There’s a side note to the discussion
about EPA’s proposed Effluent Limitations Guidelines at the IECA conference two
weeks ago in Reno. The Waterkeeper Alliance, while not participating directly in
the session, provided a two-page handout listing its objections to the proposed
guidelines.
Read the Discussion
Briefly, their comments include
the following:
* The
proposed guidelines don’t contain post-construction standards or requirements.
*
They
don’t contain a standard for pollutants that aren’t covered by the category of
“turbidity,” such as oil and grease or pH. In addition, flow and volume aren’t
addressed.
*
They
contain no narrative standards that prohibit discharges of visible sediment from
a construction site.
*
The
limit of 13 nephelometric
turbidity
unit (NTU) does not
apply to enough sites—it would affect fewer than half the construction sites in
the country. The Waterkeeper Alliance wants to see a numeric limit for all
NPDES-regulated sites. (As the guidelines are currently written, a site must
meet three criteria for the guidelines to apply: it must be 30 acres or more, it
must be in an area of the country with an R factor of 50 or greater, and its
soil must have at least 10% clay content.)
*
Site
design approaches for limiting turbidity were not evaluated.
*Sites
smaller than 30 acres have no numeric effluent limit.
What do you think—are the
guidelines as written too stringent to be feasible, or don’t they go far enough?
You can read the complete document here,
and you still have a couple of days left to submit comments to EPA here.