FYI --

I recently read an article in the June issue of WEF Highlights (News for members of the Water Environment Federation), stating that the US EPA issued a guidance on April 19th recommending that facilities meeting certain compliance and performance standards be allowed to submit fewer discharge monitoring reports.  The guidance was issued in response to President Clinton's Regulatory Reinvention Initiative for EPA.  

EPA estimates that the overall NPDES reporting burden would be reduced by 26% if all eligible facilities took advantage of the recommendations.  To meet the eligibility requirements, facilities must not have been in significant noncompliance for two years or had effluent violations of "selected parameters" for at least one year.  Additional reductions could be granted based on documented effluent concentrations that are well below permit-specified limits.  

For example, a discharger whose copper discharge is consistently only 20% of its permit limit could have its monitoring frequency for copper reduced from weekly to bi-monthly.  The NPDES permit authority (usually states) would have to adopt EPA's recommendations before they could be written into facility permits.  EPA is planning 12-18 month pilot projects in Oklahoma and Louisiana and may consider changes to the interim permit based on the results.  Dischargers interested in reducing reporting under the guidance should contact their permit authorities to assess their options.  

The EPA document, Interim Guidance for Performance-Based Reductions of NPDES Permit Monitoring Frequencies, is available electronically on WEF's web site (http://www/wef.org) under "Regulations and Legislation."

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