Assigned to NRAE & APPROP                                                                                 FOR CAUCUS & FLOOR ACTION

 

 


 

ARIZONA STATE SENATE

Phoenix, Arizona

 

REVISED

FACT SHEET FOR H.B. 2426

 

environment; NPDES program

(NOW: environment; water quality; AZPDES)

 

Purpose

 

                        Establishes the Arizona Pollutant Discharge Elimination System (AZPDES) program to be administered by the Arizona Department of Environmental Quality (ADEQ) and requires ADEQ to seek state primacy for the federal National Pollutant Discharge Elimination System permit program.  

 

Background

 

The federal Clean Water Act (CWA) requires the permitting of all point sources that directly discharge pollutants to navigable waters of the United States under a National Pollutant Discharge Elimination System (NPDES) permit.  Entities that discharge, such as mines, utilities and governmental jurisdictions, must apply for an NPDES permit from the United States Environmental Protection Agency (EPA).  The EPA currently administers this permitting program in states that do not have primacy for this permitting program.  NPDES permitting, compliance and enforcement decisions in Arizona are currently made in the EPA Region 9 office based in San Francisco, California.

  

All but six states currently have primacy for the NPDES program (Alaska. Arizona, Idaho, Massachusetts, New Hampshire and New Mexico).  In order for a state to be granted primacy for the NPDES program, the state must demonstrate its administering and enforcing agency has appropriate statutory authority.  Additionally, the state must enter into a Memorandum of Understanding with the EPA to assume primacy. The federal requirements are contained in section 402 (b) of the CWA.  

 

Under the NPDES program, the EPA does not assess permitting fees on the permittees.  H.B. 2426 prohibits ADEQ from charging any permit fees for the AZPDES program.  ADEQ estimates that implementing and enforcing the AZPDES program as established by H.B. 2426 will require nine new FTEs and will require funding of $472,400 in the first year (FY 2001-2002) and $432,500 in year two (FY 2002-2003).  There is no funding for the AZPDES program provided in H.B. 2426, however, full funding for FY 2001-2002 and FY 2002-2003 is currently included in the budget adopted by the Legislature, subject to enactment (S.B. 1578/H.B. 2631).

 


Provisions

 

AZPDES  (Arizona Pollutant Discharge Elimination Program)

 

1.      Requires the Director of ADEQ to adopt rules to establish an AZPDES program consistent with requirements of the CWA relating to state permit programs and municipal and industrial stormwater discharges. The program shall include requirements to ensure compliance with the toxic and pretreatment effluent standards of the CWA and requirements for the control of discharges consistent with CWA requirements relating to aquaculture and the disposal and use of sewage sludge. (Section 49-255.01)

 

2.      Requires the AZPDES rules, except for procedural rules, to be consistent with, but no more stringent than the requirements of, the CWA and to provide for:  (Sections 49-203 and 49-255.01)

 

·        Issuing, authorizing, denying, modifying, suspending or revoking permits.

·        The establishment of permit conditions and discharge limitations.

·        Other provisions necessary for maintaining primacy under the CWA.

·        Modifications and variances as allowed by the CWA.

·        Other rules necessary for maintaining state primacy of the program.

 

3.      Allows the Director to adopt either the federal NPDES rules by incorporation by reference, or rules that reflect local environmental conditions as long as they are consistent with and no more stringent than the CWA and this act.   (Section 49-255.01)

 

4.      Provides that existing ADEQ rules relating to the NPDES program remain in effect until the AZPDES rules are adopted. (Section 49-255.01)

 

5.      Prohibits ADEQ from charging any fees to issue, deny, modify, suspend or revoke a permit or to process permit applications.  (Section 49-255.01)

 

6.      Specifies that an “upset” is an affirmative defense to any criminal, civil or administrative enforcement action brought for noncompliance with technology-based permit discharge limitations if the permittee proves by a preponderance of the evidence that the upset condition occurred and properly signs logs or other relevant evidence that:   (Section 49-255.01)

 

·        An upset occurred and the permittee can identify the cause of the upset.

·        The permitted facility was being properly operated at the time of the upset.

·        ADEQ was notified within 24 hours of an upset in which discharge exceeded any discharge limitation.

·        Proper remedial measures have been taken to minimize the effects on human health or the environment.

 

7.      Defines an “upset” to mean an exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit discharge limitations because of factors that are beyond the reasonable control of the permittee and does not include noncompliance to the extent it is caused by operational error, improper facility design or inadequate facilities, lack of preventative maintenance or improper care. (Section 49-255)

 

8.      Prohibits an AZPDES permit from being combined with an aquifer protection permit. (Section 49-255.01)

 

9.      Specifies that a decision of the Director to issue or modify a permit takes effect on issuance if there were no changes requested to the draft permit unless a later date is specified in the decision.  In all other cases, a permit decision by the Director takes effect 30 days after the decision is served on the permit applicant unless an appeal is filed with the Water Quality Appeals Board within the 30-day period. (Section 49-255.01)

 

10.  Provides that compliance with an AZPDES permit shall be deemed compliance with:  (Section 49-255.01)

 

·        All requirements of CWA relating to effluent and water quality limitations, national performance standards and toxic and pretreatment effluent standards, except for any standard for a toxic pollutant that is injurious to human health.

·        Limitations for pollutants in state aquifer water quality standards and water quality standards for navigable waters provided the discharge is specifically limited in an AZPDES permit or the pollutant was specifically identified as present or potentially present in facility discharges during the permit application process.

 

11.  Allows ADEQ to require AZPDES permittees to maintain records and to sample and monitor for discharges or sewage sludge use or disposal. (Section 49-203)

 

12.  Requires additional permit information to be made available to the public under the AZPDES program, including information required in a permit application, the frequency, temperature and pH of the discharge, as well as other water quality characteristics required to be reported under the permit.  (Section 49-205)

 

Pretreatment Program  (Section 49-255.02)

 

13.  Requires the Director to adopt rules for a pretreatment program that is consistent with the toxic and pretreatment effluent standards and reporting and inspection requirements of the CWA, as well as Section 402 of the CWA.   The rules must address:

 

a)      Development or modification of local pretreatment programs by the owners of treatment works that discharge, or as otherwise required to prevent the use or disposal of sludge produced by the works in violation of the CWA or the sewage sludge rules.

b)      Approval by the Director of new or modified local pretreatment programs or site specific modifications to pretreatment standards.

c)      Oversight of local program implementation.

 

14.  Specifies that the rules must ensure that any industrial user of publicly owned treatment works will comply with the toxic and pretreatment effluent standards and reporting and inspection requirements of the CWA.

 

Sewage Sludge Program  (Section 49-255.03)

 

15.  Requires the Director to adopt rules for a sewage sludge program consistent with the requirements of the CWA relating to the disposal or use of sewage sludge.  Defines sewage sludge to mean solid and/or liquid residue and includes materials removed in the treatment processes. It does not include ash from a sludge incinerator. (Sections 49-255 and 49-255.03)

 

16.  Establishes criminal penalties for specified offenses under the sludge program that are to be enforced by the Attorney General.  The following criminally negligent violations of the following are subject to a class 1 misdemeanor: (Section 49-263.02)

 

·        Application of sludge in violation of rules.

·        Violation of standards or limitations.

·        Violation of permit conditions or other authorizations.

·        Failure to comply with filing or reporting requirements.

·        Alteration, modification or destruction of monitoring devices (*class 5 felony  for “knowing violation”).

·        Failure to maintain, operate or repair monitoring devices or install monitoring devices required by a permit (*class 5 felony for “knowing violation”).

·        Failure to discharge without a permit or appropriate authority.

 

17.  Specifies that each day of violation constitutes a separate offense.

 

Enforcement and Penalties - AZPDES

 

Compliance Orders (Section 49-261)

 

18.  Allows the Director of ADEQ to issue compliance orders for violations of AZPDES laws, rules, permit conditions or discharge limitations, or, if a person is creating an imminent and substantial endangerment to the public health or environment.

 

Injunctive Relief and Civil Penalties (Section 49-262)

 

19.  Specifies that violations of the AZPDES program are subject to injunctive relief and civil penalties under the existing state water quality law.  These violations include violations of program laws, rules, permit requirements, discharge limitations or when a person is creating an actual or potential endangerment to public health or the environment.  Civil penalties are not to exceed $25,000 per day per violation.

 

20.  Requires the court to consider the following factors in determining the amount of civil penalties relating to violations of the APP or AZPDES program:

 

·        The seriousness of the violation(s).

·        The economic benefit, if any that results from the violation.

·        Any history of similar violations.

·        Any good faith efforts to comply with the applicable requirements.

·        The economic impact of the penalty on the violator.

·        The extent to which the violation was caused by a third party.

·        Other matters as justice may require.

 

21.  Specifies that a single operational upset that leads to simultaneous violations of more than one pollutant limitation in a permit issued or authorized pursuant the rules and standards of the AZPDES program, constitutes a single violation for purposes of any penalty calculation.   

 

22.  Stipulates that if a permittee holds an APP and AZPDES and violates a similar provision in both permits simultaneously, the agency cannot recover penalties for violations of both permits based on the same act.

 

Criminal Penalties (Section 49-263.01)

 

23.  Establishes the following reckless violations as class 6 felonies under the AZPDES program (“knowing” violations are class 5 felonies):

 

·        Discharging without a permit.

·        Failure to monitor, sample or report discharges.

·        Violation of a permit discharge limitation or standard.

·        Alternation or modification of monitoring devices or sampling methods to be inaccurate.

·        Failure to install, maintain and operate monitoring devices.

·        Bypassing waste streams from treatment works resulting in a discharge.

·        Violation of a compliance order.

         

24.  Establishes as class 1 misdemeanors for criminally negligent violations of permit conditions, standards, limits, and filing or reporting requirements.

 

25.  Establishes a class 5 felony for a person who knowingly introduces pollutants or hazardous substances into a sewer system or treatment works if the person knew personal injury or property could be caused or if it causes a violation of a discharge limitation or permit condition.

 

26.  Establishes a class 5 felony for a person who knowingly violates a state, local or federal pretreatment standard or requirement that is required under the AZPDES program.

         

27.  Specifies that a person who knowingly or recklessly manifests extreme indifference for human life in performing acts that are subject to prosecution under the AZPDES program is subject to a class 2 felony.  Specifies criteria for determining if a person is subject to prosecution for a class 2 felony and establishes an affirmative defense to prosecution that can be met by a preponderance of the evidence.

 

28.  Specifies that for all criminal violations under the AZPDES program, each day of violation constitutes a separate offense

 

29.  Requires the Attorney General to enforce the criminal violations of the AZPDES program.

 

Water Quality Appeals Board  (WQAB)

 

30.  Modifies the existing limitation on membership in the WQAB that prohibits persons from being members if they who have been employed by entities that are subject to state water quality permits during the two years prior to their appointment.  Further restricts the existing exemption from this employment disqualifier for public employees to allow only employees of state agencies to serve on the Board.  (Section 49-322)

 

31.  Requires the Board to hold a hearing if questions of material fact are at issue in the appeal. (Section 49-323)

 

32.  Modifies the standard under which a person may appeal a decision by ADEQ under the APP or AZPDES programs to allow appeals by any person who will be adversely affected by the action or may with reasonable probability be adversely affected by the decision.  The person must have also exercised the person’s right to comment on the action. (Section 49-323)

 

33.  Provides that notwithstanding the provisions of the Administrative Procedures Act relating to actions on licenses and opportunities for hearing, if an AZPDES permit is appealed, the permit provisions that are specifically identified in the notice of appeal as being contested and those other permit provisions that cannot be severed from the contested provisions are automatically stayed while the appeal is pending.  (Section 49-324)

 

34.  Stipulates that any uncontested permit provisions that are severable from the contested provisions are effective and enforceable 30 days after the Director serves notice on an applicant, the WQAB and any party who commented on the proposed action of the conditions that are uncontested and severable.  (Section 49-324)

 

Miscellaneous

 

35.  Defines terms relating to the AZPDES program.  (Section 49-255)

 

36.  Authorizes ADEQ, upon presentation of credentials, to enter property where sludge is disposed or applied where AZPDES-regulated treatments occur and where records relating to a discharge or records required to be maintained by state water quality laws are kept.    (Section 49-203)

 

37.  Exempts the AZPDES program from the requirement that new programs established by the Legislature must have an expiration date of not more than ten years. (Section 49-255.01)

 

38.  Limits any permit condition concerning threatened or endangered species to only those conditions required by the federal Endangered Species Act.  (Section 49-255.01)

 

39.  Provides that beginning on the date of approval by the EPA, ADEQ shall process all requests to modify or renew an existing NPDES permit or issue a new AZPDES permit.  If the application was submitted to EPA before the approval, the applicant may choose to continue the application with the EPA or ADEQ.   (Section 13, session law)

 

40.  Requires ADEQ to provide at least 30 days for written public comment before submitting the Memorandum of Agreement to the EPA, which is required as a condition of obtaining state primacy.  The Governor’s Regulatory Review Council shall hold a hearing to evaluate whether the memorandum is consistent with legislative intent and ADEQ's statutory authority.  (Section 14, session law)

 

41.  Stipulates that if the EPA approves the AZPDES program, the appropriate committee of reference (COR) on environmental matters shall hold at least one public hearing within five years of the date of that approval to evaluate the effectiveness of the program and to evaluate whether it is being implemented in a manner consistent with legislative intent. The COR shall also recommend any necessary changes to improve the program in its report to the Joint Legislative Audit Committee and to ADEQ .  (Section 15, session law)  

 

42.  Allows the COR to request specified information from ADEQ for the evaluation including information on number of permits issued, the number of permit appeals and their disposition, the number of permits assumed by the EPA and the number of enforcement actions taken by ADEQ or the EPA and their resolution.

 

43.  Specifies that while all EPA regulatory documents under the NPDES program have no force of law in Arizona once the AZPDES  program is established, EPA documents may be used by ADEQ and regulated entities in negotiating permit conditions and interpretations of program requirements. (Section 16, session law)

 

44.  Provides a legislative intent clause. (Section 17, session law)

 

45.  Makes other technical and conforming changes.

 

46.  Provides for a general effective date.

 

Amendments Adopted by NRAE Committee

 

1.      Authorizes ADEQ to have access to any property where sewage sludge is being disposed or is being subject to land application, or any property where any AZPDES regulated treatment is taking place. 

 

2.      Clarifies that information required to be submitted for an AZPDES permit must be made available to the public.

 

3.      Specifies that rules adopted by ADEQ for the pretreatment program relating to local pretreatment programs for publicly owned treatment works, address requirements of the CWA or state law to prevent the use or disposal of sewage sludge in violation of Section 405 of the CWA or the state sewage sludge program.

4.      Specifies that for purposes of calculating a civil penalty for simultaneous violations of more than one pollutant limitation in a permit resulting from a single operational upset, this event is determined to be a single violation.

 

5.      Specifies that the criminal penalties apply to only those persons subject to the AZPDES program and the pretreatment program.

 

6.      Provides criteria to be used in determining whether a person who is subject to prosecution for a class 2 felony, knowingly or recklessly manifested an extreme indifference for human life.  Establishes an affirmative defense for prosecution for a class 2 felony and allows such defense to be established by a preponderance of the evidence.

 

7.      Establishes a class 5 felony for a person who knowingly introduces pollutants or hazardous substances into a sewer system or treatment works if the person knew personal injury or property could be caused or if it causes a violation of a discharge limitation or permit condition.

 

8.      Establishes a class 5 felony for a person who knowingly violates a state, local or federal pretreatment standard or requirement that is required under the AZPDES program.

 

9.      Establishes an additional criminal penalty under the sewage sludge program (class 5 felony for a knowing violation or class 1 misdemeanor for criminal negligence) for discharging without an AZPDES permit or appropriate authority under the AZPDES program.

 

10.  Modifies the standard under which a person may appeal a decision by ADEQ under the APP or AZPDES programs to allow appeals by any person who may with reasonable probability be adversely affected by the decision.  The person must have also exercised their right to comment on the action.

 

11.  Makes several technical and clarifying changes.

 

House Action                                                                  Senate Action

 

ENV                2/13/01            DPA/SE      7-1-1-1       NRAE           4/5/01       DPA    7-1-0-0

CM                  3/6/01              DPA/SE      7-2-1-0       APPROP      4/10/01     DP       12-0-0-0

3rd Read           3/19/01                                31-25-4-0                                   

 

 

Prepared by Senate Staff

April 16, 2001