EPA's effluent guidelines 2004-2005 Preliminary Plan (Plan, 68 Fed. Reg. 75515, December 31, 2003) targeted for review the promulgated effluent guidelines of two existing industrial categories, the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) and Petroleum Refining
point source categories. In developing the Plan EPA chose to deviate from the technically sound effluent guidelines Strategy it proposed in 2002 (67 Fed. Reg. 71165, November 29, 2002). EPA's decision to target the OCPSF and Petroleum Refining categories was based on limited data
from the Toxic Release Inventory (TRI) and did not seek to identify, account for, or address environmental risk or impairment. Had EPA followed its 2002 Strategy and focused its review on addressing discharges posing true environmental risk and identifying achievable technologies to address
that risk, the Petroleum Refining and OCPSF point source categories would not have been selected.
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