The document describes the supporting information for the Agency's proposed responses to the U.S. Fifth Circuit Court of Appeals' remand decision related to the Organic Chemicals Plastics and Synthetic Fibers (OCPSF) regulation (40 CFR Part 414), Chemical Manufacturers Association v. Environmental Protection Agency, 870 F.2d 177 (5th Cir.), modified, 885 F.2d 253 (5th Cir. 1989). The Court remanded three aspects of the OCPSF guidelines: (1) the subcategorization of the industry into two subparts imposing differing Best Available Technology Economically Achievable (BAT) limitations because the Agency did not provide sufficient notice for establishing 'less stringent' BAT Subpart J limitations for approximately 23 direct-discharge plants without biological treatment, (2) limitations for 19 of the 20 BAT Subpart J pollutants (and 13 corresponding Pretreatment Standards for Existing Sources (PSES)) that were based upon in-plant biological treatment technology because the design of the model treatment system used to estimate the cost of compliance was inconsistent with the technical basis for the numerical limitations, and (3) the New Source Performance Standards (NSPS) and the Pretreatment Standards for New Sources (PSNS) for consideration of whether zero discharge limits would be appropriate for new plants in the OCPSF industry because of the existence of recycling of wastewater.

"November 1991." "Technical support was provided under EPA contract Nos. 68-033509 and 68-C1-0006"--Page [i]. Includes bibliographical references. "EPA 440/1-91-009a."