EPA MEMO ON PROPOSED 503 SLUDGE RULE.
From: . NAME: BURNELL VINCENT
The sludge rule discussions with OW are on hold waiting for Ryan and Chancy' s rewrite. Meanwhile, with the clock still
ticking on the court deadline, OGC is asking ORB to co-sign an affidavit that resolving our concerns will require more
time and that they can be resolved within the requested three-month extension.
Committing to success raises the horizon of our discussion.
Options facing the Agency if the problems persist in the next
edition include boldly publishing on admittedly weak science,
using a factor of safety to compensate for any weakness, or
scrapping the whole exercise, promulgating the Feb 89 proposal
as interim. .
Your advice is solicited. Are human health and the environment "pretty safe" with the application rates drafted, or does
the Adminslstrator need to hear that major work is necessary just to be pretty safe? Can we feel ok as long as the
uncertainty is fully discussed, both in the preamble and the guidance documents?
Can you join in an ORD discussion on Monday the 11th at 1:00 PM Eastern Daylight time? Come to Peter's office, or call
(202) 260-3302. If you have a conflict, comments by return Email or by phone would be appreciated.
To Distribution List: .
NAME: ERL ADA <ERL/ADA@A1@Mail>,
NAME: ERL DULUTH <ERL/DULUTH@A1@MAlL>,
NAME: RANDY BRUINS <BRUINS.RANDY@A1@MAIL>,
NAME: RICHARD BENNETT <BENNETT.RICHARD@A1@MAIL>,
NAME: EMSL .LD <EMSL.LD@A1@MAIL>.
NAME: ECAO RTP <ECAO.RTP@A1@MAIL>,
NAME; ECAO CINC <ECAO/CINC@A1@MAIL>,
NAME: dourson.michael <PAPARODIS.PHIL@A1@MAIL>