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MEMORANDUM
TO:
EPA
Docket
OW­
2003­
0074,
Effluent
Guidelines
Program
Plan
for
2004/
2005
FROM:
Betsy
Bicknell,
ERG
DATE:
26
February
2004
SUBJECT:
Meeting
Between
EPA
and
Representatives
of
the
American
Chemistry
Council,
Vinyl
Institute,
and
Chlorine
Chemistry
Council
On
Thursday,
26
February
2004,
representatives
of
the
American
Chemistry
Council,
Vinyl
Institute,
and
Chlorine
Chemistry
Council
met
with
EPA/
EAD
and
their
contractors.
The
meeting
was
held
in
the
offices
of
American
Chemistry
Council
(
Arlington,
VA).

Attendees:

Name
Affiliation
Robert
Elam
Director,
Regulatory/
Technical
Affairs
American
Chemistry
Council
David
Fischer
Managing
Counsel
Chlorine
Chemistry
Council
Todd
Abel
Chlorine
Chemistry
Council
Thomas
Berger
Attorney
Keller
and
Heckman,
LLP
counsel
to
the
Vinyl
Institute
Frank
Borelli
Technical
Director
The
Vinyl
Institute
Gary
Morris
ExxonMobil
Ken
Wood
DuPont
Jonathan
Pompan
American
Chemistry
Council
American
Plastics
Council
Memorandum
16
February
2004
Page
2
1Comment
period
for
the
preliminary
Plan
closes
on
March
18,
2004.
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Tom
Wall
Chief,
Chemical
Engineering
Branch
EPA,
Office
of
Water
Engineering
and
Analysis
Division
Carey
Johnston
Engineering
and
Analysis
Division
Deb
Bartram
ERG
(
EPA
contractor)

Betsy
Bicknell
ERG
(
EPA
contractor)

Meghan
Kandle
ERG
(
EPA
contractor)

By
telephone:

Carolyn
Johnson
Dow
Chemical
Tracey
Maloney
Rohm
&
Haas
Bob
Reich
DuPont
Bob
Budinsky
Dow
Chemical
Tom
Burns
Merck
Bill
Yancey
BP­
Amoco
Issues
Discussed
EPA/
EAD
met
with
representatives
of
ACC
and
its
affiliates
to
discuss
EPA's
Effluent
Guidelines
Program
Plan
for
2004/
2005.
The
preliminary
plan
was
published
in
the
Federal
Register
on
December
31,
2003.
This
meeting
took
place
during
the
comment
period
for
the
preliminary
plan.
1
Discussion
focused
on
dioxin­
discharging
facilities.
Frank
Borelli
noted
that
most
PVC
plants
are
not
co­
located
with
other
organic
chemicals
manufacturing.
In
contrast,
EDC/
VCM
operations
are
typically
located
in
complexes
with
other
processes
and
wastewaters
are
not
discharged
separately.
The
industry
noted
that
its
estimates
of
dioxin
releases
went
down
from
24.3
to
8.4
g/
year
between
2000
and
2002.
They
attributed
this
reduction
to
improved
analytical
work
and
solids
control.
Additional
information
will
be
provided
in
a
four­
volume
report
prepared
by
the
Vinyl
Institute
(
Dioxin
Characterization
Program,
July,
2002)
and
in
audited
TRI
data
that
the
Chlorine
Chemistry
Council
will
provide
to
Dwain
Winters,
EPA/
OPPT
National
Program
Chemicals
Division.
EAD
will
obtain
that
information
from
Mr.
Winters.
Memorandum
16
February
2004
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The
ACC
representatives
had
no
information
about
PAC
dischargers
(
Coal
Tar
Refiners),
but
suggested
that
EAD
contact
the
American
Coke
and
Coal
Chemicals
Institute.

The
ACC
representatives
noted
that
they
did
not
believe
that
any
aniline
dischargers
were
members
of
the
water
team
and
suggested
that
EAD
contact
SOCMA.
They
also
requested
a
list
of
the
facilities
reporting
aniline
and
sodium
nitrite
discharges.

EAD
reiterated
the
requests
for
additional
information
that
were
included
in
the
December
31,
2003
Federal
Register
Notice.
EAD
also
identifying
other
areas
for
industry
to
provide
information
(
e.
g.,
accurate
facility
and
outfall
location
information
(
latitude
and
longitude)
for
OCPSF
facilities).
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2/
26
Attendance
for
ACC/
EPA
Meeting
Bob
Elam
ACC
703­
741­
5242
Todd
Abel
CCC
703­
741­
5856
David
Fischer
CCC
703­
741­
5179
Tom
Berger
Keller
&
Heckman,
LLP
202­
434­
4285
Frank
Borrelli
VI
703­
741­
5668
Tom
Wall
EPA
202­
566­
1060
Carey
Johnston
EPA
202­
566­
1014
Betsy
Bicknell
ERG
703­
633­
1612
Deb
Bartram
ERG
703­
633­
1669
Meghan
Kandle
ERG
703­
633­
1684
Gary
Morris
ExxonMobil
215­
321­
5212
Ken
Wood
DuPont
302­
774­
8023
Jonathan
Pompan
ACC/
APC
703­
741­
5175
By
Phone:

Carolyn
Johnson
Dow
Tracey
Maloney
Rohn
&
Haas
Bob
Reich
DuPont
Bob
Budinsky
Dow
Tom
Burns
Merck
Bill
Yancey
BP
