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Friday, May 9, 1997
AMSA held a very productive and successful National Environmental Policy Forum and Annual Meeting this past week that included several committee meetings, and sessions to discuss regulatory, legislative, and management issues. In addition, several special meetings were conducted with EPA to address issues described below:
AMSA-EPA Address Draft WET Implementation Strategy Issues
Representatives of AMSA's Water Quality Committee leadership and National Office met with EPA officials to discuss Association concerns with the agency's draft whole effluent toxicity (WET) implementation strategy. The meeting was held in response to AMSA's April 23 letter and comments which expressed strong disappointment with the draft's failure to adhere to the conclusions of the WET Pellston Conference and related follow-up activities. Several key items on WET testing that EPA agreed to collaborate with AMSA on include: formation of a small working group of various stakeholders for developing a stepwise or tiered approach to WET permitting; involvement of AMSA in the peer review of EPA's work on WET data interpretation and statistics; opening of EPA WET training to a wider audience including AMSA members; invitation to AMSA members to submit manuscripts for a SETAC session in the fall in San Francisco on WET testing; and collaborate with AMSA on policy decisions relating to the determination of "reasonable potential" for WET limits and the use of WET limits for combined sewer overflows and stormwater discharges. EPA committed to follow through on these issues and will share its plans for WET implementation before the AMSA summer conference in July.
AMSA-EPA Meet to Prioritize ANPRM Issues
AMSA's Water Quality Committee leadership and National Office also met with EPA officials to identify issues of primary concern to the Association relating to the development of the upcoming release of a streamlined advanced notice of proposed rulemaking (ANPRM) for revising the water quality standards program. EPA is in the process of revising the draft ANPRM to respond to public comments and to narrow the scope of issues. While AMSA continues to support a comprehensive review of the regulation, the two highest priorities identified were issues relating to designated uses and water quality criteria, followed in priority by antidegradation, and a call for EPA to clarify existing regulation and policy. Under the general category of uses, a recommendation was made to consolidate issues under the headings of specificity of use designations, minimum elements of a use attainability analysis, and definition of existing uses. AMSA's Water Quality Committee will be requested over the next few weeks to review the outline of issues and identify those in most need of revision. EPA plans to complete its stakeholder dialogue with industry, states, and public interest groups over the next six weeks to find common areas of agreement as high priority for improving national water quality and the standards program. A Federal Register notice of the ANPRM is expected during Summer 1997 and will be distributed to the membership at that time.
AMSA-WEF-EPA-NRC Meet on POTW Radioactivity Survey
A joint stakeholder meeting involving AMSA, WEF, EPA, and the Nuclear Regulatory Commission (NRC) was held this week to review NRC plans to conduct a survey of some 300-400 POTWs for analysis of the presence of radionucleides in biosolids samples and discuss educational tools to communicate radioactivity issues with wastewater agencies and general public. While the survey is anticipated to be voluntary in nature, several participants had pressed NRC to fix its existing regulation under 40 CFR 20 and release its draft guidance document on discharges of radionucleides to wastewater systems for review by the POTW community. A Federal Register notice is expected later this Summer announcing NRC plans to conduct a survey later in 1997. Both AMSA and WEF plan to submit a joint letter to NRC regarding the conduct of the survey and the need to establish a peer review group to oversee and monitor the results. The group plans to reconvene in Philadelphia in July to discuss next steps.