Monthly Update www.scap1.org January 2012 Homepage Air Quality Report Biosolids Report Collections Report Energy Report Water Issues Report Pretreatment Report Meeting Schedule Announcements - SCAP STAFF John Pastore, Executive Director [email protected]Pam Merriam, Administrator [email protected]Ray Miller, E. D. Emeritus [email protected]Southern California Alliance of Publicly Owned Treatment Works P.O. Box 231565 Encinitas, CA 92024-1565 Ph. (760) 479-4880 Fax (760) 479-4881 Executive Director’s Message GREETINGS FROM OUR PRESIDENT HAPPY NEW YEAR! SCAP’S LEGACY As this is my first opportunity addressing the entire SCAP membership, l would like to take the opportunity to wish all of you the very best in 2012. I am very proud to be serving my second year as SCAP President and look forward to meeting the challenges that this new year will bring. Last year was one of much activity in our industry. Some of us made our case for much needed rate adjustments, a very difficult undertaking given the stuttering economic recovery. The City of Los Angeles has suffered from the downturn in the economy as have all parts of the state and like the rest of you we have been faced with shrinking budgets and workforce. Yet we must continue to provide the essential public services that our agencies are tasked with. As you very well know, this is no easy task when much of what is reported in the news continues to be negatively focused on public employees’ pensions and benefits rather than on the important services we provide. Fortunately, the Los Angeles Mayor and City Council agreed with our budget projections and infrastructure needs assessment and unanimously approved a significant rate increase over the next 10 years. A final Prop 218 public hearing will be held in late January by the City Council as part of the approval process. Many of you will be facing a similar challenge in the coming years and I would be happy to share our experiences with you for those that are interested in how we accomplished this, including the garnering of support from the residential and business communities. Last month we held our December Board of Directors meeting, which was followed by our General Membership meeting and annual Holiday Luncheon. It was a festive occasion as always and gave us all a chance to catch up with old friends as well as meet new members. Making this year’s event even more special was the fact that SCAP is celebrating its 20 th
Southern California Alliance of Publicly Owned Treatment Works P.O. Box 231565 Encinitas, CA 92024-1565 Ph. (760) 479-4880 Fax (760) 479-4881
Executive Director’s Message
GREETINGS FROM OUR PRESIDENT HAPPY NEW YEAR! SCAP’S LEGACY
As this is my first opportunity addressing the entire SCAP membership, l would like to take the opportunity to wish all of you the very best in 2012. I am very proud to be serving my second year as SCAP President and look forward to meeting the challenges that this new year will bring. Last year was one of much activity in our industry. Some of us made our case for much needed rate adjustments, a very difficult undertaking given the stuttering
economic recovery. The City of Los Angeles has suffered from the downturn in the economy as have all parts of the state and like the rest of you we have been faced with shrinking budgets and workforce. Yet we must continue to provide the essential public services that our agencies are tasked with. As you very well know, this is no easy task when much of what is reported in the news continues to be negatively focused on public employees’ pensions and benefits rather than on the important services we provide. Fortunately, the Los Angeles Mayor and City Council agreed with our budget projections and infrastructure needs assessment and unanimously approved a significant rate increase over the next 10 years. A final Prop 218 public hearing will be held in late January by the City Council as part of the approval process. Many of you will be facing a similar challenge in the coming years and I would be happy to share our experiences with you for those that are interested in how we accomplished this, including the garnering of support from the residential and business communities. Last month we held our December Board of Directors meeting, which was followed by our General Membership meeting and annual Holiday Luncheon. It was a festive occasion as always and gave us all a chance to catch up with old friends as well as meet new members. Making this year’s event even more special was the fact that SCAP is celebrating its 20th
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anniversary and honored all of the past SCAP presidents, who were also in attendance. At one point, I found myself looking around the room at the more than 120 people in attendance and thought what a great testament to the
foresight brought to this organization from the presidents and directors that preceded me. We were also able to honor two other individuals that were directly responsible for the success of SCAP: Our executive director emeritus, Ray Miller, who was chosen to lead SCAP back in 1992 and whose efforts over the following 14 years insured its sustainability; and Don Rebeck, who many of you remember as Ray’s right-hand man. Don was given a special award and the title of SCAP’s “Ambassador of Goodwill” was bestowed upon him by the Board.
SCAP Presidents from left to right: Jim Stahl, Blake Anderson, Kamil Azoury, Chuck Carry, John Pastore, Rich Atwater and Enrique Zaldivar
Remembrance of the past is vitally important lest we forget why we were formed and what we have accomplished. From our humble beginning in 1992 with just a handful of members, SCAP has grown to its present size - over 100 members (including Associates) and now represents the majority of POTWs in Southern California. We are fortunate to have John Pastore as our executive director who has kept us on a steady course and has empowered the committees to become the strength of our organization. However, there remains much work still to be done. To match the intensity of the California regulators we have recently expanded the number of SCAP directors from 7 to 14 for better representation and have added a new working committee to evaluate the needs of the wastewater pretreatment community. Speaking of the SCAP committees, I would like to personally thank all of the past and present committee chairs and vice chairs for the excellent job they do in keeping our membership informed on all of the new regulations and legislation affecting the wastewater industry. Their effort, which is purely voluntary, is in addition to their regular jobs and is very much appreciated by all of us. Again, I wish all of you a happy and prosperous New Year and would like to thank all of our members including our Associates for their support of this organization. Always remember there is strength in numbers. Yours truly, Enrique Zaldivar, President
Comments? If you would like to leave a comment about content or layout of this newsletter, please feel free to contact us at SCAP.
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Clean Water Summit Partners Update by John Pastore, SCAP The next meeting of the Clean Water Summit Partners (CASA, CWEA, SCAP, BACWA & CVCWA) is scheduled for February 6th in Sacramento at which Dave Smith, the Managing Director of WateReuse-California, will be the featured guest for this meeting.
Winter in Southern California (Photo Courtesy of Ralph Palomares)
LOCAL AIR DISTRICT NEWS AT A GLANCE Posted meeting dates and proposed new rule development for the following air districts can be found at these sites:
Imperial County APCD Mojave Desert AQMD San Diego APCD Santa Barbara APCD Ventura County APCD South Coast AQMD
Major Air Issues for 2012 by Kris Flaig, City of LA We have extensively covered all of the important air issues, both local and statewide, in this column over the last 12 months and since there is nothing significant that occurred in December 2011 to report, I thought we would begin
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this month by listing what the SCAP Air Committee views as the major issues that we will be following in 2012 as the new year unfolds: Major Issues
Final resolution of Section 185 Clean Air Act Non-Attainment Fees.
Continue fighting to attain reasonable SCAQMD Rule 1110.2 biogas limits.
Continue to press for the successful conclusion to PAR 1470 lobbying to hold emergency standby generators free of the requirement to install Diesel Particulate Filters in their exhaust stacks.
SCAQMD’s AQMP Advisory Committee to Implement the 24-hour PM 2.5 standard.
Monitor NGO activity dealing with PM 2.5 and the rescinded 1-hour ozone SIP issues.
Monitor new legislation.
Continue involvement with CWCCG AB32 activities: CARB follow-up on promises to address continuing rival perspectives regarding specific aspects of the
Cap and Trade Program and Mandatory Reporting Requirements. CPUC assignment of biogas/biomass renewable products to Category One and otherwise placed on equal
footing with other renewables. CPUC on-going Rule 21 (interconnection) activities. California’s Renewable Portfolio Standard (RPS)
CWCCG Update on Cap and Trade and Mandatory Greenhouse Gas Reporting by John Pastore, SCAP According to our CWCCG Program Manager, Zeynep Erdal, “Both the Cap and Trade and the Mandatory Reporting Regulations have become law with the completion of the final Office of Administrative Law (OAL) approval process. Both will be effective January 1, 2012. CARB is still in the process of finalizing the mechanics of the processes related to market monitoring and auctions”. Summary The OAL has approved the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Regulation, including Compliance Offset Protocols. The regulation is effective January 1, 2012. The version approved by OAL removed several ‘reserved’ sections (that is, sections that referenced future regulatory elements that have not yet been approved) in the regulation to conform to rulemaking requirements under the Administrative Procedure Act. The removal of ‘reserved’ sections does not reflect policy decisions on whether those areas will or will not be addressed in future rulemakings. Staff will continue to engage with stakeholders on issues identified in Resolutions 10-42 and 11-32. The regulatory materials can be accessed from ARB’s website at this address: ARB has updated its cap-and-trade program webpages to provide information related to program implementation. These webpages will be updated regularly as implementation guidance and systems are completed. The cap-and-trade program webpage can be accessed here: OAL has also approved the Mandatory Reporting of GHG Emissions Regulation. The regulation includes amendments to harmonize the California GHG reporting requirements with federal GHG reporting requirements and support the California cap-and-trade program. The regulation is effective January 1, 2012. The regulatory materials can be accessed at the address: http://www.arb.ca.gov/regact/2010/ghg2010/ghg2010.htm
Upcoming SCAP Biosolids Committee Meeting by Matt Bao, LACSD The SCAP Biosolids Committee will hold its next meeting on Tuesday, January 17th, from 9:00 AM to 12:00 PM, in conjunction with Tri-TAC. The meeting will be held at the Radisson Ontario Airport Hotel, located at 2200 East Holt Boulevard in Ontario. Kern County Measure E, the CalRecycle proposed FOG and food waste regulations, the CDFA proposed rendering regulations, and other major biosolids issues will be discussed at this meeting. More details and an agenda will be sent out prior to the meeting. CWEA FOG and Food Waste Digestion Workshop – January 18, 2012 by Matt Bao, LACSD The California Water Environment Association (CWEA) will be holding a one-day specialty workshop titled, “Biosolids: Energizing Your Gas Production – FOG and Food Waste Co-Digestion Workshop”, on Wednesday, January 18th at the City of Los Angeles Hyperion WTP, located at 12000 Vista Del Mar, Los Angeles. This workshop will provide information about the state of the regulations, availability and competition for FOG and food waste, operational experiences, and considerations that can be incorporated into new designs. Up to 8.9 CWEA contact hours can be earned. The workshop brochure can be found here. WEF Updated Position Statement on Biosolids by Matt Bao, LACSD On December 2nd, the Water Environment Federation (WEF) approved a revised position statement that calls for innovative and beneficial uses of biosolids. The statement expands on WEF's existing support of federally regulated land application by encouraging a comprehensive approach to wastewater treatment and solids management that ensures the recycling and recovery of all associated resources including water, nutrients, organic matter and energy. WEF believes that a cultural move toward sustainability has the potential to shift policy-maker and public perception of biosolids from a waste to a community resource that can help achieve sustainability goals. This shift is creating unprecedented opportunities for the wastewater and biosolids community to position biosolids as a valuable commodity. Also recognizing that biosolids recycling remains a local decision, WEF encourages the use of whatever associated practice – land application, composting, energy generation, product development, landfilling, incineration, or other uses – is best suited to a community's economic and technological capabilities. To take full advantage of the inherent resource value of biosolids, WEF supports development of multiagency coordinated regulations that are based on sound research and best practices; advancements, innovation, and development of new technologies; recognition of the expanded role of wastewater and solids management; enhanced sharing of knowledge both within the profession and with other organizations, the regulatory community, and the public; and continued research. This position is consistent with decades of scientific research and years of field practice that have clearly established the value and environmental benefits of biosolids, when properly treated and managed. It is also consistent with the
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U.S. Environmental Protection Agency's (EPA) position and those of other federal agencies, which encourage the beneficial use of biosolids through policies and regulations, including the Clean Water Act. The WEF position statement on biosolids can be found here. (Source: Water Online). Update to CalRecycle Regulations of FOG and Food Waste Receipt at POTWs by Tom Meregillano, OCSD CASA has made tremendous strides coordinating with the State Water Resource Control Board (SWRCB) and CalRecycle to help resolve the issue of duplicative regulations concerning permitting Publicly Owned Treatment Works (POTWs) that accept and receive hauled Fats, Oils, and Grease (FOG) and food waste. As a product of this effort, on December 6, 2011, Tom Howard, Executive Director of SWRCB, sent a letter to Carroll Mortensen, new CalRecycle Director, to help address the cross media issue between the two agencies. Providing regulatory oversight of permitting POTWs under a National Pollutant Discharge Elimination System (NPDES) permit, the SWRCB recommended to CalRecyle that the Regional Water Board staff would place standard provisions in NPDES permits that would require POTWs to develop and implement standard operating procedures for waste hauled FOG for direct anaerobic digestion. The Regional Water Boards would be responsible for enforcing the standard provision. Accordingly, the SWRCB recommended that a blanket exemption by CalRecycle would be the best path to take to avoid duplicative regulation. CASA continues to work closely with both SWRCB and CalRecycle. The focus has been to broaden the scope of hauled waste to include not only FOG but also organic waste such as food waste. SCAP will continue to monitor the progress of this effort and provide its members with updates as information becomes available. (Source: Greg Kester, CASA)
New Collection Systems Committee Officers for 2012 by John Pastore, SCAP There are a few changes to the Collection Systems Committee that take effect in 2012, which include saying thanks for a job well done to LACSD’s Sam Espinoza, who is stepping down as Committee Chair after 5 years serving as both chair and vice chair of the Collections Committee, and welcoming El Toro Water District’s Ralph Palomares as the new Committee Chair. This will be Ralph’s second stint as chair and we are expecting big things from him including more of his great wit that he never fails to share with us. Although Sam is stepping down, he has assured me that he will remain involved in our meetings and that he and his staff will be frequent contributors to the meeting presentations. I am also pleased to announce that Dindo Carrillo has volunteered to serve as a second vice chair of the Committee along with our first vice-chair, Nicole Greene, from the great City of Montclair. Dindo has been with OCSD for the last 8 years and is currently working in the Environmental Compliance Division as a Senior Environmental Specialist,
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where he spends most of his time these days dealing with the SSS WDR Order, NPDES permit administration, regulatory advocacy and stakeholder coordination. Dindo has a degree in Chemistry from UC Irvine as well as a Masters in Chemistry from Cal State Long Beach so he will be a great resource to us at the committee level. Happy New Year 2012 to the Collection Systems Committee by Ralph Palomares, ETWD Well it’s a new year and I am glad to be back as the SCAP Collections Chair for the upcoming year and we do have our work cut out for us with our first meeting in February on the 28th at the El Toro Water District. We will be discussing, among other things, the IAPMO garbage grinder issue and the removal of calcium deposits in our sewer pipes. Another hot topic is the SSMP WDR audits, which are currently happening around our state and what they mean, as well as what we have to look forward to in 2012. I could go on and on with many other issues that affect our industry in today’s world but I will leave that to our upcoming Collections meetings for discussion. As always be safe and if you have topics that you would like to discuss at our meetings please e-mail me or John with your topic of concern. Lastly, I would also like to thank El Toro Water District for allowing me the time to chair this year’s Collections Committee. SWRCB Public Workshop for Review and Update of the SSS-WDR Order by John Pastore, SCAP The long awaited public workshop by the SWRCB staff concerning revisions to the Sanitary Sewer System Waste Discharge Requirements (SSS-WDRs) has been scheduled for January 24th in Sacramento. At the workshop, SWRCB staff will present the proposed revisions to the SSS-WDRs, review the previous comments received on these revisions, summarize staff’s response to the comments received and discuss alternatives developed for further revising the SSS-WDRs to address some of the comments. While some members of the Water Board may be present, no action will be taken at this meeting. The SWRCB Notice can be found here. IAPMO Proposal to Regulate the Disposal of Food Waste Within the Uniform Plumbing Code by John Pastore, SCAP SCAP has recently received information from a number of our members that IAPMO has planned to propose changes to the Uniform Plumbing Code as follows:
1. Food waste shall be disposed to the sanitary drainage system through a food waste grinder or shall be collected for composting. Food waste shall not be discarded to a trash or garbage container intended for disposal to a landfill.
2. Food waste grinders shall not discharge through a grease interceptor. OCSD’s staff, Merrill Seiler, was able to attend last month’s IAPMO meeting and got the proposal tabled. He has informed us that this proposal will be sent back to the GTC Food Services Task Group for further discussion. Merrill was also able to join this group as a committee member to provide a collection system perspective. Last month SCAP sent out an alert with attached documents showing the proposal with pertinent language highlighted in yellow. Also included in the alert was a copy of OCSD’s persuasive argument on why we should all be opposed to it SCAP will continue to monitor this important issue and will work with the other collection groups and associations throughout the state to make our comments known to IAMPO. We will definitely discuss this issue at our upcoming February 28th Collection Systems Committee meeting.
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[Editor’s Note: IAPMO R&T advertises itself as North America’s premier plumbing and mechanical product certification agency. It is accredited by American National Standards Institute (ANSI) and Standards Council of Canada (SCC)].
REMINDER: SARBS 21st Collections Seminar on January 26, 2012
ENERGY MANAGEMENT COMMITTEE REPORT
Andre Schmidt, Chair Chris Berch, Vice Chair [email protected][email protected] California State Renewables Portfolio Standard (RPS) Programs Implementation by Andre Schmidt, LACSD Senate Bill 2 (1x), which was signed by the Governor in April 2011, legislated the increase of California’s Renewables Portfolio Standard (RPS) to 33 percent by 2020. Later in the year, the California Public Utilities Commission (CPUC) initiated a proceeding to implement the terms of the bill. The proceeding incorporates SB 32, which calls for implementation of a new feed-in tariff (FIT) program. The FIT program would provide standard contracts for the purchase of eligible renewable generation from generation facilities up to 3 MW in size. POTW that produce more renewable power than can be utilized on-site could sell the excess electricity under the FIT program. A comment letter was filed in July by the California Wastewater Climate Change Group (CWCCG) responding to the CPUCs ruling specifically addressing implementation provisions of SB 32. SCAP members contributed to CWCCG’s comments, which called for technology-specific rates that accurately reflect the price of renewable energy generation, recognize real avoided costs and truly incentivize renewable distributed
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generation. The comments also supported increasing the size of an eligible facility to 3 MW and raising the program cap to 750 MW. Another comment letter mirroring the earlier comments was filed with the CPUC in November responding to an October CPUC Staff Proposal on the FIT. The CPUC has indicated the goal of issuing a Proposed Decision on the FIT by the end of 2011. The other main issue in the proceeding that affects the wastewater industry is that of unbundled renewable energy credits (RECs). RECs are certificates issued for the renewable attributes associated with renewable energy production. When RECs are sold or procured separately from the energy associated with them, they become “unbundled” RECs. Specifically for POTWs, unbundled RECs can be claimed for renewable generation that is consumed onsite at the treatment plant. It is anticipated that the value of an unbundled REC could be anywhere between $0.005 and $0.05 per kWh depending on how SB 2 (1x) is implemented. There are two implementation scenarios. The unfavorable scenario is where all unbundled RECs are placed in the third of the three RPS compliance categories. This category faces a decreasing cap, with utilities being limited to providing no more than 10 percent of their RPS obligations from it by 2020. The favorable scenario is where specific unbundled RECs, including those produced at California POTWs, would be included in the first RPS compliance category, which is uncapped and from which utilities must provide at least 75 percent of their RPS obligations by 2020. The favorable scenario would create a stable and robust market for unbundled RECs produced at POTWs that would provide an additional revenue stream to pay for the development of onsite renewable generation. The SCAP Energy Management Committee was active with CWCCG in filing comment letters with the CPUC on the unbundled REC issue during the rulemaking process in August. In October the CPUC issued a Proposed Decision which placed all unbundled RECs in the unfavorable third category. A comment letter was filed by CWCCG in response to this Proposed Decision. The five CPUC Commissioners discussed the issue during the November 10 CPUC business meeting. Two Commissioners indicated support for the Proposed Decision’s treatment of unbundled RECs, while two others indicated opposition to it and the fifth Commissioner did not indicate a position. The CPUC will likely make a final decision on the issue by the end of 2011. California State Renewables Portfolio Standard (RPS) Programs Implementation Follow-Up by Zeynep Erdal, CWCCG Program Manager The joint motion recently filed with the CPUC in collaboration with the Center for Energy Efficiency and Renewable Technologies (CEERT) and other parties, requesting consideration of alternate Feed in Tariff (FIT) proposals is posted here. The emphasis continues to be the cost basis of the draft staff proposal, as well as the calculation of the FIT for smaller renewable energy projects being categorized under a poorly incentivized “baseload” energy category. The motion also requests consideration of an alternate avoided cost-based analysis. As the ALJ had previously indicated, the timeline for a decision on FIT is delayed to the first quarter of 2012. CWCCG will continue to monitor and participate in the next phase of the process as well as the workshops. Upcoming SCAPEnergy Management Committee Meeting by John Pastore, SCAP On Thursday January 12th, the SCAP Energy Management Committee will be treated to a tour of the City of San Diego’s Beneficial Use of Digester Gas (BUDG) Project located at the Point Loma Wastewater Treatment Plant. This “first of its kind project” converts Point Loma WTP’s excess digester gas into natural gas that is then injected into the San Diego Gas & Electric (SDG&E) natural gas distribution system. This renewable gas is then “received” by the University of California, San Diego (UCSD) campus and to the Public Utilities Department’s South Bay Water
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Reclamation Plant, where the gas is ultimately used to supply ultra clean fuel cells for generating renewable electricity.
The tour will be preceded by presentations by City staff on the technical aspects of the BUDG Project and the City’s Public Utilities Energy portfolio of related projects. Normal committee business will also be discussed prior to the tour. The City has indicated that if time permits, it may be possible for those interested to visit the City’s new wind turbine located close by on Harbor Island. Space is limited so be sure and rsvp as soon as possible.
WATER ISSUES COMMITTEE REPORT
Al Javier, Vice Chair, Chair Jennifer Shepardson, Vice Chair [email protected][email protected] New Water Issues Committee Officers for 2012 by John Pastore, SCAP There are a few changes to the Water Issues Committee that take effect in 2012, which include saying thanks for a job well done to the City of San Bernardino Water Dept.’s Valerie Housel, who is stepping down as Committee Chair after having served in this position for the last couple of years, and welcoming Eastern Municipal Water District’s Al Javier as the new Committee Chair. Al has been serving as vice chair of the Committee all along so it should be a very smooth transition for him. Valerie and her technical insights will be greatly missed as will her delicious homemade pies that she frequently brought to the meetings. Taking Al’s place as Vice Chair will be Jennifer Shepardson, who like Valerie works for the City of San Bernardino Water Dept. Jennifer has regularly attended all of our water meetings in the past and we look forward to her assistance with the committee. SB 482 Beach Monitoring and Contracting Program Discussion - January 18th by John Pastore, SCAP Ocean dischargers will want to attend the Beach Water Quality Monitoring and Contracting Meeting presented by the SWRCB on January 18th and hosted by the Southern California Coastal Water Research Project (SCCWRP) located at 3535 Harbor Blvd., Suite 110 in Costa Mesa. The meeting is from 9:30 am to 3:00 pm. Jonathan Bishop of the SWRCB will be present and will be talking about the change of the Beach monitoring program AB 411 (April 1 - October 31) funding from DPH to the Water Boards required as part of SB 482 for years 2012 and thereafter. The primary topics for the agenda will be: * Budget - What will be available and when (Sustainable Fee based beach funding starting 7/1/2012) * Contracting changes and requirements (SWRCB to do contracting instead of DPH) * Review and possible Realignment of sampling locations and frequencies SB 482 added Section 115881 to the Health and Safety Code, to read:
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(a) Commencing January 1, 2012, the Water Boards shall be responsible for all of the following:
(1) Directing the monitoring required to be conducted by Section 115880 (AB 411 testing required by DPH). (2) Establishing and reviewing monitoring protocols, site locations, and monitoring frequencies consistent with
Section 115880. (3) Identifying options for funding the monitoring needed to fulfill the requirements of Section 115880,
Upcoming SCAP Water Issues Committee Meeting by John Pastore, SCAP The SCAP Water Issues Committee will hold its next meeting on Tuesday, January 17th, from 9:00 AM to 12:00 PM, in conjunction with the Tri-TAC Water Committee. The meeting will be held at the Radisson Ontario Airport Hotel, located at 2200 East Holt Boulevard in Ontario. More details and an agenda will be sent out prior to the meeting.
WASTEWATER PRETREATMENT COMMITTEE REPORT
Jim Colston, Chair [Vacant], Vice Chair
[email protected] The very first meeting of the SCAP Wastewater Pretreatment Committee will be held on Tuesday, February 7, 2012 at the offices of the Inland Empire Utilities Agency in Chino, CA. Please join us for this initial meeting in which we will discuss the goals of the committee and develop a list of relevant issues for future discussions. All interested parties are welcome to attend and participate. RSVPs are requested by February 2nd if you plan on attending this meeting. Suggested Committee Goals and Issues by Jim Colston, OCSD The following are suggested Goals of the Pretreatment Committee and a list of current issues that have been prepared by our newest committee chair, Jim Colston: Goals:
Provide a routine forum for members to exchange information about industrial and non-industrial pretreatment issues.
Review developing federal regulations related to the pretreatment program.
Discuss federal and local compliance activities for pretreatment programs including Pretreatment Compliance Inspections and Audits
Possibly include Pollution Prevention Programs in this committee Current Issues:
EPA Dental Amalgam rule
Enhanced Source Control for water reclamation
EPA Audits and Inspections and Federal Categorical review
Pretreatment Program software selection
Comparison of programs to enhance effectiveness and efficiency (bang for buck)
Contaminants of Emerging Concern and Medication/Drug programs to prevent dumping to the sewer
Components of a Non-Industrial Source Control Program
