it's okay if you don't know everything
a rainy night, followed by a dark and blustery morning. that is, a perfect day to ride to work!
i am still a little blown away by the publication of a draft wastewater blending guidance by NACWA (the National Association of Clean Water Agencies) and NRDR (the Natural Resources Defense Council). the proverbial fox and goose have lain together, and look what they brought back! and EPA is at least tentatively saying they like it; OWM anyway, if not OECA. for me it is a little vindication, and even a very slight thawing of feeling toward the enviros, who really earned my contempt with their relentless onslaught of disinformation on the subject.
i was genuinely depressed last may, when EPA withdrew its draft policy, faced with the preposterous efforts of bart stupak and others in congress to ban "dumping" of "partially treated sewage", concepts they couldn't have possibly come up with on their own but which were clear reflections of the enviros' (wrong) take on the topic. it doesn't surprise me that the average member of the sierra club doesn't understand the technical details of wastewater treatment, to say nothing of the regulatory framework for water quality standards and discharge permitting, but i'd like to think that average member would at least be open to learning a thing or two about it, before unleashing a barrage of ignorance-fueld invective and criticism. they kept talking about how "biological treatment removes pathogens" - this is fiction! i fully understand that my work is arcane, but i would be delighted to explain it to anyone willing to listen. the scary thought is that if they are half as wrong about their other impassioned causes as they are about EPA's draft blending policy, then they just basically don't know shit. and yet they are so proud of themselves anyway.
but i managed to put a lot of this misery behind me, after the whole "swimming in sewage" debacle and my (anonymously contributed) refutations of the "katonak-rose paper" attached to nrdc's comment to epa...that was a blow, too, to have the good dr. rose lend her name to that misinformed piece of work. and i had productive arguments (all professional, of course) with dr. haas, who along with dr. rose wrote comments submitted on behalf of the american society of microbiologists, which got at the technical issues concerning pathogens remaining after various stages of treatment, and risk, but still fell somewhat short of recognizing the need for authorizing blending in npdes permits. but i was getting over that crushing feeling i got when i read that congressional record, and those politicians blathering about sewage and dumping and regulations...regulations! EPA wasn't promulgating any new regulations! if our lawmakers don't understand the difference between an agency policy (which is not enforceable) and regulations (which are) then we are in real trouble. anyway i had let it go, wondering where we would go next exactly, when nacwa/nrdc (two acronyms that one does not ordinarily connect with a forward slash) put out this revised, suggested guidance. and it's very good. it distinguishes between "good" blending and "bad" blending, and lays out what would be required in the "no feasible alternatives analysis" that permittees would have to submit with their application before their permits could authorize blending. it will not go over well with the "black box" crowd ((as long as i meet my permit limits you can't tell me how to run my plant), and it could possibly be challenged on the basis of the NPDES regs ("new" requirements that must go through rulemaking) but it is something positive nonetheless. and it shows that the enviros can be educated on the subject. nancy stoner saying that blending can be approved as an "anticipated bypass" per 40 CFR Part 122.41(m)? better check the temperature of hell...
i would link the proposed guidance but it is in a nacwa members-only part of their website for now. stay tuned.
i am still a little blown away by the publication of a draft wastewater blending guidance by NACWA (the National Association of Clean Water Agencies) and NRDR (the Natural Resources Defense Council). the proverbial fox and goose have lain together, and look what they brought back! and EPA is at least tentatively saying they like it; OWM anyway, if not OECA. for me it is a little vindication, and even a very slight thawing of feeling toward the enviros, who really earned my contempt with their relentless onslaught of disinformation on the subject.
i was genuinely depressed last may, when EPA withdrew its draft policy, faced with the preposterous efforts of bart stupak and others in congress to ban "dumping" of "partially treated sewage", concepts they couldn't have possibly come up with on their own but which were clear reflections of the enviros' (wrong) take on the topic. it doesn't surprise me that the average member of the sierra club doesn't understand the technical details of wastewater treatment, to say nothing of the regulatory framework for water quality standards and discharge permitting, but i'd like to think that average member would at least be open to learning a thing or two about it, before unleashing a barrage of ignorance-fueld invective and criticism. they kept talking about how "biological treatment removes pathogens" - this is fiction! i fully understand that my work is arcane, but i would be delighted to explain it to anyone willing to listen. the scary thought is that if they are half as wrong about their other impassioned causes as they are about EPA's draft blending policy, then they just basically don't know shit. and yet they are so proud of themselves anyway.
but i managed to put a lot of this misery behind me, after the whole "swimming in sewage" debacle and my (anonymously contributed) refutations of the "katonak-rose paper" attached to nrdc's comment to epa...that was a blow, too, to have the good dr. rose lend her name to that misinformed piece of work. and i had productive arguments (all professional, of course) with dr. haas, who along with dr. rose wrote comments submitted on behalf of the american society of microbiologists, which got at the technical issues concerning pathogens remaining after various stages of treatment, and risk, but still fell somewhat short of recognizing the need for authorizing blending in npdes permits. but i was getting over that crushing feeling i got when i read that congressional record, and those politicians blathering about sewage and dumping and regulations...regulations! EPA wasn't promulgating any new regulations! if our lawmakers don't understand the difference between an agency policy (which is not enforceable) and regulations (which are) then we are in real trouble. anyway i had let it go, wondering where we would go next exactly, when nacwa/nrdc (two acronyms that one does not ordinarily connect with a forward slash) put out this revised, suggested guidance. and it's very good. it distinguishes between "good" blending and "bad" blending, and lays out what would be required in the "no feasible alternatives analysis" that permittees would have to submit with their application before their permits could authorize blending. it will not go over well with the "black box" crowd ((as long as i meet my permit limits you can't tell me how to run my plant), and it could possibly be challenged on the basis of the NPDES regs ("new" requirements that must go through rulemaking) but it is something positive nonetheless. and it shows that the enviros can be educated on the subject. nancy stoner saying that blending can be approved as an "anticipated bypass" per 40 CFR Part 122.41(m)? better check the temperature of hell...
i would link the proposed guidance but it is in a nacwa members-only part of their website for now. stay tuned.
posted by cicadashell at
4:48 PM
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