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1
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UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
May
5,
2004
OFFICE
OF
WATER
Mr.
Tim
Westman
Muskegon
County
Wastewater
Treatment
Plant
8301
White
Road
Muskegon,
MI
49442
Phone:
(
616)
788­
2311
Dear
Mr.
Westman:

The
Clean
Water
Act
(
CWA)
requires
that
EPA
periodically
review
existing
effluent
guidelines,
pretreatment
standards,
and
standards
of
performance
for
new
sources
and
to
revise
them
"
if
appropriate"
or,
in
the
case
of
new
source
performance
standards,
"
as
technology
and
alternatives
change."
As
the
project
manager
for
the
technology­
based
effluent
guidelines
planning
process
(
see
www.
epa.
gov/
guide/
plan.
html),
I
am
assembling
the
final
Effluent
Guidelines
Program
Plan
for
2004/
2005.
The
final
Plan
will
describe
EPA's
effluent
guidelines
program,
current
development
efforts,
and
the
analyses
that
will
help
EPA
to
decide
whether
to
revise
or
establish
effluent
guidelines
and/
or
pretreatment
standards
for
particular
industries.

As
part
of
this
planning
process,
we
are
reviewing
the
Organic
Chemicals,
Plastics,
Synthetics,
and
Fibers
(
OCPSF)
effluent
limitation
guideline,
codified
in
40
CFR
Part
414.
We
are
using
information
reported
to
the
Toxic
Release
Inventory
(
TRI)
to
evaluate
current
discharges
from
OCPSF
facilities.
The
2000
TRI
shows
that
a
subset
of
OCPSF
facilities
(
those
with
a
primary
SIC
Code
2865)
discharged
more
than
850,000
pounds
of
aniline
to
POTWs.
We
are
trying
to
obtain
additional
information
on
OCPSF
discharges
of
aniline
and
other
pollutants
to
POTWs
to
understand
the
impact,
if
any,
of
these
discharges
on
POTWs.

In
the
2000
TRI,
two
facilities
reported
discharging
OCPSF­
generated
wastewaters
to
your
collection
system.
In
particular,
these
facilities
reported
the
following
discharges:

Pounds
of
Aniline
Discharged
to
the
Muskegon
County
Wastewater
Treatment
Plant
As
Reported
in
the
2000
TRI
Facility
Name
Facility
Location
Pounds
of
Aniline
Reported
Sun
Chemical
Muskegon,
MI
33,001
Lomac,
LLC
Muskegon,
MI
10
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2
of
3
As
a
result,
we
would
like
to
obtain
any
readily
available
information
on
discharges
from
these
facilities
to
your
facility
as
well
as
any
associated
impacts.
This
information
and
your
knowledge
will
help
us
better
formulate
policy
options
for
the
final
Effluent
Guidelines
Program
Plan.
In
particular,
we
request
the
following
data
and
information
(
if
available):

A.
General
information
about
discharges
from
the
Sun
Chemical
and
Lomac,
LLC
facilities
to
your
POTW.

1.
The
pretreatment
permits
for
these
facilities
and
any
supporting
documentation
equivalent
to
a
fact
sheet
that
describes
the
development
of
the
current
permit
limits;
2.
Recent
compliance
monitoring
data
for
these
facilities
(
for
all
pollutants
monitored
and
flow)
for
the
past
twelve
months;
and
3.
Any
particular
issues
or
concerns
presented
by
discharges
from
these
facilities,
even
if
these
concerns
are
not
related
to
aniline.

B.
Information
about
the
aniline
impact
on
your
treatment
plant:

1.
A
list
of
any
other
manufacturers
of
dyes
or
aniline
known
to
discharge
aniline
to
your
POTW,
and
2.
Any
interference
problems
experienced
by
your
treatment
plant
from
aniline.

C.
Description
of
your
treatment
plant:

1.
The
annual
average
flow
treated
by
your
POTW
in
2000,
2.
The
wastewater
treatment
scheme
at
your
POTW,
and
3.
Any
recent
aniline
discharge
monitoring
data
(
last
twelve
months)
from
your
POTW.

We
would
like
to
obtain
this
information
within
the
next
month
as
we
are
in
the
process
of
finalizing
our
current
plan.
Please
send
this
information
to
me
using
one
of
the
addresses
listed
below:

USPS
Mailing
Address:
FedEx
Delivery
Address:

Carey
A.
Johnston,
P.
E.
Carey
A.
Johnston,
P.
E.
U.
S.
EPA,
Office
of
Water
U.
S.
EPA,
Office
of
Water
Mail
Code:
4303T
EPA
West
6231G
1200
Pennsylvania
Avenue
NW
1301
Constitution
Avenue
NW
Washington,
DC
20460
Washington,
DC
20004
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of
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Please
contact
me
at
(
202)
566­
1014
or
johnston.
carey@
epa.
gov
if
you
have
any
questions
about
this
request
or
the
effluent
guidelines
planning
process
in
general.
Your
POTW
is
under
no
obligation
to
answer
these
questions.
However,
any
information
you
supply
will
help
us
understand
discharges
from
OCPSF
to
POTWs,
which
will
lead
to
better
formulated
policy
options
for
the
final
Effluent
Guidelines
Program
Plan.
Thank
you.

Sincerely,

Carey
A.
Johnston,
P.
E.
U.
S.
EPA,
Office
of
Water
