April 12, 1995

In February the American Textile Manufacturers Institute met with the EPA Office of Water/Science & Technology Division and Permitting Division to discuss relief for textile companies facing permit renewals and metal limits being incorporated into their permits. Specifically, representatives of the textile industry proposed that EPA suspend its metal limits for the duration of currently ongoing studies.

EPA agreed to set up a meeting with their water quality and permitting colleagues in EPA Region IV and their equivalents in other areas including Region I. In addition they invited the pretreatment coordinators in these states. The meeting is scheduled for Friday, April 21 in Atlanta at EPA’s Region IV offices beginning at 8:30 and going to no later than 1 p.m. Our association strongly urges you to attend.

As you know, EPA based its limits on total recoverable metal; this is scientifically questionable. The current methods cost $300,000 to do a site-specific metal limit and another $300,000 to comply; this money is spent to control metals with no toxic impact. EPA and state agencies face regulatory gridlock on this issue. All parties (industry, POTW’s, EPA, states) are vulnerable to citizen suits.

The purpose of this meeting is to present a method developed by textile industry to properly regulate textile metal discharges, and to discuss what the EPA and state interim policy should be. Again, the Northern Textile Association wishes to impress on you the importance of your attendance at this meeting.

Sincerely yours,


Karl Spilhaus
President