Portable Sanitation Association International

Association Insight October 19 2016

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W EEKLY EDITION OCT 19, 2016 Portable Sanitation and the EPA …continued Part I particular sewage constituent might be. Sometimes they want advice because their disposal facil ity has told them, "EPA won't accept this level of magnesium" or a contractor on a job site says, "EPA requires containment pans so you have to provide them." With so much confusing information around, it seems important for operators and suppliers of deod orizers/cleaners to understand how EPA does – and doesn't – affect your company. • EPA has no rules specific to portable sanitation. You can search EPA's website, call the agency, and read the CFR – the Code of Federal Regulations , and you'll find the same thing. EPA does not specifically regulate portable sanitation. EPA focuses the bigger picture. So, for example, EPA sets wastewater standards in general, sets water quality standards for all contaminants in surface water regardless of the source of the con taminants , and EPA makes it unlawful to discharge any pollutant from a point source into navigable waters. Its rules apply to every industry, not just portable sanitation. • Local agencies, local rules. The EPA works through state and local level authorities to carry out the requirements of the Clean Water Act, but local authorities create the policies, guidance, and local ordinances that industry lives by. What these turn out to be depends on a variety of factors. Each area's leaders have to determine what m easures need to be in place to ensure their water meets EPA's minimum standards – and this will vary depending upon the conditions on the ground. Waterways that have been grossly polluted for years, or those downstream from an industrial area face differen t challenges in meeting EPA requirements than areas that are comparatively rural and unpolluted. Sometimes unforeseen factors can influence water quality also. The recent situation in Flint, Michigan is an example of this. The local leaders put procedures in place for water that would have met EPA limits with a slight margin for variation. Unfortunately, the degradation of the pipes carrying the city's water resulted in num bers that were well above E PA's limits for lead . P AGE 2 CONTINUED ON PAGE 3

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