July 11, 1997
Brian J. Maas
Director
Water Enforcement Division (2243A)
Office of Regulatory Enforcement
Office of Enforcement & Compliance Assurance
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20044
and
James F. Pendergast
Acting Director
Permits Division (4203)
Office of Wastewater Management
401 M Street, SW
Washington, DC 20460
Dear Brian and Jim:
The Association of Metropolitan Sewerage Agencies (AMSA) appreciates the opportunity to review and comment on EPA's May 30, 1997 draft pretreatment streamlining proposal. AMSA has been a long-standing advocate of this streamlining effort and believes that such an initiative is warranted after nearly 25 years of experience with administration of the pretreatment program. Furthermore, AMSA believes that many of these proposed changes should allow POTW with greater flexibility to shift emphasis from tracking compliant industrial users to noncompliant industrial users.
A summary of AMSA's comments are enclosed for your review. In general, AMSA supports many of the proposed changes to the pretreatment program. While AMSA supports the two modifications proposed by EPA on significant noncompliance (SNC), the Association is very disappointed that the Agency did not propose modifications or seek comments on other SNC provisions. A significant amount of discussion and recommendations have been put forwarded in collaboration with other stakeholders that merit an opportunity for public review and comment. AMSA has provided comments on these specific areas and strongly urge the Agency to include these issues when the streamlining package is proposed later this year.
While specific language on SNC is not included in this transmittal, AMSA plans to craft such language in the next several weeks. We also plan to share this language with the Natural Resources Defense Council (NRDC).
In addition to AMSA's comments, I have enclosed a set of some 40 individual comments which we received from our member agencies. I trust that each of the comments will be reviewed and considered during your review. AMSA also looks forward to our continued working relationship with your staffs over the next several months on the pretreatment streamlining package.
AMSA appreciates the opportunity to comment on the draft. If you have any questions regarding the enclosed materials, please do not hesitate to contact me at (202) 833-4655.
Sincerely,
Samuel J. Hadeed
Director, Regulatory Affairs & Technical Services
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