Synthetic
Organic
Chemical
Manufacturers
Association
Meeting
with
Water
Permits
Division
February
17,
2004
Attendees
Deborah
Nagle,
Water
Permits
Division,
OWM
Jan
Pickrel,
Water
Permits
Division,
OWM
Greg
Schaner,
Water
Permits
Division,
OWM
Elaine
Brenner,
Water
Permits
Division,
OWM
Linda
Boornazian,
Water
Permits
Division,
OWM
Pat
Nevrincean,
FMC
Joyce
McCarty,
Attorney
for
SOCMA
Jeff
Gunnulfsen,
SOCMA
Bill
Turetsky,
ISP
Martha
Murroy,
AeroJet
Seth
Levine,
Cambrex
Purpose
and
Summary
of
Meeting
SOCMA
met
with
Water
Permits
Division
to
outline
what
it
views
to
be
the
primary
issues
in
the
Pretreatment
Streamlining
Rule.
The
following
summarizes
the
discussion:

 
pH
 
Linda
Boornazian
expressed
a
need
for
resources
to
study
pH
because
more
data
is
required
to
assess
impact
on
integrity
to
the
system.
SOCMA
supports
AMSA's
comments
in
favor
of
establishing
alternative
short­
term
exclusions
of
discharges
of
pH
between
5.0
and
5.5.
EPA
should
not
limit
this
provision
to
facilities
which
have
continuous
pH
monitors.
SOCMA
supports
short­
term
relief,
such
as
allowing
discharges
less
than
4.0
for
less
than
five
hours
per
month
and
less
than
60
minutes
per
day
based
on
40
CFR
401.17
and
Control
Authority
monitoring
and
assessment.
Linda
raised
concerns
about
lack
of
data
that
shows
these
pH
values
do
not
cause
harm
to
the
POTW
and
collection
system.

 
Equivalent
Mass
Limits
 
SOCMA
members
favor
clarity
of
when
mass
limits
can
be
used,
having
encountered
that
permitting
authorities
are
reluctant
to
use
mass
limits
because
of
uncertainties
about
where
they
can
be
applied
and
the
intent
of
applying
them.
One
concern
includes
that
a
grab
sample
of
an
intermittent
flows
of
high
concentration
in
small
quantities
may
not
provide
representative
results
of
the
overall
mass
characteristics.
SOCMA
argued
that
mass
limits
conflict
with
the
general
goal
of
pollution
prevention
and
water
conservation
measures.
SOCMA
cited
example
of
someone
being
penalized
for
water
reduction.
Linda
questioned
monetary
benefits
to
small
business.
SOCMA
replied
water
conservation
can
provide
incentives
to
encourage
pollution
prevention
activities.
On
a
practical
note,
increased
sampling
would
provide
representative
data
when
flow
is
variable.
Some
facilities
have
essentially
been
forced
into
having
to,
unnecessarily,
truck
wastewater
offsite
for
disposal
due
to
lack
of
clarity
of
permit,
when
could
have
discharged
to
the
POTW
if
the
POTW
understood
how
and
when
to
apply
mass
limits
in
the
permits.
An
example
of
a
circumstance
is
for
a
batch
discharge
that
may
have
a
"
spike"
(
high
concentration
value)
on
one
day,
while
the
quality
for
the
rest
of
the
month
is
more
dilute.
Linda
queried,
"
Is
there
a
potential
concentration
that
POTW
couldn't
accommodate?"
SOCMA
replied
that
there
was
not
a
pass­
through
issue.
Jan
asked
what
would
the
flow
basis
be
to
determine
mass
for
batch
discharger?
SOCMA
agreed
with
the
need
for
some
clarity
of
how
to
set
a
flow
value
that
is
in
everyone's
interest.
Some
plants,
however,
can't
afford
to
do
flow
measurements.
In
other
cases,
there
are
standards
that
would
required
both
a
mass
[
instantaneous]
maximum
limit
and
also
an
average
limit.
Some
facilities
might
be
able
to
report
a
flow
based
on
tank
volume,
but
can't
use
a
meter.
Dilution
from
non­
categorical
wastewater
is
also
problematic.
SOCMA
says
they
have
examples
to
show
how
concentration
value
can
vary
with
a
flow.
SOCMA
says
some
of
their
facilities
are
interested
in
this
flexibility,
while
some
are
not.

 
Pollutants
Not
Present
 
SOCMA
is
concerned
that
OCPSF
facilities
have
been
singled
out,
unnecessarily
so,
for
exclusion
from
this
provision.
Most
of
its
members
have
consistent
data.
Control
Authority
has
data
that
show
this.
SOCMA
members
consist
of
two
primary
types
of
operations:
1)
facilities
that
produce
a
suite
of
products,
2)
facilities
that
essentially
are
devoted
to
production
of
one
chemical
with
no
changes.
The
regulations
also
establish
limitations
for
45
pollutants,
24
of
which
are
chlorinated
organics
which
FMC,
for
example,
doesn't
have.
If
dischargers
introduce
a
new
chemical
into
its
production,
such
change
in
process
is
required
to
be
reported
anyway.
Linda
asked
how
likely
will
a
facility
change
its
product
line
over
time.
SOCMA
replied
that
such
changes
would
be
determined
on
a
cost
basis
per
business.
A
SOCMA
member
asked
whether
OCPSF
was
excluded
in
pre­
proposal
drafts
of
this
rule.

 
Removal
Credits
 
SOCMA
asked
why
one
of
the
removal
credits
concepts
was
in
a
preproposal
draft,
but
then
was
not
in
the
published
proposal.
Elaine
responded
that
some
of
the
options
were
determined
to
be
available
without
a
regulatory
modification.
A
SOCMA
member
agreed
that
some
provisions
do
not
need
to
be
addressed
within
this
rulemaking,
but
that
the
Removal
Credits
option
of
the
current
regulation
is
just
not
an
operable
program
that
can
provide
financial
savings
to
industries
in
its
current
mode.
For
example,
in
the
2003
Sewage
Sludge
Proposal
EPA
didn't
agree
to
study
15
chemicals
for
inclusion
as
eligible
pollutants
for
Removal
Credits.
SOCMA
believes
the
reasoning
for
not
studying
these
15
pollutants
is
unclear;
why
was
the
2003
study's
focus
so
narrow?
