Attachment E
Pretreatment & Hazardous Waste Committee
Guy Aydlett, Chair
Kevin Aiello, Vice Chair
Sam Hadeed, Lead Staff
Report to the Board of Directors
July 1998
The following report sets forth issues and activities anticipated to be addressed through the Pretreatment & Hazardous Waste Committee over the next year:
- Continue active technical and regulatory review of EPA guidance, proposed effluent guidelines, and policies relevant to the national industrial pretreatment program.
- Sponsor 9th Annual Pretreatment Coordinators Workshop in Kansas City, Missouri on October 27-30, 1998. This workshop will be jointly sponsored with U.S. EPA for the fifth time and will involve AMSA members, EPA Headquarters, Regions and State Authority officials.
- Review, comment, and provide appropriate regulatory language on EPA's Pretreatment Program Streamlining proposal to develop recommendations for improving program efficiency and compliance.
- Encourage AMSA agency participation in proposed EPA pretreatment program reinvention activities patterned after a modified version of Project XL. Pilot efforts will allow designated local programs to optimize resources by providing greater flexibility and local control in the administration of progressive programs at POTWs, while still providing for direct accountability to create through a regulatory change or other mechanism.
- Continue joint AMSA-Silver Council project on EPA-funded demonstration program using the photo processing industry as a model to evaluate the use of alternative compliance mechanisms such as a code of good management practices as a means of controlling wastewater discharges in streamlining local pretreatment limits.
- Continue participation on EPA FACA initiative to improve the accuracy of the Toxic Release Inventory (TRI) reporting by industry and how to address transfers and removal efficiencies of toxic chemicals to POTWs for further management.
- Participate in collaborative efforts with the Nuclear Regulatory Commission (NRC) and EPA to assess POTW data on radionuclide content in biosolids from releases of NRC licensees into sanitary sewer systems, review of NRC guidance document on radioactive materials at POTWs, and any other issues that may impact local pretreatment programs.
- Continue participation on EPA's Effluent Guidelines Task Force. Assist in data collection, technical review, and meet with affected industry groups, where necessary, for the purposes of prioritizing the development of effluent guidelines for industries identified under consent decree and assessing opportunities to pursue alternatives to effluent guidelines.
- Continue participation on EPA's Common Sense Initiative (CSI) Council and appropriate industry sector subcommittees to ensure that these groups address POTW issues.
- Participate in AMSA Mercury Strategy Workgroup activities through the Regulatory Policy Committee to develop recommendations that address EPA proposed mercury strategy and its potential impact on POTW operations.
- Develop joint guidance with the U.S. Department of Navy for consideration by EPA to regulate shipboard waste as domestic wastes to eliminate issuance of industrial permits in coastal communities.
- Assist in reviewing Clean Water Act, Resource Conservation & Recovery Act and Superfund reauthorizations and other legislative proposals affecting pretreatment and hazardous waste issues.