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Regulatory - Alert (RA 99-10)

Member Pipeline - Regulatory - Alert (RA 99-10)

To:

Members, Affiliates, Wet Weather Issues Committee & SSO Workgroup

From:

National Office

Date:

May 28, 1999

Subject:

NPDES Requirements For Sanitary Sewer Collection Systems

Reference:

RA 99-10

During AMSA's May 22-26 National Environmental Policy Forum in Washington, DC, EPA released four papers outlining draft regulations for municipal sanitary sewer collection systems. On May 22, AMSA's Wet Weather Issues Committee was briefed by EPA on the papers and draft regulations, and members were given the opportunity to provide feedback to EPA throughout the five-day meeting.

The U.S. Environmental Protection Agency (EPA) is developing a Federal Register notice to provide guidance, policies and propose regulations to clarify National Pollutant Discharge Elimination System (NPDES) requirements for municipal sanitary sewer collection systems and sanitary sewer overflows (SSOs). The Federal Register notice will have four major objectives:

  1. Standard Permit Conditions - Propose standard NPDES permit conditions to clarify requirements for municipal sanitary sewer collection systems. The standard permit conditions, which will be required in all NPDES permits for publicly-owned treatment works (POTWs) or sanitary sewer collection systems will address:
    1. Record keeping and reporting requirements for SSOs;
    2. Public notification requirements for SSOs;
    3. Capacity assurance, management, operation and maintenance requirements for municipal sanitary sewer collection systems; and,
    4. A prohibition on SSO discharges to waters of the United States (but describing circumstances where a discharge may be exempted from enforcement action or where an affirmative defense can be claimed for a discharge beyond the operator's control).

  2. Municipal Satellite Collection Systems - Propose regulations that clarify that satellite municipal sewer collection systems are to obtain NPDES permit coverage. Satellite municipal collection systems are collection systems that do not treat and discharge their wastewater. Rather, satellite municipal collection systems convey flows to a treatment facility where the NPDES permittee is a different municipal entity.

  3. Emergency Overflow Structures - Propose regulations that provide criteria for evaluating the location of constructed emergency overflow structures for municipal sanitary sewer collection systems; and,

  4. Additional Issues - Provide clarifying policy and/or guidance statements on additional issues, including: existing requirements for reporting SSOs; how secondary treatment regulations should be applied to permits for infrequent, noncontinuous discharges from peak excess flow treatment facilities serving sanitary sewer collection systems; and when non-municipal satellite collection systems that introduce sewage, industrial wastes or other pollutants into a POTW may be regulated under the NPDES permit program, pretreatment program, and/or local requirements.

EPA's Next Steps
An internal EPA/State SSO work group with representatives from Regional Offices and over 15 States has developed draft regulations for municipal sanitary sewer collection systems (see attachments). EPA has scheduled a public meeting with the SSO Federal Advisory Committee (FAC) for July 28 and 29 at the Madison Hotel in Washington, DC. AMSA has two designated representatives on the SSO FAC, and a total of six member agencies represented. The SSO FAC is comprised of representatives from environmental groups, health officials, public works agencies municipal officials, wastewater professionals, States, and EPA. EPA hopes to formally propose regulations by the end of 1999.

AMSA's Next Steps
AMSA plans to convene a meeting of its Wet Weather Issues Committee/SSO Workgroup at the end of June or early July 1999 to discuss concerns on EPA's draft proposals. In the meantime, conference calls with the SSO FAC have been scheduled to discuss some of the substantive issues with the draft rules. An additional meeting of the Wet Weather Issues Committee/SSO Workgroup will be held during AMSA's July conference, Unifying Urban Wet Weather Programs, July 20-23, in Philadelphia, PA. Details of these meetings will be forthcoming in a future AMSA FaxAlert. If you have any comments or questions, please contact Mark Hoeke, AMSA at 202/833-9106.

ATTACHMENT: