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December 4, 1998

EPA Issues Proposed POTW MACT Standard

EPA published the long-awaited proposed maximum achievable control technology (MACT) standard for POTWs in the Federal Register on December 1. In the notice, EPA is not proposing any standard for POTWs and wastewater collection systems at this time because sufficient information is not available to determine the amount of hazardous air pollutant (HAP) emissions from these systems or to evaluate the practicality of controlling such emissions. The standard would require control for HAP emissions from each new or reconstructed POTW which is a major source of HAPs. The standards would also require each existing and new POTW that treats specific industrial waste streams from an industrial user, for the purpose of allowing that industrial user to comply with another National Emission Standard for Hazardous Air Pollutants (NESHAP), to meet the treatment and control requirements of the relevant NESHAP. The National Office will distribute copies of the proposal via Regulatory Alert 98-23. Comments are due to EPA by January 15, 1999; member comments need to sent to AMSA by January 8.

AMSA Members Meet to Craft Position on EPA's Draft ANPRM

AMSA leaders met this week to refine the Association's position on the U.S. Environmental Protection Agency's (EPA) draft advanced notice of proposed rulemaking (ANPRM) on the nation's water quality standards regulation. Members of the Association's board of directors, Water Quality, Wet Weather, and Regulatory Policy committees attended the one and a half day meeting, Dec. 1-2, in San Francisco, Calif., to discuss the overall direction of EPA's water quality standards program, with an emphasis on program flexibility, criteria development, designated-use refinement, anti-degradation, and the relationship between the water quality standards, TMDL, wet weather programs, and Endangered Species Act implementation. AMSA plans to present its vision of the water quality standards program, as well as answering specific questions posed by EPA in the ANPRM in comments that will be forwarded to the Agency prior to the January 4, 1999 deadline.

EPA Releases Y2K Enforcement Policy

On November 30, 1998, EPA released their Y2K Enforcement Policy focusing on testing-related violations that are reported to EPA by February 1, 2000. Through this policy, EPA would like to encourage agencies to perform any necessary testing of computer systems and their related environmental components well in advance of the Year 2000. The policy states EPA's intent to "waive 100% of the civil penalties that might otherwise apply, and to recommend against criminal prosecution, for environmental violations caused during specific tests that are designed to identify and eliminate Y2K-related malfunctions." The Agency has developed a set of nine criteria which must be meet for EPA to waive civil penalties and recommend against criminal prosecution. These criteria focus on testing protocols, the violations caused by testing, the time, length and necessity of the test, the level of harm caused by violations, immediate correction and remediation, reporting violations, retesting and the agency's cooperation with EPA. The policy is being forwarded to the membership via AMSA Member Update MU 98-23.

  • Pretreatment Meeting Date Change: The dates for the 1999 AMSA-EPA Pretreatment Coordinators' Workshop have been moved to November 3-5, 1999. The workshop will be held at the Sheraton Park Central Hotel in Dallas, TX.

  • Awards Deadline Near: AMSA member agencies should note that the Dec. 18 deadline for submitting nominations for AMSA's 1999 National Environmental Achievement Awards program is fast approaching. Application materials were distributed to the membership in early October via Member Update 98-19.