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The Association of Metropolitan Sewerage Agencies (AMSA) sent a letter to EPAs Assistant Administrator for Water, Benjamin Grumbles last week, following up on a Dec. 20, 2004 meeting urging the agency to finalize the timeline for its proposed pretreatment streamlining rule.
AMSA recommended in the letter that EPA, which proposed the rule in 1999, provide a timeline for finalizing the pretreatment streamlining proposal. In line with its report, EPA Needs to Reinforce its National Pretreatment Program, EPAs Office of Inspector General (OIG) requested the Office of Water develop such a timeline.
The report found wastewater agencies with approved pretreatment programs were about half as likely to experience a pass through and/or interference event as those without an approved pretreatment program, making finalization of the rule critical to continued progress of the pretreatment program. In addition, OIGs December 2004 Semiannual Regulatory Agenda anticipated finalization of the rule by February 2005.
The association continually has emphasized the need for flexibility in converting traditional concentration-based limits to mass-based limits, revised definitions of nonsignificant or de minimis categorical industrial users, and significant non-compliance criteria.
These AMSA-supported changes would have no negative impact on the environment and would have the potential to save wastewater utilities hundreds of millions of dollars and other resources for facilities of all sizes to channel into other high-priority water quality projects.
EPA now has a valuable opportunity to reevaluate the pretreatment program, reduce unnecessary administrative burden and allocate saved resources to other programs that can achieve greater environmental benefit.
AMSA strongly supports OIGs recommendation that the agency finalize the Pretreatment Streamlining Rule as a key component of updating the pretreatment program.
AMSA is a national trade association representing hundreds of the nation's publicly owned wastewater treatment utilities.