Page
1
of
5
Teleconference
with
ASIWPCA
and
States
June
5,
2003
Meeting
Synopsis
EPA
Mary
Smith,
Division
Director
for
EAD
Pat
Harrigan,
Team
Leader
for
304(
m)
Kathy
Monk,
304(
m)
Team
ASIWPCA
Linda
Eichmiller
Sean
Rolland
States
Alabama:
Glenda
Dean
California:
Jim
Maughan,
Adam
Morrill
Delaware:
John
Defriece
Florida:
Vince
Seibold
Louisiana:
Gary
Aydell
West
Virginia:
David
Vande
Linde
Mary
Smith
opened
the
discussion
by
introducing
herself
and
her
goals.
Pat
Harrigan
ensured
that
everyone
had
received
the
two­
page
background
paper
(
attached),
and
briefly
went
through
Background,
How
the
Information
Will
be
Used,
and
Progress
to
Date
sections
of
the
paper.

In
response
to
a
question,
Pat
read
the
list
of
discharge
categories
identified
to
date
by
Stakeholders
as
potential
candidates
for
development
of
an
effluent
guideline.
States
are
invited
to
provide
feedback
on
which
of
these
seem
the
most
important,
which
the
least
important,
and
which
raise
other
issues.
Drinking
Water
Treatment
(
Public
Water
Supply)
Coal
Bed
Methane
Extraction
Stormwater/
Urban
Runoff
(
construction
portion
already
in
development)
Ballast
&
Bilge
Water/
Cruise
Ships
Aquaculture
(
already
in
development)
Petroleum
Bulk
Storage
Terminals
Airport
Deicing
Dental
Facilities/
Hospitals
&
Related
Health
Care
Facilities
POTWs/
Municipal
Treatment
Plants
Food
Service
Establishments
Chemical
Formulators
(
includes
Adhesives
and
Sealants
subcategory)
Laboratories
Drum
Reconditioning
(
subcategory
of
Transportation
Equipment
Cleaning)
Printing
and
Publishing
Page
2
of
5
Cosmetics,
Fragrants,
Flavors,
Food
Additives
The
following
points
were
made
about
two
discharge
categories
without
effluent
guidelines:
°
Stormwater/
Urban
Runoff
 
addressed
by
BMPs,
TMDLs
(
AL,
FL);
there
are
also
issues
with
runoff
scouring
river
banks
in
areas
with
increased
development
 
the
sediment
washed
into
the
water
along
with
the
metals
and
other
components
of
the
soil
is
part
of
the
problem,
may
require
creative
approaches
to
minimize
scouring.
°
Dental
Facilities/
Hospitals
&
Related
Health
Care
Facilities
 
resource
intensive
to
implement
(
AL)

Pat
also
read
the
list
of
existing
guidelines
recommended
to
date
by
Stakeholders
for
revision.
States
are
invited
to
provide
feedback
on
which
of
these
seem
the
most
important,
which
the
least
important,
and
which
raise
other
issues.
Petroleum
Refining
Steam
Electric
Power
Plants
Food
Processing
Meat
Products
(
in
development)
Ore
Mining
and
Dressing
Pulp,
Paper,
and
Paperboard
Subcategories
Metal
Molding
and
Casting
Coal
Mining
Metal
Finishing
Mineral
Mining
&
Processing
Waste
Reclamation
Services
(
Waste
Oil
Reclamation)

The
following
points
were
made
about
some
of
the
existing
categories:

Guidelines
that
do
not
regulate
pollutants
now
understood
to
cause
problems:
°
Food
processing,
specifically
seafood
processing
­
nutrients
and
fecal
coliform
(
AL,
LA,
FL)
°
Coal
mining
­
manganese
issues
(
WV)
°
Other
guidelines
that
do
not
include
nitrates/
nitrites
may
be
worth
revising,
as
a
means
to
address
nutrient
concerns
such
as
the
Gulf
of
Mexico
Hypoxia
(
LA)
°
Key
pollutants
selected
from
standards
under
development,
then
identify
guidelines
that
discharge
those
pollutants
and
are
not
regulated.
(
LA)

Guidelines
that
are
out
of
date
relative
to
available
technology:
°
Petroleum
refining
(
AL)
°
Food
processing,
specifically
seafood
processing
(
AL,
LA,
FL)
°
Meat
products
(
AL)
°
Metal
Molding
and
Casting
(
AL)

Pat
then
moved
to
the
first
question
in
the
section
Questions
We
Have
Asked
Stakeholders
to
Page
3
of
5
Consider
of
the
background
document,
which
asked
for
recommendations
for
existing
guidelines
needing
revision,
and
discharge
categories
without
an
effluent
guideline
that
may
need
one.
Participants
suggested
the
following:
°
Review
effluent
guidelines
with
unregulated
nutrients
in
their
effluents
(
LA)
°
Consider
addressing
problems
generated
by
precipitation­
based
runoff;
concerns
for
iron,
manganese,
aluminum,
and
soil
contributions.
(
WV)
°
Consider
information
gained
in
developing
mining
regulations
when
dealing
with
construction
issues.
BATs
generate
to
address
acid­
base
accounting
may
be
transferable
to
BMPs.
(
WV)

Moving
to
the
second
question,
on
technology
advances,
encouraging
innovation,
and
voluntary
programs,
the
following
suggestions
were
made:
°
The
ELG
for
the
seafood
processing
industry
currently
only
requires
screening
of
the
effluent.
This
is
the
crudest
advanced
technology
available,
and
the
technology
has
advanced
beyond
this
level
(
AL)
°
When
looking
at
total
stream
health,
there
may
be
ways
to
adjust
the
limits
to
obtain
a
better
result;
allowing
higher
manganese
discharges
allowed
the
discharger
to
avoid
increasing
the
pH
required
for
the
higher
removal
rates
and
the
result
was
an
improvement
in
the
receiving
stream
(
WV)
°
Support
voluntary
programs
such
as
that
included
in
pulp
and
paper
guidelines;
one
approach
could
be
offering
a
reduction
in
monitoring
requirements
in
exchange
for
implementing
better­
than­
required
wastewater
treatment
technology
(
AL,
LA)

The
subject
of
trading
generated
some
discussion:
°
One
participants
prefers
it
not
be
included
in
ELGs.
It
might
be
best
to
put
it
in
a
separate
guideline
of
its
own.
(
AL)
°
Another
participant
supports
trading.
Currently,
the
way
guidelines
are
written
make
it
impossible
for
industries
to
remove
more
than
what
is
required;
recommend
trading
be
used
for
non­
toxic
pollutants,
such
as
dissolved
oxygen
parameters.
(
LA)
°
A
third
participant
also
supports
trading,
especially
if
it
allows
an
improvement
in
stream
health,
as
in
the
example
referring
to
manganese
and
pH
discharges
above.
(
WV)

Mary
asked
the
group
to
identify
the
overarching
issues
they
are
facing,
to
determine
the
relative
importance
of
the
problems
that
could
be
addressed
under
the
effluent
guidelines
program.
°
The
305(
b)
process
and
TMDLs/
water
quality
standards
are
LA's
primary
focus.
°
Stringent
anti­
degradation
rules
are
overshadowing
BAT
in
WV.

The
conference
call
ended
with
Pat
confirming
that
she
would
send
the
meeting
summary
and
list
of
unregulated
discharge
categories
and
existing
guidelines
to
Linda
for
her
to
distribute
to
the
States.
Pat
would
followup
with
Vince
to
answer
his
question
about
the
subcategories
being
addressed.
Page
4
of
5
SUPPORTING
INFORMATION
Background
We
are
required
to
develop
a
plan
every
two
years
showing
which
effluent
limitations
guidelines
the
Agency
will
revise
and
which
discharge
categories
currently
without
effluent
guidelines
it
will
regulate.
For
most
of
the
last
10
years,
selections
of
industries
for
guidelines
and
their
schedules
were
substantially
influenced
by
court­
ordered
consent
decree.
With
the
consent
decree
ending,
we
are
currently
developing
and
implementing
a
planning
process
to
determine
future
work
on
effluent
limitations
guidelines.

!
The
process
will
allow
the
Agency
to
(
1)
identify
existing
effluent
limitations
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revisited,
and
(
2)
identify
industries
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
limitations
guideline
development.

!
Two
overarching
goals
are
guiding
the
process:
reducing
risk
to
human
health
and
the
environment,
and
assuring
transparent
decision­
making.

!
We
are
pursuing
many
avenues
of
investigation
to
determine
how
to
identify
and
prioritize
industries
(
or
parts
of
industries)
for
guideline
revision
and
development.
One
major
component
of
this
effort
is
consulting
with
the
people
in
the
field
who
do
the
work
 
to
find
out
what
they
thin
the
problems
(
and
solutions)
are.

How
the
Information
Will
be
Used
!
The
information
collected
will
first
be
reviewed
by
the
304(
m)
team
in
EAD.
It
will
be
considered
together
with
other
information
being
developed,
for
example,
on
the
relative
risks
posed
by
the
current
estimated
loadings
for
different
industries.
Recommendations
on
which
industries
to
consider
for
guideline
development
or
revision
will
then
be
provided
to
an
Agency
workgroup
for
their
consideration
and
input.
Finally,
the
information
and
recommendations
will
be
presented
to
upper
management
in
the
Office
of
Water
and
the
Agency
for
decision.
The
Agency
will
then
publish
and
take
comment
on
a
proposed
plan,
and
develop
a
final
plan
by
February
4,
2004
and
every
two
years
thereafter.

Progress
to
Date
!
We
have
already
gathered
some
information
through
public
meetings,
participation
in
conferences
including
the
Nashville
BAT
conference
in
February
and
the
WEF
conference
in
April,
as
well
as
gathering
the
comments
on
the
last
plan,
comments
on
the
draft
Strategy,
and
input
received
during
meetings
with
individual
stakeholder
groups.
Page
5
of
5
!
Internally,
we
are
working
closely
with
permit
writers
and
pretreatment
coordinators
to
hear
about
the
problems
that
they
are
aware
of,
and
to
gather
any
supporting
information
they
have.

!
We
will
be
contacting
nine
states
directly
for
in­
depth
discussions
 
we
are
limited
to
nine
because
we
are
not
preparing
a
formal
ICR
(
Information
Collection
Request).
And
we
will
be
following
up
with
individuals
in
the
states
who
have
provided
information
that
we
need
to
clarify
or
who
are
identified
as
knowing
a
lot
about
a
specific
issue.

Today
we
wanted
to
let
you
know
where
we
are
in
the
process
 
what
we
have
done
and
are
in
the
process
of
doing,
and
to
see
what
input
you
have
regarding
issues
and
information
sources
as
well
as
any
suggestions
on
ways
to
best
obtain
this
information.

Questions
We
Have
Asked
Stakeholders
to
Consider:

1)
Are
there
existing
effluent
limitations
guidelines
(
or
specific
aspects
of
guidelines)
that
need
to
be
revisited
(
for
example,
because
the
current
guideline
no
longer
reflects
the
performance
of
the
best
available
technologies,
or
because
there
are
problems
in
implementation,
compliance,
or
enforcement;
because
changes
in
industry
have
made
certain
provisions
or
requirements
obsolete,
etc.)
and
industries
(
or
specific
parts
of
industries)
that
have
not
been
previously
addressed
that
should
be
considered
for
effluent
limitations
guideline
development?

2)
Technology:
°
Are
there
facilities
which
may
be
employing
technologies
that
have
potential
for
more
widespread
application
across
an
industry
sector
to
reduce
wastewater
pollutant
discharges
below
current
levels?
°
How
should
technological
innovation
be
encouraged
and
rewarded?
°
What
drives
innovation
in
industries?
°
How
should
voluntary
loading
reductions
be
taken
into
account
and
how
do
you
verify
this,
especially
with
changing
production
by
industry?
°
What
role
should
market
incentives,
including
pollutant
trading,
have?

3)
Information:
°
What
additional
sources
of
information
should
we
be
considering?
°
How
can
we
best
obtain
information
for
the
more
detailed
analysis
of
industries
 
we
need
good
information
early
in
the
process?
°
How
can
we
obtain
the
information
necessary
to
fairly
evaluate
assertions
by
stakeholders?
