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NPDES Permit Issue

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: EPA plans to publish a final rule in April 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 March 1998. CONTACTS: Sam Hadeed, AMSA 202/833-4655, or Robin Danesi, EPA 202/260-2991.

Related Items of Interest

EPA's Permits Division hosted the first NPDES Permit Writers' Training Course in Honolulu, HI on January 12-16, 1998. The Workshop was the first in a series of five courses co-sponsored by the Department of the Navy. Other course locations planned for this year include: Jacksonville, FL; Portsmouth, NH; Austin, TX; and, Seattle, WA. For more information, contact Daniel Weese, EPA 202/260-6809.