NPDES Permit Issues
NPDES Streamlining - Proposed Rule
Background: In response to President Clinton's February 21, 1995 Reinventing Government directive, EPA proposed revisions to NPDES requirements in 40 CFR Parts 122, 123, and 124 to eliminate redundant regulations, provide clarification, and remove or streamline unnecessary procedures which do not provide environmental benefits (Round II). Proposed revisions for Round II, as published by EPA on December 11, 1996, include: 1) allowing general permits to cover multiple categories of discharges, thus, increasing the ability of general permits to cover currently unregulated sources, and streamline reissuance procedures of general permits where no changes in permit conditions are anticipated; 2) allowing permit writers not to require permit limits for all effluent guideline listed pollutants under certain circumstances; 3) removal of stormwater group application requirements; 4) streamlining permit terminations procedures; and, 5) revising Part 124 evidentiary hearing procedures.
Status: A second draft
of the final regulation preamble language for Round II is currently
undergoing internal EPA review. EPA plans to publish a final rule
in September 1998. Work has begun on Round III streamlining
and may include (1) additional permit modifications that can be
considered minor, and (2) changes to requirements concerning EPA's
review of State permits. Other NPDES streamlining efforts are
described in more detail in other sections of this Update. CONTACT:
Thomas Charlton, EPA 202/260-6960.
NPDES Permit Application Requirements for POTWs, Form 2A
and 2S - Proposed Rule
Background: On December
6, 1995, EPA published a proposed regulation which will amend
NPDES permit application requirements and application forms for
POTWs and will replace existing Standard Form A and Short Form
A to account for changes in the NPDES program since the forms
were issued in 1973. The proposal consolidates POTW application
requirements, including information regarding toxics monitoring,
whole effluent toxicity (WET) testing, pretreatment facility and
hazardous waste contributions, and combined sewer overflows (CSOs).
The most significant proposed revisions according to EPA, would
require toxic and WET monitoring by major and pretreatment POTWs.
The proposed rule allows waivers where information is already
available to the permitting authority.
Status: AMSA submitted
comments to EPA on March 28, 1996. EPA expects to publish a
final rule in fall 1998. CONTACTS: Sam Hadeed, AMSA 202/833-4655,
or Robin Danesi, EPA 202/260-2991.
F EPA has scheduled one more NPDES Permit Writers' Training Course for 1998: September 21-25 in Seattle, WA. For more information, contact Betty Peterson, SAIC 703/917-8240.