Clean Water Advocacy - Newsroom - AMSA in the News
EPA LIKELY TO MOVE FORWARD WITH PRETREATMENT STREAMLINING RULE
Date: December 29, 2003 -
EPA is preparing to issue a rule that would streamline pretreatment requirements
for wastewater facilities by removing administrative burdens, according to
agency and publicly owned treatment works (POTW) officials, who say the rule
would allow POTWs to administer pretreatment programs more efficiently.
An EPA source says the agency will, sometime in 2004, move forward with a
pretreatment streamlining rule that would reduce the requirements for POTWs to
determine if a system is in significant noncompliance (SNC) and allow for pH
discharges slightly more acidic than the standard of five if the discharges are
"minor excursions" that do not occur on a regular basis.
EPA issued a proposal to streamline the regulations in July 1999, but delayed
moving forward with the rule to focus on other rules, such as regulations
governing total maximum daily loads, animal feedlots and cooling water intakes
(Water Policy Report, Feb. 16, 2000, p22).
Following a meeting with EPA earlier this month, members of the Association of
Metropolitan Sewerage Agencies (AMSA) sent a letter to the agency Dec. 12,
asking EPA to move forward with the rule. In the letter AMSA also provided a
list of specific easements that should be included to enhance wastewater system
efficiency. The letter is available on InsideEPA.com.
An AMSA spokesman says the letter is intended to ensure EPA includes specific
language easing the administrative burden for pretreatment systems. For example,
AMSA asks EPA to change the way it determines whether a system is in SNC so that
systems are not held in SNC solely because their paperwork is up to 45 days
late.
AMSA also asks that SNC determinations be based on six-month periods and not
"rolling quarters," because the rolling quarters approach holds an industrial
user that is in SNC for the first quarter of the year and compliant in the
second quarter in SNC overall because EPA always considers the previous six
months of data.
AMSA further recommends that EPA develop new technical review criteria
(TRC) that are relevant to effluent guidelines and local limits, instead of
using the current TRC, which were taken from the National Pollutant Discharge
Elimination System program and assume that discharges are immediately entering
the environment, instead of passing through POTWs.
Finally, AMSA recommends EPA not require systems to sample for a pollutant if
the pollutant is not expected to be present in its waste stream in a quantity
greater than the background level present in the water supply.
The AMSA spokesman says the group is confident EPA will make the changes to the
pretreatment program and promulgate a rule in upcoming months.
"This is really a non-controversial issue for EPA, and there seems to be
consensus that they should move forward with a rule," the spokesman says.