MEMORANDUM
SUBJECT:
Meeting
with
UWAG
Representatives
to
Discuss
UWAG's
Comments
on
Proposed
304(
m)
Plan,
EPA's
Follow­
up
Questions
and
Next
Steps
FROM:
Janet
K.
Goodwin,
Environmental
Scientist
Engineering
&
Analysis
Division
TO:
The
Record
On
June
3,
2004
EPA
staff
and
contractors
met
with
representatives
from
the
Utilities
Water
Act
Group
(
UWAG)
to
discuss
the
rankings
assigned
to
the
Steam
Electric
Point
Source
Category
in
the
proposed
304(
m)
Plan.
The
list
of
attendees
at
this
meeting
is
attached
(
Attachment
1).

UWAG
submitted
comments
to
EPA
on
the
proposed
plan
which
raised
a
number
of
questions
about
the
way
EPA
had
estimated
pollutant
loadings
for
this
category,
especially
for
the
pollutant
chlorine.
After
reviewing
the
comments
and
data
submitted
by
UWAG,
EPA
made
some
revisions
to
its
approach
to
estimating
loadings,
but
also
identified
some
questions
that
arose
from
UWAG's
comments.
EPA
asked
UWAG
for
their
assistance
in
responding
to
the
questions
(
Attachment
2)
and
suggested
that
a
meeting
be
scheduled.

We
discussed
the
revised
approach
that
EPA
is
taking
to
calculate
chlorine
loadings
from
data
in
PCS.
In
aggregate
when
EPA's
estimates
are
compared
with
UWAG's
estimates
we
have
very
similar
loadings,
although
individual
facility
loads
may
vary
considerably.
EPA
offered
that
we
plan
to
continue
to
use
the
revised
methodology,
but
would
consider
making
further
refinements
if
UWAG
can
provide
some
assistance
with
our
assumptions.
For
example,
EPA
used
the
PCS
data
from
facilities
that
reported
both
an
average
chlorine
value
and
a
maximum
chlorine
value
to
develop
a
relationship
between
the
maximum
and
average
values.
This
relationship
was
then
applied
to
any
facility's
data
where
an
average
was
not
reported
to
simulate
an
average
value
that
could
then
be
used
to
calculate
a
load.
Also,
PCS
does
not
provide
any
information
about
the
frequency
of
chlorine
addition;
thus,
if
a
facility
only
added
chlorine
on
one
day
out
of
the
month
and
reported
measurement
data
that
only
reflect
that
one
day,
EPA
assumed
that
chlorine
was
being
applied
every
day
of
that
month.
EPA
asked
UWAG
if
they
would
be
able
to
assist
with
a
better
method
to
relate
the
monthly
maximum
value
for
chlorine
to
an
average
value
and
if
there
were
some
rules
that
could
be
applied
based
on
geographic
location
or
other
factors
to
estimate
the
number
of
days
and
hours
per
day
that
chlorine
is
being
discharged.

We
also
discussed
the
use
of
brominated
compounds
and
the
prevalence
of
their
use.
EPA
expressed
some
concerns
about
the
toxicity
of
these
compounds
but
irrespective
of
the
toxicity,
is
concerned
that
this
pollutant
loading
has
not
been
included
in
the
overall
estimated
loads
from
this
industry.

UWAG
was
informed
that
based
on
revised
analysis
of
the
PCS
and
TRI
loadings
data
bases
we
are
no
longer
showing
a
high
loading
of
chlorine
from
the
steam
electric
industry,
but
the
data
do
indicate
that
the
metals
loads
are
very
high.
We
have
high
loads
for
copper,
boron,
and
arsenic.
UWAG
thought
that
the
copper
loads
are
probably
resulting
from
the
copper
tubing
used
in
the
facility.
Also
there
could
be
small
volume,
high
concentration
discharges
of
copper
associated
with
metal
cleaning
that
occurs
periodically,
generally
over
a
period
of
a
few
days
and
may
be
reported
in
PCS
with
no
indication
of
its
relevance
to
the
overall
facility
load.
Also,
UWAG
indicated
that
we
should
examine
whether
these
metal
pollutants
are
part
of
the
intake
water.
UWAG
encourages
EPA
to
deduct
the
intake
concentrations,
but
these
data
are
not
routinely
sampled
by
utilities
and
is
not
reported
to
PCS.
UWAG
thought
that
some
correlation
could
be
made
with
flow.
If
high
loads
of
metals
the
metal
loads
should
be
considered
to
be
present
as
a
result
of
the
intake.

At
the
conclusion
of
the
meeting
we
identified
several
action
items
that
we
and
UWAG
will
follow
up
on.
EPA
will
provide
UWAG
with
a
more
succinct
list
of
data
needs
we
would
like
UWAG
to
assist
the
Agency
in
obtaining.
We
will
also
provide
a
reference
to
a
study
produced
by
the
Bromine
Institute
in
1992
that
discussed
the
toxicity
of
brominated
compounds.

UWAG
will
provide
EPA
with
an
EPRI
report
on
the
use
of
brominated
compounds
at
utilities
and
will
submit
a
copy
of
comments
that
they
previously
submitted
to
the
Agency
when
EPA
published
its
1996
study
of
the
steam
electric
industry.

Attachments
