ANALYTIC
BLUEPRINT
FOR
THE
EFFLUENT
GUIDELINES
PROGRAM
PLAN
FOR
2004/
2005
NOVEMBER
2003
November
10,
2003
DRAFT
Analytic
Blueprint
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
Contents
I.
Introduction
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1
Title
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1
Action
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1
SAN
Number
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1
RIN
Number
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1
Regulatory
Tier
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1
Deadline
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1
Background
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1
II.
Statutory
Requirements
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2
III.
Schedule
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2
IV.
Planning
Process
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4
Four
Major
Factors
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4
Screening
Level
Analysis
Phase
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5
Eliminating
Categories
from
Further
Consideration
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7
Ranking
Results
of
the
Analysis
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9
Further
Investigation
Phase
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9
Decision
on
Effluent
Guidelines
Rulemaking
Activities
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10
V.
Key
Issues
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11
Four
Major
Factors
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11
Screening
Level
Review
Phase
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11
Ranking
Results
of
the
Analysis
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11
Loading
Reductions
(
Voluntary
and
Multi­
media)
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11
Future
of
the
Effluent
Guidelines
Program
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12
VI.
Regulatory
Development
Requirements
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12
E.
O.
12866,
Regulatory
Planning
and
Review
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13
E.
O.
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations
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14
E.
O.
13045,
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
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14
E.
O.
13132,
Federalism
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14
Regulatory
Flexibility
Act
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14
Unfunded
Mandates
Reform
Act
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14
Paperwork
Reduction
Act
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14
National
Technology
Transfer
and
Advancement
Act
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.
15
November
10,
2003
DRAFT
VII.
Analytic
and
Other
Products
required
for
Proposed
Plan
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15
Draft
Factor
Analyses
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15
Category­
Specific
Overview
Documents
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15
Response
to
Comments
on
the
draft
Strategy
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15
Response
to
Comments
from
the
2002/
2003
Plan
That
Apply
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15
VIII.
Resources
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16
IX.
Workgroup
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16
X.
Contact
Information
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16
November
10,
2003
DRAFT
Page
1
of
25
I.
INTRODUCTION
Title:
Effluent
Guidelines
Program
Plan
for
2004/
2005
Action:
Plan
SAN
#:
4766
RIN
#:

Regulatory
Tier:
Tier
II
Deadline:
Final
Plan
published
in
the
Federal
Register
by
February
4,
2004
Background
The
preparation
of
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
(
the
"
Plan")
has
been
designated
a
Tier
2
action,
and
as
such,
requires
an
Analytic
Blueprint.
This
Blueprint
provides
background
on
the
Plan,
outlines
the
schedule
and
the
process
under
which
the
Plan
will
be
developed,
and
provides
a
preliminary
assessment
of
what
information
and
resources
are
available
and
what
information
is
needed
to
prepare
the
Plan.
Although
the
Plan
is
not
a
rulemaking,
Section
304(
m)(
2)
of
the
Clean
Water
Act
requires
that
it
be
made
available
for
public
review
and
comment
before
the
final
Plan
is
published.
This
process
will
give
workgroup
members
the
opportunity
to
review
and
comment
on
the
language
for
the
Federal
Register
notice
as
well
as
the
supporting
documents.

To
meet
the
statutory
requirements
that
are
specified
in
sections
304(
b),
304(
g),
304(
m),
306(
b),
and
307(
b)
of
the
Clean
Water
Act,
the
EPA
must
publish
a
biennial
plan.
EPA's
first
attempt
to
comply
with
these
requirements
resulted
in
litigation
by
the
Natural
Resources
Defense
Council
and
Public
Citizen,
Inc.
for
failure
to
comply
with
section
304(
m).
EPA
entered
into
a
consent
decree
in
1992
that
has
governed
the
program
for
the
past
decade.
EPA
will
soon
fulfill
its
commitments
under
the
provisions
of
that
consent
decree.
The
Agency
developed
the
draft
Strategy
for
National
Clean
Water
Industrial
Regulations
(
the
"
draft
Strategy")
as
a
means
to
comply
with
the
304(
m)
planning
requirements
in
the
future.

The
first
biennial
plan
developed
using
the
draft
Strategy
is
the
2004/
2005
Plan.
The
draft
Strategy
outlines
the
approach
the
304(
m)
Team
in
EPA's
Office
of
Water
has
begun
to
use
in
assessing
the
need
to
develop
and/
or
revise
effluent
guidelines
for
specific
industrial
categories.
As
required
by
CWA
Section
304(
m),
the
Plan
must
(
A)
establish
a
schedule
for
the
annual
review
and
revision
of
promulgated
effluent
guidelines,
in
accordance
with
CWA
section
304(
b),
(
B)
identify
categories
of
sources
discharging
toxic
or
nonconventional
pollutants
for
which
guidelines
under
CWA
sections
304(
b)(
2)
or
306
have
not
previously
been
published,
and
(
C)
November
10,
2003
DRAFT
Page
2
of
25
establish
a
schedule
for
the
promulgation
of
effluent
guidelines
identified
under
paragraph
(
B).
EPA
anticipates
that
this
Plan
would
also
describe
the
results
of
its
first
annual
review
process,
including,
to
the
extent
possible:
1)
the
outcomes
of
all
stages
of
the
screening
process
(
the
screening
level
review
phase,
second­
level
screening,
and
the
further
investigation
phase),
2)
EPA's
selection
of
industrial
categories
for
further
study,
and
3)
the
rationale
for
this
selection
of
industrial
categories
for
further
study.
In
addition,
the
Plan
would
summarize
additional
information
collected
and
analyzed
on
specific
industrial
categories
beyond
the
initial
screening
step,
and
would
identify
data
gaps.

II.
STATUTORY
REQUIREMENTS
The
development
of
the
2004/
2005
Plan
is
mandated
by
CWA
section
304(
m).
Section
304(
m)
requires
EPA
to
publish
the
Plan
in
the
Federal
Register
by
February
4,
2004,
and
every
two
years
thereafter.
Sections
301(
b)(
2)
and
304(
b)
specify
the
factors
EPA
must
consider
when
selecting
the
best
available
technology
economically
achievable
for
an
industrial
category.
In
addition,
section
304(
b)
authorizes
EPA
to
consider
other
factors
as
the
Administrator
deems
appropriate.
Additional
requirements
for
industrial
categories
that
presently
are
not
subject
to
technology­
based
limitations
are
described
in
section
304(
m)(
1)(
B).

Commenters
on
the
draft
Strategy
raised
several
issues
that
address
interpretations
of
the
statutory
requirements
of
the
304(
m)
process.
These
include
the
the
appropriate
use
of
the
factors
discussed
above,
and
how
to
define
a
new
category
as
opposed
to
a
new
subcategory
of
an
existing
guideline.
Such
issues
will
be
addressed
during
the
planning
process
cycle,
discussed
with
the
workgroup,
and
presented
in
the
proposed
and
final
Plans.

III.
SCHEDULE
The
schedule
below
outlines
the
304(
m)
Team's
approach
for
publishing
the
final
Plan
by
the
statutory
deadline
of
February
4,
2004.
It
includes
at
least
five
review
periods
by
the
workgroup
(
shown
in
bold
text
in
the
schedule
below),
with
the
potential
for
more
reviews
based
on
the
significance
of
revisions
made
based
on
workgroup
input.
These
five
reviews
include
two
rounds
for
the
Analytic
Blueprint,
two
reviews
of
the
draft
proposed
Plan
and
supporting
documents
(
one
preliminary,
and
one
as
part
of
the
Final
Agency
Review
or
FAR
process),
and
two
reviews
of
the
draft
final
Plan
(
one
preliminary
and
one
FAR).
In
addition,
we
have
built
in
a
30­
day
period
for
OMB
review
prior
to
publication
of
both
the
proposed
Plan
and
the
final
Plan.

Because
the
Office
of
Water
must
develop
and
publish
the
Plan
fairly
quickly,
we
anticipate
that
some
steps
outlined
in
the
draft
Strategy
won't
be
fully
incorporated
into
the
Plan.
However,
the
Plan
will
reflect
the
progress
made
to
date,
will
discuss
any
likely
recommendations
as
to
guidelines
for
development
or
revision,
and
will
include
a
discussion
of
anticipated
completion
dates
for
outstanding
steps
of
the
process
for
this
Plan.
The
304(
m)
Team
has
also
prepared
a
November
10,
2003
DRAFT
Page
3
of
25
document
that
describes
the
steps
taken
for
this
first
cycle,
for
use
in
subsequent
planning
cycles.
A
draft
of
this
document,
called
the
Rationale
Memo,
was
distributed
to
the
workgroup
as
part
of
the
Final
Agency
Review
package.

EXPECTED
TIME
LINE
FOR
2004/
2005
EFFLUENT
GUIDELINES
PROGRAM
PLAN

indicates
completion
as
of
this
Version
PROPOSED
PLAN
2003

February
10
Begin
drafting
Analytic
Blueprint

February
18
Announce
Tiering
results
to
workgroup
&
3/
6
mtg

Mar
6
Workgroup
kickoff
meeting

Mar
3
­
Mar
21
Workgroup
review
of
Analytic
Blueprint

March
31
Complete
draft
of
Factor
Analyses
&
Plan

Apr
3
­
Apr
17
Distribute
draft
analyses
to
Workgroup
May
23
­
Jun
6
Workgroup
Review
of
Revised
Analytic
Blueprint
and
Outline
of
Proposed
Plan

June
9
Meet
with
Workgroup
to
Discuss
Blueprint
and
Proposed
Plan

June
16
­
June
20
Brief
Division
Director
and
Office
Director

June
27
Send
Options
Selection
Materials
to
Workgroup

July
3
Revise
Analytic
Blueprint
to
reflect
workgroup
comments

September
26
Complete
AA/
RA
Decision
Process/
Option
Selection

Oct
24
Complete
draft
of
Proposed
Plan

Oct
24
­
Nov
6
Final
Agency
Review
process
(
3
weeks)


November
6
Final
Agency
Review
Meeting

November
10
Update
Analytic
Blueprint
with
Current
Schedule
Nov
13
­
Dec
15
Informal
OMB
review
(
30
days)
December
22
AA
signs
Proposed
Plan
December
29
PUBLISH
PROPOSED
PLAN
IN
FEDERAL
REGISTER
2004
January
28
Hold
Public
Meeting
February
12
End
comment
period
(
60
days)
FINAL
PLAN
March
13
AA
Decision/
Option
Selection
March
27
Complete
AA/
RA
Decision/
Option
Selection
Apr
2
­
Apr
16
Final
Agency
Review
process
(
3
weeks)
April
16
FAR
Meeting
Apr
23
­
May
24
OMB
review
(
30
days)
May
27
AA
signs
Final
Plan
JUNE
10
PUBLISH
FINAL
PLAN
IN
FEDERAL
REGISTER
November
10,
2003
DRAFT
Page
4
of
25
IV.
PLANNING
PROCESS
The
draft
Strategy
includes
a
description
of
the
basic
process
the
304(
m)
Team
in
EPA's
Office
of
Water
intends
to
follow
in
preparing
the
Plan.
The
Strategy
can
be
viewed
online
at
http://
epa.
gov/
guide/
strategy/
304mstrategy.
pdf.
As
discussed
in
that
document,
EPA
identified
four
major
factors
that
the
Agency
would
explore
as
a
means
to
determine
whether
a
revision
of
an
existing
effluent
guideline
or
development
of
a
new
guideline
would
be
necessary
and
appropriate.
The
Strategy
also
outlines
the
steps
(
or
phases)
the
Agency
would
take
in
the
planning
process.
Below
is
a
summary
of
that
process,
with
additional
information
reflecting
the
current
status
of
each
step
of
the
implementation
of
the
process.

One
of
the
issues
for
which
we
need
workgroup
assistance
is
to
resolve
is
the
test
for
determining
whether
EPA
is
required
to
develop
a
new
effluent
guideline
for
an
industry
without
an
existing
guideline.
The
industry
discharges
must
be
subjected
to
a
"
test"
under
CWA
section
304(
m)(
1)(
B):
"
discharges
of
toxic
&
nonconventional
pollutants
in
significant/
non­
trivial
amounts."
We
will
be
looking
at
"
new"
categories
based
on
the
"
significance"
of
their
discharge,
and
we
need
to
determine
how
to
judge
what
constitutes
a
significant
discharge.
EPA
may
be
required
in
the
proposed
Plan
to
identify
which
unregulated
categories
have
"
significant"
discharges.
Information
included
in
industry­
specific
overview
documents
(
see
attached
structure
and
definitions)
will
assist
in
assessing
this
issue
and
making
recommendations
for
management.
These
reports
are
discussed
in
more
detail
in
the
"
Screening
Level
Review"
section
below.

Four
Major
Factors
The
draft
Strategy
identified
four
factors
that
the
304(
m)
Planning
Team
would
consider
while
implementing
the
Strategy:

!
consideration
of
the
extent
to
which
the
pollutants
remaining
in
an
industry
category's
discharge
pose
a
substantial
risk
to
human
health
or
the
environment;

!
identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
the
pollutants
remaining
in
the
industry
category's
wastewaters
and
thereby
substantially
reduce
any
identified
risk
to
human
health
or
the
environment
associated
with
those
pollutants;

!
estimation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor;
and
!
consideration
of
implementation
and
efficiency
concerns.
Under
this
factor,
EPA
would
consider
whether
existing
effluent
guidelines
could
be
revised,
for
example,
to
eliminate
inefficiencies
or
impediments
to
technological
innovation,
or
to
decide
not
to
develop
a
new
effluent
guideline
for
an
industry
category
where
the
pollutant
source
is
already
being
addressed
by
another
regulatory
program,
such
as
TMDLs,
or
non­
regulatory
programs
November
10,
2003
DRAFT
Page
5
of
25
that
may
more
effectively
address
the
problem.

Stakeholder
information
is
an
important
part
of
the
analysis
of
each
of
these
factors,
and
will
be
sought
throughout
the
process
as
well
as
when
the
proposed
Plan
is
published.
The
draft
Factor
Analyses
were
distributed
to
the
workgroup
for
review
in
early
April,
2003,
and
workgroup
comments
are
currently
being
incorporated.
These
analyses
are
discussed
in
more
detail
in
the
following
section,
"
Screening­
Level
Review
Phase."

As
described
in
the
draft
Strategy,
EPA
can
consider
additional
factors,
and
the
workgroup
will
be
involved
in
the
discussion
of
any
such
factors
that
are
identified
during
the
process,
and
in
the
decision
whether
to
include
them
in
the
development
of
the
Plan.
The
workgroup
is
also
invited
to
suggest
additional
factors.
To
date,
no
additional
factors
have
been
identified,
however
the
comments
on
the
draft
Strategy
have
not
yet
been
systematically
reviewed.
The
comment
period
for
the
draft
Strategy
closed
on
February
27,
2003,
and
the
Agency
received
28
comments.
Any
additional
factors
identified
by
commenters
will
be
shared
with
the
workgroup.
(
Comments
are
available
for
review
on
e­
dockets
http://
www.
epa.
gov/
edocket/
under
docket
OW­
2002­
0020.)

Screening
Level
Analysis
Phase
The
first
phase
of
the
planning
process
is
an
initial
screen
of
readily
available
information,
and
has
been
completed.
Accordingly,
in
this
step
EPA
evaluates
readily
available,
screening­
level
data
to
create
an
initial
list
of
potential
categories
that
warrant
further
examination
in
subsequent
steps.
Readily
available
screening
level
data
includes
publicly
available
Agency
databases
and
reports
that
are
broad
enough
to
provide
nation­
wide
information
either
on
an
industry
basis
or
on
a
pollutant
basis.
(
The
latter
information
could
contribute
information
for
use
in
the
second­
level
screening
phase
where
changes
in
pollutant
toxicity
or
the
identification
of
new
chemicals
of
concern
are
considered
relative
to
recently
promulgated
effluent
guidelines.)

The
Team
has
documented
the
initial
results
of
the
data
evaluation
efforts
in
three
two
factorspecific
analyses
which
discuss
the
data
sources
identified
and
report
preliminary
results
accomplished
to
date.
These
are
the
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
and
the
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations.
The
draft
Analyses
were
distributed
to
the
workgroup
for
review
in
early
April,
2003,
and
workgroup
comments
are
currently
being
incorporated.

The
Factor
1
screening
analysis
seeks
to
review
potential
human
health
and
ecological
risk
associated
with
industrial
categories
of
point
source
discharges
of
pollutants
by
identifying
and
evaluating
readily
available
data
and
information.
The
Factor
1
Analysis
summarizes
findings
by
other
offices
in
EPA
by
1)
extracting
and
sorting
data
from
databases
including
the
Toxic
Release
Inventory
(
TRI)
and
the
Permit
Compliance
System
(
PCS),
2)
evaluating
ranking
results
generated
by
models
such
as
the
Risk
Screening
Environmental
Indicators
(
RSEI)
including
assessing
data
reliability,
and
3)
analyzing
the
results
from
all
sources
for
possible
patterns
or
consistency
of
concerns.
Industries
are
typically
identified
through
Standard
Industrial
November
10,
2003
DRAFT
Page
6
of
25
Classification
(
SIC)
codes,
whether
separately
or
aggregated
to
approximate
definitions
of
scope
for
existing
effluent
guidelines.
Data
gaps,
assumptions,
uncertainties,
biases,
and
caveats
will
also
be
discussed,
with
particular
focus
on
the
following:

!
Any
data
gaps
will
be
identified
in
the
analysis,
including
those
related
to
 
­
potential
ecological
impacts
­
variability
in
geographic
distribution
of
data
sources
­
pollutants
included/
not
included
(
conventional,
hormones,
pathogens,
antibiotics)
­
temporal
variation
between
data
sets
­
non­
water
media
sources
!
Where
data
gaps
exist,
or
work
is
not
yet
complete,
the
analysis
will
describe
the
work
that
is
planned
and
the
anticipated
time­
frame.
Tools
that
are
not
available
for
use
in
the
current
planning
cycle
but
potentially
of
use
in
future
cycles
are
discussed
in
a
separate
section
of
the
Analysis.
For
those
areas
that
continue
to
be
data
gaps,
the
screen
will
clearly
identify
these
areas
and
seek
stakeholder
input.

!
Bias
and
uncertainty
will
be
acknowledged
in
the
analysis.
For
example,
depending
on
data
sources,
we
are
more
likely
to
identify
pollutants
and
industry
sectors
identified
previously
versus
those
emerging
problems.
Also,
the
use
of
regional,
discrete
geographical
data
sets
are
more
likely
to
target
specific
pollutants
and
industries.
This
type
of
potential
bias
and
uncertainty
will
be
discussed
in
the
analysis.

!
Data
quality
and
our
confidence
in
each
of
the
data
sources
used
in
the
screen
will
be
discussed
in
the
screen.
In
addition,
how
we
considered
or
weighted
these
various
sources
relative
to
each
other
will
be
described
!
The
rationale
for
removal
of
any
existing
data
sources
from
the
analysis
(
e.
g.,
outlier
facilities
in
RSEI
analysis)
will
be
clearly
articulated
in
the
screen.

The
Factor
4
Analysis
considers
stakeholder
suggestions
about
ways
to
eliminate
inefficiencies
or
impediments
to
implementing
existing
effluent
guidelines.
For
the
initial
review
process,
the
304(
m)
Team
considered
suggestions
offered
by
stakeholders
during
the
comment
period
for
the
2002/
2003
Plan
and
during
the
comment
period
for
the
draft
Strategy.
The
team
also
considered
suggestions
collected
during
the
current
cycle
through
outreach
efforts
including
1)
presentations
at
national
conferences,
2)
meetings
and
teleconferences
with
external
stakeholder
groups,
and
3)
meetings
and
teleconferences
with
internal
stakeholder
groups.
The
team
also
sought
information
on
ways
to
promote
innovative
approaches
to
pollution
control,
and
alternative
controls
to
reduce
pollutant
discharges,
including
non­
regulatory
programs.
In
places
where
information
is
not
yet
available
or
work
is
not
yet
complete,
the
analysis
will
describe
the
work
that
is
planned
and
the
anticipated
time­
frame.
Tools
that
are
not
available
for
use
in
the
current
planning
cycle
but
potentially
of
use
in
future
cycles
are
discussed
in
a
separate
section
of
the
Analysis.
November
10,
2003
DRAFT
Page
7
of
25
The
specific
reports
and
databases
considered
through
this
point
in
the
process
are
identified
in
the
attached
two
Factor
Analysis
outlines.
This
list
is
not
exhaustive,
and
may
be
weighted
in
favor
of
Factor
1,
for
which
far
more
resources
have
been
identified.
In
addition,
once
workgroup
comments
are
addressed,
these
outlines
will
change
to
reflect
the
partitioning
between
tools
that
are
used
in
the
current
planning
cycle
and
those
that
may
be
useful
in
future
cycles.
The
304(
m)
Team
will
rely
on
the
workgroup
for
assistance
in
presenting
this
information
clearly
and
correctly
in
the
Factor
analyses,
including
discussions
of
completeness
and
reliability
of
the
information
provided.

The
304(
m)
Planning
Team
was
unsuccessful
in
its
attempt
to
obtain
the
information
needed
to
perform
a
meaningful
screening
level
analysis
both
for
Factor
2:
Technology
Innovation
and
Process
Changes
and
for
Factor
3:
Cost,
Performance,
and
Affordability.
As
a
result,
the
team
identified
the
industries
(
both
those
covered
by
an
existing
guideline
and
those
that
are
not)
with
concerns
established
in
either
the
Factor
1
analyses
(
addressing
discharge
amounts,
toxicity
and
effects)
or
Factor
4
analyses
(
addressing
efficiency
of
the
guidelines
and
NPDES
permitting
programs,
multi­
media
issues,
etc).
Before
proceeding
to
the
next
step,
described
below,
the
Team
is
preparing
overview
documents
for
each
of
these
industries.
These
documents
will
include
a
summary
of
the
concerns
identified
through
the
Factor
1
and
Factor
4
Analyses.
They
will
also
include,
to
the
extent
possible,
screening­
level
information
addressing
Factor
2
and
Factor
3.
The
draft
layout
of
those
overview
documents
is
also
attached
for
workgroup
review
and
comment.
Once
these
overview
documents
are
completed,
the
Team
will
share
the
results
with
the
workgroup,
and
with
workgroup
input,
the
Team
will
proceed
to
the
next
step
in
the
process.

The
workgroup
participated
in
the
304(
m)
Team
decisions
on
which
of
these
sources
of
information
should
be
part
of
the
planning
process
and
how
to
follow­
up
on
those
information
sources
that
are
retained.
The
workgroup
also
participated
in
the
process
of
identifying
industry
categories
which
appear
to
merit
further
investigation
and
thus
should
proceed
to
the
second­
level
screening.
An
initial
approach
to
doing
this
is
to
review
the
summary
documents
and
comparing
them
to
determine
whether
any
industries
appear
worthy
of
more
detailed
investigation.
The
workgroup
also
assisted
in
determining
whether
any
of
the
factor
results
should
be
weighted
more
heavily
and
why.

Eliminating
Categories
from
Further
Consideration
The
outcome
of
the
initial
screening
process
is
several
discrete
lists
of
industrial
categories
generated
as
a
result
of
each
factor­
specific
analysis.
The
next
phase
of
the
planning
process
includes
a
review
of
the
industries
identified
by
the
screening
level
review,
to
determine
whether
it
is
appropriate
to
continue
to
consider
them
under
the
304(
m)
planning
process.
EPA
used
four
criteria
to
help
establish
priorities
among
these
categories
for
further
study.

!
The
first
criterion
is
whether
rulemaking
is
already
underway
for
an
industry
category
identified
by
the
screening
level
process.
If
a
rulemaking
is
already
underway,
the
November
10,
2003
DRAFT
Page
8
of
25
concerns
identified
during
the
screening
process
would
be
shared
with
the
rulemaking
team,
and
the
industry
category
would
not
be
considered
for
further
investigation
as
part
of
this
process.

!
The
second
criterion
is
whether
an
effluent
guideline
has
recently
been
promulgated,
but
not
yet
implemented.
In
general,
EPA
would
probably
remove
categories
for
which
effluent
guidelines
have
been
promulgated
within
the
past
seven
years
from
the
lists,
and
not
consider
them
for
further
study
at
that
time.
A
seven­
year
time
frame
takes
into
account
the
lag
time
that
occurs
as
effluent
guidelines
are
implemented.
In
addition,
there
are
unlikely
to
be
dramatic
changes
in
the
industry
category
during
the
first
seven
years
after
promulgation
of
a
new
or
revised
guideline.

In
cases
where
EPA
is
aware
of
the
growth
of
a
new
segment
within
a
source
category,
or
in
cases
where
new
concerns
are
identified
for
previously
unevaluated
pollutants
(
such
as
endocrine
disruptors)
or
pollutants
whose
toxicity
determination
has
been
recently
revised
or
for
which
improved
analytical
methods
now
exist,
EPA
would
continue
to
list
the
subcategory
for
further
consideration.
The
304(
m)
Team
is
planning
to
obtain
this
information
through
several
sources,
including
information
provided
by
workgroup
members,
periodic
review
of
the
information
in
the
Integrated
Risk
Information
System
(
IRIS)
to
determine
whether
any
risk
values
have
been
revised
upward,
and
press
releases
and
other
news
items
identifying
new
information
on
pollutant
toxicity.

!
The
third
criterion
is
whether
the
source
category
has
demonstrated
continual
improvement
through
voluntary
effluent
reductions.
EPA
agrees
that
voluntary
efforts
should
be
encouraged
and
rewarded,
especially
where
those
voluntary
reductions
have
been
widely
adopted
within
an
industry
and
have
led
to
significant
reductions
in
pollutant
discharges.
Ultimately,
EPA
may
choose
not
to
revise
an
existing
effluent
guideline
or
develop
a
new
effluent
guideline
for
an
industrial
category
that
has
demonstrated
that
significant
progress
is
being
made
through
voluntary
industry
effort
to
reduce
risk
to
human
health
and
the
environment.
The
methodology
for
evaluating
this
criteria
has
not
yet
been
developed.
The
Agency
solicited
comments
on
this
issue
when
it
published
the
draft
Strategy
in
November,
and
will
share
all
suggestions
with
the
workgroup
for
discussion
and
assistance
in
developing
the
methodology.
Some
preliminary
information
is
included
in
the
draft
Factor
4
analysis.

!
The
fourth
criterion,
not
discussed
in
the
draft
Strategy,
was
identified
during
the
planning
process.
This
criterion
was
the
applicability
of
Section
304(
m)
of
the
CWA
for
the
industrial
category
identified.
For
example,
ocean
going
vessels
and
ballast
and
bilge
water
were
identified
as
concerns
during
the
screening
level
review
for
the
2004/
2005
Plan.
These
concerns
are
addressed
under
Section
312
of
the
CWA,
and
therefore
deemed
not
appropriate
for
further
investigation
under
Section
304(
m).
In
addition,
a
number
of
industrial
categories
identified
under
the
screening
process
were
composed
of
only
indirect
dischargers.
These
categories
are
addressed
under
Section
304(
g)
of
the
November
10,
2003
DRAFT
Page
9
of
25
CWA,
and
again
deemed
not
appropriate
for
further
investigation
under
Section
304(
m).

Ranking
Results
of
the
Analysis
Once
the
304(
m)
Team
and
the
workgroup
completes
its
consideration
of
the
previous
four
criteria,
they
rank
the
remaining
industry
categories
for
further
study.
The
attached
blank
summary
table
is
used
to
compile
the
results
of
the
screening
level
review
for
each
industry
identified
through
the
evaluation
of
the
Factors
described
above.
That
information
identifies
which
of
these
industry
categories
assists
the
304(
m)
Team
in
setting
priorities
and
making
recommendations
as
to
which
industry
categories
to
focus
further
investigations.
The
team
considered
1)
the
relative
size
of
the
industry
and
whether
it's
facilities
were
concentrated
in
a
region
or
nation­
wide,
2)
the
quantity
of
pollutants
discharged,
3)
the
potential
hazard
generated
by
those
discharges
when
pollutant
toxicity
was
included,
4)
the
relative
risk
posed
when
this
could
be
estimated,
5)
the
presence
of
facilities
on
impaired
river
reaches,
6)
the
extent
of
concerns
reported
by
stakeholders,
and
when
available,
7)
screening
level
economic
information
including
trends,
8)
information
on
the
pollutants
of
greatest
concern,
9)
changes
in
the
industry
or
in
the
wastewater
treatment
technologies
and
pollution
prevention
approaches,
and
10)
whether
there
were
any
EPA
tools
or
programs
available
or
underway
to
address
the
discharges.
The
results
of
this
exercise
are
being
reviewed
by
the
workgroup.

The
number
of
categories
for
which
EPA
will
be
able
to
conduct
further
study
may
vary
from
year
to
year
depending
upon
known
sources
of
information,
known
complexity
of
the
industry
category,
and
available
resources.
EPA
plans
to
select
industrial
categories
for
further
review
based
on
the
latest
information
available,
duly
noting
level
of
confidence
in
that
information
and
the
existing
gaps
in
information.
The
304(
m)
Team
will
rely
on
the
workgroup
to
assist
in
making
sound
decisions
at
this
current
stage
in
the
process.

Further
Investigation
Phase
During
this
phase,
the
304(
m)
Team
intends
to
focus
its
efforts
on
the
subset
of
industries
generated
in
the
previous
step.
The
team
will
continue
to
collect
and
analyze
as
much
information
as
possible
on
all
of
the
relevant
factors.
The
team
will
also
consider
using
proxy
data
where
necessary
and
available.
In
the
first
stage
of
in­
depth
study,
the
team
intends
to
validate
and
expand
on
the
basic
information
collected
on
each
category
during
the
initial
screening
step.
The
304(
m)
Team
will
also
begin
identifying
data
gaps
that
need
to
be
filled.
For
example,
for
each
industry
that
enters
this
phase,
the
304(
m)
Team
will
identify
and
verify
the
information
gathered
during
the
screening
level
review,
determine
which
factors
information
is
still
missing,
and
gather
information
necessary
to
address
each
of
the
four
factors
to
the
highest
possible
level
of
confidence
in
the
time
available.

The
general
method
for
doing
this
has
not
been
determined
at
this
time,
but
is
likely
to
parallel
the
process
used
by
the
Engineering
and
Analysis
Division
when
preparing
industry­
specific
studies.
It
will
entail
a
more
in­
depth
look
at
information
and
data
available
pertaining
to
each
of
the
November
10,
2003
DRAFT
Page
10
of
25
factors,
and
where
possible,
include
a
more
rigorous
assessment
of
the
factors.
One
aspect
of
this
phase
for
industries
with
existing
effluent
guidelines
will
be
a
comparison
of
each
industry's
discharged
pollutants
identified
through
TRI
and/
or
PCS
with
the
pollutants
for
which
limits
were
generated
in
the
existing
effluent
guideline.

Finally,
the
requirements
identified
by
the
information
quality
guidelines
and
Science
Policy
Council
Handbook
on
Peer
Review
will
be
addressed
during
this
phase
of
the
planning
process.
This
will
include
identifying
the
necessity
of
a
peer
review
and
any
science
products
that
would
require
peer
review.

In
order
to
ensure
that
the
best
possible
data
are
made
available
during
the
study
phase,
the
team
will
work
closely
with
both
the
workgroup
and
with
stakeholders,
including
industry,
States
and
local
governments,
academia,
environmental
groups,
and
members
of
the
public
to
gather
and
analyze
the
relevant
information.
This
includes
participation
in
conferences,
meetings,
and
teleconference
industry
associations,
and
distribution
of
the
screener
questionnaire.
Sampling
to
support
this
step
may
be
possible
to
support
future
Plans,
but
is
not
feasible
for
this
cycle.
The
304(
m)
Team
expects
the
results
of
this
phase
to
be
a
number
of
industry­
specific
profiles
with
information
pertaining
to
each
of
the
four
factors
and
a
discussion
of
how
these
factors
interrelated
For
example,
the
information
on
impacts
to
human
health
and
the
environment
and
on
available
wastewater
technologies
will
be
compared
with
anticipated
costs
to
change
or
introduce
such
technologies.

The
workgroup
will
be
asked
to
review
these
profiles
for
soundness
of
their
contents
and
completeness
of
their
coverage
as
part
of
the
review
process
for
the
final
Plan.
Preliminary
results
of
this
step
should
be
available
for
workgroup
review
by
the
time
of
the
preliminary
review
of
the
final
Plan
in
mid­
October,
2003,
more
definitive
results
should
be
available
for
workgroup
review
by
the
FAR
step
of
the
final
Plan
in
mid­
November,
2003.

Decision
on
Effluent
Guidelines
Rulemaking
Activities
After
considering
the
results
of
the
studies
generated
in
the
previous
step,
EPA
would
then
determine
whether
development
or
revision
of
an
effluent
guideline
is
appropriate.
Final
determinations
would
be
presented
in
the
next
biennial
effluent
guidelines
plan.
If
EPA
determines
that
developing
a
new
or
revised
effluent
guideline
is
not
appropriate,
EPA
would
attempt
to
identify
other
Agency
actions
that
may
be
appropriate
to
address
any
remaining
risk.
Such
action
may
include
the
issuance
of
compliance
or
permitting
guidance,
technical
assistance
to
the
States
or
industry,
or
a
voluntary
partnership
to
support
broader
environmental
goals.
For
example,
EPA
may
determine
that
a
targeted
program
to
implement
comprehensive
Environmental
Management
Systems
is
a
more
efficient
approach
to
dealing
with
certain
types
of
environmental
issues.
This
effort
would
include
input
from
the
workgroup,
though
it
is
uncertain
whether
this
phase
will
be
reached
during
the
development
of
the
2004/
2005
Plan.
Preliminary
results
of
this
step
may
be
available
for
workgroup
review
by
the
time
of
FAR
step
of
the
final
Plan
in
mid­
November,
2003.
November
10,
2003
DRAFT
Page
11
of
25
V.
KEY
ISSUES
There
are
several
specific
issues
discussed
in
the
draft
Strategy
about
which
EPA
requested
comments.
All
suggestions
received
from
commenters
on
the
draft
Strategy
will
be
shared
with
the
workgroup
for
evaluation
as
part
of
the
preamble
for
the
proposed
Plan
and
in
the
draft
response
to
comments.
The
workgroup
is
also
invited
to
provide
their
input
to
these
issues,
which
are
synopsized
below.

Four
Factors

the
appropriateness
of
the
four
factors,
and
whether
additional
or
different
factors
would
be
more
appropriate;

whether
each
of
the
four
factors
should
be
ranked,
and
if
so,
whether
different
weights
should
be
applied
to
each;
and

what
constitutes
a
significant
discharge
of
toxic
&
nonconventional
pollutants
under
CWA
section
304(
m)(
1)(
B)
to
determine
for
which
"
new"
categories
EPA
is
required
to
develop
effluent
guidelines.

Screening
Level
Review
Phase

suggestions
on
information
on
sources
of
water
quality
impairments,
particularly
data
relating
to
facilities
that
discharge
to
publicly
owned
treatment
works
(
POTWs);
and

whether
new
or
better
tools
would
allow
for
a
meaningful,
screening­
level
review
of
the
performance,
cost
and
economic
achievability
of
new
or
additional
technologies
for
55
already­
regulated
industrial
categories
on
an
annual
basis,
as
well
as
a
similar
review
for
all
unregulated
industry
categories.

Ranking
Results
of
the
Analysis

what
information
the
Agency
should
use
to
prioritize
industrial
categories
that
survive
the
secondary
screening
level.

Loading
Reductions
(
Voluntary
and
Multi­
media)

how
the
Agency
should
evaluate
voluntary
loading
reduction,
including
possibly
setting
as
a
target
a
specific
goal,
such
as
a
10
or
25
percent
reduction
in
total
or
toxic­
equivalent
load;

how
the
EPA
can
identify
categories
for
which
loadings
have
decreased,
in
addition
to
the
information
in
the
PCS
system

how
to
assess
voluntary
pollutant
reductions
in
industrial
categories
with
increased
production
over
five
years.

how
to
evaluate
claims
of
decreases
in
water
loadings
of
toxicity
relative
to
possible
increases
in
release
of
these
emissions
to
other
environmental
media,
for
example
volatilization
to
air
or
land
disposal
of
sludge;

the
extent
to
which
the
Agency
should
consider
multi­
media
pollutant
reduction
opportunities,
and
the
relative
weight
the
Agency
should
assign
to
loading
reductions
to
November
10,
2003
DRAFT
Page
12
of
25
surface
waters
relative
to
reductions
in
loadings
to
other
media;
and

ways
to
identify
industry
categories
for
which
development
or
revision
of
an
effluent
guideline
may
provide
an
opportunity
for
multi­
media
pollutant
reduction.

Future
of
the
Effluent
Guidelines
Program

ways
the
Agency
might
structure
the
effluent
guidelines
program
to
encourage
and
reward
technology
innovation;

the
role
of
market­
based
incentives,
including
pollutant
trading,
can
play
in
the
effluent
guidelines
program;
and

whether
EPA
should
devote
the
same,
less,
or
greater
resources
to
the
effluent
guidelines
program
as
it
has
in
the
past.

VI.
REGULATORY
DEVELOPMENT
REQUIREMENTS
There
are
several
specific
regulatory
development
requirements,
mostly
analytical,
that
are
imposed
on
Agency
actions
by
the
Presidential
Executive
Orders
(
E.
O.
s),
EPA
policy
or
by
other
statutory
or
legal
requirements.
An
assessment
of
applicable
regulatory
development
requirements
is
provided
in
the
following
table.
Only
one
of
these
requirements
applies
to
the
Plan.
The
rest
are
applicable
only
to
regulatory
actions.
However,
the
Agency
will
be
including
consideration
of
several
of
the
issues
addressed
by
these
E.
O.
s
as
part
of
the
planning
process
for
developing
the
Plan.
All
of
these
requirements
considered
as
part
of
the
development
of
the
Plan
are
discussed
below.
(
The
order
of
the
discussion
reflects
the
order
presented
in
the
table.)

Regulatory
Development
Requirements
Applicability1
E.
O.
12630,
Governmental
Actions
and
Interference
with
Constitutionally
Protected
Property
Rights
NA
E.
O.
12866,
Regulatory
Planning
and
Review
A
E.
O.
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations
NA/
C
E.
O.
12988,
Civil
Justice
Reform
(
replaces
E.
O.
12788)
NA
E.
O.
13045,
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
NA/
C
E.
O.
13132,
Federalism
NA/
C
E.
O.
13175,
Consultation
with
Tribes
NA
Regulatory
Development
Requirements
Applicability1
November
10,
2003
DRAFT
Page
13
of
25
E.
O.
13211,
Actions
Concerning
Regulations
that
Significantly
Affect
Energy
Supply
NA
Regulatory
Flexibility
Act
NA/
C
Unfunded
Mandates
Reform
Act
NA/
C
Paperwork
Reduction
Act
NA/
C
National
Technology
Transfer
and
Advancement
Act
NA/
C
Congressional
Review
Act
NA
A
=
Applicable
as
a
Tier
2
Action
NA
=
Not
Applicable
­
the
requirement
does
not
need
to
be
addressed
in
the
Federal
Register
Notice.
NA/
C
=
Not
Applicable,
but
will
be
included
in
the
planning
process.

E.
O.
12866,
Regulatory
Planning
and
Review
Although
the
Agency's
biennial
plan
is
not
a
regulation,
there
are
no
impacts
to
be
evaluated
relative
to
the
twelve
points
identified
in
this
Executive
Order.
For
example,
there
are
no
inherent
costs
associated
with
publishing
the
Plan.
However,
the
planning
process
follows
quite
closely
the
concerns
listed
in
this
Executive
Order,
including
efforts
to
(
1)
identify
the
problem
effluent
guidelines
may
address
and
the
significance
of
those
problems;
(
2)
identify
whether
existing
regulations
have
created
or
contributed
to
those
problems
and
whether
modifications
to
those
regulations
would
resolve
those
problems;
(
3)
identify
and
assess
available
alternatives
to
direct
regulation;
(
4)
set
priorities
based
on
a
consideration
of
the
degree
and
nature
of
the
risks
posed;
(
5)
evaluate
incentives
to
innovation;
(
6)
identify
potential
costs
and
benefits;
(
7)
utilize
the
best
reasonably
obtainable
scientific,
technical,
economic,
and
other
information;
(
8)
identify
and
assess
alternative
forms
of
regulation;
(
9)
seek
views
of
appropriate
State,
local,
and
tribal
officials
as
part
of
the
planning
process;
and
(
10)
avoid
duplicative
efforts
where
a
problem
is
already
being
addressed
by
other
regulatory
programs.

E.
O.
12898,
Federal
Actions
to
Address
Environmental
Justice
in
Minority
Populations
and
Low­
Income
Populations
Since
the
Plan
is
not
a
regulation,
there
are
no
impacts
to
be
evaluated
relative
to
Environmental
Justice.
However,
the
304(
m)
Team
plans
to
consider
such
impacts
as
part
of
the
industryspecific
evaluation
of
Factor
One
concerns
(
impacts
to
human
health
and
the
environment)
during
the
Further
Investigation
Phase.
The
team
is
currently
attempting
to
develop
a
method
for
evaluating
disproportionate
impacts
on
minority
and
low
income
communities
or
individuals,
and
will
rely
on
the
workgroup
to
provide
information
and
suggestions
as
that
method
progresses.
November
10,
2003
DRAFT
Page
14
of
25
E.
O.
13045,
Protection
of
Children
from
Environmental
Health
Risks
and
Safety
Risks
Since
the
Plan
is
not
a
regulation,
there
are
no
impacts
to
be
evaluated
relative
to
children's
health.
However,
the
304(
m)
Team
plans
to
consider
such
impacts
as
part
of
the
industry­
specific
evaluation
of
Factor
One
concerns
(
impacts
to
human
health
and
the
environment)
during
the
Further
Investigation
Phase.
The
team
is
currently
attempting
to
develop
a
method
for
identifying
any
disproportionate
impacts
on
children,
and
will
rely
on
the
workgroup
to
provide
information
and
suggestions
as
that
method
progresses.

E.
O.
13132,
Federalism
Since
the
Plan
is
not
a
regulation,
there
are
no
policies
to
be
evaluated
by
State
and
local
officials
for
potential
federalism
concerns.
However,
we
will
be
including
State
and
local
officials
as
part
of
our
Stakeholders
list
to
receive
announcements
about
the
planning
process
and
the
development
of
the
2004/
2005
Plan.
This
includes
the
following
organizations:
the
National
Governor's
Association,
the
National
Conference
of
State
Legislatures,
the
Council
of
State
Governments,
the
National
League
of
Cities,
the
U.
S.
Conference
of
Mayors,
the
National
Association
of
Counties,
the
International
City/
County
Management
Association,
the
National
Association
of
Towns
and
Townships,
and
the
County
Executives
of
American,
as
well
as
the
Agency's
Local
Government
Advisory
Committee.
They
will
be
informed
about
the
Plan
and
invited
to
participate
during
the
public
comment
period.

Regulatory
Flexibility
Act
Since
the
Plan
is
not
a
regulation,
there
will
be
no
impacts
to
small
businesses.
However,
the
304(
m)
Team
plans
to
consider
such
impacts
as
part
of
the
industry­
specific
evaluation
of
Factor
Three
concerns
(
economic
considerations
including
cost,
performance,
and
affordability)
during
the
Further
Investigation
Phase.

Unfunded
Mandates
Reform
Act
Since
the
Plan
is
not
a
regulation,
there
will
be
financial
impacts.
However,
the
304(
m)
Team
plans
to
consider
such
impacts
as
part
of
the
industry­
specific
evaluation
of
Factor
Three
concerns
(
economic
considerations
including
cost,
performance,
and
affordability)
during
the
Further
Investigation
Phase.

Paperwork
Reduction
Act
This
requirement
will
be
triggered
when
the
Agency
distributes
the
screener
questionnaire
it
is
developing
to
support
the
planning
process.
This
questionnaire
is
not
expected
to
be
completed
in
time
to
benefit
the
development
of
the
2004/
2005
Plan,
but
is
currently
under
development
and
will
meet
all
Paperwork
Reduction
Act
requirements.

National
Technology
Transfer
and
Advancement
Act
Since
the
Plan
is
not
a
regulation,
no
technical
standards
will
be
set,
and
therefore
no
requirement
to
consider
voluntary
concensus
standards.
However,
EPA
will
be
considering
voluntary
approaches
as
part
of
its
Factor
Four
analysis,
and
will
be
evaluating
technology
advances
as
part
of
its
Factor
Two
analysis.
November
10,
2003
DRAFT
Page
15
of
25
VII.
ANALYTIC
AND
OTHER
PRODUCTS
REQUIRED
FOR
PROPOSED
PLAN
Draft
Factor
Analyses
Draft
analyses
of
Factors
1
and
4,
discussed
above,
will
be
used
to
support
the
proposed
Plan.
These
analyses
will
be
reviewed
at
least
twice
by
the
workgroup
before
proposal
of
the
Plan
in
the
Federal
Register,
during
both
an
informal
review
period
and
during
the
Final
Agency
Review.

Category­
Specific
Overview
Documents
Two­
page
overview
documents
(
summary
tables)
are
prepared
for
each
of
the
industries
identified
in
the
Factor
1
and
Factor
4
Analyses
and
surviving
the
four
elimination
criteria.
These
documents
will
include
a
summary
of
the
concerns
identified
through
the
two
Factor
Analyses.
They
will
also
include,
to
the
extent
possible,
screening­
level
information
addressing
Factor
2
and
Factor
3.
These
documents
will
be
used
to
select
industries
for
detailed
investigation.

Response
to
Comments
on
the
draft
Strategy
The
comment
period
for
the
draft
Strategy
closed
on
February
27,
2003.
A
response
to
those
comments
will
be
prepared
and
included
in
the
public
record
for
the
proposed
Plan.
This
response
will
be
shared
with
the
workgroup.
Any
comments
that
address
the
issues
outlined
above
will
also
be
shared
with
the
workgroup
for
consideration
and
possible
inclusion
in
the
planning
process.
Any
comments
that
suggest
specific
industry
categories
to
be
considered
for
development
or
revision
of
an
effluent
guideline
will
also
be
shared
with
the
workgroup
and
those
suggestions
will
be
included
in
the
Factor
Four
Analysis.

Response
to
Comments
from
the
2002/
2003
Plan
That
Apply
In
response
to
the
proposed
Effluent
Guidelines
Program
Plan
for
2002/
2003,
several
commenters
suggested
specific
industry
categories
to
be
considered
for
development
or
revision
of
an
effluent
guideline.
Those
comments
have
been
synopsized
and
will
be
included
in
the
Factor
Four
Analysis
as
well.
The
workgroup
will
be
invited
to
review
this
analysis
(
as
well
as
the
others)
during
the
spring
review
period.

VIII.
RESOURCES
The
304(
m)
Team
is
comprised
of
a
team
leader,
and
contributions
of
time
from
an
engineer,
an
economist,
an
environmental
assessor,
a
GIS/
database
analyst,
analytical
methods
staff,
and
a
statistician.
The
team
is
also
supported
by
the
efforts
of
one
full­
time
detailee
from
the
Office
of
Pesticides
Programs
and
by
the
participation
of
an
engineer
technical
coordinator
and
a
branch
chief.
Between
$
600K
to
$
950K
is
budgeted
to
support
this
program.
These
funds
will
primarily
be
used
to
conduct
screening­
level
reviews
on
the
toxicity,
amount
and
effect
of
industrial
discharges
of
pollution,
detailed
reviews
as
appropriate
on
a
subset
of
industrial
categories,
and
outreach
efforts.
Additional
support
is
being
provided
by
the
Office
of
Pollution
Prevention,
which
performed
the
initial
runs
of
the
Risk
Screening
Environmental
Indicators
(
RSEI)
model.
November
10,
2003
DRAFT
Page
16
of
25
IX.
WORKGROUP
As
a
result
of
the
Tiering
exercise,
the
following
workgroup
was
formed.
2004/
2005
Program
Plan
Workgroup
Members
Office:
Representative:
OAR
Barbara
Driscoll
OECA
Steve
Rubin
OGC
Carol
Ann
Siciliano
OGWDW
Robyn
Delahanty
(
lead),
Suzanne
Kelly
OPEI
Mindy
Gampel
(
lead),
Roger
Holtorf,
Michael
Hessling,
Amanda
Bassow
OPPTS
Steven
Hassur
(
lead),
Richard
Engler
ORD
Pam
Noyes
(
lead),
Glenn
Shaul,
Danielle
Tillman
OROSLR
Anne
Randolph
OSWER
Steve
Kroner
(
lead),
Nerendra
Chaudhari,
Lisa
Lauer
OW­
OWM
Jan
Pickrel
Region
2
Judy­
Ann
Mitchell
(
Regional
Coordinator)
Region
5
Matthew
Gluckman
Region
6
Brian
Mueller,
Scott
Wilson
Region
8
Bruce
Kent
X.
CONTACT
INFORMATION
For
information,
please
contact:
Carey
Johnston,
team
leader
Engineering
and
Analysis
Division
Office
of
Science
and
Technology
EPA's
Office
of
Water
202/
566­
1014
johnston.
carey@
epa.
gov
Tom
Wall,
branch
chief
Engineering
and
Analysis
Division
Office
of
Science
and
Technology
EPA's
Office
of
Water
202/
566­
1060
wall.
tom@
epa.
gov
Attachments
Factor
1
Analysis:
Human
Health
and
Environmental
Risk
OUTLINE
of
Initial
Draft
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
OUTLINE
of
Initial
Draft
Industry­
Specific
Overview
Document:
Structure
and
Definitions
November
10,
2003
DRAFT
Page
17
of
25
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
Status
of
Screening
Level
Review
Phase
Table
of
Contents
May
7,
2003
EXECUTIVE
SUMMARY
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ES­
1
1.0
INTRODUCTION
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1­
1
2.0
TOXIC
RELEASE
INVENTORY
DATA
AND
ANALYSES
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2­
1
2.1
Overview
of
TRI
Reporting
and
Relation
to
RSEI
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2­
1
2.2
The
RSEI
Model
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2­
2
2.2.1
Calculation
of
Risk­
Related
Results
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2­
3
2.2.2
Preliminary
Findings
from
Risk
Screening
Level
Analysis
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2­
5
2.2.3
Preliminary
Findings
from
Environmental
Justice
Analysis
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2­
10
2.2.4
Potential
Susceptible
Populations
Analysis
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2­
12
3.0
PERMIT
COMPLIANCE
SYSTEM
DATA
AND
ANALYSES
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3­
1
3.1
Description
of
PCS
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3­
1
3.2
PCS
Use
for
Human
Health
and
Environmental
Impacts
Analysis
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3­
2
4.0
WATER
QUALITY
IMPAIRMENT
DATA
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4­
1
4.1
National
Water
Quality
Inventory:
2000
Report
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4­
1
4.1.1
Description
of
Resource
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4­
1
4.1.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
4­
2
4.2
Dischargers
to
Impaired
Waters
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4­
6
4.2.1
Approach
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4­
6
4.2.2
Results
from
July
2002
Analysis
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4­
6
4.2.3
Results
from
March
2003
Analysis
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4­
6
4.2.4
Additional
Analysis
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4­
6
4.3
Ambient
Water
Quality
Near
Industrial
Facilities
(
STORET)
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4­
8
4.3.1
Description
of
Resource
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4­
9
4.3.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
4­
9
5.0
U.
S.
GEOLOGICAL
SURVEY
(
USGS)
DATA
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5­
1
5.1
National
Water
Quality
Assessment
Program
(
NAWQA)
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5­
1
5.1.1
Description
of
Resource
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.
.
.
.
.
.
.
.
.
5­
1
5.1.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
5­
2
5.2
NAWQA
National
Report
on
Nutrients
.
.
.
.
.
.
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.
.
5­
3
5.2.1
Description
of
Resource
.
.
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.
.
5­
3
5.2.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
5­
4
November
10,
2003
DRAFT
Page
18
of
25
5.3
National
Water
Information
System
(
NWIS)
.
.
.
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.
.
.
.
.
.
.
.
.
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.
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.
.
5­
4
5.3.1
Description
of
Resource
.
.
.
.
.
.
.
.
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.
.
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.
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.
.
.
.
.
.
.
5­
4
5.3.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
5­
5
5.4
Applications
of
SPARROW
.
.
.
.
.
.
.
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.
.
.
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.
.
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.
.
.
5­
5
5.4.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
5­
6
5.4.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
5­
7
6.0
OFFICE
OF
SCIENCE
AND
TECHNOLOGY
DATA
AND
RESOURCES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
1
6.1
Resources
Providing
Chemical­
Specific
and
Point
Source
Discharge
Data
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
6­
1
6.1.1
The
National
Sediment
Contaminant
Point
Source
Inventory
(
1997)
.
.
6­
1
6.1.2
Better
Assessment
Science
Integrating
point
and
Nonpoint
Sources
(
BASINS)
Model
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
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.
.
.
.
.
.
.
.
6­
5
6.1.3
Conclusions/
Recommendations
for
Resources
Providing
Chemical­
Specific
and
Point
Source
Discharge
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6.2
Resources
Providing
Chemical­
Specific
Data
Only
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
6
6.2.1
National
Listing
of
Fish
and
Wildlife
Consumption
Advisories
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
6­
7
6.2.2
National
Fish
Tissue
Study
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
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.
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.
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.
.
.
.
.
.
.
.
.
.
6­
9
6.2.3
National
Sediment
Quality
Survey
(
2001)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
6­
10
6.2.4
Beaches
Environmental
Assessment
and
Coastal
Health
Act
(
BEACH
Act)
6­
12
6.2.5
Conclusions/
Recommendations
for
Resources
Providing
Chemical­
Specific
Data
Only
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
6­
13
7.0
DRINKING
WATER
DATA
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
7­
1
7.1
Safe
Drinking
Water
Act
Candidate
Contaminant
List
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7­
1
7.1.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
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.
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.
.
.
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.
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.
.
.
.
.
.
.
7­
1
7.1.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
7­
2
7.2
Source
Water
Assessment
Program
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
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.
.
.
.
7­
2
7.2.1
Description
of
Resource
.
.
.
.
.
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.
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.
.
.
.
.
.
.
7­
3
7.2.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
7­
4
8.0
OFFICE
OF
RESEARCH
AND
DEVELOPMENT
TOOLS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
1
8.1
Resources
Providing
Regional
Data
on
Chemical
Contaminants
.
.
.
.
.
.
.
.
.
.
.
8­
1
8.1.1
Environmental
Monitoring
and
Assessment
Program
(
EMAP)
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
8­
1
8.1.2
Regional
Vulnerability
Assessment
(
ReVA)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
2
8.1.3
Conclusions/
Recommendations
for
Resources
Providing
Regional
Data
on
Chemical
Contaminants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
3
8.2
Resources
for
Estimating
Potential
Exposure
and
Risk
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
4
8.2.1
Frameworks/
Multimedia,
Multipathway
and
Multireceptor
Risk
Assessment
(
3MRA)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
8­
4
8.2.2
Total
Human
Exposure
Risk
Database
and
Advanced
November
10,
2003
DRAFT
Page
19
of
25
Simulation
Environment
(
THERdbASE)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
8­
5
8.2.3
Total
Exposure
Model
(
TEM)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
8­
6
9.0
ADDITIONAL
SOURCES
OF
DATA
.
.
.
.
.
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.
.
.
.
9­
1
9.1
Pathogen
Impacts
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
9­
1
9.1.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9­
1
9.1.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
9­
2
9.2
Gulf
Hypoxia
Action
Plan
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
9­
2
9.2.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9­
2
9.2.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
9­
3
9.3
National
Report
on
Human
Exposure
to
Environmental
Chemicals
.
.
.
.
.
.
.
.
.
9­
5
9.3.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
9­
5
9.3.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
9­
6
10.0
NON­
FEDERAL
AGENCY
RESOURCES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
.
.
.
.
.
.
.
10­
1
10.1
Toxic
Releases
and
Health:
A
Review
of
Pollution
Data
and
Current
Knowledge
on
the
Health
Effects
of
Toxic
Chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
10­
1
10.1.1
Description
of
Resource
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
10­
1
10.1.2
Resource
Use
for
Human
Health
and
Environmental
Impacts
Analysis
10­
3
11.0
CONCLUSIONS
AND
RECOMMENDATIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
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.
.
.
.
.
.
.
.
11­
1
November
10,
2003
DRAFT
Page
20
of
25
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
Status
of
Screening
Level
Review
Phase
Table
of
Contents
May
8,
2003
EXECUTIVE
SUMMARY
.
.
.
.
.
.
.
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.
ES­
1
1.0
INTRODUCTION
.
.
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.
1­
1
2.0
STAKEHOLDER
INPUT
.
.
.
.
.
.
.
.
.
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.
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.
.
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.
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.
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.
.
.
.
.
.
.
.
2­
1
2.1
Comments
on
the
Proposed
2002/
2003
Effluent
Guidelines
Program
Plan
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
2­
1
2.1.1
Industrial
Categories
Without
Guidelines
(
Alphabetically)
.
.
.
.
.
.
.
.
.
.
2­
1
2.1.2
Industrial
Categories
With
Guidelines
(
Alphabetically)
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
2.1.3
Pollutants
of
Concern
(
Alphabetically)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
3
2.2
Comments
on
Draft
Strategy
for
National
Clean
Water
Industrial
Regulations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
2­
3
2.3
Previous
Outreach
Efforts
.
.
.
.
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.
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.
.
.
2­
4
2.4
NPDES
Permit
Review
Process
.
.
.
.
.
.
.
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.
.
2­
7
2.5
Internal
EPA
Stakeholders
.
.
.
.
.
.
.
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.
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.
.
.
2­
8
2.6
Other
Governmental
Bodies
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
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.
.
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.
.
.
.
.
.
.
2­
9
2.6.1
FACAs
for
State
and
Local
Governments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
9
2.6.2
Water
Pollution
Control
Authorities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
11
3.0
VOLUNTARY
LOAD
REDUCTIONS
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
3­
1
3.1
Suggestions
From
Stakeholders
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
1
3.2
Permit
Compliance
System
(
PCS)
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
.
.
.
3­
2
3.3
Toxic
Release
Inventory
(
TRI)
Data
.
.
.
.
.
.
.
.
.
.
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.
.
3­
3
3.4
Design
for
the
Environment
(
DfE)
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
3­
5
4.0
OTHER
EPA
OFFICES'
RANKINGS
&
LISTS
FOR
MULTI­
MEDIA
CONCERNS
.
.
.
.
.
.
.
.
.
4­
1
4.1
Office
of
Air's
Integrated
Urban
Air
Toxics
Strategy
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
1
4.2
Office
of
Enforcement
and
Compliance
Assurance
Sector
Notebooks
.
.
.
.
.
.
4­
5
4.3
Office
of
Enforcement
and
Compliance
Assurance
Multi­
media
Data
Systems
4­
7
4.3.1
Sector
Facility
Indexing
Project
(
SFIP)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
8
4.3.2
Integrated
Data
for
Enforcement
Analysis
(
IDEA)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10
4.3.3
Integrated
Compliance
Information
System
(
ICIS)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
9
4.3.4
Enforcement
Compliance
History
Online
(
ECHO)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
9
4.6
Office
of
Policy,
Economics,
and
Innovation's
Sector
Ranking/
Performance
Project
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
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.
.
.
.
.
.
.
4­
11
4.7
Office
of
Environmental
Information/
Office
of
Research
and
Development
Environmental
Indicators
Initiative
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
4­
12
November
10,
2003
DRAFT
Page
21
of
25
4.8
National
Advisory
Council
for
Environmental
Policy
and
Technology
(
NACEPT)
Report:
Emerging
Challenges
and
Opportunities
for
EPA
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
4­
13
5.0
POTENTIAL
ALTERNATIVE
APPROACHES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
5­
1
5.1
Office
of
Air
Quality
Planning
and
Standards
Innovative
Regulatory
Strategies
Program
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
.
5­
1
5.2
Trading
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
5­
3
5.3
Voluntary
Programs/
Pollution
Prevention
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
5­
4
5.3.1
Environmental
Management
Systems
(
EMSs)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
5­
4
6.0
CONCLUSIONS
AND
RECOMMENDATIONS
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
6­
1
November
10,
2003
DRAFT
Page
22
of
25
Selecting
Industries
for
Detailed
Review:
Summary
Table
for
Industry
Name
Here
Date
Category
Information
New
or
Existing:

SIC
Code(
s)
Covered
in
Whole
or
in
Part:

Date(
s)
Promulgated/
Revised:
Date
of
Most
Recent
EAD
Study:

Facility
Count
Information
Facilities
Census
Data
(
Year
1997)
TRI/
RSEI
Reporters
(
Year
2000)
PCS
(
Year
2000)
Indexed
to
Waterbody
Segments
All
Reporting
w/
Loading
Estimates
Total
#
Directs
#
Indirects
Discharge
Information
(
All
for
Year
2000)

Pollutant
Type
&
Pounds
TRI/
RSEI
PCS
Other
Sources
Lbs
TWPE
Lbs
TWPE
Priority
Nonconventional
Conventional
Category
Ranking
(
All
for
Year
2000)

Hazard
Rank
#
facilities
=
90%
hazard
Risk
Rank
#
facilities
=
90%
risk
Impairment
Rank
Cause(
s)
of
Impairment
#
PCS
facilities
on
imp.
reaches
(%
tot)
November
10,
2003
DRAFT
Page
23
of
25
Selecting
Industries
for
Detailed
Review:
Summary
Table
for
Industry
Name
Here
continued
Factor
Analyses
Results
(
How
Identified)

Screening
Level
Factor
1
Concerns
Screening
Level
Factor
4
Concerns
Economic
Screen
(
1997
Data)

Sales/
Revenue
#
Employees
#
Firms
%
Small
Capital
Expend
Noteworthy
Issues
Pollutants
Driving
Concern?

Geographic
Concentration?

Industry
Changed
since
ELG?

Advances
in
P2
and
WWT?

Economic
Trends?

Other
Tools
to
Address
Concern?

Ongoing
Agency
Activities?

Recommendations
November
10,
2003
DRAFT
Page
24
of
25
Data
Dictionary
for
Summary
Table
Data
Element
or
Section
Description
New
or
Existing
This
refers
to
whether
the
industry
category
is
currently
not
regulated
under
an
existing
effluent
guideline
point
source
category
(
new)
OR
is
regulated
under
an
existing
effluent
or
is
identified
as
a
new
subcategory
under
an
existing
effluent
guideline
point
source
category
(
existing).

SIC
Code(
s)
Covered
in
Whole
or
in
Part:
This
refers
to
the
Standard
Industrial
Classification
(
SIC)
codes
that
were
used
to
`
roll
up'
data
at
the
SIC
level
into
this
industry
category.
Whenever
possible,
EPA
attempted
to
avoid
the
double
counting
of
SIC
level
data
into
two
or
more
industry
categories
investigated
as
part
of
the
304(
m)
planning
process.
SIC
codes
organizes
business
entities
into
production­
based
and
market­
based
categories
identified
by
a
4­
digit
code.
There
are
three
levels
of
SIC
codes:
primary,
secondary,
and
tertiary.
Primary
SIC
codes
are
assigned
based
on
the
principal
product
or
group
of
products
produced
or
distributed
by
an
establishment
or
for
services
rendered
by
the
plant.
Additional
SIC
codes
are
assigned
for
any
secondary
and
tertiary
products
produced
or
for
services
rendered
by
an
establishment.

Date(
s)
Promulgated/
Revised:
This
refers
to
the
first
time
EPA
promulgated
effluent
guidelines
for
this
industry
category
and
any
subsequent
revisions.

Date
of
Most
Recent
EAD
Study:
This
refers
to
the
most
recent
date
when
EPA
completed
a
study
(
not
a
rulemaking)
for
this
industry
category.

Facility
Count
Information
This
section
of
the
summary
sheet
uses
data
from
four
main
sources:
­
U.
S.
Census
1997
Economic
Census;
­
Toxic
Release
Inventory
(
TRI);
­
Permit
Compliance
System
(
PCS);
and
­
303(
d)
Impaired
Waters
Information.

EPA
was
only
able
to
use
the
TRI
data
to
differentiate
between
direct
and
indirect
dischargers.
The
PCS
data
element
"
All
Reporting"
identifies
all
facilities
(
major
and
minor)
that
report
a
SIC
code.
Please
note
that
many
minor
facilities
do
not
have
SIC
codes
in
PCS.
The
PCS
data
element
"
w/
Loading
Estimates"
identifies
the
number
of
facilities
in
this
industry
category
that
EPA
was
able
to
calculate
pollutant
loadings
estimates.

The
term
"
Indexed
to
Waterbody
Segments"
lists
the
number
of
facilities
in
this
industrial
category
that
are
linked
to
RF1
segments.
Data
Element
or
Section
Description
November
10,
2003
DRAFT
Page
25
of
25
Discharge
Information
(
All
for
Year
2000)
This
section
reports
the
estimate
of
pounds
discharged
from
TRI
and
PCS
in
categories
of
priority,
non­
conventional,
and
conventional
pollutants.
This
section
reports
the
straight
pollutant
pounds
discharged
(
unweighted)
and
the
toxic
pollutant
pounds
discharged
(
weighted
through
use
of
EAD's
toxic
weighting
factor
and
identified
as
toxic
weighted
pound
equivalents
(
TWPE)).

Category
Ranking
(
All
for
Year
2000)
EPA
identified
those
industries
that
cumulatively
represent
90%
of
the
risk
or
hazard
across
all
industry
categories.
If
an
industry
category
is
a
component
of
this
90%
of
the
risk
or
hazard
total,
then
its
rank
is
listed
along
with
the
total
number
of
industrial
categories
that
make
up
this
90%
of
the
risk
or
hazard
total.
If
an
industry
category
is
not
part
of
this
90%
of
the
risk
or
hazard
total,
then
`
NA'
is
reported
in
the
table.

The
term
"#
facilities
=
90%
hazard"
identifies
the
number
of
facilities
in
this
industry
category
that
comprise
90%
of
the
hazard
for
this
industrial
sector.

The
term
"#
facilities
=
90%
risk"
identifies
the
number
of
facilities
in
this
industry
category
that
comprise
90%
of
the
risk
for
this
industrial
sector.
EPA
was
only
able
to
calculate
this
value
for
TRI
data.

Cause(
s)
of
Impairment
This
term
identifies
the
reasons
for
impairment
on
water
segments
linked
to
facilities
in
this
industrial
category
(
see
also
"#
PCS
facilities
on
imp.
reaches
(%
tot)").

#
PCS
facilities
on
imp.
reaches
(%
tot)
This
term
identifies
2002
PCS
facilities
that
discharge
to
303(
d)
listed
impaired
waters,
where
at
least
one
"
pollutant
discharged"
is
the
same
as
at
least
one
of
the
pollutants
identified
as
a
cause
of
impairment.
"
Pollutant
discharged"
refers
to
either
PCS
parameters
or
Typical
Pollutant
Concentrations
(
TPC).
PCS
limits
are
used
to
assign
PCS
majors
to
impaired
waters.
TPCs
­
pollutants
typically
discharged
by
facilities.

The
percentage
in
parentheses
refers
to
the
percentage
of
the
number
of
PCS
facilities
in
this
industrial
category
on
impair
reaches
(
see
above)
to
the
total
number
of
facilities
in
this
industrial
category
indexed
to
RF1
segments
(
required
for
water
modeling).
