Document VJz3BqXYgNvXQkY8M6j3Qg22K

ICC-03 'SSTL^ilT GENERhL TIRE AKRON - OP.-IP HQ P.02 DgeivneersriaTlech ObmQwpcomoam ;11 TO: DIVERSITECH POLYMERS D VISION ATTENTION: H. S. Wheeler FROM: R. W. Frase DATE: September 20, 1985 mkmo SUBJECT: Ashtabula Plant Fundamental 1y Differen : Factors (FDF) Or Friday, September 13, ' CP K I r,2d an hour long conversation with Mr. Hugh Wise of the Fetie'-al EPA. Mr. V '. if is a technical consultant in the effl jent guiceline division of ire EPA. Mr tMsa the person who ulfratsly makes a decision on an application for variance based upon a "OF er-gument. callec after ram. Graff cf Ashtabu'a told m* at; a con /ersation that ns had with Mr. Wise. rank said that Mr. Wist had not seemed favcmole to our arguments, go: e same response du"1nc conversation. Mr. Wise listened as I enumerated the many differences between the Ashtabula riant and ifactu: faculties. He readily agreed with my poin s and told me ne u cocnitant of all lhe information. Wnat he didn't agree to wws ny content'or that these differences constitute FDF. H's response was we use tke sets react'cr. process to make susper.sicn FVC as the rest cf the Industry, and cc .sequent'y we are not fundamental 1 y different in hMs eyes. This amounts to a nc win situation. I tell him of ail the cp Terences specifics11y allowed in tne FDF guidelines ar.d h e sImply says no, T-e bottom 1'ne is, ever if the State of Ohio is willing tc issue a permit w-ii- in efr'u Cut limit that will allow us to operate the plant as is, Mr. Wise prot-ab*y wo" 11 give it t" e federal blessing! sms:38 CC.` H. B. Thompson W. J. Henrick H. Graff - Asht&bu'a Kl X-lUAMK GENC 26192