Member Pipeline - Member Services & Information - Update (MU04-13)
| To: | Members & Affiliates Special Committee Members |
| From: | National Office |
| Date: | August 12, 2004 |
| Subject: | Special Committee reports |
| Reference: | MU 04-13 |
Printer friendly versionAMSA’s special committees gathered at the Association’s July 2004 Summer Conference, Leading the Way… POTWs Take Environmental Protection Beyond the Pipe, in Denver, Colorado. While the committee meeting summaries have generally appeared in AMSA’s monthly Clean Water News, they will now appear via Member Update (MU). In some instances, there have been significant developments since the committees last met in May 2004. This MU provides an up-to-date description of the current challenges faced by, and initiatives led by, AMSA’s special committees. To become a member a member of an AMSA committee, e-mail info@amsa-cleanwater.org or call 202-833-2672.
Air Quality
Co-Chair, Ed Torres, Orange County Sanitation District, Calif.
Co-Chair, Greg Adams, Los Angeles County Sanitation Districts, Calif.
The Air Quality Committee discussed several U.S. Environmental Protection Agency (EPA) initiatives that will impact publicly owned treatment works (POTWs), including EPA’s final National Emission Standards for Hazardous Air Pollutants (NESHAP) for reciprocating internal combustion engines (http://www.epa.gov/fedrgstr/EPA-AIR/2004/June/Day-15/a4816.pdf). AMSA commented on the proposed rule in February 2003 (http://www.amsa-cleanwater.org/private/legreg/outreach/02-18-03NESHAP.pdf). The final standards, which made changes to the testing and monitoring provisions, will impact POTW operations by regulating the air emissions from combustion engines larger than 500 horsepower. For the most part, AMSA’s comments were reflected in the final rule, including a provision to regulate such engines from the date of installation rather than the date of manufacture, a favorably revised definition of rich burn engines, and flexibility to measure percent of pollutant reduction or final pollutant concentrations. Also discussed were EPA actions to change the Equipment Replacement Rule (http://www.epa.gov/fedrgstr/EPA-AIR/2004/July/Day-01/a14992.pdf), which AMSA supports, and the creation of a Clean Air Act Title V Federal Advisory Committee Act group, which AMSA will monitor.
The committee also discussed AMSA’s Targeted Action Fund (TAF) project to review EPA’s WATER9 Model. The WATER9 Model is designed to estimate air emissions from wastewater treatment plants and collection systems. The committee was provided with a presentation on the outcome of Task 1 of the project, which was an in-depth literature review of published data on emissions from wastewater collection, storage, treatment, and disposal facilities, and a comparison of results from WATER9 and two alternative industry models. At AMSA’s May National Environmental Policy Forum, the committee voted to move forward with Task 2 of the project, which will be to evaluate the algorithms and codes in WATER9 that are resulting in varying predictions of emissions, and to develop a white paper for AMSA members to use as an advocacy piece when dealing with permitting authorities on air emission modeling issues.
Biosolids Management
Co-Chair, Robert Dominak, Northeast Ohio Regional Sewer District,
Ohio
Co Chair, Dave Taylor, Madison Metropolitan Sewerage District, Wis.
With the Interagency Steering Committee on Radiation Standards’ (ISCORS) work on radioactivity in biosolids nearly complete, key members of AMSA’s Biosolids Management Committee reported on their ongoing discussions with ISCORS and their June meeting to discuss revisions to the ISCORS POTW recommendations document. The committee learned that many of AMSA’s comments on the draft were being addressed and were assured that the final document would be more representative of real-world biosolids management scenarios.
The Committee also discussed its TAF project to develop a user’s guide to the lengthy ISCORS recommendations document and decided to wait until the final recommendations document was released before initiating development of the user’s guide. In its comments on the draft, AMSA had expressed concern that the recommendations document, which includes a guideline level for assessing radioactivity in biosolids, may be misused in a regulatory context. The Committee learned that the Association’s fears would be realized when the State of California’s Water Resources Control Board incorporated the draft recommendations document by reference into its regulations later that same week. Steve Frank, Public Information Officer with the Denver Metropolitan Wastewater Reclamation District provided the committee with an overview of Denver Metro’s biosolids management activities, including its own 52,000 acre farm used for land application. Work continues on the Continuing Emissions Monitoring System/Total Hydrocarbon (CEMS/THC) biosolids incineration survey and additional efforts to improve the overall number of survey responses.
King County, Washington is expected to graduate from the National Biosolids Partnership’s (NBP) environmental management system program later this summer. Four additional agencies are expected to apply for the third party audit by the end of the year. Other NBP projects include a redesign of the website, a new metrics tool to measure the benefits of participation in the NBP EMS program, and on-going workshops for new NBP wastewater treatment agencies. Finally, the Committee learned that the U.S. Department of Labor had dismissed the case of former EPA scientist David Lewis, a vocal advocate against the land application of biosolids, who claimed that EPA had violated federal whistleblower laws and that he had been wrongfully terminated.
Pretreatment & Hazardous Waste
Chair, Guy Aydlett, Hampton Roads Sanitation District, Va.
AMSA's Pretreatment and Hazardous Waste Committee discussed several Association initiatives that are receiving significant Agency attention. Of greatest importance to the committee was the data AMSA submitted to EPA, the Office of Management and Budget, and the Small Business Administration in support of key provisions of EPA’s Pretreatment Streamlining Rule. The data, which was based on nearly 100 agency responses and sent to EPA in early June, demonstrated the hundreds of millions of dollars of savings to clean water agencies annually that would result from various AMSA-recommended changes to the current regulatory regimen. These changes would have no negative environmental impact and would free up much-needed resources for other priority water quality projects. AMSA is continuing to urge EPA to finalize the rule this year.
Other issues considered by the committee included AMSA’s work in the security arena to develop a decontamination wastewater planning tool, which should be completed and made available at the 2005 Winter Conference. The tool will provide guidance to POTWs on how to deal with decontamination wastewater resulting from a biological or chemical attack or accident. The committee also expressed the importance of the upcoming National Pretreatment Coordinators Workshop, October 27-29, in Norfolk, Va., which will delve into far greater detail on some of the above and many other pivotal pretreatment issues (see http://www.amsa-cleanwater.org/meetings/#future for hotel and upcoming agenda information).
Security & Emergency Preparedness Committee
Chair, TBD
The Security & Emergency Preparedness Committee (formerly the Wastewater Infrastructure Security Task Force) held its first meeting at the Summer Conference in Denver. The Committee focused its attention on a wide array of initiatives. Committee members were brought up-to-date with regard to activities associated with AMSA’s cooperative agreement with the U.S. EPA. These include the recently released upgrade to the suite of Vulnerability Self Assessment Tools (VSAT™) – VSAT 3.1; the June debut of the Wastewater Sector Security Link, an electronic newsletter covering a wide array of wastewater sector security initiatives; and the Decontamination Wastewater Acceptance & Treatment – A Wastewater Utility Planning Tool project. AMSA will also begin work on a project to develop a decision tree document for evaluating chlorine gas alternatives.
Committee members learned that on July 8, 2004 the WaterISAC Board of Managers voted to lower subscription fees for utilities. It is hoped that the new fees will make subscriptions to the WaterISAC both accessible and advisable for all water and wastewater utilities. The new WaterISAC subscription fees structure makes no distinction between whether utilities are water or wastewater only – or provide both services – and will go into effect for the next billing cycle for current subscribers to the WaterISAC (Fall 2004) and upon joining for new subscribers.
It was reported that representatives of AMSA Member Agencies, Affiliates and staff are continuing their participation in a study being conducted by the Government Accountability Office (GAO) addressing the allocation of federal funds for wastewater security. The study is being conducted at the request of the Senate Environment and Public Works Committee and will continue throughout the summer months, with a final report anticipated prior to the end of the federal fiscal year.
It was reported to the Committee that H. J. “Bud” Schardein, Jr., Executive Director of the Louisville & Jefferson County Metropolitan Sewer District, will serve as AMSA representative on the National Drinking Water Advisory Council’s Water Security Working Group (WSWG). The WSWG, which was formed for the purpose of addressing best drinking water and wastewater security practices and policies, held its first meeting in June.
Utility Management
Co-Chair, Brian Crewdson, Anchorage Water & Wastewater Authority, Alaska
Co-Chair: Jon W. Schellpfeffer, Madison Metropolitan Sewerage District, Madison
, Wis.
The Utility Management Committee enjoyed lively discussions on several ongoing committee initiatives, including the schedule and timeline for completion of the 2005 Financial Survey. Committee leaders asked for final comments on the draft survey form and urged participants to capitalize on the ability to complete the 2005 Survey online through the CleanWater Central website. The committee received both an update on the increasing use of CleanWater Central (http://www.cleanwatercentral.org) and a reminder that public utilities must log on and update their agencies’ baseline data before September 30, 2004 to continue to receive a free subscription to this service. The committee discussed the recent release of the Changing Workforce… Crisis and Opportunity publication and what next steps may be needed to assist utility leaders with many of the workforce issues presented in this first publication. Attendees agreed that AMSA should explore opportunities for developing a how-to, strategic manual on succession planning as a partner resource to The Changing Workforce handbook.
The Asset Management Workgroup, reported to the committee that AMSA should consider several new asset management projects. These include a potential brochure-style document, based upon AMSA’s 2002 Managing Public Infrastructure Assets publication, to educate local elected and appointed officials on the importance of utilities conducting comprehensive asset management programs in an easy-to-read format. Finally, the Committee was made aware of the upcoming 2005 Water and Wastewater Leadership Center, which will again be held at the University of North Carolina – Chapel Hill, February 13 – 25. It was noted that the application deadline for this invaluable program is December 3, 2004.
Water Quality
Chair, Norm LeBlanc, Hampton Roads Sanitation District, Va.
Vice Chair, Patti Grace-Jarrett, Louisville & Jefferson County Metropolitan
Sewer District, Ky.
Nutrient issues once again topped the Water Quality Committee’s agenda. Members of the Committee provided updates on the nutrient farming project in Illinois, including recent efforts to secure additional federal funds for the pilot projects and the recent formation of an Ohio River Basin Steering Committee tasked with exploring ways to decrease the amount of nutrients entering the Gulf of Mexico. The principal investigator for a nutrient project in Texas, which AMSA is supporting through the TAF, presented the findings of the project’s one-year, interim report (copies are available by calling AMSA’s Chris Hornback at 202/833-2672).
The committee also received a draft copy of the report from AMSA’s review of EPA’s 2001 cadmium criteria, and AMSA’s contractor was on hand to present the findings. The committee agreed to defer action on whether AMSA should hire a consultant to assist in its review of an EPA staff paper on the Agency’s risk assessment methodologies until it had an opportunity to review the comments of industry stakeholders. The committee also heard a report on AMSA’s reply brief in the ongoing lawsuit over EPA’s whole effluent toxicity methods. Members of the committee were encouraged to contact AMSA staff if they were interested in joining a new working group to include key state regulators with the purpose of expanding interest in, and acceptance of, watershed-based permitting.
The Committee’s packed agenda wrapped up with discussions of EPA’s recent announcement that it was planning to revise the ammonia criteria based on new freshwater mussel data — a move that would result in criteria more stringent than those published in 1999 — and EPA’s proposal to establish bacteria criteria (using E. coli and enterococci as the indicator organisms) for any coastal state not in compliance with the BEACH Act. AMSA’s comments on the bacteria criteria are available on the Association’s website (http://www.amsa-cleanwater.org/private/reg_outreach.cfm). The Association received a 30-day extension for filing comments on the ammonia criteria, and is currently collecting comments from member agencies. AMSA plans to critically review the new scientific studies and explore implementation alternatives prior to submitting comments on the ammonia criteria to EPA on September 8, 2004.
Wet Weather
Chair, Karen Pallansch, Alexandria Sanitation Authority, Va.
Vice Chair, Marty Umberg, Metropolitan Sewer District of Greater Cincinnati,
Ohio
EPA Regional wet weather activity on various, critical wet weather-related topics topped the agenda for the Wet Weather Issues Committee. Due largely to the upcoming presidential elections, EPA’s draft blending policy, its CSO-SSO Report to Congress on the impacts of combined and sanitary sewer overflows (CSOs & SSOs), and the Agency’s memo clarifying the “shall conform to” language in the CSO Control Policy have shown few signs of moving forward. The SSO rule package also awaits action. As a result, the committee’s focus shifted to ongoing activity at the state and regional level. EPA Region IV’s capacity, management, operations, and maintenance (CMOM) program appears to be leading the way for other parts of the country. Region V has indicated that they plan to emulate the Region IV program in a pilot project to begin later this year in several communities in the Cleveland area.
The committee had an extended discussion on a brief AMSA survey on affordability issues and discussed whether EPA’s existing guidance documents are of help when communities conduct their affordability analyses. The information will be used by AMSA at an August 18 Environmental Financial Advisory Board workshop in San Francisco. The committee also agreed to seek TAF funding to develop a white paper to explore the realities of conducting an affordability analysis outside the confines of EPA’s guidance and provide a series of case study examples of where those analyses had been done correctly. AMSA agreed to coordinate this effort with other organizations working on the subject, including the Water Environment Federation.