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December 5, 1997
EPA To Release Draft Mercury Strategy In Mid-DecemberAMSA has learned this week that EPA will outline its key action items to reduce public exposure to mercury in a draft plan being released in mid-December. The plan will highlight actions to reduce mercury discharges from all media, and will accompany the release of EPA's Mercury Study Report to Congress. The mercury reduction plan will also address one aspect of the Vice President's Oct. 18 Clean Water Initiatives calling on EPA to "reduce the need for fish consumption advisories." EPA has cited mercury as one of the leading causes of fish advisories.
A key component of the plan is the accelerated development of a revised national water quality criterion for mercury that incorporates new risk assessment data, and uses a revised approach to determine mercury criterion based on human health. This revised approach uses a bioaccumulation factor (BAF), which was used in the development of mercury criterion in the Great Lakes basin and incorporates assumptions on biomagnification of mercury in the food chain. The BAF approach, along with the revised risk assessment data, is expected to reduce the national mercury criterion by a factor of 100. (The Great Lakes human health criterion for mercury is 1.8 ng/l.) In addition to a new criterion for mercury, EPA plans to revise its required analytical method "to be more sensitive (below the new criterion level) and less subject to false positives through contamination." The revised method is expected to be finalized in late 1998.
Though the plan acknowledges the relatively small mercury contribution made by direct water discharges when compared to input from air deposition, it does stress the effect that more stringent water quality criterion will have on discharge permits for municipalities. The plan indicates that when discharges are contributing to exceedences of water quality standards, corrective actions taken will most likely be pollution prevention to find and control sources of mercury into the wastewater, rather than end-of-pipe treatment. The plan does not discuss what actions will be taken when source control efforts fail to bring required reductions in mercury discharges. EPA adds that it will "provide information to sewage treatment works nationwide on voluntary initiatives to reduce mercury releases, development of required pollutant minimization programs, State and/or Federal compliance assistance efforts, and development of Supplemental Environmental Projects in enforcement actions."
AMSA members will receive a copy of the plan via a Regulatory Alert when it is issued. A review of the plan and its implications will be led by AMSA's Water Quality Committee.
AMSA Comments On EPA's Draft MACT Standards For POTWs
On Dec. 3, AMSA submitted comments on the newly released draft Maximum Achievable Control Technology (MACT) Standards for POTWs. AMSA is primarily concerned with EPA's proposal to determine whether POTWs are major sources of hazardous air emissions (HAPs) using the highly conservative Water8 methodology. In AMSA's comments directed to Bruce Jordan, director of the Emissions Standards Division at EPA's Office of Air Quality Planning & Standards, are recommended changes to the draft's language that would enable POTWs to use more representative and realistic emission estimation methods, including direct measurement of the air emissions, and peer reviewed emission factors and fate transport models. To complete AMSA's review of the POTW MACT Standard, the Association also requested other documentation from EPA, such as the preamble and regulatory impact assessment. (See related article in the upcoming December/January issue of the Clean Water News.)
AMSA to Meet with NRC, EPA, and WEF on Sludge Survey
There will be a meeting on Dec. 8 between AMSA, WEF, the Nuclear Regulatory Commission (NRC), and EPA focusing on a planned survey of POTWs for radioactive material in sewage sludge. On Wednesday, Dec. 3, a notice on the upcoming survey appeared in the Federal Register. As reported in the October/November Regulatory Update, AMSA and WEF have been actively engaging the NRC and EPA regarding the proposed survey. It is hoped that next Monday's meeting will lay the groundwork for collaboration with NRC and EPA on the planned national survey. (See related article in upcoming December/January issue of the Clean Water News.)