### Memorandum From: Carey A. Johnston, P.E. USEPA/OW/OST pli: (202) 566 1014 johnston.carey@epa.gov Public Rccord for the Effluent Guidelines Program Plan for 2004/2005 DCN XXX, Section XXX EPA Docket Number OW-2003-0074 (www.epa.gov/edocketsl) March 5, 2004 Talking Points from March 4, 2004, Meeting Between EPA Acting Assistant Administrator for Water and the Chlorine Chemistry Council

On March 4, 2004, the Chlorine Chemistry Council (CCC) and Cornerstone Government Affairs niet with Benjamin Grumbles, EPA's Actiiig Assistant Administrator for Water. Topics discussed EPA's Stage 2 Disinfection By-Product Rule, chemical security at waterlwastewater treatment plants, EPA's dioxin reassessment, and EPA's effluent guidelines planning.' As documented in the record for the preliminary plan, dioxin discharges are a significant portion of the toxic pollutant loadings reported in EPA's Toxics Release hiventory (TRI) and Pennit Compliance Systent (PCS) databases for the Organic Chemicals, Plastics, and Syiithetic Fibers industrial point source category (40 CFR 414). Below are the CCC talking points that relate to thc discussions on EPA's dioxin reassessment and effluent guidelines planning.DIOXIN ISSUES
EPA's Dioxin Reassessment EPA's drafi, reassessment should not serve as the scientific basis for EPA decision-making. Thus, EPA's disclaimer langttage that currently accompanies the pttblicly available draft dioxin reassessment posted on EPA's website should remain in force. EPA's reassessment catulot be finalized until aRer the NAS issues its report on the reassessment and EPA amends the reassessment accordingly. Congress specifically requested an NAS revicw in the omnibus appropriations bill signed Feb. 20, 2003 by President Bush. The NAS review of the reassessment will address a ntimber of key issues, including: Wliether EPA's risk estimates are scientiftcally robust, Whether EPA lias clearly delineated all the substantial uncertainties and variability, EPA's classification of dioxin as a htiman carcinogen, The validating of the non-threshold linear dose-response model and the cancer slope factor, The utility of toxicity equivalence factors and the uncertainties associated with their ttse.
Effluent Guidelines Tlie Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) industrial category shotild not be identified for possible efflucnt guidelines rulemakings in the final Effluent Gtiidelines Program Plan for 2004/2005. OCPSF facilities, iticluding vinyl ehloride itnonomer and ethylene diehloride facilities, do not "offer the most significant opportunities for redticing risks or hazards." OCPSF discharges of dioxin do not pose a hazard to human healtli or the environment.

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CCC Meeting with Ben Grumbles, Acting AA for EPA's Office of Water

STAGE 2 DBP RULE: Proposed rule overstates potential reproductive and developmental health risks. •"Summary" incorrectly implies strong, consistent evidence of risks. • Rule should include a"weight of evidence" assessment for specific reproductive and developmental effects. • Evidence for most of these effects is niixed, inconsistent or wealC.
Final rule should not include an "illustrative calculation" of fetal losses. • This calculation is inconsistent with EPA's conclusion that data do not support a quantified risk assessment for fetal loss, or any reproductive or developmental effect. • EPA cherry-picks data froni selected epidemiology studies to suggest that thousands of fetal losses niay be prevented by the rule. • EPA fails to present alternative calculations, particularly one illustrating that the number of fetal losses may, in fact, be zero. • This fundamental bias violates OMB and EPA information quality guidelines. • The note of caution to readers is itlsufficient. A11 references to this calculation must be removed. EPA should not dismiss value of high quality studies on DBA and BDCM.
• Christian et al. studies were desigtled in consultation with EPA and conducted in full compliance witth all relevant EPA guidelines. • NOAELs identified by Christian et al. are valid for dose response evaluations. • EPA statenients on DBA and BDCM toxicology should discuss high margins of exposure (i.e., NOAELs were observed at drinking water concentrations thousands of times higher thail human exposure).CHEMICAL SECURITY AT WATER/WASTEWATER TREATMENT PLANTS
EPA should include chlorine industry representatives as stakeholders in addressing chemical security at water treatment plants. • Chlorine disitifectants are critical assets for drinking water and wastewater treatment plants. • The chlorine industry has developed a range of resources and tools to help chlorine users improve safety and strengthen security. Water treatment plants should address chemical security issues as part of comprehensive vulnerability assessments and security plans. Options niust be weighed and prioritized to improve overall safety and security. Each disinfectioti technology has unique benefits, challenges, and costs. Individual plants evaluate these tradeoffs, and adopt disinfection systems based on the unique circumstanccs, needs and resources of the communities they serve. We will be nominating an industry representative for the Water Security Working Group of NDWAC.• The RFHEE project compliments and supports ongoing work by EPA and AMSA. EPA recently awarded a grant to AMSA to enhance the Vulnerability Self Assessment tool for wastewater and water utilities. This grant is to improve report functioris, update and enhance countermeasure libraries, and include an emergency response function.DIOXIN ISSUES
EPA's Dioxin Reassessment • EPA's draft reassessment should not serve as the scientific basis for EPA decision-making. Thus, EPA's disclainler language that currently accompanies the publicly available draft dioxin reassessment posted on EPA's website should remain in force. • EPA's reassessment cannot be finalized until after the NAS issues its report on the reassessment and EPA amends the reassessment accordingly. Congress specifically requested an NAS review in the omnibus appropriations bill signed Feb. 20, 2003 by President Bush. The NAS review of the reassessment will address a number of key issues, including: Whether EPA's risk estimates are scientifically robust, Whether EPA has clearly delitieated all the substantial uncertainties and varriability, EPA's classification of dioxin as a human carcinogen, The validating of the non-threshold linear dose-response model and the caiicer slope factor, The utility of toxicity equivalence factors and the uncertainties associated with their use.

Effluent Guidelines The Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) industrial category should not be identified for possible effluent guidelities rulenlakings in the final Effluent Guidelines Program Plan for 2004/2005. • OCPSF facilities, including vinyl chloride moiiomer and ethylene dichloride facilities, do not "offer the most significant opportunities for reducing risks or hazards." • OCPSF discliarges of dioxin do not pose a hazard to human health or the environnient.