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October 22, 2003 AMSA Fax Alert

Member Pipeline - Fax Alerts SpecialEdition - November 4, 2003

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November 4, 2003

EPA Releases Proposed Blending Guidance

The U.S. Environmental Protection Agency (EPA) released its proposed guidance on blending Monday morning reaffirming a long-standing practice used by publicly owned treatment works (POTWs) to address peak wet weather flows. The document provides important guidance to EPA Regions and permitting authorities that blending is an acceptable practice that ensures peak wet weather flows receive a minimum level of treatment that, without blending, would not be possible. The guidance is available at http://www.epa.gov/npdes/pubs/blending_policy.pdf.

EPA Proposes Six Key Blending “Principles” to Consider in Permits
The substantive portion of EPA’s proposal can be found from pages 30-34 of the guidance where six main principles are outlined. EPA states that blending would not constitute a prohibited bypass and could be authorized in a National Pollutant Discharge Elimination System (NPDES) permit if “all of the following principles were followed:

  1. “The final discharge meets effluent limitations based on the secondary treatment regulation (40 CFR Part 133), including applicable 30-day average percent removal requirements, or any more stringent limitations necessary to attain water quality standards;”
  2. “The NPDES permit application for the POTW provides notice of, and specifically recognizes, the treatment scenario that would be used for peak flow management;”
  3. “The treatment scenario that would be used for peak flow management should provide, prior to blending, at least the equivalent of primary clarification for the portion of flow routed around biological or other advanced treatment units;”
  4. “The peak flow treatment scenario chosen by the permittee for use when flows exceed the capacity of storage/equalization units, biological treatment units or advanced treatment units should be operated as it is designed to be operated and in accordance with the treatment scenario reflected in the permit record and conditions set forth in the permit;”
  5. “The permit must require monitoring, including type, interval and frequency sufficient to yield data which are representative of the final blended discharge to ensure compliance with applicable water quality-based effluent limitations;” and
  6. “The permit must require, at minimum, that the permittee properly operate and maintain all parts of the collection system over which the permittee has operational control in a manner consistent with 40 CFR 122.41(e).”

These six considerations, discussed in more detail in the guidance, constitute the most critical part of the initiative.

AMSA and EPA Release Explanatory Press Releases on Guidance
AMSA has responded to the proposal with its own press release which voices the POTW position reinforcing its support of blending. The AMSA press release follows with this document. EPA has sent out a press release noting that their policy will help to clarify provisions in the Clean Water Act (CWA) applicable to blending and emphasizes that POTWs must maintain compliance with the CWA to ensure blending is addressed in the permitting process. Tracy Mehan, Assistant Administrator for Water is quoted as saying, “This policy will provide a consistent set of principles to guide local sewage treatment facilities in managing wet-weather events. We are working with these facilities to prevent backups of sewage in homes and the environment while requiring all discharges to meet Clean Water Act permit limits.”

AMSA Provides POTW Voice in Media on Blending
AMSA member, Mike Marcotte, Chief Engineer at the District of Columbia Water and Sewer Authority, was interviewed yesterday by CNN Headline News to give the wastewater utility perspective on the practice of blending. In addition, the national press has picked up the story which has been printed in the Los Angeles Times, USA Today, the Associated Press, the Boston Globe and the Seattle Times, among other city newspapers and trade press publications. These articles, along with the Association’s press release will be made available on AMSA’s website at http://www.amsa-cleanwater.org/advocacy/releases.cfm. An upcoming Regulatory Alert will provide more detail and solicit member agency comments on the guidance. AMSA will continue to voice the wastewater industry’s position on blending during the 60-day comment period and will work with EPA on this issue in the coming months.