
.
Signature:
Project
No.:
0172.01.005.071
 
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Project
Name:
304m
Industry
Investigations:
Timber
Products
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
January
16,
2004
Time:
11:
45
AM­
12
PM
Company
Name:
US
EPA,
Region
4,
Water
Management
Division
Contact
Name:
Roosevelt
Childress,
Chief,
Surface
Water
Permits
Branch
Phone
No.:
(
404)
562­
9279
Name:
Betsy
Bicknell
&
Arash
Hooshangi
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Wood
Treating
Facilities
NPDES
Permitting
TOPICS
DISCUSSED
AND
ACTION
TAKEN
Arash
and
I
called
Roosevelt
Childress,
EPA
Region
4,
about
permitting
at
wood
treating
facilities.
He
didn't
have
much
detailed
information,
but
will
e­
mail
his
contacts
in
NC
and
AL
(
both
of
which
have
a
lot
of
wood
treating
sites),
to
try
to
identify
a
permit
writer
familiar
with
wood
treating
who
might
be
able
to
more
specifically
answer
my
questions.
He
did
provide
the
following
useful
insights:

­
facilities
that
have
no
discharge,
but
that
have
the
potential
for
a
discharge
(
say
from
overtopping
a
storage
pond),
should
be
given
a
"
no
discharge"
permit.
In
the
event
of
a
discharge
due
to
an
upset
or
by­
pass,
the
facility
would
be
shielded
from
prosecution
for
an
unpermitted
discharge.

­
discharges
from
clean­
up
of
a
superfund
site
would
not
usually
be
issued
an
NPDES
permit.
The
discharge
would
be
controlled
by
the
ROD
(
record
of
decision).
[
I'm
not
sure
if
this
would
also
apply
to
RCRA
clean
ups
at
operating
facilities.]

­
Mr.
Childress
thought
that
stormwater
discharges
from
wood
preserving
facilities
would
be
covered
by
the
Multi
Sector
General
Permit
(
MSGP),
and
probably
would
have
the
monitoring
requirements
specified
in
the
MSGP
for
wood
preserving
facilities.
He
didn't
know
if
individual
states
had
general
stormwater
permits
for
wood
treaters
(
possibly
requiring
additional
monitoring).
He
did
agree
that
any
stormwater
monitoring
data
would
be
at
the
states.
