The
Policy
Group
Meeting
with
Water
Permits
Division,
Office
of
Wastewater
Management
February
10,
2004
Attendees
Deborah
Nagle,
Water
Permits
Division,
OWM
Christian
Richter,
The
Policy
Group
B.
J.
Mason,
Mid­
Atlantic
Finishing
Corporation
J.
L.
Lindstedt,
Artistic
Plating
Bill
Wiggins,
Automation
Plating
J.
Kelly
Lowry,
(
illegible)
Bill
Saas,
Yaskem,
Inc.
David
Jacobs,
Northwussors
Plating
Joelie
Zak,
Scientific
Control
Labs
Mike
Kelly,
Asko
Processing,
Inc.
David
S.
Marsh,
Marsh
Plating
Corp.
Jeff
Hannapel,
The
Policy
Group
Elaine
Brenner,
Water
Permits
Division,
OWM
Jan
Pickrel,
Water
Permits
Division,
OWM
Greg
Schaner,
Water
Permits
Division,
OWM
Purpose
and
Summary
of
Meeting
The
Policy
Group
met
with
Water
Permits
Division
staff
to
outline
its
priorities
for
the
Pretreatment
Streamlining
Rule.
The
following
summarizes
the
discussion:

 
Sampling
for
Pollutants
Not
Present
 
Policy
Group
members
consider
this
a
major
priority.
One
member
discusses
the
rising
costs
of
sampling
in
Region
5
and
the
need
to
provide
some
reasonable
relief
from
these
costs.

 
Non­
Significant
CIU
 
Policy
Group
indicated
that
if
EPA
chooses
to
finalize
the
100
gpd
threshold,
it
will
provide
no
streamlining
for
their
finishing
members.
They
would
prefer
that
EPA
not
go
forward
with
the
100
gpd
threshold,
in
favor
of
collecting
more
data
on
a
more
significant
cutoff.
They
suggested
instead
that
EPA
adopt
the
0.01%
approach
that
NACWA
has
supported.

 
Many
of
the
industry's
arguments
in
support
of
streamlining
has
to
do
with
the
decreased
profit
margins
faced
by
their
operations.
Attendees
also
mentioned
the
fact
that
POTWs
are
increasing
their
sewer
rates
despite
their
water
conservation
efforts.

 
Equivalent
mass
limits
 
Policy
Group
and
members
indicated
that
they
favored
concentration
limits.
They
indicated
that
when
water
consumption
is
reduced,
they
are
still
able
to
reduce
pollutant
loadings
because
of
the
chemical
precipitation
treatment
that
they
have
installed.
