Emails
regarding
Streamlining
Pretreatment
Rule
from
Kevin
Bromberg,
Small
Business
Administration
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
06/
16/
2005
11:
40
AM
To:
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
"'
jlaity@
omb.
eop.
gov'"
<
jlaity@
omb.
eop.
gov>,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA
Cc:

Subject:
Chicago
POTW
Project
XL
http://
www.
epa.
gov/
projectxl/
mwrd/
chicfpa9.
pdf
This
is
the
project
agreement
for
Chicago
Project
XL/

In
the
excerpt
below,
you
will
see
that
the
Chicago
project
adopted
the
AMSA
1999
middle
tier
approach
verbatim
and
declared
it
"
consistent"
with
the
EPA
1999
streamlining
proposal.
EPA
Region
V
signed
this
agreement,
so
we
assume
that
EPA
HQ
also
agreed
with
this
determination.
In
October
2001,
in
the
final
rule
granting
the
authority
to
the
Chicago
POTW
to
provide
streamlining
relief,
EPA
received
only
three
comments
on
the
AMSA
approach
­
two
approving
it,
and
one
addressing
another
a
separate
unrelated
matter.
This
Chicago
material
should
be
placed
in
the
record
for
this
rulemaking.

The
Chicago
program
was
terminated
because
it
was
too
expensive
to
run
this
program,
and
Chicago
wasn't
getting
any
support
for
the
program.
Chicago
also
ended
up
not
using
the
flexibility
for
monitoring
for
itself
­
performed
monitoring
2X
year
for
all
NCIUs
and
CIUs
­
and
therefore
the
POTW
didn't
benefit
from
the
reductions,
only
the
users.
The
contact
person
at
Chicago
didn't
really
know
why
the
frequency
was
not
reduced
as
per
the
agreement.
His
predecessor,
Rich
Sustich,
who
was
more
knowledgeable
retired
last
year.

"
1.
Reduced
Oversight
of
De
Minimis
and
Non­
Significant
Categorical
Industrial
Users
This
project
is
intended
to
provide
regulatory
flexibility
to
the
District
with
respect
to
the
oversight
of
small
CIUs
that
have
very
low
potential
to
violate
Pretreatment
Standards
and
Requirements
or
adversely
impact
the
operations
of
the
District's
WRPs
and
the
environment.
Under
current
regulations
all
CIUs
are
classified
as
SIUs.
This
pilot
project
creates
two
categories
of
CIU
that
are
not
significant
industrial
users
(
SIU).
For
purposes
of
this
project
there
are
two
categories
of
small
CIUs:
(
1)
de
minimis
and
(
2)
non­
significant
categorical
industrial
users.
Currently,
the
District
receives
wastewater
from
358
CIUs.
In
this
XL
project,
the
District
is
seeking
to
reduce
the
oversight
requirements
for
"
de
minimis"
and
"
non­
significant"
CIU
facilities.
This
part
of
the
XL
proposal
is
consistent
with
EPA's
proposal
regarding
"
non­
significant"
categorical
industrial
users
in
its
July
22,
1999,
Pretreatment
Streamlining
Proposal
(
64
FR
39564).
These
reduced
oversight
requirements
will
not
deregulate
any
CIU
in
the
sense
that
they
are
no
longer
required
to
comply
with
Categorical
Pretreatment
Standards.
Rather,
this
approach
will
reduce
both
the
CIU's
and
the
District's
burden
in
demonstrating
compliance
with
the
applicable
standards.

A
CIU
will
be
considered
as
de
minimis
if
it
discharges
no
untreated
categorical
wastewater
and
it
discharges
a
total
of
less
than
100
gallons
per
day
of
process
wastewater,
or
if
it
is
only
subject
to
certification
requirements
of
applicable
categorical
standards.
In
addition,
the
CIU
will
not
have
been
in
significant
noncompliance
(
SNC),
as
defined
at
40
CFR
403.3(
t),
with
applicable
effluent
discharge
standards
or
requirements
for
the
prior
eight
consecutive
calendar
quarters.
The
oversight
reductions
for
those
CIUs
that
meet
the
de
minimis
criteria
would
include:
*
Non­
expiring
Discharge
Authorizations
(
DAs)
*
Reduction
in
frequency
of
self­
monitoring
from
twice
per
year
to
at
the
District's
discretion.
These
CIUs
would
be
required
to
report
annually
to
verify
their
de
minimis
status.
*
The
District
will
perform
a
minimum
of
one
random
site
visit
annually.
The
site
visit
will
include,
at
a
minimum,
verification
of
proper
operation
of
wastewater
pretreatment
facilities
necessary
to
maintain
compliance
with
applicable
standards
and
a
grab
sampling
of
the
CIU's
discharge
to
the
sewerage
system.

The
District
is
also
seeking
reduced
oversight
requirements
for
small
capacity
"
non­
significant,"
CIUs.
To
qualify
as
a
non­
significant
CIU,
the
process
wastewater
subject
to
Categorical
Pretreatment
Standards
that
is
discharged
from
the
facility:
*
Shall
not
exceed
0.01
percent
of
the
hydraulic
capacity
of
the
receiving
WRP
or
10,000
gallons
per
day,
whichever
is
less,
*
Shall
not
exceed
0.01
percent
of
the
organic
treatment
capacity
of
the
receiving
WRP,
and
*
Shall
not,
for
all
applicable
pollutants,
exceed
0.01
percent
of
the
five­
year
average
headworks
loading
at
the
receiving
WRP.
The
maximum
allowable
discharge
criteria
for
non­
significant
CIUs
tributary
to
each
of
the
District's
seven
WRPs
are
shown
in
Appendix
I.

In
addition:
*
The
CIU
will
not
have
been
in
significant
noncompliance
(
SNC),
as
defined
at
40
CFR
403.3(
t),
with
applicable
effluent
discharge
standards
or
requirements
for
the
prior
eight
consecutive
calendar
quarters.
The
District
will
reassess
conformance
of
each
non­
significant
CIU
with
the
above
four
criteria
at
least
annually.
The
oversight
reductions
for
those
CIUs
that
meet
the
non­
significant
criteria
would
include:

*
Non­
expiring
Discharge
Authorizations
(
DAs)
*
Reduction
in
frequency
of
self­
monitoring
and
submittal
of
compliance
reports
from
twice
per
year
to
once
per
year
*
Reduction
in
frequency
of
full
facility
inspection
and
sampling
by
the
District
from
once
per
year
to
once
every
two
years
*
During
non­
inspection
years,
the
District
will
perform
a
minimum
of
one
random
site
visit
and
sampling.

Conformance
with
the
conditions
set
forth
in
the
definitions
of
de
minimis
and
non­
significant
CIU
will
be
reassessed
at
least
annually
by
the
POTW.
If
a
facility
no
longer
falls
within
the
scope
of
the
de
minimis
or
non­
significant
CIU
definition
because
of
a
change
in
the
nature
of
its
operations
or
if
the
facility
is
found
in
significant
noncompliance
(
SNC),
the
facility's
status
as
a
de
minimis
or
non­
significant
CIU
will
be
revoked
and
the
facility
will
revert
to
full
CIU
status.
The
District
estimates
that
80
of
the
358
CIUs
currently
regulated
under
the
District's
Pretreatment
Program
would
qualify
for
de
minimis
or
nonsignificant
status.
At
the
time
of
FPA
signature,
it
is
estimated
that
2
of
these
80
CIUs
would
qualify
as
de
minimis
and
78
of
these
80
CIUs
would
qualify
as
non­
significant."
<<
chicfpa9.
url>>

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[
Attachment
chicfpa9.
url
removed]

"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
06/
16/
2005
12:
15
PM
To:
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
"'
jlaity@
omb.
eop.
gov'"
<
jlaity@
omb.
eop.
gov>,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA
Cc:

Subject:
FW:
updated
CIU
data
from
AMSA
From
the
survey
at
the
POTWs
themselves
­
AMSA
calculates
4.5%
(
really
4.6%)
under
100
gpd
among
nonzero
discharges
­
an
additional
4.4%,
for
a
total
of
9%.
This
was
a
sample
of
42
(
by
my
count)
individual
POTWs
and
in
one
case
one
statewide
number
(
North
Carolina).
These
numbers
are
consistent
with
what
AMSA
believed
was
in
the
universe.

I
would
guess
that
more
accurate
numbers
are
provided
for
Denver,
CO
and
Colorado
Springs,
CO
by
these
contacts
than
the
EPA
contacts
(
see
below).
Denver
was
missing
about
10
CIUs.

Kevin
­­­­­
Original
Message­­­­­
From:
Will
Pettit
[
mailto:
wpettit@
nacwa.
org]
Sent:
Thursday,
June
16,
2005
11:
54
AM
To:
Aydlett,
Guy;
kevin.
bromberg@
sba.
gov
Subject:
updated
CIU
data
Gentleman,
I've
got
some
great
data
from
our
members
and
other
POTWs
around
the
country
on
this
CIU
issue.

From
the
responses
I've
gotten
so
far,
out
of
2375
CIUs
only
109
would
qualify
for
the
<
100
GPD
cutoff.
That's
4.5%!
Not
much
of
a
saving...

First,
I'll
hit
the
big
ones,
especially
those
that
EPA
has
specifically
cited.

Denver,
CO
We
currently
have
37
permitted
CIUs
and
of
those
only
2
consistently
discharges
less
than
100
gallons
per
day
and
are
actually
in
process
of
eliminating
categorical
process,
so
once
chemicals
and
equipment
are
eliminated,
permits
will
be
terminated.

We
also
have
45
zero
discharge
CIUs
with
a
majority
of
them
having
less
than
100
gallons
a
day
of
wastewater
generated.
These
facilities
have
either
installed
evaporators,
or
recycle
the
wastewater
or
have
it
hauled
off­
site;
a
few
don't
generate
any
wastewater
from
their
process
operations.
Also,
we
have
a
handful
of
small
batch
dischargers
(
250­
500
gallons
a
day
of
dischargers)
that
have
gone
to
a
batch
mode
and
may
only
discharge
once
or
twice
a
week
(
or
in
1
case
­
1/
quarter)
because
their
discharge
was
so
low
we
could
not
collect
good
representative
samples.
However,
if
discharging
less
than
100
gallons
a
day
would
get
them
out
of
categorical
regulations,
I'm
sure
they
would
be
requesting
us
to
modify
their
discharge
practices
so
they
would
fall
under
that
deminimus
exclusion.

EPA's
number
for
Denver
was
72
CIUs,
with
44
<
100
GPD.
That
number
is
seriously
flawed.

Colorado
Springs,
CO
Number
in
Pretreatment
Program
Zero
Discharge
1
to
100
gal.
process/
day
Total
less
than
100
gpd
process
CIU
33
4
3
7
Non
CIU
5
1
1
EPA's
number
for
Colorado
Springs
was
34
CIUs,
with
11
<
100
GPD.
Again,
completely
incorrect.

NOTE:
It
is
important
to
know
that
a
"
permit"
for
zero
dischargers
is
NOT
done
nationwide.
Only
a
handful
of
POTWs
actually
permit
them
and
if
they
do,
it's
nothing
like
the
permit
for
a
discharger.
Inspections
are
usually
only
done
once
to
verify
they
are
zero.
Once
verified,
all
they
get
is
an
annual
self­
certification.
If
zero
dischargers
are
included
in
this
rule
the
savings
would
be
absolutely
negligible
and
especially
cannot
be
included
as
any
real
savings
for
the
POTW.
Most
POTWs
don't
even
consider
them
to
be
SIUs
since
they
don't
discharge
anything.

Here
is
the
data
from
all
the
responses
I
received.
Location
CIUs
<
100
ZD
Chesterfield
County,
VA
12
0
0
Tampa,
FL
14
0
0
Charlotte­
Mecklenburg,
NC
36
0
0
Ocean
County
Utilities
Authority
10
1
0
Monroe
County
33
0
0
King
County,
WA
70
1
0
Anchorage,
AK
2
0
0
Spokane,
WA
11
1
0
Clean
Water
Services,
OR
45
3
8
Wichita,
KS
34
2
0
Portland,
OR
39
0
0
United
Water,
Burbank,
CA
46
0
0
Manchester,
NH
10
5
0
Fort
Worth,
TX
60
0
0
State
of
North
Carolina
342
4
0
Tacoma,
WA
11
0
0
Springfield,
MO
24
0
0
Syracuse,
UT
7
0
0
Austin,
TX
25
3
0
Troy,
OH
5
0
0
Littleton/
Englewood,
CO
9
0
0
Howard
County,
MD
9
1
0
Greenville,
SC
52
0
0
Colorado
Springs,
CO
33
3
4
Washington
Suburban
Sanitary
Commission
14
2
0
Hampton
Roads
Sanitation
District
25
0
0
Los
Angeles
County
Sanitation
District
544
25
0
Norman,
OK
3
0
0
Beloit,
WI
6
0
0
JEA
21
3
0
Northeast
Ohio
Regional
Sewer
District
141
14
0
Madison,
WI
19
0
0
St.
Louis,
MO
152
20
28
Denver,
CO
37
2
45
Phoenix,
AZ
57
3
0
St.
Paul/
Minneapolis,
MN
203
1
0
Rockford,
IL
39
0
0
Broward
County,
FL
13
0
0
Suffolk
County,
NY
62
13
18
Oroville,
CA
3
0
0
Ft.
Lauderdale,
FL
6
0
0
Passaic
Valley
Sewerage
Commissioners,
NJ
91
2
0
Total
2375
109
103
Will
Pettit
Manager,
Regulatory
Affairs
National
Association
of
Clean
Water
Agencies
1816
Jefferson
Place,
N.
W.
Washington,
D.
C.
20036­
2505
Phone:
(
202)
833­
3280
Fax:
(
202)
833­
4657
Internet:
www.
nacwa.
org
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
06/
16/
2005
12:
30
PM
To:
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
"'
jlaity@
omb.
eop.
gov'"
<
jlaity@
omb.
eop.
gov>,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA
Cc:
Subject:
RE:
updated
CIU
data
from
AMSA
Correction
­
Denver's
number
was
87,
not
72
(
my
error
in
reporting
this
to
AMSA).
Denver's
two
sets
of
numbers
are
now
very
comparable.
Denver
(
POTW)
is
reporting
82
below.
The
44
<
100
gpd
(
EPA)
closely
matches
Denver
(
POTWs)
observation
of
45
zero
dischargers
and
2
<
100
gpd.
These
figures
really
confirm
each
other.
The
main
lesson
here
is
the
large
preponderance
of
zero
discharges
45
or
47
<
100
gpd.

­­­­­
Original
Message­­­­­
From:
Bromberg,
Kevin
L.
Sent:
Thursday,
June
16,
2005
12:
15
PM
To:
'
Cristofaro.
Alexander@
epamail.
epa.
gov';
'
Schaner.
Greg@
epamail.
epa.
gov';
'
Schaaff.
Lesley@
epamail.
epa.
gov';
'
jlaity@
omb.
eop.
gov';
'
Nagle.
Deborah@
epamail.
epa.
gov';
'
Boornazian.
Linda@
epamail.
epa.
gov'
Subject:
FW:
updated
CIU
data
from
AMSA
From
the
survey
at
the
POTWs
themselves
­
AMSA
calculates
4.5%
(
really
4.6%)
under
100
gpd
among
nonzero
discharges
­
an
additional
4.4%,
for
a
total
of
9%.
This
was
a
sample
of
42
(
by
my
count)
individual
POTWs
and
in
one
case
one
statewide
number
(
North
Carolina).
These
numbers
are
consistent
with
what
AMSA
believed
was
in
the
universe.

I
would
guess
that
more
accurate
numbers
are
provided
for
Denver,
CO
and
Colorado
Springs,
CO
by
these
contacts
than
the
EPA
contacts
(
see
below).
Denver
was
missing
about
10
CIUs.

Kevin
­­­­­
Original
Message­­­­­
From:
Will
Pettit
[
mailto:
wpettit@
nacwa.
org]
Sent:
Thursday,
June
16,
2005
11:
54
AM
To:
Aydlett,
Guy;
kevin.
bromberg@
sba.
gov
Subject:
updated
CIU
data
Gentleman,
I've
got
some
great
data
from
our
members
and
other
POTWs
around
the
country
on
this
CIU
issue.

From
the
responses
I've
gotten
so
far,
out
of
2375
CIUs
only
109
would
qualify
for
the
<
100
GPD
cutoff.
That's
4.5%!
Not
much
of
a
saving...

First,
I'll
hit
the
big
ones,
especially
those
that
EPA
has
specifically
cited.

Denver,
CO
We
currently
have
37
permitted
CIUs
and
of
those
only
2
consistently
discharges
less
than
100
gallons
per
day
and
are
actually
in
process
of
eliminating
categorical
process,
so
once
chemicals
and
equipment
are
eliminated,
permits
will
be
terminated.
We
also
have
45
zero
discharge
CIUs
with
a
majority
of
them
having
less
than
100
gallons
a
day
of
wastewater
generated.
These
facilities
have
either
installed
evaporators,
or
recycle
the
wastewater
or
have
it
hauled
off­
site;
a
few
don't
generate
any
wastewater
from
their
process
operations.

Also,
we
have
a
handful
of
small
batch
dischargers
(
250­
500
gallons
a
day
of
dischargers)
that
have
gone
to
a
batch
mode
and
may
only
discharge
once
or
twice
a
week
(
or
in
1
case
­
1/
quarter)
because
their
discharge
was
so
low
we
could
not
collect
good
representative
samples.
However,
if
discharging
less
than
100
gallons
a
day
would
get
them
out
of
categorical
regulations,
I'm
sure
they
would
be
requesting
us
to
modify
their
discharge
practices
so
they
would
fall
under
that
deminimus
exclusion.

EPA's
number
for
Denver
was
72
CIUs,
with
44
<
100
GPD.
That
number
is
seriously
flawed.

Colorado
Springs,
CO
Number
in
Pretreatment
Program
Zero
Discharge
1
to
100
gal.
process/
day
Total
less
than
100
gpd
process
CIU
33
4
3
7
Non
CIU
5
1
1
EPA's
number
for
Colorado
Springs
was
34
CIUs,
with
11
<
100
GPD.
Again,
completely
incorrect.

NOTE:
It
is
important
to
know
that
a
"
permit"
for
zero
dischargers
is
NOT
done
nationwide.
Only
a
handful
of
POTWs
actually
permit
them
and
if
they
do,
it's
nothing
like
the
permit
for
a
discharger.
Inspections
are
usually
only
done
once
to
verify
they
are
zero.
Once
verified,
all
they
get
is
an
annual
self­
certification.
If
zero
dischargers
are
included
in
this
rule
the
savings
would
be
absolutely
negligible
and
especially
cannot
be
included
as
any
real
savings
for
the
POTW.
Most
POTWs
don't
even
consider
them
to
be
SIUs
since
they
don't
discharge
anything.

Here
is
the
data
from
all
the
responses
I
received.
Location
CIUs
<
100
ZD
Chesterfield
County,
VA
12
0
0
Tampa,
FL
14
0
0
Charlotte­
Mecklenburg,
NC
36
0
0
Ocean
County
Utilities
Authority
10
1
0
Monroe
County
33
0
0
King
County,
WA
70
1
0
Anchorage,
AK
2
0
0
Spokane,
WA
11
1
0
Clean
Water
Services,
OR
45
3
8
Wichita,
KS
34
2
0
Portland,
OR
39
0
0
United
Water,
Burbank,
CA
46
0
0
Manchester,
NH
10
5
0
Fort
Worth,
TX
60
0
0
State
of
North
Carolina
342
4
0
Tacoma,
WA
11
0
0
Springfield,
MO
24
0
0
Syracuse,
UT
7
0
0
Austin,
TX
25
3
0
Troy,
OH
5
0
0
Littleton/
Englewood,
CO
9
0
0
Howard
County,
MD
9
1
0
Greenville,
SC
52
0
0
Colorado
Springs,
CO
33
3
4
Washington
Suburban
Sanitary
Commission
14
2
0
Hampton
Roads
Sanitation
District
25
0
0
Los
Angeles
County
Sanitation
District
544
25
0
Norman,
OK
3
0
0
Beloit,
WI
6
0
0
JEA
21
3
0
Northeast
Ohio
Regional
Sewer
District
141
14
0
Madison,
WI
19
0
0
St.
Louis,
MO
152
20
28
Denver,
CO
37
2
45
Phoenix,
AZ
57
3
0
St.
Paul/
Minneapolis,
MN
203
1
0
Rockford,
IL
39
0
0
Broward
County,
FL
13
0
0
Suffolk
County,
NY
62
13
18
Oroville,
CA
3
0
0
Ft.
Lauderdale,
FL
6
0
0
Passaic
Valley
Sewerage
Commissioners,
NJ
91
2
0
Total
2375
109
103
Will
Pettit
Manager,
Regulatory
Affairs
National
Association
of
Clean
Water
Agencies
1816
Jefferson
Place,
N.
W.
Washington,
D.
C.
20036­
2505
Phone:
(
202)
833­
3280
Fax:
(
202)
833­
4657
Internet:
www.
nacwa.
org
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
06/
27/
2005
05:
25
PM
To:
"'
Laity,
James
A.'"
<
James_
A._
Laity@
omb.
eop.
gov>,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA
Cc:

Subject:
RE:
Streamlining
Rule
­
Excerpts
from
Rules,
Reports,
Guidances
­
Comment
Response
Document
Response
to
comments
­
I
see
a
reference
on
page
6
of
the
draft
preamble
to
the
RTC
comments
­
could
Jim
and
I
see
the
draft
document?

Thanks
Kevin
­­­­­
Original
Message­­­­­
From:
Laity,
James
A.
[
mailto:
James_
A._
Laity@
omb.
eop.
gov]
Sent:
Thursday,
June
23,
2005
4:
48
PM
To:
Bromberg,
Kevin
L.;
Schaner.
Greg@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Nagle.
Deborah@
epamail.
epa.
gov
Subject:
FW:
Streamlining
Rule
­
Excerpts
from
Rules,
Reports,
Guidances
Kevin,
EPA
just
sent
me
the
attached.
Any
thoughts?

EPA,
Please
copy
Kevin
on
any
materials
you
send
in
my
absence,
including
the
updated
burden
reduction
analysis.
Thanks.
jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]

Sent:
Thursday,
June
23,
2005
3:
45
PM
To:
Laity,
James
A.
Cc:
Nagle.
Deborah@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov
Subject:
Streamlining
Rule
­
Excerpts
from
Rules,
Reports,
Guidances
Jim
­
Per
your
request,
here
are
some
of
the
references
I
found
that
were
relevant
to
our
discussions
on
non­
significant
CIU.
I
will
add
to
it
where
I
find
additional
references,
and
send
them
to
you
as
that
happens.
For
now,
this
is
what
I
have.
Let
me
know
if
you
have
any
questions.
Have
a
nice
break.
Greg
(
See
attached
file:
EPARuleReportExcerpts_
OMB.
doc)

Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
