Document G52xwNOwp2Ov8jbR2pVDLnGon

0 ro- legal department INTER-ORGANIZATION ATTENTION: W. J. Henrlck FROM: A. W. Laundrle OXrf: April 6, 1981 SUBJECT: DECEIVED APR 6 1981 SUBJECT: GTR Permit No. OH 0002283, NPDES Consolidated Permi t'** l-*Undl1e Renewal for Ashtabula Plant. The attached letter from Region V Enforcement Division has me upset, to say the least. It indicates that our people at Ashtabula agreed to an almost open-ended research project to determine the amount, to the 10 ppb level, of all conceivable and even inconceivable side reaction compounds in our effluent. Neither the plant nor Research has the present capability to conduct analytical determinations to this level. Our capability Is in the area of 100 ppb, at best. I'm concerned that this open-ended research project can lead to the useless expenditure of tens of thousands of dollars. Searching for unintentional side reactions or by-products is an endless chore. Note paragraph 3 on page 2. Where do we get this capability? It requires competence in physiology, toxicology, medicine, statistics, limnoloty, etc., and many other professional fields. I see a no-win situation developing. First, guess what's there - then analyze for your guesses - than EPA will rule on the findings. Neither best management plans for the PVC industry nor Effluent Guidelines have been published for PVC Industry. Why is General being tapped for this chore? Borden at tlliopolls is not being required to go through this exercise. We're checking other companies as to their status. I feel we should tell EPA to run their own research project at their cost. I suggest withdrawal of any agreements made and let them send the 308 letter which in the past has been more specific. I think the whole request as depicted in the letter is unreasonable. Afteryou digest, let's sit down to plan strategy. W. C. Lang - w/attachment Ron Frase - w/attachment H. Jewett - w/o attachment W. Laundrie GENC 19826 "BETTER Service Is Our Business'