Synthetic
Organic
Chemical
Manufacturers
Association
Meeting
with
Water
Permits
Division
August
3,
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
Beth
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
 
SOCMA
supports
AMSA's
comments
in
favor
of
establish
an
alternative
approach
to
handling
discharges
of
pH
between
4.0
and
5.0.
EPA
should
not
limits
this
provision
to
facilities
which
have
continuous
pH
monitors.
Supports
use
of
exemptions
established
in
the
NPDES
program
for
low
pH
under
§
401.17.
SOCMA
further
indicated
that
the
POTW
has
the
ability
to
reject
discharges,
and
that
they
should
know
when
corrosion
presents
a
problem.

 
Equivalent
Mass
Limits
 
SOCMA
members
favor
the
proposed
rule
because
it
would
provide
more
clarity
in
this
area.
They
have
found
that
permitting
authorities
are
reluctant
to
allow
mass
limits
because
of
the
lack
of
guidance.
Mass
limits
generally
provide
a
better
understanding
of
the
loadings,
while
concentration
does
not
represent
the
overall
discharge.
In
addition,
SOCMA
argued
that
concentration
limits
conflict
with
the
general
goal
of
water
conservation
because
they
encourage
dilution.
SOCMA
indicated
that
flow
measurement
was
a
reasonable
requirement
to
establish
the
appropriate
limit.
If
a
facility
cannot
afford
a
flow
monitor,
then
they
would
not
be
able
to
pursue
mass
limits.

 
Pollutants
Not
Present
 
OCPSF
facilities,
which
were
left
out
of
the
pollutants
not
present
provision,
should
be
included
in
the
final
rule.
SOCMA
has
14
years
of
data
indicating
that
this
waiver
can
work
with
the
industry.
SOCMA
indicated
that
the
certification
statement
requirement
should
provide
the
necessary
comfort
level
for
the
POTW
that
the
facility
does
not
have
the
particular
pollutant.

 
Removal
Credits
 
SOCMA
is
not
arguing
that
removal
credits
be
addressed
in
this
rulemaking.
However,
they
would
like
to
see
removal
credits
be
a
more
functional
part
of
the
program.
