Memo
to
316(
b)
Phase
3
record
Date:
September
14,
2004
From:
Paul
Shriner
Re:
Conference
call
with
AF&
PA
and
NCASI
regarding
Phase
3
Data
Paul
Shriner
(
EPA)
and
Martha
Segall
(
EPA)
had
a
conference
call
with
Jerry
Schwartz
(
American
Forest
and
Paper
Association)
and
Bill
Gillespie
(
National
Council
for
Air
and
Stream
Improvement)
to
discuss
the
universe
of
Phase
3
manufacturing
facilities
and
their
cooling
water
intake
structure
flows.

NCASI
expressed
concern
that
they
could
only
identify
9
paper
and
associated
product
facilities
with
cooling
water
design
intake
flows
of
more
than
50
million
gallons
per
day.
Their
information
was
mostly
obtained
from
copies
of
EPA's
screener
survey
as
provided
to
NCASI
directly
by
the
manufacturing
facilities.

First
EPA
reiterated
the
Confidential
Business
Information
(
CBI)
policy
adhered
to
by
EPA.
EPA
stated
any
detailed
discussion
of
the
industry
would
be
necessarily
constrained
by
EPA's
obligation
to
protect
facility
level
information
from
disclosure.

EPA
explained
the
flow
data
came
from
the
detailed
questionnaire,
and
that
EPA
had
facility
responses
from
27
paper
and
associated
product
facilities
with
more
than
50
million
gallons
per
day
design
intake.
EPA
indicated
the
total
design
intake
flows
from
the
27
paper
respondents
totaled
6
billion
gallons
per
day
and
the
actual
intake
flows
were
around
3
billion
gallons
per
day.
EPA
further
explained
that
in
some
cases
the
information
from
the
screener
survey
as
used
by
NCASI
had
changed
for
a
number
of
reasons
including:
changes
to
information
as
reported
by
a
facility
in
the
detailed
questionnaire,
and
corrections
made
by
EPA
as
a
result
of
follow­
up
discussions
with
an
individual
facility.

EPA
then
explained
that
standard
statistical
methods
were
used
to
develop
weighting
factors
for
each
facility
that
are
designed
to
produce
the
national
estimates
EPA
uses
in
the
rule
analyses.
The
statistical
weights
for
paper
facilities
with
more
than
50
million
gallons
per
day
design
intake
flow
were
typically
between
1
and
2.
EPA
indicated
the
weighted
total
design
intake
flows
from
the
50
weighted
paper
facilities
totaled
11
billion
gallons
per
day
and
the
actual
intake
flows
were
around
5.7
billion
gallons
per
day.
