Document JNnq0d4KQLX89me5wnLvoGyYv

To: From: Sent: Subject: Jackson, Ryan[jackson.ryan@epa.gov] John Blount Tue 9/19/2017 3:42:50 PM FW: Harvey and EPA See Mr. Durkay comments below. Not a bad idea. They got hammered by Harvey. John Blount SVP, Global Government Affairs Ervin | Hill Strategy 410 First Street, SE Suite 300 Washington, D.C. 20003 202.425.4618-cell From: "john.durkay@istc.net" <john.durkay@istc.net> Date: Friday, September 15, 2017 at 8:39 AM To: John Blount <john.blount@ervinhillstrategy.com> Subject: Harvey and EPA Here is a thought for our EPA friends. It has been long standing policy that when a drop of rain falls inside a chemical plant or refinery fence, it is process water which must be treated before release outside the fence. 64 inches of rain were never contemplated and the damage caused by the inability of Southeast Texas facilities to direct discharge what is really fairly safe water (Drainage District 7 was pumping water out of Port Arthur as fast as it could) is off the charts. When air upsets occur, plants are allowed to flair, the actual total emissions being fairly nondescript. There needs to be a national level emergency water discharge waiver permitted so our plants can avoid catastrophic flooding. 17cv1906 Sierra Club v. EPA ED_001523_00001647-00001 John Durkay General Counsel Office: 409-527-3349 | Mobile: 409-718-2758 | Fax: 409-724-0525 3749 Hwy 69, N. | Beaumont, TX | 77705 | www.istc.net | www.johndurkay.com ftgtgiyglgsystOgBlBSMegglcjgggagigspicgo^ gfSSxS&SiSSSsSfSSSSS^ 17cv1906 Sierra Club v. EPA ED_001523_00001647-00002