Member Pipeline - Regulatory - Alert (RA 99-15)
To: Members & Affiliates From: National Office Date: August 5, 1999 Subject: EPA Pretreatment Program Streamlining Proposal Reference: RA 99-15 Action Please By: August 25, 1999
On July 22, 1999 U.S. Environmental Protection Agency released proposed regulatory and administrative changes to streamline the national industrial pretreatment program (40 CFR Part 403). The effort is designed to provide administrative changes to reduce the burden on entities regulated under the pretreatment program. In May 1997 EPA released similar draft revisions to the rule for external stakeholder input. The revisions were based on informal issue papers developed by EPA in May, 1996 and the results of the AMSA/Water Environment Federation Pretreatment Streamlining workshop held in August of 1996.
In many instances EPA has proposed changes that reflect AMSA's positions on pretreatment streamlining; however, the Association continues to have serious concerns with regard to modifications of significant noncompliance (SNC) criteria.
AMSA's Pretreatment and Hazardous Waste Committee leadership plans to develop a formal position paper on all of the proposed changes this month and encourages all members to review the proposal and provide any comments by August 25. The position paper will be distributed to the membership in September and AMSA members will be encouraged to attach the paper to their individual comments to EPA. It is imperative that EPA receive numerous comments from AMSA member agencies in support of all of the Association's recommendations on streamlining. In particular, the identified issues of concern relating to significant noncompliance (SNC) criteria are vital and need serious attention by each AMSA member agency.
An outline of the proposed changes is attached for your review, along with AMSA's 1997 comments on the initial draft proposal and the Federal Register notice itself. The comment period currently ends on September 20, 1999; however, AMSA is working to secure an extension to allow additional time for members to provide input to the Agency. If you have additonal comments specific to the rule, please forward to Mark Hoeke at mhoeke@amsa-cleanwater.org or fax, 202/833-4657 by August 25, 1999. If you have any questions, please call Mark Hoeke in AMSAs National Office, 202/833-9106 .
Attachments:
- Summary of EPA Draft Pretreatment Streatmlining Proposal
- AMSA's July 1997 Comments on EPA's draft Pretreatment Streamlining Proposal
- July 1999 Federal Register Notice of EPA's Pretreatment Program Streamlining Proposal (PDF)
- 1999 National Pretreatment Streamlining Proposal AMSA Comments on (PDF ~2,201 KB)
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