Association
of
Metropolitan
Sewerage
Agencies
Meeting
with
Associate
Administrator
for
the
Office
of
Policy,
Economics
and
Innovation
April
15,
2004
Attendees
Jessica
Furey,
USEPA/
OPEI
Louise
Wise,
USEPA/
OPEI
Mindy
Gampel,
USEPA/
OPEI
Robert
Benson,
USEPA/
OPEI
Michael
Hessling,
USEPA/
OPEI
Richard
Kashmanian,
USEPA/
OPEI
Deborah
Nagle,
USEPA/
OW
Ken
Kirk,
AMSA
Will
Pettit,
AMSA
Guy
Aydlett,
AMSA/
Hampton
Roads
Sanitation
District
Purpose
and
Summary
of
Meeting
AMSA
met
with
Jessica
Furey,
AA
for
OPEI,
to
provide
some
of
the
history
of
the
Pretreatment
Streamlining
Rule,
convey
the
importance
of
it
to
AMSA
and
the
POTW
community,
and
highlight
their
most
significant
issues.

°
Sampling
for
Pollutants
Not
Present
­
consider
this
to
be
an
easy
change
that
is
wellsupported
by
data.

°
Converting
Concentration­
based
Limits
Into
Mass­
based
­
would
like
EPA
to
promulgate
what
was
proposed
as
this
would
provide
POTWs
with
a
tool
that
they
could
use
to
address
water
conservation.
AMSA
felt
that
POTWs
are
capable
of
evaluating
a
CIU's
prior
history,
assessing
whether
water
reduction
is
due
to
conservation
or
something
else
(
e.
g.,
production
changes),
and
would
document
the
conversion
similar
to
the
worksheet
used
for
the
combined
wastestream
formula.
AMSA
specifically
noted
that
this
provision
would
be
particularly
applicable
to
cases
where
regulated
process
waters
do
not
go
through
the
treatment
system,
and
still
meet
concentration
limits,
but
with
water
conservation,
concentration
limits
would
be
violated
without
any
additional
mass
being
discharged.

°
Non­
Significant
Categorical
Industrial
User
(
NCIU)
­
This
represents
the
most
important
issue
for
AMSA
and
would
provide
the
greatest
cost
savings.
AMSA
would
like
EPA
to
set
a
higher
threshold
for
NCIU
than
what
was
proposed
(
i.
e.,
100
gallons
per
day),
which
they
felt
would
not
help
them.
AMSA
noted
that
100s
of
pretreatment
programs
require
far
more
than
the
federal
minimum
requirements
for
SIU
reporting
and
POTW
oversight.
They
would
like
to
have
the
flexibility
to
redesignate
CIUs
as
NCIU
based
on
history
of
good
compliance
and
threshold
tied
to
POTW
capacity
(
0.01%
of
POTW
flow,
capped
at
25,000
gallons
per
day).
AMSA
argued
that
this
would
still
be
protective
of
the
treatment
plants,
surface
waters
and
sludge
quality,
as
industries
would
still
have
to
meet
their
categorical
limits
and
POTWs
would
only
reduce
oversight
for
a
select
group
of
IUs.
Additionally,
AMSA
stated
that
this
provision
and
others
in
the
rule
should
not
be
deemed
a
substantial
program
modification.
Given
the
permit
backlog
and
tight
resources
of
all
regulatory
agencies,
the
most
significant
flexibilities
in
the
rule
would
not
be
able
to
be
implemented.

°
Significant
Noncompliance/
Late
Reports
­
AMSA
believes
that
a
report
that
is
more
than
30
days
late
should
not
automatically
be
deemed
SNC.
If
a
report
is
submitted
late,
shows
full
compliance,
and
the
IU
can
demonstrate
that
there
were
extenuating
circumstances
for
why
the
report
was
late,
AMSA
would
like
the
ability
to
not
to
label
it
SNC
and
publish
that
facility
in
the
newspaper.

AMSA
noted
that
they
did
not
provide
a
complete
assessment
of
potential
cost
savings
when
they
originally
submitted
comments
on
the
proposed
rule.
They
plan
on
submitting
to
the
Agency
revised
figures
in
the
next
few
weeks.

Attachments
AMSA/
WEF
White
paper
submitted
at
the
time
of
proposal
Letter
from
AMSA
to
Ben
Grumbles
and
Jim
Hanlon,
March
16,
2004
