conclusions and has committed to partnering with the Agency to explore ways to increase the amount of data with the hope of ultimately examining at least 50 POTWs.

NACWA, Municipal Coalition Active on Stormwater Issues
In the appeal of the District of Columbia’s (District’s) municipal separate storm sewer system (MS4) permit, the Association submitted comments on August 18 to EPA Region 3 on proposed permit modifications. In the comments, NACWA, and its coalition partners, note that proposed changes to the District's permit seriously undermine the Clean Water Act’s (CWA) standard for MS4 discharges – calling for cities to remove stormwater pollutants to the maximum extent practicable (MEP) using best management practices. NACWA will keep the membership apprised of developments in this case and other related stormwater matters.