1See
http://
www.
cibasc.
com/
view.
asp?
id=
1295.

Page
1
of
3
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
May
5,
2004
OFFICE
OF
WATER
Mr.
Kash
Srinivasan,
Commissioner
Wilmington
Department
of
Public
Works
Louis
L.
Redding
City/
County
Building
800
N.
French
Street,
6th
Floor
Wilmington,
DE
19801
Phone:
(
302)
576­
3069
Dear
Mr.
Srinivason:

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,
the
CIBA
Specialty
Chemicals
facility1
in
Newport,
Delaware
(
TRI
No.
19804CBGGYJAMES)
reported
the
discharge
of
OCPSF­
generated
wastewaters
to
your
collection
system.
In
particular,
the
CIBA
Specialty
Chemicals
facility
reported
that
it
discharged
27,552
pounds
of
aniline
to
your
POTW.
As
a
result,
we
would
like
to
obtain
any
readily
available
information
on
discharges
from
CIBA
Specialty
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.
Page
2
of
3
In
particular,
we
request
the
following
data
and
information
(
if
available):

A.
General
information
about
discharges
from
the
CIBA
Specialty
facility
to
your
POTW.

1.
This
facility's
pretreatment
permit
and
any
supporting
documentation
equivalent
to
a
fact
sheet
that
describes
the
development
of
the
current
permit
limits;
2.
Recent
compliance
monitoring
data
for
this
facility
(
for
all
pollutants
monitored
and
flow)
for
the
past
twelve
months;
and
3.
Any
particular
issues
or
concerns
presented
by
wastewater
discharges
from
the
facility,
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
Page
3
of
3
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
