Emails
regarding
Streamlining
Pretreatment
Rule
from
Jim
Laity,
Office
of
Management
and
Budget
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
13/
2005
04:
36
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
Subject:
RE:
Non­
Signif
CIUs
in
Pretreatment
Rule
Greg:
I
had
not
understood
that
22%
was
not
a
nationally
applicable
estimate.
I
am
disappointed
that
even
based
on
this
new
data,
you
estimate
only
4%
of
CIUs
nationally
would
be
affected.
This
is
not
much
higher
than
the
2%
you
estimated
at
proposal.
Do
you
have
any
data
for
a
500
MGD
cutoff?
Jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]
Sent:
Monday,
June
13,
2005
7:
17
AM
To:
Laity,
James
A.
Cc:
Schaaff.
Lesley@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Noe,
Paul
R.
Subject:
Re:
Non­
Signif
CIUs
in
Pretreatment
Rule
Jim
­
We
had
our
Regions
assess
the
impact
of
different
thresholds
on
some
of
their
larger
POTWs
(
which
I
believe
are
all
NACWA
members).
Here's
the
table
that
was
generated
showing
an
impact
of
22%
for
the
100
gpd
threshold
(
see
far
right
column).
Nationally,
we
estimate
that
the
100
gpd
would
potentially
affect
about
4%
of
CIUs.

(
Embedded
image
moved
to
file:
pic28145.
jpg)

We
are
still
finalizing
language
for
the
100
gpd
provision,
but
you
are
correct
in
your
assessment.
I'll
send
it
along
once
I've
had
management
review
it.
The
major
different
between
a
nonsignificant
CIU
(
NSCIU)
and
either
an
SIU
and
a
regular
IU
is
essentially
the
following:

­­
No
permitting
requirement
for
NSCIU
(
SIUs
required
to
be
permitted;
IUs
don't
have
to
be
permitted)
­­
No
minimum
sampling
requirement
(
SIUs
must
sample
a
minimum
of
2
times
per
year;
)
­­
Must
submit
annual
certification
statement
indicating
they
still
meet
criteria
for
NSCIU
and
comply
w/
categorical
standards
(
SIUs
must
report
2
times
per
year)
­­
POTWs
conduct
a
yearly
"
evaluation"
of
NSCIUs
to
determine
whether
they
still
meet
the
criteria
for
NSCIU
(
this
is
to
be
differentiated
from
the
annual
on­
site
inspection
that
POTWs
must
conduct
for
SIUs)

I
hope
this
helps.
Greg
Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
15/
2005
05:
18
PM
To:
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
Cc:
Subject:
Non­
Signif
CIUs
Linda:
A
couple
of
thoughts
for
tomorrow's
discussion.

1)
If
you
drop
2
POTWs
(
NY
and
Denver)
that
account
for
162
(
65%)
of
the
<
100
MGD,
you
get
88/
758
=
12%
of
CIUs.
I
understand
that
NY
has
mainly
small
jewelry
finishers,
who
may
be
atypical
of
other
cities.
Do
we
have
any
other
info
on
how
representative
these
two
are?

2)
I
assume
these
estimates
include
zero
dischargers.
Do
we
know
how
many?
Is
there
any
significant
burden
reduction
for
zero
dischargers?
What
are
they
currently
required
to
do?

3)
I
did
a
hand
tally
of
the
AMSA
survey
results
for
about
19
POTWs
(
attached).
Only
five
had
enought
data
to
see
what
percent
of
CIUs
were
<
100
MGD,
but
for
these
5,
31/
486
or
6%
were
<
100
MGD.
While
there
was
insufficient
data
for
conclusive
statements
about
the
others,
the
data
strongly
suggest
that
the
percentage
for
this
group
as
a
whole
would
be
well
below
10%.

I
am
eager
to
hear
your
thoughts
on
the
three
tier
approach.
jim
PS:
Not
sure
who
all
else
to
send
this
to,
please
forward.
J
(
Attachment
AMSA
PT
Streamlining.
xls)

Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
22/
2005
06:
02
PM
To:
Linda
Boornazian/
DC/
USEPA/
US@
EPA
Cc:
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA
Subject:
RE:
PT
Streamlining
Mass
Limits
Linda,
I
see
from
a
quick
skim
that
the
requirement
to
recalculate
mass
limits
based
on
new
flow
at
end
of
permit
term
is
still
in
the
draft,
in
brackets.
Based
on
our
conversation
yesterday,
I
already
told
John
Graham
that
this
was
resolved.
Do
I
need
to
reopen
this
issue?
jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
23/
2005
04:
44
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA
Subject
RE:
Streamlining
Rule
­
Excerpts
from
Rules,
Reports,
Guidances
Thanks
Greg,
I'm
afraid
I
don't
find
these
excerpts
very
relevant
or
persuasive.
The
quotes
from
the
IG
report
are
highly
selective.
Where
is
the
part
about
urging
EPA
to
complete
this
rule
in
a
timely
fashion,
or
criticizing
EPA
and
the
States
for
not
doing
as
good
a
job
of
ovreseeing
IUs
at
non­
approved
POTWs
as
the
approved
POTWs
are
themselves
doing.
I
didn't
see
anything
in
the
quotes
you
provided
that
suggested
it
was
inappropriate
to
tailor
the
level
of
oversight
of
small
dischargers
to
their
potential
for
environmental
harm,
as
the
NAWQA
proposal
would
do.

The
quotes
from
the
Pretreatment
Regs
go
to
the
need
for
oversight
of
SIUs,
which
nobody
is
questioning.
The
issue
is
,
who
should
be
counted
as
an
SIU,
and
what
is
the
appropriate
minimum
level
of
oversight?
As
we
discussed
on
the
phone.
For
SIUs,
whether
>
0.01
%
or
not,
for
which
the
POTW
determines
that
the
appropriate
level
of
oversight
is
greater
than
the
current
minimum
requirements,
there
would
presumably
be
no
change
by
relaxing
the
minimum,
either
in
terms
of
burden
or
in
terms
of
environmental
protection.

Most
of
the
other
cites
are
VERY
old.
The
fact
that
most
POTWs
did
not
have
WET
or
toxic
limits
in
a
1991
Report
to
Congress
(
probably
based
on
data
that
was
older
still)
is
not
very
informtive.

I
only
skimmed
quickly.
Maybe
I
missed
something.
We
can
discuss
in
detail
on
Thurdsay.
­­
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
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
23/
2005
04:
47
PM
To:
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA
Cc:
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
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
30/
2005
12:
59
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Sandy
Evalenko/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Laurie
Dubriel/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
Subject:
RE:
Streamlining
­
Revised
Rule
Greg:
I
had
expected
to
get
a
revised
burden
analysis
showing
your
best
estimate
of
affected
CIUs,
split
into
zero­
dischargers
and
non­
zero­
dischargers,
and
the
burden
reduction
you
estimate
for
each.
I
don't
see
this
anywhere
in
my
e­
mail.
Did
I
miss
something?

Also,
we
have
received
a
request
from
Nancy
Stoner
of
NRDC
for
a
meeting
with
OIRA
to
discuss
the
rule.
I
will
let
you
know
when
it
is
scheduled.
jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]
Sent:
Wednesday,
June
29,
2005
4:
05
PM
To:
Laity,
James
A.
Cc:
Johnston.
Carey@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Evalenko.
Sandy@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov;
Nagle.
Deborah@
epamail.
epa.
gov;
Schaner.
Greg@
epamail.
epa.
gov;
Pickrel.
Jan@
epamail.
epa.
gov;
Dubriel.
Laurie@
epamail.
epa.
gov
Subject:
Streamlining
­
Revised
Rule
Jim
­
This
version
of
the
final
Streamlining
Rule
has
removed
the
provisions
and
preamble
discussion
relating
to
the
recalculation
of
the
mass
limits,
per
prior
discussions.
Thanks.
Greg
(
See
attached
file:
FinalRule_
OMBEdits_
062905.
doc)

Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
30/
2005
05:
37
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
Jim
Hanlon/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Laurie
Dubriel/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Sandy
Evalenko/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
kevin.
bromberg@
sba.
gov
Subject:
RE:
Streamlining
­
Revised
Rule
Greg,
Thanks.
The
spreadsheet
is
very
thorough.
The
burden
reduction
analysis
is
still
missing
several
pieces.
I
need
to
know
what
the
"
actual"
burden
reduction
is
for
zero
dischargers,
not
the
"
paper"
reduction
based
on
your
ICR
assumption
that
zero
dischargers
currently
face
the
same
sampling
burden
as
non­
zero
dischargers.
This
assumption
is
clearly
not
correct.
I
specifically
asked
Linda
for
this
last
week
and
I
thought
she
agreed.

Also,
I
appologize
if
this
is
more
work,
but
I
really
need
to
see
the
86,451
hours
(
or
whatever
it
becomes
after
correcting
the
treatment
of
zero
dischargers)
broken
out
into
its
component
pieces
(
eg,
burden
reduction
to
POTWs,
burden
reduction
to
CIUs,
burden
reduction
to
zero
dischargers,
burden
reduction
to
non­
zero
dischargers,
etc).
Presumably
is
was
estimated
"
from
the
ground
up"
so
it
should
not
be
too
difficult
to
show
me
the
various
pieces
and
how
much
burden
reduction
is
accounted
for
by
each.
Thanks
in
advance.
jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]

Sent:
Thursday,
June
30,
2005
5:
25
PM
To:
Laity,
James
A.
Cc:
Johnston.
Carey@
epamail.
epa.
gov;
Hanlon.
Jim@
epamail.
epa.
gov;
Nagle.
Deborah@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov;
Pickrel.
Jan@
epamail.
epa.
gov;
Bromberg,
Kevin
L.;
Dubriel.
Laurie@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Evalenko.
Sandy@
epamail.
epa.
gov
Subject:
RE:
Streamlining
­
Revised
Rule
Jim
­
I'm
attaching
our
most
current
breakdown
of
the
data
we
have
on
facilities
affected
by
the
<
100
gpd
threshold,
including
a
breakdown
of
burden
reduction
for
zero
dischargers
and
nonzero
dischargers,
as
well
as
the
assumptions
this
is
based
on.
See
both
attachments.
Thanks.
Greg
(
See
attached
file:
NSCIU
data.
xls)(
See
attached
file:
ICR
Assumptions
burden
Regarding
NCIUs.
v04.
doc)

Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov
06/
30/
2005
03:
42
To:;
Greg
Schaner/
DC/
USEPA/
US@
EPA;
cc
Carey
Johnston/
DC/
USEPA/
US@
EPA,
PM
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Laurie
Dubriel/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Sandy
Evalenko/
DC/
USEPA/
US@
EPA
Subject
RE:
Streamlining
­
Revised
Rule
Thanks
Greg.
jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]

Sent:
Thursday,
June
30,
2005
3:
30
PM
To:
Laity,
James
A.
Cc:
Johnston.
Carey@
epamail.
epa.
gov;
Nagle.
Deborah@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov;
Pickrel.
Jan@
epamail.
epa.
gov;
Bromberg,
Kevin
L.;
Dubriel.
Laurie@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Evalenko.
Sandy@
epamail.
epa.
gov
Subject:
RE:
Streamlining
­
Revised
Rule
Jim
­
We're
working
on
getting
you
that
break
out.
The
contractor
is
doing
a
QA/
QC
on
the
breakdown,
and
checking
the
assumptions
for
accuracy.
We'll
need
to
check
it
first,
but
should
get
it
to
you
fairly
soon.
I
apologize
for
the
delay.
Greg
Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
30/
2005
12:
59
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Sandy
Evalenko/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Laurie
Dubriel/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
kevin.
bromberg@
sba.
gov
Subject:
RE:
Streamlining
­
Revised
Rule
Greg:
I
had
expected
to
get
a
revised
burden
analysis
showing
your
best
estimate
of
affected
CIUs,
split
into
zero­
dischargers
and
non­
zero­
dischargers,
and
the
burden
reduction
you
estimate
for
each.
I
don't
see
this
anywhere
in
my
e­
mail.
Did
I
miss
something?

Also,
we
have
received
a
request
from
Nancy
Stoner
of
NRDC
for
a
meeting
with
OIRA
to
discuss
the
rule.
I
will
let
you
know
when
it
is
scheduled.
jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]

Sent:
Wednesday,
June
29,
2005
4:
05
PM
To:
Laity,
James
A.
Cc:
Johnston.
Carey@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Evalenko.
Sandy@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov;
Nagle.
Deborah@
epamail.
epa.
gov;
Schaner.
Greg@
epamail.
epa.
gov;
Pickrel.
Jan@
epamail.
epa.
gov;
Dubriel.
Laurie@
epamail.
epa.
gov
Subject:
Streamlining
­
Revised
Rule
Jim
­
This
version
of
the
final
Streamlining
Rule
has
removed
the
provisions
and
preamble
discussion
relating
to
the
recalculation
of
the
mass
limits,
per
prior
discussions.
Thanks.
Greg
(
See
attached
file:
FinalRule_
OMBEdits_
062905.
doc)

Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
06/
30/
2005
05:
49
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
Jim
Hanlon/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Laurie
Dubriel/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Sandy
Evalenko/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>

Subject:
Follow
up
to
last
e­
mail
Greg:
As
I
look
over
your
burden
reduction
memo
more
carefully,
I
realize
that
it
would
also
be
helpful
for
me
to
see,
on
an
individual
basis,
exactly
how
each
burden
reduction
number
was
calculated.
So
for
example,
where
is
says
non­
zero
discharging
NSCIUs
have
an
annual
burden
reduction
of
22.4
hours,
I
would
like
to
see
the
exact
calculation
­­
what
are
they
doing
now,
itemized
by
category
(___
samples
per
year
at
___
hrs
per
sample,
plus
___
hrs
for
reporting,
plus
whatever
else)
and
what
they
will
be
doing
after
(
1
sample
every
five
years
at
___
hrs
per
sample,
___
hrs
per
annual
certification,
etc).
And
similarly
for
the
other
burden
reduction
calculations.
Thanks.
­­
Jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
01/
2005
08:
29
PM
To:
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA
Cc:
"
Graham,
John"
<
John_
Graham@
omb.
eop.
gov>,
"
Fraas,
Arthur
G."
<
Arthur_
G._
Fraas@
omb.
eop.
gov>,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
"
Noe,
Paul
R."
<
Paul_
R._
Noe@
omb.
eop.
gov>

Subject:
Analysis
of
PT
Streamlining
Rule
Elaine:
Here
is
the
summary
memo
I
provided
to
John
Graham.
It
is
derived
from
your
detailed
analysis,
as
we
discussed
on
the
phone.
My
bottom
line
figures
do
not
exactly
match
the
summary
table
you
sent
me
later
and
I
didn't
have
time
to
reconcile
them,
but
I
think
they
are
close
enough
to
inform
policy
discussions
until
I
get
back.
If
you
and
your
staff
want
to
take
a
crack
at
refining
my
numbers
and
reconciling
them
with
your
contractor's
estimates,
feel
free.
I
will
check
in
with
you
when
I
get
back
on
Thursday,
July
7.
jim
(
See
attached
file:
Pretreatment
Streamlining
Summary
Analysis.
wpd)
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
07/
2005
10:
11
AM
To:
Elaine
Brenner/
DC/
USEPA/
US@
EPA
Cc:
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
"
Fraas,
Arthur
G."
<
Arthur_
G._
Fraas@
omb.
eop.
gov>,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
"
Graham,
John"
<
John_
Graham@
omb.
eop.
gov>,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
"
Noe,
Paul
R."
<
Paul_
R._
Noe@
omb.
eop.
gov>,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Jim
Hanlon/
DC/
USEPA/
US@
EPA,
Benjamin
Grumbles/
DC/
USEPA/
US@
EPA,
William
Anderson/
DC/
USEPA/
US@
EPA
Subject:
RE:
Analysis
of
PT
Streamlining
Rule
Thanks
Elaine.
I
appreciate
that
there
may
be
DQA
concerns
with
some
data.
However,
we
specifically
asked
(
at
several
levels)
for
your
"
best
estimate"
of
the
impacts
of
the
100
GPD
option.
I
spoke
to
Linda
about
this
personally.
I
prepared
summary
tables
for
John
based
on
the
analyses
you
sent
back.
If
you
feel
this
is
not
the
"
best
estimate,"
please
provide
us
a
best
estimate
asap.
I
am
hoping
that
the
policy
folks
can
have
one
set
of
analyses
that
we
all
agree
on
to
base
their
discussions
on.

Have
you
had
a
chance
to
look
over
my
tables?
I
tried
to
accurately
summarize
the
15
pages
of
detailed
tables
you
sent
me
last
Friday
night
before
I
left,
but
may
well
have
misinterpreted
or
miscalculated
something?
Do
you
have
any
corrections?

I
understand
that
internal
discussions
with
the
Administrator
were
postponed.
Do
you
have
a
new
target
date
that
you're
shooting
for
for
signature?
jim
From:
Brenner.
Elaine@
epamail.
epa.
gov
[
mailto:
Brenner.
Elaine@
epamail.
epa.
gov]
Sent:
Saturday,
July
02,
2005
7:
37
PM
To:
Laity,
James
A.
Cc:
cristofaro.
alexander@
epamail.
epa.
gov;
Fraas,
Arthur
G.;
Nagle.
Deborah@
epamail.
epa.
gov;
Schaner.
Greg@
epamail.
epa.
gov;
Graham,
John;
Bromberg,
Kevin
L.;
Schaaff.
Lesley@
epamail.
epa.
gov;
Boornazian.
Linda@
epamail.
epa.
gov;
Noe,
Paul
R.;
pickrel.
jan@
epamail.
epa.
gov;
hanlon.
jim@
epamail.
epa.
gov;
Grumbles.
Benjamin@
epamail.
epa.
gov;
Anderson.
William@
epamail.
epa.
gov
Subject:
Re:
Analysis
of
PT
Streamlining
Rule
Thanks,
Jim.
We
will
look
at
this.
Please
note,
we
haven't
addressed
Data
Quality
Act
requirements
for
the
SBA­
NACWA
data
that
was
used
in
this
analysis.

Elaine
Brenner
Associate
Director
Water
Permits
Division
Phone:
202
564­
0649
fax:
202
564­
6392
Mail
Code:
4203M
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
01/
2005
08:
29
PM
To:
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Lesley
Schaaff/
DC/
USEPA/
US@
EPA,
Alexander
Cristofaro/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA
Cc:
"
Graham,
John"
<
John_
Graham@
omb.
eop.
gov>,
"
Fraas,
Arthur
G."
<
Arthur_
G._
Fraas@
omb.
eop.
gov>,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>,
"
Noe,
Paul
R."
<
Paul_
R._
Noe@
omb.
eop.
gov>

Subject:
Analysis
of
PT
Streamlining
Rule
Elaine:
Here
is
the
summary
memo
I
provided
to
John
Graham.
It
is
derived
from
your
detailed
analysis,
as
we
discussed
on
the
phone.
My
bottom
line
figures
do
not
exactly
match
the
summary
table
you
sent
me
later
and
I
didn't
have
time
to
reconcile
them,
but
I
think
they
are
close
enough
to
inform
policy
discussions
until
I
get
back.
If
you
and
your
staff
want
to
take
a
crack
at
refining
my
numbers
and
reconciling
them
with
your
contractor's
estimates,
feel
free.
I
will
check
in
with
you
when
I
get
back
on
Thursday,
July
7.
jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
08/
2005
11:
38
AM
To:
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
Cc:

Subject:
AMSA
Three
Tier
Proposal
Jan,

Thanks
for
sending
me
the
excerpts
from
AMSA's
1999
comments
describing
their
three­
tier
proposal.
I
had
already
read
this,
but
thought
you
might
be
refering
to
something
else,
bc
Linda
mentioned
a
"
cumulative"
restriction,
by
which
I
thought
she
meant
a
limit
on
the
total
dishcarge
of
all
NSCIUs.
I
do
not
see
any
such
suggestion
in
the
materials
you
sent.
There
is
a
suggested
limit,
for
each
NSCIU,
of
no
more
than
0.01
percent
of
the
organic
treatment
capacity
of
the
POTW,
and
no
more
than
0.01
percent
of
the
Maximum
Allowable
Headworks
Laoding
for
any
pollutant
detected
at
the
headworks
for
which
the
CIU
is
subject
to
a
categorical
pretreatment
standard.

I
would
like
to
know
a
little
more
about
what
these
two
additional
restrictions
would
mean
in
practice,
what
data
would
be
needed
to
establish
eligibility,
and
whether
this
is
data
that
would
be
normally
available
during
the
permitting
process,
but
with
these
caveats,
at
first
glance,
these
additional
limitations
look
reasonable
to
me.
Presumably
if
AMSA
was
suggesting
them,
they
must
believe
that
the
provision
would
still
be
workable.
Were
these
additional
restrictions
included
in
the
Chicago
Project
Excell?

Please
let
me
know
if
you
would
like
to
discuss
further.
Jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
08/
2005
11:
58
AM
To:
Linda
Boornazian/
DC/
USEPA/
US@
EPA
Cc:
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>

Subject:
RE:
AMSA
Three
Tier
Proposal
As
I
said,
seems
reasonable
to
me,
provided
the
data
to
make
this
determination
is
available.
jim
­­­­­
Original
Message­­­­­
From:
Boornazian.
Linda@
epamail.
epa.
gov
[
mailto:
Boornazian.
Linda@
epamail.
epa.
gov]
Sent:
Friday,
July
08,
2005
11:
49
AM
To:
Laity,
James
A.
Cc:
Nagle.
Deborah@
epamail.
epa.
gov;
Brenner.
Elaine@
epamail.
epa.
gov;
Schaner.
Greg@
epamail.
epa.
gov;
pickrel.
jan@
epamail.
epa.
gov;
Bromberg,
Kevin
L.

Subject:
Re:
AMSA
Three
Tier
Proposal
The
headworks
is
what
I
was
asking
you
to
look
at
..

"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
07/
08/
2005
11:
38
AM
To:
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
"
Bromberg,
Kevin
L."
<
kevin.
bromberg@
sba.
gov>
Cc:

Subject:
AMSA
Three
Tier
Proposal
Jan,

Thanks
for
sending
me
the
excerpts
from
AMSA's
1999
comments
describing
their
three­
tier
proposal.
I
had
already
read
this,
but
thought
you
might
be
refering
to
something
else,
bc
Linda
mentioned
a
"
cumulative"
restriction,
by
which
I
thought
she
meant
a
limit
on
the
total
dishcarge
of
all
NSCIUs.
I
do
not
see
any
such
suggestion
in
the
materials
you
sent.
There
is
a
suggested
limit,
for
each
NSCIU,
of
no
more
than
0.01
percent
of
the
organic
treatment
capacity
of
the
POTW,
and
no
more
than
0.01
percent
of
the
Maximum
Allowable
Headworks
Laoding
for
any
pollutant
detected
at
the
headworks
for
which
the
CIU
is
subject
to
a
categorical
pretreatment
standard.

I
would
like
to
know
a
little
more
about
what
these
two
additional
restrictions
would
mean
in
practice,
what
data
would
be
needed
to
establish
eligibility,
and
whether
this
is
data
that
would
be
normally
available
during
the
permitting
process,
but
with
these
caveats,
at
first
glance,
these
additional
limitations
look
reasonable
to
me.
Presumably
if
AMSA
was
suggesting
them,
they
must
believe
that
the
provision
would
still
be
workable.
Were
these
additional
restrictions
included
in
the
Chicago
Project
Excell?

Please
let
me
know
if
you
would
like
to
discuss
further.
jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
08/
30/
2005
05:
23
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA,
Elaine
Brenner/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Linda
Boornazian/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA
Cc:

Subject:
Process
v
Categorical
Wastewater
How
about
this:

Preamble
Language:

EPA
does
not
have
data
on
process­
specific
or
category­
specific
flows
for
facilities
that
may
comingle
process
wastewater
from
multiple
industrial
operations.
In
general,
EPA
assumes
that
all
or
most
process
wastewater
discharged
by
CIUs
will
be
categorical
wastewater.
Where
facilities
co­
mingle
different
types
of
categorical
wastewater,
the
threshold
for
determining
whether
or
not
a
facility
may
be
considered
a
non­
significant
CIU,
or
a
"
middle
tier"
CIU,
would
be
based
on
the
total
amount
of
categorical
wastewater
discharged.
That
is,
the
breakdown
of
categorical
wastewater
flows
by
industrial
category
would
not
affect
the
threshold
determination.
However,
EPA
recognizes
that
there
may
be
cases
where
facilities
discharge
both
categorical
wastewater
and
non­
categorical
process
wastewater.
This
would
occur
where
some
of
a
facility's
process
wastewater
discharges
were
regulated
under
a
national
categorical
standard,
while
others
were
not,
either
because
they
were
generated
by
operations
from
a
different
(
non­
regulated)
industrial
category,
or
because
they
were
specifically
excluded
from
coverage
at
the
time
the
categorical
standards
were
promulgated.
In
such
cases,
where
the
POTW
can
reliably
distinguish
categorical
from
non­
categorical
flows,
the
POTW
may,
at
its
discretion,
base
the
threshold
determination
for
eligibility
as
a
non­
significant
or
middle
tier
CIU
on
the
total
categorical
wastewater
flow,
rather
than
the
total
process
wastewater
flow.
This
could
be
the
case
where
the
categorical
and
non­
categorical
flows
are
discharged
separately
(
not
co­
mingled)
or
where
a
reliable
estimate
of
categorical
flows
was
used
to
apply
the
combined
wastestream
formula
to
the
co­
mingled
flows
and
this
is
documented
in
the
POTW's
records.
In
cases
where
categorical
and
non­
categorical
process
wastewater
flows
cannnot
be
reliably
distinguished,
the
threshold
determination
should
be
based
on
total
process
wastewater
flow.

Rule
Language:

Use
the
term
"
categorical
wastewater"
in
place
of
"
process
wastewater."

jim
"
Laity,
James
A."
<
James_
A._
Laity@
omb.
eop.
gov>
09/
21/
2005
02:
54
PM
To:
Greg
Schaner/
DC/
USEPA/
US@
EPA
Cc:
Carey
Johnston/
DC/
USEPA/
US@
EPA,
Debra
Nicoll/
DC/
USEPA/
US@
EPA,
Henry
Kahn/
DC/
USEPA/
US@
EPA,
Jan
Matuszko/
DC/
USEPA/
US@
EPA,
Jan
Pickrel/
DC/
USEPA/
US@
EPA,
Janet
Goodwin/
DC/
USEPA/
US@
EPA,
johnston.
carey@
verizon.
net,
Richard
Witt/
DC/
USEPA/
US@
EPA,
Marla
Smith/
DC/
USEPA/
US@
EPA
Subject:
RE:
Pretreatment
Streamlining
­
Proposed
Revision
to
Water
Conservation
Sentence
Greg:
I
don't
mean
to
be
difficult
here,
but
first,
your
revised
sentences
do
not
fit
within
the
context
of
the
paragraph,
and
second,
they
do
not
answer
the
question,
why
do
we
need
to
allow
mass
limits
to
promote
water
conservation,
given
that
the
immediately
preceding
sentence
says
"
The
effect
of
concentration
limits
also
is,
over
time,
to
reduce
mass
discharges
of
pollutants
as
water
use
is
reduced."

How
about
dropping
this
sentence
as
well
and
replacing
with
the
following:

"
However,
control
authorities
do
have
the
information
necessary
to
establish
such
limits
on
a
facility­
specific
basis.
Concentration
based
limits
may
not
provide
an
incentive
for
water
conservation
because
as
water
discharges
are
reduced,
the
amount
of
pollutant
that
can
be
discharged
is
also
reduced.
In
contrast,
mass­
based
limits
promote
water
conservation
because
the
discharger
need
focus
only
on
the
mass
of
pollutant
discharged,
which
generally
goes
down
(
or
at
least
does
not
go
up)
when
wastewater
volumes
are
reduced."

Having
listened
carefully
over
the
past
month
to
Carey's
concerns
on
this
issue,
I
believe
there
is
nothing
in
these
sentences
that
you
would
find
inaccurate.
They
also
fit
into
the
paragraph
and
do
provide
a
reasonable
explanation
for
why
we
are
adopting
this
change.

jim
­­­­­
Original
Message­­­­­
From:
Schaner.
Greg@
epamail.
epa.
gov
[
mailto:
Schaner.
Greg@
epamail.
epa.
gov]

Sent:
Wednesday,
September
21,
2005
2:
13
PM
To:
Laity,
James
A.
Cc:
Johnston.
Carey@
epamail.
epa.
gov;
Nicoll.
Debra@
epamail.
epa.
gov;
Kahn.
Henry@
epamail.
epa.
gov;
Matuszko.
Jan@
epamail.
epa.
gov;
Pickrel.
Jan@
epamail.
epa.
gov;
Goodwin.
Janet@
epamail.
epa.
gov;
johnston.
carey@
verizon.
net;
witt.
richard@
epamail.
epa.
gov;
Smith.
Marla@
epamail.
epa.
gov
Subject:
Pretreatment
Streamlining
­
Proposed
Revision
to
Water
Conservation
Sentence
Jim
­
Deborah
has
left
you
a
message
about
this.
We'd
like
to
propose
a
substitute
set
of
sentences
to
replace
the
"
disincentive"
sentence
that
was
discussed
yesterday.
We
think
it
is
within
the
spirit
of
your
suggested
sentence,
and
is
consistent
with
our
past
record
on
this
subject.
Here's
the
change
we
propose:

Insert
the
following
sentences:
"
Under
the
final
rule,
Industrial
Users
whose
wastewater
discharges
are
controlled
by
equivalent
mass
limits
have
more
flexibility
as
they
mayelect
to
control
their
wastewater
discharges
through
more
efficient
wastewater
control
technologies
and
pollution
prevention
practices
(
i.
e.,
resulting
in
lower
pollutant
concentrations
in
the
discharged
wastewater)
or
more
efficient
water
conservation
practices
(
e.
g.,
resulting
in
less
wastewater
volume
discharged
from
an
industrial
operation)
or
both.
This
added
flexibility
may
encourage
Industrial
Users
to
explore
water
conservation
measures."

instead
of:

"
But
concentration
limits
may
in
some
circumstances
serve
as
a
disincentive
to
water
conservation."

Please
call
Deborah
or
me
to
discuss.
Thanks.
Greg
Schaner
Attorney
Adviser,
Permits
Division
Office
of
Wastewater
Management
phone:
(
202)
564­
0721
fax:
(
202)
564­
6431
