United States EPA 833-B-94-004
Environmental Protection July 1994
Agency
Office of Water (4203)
&EPA NPDES and Sewage
Sludge Program
Authority
A Handbook for
Federally Recognized
Indian Tribes
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Table of Contents
Introduction 3
What Are the NPDES and Sewage Sludge Programs? 5
What Is a Permit and How Is It Developed, Issued, and Enforced? 9
What Are the Roles of Federally Recognized Tribes In Administering NPDES
and/or Sewage Sludge Programs? 15
What Are the Advantages and Disadvantages of Obtaining Authorization for
NPDES and/or Sewage Sludge Programs? 17
How Can a Federally Recognized Tribe Obtain Authority to Operate an
NPDES and/or Sewage Sludge Program? 23
What Assistance Is Available to Tribes? 27
Additional Resources 31
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Introduction
Section 518 of the Clean Water Act
(CWA) directs EPA to promulgate
regulations on how Federally recognized
American Indian Tribes can obtain authority
to run their own wastewater and sewage
sludge programs. On December 22,1993,
EPA published in the Federal Register [58
FR 67966] a rule citing the requirements for
determining whether a Federally recognized
Tribe is eligible for 'Treatment in a Similar
Manner as a State."1 The rule also specified
the procedui -, for obtaining authorization
from EPA fur ihe National Pollutant Dis-
charge Elimination System (NPDES) and
sewage sludge programs.
This handbook provides general informa-
tion on the NPDES wastewater and sewage
sludge programs for Federally recognized
Tribes. It:
• Discusses Treatment in a Similar Man-
ner as a State programmatic require-
ments and the definition of Federally
recognized Tribes,
• Describes the NPDES and the National
Sewage Sludge Programs,
• Discusses the advantages and disad-
vantages in assuming these programs,
and
• Outlines the steps a Tribe would take to
qualify for Treatment in a Similar
Manner as a State.
The handbook also addresses these ques-
tions:
• What are the NPDES and National
Sewage Sludge Programs?
• What is a permit and how is it devel-
oped, issued, and enforced?
• What are the roles of Federally recog-
nized Tribes in administering an
NPDES and/or sewage sludge pro-
gram?
• What are the advantages and disadvan-
tages of obtaining authorization for an
NPDES and/or sewage sludge pro-
gram?
1. EPA has proposed regulations (59 FR 13820, March 23,1994) to simplify the demonstration Tribes must make for
Treatment in a Similar Manner as a State under various environmental programs, including CWA programs. Until this
rule is promulgated, the December 22,1993, rule and its provisions will apply.
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• How can a Federally recognized Tribe
obtain authority to operate an NPDES
and/or sewage sludge program?
• What EPA assistance is available to
Tribes?
At the end of the handbook is a list of EPA
sources and staff available to assist Tribes in
applying for Treatment in a Similar Manner
as a State and developing successful NPDES
and/or sewage sludge programs.
Unfed StatM EPA 62S/R92/013
Environmental Protection December 1*92
Agtncy
Offlc»olWat«(«03)
Environmental Regulations and
Technology: Control of
Pathogens and Vector Attrac-
tions in Sewage Sludge
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What Are the NPDES and Sewage Sludge
Programs?
The CWA's goal is to restore and main-
tain the chemical, physical, and
biological integrity of the nation's
waters. To do that, several regulatory pro-
grams limit the amount and type of pollut-
ants discharged into navigable waters, so
that fish, shellfish, wildlife, and recreational
opportunities are protected. Two of these
programs are administered by EPA, or by
authorized States and Federally recognized
Tribes approved by EPA: the NPDES permit
program and the National Sewage Sludge
Program.
The process by which States or Federally
recognized Tribes obtain EPA approval to
operate an NPDES and/or sewage sludge
program is known as "authorization."
Authorization is discussed in detail on page
15 of this handbook.
The National Pollutant Discharge Elimina-
tion System (NPDES) Program
Established under CWA Section 402, the
NPDES program regulates pollutant dis-
charges from point sources to waters of the
United States. "Point source" generally
means the end of a pipe or ditch from which
wastewater enters a stream, a lake, a river,
or the ocean.
Scope of NPDES Programs
Municipal Sewage
Sludge
Separate
Storm Water
(MunidoaO
Storm Water
(Industrial)
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Under the NPDES program, EPA or autho-
rized States and Tribes issue permits to:
• Wastewater treatment facilities,
• Industrial facilities,
• Mining operations, and
• Many animal feedlots.
NPDES permits include:
• Basic facility information and certifica-
tion,
• Limits on chemical/biological contami-
nants in the effluent,
• Monitoring and reporting require-
ments, and
• Other special conditions necessary to
protect the nation's waters.
The National Pretreatment Program
The National Pretreatment Program is the
part of the NPDES program that regulates
industrial discharges to municipal wastewa-
ter treatment works. Most treatment works
cannot handle industrial wastes, which can
interfere with treatment plant operations, or
pass through the plant untreated and con-
taminate nearby water bodies. Because of
this, significant industrial users who release
wastewater into municipal treatment works
must obtain pretreatment permits, which
specify pollutant limits that must be met
before wastewater can be discharged to a
municipal treatment works.
The National Sewage Sludge Program
Generally, wastewater treatment separates
the solid material from the liquid. The
liquids are then treated and discharged as
"effluent." The remaining solids are known
as sewage sludge (or "biosolids"). Sewage
sludge is typically:
• Applied to land (to fertilize crops or
other vegetation or to stabilize the soil),
• Sent to a surface disposal site or mu-
nicipal solid waste landfill, or
• Incinerated.
The National Sewage Sludge Program
regulates the use and disposal of sewage
sludge. Regulations under the program
require sewage sludge to meet numeric
pollutant limits, management practices, and
requirements to reduce pathogens and
attractiveness to nuisance vectors (such as
insects and rodents) before it is used or
disposed. Monitoring, recordkeeping, and
reporting are also required.
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In many cases, the sewage sludge use or
disposal standards are included in NPDES
permits or separate "sludge-only" permits
issued to facilities that generate, treat, or
dispose of sewage sludge. Facilities that do
not have sewage sludge permits must com-
ply with the standards directly.
The National Sewage Sludge Program also
regulates the use or disposal of domestic
septage (e.g., pumpings from a septic tank).
Septage with a commercial or industrial
component is not covered by the program.
Septage placed on a surface disposal site
must meet vector attraction reduction re-
quirements, while septage applied to the
land is subject to an annual application rate,
pathogen reduction requirements, and
vector attraction requirements. Septage
haulers typically do not need to apply for
permits, but must comply with the appli-
cable regulations.
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What Is a Permit and How Is It Developed,
Issued, and Enforced?
In general, a permit sets conditions
under which an activity that otherwise
would be illegal is allowed. However,
there is no right to a permit, and permits can
be revoked for cause (e.g., noncompliance).
An NPDES permit sets conditions and limits
which, as long as they are met, make dis-
charging pollutants legal. A "sludge-only"
permit sets requirements for the use or
disposal of sewage sludge. (NPDES permit
limits are based on technology and/or water
quality. Sewage sludge limits are generally
risk-based.)
Technology-based NPDES Limits
Technology-based limits can consist of:
• Federal effluent limitation guidelines,
• State or Tribal regulations, and
• The Best Professional Judgment of the
permit writer.
EPA has developed effluent limitation
guidelines for certain classes of industry so
that permits issued across the country have
a uniform basis. States, localities, and autho-
rized Tribes may impose stricter limits to
attain or maintain the beneficial uses of the
receiving water. In some cases where efflu-
ent limitations guidelines have not been
developed and specific State/local/Tribal
provisions do not apply, a permit writer
may use Best Professional Judgment to
determine appropriate permit limits. In any
case, these limits cannot be less stringent
than the Federal limits.
Water Quality-based NPDES Limits
Water quality-based limits are used when
limits more stringent than technology-based
effluent guidelines are necessary to protect a
"designated use" of the receiving waters (40
CFR 122.44(d)(D). Water quality-based
limitations must control all pollutants which
will cause, have the reasonable potential to
cause, or contribute to a violation of any
State or Tribal water quality standard (40
CFR 122.44(d)(l)(i)). Designated uses are
usually established on a stream segment
basis and may include such things as:
• Municipal water supply,
• Water contact recreation,
• Ground water recharge,
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• Industrial process supply, or • Development of the draft permit and
fact sheet by EPA or the authorized
• Wildlife habitat. State or Tribe,
• Notice to the public and period for
Sewage Sludge Limits public comments,
Sewage sludge permit limits are based on • Establishment of the Administrative
the requirements of Section 405 of the CWA. Record,
The standards for sewage sludge use or
disposal are codified at 40 CFR Part 503. • Award of final permit, and
These requirements vary with the different
sewage sludge use or disposal practices • Compliance.
employed, but generally include limits on
specific pollutants, pathogen and vector These steps are explained in greater detail
attraction reduction measures, and manage- on page 12. In addition, they are summa-
ment practices. A State or Tribal sewage rized in Figure 1 ("NPDES Permitting Proce-
sludge program may be part of an approved dures").
NPDES program or a separate program.
States and Tribes are free to set more strin-
gent standards.
The Permit Issuance Process
The basic steps in the permitting process
are:
• Application for a permit by the dis-
charger or sewage sludge user or dis-
poser,
10
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Figure 1: NPDES Permitting Procedures
Public notice of
draft permit,
comment period
(and optional
hearing)
Public comment
period; requests for
public hearing
New statement of basis,
fact sheet or new draft permit
Issue final permit
decision; respond to
comments
Administrative
record
Public hearing
(optional)
11
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Permit Application
All potential permittees must complete
Form 1, a permit application that requests
general information such as facility name,
address, and ownership. Form 1 directs
applicants to additional relevant application
forms.
Development of Draft Permit
and Fact Sheet
Once the application is submitted, EPA or
the authorized State or Tribe must develop a
draft permit and fact sheet. This draft per-
mit must contain:
• A cover sheet,
• Pollutant limits for effluent or sewage
sludge,
• Monitoring conditions,
• Standard conditions, and
• Any necessary special conditions.
The fact sheet typically explains the source
of the pollutant limits and special condi-
tions. For example, a fact sheet might cite
the effluent limitations guidelines that apply
to the class of permittee or the applicable
Tribal water quality standard.
Monitoring conditions specify the analytical
method, sample type, and frequency for
sampling the effluent or sewage sludge to
determine compliance with the permit
limits.
Standard conditions appear in almost all
permits; they usually include such things as
reporting and records retention require-
ments.
Special conditions are additional conditions
unique to certain dischargers.
Public Notice
The next step in the permitting process is
public notice of the draft permit and a
public comment period. Anyone who may
be affected by the conditions of the permit
has the opportunity to provide input to the
permitting process. Generally, the public
notice appears in the local newspaper, and
the public comment period can last 30 to 90
days. Hearings may be held in response to
public interest.
12
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Administrative Record
The administrative record consists of all
documents related to development of the
permit, including:
• The draft permit,
• Copies of the applicable effluent limits
or water quality standards,
• The comments raised during the public
notice period, and
• Formal responses to the public com-
ments received.
Compliance
Once the final permit has been issued to the
discharger, sewage sludge user, or disposer,
the permittee must comply with the pollut-
ant limits, monitoring and reporting re-
quirements, and other specified conditions.
It is then the responsibility of the permitting
authority (EPA, authorized State, or autho-
rized Tribe) to monitor the permittee's
compliance. The permitting authority re-
views the permittee's monitoring reports for
accuracy and conducts periodic compliance
inspections of the facility.
Final Permit
After considering the issues raised by the
public comments, a final permit is issued to
the applicant, which contains the informa-
tion found in the draft permit and revisions
made as a result of input received during
the public notice and comment period.
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What Are the Roles of Federally Recognized
Tribes In Administering NPDES and/or
Sewage Sludge Programs?
T
here are two stages of requirements in
assuming program administration
responsibility:
• Those necessary to obtain authorization
from EPA (such as satisfying §518 of
the CWA), and
• Those performed after receiving autho-
rization.
To achieve authorization, a Tribe must
develop enforceable regulations for the
NPDES (including pretreatment) or sewage
sludge program. These regulations must be
at least as strict as the Federal regulations.
The Tribe must also develop a program to
administer the NPDES and/or sewage
sludge program before authorization is
granted.
Once the Tribe receives authorization, it will
be responsible for implementing the pro-
gram (including issuing NPDES and/or
sewage sludge permits). The authorized
Tribe will also conduct compliance and
monitoring activities.
the reservation. Prior to authorization, EPA
will:
• Issue permits,
• Conduct compliance and monitoring
activities,
• Provide the necessary enforcement for
the program, and
• Provide technical assistance and train-
ing to Tribes attempting to gain Treat-
ment in a Similar Manner as a State.
After Tribal authorization, EPA will:
• Evaluate and oversee the Tribe's
NPDES and/or sewage sludge pro-
gram,
• Oversee grant programs (such as CWA
§104(b)(3) and 106 grants), and
• Provide administrative and legal sup-
port and continued technical assistance
and training.
Role of EPA
EPA's role changes as a Tribe assumes
greater authority for the CWA programs on
15
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EPA also \vil\ provide enforcement as neces- necessary in cases where Tribal authority is
sary, according to a Memorandum of Agree- limited, such as for criminal enforcement
ment worked out between the Tribe and the actions.
EPA Region. Such EPA enforcement may be
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What Are the Advantages and Disadvantages
of Obtaining Authorization for NPDES and/or
Sewage Sludge Programs?
E
PA recognizes that it is important
for Tribes to:
• Consider which environmental pro-
grams would be most beneficial, and
• Target Tribal efforts and resources
towards those specific programs.
Major issues that Tribes should consider
when deciding whether to apply for
authorization include:
• The benefits of self-determination,
• Improved administrative, regulatory,
and technical capabilities, and
• The costs in personnel and financial
resources.
Self-Determination
Obtaining authorization to regulate
reservation waters may support Tribal
self-determination in several ways. For
example, it gives the Tribe increased
authority over what happens on its lands.
The Tribe may impose its own water
pollution control priorities by establishing
Tribal regulations that are as (or more)
stringent than Federal regulations. In addi-
tion, the Tribe will implement the program
and carry out enforcement actions, as appro-
priate.
\
, ,.
17
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Administrative, Regulatory, and Technical
Capabilities
Administering an NPDES and/or sewage
sludge program provides important admin-
istrative, regulatory, and technical opportu-
nities for a Tribe. The process of obtaining
authorization to administer these programs
will:
• Broaden the scope of government,
• Build institutional capabilities, and
• Increase the Tribe's experience in:
4- Developing and overseeing large
programs, and
•$• Implementing an information man-
agement system.
These programs will enable all members of
the Tribe to gain an understanding of water
pollution and other environmental issues.
Tribal authority also imposes administra-
tive, regulatory, and technical burdens. For
example, the Tribe must write necessary
statutes and regulations. It may also need to
create or expand an independent bureau-
cracy to establish and regulate the NPDES
and/or sewage sludge program.
Tribal governments must ensure that regu-
latory and regulated entities are separate, in
order to avoid conflicts of interest when the
Tribe owns or operates a discharger or
sewage sludge facility that would be regu-
lated by the NPDES and/or sewage sludge
program. Tribes may also have to provide
training for engineers, attorneys, permit
writers, and other specialists needed to
manage effective and comprehensive pro-
grams.
Personnel and Financial Resources
Assuming responsibility for an NPDES
and/or sewage sludge program may have
material advantages for a Tribe. For ex-
ample, it may generate revenue from permit
fees and enforcement penalties. It may also
attract or discourage certain industry on
Tribal lands. Program authorization may
also provide job opportunities for Tribal
members.
18
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yf5-^1^ ^A/i
However, there may also be some disadvan- personnel. In addition, program revenues
tages to program assumption. For example, will not necessarily cover program costs and
program development entails certain costs, also will not be available until after the
such as the labor cost to develop the initial program is implemented.
submission and training costs for new
19
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Questions to Ask
Applying for Treatment in a Similar Manner
as a State and assuming authority for the
NPDES and/or sewage sludge program is
entirely voluntary. EPA recognizes that each
Tribe must evaluate its own circumstances.
The following questions outline the major
issues involved in seeking authorization and
managing an effective NPDES and/or
sewage sludge program. A Tribe's answers
to these questions may highlight possible
areas of concern before a Treatment in a
Similar Manner as a State application is
submitted or an NPDES and/or sewage
sludge program is developed.
• Do the Tribe and its members want to
expand the Tribal regulatory role and
ability to protect public health and the
environment?
• Does the Tribe have, or expect to de-
velop, the necessary infrastructure, and
is the Tribe prepared to promulgate
comprehensive NPDES and/or sewage
sludge regulations?
• Does the Tribe have the organizational
ability to develop and maintain an
independent regulatory body?
• Is the Tribe prepared to support this
type of program for many years?
• Does the Tribe have, or plan to attain,
the financial resources to support the
development and continued operation
of an NPDES and/or sewage sludge
program?
•$ Does the Tribe have the revenue to
hire and train the staff necessary to
run an NPDES and/or sewage sludge
program?
•^ Is the Tribe willing to commit to
long-term financial support of the
program?
9
9
9
20
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When to Apply for Authorization
A Tribe should seek authorization if, after
considering all of the benefits and costs, it
has determined that authorization is in its
best interest. Issues that should be consid-
ered include:
* The desire to further Tribal autonomy
and self-determination,
• The ability to play a larger role in the
protection of Tribal interests, and
• The strengthening of Tribal govern-
ment.
At the same time, the Tribe must consider
the need to develop and maintain the neces-
sary components of running an NPDES
and/or sewage sludge program. This may
include:
• Researching current environmental
statutes and regulations to determine
how they will affect the NPDES and/or
sewage sludge program and to identify
program needs,
• Enacting new statutes and regulations,
• Creating or expanding an organization
to run the program, and
• Hiring and training program personnel.
The Tribe must also consider the long-term
financial support of the program. The deci-
sion to seek authorization is one that will
have environmental and economic impacts
for many years.
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How Can a Federally Recognized Tribe Obtain
Authority to Operate an NPDES and/or Sewage
Sludge Program?
States (including Territories) and Tribes
may acquire authority for the NPDES
and/or sewage sludge programs under
Sections 402(b), 405, and 518 of the CWA. To
acquire this authority, a Tribe must:
• File for NPDES and/or sewage sludge
Treatment in a Similar Manner as a
State status. The Treatment in a Similar
Manner as a State application can be
filed simultaneously with an NPDES or
sewage sludge program application.
Tribes that have previously filed a
successful Treatment in a Similar Man-
ner as a State application for another
CWA or Safe Drinking Water Act
program may need only to update their
approved Treatment in a Similar Man-
ner as a State application.
• Develop necessary statutes and regula-
tions, a program description, a Memo-
randum of Agreement, and an Attorney
General's statement.
• After approval, receive authorization
and fully implement the programs.
Treatment in a Similar Manner as a State
Under the Clean Water Act
A Tribe must meet four criteria to be eligible
for Treatment in a Similar Manner as a
State:
• Existing substantial governmental
duties and powers,
• Defined jurisdiction over water re-
sources,
• Demonstrated Tribal capability, and
• Federal recognition by the U.S. Depart-
ment of the Interior.
Federal Recognition
To receive Treatment in a Similar Manner as
a State status, a Tribe must provide EPA
with certification that it is recognized as a
Tribe by the Department of the Interior.
Any Tribe on the list of Federally recog-
nized Tribes periodically published by the
Secretary of the Interior satisfies this re-
quirement. If a Tribe does not appear on the
Secretary's list because the list has not been
updated, the Tribe may provide appropriate
documentation to verify to EPA that it is
Federally recognized.
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Substantial Governmental Duties and
Powers
The Tribe must also demonstrate that it has
a governing body and the ability to carry
out the program for which it is seeking
authorization. EPA defines "substantial
governmental duties and powers" to mean
that the Tribe is currently performing gov-
ernmental functions to promote the public
health, safety, and welfare within a defined
geographical area. The Tribe may demon-
strate this by submitting a narrative state-
ment that:
• Describes the form of Tribal govern-
ment,
• Describes the essential governmental
functions performed (such as levying
taxes and exercising police power), and
• Identifies the legal authority for per-
forming these functions (e.g., the Tribal
constitution).
Jurisdiction Over Water Resources
The Tribe must further demonstrate legal
jurisdiction over water resources. In general,
these water resources will be located on
Tribal lands, but may, in some instances,
include those on trust land set apart for use
by American Indians. EPA suggests that
Tribes, in their Attorney General statements,
outline all bases for concluding that the
Tribe has adequate authority to regulate all
claimed water resources under the CWA.
Tribal Capability
Finally, the Tribe must demonstrate that it is
capable of effectively implementing the
program in a manner consistent with the
terms and purposes of the CWA and appli-
cable regulations.
The five factors that EPA will consider
when evaluating a Tribe's demonstration of
capability are:
• The Tribe's previous management
experience,
• Existing environmental or public health
programs it administers,
• Existing mechanism(s) to carry out the
executive, legislative, and judicial
functions of the Tribal government,
• The relationship between regulated
entities and the administrative agency
24
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of the Tribal government designated as
the primacy agency, and
• Establish procedures to implement
these authorities.
• The technical and administrative capa-
bilities of the staff to administer and
manage the program.
Tribes should note that this demonstration
does not change the traditional requirement
for assumption of an NPDES and/or sew-
age sludge program that the program be
fully effective at the time of approval.
If a Tribe satisfies these criteria and is found
eligible for Treatment in a Similar Manner
as a State, the Tribe is eligible to assume
NPDES and/or sewage sludge program
authority. All applicants for NPDES and/or
sewage sludge program authorization,
including States and Tribes, must meet
applicable NPDES and/or sewage sludge
program regulatory requirements.
NPDES and/or Sewage Sludge Program
Development
To develop an NPDES and/or sewage
sludge program, a Tribe must:
• Adopt Tribal legal authority (statutes
and regulations) that meets the mini-
mum Federal requirements, and
Because Tribal criminal authority is re-
stricted by Federal law, Tribes are not re-
quired to have comprehensive criminal
enforcement capabilities. (The rule establish-
ing requirements for Tribes to be Treated in
a Similar Manner as States includes provi-
sions requiring a Tribe to refer criminal
enforcement matters to the EPA Regional
Administrator in a timely and appropriate
manner when Tribal enforcement authority
does not exist.)
A Tribe must also develop capabilities to
implement the program. These may include:
• Providing training for engineers and
permit writers, or
• Sending such personnel to EPA- or
State-sponsored training courses.
Program development may also include
establishing a separate administrative
agency in order to ensure that a conflict of
interest does not arise between dischargers
or sewage sludge users or disposers and the
regulating agency.
25
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Procedure for Applying for NPDES and/or
Sewage Sludge Program Authorization
Tribes must submit a program request to
EPA for approval. The submittal must
include:
• A letter from the Tribe to EPA request-
ing authorization,
• A complete program description which
explains program operation and covers,
for example:
•$• Routine administrative procedures
and operation of the scope, structure,
coverage, and processes of the pro-
gram,
•$• A list of agencies which will have
responsibility for administering the
program and their organizational
charts and jurisdiction,
<• A list of the staff who will administer
the program, including the number
of employees, occupations, and
general duties of the staff,
•$• A workload analysis that estimates
the administrative and technical costs
of the program for its first two years,
•$• A description of the sources of fund-
ing for the first two years of the
program, including any estimate of
Federal funding,
•$• Copies of sample permits, applica-
tions, and reporting forms, and
•$• Descriptions of applicable Tribal
regulations or laws which address
the procedures for permitting, ad-
ministrative and judicial review,
compliance, and enforcement of
NPDES and/or sewage sludge pro-
gram permits.
Copies of applicable Tribal statutes and
regulations,
A signed Memorandum of Agreement
with the Regional Administrator con-
cerning cooperative program responsi-
bilities, and
A certification from the Tribal Attorney
General (or equivalent) that the Tribe
has adequate legal authority to admin-
ister the program.
26
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What Assistance Is Available to Tribes?
EPA will provide technical assistance to
Tribes interested in obtaining authori-
zation or desiring more information
about the NPDES and/or sewage sludge
programs. Types of available assistance
include:
• Regulation development support,
• Guidance on program submittals,
• Sample Treatment in a Similar Manner
as a State packages, and
• EPA Regional and Headquarters
NPDES and Sewage Sludge Program
Coordinators.
Regulation development support includes:
• Samples of appropriate language for
Tribal NPDES and/or sewage sludge
programs,
• A technical review by EPA personnel of
proposed Tribal statutes and regula-
tions, and
EPA Regional and Headquarters NPDES Program Coordinators
Region
I Coordinator
Region 1
(CT, ME, MA, NH, Rl, VT)
Region II
(NJ, NY, PR. VI)
Region III
(DE.DC, MD,PA,VA,WV)
Region IV
(AL, FL, GA, KY, MS, NC, SC, TN)
Region V
(IL, IN, Ml, MM, OH, Wl)
Region VI
(AR, LA, NM, OK, TX)
Region VII
(IA, KS, MO, NE)
Region VIII
(CO, MT, NO, SO. UT.WY)
Region IX
(AZ, CA, HI, NV, AS, GU)
Region X
(AK, ID, OR, WA)
EPA Headquarters
Doug Corb
Phil Sweeney
Ken Cox
Jim Patrick
Claudia
Johnson- Schultz
Jayne Fontenot
Don Toenslng
Janet Laoombe
Terry Oda
Linda Liu
Laura Phillips
617-565-3519
212-264-2911
215-597-8211
404-347-3012
31 2-886-61 OS
214-655-7190
913-551-7446
303-293-1593
415-744-1923
206-553-1447
202-260-9522
Water Management Division,
Wastewater Management Branch
Water Management Division, Water
Permits and Compliance Branch
Water Management Division,
Permits Enforcement Branch
Water Management Division,
Permits Section
Water Division
Water Management Division,
NPDES Permits Branch
Water Management Division,
Water Compliance Branch
Water Management Division,
NPDES Branch
Water Management Division,
Permits and Compliance Branch
Water Division,
Wastewater Management and
Enforcement Branch
Office of Wastewater Management,
NPDES Program Branch
27
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• In some cases, on-site support from
EPA personnel.
EPA will also provide guidance on program
submittals. For example, EPA could provide
Tribes with examples of successful program
submittals from small States. In addition,
EPA can provide sample Treatment in a
Similar Manner as a State applications.
The EPA Regional and Headquarters
NPDES and Sewage Sludge Program Coor-
dinators are also available to answer ques-
tions about the programs.
In addition, EPA has developed several
guidance documents on the NPDES and
sewage sludge programs. Information on
obtaining these documents is explained on
page 31.
EPA Regional and Headquarters Sewage Sludge
Region
1
Program Coordinators
Coordinator
Region 1
(CT, ME. MA. NH. Rl. VT)
Region II
(NJ, NY, PR. VI)
Region III
(DE.DC, MD.PA.VA.WV)
Region IV
(AL, FL, GA, KY, MS. NC, SC, TN)
Region V
(IL, IN, Ml, MN, OH. Wl)
Region VI
(AR, LA, NM. OK, TX)
Region VII
(IA, KS, MO, NE)
Region VIII
(CO. MT. NO. SD. UT.WY)
Region IX
(AZ, CA. HI, NV. AS, GU)
Region X
(AK, ID, OR, WA)
EPA Headquarters
Thelma Hamilton
AHaRoufaeaJ
AmCarkhuff
Vince Milter
AshSailad
Stephanie Kordzi
John Dunn
BobBrobsl
Lauren Fondahl
Dick Hetherington
Wendy Bell
617-565-3569
212-264-8663
215-597-9406
404-347-2391
312-886-6112
214-655-7520
913-551-7594
303-293-1627
415-744-1909
206-553-1941
202-260-9534
Water Management Division,
Municipal Evaluation Section
Water Management Division
Water Management Division,
Permits Enforcement Branch
Water Management Division,
Municipal Facilities Branch
Water Division,
Water Quality Branch
Water Management Division
Water Management Division,
Water Complance Branch
Water Management Division,
NPDES Branch
Water Management Division,
P retreat merit Section
Water Division,
Wastewater Management and
Enforcement Branch
Office of Wastewater Management,
Pretreatment and Multl-medte
Branch
28
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U.S. EPA Regional Offices
PUERTO
RICO
U.S. EPA Region 1:
U.S. EPA Region 2:
U.S. EPA Region 3:
U.S. EPA Region 4:
U.S. EPA Region 5:
U.S. EPA Region 6:
U.S. EPA Region 7:
U.S. EPA Region 8:
U.S. EPA Region 9:
U.S. EPA Region 10:
JFK Federal Building, One Congress Street, Boston, MA 02203
26 Federal Plaza, New York, NY 10278
841 Chestnut Building, Philadelphia, PA 19107
345 Courtland St., N.E., Atlanta, GA 30365
77 West Jackson Blvd., Chicago, IL 60604-3507
1445 Ross Ave., Suite 1200, Dallas, TX 75202-2733
726 Minnesota Ave., Kansas City, KS 66101
999 18th Street, Suite 500, Denver, CO 80202-2405
75 Hawthorne St., San Francisco, CA 94105
1200 Sixth Ave., Seattle, WA 98101
29
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Additional Resources
Unless otherwise indicated, to obtain a copy of the following documents, first contact the
EPA Office of Water Resource Center at the telephone number and address listed below. If
the document is not available from the Resource Center, then contact your Regional
NPDES or Sewage Sludge Program Coordinator (listed on pages 27 and 28).
Office of Water Resource Center
U.S. Environmental Protection Agency
Mail Code 4100
401 M Street SW
Washington, DC 20460
(202)260-7786
NPDES Program
• NPDES State Program Guidance (July 1986)
• Training Manual for NPDES Permit Writers (January 1993)
• Overview of the Storm Water Program (March 1993)
• NPDES Storm Water Program: Question and Answer Document, Volume 1 (Also
available from National Technical Information Service (NTIS), 1-800-553-6847; and
from Education Resources Information Center (ERIC), (614)292-6717), (EPA/833/F-93-
002), (March 1992)
• NPDES Storm Water Program: Question and Answer Document, Volume 2 (Also
available from NTIS and ERIC), (EPA/833/F-93-002B), (July 1993)
• EPA's Enforcement Management System (1989)
• Implementing State/Federal Partnerships in Enforcement (June 1984)
• Quarterly Non-Compliance Report (QNCR) Guidance (March 1986)
31
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• NPDES Compliance and Inspection Manual (May 1988)
Pretreatment Program
• Guidance on Development of Enforcement Response Plan (ERP) (September 1989)
• Industrial User Inspections/Sampling Manual for POTWs (April 1994)
• Industrial User Permitting Guidance Manual (Also available from NTTS and ERIC),
(EPA/833/R-89-001), (1990)
• Guidance Manual on the Development and Implementation of Local Discharge Limita-
tions Under the Pretreatment Program (Also available from NTIS and ERIC), (EPA/
833/B-87-202), (1987)
The National Sewage Sludge Program
* Part 503 Information Packet (Also available from National Small Flows Clearinghouse
(NSFC) #WWPCGN5O,1-800-624-8301), (1994)
• Sludge Compliance and Enforcement Strategy (Contact Regional Coordinator),
(May 1993)
• Environmental Regulations and Technology: Control of Pathogens and Vector Attrac-
tions in Sewage Sludge (Also available from Center for Environmental Research Infor-
mation (CERI), (513)569-7562), (EPA/625/R-92/013), (December 1992)
• POTW Sludge Sampling and Analysis Guidance Document (Only available from NTIS,
PB #93-227957), (August 1989)
• A Plain English Guide to the EPA Part 503 Biosolids Rule (July 1994)
32
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• Preparing Sewage Sludge for Land Application or Surface Disposal: A Guide for
Preparers of Sewage Sludge on the Monitoring, Recordkeeping, and Reporting Re-
quirements of the Federal Standards for the Use or Disposal of Sewage Sludge, 40 CFR
Part 503 (Also available from NSFC and NTIS)
• Surface Disposal of Sewage Sludge: A Guide for Owners/Operators of Surface Dis-
posal Facilities on the Monitoring, Recordkeeping, and Notification Requirements of
the Federal Standards for the Use or Disposal of Sewage Sludge, 40 CFR Part 503
(June 1994)
• Land Application of Sewage Sludge: A Guide for Land Appliers on the Recordkeeping
and Notification Requirements of the Federal Standards for the Use or Disposal of
Sewage Sludge, 40 CFR Part 503 (July 1994)
• Domestic Septage Regulatory Guidance: A Guide to the EPA Part 503 Rule (Also
available from NSFC, NTIS, and ERIC)
• State Sludge Management Program Guidance Manual (October 1990)
Indian-Specific Policy
• EPA Indian Policy (July 1984 and November 1984)
• Interim Guidance on Review of Indian Lands - Enforcement Actions (October 1992)
33
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SEPA
United States
Environmental Protection Agency
4203
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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