Association
of
Metropolitan
Sewage
Agencies
with
Water
Permits
Division
December
9,
2003
Attendees
Deborah
Nagle,
Water
Permits
Division,
OWM
Jan
Pickrel,
Water
Permits
Division,
OWM
Elaine
Brenner,
Water
Permits
Division,
OWM
Linda
Boornazian,
Water
Permits
Division,
OWM
Laurie
Dubriel,
Water
Enforcement
Division,
OECA
Mindy
Gampel,
OPEI
Guy
Aydlett,
Hampton
Roads
Sanitation
Dist.,
Hazardous
Waste
Committee,
AMSA
Rick
Sustich,
Metro.
Water
Reclamation
Dist.
of
Chicago,
Hazardous
Waste
Committee,
AMSA
Chris
Hornback,
Regulatory
Affairs,
AMSA
Will
Petit,
Regulatory
Affairs,
National
Association
of
Clean
Water
Agencies,
AMSA
Handout
WEF/
AMSA
Pretreatment
Streamlining
Workshop
Final
Report,
September
1996
Purpose
and
Summary
of
Meeting
AMSA
met
with
Water
Permits
and
Water
Enforcement
Division
to
outline
what
it
views
to
be
opportunities
to
further
improve
the
Pretreatment
Streamlining
Rule.
The
following
summarizes
the
discussion:

 
Narrative
Standards
 
AMSA
notes
that
local
narrative
(
non­
numerical)
water
quality
standards
are
not
included
in
the
current
national
pretreatment
regulations.
AMSA
proposed
that
narrative
standards
be
incorporated
in
the
Pretreatment
Streamlining
Rule
which
would
make
them
national
pretreatment
standards
and
thus
enforceable.

 
Sampling
for
Pollutants
Not
Present
 
AMSA
supports
allowing
Control
Authorities
to
determine
when
pollutant
sampling
is
needed
for
an
industrial
user
subject
to
categorical
pretreatment
standards
where
the
pollutant
is
not
expected
to
be
present
above
background
levels
in
the
IUs
wastestream.
AMSA
presented
three
preconditions
to
be
used
in
making
the
decision:
1)
pollutant
not
used
in
industrial
process,
2)
analysis
shows
not
present,
and
3)
materials
or
chemicals
containing
such
pollutants
are
verified,
via
periodic
inspections,
as
not
used
or
stored
onsite.
AMSA
requests
inclusion
of
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
OCPSF)
facilities.

 
Equivalent
Mass
Limits
for
Concentration
Limits
­
AMSA
indicates
that
current
restrictions
on
use
of
mass
limits
discourages
water
conservation.

 
Definition
of
SIUs
­
AMSA
states
that
25,000
gpd
criterion
in
the
SIU
definition
is
problematic
because
it
doesn't
account
for
relative
impact.
The
Domestic
Sewage
Exclusion
Study
says
25,000
gpd
based
on
5%
(
0.5
MGD
plant).
AMSA
favors
5%
which
could
be
based
on
the
capacity
of
the
receiving
plant.
For
example,
Chicago
has
a
plant
of
design
flow
300
MGD
and
25,000
gpd
wouldn't
be
detected.
AMSA
states
definition
has
catch­
all
to
allow
other
IUs
to
be
named
SIUs.
AMSA
also
notes
definition
gives
states
or
regions
authority
to
designate
some
IUs
as
SIUs.

 
De
Minimis
CIUs
­
AMSA
disagrees
with
proposed
100
gpd
cutoff
for
NSCIUs.
Chicago
doesn't
have
any
CIUs
less
than
100
gpd,
but
HRSD
has
a
few.
The
terms
"
other"
and
"
concentrated"
need
to
be
clarified
in
the
definition.
AMSA
supports
three
tier
 
middle
of
CIU
using
concept
of
5%
contribution,
0.01%
headworks
loading,
0.01%
treatment
capacity
and
compliance
history.
Chicago
XL
project
is
piloting
this
approach.

 
pH
 
AMSA
suggests
that
EPA
take
a
look
at
what
NRDC
agreed
to.
Don't
want
to
lose
this
issue.

 
Significant
Non­
Compliance
Criteria
 
AMSA
considers
the
biggest
issue
is
the
requirement
that
late
reports
put
a
SIU
in
SNC
when
IU
is
otherwise
in
perfect
compliance.
AMSA
states
that
IUs
may
have
done
the
monitoring
and
just
forgot
to
turn
in
the
report.
AMSA
supports
increasing
deadline
to
45
days
as
opposed
to
30
days,
because
people
operate
on
a
monthly
cycle.
However,
Chicago
uses
fine
system
and
does
not
have
a
problem
with
IUs
submitting
late
reports.
In
contrast
HRSD
AMSA
notes
technical
review
criteria
(
TRC)
 
should
be
more
relevant
to
the
goals
of
the
pretreatment
program,
rather
than
being
based
on
NPDES.
AMSA
supports
replacing
rolling
quarters
with
static
six
month
periods
for
determining
SNC
to
eliminate
situations
of
double
jeopardy.
