Date:
April
9,
2003,
10:
00
AM
to
10:
45
AM
EDT
Participants:
Laura
Burrell,
Ron
Josephson,
Lisa
Lauer
(
EPA)
Nancy
Dotson,
Janet
Evans,
Gerald
Wrye,
Rhonda
Carpenter
(
Tennessee
Eastman)

Subject:
Conference
Call
with
Tennessee
Eastman
Concerning
Questions
on
Incinerator
Scrubber
Water
and
De
Minimis
Requirements
under
the
April
8,
2003
EPA
Headworks
Rule
Revision
Proposal
The
meeting
started
with
Ron
Josephson
explaining
that
these
meeting
notes,
along
with
written
materials
previously
submitted
by
Eastman,
will
be
placed
in
the
EPA
docket
for
this
proposal.
Eastman
was
advised
not
to
include
any
material
that
is
considered
confidential
business
information.
EPA
also
considers
this
call
to
be
a
"
listening"
meeting
and
does
not
promise
any
specific
action
based
on
this
call.

Tennessee
Eastman
first
brought
up
the
issue
of
incinerator
scrubber
waters.
According
to
the
April
8
proposal,
EPA
is
modifying
its
policy
concerning
scrubber
waters
and
will
now
allow
facilities
that
incinerate
spent
solvents
to
send
scrubber
waters
to
the
facility
wastewater
treatment
system
and
still
qualify
for
the
headworks
exemption.
Eastman
incinerates
mostly
spent
solvents
and
characteristic
wastes
(
95%
of
the
incinerator
feed),
but
some
wastes
are
commercial
chemical
products
(
P
and
U­
listed)
wastes.
The
chemical
fed
in
the
greatest
quantity
is
phthalic
anhydride
(
U190).
Much
of
the
commercial
chemical
product
loading
comes
from
laboratory
facilities
and
from
soils,
spilled
materials,
and
other
residues
containing
these
chemicals.

Eastman
claims
that
no
significant
concentrations
of
organics
exist
in
the
scrubber
blowdown.
The
scrubber
removes
metals
from
the
gas
stream,
and
some
metals
wind
up
in
the
ash.
As
they
are
an
organic
chemical
manufacturing
site,
much
of
the
metals
present
in
the
waste
streams
come
from
corrosion,
and
both
the
ash
and
the
wastewater
treatment
sludges
pass
the
TC
metals
test.
The
ash
and
biosludge
pass
Land
Disposal
Restrictions
(
LDR)
Universal
Treatment
Standards
(
UTS)
levels
as
well.
The
total
organic
carbon
(
TOC)
levels
measure
1
­
2
ppm.
The
incinerator
scrubber
water
is
3
­
5%
of
total
wastewater
treatment
system
flow.

Because
some
of
the
P­
and
U­
listed
chemicals
are
listed
for
toxicity
and
not
just
for
a
characteristic,
the
waste
codes
would
carry
through
to
the
wastewater
treatment
sludge.
Eastman
is
concerned
that
given
the
effectiveness
of
the
incinerators
and
the
wastewater
treatment
system
(
as
well
as
the
low
fraction
of
wastewater
flow
that
incinerator
scrubber
water
comprises),
that
the
policy
change
announced
in
the
proposal
does
not
address
wastes
being
incinerated
adequately
and
does
not
provide
sufficient
regulatory
relief.
Eastman
requested
that
EPA
consider
a
more
general
exemption
for
all
incinerator
scrubber
waters
being
sent
to
wastewater
treatment
plants.
Eastman
will
be
following
up
with
comments
and
data
in
the
future.

The
second
issue
Tennessee
Eastman
brought
up
concerned
the
proposed
changes
to
the
de
minimis
exemption.
In
the
Agency's
proposed
revisions
to
the
de
minimis
rule
for
F
and
K
wastes,
the
regulatory
language
states
that
the
discharging
facility
must
either
have
eliminated
the
discharge
of
wastewaters
or
have
a
Clean
Water
Act
permit
that
sets
limits
for
the
constituents
for
which
the
waste
was
listed
(
in
40
CFR
261
Appendix
VII)
and
the
constituents
for
which
each
waste
has
a
treatment
standard
in
the
§
268.40
LDR
treatment
regulations.
Eastman
felt
that
the
CWA
requirement
for
the
exemption
should
be
rewritten
to
include
those
constituents
listed
in
the
permit
application,
even
if
they
are
not
included
in
the
final
permit.

Eastman
explained
that
under
their
permitting
process,
they
must
write
down
all
individual
chemicals
entering
their
wastewater
treatment
system
under
the
Organic
Chemicals,
Polymers,
and
Synthetic
Fibers
(
OCPSF)
Effluent
Guidelines.
The
facility
must
state
for
these
chemicals,
which
includes
dioxins
and
furans,
what
chemicals
(
1)
they
expect,
(
2)
they
do
not
expect,
and
(
3)
are
probably
present.
In
addition
they
must
provide
what
concentrations
are
expected
in
the
influent
to
the
wastewater
treatment
system.
Eastman
says
that
their
list
covers
SARA
chemicals,
UTS
list,
and
priority
pollutants.
The
permitting
official
then
decides
what
limits
to
set
for
the
effluent.
The
fate
of
all
chemicals
in
the
influent
must
be
taken
into
account.
The
facility
must
also
undergo
a
45
day
public
notice
on
the
permit
process
for
manufacturing
facilities.

Eastman
also
claimed
that
getting
a
list
of
all
chemicals
that
could
affect
the
environment
is
impossible,
and
that
is
why
they
perform
BOD
and
COD
tests.
They
stated
that
the
biological
monitoring
they
must
do
is
adequately
protective
of
the
water
quality
and
downstream
risk
without
requiring
specific
chemical
limits
for
the
other
chemicals.
They
also
perform
acute
and
chronic
toxicity
monitoring
on
their
effluentsThe
wastewater
treatment
sludge
contains
concentrations
of
both
organic
and
metal
constituents.
However,
because
the
sludge
is
combusted,
the
only
issue
associated
with
sludge
is
metals
concentrations.
Eastman
then
turned
to
the
only
two
other
sites
which
would
theoretically
be
eligible
for
this
proposed
exemption.
Because
the
sludges
at
the
Texas
Eastman
facility
are
already
delisted,
this
proposal
will
probably
not
materially
affect
them.
The
Arkansas
Eastman
facility
might
be
eligible,
depending
on
the
total
amount
of
solvent
usage.
Currently
this
facility
separates
spent
solvents
from
the
wastes
going
to
the
onsite
incinerator
and
puts
them
in
a
boiler.

Lastly,
Eastman
had
some
questions
and
comments
on
other
parts
of
the
proposal.
They
noted
that
they
would
have
to
route
their
landfill
leachate
to
the
local
POTW
rather
than
their
own
wastewater
treatment
system
to
take
advantage
of
the
exemption
or
else
their
wastewater
treatment
sludges
would
be
classified
as
F039.
Eastman
also
asked
what
would
happen
in
the
case
of
exceedances
if
they
were
to
perform
GRAB
sampling
on
the
wastewaters,
and
if
extra
sampling
could
be
done
to
"
bring
down"
the
averages.
EPA
responded
that
it
preferred
to
have
the
state
agency
most
familiar
with
the
site
to
determine
what
would
be
acceptable
monitoring
requirements.
Eastman
also
commented
that
the
reference
to
landfill
leachate
date
on
page
17243
of
the
proposal
in
fact
does
not
have
a
lot
of
data
because
municipal
landfills
do
not
often
monitor
for
hazardous
constituents.
Since
the
comment
period
is
open
until
June
9,
2003,
EPA
expects
written
comments
to
be
submitted.
Agency
personnel
remain
open
to
discuss
issues
not
only
with
Eastman,
but
also
with
other
parties
interested
in
details
and
applicability
of
the
headworks
proposal.
