MEMORANDUM
TO:
Carey
Johnston,
EPA
Martha
Segall,
EPA
FROM:
Lori
Weiss,
ERG
DATE:
24
March
2005
SUBJECT:
Teleconference
with
EPA
and
UWAG
on
March
24,
2005
EPA
and
ERG
participated
in
a
conference
call
with
the
Utility
Water
Act
Group
(
UWAG)
on
March
24,
2005
to
discuss
the
status
of
the
action
items
from
the
February
22,
2005
meeting.
The
following
people
participated
in
the
call:

UWAG
Jim
Stieritz,
Cinergy
Elizabeth
Aldridge,
Hunton
&
Willians
Mike
Winkler,
LG&
E
Donna
Hill,
Southern
Company
EPA
Carey
Johnston
Martha
Segall
ERG
Lori
Weiss
This
memorandum
summarizes
the
meeting
discussion
points.

Industry
Survey

UWAG
proposed
an
industry
survey
to
their
members
at
their
last
meeting.
There
were
mixed
feelings
about
participating
in
a
survey.
UWAG
developed
a
draft
survey
which
they
have
sent
out
to
some
members
to
gauge
their
reaction
to
the
information
request
and
help
determine
the
response
rate.
UWAG
focused
on
the
issues
they
felt
were
important
and
reasonable.
UWAG
will
be
meeting
with
their
members
again
on
April
7
and
8
and
will
have
a
better
idea
of
whether
or
not
they
will
proceed
with
the
survey
at
that
time.
Memorandum
March
24,
2005
Page
2

Carey
Johnston
stated
that
EPA
will
not
be
able
to
provide
input
on
UWAG's
survey
structure
due
to
limitations
of
the
Paperwork
Reduction
Act
(
PRA).
Carey
stated
EPA
may
have
to
move
forward
with
their
own
survey
depending
on
UWAG's
decision.
EPA
would
be
restricted
to
gathering
information
from
nine
or
less
facilities.
EPA
would
review
the
initial
questions
about
the
industry
as
well
as
the
information
that
has
been
collected
in
past
data
collections
to
tailor
the
survey
to
particular
facilities
of
interest.

2002
PCS
and
TRI
Data
°
UWAG
asked
about
the
status
of
the
PCS
and
TRI
data
for
the
steam
electric
industry.
Lori
Weiss
stated
ERG
is
finishing
the
QA
and
outlier
analysis
for
the
entire
database
and
will
be
able
to
use
the
final
databases
to
extract
the
information
for
the
steam
electric
industry.
ERG
will
provide
to
EPA
the
PCS
and
TRI
information
by
April
1.
EPA
will
review
the
information
and
provide
the
databases
to
UWAG
by
April
8.

TRI
Chlorine
Releases
°
Donna
Hill
gave
an
update
on
her
research
into
the
reported
chlorine
releases
in
TRI.
There
are
13
facilities
reporting
chlorine
discharge
in
the
2002
TRI
data.
Donna
believes
this
is
likely
an
error.
Chlorine
reacts
quickly
to
form
HOCl
and
OCl.
Chlorine
as
Cl
2
is
the
form
that
is
reportable
to
TRI.
At
the
pH
levels
of
the
discharges,
Cl
2
should
not
be
present.
The
guidance
on
reporting
chlorine
is
not
clear
in
the
TRI
utilities
guidance.
UWAG
will
provide
a
memo
to
EPA
discussing
their
findings.

Boron
°
UWAG
asked
if
boron
is
still
one
of
the
top
pollutants
discharged.
ERG
verified
that
boron
still
ranks
as
one
of
the
top
five
pollutants.
UWAG
would
like
additional
information
on
EPA's
method
of
calculating
pollutant
loadings.
UWAG
believes
most
of
the
data
reported
to
PCS
is
from
2C
data.
Boron
is
not
a
high
priority
for
steam
electric
facilities.
Most
facilities
do
not
monitor
for
boron
and
therefore
the
only
information
is
from
2C
data.

°
Donna
Hill
researched
the
boron
discharges
for
the
Southern
plants.
She
found
that
plants
digesting
samples
in
plasticware
were
not
reporting
high
levels
of
boron
discharge.
One
of
her
companies
that
reported
high
boron
levels
was
using
glassware.
The
blanks
for
this
plant
also
contained
high
levels
of
boron.

°
UWAG
asked
if
EPA
took
the
naturally
occurring
constituents
of
background
water
into
account
when
analyzing
the
pollutant
loads.
Carey
Johnston
explained
an
evaluation
of
Memorandum
March
24,
2005
Page
3
source
water
characteristics
is
included
in
any
rulemaking
effort.
EPA
will
also
look
into
this
issue
as
part
of
the
detailed
study.

°
UWAG
asked
about
the
toxic
weighting
factor
(
TWF)
for
boron
and
if
any
of
the
TWFs
would
be
adjusted
to
reflect
new
information.
Carey
stated
the
TWFs
that
will
be
used
in
the
304(
m)
analysis
and
the
steam
electric
detailed
study
will
be
available
for
public
comment.

Site
Visits
°
UWAG
mentioned
the
possibility
of
site
visits
to
their
members
and
asked
if
any
companies
would
like
to
volunteer.
Sites
did
not
want
to
volunteer
if
sampling
was
included
in
the
visit.
UWAG
felt
site
visits
would
be
a
beneficial
activity
and
they
felt
they
could
find
volunteers
if
sampling
was
not
a
part
of
the
visit.
Carey
stated
that
EPA
would
evaluate
their
needs
and
decide
whether
sampling
needs
to
be
included
in
any
potential
site
visits.

Turbine
Cleaning
Chemicals

UWAG
is
trying
to
collect
information
on
turbine
cleaning
chemicals
and
will
send
EPA
a
short
memo
on
their
findings.

Action
Items
The
meeting
resulted
in
the
following
action
items.

°
ERG
will
provide
the
steam
electric
PCS
and
TRI
data
to
EPA
by
April
1.
°
EPA
will
provide
the
steam
electric
PCS
and
TRI
data
to
UWAG
by
April
8.
°
UWAG
will
provide
EPA
with
a
memo
regarding
the
reporting
of
chlorine
to
TRI.
°
UWAG
will
summarize
any
information
they
have
on
boron
releases
and
potential
sources
of
the
pollutant.
°
UWAG
will
provide
information
on
turbine
cleaning
chemicals
to
EPA.
°
The
next
status
call
between
UWAG,
EPA,
and
ERG
is
tentatively
scheduled
for
April
14
at
9:
30.
UWAG
will
have
received
the
PCS
and
TRI
databases
and
feedback
on
a
potential
survey
by
this
date.
