NACWA Asks EPA to Clarify Pretreatment Sampling Requirements

(July 10, 2019) - NACWA sent a letter to the US Environmental Protection Agency (EPA) on July 2, requesting assistance in clarifying influent and effluent sampling requirements for pretreatment programs of publicly owned treatment works (POTWs).  The issue of periodic, mandatory scans for priority pollutants was raised by NACWA Member Agency the San Jacinto River Authority (SJRA) and discussed by the Association’s Pretreatment & Pollution Prevention Committee during its meeting at the NACWA Pretreatment Workshop in May. 

Committee members reported a wide variety of sampling requirements, ranging from quarterly sampling to no sampling at all.  The requirements seem to depend primarily on the implementing state, and not on individual characteristics of the POTW.  Committee members also reported that this preemptive pollutant sampling very rarely provides any actionable information for the POTW, and that other methods for identifying industrial discharges are more effective.  The high cost of the sampling is therefore not justified by the environmental benefits. 

NACWA asked EPA to provide clarification to the states that this type of sampling is not a federal requirement, and that multiple EPA guidance documents provide alternative and more flexible methods for identifying pollutant sources and discharges. 

For more information on this issue, please contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.