.
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
21,
2004
Time:
3:
30
PM
Company
Name:
Eastern
Research
Group,
Inc.
Contact
Name:
Shannon
Maher,
EPA
Region
4,
RCRA
Enforcement
Phone
No.:
(
404)
562­
9623
Name:
Betsy
Bicknell
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
NPDES
Permits
for
Wood
Treating
Facilities
TOPICS
DISCUSSED
AND
ACTION
TAKEN
I
called
Shannon
to
explore
comments
made
by
Seth
Heminway,
EPA/
OECA/
Office
of
Compliance.
Seth
mentioned:

a
couple
of
points
about
wood
treaters
and
NPDES,
namely,
that
some
plants,
even
though
they
are
supposed
to
be
0
discharge,
have
succeeded
in
getting
what
I
would
consider
sham
NPDES
permits
in
an
attempt
to
have
their
sumps
and
tanks
exempted
from
RCRA
under
the
wastewater
exemption.
Probably
all
and
especially
those
with
uncovered
storage
yards
have
stormwater
toxicity
problems.

Shannon
was
not
familiar
with
any
cases
of
"
sham
NPDES
permits"
in
Region
4.
She
felt
that
both
the
RCRA
and
stormwater
programs
were
quite
familiar
with
the
operations
of
wood
preserving
facilities
in
the
Region.

I
asked
what
the
facilities
planned
to
do
as
CCA
is
phased
out.
Would
they
undertake
RCRA
closure?
Shannon
said
that
the
states
have
contacted
the
plants
to
ask
what
they
intend
to
do.
At
this
point,
most
seem
to
be
planning
to
continue
operating
under
Subpart
W,
because
closure
would
be
more
onerous
(
costly,
dificult)
than
continuing
to
operate
under
RCRA.

Shannon
noted
in
passing
that
only
8
percent
of
RCRA
facilities
are
TRI
reporters.
