Page
1
of
3
Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005
DCN
XXX,
Section
XXX
EPA
Docket
Number
OW­
2003­
0074
(
www.
epa.
gov/
edockets/)

Date:
August
5,
2004
Re:
Talking
Points
from
August
5,
2004,
Meeting
Between
EPA
and
Wood
Treaters
On
August
5,
2004,
several
industry
trade
associations
met
with
EPA
to
discuss
EPA's
effluent
guidelines
planning
process
and
industrial
discharges
from
the
wood
treater
industry.
The
list
of
attendees
is
presented
in
Table
1.

General
Industry
Discussion
The
meeting
started
with
a
brief
discussion
of
the
wood
treater
industry
and
which
segments
were
represented
by
meeting
participants.

Ms.
Leslie
Hyde,
Koppers
Inc.,
indicated
that
her
company
produces
a
variety
of
treated
wood
products
(
e.
g.,
utility
poles,
pilings)
using
creosote,
pentachlorophenol,
and
chromated
copper
arsenate.
Ms.
Hyde
also
indicated
that
all
creosote
treaters
are
very
similar
as
they
use
similar
chemicals
and
processes
for
producing
creosote
treated
wood
products.
Mr.
Bob
Matthews,
Creosote
Council,
which
represented
the
interests
of
manufacturers
and
suppliers
of
industrial
grades
of
creosote
along
with
timber
treatment
companies
and
users
of
creosoted
timber.

Mr.
John
Wilkinson,
Pentachlorophenol
Task
Force,
indicated
that
his
organization
represents
two
companies:
Vulcan
Chemicals
and
KMG­
Bernuth.
These
companies
produce
pentachlorophenol
which
wood
treaters
use
to
produce
a
variety
of
treated
wood
products
(
e.
g.,
utility
poles,
railroad
crossties,
bridge
timbers).
Mr.
Wilkinson
stated
that
there
are
approximately
50
to
60
facilities
producing
pentachlorophenol
treated
utility
poles
(
approximately
60%
of
the
utility
pole
market).
Mr.
Jeff
Miller
indicated
that
his
organization
represented
water­
based
wood
treaters.
Page
2
of
3
EPA's
Effluent
Guidelines
Planning
Mr.
Carey
Johnston,
EPA,
provided
a
brief
overview
of
EPA's
effluent
guidelines
planning
process.
Under
the
Clean
Water
Act
(
CWA),
EPA
establishes
national
regulations,
called
"
effluent
guidelines,"
to
reduce
discharges
of
pollutants
from
industries
to
surface
waters
and
publicly
owned
treatment
works.
Section
304(
m)
of
the
CWA
requires
EPA
to
publish
an
Effluent
Guidelines
Program
Plan
every
other
year.
The
current
(
2004)
Plan
is
expected
to
be
published
by
the
end
of
August
2004.
Mr.
Johnston
also
indicated
that
it
would
be
unlikely
for
the
Agency
to
identify
the
Timber
Products
effluent
guidelines
(
40
CFR
429),
which
regulates
industrial
wastewater
discharges
from
wood
treaters,
in
the
current
Plan
due
to
additional
data
needs
and
data
quality
checks.

Wood
Treater
Discharges
Mr.
Johnston
then
lead
the
group
in
a
discussion
on
how
facilities
estimate
their
discharges
of
toxic
pollutants
for
the
Toxics
Release
Inventory
(
TRI).
Mr.
Martin
Rollins,
industry
consultant,
indicated
in
the
meeting
that
he
helped
develop
a
guidance
document
and
spreadsheet
for
estimating
TRI
discharges
for
wood
treaters
using
pentachlorophenol
(
penta).
In
order
to
estimate
dioxin
discharges,
the
protocol
uses
stormwater
monitoring
data
and
surrogate
parameters
(
e.
g.,
oil
and
grease,
penta).
Facilities
can
backcalculate
the
amount
of
dioxin
discharged
as
the
amount
of
dioxin
in
penta
is
monitored
as
part
of
production.
Mr.
Johnston
asked
for
a
copy
of
this
guidance
document.
Mr.
Herb
Estreicher
agreed
to
provide
this
document
to
EPA.
The
group
also
touched
on
many
of
the
questions
EPA
distributed
in
advance
of
the
meeting.
Mr.
Estreicher
also
mentioned
that
some
facilities
are
voluntarily
performing
additional
monitoring
to
better
refine
their
environmental
releases.
Finally,
Mr.
Estreicher
mentioned
that
there
are
a
number
of
changes
within
the
wood
treater
industry
that
the
Agency
should
consider.

EPA's
Toxic
Weighting
Factors
Mr.
Johnston
then
lead
the
group
on
a
discussion
of
EPA's
Toxic
Weighting
Factors
(
TWFs).
These
factors
are
used
in
the
effluent
guidelines
planning
process
to
assess
the
hazard
of
industrial
wastewater
discharges.
In
a
rulemaking,
they
are
used
to
compare
the
costs
of
various
treatment
technology
options
with
toxic
pollution
reductions.
Ms.
Lynn
Zipf,
EPA,
also
discussed
how
EPA
recently
updated
its
TWFs
for
dioxin
and
its
congeners.
These
updates
include
adding
congener
specific
bioaccumulative
factors,
using
the
Agency's
current
fish
consumption
rate,
and
incorporating
the
1998
World
Health
Organization
Toxic
Equivalency
Factors.

Next
Steps
Mr.
Johnston
stated
that
it
was
important
to
understand
the
difference
between
the
Agency's
TRI
data
and
industry's
estimates.
Mr.
Johnston
also
asked
the
group
to
consider
helping
the
Agency
gather
more
data
to
better
refine
releases
from
this
industrial
sector
(
e.
g.,
stormwater
monitoring
data,
NPDES
permits,
changes
in
industry
profile
and
environmental
releases).
The
group
agreed
to
this
and
agreed
to
meet
again
in
October
2004.
Page
3
of
3
Table
1:
EPA
Meeting
with
Wood
Treaters
­
Attendees
August
5,
2004,
11AM
­
12
noon
EPA
Headquarters,
Washington
DC
Name
Organization
(
Representing)
Telephone
E­
mail
Robert
Matthews
McKenna
Long
&
Aldridge
LLP
(
Creosote
Council)
(
202)
496
7737
rmatthews@
mckennalong.
com
Leslie
Hyde*
Koppers
Inc.
(
412)
227­
2001
hydels@
koppers.
com
John
Wilkinson
Pentachlorophenol
Task
Force
(
703)
538
4915
wilkinsonj@
cox.
net
Martin
Rollins*
Independent
industry
consultant
for
the
wood
treater
sector
(
228)
832
1738
martinrollins@
hmrollins.
com
Jeff
Miller
Treated
Wood
Council
(
202)
463
2045
jeff_
miller@
treated­
wood.
org
Herb
Estreicher
Keller
and
Heckman
LLP
(
Pentachlorophenol
Task
Force)
(
202)
434
4334
estreicher@
khlaw.
com
Besty
Bicknell*
ERG
(
Contractor
to
EPA)
(
703)
633
1612
besty.
bicknell@
erg.
com
Carey
Johnston
EPA/
Office
of
Water
(
202)
566
1014
johnston.
carey@
epa.
gov
Donald
F.
Anderson
EPA/
Office
of
Water
(
202)
566
1021
anderson.
donaldf@
epa.
gov
Lynn
Zipf
EPA/
Office
of
Water
(
202)
566
1429
zipf.
lynn@
epa.
gov
Ahmar
Siddiqui
EPA/
Office
of
Water
(
202)
566
1044
siddiqui.
ahmar@
epa.
gov
*
Note:
Participated
in
meeting
via
teleconference.
