&EPA
United States
Environmental Protection
Agency
Technical Support Document for the 2004
Effluent Guidelines Program Plan
-------
Technical Support Document for the 2004
Effluent Guidelines Program Plan
EPA-821-R-04-014
Mike Leavitt
Administrator
Ben Grumbles
Assistant Administrator, Office of Water
Geoffrey H. Grubbs
Director, Office of Science and Technology
Mary Smith
Director, Engineering and Analysis Division
Tom Wall
Chief, Chemical Engineering Branch
Jan Goodwin
Technical Coordinator
Carey Johnston
Jan Matuszko
Project Managers
U.S. Environmental Protection Agency
Office of Water (4303T)
Engineering and Analysis Division
Office of Science and Technology
Washington, DC 20460
August 2004
-------
ACKNOWLEDGMENTS AND DISCLAIMER
This report has been reviewed and approved for publication by the Engineering and Analysis
Division, Office of Science and Technology. This report was prepared with the support of
Eastern Research Group, Inc., under the direction and review of the Office of Science and
Technology.
Neither the United States government nor any of its employees, contractors, subcontractors, or
other employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of, or the results of such use of, any information,
apparatus, product, or process discussed in this report, or represents that its use by such a third
party would not infringe on privately owned rights.
-------
TABLE OF CONTENTS
Page
SECTION 1 BACKGROUND 1-1
1.1 EPA's Clean Water Act Program 1-1
1.2 The Effluent Guidelines Program 1-1
1.2.1 Best Practicable Control Technology Currently Available
(BPT) - CWA Sections 301(b)(l)(A) & 304(b)(l) 1-3
1.2.2 Best Conventional Pollutant Control Technology (BCT) -
CWA Sections 301(b)(2)(E) & 304(b)(4) 1-3
1.2.3 Best Available Technology Economically Achievable (BAT) -
CWA Sections 301(b)(2)(A) & 304(b)(2) 1-3
1.2.4 New Source Performance Standards (NSPS) - CWA
Section 306 1-4
1.2.5 Pretreatment Standards for Existing Sources (PSES) - CWA
Section 307(b) 1-4
1.2.6 Pretreatment Standards for New Sources (PSNS) - CWA
Section 307(c) 1-4
1.3 Requirements Applicable to Effluent Guidelines Program Planning
Efforts 1-4
SECTION 2 PUBLIC COMMENTS ON THE PRELIMINARY EFFLUENT GUIDELINES
PROGRAM PLAN FOR 2004/2005 2-1
SECTION 3 ANNUAL REVIEW OF EFFLUENT GUIDELINES PROMULGATED
UNDER SECTION 304(b) 3-1
3.1 Results of 2003 Annual Review 3-1
3.2 2004 Annual Review 3-1
SECTION 4 DATA SOURCES AND LIMITATIONS 4-1
4.1 Industry Identification 4-1
4.1.1 SIC Codes 4-1
4.1.2 Relationship Between SIC Codes and Point Source
Categories 4-1
4.1.3 Economic Census 4-2
4.2 Pollutant Loadings Estimates 4-2
4.2.1 Data from TRI 4-2
4.2.1.1 Utility of TRI 4-4
4.2.1.2 Limitations of TRI 4-4
4.2.2 Data from PCS 4-6
4.2.2.1 Utility of PCS 4-7
4.2.2.2 Limitations of PCS 4-8
4.2.3 Toxic Weighting Factors 4-9
4.2.4 Calculation of TWPE 4-10
4.2.4.1 Methodology and Assumptions Used to Calculate
TWPE 4-10
-------
TABLE OF CONTENTS (Continued)
Page
4.2.4.2 Dioxins and Dioxin-Like Compounds 4-11
4.2.4.3 Polycyclic Aromatic Compounds (PACs) 4-15
4.3 Impaired Waters Analysis 4-17
4.3.1 Data Gaps and Limitations in Estimating Impairment
Analysis 4-19
4.4 Nutrients Analysis 4-19
4.5 References 4-20
SECTION 5 EXISTING INDUSTRY REVIEW 5-1
5.1 Organization of this Section 5-1
5.2 Group I Industries 5-4
5.3 Group II Industries 5-4
5.3.1 Inorganic Chemicals (Part 415) 5-4
5.3.1.1 Industry Description 5-5
5.3.1.2 Regulatory Background 5-7
5.3.1.3 Wastewater Characterization 5-9
5.3.1.4 Treatment Technologies 5-13
5.3.1.5 Conclusions 5-15
5.3.1.6 References 5-16
5.3.2 Nonferrous Metals Manufacturing (Part 421) 5-16
5.3.2.1 Industry Description 5-17
5.3.2.2 Regulatory Background 5-20
5.3.2.3 Wastewater Characterization 5-21
5.3.2.4 Treatment Technologies 5-24
5.3.2.5 Conclusions 5-26
5.3.2.6 References 5-27
5.4 Group III Industries 5-27
5.4.1 Fertilizer and Phosphate Manufacturing (Parts 418 and
422) 5-27
5.4.1.1 Industry Description 5-28
5.4.1.2 Regulatory Background 5-33
5.4.1.3 Wastewater Characteristics and Pollutant Sources . . . 5-36
5.4.1.4 Pollutant Prevention and Treatment Technology .... 5-38
5.4.1.5 Industry Trends 5-39
5.4.1.6 Stakeholder and EPA Regional Issues 5-39
5.4.1.7 Conclusions 5-40
5.4.1.8 References 5-40
5.4.2 Ore Mining and Dressing 5-41
5.4.2.1 Industry Description 5-41
5.4.2.2 Regulatory Background 5-43
5.4.2.3 Wastewater Characteristics 5-45
5.4.2.4 Pollution Prevent! on and Treatment Technology .... 5-54
5.4.2.5 Industry Trends 5-55
ii
-------
TABLE OF CONTENTS (Continued)
Page
5.4.2.6 Stakeholder and EPA Regional Issues 5-55
5.4.2.7 Conclusions 5-56
5.4.2.8 References 5-56
5.4.3 Pulp, Paper, and Paperboard Phase II 5-57
5.4.3.1 Industry Description 5-57
5.4.3.2 Regulatory Background 5-61
5.4.3.3 Wastewater Characteristics and Pollutant Sources . . . 5-63
5.4.3.4 Pollution Prevent! on and Treatment Technology .... 5-71
5.4.3.5 Industry Trends 5-72
5.4.3.6 Stakeholder and Regional EPA Issues 5-72
5.4.3.7 Conclusions 5-72
5.4.3.8 References 5-73
5.4.4 Steam Electric 5-73
5.4.4.1 Industry Description 5-73
5.4.4.2 Regulatory Background 5-74
5.4.4.3 Wastewater Characteristics and Pollutant Sources . . . 5-77
5.4.4.4 Pollutant Prevention and Treatment Technology .... 5-83
5.4.4.5 Industry Trends 5-84
5.4.4.6 Stakeholder and Regional EPA Issues 5-85
5.4.4.7 Conclusions 5-86
5.4.4.8 References 5-87
5.4.5 Textile Mills 5-87
5.4.5.1 Industry Description 5-87
5.4.5.2 Regulatory Background 5-90
5.4.5.3 Wastewater Characteristics and Pollutant Sources . . . 5-92
5.4.5.4 Pollutant Prevention and Treatment Technology ... 5-100
5.4.5.5 Industry Trends 5-102
5.4.5.6 Stakeholder and EPA Regional Issues 5-103
5.4.5.7 Conclusions 5-103
5.4.5.8 References 5-104
5.4.6 Timber Products Processing Point Source Category 5-105
5.4.6.1 Industry Description 5-105
5.4.6.2 Regulatory Background 5-107
5.4.6.3 Wastewater Characteristics and Pollutant Sources . . 5-112
5.4.6.4 Pollution Prevent! on and Treatment Technology ... 5-120
5.4.6.5 Industry Trends 5-121
5.4.6.6 Stakeholder and EPA Regional Issues 5-121
5.4.6.7 Conclusions 5-123
5.4.6.8 References 5-124
5.5 Group IV Industries 5-125
5.5.1 Canned and Preserved Fruits and Vegetables Processing
(Part 407) 5-125
5.5.1.1 Industry Description 5-125
iii
-------
TABLE OF CONTENTS (Continued)
Page
5.5.1.2 Regulatory Background 5-126
5.5.1.3 Wastewater Characteristics and Pollutant Sources .. 5-127
5.5.1.4 Treatment Technology and Pollution Prevention ... 5-131
5.5.1.5 Industry Trends 5-131
5.5.1.6 Stakeholder and EPA Regional Issues 5-132
5.5.1.7 Potential Additional Subcategories 5-134
5.5.1.8 Conclusions 5-138
5.5.1.9 References 5-138
5.5.2 Canned and Preserved Seafood Processing (Part 408) 5-138
5.5.2.1 Industry Description 5-138
5.5.2.2 Regulatory Background 5-139
5.5.2.3 Wastewater Characteristics and Pollutant Sources .. 5-140
5.5.2.4 Treatment Technology and Pollution Prevention . . . 5-144
5.5.2.5 Industry Trends 5-144
5.5.2.6 Stakeholder and EPA Regional Issues 5-145
5.5.2.7 Conclusions 5-147
5.5.2.8 References 5-147
5.5.3 Coal Mining (Part 434) 5-147
5.5.3.1 Industry Description 5-148
5.5.3.2 Regulatory Background 5-149
5.5.3.3 Wastewater Characteristics and Pollutant Sources .. 5-151
5.5.3.4 Treatment Technology and Pollution Prevention ... 5-154
5.5.3.5 Industry Trends 5-154
5.5.3.6 Stakeholder and EPA Regional Issues 5-156
5.5.3.7 Conclusions 5-157
5.5.4 Coil Coating (Part 465) 5-157
5.5.4.1 Industry Description 5-157
5.5.4.2 Regulatory Background 5-158
5.5.4.3 Wastewater Characterization and Pollutant Sources . 5-161
5.5.4.4 Treatment Technology and Pollution Prevention . . . 5-163
5.5.4.5 Industry Trends 5-164
5.5.4.6 Stakeholder and Regional Issues 5-165
5.5.4.7 Conclusions 5-166
5.5.5 Dairy Products Processing (Part 405) 5-167
5.5.5.1 Industry Description 5-167
5.5.5.2 Regulatory Background 5-168
5.5.5.3 Wastewater Characteristics and Pollutant Sources .. 5-170
5.5.5.4 Treatment Technology and Pollution Prevention . . . 5-173
5.5.5.5 Industry Trends 5-174
5.5.5.6 Stakeholder and EPA Regional Issues 5-175
5.5.5.7 Conclusions 5-176
5.5.5.8 References 5-176
5.5.6 Electrical and Electronic Components (Part 469) 5-176
IV
-------
TABLE OF CONTENTS (Continued)
Page
5.5.6.1 Industry Description 5-177
5.5.6.2 Regulatory Background 5-178
5.5.6.3 Wastewater Characteristics and Pollutant Sources .. 5-181
5.5.6.4 Treatment Technology and Pollution Prevention ... 5-185
5.5.6.5 Industry Trends 5-185
5.5.6.6 Stakeholder and EPA Regional Issues 5-186
5.5.6.7 Conclusions 5-187
5.5.6.8 References 5-187
5.5.7 Metal Molding and Casting (Part 464) 5-189
5.5.7.1 Industry Description 5-189
5.5.7.2 Regulatory Background 5-189
5.5.7.3 Wastewater Characteristics and Pollutant Sources .. 5-191
5.5.7.4 Treatment Technology and Pollution Prevention ... 5-195
5.5.7.5 Industry Trends 5-195
5.5.7.6 Stakeholder and EPA Regional Issues 5-196
5.5.7.7 Conclusions 5-199
5.5.8 Mineral Mining and Processing (Part 436) 5-199
5.5.8.1 Industry Description 5-200
5.5.8.2 Regulatory Background 5-203
5.5.8.3 Wastewater Characteristics and Pollutant Sources .. 5-206
5.5.8.4 Treatment Technology and Pollution Prevention . . . 5-209
5.5.8.5 Industry Trends 5-210
5.5.8.6 Stakeholder and EPA Regional Issues 5-212
5.5.8.7 Conclusions 5-213
5.5.9 Oil and Gas Extraction (40 CFR Part 435) 5-213
5.5.9.1 Industry Description 5-213
5.5.9.2 Regulatory Background 5-216
5.5.9.3 Wastewater Characteristics and Pollutant Sources .. 5-218
5.5.9.4 Pollutants of Concern Identified 5-219
5.5.9.5 Offshore Subcategory (Subpart A) 5-220
5.5.9.6 Coastal Subcategory (Subpart D) 5-225
5.5.9.7 Coal Bed Methane Extraction 5-232
5.5.9.8 References 5-245
5.6 Group V Industries 5-245
5.6.1 Metal Products and Machinery, Metal Finishing, and
Electroplating (Parts 438, 413, and 433) 5-249
5.6.1.1 Background 5-249
5.6.1.2 Public Comments 5-250
5.6.1.3 EPA Review of Available Data 5-250
5.6.1.4 Conclusions 5-248
5.6.2 Pulp and Paperboard (Part 430) 5-252
5.6.2.1 Technology Basis for Phase I 5-252
5.7 Group VI Industries 5-253
-------
TABLE OF CONTENTS (Continued)
Page
SECTION 6 ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS
DETAILED REVIEW 6-1
6.1 Introduction 6-1
6.2 Data Sources 6-2
6.2.1 Toxic Release Inventory (TRI) 6-2
6.2.1.1 Facility-Specific Verification of TRI Data 6-4
6.2.1.2 Data Submitted with Comments 6-4
6.2.1.3 Correction for PCBs and Pesticides 6-4
6.2.2 Permit Compliance System (PCS) 6-5
6.2.2.1 Data Submitted with Comments 6-5
6.2.2.2 Correction for PCBs and Pesticides 6-6
6.2.3 Economic Census 6-6
6.2.4 The Chlorine Chemistry Council 6-6
6.2.5 The Vinyl Institute 6-7
6.2.6 Office of Solid Waste Chlorinated Aliphatics Rule 6-7
6.2.7 Office of Air and Radiation NESHAPs Rule for Mercury
Cell Chlor-Alkali Plants 6-8
6.2.8 Other Data Sources 6-8
6.3 General Industry Profile and Identification of Focus Industries 6-9
6.3.1 General Overview of the OCPSF Category 6-9
6.3.2 OCPSF Manufacturing Processes 6-12
6.3.3 General Wastewater Characteristics and Treatment 6-13
6.3.3.1 General Wastewater Characteristics 6-13
6.3.3.2 General Wastewater Treatment 6-16
6.3.4 Focus Industry Identification and SIC Code Analysis 6-17
6.3.4.1 Focus Industry Identification 6-17
6.3.4.2 No Further Consideration of SIC Codes 2823 and
2824: Fiber Manufacturers 6-18
6.3.4.3 Decision for No Further Investigation 6-22
6.4 Current Effluent Limitations Guidelines and Standards 6-22
6.5 Other Regulations Affecting OCPSF Facilities 6-24
6.5.1 Resource Conservation and Recovery Act (RCRA) 6-24
6.5.2 Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) 6-25
6.5.3 Clean Air Act (CAA) 6-25
6.5.3.1 NESHAPs Program 6-26
6.5.3.2NSPS 6-27
6.5.3.3 Consolidated Air Rule (CAR) 6-27
6.5.3.4 State Implementation Plans (SIP) 6-27
6.5.3.5 New Source Review 6-27
6.5.3.6 Title VI Stratospheric Ozone Protection 6-28
6.5.4 Toxic Substances Control Act (TSCA) 6-28
vi
-------
TABLE OF CONTENTS (Continued)
Page
6.5.5 Emergency Planning and Community Right-To-Know Act
(EPCRA) 6-29
6.5.6 Pending and Proposed Regulatory Requirements 6-29
6.6 Focus Group 1: Coal Tar Refiners 6-29
6.6.1 Facilities 6-29
6.6.2 Process Description and Wastewater Sources 6-30
6.6.3 Pollutants of Concern 6-32
6.6.3.1 TRIData 6-32
6.6.3.2 PCS Data 6-33
6.6.4 Wastewater Treatment 6-35
6.6.5 Industry Trends 6-35
6.6.6 Conclusions 6-36
6.7 Focus Group 2 - Aniline Dischargers 6-36
6.7.1 Facilities 6-36
6.7.2 Process Description and Wastewater Sources 6-38
6.7.2.1 Aniline Production 6-38
6.7.2.2 Azo Dye Manufacturing 6-41
6.7.3 Pollutants of Concern 6-43
6.7.4 Wastewater Treatment 6-44
6.7.5 Conclusions 6-46
6.8 Focus Group 3: Dioxin Dischargers 6-46
6.8.1 Facilities 6-47
6.8.2 Process Descriptions 6-51
6.8.2.1 Chlor-Alkali 6-51
6.8.2.2 Ethylene Dichloride and Vinyl Chloride Monomer . . 6-55
6.8.2.3 Polyvinyl Chloride 6-57
6.8.3 Wastewater Sources 6-58
6.8.4 Pollutants of Concern 6-60
6.8.4.1 Pollutants of Concern by Product Group 6-60
6.8.4.2 Dioxin as a Pollutant of Concern 6-63
6.8.5 Comparison of Dioxin Release Data for OCPSF Focus
Group 3 6-71
6.8.6 Wastewater Treatment in Place 6-72
6.8.6.1 Chlor-Alkali 6-78
6.8.6.2 Integrated Chlor-Alkali/EDC/VCM 6-78
6.8.6.3 EDC/VCM 6-78
6.8.7 Industry Trends 6-78
6.8.7.1 Dioxin Discharge Trends 6-78
6.8.7.2 Chlorine Industry Trends 6-80
6.8.8 Conclusions 6-80
6.9 Control of Dioxin in Wastewater 6-83
6.9.1 Treatment Technologies for Control of Dioxin in
Wastewater 6-83
vn
-------
TABLE OF CONTENTS (Continued)
Page
6.9.1.1 Pollution Prevention 6-83
6.9.1.2 In-Process Wastewater Treatment 6-83
6.9.1.3 End-of-Pipe Wastewater Treatment 6-84
6.9.2 Summary of Available Treatment Cost Data and
Justification for Not Estimating Costs 6-84
6.10 Chemical Formulators, Packagers, and Repackagers 6-85
6.10.1 CFPR Industry Description 6-85
6.10.2 Process Descriptions and Wastewater Sources 6-87
6.10.2.1 CFPR Processes 6-87
6.10.2.2 CFPR Process Wastewater 6-88
6.10.3 Pollutants of Concern 6-89
6.10.3.1 PCS and TRI Data for the CFPR Industry 6-89
6.10.3.2 Pollutants of Concern for SIC Code 2842 6-91
6.10.3.3 Pollutants of Concern for SIC Code 2844 6-91
6.10.3.4 Pollutants of Concern for SIC Code 2891 6-91
6.10.3.5 Pollutants of Concern for SIC Code 2899 6-92
6.10.3.6 Total TWPE for CFPR Operations 6-92
6.10.4 Wastewater Treatment/Best Management Practices 6-93
6.10.4.1 CFPR Wastewater Treatment 6-93
6.10.4.2 Permit Review Summary 6-94
6.10.5 Conclusions 6-95
6.11 References 6-95
SECTION 7 PETROLEUM REFINING 7-1
7.1 Introduction 7-1
7.2 Data Sources 7-2
7.2.1 Toxic Release Inventory (TRI) 7-2
7.2.1.1 Identification of Petroleum Refineries Operating in
2000 7-4
7.2.1.2 Refinery-Specific Verification of TRI Data 7-4
7.2.1.3 Meetings with Representatives from Refinery and
Trade Associations 7-6
7.2.1.4 Comments Received in Response to the Federal
Register Notice of the 2004/2005 Preliminary
Effluent Guidelines Program Plan 7-6
7.2.2 Permit Compliance System (PCS) 7-7
7.2.3 The U.S. Economic Census 7-8
7.2.4 Data Sources Specific to the Petroleum Refining Industry .... 7-8
7.3 Industry Description 7-9
7.3.1 Number of Refineries 7-9
7.3.2 Discharge Status for Petroleum Refineries 7-10
7.3.3 Overview of Refinery Operations 7-10
7.3.3.1 Crude Petroleum Processing 7-11
viii
-------
TABLE OF CONTENTS (Continued)
Page
7.3.3.2 Refining of Petroleum Fractions - Cracking, Coking,
Hydrotreating/Hydroprocessing, Alkylation,
Polymerization, and Isomerization 7-11
7.3.3.3 Refining of Petroleum Fractions - Catalytic
Reforming and Reformer Catalyst Regeneration 7-13
7.3.3.4 Refining of Petroleum Product Properties 7-17
7.3.3.5 Supporting Operations at Petroleum Refineries 7-17
7.4 Regulatory Background 7-18
7.4.1 Effluent Guidelines History 7-18
7.4.2 Subcategorization and Applicability 7-18
7.4.3 Technical Basis of Regulation 7-20
7.4.4 Regulated Pollutants 7-20
7.4.5 Other Regulations Affecting Petroleum Refineries 7-21
7.4.5.1 RCRA 7-21
7.4.5.2 CAA National Emission Standards for Hazardous
Air Pollutants (NESHAPs) 7-22
7.4.5.3 Other CWA Requirements 7-22
7.5 Wastewater Characterization 7-23
7.5.1 Wastewater Sources 7-23
7.5.2 Discharge Volumes 7-25
7.5.2.1 Discharge Volumes from the 1996 Preliminary Data
Summary 7-25
7.5.2.2 Discharge Volumes from All Refineries Reported to
2000 PCS 7-25
7.5.3 Pollutant Loadings 7-25
7.5.3.1 Pollutant Loadings Calculated Using TRI Data 7-26
7.5.3.2 Pollutant Loadings Calculated Using PCS Data 7-27
7.5.4 Treatment In Place 7-28
7.6 Polycyclic Aromatic Compounds 7-29
7.6.1 Identification and Description of PACs 7-30
7.6.2 Estimation of TWPE 7-31
7.6.3 Sources at Petroleum Refineries 7-31
7.6.4 Reported PAC Discharges 7-33
7.6.4.1 TRI Discharges 7-33
7.6.4.2 PCS Discharges 7-33
7.6.4.3 Data Provided in Comments Regarding Preliminary
Plan 7-36
7.6.5 Further Analysis of PACs 7-37
7.6.6 PAC Control Technologies 7-40
7.6.7 Detailed Study Findings on PACs 7-42
7.7 Dioxins 7-43
7.7.1 Identification and Description of Dioxins 7-43
7.7.2 Estimation of TWPE 7-44
IX
-------
TABLE OF CONTENTS (Continued)
Page
7.7.3 Dioxin Sources at Petroleum Refineries 7-45
7.7.4 Reported Dioxin Discharges 7-45
7.7.4.1 TRI Discharges 7-45
7.7.4.2 PCS Discharges 7-47
7.7.4.3 In-Plant Monitoring 7-47
7.7.4.4 Industry Comments About Dioxins 7-50
7.7.5 Compilation and Discussion of Measured Effluent Dioxin
Concentrations 7-50
7.7.6 Dioxin Control Technologies 7-58
7.7.7 Detailed Study Findings for Dioxins 7-59
7.8 Metals 7-63
7.8.1 Identification and Description of the Metals Discharged in
Petroleum Refinery Wastewater 7-63
7.8.2 Sources of Metals at the Petroleum Refinery 7-63
7.8.3 Reported Metal Discharges 7-64
7.8.3.1 Mass Discharges: TRI and PCS 7-64
7.8.3.2 Additional Metals Data (Concentrations) 7-66
7.8.4 Metals Control Technologies 7-70
7.8.5 Detailed Study Findings for Metals 7-70
7.9 Conventional and Nonconventional Pollutants 7-72
7.9.1 Reported Conventional and Nonconventional Pollutant
Discharges 7-72
7.9.1.1 Mass Discharges: PCS 7-72
7.9.1.2 Conventional and Nonconventional Pollutant
Concentrations 7-73
7.9.2 Detailed Study Findings for Conventional and Other
Nonconventional Pollutants 7-76
7.10 Pollution Control 7-77
7.11 Petroleum Refining References 7-78
7.12 Petroleum Bulk Stations and Terminals 7-81
7.12.1 Introduction 7-81
7.12.2 Data Sources 7-82
7.12.2.1 Toxic Release Inventory 7-82
7.12.2.2 Permit Compliance System 7-84
7.12.2.3 Other Data Sources 7-85
7.12.3 Industry Description 7-86
7.12.3.1 Industry Groups 7-86
7.12.3.2 Industry Statistics 7-87
7.12.3.3 Discharge Status 7-88
7.12.3.4 Overview of Operations and Potential
Wastewater Sources 7-89
7.12.4 Regulatory Background 7-96
7.12.4.1 Clean Water Act 7-97
-------
TABLE OF CONTENTS (Continued)
Page
7.12.4.2 Clean Air Act 7-98
7.12.4.3 Resource Conservation and Recovery Act ...7-99
7.12.4.4 Emergency Planning and Community
Right-to-Know Act 7-102
7.12.4.5 Safe Drinking Water Act 7-103
7.12.4.6 Regional and State Programs 7-103
7.12.5 Wastewater Characterization 7-111
7.12.5.1 TRIData 7-111
7.12.5.2 PCS Data 7-111
7.12.5.3 Stormwater Contributions to TRI and PCS
Data 7-112
7.12.5.4 Wastewater Handling 7-113
7.12.6 Pollution Prevention Practices 7-114
7.12.6.1 Stormwater Pollution Prevention Practices .. 7-115
7.12.6.2 Minimizing Generation of Wastewater 7-117
7.12.6.3 Pollution Prevention Practices for Reducing
Other Sources of Wastewater 7-124
7.12.6.4 Conclusions 7-125
7.12.7 PBST References 7-126
SECTION 8 NUTRIENT ANALYSIS 8-1
8.1 Introduction 8-1
8.2 Reference Conditions 8-1
8.3 Decay Coefficients 8-2
8.4 Methodology for Developing Total Nitrogen and Total Phosphorous
Loads 8-3
8.4.1 Total Nitrogen Load 8-3
8.4.2 Total Phosphorus Load 8-5
8.5 Stream Dilution Modeling 8-6
8.6 Results 8-7
8.6.1 Petroleum Refining 8-7
8.6.2 OCPSF 8-8
8.7 References 8-9
SECTION 9 INDUSTRIES IDENTIFIED AS NEW BY COMMENTERS 9-1
9.1 Airport Deicing Operations 9-1
9.2 Drinking Water Supply & Treatment 9-2
XI
-------
LIST OF TABLES
Page
2-1 Comments on Preliminary Effluent Guidelines Program Plan for
2004/2005 EPA Docket Number: OW-2003-0074 2-1
4-1 Dioxins and Their Toxic Equivalency Factors 4-13
4-2 Dioxins and Their Toxic Weighting Factors 4-14
4-3 Definition of Poly cyclic Aromatic Compounds 4-15
5-1 Industries Covered by National Clean Water Industrial Regulations 5-2
5-2 Number of Facilities in Inorganic Chemicals Manufacturing Industry 5-6
5-3 Number of Facilities by Discharge Type and SIC Code 5-6
5-4 Reserved Subparts in 40 CFR Part 415 5-8
5-5 Subparts in 40 CFR Part 415 Requiring No Discharge at BPT 5-8
5-6 Regulated Pollutants/Parameters by Subpart in 40 CFR Part 415 5-9
5-7 2000 TRI Top Pollutants Discharged by the Inorganic Chemicals
Manufacturing Industry 5-10
5-8 2000 PCS Top Pollutants Discharged by the Inorganic Chemicals
Manufacturing Industry 5-11
5-9 1992 and 2000 Wastewater Flows by SIC Code 5-12
5-10 Pollutants of Concern from 2000 TRI Data (Direct and Indirect
Dischargers) 5-12
5-11 Pollutants of Concern from 2000 PCS Data (Direct Dischargers) 5-13
5-12 Wastewater Treatment Operations Reported By Inorganic Chemicals
Manufacturing Facilities, TRI Reporting Year 2000 5-14
5-13 SIC Codes and Subcategories in Part 421 5-17
5-14 Number of Operating Facilities, By Year and Data Source 5-19
5-15 Wastewater Discharge Status Reported in TRIReleases2000 5-20
xn
-------
LIST OF TABLES (Continued)
Page
5-16 Top Pollutants Discharged by the NFM Manufacturing Industry 5-22
5-17 Pollutants of Concern Identified in TRIReleases2000 (Direct and Indirect
Dischargers) 5-23
5-18 Pollutants of Concern Identified in PCS Database (Direct Dischargers) .... 5-24
5-19 NFM Manufacturing Category Pollutant Reductions 5-25
5-20 Wastewater Treatment Operations Reported By NFM Manufacturing
Facilities, TRI Reporting Year 2000 5-25
5-21 Subcategories in the Fertilizer Manufacturing Point Source
Category (Part 418) 5-28
5-22 Subcategories in the Phosphate Manufacturing Point Source
Category (Part 422) 5-29
5-23 Review of Top Fertilizer and Phosphate Dischargers Reporting SIC 2874
as Primary SIC Code 5-30
5-24 Number of Fertilizer and Phosphate Facilities 5-33
5-25 Pollutants Regulated by Existing Fertilizer and Phosphate ELGS 5-34
5-26 2000 Wastewater Flows for Fertilizer and Phosphate Facilities 5-36
5-27 Fertilizer and Phosphate Pollutant Discharges Reported by Major Facilities
to PCS for 2000 5-37
5-28 Fertilizer and Phosphate Chemical Releases to Surface Water Reported to
TRI for 2000 5-37
5-29 Wastewater Treatment Operations Reported By Fertilizer and Phosphate
Manufacturing Facilities, TRI Reporting Year 2000 5-38
5-30 Number of Ore Mining and Dressing Facilities 5-42
5-31 Number of Ore Mining and Dressing Facilities by Discharge Type
(TRI 2000) 5-43
5-32 Ore Mining and Dressing Pollutants Regulated by Existing Effluent
Limitations Guidelines and Standards 5-44
xiii
-------
LIST OF TABLES (Continued)
Page
5-33 2000 Wastewater Flows for Ore Mining and Dressing Facilities 5-45
5-34 Ore Mining and Dressing Chemical Releases to Surface Water Reported
to TRI for 2000 5-46
5-35 Ore Mining and Dressing Pollutant Discharges Reported to PCS for 2000 .. 5-47
5-36 Ore Mining and Dressing Top Pollutants Reported to TRI and PCS for
2000 That Are Not Regulated Under 40 CFR Part 440 5-50
5-37 Toxic Metals in Ore Mining Wastewater 5-51
5-38 Ore Mining and Dressing Stormwater Discharges Reported to TRI
for 2000 5-52
5-39 Wastewater Treatment Operations Reported By Ore Mining and Dressing
Facilities, TRI Reporting Year 2000 5-54
5-40 Comparison of Ore Mining and Dressing Facilities in 1982 and 2000 5-55
5-41 Number of Pulp, Paper, and Paperboard Establishments 5-59
5-42 Pulp and Paper Mills Reporting to TRI for Reporting Year 2000 5-60
5-43 Pulp and Paper Mills with Data in PCS 5-60
5-44 Phase II Mills 5-61
5-45 ELGS for Pulp, Paper, and Paperboard Phase II Subcategories (Part 430) . . . 5-62
5-46 2000 Wastewater Flows for Phase II Mills (All SIC Codes) 5-63
5-47 Pulp and Paper Phase II Chemical Releases Reported to TRI for 2000 5-65
5-48 Pulp and Paper Phase II Chemical Releases Reported to TRI for 2000
Without PACs or Dioxins 5-65
5-49 Pulp and Paper Phase II PCS Pollutant Discharges Reported for
PCS for 2000 5-66
5-50 Comparison of Analytes Detected in Treated Wastewater (Final Effluent) .. 5-67
5-51 Phase II Mills Reporting Releases of PACs for TRI Reporting Year 2000 . . 5-68
xiv
-------
LIST OF TABLES (Continued)
Page
5-52 Phase II Mills Reporting Releases of Dioxin and Dioxin-Like Compounds
to TRI for Reporting Year 2000 5-70
5-53 Wastewater Treatment Operations Reported by Phase II Mills, TRI
Reporting Year 2000 5-71
5-54 Trends in U.S. Papermaking Industry (Pulp, Paper, and Converted
Products) 5-72
5-55 Number of Steam Electric Facilities 5-74
5-56 Steam Electric Pollutants Regulated by ELGS 5-76
5-57 Sources of Process Wastewater in Steam Electric Facilities 5-77
5-58 2000 Wastewater Flows for Steam Electric Facilities 5-78
5-59 Steam Electric Chemical Releases to Surface Water Reported to
TRI for 2000 5-79
5-60 Pollutant Discharges Reported by Major Steam Electric Facilities
to PCS for 2000 5-80
5-61 Five Highest Parameter Loadings (as Measured by TWPE) Reported to
PCS in 1992 and 2000 5-82
5-62 Wastewater Treatment Operations Reported By Steam Electric Facilities,
TRI Reporting Year 2000 5-84
5-63 Comparison of Industry Statistics 5-85
5-64 Textile Mills Subcategories 5-87
5-65 Number of Textile Mills 5-88
5-66 Number of Textile Mills by Discharge Type (TRI 2000) 5-89
5-67 Pollutants Regulated by Existing Textile Mill ELGS 5-92
5-68 2000 Wastewater Flows for Textile Mills 5-93
5-69 Textile Mill Chemical Releases to Surface Water Reported to TRI
for 2000 5-95
xv
-------
LIST OF TABLES (Continued)
Page
5-70 Textile Mill Pollutant Discharges Reported to PCS for 2000 5-96
5-71 Textile Mill Pollutant Discharges Reported in 1996 Preliminary Study 5-96
5-72 Eight Highest Chemical Releases Reported to TRI in 1992 and 2000 5-97
5-73 Five Highest Parameter Loadings Reported to PCS in 1994 and 2000 5-98
5-74 Sources of Process Wastewater in Textile Manufacturing 5-99
5-75 Wastewater Treatment Operations Reported By Textile Mills, TRI
Reporting Year 2000 5-101
5-76 Comparison of Industry Statistics 5-103
5-77 Timber Products Processing SIC Code Descriptions 5-105
5-78 Number of Facilities in Timber Products Processing SIC Codes 5-106
5-79 Number of Timber Products Processing Facilities by Discharge
Type (TRI 2000) 5-107
5-80 Pollutants Regulated by Existing Timber Products Processing ELGS 5-108
5-81 Summary of Technology Basis of Existing Timber Products ELGS 5-110
5-82 Timber Products Wastewater Flows Reported to PCS for 2000 5-113
5-83 Timber Products Processing Pollutant Discharges Reported to PCS
for 2000 5-114
5-84 Timber Products Processing Pollutant Releases to Surface Water
Reported to TRI for 2000 5-116
5-85 Stormwater Discharges of Pollutants Accounting for 90 Percent of
Unweighted Pounds of Wood Preserving Pollutant Loads 5-118
5-86 Stormwater Discharges of Pollutant Accounting for 90 Percent of Wood
Preserving TWPE 5-118
5-87 Nonstormwater Discharges of Pollutants from Wood Preserving
Facilities 5-119
xvi
-------
LIST OF TABLES (Continued)
Page
5-88 Wastewater Treatment Operations Reported By Timber Products
Processing Facilities TRI Reporting Year 2000 5-120
5-89 Number of Facilities in Fruits and Vegetable Processing SIC Codes 5-126
5-90 Effluent Guidelines for Canned and Preserved Fruits and Vegetables
Processing, Part 407 5-127
5-91 Wastewater Flows in the Canned and Preserved Fruits and Vegetables
Processing Industry 5-127
5-92 Sources of Process Wastewater in Canned and Preserved Fruits and
Vegetables Processing Industry 5-128
5-93 Pollutant Discharges Reported to PCS and TRI 5-129
5-94 Canned and Preserved Fruits and Vegetables Processing TWPE Reported
to PCS Compared to Industries Reporting Highest Discharge 5-130
5-95 Canned and Preserved Fruits and Vegetables Processing TWPE Reported
to TRI Compared to Industries Reporting Highest Discharges 5-130
5-96 Water Conservation and Pollution Prevention Alternatives 5-131
5-97 Comparison of 1992 and 1997 Census Data 5-132
5-98 Comparison of 1997 and 2002 U.S. Economic Census Data 5-132
5-99 Number of Facilities in the Canned and Preserved Seafood
Processing Category 5-139
5-100 Effluent Guidelines for Canned and Preserved Seafood Processing
Part 408 5-141
5-101 Wastewater Flows 5-140
5-102 Pollutant Discharges Reported to PCS and TRI in 2000 5-142
5-103 Canned and Preserved Seafood Processing TWPE Reported to PCS
Compared to Industries Reporting 10 Highest Discharges 5-143
5-104 Canned and Preserved Seafood Processing TWPE Reported to TRI
Compared to Industries Reporting 10 Highest Dischargers 5-143
xvii
-------
LIST OF TABLES (Continued)
Page
5-105 Water Conservation and Pollution Prevention Alternatives 5-144
5-106 1992 and 1997 Census Data 5-145
5-107 1997 and 2002 Census Data 5-145
5-108 Number of Facilities in the Coal Mining Category 5-149
5-109 Effluent Guidelines for Coal Mining Part 434 5-150
5-110 Catastrophic Precipitation Event Exemption 5-150
5-111 Wastewater Flows for Coal Mining Facilities 5-151
5-112 Sources of Process Wastewater in Coal Mining 5-151
5-113 Pollutant Discharges Reported to PCS and TRI in 2000 5-152
5-114 Coal Mining TWPE Reported to PCS Compared to Industries Reporting
10 Highest Discharges 5-153
5-115 Coal Mining TWPE Reported to TRI Compared to Industries Reporting
10 Highest Discharges 5-153
5-116 1992 and 1997 Census Data 5-155
5-117 Number of U.S. Coal Mining Operations from 1997 to 2002 5-155
5-118 U.S. Coal Product!on from 1997 to 2000 (in millions of short tons) 5-155
5-119 Number of Facilities 5-158
5-120 Effluent Guidelines for Coil Coating and Canmaking 5-160
5-121 Sources of Process Wastewater in Coil Coating and Canmaking 5-161
5-122 Pollutant Discharges Reported to PCS and TRI 5-162
5-123 Coil Coating TWPE Reported to PCS Compared to Industries Reporting
10 Highest Discharges 5-162
5-124 Coil Coating TWPE Reported to TRI Compared to Industries Reporting
10 Highest Discharges 5-163
xviii
-------
LIST OF TABLES (Continued)
Page
5-125 Water Conservation and Pollution Prevention Alternatives 5-164
5-126 1992 and 1997 Census Data 5-165
5-127 1997 and 2002 Census Data 5-165
5-128 Can Shipments by Category 5-165
5-129 Number of Facilities in the Dairy Products Processing Category 5-168
5-130 Effluent Guidelines for Dairy Products Processing Part 405 5-169
5-131 Wastewater Flows 5-170
5-132 Sources of Process Wastewater in Dairy Products Processing 5-170
5-133 Pollutant Discharges Reported to PCS and TRI 5-171
5-134 Dairy Products Processing TWPE Reported to PCS Compared to
Industries Reporting Highest Discharges 5-172
5-135 Dairy Products Processing TWPE Reported to TRI Compared to
Industries Reporting Highest Discharges 5-172
5-136 Pollution Prevention Alternatives for Dairy Products Processing 5-174
5-137 1992 and 1997 Census Data 5-175
5-138 1997 and 2002 Census Data 5-175
5-139 Number of Facilities in the Electrical and Electronic Components
Category 5-177
5-140 Effluent Guidelines for Semiconductors and Electronic Crystals
Manufacturing (Concentration-Based) 5-179
5-141 Effluent Limitations and Standards for Cathode Ray Tubes and
Luminescent Materials Manufacturing (Concentration-Based) 5-180
5-142 Wastewater Flows 5-181
5-143 Sources of Process Wastewater in Electrical and Electronic
Components Category 5-182
xix
-------
LIST OF TABLES (Continued)
Page
5-144 Pollutant Discharges Reported to PCS and TRI 5-183
5-145 Electrical and Electronic Components TWPE Reported to PCS Compared
to Industries with the 10 Highest Discharges 5-184
5-146 Electrical and Electronic Components TWPE Reported to TRI Compared
to Industries with the 10 Highest Discharges 5-184
5-147 Water Conservation and Pollution Prevention Alternatives for the
Electrical and Electronic Components Category 5-185
5-148 1992 and 1997 Census Data 5-186
5-149 1997 and 2002 Census Data 5-186
5-150 Copper Discharges Reported to TRI by Electrical and Electronic
Component Manufacturing Facilities 5-187
5-151 Copper1 Discharge Data in PCS for Electrical and Electronic Component
Manufacturing Facilities 5-187
5-152 Number of Facilities in the Metal Molding and Casting Category 5-189
5-153 Effluent Guidelines for Metal Molding and Casting - Continuous Direct
Dischargers (kg/kkg) 5-191
5-154 Wastewater Flows in Metal Molding and Casting 5-192
5-155 Sources of Process Wastewater in Metal Molding and Casting 5-192
5-156 Pollutant Discharges Reported to PCS and TRI 5-193
5-157 Metal Molding and Casting TWPE Reported to PCS Compared to
Industries Reporting Highest Discharges 5-194
5-158 Metal Molding and Casting TWPE Reported to TRI Compared to
Industries Reporting Highest Discharges 5-194
5-159 Water Conservation and Pollution Prevention Alternatives for the Metal
Molding and Casting Category 5-195
5-160 1992 and 1997 Census Data 5-196
xx
-------
LIST OF TABLES (Continued)
Page
5-161 1997 and 2002 Census Data 5-196
5-162 Number of Facilities 5-203
5-163 Effluent Guidelines for Crushed Stone, Construction Sand and Gravel, and
Industrial Sand Subcategories of Part 436 5-205
5-164 Effluent Guidelines for Other Subcategories of Part 436 5-205
5-165 Normalized Effluent Guidelines for Subcategories of Part 436 5-206
5-166 Wastewater Flows 5-206
5-167 Process Sources of Wastewater 5-207
5-168 Pollutant Discharges Reported to PCS and TRI 5-208
5-169 Mineral Mining TWPE Reported to PCS Compared to Industries
Reporting Highest Discharges 5-208
5-170 Mineral Mining TWPE Reported to TRI Compared to Industries
Reporting Highest Discharges 5-209
5-171 Water Conservation and Pollution Prevention Alternatives 5-210
5-172 1992 and 1997 Census Data 5-211
5-173 1997 and 2002 Census Data 5-211
5-174 Number of Facilities in the Oil and Gas Extraction Category 5-214
5-175 Number of Wells Drilled Annually, 1995 - 1997, by Geographic Area .... 5-215
5-176 Identification of Oil and Gas Extraction Fixed Facilities in the Gulf of
Mexico Outer Continental Study 5-215
5-177 Process Wastewater Sources for the Oil and Gas Extraction Industry 5-219
5-178 Pollutant Discharges Reported to PCS and TRI for 2000 5-220
5-179 2000 Discharge Monitoring Report (DMR) Data for the Union Oil
Company of California 5-221
xxi
-------
LIST OF TABLES (Continued)
Page
5-180 Estimated TWPE from Oil and Gas Extraction Facilities in Cook
Inlet, AK 5-226
5-181 Current Sources of CBM Production 5-233
5-182 Estimated CBM Industry Pollutant Loadings 5-234
5-183 Effluent Guidelines Recently Established, Revised, or Reviewed 5-246
5-184 Low Ranked Industries Not Identified by Stakeholders 5-254
6-1 OCPSF Subcategories for BPT (40 CFR Part 414) 6-10
6-2 Examples of Chemicals Produced by OCPSF Facilities 6-10
6-3 SIC Codes in OCPSF 6-12
6-4 Examples of Generic OCPSF Processes Identified in the 1987 TDD 6-12
6-5 Examples of Feedstock and End Products Identified in the 1987 TDD 6-13
6-6 Untreated Wastewater Characteristics for Direct and Indirect
Dischargers in the OCPSF Category 6-14
6-7 Examples of Pollutants Discharged from the Manufacturing of
Certain Products 6-14
6-8 OCPSF Pollutant Load Discharged to Surface Water in 2000 by SIC Code .6-15
6-9 OCPSF Annual Wastewater Flows by SIC Code as Reported to
PCS in 2000 6-15
6-10 Wastewater Treatment Operations Reported by OCPSF Facilities
TRI Reporting Year 2000 6-16
6-11 Top Pollutants Reported Discharged in 2000 for the OCPSF Category 6-17
6-12 Facilities in SIC Codes 2823 and 2824 in the 2000 TRI and/or PCS 2000 ... 6-19
6-13 Facilities with Primary SIC Code 2824 in PCS and 2821 in TRI 6-20
6-14 Facilities with Primary SIC Code 2824 in TRI and Other in PCS 6-20
xxn
-------
LIST OF TABLES (Continued)
Page
6-15 Pollutants with Highest TWPE Based on 2000 TRI Data 6-21
6-16 Pollutants with Highest TWPE Based on PCS 2000 Data 6-22
6-17 Summary of Existing Effluent Limitations Guidelines and
Pretreatment Standards (40 CFR Part 414) 6-23
6-18 Coal Tar Refiners in the United States 6-30
6-19 PACs Water Discharges Reported to TRI for 2000 and 2001 6-32
6-20 PACs Wastewater Discharges Reported to PCS in 2000 6-33
6-21 Concentrations of PACs Reported to PCS 6-34
6-22 Pollutants of Concern for Coal Tar Refiners 6-34
6-23 Production Trend for Cokemaking and Coal Tar Pitch 6-35
6-24 OCPSF Aniline Dischargers in the United States 6-37
6-25 Aniline Discharges Reported to TRI and PCS in 2000 for SIC Code 2865 . . 6-43
6-26 Aniline Discharges Reported to TRI 6-44
6-27 Pollutants of Concern for Aniline Dischargers 6-44
6-28 Facilities That Discharge Indirectly and Their Respective POTWs 6-45
6-29 OCPSF Dioxin Dischargers in the United States 6-48
6-30 Facilities Reporting Dioxin Discharges to TRI that Manufacture Other
Organic Chemicals in the United States 6-50
6-31 Pollutants of Concern for 24 Stand-Alone Chi or-Alkali Manufacturers 6-60
6-32 Pollutants of Concern for Stand-Alone EDC/VCM Manufacturers (No
Chlor Alkali) 6-61
6-33 Pollutants of Concern for Integrated Chi or-Alkali and Vinyl Facilities
(Manufacturers of Chi or-Alkali and EDC/VCM, May Also Produce PVC) . . 6-62
xxin
-------
LIST OF TABLES (Continued)
Page
6-34 Pollutants of Concern for Stand-Alone Manufacturers of Polyvinyl
Chloride 6-62
6-35 Dioxin Releases Reported by OCPSF Facilities to TRI for 2000 and 2001,
Adjusted for POTW Removals 6-65
6-36 Dioxin Loads Reported by OCPSF Facilities to PCS for 2000 6-66
6-37 Wastewater Emission Factors and Estimated Releases for PVC-Only and
EDC/VCM/PVC Manufacturing Facilities 6-67
6-38 CCC Data for Dioxin Discharges from Facilities Manufacturing Chlorine
or Chlorine-Related Products for 2000 6-68
6-39 Dioxin Congeners Detected in Raw Wastewater from EDC/VCM
Operations 6-69
6-40 Focus Group 3 Industry Analytical Data on Dioxin in Wastewater 6-70
6-41 Wastewater Dioxin Discharges from Focus Group 3 Based On
Industry Data 6-71
6-42 Comparison of Wastewater Dioxin Discharges from Focus Group 3 6-72
6-43 List of Facilities Manufacturing Chi or Alkali, EDC, VCM, and PVC 6-73
6-44 Vinyl Manufacturing and Chlor-Alkali Facility Dioxins in Wastewater .... 6-79
6-45 Chlorine Production in the United States 6-80
6-46 Counts of CFPR Facilities 6-87
6-47 Chemical Releases to Surface Water Reported to TRI for 2000 6-89
6-48 Pollutant Discharges Reported to PCS for 2000 6-90
6-49 PCS and TRI TWPEs by SIC Code for CFPR Sectors 6-93
6-50 Wastewater Treatment Practices at CFPR Facilities 6-93
7-1 Facilities Reporting to TRI and PCS Under SIC Code 2911 that are
Not Operating Refineries 7-5
xxiv
-------
LIST OF TABLES (Continued)
Page
7-2 2000 Discharge Status for Petroleum Refineries 7-10
7-3 Reformer Catalyst Regeneration Processes in 2000 7-14
7-4 Process Wastewater at Petroleum Refineries 7-24
7-5 Discharges Reported to the 2000 TRI for the Petroleum Refining Industry -
Pollutants Comprising Approximately 90 Percent of the TWPE 7-26
7-6 Stormwater Discharges Reported to the 2000 TRI 7-27
7-7 Discharges Reported to the 2000 PCS for the Petroleum Refining
Industry - Top 10 Pollutants Composing 91 Percent of the TWPE 7-27
7-8 Wastewater Treatment Operations Reported By Petroleum Refineries,
TRI Reporting Year 2000 7-29
7-9 Individual Poly cyclic Aromatic Compounds 7-30
7-10 Individual PACs and Petroleum Refinery Sources 7-32
7-11 Petroleum Refineries Reporting Releases of PACs to the 2000 TRI 7-34
7-12 California Refineries Reporting PAH Discharges 7-35
7-13 Individual PACs Reported in 2000 PCS 7-35
7-14 PAC Measurement Data from Activated Sludge Units at 10 Refineries 7-36
7-15 NPRA and API Comments on PAC Discharge Estimates Reported to the
2000 TRI 7-38
7-16 Estimated Concentration of PACs in Petroleum Refining Effluent 7-41
7-17 Individual Dioxin Congeners 7-44
7-18 Petroleum Refineries Reporting Releases of Dioxins to 2000 TRI 7-46
7-19 Petroleum Refineries Reporting 2,3,7,8-TCDD to the 2000 PCS 7-47
7-20 Dioxin Sampling Data from Washington State Refineries (2000-2003) 7-48
7-21 TCDD Equivalents in Petroleum Refinery Wastes 7-49
xxv
-------
LIST OF TABLES (Continued)
Page
7-22 NPRA and API Comments on Dioxin Discharge Estimates
Reported to the 2000 TRI 7-51
7-23 Dioxin Concentrations Measured in U.S. Petroleum Refinery Final
Effluent 7-53
7-24 Treated Effluent Dioxin/Furan Sample Results, pg/L 7-56
7-25 Metals in Petroleum Refining Wastewater 7-63
7-26 Metals Discharges as Percentage of Total TWPE 7-64
7-27 Top Five Metals as Percentage of Total Metal TWPE 7-65
7-28 Five Metals with Highest Estimated TWPE (TRI) 7-65
7-29 Five Metals with Highest Estimated TWPE (PCS) 7-66
7-30 Pollutant Discharge Concentrations for Metals at Petroleum Refineries .... 7-68
7-31 Conventional and Nonconventional Pollutant Discharges in PCS 7-72
7-32 Conventional Pollutants with Highest Estimated Pounds Discharged (PCS) . 7-73
7-33 Nonconventional Pollutants with Highest Estimated TWPE (PCS) 7-73
7-34 Pollutant Discharge Concentrations for Conventional and
Nonconventional Pollutants at Petroleum Refineries 7-74
7-35 Geographic Distribution of PBSTs, per 1997 Economic Census 7-88
7-36 Facilities Reporting to TRI and PCS in 2000 and Their Discharge Status . . . 7-89
7-37 Concentrations That Would Render Tank Bottoms Water a RCRA
Hazardous Waste 7-101
7-38 Sample Limits in North Carolina's Stormwater General Permit 7-104
7-39 Parameters Considered by Ohio While Developing Permits 7-106
7-40 Limitations by Discharge Type 7-107
7-41 Arkansas Limits by Outfall Type 7-108
xxvi
-------
LIST OF TABLES (Continued)
Page
7-42 Texas General Permit Limits 7-109
7-43 Oregon Stormwater Pollution Control Plan benchmarks 7-110
7-44 TWPE Discharges of Individual Pollutants Based on 2000 TRI Data 7-111
7-45 TWPE Discharges of Individual Pollutants Based on 2000 PCS Data 7-112
7-46 Percent Discharges to Surface Waters Due to Stormwater for 2000
TRI Reporters 7-112
8-1 Decay Coefficients for Nitrogen and Phosphorus, Segregated by
Stream Flowrate 8-3
8-2 Nitrogen Compounds Reported to TRI and PCS by OCPSF and
Petroleum Refining Facilities 8-4
8-3 Phosphorus Parameters Reported to PCS by OCPSF and Petroleum
Refining Facilities 8-5
8-4 Summary of Screening-level Nutrient Analysis for Petroleum
Refining Direct Discharge Facilities 8-8
8-5 Summary of Screening-level Nutrient Analysis for OCPSF Direct
Discharge Facilities 8-9
xxvn
-------
LIST OF FIGURES
Page
6-1 Coal Tar Refining Process Flow Diagram 6-31
6-2 Vapor-Phase Aniline Manufacturing Process 6-39
6-3 Dupont/KBR Liquid-Phase Aniline Process 6-40
6-4 Azo Dye Manufacturing Process 6-42
6-5 Mercury Cell Chlor-Alkali Process 6-53
6-6 Membrane or Diaphragm Cell Chlor-Alkali Process 6-54
6-7 Flow Diagram for EDC/VCM Balanced Process 6-56
6-8 Process Flow Diagram for Suspension PVC Productions 6-59
7-1 Semi-Regenerative Catalytic Reforming Process 7-15
7-2 Cyclic Catalytic Reforming Process 7-16
7-3 Continuous Catalytic Reforming Process 7-16
xxvin
-------
LIST OF ACRONYMS
BAT
BCT
BMP
BOD
BPJ
BPT
CAA
CDD
CDF
CERCLA
CFC
COD
CWA
ELGS
EPA
EPCRA
FIFRA
NESHAP
NPDES
NSPS
OCPSF
PAC
PCS
POTW
PSES
PSNS
RCRA
SIC
TCDD
TCDF
TEF
TEQ
TOC
TRI
TSCA
TSDF
TSS
TWF
TWPE
VOC
Best Available Technology Economically Achievable
Best Control Technology for Conventional Pollutants
Best Management Practice
Biochemical Oxygen Demand
Best Professional Judgment
Best Practicable Control Technology Currently Available
Clean Air Act
Polychlorinated Dibenzo-p-dioxin
Polychlorinated Dibenzofurans
Comprehensive Environmental Response, Compensation, and Liability
Act
Chi orofluorocarb on s
Chemical Oxygen Demand
Clean Water Act
Effluent Limitations Guidelines and Standards
Environmental Protection Agency
Emergency Planning and Community Right-To-Know Act
Federal Insecticide, Fungicide, and Rodenticide Act
National Emissions Standards for Hazardous Air Pollutants
National Pollutant Discharge Elimination System
New Source Performance Standards
Organic Chemicals, Plastics, and Synthetic Fibers
Polycyclic Aromatic Compound
Permit Compliance System
Publicly-Owned Treatment Works
Pretreatment Standards for Existing Sources
Pretreatment Standards for New Sources
Resource Conservation and Recovery Act
Standard Industrial Classification
Tetrachlorodibenzo(p)dioxin
Tetrachl orodib enzofuran
Toxic Equivalency Factor
Toxic Equivalent
Total Organic Carbon
Toxic Release Inventory
Toxic Substances Control Act
Treatment, Storage, and Disposal Facilities
Total Suspended Solids
Toxicity Weighting Factor
Toxic-Weighted Pound Equivalent
Volatile Organic Compound
xxix
-------
Section 1 - Background
SECTION 1 BACKGROUND
The Effluent Guidelines Program is one part of EPA's Clean Water Act Program.
This section explains how the Effluent Guidelines Program fits into the Clean Water Act
Program, describes the general and legal background of the Effluent Guidelines Program, and
describes EPA's process for making effluent guidelines revision and development decisions.
1.1 EPA's Clean Water Act Program
EPA's Office of Water is responsible for implementing the Clean Water Act (or
"CWA"), which provides EPA and the states with a variety of programs and tools to protect and
restore the Nation's waters. These programs and tools generally rely either on water-quality-
based controls, such as water quality standards and water-quality-based permit limitations, or
technology-based controls such as effluent guidelines and technology-based permit limitations.
Permits developed using the technology-based industrial regulations have been a critical element
of the Nation's clean water program for the past 30 years, helping EPA and the states
substantially reduce industrial water pollution.
The CWA gives states the primary responsibility for establishing, reviewing, and
revising water quality standards. These consist of designated uses for each water body (e.g.,
fishing, swimming, supporting aquatic life), numeric pollutant concentration limits ("criteria") to
protect those uses, and an antidegradation policy. EPA develops national criteria for many
pollutants, which states may adopt or modify as appropriate to reflect local conditions. While
technology-based permits may, in fact, result in meeting state water quality standards, the
effluent guidelines program is not specifically designed to ensure that the discharge from each
facility meets the water quality standards for that particular water body. For this reason, the
CWA also requires states to establish water quality-based permit limitations, where necessary to
attain and maintain water quality standards, that require industrial facilities to meet requirements
that are more stringent than those in a national effluent guideline regulation. Consequently, in
the overall context of the CWA, effluent guidelines must be viewed as one tool in the broad
arsenal of tools Congress provided to EPA and the states to protect and restore the Nation's
water quality.
1.2 The Effluent Guidelines Program
The Effluent Guidelines Program is one component of the Nation's clean water
program, established by the 1972 CWA. The national clean water industrial regulatory program
is authorized under sections 301, 304, 306 and 307 of the CWA and is founded on six core
concepts.
First, the program is designed to address specific industrial categories. To date,
EPA has promulgated effluent guidelines that address 56 categories — ranging from
manufacturing industries such as petroleum refining to service industries such as centralized
waste treatment. These regulations apply to between 35,000 and 45,000 facilities that discharge
1-1
-------
Section 1 - Background
directly to the Nation's waters, as well as another 12,000 facilities that discharge into publicly
owned treatment works (POTWs).
Second, national effluent guideline regulations typically specify the maximum
allowable levels of pollutants that may be discharged by facilities within an industrial category
or subcategory. While the limits are based on the performance of specific technologies, they do
not generally require the industry to use these technologies, but rather allow the industry to use
any effective alternatives to meet the numerical pollutant limits.
Third, each facility within an industrial category or subcategory must generally
comply with the applicable discharge limits — regardless of its location within the country or on
a particular water body. See CWA section 307(b) and (c); and CWA section 402(a)(l). The
regulations, therefore, constitute a single, standard, pollution control obligation for all facilities
within an industrial category or subcategory.
Fourth, in establishing national effluent guidelines for pollutants, EPA considers
various factors, including: (1) the performance of the best pollution control technologies or
pollution prevention practices that are available for an industrial category or subcategory as a
whole; and (2) the economic achievability of that technology, which can include consideration of
costs, benefits, and affordability of achieving the reduction in pollutant discharge.
Direct and Indirect Discharges
Fifth, national
regulations apply to three types of
facilities within an industrial category:
existing facilities that discharge
directly to surface waters (i.e., direct
dischargers); existing facilities that
discharge to POTWs (indirect
dischargers); and newly constructed
facilities (new sources) that discharge
to surface waters either directly or
indirectly.
Finally, the CWA section 304(b) requires EPA to conduct an annual review of
existing effluent guidelines and, if appropriate, to revise these regulations to reflect changes in
the industry and/or changes in available pollution control technologies.
The CWA directs EPA to promulgate effluent limitations guidelines and
standards that reflect pollutant reductions that can be achieved by categories or subcategories of
industrial point sources using specific technologies. See CWA sections 301(b)(2), 304(b), 306,
307(b), and 307(c). For point sources that discharge pollutants directly into the waters of the
United States (direct dischargers), the limitations and standards promulgated by EPA are
implemented through National Pollutant Discharge Elimination System (NPDES) permits. See
CWA sections 301(a), 301(b), and 402. For sources that discharge to POTWs (indirect dischargers),
1-2
-------
Section 1 - Background
EPA promulagates pretreatment standards that apply directly to those sources and are enforced by
POTWs and state and federal authorities. See CWA sections 307(b) and (c).
1.2.1 Best Practicable Control Technology Currently Available (BPT) - CWA
Sections 301(b)(l)(A) & 304(b)(l)
EPA defines BPT effluent limitations for conventional, toxic, and
nonconventional pollutants. Section 304(a)(4) designates the following as conventional
pollutants: biochemical oxygen demand (BOD5), total suspended solids, fecal coliform, pH, and
any additional pollutants defined by the Administrator as conventional. The Administrator
designated oil and grease as an additional conventional pollutant on July 30, 1979. See 44 FR
44501 (July 30, 1979). EPA has identified 65 pollutants and classes of pollutants as toxic
pollutants, of which 126 specific substances have been designated priority toxic pollutants. See
Appendix A to part 423, reprinted after 40 CFR Part 423.17. All other pollutants are considered
to be nonconventional.
In specifying BPT, EPA looks at a number of factors. EPA first considers the
total cost of applying the control technology in relation to the effluent reduction benefits. The
Agency also considers the age of the equipment and facilities, the processes employed and any
required process changes, engineering aspects of the control technologies, non-water-quality
environmental impacts (including energy requirements), and such other factors as the EPA
Administrator deems appropriate. See CWA Section 304(b)(l)(B). Traditionally, EPA
establishes BPT effluent limitations based on the average of the best performances of facilities
within the industry of various ages, sizes, processes or other common characteristics. Where
existing performance is uniformly inadequate, BPT may reflect higher levels of control than
currently in place in an industrial category if the Agency determines that the technology can be
practically applied.
1.2.2 Best Conventional Pollutant Control Technology (BCT) - CWA Sections
301(b)(2)(E) & 304(b)(4)
The 1977 amendments to the CWA required EPA to identify effluent reduction
levels for conventional pollutants associated with BCT for discharges from existing industrial
point sources. In addition to the other factors specified in Section 304(b)(4)(B), the CWA
requires that EPA establish BCT limitations after consideration of a two part
"cost-reasonableness" test. EPA explained its methodology for the development of BCT
limitations in 1986. See 51 FR 24974 (July 9, 1986).
1.2.3 Best Available Technology Economically Achievable (BAT) - CWA Sections
301(b)(2)(A) & 304(b)(2)
For toxic pollutants and nonconventional pollutants, EPA promulgates effluent
guidelines based on the BAT. See CWA Section 301(b)(2)(C), (D) & (F). The factors
considered in assessing BAT include the cost of achieving BAT effluent reductions, the age of
1-2
-------
Section 1 - Background
equipment and facilities involved, the process employed, potential process changes, non-water-
quality environmental impacts, including energy requirements, and other such factors as the EPA
Administrator deems appropriate. See CWA Section 304(b)(2)(B). The technology must also be
economically achievable. See CWA Section 301(b)(2)(A). The Agency retains considerable
discretion in assigning the weight it accords to these factors. BAT limitations may be based on
effluent reductions attainable through changes in a facility's processes and operations. Where
existing performance is uniformly inadequate, BAT may reflect a higher level of performance
than is currently being achieved within a particular subcategory based on technology transferred
from a different subcategory or category. BAT may be based upon process changes or internal
controls, even when these technologies are not common industry practice.
1.2.4 New Source Performance Standards (NSPS) - CWA Section 306
NSPS reflect effluent reductions that are achievable based on the best available
demonstrated control technology. New sources have the opportunity to install the best and most
efficient production processes and wastewater treatment technologies. As a result, NSPS should
represent the most stringent controls attainable through the application of the best available
demonstrated control technology for all pollutants (i.e., conventional, nonconventional, and
priority pollutants). In establishing NSPS, EPA is directed to take into consideration the cost of
achieving the effluent reduction and any non-water-quality environmental impacts and energy
requirements.
1.2.5 Pretreatment Standards for Existing Sources (PSES) - CWA Section 307(b)
PSES are designed to prevent the discharge of pollutants that pass through,
interfere with, or are otherwise incompatible with the operation of POTWs, including sludge
disposal methods at POTWs. Pretreatment standards for existing sources are technology-based
and are analogous to BAT effluent limitations guidelines.
The General Pretreatment Regulations, which set forth the framework for
implementing national pretreatment standards, are found at 40 CFRPart 403.
1.2.6 Pretreatment Standards for New Sources (PSNS) - CWA Section 307(c)
Like PSES, PSNS are designed to prevent the discharges of pollutants that pass
through, interfere with, or are otherwise incompatible with the operation of POTWs. PSNS are
to be issued at the same time as NSPS. New indirect dischargers have the opportunity to
incorporate into their plants the best available demonstrated technologies. The Agency considers
the same factors in promulgating PSNS as it considers in promulgating NSPS.
1.3 Requirements Applicable to Effluent Guidelines Program Planning Efforts
Section 304(b) of the CWA requires EPA to review effluent guidelines for
existing direct dischargers each year and to revise such regulations as appropriate. Section
1-4
-------
Section 1 - Background
304(b) also specifies factors that EPA must consider when deciding whether revising an effluent
guideline is appropriate. See Section IV. A. of the December 31, 2003 Preliminary Effluent
Guidelines Program Plan FRN [FRL-7604-7]. Section 304(m) supplements the core requirement
of section 304(b) by requiring EPA to publish a plan every two years announcing its schedule for
performing this annual review and for revising any effluent guideline it selects for possible
revision as a result of that annual review. Section 304(m) also requires the plan to identify
categories of sources discharging nontrivial amounts of toxic or nonconventional pollutants for
which EPA has not published effluent limitations guidelines under section 304(b)(2) or NSPS
under section 306. See CWA section 304(m)(l)(B); S. Rep. No. 50, 99th Cong., 1st Sess. (1985);
WQA87 Leg. Hist. 31. Finally, under section 304(m), EPA must establish a schedule for
promulgating effluent guidelines for industrial categories for which it has not already established
such guidelines, with final action on such rulemaking required not later than three years after the
industrial category is identified in a final Effluent Guidelines Program Plan. See CWA section
304(m)(l)(C). EPA is required to publish its Effluent Guidelines Program Plan for public
comment prior to taking final action on the plan. See CWA section 304(m)(2).
In addition, CWA section 301(d) requires EPA to review the effluent limitations
required by CWA section 301(b)(2) every five years and to revise them if appropriate pursuant
to the procedures specified in that section. Section 301(b)(2), in turn, requires point sources to
achieve effluent limitations reflecting the application of BAT (for toxic pollutants and
nonconventional pollutants) and BCT (for conventional pollutants), as determined by EPA under
sections 304(b)(2) and 304(b)(4), respectively. For nearly three decades, EPA has implemented
sections 301 and 304 through the promulgation of effluent limitations guidelines. See E.I. du
Pont de Nemours & Co. v. Train, 430 U.S. 113 (1977). Consequently, as part of its annual
review of effluent limitations guidelines under section 304(b), EPA is also reviewing the effluent
limitations they contain, thereby fulfilling its obligations under section 301(d) and 304(b)
simultaneously.
1-5
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
SECTION 2 PUBLIC COMMENTS ON THE PRELIMINARY EFFLUENT GUIDELINES
PROGRAM PLAN FOR 2004/2005
EPA published its preliminary 2004/2005 Effluent Guidelines Program Plan on
December 31, 2003 (68 FR 75515-75531). Comments EPAreceived on this preliminary plan are
located in EPA Docket Number OW-2003-0074. This section provides background information
on the list of commenters to and issues raised on the Preliminary Effluent Guidelines Program
Plan.
The Agency received 59 comments from a variety of commenters including
industry and industry trade associations, municipalities and sewerage agencies, environmental
groups, other advocacy groups, two tribal governments, a private citizen, a federal agency, and a
state government agency. Stakeholders' suggestions played a significant role in the 2004 annual
review. Examples of industrial sectors identified by commenters include OCPSF, petroleum
refining, metal finishing, coastal oil and gas extraction, and coalbed methane extraction. Table
2-1 lists all commenters on the Preliminary Plan as well as a synopsis of the comments.
Table 2-1. Comments on Preliminary Effluent Guidelines Program Plan for 2004/2005
EPA Docket Number: OW-2003-0074
No.
Commenter Name
EPA
E-Docket
No.1
Comment Synopsis
Environmental Groups
1
2
3
4
Chesapeake Bay
Foundation
Natural Resources
Defense Council
Cook Inlet Keeper
Environmental
Advocates
0685
0733
0735
0706
Plan should focus on industries discharging excess nutrients,
including meats, paper, chemicals, and textiles. There is low-
cost technology available for control of Total N and Total P.
"(USEPA) to announce a schedule for revising inadequate
guidelines and promulgating new guidelines for industries not
already subject to technology standards."
"Keeper supports revision of the 1982 Effluent Guidelines for
petroleum refining, and including petroleum bulk stations and
terminals hi this revision."
"EGP as proposed violates CWA section 304(m)(l)2 and CWA
Section 301(d)3 in four key respects."
Municipalities and POTWs
5
Metropolitan Council
Environmental Services,
Minnesota
0670
Responds to EPA's request for information on Pretreatment
Program. Generally supports guidance rather than regs.
Industry information on Airport Deicing (strongly disappointed
that EPA did not regulate), Dental Clinics (supports guidance).
Groundwater Remediation (standards may be helpful). Drinking
Water (adequately covered). Food Sendee (seem to be
adequately covered), Stand-Alone Labs (adequately handled).
Industrial Laundries (time to regulate lias passed). Printing &
Publishing (regs would be burdensome).
2-1
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
6
7
8
9
10
11
12
13
14
Commenter Name
Clean Water Services,
Oregon
County Sanitation
Districts of Los Angeles
County, California
Narragansett Bay
Commission, Rhode
Island
Hampton Roads
Sanitation District,
Virginia
Metropolitan St. Louis
Sewer District. Missouri
City of Canby, Oregon
King County
Waste-water Treatment
Division, Washington
Metropolitan Sewer
District of Greater
Cincinnati, Ohio
City ofTroutdale,
Oregon
EPA
E-Docket
No.1
0681
0684
0692
0716
0480
0663
0704
0741
0441
Comment Synopsis
Requests mat EPA consider revising Metal Finishing since it
unnecessarily classifies iron phosphaters as Metal Finishers;
also believes "the regulation needlessly ignores an opportunity
to encourage certain pollution prevention practices associated
with some chemical conversion coating operations."
Supports risk analysis and encourages better use of 303d list.
Requests replacing production-based limits with concentration-
based limits. Provides data for OCPSF (dioxin and PACs not
detected; sodium nitrite use), CFPR (types of operations and
limits development). Petroleum Refining (PACs, dioxin,
vanadium), PBST (water sources). Provides effluent data for
several industries, pollutant sources, technologies. Supports
strategy, evaluation of risk, provision of permit-based support to
states. Provides information on implementation issues.
"The Narragansett Bay Commission (NBC) does not
recommend any revision to the two categories outlined in the
plan."
"HRSD continues to recommend that EPA focus more of its
attention on revising and updating the existing pretreatment
standards."
Provides comments/recommendations and information on CFPR
and PBST. Includes about 200 pages of attachments.
Requests that EPA consider revising Metal Finishing that
unnecessarily classifies iron phosphaters as Metal Finishers.
Excluding them might encourage some dischargers to consider
switching from a phosphating process that contains zinc or
manganese to one that contains iron, thus promoting a pollution
prevention alternative. Suggests that this revision also
encourage pollution prevention practices associated with some
chemical conversion coating operations.
The guidelines program should "be used as an opportunity to
introduce monitoring flexibility so as to reduce the monitoring
burden placed on POTWs."
"The District recommends that the USEPA evaluate the need for
an effluent limit guideline for the drum reconditioning and tote
recycling industry."
Recommends that the EPA draft an exemption for the iron
phosphate process from Metal Finishing. The ability to exempt
this industrial waste stream will save the City of Troutdale a
considerable amount of resources while not risking water
quality.
2-2
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
15
16
17
18
Commenter Name
CityofCorvallis,
Oregon
Hazel Dell Sewer
District (Clark County
Washington)
City of Gresham.
Oregon
Gulf Coast Waste
Disposal Authority
EPA
E-Docket
No.1
0664
0668
0679
0680
Comment Synopsis
Requests mat EPA consider revising Metal Finishing that
unnecessarily classifies iron phosphaters as Metal Finishers.
Excluding them might encourage some dischargers to consider
switching from a phosphating process that contains zinc or
manganese to one that contains iron, thus promoting a pollution
prevention alternative. Suggests that this revision also
encourage pollution prevention practices associated with some
chemical conversion coating operations.
Requests that EPA consider revising Metal Finishing since it
unnecessarily classifies iron phosphaters as Metal Finishers, a
process that contributes little or no metals to the waste stream.
Suggests excluding them, and asserts that the regulation
needlessly ignores an opportunity to encourage certain pollution
prevention practices associated with some chemical conversion
coating operations.
Requests that EPA consider revising Metal Finishing since it
unnecessarily classifies iron phosphaters as Metal Finishers;
also believes "the regulation needlessly ignores an opportunity
to encourage certain pollution prevention practices associated
with some chemical conversion coating operations."
Provides data showing no detectable PACs in refinery effluent
to POTW. and POTW removal efficiency of >99%. EPA
deviated from the draft Strategy in assessing industries and did
not address risk. Issues with stakeholder comments on OCPSF.
Federal Agencies
19
Department of Defense
0687
There is no need to create an additional regulation for Petroleum
Built Stations and Terminals.
Industry and Related Trade Associations
20
21
22
23
24
American Chemistry
Council
Chlorine Chemistry
Council
Vinyl Institute, Inc.
Dow Chemical
Company
DuPont
0697
0712
0731
0709
0737
"U.S. EPA's Preliminary Plan has prematurely identified target
industries without demonstrating a compelling reason to pursue
detailed study of these industries."
"The Organic Chemicals, Plastics, and Synthetic Fibers
(OCPSF) industrial category should not be identified for
possible effluent guidelines rulemakings."
"We agree that permit writing support to the States makes more
sense in this case than revising an effluent guideline for an
entire industry category."
"USEPA's (USEPA) effluent guidelines plan and screening
activities should be based on identified water quality impacts."
"DuPont encourages USEPA as it moves forward to involve the
regulated community in any further data gathering efforts for
specific industrial categories."
2-3
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
25
26
27
28
29
30
31
32
33
34
35
Commenter Name
General Electric
Company
National Paint and
Coatings Association
The Adhesive and
Sealant Council, Inc.
American Forest &
Paper Association
Buckeye
Rayonier
Treated Wood Council
(TWC)
Utility Water Act Group
American Petroleum
Institute
National Petrochemical
& Refiners Association
ConocoPMUips
EPA
E-Docket
No.1
0740
0683
0698
0715
0678
0690
0752
0726
0666,
0729,
0750
0747
0686
Comment Synopsis
"General Electric (GE) congratulates the Agency on its
regulatory improvement efforts."
Agrees that EPA's former studies of adhesives and sealants and
CFPR do not warrant ELG development. EPA gathered data
during development of the Miscellaneous Coatings
Manufacturing (MCM) MACT Standard that shows lack of
wastewater generation at adhesives and sealants plants.
"EPA cannot include these industries under the OCPSF category
since the processes, wastewater, pollution prevention and
treatment options are significantly different."
"American Forest & Paper Association supports USEPA's
(USEPA) decision not to review the effluent guidelines issued
for the Phase I mills."
Requests that EPA withdraw the 1993 proposed rules for
dissolving kraft pulp mills and strongly urges EPA to complete
the promulgation of revised Pulp Phase m rules for which
Buckeye provided data and support.
"The definition of bleach plant should include extraction stages
that precede the first application bleaching chemicals."
"The Treated Wood Council (TWC) does not agree with the
listing of Timber Products Processing, including Wood
Preserving, as a category in need of additional Investigation."
"UWAG strongly supports USEPA's (USEPA) preliminary
decision not to revise the steam electric effluent guidelines in
2004-2005."
Asserts that revising Petroleum Refining effluent guidelines
would be costly and time-consuming process for both the
industry and EPA. Asserts that there is no justification for
revising the ELG: no evidence of adverse effects from
discharges, and no new cost-effective treatment technologies.
"There would be little or no environmental benefit to be gained
by reopening this regulation for review."
"Development of effluent limitations guidelines and standards
fertile petroleum bulk storage terminal (PBST) category would
waste Agency and industry resources."
"USEPA has not demonstrated a need for revising the current
guidelines through this notice."
"ConocoPliillips recommends that USEPA utilize their four
factor analysis to assess and screen industries for guidelines
review utilizing monitoring data available from the States."
2-4
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
36
37
38
39
40
41
42
43
44
45
46
47
48
Commenter Name
Amerada Hess
ChevronTexaco
Petroleum Marketers
Association of America
Independent Liquid
Terminals Association
Independent Fuel
Terminal Operators
Association
New England Fuel
Institute
Alyeska Pipeline Sendee
Company
FCC Commercial
Furniture
Operations Management
International, Inc.
Pharmaceutical Research
and Manufacturers of
America
Porcelain Enamel
Institute
Edgewater Support
Services Inc.
National Stone, Sand &
Gravel Association
EPA
E-Docket
No.1
0693
0714
0689
0702
0708
0713
0719
0667
0408
0703
0718
0721
0688
Comment Synopsis
"Amerada Hess does not support the development of effluent
guidelines for petroleum bulk stations and terminals."
"USEPA's (USEPA) proposal leaves many individual sectors
without any effluent guidelines."
Comment focusing on the questions asked in the Federal
Register about discharge of wastewater from bulk plants.
"USEPA should not add petroleum bulk stations and terminals
(PBSTs) as a new subcategory of the Petroleum Refining
category."
"The Independent Fuel Terminal Operators Association strongly
recommends that USEPA refrain from initiating a rulemaking
for this subcategory of facilities" [Petroleum bulk stations and
terminals].
"EPA should not establish Effluent Guidelines for petroleum
bulk stations and terminals."
"Alyeska does not support USEPA developing effluent
limitations guidelines for terminals and bulk plants."
Urges EPA to revise Metal Finishing to exclude iron
phosphating from subject operations; suggests this exclusion
would encourage other sources to switch from zinc, nickel, or
manganese phosphating operations to iron phosphating,
resulting in environmental benefit. Argues that the Metal
Finishing regulation should be consistent with the MP&M
ELGs. Discharges to Roseburg Urban Sanitary Authority (see
0408).
Requests that the iron phosphate coating process be exempt
from Metal Finishing due to a lack of metals in the effluent
wastestream.
Urges "USEPA to revise the proposed plan by rescheduling its
evaluation effort to provide the time and resources required to
properly implement the draft strategy."
Comment refers to several general flaws in EPA's techniques
and data used to evaluate the Porcelain Enamel industry.
Comment focuses on "an industry sector currently not regulated
by effluent guidelines identified during outreach, in particular,
airport industrial discharges."
Existing effluent guidelines established by EPA for the
aggregates industry under 40 CFR Parts 436.20 and 436.30 are
adequate.
2-5
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
49
50
51
Commenter Name
Association of American
Railroads
Uniform & Textile
Service Association
Barnes & Thornburg
EPA
E-Docket
No.1
0696
0720
0723
Comment Synopsis
"A national effluent limitation guidelines regulation should be
initiated only if a significant number of impaired waters would
truly benefit."
"UTSA supports USEPA's (USEPA) current methodology that
considers industries that are 100% populated with indirect
discharges (facilities that discharge directly to the sanitary
sewer) as 'trivial'."
"USEPA's (USEPA) Effluent Guidelines Plan should be based
on sound science and collaborative efforts."
Other Advocacy Group
52
53
54
55
League of Women
Voters of Westchester,
NY
Prince William Sound
Regional Citizens'
Advisory Council
Virginia Association of
Wastewater Treatment
Agencies, Inc.
Association of
Metropolitan Sewerage
Agencies
0691
0669
0710
0700
"Opposition to the proposed guidelines which would lead to the
relaxation of current sewage treatment requirements under the
Clean Water Act."
Agrees with EPA's focus on OCPSF and Petroleum Refining,
including PBST (esp. terminals such as the Valdez Marine
Terminal (VMT)). Urges EPA to consider cross-media transfer
of pollutants from water to air (e.g.. via air stripping) driven by
tight water quality regulations. Recommends EPA include both
concentration-based AND mass-based limits, since
concentration-based limits alone may allow considerable
quantities of pollutants to be discharged at low concentrations in
very large volumes of effluents such as those at the VMT.
Notes that refineries in California have greatly reduced
pollutants entering the environment by using better technologies
for dissolved air floatation and biological rendering.
"The regulation overlooks an opportunity to encourage certain
pollution prevention practices associated with some chemical
conversion coating operations."
"Before USEPA considers updating or revising any specific
existing effluent guidelines it must update the 50 POTW Study."
Tribal Governments
56
57
Native Village or Port
Graham
Native Village of
Eklutna (Marc
Larnoreaux)
0738
0751
"Changes since permit issuance in 1999 warrant a new effluent
guidelines analysis for coastal oil and gas facilities and a zero
discharge decision by USEPA."
"Information on Cook Inlet historic ice cover, to see if
conditions have changed to allow barging of platform
discharges for disposal."
Private Citizen
58
Jett, George M.
0722
"A number of areas that need EAD attention."
2-6
-------
Section 2 - Public Comments on the Preliminary Effluent Guidelines Program Plan for 2004/2005
Table 2-1 (Continued)
No.
Commenter Name
EPA
E-Docket
No.1
Comment Synopsis
State Government
59
Arkansas DEQ (Gilliam,
Allen)
0705
"It's (it is) this state coordinator's view that small to medium
sized POTWs nationwide are not aware of the rulemaking
process, from plan to promulgation."
1 Use EPA's E-Docket's web site (http://epa.gov/edockets). the Docket Number (OW-2003-0074), and the document
number in this column to access these comments.
2-7
-------
Section 3 - Annual Review of Effluent Guidelines Promulgated Under Section 304(b)
SECTION 3 ANNUAL REVIEW OF EFFLUENT GUIDELINES PROMULGATED
UNDER SECTION 304(b)
CWA Section 304(b) requires EPA to conduct an annual review of promulgated
effluent guidelines. This section describes the results of the 2003 and 2004 reviews.
3.1 Results of 2003 Annual Review
As a result of its 2003 annual review, EPA identified two industrial categories for
detailed investigation in its 2004 annual review: Organic Chemicals, Plastics, and Synthetic
Fibers (OCPSF) (Part 414); and Petroleum Refining (Part 419). These categories are referred to
as Group I Industry Categories (see Section 5.2). In its review of the OCPSF effluent guidelines,
EPA identified a potential new subcategory for more detailed review: chemical formulating,
packaging, and repackaging (including adhesives and sealants) operations. EPA also identified a
potential new subcategory of the Petroleum Refining category: petroleum bulk stations and
terminals.
In addition, EPA identified potentially high risks or hazards associated with
discharges from two other industrial categories: Inorganic Chemicals (Part 415) and Nonferrous
Metals Manufacturing (Part 421). These categories are referred to as Group II Industry
Categories (see Section 5.3). Finally, EPA identified seven other industrial point source
categories with relatively high estimates of potential hazard or risk, referred to as Group III
Industry Categories (see Section 5.4). EPA's 2003 annual review, including stakeholder
comments received as of December 31, 2003, is discussed in the Preliminary Effluent Guidelines
Program Plan (FRN [FRL-7604-7]). EPA used the results of the 2003 annual review to inform
its 2004 annual review.
3.2 2004 Annual Review
The first component of EPA's 2004 annual review consisted of a screening-level
review of all promulgated effluent guidelines. As a starting point for this review, EPA examined
screening-level data from its 2003 annual review. EPA reexamined categories listed in the 2003
screening review where:
• Stakeholder comments identified existing effluent guidelines for revision;
or
• Additional information or data were available (e.g., from comments on the
Preliminary Plan, or contacts with facilities, industry representatives, etc.)
to revise pollutant discharge estimates.
EPA focused its 2004 screening-level review on analyzing any new data provided
by stakeholders to identify industrial categories whose pollutant discharges potentially pose the
greatest hazards or risks to human health and the environment because of their toxicity. EPA
5-1
-------
Section 3 - Annual Review of Effluent Guidelines Promulgated Under Section 304(b)
also considered efficiency and implementation issues raised by stakeholders and commenters on
the Preliminary Plan. By using this multi-layered screening approach, the Agency concentrated
its resources on those point source categories with the highest estimates of toxic-weighted
pollutant discharges (based on best available data), while assigning a lower priority to categories
that the Agency believes are not good candidates for effluent guidelines revision at this time.
EPA identified the Group I, II, and III in the 2003 annual review (see the
December 31, 2003 Preliminary Effluent Guidelines Program Plan, FRN [FRL-7604-7]).
Based on stakeholder comments, EPA included nine industries (Group IV) in the
2004 annual review (see Section 5.5). Group V industries consist of four industries where EPA
has promulgated new or revised effluent guidelines within the past seven years, but were still
identified by stakeholders as having discharges of concern (see Section 5.6). EPA evaluated
implementation and efficiency considerations and potential risks to human health and the
environment based on available discharge data from these Group IV and V industries.
Group VI industries (see Section 5.7) ranked low in terms of toxic discharges
and were not identified by stakeholders. EPA did not conduct any additional analysis with
respect to these Group VI industries in its 2004 annual review
5-2
-------
Section 4 - Data Sources and Limitations
SECTION 4 DATA SOURCES AND LIMITATIONS
This section describes data sources that EPA used in conducting its 2004 annual
review of all industrial categories and sectors . In addition, this section discusses some of the
limitations of these data sources. Industrial sector discussions (Sections 5-7) contain additional
information on data sources that are specific to an industry.
4.1 Industry Identification
During its annual review, EPA conducted a screening-level analysis and further
category review using readily available, facility-level data. To use these data to evaluate
category and industry pollutant discharges, EPA had to identify the industry to which each
facility belonged. This subsection discusses issues related to industry identification.
4.1.1 SIC Codes
The three main sources of information EPA used in the screening-level analysis
and further category review were the 1997 U.S. Economic Census, and two EPA databases, TRI
and PCS (discussed in detail in Sections 4.2.1 and 4.2.2). In each database and in the economic
census, information is organized by SIC code. The SIC system is the statistical classification
standard underlying all establishment-based federal economic statistics classified by industry (3).
Although it was developed by the Office of Management and Budget, the SIC system is used by
other government agencies, including EPA, to promote data comparability. In the SIC system,
each establishment is classified according to its primary economic activity, which is determined
by its principal product or group of products. An establishment may have activities in more than
one SIC code. Some data collection organizations assign one SIC code per establishment (e.g.,
the economic census). TRI allows reporting facilities to identify their primary SIC code and up
to five additional SIC codes. PCS includes one four-digit code, reflecting the principal activity
causing the discharge at each facility. For a given facility, the SIC code in PCS may differ from
the primary SIC code identified in TRI.
4.1.2 Relationship Between SIC Codes and Point Source Categories
EPA's effluent limitations guidelines and standards (ELGS) are developed for
specific categories of industrial dischargers. EPA has developed guidelines and standards for 56
point source categories. The categories, which may be divided into subcategories, are generally
defined in terms of combinations of products made and the processes used to make these
products. Regulations for an individual point source category may apply to one SIC code,
multiple SIC codes, or a portion of the facilities in an SIC code. Thus, to use databases that
identify facilities by SIC code, EPA linked each 4-digit SIC code to an appropriate point source
category. For facilities discharging significant amounts of toxic pollutants, EPA reviewed
readily available information to confirm that the appropriate point source category had been
identified for the facility (1,2).
4-1
-------
Section 4 - Data Sources and Limitations
There are some SIC codes for which EPA has not established national ELGS.
EPA's evaluation of industrial sectors not regulated by existing guidelines is presented in
Section 9 of this document and in the memorandum, Commenter -Identified Industrial Sectors
Not Meeting (304)(m)(l)(B) Criteria. During its screening-level review, EPA grouped SIC
codes into two-digit major industrial groups. For example, SIC code 8221 (colleges and
universities) and SIC code 8299 (schools and educational services) were combined as SIC Major
Group 82, educational services. See Evaluation of RSEIModel Runs (1) Attachment C and
Supplemental Figures and Tables for the 2004 Effluent Guidelines Program Plan Technical
Support Document for a table presenting the SIC/point source category crosswalk.
4.1.3 Economic Census
EPA used information from the 1997 U.S. Economic Census to estimate the total
number of facilities in each industrial category. EPA used 1997 data because they were the most
recent available at the time of this review. The economic census, conducted by the U.S.
Department of Commerce, is the systematic measurement of almost all national economic
activity in the United States. The 1997 Economic Census covered approximately 97 percent of
the Gross Domestic Product (GDP). This census asked questions about the number of
manufacturing establishments and the kind, quantity, and value of goods manufactured.
Although the census provides data on the number of establishments by SIC code, it does not
publish lists of facilities. New facilities might have started operation since the census was taken,
and facilities that were counted in the census might have been shut down or were no longer
operating by 2000. Nonproduction facilities such as sales offices, distribution warehouses, etc.,
are also counted as establishments in the census.
4.2 Pollutant Loadings Estimates
Section III of the December 31, 2003 Federal Register notice containing the
Preliminary Effluent Guidelines Program Plan FRN [FRL-7604-7] describes how EPA estimated
pollutant loadings for each industry in its screening-level analyses. The primary data sources for
these analyses are EPA's TRI and PCS databases.
4.2.1 Data from TRI
TRI is the common name for Section 313 of the Emergency Planning and
Community Right-to-Know Act (EPCRA). Each year, facilities that meet certain thresholds
must report their releases and other waste management activities for listed toxic chemicals. That
is, facilities must report the quantities of toxic chemicals recycled, collected and combusted for
energy recovery, treated for destruction, or disposed of. A separate report must be filed for each
chemical that exceeds the reporting threshold. The TRI list of chemicals for reporting year 2000
includes more than 600 chemicals and chemical categories. For this review, EPA used data for
reporting year 2000, because they were the most recent available at the time the review began.
4-2
-------
Section 4 - Data Sources and Limitations
A facility must meet the following three criteria to be required to submit a TRI
report for that reporting year:
(1) SIC Code Determination: Facilities in SIC codes 20 through 39, seven
additional SIC codes outside this range, and federal facilities are
potentially subject to TRI reporting. EPA generally relies on facility
claims regarding the SIC code identification. The primary SIC code
determines TRI reporting.
(2) Number of Employees: Facilities must have 10 or more full-time
employees or their equivalent. EPA defines a "full-time equivalent" as a
person that works 2,000 hours in the reporting year (there are several
exceptions and special circumstances that are well-defined in the TRI
reporting instructions).
(3) Activity Thresholds: If the facility is in a covered SIC code and has 10 or
more full-time employee equivalents, it must conduct an activity threshold
analysis for every chemical and chemical category on the current TRI list.
The facility must determine whether it manufactures, processes, OR
otherwise uses each chemical at or above the appropriate activity
threshold. Reporting thresholds are not based on the amount of release.
All TRI thresholds are based on mass, not concentration. Different
thresholds apply for persistent bioaccumulative toxic (PBT) chemicals
than for nonPBT chemicals.
In TRI, facilities report annual loads released to the environment of each toxic
chemical or chemical category that meets reporting requirements. They must report on-site
releases to air, receiving streams, disposal to land, underground wells, and several other
categories. They must also report the amount of toxic chemicals in wastes transferred to off-site
locations, including discharges to POTWs and other off-site locations, such as commercial waste
disposal facilities.
For this review, EPA focused on the amount of chemicals facilities reported either
discharging directly to a receiving stream or transferring to a POTW. For facilities discharging
directly to a stream, EPA took the annual loads directly from the reported TRI data for calendar
year 2000. For facilities that transfer toxic chemicals to POTWs, EPA first adjusted the TRI
pollutant loads reported to be transferred to POTWs to account for pollutant removal that occurs
at the POTW prior to discharge to the receiving stream. The Agency made this adjustment using
POTW removal efficiencies from EPA's Risk Screening Environmental Indicators (RSEI) model
(see Section 2.1.1 of the Water Docket for more information on TRI and the RSEI model).
Facilities reporting to TRI are not required to sample and analyze wastestreams to
determine the quantities of toxic chemicals released. They may estimate releases based on mass
-------
Section 4 - Data Sources and Limitations
balance calculations, published emission factors, site-specific emission factors, or other
approaches. Facilities are required to indicate, by a reporting code, the basis of their release
estimate. TRI's reporting guidance is that, for chemicals reasonably expected to be present but
measured below the detection limit, facilities should use one-half the detection limit to estimate
the mass released. The guidance is slightly different for dioxins and dioxin-like compounds in
that it allows nondetects to be treated as zero.
TRI allows facilities to report releases as specific numbers or as ranges, if
appropriate. Specific estimates are encouraged if data are available to ensure the accuracy;
however, EPA allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to
499 pounds, and 500 to 999 pounds. For this review, EPA used the mid-point of each reported
range to represent a facility's releases.
EPA weighted the direct and indirect pollutant releases to surface waters using
toxic weighting factors (TWFs) developed by Office of Water/Engineering and Analysis
Division (EAD), to calculate TWPE for each reported release. See 4.2.3 and 4.2.4 for more
discussion of TWFs and calculation of TWPE. EPA compiled data taken from TRI, the adjusted
releases from POTWs to surface waters, the calculated TWPE, and the relationship between SIC
codes and point source category into a Microsoft Access™ database named TRIReleases2000.
The Agency made some corrections to this database as it conducted further study on the TRI
data.
4.2.1.1 Utility of TRI
The data collected in TRI are particularly useful for the304(m) review process for
the following reasons:
• TRI is national in scope, including data from all 50 states and U.S.
territories;
• TRI includes releases to POTWs, not just direct discharges;
• TRI includes discharge data from manufacturing SIC codes and some
other industrial categories; and
• TRI includes releases of many toxic chemicals, not just those already
identified as problems and limited in facility discharge permits.
4.2.1.2 Limitations of TRI
For purposes of the 304(m) analyses, limitations of the data collected in TRI
include the following:
4-4
-------
Section 4 - Data Sources and Limitations
• Small establishments (less than 10 employees) are not required to report,
nor are facilities that don't meet the reporting thresholds. Thus, facilities
reporting to TRI may be a very small subset of an industry.
• Release reports are, in part, based on estimates, not measurements, and,
due to TRI guidance, may overstate releases, especially at facilities with
large waste water flows.
• Certain chemicals (PACs, dioxin and dioxin-like compounds, metal
compounds) are reported as a class, not as individual compounds.
Because the individual compounds in the class have widely varying toxic
effects, the potential toxicity of chemical releases can be inaccurately
estimated.
• Facilities are identified by SIC code, not point source category. For some
SIC codes, it may be difficult or impossible to identify the point source
category that is the source of the toxic wastewater releases.
Despite these limitations, EPA determined that the data summarized in
TRIReleases2000 were usable for an initial screening-level review and prioritization of the toxic-
weighted pollutant loadings discharged by industrial categories. EPA checked for and corrected
apparent errors in TRIReleases2000 (see Section 4.0 of reference (1)). However, the
TRIReleases2000 database developed from TRI is only one of the tools EPA used for its
screening-level review. In a second level of review, EPA further evaluated TRI data for
prioritized categories.
EPA received many comments relating to using information in TRI to estimate
pollutant loadings. These commenters noted additional limitations to the information in the TRI
database:
• In some instances, TRI information is based on estimates, not actual
monitored data.
• TRI encourages facilities to report some compounds as present at one-half
the detection level if a facility suspects that the compound has the
potential to be present, even if measured data show the compound is
below its detection level. As a result, many companies are conservative
and adopt this approach. For facilities with large flows, this can result in
large estimates of pounds or toxic pounds of pollutant released with no
data to support the compound was ever present.
• The list of chemicals covered by TRI is not all inclusive and changes over
time.
4-5
-------
Section 4 - Data Sources and Limitations
• Numerous sources of water pollutant discharges are not subject to TRI
reporting requirements.
• Many chemicals have high reporting thresholds, in which cases, a facility
is not required to report releases of these chemicals to TRI unless they
exceed a certain quantity.
• Information in TRI does not represent national estimates because all
facilities are not required to report to TRI.
EPA agrees that the issues raised by commenters are valid and identify data gaps
that may lead to overestimates or underestimates when using TRI information as a screening
tool. It should be noted that all estimates of toxic and nonconventional pollutant discharges
(e.g., TRI reported discharges) in this docket are based on reported data and are not scaled to a
national estimate.
4.2.2 Data from PCS
PCS is a computerized management information system maintained by EPA's
Office of Enforcement and Compliance Assurance (OECA). It was created to track permit,
compliance, and enforcement status of facilities regulated by the NPDES program under the
CWA.
More than 65,000 industrial facilities and water treatment plants have obtained
permits for water discharges of regulated pollutants. To provide an initial framework for setting
permit issuance priorities, EPA developed a major/minor classification system for industrial and
municipal wastewater discharges. Major discharges almost always have the capability to impact
receiving waters if not controlled and, therefore, have received more regulatory attention than
minor discharges. There are approximately 6,400 facilities (including sewerage systems) with
major discharges for which PCS has extensive records. Permitting authorities classify
discharges as major based on an assessment of six characteristics:
(1) Toxic pollutant potential;
(2) Discharge flow:stream flow ratio;
(3) Conventional pollutant loading;
(4) Public health impact;
(5) Water-quality factors; and
(6) Proximity to coastal waters.
Facilities with major discharges must report compliance with NPDES permit
limits via monthly Discharge Monitoring Reports (DMRs) submitted to the permitting authority.
The permitting authority enters the reported DMR data into PCS, including the type of violation
(if any), concentration and quantity values, and the Quarterly Non-Compliance Report (QNCR)
indicators. Minor discharges may, or may not, adversely impact receiving water if not
controlled.
4-6
-------
Section 4 - Data Sources and Limitations
Therefore, EPA does not require DMRs for facilities with minor discharges. For this reason, the
PCS database includes data only for a limited set of minor dischargers when the states choose to
include these data.
Parameters in PCS include water quality parameters (such as pH and
temperature), specific chemicals, bulk parameters (such as BOD5 and total suspended solids
(TSS)), and flow rates. Although other pollutants may be discharged, PCS contains only data for
the parameters identified in the facility's NPDES permit. Facilities typically report monthly
average pounds per day discharged, but also report daily maxima and pollutant concentrations.
For this review, EPA used data for reporting year 2000, to correspond to the data
obtained from TRI. EPA used its Effluent Data Statistics (EDS) system program to calculate
annual pollutant discharges using the monthly reports in PCS. Because units of measure vary
widely in PCS, EPA developed the EDS system to estimate mass loadings based on data stored
in PCS. The EDS system uses existing PCS reported mass loading values or multiplies reported
discharge flows and effluent concentrations to estimate loadings for each outfall (discharge
pipe), taking into account the various units of concentration and flow rates. Where
concentrations were reported as below detection limit (BDL), EPA assumed the parameter
concentration was equal to zero for parameters never detected by the facility in 2000. For
parameters sometimes detected and sometimes not, the "BDL" concentration was set equal to
half of the detection limit. The EDS system program sums the monthly loads to calculate annual
discharges, interpolating (using average reported loads) for months with missing reports.
EPA weighted the calculated annual pollutant discharges using EAD's TWFs to
calculate TWPE for each reported discharge, as it did for the reported TRI releases. See Sections
4.2.3 and 4.2.4 for more discussion of TWFs and calculation of TWPE. EPA compiled data
taken from PCS, the calculated TWPE, and the relationship between SIC codes and point source
category into a Microsoft Access™ database named PCSLoads2000. EPA made necessary
corrections to the data taken from PCS as it conducted further study.
4.2.2.1 Utility of PCS
The data collected in PCS are particularly useful for the 304(m) review process
for the following reasons:
• PCS is national in scope, including data from all 50 states and U.S.
territories;
• Discharge reports included in PCS are based on effluent chemical analysis
and metered flows;
• PCS includes facilities in all SIC codes; and
4-7
-------
Section 4 - Data Sources and Limitations
• PCS includes data on conventional pollutants for most facilities and for
the nutrients nitrogen and phosphorus for many facilities.
4.2.2.2 Limitations of PCS
Limitations of the data collected in PCS include the following:
• PCS includes only discharges of pollutants identified as problems and
currently limited in facility discharge permits;
• Some states do not submit all DMR data to PCS, or do not submit the data
in a timely fashion;
• PCS does not include discharge monitoring data from minor dischargers;
• PCS does not include data characterizing indirect discharges from
industrial facilities to POTWs;
• Many of the pollutant parameters included in PCS are not chemical
compounds (e.g., "total Kjedahl Nitrogen," "oil and grease") and cannot
have TWFs;
• In some cases, the PCS database identifies the type of wastewater being
discharged; however, most reported flow rates do not indicate the type of
wastewater and therefore, total flow rates reported to PCS may include
stormwater and noncontact cooling water, as well as process wastewater.
• Facilities are identified by SIC code, not point source category. For some
SIC codes, it may be difficult or impossible to identify the point source
category that is the source of the toxic wastewater releases.
Despite these limitations, EPA determined that the data summarized in
PCSLoads2000 were usable for an initial screening-level review and prioritization of the toxic-
weighted pollutant loadings discharged by industrial categories. EPA checked for and corrected
apparent errors in PCSLoads2000 (see Section 3.2 of reference (2)). However, the
PCSLoads2000 database is only one of the tools EPA used for its screening-level review. In a
second level of review, EPA further evaluated PCS data for prioritized categories.
As was the case with TRI, commenters noted additional limitations with the PCS
database. They include:
• PCS in not representative of all discharges.
4-8
-------
Section 4 - Data Sources and Limitations
• PCS data is entered into the database manually, which leads to data-entry
errors.
• Some facilities in PCS do not provide information on applicable SIC
codes.
• Facilities only provide SIC code information for the primary operations.
Therefore, data may represent other operations as well.
• Some states have not provided data to the PCS system.
EPA agrees that the issues raised by commenters are valid and represent data gaps
that may lead to overestimates or underestimates when using PCS information as a screening
tool. It should be noted that all estimates of toxic and nonconventional pollutant discharges (e.g.,
PCS reported discharges) in this docket are based on reported data and are not scaled to a
national estimate.
4.2.3 Toxic Weighting Factors
In the 30 years since Congress passed the 1972 Clean Water Act, EPA has
promulgated effluent guidelines that address 56 categories, and in the process has developed a
variety of tools and methodologies to evaluate effluent discharges. EAD maintains a Toxics Data
Base containing aquatic life and human health toxicity data, as well as physical/chemical
property data, for more than 1,900 pollutants compiled from over 100 references. The pollutants
in this database are identified by a unique Chemical Abstracts Service (CAS) number. TWFs
calculated from these data account for differences in toxicity among the pollutants of concern
and provide the means to compare mass loadings of different pollutants on the basis of their
toxic potential. For example, a mass loading of a pollutant in pounds per year (Ib/yr) may be
multiplied by a pollutant-specific weighting factor to derive a "toxic-equivalent" loading
(Ib-equivalent/yr).
TWFs are derived from chronic aquatic life criteria (or toxic effect levels) and
human health criteria (or toxic effect levels) established for the consumption offish. For
carcinogenic substances, EPA sets the human health risk level at 10"5 (i.e., protective to a level
allowing 1 in 100,000 excess lifetime cancer cases over background). In the TWF method for
assessing water-based effects, these toxicity levels of pollutants of concern are compared to a
benchmark value that represents the toxicity level of a specified pollutant. EPA selected copper,
a toxic metal commonly detected and removed from industrial effluent, as the benchmark
pollutant. EPA has used copper in previous TWF calculations for the cost-effectiveness analysis
of effluent guidelines. Although EPA revised the water quality criterion for copper in 1998 (to
9.0 micrograms per liter [|ig/L]), the TWF method uses the former criterion (5.6 |ig/L) to
facilitate comparisons with cost-effectiveness values calculated for other regulations. The
former criterion for copper (5.6 |ig/L) was reported in the 1980 Ambient Water Quality Criteria
for Copper document (U.S. EPA, 1980).
4-9
-------
Section 4 - Data Sources and Limitations
To calculate TWF values, EPA adds TWFs for aquatic life effects and for human
health effects for each pollutant of concern. EPA uses chronic effects on aquatic life and human
health effects from ingesting contaminated organisms (HHOO) as the basis for TWFs. The TWF
is calculated by dividing aquatic life and human health criteria (or toxic effect levels) for each
pollutant, expressed as a concentration in micrograms per liter (|ig/L), into the former copper
criterion of 5.6 |ig/L:
5.6
AQ HHOO
where:
TWF = toxic weighting factor
AQ = chronic aquatic life value (|ig/L)
HHOO = human health (ingesting organisms only) value (|ig/L)
For more details on how EAD determines TWFs, see Revisions to EAD's Toxic Weighting
Factor Methodology Parameters, OW-2003-0074-0372.
The TRI reportable chemicals list includes 612 chemicals and compound
categories; however, reported direct or indirect discharges to surface water in the 2000 TRI
database included a total of 329 TRI chemicals and compound categories. EPA has not
developed EAD TWFs for 56 of these chemicals, resulting in a calculated toxicity-weighted
discharge of zero for these compounds. Large amounts of two chemical compounds without
TWFs, coal tar creosote and nitrite-nitrogen, were reported discharged. The lack of TWFs for
these chemicals results in an underestimate of the toxicity-weighted releases from some
categories.
4.2.4 Calculation of TWPE
EPA weighted the annual pollutant discharges calculated by TRIReleases2000
and PCSLoads2000 using EAD's TWFs to calculate TWPE for each reported discharge. EPA
summed the estimated TWPE discharged by each facility in a point source category to
understand the potential hazard of the discharges from each category. The following subsections
discuss the calculation of TWPE.
4.2.4.1 Methodology and Assumptions Used to Calculate TWPE
Because certain chemicals may have more than one name, chemicals in EPA's
TWF database are identified by CAS number. The first step in calculating the TWPE was to
associate EPA's TWF with the reported pollutant. EPA identified CAS numbers for chemicals
reported in PCS by making the following assumptions:
4-10
-------
Section 4 - Data Sources and Limitations
• All forms of the chemical were assigned the same CAS number (e.g.,
nitrogen-organic, nitrogen-inorganic, and nitrogen-total were all assigned
the CAS number for nitrogen); and
• Chemicals that were reported in different ways were assigned only one
CAS number (e.g., nitrate (as NO3) and nitrate (as N) were both assigned
the CAS number for nitrate).
EPA estimated TWFs for some parameters reported in PCS. For example, the
Agency calculated TWF for the parameter "aldrin plus diedrin" by averaging the TWF for the
two individual compounds. EPA did not assign TWFs to all parameters reported in PCS,
primarily because EPA did not identify CAS numbers for chemicals infrequently reported. In
addition, there are no CAS numbers for bulk parameters (such as BOD5) reported in PCS that are
not specific chemical compounds.
Most pollutants reported to TRI are individual chemicals identified by a CAS
number. However, in addition to individual chemicals, the TRI reportable chemicals list
includes 30 compound categories. EPA identified representative chemicals to use to calculate
the TWPE of the compound category. For example, EPA used the TWF for a parent metal for
the metal compound category (e.g., the TWF for lead was used for lead compounds). See Table
B-l in the report Evaluation of RSEI Model Runs (1), for a complete list of TWFs used to
represent TRI chemical compound categories.
Two compound categories are particularly important, due to their relatively high
TWFs. These categories are polycyclic aromatic compounds (PACs) and dioxin and dioxin-like
compounds. For the screening-level analysis, EPA assumed that all mass-reported as PACs was
benzo(a)pyrene and used the TWF for benzo(a)pyrene to calculate the TWPE of reported PACs.
This assumption was later modified for some categories, as discussed further in 4.2.4.3. For
dioxin and dioxin-like compounds, a category comprising 17 dioxin congeners, EPA used the
TWF for 1,2,3,6,7,8 -hexachlorodibenzofuran to calculate the TWPE of reported dioxins for the
screening-level analysis. EPA chose this TWF because it is the median of the TWFs for the!7
dioxin congeners. EPA later modified this assumption for some categories, as discussed in
4.2.4.2. As a result of the assumptions used, PACs and dioxin and dioxin-like compounds,
which represent less than 0.005 percent of the TRI-reported pounds discharged to water,
accounted for approximately 93 percent of the total estimated TWPE for TRI releases calculated
during EPA's screening-level analysis.
4.2.4.2 Dioxins and Dioxin-Like Compounds
The term 'dioxins' refers to poly chlorinated dibenzo-p-dioxins (CDDs) and
poly chlorinated dibenzofurans (CDFs), which constitute a group of PBT chemicals. There are
17 CDDs and CDFs congeners with chlorine substitution of hydrogen atoms at the 2, 3, 7, and 8
positions on the benzene rings, the most toxic of which is 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD). Table 4-1 lists these compounds, their chemical name, and common abbreviated name.
4-11
-------
Section 4 - Data Sources and Limitations
The 17 compounds (called congeners) are referred to as 'dioxin-like,' because they have similar
chemical structure, similar physical-chemical properties, and invoke a common battery of toxic
responses (4), though the toxicity of the congeners varies greatly. In this report, EPA uses the
term "dioxins" to refer to all 17 of the 2,3,7,8-substituted CDDs and CDFs.
Dioxins are associated with a range of adverse human health effects, including
cancer. EPA's human health-based water quality criterion (water + organism) for the most toxic
dioxin isomer, 2,3,7,8-tetrachlorodibenzo-p-dioxin (dioxin), is 0.005 pg/L (5xlO"9 ug/L) (6).
EPA has recommended that this water quality criterion be used in conjunction
with the 1998 World Health Organization (WHO) toxicity equivalency factors to account for the
toxic effects of other dioxin-like compounds. The TEF for 2,3,7,8-tetrachlorodibenzofuran
(furan) is 0.1; thus the calculated water quality criterion for furan is 0.05 pg/L.
Dioxins have very low water solubility, and most dioxins discharged to surface
waters will adhere to sediments and suspended silts. Dioxins are long-lasting substances that can
build up in the food chain to levels that are harmful to human and ecosystem health. Because of
their persistence and bioaccumulative properties, they do not break down easily in wastewater
treatment systems or in the environment and thus present long-term risks to human health,
aquatic life, and wildlife.
EPA's analytical method for dioxins and furans (Method 1613B) establishes the
minimum concentration at which these compounds can be reliably quantified. The minimum
level (ML) for 2,3,7,8-TCDD and 2,3,7,8-TCDF is 10 pg/L, 2,000 times higher than the water
quality criterion for TCDD and 2,000 times higher then the calculated criterion for TCDF. Thus,
even if the amount of TCDD or TCDF in a facility's effluent is below 10 pg/L (e.g., below
detection limits), measured at the final effluent, the discharge could still result in pollutant
loadings that are far greater than the quantities the water quality criterion deems acceptable to
the environment.
Due to their toxicity and ability to bioaccumulate, the various congeners of dioxin
have high toxic weighting factors (TWFs). Consequently, even small mass amounts of dioxin
discharges translate into high toxic weighted pounds equivalents (TWPEs).
Toxic Equivalency Factors (TEFs) are used to simplify risk assessment and
regulatory control of exposures to dioxins and still account for the relative toxicities of the 17
compounds. As defined by Van den Berg, et al., (6), a TEF is a relative potency value that is
based on the results of several in vivo and in vitro studies. TEFs are order of magnitude
estimates of the toxicity of a compound relative to 2,3,7,8-TCDD. TEFs along with the
measured concentration of dioxin congeners are used to calculate toxic equivalent (TEQ)
concentrations. Table 4-1 lists the TEFs for the 17 dioxin and dioxin-like compounds.
4-12
-------
Section 4 - Data Sources and Limitations
Table 4-1. Dioxins and Their Toxic Equivalency Factors
CAS
Number
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
CDDs
2,3,7.8-tetrachlorodibenzo-p-dioxin
1,2,3.7.8-pentachlorodibenzo-p-dioxin
1,2,3.4.7,8-hexachlorodibenzo-p-dioxin
1,2,3.6,7,8-hexachlorodibenzo-p-dioxin
1,2,3.7,8,9-hexachlorodibenzo-p-dioxin
1,2, 3.4,6, 7,8-heptachlorodibenzo-p-dioxin
1,2, 3.4,6, 7,8, 9-octachlorodibenzo-p-dioxin
CDFs
2,3 ,7,8-tetrachlorodibenzofuran
1 ,2,3 ,7,8-pentachlorodibenzofuran
2,3,4 J,8-pentachlorodibenzofuran
1,2,3,4,7,8-hexachlorodibenzofuran
1,2,3,6,7,8-hexachlorodibenzofuran
1,2,3,7,8,9-hexaclilorodibenzofuran
2,3,4,6,7,8-hexachlorodibenzofuran
1,2,3,4,6,7,8-heptaclilorodibeiizofuran
1,2,3,4,7,8,9-heptaclilorodibeiizofuran
1,2, 3,4,6, 7,8, 9-octacMorodibenzofuran
Abbreviated Name
2.3.7,8-TCDD
1.2.3,7.8-PeCDD
1.2.3,4.7.8-HxCDD
1.2,3,6.7.8-HxCDD
1.2,3,7.8.9-HxCDD
1.2,3,4.6.7,8-HpCDD
1.2,3,4.6J,8.9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4.7.8-HxCDF
1,2,3,6.7.8-HxCDF
1,2,3,7.8.9-HxCDF
2,3,4,6.7.8-HxCDF
1,2,3,4.6.7,8-HpCDF
1,2,3,4.7.8,9-HpCDF
1,2,3,4.6,7,8,9-OCDF
Toxic Equivalency
FactoiJ
1
1
0.1
0.1
0.1
0.01
0.0001
0.1
0.05
0.5
0.1
0.1
0.1
0.1
0.01
0.01
0.0001
From reference (6).
Beginning with reporting year 2000, facilities meeting certain reporting criteria
were required to report to TRI the total mass of the 17 dioxin and dioxin-like compounds
released to the environment every year. The combined mass of the 17 compounds is referred to
as TM-17. This reporting method does not account for the relative toxicities of the 17
compounds. However, reporting facilities are given the opportunity to report a facility-specific
congener distribution. Yet even if dioxins are released to more than one medium, the facility can
report only one distribution. The single dioxin congener distribution reported by a facility may
not accurately reflect the distribution in each medium in which dioxins are released.
EPA has developed TWFs for each of the 17 dioxin congeners, ranging from
421,600,000 for 2,3,7,8-TCDD to 67,367 for OCDF (8). Table 4-2 presents the TWFs used in
the screening-level analysis.
4-1:
-------
Section 4 - Data Sources and Limitations
Table 4-2. Dioxins and Their Toxic Weighting Factors
CAS
Number
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
CDDs
2,3,7,8-tetrachlorodibenzo-p-dioxin
1,2,3,7,8-pentachlorodibenzo-p-dioxin
1,2,3,4.7.8-hexachlorodibenzo-p-dioxin
1,2,3,6.7.8-hexachlorodibenzo-p-dioxin
1,2,3.7.8,9-hexachlorodibenzo-p-dioxin
1,2,3.4.6,7. 8-heptachlorodibenzo-p-dioxin
l,2,3.4.6,7.8.9-octachlorodibenzo-p-dioxin
CDFs
2,3,7,8-tetrachlorodibenzofuran
1,2,3,7,8-pentachlorodibenzofuran
2,3,4,7,8-pentachlorodibenzofuran
1,2,3,4,7,8-hexachlorodibenzofuran
1,2,3,6,7,8-hexachlorodibenzofuran
1,2,3,7,8,9-hexachlorodibenzofuran
2,3,4,6,7,8-hexacUorodibenzofuran
1,2, 3,4,6, 7,8-heptachlorodibenzofuran
1,2,3,4,7,8,9-heptacUorodibenzofuran
1,2,3,4,6,7,8,9-octachlorodiberizofuran
Abbreviated Name
2,3,7,8-TCDD
1,2,3.7,8-PeCDD
1,2.3.4,7,8-HxCDD
1,2.3.6,7,8-HxCDD
1.2.3,7.8.9-HxCDD
1.2.3,4.6.7,8-HpCDD
1.2.3,4.6.7,8.9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3.4,7,8-HxCDF
1,2,3.6,7,8-HxCDF
1,2,3.7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
Toxic Weighting
Factor1
421,600,000
215,384.615
43.076.923
41.791.045
43.076.923
4.179.104
423.510
6,696,140
3,294,118
32,941,176
6,658.740
6,666,667
6,666,667
6,658,740
665,874
666,667
67,367
'From reference (8).
EPA completed the revision of TWFs for dioxin and its congeners as described in
a August 2004 memorandum. These revisions and the resulting TWFs are presented in (8).
The revised TWFs were used to recalculate the toxicity-weighted dioxin discharges for two
categories for which EPA conducted detailed reviews. The recalculated toxic weighted pound
equivalents (TWPE) for these two categories, Organic Chemicals, Plastics, and Synthetic Fibers
(OCPSF, including chlor-alkali chlorine manufacture) and Petroleum Refining, are also
presented in (8).
As noted in 4.2.4.1, because facilities do not report the mass of individual dioxin
congeners released to TRI, EPA did not use the congener-specific TWFs to calculate dioxin
TWPE during its screening-level analysis of TRI data. Instead, EPA used the TWF for
1,2,3,6,7,8-HxCDF because its TWF (6,666,667) is the median of the TWFs for thelV dioxin
congeners.
4-14
-------
Section 4 - Data Sources and Limitations
Facilities with NPDES permit requirements to monitor for dioxin are typically
required to monitor and report 2,3,7,8-TCDD discharges. When the specific congener was
identified in PCS, EPA used the TWF for the congener. In some cases, facilities used TEFs and
reported their dioxin discharges as TEQs. EPA used the TWF for 2,3,7,8-TCDD to calculate the
TWPE of dioxin discharges reported as TEQ (TCDD-equivalent).
EPA used a different approach to calculate TWPE during its further review of
prioritized categories where dioxin was released. These categories include OCPSF, Inorganic
Chemicals, Petroleum Refining, Timber Products Processing, and Pulp, Paper, and Paperboard,
Phase II. In its further review of these categories, EPA calculated dioxin TWPE using the TRI-
reported congener distribution to estimate the mass of each congener in the facility's reported
releases to surface waters or transfers to POTWs. If a facility did not report a congener
distribution, EPA used an industry-average distribution to calculate the mass of each congener
released. After estimating the mass of each dioxin congener released by each dioxin-reporting
facility, EPA calculated dioxin TWPE by multiplying the estimated mass of each congener by its
TWF.
4.2.4.3
Polvcvclic Aromatic Compounds (PACs)
PACs, sometimes known as polycyclic aromatic hydrocarbons (PAHs), are a class
of organic compounds consisting of two or more fused aromatic rings. Table 4-3 lists the 21
individual compounds in the PAC category for TRI reporting, Chemical Abstract Service (CAS)
number, and BAD TWF. BAD has TWFs for only eight of the 21 PACs.
Table 4-3. Definition of Polycyclic Aromatic Compounds
PAC Compound
Benzo(a)anthracene
Benzo(a)phenantlirene (chrysene)
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Beiizo(j,k)fluorene (fluoraiithene)
Benzo(r,s,t)pentaphene
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenzo(a,h)aiithracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
CAS Number
56-55-3
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
226-36-8
224-42-0
53-70-3
5385-75-1
192-65-4
Toxic Weighting
Factor
180.9752
2.1038
4283.5600
421.3560
42.1356
0.8030
1693.0160
Priority Pollutant?
/
/
/
/
/
/
/
4-15
-------
Section 4 - Data Sources and Limitations
Table 4-3 (Continued)
PAC Compound
Dibenzo(a.h)pyrene
Dibenzo(a.l)pyrene
7H-Dibenzo(e,g)carbazole
7, 12-Dimethylbenz(a)anthracene
Indeno( 1 ,2,3 -cd)pyrene
3 -Metliy Icholantlirene
5-Methylclirysene
1-Nitropyrene
CAS Number
189-64-0
191-30-0
194-59-2
57-97-6
193-39-5
56-49-5
3697-24-3
5522-43-0
Toxic Weighting
Factor
1.1388
Priority Pollutant?
/
PACs are classified as PBT pollutants. They are likely present in petroleum
products such as crude oil, fuel oil, diesel fuel, gasoline, and paving asphalt (bituminous
concrete) and refining by-products such as heavy oils, crude tars, and other residues. PAHs form
as the result of incomplete combustion of organic compounds. PACs and closely related
compounds are major constituents of creosote, a commonly used wood preservative.
For TRI, facilities must report the combined mass of PACs released; they do not
report releases of individual compounds. In the screening-level review of the 2000 TRI
database, EPA assumed that benzo(a)pyrene was the only PAC discharged. Thus, EPA used the
TWF for benzo(a)pyrene (4,283) to estimate the TWPE of PACs. Because the TWF for
benzo(a)pyrene is higher than any other PAC, this represents a worst-case scenario.
EPA used a different approach to calculate TWPE during its further review of the
Petroleum Refining and Timber Products Processing Categories. For refineries, EPA developed
a refinery-specific TWF for PACs, based on the concentration of individual PACs in petroleum
products and the relative amount of each product processed by the refining industry. The
calculated petroleum refinery PAC TWF equals 230.43. See Memorandum: Toxic Weighting
Factor for Petroleum Re fining Poly cyclic Aromatic Compounds, 12/11/2003, DCN 00646 for
further details.
EPA assumed that composition of PACs released by timber product facilities is
proportional to the PACs composition of creosote. EPA weighted the TWFs for the individual
PACs present in creosote by the percentage of total PACs in creosote represented by each
compound to calculate a creosote PAC TWF of 65.78.
4-16
-------
Section 4 - Data Sources and Limitations
4.3 Impaired Waters Analysis
Under section 303(d)(l) of the CWA, states, territories, and authorized tribes
must identify water bodies for which technology-based controls required by the Act are not
sufficient to implement applicable water quality standards (i.e., are impaired), and prioritize such
water bodies for TMDL establishment. To incorporate the Agency's goal of reducing the
number of impaired water bodies into effluent guidelines planning, EPA attempted to quantify
the number of facilities in an industrial point source category that discharge the same pollutant
(or class of pollutants) that is causing the impairment of the receiving water body. The CWA
requires states to identify waters not meeting water quality standards to develop Total Maximum
Daily Loads (TMDLs) for those waters (section 303(d) of the CWA). A TMDL is designed to
restore the health of the polluted water body by specifying the amount of pollutants that may be
present in the water and still have the water body meet water-quality standards. More than
20,000 water bodies across America have been identified as impaired. These waters include
more than 300,000 river and shoreline miles and five million acres of lakes. EPA estimates that
more than 40,000 TMDLs must be established. The CWA established both TMDLs and effluent
guidelines as complementary regulatory programs, as both are necessary for restoring the quality
of the Nation's waters and for striving towards the national goal of eliminating the discharge of
all pollutants.
PCS facilities were matched to water bodies identified by states, under CWA
Section 303(d), as impaired waters if at least one PCS pollutant limit matched at least one of the
reasons for impairment. For example, if a PCS facility has a discharge limit for mercury
and it is located in a water body that is impaired for mercury, then they were matched.
The current impairment analyses only identify spatial relationships between point source
dischargers and impaired water bodies, and do not suggest the actual correclations/causal
relationships between them. EPA will need to conduct more analyses before determining
whether there is any actual causal relationship between industrial point sources and impaired
waters.
Other limitations to the data presented in impaired waters analysis include:
• Under-counting of Facilities Because of Missing SICs: 26 percent of
PCS facilities (45,000 of 168,517) are excluded from the impaired waters
analysis because they do not have SIC codes in PCS.
• Under-estimating of Facility Loads: A potential next step in the
impaired waters analysis would be to determine discharge loads for PCS
facilities matched to impaired waters. However, both concentration and
discharge flow information are necessary to calculate load estimates for
PCS facilities. Consequently, EPA has calculated load estimates primarily
for majors because most minors do not have flow information in PCS.
4-17
-------
Section 4 - Data Sources and Limitations
Under-counting of Facilities Because They Are Not Indexed to
Reaches1: 77 percent of PCS facilities are excluded from the impaired
waters analysis because they have not been indexed to reaches, including
5 percent of majors (340 of 6,833) and 80 percent of minors (129,350 of
161,684). Twenty-three percent (74, 480) of PCS facilities have been
indexed to the National Hydrography Dataset (NHD) reaches. There are a
total of 22,347 impaired waters of which 19,674 have been indexed to the
NHD, which consists of some 3 million reaches.
Nationally, 9,741 indexed PCS facilities (1,928 majors and 7,813 minors)
have been matched to 3,493 impaired waters. EPA used PCS limits to
match major facilities to impaired waters. The Agency used Typical
Pollutant Concentrations (TPCs) (average pollutant discharge
concentrations by SIC) to match minors to impaired waters, because
minors have little or no limit information in PCS.
Over-counting of Facilities When Matches Are Based on Typical
Pollutant Concentration (TPCs): Facilities might discharge pollutants
for which there are no limits in their permits.
Under-counting of Facilities When Matches Are Based on PCS
Limits: Facilities might discharge pollutants for which there are no limits
in their permits.
Limitations in the Locational Data Quality: 69 percent of the outfalls
in the PCS database had location data considered to be of low quality. For
many facilities, particularly minors, facility locations are used as a
surrogate for the outfall location.
NHD data are not available for Alaska, Hawaii, Puerto Rico, and the U.S.
Virgin Islands.
States report only 303(d) impairments for assessed water bodies and most
water bodies are unassessed.
SIC codes are not precise, facilities self-identify their SIC codes, and a
single facility may have multiple industrial operations at a single site.
'A reach is a linear or longitudinal section of a stream or river (or other water body) defined by the upstream and
downstream locations of lower stream order tributaries flowing into a higher stream.
4-18
-------
Section 4 - Data Sources and Limitations
4.3.1 Data Gaps and Limitations in Estimating Impairment Analysis
EPA's effort to match facility discharges to impaired waters was limited by data
gaps in industry monitoring/reporting of discharges and in the ambient monitoring used by states
to develop their lists of impaired waters. Further, when EPA did match a facility discharge to an
impaired water body, the Agency could not determine whether the discharge is an insignificant
or significant contributor to the water quality problem. EPA is exploring ways to expand its
impairments analyses in future annual review cycles (see DCN 557, Section 2.1.3).
4.4 Nutrients Analysis
Nutrients entering surface waters can cause many problems for stream health and
aquatic life. Excess nutrients can lead to eutrophication resulting in algal blooms, depleted
oxygen levels, fish kills, and reduced biodiversity. EPA examined the potential water quality
impacts of nutrient discharges from petroleum refining and OCPSF facilities to surface waters.
This analysis used EPA's recommended Section 304(a) ecoregional nutrient criteria and decay
coefficients in conjunction with a screening-level stream dilution model. For more information
regarding this analysis, see Section 8 of this document.
Data limitations and gaps used in this approach include using the 14 nutrient
ecoregions instead of the 84 Level III subecoregions. Due to lack of precise geographical data
for the facility location outfalls, EPA used the nutrient criteria for the aggregate ecoregions for
the analysis. However, nutrient ecoregions are aggregations of Level III subecoregions where
the characteristics affecting nutrient levels are expected to be similar.
In performing the in-stream analysis using the screening-level simple dilution
model, EPA assumed the following:
• Background concentrations of each pollutant in the receiving stream are
equal to zero; therefore, the analysis evaluates only the impacts of
discharging facilities.
• EPA used an exposure duration of 365 days to determine the likelihood of
actual excursions of human health criteria or toxic effect levels.
• Each facility obtains the intake process water from a source other than the
receiving stream.
• The pollutant load to the receiving stream is continuous and represents
long-term facility operations. These assumptions may overestimate risks
to human health and aquatic life, but may underestimate potential short-
term effects.
4-19
-------
Section 4 - Data Sources and Limitations
• EPA used 1Q10 and 7Q10 receiving stream flow rates to estimate aquatic
life impacts; harmonic mean flow rates are used to estimate human health
impacts. EPA estimated 1Q10 low flows using the results of a regression
analysis of 1Q10 and 7Q10 flows from representative U.S. rivers and
stream (Versar, 1992). The Agency estimated harmonic mean flows from
the mean and 7Q10 flows as recommended in the Technical Support
Document for Water Quality-based Toxics Control (EPA, 1991). These
flows may not be the same as those used by specific states to assess
impacts.
• In performing the analysis, EPA did not consider all pollutant fate
processes such as volatilization and hydrolysis. This omission may result
in estimated in-stream concentrations that are environmentally
conservative (higher).
4.5 References
1. Eastern Research Group, Inc. Evaluation of RSEI Model Runs. Prepared for U.S.
EPA, Engineering and Analysis Division. December 12, 2003. Docket Section
2.1.1,DCN 00618.
2. Eastern Research Group, Inc. Development of PCSLoads2000. Prepared for U.S.
EPA, Engineering and Analysis Division. December 12, 2003. Docket Section
2.1.2, DCN 00620.
3. Office of Management and Budget. Standard Industrial Classification Manual.
1987.
4. U.S. EPA. EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within
the Dioxins andDioxin-Like Compounds Category. EPA-745-B-00-021.
Washington, D.C. December 2000.
5. U.S. EPA. Technical Support Document for Water Quality-Based Toxics
Control EPA-505/2-90-001,PB91-127415. Washington, D.C. 1991.
6. Van den Berg, et al. "Toxic Equivalency Factors (TEFs) for PCBs, PCDDs,
PCDFs, for Humans and Wildlife." Environ. Health Perspect. 106:775-792.
1998.
7. Versar, Inc. Upgrade of Flow Statistics Used to Estimate Surface Water
Chemical Concentrations for Aquatic and Human Exposure Assessment.
Prepared for the U.S. EPA. 1992.
4-20
-------
Section 4 - Data Sources and Limitations
Zipf, Lynn. Memorandum to 304(m) Docket, Revisions to TWFsfor Dioxin and
Its Congeners and Recalculated TWPEsfor OCPSF and Petroleum Refining.
August 10, 2004.
4-21
-------
Section 5 - Existing Industry Review
SECTION 5 EXISTING INDUSTRY REVIEW
Section 3 describes EPA's 2003 and 2004 annual reviews of industries with
existing effluent guidelines. This section discusses the review of each industrial category.
5.1 Organization of this Section
As explained in Section 3, EPA prioritized its 2003 and 2004 review of industries
with existing effluent guidelines based on the results of a screening-level analysis. Following
this screening-level analysis, EPA placed each industrial category into one of six groups. EPA
constructed these groups by considering the discharge estimates of toxic and nonconventional
pollution (i.e., Factor 1 analyses). EPA also considered the results of the limited Factor 2 and 3
analyses and the extensive Factor 4 analysis. Additionally, EPA had significant questions about
information and data gaps for some industrial categories (e.g., why did Timber Products
Processing (Part 429) rank second in TRI and 29th in PCS in terms of TWPE discharged). These
groupings reflect EPA's assessment of the strength of the data and information used to estimate
the discharges of toxic and nonconventional pollution. Consequently, the groups are not strictly
based on the exact rank order of toxic and nonconventional pollution discharges. Rather, EPA
used its best professional judgment to sort industrial categories into the different groups based on
all quantitative and qualitative information collected, compiled, and analyzed. These groups are:
• Group I: Industries that ranked high in the screening-level analysis and for
which EPA conducted a detailed study;
• Group II: Industries that ranked high in the screening-level analysis for
which EPA has data gaps; the Agency may conduct detailed study in
subsequent annual reviews;
• Group III: Industries that ranked high in the screening-level analysis for
which EPA has significant data gaps or inconsistencies;
• Group IV: Industries that ranked low in the screening-level analysis but
were identified by stakeholders in outreach efforts;
• Group V: Industries for which EPA has recently reviewed and
promulgated new effluent limitations guidelines and standards (ELGS);
and
• Group VI: Industries that ranked low in the screening-level analysis and
not identified in stakeholder outreach.
Table 5-1 lists the industries currently subject to effluent guidelines and their
groups.
5-1
-------
Section 5 - Existing Industry Review
Table 5-1. Industries Covered by National Clean Water Industrial Regulations
Industrial Category
Dairy products processing
Grain mills manufacturing
Fruits and vegetable processing
Canned and preserved seafood
Sugar processing
Textile mills
Cement manufacturing
Concentrated animal feeding operations (feedlots)
Electroplating
Organic chemicals, plastics and synthetic fibers
Inorganic chemicals manufacturing
Soaps and detergents manufacturing
Fertilizer manufacturing
Petroleum refining
Iron and steel manufacturing
Nonferrous metals manufacturing
Phosphate manufacturing
Steam electric power generation
Ferroalloy manufacturing
Leather tanning and finishing
Glass manufacturing
Asbestos manufacturing
Rubber manufacturing
Timber products processing
Pulp, paper and paperboard
Meat products
Metal finishing
Coal mining
Oil and gas extraction
Mineral mining and processing
Centralized waste treatment
40CFRPart
405
406
407
408
409
410
411
412
413
414
415
417
418
419
420
421
422
423
424
425
426
427
428
429
430
432
433
434
435
436
437
Group
IV
VI
rv
IV
VI
in
VI
V
V
I
n
VI
in
i
V
n
in
in
VI
VI
VI
VI
VI
m
m,v
V
V
IV, V
IV. V
IV
V
5-2
-------
Section 5 - Existing Industry Review
Table 5-1 (Continued)
Industrial Category
Metal products and machinery
Pharmaceutical manufacturing
Ore mining and dressing
Industrial laundries
Transportation equipment cleaning
Paving and roofing materials
Waste combustors
Landfills
Paint fonnulating
Ink fonnulating
Aquatic animal production
Gum and wood chemicals
Pesticide chemicals
Explosives
Carbon black manufacturing
Photographic
Hospitals
Battery manufacturing
Plastic molding and forming
Metal molding and casting
Coil coating
Porcelain enameling
Aluminum forming
Copper forming
Electrical and electronic components
Nonferrous metals forming and metal powders
40CFRPart
438
439
440
441
442
443
444
445
446
447
451
454
455
457
458
459
460
461
463
464
465
466
467
468
469
471
Group
V
V
m
V
V
VI
V
V
VI
VI
V
VI
VI
VI
VI
VI
VI
VI
VI
IV
IV
VI
VI
VI
rv
VI
5-3
-------
Section 5 - Existing Industry Review
5.2 Group I Industries
The Group I industries include Organic Chemicals, Plastics and Synthetic Fibers
(OCPSF) (Part 414), which includes an additional subcategory for Chemical Formulators,
Packagers and Repackagers (CFPR), and Petroleum Refining (Part 419), which includes an
additional subcategory for Petroleum Bulk Stations and Terminals (PBSTs). EPA categorized
these industries as Group I due to their relatively high toxic-weighted discharges, possible
opportunity for increased pollutant control, and potential additional subcategories. As explained
in Section 5.1, these are the two industries for which EPA conducted detailed studies in its 2004
annual review. Because EPA collected and analyzed more extensive data for these two
industries, it has devoted a single section to each: the OCPSF review in Section 6 and the
Petroleum Refining review in Section 7. These sections include additional information on
methodology, data sources, and analyses specific to these industries, discusses the analysis of the
data collected, and presents the decisions made based on this information.
5.3 Group II Industries
This section describes the detailed review EPA conducted on the Group II
industries. Group II industries are those that had relatively high toxic-weighted pollutant
discharges in EPA's screening analysis. However, for these industries, EPA had data gaps,
which made confirming these toxic discharges more difficult. During the review, EPA attempted
to collect additional information for these industries to better assist its decision-making. The
Group II industries include Inorganic Chemicals (Part 415) and Nonferrous Metals
Manufacturing (Part 421).
5.3.1 Inorganic Chemicals (Part 415)
EPA selected the inorganic chemicals manufacturing industry for review because
it ranked high in terms of toxic and nonconventional pollutant discharges during EPA's initial
screening-level analyses. As part of this review, EPA conducted further verification of TRI and
PCS data and reviewed data on industry characteristics.
This section describes the inorganic chemicals manufacturing industry in the
following subsections:
• Section 5.3.1.1 presents an overview of the inorganic chemicals
manufacturing industry including the overall Standard Industrial
Classification (SIC) codes that make up this industry. This section also
presents the number, location, and discharge status of the facilities
covered by this industry.
• Section 5.3.1.2 summarizes the regulatory background applicable to the
wastewater discharges from this industry.
5-4
-------
Section 5 - Existing Industry Review
• Section 5.3.1.3 discusses the wastewater characteristics of the inorganic
chemicals manufacturing industry. One subgroup within this industry,
SIC code 2812 - chlor-alkali manufacturing, is a major contributor of
dioxin and dioxin-like compound releases to wastewater. In addition,
chlor-alkali production commonly occurs at integrated OCPSF facilities.
Therefore, the characterization of the chlor-alkali production processes
and wastewaters are addressed in Section 6 of this document. Section
5.3.1.3 focuses on the other SIC codes that fall within this industry. This
subsection also identifies those pollutants of concern based on current data
from PCS and TRI.
• Section 5.3.1.4 discusses the treatment and control of wastewaters
generated by the inorganic chemicals manufacturing industry.
• Section 5.3.1.5 presents EPA's conclusions regarding the status of this
industry and whether it might warrant additional study.
5.3.1.1 Industry Description
The Inorganic Chemicals Manufacturing Point Source Category includes facilities
within the following four SIC codes:
2812- Chlor-Alkali;
• 2813 - Industrial Gases;
• 2816 - Inorganic Pigments; and
• 2819 - Other Inorganic Chemicals.
The chlor-alkali (alkali and chlorine) industry, covered under SIC code 2812,
produces chlorine, caustic soda, soda ash, sodium bicarbonate, potassium hydroxide, and
potassium carbonate. Chlorine and caustic soda account for the bulk of the production. (2)
Industrial gases, covered under SIC code 2813, are used in a wide variety of
applications, from cryogenics to fuel for welding torches. Products for this segment of the
industry include common elements such as hydrogen, oxygen, and nitrogen, common
compounds such as carbon dioxide, and over 100 specialty gases. Because nitrogen and oxygen,
which constitute a large fraction of the industrial gas market, are captured by cooling,
compressing, and distilling air, little pollution is associated with their production. (2)
Chrome pigments, produced under SIC code 2816, are used in a variety of
applications such as paints, plastics, printing inks, alkali-resistant paints and dyes, and rust-
inhibitive primers. Chrome yellows and oranges and molybdate chrome pigments compose the
majority of the chrome pigments market. These two products, as well as chrome green, contain
substantial amounts of lead. (2) Titanium dioxide is also produced under this SIC code and may
5-5
-------
Section 5 - Existing Industry Review
be of interest due to the potential generation of chlorinated dioxins and furans from the chloride
and chloride ilmenite production processes. (4)
SIC code 2819 covers a variety of chemicals, including small-volume speciality
chemicals, bulk acids, salts, phosphates, sulfur, and hydrogen peroxide. These chemicals are
used as inputs to basic industrial products such as metals, pulp and paper, and chemicals. (2)
EPA obtained information on the number of facilities in the inorganic chemicals
manufacturing industry from four sources: EPA's estimate of facilities at the time of the final
regulation (1982 and 1984), the 1997 U.S. Economic Census, the 1992 and 2000 TRI databases,
and the 2000 PCS database (major and minor direct discharging facilities). Table 5-2 presents
the number of facilities in the inorganic chemicals manufacturing industry by SIC code from
these sources.
Table 5-2. Number of Facilities in Inorganic Chemicals Manufacturing Industry
SIC Code
2812 - Odor-Alkali
2813 - Industrial Gases
2816 - Inorganic Pigments
2819 - Other Chemicals
Total
Final Regulation
(1982 and 1984)
(2)
77
223
36
434
770
1992 TRI
Database
51
140
47
412
650
1997 U.S.
Economic
Census
39
630
74
667
1410
2000 TRI
Database
37
68
46
338
489
2000 PCS
Database -
Majors/
Minors
17/7
3/38
16/12
57/82
93/139
EPA's estimates (from the final regulation and the TRI database) show that the
number of facilities in the inorganic chemicals manufacturing industry appears to be decreasing
over time with significant reductions in the chlor-alkali and the industrial gases sectors.
Table 5-3 presents the current number and percentage of facilities by type of
discharge and SIC code based on 2000 TRI data. These data indicate that a majority of facilities
within this industry are zero dischargers.
Table 5-3. Number of Facilities by Discharge Type and SIC Code
Direct Dischargers - Number (% of SIC Code)
Indirect Dischargers - Number (% of SIC Code)
Both Direct and Indirect Dischargers - Number
(% of SIC Code)
SIC Code
2812
11(30%)
1 (3%)
1 (3%)
2813
9 (13%)
3 (4%)
0 (0%)
2816
14 (30%)
13 (28%)
7 (15%)
2819
60 (18%)
69 (20%)
30 (9%)
Total
94
86
38
5-6
-------
Section 5 - Existing Industry Review
Table 5-3 (Continued)
Zero Dischargers - Number (% of SIC Code)
Total
SIC Code
2812
24 (64%)
37
2813
56 (82%)
68
2816
12 (26%)
46
2819
179 (53%)
338
Total
271
489
Inorganic chemicals manufacturing facilities are located in every region of the
United States. An analysis of facility type by location shows that facilities with SIC codes 2812
and 2816 are located primarily in the eastern third of the U.S. and facilities with SIC code 2813
are located primarily in the south.
5.3.1.2
Regulatory Background
Typically, this industry manufactures inorganic chemicals for captive or merchant
use in four or more steps starting from raw material to final product. The wastestreams
generated by the process vary based on the raw materials used, process sequence and control,
recycle potential, handling, and quality control steps. It was this variability, in part, that led EPA
to subcategorize the inorganic chemicals manufacturing industry by the type of inorganic
product produced since this approach involved the least ambiguity in applying the standards to a
given point source. (1)
EPA initially published effluent limitations guidelines and standards for the
Inorganic Chemicals Manufacturing category in 1974 for 22 subcategories (i.e., the Phase I
rule). EPA then published, in 1975, a Phase II rule for an additional 27 subcategories. Portions
of both the Phase I and Phase II rules were remanded to the Agency in 1976. In 1982, EPA
published an amendment to the Phase I rule that contained revised effluent limitations guidelines
and standards (ELGS) for 10 subcategories followed by an amendment to the Phase n aile in
1986 with revised requirements for six subcategories. Currently, there are 67 subparts in the
ELGS for the inorganic chemicals manufacturing industry. EPA reserved 20 of those subparts
for various reasons, including the following: no dischargers, the amount or toxicity of the
discharge was considered insignificant or too low to treat, or the production or flow was
considered too low.
For 24 of the subparts, EPA set the BPT effluent limitations guidelines to require
no discharge of wastewater pollutants. Tables 5-4 and 5-5 list the subparts that are reserved and
the subparts that have no discharge at BPT, respectively.
5-7
-------
Section 5 - Existing Industry Review
Table 5-4. Reserved Subparts in 40 CFR Part 415
Subpart
G
J
O
R
S
Y
Z
AF
AK
AM
Description
Hydrochloric Acid Production
Nitric Acid Production
Sodium Carbonate Production
Sodium Metal Production
Sodium Silicate Production
Ammonia Hydroxide Production
Barium Carbonate Production
Carbon Dioxide Production
Cuprous Oxide Production
Ferrous Sulfate Production
Subpart
AT
AV
AZ
BA
BD
BE
BF
BG
BI
BJ
Description
Manganese Sulfate Production
Strong Nitric Acid Production
Potassium Permanganate Production
Silver Nitrate Production
Sodium Hydrosulfide Production
Sodium Hydrosulfate Production
Sodium Silicofluorite Production
Sodium Thiosulfate
Sulfur Dioxide Production
Zinc Oxide Production
Table 5-5. Subparts in 40 CFR Part 415 Requiring No Discharge at BPT
Subpart
B
C
E
K
L
M
N
P
X
AA
AB
AC
Description
Aluminum Sulfate Production
Calcium Carbide Production
Calcium Oxide Production
Potassium Metal Production
Potassium Dichromate Production
Potassium Sulfate Production
Sodium Bicarbonate Production
Sodium Chloride Production
Ammonium Chloride Production
Borax Production
Boric Acid Production
Bromine Production
Subpart
AE
AI
AL
AN
AO
AQ
AR
AS
AX
BC
BH
BK
Description
Calcium Hydroxide
Chromic Acid
Ferric Chloride
Fluorine
Hydrogen
Iodine
Lead Monoxide
Lithium Carbonate
Potassium Chloride
Sodium Fluoride
Stannic Acid
Zinc Sulfate
Table 5-6 lists the pollutants regulated in the Inorganic Chemicals Manufacturing
category by subpart. Note that some subparts have "no discharge" requirements for direct
dischargers and numeric limits for indirect dischargers.
5-S
-------
Section 5 - Existing Industry Review
Table 5-6. Regulated Pollutants/Parameters by Subpart in 40 CFR Part 415
Subpart
A
B
D
F
H
I
L
Q
T
V
W
X
AB
AG
AH
AT
AP
AR
AU
AW
AY
BA
BB
BC
BL
Description
Aluminum Chloride
Aluminum Sulfate
Calcium Chloride
Chlor-Alkali
Hydrofluoric Acid
Hydrogen Peroxide
Potassium Bichromate
Sodium Bichromate
Sodium Sulfide
Titanium Bioxide
Aluminum Fluoride
Ammonium Chloride
Boric Acid
Carbon Monoxide and By-
Product Hydrogen
Chrome Pigments
Copper Salts
Hydrogen Cyanide
Lead Monoxide
Nickel Salts
Oxygen and Nitrogen
Potassium Iodine
Silver Nitrate
Sodium Bisulfite
Sodium Fluoride
Cadmium Pigments & Salts
Regulated Pollutants/Parameters1
pH
Zinc
Total Suspended Solids (TSS), pH
Mercury (T), Copper (T), Lead (T), Nickel (T), Total Residual
Chlorine, TSS, pH
Fluoride. Nickel (T), Zinc (T), TSS. pH
Cyanide (Amendable to Chlorine), Total Organic Carbon
(TOC), TSS, pH
Chromium (T), Chromium (H)
Chromium (T), Chromium (H), Nickel (T), TSS, pH
Chromium (T), Zinc (T), COB, TSS, pH
Chromium (T), Nickel (T), Iron (T), TSS, pH
Fluoride (T), Chromium (T), Nickel (T), TSS, pH
Ammonia (as N), pH
Arsenic, TSS. pH
COB, TSS, pH
Chromium (T). Lead (T), Zinc (T). TSS. pH
Copper (T), Nickel (T). Selenium (T), TSS, pH
Cyanide (T). Cyanide (A), Total Residual Chlorine, TSS. pH
Lead
Nickel (T), Copper (T), TSS, pH
Oil and Grease, pH
Iron, Barium, Sulfide, TSS, pH
Silver, TSS, pH
Chromium (T), Zinc (T), COB, TSS, pH
Fluoride
Cadmium (T), Selenium (T), Zinc (T), TSS, pH
'(T) - Total, (H) - Hexavalent.
5.3.1.3
Wastewater Characterization
The wastewater streams generated by the inorganic chemical manufacturing
industry vary by subcategory. Examples of the types of wastewater streams generated include
noncontact and contact cooling waters, scrubber wastewaters, distillation bottoms, condensates,
floor and equipment washings, filter operation wastewaters, and spills and maintenance-related
5-9
-------
Section 5 - Existing Industry Review
wastewaters. The Final Inorganic Chemicals TDD (1) provides subcategory-specific information
on the production processes and wastes generated by this industry.
For the inorganic chemical manufacturing facilities reporting to the 2000 TRI,
EPA estimates a total toxic weighting pound equivalent (TWPE) discharge for the industry of
624,250. The majority of this toxic discharge occurs from 12 facilities. Table 5-7 lists the
pollutants reported to TRI as discharged directly or indirectly, which account for 95 percent of
the total TWPE. This table presents the number of facilities that reported each chemical, total
pounds of chemical discharged, and total TWPE for each chemical. The 2000 TRI database does
not include all inorganic chemical manufacturing facilities or TRI-listed chemicals that are used
or produced at levels below reporting thresholds.
Table 5-7. 2000 TRI Top Pollutants Discharged by the Inorganic Chemicals
Manufacturing Industry
Pollutant
Dioxin and Dioxin-like
Compounds
Hexachlorobenzene
Sodium Nitrite
Chlorine
Manganese Compounds
Vanadium Compounds
Chromium Compounds
Silver Compounds
Number of
Facilities
Reporting
11
3
7
15
29
8
33
4
TRI Releases
2000 Total
(lb/yr)
0.11
203
243,083
99,727
224,533
22,766
19,759
588
TRI Releases
2000
TWPE/yr
266,330
147,007
90,751
48,565
15,815
14.166
10.114
9,692
Percentage of
Total SIC
Code TWPE
41.1
23.5
14.5
7.8
2.5
2.3
1.6
1.6
Cumulative
Percentage of
Total SIC Code
TWPE
41.1
64.6
79.1
86.9
89.4
91.7
93.3
94.9
Source: EPA, TRIReleases2000.
Based on the TRIReleases2000 (see Section 4.2.1), dioxin and dioxin-like
compounds represent the largest TWPE discharges for the industry. During its screening-level
analysis, EPA identified the Oxy Vinyl L.P. facility located in Deer Park, Texas as discharging
the largest dioxin and dioxin-like compound TWPE load. In a subsequent phone contact with
the company, EPA learned that the Deer Park, Texas facility closed and therefore, EPA did not
include the loads from that facility in the TRI totals in Table 5-7.
For the inorganic chemical manufacturing facilities reporting to PCS for 2000,
EPA estimates a TWPE discharge for the industry of 853,568. The majority of this toxic
discharge occurs from eight facilities, and half of the TWPE load is due to the discharge of
mercury. Table 5-8 lists the pollutants reported to PCS as discharged by major dischargers,
which account for 95 percent of the total TWPE. This table presents the number of facilities that
reported each chemical, total pounds of chemical discharged, and total TWPE for each chemical.
5-10
-------
Section 5 - Existing Industry Review
Table 5-8. 2000 PCS Top Pollutants Discharged by the Inorganic Chemicals
Manufacturing Industry
Pollutant
Mercury, Total (as Hg)
Chlorine, Total Residual
Sulfide, Total (as S)
Iron, Dissolved (as Fe)
Benzo(a)pyrene
Lead, Total (as Pb)
Aluminum, Total
Recoverable
Chloride (as Cl)
Number of
Facilities
Reporting
24
44
5
3
12
39
1
15
PCS Loads
2000 Total
(Ibs/yr)
3,671
221,979
25,634
12,673,109
12
18,517
483,625
393.760.079
PCS Loads
2000
TWPE/yr
429,818
108,100
71,789
70,969
50,109
41,479
31,188
9.587
Percentage
of Total SIC
Code TWPE
50
13
8
8
6
5
4
1
Cumulative
Percentage of
Total SIC Code
TWPE
50
63
71
80
86
90
94
95
Source: EPA. PCSLoads2000.
As described in Section 6, EPA found that the largest dioxin discharges occur at
large integrated OCPSF facilities which also operate chlor-alkali plants (whose wastewaters may
be subject to the Inorganic Chemicals effluent guidelines (Part 415)). Dioxin discharges are also
significant at stand-alone chlor-alkali plants. Because of the connection between dioxin
discharges from the chlor-alkali industry and other chloride-related processes at OCPSF
facilities, EPA discusses the chlor-alkali production process, wastewaters, and their
characterization in Section 6 and is focusing the remainder of this section on SIC codes 2813,
2816, and 2819.
Over the years, the inorganic chemicals manufacturing industry has generated less
wastewater as old processes are replaced with new processes that use less water (2).
PCSLoads2000 (see Section 4.2.2) provides total wastewater flow data by SIC code for the
inorganic chemicals manufacturing industry; no flow data are provided in TRIReleases2000.
EPA also evaluated flow using data from the 1992 PCS database included the Preliminary Data
Summary for the Inorganic Chemicals Manufacturing category prepared in 1994 (2). Table 5-9
compares the average and total annual wastewater flows for 1992 and 2000 from the PCS
database for major dischargers in the industry.
5-11
-------
Section 5 - Existing Industry Review
Table 5-9. 1992 and 2000 Wastewater Flows by SIC Code
SIC Code
2813 - Industrial Gases
2816 - Inorganic Pigments
2819 - Other Chemicals
Number of
Major Facilities
(1992/2000)
33/3
20/16
124/57
Average Flow
1992 (MGY)
2.871
3,461
4,395
Average Flow
2000 (MGY)
13,178
2,831
2,135
Total Flow
1992
(MGY)
94,731
69,220
544,927
Total Flow
2000
(MGY)
39,533
45,300
121,680
Source: EPA, PCSLoads2000 and 1992 PCS database.
EPA estimated the average flow for 1992 and 2000 by dividing the total flow
from PCS by the number of PCS facilities with flow data in each SIC code. As shown in Table
5-9, facilities in SIC code 2819, Other Chemicals, discharge most of the wastewater in this
industry. Facilities in SIC code 2816, the inorganic pigments group, discharge the least amount
of wastewater.
EPA does not currently have information on the raw waste loads generated by
dischargers in the inorganic chemicals manufacturing industry. Therefore, only discharge loads
are discussed in the remainder of this section.
Table 5-10 lists the pollutants with the highest percentage of the total TWPE by
SIC code based on TRIReleases2000 for both direct and indirect dischargers. Looking at only
SIC codes 2813, 2816, and 2819, the total TWPE discharges based on 2000 TRI data are
479,282.
Table 5-10. Pollutants of Concern from 2000 TRI Data (Direct and Indirect Dischargers)
SIC
Code
2813
2816
2819
Pollutant
Chlorine
Selenium
Hexachlorobenzene
Dioxin and Dioxin-like
Compounds
Sodium Nitrite
Chlorine
Vanadium Compounds
Silver Compounds
Regulated
Pollutant?
Yes
Yes
No
No
No
Yes
No
Yes
TWPE/yr
937
840
145,559
123,470
85,162
45,710
12,378
9,692
Number of
Facilities
Reporting
Discharge
2
1
2
6
5
9
5
4
Percentage
of TWPE
(SIC Code)
51
46
47
40
51
27
7
6
Percentage of
TWPE (Total)
0.15
0.13
23
19
13
7
2
1.5
Source: EPA. TRIReleases2000.
5-12
-------
Section 5 - Existing Industry Review
Table 5-11 lists the same information based on PCSLoads2000 for direct
dischargers. Again, looking at only SIC codes 2813, 2816, and 2819, the total TWPE discharges
based on the 2000 PCS data are 683,500.
Table 5-11. Pollutants of Concern from 2000 PCS Data (Direct Dischargers)
SIC
Code
2813
2816
2819
Pollutant
Total Mercury
Cadmium
Iron, Dissolved
Total Mercury
Total Residual Chlorine
Benzo(a)pyrene
Total Lead
Regulated
Pollutant?
Yes
Yes
Yes
Yes
Yes
No
Yes
TWPE/yr
1.480
188
70,969
359,939
84,965
46,254
40737
Number of
Facilities
Reporting
Discharge
1
1
2
6
11
1
13
Percentage
of TWPE
(SIC Code)
79
10
92
60
14
8
7
Percentage of
TWPE (Total)
0.17
0.02
8
42
10
5
5
Source: EPA, PCSLoads2000.
5.3.1.4
Treatment Technologies
EPA used various technologies as the basis for the Inorganic Chemicals
Manufacturing category effluent limitations guidelines and standards, including:
Aeration;
Precipitation;
Clarification;
Filtration;
Neutralization;
Polishing;
Recycling; and
Thickening (1).
For 24 of the 67 subcategories, EPA set zero discharge as the basis for the BPT effluent
limitations guidelines.
Table 5-12 presents the treatment technologies most commonly used in the
inorganic chemicals industry reporting to TRI for 2000.
5-1:
-------
Section 5 - Existing Industry Review
Table 5-12. Wastewater Treatment Operations Reported By Inorganic Chemicals
Manufacturing Facilities, TRI Reporting Year 2000
Wastewater Treatment Process
Neutralization
Chemical Precipitation
Settling/Clarification
Filtration
Equalization
Sludge Dewatering (Nonthermal)
Stripping - Air, Steam, or Other
Biological Treatment
Adsorption
Other Chemical Treatment
General Oxidation (including disinfection)
Number of Facilities Reporting Use
Direct
(75 Facilities)
40
44
48
28
28
9
15
17
12
8
7
Indirect
(64 Facilities)
43
34
30
27
12
13
6
1
4
4
4
Source: Section 7A Table of the TRI 2000 Database.
Most of the direct and indirect discharging facilities reporting to TRI use
neutralization, chemical precipitation, settling/clarification, filtration and/or equalization. These
types of treatment technologies are consistent with the types used as the technology basis for the
inorganic chemicals manufacturing effluent limitations guidelines and standards.
EPA's current evaluation of pollution prevention opportunities for this industry
shows that, during the manufacture of inorganic chemicals, there are several opportunities to
reduce the amount of pollutants generated and the volume of wastewater that has to be treated.
These pollution prevention alternatives include, but are not limited, to:
• Installing mechanical scrapers on filters to eliminate the need to backwash
the filters. An example is during the manufacture of sulfate and nickel
sulfate.
• Using high purity ore in the manufacturing process, which reduces the
amount of impurities in the ore that are discharged to the wastewater. An
example is in the manufacture of titanium dioxide.
• Using metal anodes instead of graphic anodes in the manufacturing
process, which reduces the amount of lead and organic pollutants
discharged to the wastewater. An example is during the manufacture of
chlorine using the diaphragm cell process.
5-14
-------
Section 5 - Existing Industry Review
• Using noncontact cooling water instead of contact cooling water in the
manufacturing process, which reduces the volume of water used as well as
the volume of wastewater generated. As an example, this can be done in
the diaphragm cell process during the manufacture of chlorine.
• Recovering and reusing inorganic chemicals used in the manufacturing
process. For example, chlorine used in manufacturing ferric chloride can
be recovered and reused.
• Recycling drip acid used in the manufacturing process. As an example,
this can be done during the manufacture of hydrofluoric acid.
• Using an ion exchange process or reverse osmosis to treat wastewater
generated during the manufacturing process. Because of the high quality
of the treated wastewater, it can be reused for various purposes, which
reduces the volume of wastewater discharged. (3)
5.3.1.5 Conclusions
The inorganic chemicals manufacturing industry ranked high in terms of toxic and
nonconventional pollutant discharges among all industrial point source categories investigated in
EPA's screening-level analyses. Based on TRIReleases2000, much of this loading is attributed
to dioxin and dioxin-like compounds generated by the chlor-alkali (SIC code 2812) and
inorganic pigment (SIC code 2816) industries. EPA notes that, as explained in Section 6, it has
identified the chlor-alkali sector of the inorganic chemicals manufacturing ELGS for possible
revision. In addition, only a dozen facilities discharge most of the TWPE load for this industry
based on 2000 TRI data. Other pollutants of concern for this industry based on 2000 TRI data
include hexachlorobenzene, sodium nitrite, chlorine, vanadium compounds, silver compounds,
and selenium. Data from the PCSLoads2000 identify mercury, chlorine, iron, benzo(a)pyrene,
lead, and cadmium as pollutants of concern.
EPA does not currently have data on the raw waste loads generated by
dischargers in this industry category. Therefore, the Agency would need to collect additional
data to assess the pollutant removals occurring in this industry. Additionally, stakeholders in
EPA's screening analyses commented that there have been substantial changes to this industrial
category since the effluent guidelines were promulgated in 1982. EPA believes that additional
study of this industry is warranted to determine whether the existing "no discharge"
requirements are reasonable and to assess whether additional BMPs or improved treatment could
achieve additional reductions in the pollutants with the highest toxic pounds.
5-15
-------
Section 5 - Existing Industry Review
5.3.1.6 References
1. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Inorganic Chemicals Manufacturing Point Source Category.
EPA-440/1 -82/007. Washington, D.C. June 1982.
2. U.S. EPA. Preliminary Data Summary for the Inorganic Chemicals
Manufacturing Point Source Category. EPA-821/R-96-016. Washington, D.C.
December 1994.
3. Center for Technology and Environmental Management. Fact Sheet: Best
Management Practices for Inorganic Chemicals Manufacturing Industry.
November 25, 1998.
4. U.S. EPA. Final Titanium Dioxide Listing Background Document for the
Inorganic Chemical Listing Determination. Washington, D.C. October 2001.
5.3.2 Nonferrous Metals Manufacturing (Part 421)
EPA selected the Nonferrous Metals (NFM) Manufacturing Point Source
Category for review because it ranked high in terms of toxic and nonconventional pollutant
discharges during EPA's screening-level analyses. As part of this review, EPA conducted
further verification of Toxic Release Inventory (TRI) and Permit Compliance System (PCS) data
and reviewed data on industry characteristics.
This section describes the NFM manufacturing industry in the following
subsections:
• Section 5.3.2.1 presents an overview of the NFM manufacturing industry
including the overall SIC codes that make up this industry and how those
relate to the regulatory subcategories included within the industry. This
section also presents the number, location, and discharge status of the
facilities in this industry.
• Section 5.3.2.2 summarizes the regulatory background applicable to
wastewater discharges from this industry.
• Section 5.3.2.3 discusses the types of wastewaters generated by the NFM
manufacturing industry and presents information on how they are
characterized. This section also identifies those pollutants of concern
based on current data from PCS and TRI.
• Section 5.3.2.4 discusses the treatment and control of wastewaters
generated by the NFM manufacturing industry.
5-16
-------
Section 5 - Existing Industry Review
Section 5.3.2.5 presents EPA's conclusions regarding the status of this
industry and whether it might warrant additional study.
5.3.2.1
Industry Description
The NFM Manufacturing category includes sites that smelt and refine metals
other than steel, such as aluminum, copper, nickel, and many others. It does not cover mining or
forming operations and includes 31 subcategories. Although sites with different primary SIC
codes could perform operations covered by Part 421, the main SIC codes that are covered by Part
421 include 3331 (Primary Smelting and Refining of Copper), 3334 (Primary Production of
Aluminum), 3339 (Primary Smelting and Refining of Nonferrous Metals, Except Copper), 3341
(Secondary Smelting and Refining of Nonferrous Metals), and a portion of 2819 (Inorganic
Chemicals, not elsewhere classified (NEC)).
SIC code 2819 includes several operations covered by Part 421. In EPA's
screening-level analysis, all of the facilities within SIC code 2819 were included as part of the
NFM manufacturing and inorganic chemicals manufacturing industries. Further review
identified that the following six sites are known to perform NFM manufacturing operations,
including the production of refined bauxite, alumina, slug uranium (radioactive), liquid metals,
and several inorganic metals. The six sites reporting under SIC code 2819 that are included in
EPA's review for NFM manufacturing are:
1. ALCOA World Alumina in Texas (TRI);
2. ALCOA World Alumina in Florida (TRI);
3. ALCOA World Chemicals in Arkansas (TRI);
4. U.S. Enrichment Corp in Kentucky (TRI and PCS);
5. U.S. Enrichment Corp in Ohio (PCS); and
6. Reynolds Metals Co in Arkansas (PCS).
Table 5-13 below presents the 31 subcategories of the NFM manufacturing
industry and the SIC codes covered by Part 421 under which they fall.
Table 5-13. SIC Codes and Subcategories in Part 421
Subcategory
1
2
3
4
5
6
Bauxite Refining
Metallurgical Acid Plants1
Primary Aluminum
Primary and Secondary
Germanium and Gallium2
Primary and Secondary
Titanium2
Primary Antimony
SIC Code
3334
3331
3334
3339
3339
3339
SIC Code Name
Primary Smelting and Refining of Copper
Primary Smelting and Refining of Copper
Primary Production of Aluminum
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
5-17
-------
Section 5 - Existing Industry Review
Table 5-13 (Continued)
Subcategory
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
Primary Beryllium
Primary Columbium and
Tantalum
Primary Copper Smelting
Primary Electrolytic Copper
Refining
Primary Lead
Primary Molybdenum and
Rhenium
Primary Nickel and Cobalt
Primary Precious Metals and
Mercury
Primary Rare Earth Metals
Primary Tungsten
Primary Zinc
Primary Zirconium and Hafnium
Secondary Aluminum
Secondary Copper
Secondary Indium
Secondary Lead
Secondary Mercury
Secondary Molybdenum and
Vanadium
Secondary Nickel
Secondary Precious Metals
Secondary Silver
SIC Code
3339
3339
3331
3331
3339
3339
3339
3339
3339
3339
3339
3339
3341
3341
3341
3341
3341
3341
3341
3341
3341
SIC Code Name
Primary Smelting and Refining of Nonferrous Metals.
Except Copper
Primary Smelting and Refining of Nonferrous Metals.
Except Copper
Primary Smelting and Refining of Copper
Primary Smelting and Refining of Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Primary Smelting and Refining of Nonferrous Metals,
Except Copper
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
5-18
-------
Section 5 - Existing Industry Review
Table 5-13 (Continued)
Subcategory
28
29
30
31
Secondary Tantalum
Secondary Tin
Secondary Tungsten and Cobalt
Secondary Uranium
SIC Code
3341
3341
3341
2819
SIC Code Name
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Secondary Smelting and Refining of Nonferrous
Metals
Smelting or Refining of Uranium (NFM Portion of
Inorganic Chemicals SIC Code)
'EPA assigned the Metallurgical Acid Plants Subcategory to SIC code 3331. According to a conversation with Dan
Edelstein of the USGS Minerals Division, metallurgical acid recovery is mostly done from primary smelting. Also,
according to the Final NFM Manufacturing Point Source Category Development Document (3), it is more often
associated with copper, zinc, lead, and molybdenum.
2EPA assigned this Subcategory to SIC code 3339, because EPA was unable to separate the secondary facility loads
from the primary facility loads.
The 1997 Economic Census provides information on the number of facilities
classified within SIC codes 2819, 3331, 3334, 3339, and 3341. Table 5-14 presents the 1997
Economic Census data, the number of "major" and "minor" direct dischargers submitting data to
PCS, and the number of facilities submitting reports to EPA's TRI for 2000 for this industrial
category.
Table 5-14. Number of Operating Facilities, By Year and Data Source
SIC Code
2819
3331
3334
3339
3341
Inorganic Chemicals, NEC
Primary Smelting and Refining of Copper
Primary Production of Aluminum
Primary Smelting and Refining of Nonferrous
Metals, Except Copper
Secondary Smelting and Refining of
Nonferrous Metals
TOTAL
1997 Economic
Census
6
16
21
142
256
438
PCS Loads
2000
3/0
3/1
23/3
13/5
14/17
56/26
TRI Releases
2000
4
5
25
30
172
236
EPA used TRIReleases2000 to determine the distribution of discharge status. Of
the 236 facilities that reported to TRI in 2000, 115 reported releases directly to surface waters
and/or transfers to POTWs and the remainder reported zero discharges. Table 5-15 shows the
distribution of direct, indirect, both direct and indirect, and zero dischargers reporting to TRI by
SIC code.
5-19
-------
Section 5 - Existing Industry Review
Table 5-15. Wastewater Discharge Status Reported in TRIReleases2000
SIC
Code
2819
3331
3334
3339
3341
Total
Number of
Direct
Dischargers
4
1
14
10
38
Percentage
of SIC
Code
100%
20%
56%
33%
22%
67 Total Directs Only
Number of
Indirect
Dischargers
0
2
0
4
23
Percentage
of SIC
Code
0%
40%
0%
13%
13%
29 Total Iiidirects
Only
Number of
Both D/I
Dischargers
0
0
2
4
13
Percentage of
SIC Code
0%
0%
8%
13%
8%
19 Total Both Direct and
Indirect
Number of
Zero
Dischargers
0
2
9
12
98
Percentage of
SIC Code
0%
40%
36%
40%
57%
121 Total Zero Dischargers
Source: EPA. TRIReleases2000.
NFM manufacturing facilities are located throughout the United States, with
concentrations near raw material sources, transportation centers, markets, or sources of
inexpensive energy (1). For copper, lead, zinc, molybdenum, and titanium primary producers,
the larger facilities are located near ore mines in the Midwest and West. Secondary metal
producers tend to be located near metropolitan areas.
5.3.2.2
Regulatory Background
As described in the 1989 NFM Final TDD (1), EPA promulgated the ELGS for
the NFM Manufacturing category in two separate rulemakings, referred to as Phase I and Phase
II. In 1984, EPA addressed 12 subcategories that generate the largest quantities of toxic
pollutants (Phase I), followed by regulation of 25 additional subcategories in 1985 (Phase II).
Because of a series of lawsuits and settlements, EPA reproposed the rule several times, with final
promulgation of both phases in August 1990. EPA determined that five of the subcategories
considered by the Phase I and II rules did not warrant national regulation because no plants in
the subcategories discharged wastewater or no plants discharged treatable concentrations of
pollutants. These five subcategories were:
• Primary Boron;
• Primary Cesium and Rubidium;
• Primary Lithium;
• Primary Magnesium; and
• Secondary Zinc.
Conventional pollutants controlled in the ELGS, for one or more of the 31
regulated subcategories, include oil and grease (O&G), TSS, and pH. Priority and
nonconventional pollutants regulated for one or more of the subcategories include the following:
5-20
-------
Section 5 - Existing Industry Review
• Aluminum • Lead
• Ammonia (as N) • Mercury
• Antimony • Molybdenium
• Arsenic • Nickel
• Benzo(a)pyrene • Palladium
• Beryllium • Phenolics
• Cadmium • Platinum
• Chromium (total) • Selenium
Cobalt • Silver
• Copper • Tantalum
• Cyanide • Tin
• Fluoride • Titanium
• Gold • Tungsten
• Hexachlorobenzene • Zinc
• Iron
The data collection effort for Part 421 took place from 1979 to 1984, and the data
were not updated for the 1990 final rule. EPA has not conducted any additional data collection
efforts for this industry since that time.
5.3.2.3 Wastewater Characterization
There are over 240 types of process wastewater streams generated by the 31
regulated subcategories of the NFM manufacturing industry. Many of these wastewaters are
associated with air pollution control treatment, contact cooling and quenching, casting, and wash
and rinsing operations. (1)
Table 5-16 presents the top pollutants discharged by the industry based on
information in the 1989 Final NFM Manufacturing TDD. Based on the 1989 TDD loading
information and accounting for toxic pound equivalents, benzo(a)pyrene was a top constituent of
concern and was regulated in the final rule under the Primary Aluminum Smelting Subcategory.
During the sampling effort for the rule, benzo(a)pyrene was found above its analytical
quantitation limit in 13 of 19 samples taken from 10 plants. Effluent concentrations ranged from
0.17 to 11.0 mg/1. Additionally, EPA determined that a concentration of 0.01 mg/1 for
benzo(a)pyrene was attainable using the rule's identified treatment technologies (lime
precipitation followed by sedimentation and multimedia filtration). In settlement negotiations
after promulgation, the Agency revised its statistical analysis of benzo(a)pyrene data to develop
one-day maximum and monthly average treatment effectiveness concentrations as a basis for
calculating mass discharge limits. The recalculated treatment effectiveness concentrations are
0.0337 mg/1 maximum for any one day and 0.0156 mg/1 maximum monthly average of daily
values. The Agency also restricted the discharge allowance for benzo(a)pyrene to those streams
that actually contain this pollutant. (3)
5-21
-------
Section 5 - Existing Industry Review
Stream-specific concentration data from PCS (for the 2000 reporting year)
indicate that current discharges of benzo(a)pyrene are generally less than 0.02 mg/1 for those
facilities reporting its discharge, with only one facility reporting a discharge above 0.01 mg/1.
These concentration data indicate that current discharges for this pollutant are generally below
treatable levels.
Table 5-16 also presents the top pollutants discharged by the industry based on
the estimated total TWPE load from both TRI and PCS (using the 2000 databases). The 2000
TRI TWPE was 978,450, with over 90 percent of the load coming from six direct discharging
facilities. The 2000 PCS TWPE was 434,925, with over 90 percent of the load coming from 15
facilities.
Table 5-16. Top Pollutants Discharged by the NFM Manufacturing Industry
Data
Source
TDD
PCS
TRI
Pollutant
Benzo(a)pyrene
Arsenic
Silver
Aluminum
Ammonia as Nitrogen
Zinc
Vanadium (total)
Benzo(a)pyrene
Chlorine (Total Residual)
Polychlorinated Biphenols
(PCBs)
Fluoride (total)
Chlorine (Free Available)
Aluminum (total)
Zinc (total)
Polycyclic Aromatic
Compounds (PACs)
Vanadium Compounds
Sodium Nitrite
Cadmium Compounds
Number of
Facilities
Reporting
Pollutant
27
195
157
116
163
229
3
14
25
6
27
19
22
26
4
4
1
8
Regulated
Pollutant?
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
Yes
No
Yes
Yes
No
No
Discharged Annual
Loading1
TWPE
220,979
27,002
11,790
2,213
1,161
471
100,592
89,743
84,373
29,319
21.321
14,524
14.239
12,107
831,010
52,174
34,727
21.812
Pounds
Per Year
52
7,783
716
34.320
771,510
10,074
161.665
21
173,257
2
609,188
29,825
220,806
258,991
194
83,851
93.019
8.351
Percentage
of the Total
TWPE Load
51%
6%
3%
1%
0.27%
0.11%
23.1%
20.6%
19.4%
6.7%
4.9%
3.3%
3.3%
2.8%
84.9%
5.3%
3.5%
2.2%
'Discharged annual loading from the TDD represents loading before application of the final regulations.
2Benzo(a)pyrene is a regulated pollutant; PACs as a group are not regulated. The TWF for benzo(a)pyrene was used
as a representative toxic weighting factor (TWF) for the PACs category to calculate TWPE.
3Cadmium is a regulated pollutant; cadmium compounds as a group are not regulated.
5-22
-------
Section 5 - Existing Industry Review
Based on the 2000 PCS data, vanadium and benzo(a)pyrene are the top pollutants
of concern for the NFM manufacturing industry. Vanadium is not currently a regulated
pollutant, and benzo(a)pyrene is regulated under the Primary Aluminum Smelting Subcategory.
Based on the 2000 TRI data, PACs are the pollutants of greatest concern and would include
benzo(a)pyrene.
The pollutants generated by facilities in this category vary by sub category and
process. For this analysis, PCS and TRI data are available at the 4-digit SIC code level. Table
5-17 lists the pollutants with the highest total TWPE by SIC code from TRIReleases2000 for
both direct and indirect dischargers. Table 5-18 presents the same information for
PCSLoads2000 for major direct dischargers. EPA analyzed wastewater characterization data at
the subcategory and segment levels for the 1990 rule, however, and are available in the
supporting TDD (1).
Table 5-17. Pollutants of Concern Identified in TRIReleases2000
(Direct and Indirect Dischargers)
SIC Code
2819
3331
3334
3339
3341
Pollutant
Mercury
Silver Compounds
Arsenic Compounds
Selenium Compounds
Cadmium Compounds
Lead Compounds
Polycyclic Aromatic
Compounds
Vanadium Compounds
Sodium Nitrite
Cadmium Compounds
Vanadium Compounds
Phosphorus (yellow or white)
Number of
Facilities
Reporting
Discharge
1
2
2
1
2
2
4
1
1
2
2
2
Pounds
of
Pollutant
4
257
258
750
257
257
194
60,260
93,019
7,852
23,336
401
TWPE
468
4,228
894
840
670
575
831,011
37,495
34,727
20,510
14,520
6,648
Percentage of
TWPE (SIC Code)
99
52
11
10
8
7
99
49
45
36
26
12
5-23
-------
Section 5 - Existing Industry Review
Table 5-18. Pollutants of Concern Identified in PCS Database (Direct Dischargers)
SIC Code
2819
3331
3334
3339
3341
Pollutant
Aluminum (Total)
PCBs
Cadmium (Total Recoverable)
Cadmium (Total)
Zinc (Total Recoverable)
Zinc (Dissolved)
Lead (Total Recoverable)
Benzo(a)pyrene
Chlorine (Total Residual)
Vanadium (Total)
Chlorine (Free Available)
PCBs
Vanadium (Total)
No. Facilities
Reporting
Discharge
1
1
1
1
1
2
1
8
12
2
1
1
1
Pounds of
Pollutant
9,158
0.035
147
143
4.434
4,285
79
21
167,184
142,237
29,825
2.2
19,428
TWPE
591
455
383
374
207
200
176
89,743
81.416
88.503
14,524
28,725
12,088
Percentage of
TWPE
(SIC Code)
38
29
27
26
15
14
12
37
33
65
11
57
24
5.3.2.4
Treatment Technologies
The 1990 rule based limitations on zero discharge for 3 of 31 subcategories. EPA
based limitations for the remaining 28 subcategories on a variety of technologies, including oil
skimming, chemical precipitation, sedimentation, and filtration. EPA based ammonia limitations
on steam stripping for nine subcategories and on air stripping for the Secondary Molybdenum
and Vanadium subcategory. Cyanide limitations were based on cyanide precipitation for four
subcategories and molybdenum limitations were based on iron co-precipitation for three
subcategories.
Table 5-19 presents the estimated reduction in pollutant loadings from raw
wastewater to discharge based on the data in the 1989 TDD (1). These data indicate that the
current treatment in the industry should be resulting in 99+ percent reductions for those
pollutants regulated in the 1990 rule.
5-24
-------
Section 5 - Existing Industry Review
Table 5-19. NFM Manufacturing Category Pollutant Reductions
Pollutant Group Name
TDD Percent Removal
Direct Dischargers
Total Conventional Pollutants
Total Nonconventional Pollutants
Ammonia
Vanadium
Total Priority Pollutants
Benzo(a)pyrene
99.3%
99.7%
99.8%
99.7%
99.7%
99.7%
Indirect Dischargers
Total Conventional Pollutants
Total Nonconventional Pollutants
Ammonia
Vanadium
Total Priority Pollutants
Benzo(a)pyrene
99.8%
99.2%
NA
NA
99.9%
NA
Source: EPA, 1989 TDD.
NA - Not available.
Table 5-20 presents the treatment technologies most commonly used by NFM
manufacturing facilities reporting to TRI for 2000.
Table 5-20. Wastewater Treatment Operations Reported By NFM Manufacturing
Facilities, TRI Reporting Year 2000
Wastewater Treatment Process
Chemical Precipitation
Filtration
Settling/Clarification
Neutralization
Sludge Dewatering (Nonthermal)
Equalization
Stripping - Air or Steam
Adsorption
General Oxidation (including disinfection)
Number of Facilities Reporting Use
Direct
(35 Facilities)
33
22
25
16
9
7
5
4
4
Indirect
(27 Facilities)
30
21
15
12
6
4
3
4
3
Source: Section 7A Table of the TRI 2000 Database.
5-25
-------
Section 5 - Existing Industry Review
The information on treatment technologies indicates that facilities reporting to
TRI in 2000 continued to use technologies that formed the basis of the final rule but also used
additional technologies, including adsorption, biological treatment, and chemical oxidation.
Over 50 percent of the NFM manufacturing facilities reporting to the 2000 TRI
are zero dischargers. It is unknown whether there are best management practices (BMPs),
pollution prevention practices, or other "dry" operations from these facilities that could be
transferrable to other discharging facilities in similar subcategories. In addition, metals removal
for this industry may be improved using multiple-stage metals precipitation or newer multimedia
filtration followed by chemical precipitation technologies.
5.3.2.5 Conclusions
The NFM manufacturing industry ranks high in estimated toxic pollutant
discharges among the industrial categories investigated in EPA's screening-level analyses.
These discharges are based on data reported to PCS and TRI. About half (54 percent) of the
facilities classified in these SIC codes (using 1997 Economic Census data) provided chemical
release data in TRI, while only 13 percent are major dischargers reporting surface water
discharges in PCS.
Based on the 2000 TRI data, EPA attributes most of the reported loading, made
up of PACs such as benzo(a)pyrene, to six facilities. From the data available in PCS,
benzo(a)pyrene, vanadium, and chlorine (total residual) appear to be the pollutants of greatest
concern based on TWPE discharges.
Concentration data from PCS (for the 2000 reporting year) indicate that current
discharges of benzo(a)pyrene are generally below 0.01 mg/1 for those facilities reporting its
discharge. These concentrations are generally below treatable concentrations and additional
reductions of this pollutant may not be possible.
The information from both PCSLoads2000 and TRIReleases2000 also indicate
that the pollutants of concern (by SIC code) are, in most cases, being discharged by only one or
two facilities. Therefore, while additional study of this industry is warranted based on the toxic
loads discharged, the need for revised national regulations may not be warranted due to the
number of facilities involved.
TRI data indicate a significant percentage (>50 percent) of facilities in this
industry are zero dischargers. However, data are not currently available to assess whether the
processes and BMPs used by the zero discharge facilities can be transferred to other facilities
that discharge similar subcategory wastewaters. The last data collection effort for this industry
occurred in the 1980s, and additional study of this industry would help EPA determine whether
facilities can achieve additional reductions in the pollutants with the highest toxic pounds by
applying existing BMPs or newer technologies. Therefore, EPA will continue to review this
industry in the next planning cycle.
5-26
-------
Section 5 - Existing Industry Review
5.3.2.6 References
1. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category,
Volume I. EPA-440/1 -89/019.1. Washington, D.C. May 1989.
2. U.S. Census Bureau. 1997Economic Census.
3. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category,
Volume II. EPA-440/1-89/019.2. Washington, D.C. May 1989.
4. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source Category,
Volume III. EPA-440/1-89/019.3. Washington, D.C. September 1986.
5.4 Group III Industries
This section provides information on the limited investigations EPA conducted on
the Group III industries. During its screening-level review, EPA identified this group of
industrial point source categories as having relatively high estimates of potential toxic-weighted
pollutant discharges. However, EPA also identified numerous data gaps and issues that may
affect the Agency's estimate of the potential hazard posed by discharges from these categories.
EPA's review of these categories focused on filling in these data gaps to better inform EPA's
decision-making. These categories are: Fertilizer Manufacturing (Part 418), Phosphate
Manufacturing (Part 422), Ore Mining and Dressing (Part 440), Pulp and Paper (Part 430) Phase
II, Steam Electric Power Generation (Part 423), Textile Mills (Part 410), and Timber Products
Processing (Part 429).
5.4.1 Fertilizer and Phosphate Manufacturing (Parts 418 and 422)
The fertilizer manufacturing and phosphate manufacturing industries ranked high
in terms of toxic and nonconventional pollutant discharges among industrial point source
categories investigated in the screening-level analyses. Because of the potential for overlap of
operations between these two point source categories, EPA evaluated the SIC codes related to
these industries and the specific facilities to better classify facilities that perform fertilizer
manufacturing operations versus phosphate manufacturing operations. EPA found that one
facility contributes over 99 percent of the toxic-weighted load from phosphate manufacturing,
and that fluoride discharges account for over 99 percent of that facility's discharge. EPA also
found that one facility contributes 84 percent of the toxic-weighted load from fertilizer
manufacturing and that fluoride discharges account for over 75 percent of that facility's
discharge. This section summarizes the review of both point source categories.
5-27
-------
Section 5 - Existing Industry Review
5.4.1.1
Industry Description
The fertilizer manufacturing industry includes facilities that produce phosphorus-
and nitrogen-based fertilizers. EPA divided the Fertilizer Manufacturing Point Source Category
into seven subcategories based on the type of fertilizer produced. ELGS found in 40 CFR Part
418 are applicable to process wastewater and contaminated nonprocess wastewater discharged
from the specific subcategories listed in Table 5-21. Facilities subject to this point source
category typically report under SIC codes 2873 (Nitrogenous Fertilizers), 2874 (Phosphatic
Fertilizers), and 2875 (Fertilizers, Mixing Only).
Table 5-21. Subcategories in the Fertilizer Manufacturing Point Source Category
(Part 418)
Subpart
A
B
C
D
E
F
G
Title
Phosphate Subcategory
Ammonia Subcategory
Urea Subcategory
Ammonium Nitrate
Subcategory
Nitric Acid Subcategory
Ammonium Sulfate Production
Subcategory
Mixed Blend Fertilizer
Production Subcategory
Description
Manufacture of sulfuric acid by sulfur burning, wet-process
phosphoric acid, normal superphosphate, triple superphosphate,
and ammonium phosphate.
Manufacture of ammonia.
Manufacture of urea.
Manufacture of ammonia nitrate.
Production of nitric acid in concentrations up to 68 percent.
Production of ammonium sulfate by the synthetic process and by-
coke oven by-product recovery.
Production of mixed1 and blend2 fertilizer.
'Mixed fertilizer means "a mixture of wet and/or dry straight fertilizer material, mixed fertilizer materials, fillers and
additives prepared through chemical reaction to a given formulation."
2Blend means "a mixture of dry straight, and mixed fertilizer materials.'1
The phosphate manufacturing industry includes facilities that produce
phosphorus-related products. EPA divided the Phosphate Manufacturing Point Source Category
into six subcategories based on the type of product. ELGS found in 40 CFR Part 422 are
applicable to process wastewater and contaminated nonprocess wastewater discharged from the
specific subcategories listed in Table 5-22. Facilities subject to this point source category
typically report under SIC codes 2874 and 2819 (Industrial Inorganic Chemicals, not elsewhere
classified).
5-28
-------
Section 5 - Existing Industry Review
Table 5-22. Subcategories in the Phosphate Manufacturing Point Source Category
(Part 422)
Subpart
A
B
C
D
E
F
Title
Phosphorus Production
Subcategory
Phosphorus Consuming
Subcategory
Phosphate Subcategory
Defluorinated Phosphate Rock
Subcategory
Defluorinated Phosphoric Acid
Subcategory
Sodium Phosphates Subcategory
Description
Production of phosphorus and ferrophosphoras by smelting of
phosphate ore.
Manufacture of phosphoric acid, phosphorus pentoxide,
phosphorus pentasulfide. phosphorus trichloride, and
phosphorus oxychloride directly from elemental phosphorus.
Manufacture of sodium tripolyphosphate. animal feed grade
calcium phosphate, and human food grade calcium phosphate
from phosphoric acid.
Defluorination of phosphate rock by applying high temperature
treatment along with wet process phosphoric acid, silica, and
other reagents (not in manufacturing).
Defluorination of phosphoric acid. Wet process phosphoric acid
is dehydrated by applying heat and other processing acids such
as vacuum and air stripping. The acid is concentrated up to
70-73% P2 O5 in the defluorination process.
Manufacture of purified sodium phosphates resulting from wet
process phosphoric acid.
During EPA's initial screening-level review, facilities that reported SIC code
2874 (Phosphatic Fertilizers) were included as part of both the Fertilizer Manufacturing category
and the Phosphate Manufacturing category. This resulted in double counting of the pollutant
loads discharged by these facilities. EPA further reviewed operations at the top dischargers in
SIC code 2874 to determine which category is most appropriate for their operations. Table 5-23
summarizes this review.
Similarly, facilities that reported SIC code 2819 were included as part of both the
Phosphate Manufacturing category and the Inorganic Chemicals Manufacturing category. EPA
further reviewed operations at the top dischargers in SIC code 2819 and confirmed that all
operations were related to inorganic chemicals manufacturing. For the purposes of this review
(and to avoid double counting pollutant loads), EPA then removed all facilities reporting SIC
code 2819 from the Phosphate Manufacturing category, although it is possible some of these
facilities also fall under the applicability of phosphate manufacturing.
5-29
-------
Section 5 - Existing Industry Review
Table 5-23. Review of Top Fertilizer and Phosphate Dischargers Reporting SIC 2874 as
Primary SIC Code
Facility
IMC Phosphates,
Uncle Sam, LA
Mississippi
Phosphates Corp..
Pascagoula, MS
Royster-Clark Inc,
Hartsville, SC
Final Category
Designation
Phosphate
Manufacturing
Fertilizer
Manufacturing
Fertilizer
Manufacturing
Description
Produces phosphoric acid and hydrofluoric acid (covered under
Subcategory D. Phosphate Manufacturing) and sulfuric acid by
burning elemental sulfur (covered under Subcategory A, Fertilizer
Manufacturing). This facility contributes over 99 percent of the
toxic -weighted load from phosphate manufacturing, and fluoride
discharges account for over 99 percent of this facility's discharge.
Manufacture of sulfuric acid, phosphoric acid, and diammonia
phosphate (covered under Subcategory A, Fertilizer
Manufacturing).
Facility purchases liquids (such as sulfuric acid or phosphoric acid)
and other by-products and combines them in a rotary drum (covered
under Subcategory G, Fertilizer Manufacturing). A reaction occurs
and the result is granular homogenous fertilizer. Facility says
primary SIC code is 2875.
Source: Facility telephone contact reports (2, 3. 4).
Fertilizer Manufacturing Process Descriptions (Part 418)
This section describes the manufacturing processes included in the Fertilizer
Manufacturing category. It describes processes included in Subcategory A (Phosphate
Fertilizers) to distinguish operations covered under phosphate manufacturing. Fertilizer is
available in both liquid and dry forms, and either as a single type of plant nutrient or a mixed
type. The industry identifies plant food content by the total percentage of nitrogen, phosphoric
acid, and water soluble potassium available in the fertilizer. The production of two basic
fertilizer ingredients, nitrogen (N) and phosphate (P2O5), is covered under Part 418. (1)
Phosphate Fertilizers (Subpart A)
Phosphoric acid (H3PO4) is produced by two commercial methods: wet process
and thermal process. Wet process phosphoric acid is typically used to produce fertilizers and
would then be covered under the Fertilizer Manufacturing category. Thermal process
phosphoric acid is covered under the Phosphate Manufacturing category, and is discussed below.
In a wet process facility, phosphoric acid is produced by reacting sulfuric acid with naturally
occurring phosphate rock. The phosphate rock is dried, crushed, and then continuously fed into
the reactor along with sulfuric acid. The reaction combines calcium from the phosphate rock
with sulfate, forming calcium sulfate (CaSO4), commonly referred to as gypsum. Gypsum is
separated from the reaction solution by filtration. The production of wet process phosphoric acid
generates a considerable quantity of acidic cooling water with high concentrations of phosphorus
and fluoride. (8)
5-30
-------
Section 5 - Existing Industry Review
Sulfuric acid used in manufacturing fertilizers is typically produced at the
phosphate fertilizer manufacturing facility using the contact process. First, elemental sulfur is
burned in a furnace to produce sulfur dioxide, which is further oxidized using a catalyst surface
to speed the oxidation reaction. The resulting sulfur trioxide is hydrolyzed with water to form
sulfuric acid. (1)
Phosphate fertilizers are classified into three groups of chemical compounds.
Two of these groups are known as superphosphates and are defined by the percentage of
phosphorus as phosphorus pentoxide (P2O5). Normal superphosphates contain between 15 and
21 percent phosphorus as P2O5 and are prepared by reacting ground phosphate rock with 65 to 75
percent sulfuric acid. Triple superphosphate contains over 40 percent phosphorus and are
prepared either by the "run-of-pile" process (identical to normal superphosphate, except
phosphoric acid is used instead of sulfuric acid) or the granular triple superphosphate process. In
the granular process, ground phosphate rock or limestone is reacted with phosphoric acid;
however, the phosphoric acid used in this process is appreciably lower in concentration (40
percent P2O5) than that used in the run-of-pile process. The remaining phosphate fertilizer group
is ammonium phosphate (NH4H2PO4), which is produced by reacting H3PO4 with anhydrous
ammonia (NH3). (1)
Nitrogen Fertilizers (Subparts B through F)
NH3 is one of the principal fertilizer materials and can be used directly as a
fertilizer or as a source of nitrogen in other synthetic fertilizers. NH3 is produced by the
chemical reaction of hydrogen with nitrogen. Urea (CO(NH2)2), also known as carbamide,
contains the highest percentage of nitrogen in solids fertilizers. It is produced by reacting
ammonia with carbon dioxide to form ammonium carbamate, which is then dehydrated to form
urea. Nitric acid is produced using anhydrous ammonia, air, water, and a catalyst. Ammonia is
oxidized with air to form nitric oxide, which is further oxidized to form nitrogen dioxide. The
gases are absorbed in water to produce nitric acid and nitric oxide. Ammonium nitrate is
produced by neutralizing ammonia with nitric acid at high temperatures, which evaporates the
water and some ammonia, leaving ammonium nitrate. (1) Synthetic ammonium sulfate is
produced by combining anhydrous ammonia and sulfuric acid in a reactor. Coke oven
by-product ammonium sulfate is produced by reacting the ammonia recovered from coke oven
off-gas with sulfuric acid. (9)
Mixed and Blended Fertilizers (Subpart G)
Mixed fertilizers are a mixture of wet and/or dry straight fertilizer materials,
fillers, and additives prepared through chemical reaction to a given formulation. Blended
fertilizers are a mixture of dry, straight, and mixed fertilizer materials. (1)
Phosphate Manufacturing Process Descriptions (Part 422)
This section describes the manufacturing processes included in the Phosphate
Manufacturing category that have potential overlap with processes covered under the Fertilizer
5-31
-------
Section 5 - Existing Industry Review
Manufacturing category: manufacture of phosphoric acid (Subcategory B) and defluorination of
phosphoric acid (Subcategory D, E).
As discussed above, phosphoric acid (H3PO4) is produced by two commercial
methods: wet process and thermal process. The wet process is typically used to produce
phosphoric acid used in fertilizer manufacture, which is covered under Fertilizer Manufacturing
(Part 418, Subpart A). The thermal process phosphoric acid, covered by Phosphate
Manufacturing (Part 422, Subpart B) is of a much higher purity and is used in the manufacture of
high-grade chemicals, pharmaceuticals, detergents, food and beverage products, and other
nonfertilizer products. Raw materials to produce phosphoric acid by the thermal process are
elemental (yellow) phosphorus, air, and water. Thermal process phosphoric acid manufacture
involves three major steps: combustion, hydration, and demisting.
In combustion, the liquid elemental phosphorus is burned (oxidized) in ambient
air in a combustion chamber at temperatures of 1,650 to 2,760°C (3,000 to 5,000°F) to form
phosphorus pentoxide. The phosphorus pentoxide is then hydrated with dilute H3PO4 or water to
produce strong phosphoric acid liquid (Reaction 3). Demisting, the final step, removes the
phosphoric acid mist from the combustion gas stream before it is released to the atmosphere.
This is usually done with high-pressure drop demistors. (7)
Concentration of H3PO4 produced from thermal process normally ranges from 75
to 85 percent. This high concentration is required for high-grade chemical production and other
non-fertilizer-product manufacturing. Efficient plants recover about 99.9 percent of the
elemental phosphorus burned as phosphoric acid. (7)
Defluorinated phosphate (DFP), also known as tricalcium phosphate (TCP), is
produced from phosphate rock, phosphoric acid, and soda ash. This process, covered under
Subpart D, can be broken down into three sections: feed preparation/mixing, defluorination (by
calcining), and product sizing. Phosphate rock, phosphoric acid, and soda ash are blended in a
batch or continuous mixer/reactor. The material is conveyed to a screening system that excludes
oversize material that is milled and recycled. The product from the screen is sent to storage prior
to feeding into the defluorination system. The second stage reactions take place in a large kiln
(or fluidized bed) where the material is heated to approximately 2,800°F. DFP from the kiln is
discharged through a cooler and cooled by air. The kiln is vented to a scrubber system that must
handle a large load of fluoride vapors. Material from the cooler is transferred to the product-
sizing area where screens, mills, and hoppers are used to classify and store the product prior to
shipping. (9)
Newer processes have been developed to produce high-purity phosphoric acid
using wet process phosphoric acid, covered under Subpart E. This procedure involves
pretreating the feed acid to remove impurities through dearseniation and filtration, solvent
extraction, stripping, reextraction, concentration of the acid, and defluorination (through
stripping). (8)
5-32
-------
Section 5 - Existing Industry Review
Facility Counts
EPA obtained information on the number of facilities in the Fertilizer and
Phosphate Manufacturing categories from three sources: the 1997 U.S. Economic Census, the
TRIReleases2000, and the PCSLoads2000. TRI includes facilities reporting discharges to any
media. In contrast, PCS includes only facilities that are permitted for discharge to surface
waters. Table 5-24 lists the number of facilities from these sources. Approximately half of the
facilities reporting to TRI in these categories collectively report no wastewater discharge of toxic
chemicals.
Table 5-24. Number of Fertilizer and Phosphate Facilities
SIC
Code
1997
Census
2000 PCS
"3
-*j
Ł
0
'c?
s
•_
0
2000 TRI
Total
Reporting
To TRI
No
Reported
Discharge
Direct
Discharge
Indirect
Discharge
Both
Direct and
Indirect
Discharge
Fertilizer Manufacturing
2873
2874
2875
Total
143
NA
449
592
40
1
6
47
25
1
0
26
15
0
6
21
63
2
42
107
21
0
29
50
38
1
8
47
1
0
5
6
3
1
0
4
Phosphate Manufacturing1
2874
Total
61
61
22
22
14
14
8
8
31
31
19
19
12
12
0
0
0
0
NA - Census totals for SIC code 2874 are included under Phosphate Manufacturing. As explained previously, EPA
identified two facilities under this SIC code as part of Fertilizer Manufacturing (see Table 5-23).
'Facilities reporting SIC code 2819 were included in the Inorganic Chemicals Manufacturing Point Source Category.
Fertilizer and phosphate manufacturing facilities are located throughout the
United States, but there is a higher concentration in the Midwest and in the Southeast.
5.4.1.2
Regulatory Background
The current ELGS, summarized in Table 5-25, are codified at 40 CFR Part 418
and 422. Fluoride limitations for Subpart A of Fertilizer Manufacturing and Subparts D and E of
Phosphate Manufacturing are the same. A number of subcategories require zero discharge of
process wastewater pollutants, with some exceptions.
ELGS for the Fertilizer Manufacturing category are based on a combination of
process changes, best management practices, and end-of-pipe technologies. For phosphate
fertilizers (Subpart A), the primary source of contaminated process and nonprocess wastewater
5-33
-------
Section 5 - Existing Industry Review
discharged is overflow from gypsum ponds. Effluent concentrations are based on double lime
neutralization of the pond water to reduce fluoride and phosphorus, and ponds designed to hold
precipitation from a 10-year, 24-hour rainfall event (for BPT) or a 25-year, 24-hour rainfall event
(for BAT). EPA considered, but did not promulgate, ammonia limits. Ammonia primarily
occurs from equipment wash water. Ammonia concentrations can range from 25 to over 600
mg/L in gypsum ponds.
For nitrogen fertilizers (Subparts B through E), mass-based limitations are based
on application of best management practices (including containment and reuse), ammonia steam
stripping, hydrolysis, and oil/water separators. More stringent limitations are also based on
process changes and other end-of-pipe technologies, including air stripping, biological
nitrification/denitrification, and ion exchange.
For ammonium sulfate (Subpart F) and mixed and blended fertilizers (Subpart G),
zero discharge limitations are based on manufacturing process controls, complete recycle and
reuse of wastewaters, and dry air pollution control devices.
ELGS for the Phosphate Manufacturing category are based primarily on end-of-
pipe treatment technologies. Similar to Subpart A of the Fertilizer Manufacturing category, the
primary source of process and nonprocess wastewater discharged from facilities in Subparts D
and E of the Phosphate Manufacturing category is overflow from containment and cooling
ponds. Effluent concentrations limits are based on lime neutralization of cooling pond water,
and ponds are designed to hold precipitation from a 10-year, 24-hour rainfall event (for BPT) or
a 25-year, 24-hour rainfall event (for BAT).
For Subpart F, ELGS are based on double lime neutralization used to remove
TSS, phosphate, radium-226, and fluoride. This process can lower fluoride levels from 9,000
mg/L to about 30 mg/L, and phosphorus levels from 6,500 mg/L to about 60 mg/L. (11) In some
cases, modified forms of phosphate may be present in certain wastewaters, which can hinder the
lime neutralization process. These wastewaters should undergo a hydrolysis pretreatment step.
(11)
Table 5-25. Pollutants Regulated by Existing Fertilizer and Phosphate ELGS
Subpart
BPT
BAT
NSPS
PSES & PSNS
Mass- or
Concentration-
Based Limits
Fertilizer Manufacturing
A1
B
Total phosphorus
Fluoride
TSS (process
wastewater only)
Ammonia
pH
Total phosphorus
Fluoride
Ammonia
Same as BPT
Ammonia
pH
No discharge of
incompatible
process
wastewater
pollutants
PSNS set equal to
NSPS
Concentration-
based
Mass-based
5-34
-------
Section 5 - Existing Industry Review
Table 5-25 (Continued)
Subpart
C
D
E
F
G
BPT
Ammonia
Organic N
Ammonia
Nitrate (as N)
Ammonia
Nitrate (as N)
No discharge of
process
wastewater
pollutants
No discharge of
process
wastewater
pollutants
BAT
Ammonia
Organic N
Ammonia
Nitrate (as N)
Ammonia
Nitrate (as N)
No discharge of
process wastewater
pollutants
No discharge of
process wastewater
pollutants
NSPS
Same as BAT
Same as BAT
Same as BAT
No discharge of
process wastewater
pollutants
No discharge of
process wastewater
pollutants
PSES & PSNS
PSNS set equal to
NSPS
PSNS set equal to
NSPS
PSNS set equal to
NSPS
PSNS:
Ammonia (as N)
PSNS:
Ammonia (as N)
Total phosphorus
Nitrate (as N)
Mass- or
Concentration-
Based Limits
Mass-based
Mass-based
Mass-based
Concentration-
based
Concentration-
based
Phosphate Manufacturing
A2
B2
C2
D2'3
E3
F
None
None
None
Total phosphorus
Fluoride
TSS
pH
Total phosphorus
Fluoride
TSS
pH
Total phosphorus
Fluoride
TSS
pH
None
None
None
Total phosphorus
Fluoride
Total phosphorus
Fluoride
Total phosphorus
Fluoride
None
None
None
Same as BPT
Same as BPT
Total phosphorus
Fluoride
TSS
pH
None
None
None
None
TDD says
reserved: nothing
inCFR
None
TDD says
reserved; nothing
inCFR
None
TDD says
reserved; nothing
inCFR
Concentration-
based
Concentration-
based
Mass-based
Source: Code of Federal Regulations, .
'Subpart A: No discharge except calcium sulfate storage pile runoff. BPT = 10-year, 24-hour rainfall event and
BAT = 25-year, 24-hour rainfall event.
2Subcategories A-C have applicability defined in the regulation. However, there are no limitations or standards.
3Subparts D-E: No discharge of process wastewater except for cooling water recirculation systems designed,
constructed, and operated to maintain surge capacity equal to the runoff from the 10-year, 24-hour rainfall event
(BPT) (25-year for BAT).
5-35
-------
Section 5 - Existing Industry Review
5.4.1.3
Wastewater Characteristics and Pollutant Sources
This section presents wastewater sources and characteristics as determined from
TRI and PCS data.
Wastewater Discharge
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-26 presents the total annual flow (in millions of gallons per year (MGY)) for 2000, median
annual discharge flow, and the range of annual flows for fertilizer and phosphate facilities.
Facilities not reporting a flow were not included in the median calculation. Data presented in
Table 5-26 are based on major dischargers reporting to PCS for 2000. One facility in each
category accounts for the majority of total flow reported for each point source category.
Table 5-26. 2000 Wastewater Flows for Fertilizer and Phosphate Facilities
Point Source Category
Fertilizer Manufacturing
Phosphate Manufacturing
Number of Major
Facilities Reporting
Nonzero Flows
24
11
Median
Facility Flow
2000 (MGY)
394
291
Range of Facility
Flows 2000
(MGY)
26 - 703,349
3 - 62,856
Total Flow
2000 (MGY)
912,489
99,827
Source: PCSLoads2000.
Pollutants
Table 5-27 lists the pollutants reported to PCS, which account for 95 percent of
the total TWPE for fertilizer and phosphate manufacturing facilities that reported discharges to
PCS by major dischargers for 2000. Table 5-28 lists the pollutants reported to TRI as discharged
directly or indirectly, which account for 95 percent of the total TWPE for fertilizer and
phosphate manufacturing facilities that reported to TRI for 2000. This table presents the number
of facilities that reported each chemical, total pounds of chemical discharged, and total TWPE
for each chemical. Note that information provided in Tables 5-27 and 5-28 reflect information
as reported to TRI or PCS.
The pollutant contributing most of the TWPE from phosphate manufacturing
facilities is fluoride. Fluoride is a component of phosphate rock, used in the production of
phosphoric acid. The vast majority of fluoride (>99 percent) reported discharged in 2000 came
from one facility covered under Subpart D, Deflourinated Phosphate Rock. This facility is in
compliance with their current NPDES permit and discharges fluoride in once-through cooling
water and stormwater at concentrations of about 50 to 60 mg/L1.
'BAT limitations for fluoride discharges from cooling water recirculation systems are 75 mg/L daily maximum and
25 mg/L monthly average.
5-36
-------
Section 5 - Existing Industry Review
Table 5-27. Fertilizer and Phosphate Pollutant Discharges Reported by Major Facilities to
PCS for 2000
Pollutant
Number of
Facilities
Reporting
PCS Total
(Ibs/yr)
PCS
TWPE/yr
Median
Facility
TWPE/yr
Range of
Facility
TWPE/yr
Percentage
of Total SIC
Code TWPE
Cumulative
Percentage
of Total SIC
Code TWPE
Fertilizer Manufacturing
Fluoride. Total (as F)
Aluminum, Total (as Al)
Iron, Total (as Fe)
Nitrogen. Ammonia
Total (as N)
Totals
3
1
1
25
26
2.188.701
346,681
1,631,865
3,483,296
508,665,081
76,605
22,357
9,138
6,375
116,464
2330
NA
NA
90
90-74.184
NA
NA
0.4- 1,595
66%
19%
8%
5%
66%
85%
93%
98%
Phosphate Manufacturing
Fluoride. Total (as F)
Total
14
14
31,243,823
110,978,734
le+06
le+06
255
14- 1,080,892
99.8%
99.8%
Source: EPA, PCSLoads2000.
NA - Not applicable; only one facility reported this pollutant.
Table 5-28. Fertilizer and Phosphate Chemical Releases to Surface Water Reported to TRI
for 2000
Pollutant
Number of
Facilities
Reporting
TRI Total
(Ibs/yr)
TRI
TWPE/yr
Median
Facility
TWPE/yr
Range of
Facility
TWPE/yr
Percentage
of Total SIC
Code TWTE
Cumulative
Percentage
of Total SIC
Code TWPE
Fertilizer Manufacturing
Chromium Compounds
Dioxin and Dioxin-like
Compounds1
Copper Compounds
Chlorine
Manganese Compounds
Zinc Compounds
Ammonia
Totals
2
2
11
9
7
13
48
107
14,030
0.01
3.011
3,725
24,056
33,523
522.929
5,498,199
7,181
6,626
1,888
1.814
1.694
1,567
787
22,566
3,591
3,313
160
67
18
12
4.1
10-7,171
384 - 6,242
3-754
2-519
0- 1.414
0-796
0-83
329-6
29%
8%
8%
8%
7%
3%
329-6
61%
709-6
78%
85%
92%
96%
Phosphate Manufactumig
Ammonia
Zinc Compounds
Manganese Compounds
Total
12
1
1
31
15,113
105
66
18,427
22.8
4.9
4.7
32.5
0.4
NA
NA
<1 - 12
NA
NA
709-6
15%
14%
709-6
85%
99%
Source: EPA, TRIRelease.?2000.
NA - Not applicable; only one facility reported this pollutant.
1 EPA estimated the TWPE for dioxin using the congener distributions reported to TRI. For facilities that did not report a distribution, EPA used
an average distribution reported by facilities in this point source category.
5-37
-------
Section 5 - Existing Industry Review
The primary pollutants contributing most of the TWPE for fertilizer
manufacturing facilities include fluoride, metal compounds, ammonia, and dioxin and dioxin-
like compounds. With the exception of ammonia, these pollutants are reported as discharged by
a few facilities. Ammonia was discharged by over half of the facilities in PCS and nonzero
dischargers reporting to TRI. The primary pollutants contributing to the TWPE as reported to
TRI are metal pollutants and dioxin and dioxin-like compounds. Over half of the TWPE
reported is attributed to a few facilities. Note that 2000 was the first year that facilities were
required to report dioxin discharges to TRI. Based on information from this review, many
facilities report dioxin discharges at a concentration equal to half of the method detection limit
and most do not sample their effluents for dioxin.
5.4.1.4
Pollutant Prevention and Treatment Technology
Table 5-29 lists the treatment technologies most commonly used by fertilizer and
phosphate manufacturing facilities reporting to TRI for 2000.
Table 5-29. Wastewater Treatment Operations Reported By Fertilizer and Phosphate
Manufacturing Facilities, TRI Reporting Year 2000
Wastewater Treatment
Process
Neutralization
Equalization
Settling/Clarification
Biological Treatment
Steam Stripping
Other Chemical Treatment
Oil Skimming
Chemical Precipitation - Lime or
Sodium Hydroxide
Other Physical Treatment
Other Treatment
Number of Fertilizer Facilities Reporting Use
Direct Dischargers
(22 facilities)
9
6
4
6
4
o
J
3
1
2
3
Indirect Dischargers
(1 facility)
1
1
1
-
-
-
1
-
-
-
Number of Phosphate
Facilities Reporting Use
Direct Dischargers
(5 facilities)
2
-
2
-
-
1
-
2
-
2
Source: EPA. Section 7A Table of the TRI 2000 Database.
5-38
-------
Section 5 - Existing Industry Review
5.4.1.5 Industry Trends
The Census Bureau released preliminary results of the 2002 economic census on a
subsector basis. The Chemical Manufacturing subsector, classified under North American
Industrial Classification System (NAICS) code 325, includes establishments that manufacture
basic chemicals and establishments that transform organic and inorganic raw materials by a
chemical process and formulate the materials into intermediate and end products. This NAICS
subsector includes:
• Basic chemical manufacturing;
• Resin, synthetic rubber, and artificial and synthetic fibers and filaments
manufacturing;
• Pesticide, fertilizer, and other agricultural chemical manufacturing;
• Pharmaceutical and medicine manufacturing;
• Paint, coating, and adhesive manufacturing;
• Soap, cleaning compound and toilet preparation manufacturing; and
• Other chemical product manufacturing.
Thus, NAICS code 325 includes more than just the fertilizer and phosphate manufacturing
industries. The trends shown below over the period 1997 - 2002 represent the entire subsector
and may not be comparable for the fertilizer and phosphate manufacturing industries. Chemical
manufacturing sales increased over the five-year period while the number of establishments
declined, and employment dropped by 10 percent.
Trends in U.S. Chemical Manufacturing Industry
Establishments
Sales
Paid Employees
1997
13,474
$4 15 billion
883 thousand
2002
13,107
$427 billion
790 thousand
Source: 2002 Economic Census, http://www.census.gov/econ/census02/advance/TABLE2.HTM.
5.4.1.6 Stakeholder and EPA Regional Issues
During EPA's outreach effort, some stakeholders suggested that the fertilizer
manufacturing ELGS are outdated and do not seem to be sufficiently stringent. During previous
outreach efforts, stakeholders in Oklahoma noted concerns related to ammonia discharges in this
5-39
-------
Section 5 - Existing Industry Review
industry. Based on the information presented in Section 5.4.1.3 concerning wastewater
discharges, EPA concludes that only a few facilities discharge the majority of TWPE load from
these industries. However, ammonia was discharged by over half of the facilities in PCS and
nonzero dischargers reporting to TRI.
5.4.1.7 Conclusions
Pollutants with the highest TWPE reported to TRI and PCS for 2000 are fluoride,
metal compounds, ammonia, dioxin, and dioxin-like compounds for fertilizer manufacturing
facilities and fluoride for phosphate manufacturing facilities.
For phosphate manufacturing, a single facility, which is in compliance with its
permit limits, contributes greater than 99 percent of the reported fluoride discharges.
Consequently, based on the information available at this time, EPA concludes the phosphate
manufacturing ELGs do not need additional study at this time.
For fertilizer manufacturing, with the exception of ammonia, only a few facilities
contribute the majority of the TWPE. Over half of the facilities in PCS and nonzero dischargers
reporting to TRI reported discharging ammonia. EPA plans to further evaluate its methodology
for considering ammonia and nitrogen compound discharges.
5.4.1.8 References
1. U.S. EPA. Industrial Technology Division Rulemaking Summary, Category:
Fertilizer Manufacturing, 40 CFR Part 418. Washington, D.C. No Date.
2. Telephone conversation with Russell G. Oliver of IMC Phosphates, Uncle Sam,
LA, and Bob Southworth of ERG. "SIC Code for Uncle Sam and Faustina
Facilities." November 18, 2003.
3. Telephone conversation with Jim Smith of Mississippi Phosphate Corp,
Pascagoula, MS, and Arash Hooshangi of ERG. "Clarification of Manufacturing
Processes and Pollutant Discharges." January 16, 2004.
4. Telephone conversation with Billy Pirkle of Royster-Clark, Hartsville, SC, and
Arash Hooshangi of ERG. "Clarification of Manufacturing Processes and
Pollutant Discharges." January 16, 2004.
5. Australian Government. Emission Estimation Technique Manual for Inorganic
Chemicals Manufacturing, Version 2.0. Department of the Environment and
Heritage. 2004. Available online at: http://www.npi.gov.au/handbooks/
approved handbooks/pubs/inorganic-chemical.pdf
5-40
-------
Section 5 - Existing Industry Review
6. Australian Government. Emission Estimation Technique Manual for Ammonium
Sulfate Manufacturing, Version 2.0. Department of the Environment and
Heritage. 2004. Available online at: http://www.npi.gov.au/handbooks/
approved_handbooks/pubs/fammsulfpdf
7. U. S. EPA. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition,
Volume I: Stationary Point and Area Sources, Chapter 8: Inorganic Chemical
Industry. Washington, D.C. 1988. Available online at:
http ://www. epa. gov/ttn/chief/ap42/ch08/.
8. Vichem. "Phosphoric Acid Purification." 2004. Available online at:
http://www.vichem.fr/apurifacidphos.htm
9. KEMWorks Technology, Inc. Animal Feed Ingredients: Defluorinated
Phosphate Rock (DFP). 2004. Available online at:
http://www.kemworks.com/Animal_Nutrition.htm
10. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Phosphorus Derived Chemicals Segment
of the Phosphate Manufacturing Point Source Category. EPA-440/1 -74-006-a.
Washington, D.C. January 1974.
11. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Other Non-Fertilizer Phosphate
Chemicals Segment of the Phosphate Manufacturing Point Source Category.
EPA-440/l-75/043-a. Washington, D.C. June 1976.
12. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. EPA-440/1 -74-011 -a.
Washington, D.C. March 1974.
13. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Formulated Fertilizer Chemicals Segment
of the Fertilizer Manufacturing Point Source Category. EPA-440/1 -75/042-a.
Washington, D.C. January 1975.
5.4.2 Ore Mining and Dressing
5.4.2.1 Industry Description
Regulations in 40 CFR Part 440 for the Ore Mining and Dressing Point Source
Category apply to discharges from facilities that are engaged in the mining, milling, or preparing
of 23 separate metal ores. Metal ore mining is conducted by a variety of methods, such as
5-41
-------
Section 5 - Existing Industry Review
surface mining, underground mining, and in situ mining. Surface mining operations include
quarrying, open pit, open cut, open cast, stripping, placarding, and dredging. Underground
mining, which is used primarily for lead and zinc ores, is carried out through shafts. In situ
mining, or solution mining, includes leaching of uranium and copper. Metals are separated from
less valuable material (gangue) in milling processes. Methods of extraction include gravity
concentration, magnetic separation, electrostatic separation, floatation, and leaching. Leaching
involves processes such as amalgamation, cyanidation, solvent extraction, and ion exchange.
Chemicals used in separation processes, in particular the reagents used in froth floatation, are the
primary source of toxic organic pollutants for this industry. This industry is divided into nine
SIC codes, as shown in Table 5-30.
EPA obtained information on the number of facilities in the Ore Mining and
Dressing category from three sources: the 1997 U.S. Economic Census, the TRIReleases2000,
and PCSLoads2000. Table 5-30 lists the number of ore mining and dressing facilities by SIC
code from these sources. The number of facilities reporting to TRI for 2000 represent only about
14 percent of the ore mining and dressing industry based on the total number of facilities in the
census, while the number of major dischargers reporting to PCS represent about 11 percent of
the number of facilities in the census.
Table 5-30. Number of Ore Mining and Dressing Facilities
SIC Code
10 11 Iron Ores
1021 Copper Ores
103 1 Lead and Zinc Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores
1081 Metal Mining Services
1 094 Uranium-Radium-Vanadium
Ores
1099 Metal Ores, Not Elsewhere
Classified
Total
1997 U.S.
Economic Census
32
49
31
300
16
NR
203
29
36
696
2000 TRI - All
Dischargers
NA
19
19
40
5
7
NA
NA
6
96 (14%)
2000 PCS
Major
Dischargers
5
11
23
18
1
6
0
10
3
77(11%)
Minor
Dischargers
5
2
6
14
5
1
1
13
4
51 (7%)
Source: U.S. Economic Census, 1997; TRIReleases2000: PCSLoads2000.
NA - Facilities in this SIC code are not required to report to TRI.
NR - No facilities are reported in this SIC code.
Of the 96 ore mining and dressing facilities in TRIReleases2000, Table 5-31
presents the number and percentage of facilities by type of discharge. According to available
5-42
-------
Section 5 - Existing Industry Review
data in TRI 2000, no ore mining and dressing facilities reported both direct and indirect
discharges. Over half of the facilities reporting to TRI indicated no wastewater discharge. Of
those that discharge, almost all are direct dischargers (39 of 41).
Ore mining and dressing facilities are geographically concentrated in the western
states and Alaska.
Table 5-31. Number of Ore Mining and Dressing Facilities by Discharge Type (TRI 2000)
SIC
Code
1021
1031
1041
1044
1061
1099
Total
Direct Dischargers Only
Number
8
18
6
3
2
1
Percentage
of All
Facilities in
SIC Code
42%
95%
15%
60%
43%
17%
39 (41%)
Indirect Dischargers Only
Number
0
0
2
0
0
0
Percentage
of All
Facilities in
SIC Code
0%
0%
5%
0%
0%
0%
2 (2%)
No Reported Wastewater
Discharge
Number
11
1
32
2
4
5
Percentage
of All
Facilities in
SIC Code
58%
5%
80%
40%
57%
83%
55 (57%)
Source: EPA, TRIReleases2000.
Sources of wastewater for ore mining and dressing facilities include:
Spillage from thickeners; lubricants and floatation agents;
Transport water; and
Leaching processes.
5.4.2.2
Regulatory Background
The ELGS for this industry are codified under 40 CFR Part 440. Subcategories
are based on the metal being extracted, the differences between mine and mill wastewater, and
the type of mill process. Climate, rainfall, and location were considered in determining if any
subcategories could achieve zero discharge. Mines located in arid regions can effectively reduce
effluent discharge quantities by evaporation. Other facilities, located in areas with net positive
precipitation or icy conditions, have less control over their discharge volumes.
The final regulation was promulgated in 1982. BPT limitations are based on lime
precipitation and settling. For BAT, EPA also considered adding secondary settling,
flocculation, or granular media filtration as the technology basis. EPA further considered
5-43
-------
Section 5 - Existing Industry Review
secondary settling because it was the least expensive of these three options. EPA analyzed plant
data from facilities using secondary settling, and determined that nationally applicable
regulations based on secondary settling were not necessary for the following reasons:
• BPT removes at least 95 percent of the relevant pollutants;
• The only environmentally significant pollutants remaining after stream
flow dilution are cadmium and arsenic, and no appreciable reduction of
these pollutants was observed with secondary settling; and
• The BPT limitations for the Ore Mining and Dressing category are more
stringent than BAT limitations for other industries in 1982.
BAT ELGS are set at BPT levels for toxic pollutants. The toxic pollutants regulated by BAT for
this industry in at least one subcategory are cadmium, copper, lead, mercury, and zinc. Table
5-32 presents the pollutants regulated by ELGS for each ore mining subcategory.
Process wastewater for this industry includes any water used in the mill or in the
ancillary operations required for beneficiating the ore, and contacting the ore, processing
chemicals, intermediate products, by-products or products of a process, including contact cooling
water.
Table 5-32. Ore Mining and Dressing Pollutants Regulated by Existing Effluent
Limitations Guidelines and Standards
40CFR
Part
440.10
440.20
440.30
440.40
440.50
440.60
440.70
440.80
440.90
Subcategory
Iron Ore
Aluminum Ore
Uranium, Radium, &
Vanadium Ores
Mercury Ore
Titanium Ore
Tungsten Ore
Nickel Ore
Vanadium Ore
Antimony Ore
BPT
TSS, Dissolved Fe,
pH
TSS, Fe, Al, pH
TSS, COD, Zn,
Ra226 (dissolved),
Ra226 (total), U, pH
TSS, Hg, Ni, pH
TSS, Fe, pH, Zn, Ni
TSS, Cd, Cu, Zn, Pb,
As,pH
TSS, Cd, Cu, Zn, Pb,
As,pH
TSS, Cd, Cu, Zn, Pb,
As.pH
Reserved
BAT
Dissolved Fe
Total Fe, Al
COD, Zn, Ra226
(dissolved), Ra226
(total). U
Hg
Fe, Zn
Cd, Cu, Zn
Reserved
Reserved
Reserved
NSPS
TSS, Dissolved Fe, pH
TSS, Fe, Al, pH
TSS, COD. Zn, Ra226
(dissolved), Ra226
(total), U, pH
TSS, Hg, pH
TSS, Fe, pH, Zn
Cd, Cu, Zn, pH, TSS
Reserved
Reserved
Reserved
5-44
-------
Section 5 - Existing Industry Review
Table 5-32 (Continued)
40CFR
Part
440.100
440.110
440.140
Subcategory
Copper. Lead. Zinc. Gold.
Silver. Molybdenum Ores
Platinum Ore
Gold Placer Mines
BPT
TSS, Cu. Zn, Pb. Hg.
Cd.pH
Reserved
Settleable Solids
BAT
Cu. Zn, Pb. Hg. Cd
Cu, Zn, Pb, Hg, Cd
Settleable Solids
NSPS
TSS. Cu, Zn. Pb, Hg.
Cd.pH
Reserved
Settleable Solids
Source: Code of Federal Regulations .
5.4.2.3 Wastewater Characteristics
Of the 77 major facilities reporting to PCS, 57 (74 percent) report information on
discharge outfall flow rates. Table 5-33 presents the total annual flow (in million gallons) for
2000, median annual discharge flow, and range of annual flows for each SIC code. Facilities not
reporting a flow were not included in the median calculation. Data presented in Table 5-33 are
based on major dischargers reporting to PCS for 2000. Iron ore mines (SIC code 1011) had the
largest median facility flow, while copper ores (SIC code 1021) had the lowest median facility
flow. However, for uranium, radium, and vanadium ores (SIC code 1094), 8 of 10 facilities
reported zero flows. The total number of facilities reporting wastewater flows to PCS for 2000
accounts for about 12 percent of the Ore Mining and Dressing industry based on 1997 Economic
Census, and thus may not characterize the entire industry.
Table 5-33. 2000 Wastewater Flows for Ore Mining and Dressing Facilities
SIC
Code
1011
1021
1031
1041
1044
1061
1094
1099
Total
1997 U.S.
Economic
Census
32
49
31
300
16
NR
29
36
493
Number of Major
Facilities Reporting
Nonzero Flows
5
5
20
16
1
5
2
3
57
Median Facility
Flow 2000
(MGY)
2,455
2
350
398
553
732
72
1.372
Range of Facility
Flows (MGY)
2-48,680
0.003-5,051
38-6,548
2-3,797
NA
84-8,096
3-142
275-1,607
Total Flow
2000 (MGY)
1,000,173
351.130
587,837
567,185
553
184,542
5,129
17,732
2,714,281
Source: EPA, PCSLoads2000 and 1997 U.S. Economic Census.
NR - None reported.
Table 5-34 presents the chemicals reported to TRI for 2000 as discharged directly
or indirectly that account for 95 percent of the total TWPE for each SIC code. This table presents
5-45
-------
Section 5 - Existing Industry Review
the number of facilities that reported each chemical, total pounds of chemical discharged for
each SIC code, and total TWPE for each chemical. Iron ore mines, metal mining service
facilities, and uranium-radium-vanadium ore mines (SIC codes 1011, 1081, 1094) are not
required to report to TRI.
Table 5-34. Ore Mining and Dressing Chemical Releases to Surface Water Reported to
TRI for 2000
SIC
Code
1021
1021
1021
1021
1021
1021
1021
1021
1031
1031
1031
1031
1031
1041
1041
1041
1044
1044
1044
1044
1044
1061
1061
Total
Pollutant
Silver Compounds
Copper Compounds11
Arsenic Compounds
Cadmium CompoundsR
Lead Compounds'1
Selenium Compounds
Thallium Compounds
Nickel Compounds
Lead Compounds'1
Manganese Compounds
Copper Compounds1'
Zinc CornpoundsR
Cadmium Compounds'1
Arsenic Compounds
Sodium Nitrite
Copper Compounds'1
Lead Compounds'1
Arsenic Compounds
Silver Compounds
Manganese Compounds
Mercury Compounds"
Lead
Manganese Compounds
Number of
Facilities
Reporting
1
6
1
1
2
1
1
2
11
3
9
17
5
4
1
2
3
2
2
3
1
1
2
41
TRI
Total
(Ibs/yr)
255
1,777
255
255
256
255
255
1,701
6,062
73,700
1,571
21,027
324
4,374
1,955
516
819
326
32
5,122
2
117
654
491,249
TRI
TWPE/yr
4,200
1,114
885
666
573
286
255
185
13,579
5.191
985
983
846
15,175
730
324
1,835
1.131
527
361
234
262
46
52,627
Median
Facility
TWPE/yr
4,200
1,114
885
666
287
286
255
93
571
6
82
35
31
1,993
730
162
591
566
264
106
234
262
23
Range of
Facility
TWPE/yr
NA
NA
NA
NA
2-571
NA
NA
0-185
29-8,590
1-5,184
7-320
0-219
8-713
87-11,102
NA
129-194
34-1,210
212-919
247-280
82-173
NA
NA
0-46
Percentage
of Total SIC
Code
TWPE
49%
13%
10%
8%
7%
3%
3%
2%
61%
23%
4%
4%
4%
89%
4%
2%
43%
27%
12%
9%
6%
82%
14%
Cumulative
Percentage of
Total SIC Code
TWPE
49%
62%
72%
80%
87%
90%
93%
95%
61%
84%
88%
92%
96%
89%
93%
95%
43%
70%
82%
91%
97%
82%
96%
Source: TRIReleases2000.
R- Pollutants that are currently regulated by ELGS.
NA - No range was calculated because only one facility reported a nonzero release.
Information in Table 5-34 shows that for some SIC codes (such as 1021 and
1041) and many of the pollutants listed, the pollutants are primarily attributed to a handful of
discharging facilities. However, of the chemical releases reported to TRI for 2000, the following
5-46
-------
Section 5 - Existing Industry Review
pollutants are the major contributors to the total TWPE (52,627 Ib-eq/yr) for ore mining and
dressing facilities:
• Lead in SIC code 1031 (lead and zinc ores) accounts for 26 percent of the
ore mining TWPE and is discharged by just over half of the facilities
reporting to TRI in this SIC code; and
• Arsenic in SIC code 1041 (gold ores) accounts for 29 percent of the ore
mining TWPE, which is reported as discharge by only 10 percent of
facilities reporting to TRI in this SIC code.
Lead is regulated under 40 CFR Part 440 by BPT and BAT for mining activities
in the following SIC codes:
1021 - Copper ores;
1031 - Lead and zinc ores;
1041 -Gold ores;
1044 - Silver ores; and
1061 - Ferroalloy ores (molybdenum).
In developing the ELGS for the Ore Mining and Dressing category, EPA concluded that
limitations on copper, lead, zinc, and mercury would ensure adequate control of arsenic (1).
Arsenic is, therefore, not specifically regulated under the existing rule.
Table 5-35 lists the pollutants reported to PCS for 2000, which account for 95
percent of the total TWPE for each SIC code.
Table 5-35. Ore Mining and Dressing Pollutant Discharges Reported to PCS for 2000
SIC
Code
1011
1021
1021
1021
1021
1021
1021
Pollutant
Molybdenum, Total (as
Mo)
Copper. Total (as Cu)
Arsenic, Total (as As)
Zinc, Total (as Zn)
Cadmium. Total (as Cd)
Cyanide, Total (as Cn)
Lead, Total (as Pb)
Number
of
Facilities
Reporting
1
3
2
3
4
3
2
PCS Total
(Ibs/yr)
819,646
14,166
576
15,129
196
412
127
PCS
TWPE/yr
165,108
8,881
2,000
707
513
444
285
Median
Facility
TWPE/yr
165,108
4,440
2,000
354
256
444
285
Range of
Facility
TWPE/yr
NA
443-8,438
NA
134-573
227-285
NA
NA
Percentage
of Total
SIC Code
TWPE
96%
67%
15%
5%
4%
3%
2%
Cumulative
Percentage
of Total SIC
Code TWPE
96%
67%
82%
87%
91%
94%
96%
5-47
-------
Section 5 - Existing Industry Review
Table 5-35 (Continued)
SIC
Code
1031
1031
1031
1041
1041
1041
1041
1041
1041
1041
1041
1041
1041
1041
1044
1044
1061
1061
1061
1061
1061
1094
1094
1094
1099
Total
Pollutant
Mercury Total
Recoverable
Cadmium. Total (as Cd)
Lead, Total Recoverable
Arsenic, Total
Recoverable
Manganese, Total
Recoverable
Aluminum, Total
Recoverable
Silver, Total Recoverable
Copper, Total
Recoverable
Cyanide, Weak Acid,
Dissociable
Lead. Total Recoverable
Selenium. Total
Recoverable
Zinc, Potentially
Dissolved
Cadmium, Total
Recoverable
Zinc, Total Recoverable
Arsenic, Total
Recoverable
Copper, Total
Recoverable
Molybdenum, Total {as
Mo)
Fluoride, Total (as F)
Manganese, Potentially
Dissolved
Manganese, Total
Recoverable
Cyanide, Total (as Cn)
Manganese, Total (as Mu)
Selenium, Total (as Se)
Copper. Total
Recoverable
Iron, Total Recoverable
Number
of
Facilities
Reporting
3
15
9
10
6
3
9
11
11
11
9
3
11
11
1
1
3
2
1
3
3
2
9
1
3
77
PCS Total
(Ibs/yr)
641
19,025
5,128
1,083
8,416
5,025
19
485
275
60
105
2,183
28
1,298
11
2
131,433
203,918
93,362
64,645
557
659
40
10
7,508
1 10,515,980
PCS
TWPE/yr
75,044
49,694
11,487
3,757
593
324
312
304
296
135
118
102
73
61
39
1
26,476
7,137
6,567
4,553
600
46
44
7
42
383,560
Median
Facility
TWPE/yr
75,044
17
1,091
164
166
78
53
11
21
8
17
38
3
8
39
1
13,238
3,569
6,576
2,277
600
46
44
7
1.1
Range of
Facility
TWPE/yr
NA
3-49,205
71-4,989
6-1,896
11-250
66-180
18-240
132-304
0-253
1-73
1-41
0-64
0-56
1-23
NA
NA
457-26,018
76-7,062
NA
98-4,455
NA
NA
NA
NA
2-29
Percentage
of Total
SIC Code
TWPE
52%
35%
8%
59%
9%
59/o
5%
5%
5%
2%
2%
2%
1%
1%
93%
2%
56%
15%
14%
10%
1%
47%
45%
7%
100%
Cumulative
Percentage
of Total SIC
Code TWPE
52%
87%
95%
59%
68%
73%
78%
83%
88%
90%
92%
94%
95%
95%
93%
95%
56%
80%
95%
95%
47%
92%
99%
100%
Source: EPA,PCSLoads2000.
NA - No range was calculated because only one facility reported a nonzero release.
5-48
-------
Section 5 - Existing Industry Review
Of the major facility discharges from the Ore Mining and Dressing category, the
following pollutants are the major contributors to the total PCS TWPE (383,560 Ib-eq/yr):
• Molybdenum accounts for 43 percent of the ore mining TWPE and is
discharged by a single facility in SIC code 1011 (Iron Ores);
• Mercury accounts for 20 percent of the ore mining TWPE and is
discharged by approximately 10 percent of the facilities in SIC code 1031
(Lead and Zinc Ores);
• Cadmium accounts for 13 percent of the ore mining TWPE and is
discharged by approximately 56 percent of the facilities in SIC code 1031
(Lead and Zinc Ores); and
• Molybdenum accounts for 7 percent of the ore mining TWPE and is
discharged by 25 percent of the facilities in SIC code 1061 (Ferroalloy
Ores).
Cadmium and mercury are regulated under 40 CFR Part 440 by BPT and BAT in
several sub categories, including the mining activities in the following SIC codes:
1021-Copper Ores;
• 1031 - Lead and Zinc Ores;
1041-Gold Ores;
• 1044 - Silver Ores; and
• 1061 - Ferroalloy Ores (Molybdenum).
Molybdenum was not among the pollutants identified for control in the 1982 Development
Document (1), and thus is not regulated in any ore mining subcategory. Molybdenum has not
been historically regulated in ELGS. Data collected for recent ELGS development for other
industries demonstrates that molybdenum removal requires precipitation and solid/liquid
separation at a pH unique to molybdenum. (3)
Table 5-36 lists the pollutants from Tables 5-34 and 5-35 with the highest TWPE
that are not currently regulated under 40 CFR Part 440.
5-49
-------
Section 5 - Existing Industry Review
Table 5-36. Ore Mining and Dressing Top Pollutants Reported to TRI and PCS for 2000
That Are Not Regulated Under 40 CFR Part 440
Pollutant
Molybdenum
Arsenic
Manganese
Silver
TRI
TWPE/yr
NR3
16,174
5,353
4,315
Percentage
of Total
TRI
TWPE/yr '
NR3
31%
10%
8.2%
PCS
TWPE/yr
191,584
3,796"
6,5785
3126
Percentage
of Total
PCS
TWPE/yr 2
50%
0.99%
1.7%
0.081%
Reason for
Exclusion from
ELGS
Not identified for
control.
Limits on Cu, Pb, Zn,
& Hg effectively
control releases of
this pollutant.
Not identified for
control.
Detected at levels too
low for treatment by
known technologies.
Additional
Information
Only 4 facilities report
discharge of this
pollutant; requires
precipitation at a unique
pH.
Primarily reported in
both TRI and PCS from
SIC code 1041
facilities.
Generally not regulated
in ELGs because it can
be used as a treatment
chemical.
Over97%ofTWPE
reported by a single
facility in SIC code
1021.
Source: Development Document for Effluent Limitations Guidelines and Pretreatment Standard, 1982; TRIReleases2000;
PCSLoads2000.
'The total TWPE for all ore mining and dressing facilities reporting to TRI for 2000 is 52,627 Ib-eq/yr.
2The total TWPE for all ore mining and dressing facilities reporting to PCS for 2000 is 383,560 Ib-eq/yr.
3Molybdenum discharges are not required to be reported to TRI.
4The discharge of arsem'c represents the amount reported to PCS as arsenic, total recoverable.
5The discharge of manganese presents the amount reported to PCS as manganese, potentially dissolved.
6The discharge of silver represents the amount reported to PCS as silver, total recoverable.
EPA also attempted to determine how effective this regulation has been by
comparing previously collected data to the 2000 TRI and PCS data. In 1977, EPA began a series
of sampling and analysis programs to identify pollutants of concern in the ore mining and
dressing industry, placing an emphasis on toxic pollutants. These programs in support to the
existing regulations included:
Screen Sampling Program (20 facilities);
Verification Sampling Program (14 facilities);
Verification Monitoring Program (3 facilities);
EPA Regional Offices Surveillance and Analysis Program (15 facilities);
Cost Site Visit Program (7 facilities);
Uranium Study (5 mines and 5 mills);
Gold Placer Mining Study (11 mines);
Titanium Sand Dredging Mining and Milling Study (3 facilities); and
Solid Waste Study (6 subcategories).
5-50
-------
Section 5 - Existing Industry Review
The results of these nine sampling programs are as follows:
• Out of 129 toxic organic pollutants, 29 were detected in treated
wastewater;
• All 13 toxic metals were detected in wastewater; and
• Cyanide and asbestos were observed in many samples.
Table 5-37 compares the results of wastewater sampling presented in the 1982
Development Document (1) with counts of facilities reporting discharges of the 13 toxic metals
and cyanide to TRI and PCS for 2000. Because only facilities with permit limits report to PCS
and only facilities above thresholds report to TRI, the PCS and TRI counts are minimum
estimates of facilities discharging wastewater containing these metals. No new pollutants were
identified for this industry after reviewing the 2000 TRI and PCS data.
Table 5-37. Toxic Metals in Ore Mining Wastewater
Chemical
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
1982 Development
Document
# Detects / # Samples
6/82
106/114
43/84
54/106
70/85
100/103
24/68
70/86
54/87
70/86
58/84
29/84
3/82
106/106
TRIReleases20001
Number of Facilities
Reporting Chemical
4
7
0
7
5
17
4
15
2
6
2
2
1
23
PCSLoads20002
Number of Facilities
Reporting Chemical
1
6
1
34
5
28
18
24
34
2
13
1
2
38
Source: EPA. Development Document for Effluent Limitations Guidelines and Standards, 1982 (1):
TRIReleases2000;PCSLoads2000.
'96 facilities reported wastewater discharges to TRI for 2000.
277 major dischargers reported to PCS for 2000.
5-51
-------
Section 5 - Existing Industry Review
In general, this information suggests the number of ore mining and dressing facilities discharging
these toxic metals in process wastewater decreased substantially after promulgation of the ore
mining and dressing ELGS.
Stormwater
EPA staff in Region 9 expressed a concern over high concentrations of metals in
active and inactive mine site runoff that are violating water-quality standards. In particular, they
cited arsenic, copper, mercury, and selenium. These discharges are currently considered
industrial stormwater discharges and are not subject to ELGS. EPA analyzed information
reported to TRI to determine if the reported polluted releases originated from stormwater. TRI
requires facilities that monitor stormwater runoff pollutant concentrations to report the
percentage of the total quantity of pollutant released to a receiving stream contributed by
stormwater. Stormwater discharges are reported to Section 5 of TRI as a percentage of a total
stream discharge. Table 5-38 compares the surface water releases of pollutants to the amount of
discharge attributed to stormwater runoff at ore mining and dressing facilities.
Table 5-38. Ore Mining and Dressing Stormwater Discharges Reported to TRI for 2000
SIC
1021
1021
1021
1021
1021
1031
1031
1031
1031
1031
Chemical
Lead
Compounds
Manganese
Compounds
Nickel
Compounds
Zinc
Compounds
Copper
Compounds
Zinc
Compounds
Cadmium
Compounds
Copper
Compounds
Lead
Compounds
Mercury
Compounds
Annual Discharge
Number of
Facilities
Reporting
2
->
3
2
*j
3
6
11
5
9
U
1
Pounds
256
352
1.701
1,917
1,777
21,027
324
1,371
6,062
3
TWPE
573
25
185
90
1,114
983
846
985
13,579
351
Stormwater
Number of
Facilities
Reporting
1
2
1
1
3
8
2
2
I
1
Pounds
1
87
1
97
15
3,037
52
53
70;
0.0003
0
TWPE
2.2
6.1
0.11
4.5
9.4
142
136
34
157
0.035
Percent
Pounds of
Reported
Annual
Discharge
From
Stormwater
0.39%
25%
0.06%
5.0%
0.84%
14%
16%
3.5%
1.2%
0.010%
5-52
-------
Section 5 - Existing Industry Review
Table 5-38 (Continued)
SIC
1041
1061
1061
1061
Chemical
Manganese
Compounds
Lead
Barium
Manganese
Compounds
Annual Discharge
Number of
Facilities
Reporting
5
I
I
2
Pounds
1,298
117
109
654
TWPE
91
262
0.22
262
Stormwater
Number of
Facilities
Reporting
1
1
1
1
Pounds
2
117
109
4
TWPE
0.14
262
0.22
0.28
Percent
Pounds of
Reported
Annual
Discharge
From
Stormwater
0.15%
100%
100%
0.11%
Source: EPA, TRIReleases2000.
Note: Of the 96 facilities that reported surface water discharges, 14 facilities attributed a percentage of their
discharge to Stormwater runoff.
None of the arsenic or selenium releases reported to TRI were identified as
originating from Stormwater. The total mercury TWPE from Stormwater is 0.035 Ib-eq/year,
which accounts for 0.005 percent of the total mercury TWPE reported to TRI by ore mining and
dressing facilities. The total copper TWPE from Stormwater is 42.92 Ib-eq/year, which accounts
for 1.7 of the total copper TWPE reported to TRI by ore mining and dressing facilities. Stream
descriptions are not provided for Stormwater, so it is not possible to determine what percentage
of the discharges are from waste rock and overburden piles. Except for one facility in SIC code
1061 (Ferroalloy Ores), the percentage of reported TWPE/yr identified as Stormwater discharges
was 25 percent or less.
These Stormwater discharges are currently subject to industrial Stormwater
discharge requirements contained in EPA's Multi-Sector General Permit (MSGP) for Industrial
Activities Sector G for Metal Mining. The MSGP establishes benchmark monitoring for
pollutants such as TSS, pH, arsenic, beryllium, cadmium, copper, iron, lead, manganese,
mercury, nickel, selenium, silver, zinc, and uranium. While facilities should be monitoring these
discharges, there is no central repository for these monitoring data. Many mines are subject only
to the Stormwater permit and do not report to TRI or PCS. Consequently, for this review, EPA
does not have adequate information to assess whether or not Stormwater discharges associated
with this industry are a significant source of pollution. Benchmark monitoring information
supplied by the affected states and/or facilities is necessary to evaluate these discharges further.
5-53
-------
Section 5 - Existing Industry Review
5.4.2.4
Pollution Prevention and Treatment Technology
Most direct discharging ore mining and dressing facilities use settling or
precipitation treatment. Of the 41 facilities reporting either direct or indirect discharges to TRI
for 2000, 23 facilities provided information on their wastewater treatment operations. Table
5-39 lists the treatment technologies used by ore mining and dressing facilities reporting to TRI
for 2000.
Table 5-39. Wastewater Treatment Operations Reported By Ore Mining and Dressing
Facilities, TRI Reporting Year 2000
Wastewater Treatment Process
Settling/Clarification
Chemical Precipitation
Biological Treatment
Adsorption
Cyanide Oxidation
Filtration
Other Physical Treatment
Number of Facilities Reporting Use
Direct Dischargers1
(22 facilities)
20
7
4
3
2
2
2
Indirect Dischargers1
(1 facility)
0
0
0
0
1
0
1
Source: EPA. Section 7A Table of the TRI 2000 Database.
'In TPJ 2000, of the facilities that provided information on their wastewater treatment operations, 22 facilities
reported direct releases, 1 reported transfers to POTWs, and no facilities reported both direct releases and transfers
to POTWs.
For this study, EPA did not evaluate any pollution prevention or treatment
methods to control pollutant discharges from stormwater discharges from ore mining and
dressing facilities. However, EPA Region 9 suggests the following should be considered to
control stormwater discharges:
• Reclamation of waste rock or overburden and tailing piles (regrading and
restoration to natural contours); and/or
• Containment of stormwater through grading, berms, retention ponds (e.g.,
designed to contain 100-year, 24-hour storm).
EPA did not evaluate the costs or the effectiveness of these suggestions for this review.
5-54
-------
Section 5 - Existing Industry Review
5.4.2.5 Industry Trends
Table 5-40 compares the ore mining and dressing industry as presented in the
1982 TDD (1) with 2000 TRI data and 1997 Economic Census data. In this 15-year period, the
number of mining facilities increased by 7 percent. The percentage of facilities that did not
discharge wastewater may have increased, but this conclusion is based on information from the
limited number of facilities that reported to TRI.
Table 5-40. Comparison of Ore Mining and Dressing Facilities in 1982 and 2000
Total Number of
Facilities
650 (1982)
696' (1997)
Direct Dischargers
67%
41%2
Indirect Dischargers
0%
2%2
No Discharge
33%
57%2
Source: Development Document for Effluent Limitations Guidelines and Standards, 1982 (1); U.S. Economic
Census, 1997 (2); TRIReleases2000.
'Number of ore mining and dressing facilities identified in 1997 Economic Census.
Percentage of the 96 total facilities reporting to TRI in 2000.
5.4.2.6 Stakeholder and EPA Regional Issues
Stakeholders and EPA Regional staff submitted the following comments
regarding the Ore Mining and Dressing category:
• The current ELGS may be outdated and the BAT technology basis may no
longer be appropriate.
• The current ELGS should be revised to address discharges from waste
rock, spent ore, and leach material. Other issues that need to be addressed
include closure/financial assurance plans, remediation, and a definition of
active versus inactive mines.
• The recommendations of EPA's National Mining Team, which include
water budgets and closure plans, should be considered when revising the
hard rock mining ELGS.
• The decision to exclude seepage from the waste dumps from the 40 CFR
Part 440 definition of mine drainage should be reversed.
• Discharges from waste rock and overburden piles should be subject to the
ELGS and should not be considered industrial stormwater, which is not
subject to guidelines. Pollutants of concern in the discharges include
arsenic, copper, mercury, and selenium.
5-55
-------
Section 5 - Existing Industry Review
5.4.2.7 Conclusions
Pollutants with the highest TWPE in TRI and PCS for 2000 are metals, which are
naturally associated with the ores being mined. Cadmium, copper, lead, mercury, and zinc are
regulated by BAT, BPT, and NSPS under existing regulations.
In TRI, lead and arsenic contribute the most TWPE for this industry (over 60
percent). In PCS, molybdenum, mercury, and cadmium contribute the most TWPE for the
industry (over 80 percent). As explained above, lead, cadmium, and mercury are regulated by
this ELGS. Molybdenum is not regulated, only reported by four facilities, and requires chemical
precipitation at a unique pH. Arsenic was not regulated under the existing rule because it was
determined to be adequately controlled through regulation of other metals. This pollutant was
primarily reported in a single SIC code 1041.
The number of facilities reporting to TRI for 2000 represent only about 14 percent
of the ore mining and dressing industry based on the total number of facilities in the 1997
Economic Census, while the number of major dischargers reporting to PCS represent about 11
percent of the industry. Consequently, the reported pollutant discharges may or may not
accurately characterize the entire industry. Other data limitations and quality concerns include:
• Outfall descriptions are not included in PCSLoads2000, and must be
obtained on a per-facility basis from PCS; and
• Few facilities report percent stormwater discharges in TRI, and it is
difficult to compare TRI discharges from stormwater with other surface
water discharges.
During review of this regulation, EPA Regional staff raised concerns about metal
pollutants associated with stormwater discharges. EPA does not have sufficient information on
these discharges to evaluate them. These discharges are generally subject to benchmark
monitoring in stormwater permits (e.g., Multi-Sector Stormwater General Permits) rather than
ELGS requirements. More specific monitoring data on stormwater discharges from mines would
be necessary to determine the extent of metal discharges from waste rock and overburden piles.
Monitoring data for stormwater permits are not easily obtained since records of any monitoring
data provided by mining operations are, in most instances, maintained at the state level. EPA did
not contact any facilities directly because it did not identify any reported discharges to TRI or
PCS as being uncharacteristic for the industry. In the next annual review, EPA will continue to
obtain and consider information to fill remaining data gaps.
5.4.2.8 References
1. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Ore Mining and Dressing Point Source Category.
EPA-440/1 -82/061. Washington, D.C. 1982.
5-56
-------
Section 5 - Existing Industry Review
2. U.S. Economic Census. 1997. Available online at:
http ://www. census. gov/epcd/www/econ97.html.
3. U. S. EPA. Federal Register (Volume 68, Number 245), 40 CFR Part 43 7 [FRL-
7601-3] RIN 2040-AD95, "Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance Standards for the Centralized Waste
Treatment Point Source Category." December 22, 2003, pp. 71014-71026.
5.4.3 Pulp, Paper, and Paperboard Phase II
5.4.3.1 Industry Description
Paper is composed of cellulose fibers and nonfibrous additives, felted together
into a uniform sheet. In the U.S., the most common fiber source is wood, followed by recovered
waste paper. Pulp is the term used for the fibrous material produced chemically and/or
mechanically from wood or other cellulosic materials. Paperboard is thick paper, nominally with
thickness greater than 0.3 mm. For statistical purposes, the U.S. Government divides the pulp,
paper, and paperboard industry into three parts, each assigned a 4-digit SIC code:
• 2611 Pulp Mills - Establishments that make pulp from wood or other
materials and whose primary product shipped is pulp.
• 2621 Paper Mills - Establishments whose primary product is paper.
Integrated facilities that make both pulp and paper are included in this SIC
code if they primarily ship paper or paper products. Thus, some facilities
in SIC code 2621 make paper from purchased pulp while others make pulp
and paper at the same site.
• 2631 Paperboard Mills - Establishments whose primary product is
paperboard. Again, integrated facilities that make both pulp and
paperboard are included in this SIC code if they primarily ship paperboard
or paperboard products.
ELGS for the Pulp, Paper, and Paperboard Point Source Category are codified at
40 CFR Part 430. As discussed in Section 5.4.3.2, EPA divided the category into 12
subcategories based on the primary sources of wastewater pollutants. These subcategories do
not correspond to the SIC codes. For example, the regulations in Subpart B (Bleached
Papergrade Kraft and Soda) apply to discharges resulting from production of bleached kraft
market pulp (SIC code 2611), integrated production of bleached kraft pulp and paper (SIC code
2621), or integrated production of bleached kraft pulp and paperboard (SIC code 2631).
5-57
-------
Section 5 - Existing Industry Review
EPA 's Phased Approach for Reviewing Pulp and Paper Effluent Guidelines
Phase I. In 1988, a legal suit brought by the Environmental Defense Fund and
National Wildlife Federation resulted in a consent decree obligating EPA to address discharges
of dioxins and furans from 104 bleaching pulp mills, including nine dissolving pulp mills2. At
the same time it addressed the dioxin and furan issues at these 104 mills, EPA chose to review
the ELGS for the entire Pulp, Paper, and Paperboard category. On December 17, 1993, EPA
proposed a new subcategorization scheme and revised regulations for all 12 new subcategories.
In a 1996 Notice of Data Availability (July 1996), EPA announced that it would promulgate final
ELGS for the Pulp, Paper, and Paperboard category in stages. EPA first addressed Subparts B
(Bleached Papergrade Kraft and Soda) and E (Papergrade Sulfite), because these subparts
applied to the majority of the 104 mills identified in the consent decree. Revised ELGS for
Subparts B and E were promulgated April 15, 1998, and became known as Pulp, Paper, and
Paperboard Phase I. The new subcategorization scheme was also promulgated at this time.
Phase III. EPA proposed ELGS addressing discharges of dioxins and furans for
the two dissolving pulp subcategories (Subpart A, Dissolving Kraft, and Subpart D, Dissolving
Sulfite) in 1993. However, EPA did not promulgate regulations for these two subcategories in
1998 because EPA anticipated that the final ELGS for these subcategories would be based on
different technologies than those that served as the basis for the proposed ELGS, and because
affected companies were undertaking multi-year laboratory studies and mill trials to develop
alternative bleaching technologies (61 FR 36835, July 1996). More recently, EPA determined it
will not promulgate revised regulations for Phase III because there are only four affected
facilities in these two subcategories (as of July 2004): two in Florida and one each in Georgia
and Washington. Instead, EPA will support NPDES permit writers as they develop ELGS for
dissolving pulp mills.
Phase II. The remaining eight subcategories, listed below, compose Phase II:
• Subpart C. Unbleached Kraft Subcategory;
• Subpart F. Semi-Chemical Subcategory;
• Subpart G. Mechanical Pulp Subcategory;
• Subpart H. Nonwood Chemical Subcategory;
• Subpart I. Secondary Fiber Deink Subcategory;
• Subpart J. Secondary Fiber Non-Deink Subcategory;
2Five of these dissolving pulp mills remained in operation in 2000, but one has since closed.
5-58
-------
Section 5 - Existing Industry Review
• Subpart K. Fine and Lightweight Papers From Purchased Pulp
Sub category; and
• Subpart L. Tissue, Filter, Non-Woven and Paperboard From Purchased
Pulp Subcategory.
In 1993, EPA proposed revised BPT and NSPS for control of conventional
pollutant discharges from these eight subcategories. EPA did not propose ELGS for dioxins and
furans because they were not identified as pollutants of concern in discharges from these
subcategories. In 1996, EPA planned to promulgate ELGS for the Phase n subcategories after
promulgating the final rules for the Phase I subcategories. However, in the Effluent Guidelines
Program Plan for 2002/2003 (67 FR 55012-55014, August 27, 2002), EPA announced it was not
including revision of ELGS for the eight Phase n subcategories. Instead, EPA announced it
would decide whether to move forward with regulatory development for the Phase n
subcategories during its 2004 annual review.
Number and Discharge Status of Phase II Mi Us
As listed in Table 5-41, the 1997 U.S. Economic Census reports the total number
of establishments in the pulp, paper and paperboard industry by SIC code.
Table 5-41. Number of Pulp, Paper, and Paperboard Establishments
SIC Code
2611
2621
2631
Total
Description
Pulp Mills
Paper Mills
Paperboard Mills
1997 U.S. Economic Census
39
256
217
512
Source: 1997 U.S. Economic Census.
Of the 512 facilities identified by the 1997 Census, 232 (45 percent) reported
releases to TRI in 2000 and 291 were included in PCS. EPA classified each mill as Phase I,
Phase II, or Phase III, based on information reported by mills in EPA's 1990 survey of the pulp,
paper, and paperboard industry. In this survey, mills reported production by subcategory (5).
The name and operations of the mills as of 2000 were confirmed by consulting Lockwood-Post's
Directory of the Pulp, Paper and Allied Trades (4). Mills with any operations in Phase I
subcategories were identified as Phase I, though wastewater generated by part of their production
may be subject to ELGS for Phase n subcategories. By definition, the production at mills with
operations in the Phase III subcategories does not overlap with other subcategories.
Table 5-42 presents the distribution of the 232 TRI-reporting facilities, by SIC
code and regulatory review phase. Note that 78 facilities reported to TRI a primary SIC code of
2611 (pulp mills), while the census only identified 39 facilities in SIC code 2611. This
5-59
-------
Section 5 - Existing Industry Review
discrepancy might result from the differences in identification of the SIC code at integrated
mills. The census based primary SIC code on value of shipments, while the TRI primary SIC
code might be based on the primary source of toxic chemical releases. Thus, integrated mills are
identified as SIC code 2621 (paper) or 2631 (paperboard) in the census, but might be identified
as SIC code 2611 (pulp) in TRI, because pulping is the source of more toxic releases. Of the
mills reporting to TRI for reporting year 2000, the majority (139, or 60 percent) are in regulatory
review Phase II.
Table 5-42. Pulp and Paper Mills Reporting to TRI for Reporting Year 2000
SIC Code
2611
2621
2631
Total (%)
Total
78
109
45
232
Phase I
51
30
7
88 (38)
Phase H
22
79
38
139 (60)
Phase m
5
0
0
5(2)
Source: EPA, TRIReleases2000.
Of the 512 facilities identified by the 1997 Census, 255 (50 percent) were mills
classified as "major dischargers" whose 2000 discharges were reported to PCS. In addition to
these major dischargers, PCS identified another 36 minor dischargers in the three pulp and paper
SIC codes. Table 5-43 presents the distribution of PCS reporting facilities, by SIC code and
regulatory review phase. Note that 86 major discharge mills were identified in PCS with a
primary SIC code of 2611 (pulp mills), while the census only identified 39 facilities in SIC code
2611. Similar to the TRI database, this discrepancy might result from the differences between
identification of the source of pollutants (e.g., pulping) and the product shipped from integrated
mills. Of the major discharge mills with 2000 discharge data in PCS, the majority (172, or 67
percent) are in regulatory review Phase II.
Table 5-43. Pulp and Paper Mills with Data in PCS
SIC
Code
2611
2621
2631
Total
Total
Major
Dischargers
86
125
44
255
Minor
Dischargers
6
23
7
36
Phase I
Major
Dischargers
36
35
7
78
Minor
Dischargers
1
0
0
1
Phase H
Major
Dischargers
46
90
36
172
Minor
Dischargers
5
23
7
35
Phase III
Major
Dischargers
4
0
1
5
Minor
Dischargers
0
0
0
0
Source: EPA. PCSLoads2000.
Table 5-44 presents discharge information about the Phase II mills from
TRIReleases2000 and PCSLoads2000. All mills that reported to TRI reported wastewater
5-60
-------
Section 5 - Existing Industry Review
releases of toxic chemicals. The majority (107 mills or 78 percent) reported at least some
releases of toxic chemicals directly to receiving streams.
Table 5-44. Phase II Mills
PCS
Total
207
Major
Dischargers
172
Minor
Dischargers
35
TRI
Total
Reporters
139
No Reported
Discharge
0
Direct
Discharge
103
Indirect
Discharge
32
Both Direct
and Indirect
Discharge
4
Source: EPA. PCSLoads2000 and TRIReleases2000.
5.4.3.2
Regulatory Background
EPA promulgated BPT regulations for the Pulp, Paper, and Paperboard category
from 1974 to 1982. Using data from the early to mid-1970s, EPA divided the industry into 25
subcategories. BPT limitations for BOD5, TSS, and pH for all subcategories, including those
that are now "Phase n," was based on the performance (percent removal) of biological
wastewater treatment, subcategory raw waste loads, and characteristic production-normalized
effluent flow rates. During the industry review leading to the 1993 proposal of revised
regulations, EPA determined that its original subcategorization scheme could be simplified to 12
subcategories. EPA also determined that the average performance of the industry, in terms of
conventional pollutants discharged, had improved markedly from the time the original
regulations were promulgated. In 1993, EPA proposed revised BPT and NSPS regulations for
conventional pollutants for all 12 new subcategories. However, in 1996, EPA determined that it
would not revise BPT for the Pulp, Paper, and Paperboard category and has taken no further
action on the proposal since that time.
In 1982, EPA promulgated BAT ELG for trichlorophenol and pentachlorophenol
for 24 subcategories (all but the then existing groundwood-chemi-mechanical subcategory). The
priority pollutant zinc was limited in four groundwood subcategories.
During the development of the 1993 proposed regulations, EPA studied 443
specific pollutants (5). Although the focus of EPA's study was revising the BAT ELG for
chemical pulp mills that bleach, EPA also investigated the generation of chlorinated organic
pollutants at nonchemical pulp mills and chemical nonwood pulp mills (mills that were later
classified as Phase II) that bleach with chlorine and/or hypochlorite. EPA found levels of
chloroform, chlorinated phenolic compounds, and dioxins in the final effluents from these mills.
EPA did not propose ELGS for these priority and nonconventional pollutants in Phase n
subcategories in 1993, but did not exclude the subcategories from regulation. EPA decided to
consider whether to develop regulations for these pollutants as part of its 2004 annual review.
Table 5-45 presents the existing limitations for Phase n subcategories.
5-61
-------
Section 5 - Existing Industry Review
Table 5-45. ELGS for Pulp, Paper, and Paperboard Phase II Subcategories (Part 430)
Subpart
C- Unbleached Kraft
C - Unbleached Kraft and
Semi -chemical
Cross Recovery
(Reserved)
F - Semi-chemical,
Ammonia
F - Semi-chemical, Sodium
G - Groundwood Chern-
mechanical
G - Groundwood
Thermomechanical
G - Groundwood,
Integrated, Coarse Paper
G - Groundwood,
Integrated Fine Paper
H - Nonwood
I - Secondary Fiber Deink,
Fine Paper
I - Secondary Fiber Deink,
Tissue Paper
I - Secondary Fiber Deink,
Newsprint
J - Secondary Fiber Non-
deink, Paperboard
J - Secondary Fiber Non-
deink, Paperboard and
Corrugating Medium
J - Secondary Fiber Non-
deink. Builders Paper and
Roofing Felt
J - Secondary Fiber Non-
deink. Tissue
J - Secondary Fiber Non-
deink. Molded Products
K - Non-integrated, Fine
Paper
BPT - Monthly Average Maximum
BOD5
TSS
NSPS - Monthly Average Maximum
BOD5
TSS
pounds per 1,000 Ib of product
2.8
4.0
4.0
4.35
7.05
5.55
3.9
3.6
reserved
9.4
9.4
9.4
1.5
2.8
3.0
4.0
1.3
4.25
6.0
6.25
5.0
5.5
10.65
8.35
6.85
6.3
reserved
5.3
5.3
5.3
2.5
4.6
3.0
5.1
3.2
5.9
1.8-2.71 '
2.1
1.6
1.6
~
2.5
2.5
1.9
reserved
3.1
5.2
3.2
1.4
2.1
0.94
2.5
1.1
1.9
3.0-4.8
3.8
3.0
3.0
~
4.6
3.8
3.0
reserved
4.6
6.8
6.3
1.8
2.3
1.4
5.3
2.3
2.3
5-62
-------
Section 5 - Existing Industry Review
Table 5-45 (Continued)
Subpart
K - Non-integrated, Fine
Paper, Cotton Furnish
K - Non-integrated,
Lightweight Paper
K - Non-integrated,
Electrical Paper
L - Non-integrated, Tissue
L - Non-integrated, Filter
and Nonwoven
L - Non-integrated.
Paperboard
BPT - Monthly Average Maximum
BOD5
TSS
NSPS - Monthly Average Maximum
BOD5
TSS
pounds per 1,000 Ib of product
9.1
13.2
20.9
6.25
16.3
3.6
13.1
10.6
16.7
5.0
13.0
2.8
4.2
6.7
11.7
3.4
8.3
1.9
4.9
5.2
9.2
2.6
6.6
1.5
The range of values represent limits for different size operations.
5.4.3.3
Wastewater Characteristics and Pollutant Sources
This subsection presents wastewater flow and pollutant load information reported
to PCS and TRI for the year 2000. Also discussed are results of EPA sampling at five deink
mills, and the basis of mill estimates of PACs releases reported to TRI.
Wastewater Flows
Of the 172 mills for which information was reported to PCS, 168 reported
nonzero flows in 2000. Table 5-46 presents the median mill flow and the range of per mill flows
for Phase n mills that are major dischargers. Wastewater flow information was not available for
minor dischargers. In some cases, the reported flows may include stormwater discharges and
noncontact cooling water, as well as process wastewater.
Table 5-46. 2000 Wastewater Flows for Phase H Mills (All SIC Codes)
Number of Major
Dischargers Reporting
Nonzero Flows
168
Median Per Mill Flow 2000
MGY (MGD)
1,400 (3.8)
Range of Mill Flows MGY
(MGD)
0.0008 to 49,000
(O.OOto 13)
Total Flow 2000
MGY (MGD)
660,000 (1,800)
Source: EPA, PCSLoads2000.
5-63
-------
Section 5 - Existing Industry Review
Wastewater Pollutant Loads from TRI and PCS
Table 5-47 presents information reported to TRI for reporting year 2000 by Phase
II mills. The table lists the chemicals that account for 97 percent of the TWPE, the number of
facilities that reported each chemical, and the total pounds of chemical discharged to surface
waters. Indirect discharging facilities reported transfers to POTWs. Using average POTW
removal efficiencies, EPA estimated the amount of pollutant discharged to surface water (see
DCN 00618, Evaluation of RSEIModel Runs, for more information). Therefore, the TWPE
estimates in this table have been adjusted to account for POTW treatment. PACs contribute 80
percent of the Phase II TWPE. As discussed later in this section, Phase II mills may have over-
reported PAC and dioxin releases to TRI. Table 5-48 shows that manganese compounds and
chlorine contribute 68 percent of the Phase II TWPE when PACs and dioxins are not included in
the analysis.
Table 5-49 presents information about Phase II mills' calendar year 2000
discharges, reported to PCS. The table lists the chemicals that account for 95 percent of the total
TWPE. Total residual chlorine and aluminum contribute 69 percent of the Phase II TWPE.
Wastewater Pollutant Loads from EPA Sampling
In 2000, EPA undertook a sampling program at five mills in the Secondary Fiber
Deink Subcategory, one of the eight Phase II subcategories (1). EPA sampled mills with stand-
alone deink operations that produce tissue and toweling, including two mills that use chlorinated
bleaching agents and three mills that do not. Table 5-50 presents the production-normalized
loads of selected analytes detected in treated mill effluent.
Other than a low concentration of phenol detected at one mill, the only organic
priority pollutant detected in treated mill effluent was chloroform. EPA analyzed effluent
samples for several PACs, but none were detected. With the exception of zinc, which was
detected at concentrations ranging from 0.194 to 0.256 mg/L in the Mill 1 final effluent, the few
priority pollutant metals detected in treated mill effluent were present at less than 0.035 mg/L.
PACs and dioxins and furans, reported to TRI in Phase II mill wastewater releases, were not
detected above the analytical method detection limit in treated wastewater during this study.
5-64
-------
Section 5 - Existing Industry Re\>iew
Table 5-47. Pulp and Paper Phase H Chemical Releases Reported to TRI for 2000
Pollutant
Polycyclic Aromatic
Compounds
Manganese Compounds
Chlorine
Potassium
Dimethyldithiocarbamate
Dioxin and Dioxin-like
Compounds
Total All Pollutants
Number of
Facilities
Reporting
12
36
10
2
12
139
TRI Total
(Ibs/yr)
113
790,947
48,903
23,529
0.0047
5,677,680
TRI
TWPE/yr
484,471
55,709
23,815
21,960
7,480
608,875
Median
Facility
TWPE/yr
32,340
1,268
550
10,980
36
Range of Facility
TWPE/yr
8,567 to 77, 104
2 to 5,589
2.4 to 10,714
9,701 to 12.259
0.18 to 5,296
Percentage of
Total Phase H
TWPE
80%
9%
4%
4%
1%
Cumulative
Percentage of
Total Phase II
TWPE
80%
89%
93%
96%
97%
L/1
ON
Source: EPA. TRI Re I eases 2000.
Table 5-48. Pulp and Paper Phase II Chemical Releases Reported to TRI for 2000 Without PACs or Dioxins
Pollutant
Manganese Compounds
Chlorine
Potassium
Dimethyldithiocarbamate
Vanadium Compounds
Zinc Compounds
Manganese
Total All Pollutants
Number of
Facilities
Reporting
36
10
2
7
26
1
139
TRI Total
(Ibs/yr)
790,947
48,903
23,529
6,314
80,615
38,605
5,677,567
TRI
TWPE/yr
55,709
23,815
21,960
3,929
3,769
2,719
116,925
Median
Facility
TWPE/yr
1,268
550
10,980
622
77
2,719
Range of Facility
TWPE/yr
2 to 5589
2.4 to 10,714
9,701 to 12,259
182 to 1,121
0.9 to 1,117
NA
Percentage of
Total Phase O
TWPE
48%
20%
19%
3%
3%
2%
Cumulative
Percentage of
Total Phase n
TWPE
48%
68%
87%
90%
93%
96%
Source: EPA, TRI Re/eases 2000.
-------
Section 5 - Existing Industry Re\>iew
Table 5-49. Pulp and Paper Phase H PCS Pollutant Discharges Reported for PCS for 2000
Pollutant
Chlorine, Total Residual1
Aluminum, Total (As Al)
Aluminum, Total
Recoverable
Arsenic. Total Recoverable
Lead Total Recoverable
Nitrogen, Ammonia Total
(AsN)
Copper, Total (As Cu)
Lead, Total (As Pb)
PCB-1242 (Arochlor 1242)
Zinc, Total (As Zn)
Total All Pollutants
Number of
Facilities
Reporting
16
10
7
2
4
50
24
5
1
32
172
PCS Total
(Ibs/yr)
48,134
267,639
95,760
1,522
2,143
986,219
2,747
652
0
19,949
690 million
PCS TWPE/yr
23,440
17,260
6,175
5.280
4,801
1,805
1,722
1,460
1.355
933
67,796
Median
TWPE/yr
121
300
876
2,640
9.5
14
49
177
NA
11
Range of Facility
TWPE/yr
1 to 10,741
11 to 9,989
23 to 2,682
2 to 5,278
1 to 4,781
0.006 to 264
0.25 to 387
50 to 853
NA
0.005 to 300
Percentage
of Total
Phase H
TWPE
35%
25%
9%
8%
7%
3%
3%
2%
2%
1%
Cumulative
Percentage of
Total Phase H
TWPE
35%
60%
69%
77%
84%
87%
89%
91%
93%
95%
ON
ON
Source: EPA, PCSLoads 2000.
NA - Not applicable, only one reported value.
'Total residual chlorine discharges reported to PCS may be daily maximum calculated load may be overestimated.
-------
Section 5 - Existing Industry Review
Table 5-50. Comparison of Analytes Detected in Treated Wastewater (Final Effluent)
Analyte
Chloroform (g/ADMT)
2,4.6-TCP (1653) (g/ADMT)
Dioxin TEQ (ug/ADMT)
AOX1 (kg/ADMT)
BOD, (kg/ADMT)
COD (kg/ADMT)
TSS (ks/ADMT)
Mills with Hypochlorite Bleaching
Milll
1.07
0
0
0.067
3.52
7.35
2.33
Mill2
0.252
0
0
0.0362
18.52
2.87
0.642
Mill 3
5.36
0.149
0
0.402
1.33
9.75
0.91
Mills with TCF Bleaching Only
Mill4
0
0
0
0.0211
0.156
2.64
0.342
MillS
0
0
0
0.0121
0.667
8.02
1.83
Source: Five-Deink Mill Summary Report, Revision 2, April 15, 2003. Table 6-3.
ADMT - Air Dried Metric Ton.
'Adsorbable Organic Halides. A bulk parameter that is measured by EPA Method 1650. This method measures the
total mass of halogenated organic matter in water and wastewater. In pulp mill wastewaters, this material
is ahnost exclusively chlorinated organic matter.
2Mill 2 has questioned EPA's measured concentration of BOD5 in their final effluent.
Poly cyclic Aromatic Compounds (PACs)
Table 5-51 lists mills that reported releases of PACs to TRI for reporting year
2000 along with the reported basis of their estimate. No mills reported using monitoring data or
measurements as the basis of their estimate. The major operations at these mills are the
production of unbleached kraft pulp that is made into paperboard on site. Most mills also repulp
waste paperboard without bleaching. Kraft pulp mills often burn waste wood (known as hog
fuel), coal, and fuel oil to generate steam used directly in the mill or used to generate electricity.
Waste from the boilers includes fly ash and bottom ash.
EPA contacted one of the mills that reported PAC releases to obtain information
about its operations and verify PACs discharges (2, 3). The mill contact reported using estimates
from the National Council for Air and Stream Improvement (NCASI). They reported that the
NCASI document references EPA's compilation of air pollution emission factors, AP 42, 5th Ed,
Volume 1 for coal, fuel oil, gas, and wood combustion, lists individual PACs released from each
type of fuel combusted, and lists benzo(a) pyrene and benzo(j,k) fluorene as the predominant
PACs in combustion ash.
For PACs, the contacted mill used an emission factor to estimate 7.1 pounds of
PACs that were released to the water in 2000 due to trace amounts in chemicals used at the site
(3). The mill contact reported that the majority of the PACs reported released from this mill are
associated with wood ash. According to the mill contact, the ash settles out in the settling basin
of the wastewater treatment system and will remain on site when this basin fills with solids and
is closed, essentially landfilling 158 pounds in 2000. The mill mistakenly reported PACs in this
landfilled ash as released to surface water. They corrected this error with EPA's TRI office, and
the corrected mass is reflected in Tables 5-47 and 5-51 of this report.
5-67
-------
Section 5 - Existing Industry Re\>iew
Table 5-51. Phase II Mills Reporting Releases of PACs for TRI Reporting Year 2000
Mill
International Paper
Stone Container Corp.
Packaging Corp. Of America
Great Southern Paper Co.
International Paper
Packaging Corp. Of America
Georgia-Pacific Corp.
Stone Container Corp.
Gaylord Container Corp.
International Paper Pineville Mill
Willamette Inds. Inc. Albany Paper Mill
Longview Fibre Co.
Location
Roanoke Rapids, NC
Florence, SC
ClyatrviUe, GA
Cedar Springs, GA
Prattville, AL
Cornice, TN
Monticello. MS
Missoula. MT
Bogalusa, LA
Pineville, LA
Albany, OR
Longview. WA
Subcategory
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft & Semi-
chem.
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Direct
Discharge
(lb/yr)
10
7.1
7
o
j
18
16
18
8
14
4
6
2
Direct
Discharge
(TWPE/yr)
42,836
30,413
29,985
12,851
77,104
68,537
77,104
34,268
59,970
17,134
25,701
8,567
Basis of
Estimate for
TRI Releases
20001
0
C
E
0
E
O
O
E
E
0
E
E
ON
OO
'Mills reported basis of estimate in 2000 TRI as: C - Mass balance calculations; E - Published emission factors; and O - Other approaches (e.g., engineering
calculations). No mills reported M - Monitoring data/measurements as the basis of their estimate.
-------
Section 5 - Existing Industry Review
Information from the 2000 TRI database provides no concentrations of PACs
measured by chemical analysis in Phase II wastewaters above analytical detection limits.
Furthermore, EPA sampling at five phase II mills did not detect any PACs. Therefore, EPA
concludes TRI-reported PAC discharges are most likely overestimated.
Dioxins
Dioxins are known to be present in wastewaters generated from bleaching
chemically pulped wood with chlorine and chlorine-containing compounds. Dioxins are also
generated during a variety of combustion processes, including combustion of wood. Wet
scrubbers and water conveyance of wood ash may be sources of dioxins in wastewater.
Table 5-52 lists mills that reported releases of dioxin and dioxin-like compounds
to TRI for reporting year 2000, along with the reported basis of their estimate. Only 1 of the 11
mills reporting dioxin releases used monitoring data or measurements as the basis of their
estimate. These mills have operations in a variety of subcategories, including producing paper
from purchased pulp, groundwood, nonwood fibers (cotton linters and flax), and semi-chemical
pulp. Mills that use nonwood fibers and mills that purchase pulp typically do not have
wastewood boilers, so are unlikely to have wood ash as a dioxin source. Groundwood and semi-
chemical mills may have wastewood boilers.
EPA contacted a mill, described above, that reported both PAC and dioxin
releases (2,3). The mill contact reported that they used an emission factor based on combustion
of wood to calculate dioxin releases, as the dioxins were presumed to be released with sluiced
wood ash. This facility changed the assumption underlying its estimate, assuming instead that
the wood ash settles out in the settling basin of the wastewater treatment system and will remain
on site when this basin fills with solids and is closed, essentially landfilling the waste. From
originally reporting a release to surface water of 0.047 grams, the mill contact changed the
estimated release to zero.
Three Phase II mills are required to monitor for dioxins in their NPDES permits.
However, none of these mills detected dioxins in their effluent in 2000.
Information from the 2000 TRI database and PCS database provides little
evidence that dioxins are present in Phase II mill wastewaters above analytical detection limits.
Only 1 of 12 mills that reported wastewater releases of dioxins to TRI reported using monitoring
data/measurements as the basis for the reported release. In addition, EPA sampling in 2000 did
not detect any dioxin above the minimum detection level.
5-69
-------
Section 5 - Existing Industry Re\>iew
Table 5-52. Phase II Mills Reporting Releases of Dioxin and Dioxin-Like Compounds to TRI for Reporting Year 2000
Mill
Daishowa America Co. Ltd.
Buckeye Lumberton Inc.
Schweitzer Mauduit Intl. Inc.
Schweitzer-Mauduit Intl. Inc.
Procter & Gamble Paper Prods.
Co.
Felix Schoeller Technical
Papers Inc.
Procter & Gamble Paper Prods.
Co.
Blandin Paper Co.
Georgia-Pacific Corp.
Procter & Gamble Paper Prods.
Co.
Smart Papers L.L.C.
Procter & Gamble Paper Prods.
Location
Port Angeles, WA
Lumberton. NC
Lee, MA
Ancram, NY
Mehoopany, PA
Pulaski, NY
Jackson, MO
Grand Rapids,
MN
Pittsburgh, NY
Albany, NY
Hamilton, OH
Oxnard, CA
Subcategories1
Groundwood
Purchased Pulp
Nonwood
Nonwood
Purchased Pulp
Purchased Pulp
Purchased Pulp
Purchased Pulp
Groundwood.
Nondeink.
Purchased Pulp
Nondeink,
Purchased Pulp,
Semi-chemical
Purchased Pulp
Purchased Pulp
Purchased Pulp
Direct
Discharge
(g/yr)
0.68
0.227
0.07
0.02
0.01
0.003
0.004
Direct
Discharge
(TWPE/yr)
5297
515
246
30
42
13
9
To
POTW
(g/yr)
6.36
0.31
0.015
0.004
0.00075
After
POTW
(g/yr)2
1.082
0.053
0.0027
0.0005
0.0001
After
POTW
(TWPE/yr)2
1221
93
12
2.17
0.18
Basis of
Estimate for
TRI
Releases
20003
M
E
0
O
E
C
O
not reported
not reported
not reported
not reported
not reported
L/1
O
Source: EPA, TRIReleases2000.
'Purchased pulp - subpart K, fine and lightweight paper from purchased pulp and/or subpart L, tissue, filter, nonwoven and paperboard from purchased pulp.
2Mass transferred to POTW. dial is ultimately discharged to surface waters. Accounts for POTW removals.
3Mills reported basis of estimate in 2000 TRI as: C - Mass balance calculations: E - Published emission factors: and O - Other approaches (e.g., engineering
calculations); M - Monitoring data/measurements.
-------
Section 5 - Existing Industry Review
5.4.3.4
Pollution Prevention and Treatment Technology
Table 5-53 lists the treatment technologies used by Phase II pulp, paper, and
paperboard mills reporting to TRI in 2000. Because production at individual pulp and paper
mills has increased over time, they have added treatment units, in sequence or parallel, to their
existing treatment. This may explain why a greater number of biological treatment systems were
reported (101) than there are direct discharge facilities (95) reporting to TRI for 2000.
Table 5-53. Wastewater Treatment Operations Reported by Phase n Mills, TRI Reporting
Year 2000
Wastewater Treatment Process
Adsorption - Other
Air Flotation
Biological Treatment
Chemical Precipitation - Other
Condenser
Equalization
Filtration
General Oxidation (Including Disinfection) - Chlorination
General Oxidation (Including Disinfection) - Other
Mechanical Separation
Neutralization
Oil Skimming
Other Chemical Treatment
Other Blending
Other Incineration/ Thermal Treatment
Other Physical Treatment
Settling/ Clarification
Sludge Dewatering (Nonthermal)
Stripping - Air
Stripping - Steam
Number of Facilities Reporting Use
Direct1
(95 facilities)
11
9
101
5
1
4
2
0
0
1
14
2
0
1
->
j
6
75
24
3
3
Indirect1
(18 facilities)
0
2
7
1
0
1
~i
j
1
1
0
4
1
2
0
0
1
8
5
0
0
Source: EPA, TRIReleases2000 (Section 7A Table).
'In TPJ 2000, of the facilities mat provided information on their wastewater treatment operations, 95 facilities
reported direct releases, 18 transferred to POTWs, and 2 facilities had both direct releases and transfers to POTWs.
5-71
-------
Section 5 - Existing Industry Review
5.4.3.5 Industry Trends
The Census Bureau released preliminary results of the 2002 Economic Census on
a subsector basis. The Paper Manufacturing subsector, NAICS code 322, includes
establishments that make converted paper products as well as establishments that make pulp
and/or paper. Thus, NAICS code 322 includes more than just the pulp, paper, and paperboard
industry. Never the less, trends shown in Table 5-54 are expected to be the same as for the pulp,
paper, and paperboard industry. Sales were flat over the five-year period while the number of
establishments declined and employment dropped by more than 15 percent.
Table 5-54. Trends in U.S. Papermaking Industry (Pulp, Paper, and Converted Products)
Establishments
Sales
Paid Employees
1997
5,868
$150 billion
574 thousand
2002
5,463
$151 billion
476 thousand
Source: 2002 Economic Census, http://www.census.gov/econ/census02/advance/TABLE2.HTM.
5.4.3.6 Stakeholder and Regional EPA Issues
During previous outreach efforts, some stakeholders raised concerns about
discharge of dyes and dioxin from bleaching at secondary fiber mills. During the current
outreach cycle, some stakeholders supported the Phase II rule, due to concerns for the number of
pollutants discharged by the chemical, mechanical, and secondary fiber de-inking subcategories.
Stakeholders did not provide any data (e.g., estimates of discharge loads, or
instances of water quality violations resulting from Phase II mill discharges) supporting their
concerns. Nor did EPA's review of available data describing Phase II mill discharges support
stakeholders' concerns.
5.4.3.7 Conclusions
In the screening-level analysis of TRI data, the major identified toxic pollutant
problem associated with phase II mills was discharges of PACs. No mills reported using
monitoring data or measurements as the basis of their estimate of PACs released to surface
waters. In a sampling program conducted by EPA at five Phase II mills (all secondary fiber
mills), priority pollutant PACs were never detected. In none of the data reviewed by EPA were
PACs detected in Phase II wastewaters.
A second pollutant driving the TWPE estimate in the screening-level analysis of
TRI data was dioxins. Only one mill reported using monitoring data or measurements as the
basis of its estimates of dioxin discharges. The three mills required by NPDES permits to
monitor their effluent for dioxins did not detect them in 2000. Also, in a sampling program
5-72
-------
Section 5 - Existing Industry Review
conducted by EPA at five Phase II mills (all secondary fiber mills, including three mills that
bleached with chlorine-containing compounds), dioxins and furans were not detected above the
method minimum level in treated effluent. Thus, the data reviewed by EPA for this report do not
identify that dioxins are present in Phase II mill wastewaters.
If PAC and dioxin releases are not included in the estimate of the Phase II TWPE,
Phase II toxic pollutant discharges estimated using TRI release information for reporting year
2000 are reduced from 608,875 TWPE to 116,925 TWPE, attributable mainly to manganese,
chlorine, and potassium dimethyldithiocarbamate. Detectable levels of PACs and dioxins were
not found in data-reported to PCS; therefore, changes to the assumptions about PACs and
dioxins have no impact on the Phase II PCS loads (67,800 TWPE), which are attributable mainly
to chlorine and aluminum.
5.4.3.8 References
1. Eastern Research Group, Inc. Five-Deink-Mill Study Summary Report, Revision
2. Prepared for U.S. EPA Office of Research and Development and Office of
Water. April 15,2003.
2. Heately, Bill. Personal communication from Corporate Environmental Director,
Smurfitt Stone Container Corporation, to A. Hooshangi, ERG. February 3, 2004.
3. Heately, Bill. E-mail message from Corporate Environmental Director, Smurfitt
Stone Container Corporation, to B. Bicknell, ERG. February 4, 2004.
4. Paperloop Publications, 2001. Lockwood-Post 's Directory of the Pulp, Paper and
Allied Trades, 2002. San Francisco, Paperloop Publications.
5. U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines
and Standards for the Pulp, Paper, and Paperboard Point Source Category.
EPA-821-R-93-019. Washington, D.C. October 1993.
5.4.4 Steam Electric
5.4.4.1 Industry Description
The steam electric industry includes electric utilities that combust coal, natural
gas, and/or oil to generate electricity for distribution in commerce. Steam electric operations are
classified in the following SIC codes:
• SIC code 4911 Electrical Services: Establishments engaged in the
generation, transmission and/or distribution of
electric energy for sale; and
5-73
-------
Section 5 - Existing Industry Review
• SIC code 4931 Electric and Other Services Combined:
Establishments primarily engaged in providing
electric services in combination with other services,
with electric services as the major part though less
than 95 percent of the total.
This summary does not include nonutility steam electric power plants located in
industrial, commercial, or other facilities. These cogenerators exist as ancillary processes at
chemical, pulp and paper, petroleum refining, or other industrial plants. Any pollutant loads
associated with these operations are currently considered as part of the primary industry
operation.
Information on the number of facilities in the Steam Electric Point Source
Category was obtained from three sources: the 1997 U.S. Economic Census, TRIRe leases 2 000,
and PCSLoads2000. TRI includes all facilities reporting discharges to any media. In contrast,
the PCS includes only facilities that are permitted for discharge to surface waters. Table 5-55
lists the number of steam electric facilities from these sources. The number of facilities under
SIC code 4911 reporting to TRI for 2000 represents only about 10 percent of the steam electric
industry based on the total number of facilities in the census, while the number of SIC code 4911
facilities reporting discharges to PCS for 2000 represent about 13 percent of the total industry.
Of the facilities reporting to TRI, only 48 percent report water discharges.
Table 5-55. Number of Steam Electric Facilities
SIC
Code
4911
4931
Total
1997
Census
6.212
NA
2000 PCS
Total
835
53
888
Major
Dischargers
541
9
550
Minor
Dischargers
294
44
338
2000 TRI
Total
638
43
681
No
Reported
Discharge
296
29
325
Direct
Dischargers
321
10
331
Indirect
Dischargers
9
2
11
Both Direct
and Indirect
Dischargers
12
2
14
NA - Data were not presented for SIC code 4931 in the 1997 Economic Census. Data in the Census for SIC code 493 (which includes SIC codes
4931, 4932, and 4939) included 1,989 facilities.
Steam electric facilities are dispersed throughout the United States, with a higher
concentration located on the east coast.
5.4.4.2
Regulatory Background
ELGS for the Steam Electric Point Source Category (40 CFR Part 423) are
described below.
EPA first proposed ELGS in October 1974 based on BPT, BAT, NSPS,
and PSNS.
5-74
-------
Section 5 - Existing Industry Review
• The Agency promulgated final versions of the ELGS in June 1975.
• The proposed 1974 regulations applied to thermal and chemical pollution.
In 1976, the thermal regulations were remanded and are now covered
under section 316(a) of the Clean Water Act. The chemical pollution
limitations affected the following wastestreams:
— Once-through cooling water,
— Cooling tower blowdown,
— Bottom ash transport water,
— Fly ash transport water,
— Boiler blowdown,
— Metal cleaning wastes, and
— Material storage and construction runoff (including coal pile
runoff).
• In 1976, the U.S. Court of Appeals remanded to EPA for reconsideration:
— NSPS limitations for fly ash transport water,
— Rainfall runoff limitations for material storage and construction
runoff, and
— BPT clause concerning receiving water characteristics.
• EPA promulgated PSES in 1977, which covered copper in metal cleaning
wastes, polychlorinated biphenyls (PCBs), and oil and grease.
• EPA promulgated a second rule in 1982 that:
— Included the 1974 and 1977 limitations,
— Revised BAT, NSPS, PSES, and PSNS, and
— Established separate limitations for each type of wastestream.
The current ELGS, summarized in Table 5-56, are codified at 40 CFR Part 423.
EPA promulgated the following additional rules under section 316(b) of the Clean Water Act
based on BTA for cooling water intake structures:
• Rules for new sources discharging over 2 MGD (2001); and
• Rules for existing sources discharging over 50 MGD (February 2004).
5-75
-------
Section 5 - Existing Industry Review
Table 5-56. Steam Electric Pollutants Regulated by ELGS
Waste
Stream
All
Wastestreams
Low Volume
Wastes
Fly Ash
Handling
Bottom Ash
Handling
Chemical
Metal
Cleaning
Non-
Chemical
Metal
Cleaning
Once-
Through
Cooling
Cooling
Tower
Blowdown
Coal Pile
Runoff
BPT
pH: 6-9
PCBs: Zero Discharge
TSS: 100/30
Oil and Grease: 20/15
TSS: 100/30
Oil and Grease: 20/15
TSS: 100/30
Oil and Grease: 20/1 5
TSS: 100/30
Oil and Grease: 20/15
Cu: 1.0/1.0
Fe: 1.0/1.0
No Limitation
FAC: 0.5/0.2 (2
hrs/day)
FAC: 0.5/0.2 (2
hrs/day)
TSS: 50 max
BAT
PCBs: Zero
Discharge
No Limitation
No Limitation
No Limitation
Cu: 1.0/1.0
Fe: 1.0/1.0
Reserved
TRC: 0.20 (2
hrs/day) or = BPT if
<25MW
FAC: 0.5/0.2 (2
hrs/day)
126 Pr. Pol.: No
Detect
Cr: 0.2/0.2
Zn: 1.0/1.0
No Limitation
NSPS
pH: 6-9
PCBs: Zero Discharge
Equal to BPT
Zero Discharge
TSS: 100/30
Oil and Grease: 20/15
TSS: 100/30
Oil and Grease: 20/15
Cu: 1.0/1.0
Fe: 1.0/1.0
Reserved
TRC: 0.20 (2 hrs/day)
or = BPTif<25MW
FAC: 0.5/0.2 (2
hrs/day)
126Pr. Pol.: No
Detect
Cr: 0.2/0.2
Zn: 1.0/1.0
TSS: 50 max
PSES & PSNS
PCBs: Zero
Discharge
No Limitation
Zero Discharge
(PSNS only)
No limitation in
PSES
No Limitation
Cu: 1.0 max
Reserved
No Limitation
126Pr. Pol.: No
Detect
Cr: 0.2 max
Zn: 1.0 max
No Limitation
Source: Code of Federal Regulations .
Notes:
- Concentrations are in mg/1. If maximum and average concentrations apply, they are given as "maximum/average.'
TRC is Total Residual Chlorine, and equals Free Available Chlorine (FAC) plus Combined Residual Chlorine
(CRC).
- BCT is reserved for all wastestreams.
-Low Volume Wastes include: clarifier blow down, makeup water filter backwash, lime softener blowdown, ion
exchange softener regeneration, demineralizer regeneration, powdered resin demineralizer back flush, reverse
osmosis brine, boiler blowdown, evaporator blowdown, laboratory drains, sanitary wastes, diesel engine cooling
system discharge.
5-76
-------
Section 5 - Existing Industry Review
5.4.4.3
Wastewater Characteristics and Pollutant Sources
This subsection presents wastewater sources and characteristics as determined
from TRI and PCS data. This section also compares pollutant releases reported to TRI and PCS
for 2000 with pollutant releases reported in the 1996 PDS (1).
Wastewater Sources
The steam electric power industry is the single largest industrial user of water in
the United States. Most of the water used in the steam electric industry is cooling water. Water
is heated to high temperatures to create high-temperature and high-pressure steam, which turns
the turbines. A generator converts the turbine's mechanical energy into electrical energy. To
maintain high pressure in the process, low-pressure steam leaving the turbines must be cooled in
condensing tubes, which are kept cool with the constant flow of cooling water.
Types of wastewater discharged by steam electric facilities include cooling water,
ash-handling wastes, coal pile drainage, water treatment wastes, boiler blowdown, wet air
pollution control device wastes, maintenance cleaning wastes, and miscellaneous waste streams.
Table 5-57 lists the typical pollutants from various wastewater streams in steam electric
facilities.
Table 5-57. Sources of Process Wastewater in Steam Electric Facilities
Process
Cooling Water
Ash Handling
Coal Pile Runoff
Wastewater Treatment
Wastewater Pollutants
Chlorine, iron, copper, nickel, chlorinated organic compounds, temperature.
suspended solids
Generally: SiO2, A12O3, Fe3O3, CaO, MgO, TiO2, SO3, P2O3, and carbon residuals
Possibly: TDS, TSS, sulfate, calcium, chloride, magnesium, nitrate, turbidity,
antimony, arsenic, cadmium, chromium, copper, cyanide, iron, lead, mercury,
nickel, selenium, silver, thallium, vanadium, and zinc
Generally: Acidity. COD. calcium, magnesium, iron, aluminum, manganese,
silica, chloride, sulfate. TDS. TSS. arsenic, chromium, copper, nickel, vanadium.
and zinc
Possibly: Antimony, cadmium, beryllium, lead, selenium, thallium, mercury, and
silver
Clarification: Aluminum sulfate, sodium aluminate. ferrous sulfate, ferrous
chloride, and calcium carbonate
Filtration: Suspended solids
Ion Exchange: Calcium and magnesium salts, iron, copper, zinc, aluminum,
manganese, potassium, soluble sodium, chlorides, sulfates, organics, sulfuric acid,
and sodium hydroxide
Evaporation: Salts (type depends on intake water characteristics)
Softening: Calcium carbonate, magnesium hydroxide, and sodium salts
5-77
-------
Section 5 - Existing Industry Review
Table 5-57 (Continued)
Process
Boiler Slowdown
Wet Air Pollution Control
Device Waste
Maintenance Cleaning
Miscellaneous
Wastestreams
Wastewater Pollutants
Chlorides, sulfates, precipitated solids containing calcium and magnesium salts,
soluble and insoluble corrosion products, and chemical additives
Generally: No wastewater is produced
Possibly: Sodium and magnesium chlorides, calcium sulfates and sulfide, and
trace metals
Oil, grease, phosphates, nitrites, suspended solids, dissolved solids, iron, nickel.
chromium, vanadium, zinc, magnesium salts, polynuclear hydrocarbons, acidity.
alkalinity, and oil
Suspended solids, dissolved solids, oil and grease, phosphates, surfactants,
acidity, methylene chloride, phthalates, BOD, COD, fecal coliform, and nitrates
Source: Preliminary Study of the Steam Electric Point Source Category, 1996.
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-58 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for steam electric facilities. Facilities not reporting a flow
were not included in the median calculation. Data presented in Table 5-58 are based on major
dischargers reporting to PCS for 2000.
Table 5-58. 2000 Wastewater Flows for Steam Electric Facilities
SIC Code
4911
4931
Number of Major
Facilities Reporting
Nonzero Flows
497
8
Median Facility Flow
in 2000 (MGY)
58,661
44,390
Range of Facility
Flows in 2000
(MGY)
0.09-1,351,273
32-360,921
Total Flow in
2000 (MGY)
54,354,346
745,410
Source: EPA, PCSLoads2000.
Wastewater Pollutants
Table 5-59 lists the pollutants reported to TRI as discharged directly or indirectly,
which account for 95 percent of the total TWPE for steam electric facilities that reported to TRI
for 2000. This table presents the number of facilities that reported each chemical, total pounds
of chemical discharged, and total TWPE for each chemical. The 2000 TRI database does not
include all steam electric facilities or TRI-listed chemicals that are used or produced at levels
below reporting thresholds.
Table 5-60 lists the pollutants reported to PCS, which account for 95 percent of
the total TWPE for steam electric facilities that reported discharges by major dischargers to PCS
for 2000.
5-78
-------
Section 5 - Existing Industry Review
Table 5-59. Steam Electric Chemical Releases to Surface Water Reported to TRI for 2000
SIC
Code
Pollutant
Number of
Facilities
Reporting
TRI Total
(Ibs/yr)
TRI
TWPE/yr
Median
Facility
TWPE/yr
Range of
Facility
TWPE/yr
Percentage
of Total
SIC Code
TWPE
Cumulative
Percentage of
Total SIC Code
TWPE
SIC 4911- Electrical Services
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
Arsenic
Compounds
Polycyclic
Aromatic
Compounds
(PACs)"
Copper
Compounds
Vanadium
Compounds
Mercury
Compounds
Lead Compounds
Selenium
Compounds
Chromium
Compounds
Manganese
Compounds
Totals
111
4
191
83
48
90
39
164
198
342
156,682
9,611
337,322
284,781
1.251
34,898
51,944
109,971
521,321
4,193,725
543,582
475,475
211,468
177,197
146.500
78,172
58,203
56,290
36.718
1,854,204
624
102,805
182
100
293
65
583
46
34
3 - 68.235
4.284-265,581
1 - 11,284
1 - 25,947
37 - 55,377
2 - 38,806
1 - 8,331
1 - 13,820
0.1-3,451
29%
26%
11%
10%
8%
4%
3%
3%
2%
29%
55%
66%
76%
84%
88%
91%
94%
96%
SIC 4931- Electric and Other Services Combined
4931
4931
4931
4931
4931
4931
4931
4931
4931
4931
4931
Chlorine
Thallium
Mercury
Compounds
Copper
Compounds
Manganese
Vanadium
Compounds
Vanadium
Arsenic
Copper
Chromium
Compounds
Total
4
1
2
2
1
2
1
1
1
2
14
1.999
540
2
260
1200
135
130
21
110
112
15,895
973
541
234
163
85
84
81
73
69
58
2,441
6
NA
117
82
NA
42
NA
NA
NA
29
2-959
NA
117-117
3-160
19-65
NA
NA
NA
1-56
40
22
10
7
3
3
3
3
3
2
40
62
72
78
82
85
89
91
94
97
Source: EPA. TRIReleases2000.
NA - Not applicable. Only one facility reported discharge of chemical.
'The TWF for beuzo(a)pyreue was used as a representative TWF for the PACs category to calculate TWPE.
5-79
-------
Section 5 - Existing Industry Review
Table 5-60. Pollutant Discharges Reported by Major Steam Electric Facilities to PCS for
2000
SIC
Code
Pollutant
Number of
Facilities
Reporting
PCS Total
(Ibs/yr)
PCS
TWPE/yr
Median
Facility
TWPE/yr
Range of
Facility
TWPE/yr
Percentage
of Total SIC
Code
TWPE
Cumulative
Percentage of
Total SIC
Code TWPE
SIC 4911- Electrical Services
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
4911
Copper. Total (as CU)
Boron, Total (as B)
Arsenic, Total (as As)
Chlorine, Total
Residual
Lead, Total (as Pb)
Mercury. Total (as Hg)
.Arsenic. Total
Recoverable
Nitrogen. Nitrate Total
(as NO3)
Copper. Total
Recoverable
Aluminum, Total (as
Al)
Silver. Total (as Ag)
Iron. Total (as Fe)
Zinc, Total (as Zn)
Fluoride, Total (as F)
Boron, Total
Recoverable
Selenium, Total (as Se)
Totals
112
23
28
173
23
6
17
5
48
26
6
136
75
7
1
33
541
1.181.324
2,265,554
106,098
526.841
101,823
1.821
29.559
1,549,432.967
122.593
954,636
3,336
6,914,403
770,111
693,893
129.904
18,961
13,646,371,340
740,574
401,491
368,090
256,562
228,083
213.179
102.550
96,065
76,854
61,563
54,946
38,721
36,001
24,286
23,021
21,246
2,857,536
41
3,628
1,398
154
81
94
482
8
95
118
806
2
13
513
23,021
159
0.1-188,359
41-232.358
5-230.012
0.02- 34.034
1-174,004
4-211,218
1- 56,943
0.0002-
96,036
0.03-37,101
0.03-26,315
16-27,446
0.002-
18,655
0.02-7,212
0.1-12,524
NA
0.04-5,378
26%
14%
13%
9%
8%
7%
4%
3%
3%
2%
2%
1%
1%
1%
1%
1%
26%
39%
52%
61%
69%
76%
80%
83%
86%
88%
90%
91%
92%
93%
94%
95%
SIC 4931- Electric ami Other Services Combined
4931
4931
4931
4931
4931
Copper, Total (as Cu)
Chlorine, Total
Residual
Arsenic. Total
Recoverable
Selenium. Total
Recoverable
Total
2
2
1
2
9
75,077
45.185
724
1.869
3,152,453
47,066
22,004
2,512
2.094
75,673
23,533
1 1,002
2,512
1,047
2-47.064
9,560-
12,444
2,512
675-1,419
62%
29%
3%
3%
62%
91%
95%
97%
Source: EPA, PCSLoads2000.
5-80
-------
Section 5 - Existing Industry Review
As shown in Table 5-59, the pollutants reported to TRI that account for the
majority of the total TWPE are arsenic, PACs, copper, vanadium, mercury, lead, selenium,
chromium, and manganese. All of these pollutants are likely from coal pile runoff and ash-
handling wastes. Coal pile runoff occurs when stored coal is exposed to rainfall and impurities
in the coal are rinsed off in the stormwater. Ash is a product of coal or oil combustion and is
generally collected in ponds where the ash settles and the water is reused or treated; the ash pond
overflow is the ash-handling wastewater. Copper may also be present in cooling water because
of cooling equipment corrosion. Copper and other metals may also be present in treated metal
cleaning wastes.
As shown in Table 5-60, the pollutants reported to PCS that account for the
majority of the total TWPE are mainly metals, including copper, boron, arsenic, lead, aluminum,
silver, iron, zinc, and selenium. Chlorine, nitrogen, and fluoride also account for a high TWPE
in the industry. The metals and nitrogen are likely from coal pile runoff and ash handling.
Chlorine is used in the steam electric industry mainly to control the growth of microorganisms in
cooling water systems. Fluoride air pollution is a by-product of coal combustion, and the
fluoride present in the water is likely from wet air pollution control devices.
Tables 5-59 and 5-60 also demonstrate that facilities in SIC code 4911 discharge
the vast majority of pollutants contributing to the TWPE from this industry, where as SIC code
4931 accounts for less than 0.1 percent of the TWPE discharges from this industry reported to
TRI and less than 3 percent of the TWPE discharges reported to PCS.
EPA originally estimated chlorine loads for the industry using PCS data. During
subsequent review of the calculation, EPA identified several unique characteristics of the way
chlorine is reported to PCS for this industry that contributed to an overestimation of chlorine
loads. These characteristics include:
• Chlorine concentration and/or loads may only be reported as maximum
values.
• Some facilities report both TRC and FAC, and both values were included
in the calculation3.
• PCS may report pollutant concentrations as either a daily maximum or
average or as a 2-hour maximum or average. When the concentration is
reported as a daily value, EPA calculated annual loads assuming 24 hours
of discharge. However, the steam electric regulation (40 CFR Part 423)
states that chlorine may only be discharged for 2 hours a day. EPA
contacted steam electric facilities in each region and confirmed that
chlorine discharge occurs for only 2 hours a day. Therefore, chlorine
3 Free Available Chlorine (FAC) is a subset of Total Residual Chlorine (TRC).
5-81
-------
Section 5 - Existing Industry Review
loads based on 24 hours of discharge were overestimated by a factor of
twelve.
EPA adjusted the PCS loads to correct for facilities reporting only maximum
chlorine discharge, eliminate double counting of different types of chlorine, and correct the time
period of the discharge. Before the adjustments, the PCS chlorine loads were 8,907,981 pounds
per year (4,338,035 TWPE). After adjustments, the PCS chlorine loads were 526,841 pounds
per year (256,562 TWPE).
The 1996 PDS estimated parameter loadings from NPDES monitoring data,
which were extracted from PCS reports for 1992. A total of 512 major facilities reported to PCS
under SIC codes 4911 and 4931 in 1992. However, data were included in PCSLoads2000 for
only 361 facilities due to missing or erroneous data. In comparison, the PCS data for 2000
includes pollutant loads for 550 major dischargers. The 1996 PDS made the following
conclusions about the 1992 PCS monitoring data:
1. Chlorine and iron constitute the greatest overall loads in pounds;
2. Chlorine represents the greatest overall load in TWPEs; and
3. Mercury and arsenic were the greatest contributors of priority pollutant
TWPEs.
Table 5-61 shows the highest parameter loadings (as measured by TWPE)
reported to PCS in 1994, compared to the reported 2000 discharges.
Table 5-61. Five Highest Parameter Loadings (as Measured by TWPE)
Reported to PCS in 1992 and 2000
Parameter
Chlorine
Polychlorinated
Biphenyls, PCBs
Mercury
Boron
Arsenic
1992 PCS Data (361 facilities)
# Facilities
218
1
18
15
54
Pounds Released
7,710,000'
35
652
1,330,000
32,600
2000 PCS Data (550 facilities)
# Facilities
203
0
6
23
28
Pounds Released
497,503
NA
1.821
2,265,555
106,098
Source: EPA. Preliminary Study of die Steam Electric Point Source Category, 1996 wdPCSLoads2000.
'Chlorine pounds may represent a maximum due to calculation from reported daily maximum concentrations.
The PDS did not adjust chlorine loads to address the unique reporting issues
associated with chlorine. Before EPA adjusted the 2000 PCS data, the 1992 and 2000 estimated
chlorine loads were similar. However, because the chlorine releases reported in 2000 in Table
5-82
-------
Section 5 - Existing Industry Review
5-61 were adjusted, they might not be comparable to 1992 PCS data. PCBs were also identified
as a top pollutant using 1992 PCS data. However, only one facility reported a PCB discharge.
Mercury, boron, and arsenic were reported as top pollutants in both 1992 and 2000.
The following is a summary of the comparison of the 1996 PDS and the 2000 TRI
and PCS data used for this review:
• The total number of major dischargers reporting to PCS and having
estimated annual loads increased from 361 to 550;
• PCS releases:
— Chlorine and iron constituted the greatest overall loads in pounds
in 1992; nitrate nitrogen and iron constituted the greatest overall
loads in pounds in 2000.
— Chlorine, mercury, boron, and arsenic were the pollutants
discharged by more than one facility that contributed the bulk of
the TWPE estimate in 1992.
— Copper, boron, arsenic, chlorine, lead and mercury contributed the
bulk of the TWPE estimate in 2000.
— Chlorine contributed the most to the pollutant load in 1992, but not
in 2000 due to adjustments made to the load calculation.
Other Wastewater Pollution Issues
Some steam electric facilities use bromine in place of chlorine to prevent the
growth of microorganisms in condenser tubes. Bromine is not explicitly regulated under 40 CFR
Part 423, although total residual oxidants (TRO) or free available oxidants (FAO) may be limited
by facilities' NPDES permits. The 1996 PDS presented information from a survey of regional
contacts to determine the extent of bromine use. The survey showed that bromine usage was
increasing, and the limits for bromine are generally based on chlorine. Of the 550 facilities with
load estimation based on 2000 PCS data, 89 facilities (16 percent) reported TRO or FAO.
5.4.4.4 Pollutant Prevention and Treatment Technology
Most direct discharge facilities reporting to TRI use settling/clarification. Table
5-62 lists the treatment technologies most commonly used by steam electric facilities reporting
to TRI for 2000.
5-83
-------
Section 5 - Existing Industry Review
Table 5-62. Wastewater Treatment Operations Reported By Steam Electric Facilities,
TRI Reporting Year 2000
Wastewater Treatment Process
Settling/Clarification
Neutralization
Oil Skimming
Chemical Precipitation - Lime or Sodium Hydroxide
Equalization
Sludge Dewatering (Nonthermal)
Chemical Precipitation - Other
Filtration
Aerobic Biological Treatment
Other Chemical Treatment
Number of Facilities Reporting Use
Direct Dischargers
(235 facilities)
222
112
53
42
40
25
23
23
12
12
Indirect Dischargers
(11 facilities)
9
6
0
2
1
3
->
j
1
0
0
Source: EPA, Section 7A Table of the TPJ 2000 Database.
As new wastewater treatment technologies become affordable and available, they
have been used in the steam electric industry. One of the most commonly used in the industry is
membrane filtration, especially reverse osmosis. Along with membrane filtration, ultrafiltration
and microfiltration have been used to pretreat the water entering the reverse osmosis membranes.
The industry is also using electrodeionization (EDI). EDI combines ion exchange membranes
and ion exchange resins to produce boiler feed water with treatment that minimizes the use of
chemical additives. Additionally, the industry is using ozone and ultraviolet light to replace
chlorine as a disinfectant. (3)
5.4.4.5
Industry Trends
The steam electric industry was last studied by EPA in 1996 for ELGS (1). Table
5-63 compares the industry statistics presented in the 1996 PDS with data collected by the
Energy Information Administration (EIA) for 2000. Total electricity production has increased
by about 30 percent. The percentage of total electricity generated by nonutilities has increased
from 11 percent to 21 percent.
5-84
-------
Section 5 - Existing Industry Review
Table 5-63. Comparison of Industry Statistics
Operable Capacity, megawatts
Total Electricity Production,
million megawatthours
Electricity Production by Utilities,
million megawatthours
Electricity Production by
Nonutilities, million megawatthours
Number of Major Facilities With
Loads Calculated from PCS
1996 PDS
699,971
2,883
2,558 (89 percent of total)
3 25 (11 percent of total)
361
2000 Review
811,625
3,800
3,015 (79 percent of total)
785 (21 percent of total)
541
Source: Preliminary Study of the Steam Electric Point Source Category, 1996; U.S. Economic Census, 1997: EPA,
PCSLoads2000: EiA 2000 (2).
5.4.4.6
Stakeholder and Regional EPA Issues
Stakeholder and EPA Regional issues identified during ELGS review are
summarized below. Commenters noted:
• Applicability concerns for cogeneration units;
• Potential for toxic pollutants in coal pile runoff (including mercury and
selenium);
• The growing use of POTW effluent as cooling water; and
• The need to expand the scope of the regulations due to exempt facilities
that should not be exempt and many newer facilities that are not covered.
EPA met with representatives from the Utility Water Act Group (UWAG).
Concerns expressed by UWAG include:
• Using half the detection limit for values below the detection limit when
pollutant concentrations are reported at all during the year might
overestimate metal loads;
• The failure to adjust for intake pollutants unfairly disadvantages the steam
electric industry;
• EPA should exclude pollutants not representative of the loads discharged
by steam electric facilities from the pollutant data; and
• The toxic-weighting factor for chlorine is inappropriate.
5-85
-------
Section 5 - Existing Industry Review
5.4.4.7 Conclusions
In the screening-level analysis of TRI data, EPA identified the major toxic
pollutants associated with steam electric power plants as metals (including arsenic, copper and
others) and PACs. These pollutants likely come from coal pile runoff and ash-handling wastes.
With the exception of copper and iron in chemical metal cleaning, the steam electric ELGS do
not contain limits for most metals or PACs.
In the review of PCS data, EPA identified the major pollutants of concern as
metals (copper, boron, arsenic, and others) and chlorine. The metals are likely from coal pile
runoff and ash handling, while chlorine is used as a biocide in cooling water systems.
Coal pile runoff has effluent limitations only for TSS. The ash-handling
wastestream has limits for oil and grease and TSS. Neither wastestream has limits for metals or
PACs, though coal pile runoff and ash handling may be sources of toxic metals and PACs.
The once-through cooling and the cooling tower blowdown wastestreams have
limits for chlorine. However, there are available substitutes for chlorine that are not controlled
by 40 CFR Part 423. Bromine is an effective biocide that is being used in the industry. Some
permits may limit bromine based on the chlorine limits, although bromine is more toxic than
chlorine in freshwater.
EPA still lacks information about the steam electric industry. EPA does not know
the following:
• The source of metals in reported discharge;
• The concentrations of pollutants discharged and present in in-process
wastestreams;
• The available control technologies for metals and PACs;
• Alternatives to chlorine-containing biocides, including their toxicity, cost,
and other environmental impacts;
• The impact of nondetects being estimated to be equal to half the detection
limit; and
• How electricity production wastewater streams are controlled at
cogeneration operations.
Because this industry ranks high relative to other industries in terms of TWPE
and because EPA continues to have data gaps and issue that remain unresolved, EPA will
continue to study of the steam electric industry during the next review cycle.
5-86
-------
Section 5 - Existing Industry Review
5.4.4.8
References
U.S. EPA. Preliminary Study of the Steam Electric Point Source Category.
Washington, D.C. 1996.
Energy Information Administration. Electric Power Annual 2000. U.S.
Department of Energy. DOE/EIA-0348(2000)/1. Washington, D.C. 2001.
Available online at: http://tonto.eia.doe.gov/FTPROOT/electricitv/0348001.pdf.
Industrial WaterWorld. "Growth Projected for Power Plant Water Treatment
Technologies Market." January 2004. Available online at:
http://ww.pennnet.com/ Articles/Article_Display.cfm?Section=Articles&ARTICL
E ID=199184&VERSION NUM=l&pc=ENL.
5.4.5
Textile Mills
5.4.5.1
Industry Description
The textile industry includes facilities that manufacture and process textile
materials, such as carpets, broad woven fabrics, and knitwear. These facilities are classified
under SIC major group 22, Textile Mill Products, which includes facilities using wet processes,
such as scouring, dyeing, finishing, printing, and coating, discharge contact wastewater. EPA
divided the Textile Mills Point Source Category into nine subcategories based on the wet
processing segment of the industry. Table 5-64 lists the regulated subcategories as well as their
associated SIC codes.
Table 5-64. Textile Mills Subcategories
Subpart
A
B
C
D
E
F
G
H
I
Name
Wool Scouring1
Wool Finishing1
Low Water Use Processing
Woven Fabrics Finishing1
Knit Fabric Finishing1
Carpet Finishing1
Stock & Yarn Finishing1
Nonwoven Manufacturing
Felted Fabric Processing
Applicable SIC Code(s)
2299
2231
2211, 2221, 2231, 2241, 2253, 2254, 2259, 2273,
2281, 2282, 2284, 2295, 2296, 2298
2261, 2262
2251,2252,2257,2258
2273
2269
2297
2299
Source: Preliminary Study of the Textile Mills Point Source Category, 1996.
Subcategories with wet processing.
5-87
-------
Section 5 - Existing Industry Review
EPA obtained information on the number of facilities in the Textile Mills
category from three sources: the 1997 U.S. Economic Census, the TRIReleases2000, and
PCSLoads2000. The 2000 TRI database includes all facilities reporting discharges to any media.
The 2000 PCS database includes facilities that are permitted for discharge to surface waters.
Table 5-65 lists the number of textile mills by SIC code from these sources. The number of
facilities reporting to TRI for 2000 represents only about 5 percent of the textile industry based
on the total number of textile mills in the census, while the number of facilities reporting
discharges to PCS for 2000 represents less than 2 percent of the total industry.
Table 5-66 presents the number and percentage of the textile mills in
TRIReleases2000.
Textile mills are predominantly located on the east coast, with concentrations in
North Carolina and South Carolina.
Table 5-65. Number of Textile Mills
SIC Code
2211 - Broadwoven Mils, Cotton
2221 - Broadwoven Mills, Mamnade
Fiber & Silk
2231 - Broadwoven Mills, Wool
224 1 - Narrow Fabric
2251 - Women's Hosiery
2252 - Hosiery. NEC
2253 - Knit Outerwear
2254 - Knit Underwear
2257 - Circular Knit Fabric Mills
2258 - Lace and Warp Knit
2259 - Knitting Mills, NEC
2261- Finishers, Broadwoven Cotton
2262 - Finishers, Broadwoven
Manmade & Silk
2269 - Finishers, NEC
2273 - Carpets & Rugs
228 1 - Yarn Spinning
2282 -Yam Texturing
1997 U.S.
Economic Census
398
452
78
273
137
455
643
54
359
262
62
442
306
155
474
393
146
2000 TRI-All
Dischargers
15
28
13
5
0
->
j
4
1
1
4
3
13
15
10
17
5
1
2000 PCS
Major
Dischargers
12
8
4
0
1
1
2
1
3
3
0
11
12
11
4
3
0
Minors
Dischargers
9
10
2
2
0
2
0
0
0
0
0
7
2
2
1
7
5
-------
Section 5 - Existing Industry Review
Table 5-65 (Continued)
SIC Code
2284 - Thread Mills
2295 - Coated Fabrics
2296 - Tire Cord and Fabrics
2297 - Nonwoven Fabrics
2298 - Cordage & Twine
2299 - Textile Goods, NEC
Total
1997 U.S.
Economic Census
67
229
21
193
201
355
6,155
2000 TRI-All
Dischargers
4
6
8
5
3
5
296 (4.8%)
2000 PCS
Major
Dischargers
2
0
0
0
0
1
79 (1.3%)
Minors
Dischargers
0
3
0
3
1
5
61 (0.99%)
Source: U.S. Economic Census, 1997; EPA, TRIReleases2000; EPA, PCSLoads2000.
Table 5-66. Number of Textile Mills by Discharge Type (TRI 2000)
SIC
Code
2211
2221
2231
2241
2252
2253
2254
2257
2258
2259
2261
2262
2269
2273
2281
2282
2284
Direct Dischargers Only
Number
3
0
3
0
0
0
1
0
2
1
1
5
2
1
0
0
0
Percentage
of All
Facilities in
SIC Code
20%
0%
23%
0%
0%
0%
100%
0%
29%
25%
4%
21%
9%
3%
0%
0%
0%
Indirect Dischargers
Only
Number
4
3
2
0
->
J
3
0
0
2
2
12
10
8
15
0
1
4
Percentage
of All
Facilities in
SIC Code
27%
11%
15%
0%
100%
75%
0%
0%
29%
50%
50%
42%
35%
41%
0%
25%
57%
Both Direct and
Indirect Dischargers
Number
1
1
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
Percentage
of All
Facilities in
SIC Code
6%
4%
0%
0%
0%
25%
0%
0%
0%
0%
0%
0%
0%
3%
0%
0%
0%
No Reported
Wastewater Discharge
Number
7
24
8
5
0
0
0
1
->
3
1
11
9
13
20
5
3
->
3
Percentage
of All
Facilities in
SIC Code
47%
85%
62%
100%
0%
0%
0%
100%
43%
25%
46%
37%
56%
54%
100%
75%
43%
5-89
-------
Section 5 - Existing Industry Review
Table 5-66 (Continued)
SIC
Code
2295
2296
2297
2298
2299
Total
Direct Dischargers Only
Number
1
0
1
0
1
Percentage
of All
Facilities in
SIC Code
2%
0%
8%
0%
8%
22 (7.4%)
Indirect Dischargers
Only
Number
3
6
4
0
4
Percentage
of All
Facilities in
SIC Code
6%
46%
33%
0%
31%
86 (29%)
Both Direct and
Indirect Dischargers
Number
2
2
0
0
0
Percentage
of All
Facilities in
SIC Code
4%
15%
0%
0%
0%
8 (2.7%)
No Reported
Wastewater Discharge
Number
44
5
7
3
8
Percentage
of All
Facilities in
SIC Code
88%
38%
58%
100%
62%
180(61%)
Source: EPA. TRIReleases2000.
5.4.5.2
Regulatory Background
Under the existing ELGS for the Textile Mills Point Source Category, EPA
divided the industry into nine subcategories based on the type of processes used. ELGS found in
40 CFR Part 410 are applicable to process wastewater discharged from operations in the nine
subcategories that manufacture textiles. ELGS for the Textile Mills category are described
below:
EPA first proposed ELGS in February 1974 based on BPT, BAT, NSPS,
and PSNS.
EPA first promulgated ELGS in July 1974.
• The U. S. Court of Appeals remanded all regulations except BPT to EPA
for reconsideration.
• EPA promulgated a revised rule in 1982 that:
— Imposed BPT limits on two new subcategories,
— Revised BAT and NSPS for all subcategories, and
— Required POTWs to enforce local limits in place of PSNS or PSES
(i.e., no pretreatment standards established for new or existing
sources).
5-90
-------
Section 5 - Existing Industry Review
Subcategories for this category are presented below.
Subpart
A
B
C
D
E
F
G
H
I
Subcategory
Wool Scouring1
Wool Finishing1
Low Water Use Processing
Woven Fabrics Finishing1
Knit Fabric Finishing1
Carpet Finishing1
Stock & Yarn Finishing1
Nonwoven Manufacturing
Felted Fabric Processing
Source: Preliminary Study of the Textile Mills Point Source Category, 1996.
Subcategories with wet processing.
• EPA established the basis for BPT as biological treatment.
• EPA established the basis for BAT for the nine subcategories as follows:
— Biological treatment (same technology as BPT): Felted Fabric
Processing.
— Biological treatment and filtration: Woven Fabric Finishing; Knot
Fabric Finishing; Carpet Finishing; Stock& Yarn Finishing; and
Nonwoven Manufacturing.
— Biological treatment and chemical coagulation and filtration: Wool
Scouring; Wool Finishing; and Hosiery Products Subdivision of
Knit Fabrics.
The current ELGS, summarized in Table 5-67, are codified at 40 CFR Part 410.
5-91
-------
Section 5 - Existing Industry Review
Table 5-67. Pollutants Regulated by Existing Textile Mill ELGS
40CFR
Part
410.10
410.20
410.30
410.40
410.50
410.60
410.70
410.80
410.90
Subcategory
Wool Scouring1
Wool Finishing1
Low Water Use
Processing
Woven Fabrics
Finishing1
Knit Fabric
Finishing1
Carpet Finishing1
Stock & Yarn
Finishing1
Nonwoven
Manufacturing
Felted Fabric
Processing
BPT
BOD5. COD, TSS, Oil &
Grease, Sulfide, Phenols,
Total Chromium, pH
BOD5, COD, TSS. Sulfide.
Phenols. Total Chromium. pH
BOD5. COD, TSS, pH
BOD5, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BOD5, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BOD5, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BOD,. COD, TSS, Sulfide.
Phenols, Total Chromium, pH
BOD5, COD, TSS. Sulfide.
Phenols, Total Chromium. pH
BOD,, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BAT
COD. Sulfide.
Phenols. Total
Chromium
COD. Sulfide,
Phenols, Total
Chromium
COD
COD, Sulfide,
Phenols, Total
Chromium
COD, Sulfide,
Phenols, Total
Chromium
COD, Sulfide,
Phenols, Total
Chromium
COD. Sulfide.
Phenols, Total
Chromium
COD. Sulfide,
Phenols, Total
Chromium
COD, Sulfide,
Phenols, Total
Chromium
NSPS
BOD5, COD. TSS,
Sulfide. Phenols. Total
Chromium, pH
BOD5. COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5, COD. TSS, pH
BOD,, COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5, COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5, COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5, COD. TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5. COD, TSS,
Sulfide, Phenols, Total
Chromium. pH
BOD,. COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
Source: Code of Federal Regulations .
'Subcategories with wet processing.
5.4.5.3
Wastewater Characteristics and Pollutant Sources
This subsection presents the wastewater characteristics of PCS reporting facilities
and the pollutants contributing the highest load as reported by TRI and PCS facilities. This
section also compares pollutant releases reported to TRI and PCS for 2000 with pollutant
releases reported in the 1996 Preliminary Study (1). For this 304(m) review, EPA collected very
little new information on indirect dischargers and continues to rely on the 1996 Preliminary
Study.
5-92
-------
Section 5 - Existing Industry Review
Wastewater Characteristics
Most major facilities reporting to PCS also report discharge outfall flow rates.
Table 5-68 presents the total annual flow (in millions of gallons) for 2000, median annual
discharge flow, and the range of annual flows for each SIC code. Facilities not reporting a flow
were not included in the median calculation. Data presented in Table 5-68 are based on major
dischargers reporting to PCS for 2000. In some cases, the PCS reported flows may include
stormwater discharges and noncontact cooling water, as well as process wastewater.
Table 5-68. 2000 Wastewater Flows for Textile Mills
SIC Code
2211
2221
223 11
225 11
22521
2253
2254
22571
2258'
2261'
2262'
2269
2273 '
2281
2284
2299
Total
Number of Major
Facilities
Reporting
Nonzero Flows
12
8
4
1
1
2
1
3
3
11
10
11
4
3
2
1
79
Median Facility
Discharge 2000
(MGY)
422
114
96
22
52
79
796
202
286
726
332
132
550
221
206
70
Range of Facility
Flows 2000 (MGY)
9-1,359
13-311
39-1,088
NA
NA
64-95
NA
7-291
246-293
49-1,778
1-5,061
7-675
490-672
67-330
30-382
NA
Total Flow 2000 (MGY)
5,467
1,273
1,320
22
52
159
796
500
825
7,814
7,697
2,950
2,262
618
413
70
32,238
Source: EPA, PCSLoads2000.
'Wet Process.
NA - Not applicable; only one facility reported a nonzero discharge flow rate.
Finishers of broadwoven cotton, manmade fibers, and silk (SIC codes 2261 and
2262) had the largest total wastewater flows. Of the 10 facilities reporting wastewater flows in
SIC code 2262, one facility's reported flow accounts for 66 percent of the total wastewater flow.
The total annual wastewater flow is more equally distributed among the 11 facilities reporting in
5-93
-------
Section 5 - Existing Industry Review
SIC code 2261, and no facility's reported flow accounts for more than 23 percent of the total
wastewater flow.
Table 5-69 lists the pollutants reported to TRI as discharged directly or indirectly,
which account for 95 percent of the total TWPE for textile mills that reported to TRI for 2000.
This table presents the number of facilities that reported each chemical, total pounds of chemical
discharged for SIC code 22, and total TWPE for each chemical.
Table 5-70 lists the pollutants reported to PCS, which account for 95 percent of
the total TWPE for textile mills that reported discharges to PCS for 2000.
As shown in Tables 5-69 and 5-70, the pollutants reported to TRI and PCS that
account for the majority of the total TWPE are sulfide and chlorine. In TRI, over 97 percent of
the TWPE results from indirect dischargers. In some dyeing processes, sulfur dyes are reacted
with sodium sulfide to make the sulfur dye water soluble. This operation is the source of sulfide
in textile mill effluent. Sulfide is regulated by BPT and BAT limitations in every wet processing
subcategory. Thirty-day average limits on sulfide range from 0.04 to 0.22 kg/kkg of product.
Chlorine is used primarily in bleaching processes, and in minor applications, to disinfect treated
wastewater and remove color from wastewater (1).
In PCS, the chlorine loads are reported as total residual chlorine (TRC). The TRC
discharges may be calculated from reported daily maximum concentration, and thus represent a
maximum mass discharge. Other pollutant mass discharges are based on reported monthly
averages for either mass or concentration.
EPA conducted a study of the textile mills industry in 1996 to determine if
existing ELGS for this industry required updating or revision. Data sources for the 1996
Preliminary Study include the Textiles Blue Book, the U.S. Department of Commerce, POTW
surveys, and the TRI and PCS databases. Table 5-71 presents the total annual loads of chlorine
and sulfide that were reported in the 1996 Preliminary Study (1). The 1996 study used 1992 TRI
data and 1994 PCS data.
The TRI database for 1992 or any reporting year does not include all textile mills
or TRI-listed chemicals that are used or produced at levels below reporting thresholds.
Furthermore, estimates may be based on monitoring data or on mass balance calculations. The
accuracy and comparability of these estimates, therefore, is unknown, as the method of
estimation may vary from facility to facility or for the same facility for different time periods.
5-94
-------
Section 5 - Existing Industry Re\>iew
Table 5-69. Textile Mill Chemical Releases to Surface Water Reported to TRI for 2000
SIC Code
22
22
22
Pollutant
Chlorine
Sodium Nitrite
Chromium
Compounds
Number of Facilities
Reporting1
Direct
5
0
7
Indirect
3
5
6
TRI Total
(Ibs/yr)
Direct
2,681
0
1.714
Indirect
126,296
43.559
1.677
Total
128,977
43.559
3.391
TRI TWPE/yr
Direct
1,306
0
877
Indirect
61,504
16,262
858
Total
62,810
16.262
1.735
Median
Facility
TWPE/yr
210
890
92
Range of
Facility
TWPE/yr
2-53,125
93-13,355
1-505
Percentage
of Total
SIC Code
TWPE
74%
19%
2%
Cumulative
Percentage
of Total
SIC Code
TWPE
74%
93%
95%
Source: EPA. TRIReleases2000.
'A total of 116 facilities reported wastewater releases to TRI for 2000.
-------
Section 5 - Existing Industry Review
Table 5-70. Textile Mill Pollutant Discharges Reported to PCS for 2000
SIC
Code
22
22
22
22
Pollutant
Sulfide. Total
(asS)
Chlorine
Sulfide, Total
Copper. Total
(as Cu)
Number of
Facilities
Reporting1
66
30
3
33
PCS Total
(Ibs/yr)
53.067
223,975
5,708
19,366
PCS
TWPE/yr
148.616
109.072
15.985
12.140
Median
Facility
TWPE/yr
885
39
6.443
23
Range of
Facility
TWPE/yr
22-44.274
0-78,414
1,332-
8,210
0-10,949
Percentage
of Total
SIC Code
TWPE
50%
37%
5%
4%
Cumulative
Percentage
of Total
SIC Code
TWPE
50%
87%
92%
96%
Source: PCSLoads2000.
'PCS loads contains discharge data for 79 facilities in SIC code 22.
Table 5-71. Textile Mill Pollutant Discharges Reported in 1996 Preliminary Study
Pollutant
Chlorine
Sulfide
Total Annual Load (Ib/yr)
1994 PCS1
86,598
32.254 to 71. 118
Number of
Reporting
Facilities
10
10
1992 TRI
259,601
NRb
Number of
Reporting
Facilities
21
NRb
Source: Preliminary Study of Textile Mills Point Source Category, 1996, Table IX-1, pg. 47.
'The range of PCS loads represents values that were calculated assuming ND = 0 and ND = !/2 DL. Chlorine loads
were calculated only assuming ND = 0.
NR - The pollutant was not reported in the data source.
A total of 228 textile mills reported chemical releases to TRI for 1992 compared
to the 296 mills that reported for 2000. Table 5-72 presents the highest total annual chemical
releases reported to TRI for 1992, compared to the data reported for 2000. The total pounds and
the number of facilities reporting releases of these chemicals have significantly decreased from
1992 to 2000. Because many reported releases are based on estimates (not measurements), the
decrease in reported releases might be attributed to changes in estimation methodology as well as
reduction in actual releases.
5-96
-------
Section 5 - Existing Industry Review
Table 5-72. Eight Highest Chemical Releases Reported to TRI in 1992 and 2000
Chemical
Ammonium sulfate1
Sulfuric acid1
Ammonia
Biphenyl
Ethylene glycol
Chlorine
Chromium compounds
Chromium
1992 TRI Database
Number of
Facilities
38
19
62
23
19
21
20
1
Pounds Released
2,572,379
1,284,439
978,434
668,528
639,457
259,601
125,477
512
2000 TRI Database
Number of
Facilities
0
1
22
5
8
8
13
2
Pounds Released
NR
0
77.221
3,660
22,383
128,977
3,390
231
Source: EP, Preliminary Study of the Textile Mills Point Source Category, 1996 and TRIReleases2000.
'Ammonium sulfate and sulfuric acid were removed from the TRI list and reporting requirements.
NR - The pollutant was not reported to the data source.
The 1996 study estimated parameter loadings from NPDES monitoring data,
which were extracted from PCS reports for 1994. A total of 423 records were found under SIC
code 22, of which only 59 reported both concentration and flow values needed to estimate loads.
For any given pollutant, 10 was the highest number of facilities reporting discharges of that
pollutant. In comparison, the PCS data for 2000 include pollutant loads for 79 major
dischargers, and up to 69 facilities reported discharges of a single pollutant. The 1996
Preliminary Study made the following conclusions about the 1994 PCS monitoring data:
1. Metal parameters consistently detected at low levels were copper,
chromium, and zinc;
2. Ammonia, chlorine, and sulfide were the most frequently monitored
inorganic parameters; and
3. Few organic priority pollutants were consistently identified.
Table 5-73 presents the highest parameter loadings reported to PCS in 1994,
compared to the reported 2000 discharges.
5-97
-------
Section 5 - Existing Industry Review
Table 5-73. Five Highest Parameter Loadings Reported to PCS in 1994 and 2000
Parameter
Zinc
Chlorine
Sulfide
Ammonia
Copper
1994 PCS Data
Number of
Facilities
10
10
10
10
10
Pounds Released
233.856
86,598
71,118
48,784
25,228
2000 PCS Data
Number of
Facilities
28
30
66
34
33
Pounds Released
3.949
223,975'
53,067
120,551
19,366
Source: EPA, Preliminary Study of die Textile Mills Point Source Category, 1996; PCSLoads2000.
'Chlorine pounds may represent a maximum due to calculation from reported daily maximum concentrations.
Chlorine contributes the majority of the TWPE for the textile industry in 2000.
Chlorine accounts for 90 percent of the total TWPE in TRI and 30 percent of the total TWPE in
PCS in 2000. Chlorine releases from 1994 and 2000 may not be comparable since 2000 chlorine
pounds might have been calculated using daily maximum concentrations. However, the 1994
chorine discharges might be calculated the same way. Sulfide was also identified in PCS as a
high contributor to the pollutant loading, accounting for 60 percent of the total TWPE in 2000.
According to data in Table 5-73, sulfide releases per facility decreased although the number of
reporting facilities increased since 1994. Ammonia is the only pollutant for which reported total
industry releases were higher in 2000 than in 1994; however, the per-facility releases decreased
more than 15 percent4.
The following is a summary of the comparison of the 1996 Preliminary Study and
the 2000 TRI and PCS data used for this review:
• The total number of facilities reporting to TRI has increased from 228 to
296;
• The total number of major dischargers with data in PCS has increased
from 59 to 79;
• Total releases of the top five pollutants reported to TRI for the industry in
1992 have significantly decreased;
• Total chlorine releases reported to TRI have decreased from 259,601 to
128,977 Ib/yr;
4Based on the total pounds released and the number of reporting facilities for 2000 and 1994.
5-98
-------
Section 5 - Existing Industry Review
• Chlorine releases in the PCS 2000 data are not comparable to 1994 data
since the 2000 pounds might have been calculated from reported daily
maximum concentrations; and
• Ammonia is the only pollutant for which reported total industry releases
were higher in 2000 than in 1994.
Wastewater Pollutant Sources
Types of wastewater discharged by textile mills include cleaning water, process
water, noncontact cooling water, and storm water. Likely sources of textile process wastewater
include wet processes such as scouring, dyeing, finishing, printing, and coating of textile
products. One of the largest sources of wastewater pollutants is desizing, or the process of
removing size chemicals from textiles (1). Typical sizing agents include starch, polyvinyl
alcohol, carboxymethyl cellulose, and polyacrylic acid (2).
Dyeing processes are another large source of wastewater. The primary source of
wastewater from dyeing operations is spent dyebath and washwater. Wastewater from dyeing
operations typically contains residual dye and auxiliary chemicals, as well as cleaning solvents.
Dyes are also a major source of metals in textile wastewater. Metals are usually present in low
concentrations, and typically include zinc, nickel, chromium, and cobalt.
Finishing processes generally produce wastewater containing natural and
synthetic polymers. Chemical handling and high pH are the primary pollution concerns
associated with the bleaching process. Table 5-74 lists the typical pollutants generated from
various process steps in textile manufacturing.
Table 5-74. Sources of Process Wastewater in Textile Manufacturing
Process
Slashing/Sizing
Desizing
Scouring
Bleaching
Mercerizing
Dyeing
Printing
Finishing
Wastewater
BOD; COD; metals; cleaning waste, size
BOD from water soluble sizes: synthetic size: lubricants; biocides;
Disinfectants and insecticide residues; NaOH; detergents; fats: oils
lubricants; spin finishes; spent solvents
antistatic compounds
, pectin; wax; knitting
Hydrogen peroxide, sodium silicate or organic stabilizer; high pH
High pH; NaOH
Metals; salt; surfactants; toxics; organic processing assistants; cationic materials: color;
BOD; COD; sulfide; acidity /alkalinity; spent solvents
Suspended solids; urea; solvents; color; metals; heat; BOD: foam
BOD; COD; suspended solids: toxics; spent solvents
Source: EPA., Preliminary Study of the Textile Mills Point Source Category, 1996.
5-99
-------
Section 5 - Existing Industry Review
Other Wastewater Pollution Issues
Dyes and pigments released from the printing and dyeing processes are the major
sources of color in textile wastestreams. Dyes that are not anchored to fabric are discarded as
spent dyebath. Large releases of color can interrupt photosynthesis, which can decrease the
levels of dissolved oxygen in receiving streams (2). EPA has not historically regulated color in
the ELGS program.
Brominated flame retardants (BFRs) might be released to wastewater during
finishing steps of the textile manufacture process. Significant water releases might result from
bath dumps from finishing processes, equipment cleaning waste, rinse water from the cleaning of
containers that contained the flame retardant chemicals, and area washdowns (3). The five major
types of BFRs include:
• Tetrabromobisphenol A;
• Hexabromocyclododecane;
• Decabromodipheyl ether (DBDE);
• Octabromodiphenyl ether (OBDE); and
• Pentabromodiphenyl ether (PentaBDE).
DBDE is the most commonly used BFR, and accounts for 80 percent of the total
polybrominated diphenyl ether production worldwide. BFRs have been detected in the
environment in locations far from sites where they are produced or used. Research has shown
that concentrations of BFRs in the environment and in humans are increasing (4). The detection
of PBDEs in human breast milk raises concerns regarding the persistence, bioaccumulation, and
potential for toxicity in humans and animals. Little is known about the fate of BFRs once they
are released into the environment.
Sources of aquatic toxicity in textile wastewaters include salt, surfactants, ionic
metals and their metal complexes, toxic organic chemicals, biocides, and toxic anions. Salt has
been identified as a potential problem because large quantities of salt are often needed to
improve dye fixation onto fibers (2). The salts most commonly used in textile processes are
sodium chloride and sodium sulfate. Magnesium chloride and potassium chloride are used less
frequently. Surfactants are widely used in textile processes, and can be a large contributor to
effluent aquatic toxicity (2). Since salt and surfactants are not reported to TRI or PCS by textile
mills, EPA does not have characterization data for these parameters.
5.4.5.4 Pollutant Prevention and Treatment Technology
Most direct-discharging facilities reporting to TRI use aerobic biological
treatment. Table 5-75 lists the treatment technologies used by textile mills reporting to TRI for
2000.
5-100
-------
Section 5 - Existing Industry Review
Table 5-75. Wastewater Treatment Operations Reported By Textile Mills,
TRI Reporting Year 2000
Wastewater Treatment Process
Aerobic Biological Treatment
Anaerobic Biological Treatment
Settling/Clarification
Sludge Dewatering (Nonthermal)
Thermal Drying/Dewatering
Emulsion Breaking - Chemical
Equalization
Filtration
Oxidation
Neutralization
Chemical Precipitation - Other
Chemical Precipitation - Lime or Sodium Hydroxide
Chemical Precipitation - Sulfide
Cyanide Oxidation
Other Physical Treatment
Oil Skimming
Other Chemical Treatment
Air Floatation
Other Blending
Other Liquid Phase Separation
Number of Facilities Reporting Use
Direct Dischargers1
(22 facilities)
17
1
19
9
0
0
13
9
5
10
->
j
2
1
1
2
2
3
1
1
1
Indirect Dischargers1
(30 facilities)
4
1
13
9
1
3
13
11
1
15
8
6
0
0
0
1
2
2
2
1
Source: EPA, Section 7A Table of the TRI 2000 Database.
'Of die facilities mat provided information on their wastewater treatment operations to TRI in 2000, 22 facilities
reported direct releases, 30 reported transfers to POTWs, and 1 reported both direct releases and transfers to
POTWs.
The treatment and control technologies used by indirect dischargers in the 1996
Preliminary Study include:
• Biological Treatment;
• Equalization;
• Filtration;
• Neutralization;
5-101
-------
Section 5 - Existing Industry Review
• Oil-Water Separation;
• Screening;
• Sedimentation;
• Sulfide Oxidation; and
• Temperature.
The 1996 Preliminary Study compares water use for the textile industry in 1993
and 1980. In 1980, textile water use was, on average, 15.1 gal/lb of fiber processed. In 1993,
the water use was, on average, to 11.7 gal/lb of fiber processed. This 22-percent reduction in
water use resulted from more efficient use of water in wet processing and the development of
water conservation programs at textile mills throughout the industry (1). Comparable
information on production-normalized water use for 2000 was not available in the data sources
EPA consulted for this review. Examples of water reuse at textile mills include:
• Print screen rinse water is reused for rinsing;
• Rinses from scouring machines are reused in scouring process; and
• Sizing chemicals are reused after being removed from fabric.
In addition to water reuse, other pollution prevention practices reported in the 1996 Preliminary
Study included:
• Alternative process chemicals (e.g., biodegradeable, water soluble);
• Process changes (e.g., dyeing, sizing); and
• Equipment changes (e.g.,dye machinery).
5.4.5.5 Industry Trends
EPA last studied the textile industry in 1996 (1). Table 5-76 compares the textile
industry as presented in the 1996 Preliminary Study with 1997 Economic Census data and TRI
data for 2000. Although the total number of establishments has decreased, the results of this
review are consistent with the 1996 Preliminary Study finding that about half of the textile mills
are in wet processing SIC codes, and a large percentage of discharges from textile mills are
transferred to POTWs.
5-102
-------
Section 5 - Existing Industry Review
Table 5-76. Comparison of Industry Statistics
Total number of establishments
Percentage of establishments in wet
processing SIC codes
Percent of establishments that
discharge to POTWs
1996 Preliminary Study
5,887 mills in 1992 Census of
Manufacturers
35-50%
91-96%
2000 Review
4,792 mills in 1997 Economic
Census
50% of mills in 1997 Economic
Census
80% of the 72 mills reporting
discharges to TRI for 2000
Source: EPA, Preliminary Study of the Textile Mills Point Source Category, 1996; U.S. Economic Census, 1997;
and EPA, TRIReleases2000.
5.4.5.6
Stakeholder and EPA Regional Issues
Stakeholder and EPA Regional issues identified during this review are
summarized below:
• In general, stakeholders were concerned with industrial sludge disposal,
and based on an EPA Region 4 poll, stakeholders expressed a need for a
measurable limit for color and copper.
• The source for releases of color and copper is the dyeing process.
• Because facilities are not required to report color releases to TRI and PCS,
available data are not sufficient to evaluate color discharges for this
industry. Only one facility reported color releases to PCS.
• Copper releases account for less than 1 percent of the total TWPE in TRI
and PCS.
EPA did not receive any public comments on the December 31, 2003 Preliminary
Effluent Guidelines Program Plan, FRN [FRL-7604-7] from this industry.
5.4.5.7
Conclusions
Pollutants driving the total TWPE for this industry are sulfide and chlorine.
Based on 2000 PCS data, sulfide accounts for 50 percent of the total TWPE for the textile
industry. Currently, every wet processing subcategory under 40 CFR Part 410 contains
limitations under BPT and BAT for sulfide. According to the 1996 Preliminary Study, some
textile mills use sulfide oxidation as a pretreatment technology to reduce sulfide concentrations.
At this time, EPA has not identified any other pollution prevention or treatment processes to
lower sulfide releases. 2000 TRI and PCS data showed high TWPE values for chlorine, which
accounts for 37 percent of the PCS TWPE and 90 percent of the TRI TWPE.
5-103
-------
Section 5 - Existing Industry Review
The number of facilities reporting to TRI for 2000 represents only about 5 percent
of the textile industry based on the total number of textile mills in the 1997 Economic Census,
while the number of facilities reporting discharges to PCS for 2000 represent less than 2 percent
of the total industry. Consequently, the reported pollutant discharges may not accurately
characterize the entire textile industry. In comparison, the 1996 Preliminary Study presents year
1992 TRI data for 228 textile mills and 1994 PCS data for 59 textile mills. When compared to
the 1992 Census count of textile mills, the 1992 TRI data represent only about 4 percent of
textile mills, and PCS data represent only about 1 percent of textile mills in the United States.
Other data quality concerns include:
• Releases reported to TRI might be based on estimates, not measurements,
and tend to overestimate actual discharges.
• Total residual chlorine discharges reported to PCS may reflect daily
maximum concentration. Thus, loads calculated from this maximum
concentration represent a maximum pollutant mass discharge.
Textile mills may release compounds that are not reported to TRI or in PCS, such
as BFRs used in textile finishing processes. BFRs are bioaccumulative and persistent chemicals
that have been detected in the environment and in humans. However, EPA does not currently
have actual data for these chemicals. EPA is concerned about persistent bioaccumulative
compounds and has formed a task force to consider these compounds further. The ELG program
will follow the work of this task force and plans to incorporate relevant suggestions/concerns
into future planning activities. In the next annual review, EPA will continue to obtain and
consider information to fill remaining data gaps.
5.4.5.8 References
1. U.S. EPA. Preliminary Study of the Textile Mills Category. Washington, D.C.
1996.
2. U.S. EPA. Clean Technologies in U.S. Industries: Focus on Textiles. 1991.
Available online at: http://www.usaep.org/resources/reports/
rep_cleantech_text.html.
3. U.S. EPA. 2003. Proposed Significant New Use Rule for Flame Retardants in
Residential Upholstered Furniture: Evaluation of Releases and Occupational
Exposures. Report prepared by ERG, Inc. Chantilly, VA.
4. Birnbaum, L., and Staskal, D. "Brominated Flame Retardants: Cause for
Concern?" Environmental Health Perspectives, 112:9-17. 2004.
5-104
-------
Section 5 - Existing Industry Review
5. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards for the Textile Mills Point Source Category. EPA-440/l-79/022b.
Washington, B.C. 1979.
5.4.6 Timber Products Processing Point Source Category
5.4.6.1 Industry Description
As defined in 40 CFR Part 429.10, the Timber Products Processing Point Source
Category includes all facilities with timber products processing operations and any plant
producing insulation board with wood as the major raw material. Products manufactured by this
category include veneer, plywood, hardboard, preserved wood (pressure and non-pressure-
treated), particle board, and wood furniture and fixtures. Operations covered by this category are
included in the six SIC codes presented in Table 5-77.
Table 5-77. Timber Products Processing SIC Code Descriptions
SIC
Code
2421
2435
2436
2491
2493
2499
Description
Sawmills & Planing
Mills, General
Hardwood Veneer
and Plywood
Softwood Veneer &
Plywood
Wood Preserving
Reconstituted Wood
Products
Wood Products, NEC
Activities
Sawing rough lumber and timber from logs and bolts; sawing box lumber and
softwood cut stock; planing mills combined with sawmills; and separately
operated planing mills.
Producing commercial hardwood veneer and manufacturing plywood or
prefinished hardwood plywood.
Producing commercial softwood veneer and plywood from veneer produced in
the same establishment or from purchased veneer.
Treating wood, sawed, or planed hi other establishments, with creosote or
other preservatives to prevent decay and to protect against fire and insects.
Manufacturing reconstituted wood products, such as hardboard. particleboard.
insulation board, medium density fiberboard, waferboard. and oriented strand
board.
Manufacturing miscellaneous wood products, and products from rattan, reed,
splint, straw, veneer, wicker, and willow.
EPA obtained information on the number of facilities included in each SIC code
from three sources: the 1997 U.S. Economic Census, and EPA's TRI and PCS databases for
2000. Table 5-78 lists the number of facilities by SIC code from these sources. The TRI-
reporting facilities in Table 5-78 include facilities reporting releases to any medium, even those
that reported no wastewater releases. In contrast, the PCS-reporting facilities include only
facilities that are permitted to discharge to surface waters. The number of facilities reporting to
TRI for 2000 represent only about 4 percent of the total industry, based on total number of
facilities in the 1997 Economic Census. One sector of the industry, wood preserving, is
relatively better represented in TRI. The number of wood preserving facilities reporting to TRI
5-105
-------
Section 5 - Existing Industry Review
for 2000 represents about 32 percent of the wood preserving facilities in the 1997 Economic
Census.
Table 5-78. Number of Facilities in Timber Products Processing SIC Codes
SIC
Code
2421
2435
2436
2491
2493
2499
Total
Description
Sawmills & Planing Mills. General
Hardwood Veneer and Plywood
Softwood Veneer & Plywood
Wood Preserving
Reconstituted Wood Products
Wood Products, NEC
1997 U.S.
Economic
Census
5,176
332
155
451
316
2,842
9,272
2000 TRI-A11
Dischargers
33
8
46
144
108
33
372
2000 PCS
Major
Dischargers
2
0
2
1
4
2
11
Minor
Dischargers
102
13
12
19
15
13
174
Source: EPA, TRIReleases2000 arulPCSLoads2000 and 1997 U.S. Economic Census.
Table 5-79 presents the number of facilities reporting to TRI by type of discharge.
This table shows that the majority of facilities reporting to TRI did not report releasing TRI
chemicals to surface waters or POTWs. However, the wood preserving industry does not follow
this trend, in that more than half of the facilities in SIC code 2491 reported a direct or indirect
wastewater discharge.
Operations in timber products processing are primarily located in the South and
Northwest.
5-106
-------
Section 5 - Existing Industry Review
Table 5-79. Number of Timber Products Processing Facilities by Discharge Type
(TRI 2000)
SIC
Code
2421
2435
2436
2491
2493
2499
Total
Description
Sawmills & Planing Mills,
General
Hardwood Veneer and
Plywood
Softwood Veneer &
Plywood
Wood Preserving
Reconstituted Wood
Products
Wood Products, NEC
Total
Reporting to
TRI
33
8
46
144
108
*> *)
JJ
372
Direct
Dischargers
Only
2
0
0
49
6
3
60
Indirect
Dischargers
Only
1
0
1
5
9
1
17
Both Direct
and Indirect
Dischargers
0
0
0
21
4
0
25
No Reported
Wastewater
Discharge
30
8
45
69
89
29
270
Source: EPA. TRIReleases2000.
5.4.6.2
Regulatory Background
EPA promulgated the existing regulations (40 CFR Part 429) for the Timber
Products Processing category in stages, between April 1974 and November 1981. These
regulations divide this category into 16 subparts (subcategories), as summarized in Table 5-80.
The subcategories are generally defined by combinations of products made and the processes
used to make these products. They are not generally defined by SIC code. Regulations for the
timber products processing subcategories may apply to one SIC code, multiple SIC codes, or a
portion of the facilities in an SIC code. Table 5-80 presents the general relationship between
SIC codes and timber products processing subcategories as well as the current ELGS for this
industry.
BAT regulations for 11 subcategories require no discharge of process wastewater.
This is compatible with the information presented in Table 5-79, in that more than 70 percent of
the timber products processing facilities reporting to TRI reported no wastewater releases of
pollutants. In 40 CFR Part 429.11, the term "process wastewater" specifically excludes
noncontact cooling water, material storage yard runoff (either raw material or processed wood
storage), and boiler blowdown. For the dry process hardboard, veneer, finishing, particleboard,
and sawmills and planing mills subcategories, fire control water is excluded from the definition.
Thus, all timber products processing facilities may be permitted to discharge noncontact cooling
water, storage yard runoff, and fire control water. In addition, barking, wet storage, and log
washing operations may be located at facilities with primary operations in subcategories for
which BPT and/or BAT is "no discharge of process wastewater." Because there are ELG for
barking, wet storage, and log washing, facilities may be permitted to discharge wastewaters from
these operations.
5-107
-------
Section 5 - Existing Industry Review
Thus, even though BAT guidelines for two of the three wood preserving
subcategories require "no discharge of process wastewater," facilities in all three wood
preserving subcategories may be permitted to discharge storage yard runoff, which might be
contaminated with wood preserving chemicals, as well as noncontact cooling water, and
wastewaters from any on-site barlcing, wet storage, and log washing operations.
PSES regulations for all but two subcategories require discharging facilities to
comply with the general pretreatment standards in 40 CFR Part 403. EPA established PSES for
two wood preserving subcategories, G - Steam and H - Boulton. The standards are the same for
both subcategories and include maximum concentrations for any one day, for four pollutants:
• Oil and grease, 100 mg/L;
• Copper, 5 mg/L;
• Chromium, 4 mg/L; and
• Arsenic, 4 mg/L.
Table 5-80. Pollutants Regulated by Existing Timber Products Processing ELGS
40
CFR
Part
A
B
C
D
E
F
G
H
Subcategory
Barking
Veneer
Plywood
Dry Process
Hardwood
Wet Process
Hardwood
Wood
Preserving -
Water-Borne or
Nonpressure
Wood
Preserving -
Steam
Wood
Preserving -
Boulton
Approximate SIC
Code
Major Group 24,
facilities that bark logs
2435 and 2436,
without wet storage
2435 and 2436,
without wet storage
2493, hardboard using
dry matting
2493. hardboard using
wet matting
2491, CCA and other
inorganics
2491, oil borne and
combination
2491. oil borne
SIC Code
Description
Hardwood and
Softwood Veneer
and Plywood
Hardwood and
Softwood Veneer
and Plywood
Reconstituted
Wood Products
Reconstituted
Wood Products
Wood Preserving
Wood Preserving
Wood Preserving
BPT
BOD,, TSS, pH
BOD5, pH
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
BOD5. TSS. pH
No discharge of
process
wastewater1
pollutants
COD, Oil &
Grease, phenols.
pH
No discharge of
process
wastewater1
pollutants
BAT
Reserved
No discharge of
process
wastewater
pollutants
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
Reserved
No discharge of
process
wastewater1
pollutants
Reserved
No discharge of
process
wastewater1
pollutants
NSPS
BOD,, TSS, pH
No discharge of
process wastewater
pollutants
No discharge of
process waslewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
5-108
-------
Section 5 - Existing Industry Review
Table 5-80 (Continued)
40
CFR
Part
I
J
K
L
M
N
0
P
Subcategory
Wet Storage
Log Washing
Sawmills and
Planing Mills
Finishing
Particleboard
Manufacturing
Insulation
Board
Wood Furniture
and Fixture
Production
Without Water
Wash Spray
Booth(s) or
Laundries
Wood Furniture
and Fixture
Production
With Water
Wash Spray
Booth(s) or
Laundries
Approximate SIC
Code
Major Group 24,
facilities with wet log
storage
Major Group 24,
facilities with log
washing
2421, except hydraulic
barking
Not defined by SIC;
includes staining,
moisture proofing, etc.
at timber processing
operations
2493, particleboard
2493, wood insulation
board (excludes
bagasse)
2499
2499
SIC Code
Description
Sawmills & Planing
Mills, General
Reconstituted
Wood Products
Reconstituted
Wood Products
Wood products,
NEC
Wood products,
NEC
BPT
pH, debris
TSS, pH
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
BODj, TSS, pH
No discharge of
process
wastewater1
pollutants
TSS, pH
BAT
pH, debris
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
Reserved
No discharge of
process
wastewater1
pollutants
No discharge of
process
wastewater1
pollutants
NSPS
pH. debris
No discharge of
process waslewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
No discharge of
process wastewater1
pollutants
Source: Code of Federal Regulations, .
1-riie term "process wastewater" specifically excludes noncontact cooling water, material storage yard runoff (either raw material or processed
wood storage), and boiler blowdown. For the dry process hardboard, veneer, finishing, particleboard. and sawmills and planing mills
subcategories, fire control water is excluded from the definition.
Technology Basis for Existing Limitations
Table 5-81 summarizes the technology basis for existing limitations.
5-109
-------
Section 5 - Existing Industry Review
Table 5-81. Summary of Technology Basis of Existing Timber Products ELGS
Subcategory
F - Wood
Preserving-
Water-Borne
or
Nonpressure
G - Wood
Preserving -
Steam
H - Wood
Preserving -
Boulton
Others
BPT
No discharge of process
wastewater based on
recovery and reuse of
contaminated water as
make-up water for treating
solutions (4).
Limits based on in-plant
controls, oil/water
separation, and biological
treatment (4).
No discharge of process
wastewater based on leak
and spill control and
disposal of small wastewater
volumes by evaporation or
percolation (4).
Limits for insulation board
and wet process hardboard,
based on primary and
secondary treatment, with
reuse of a portion of the
treated wastewater (4).
BAT
BAT (no process wastewater
discharge) based on process
controls such as use of surface
condensers rather than
barometric condensers or recycle
of barometric condenser cooling
water, and on-site disposal
techniques, such as containment
and spray -evaporation and/or
spray irrigation to eliminate
discharges to surface waters (3).
Reserved.
See Subpart F.
Most other subcategories have a
"no discharge of process
wastewater" requirement, based
on internal controls and reuse of
recovered wastewater (3 and 4).
PSES
Comply with 40 CFR Part
403.
Limits based on oil/water
separation and the rationale
that die 100 mg/L oil and
grease limit would control
pentachlorophenol
discharges to 15 mg/L or
less (3).
See Subpart G.
Comply with 40 CFR Part
403.
Sources: EPA, 1974 and 1981 Development Documents (3 and 4).
Stormwater Multi-Sector General Permit
Timber products processing facilities are covered by EPA's multi-sector general
permit (MSGP) for industrial stormwater discharges. The MSGP authorizes stormwater
discharges associated with industrial activities covered by ELGS. The timber products
processing industry is included as Industrial Sector A in the MSGP. The MSGP requirements
apply only in the five states for which EPA issues permits. Most of the remaining states issue
general stormwater permits that, at a minimum, generally contain the same requirements as the
MSGP. EPA or other permitting authority may require an individual permit for a facility instead
of coverage under the MSGP or general permit. For example, the state of Alabama does not
issue general stormwater permits for wood preserving facilities. Instead, each facility is issued
5-110
-------
Section 5 - Existing Industry Review
an individual NPDES permit. For most of these facilities, the permitted wastewater discharge is
stormwater (6). The MSGP includes the following permit conditions:
• Facilities must submit a "Notice of Intent" to discharge stormwater prior
to receiving authorization to discharge.
• Facilities must prepare and implement a Stormwater Pollution Prevention
Plan (SWPPP).
• Facilities must conduct chemical analytical monitoring of specified
benchmark parameters to determine if a stormwater discharge merits
further monitoring. The MSGP provides benchmark levels that represent
target concentrations for a facility to achieve by implementing pollution
prevention measures.
Wood preserving facilities are subject to benchmark monitoring for arsenic and copper. They
are required to monitor once per quarter for monitoring years 2 and 4. The wood preserving
sector-specific benchmark cut-off concentrations are:
Total Arsenic 0.16854 mg/L.
Total Copper 0.0636 mg/L.
Resource Conservation and Recovery Act (RCRA) Hazardous Waste Regulations
As discussed in the Preliminary Data Summary for the Wood Preserving Segment
of the Timber Products Processing Point Source Category (5), in 1990, EPA issued final
regulations that specifically listed wood preserving wastes from facilities that use chlorophenolic
formulations, creosote formulations, and inorganic preservatives containing arsenic or chromium
as hazardous wastes. The types of wastes identified include wood preserving wastewaters,
process residuals, preservative drippage, and spent preservatives. In addition to identifying
specific wood preserving wastes as hazardous, EPA identified a "drip pad" as a new RCRA
hazardous waste management unit unique to wood preserving facilities. EPA developed specific
standards (referred to as RCRA Subpart W standards) for the design, installation, operation, and
closure of hazardous waste drip pads.
Preservative drippage and process residuals might accumulate on drip pads, in
pathways over which treated wood is transported, and in treated wood storage yards. This
category of waste includes drippage of preservative from treated wood, preservative that is
washed off treated wood by rainwater, and residuals from collecting and recycling preservative
that drips off or is washed off treated wood. However, preservative that is washed off treated
wood in storage yards by rainwater is not specifically identified as a RCRA listed waste.
5-111
-------
Section 5 - Existing Industry Review
Existing Regulatory Conclusions
After its preliminary review of existing regulations for SIC code 2491 (wood
preserving), EPA come to the following conclusions:
• Even though BAT guidelines for two of the three wood preserving
subcategories are "no discharge of process wastewater," facilities in all
three wood preserving subcategories may be permitted to nonprocess
discharge storage yard runoff, which may be contaminated with wood
preserving chemicals, as well as noncontact cooling water and
wastewaters from any on-site barking, wet storage, and log washing
operations.
• Wood preserving facilities are subject to EPA's MSGP or general
stormwater permits issued by the states, unless a permitting authority
issues individual NPDES permits for stormwater discharges. MSGP and
general stormwater permits require baseline monitoring for arsenic and
chromium, but not for constituents of organic wood preservatives, such as
PACs, pentachlorophenol, or dioxins (dioxins are potential contaminants
of pentachlorophenol).
• Preservative that is washed off treated wood in storage yards by rainwater
is not specifically identified as a RCRA-listed waste and is not subject to
RCRA hazardous waste treatment, storage, and disposal regulations unless
it exhibits a characteristic hazard (such as toxicity).
5.4.6.3 Wastewater Characteristics and Pollutant Sources
This subsection presents the wastewater characteristics of facilities reporting to
PCS and the pollutants that contribute the most to the pollutant load reported in each SIC code
by facilities in TRIReleases2000 and PCSLoads2000. This subsection also describes an analysis
of stormwater discharges of wastewater pollutants.
Wastewater Characteristics Reported in PCS
Ten of the 11 major dischargers reporting to PCS also report discharge outfall
flow rates. Flow rates are not available for the 174 facilities identified as minor dischargers.
Table 5-82 presents the total annual flow (in million gallons) for 2000 and range of facility flows
for each SIC code. Facilities not reporting a flow were not included in the calculation of the
median. As noted in Table 5-82, BAT limitations for most of the timber products processing
subcategories is "no discharge of process wastewater," although facilities may be permitted to
discharge material storage yard runoff and other nonprocess wastewaters. Only 0.1 percent of
the timber products processing facilities in the 1997 Economic Census had discharge flow rates
in PCSLoads2000. Thus, the reported flows are not likely to characterize the entire industry.
5-112
-------
Section 5 - Existing Industry Review
Table 5-82. Timber Products Wastewater Flows Reported to PCS for 2000
SIC
Code
2421
2435
2436
2491
2493
2499
Total
Description
Sawmills &
Planing Mills,
General
Hardwood
Veneer and
Plywood
Softwood
Veneer &
Plywood
Wood
Preserving
Reconstituted
Wood Products
Wood Products,
NEC
Applicable
Subparts
K
B&C
B&C
F- Water-
Bome
G - Steam
Conditioning
H - Bolton
Conditioning
D-Dry
Hardboard
E-Wet
Hardboard
M - Particle
Board
N- Insulation
Board
O&P
BAT
No discharge of
process wastewater1
No discharge of
process wastewater1
No discharge of
process wastewater1
No discharge1
BPT limits, BAT
reserved
no discharge1
No discharge3
BPT limits, BAT
reserved
no discharge1
BPT limits, BAT
reserved
No discharge of
process wastewater1
Number of
Major
Facilities
Reporting
Nonzero
Flows
1
0
2
0
4
2
10
Range of
Facility
Flows in
2000 (MGY)
NA
NR
110-701
NR
326 - 2,002
246 - 256
Total
Flow in
2000
(MGY)
900
NR
811
NR
3,780
501
5,993
Source: EPA, PCSLoads2000.
NA - Not applicable; only one facility reported flow rate.
NR - No reported flow.
'The temi "process wastewater" specifically excludes noncontact cooling water, material storage yard runoff (either
raw material or processed wood storage), and boiler blowdown. For the dry process hardboard, veneer, finishing,
particleboard, and sawmills and planing mills subcategories, fire control water is excluded from the definition. In
addition, discharges from barking, wet storage, and log washing located at timber products processing facilities may
be permitted using guidelines for Subparts A, I, and J.
Table 5-83 presents the chemicals reported to PCS that account for 95 percent of
the total TWPE for each SIC code. No wastewater discharges for facilities with SIC codes
242land 2491 were reported to PCS. One facility in SIC code 2436, Softwood Veneer and
Plywood, reported discharge of several metal pollutants. This facility did not comply with its
5-113
-------
Section 5 - Existing Industry Review
copper limits in seven of eight quarters in 2002-2004. None of the other facilities reporting to
PCS had apparent compliance problems.
Table 5-83. Timber Products Processing Pollutant Discharges Reported to PCS for 2000
SIC
Code
24361
24932
24993
Pollutant
Lead, Total Recoverable
Iron, Total Recoverable
Copper, Total Recoverable
Chlorine, Total Residual
Cadmium, Total Recoverable
Chlorine, Total Residual
Copper, Total (As Cu)
Zinc, Total (As Zn)
Chromium, Hexavalent (As Cr)
Nitrogen, Ammonia Total (As N)
Phenolics, Total Recoverable
Number of
Facilities
Reporting
1
1
1
1
1
2
1
1
1
1
1
PCS
Total
(Ibs/yr)
31
5,622
31
20
3
1,126
196
1,045
86
19.886
5
PCS
TWPE/yr
69
31
20
10
8
548
123
49
44
36
0.1
Median
Facility
TWPE/yr
69
31
20
10
8
274
123
49
44
36
0.1
Percentage
of Total
SIC Code
TWPE
49%
22%
14%
7%
6%
67%
15%
6%
5%
4%
100%
Source: EPA, PCSLoads2000.
'Softwood Veneer & Plywood, loads from one facility that was not complying with copper limits from April 2002 to
March 2004.
Reconstituted Wood Products.
3Wood Products. NEC,
Wastewater Characteristics Reported in TRI
As discussed in Section 4.2.4.2, in the screening-level review of the 2000 TRI
data, EPA used a median toxic-weighting factor of the 17 dioxin and dioxin-like compounds to
represent a toxic-weighting factor for this class of compounds. For the Timber Products
Processing category review, EPA recalculated the estimated toxic-weighted pounds of dioxins
using the TRI-reported congener distributions. For facilities that reported dioxin congener
distributions, EPA calculated TWPE using the congener distributions and TWFs of the
individual dioxin compounds. For facilities that did not report a dioxin congener distribution,
EPA used the average distribution of the reporting facilities to recalculate TWPE.
In the screening-level review, EPA estimated that wood preserving facilities (SIC
code 2491) released 5,359,154 TWPE of dioxins. EPA's revised estimate, based on reported
congener distribution, is 379,324 TWPE. EPA notes that 2000 was the first year that facilities
were required to report dioxin releases to TRI. See Section 4.2.4.2 for issues related to dioxin
reporting.
5-114
-------
Section 5 - Existing Industry Review
For the screening-level review of the 2000 TRI data, EPA assumed that the only
PAC reported to be discharged by timber products processing facilities was benzo(a)pyrene.
Thus, EPA used the toxic-weighting factor (TWF) for benzo(a)pyrene to estimate the TWPE of
PACs released by wood preserving facilities. For this review, EPA assumed that composition of
PACs released by the timber products processing facilities is proportional to the PACs
composition of creosote. EPA made this assumption and revised its methodology accordingly
because facilities that reported PACs to TRI also reported discharging creosote. Because
creosote contains PACs, EPA assumed that the source of the PACs is creosote. Using this
methodology, the TWF for the PACs category is reduced from 4,284 to 65.78, which reduces the
total TWPE for PACs from 1,051,876 to 16,153.
Table 5-84 presents the pollutants reported to TRI as discharged directly or
indirectly that account for 95 percent of the total TWPE for each SIC code. This table presents
the number of facilities that reported each pollutant, total pounds of pollutant discharged for each
SIC code, and total TWPE for each pollutant. Note that this table reflects information as
reported to TRI and that EPA has not verified this information.
As with PCS, no facilities in SIC code 2435, Hardwood Veneer and Plywood,
reported wastewater pollutant releases.
Two facilities in SIC code 2421, Sawmills and Planing Mills, reported releases of
arsenic, copper, and chromium, metals that are the active ingredients in inorganic wood
preservatives.
The most releases, both in terms of number of facilities reporting and TWPE,
were reported by facilities in SIC code 2491, Wood Preserving. Dioxin and dioxin-like
compounds have the highest TWPE reported to TRI among the six SIC codes and were reported
to TRI by approximately 25 percent of the discharging wood preserving facilities. Releases of
coal tar creosote were reported by 29 wood preserving facilities. However, because there is no
toxic-weighting factor for creosote, it does not contribute to the total TWPE discharged by
facilities in SIC code 2491. There are no pretreatment standards or ELGS for any of the
pollutants identified in Table 5-84 that are discharged by wood preserving facilities.
The information in Tables 5-83 and 5-84 provides the basis of the following
conclusions:
• More than 93 percent of the TWPE discharges reported to TRI for 2000
were discharges of dioxin and dioxin-like compounds from SIC code 2491
(wood preserving);
• If EPA assumes a toxic-weighting factor for creosote based on its
chemical composition, creosote would add 126,000 TWPE to the total
TWPE for this industry;
5-115
-------
Section 5 - Existing Industry Review
• Based on the information reported to TRI, compared to wood preserving,
toxic discharges from other timber products processing SIC codes are low;
• Very little information about discharges of toxic pollutants from this
industry is included in PCS; and
• Because process wastewater discharge is prohibited, pollutant discharges
from most subcategories most likely originate from noncontact cooling
water, material storage yard runoff (either raw material or processed wood
storage), and boiler blowdown, fire control water, barking, wet storage, or
log washing. Of these sources, runoff from preserved wood storage is the
most likely source of pollutants.
Table 5-84. Timber Products Processing Pollutant Releases to Surface Water Reported to
TRI for 2000
SIC
Code
2421
2436
2491
2493
2499
Description
Sawmills &
Planing Mills,
General
Softwood
Veneer &
Plywood
Wood Preserving
Reconstituted
Wood Products
Wood Products,
NEC
Pollutant
Arsenic
compounds
Copper
compounds
Chromium
compounds
Methyl
methacrylate
Creosote
Dioxin and
dioxin-like
compounds
Polycyclio
aromatic
compounds
Ammonia
Formaldehyde
Phenol
1,2,4-
Trichlorobenzene
Dioxin and
dioxin-like
compounds
Number of
Facilities
Reporting
Pollutant/ Any
Wastewater
2 of 3
2 of
2 of 3
lofl
29 of 75
24 of 75
6 of 75
4 of 19
12 of 19
2 of 19
lof 19
Iof4
TRI Total
(Ibs/yr)
260
260
260
23
37.994
0.8
246
21,112
5,516
260
35
0.0004
TRI-
TWPE/yr
902
163
133
0.007
NC
379.324
16,153
32
13
7
3
184
Median
Facility
TWPE/yr
451
81
67
0.007
NC
3,825
375
1
1
4
Si
184
Range of
Facility
TWPE/yr
17-885
3- 160
3- 131
NA
NC
75 - 122,187
39-12,865
0,4-30
0.01-8
0.1-7
NA
NA
Percent
of Total
SIC Code
TWPE
75%
14%
11%
100%
NC
94%
4%
57%
23%
13%
5%
98%
Source: EPA, TRIReleases 2000.
NC - Not calculated. Creosote does not have a toxic-weighting factor; therefore, no TWPE is calculated.
NA - Not applicable; only one facility reported pollutant discharge.
5-116
-------
Section 5 - Existing Industry Review
Wastewater Pollutant Sources
This subsection describes the sources of wastewater discharged to receiving
streams by wood preserving facilities (SIC code 2491). Because wood preserving facilities
account for almost all of the TRI-reported releases of TWPE for the Timber Products Processing
category, EPA's review of timber products wastewater pollutant sources focused on the wood
preserving industry.
As described in the 1991 PDS (1), the major sources of wastewater in the wood
preserving industry are internal wood water, which is removed from the wood during the
conditioning process, and steam condensate, which is generated during conditioning. The wood
water and steam condensate become contaminated from contact with wood constituents, oil and
grease, and preservative. Other sources of wastewater include wastewater generated during
preservative formulation recovery and regeneration, drippage and spills from the retort, other
miscellaneous sources, and stormwater runoff.
TRI requires facilities to estimate on-site releases of toxic chemicals, including
discharges to receiving streams. Some facilities monitor stormwater runoff chemical
concentrations. TRI requires facilities that monitor stormwater to report the percentage of the
total quantity of the chemical discharged that was contributed by stormwater.
The BPT limitations guidelines for Timber Products Subpart F (Wood Preserving
- Water-borne or Nonpressure Subcategory) and Subpart H (Wood Preserving - Boulton
Subcategory) require "no discharge of process wastewater pollutants." However, the definition
of process wastewater specifically excludes material storage yard runoff. Thus, wood preserving
facilities may be permitted to release material storage yard runoff and other stormwater.
EPA analyzed information reported to TRI to determine if the reported pollutant
releases originated from stormwater or from other sources. EPA determined the number of wood
preserving facilities that reported stormwater contributions to their wastewater discharges. EPA
found that, of the 75s wood preserving facilities that reported discharging wastewater to TRI, 51
facilities reported that stormwater contributes 100 percent of the mass of the chemicals they
released to surface waters.
Table 5-85 lists the chemicals that account for 90 percent of the total, un-
weighted pounds of pollutants released by all wood preserving facilities reporting to TRI. In
contrast, Table 5-86 lists the total TWPE of pollutants released, and lists the one chemical group,
dioxin and dioxin-like compounds, that accounts for more than 90 percent of the total TWPE
released by all wood preserving facilities reporting to TRI. Each table lists the number of
facilities that reported releasing the chemical. For each chemical, the tables also lists the number
of facilities
5The 75 facilities in SIC code 2491, Wood Preserving, that reported wastewater discharges to TRI, include 49 that
reported only releases to surface water, 21 that reported transfers to POTWs, and 5 that reported both releases to
surface water and transfers to POTWs.
5-117
-------
Section 5 - Existing Industry Review
that reported the percentage contributed by stormwater. Finally, each table lists the number of
facilities that reported that stormwater contributed 100 percent of the quantity of chemical
discharged.
Table 5-85. Stormwater Discharges of Pollutants Accounting for 90 Percent of
Unweighted Pounds of Wood Preserving Pollutant Loads
Chemical
Creosote, Coal Tar
Chromium Compounds
Arsenic Compounds
Releases
Reported to
TRI
( Pounds)
37,994
2,183
1,523
Percentage
of SIC 2491
Total TRI
Pounds
82%
5%
3%
Number of
Facilities
Reporting
Releasing the
Chemical
29
25
22
Number of
Facilities
Providing
Percentage
Contributed by
Stormwater
29
24
22
Number of
Facilities That
Report 100
Percent of the
Discharge is
from Stormwater
20
15
14
Source: EPA. TRIReleases2000.
Table 5-86. Stormwater Discharges of Pollutant Accounting for 90 Percent of Wood
Preserving TWPE
Chemical
Dioxin and Dioxin-
Like Compounds
Releases
Reported to
TRI
(TWPE)
379,324
Percentage
of SIC 2491
Total TRI
TWPE
94%
Number of
Facilities
Reporting
Releasing the
Chemical
24
Number of
Facilities
Providing
Percentage
Contributed by
Stormwater
24
Number of
Facilities That
Report 100
Percent of the
Discharge is
from Stormwater
21
Source: Section 5 Table of the TRI 2000 Database.
As shown in Table 5-86, of the 24 facilities reporting percentage of the mass of
dioxins released that derived from stormwater, 21 facilities reported that stormwater contributed
100 percent of the released mass. Of the three facilities that did not report 100 percent
stormwater discharge of dioxins, two were direct dischargers and one was an indirect discharger.
In addition, as shown in Table 5-85, creosote, chromium compounds, and arsenic
compounds account for 90 percent of the total unweighted pounds of toxic chemicals released by
all wood preserving facilities reporting to TRI. Over half of the facilities reporting releases of
these chemicals reported that 100 percent of the mass discharged was contributed by stormwater.
EPA analyzed reported releases to determine what pollutants were associated
with nonstormwater releases. Twenty-four facilities for which usable information was available
reported that stormwater contributed less than 100 percent of the mass of chemical they
discharged to receiving streams. Table 5-87 lists the chemicals these 24 facilities reported
5-118
-------
Section 5 - Existing Industry Review
discharging. Except for dioxin, these chemicals are constituents of wood preservatives. Dioxin
is a potential contaminant of pentachlorophenol. The table also lists the number of facilities
reporting non-stormwater-derived discharges of these chemicals.
Table 5-87. Nonstormwater Discharges of Pollutants from Wood Preserving Facilities
Chemical
Chromium Compounds or Chromium
Arsenic Compounds or Arsenic
Copper Compounds or Copper
Creosote, Coal Tar
Dioxin and Dioxin-Like Compounds
Pentachlorophenol
Number of Facilities Reporting That
Percent of Their Discharge Is from
Less than 100
Stormwater
11
9
8
2
2
2
Source: EPA, TRIReIeases2000.
EPA does not currently have information about the wastewaters that are the
source of these pollutant releases.
The information reported to TRI by facilities in SIC code 2491 (wood preserving)
provides the basis of the following conclusions:
• Of the 144 facilities reporting to TRI, almost half (69) did not report
releasing TRI chemicals to surface water or transferring them to POTWs.
• Of the 75 facilities that reported releasing TRI chemicals to surface water
or transferring them to POTWs, 51 facilities reported that Stormwater
contributes 100 percent of the direct chemical discharges.
• Facilities reporting releases of TRI chemicals that did not originate from
Stormwater reported releasing chromium, arsenic, copper, creosote, dioxin
and dioxin-like compounds, and pentachlorophenol. Except for dioxin,
these chemicals are constituents of wood preservatives. Dioxin is a
potential contaminant of pentachlorophenol.
• EPA has not identified the nonstormwater sources of TRI-reported
chemical releases that are attributable to Stormwater.
EAD Preliminary Data Summary
EPA conducted a preliminary characterization study of the wood preserving
industry and published the results of that study in 1991(1). As reported in the 1991 PDS, EPA
conducted sampling episodes at five wood preserving facilities, four in the Boulton subcategory
5-119
-------
Section 5 - Existing Industry Review
and one in the steam subcategory. Two of the five facilities did not discharge process
wastewater, while the other three discharged to POTWs and are subject to PSES for oil and
grease, copper, chromium, and arsenic. EPA did not sample facilities that treat only with
inorganic preservatives, nor did it sample nonprocess wastewater discharges, such as storage
yard run-off EPA did not estimate industry-wide loads of pollutants discharged by wood
preserving facilities. For this reason, the information presented in the PDS is not readily
comparable to the information reported to TRI or PCS in 2000.
EPA frequently detected toxic and priority pollutants not limited by existing
PSES in treated effluents discharged to POTWs. These pollutants included, among many others:
• Dioxins and dioxin-like compounds (including 1,2,3,7,8-PeCDD, 2,,3,7,8-
TCDF, and others);
• PACs (including Benzo(j,k)fluorene (fluoranthene),
Benzo(a)phenanthrene (chrysene), and others); and
5.4.6.4
• Pentachlorophenol.
Pollution Prevention and Treatment Technology
Table 5-88 lists the treatment technologies used by timber products processing
facilities reporting to TRI for 2000. Timber products processing facilities use biological
treatment more than any other wastewater treatment processes. Three types of biological
treatment have been used by this industry: aerobic, anaerobic, and facultative. Biological
treatment reduces concentrations of COD, total phenols, oil and grease, pentachlorophenol, and
organic compounds in wastewater. This treatment is normally used as a pretreatment step prior
to discharge to a POTW (1).
Table 5-88. Wastewater Treatment Operations Reported By Timber Products Processing
Facilities TRI Reporting Year 2000
Wastewater Treatment Process
Biological Treatment
Settling/Clarification
Equalization
Adsorption ~ Carbon
Oil Skimming
Filtration
Emulsion Breaking ~ Chemical
Number of Facilities Reporting Use
Direct
Dischargers1
(37 facilities)
22
16
9
9
7
6
6
Indirect
Dischargers1
(25 facilities)
17
10
6
5
2
2
4
5-120
-------
Section 5 - Existing Industry Review
Table 5-88 (Continued)
Wastewater Treatment Process
Chemical Precipitation ~ Other
Sludge Dewatering (Nonthermal)
Air Flotation
Neutralization
Thermal Drying/Dewatering
Other Incineration/thermal Treatment
Other Liquid Phase Separation
Other Physical Treatment
General Oxidation (Including Disinfection) ~ Ozonation
General Oxidation (Including Disinfection) ~ Other
Other Chemical Treatment
Stripping ~ Air
Number of Facilities Reporting Use
Direct
Dischargers1
(37 facilities)
3
3
3
2
2
2
2
2
1
1
0
0
Indirect
Dischargers1
(25 facilities)
2
1
1
1
0
0
0
0
2
1
1
1
Source: EPA, Section 7A Table of the TRI2000 Database.
'Of the facilities that provided information on their wastewater treatment operations in TRI 2000, 37 facilities
reported direct releases, 25 reported transfers to POTWs, and 19 reported both direct releases and transfers to
POTWs.
5.4.6.5
Industry Trends
Wood preserving is the major source of toxic releases reported by this industrial
category. Stormwater discharges reported to TRI include creosote, chromium, arsenic, and the
potential pentachlorophenol contaminant, dioxins. Wood preservers have voluntarily agreed to
cancel certain chromated copper arsenate (CCA) wood preservative products and terminate
certain uses of other CCA products (68 FR 17366; April 9, 2003). These changes, when fully
implemented, might affect the toxicity of discharged Stormwater; however, they will not have
any direct impact on dioxin or PACs releases resulting from the use of pentachlorophenol and
creosote wood preservatives.
5.4.6.6
Stakeholder and EPA Regional Issues
Stakeholders believe that EPA should amend the definition of process wastewater
in 40 CFR Part 429 to exclude wastewater generated in air pollution control devices and in
operation and maintenance activities. The final rule for the Plywood and Composite Wood
Products Manufacture National Emission Standards for Hazardous Air Pollutants (NESHAP)
was published on July 30, 2004 (see http://www.epa.gov/ttn/atw/plypart/plywoodpg.html and 69
5-121
-------
Section 5 - Existing Industry Review
FR 45944). These new standards are based, in part, on the use of wet electrostatic precipitators
(WESP), a form of wet air pollution control. In addition to promulgating the new air pollution
regulation, EPA also amended the ELGS for the Timber Products Processing Point Source
Category codified at 40 CFR Part 429, Subpart B (Veneer Subcategory), Subpart C (Plywood
Subcategory), Subpart D (Dry Process Hardboard Subcategory), and Subpart M (Particleboard
Manufacturing Subcategory). The amendments adjusted the definition of process wastewater
found at 40 CFR Part 429.1 l(c) to exclude certain sources of wastewater generated by air
pollution control devices expected to be installed to comply with the final Plywood and
Composite Wood Products NESHAP.
EPA estimated that the nationwide increase in wastewater flow as a result of the
amendment is within the range of water flow rates currently handled by individual facilities.
EPA believes that facilities would likely dispose of this wastewater by sending it to a municipal
treatment facility, reusing it on site (e.g., in log vats or resin mix), or hauling it off site for spray
irrigation.
In addition, Washington State permitting authorities suggest revising these
guidelines to include effluent limits for stormwater discharges from associated log yards. The
state has prepared a manual for implementing industrial stormwater general permits at log yards
(7).
EPA will need considerably more data and information to promulgate new
effluent guidelines affecting Subparts B, C, D, and M of 40 CFR Part 429 for air pollution
control device wastewaters generated in complying with the final NESHAP for Plywood and
Composite Wood Products Manufacture. In particular, EPA will need information to adequately
characterize the quantity and quality of wastewater that would be generated as result of
compliance with the standards. The volume and pollutant content of wastewater generated at
these facilities are related to production processes, air pollution control equipment that generate
wastewater, the extent of opportunities for internal recycling of wastewater, and the availability
of other process uses for wastewater. Until EPA promulgates ELGS for pollutants in these
process wastewaters, technology-based effluent limits should be established on a case-by-case
basis under 40 CFR Part 125.3. Thus, individual facilities seeking a discharge permit will have
the opportunity, on a case-by-case basis, to characterize and obtain discharge allowances for
their wastewaters from air pollution control devices installed to comply with the final NESHAP
for Plywood and Composite Wood Products Manufacture. The permit writer would be expected
to determine, based upon BPJ, the appropriate effluent limitations for these air pollution control
wastewaters. (See 40 CFR Part 125.3.) The permit writer can take into account facility-specific
information on wastewater volumes and pollutants, available wastewater control and treatment
technologies, costs and effluent reduction benefits, receiving water quality, and any applicable
State water quality standards.
5-122
-------
Section 5 - Existing Industry Review
5.4.6.7 Conclusions
Based on the information for this review, the major toxic discharge associated
with timber products processing facilities is stormwater discharges of dioxin and dioxin-like
compounds from wood preserving facilities. Stormwater discharges of creosote from wood
preserving facilities may also be a significant problem. EPA's conclusions after reviewing this
industry are listed below.
• More than 93 percent of the TWPE discharges reported to TRI for 2000
were discharges of dioxin and dioxin-like compounds from SIC code 2491
(wood preserving).
• The majority of the wood preserving facilities report that all dioxin
releases derive from stormwater. However, stormwater releases are
extremely difficult to estimate because stormwater events are intermittent
and vary in intensity. Therefore, the pollutant loads in stormwater
releases are uncertain.
• If EPA assumes a toxic-weighting factor for creosote based on its
chemical composition, creosote would add 126,000 TWPE to the total
TWPE for this industry.
• Based on the information reported to TRI, compared to wood preserving,
toxic discharges from other timber products processing SIC codes are low.
• Very little information about discharges of toxic pollutants from this
industry is included in PCS.
• Because process wastewater discharge is prohibited, pollutant discharges
from most subcategories most likely originate from noncontact cooling
water, material storage yard runoff (either raw material or processed wood
storage), and boiler blowdown, fire control water, barking, wet storage, or
log washing. Of these sources, runoff from preserved wood storage is the
most likely source of pollutants.
• Wood preserving facilities are subject to EPA's MSGP or general
stormwater permits, unless a permitting authority issues individual
NPDES permits for stormwater discharges. MSGP and general
stormwater permits require baseline monitoring for arsenic and chromium,
but not for constituents of organic wood preservatives, such as PACs,
creosote, pentachlorophenol, or dioxins. (Dioxins are potential
contaminants of pentachlorophenol.)
5-123
-------
Section 5 - Existing Industry Review
• Preservative that is washed off treated wood in storage yards by rainwater
is not specifically identified as a RCRA-listed waste and is not subject to
RCRA hazardous waste treatment, storage, and disposal regulations unless
it exhibits a characteristic hazard (such as toxicity).
• Wood preserving facilities have voluntarily agreed to cancel certain CCA
wood preservative products and terminate certain uses of other CCA
products (68 FR 17366; April 9, 2003). These changes, however, will not
have any direct impact on creosote, PACs, or dioxin releases that are
related to the use of pentachlorophenol and creosote wood preservatives.
EPA plans to consider stormwater discharges from wood preserving facilities in
the next annual review. In particular, EPA will consider whether these discharges are
appropriately controlled through current stormwater discharge permits, whether requirements for
these discharges need to be reevaluated, and/or whether it may be appropriate to revise the ELGS
to include stormwater discharge requirements.
5.4.6.8 References
1. U.S. EPA. Preliminary Data Summary for the Wood Preserving Segment of the
Timber Products Processing Point Source Category. EPA-440/1-91 /023.
Washington, D.C. 1991.
2. U.S. EPA. 1981. Development Document for Effluent Limitations Guidelines
and Standards for the Timber Products Point Source Category. EPA-440/1-
81/023. Washington, D.C. 1981.
3. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Plywood, Hardboard, and Wood
Preserving Segment of the Timber Products Processing Point Source Category.
EPA-440/l-74-023-a. Washington, D.C. April 1974.
4. 1997 Economic Census Data. Available online at:
http://www.census.gov/epcd/www/econ97.html
5. U.S. EPA. 1996 Wood Preserving Resource Conservation and Recovery
Compliance Guide to Federal Environmental Regulation. EPA-305-B-96-001.
June 1996.
6. Festoso, Shari. Personal communication from NPDES Permit Writer, Alabama
Department of Environmental Protection to Betsy Bicknell, ERG. January 2004.
7. Washington State Department of Ecology. Industrial Stormwater General Permit
Implementation Manual for Log Yards. 04-10-031. April 2004.
5-124
-------
Section 5 - Existing Industry Review
5.5 Group IV Industries
This section describes the limited investigations EPA conducted on the Group IV
industries. During its screening-level review, EPA did not identify this group of industrial point
source categories as having high estimates of potential toxic-weighted pollutant discharges.
Rather, EPA identified this group of industries based on stakeholder response to public outreach.
Therefore, EPA focused this review on the issues identified by stakeholders. In particular, EPA
evaluated implementation and efficiency considerations and stakeholder concerns about potential
risks to human health and the environment based on available data about discharges from these
industries.
5.5.1 Canned and Preserved Fruits and Vegetables Processing (Part 407)
During the screening-level review, canned and preserved fruits and vegetable
processing was one of eight industrial categories identified solely through Factor 4 concerns.
Issues driving the concerns include: 1) discharges of nutrients and conventional pollutants,
2) lack of BOD limits, and 3) improvements in industry capacity to control discharges. In
addition, EPA determined that three industrial sectors are unregulated subcategories within Part
407. These sectors, Distilled and Blended Liquors, Malt Beverages, and Soybean Oil Mills, are
discussed in Section 5.5.1.7.
5.5.1.1 Industry Description
The Canned and Preserved Fruits and Vegetables Processing Point Source
Category is regulated at 40 CFR Part 407. This point source category includes facilities
reporting under SIC industry group 203, Canned, Frozen, and Preserved Fruits and Vegetables.
Specifically, it includes SIC codes listed below:
• SIC code 2033 - Canned Fruits, Vegetables, Preserves, Jams, and Jellies.
Establishments primarily engaged in canning fruits, vegetables, and fruit
and vegetable juices, and in manufacturing catsup and similar tomato
sauces, or natural and imitation preserves, jams, and jellies.
• SIC code 2034 - Dried and Dehydrated Fruits, Vegetables, and Soup
Mixes. Establishments primarily engaged in sun drying or artificially
dehydrating fruits and vegetables, or in manufacturing packaged soup
mixes from dehydrated ingredients.
• SIC code 2035 - Pickled Fruits and Vegetables, Vegetable Sauces and
Seasonings, and Salad Dressings. Establishments primarily engaged in
pickling and brining fruits and vegetables, and in manufacturing salad
dressings, vegetable relishes, sauces, and seasonings.
5-125
-------
Section 5 - Existing Industry Review
• SIC code 2037 - Frozen Fruits, Fruit Juices, and Vegetables.
Establishments primarily engaged in freezing fruits, fruit juices, and
vegetables. These establishments also produce important by-products such
as fresh or dried citrus pulp.
• SIC code 2096 - Potato Chips, Corn Chips, and Similar Snacks.
Establishments primarily engaged in manufacturing potato chips, corn
chips, and similar snacks.
Juice manufacturing (covered by SIC codes 2033 and 2037) was identified at a potential
subcategory during the Factor 4 analysis.
Facility Counts
EPA obtained information on the number of facilities in the Canned and
Preserved Fruits and Vegetables Processing category from three sources: the 1997 U.S.
Economic Census, the TRIReleases2000, and PCSLoads2000. TRI includes facilities reporting
discharges to any media. In contrast, the PCS includes only facilities that are permitted for
discharge to surface waters. Table 5-89 lists the number of facilities from these sources.
Table 5-89. Number of Facilities in Fruits and Vegetable Processing SIC Codes
SIC
Code
2033
2034
2035
2037
2096
1997 U.S.
Economic
Census
695
152
354
258
368
PCS
Total
Dischargers
70
1
12
20
2
Major
Dischargers
8
0
2
7
1
Minor
Dischargers
62
1
10
13
1
TRI
Total
Reporters
12
8
11
57
20
No
Reported
Discharge
11
5
7
42
14
Direct
Discharge
1
0
0
9
2
Indirect
Discharge
0
3
4
5
4
Both
Direct &
Indirect
0
0
0
1
0
Source: EPA, PCSLoads2000, TRIReleases2000.
Of the 40 reporting facilities, 8 are located in Florida. The rest are located in 18 states around
the country.
5.5.1.2 Regulatory Background
• Final effluent limitations for Subparts A - E were promulgated March 21,
1974.
• Final effluent limitations for Subparts F, G, and H were promulgated April
16, 1976.
5-126
-------
Section 5 - Existing Industry Review
The current ELGs for the Canned and Preserved Fruits and Vegetables Processing
Source category, 40 CFRPart 407, contain 8 subcategories (Subparts A - H). Table 5-90 lists
the limitations. The technology basis of existing regulations is (BPT) was in-plant waste
management and operating methods and end-of-pipe preliminary screening, primary treatment,
and secondary biological treatment. BAT and NSPS are the same as BPT followed by
disinfection (chlorination). For some facilities, more intensive biological treatment and final
multimedia or sand filtration may be required to meet BAT limits. BAT and NSPS limitations
are normalized on the basis of metric ton (kkg) of raw material. EPA did not establish
pretreatment standards for existing or new indirect dischargers (PSES or PSNS), and reserved
NSPS for Subparts F, G, and H.
Table 5-90. Effluent Guidelines for Canned and Preserved Fruits and Vegetables
Processing, Part 407
Pollutant
BOD5
TSS1
Oil and Grease2
PH
BPT 30-day Averages
(kg/kkg)
0.05 to 3. 34
0.00 to 5.09
20mg/L
within the range 6 to 93
NSPS 30-day Averages
(kg/kkg)
0.07 to 0.55
0.1 to 0.55
none
within the range 6 to 93
'BPT TSS limit for "added ingredients" in Subpart H is 0 kg/kkg. NSPS for Subpart H is reserved.
2Oil and grease limits for Subpart H only.
3pH range 6 to 9.5 for Subparts F, G, and H.
5.5.1.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-91 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for fruits and vegetable processing facilities. Facilities not
reporting a flow were not included in the median calculation. Data presented in Table 5-91 are
based on major dischargers reporting to PCS for 2000.
Table 5-91. Wastewater Flows in the Canned and Preserved Fruits and Vegetables
Processing Industry
SIC
Code
2033
2034
2035
2037
Number of Major Discharge
Facilities Reporting Nonzero
Flows
7
0
2
7
Median Facility
Flow in 2000
(MGY)
82
-
103
889
Range of Facility
Flows (MGY)
15 to 542
-
84 to 123
9 to 1510
Total Flow
(MGY)
1.330
-
207
5.170
5-127
-------
Section 5 - Existing Industry Review
Table 5-91 (Continued)
SIC
Code
2096
Number of Major Discharge
Facilities Reporting Nonzero
Flows
1
Median Facility
Flow in 2000
(MGY)
101
Range of Facility
Flows (MGY)
NA
Total Flow
(MGY)
101
Source: EPA, PCSLoads2000.
NA - No range was calculated: only 1 facility reported nonzero flow.
Fruit and vegetable processing is seasonal for most producers. Water use and
wastewater pollutant loads vary according to the specific raw material processes (e.g., 2,400
gal/ton apples to 17,000 gal/ton cauliflower). Total pollutant loads are directly correlated to the
amount of water used in processing, and consequently, water conservation practices can reduce
pollutant loads. Most processors use secondary (biological) treatment.
Table 5-92 presents sources of process wastewater in this category.
Table 5-92. Sources of Process Wastewater in Canned and Preserved Fruits and
Vegetables Processing Industry
Process
Washing: general cleaning and dirt
removal of raw products
Grading, stemming, pitting, and
seeding
Peeling, steam or lye and washing
Blanching (scalding with water or
steam)
Post-blanching washing and cooling
Pluming (conveyance)
Filling and packaging, including
adding syrup, brine, etc.
Sanitation and plant clean-up
Wastewater Pollutants
Suspended solids including fibers and soil particles; possibly pesticides
residues
Dissolved organic material (BOD5), suspended solids including fibers
and soil particles, and possibly pesticides residues
Sodium hydroxide (high pH), BOD5, and suspended solids
Dissolved organic material (BOD5) and suspended solids
Dissolved organic material (BOD5) and suspended solids
Dissolved organic material (BOD5)and suspended solids
Dissolved organic material (BOD5), salt, oil and grease (depending on
product)
Dissolved organic material (BOD5) and suspended solids, residual
disinfectant (e.g., chlorine)
Sources: Waste Management and Utilization in Food Production and Process, 1995; State of the Art Report, 2004;
Clean Technologies in U.S. Industries: Food Processing. 2004.
Pollutants Discharged
Table 5-93 lists the pollutants reported to PCS for fruit and vegetable processing
facilities that reported discharges to PCS by major dischargers in 2000. In addition, this table
also lists the pollutants reported to TRI as discharged directly or for fruit and vegetable
processing facilities that reported to TRI for 2000. This table lists the number of facilities that
5-128
-------
Section 5 - Existing Industry Review
reported each chemical and the total pounds of chemical discharged to surface waters. Indirect
discharging facilities reported transfers to POTWs. Using average POTW removal efficiencies,
EPA estimated the amount of pollutant discharged to surface water (see DCN 00618, Evaluation
of RSEIModel Runs, for more information). Therefore, the TWPE estimates in this table have
been adjusted to account for POTW treatment
Table 5-93. Pollutant Discharges Reported to PCS and TRI
Pollutant Category & Primary
Pollutants
All Pollutants
Nonconventional
Total Dissolved Solids
Total Sulfide
Ammonia as Nitrogen
Chlorine, Total Residual
Chloride
Nitrogen, Nitrate Total (As N)
Conventional
Total Suspended Solids
BOD5
Oil and Grease
Priority
Arsenic
Copper
Selenium
PCS
Pounds/yr
16,020,109
14,614,715
7,603.747
764
73,127
261
4.137,463
1,422,715
1,404,936
990,347
368.122
46,467
457
34
119
34
PCS
TWPE/yr
2,905
2,638
0
2,140
134
127
101
88
NA
-
-
-
267
117
74
38
TRI All
Discharge Ibs
Pounds/yr
7,713,669
7,713,699
0
0
21,022
35,253
0
7,657,242
0
0
TRI All
TWPE/yr
17,674
17,674
0
0
32
17,167
0
475
NA
0
Source: EPA, PCSLoads2000 and TRIReleases2000.
NA - EPA does not have TWFs for conventional pollutants, therefore, it did not calculate TWPE for conventional
pollutants.
Relative to other industries evaluated, TWPE discharges in the PCSLoads20QO
and TPJReleases2000 are low. Generally, a few facilities reporting to TRI and PCS contribute
most of the TWPE in this industry. For purposes of comparison, Tables 5-94 and 5-95 list the
TWPE for fruit and vegetable processing plants along with the industries reporting the highest
discharges in each database. Table 5-94 presents the information reported to PCS and Table
5-95 presents the information reported to TRI. (Note: These tables include TWPE loading
estimates for the three potential additional subcategories - distilled and blended liquors, malt
beverages, and soybean oil mills. No other tables in this subsection reflect facilities or
discharges in these subcategories.) For a description of the derivation of the values in these
tables, see the memorandum in the public docket Description and Results of EPA Methodology
to Synthesize Screening Level Results for the Effluent Guidelines Program Plan for 2004, which
is available through E-docket, document number OW-2003-0074-0391.
5-129
-------
Section 5 - Existing Industry Review
Table 5-94. Canned and Preserved Fruits and Vegetables Processing TWPE Reported to
PCS Compared to Industries Reporting Highest Discharge
40CFR
Part
423
414
422
415
421
440
410
419
455
418
407
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Fertilizer Manufacturing
Canned and Preserved Fruits and Vegetables Processing
PCS-Reported
TWPE/yr
2,933,209
1.805.928
1,095,321
853,568
434,925
383,560
296.601
198,251
178,977
116,464
28,779'
PCS Rank
1
2
->
J
4
5
6
7
8
9
10
16
Includes TWPE loading estimates forthree potential additional subcategories as described in Section 5.5.1.7.
Table 5-95. Canned and Preserved Fruits and Vegetables Processing TWPE Reported to
TRI Compared to Industries Reporting Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
407
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Rubber Manufacturing
Plastic Molding and Forming
Canned and Preserved Fruits and Vegetables Processing
TRI Reported
TWPE/yr
7.303,782
1,856,645
978,450
628,785
624.250
404,926
385,347
324,393
166,343
106,189
38,338'
TRI Rank
1
2
3
4
5
6
7
8
9
10
17
Includes TWPE loading estimates for three potential additional subcategories as described in Section 5.5.1.7.
5-130
-------
Section 5 - Existing Industry Review
5.5.1.4
Treatment Technology and Pollution Prevention
Standard treatment in this industry is biological treatment with primary solids
removal, oil and grease removal, and neutralization (pH adjustment) depending on products.
Treatment systems must be sufficiently robust to handle seasonal variations in pollutant loads.
Direct discharging plants may disinfect wastewater with chlorine prior to
discharge. Advanced treatment would replace chlorine disinfection with ozone or ultraviolet
light.
Most advances in reducing pollutant discharges involve water conservation and
other pollution prevention practices listed in Table 5-96.
Table 5-96. Water Conservation and Pollution Prevention Alternatives
Process
Washing: general cleaning and dirt
removal of raw products
Grading, stemming, pitting, and seeding
Peeling, steam or lye and washing
Blanching (scalding with water or
steam)
Post-blanching washing and cooling
Pluming (conveyance)
Fining and packaging, including adding
syrup, brine, etc.
Sanitation and plant clean-up
Water Conservation and
Pollution Prevention Alternatives
• Perform washing and cleaning at the agricultural site, so wastes
are reused at the fann.
• Use air flotation to remove suspended debris from raw crop
materials.
• Minimize water use.
• Minimize water use.
• Use dry peeling methods.
• Use steam blanching rather than water blanching.
• Replace blanching with nonthermal means of destroying
microbes.
• Use air cooling.
• Reuse relatively clean cooling water for peeling, primary washing.
or post -peeling washing.
• Replace water flumes with pneumatic (air-based) transport.
• Reuse relatively clean fluming water for peeling, primary
washing, or post-peeling washing.
• Minimize water use.
• Use low-volume/high-pressure cleaning systems.
Sources: Waste Management and Utilization in Food Production and Process, 1995; State of the Art Report, 2004;
Clean Technologies in U.S. Industries: Food Processing. 2004.
5.5.1.5
Industry Trends
Table 5-97 presents the change in the number of fruit and vegetable processing
facilities between 1992 and 1997 by SIC code. The table also shows the difference in the value
of goods shipped during this period. Depending on sector, the value of goods shipped has
5-131
-------
Section 5 - Existing Industry Review
declined by as much as 10 percent or increased by as much as 28 percent. Table 5-98 presents
similar data for facilities in NAICS code 311 (food manufacturing including grains, fruits and
vegetables, dairy, meats, seafood, and miscellaneous food) and shows a very small increase in
the number of establishments (less than 1 percent) and an 8-percent increase in the value of
shipments (not adjusted for inflation).
Table 5-97. Comparison of 1992 and 1997 Census Data
SIC
2033
2034
2035
2037
2096
Industry Sector
Canned Fruits, Vegetables
Preserves, Jams, and Jellies
Dried and Dehydrated Fruits,
Vegetables, and Soup Mixes
Pickled Fruits & Vegetables,
Vegetable Sauces & Seasonings,
and Salad Dressings
Frozen Fruits, Fruit Juices, and
Vegetables
Potato Chips, Com Chips, and
Similar Snacks
Number of Establishments
1997
695
152
354
258
368
1992
683
159
377
255
408
Percent
Change
1.8
-1.9
-6.1
1.2
-9.8
Value of Goods Shipped
(millions of dollars)
1997
14.5
2.9
7.1
9.6
9.1
1992
15.0
2.8
7.8
7.5
7.3
Percent
Change
-3.7
1.3
-9.6
27.9
25.6
Source: 1997 U.S. Economic Census and 1992 U.S. Census Data.
Table 5-98. Comparison of 1997 and 2002 U.S. Economic Census Data
NAICS
311
Industry Segment
Food Manufacturing
Number of Establishments
2002
26,374
1997
26.302
Percent
Change
0.27
Value of Goods Shipped
(billions of dollars)
2002
457
1997
422
Percent
Change
8.4
Source: 2002 U.S. Economic Census and 1997 U.S. Economic Census.
5.5.1.6
Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and EPA Regional staff issues. EPA
primarily received input from stakeholders prior to publication of the Preliminary Effluent
Guidelines Plan. EPA did not receive any comments on the Preliminary Plan pertaining to the
existing ELGs for the canned and preserved fruits and vegetables processing industry.
5-132
-------
Section 5 - Existing Industry Review
Concerns Identified Pre-Proposal
In the process of conducting its 2003 annual review, EPA solicited input from
stakeholders (EPA Regions and industry) on the regulatory status of this industry. Stakeholder
suggestions are summarized below.
Previous Suggestions (Section 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening-Level Review Phase " (Edocket OW-2003-0074-
0329))
In general, responders were concerned with the discharge of nutrients, as well as
overloading POTWs and small streams (for direct dischargers) with conventional pollutants such
as BOD. Responders identified several specific industries as having such characteristics,
including vegetables processing. Another issue identified was nonapproved pretreatment
processes in relation to juice manufacturing.
Permitting Authorities (Section 2.5 of the "Factor 4 Analysis: Implementation
and Efficiency Considerations - Status of Screening-Level Review Phase " (Edocket OW-2003-
0074-0329))
Washington State permitting authorities suggest updating these guidelines for
both direct and indirect dischargers. Direct dischargers are performing well below the limits,
and permitting authorities have found it difficult to address that gap effectively and lower
discharges. In addition, permitting authorities suggest that revising these guidelines could
address dissolved oxygen problems, since there are no water quality criteria for BOD and no
equitable way to determine the far-field impacts of BOD.
Additional Concerns Identified Post-Proposal
One EPA Regional stakeholder noted that POTWs would also benefit from more
EPA assistance in managing wastewater with high pollutant loads (BOD, TSS, ammonia). EPA
lists these among the 15 pollutants of concern in the new Local Limits Guidance Manual;
however, conventional pollutant management is not integrated into many aspects of this manual.
In addition, an update of the 1971 document Equitable Recovery of Industrial Waste Treatment
Costs could be helpful to POTWs needing to manage their capacity and recover the costs for
users with high pollutant loads and users whose flows and loadings tend to spike.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. Some stakeholders identified nutrient discharges
from fruit and vegetable processing plants as a concern. Information in PCS and TRI does not
indicate that fruit and vegetable processing plants discharge significant quantities of nutrients
relative to other industrial categories. State permitting authorities also suggested that EPA
should revise the existing guidelines because dischargers are performing well below the limits.
5-133
-------
Section 5 - Existing Industry Review
Because TRI and PCS data indicate toxic discharges from fruit and vegetable processing plants
are small relative to other industries, EPA has concluded that a revision would provide only
small incremental gains, if any. If stakeholders provide additional data and supporting
information on these or any of the issues identified above, EPA will reevaluate them at that time.
5.5.1.7 Potential Additional Subcategories
Based on comments and information received by stakeholders, EPA also
evaluated whether it should consider additional subcategories of the Canned and Preserved Fruits
and Vegetables Processing category for Distilled and Blended Liquors, SIC code 2085; Malt
Beverages, SIC code 2082; and Soybean Oil Mills, SIC code 2075. EPA determined it was
appropriate to consider these industrial operations as potential additional subcategories of Part
407.
Distilled and Blended Liquors
One of the industries identified by commenters for new effluent guidelines
development is distilled and blended liquors (SIC code 2085), which applies to: establishments
primarily engaged in manufacturing alcoholic liquors by distillation, and in manufacturing
cordials and alcoholic cocktails by blending processes or by mixing liquors and other
ingredients. Establishments primarily engaged in manufacturing industrial alcohol are classified
in SIC code 2869, and those only bottling purchased liquors are classified in Wholesale Trade,
SIC code 5182. (See SIC Manual, 1987 for a list of specific products included in SIC code
2085).
EPA reviewed the applicability of existing ELGs to determine if discharges from
distilled and blended liquor operations were already subject to existing ELGs. In particular, EPA
considered Canned and Preserved Fruits and Vegetables Processing (40 CFR Part 470). EPA
found that none of the existing categories of Canned and Preserved Fruits and Vegetables
Processing apply to discharges from SIC code 2085.
Next, EPA evaluated whether this industrial activity should be addressed as a
potential new subcategory under Canned and Preserved Fruits and Vegetables Processing (40
CFR Part 407). Part 407 applies to the processing of a variety of raw fruits and vegetables into
fruit and vegetable products. EPA compared the processes, operations, wastewaters, and
pollutants addressed by the Canned and Preserved Fruits and Vegetables Processing ELG to the
processes, operations, wastewaters, and pollutants of the potential new subcategory.
The basic unit processes employed in producing distilled and blended liquors
include milling of grain and malt (soaked and germinated grain); cooking; cooling; filtration;
fermenting; distillation; aging; vessel clean up, and packaging. Cordials and liqueurs are
manufactured by blending liquors with other ingredients, such as fruit syrups. The grain
processing, cooking, filtration, clean-up, and packaging operations at distilled liquors plants are
similar to preserved fruit and vegetable operations. Wastewater pollutants from distilled and
blended liquors include BOD5, and suspended solids. (1, Table 50), which are also pollutants
5-134
-------
Section 5 - Existing Industry Review
found in wastewaters from fruit and vegetable processing. Molasses distillery wastes include
nitrogen and phosphates (1, Table 52). In addition, distilled and blended liquor plants and fruit
and vegetable processing plants employ the same type of wastewater treatment: conventional
biological treatment.
As a result of this review, EPA concluded the processes, operations, wastewaters,
and pollutants at distilled and blended liquor plants are similar to those at fruit and vegetable
processing plants.
Based on information in the 1997 Economic Census, EPA estimates there are 60
distilled and blended liquor facilities in the United States. EPA's primary source of wastewater
data for this industry is information reported to TRI and PCS for the year 2000. Three facilities
reported information to TRI in 2000. Of these, two are zero dischargers and one is a direct
discharger. The total toxic pounds reported by the direct discharger in 2000 was 78 TWPE,
mostly attributed to chlorine. Twenty-seven facilities reported direct discharges to PCS in 2000.
Of these, 7 were major dischargers and 20 were minor dischargers. Detailed discharge
information in PCS indicates that the total toxic pounds discharged by the seven major
dischargers were 94 TWPE. Therefore, based on the information available at this time, EPA has
concluded that it is not appropriate to revise the ELGs for canned and preserved fruits and
vegetables processing to include limits for this additional subcategory (distilled and blended
liquors) because discharges from this potential subcategory rank low in terms of TWPE.
Malt Beverages
One of the industries identified by commenters for effluent guidelines
development is malt beverages (SIC code 2082). SIC code 2082 applies to establishments
primarily engaged in manufacturing malt beverages.
EPA reviewed the applicability of existing ELGs to determine if discharges from
malt beverages operations were already subject to existing ELGs. In particular, EPA considered
Canned and Preserved Fruits and Vegetables Processing (40 CFR Part 70). EPA found that none
of the existing subcategories in 40 CFR Part 70 apply to discharges from SIC code 2082.
Next, EPA evaluated whether this industrial activity should be addressed as a
potential new subcategory under the Canned and Preserved Fruits and Vegetables Processing (40
CFR Part 407) category. Part 407 applies to the processing of a variety of raw fruits and
vegetables into fruit and vegetable products. EPA compared the processes, operations,
wastewaters, and pollutants addressed by Canned and Preserved Fruits and Vegetables
Processing ELGto the processes, operations, wastewaters, and pollutants of the potential new
subcategory.
The basic unit processes used in the malt beverage industry are grinding of rice,
corn, and malt (soaked and germinated grain); brewing (cooking); filtration; fermenting; aging;
vessel clean-up, and packaging. The grain processing, cooking, filtration, and packaging
5-135
-------
Section 5 - Existing Industry Review
operations at malt beverage plants are similar to preserved fruit and vegetable operations.
Wastewater pollutants from this industry include BOD5 and suspended solids. (1, Tables 33 and
35), which are also pollutants found in wastewaters from fruit and vegetable processing. In
addition, malt beverages processing plants employ the same type of wastewater treatment as fruit
and vegetable processing plants: conventional biological treatment. Spent grain (mash) is
typically recovered for use as animal feed.
As a result of this review, EPA concluded the processes, operations, wastewaters,
and pollutants at malt beverage plants are similar to those at fruit and vegetable processing
plants. Malt beverages are appropriately considered as a potential new subcategory of 40 CFR
Part 407.
Based on information in the 1997 Economic Census, EPA estimates there are 529
malt beverage facilities in the United States. As EPA's primary source of wastewater data for
this industry is information reported to TRI and PCS for the year 2000. Twenty-seven malt
beverage facilities reported information to TRI in 2000. Of these, 13 were indirect dischargers, 5
were direct dischargers, and 9 were zero dischargers. The total toxic pounds reported by all malt
beverage facilities in TRI was 7,594 TWPE with one indirect discharger contributing 97 percent
of the TWPE from sodium nitrite. Eleven facilities reported direct discharges to PCS in 2000. Of
these, four were major dischargers and seven were minor dischargers. Detailed discharge
information for the four major dischargers in PCS indicates that the total toxic pounds
discharged by these facilities was 25,781 TWPE. One facility contributed 97 percent of the
TWPE from chlorine. Based on the information in TRI and PCS, EPA concludes that, with a
few exceptions, discharges from malt beverage facilities rank low in terms of toxic pounds
discharged. As a result, EPA has concluded that it is not appropriate to revise the ELGs for
canned and preserved fruits and vegetables processing to include limits for this additional
subcategory because only a few facilities contribute the bulk of the TWPE for this industry.
Soybean Oil Mills
One of the industries identified by commenters for effluent guidelines
development is soybean oil mills (SIC code 2075). The SIC code 075 applies to establishments
primarily engaged in manufacturing soybean oil, cake, and meal, and soybean protein isolates
and concentrates, or in processing purchased soybean oil other than into edible cooking oils.
Establishments primarily engaged in refining soybean oil into edible cooking oils are classified
in SIC code 2079.
EPA reviewed the applicability of existing ELGs to determine if discharges from
soybean oil mill operations were already subject to existing ELGs. In particular, EPA reviewed
the applicability of Canned and Preserved Fruits and Vegetables Processing (40 CFR Part 407)
to these operations. EPA found that none of the current subcategories of Canned and Preserved
Fruits and Vegetables Processing apply to discharges from SIC code 2079.
5-136
-------
Section 5 - Existing Industry Review
Next, EPA evaluated whether this industrial category should be addressed as a
potential new subcategory under Canned and Preserved Fruits and Vegetables Processing (40
CFR 407). Part 407 applies to the processing of a variety of raw fruits and vegetables into fruit
and vegetable products. EPA compared the processes, operations, wastewaters, and pollutants
addressed by Canned and Preserved Fruits and Vegetables Processing to the processes,
operations, wastewaters, and pollutants of the potential new subcategory.
At soybean oil mills, a vegetable (raw soybeans) is processed into soybean
products. Soybeans are dehulled, cooked and flaked, then crushed and subjected to direct solvent
extraction to produce two types of products, soybean oil and soybean meal and cakes. Solvent is
removed from the meal by steam (vapor) stripping followed by toasting. Solvent is recovered
from the oil by evaporation followed by steam stripping. The dehulling, cooking, flaking,
toasting, and clean-up operations at soybean oil mills are similar to preserved fruit and vegetable
processing operations. Wastewater pollutants from this industry include BOD, suspended solids,
and fats, oils, and greases (1, Table 18), which are also pollutants found in wastewaters from
fruit and vegetable processing. In addition, soybean oil mills and fruit and vegetable processing
plants employ the same type of wastewater treatment: conventional biological treatment
preceded by oil/water separation of high oil concentration wastewaters.
As a result of this review, EPA concluded the processes, operations, wastewaters,
and pollutants at soybean oil mills are similar to those at fruit and vegetable processing plants.
Soybean Oil Mills is appropriately considered an a potential new subcategory of 40 CFR Part
407.
Based on information in the 1997 economic census, EPA estimates there are 118
soybean oil mills in the United States. EPA's primary source of wastewater data for this industry
is information reported to TRI and PCS for the year 2000. Sixty-five soybean oil mills reported
information to TRI in 2000. Of these, 42 were indirect dischargers, 6 were direct dischargers, 4
were both indirect and direct dischargers, and 13 were zero dischargers. The total toxic pounds
reported by all malt beverage facilities in TRI was 12,991 TWPE, with two direct discharging
facility contributing 98 percent of the TWPE from sodium nitrite and chlorine. Nineteen
facilities reported direct discharges to PCS in 2000. Of these, one was a major discharger and the
remainder were minor discharges. Detailed discharge information for the single major
dischargers indicates that the facility's permit includes only limitations for conventional
pollutants. Therefore, the TWPE estimate from the PCS facilities is 0 TWPE. Based on the
information in TRI and PCS, EPA concludes that, with a few exceptions, discharges from
soybean oil mills rank low in terms of toxic pounds discharged. As a result, EPA has concluded
that it is not appropriate to revise the ELGs for canned and preserved fruits and vegetables
processing to include limits for this additional subcategory because only a few facilities
contribute the bulk of the TWPE for this industry.
5-137
-------
Section 5 - Existing Industry Review
5.5.1.8 Conclusions
Based on information reported to TRI and PCS, toxic discharges from fruits and
vegetable processing plants are low relative to other industrial categories. In addition, only a
few facilities generally are the main contributors to the TWPE for this industry. The pollutants
driving the TWPE estimate for these few facilities are total residual chlorine and total sulfide.
Stakeholders and EPA Regional staff identified various issues associated with
discharges from fruit and vegetable processing plants. At this time, the information in the docket
for this annual review does not support the concerns raised. In the event that stakeholders
provide additional data and supporting information during subsequent review cycles, EPA will
reevaluate them at that time.
In this review, EPA also evaluated whether it should consider developing
limitations and standards for additional subcategories for Distilled and Blended Liquors, SIC
code 2085; Malt Beverages, SIC code 2082; and Soybean Oil Mills, SIC code 2075. EPA
concluded that it is not appropriate to revised the ELG for Canned and Preserved Fruits and
Vegetables Processing category to include limits for these additional subcategories because only
a few facilities contribute the bulk of the TWPE and/or discharges rank low relative to other
industrial categories.
5.5.1.9 References
1. Environmental Science and Engineering. Draft Development Document for
Effluent Limitations Guidelines and New Source Performance Standards for the
Miscellaneous Foods and Beverages Point Source Category. Prepared for U. S.
EPA Effluent Guidelines Division. 1975.
5.5.2 Canned and Preserved Seafood Processing (Part 408)
During the screening-level review phase, the Canned and Preserved Seafood
Processing Point Source Category was one of eight industrial categories identified solely through
Factor 4 concerns. Issues driving the concerns include: 1) discharges of nutrients and
conventional pollutants resulting in overloading POTWs and small streams; 2) no limits for
pollutants such as nutrients and pathogens, now causing concern; and 3) changes in control
technologies since the promulgation of the guidelines.
5.5.2.1 Industry Description
The Canned and Preserved Seafood Processing category is regulated at 40 CFR
Part 408. This category includes facilities reporting under SIC industry group 20, Food and
Kindred Products. Specifically, it includes SIC code 2091, Canned and Cured Fish and
Seafoods, and SIC code 2092, Prepared Fresh or Frozen Fish and Seafoods. EPA identified no
specific subcategories during the Factor 4 analysis; however, follow-up discussions identified
5-138
-------
Section 5 - Existing Industry Review
about 150 companies, primarily in Washington and Alaska that are categorized under SIC code
2091, and just under 600 companies categorized under SIC code 2092.
• SIC code 2091 - Canned and Cured Fish and Seafoods. Establishments
primarily engaged in cooking and canning fish, shrimp, oysters, clams,
crabs, and other seafoods, including soups, and those engaged in smoking,
salting, drying, or otherwise curing fish and other seafoods for the trade.
• SIC code 2092 - Prepared Fresh or Frozen Fish and Seafoods.
Establishments primarily engaged in preparing fresh and raw or cooked
frozen fish and other seafoods and seafood preparations, such as soups,
stews, chowders, fishcakes, crabcakes, and shrimp cakes. Prepared fresh
fish are eviscerated or processed by removal of heads, fins, or scales. This
industry also includes establishments primarily engaged in the shucking
and packing of fresh oysters in nonsealed containers.
EPA obtained information on the number of facilities in this categoiy from three
sources: the 1997 U.S. Economic Census, TRIReIeases2000, and PCSLoads2000. TRI includes
facilities reporting discharges to any media. In contrast, PCS includes only facilities that are
permitted for discharge to surface waters. Table 5-99 lists the number of facilities from these
sources.
Table 5-99. Number of Facilities in the Canned and Preserved Seafood Processing
Category
SIC
2091
2092
U.S.
Economic
1997
Census
163
669
PCS
Total
19
70
Major
Dischargers
5
3
Minor
Dischargers
14
67
TRI
Total
Reporting
5
5
No Reported
Discharge
5
3
Direct
Discharge
0
2
Indirect
Discharge
0
0
Both Direct
& Indirect
0
0
Source: EPA, PCSLoads2000, TRIReleases2000.
Of the seven facilities reporting discharges to PCS or TRI, three are located in Alaska. The
others are located in Mississippi, Ohio, Rhode Island, and Puerto Rico.
5.5.2.2
Regulatory Background
EPA promulgated ELGS for BPT, BAT, and NSPS for the catfish, crab, shrimp,
and tuna segments of the industry (Subparts A-N) in 1974.
EPA promulgated ELGS for BPT, BAT, and NSPS for the fish meal, bottom fish,
clam, oyster, sardine, scallop, herring, and abalone segments of the industry (Subparts O-AG) in
1975.
5-139
-------
Section 5 - Existing Industry Review
The current ELGS for the Canned and Preserved Seafood Processing category, 40
CFR Part 408 (listed in Table 5-100), contain 33 subcategories (Subpart A - AG). EPA
established limitations only for the BOD, TSS, and oil and grease. The technology basis for
existing effluent guidelines includes screening, dissolved air flotation, and biological treatment.
Coliform Test as Indicator
EPA considered including a coliform test as an indicator of fecal content in
seafood processing wastewater (1, pg 213). Coliform organisms, however, are not naturally
found in the intestines of cold-blooded animals. Therefore, no correlation exists between fish
fecal contamination and fecal coliform levels in fish processing wastewater. An EPA-sponsored
study of fecal coliform levels in fish processing wastewater conducted in 1973 concluded that
the coliform test produced extremely inconsistent results. Based on the results of the study, EPA
decided not to include fecal coliform in the list of parameters selected for regulation.
Kjeldahl Test for Monitoring Nitrogen
EPA considered including a kjeldahl test for monitoring organic nitrogen and
ammonia levels in fish processing wastewater. EPA did not include a monitoring requirement
for total kjeldahl nitrogen (TKN) because the removal of nitrogen in physical/chemical and
biological treatment had yet to be evaluated. Furthermore, there was no demonstrated need for a
separate treatment technology specific to nitrogen compounds.
5.5.2.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-101 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for seafood processing facilities. Facilities not reporting a
flow were not included in the median calculation. Data presented in Table 5-101 are based on
major dischargers reporting to PCS for 2000.
Table 5-101. Wastewater Flows
SIC Code
2091
2092
Number of Major
Facilities Reporting
Nonzero Flows
4
2
Median Facility Flow
2000 (MGY)
736
518
Range of Facility
Flows 2000 (MGY)
523 - 1679
31 - 1006
Total Flow 2000
(MGY)
3,674
1,036
Source: EPA, PCSLoads2000.
Wastewater is high in solids, dissolved proteins, BOD, oil and grease, organic
nitrogen, and ammonia. Wastewater sources in seafood processing include thawing, butchering,
washing, peeling, picking, meat flumes, separators, cooking, and cleaning. Wastes generally
include carcasses, shells, trimmings, and by-catch not suitable for human consumption.
5-140
-------
Section 5 - Existing Industry Re\>iew
Table 5-100. Effluent Guidelines for Canned and Preserved Seafood Processing Part 408
Subparts
Farm-raised catfish: A
Crab- B C D F H
Remote Alaskan crab: E, G
Shrimp: I. K. L, M
Remote .Alaskan shrimp: J
Tuna: N
Fish meal: O
Salmon: P, Q (nonremote), R, S
Remote Alaskan salmon: Q
Bottom fish: T, LI. V
Clam: W, X
Oyster: Y. Z, AA
Sardine: AB
Scallop: AC, AD
Herring filet: AE (nonremote). AF
Alaskan herring filets (remote): AE
Alabone: AG
BOD5 - 30-Day Average (kg/kkg)
BPT
NA
NA
NA
NA
NA
9.0
3.5
NA
__2
NA
NA
NA
NA
NA
NA
-2
NA
BAT
2.3
0.15 to 2.5
NA
10 to 28
NA
0.62
2.6
1.0 to 133
NA
0.58to5.33
5.73
173
NA
NA
6.23
NA
NA
NSPS
2.3
2.5to4.l'
NA
25 to 621
NA
8.1
2.9
1.4to32'
-'
0.58to7.4'
5.71
171
NA
NA
151
__2
NA
TSS - 30-Day Average (kg/kkg)
BPT
9.2
0.74to 12
--2
38to210
--•
3.3
1.3
1.4 to 22
-1
2.1 to 14
15 to 18
15 to 190
10 to 16
1.4
24
--!
15
BAT
5.7
0.23 to 6.3
3.3 to 5.3
3.4to 18
180
0.62
1.3
0.12 to 2.2
21
0.73 to 1.1
4.4 to 17
15 to 39
10
1.4
1.8
18
14
NSPS
5.7
0.45 to 6.3
3.3 to 5.3
10 to 180
180
3.0
1.3
0.37 to 21
-2
0.73 to 2. 5
4.4 to 17
15 to 39
10
1.4
5.2 to 18
--!
14
Oil and Grease - 30-Day Average (kg/kkg)
BPT
3.4
0.20 to 4.2
~2
12 to 17
--2
0.84
0.63
0.17 to 10
--2
0.55 to 5.7
0.23 to
0.97
0.70 to 1.7
1.4 to 2.8
0.24
10
-2
1.4
BAT
0.45
0.045 to 1.3
0.36 to 0.52
1.0 to 3. 8
15
0.077
0.63
0.018 to 1.0
10
0.03 to 0.34
0.092 to 0.21
0.42 to 1.6
5.2
0.23
0.73
7.3
1.3
NSPS
0.45
0.06510 1.3
0.36to0.52
l.Sto 15
15
0.76
0.63
0.023 to 10
-'
0.03 to 0.39
0.092 to 0.21
0.42 to 1.6
0.57
0.23
1.1 to 7.3
__2
1.3
Sources: EPA. Technical Development Documents. 1974 and 1975.
NA - no limitations were established.
"There are no NSPS for BOD for Subparts D, F. I, P, Q. T, W, Y, Z. and AE.
2No pollutants exceeding 1.27cm in any dimension may be discharged.
3There are no BAT limits for BOD for Subparts P. T, W, Y. and Z.
-------
Section 5 - Existing Industry Review
Pollutants Discharged
Table 5-102 lists the pollutant discharges reported to PCS and TRI in 2000 for
seafood processing facilities. This table lists the number of facilities that reported each chemical
and the total pounds of chemical discharged to surface waters. Indirect discharging facilities
reported transfers to POTWs. Using average POTW removal efficiencies, EPA estimated the
amount of pollutant discharged to surface water (see DCN 00618, Evaluation of RSEIModel
Runs, for more information). Therefore, the TWPE estimates in this table have been adjusted to
account for POTW treatment.
Table 5-102. Pollutant Discharges Reported to PCS and TRI in 2000
Pollutant Category and Primary
Pollutants
All Pollutants
Nonconventionals
Total Sulfide
Ammonia as Nitrogen
Nitrogen, Nitrate Total
Conventionals
BOD5
TSS
Oil and Grease
Priority
Lead
Copper
Zinc
PCS
(Pounds/yr)
103,177,359
969,315
6,728
4,988
431,852
102,207,906
48,117,494
38,672,465
15,417,947
138
7
9
122
PCS
TWPE/yr
18,961
18,933
18,842 (100%)
9
27
0
-
-
-
28
17
6
6
TRI
(Pounds/yr)
53,562
53,562
0
11,388
42,174
0
-
-
-
0
0
0
0
TRI
TWPE/yr
20
20
0
17 (87%)
3 (13%)
0
-
-
-
0
0
0
0
Sources: EPA, TRIReleases2000 andPCSLoacls2000.
Relative to other industries evaluated, TWPE discharges in PCS and TRI are low.
Sulfide from a single facility contributes almost 99 percent of the overall TWPE discharged from
this industry. For comparison purposes, Tables 5-103 and 5-104 present the TWPE for seafood
processing along with the industries reporting the highest discharges in each database. Table 5-
103 presents the information reported to PCS and Table 5-104 presents the information reported
to TRI. For a description of the derivation of the values in these tables, see the memorandum in
the public docket titled Description and Results of EPA Methodology to Synthesize Screening
Level Results for the Effluent Guidelines Program Plan for 2004, which is available through
Edocket at document number OW-2003-0074-0391.
5-142
-------
Section 5 - Existing Industry Review
Table 5-103. Canned and Preserved Seafood Processing TWPE Reported to PCS
Compared to Industries Reporting 10 Highest Discharges
40CFR
Part
423
414
422
415
421
440
410
419
455
418
408
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Fertilizer Manufacturing
Canned and Preserve Seafood Processing
PCS-Reported
TWPE/yr
2,933,209
1,805,928
1.095,321
853,568
434.925
383.560
296.601
198.251
178,977
116,464
18,961
PCS Rank
1
2
3
4
5
6
7
8
9
10
20
Source: EPA, PCSLoads2000.
Table 5-104. Canned and Preserved Seafood Processing TWPE Reported to TRI
Compared to Industries Reporting 10 Highest Dischargers
40CFR
Part
414
423
421
430
415
429
419
455
428
463
408
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Rubber Manufacturing
Plastic Molding and Forming
Canned and Preserved Seafood Processing
TRI-Reported
TWPE/yr
7,303.782
1,856.645
978,450
628,785
624,250
404,926
385,347
324,393
166,343
106,189
20
TRI Rank
1
2
->
j
4
5
6
7
8
9
10
42
Source: EPA, TRIReleases2000.
5-143
-------
Section 5 - Existing Industry Review
5.5.2.4 Treatment Technology and Pollution Prevention
Most processing plants use screening and sedimentation for solids-liquid
separation, dissolved air flotation units, and biological treatment. Seafood processing plants also
use in-process controls such as water management and by-product/waste recovery.
Pollution prevention efforts focus on reductions in BOD and wastewater
management, such as by-product recovery, in-plant controls, and recycling. Increased contact
between water and seafood products and wastes is undesirable because it results in higher
pollutant loadings and decreases the nutritional value of by-products. Table 5-105 presents
water conservation and pollution prevention alternatives for this industry.
Table 5-105. Water Conservation and Pollution Prevention Alternatives
Process
Cleaning
Recycling
Transportation
By-product
recovery
Water Conservation/PoDution Prevention Alternative
• Reuse water from "clean" processes in less hygiene-demanding processes, such as
cleaning.
• Filter, store, and reuse cleaning water.
• Install heat pump evaporator to reduce BOD concentrations in wastewater to allow
closed-loop process. Eliminates water discharge.1
fora
• Use dry handling in place of flumes for in-plant transport of products.
• Use collection hoppers to collect dry waste from butchering and clean up to eliminate
waste flumes.
• Collect dry wastes using pneumatic brooms or nozzles in place of water.
• Recover protein from wastewater for use as fish meal or animal feed.
• Recover solids early from wastewater to lower BOD and nitrogen, and to avoid
decomposition of potentially valuable by-products.
Sources: EPA, Technical Development Documents, 1974 and 1975; Anderson, Driscoll, Carawan, and Pacific
Northwest Pollution Prevention Research Center.
'The heat pump evaporator was used in a case where a local POTW did not have enough capacity to treat a crabmeat
processor's wastewater, which was high in BOD.
5.5.2.5 Industry Trends
1997 U.S. Economic Census provides data that illustrates the changes in the
number of facilities and in the value of goods shipped between 1992 and 1997, as shown in
Table 5-106. Table 5-107 presents similar data for facilities in NAICS code 311 (food
manufacturing including grains, fruits and vegetables, dairy, meats, seafood, and miscellaneous
food) for the years 1997 and 2002. The table shows a very small increase in the number of
establishments (less than 1 percent) and an 8-percent increase in the value of shipments (not
adjusted for inflation).
5-144
-------
Section 5 - Existing Industry Review
Table 5-106. 1992 and 1997 Census Data
SIC
2091
2092
Industry Sector
Canned and Cured Fish and Seafoods
Prepared Fresh or Frozen Fish and
Seafoods
Number of Establishments
1997
163
669
1992
159
685
Percent
Change
2.5
-2.3
Value of Goods Shipped
(millions of dollars)
1997
854
7,039
1992
969
W
Percent
Change
-11.9
NA
Source: 1997 and 1992 U.S. Economic Census.
W - Data were withheld to avoid disclosure.
NA - Comparable data were not available.
Table 5-107. 1997 and 2002 Census Data
NAICS
311
Industry Segment
Food Manufacturing
Number of Establishments
2002
26,374
1997
26,302
Percent
Change
0.27
Value of Goods Shipped
(billions of dollars)
2002
457
1997
422
Percent
Change
8.4
Source: 2002 and 1997 U.S. Economic Census.
5.5.2.6
Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and regional staff issues. EPA primarily
received input from stakeholders prior to publication of the Preliminary Plan. EPA did not
receive any comments on the Preliminary Plan pertaining to existing ELGS for the seafood
processing industry.
Concerns Identified Pre-Proposal
Several stakeholder groups surveyed by the Agency during the 2004 annual
review provided input on the Canned and Preserved Seafood Processing category. Each group's
suggestions are summarized below.
Previous Suggestions (Section 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase " (Edocket OW-2003-0074-
0329)
In the fall of 1999 and again in the spring of 2001, EAD requested suggestions
from Headquarters, Regional, and state staff charged with the task of implementing ELGS to
follow up on concerns and to gather recommendations regarding which effluent guidelines the
Agency might develop or revise. Responders identified seafood processing on the basis of
5-145
-------
Section 5 - Existing Industry Review
concerns over the discharge of nutrients. They were also concerned about overloading POTWs
and small streams (for direct dischargers) with conventional pollutants such as BOD.
Draft Strategy Outreach: Permitting Authorities (Section 2.5 of the "Factor 4
Analysis: Implementation and Efficiency Considerations - Status of Screening Level Review
Phase" (Edocket OW-2003-0074-0329))
Upon announcing the draft Strategy in 2002, EPA began collecting information
from experts in effluent guidelines implementation. This includes management and staff in
EPA's Office of Wastewater Management (OWM). It also includes EPA Regional and state
NPDES permit writers, NPDES, pretreatment coordinators, and coordinators for the Total
Maximum Daily Load (TMDL) program. These EPA permitting authorities identified concerns
for seafood processing guidelines. Issues include the discharge of conventional pollutants BOD
and pathogens, especially fecal coliform during seafood processing.
Washington State permitting authorities also noted that the guidelines are out of
date (originally promulgated in 1974) and need to be updated. Alaska noted that six of its seven
impairments are due to seafood processing, specifically from discharges of residues and resulting
dissolved gas concentrations.
Draft Strategy Outreach: AMSA & ASIWPCA (Section 2.6 of the "Factor 4
Analysis: Implementation and Efficiency Considerations - Status of Screening Level Review
Phase" (Edocket OW-2003-0074-0329))
Upon announcing the draft Strategy in 2002, EPA gathered information from
stakeholders in two water pollution control associations: Association of Metropolitan Sewerage
Agencies (AMSA) and the Association of State and Interstate Water Pollution Control
Authorities (ASIWPCA).
In a teleconference with ASIWPCA members, EPA listed the industrial categories
with existing effluent guidelines identified by other stakeholders as possibly warranting revision.
In response, ASIWPCA stakeholders made several points. First, seafood processing effluent
guidelines do not regulate pollutants now understood to cause problems, such as discharge
nutrients and fecal coliform for which there are no limits. Second, the guidelines for this
industry are out of date, requiring only screening of the effluent, when the available technology
has advanced well beyond this level.
Additional Concerns Identified Post-Proposal
One stakeholder noted that POTWs would also benefit from more EPA assistance
in managing wastewater with high pollutant loads (BOD, TSS, ammonia). EPA lists these
among the 15 pollutants of concern in the new Local Limits Guidance Manual; however,
conventional pollutant management is not integrated into many aspects of this manual. In
addition, the pretreatment community should be reminded of the relationship between accepting
5-146
-------
Section 5 - Existing Industry Review
wastewater with high BOD levels and meeting ammonia limits. Finally, Alaska seafood
processors have not yet converted to recovering by-products for other uses, which could
significantly reduce pollutant loadings.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. Some stakeholders identified nutrient discharges
from seafood processing plants as a concern. Information in PCS and TRI does not indicate that
seafood processing plants are discharging significant quantities of nutrients relative to other
industrial categories. State permitting authorities also suggested that EPA should revise the
existing guidelines to include limitations for fecal coliform. EPA does not generally regulate
fecal coliform in ELGS. In the event that stakeholders provide additional data and supporting
information, on these or any of the issues identified above, EPA will reevaluate them at that
time.
5.5.2.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from seafood
processing plants are low relative to other industrial categories. Sulfide from a single facility
contributes almost 99 percent of the overall TWPE for this industry.
Stakeholders and EPA staff identified various issues associated with discharges
from seafood processing plants. At this time, the information in the docket for the annual review
does not support the concerns raised. In the event that stakeholders provide additional data and
supporting information during subsequent review cycles, EPA will reevaluate them at that time.
5.5.2.8 References
1. U. S. EPA. Development Document for Effluent Limitations Guidelines and
Standards of Performance for the Catfish, Crab, Shrimp, and Tuna Segments of
the Canned and Preserved Seafood Processing Industry Point Source Category.
Phase I. EPA-440-l-74-020a. Washington, D.C. 1974.
2. U. S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Fish Meal, Salmon, Bottom Fish, Clam,
Oyster, Sardine, Scallop, Herring, andAbalone Segment of the Canned and
Preserved Fish and Seafood Processing Industry Point Source Category: Group
1, Phase II. EPA-440-1-75-041A. Washington, D.C. 1975.
5.5.3 Coal Mining (Part 434)
During the screening-level review phase, coal mining was one of eight industrial
categories identified solely through Factor 4 concerns. Issues driving the concerns include:
1) stormwater runoff, 2) high discharges of total dissolved solids (TDS) and total suspended
solids (TSS), and 3) manganese discharges.
5-147
-------
Section 5 - Existing Industry Review
5.5.3.1 Industry Description
The Coal Mining Point Source Category is regulated at 40 CFR Part 434. This
point source category includes facilities reporting under SIC industry group 122, Bituminous
Coal and Lignite Mining. Specifically, it includes SIC code 1221, Bituminous Coal and Lignite
Surface Mining, and SIC code 1222, Bituminous Coal Underground Mining. No specific
subcategories were identified during the Factor 4 analysis. Below is a description of these SIC
codes:
• SIC code 1221 - Bituminous Coal and Lignite Surface Mining.
Establishments primarily engaged in producing bituminous coal or lignite
at surface mines or in developing bituminous coal or lignite surface mines.
This industry includes auger mining, strip mining, culm bank mining, and
other surface mining, by owners or lessees or by establishments which
have complete responsibility for operating bituminous coal and lignite
surface mines for others on a contract or fee basis. Bituminous coal and
lignite preparation plants performing such activities as cleaning, crushing,
screening or sizing are included if operated in conjunction with a mine
site, or if operated independently of any type of mine.
• SIC code 1222 -Bituminous Coal Under ground Mining. Establishments
primarily engaged in producing bituminous coal in underground mines or
in developing bituminous coal underground mines. This industry includes
underground mining by owners or lessees or by establishments which
have complete responsibility for operating bituminous coal underground
mines for others on a contract or fee basis. Bituminous coal preparation
plants performing such activities as cleaning, crushing, screening or sizing
are included if operated in conjunction with a mine. Independent
bituminous coal preparation plants are classified in SIC code 1221.
• SIC code 1231 -AnthraciteMining. Establishments primarily engaged in
producing anthracite or in developing anthracite mines. All establishments
in the United States that are classified in this industry are located in
Pennsylvania. This industry includes mining by owners or lessees or by
establishments which have complete responsibility for operating
anthracite mines for others on a contract or fee basis. Also included are
anthracite preparation plants, whether or not operated in conjunction with
a mine.
Facility Counts
EPA obtained information on the number of facilities in the Coal Mining category
from three sources: the 1997 U.S. Economic Census, TRIReleases2000, andPCSLoads2000.
TRI includes facilities reporting discharges to any media. In contrast, PCS includes only
5-148
-------
Section 5 - Existing Industry Review
facilities that are permitted for discharge to surface waters. Table 5-108 lists the number of
facilities from these sources.
Table 5-108. Number of Facilities in the Coal Mining Category
SIC
1221
1222
1231
1997
Economic
Census
829
614
68
PCS
Total
129
17
0
Major
Dischargers
15
1
0
Minor
Dischargers
114
16
0
TRI
Total
50
27
0
No Reported
Discharge
33
22
0
Direct
Discharge
17
5
0
Indirect
Discharge
0
0
0
Both Direct
& Indirect
0
0
0
Source: EPA, PCSLoads2000. TRIReleases2000.
Coal mining facilities are located throughout the United States, with the highest
concentration in West Virginia, Alabama, and Ohio.
5.5.3.2 Regulatory Background
Below is a summary of the regulatory background of this industry:
• EPA first promulgated BPT limitations for Subparts B (preparation
plants), C (acid drainage mines), and D (alkaline drainage mines) on April
26, 1977;
EPA promulgated NSPS for Subparts B, C, and D on January 12, 1979,
and established subcategories for reclamation and western mines;
EPA revised BPT and NSPS rainfall exemptions on December 28, 1979;
and
• EPA published proposed BAT and NSPS limitations for all subcategories
in January 1981 including proposed amendments to BPT.
The current ELGS for the Coal Mining category, 40 CFRPart 434, contain eight
subcategories (Subpart A - H). Table 5-109 lists the limitations. The technology basis for these
limitations and standards is neutralization and settling. BAT limitations are the same as BPT
limitations. In addition, NSPS is identical to BAT, except NSPS requires no discharge of
wastewater pollutants from preparation plants (Subpart B). The technology basis for the no-
discharge requirement was a complete water recycle system. No limits were established for
Subpart H (Western Mines). Rather, operators are required to submit and implement a Sediment
Control Plan to maintain sediment discharges at or below premining levels.
5-149
-------
Section 5 - Existing Industry Review
Table 5-109. Effluent Guidelines for Coal Mining Part 434
TSS
Settleable Solids1
pH
Iron, Total
Manganese. Total2
BPT - 30-day Averages (mg/L)
35
0.5 niL/L
within range of 6 to 9
3.5
2.0
BPT - Daily Maximum (mg/L)
70
within range of 6 to 9
7.0
4.0
Source: US EPA, 1981. Development Document for Effluent Limitations Guidelines and Standards for the Coal
Mining Point Source Category. 440181057b.
'Limits for settleable solids only apply to Subpart E (post mining areas).
2No manganese limits exist for Subpart D (alkaline drainage mines).
In addition, Subpart F, Miscellaneous Provisions, contains alternative limitations
that apply during catastrophic precipitation events. These limitations, listed in Table 5-110, and
apply to discharges that result from a rainfall or snowmelt event less than the 10-year, 24-hour
storm. For events greater than the 10 year, 24-hour precipitation event, there are no limitations
on settleable solids. The only limitation is that pH remain between 6 and 9.
Table 5-110. Catastrophic Precipitation Event Exemption
Settleable Solids1
PH
BPT - Daily Maximum
0.5 mL/L
within range of 6 to 9
Source: US EPA, 1981. Development Document for Effluent Limitations Guidelines and Standards for the Coal
Mining Point Source Category. EPA 440-l-81-057b.
'No limits on settleable solids when precipitation exceeds the 10-year, 24-hour storm.
Other Regulations
In addition to regulating wastewater discharges under the effluent guidelines
program, EPA regulates hazardous and solid waste under the RCRA and air emissions under the
Clean Air Act (CAA). Other regulating authorities applicable to coal mining include:
• Department of Labor, Mine Safety and Health Administration (MSHA):
Responsible for all federally required plans, approvals, certifications, and
licensing relating to mine safety.
• Department of Interior, Office of Surface Mining (OSM)\ Regulates active
coal mining operations and supports the reclamation of abandoned mines
as required by the Surface Mining Control and Reclamation Act of 1977
(SMCRA).
5-150
-------
Section 5 - Existing Industry Review
Army Corps of Engineers (COE): Responsible for processing permit
applications and issuing permits as outlined in Section 404 of the CWA.
5.5.3.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-111 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for coal mining facilities. Facilities not reporting a flow
were not included in the median calculation. Data presented in Table 5-111 are based on major
dischargers reporting to PCS for 2000.
Table 5-111. Wastewater Flows for Coal Mining Facilities
SIC Code
1221
1222
Number of Major Facilities
Reporting Nonzero Flows
9
1
Median Facility Flow
in 2000 (MGY)
831.21
526.11
Range of Facility
Flows in 2000 (MGY)
63 -6.914
NA
Total Flow in 2000
(MGY)
15,676.75
526.11
Source: EPA, PCSLoads2000.
NA - No range was calculated: only one facility reported a nonzero flow.
Common sources of wastewater in the coal mining industry include precipitation,
surface runoff, ground water infiltration, and coal preparation plant effluent. No process water is
used during the coal mining process. Preparation plants use water for washing the coal to
remove impurities. The wastewater content from coal mining facilities varies according to mine
location, soil content, and purity of the coal extracted. There does not appear to be a correlation
between production rate and wastewater volume. Table 5-112 presents characteristics of
different classifications of coal mine wastewater.
Table 5-112. Sources of Process Wastewater in Coal Mining
Wastewater Source
Acid mine drainage
Alkaline mine drainage
Preparation plants
Reclamation
Characteristics
Suspended solids, low pH, high concentrations of iron and other metals
Low levels of suspended solids, neutral or slightly high pH, low concentrations
metals
of
High levels of coal fines.
Variable levels of suspended solids, low concentrations of iron & manganese
Source: US EPA, 1981. Development Document for Effluent Limitations Guidelines and Standards for the Coal
Mining Point Source Category, EPA 440-l-81-057b.
5-151
-------
Section 5 - Existing Industry Review
Pollutants Discharged
Table 5-113 lists the pollutants reported to PCS for coal mining facilities (major
dischargers) that reported to PCS in 2000. Table 5-114 lists the direct discharges by pollutant as
reported to 2000 TRI for coal mining facilities.
Table 5-113. Pollutant Discharges Reported to PCS and TRI in 2000
Pollutant Category
and Primary Pollutants
All Pollutants
Nonconventional
Total Dissolved Solids (IDS)
Manganese
Iron
Ammonia as Nitrogen
Conventional
TSS
BODS
Oil and Grease
Priority
Mercury
Arsenic
PCS
(Pounds/yr)
33,529,627
31,563,104
31.471.976
11,621
7,742
-
1,966,515
1,966,357
96
62
81
-
—
PCS
TWPE/yr
1,385
1,380
n/a
818 (59%)
434 (31%)
3
0
-
-
-
51
-
-
TRI (Pounds/yr)
(Direct Only)
741,083
739,958
-•
16,400
-
723,229
0
-
-
-
1,125
149
769
TRI TWPE/yr
(Direct Only)
22,472
2,245
-
1,155 (51%)
-
1,089 (49%)
0
-
-
-
20,227
17,444 (86%)
2.668 (13%)
'Copper discharge.
Relative to other industries evaluated, TWPE discharges for this category are low.
Generally, a few facilities drive the TWPE estimates from both TRI and PCS. For comparison,
Tables 5-114 and 5-115 present the TWPE for coal mining along with the industries reporting
the highest discharges in each database. Table 5-114 presents the information reported to PCS
and Table 5-115 presents the information reported to TRI. For a description of the derivation of
the values in these tables, see the memorandum in the public docket titled Description and
Results of EPA Methodology to Synthesize Screening Level Results for the Effluent Guidelines
Program Plan for 2004, which is available through Edocket at document number OW-2003-
0074-0391.
5-152
-------
Section 5 - Existing Industry Review
Table 5-114. Coal Mining TWPE Reported to PCS Compared to Industries Reporting
10 Highest Discharges
40CFR
Part
423
414
422
415
421
440
410
419
455
418
434
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Fertilizer Manufacturing
Coal Mining
PCS-Reported
TWPE/yr
2,933,209
1.805,928
1,095,321
853,568
434,925
383,560
296,601
198,251
178,977
116,464
1,385
PCS Rank
1
2
3
4
5
6
7
8
9
10
32
Source: EPA, PCSLoads2000.
Table 5-115. Coal Mining TWPE Reported to TRI Compared to Industries Reporting
10 Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
434
Point Source Category
Organic chemicals, plastics and synthetic fibers
Steam electric power generation
Nonferrous metals manufacturing
Pulp, paper and paperboard (Phase n)
Inorganic chemicals manufacturing
Timber products processing
Petroleum refining
Pesticide chemicals manufacturing, formulating
Rubber manufacturing
Plastic molding and forming
Coal Mining
TRI-Reported
TWPE/yr
7,303.782
1,856,645
978,450
628,785
624,250
404,926
385,347
324,393
166,343
106,189
22,472
TRI Rank
1
2
3
4
5
6
7
8
9
10
21
Source: EPA. TRIReleases2000.
5-153
-------
Section 5 - Existing Industry Review
5.5.3.4 Treatment Technology and Pollution Prevention
A cid Discharges
Mines with acid discharges treat wastewater using chemical precipitation, pH
adjustment, aeration, and settling. Neutralization and aeration promote oxidation of metals such
as iron and magnesium. The metal ions form insoluble metal hydroxides, which precipitate out
of solution and may be removed by settling.
Acid mine drainage is caused by the oxidation of pyrite, which release iron,
sulfide, and hydrogen ions into surface waters. In some locations, manganese also may be
released. The rate of acid formation is dependent on the amount of pyrite in overburden, the
presence of limestone or other neutralizers, and exposure to air containing the oxygen necessary
for oxidation. Special handling techniques and water management may be applied to reduce acid
mine drainage. Special handling techniques include identifying potentially acid rock prior to
placement, and strategically locating potentially acid materials to minimize exposure to water
and air. Water management techniques include: 1) installing high wall drainage systems to
promote surface runoff and reduce contact between water and the spoil surface; 2) installing
spoil drains to minimize contact time between groundwater and mine spoil; 3) filling trenches
with alkaline material to lower the rate of acid formation; and 4) flooding acid-forming
materials to avoid air contact.
Alkaline Discharges
Some mines with alkaline discharges use settling ponds to remove suspended
solids from wastewater.
Preparation Plants
These plants use a slurry treatment system, consisting of a settling basin or
clarifier and thickeners, to treat the coal wash water. Runoff from surrounding areas is treated in
a settling pond.
Reclamation Areas
Such areas use sedimentation ponds to remove solids from wastewater.
5.5.3.5 Industry Trends
Table 5-116 compares information from the 1992 and 1997 Economic Census for
the coal mining industry. U.S. Census data indicates a decrease in the number of the number of
coal mines by almost 40 percent between 1992 and 1997. Value of goods shipped also declined
by 10 percent or more for bituminous coal during the same time period. Anthracite mining
showed an almost 14-percent increase in value of goods shipped.
5-154
-------
Section 5 - Existing Industry Review
In addition to U.S. Census data, statistics for the coal mining industry are
provided by the U.S. Department of Labor and the Energy Information Administration (EIA).
Table 5-117 presents the number of coal operations in the U.S. from 1997 to 2002, generally
decreasing by around 20 percent. Table 5-118 presents coal production from 1996 to 2000,
which remains steady.
Table 5-116. 1992 and 1997 Census Data
SIC
1221
1222
1231
Sector
Bituminous coal and lignite -
surface
Bituminous coal - underground
Anthracite mining
Number of Establishments
1997
829
614
68
1992
1,359
1,008
N
Percent
Change
-39.0
-39.1
N
Value of Goods Shipped
(in billions of dollars)
1997
12.5
10.8
0.18
1992
13.8
12.6
0.16
Percent
Change
-9.9
-14.4
13.8
Source: 1997 U.S. Economic Census.
N - Comparable data were not available.
Table 5-117. Number of U.S. Coal Mining Operations from 1997 to 2002
Operations
Underground Mines
Surface Mines
Preparation Plants
Total Mining Operations
1997
968
1,117
432
2.578
1998
910
1,069
422
2,459
1999
817
1,011
399
2,274
2000
771
920
363
2,099
2001
111
937
354
2,122
2002
711
921
355
2,046
Percent Change
from 1997 to
2002
-26.5
-17.5
-17.8
-20.6
Source: U.S. Department of Labor.
Table 5-118. U.S. Coal Production from 1997 to 2000 (in millions of short tons)
Total U.S. Production
1996
1,064
1997
1,090
1998
1,118
1999
1,100
2000
1,074
Average Annual
Percent Change
(1996-2000)
0.20
Source: EIA web page.
5-155
-------
Section 5 - Existing Industry Review
5.5.3.6 Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and EPA Regional issues. EPA primarily
received input from stakeholders and EPA Regional staff prior to the Preliminary Effluent
Guidelines Plan. EPA did not receive any comments on the Preliminary Plan pertaining to the
coal mining industry.
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the process of the 2004 annual review
provided input on the Coal Mining category. Their suggestions and/or concerns are summarized
below.
Comments on the 2002/2003 Plan (Section 2.3 of the "Factor 4 Analysis:
Implementation and Efficiency Considerations - Status of Screening Level Review Phase "
(Edocket OW-2003-0074-0329))
A commenter asserted that the effluent guidelines for the Coal Mining category
require revision because rainfall exemptions for coal mining in the current effluent guidelines
allow for relaxation of limits as soon as it rains. Furthermore, the commenter stated that
settlement basins used as primary control for mine drainage do not work very well when it rains.
(Note: EAD recently revised these effluent guidelines, with revisions promulgated in January
2002; however, the revised rule did not reassess the effluent limitations for precipitation events.)
Previous Suggestions (Section 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
Although responders recommended coal mining for revised effluent guidelines
development, no specific concerns were noted.
AMSA & ASIWPCA (Section 2.6 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
A stakeholder noted that coal mining operations discharge manganese, which is
generating problems, notably in West Virginia streams. In follow-up discussion with this
stakeholder, EPA explained that manganese in coal mining effluent does not necessarily
adversely effect the receiving stream as much as the discharge stream remaining after treatment
to remove manganese, which consists basically of increasing the pH. (The water quality
standard for manganese is based on concerns for staining relative to drinking water uses.) The
effluent then must be neutralized before discharge; options typically include adding either acid
or aluminum to the effluent. (Another side effect of changing the pH is the potential increase in
5-156
-------
Section 5 - Existing Industry Review
concentration of the more toxic selenium in the effluent, since it can more readily leach into the
water from the pit cleanings.)
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA can not address these
suggestions without adequate supporting data. In the event that stakeholders provide additional
data and supporting information on these or any of the issues identified above, EPA will
reevaluate them at that time.
5.5.3.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from coal
mining operations are low relative to other industrial categories. In addition, a few facilities
generally contribute the bulk of the TWPE for this industry. The pollutants driving the TWPE
estimate for these few facilities are mercury and arsenic.
Stakeholders and EPA staff identified various issues associated with discharges
from coal mining operations. The information in the docket on the 2004 annual review does not
at this time support the concerns raised. In the event that stakeholders provide additional data
and supporting information during subsequent review cycles, EPA will reevaluate them at that
time.
5.5.4 Coil Coating (Part 465)
During the screening-level review phase of the 2004 annual review, coil coating,
including the can making subcategory, was one of eight industrial categories identified solely
through Factor 4 concerns. Issues driving the concerns include changes to industry since
promulgation, such as: 1) discharges of new solvents adopted by the industry and not regulated
by existing guidelines, 2) costs to monitor pollutants no longer used by the industry, and 3)
applicability issues for multi-process facilities.
5.5.4.1 Industry Description
The Coil Coating Point Source Category is regulated at 40 CFR Part 465. This
point source category includes facilities reporting under SIC industry group 341, Metal Cans and
Shipping Containers. Specifically, it includes SIC code 3411, Metal Cans. The SIC description
for metal cans is establishments primarily engaged in manufacturing metal cans from purchased
materials. The canmaking subcategory was identified during the Factor 4 analysis.
Facility Counts
EPA obtained information on the number of facilities in the Coil Coating Point
Source Category from three sources: the 1997 U.S. Economic Census, TRIReleases2000, and
PCSLoads2000. The 2000 TRI database includes facilities reporting discharges to any media.
In
5-157
-------
Section 5 - Existing Industry Review
contrast, the 2000 PCS database includes only facilities that are permitted for discharge to
surface waters. Table 5-119 lists the number of facilities from these sources.
Table 5-119. Number of Facilities
SIC
3411
1997
Census
274
PCS
Total
8
Major
Dischargers
0
Minor
Dischargers
8
TRI
Total
136
No Reported
Discharge
94
Direct
Discharge
1
Indirect
Discharge
41
Both Direct
& Indirect
0
Source: EPA, PCSLoads2000, TRIReleases2000.
No facilities for this SIC code reported to PCS as major dischargers. Eight minor
dischargers report to PCS under SIC code 3411, but these facilities do not need to report their
discharge data. There are 42 facilities that report discharges to TRI; all but one of these report
only indirect discharges. Facilities are located in 21 states and Puerto Rico. Of the 42 facilities,
10 are located in EPA Region 5.
5.5.4.2
Regulatory Background
The current ELGS for the Coil Coating Point Source Category, 40 CFR Part 465,
contain four subcategories (Subpart A - D), which are based on the material used or product
(e.g., metal cans). EPA promulgated final versions of the effluent limitations for Subparts A - C
on October 30, 1982 and promulgated effluent limitations for Subpart D (Canmaking) in
November 1983.
The technology basis of existing regulations for Subparts A - C is:
• Recycle, cyanide treatment, chromium reduction, oil removal, lime
precipitation and sedimentation, and sludge dewatering for BPT;
• Cyanide treatment, chromium reduction, oil removal, lime precipitation
and sedimentation for BAT and PSES;
• Recycle, cyanide treatment, chromium reduction, oil removal, chemical
precipitation and sedimentation, and sludge dewatering forNSPS; and
• Recycle, cyanide treatment, chromium reduction, chemical precipitation
and sedimentation, and sludge dewatering for PSNS.
The technology basis for existing regulations for Subpart D is:
• Wastewater flow normalization, chromium reduction, oil removal, and
lime precipitation and sedimentation for BPT;
5-158
-------
Section 5 - Existing Industry Review
• In-process flow reduction, chromium reduction, oil removal, and lime
precipitation and sedimentation for BAT and PSES; and
• BPT end-of-pipe treatment and in-process flow reduction for NSPS and
PSNS.
Effluent limitations guidelines are mass-based on the basis of milligram (mg) per
surface area processed in square meters (m2) and grams (g) per one million cans produced. BCT
was deferred for all Subparts (A-D). Table 5-120 lists these limitations.
5-159
-------
Section 5 - Existing Industry Re\>iew
Table 5-120. Effluent Guidelines for Coil Coating and Canmaking
Pollutant
Chromium
Copper
Cyanide
Zinc
Aluminum
Iron
Phosphorous
Manganese
Oil and grease
TSS
TTO1
pH
BPT 30-day averages
Subparts A-C
(mg/m2)
0.45-0.58
2.61-
0.32-0.41
1.46-1.89
6.26''
1.65-1.74
NR
NR
31.31-40.4
52.2-67.3
NR
7.5-10.0
Subpart D
(g/1 million
cans)
38.70
NR
NR
131.15
688.00
5676.00
1468.45
NR
2580
4192.5
NR
7.0-10.0
BAT 30-day averages
Subparts A-C
(mg/m2)
0.16-2.0
0.903
0.11-0.14
0.51-0.66
1.843
0.57-0.74
NR
NR
NR
NR
NR
NR
Subpart D
(g/1 million
cans)
15.10
NR
NR
51.18
268.48
2214.96
573.04
NR
NR
NR
NR
NR
NSPS 30-day averages
Subparts A-C
(mg/m1)
0.052-0.47
0.21 2
0.028-0.25
0.14-0.20
0.593
0.20-0.22
NR
NR
3.16-4.75
3.79-5.70
NR
7.5-10.0
Subpart D
(g/1 million
cans)
11.45
NR
NR
38.80
203.52
1679.04
434.39
NR
763.20
1240.20
NR
7.0-10.0
PSES 30-day averages
Subparts A-C
(mg/m2)
0.16-0.20
0.902
0.11-0.14
0.51-0.66
NR
NR
NR
NR
NR
NR
NR
NR
Subpart D
(g/1 million
cans)
15.10
83.90
NR
51.18
NR
2214.96
573.04
24.33
1006.80
NR
12.59
NR
PSNS 30-day averages
Subparts A-C
(mg/m2)
0.052-0.047
0.21:
0.025-0.38
0.14-0.20
NR
NR
NR
NR
NR
NR
NR
NR
Subpart D
(g/1 million
cans)
11.45
63.60
NR
38.80
NR
1679.04
434.39
18.44
763.20
NR
9.54
NR
NR = Not regulated
'Total toxic organic pollutants include
(dichloromethane), Pentachlorophenol.
2Subpart B only.
^Subpart C only.
1,1.1-Trichloroethane. 1.1-Dichloroethane, 1.1,2,2-Tetrachloroethane. Bis (2-chloroethyl) ether, Chlorofomi, 1.1-Dichloroethylene. Methylene chloride
Bis (2-ethylhexyl) phthalate. Butyl benzyl-phthalate, Di-N-butyl phthalate, Phenanthrene, Tetrachloroethylene, and Toluene.
-------
Section 5 - Existing Industry Review
Pretreatment standards for total toxic organics (TTO) were established for new
and existing sources in the canmaking subcategory. EPA detected 14 organic compounds at
quantifiable levels during wastewater sampling, and selected these compounds to be included in
the regulation. According to Part 465, TTO is the sum of the mass of each of the following toxic
organic compounds that are found at a concentration greater than 0.010 mg/1:
1,1,1 -Trichloroethane; 1,1 -Dichloroethane;
1,1,2,2-Tetrachloroethane; Bis (2-chloroethyl) ether;
Chloroform; 1,1-Dichloroethylene;
Methylene chloride (dichloromethane); Pentachlorophenol;
Bis (2-ethylhexyl) phthalate; Butyl benzyl-phthalate;
Di-N-butyl phthalate; Phenanthrene;
Tetrachloroethylene; and Toluene.
Other Effluent Guidelines
40 CFR Part 467 (Aluminum Forming) is applicable to rolling, drawing,
extruding, forging, and related operations such as heat treatment, casting, and surface treatments.
For the purposes of this regulation, surface treatment of aluminum is considered to be an integral
part of aluminum forming whenever it is performed at the same plant site at which the aluminum
is formed.
Most major facilities reporting to PCS report discharge outfall flow rates.
Because no major dischargers from this industry reported to PCS in 2000, EPA is not providing
information on annual flow rates.
5.5.4.3 Wastewater Characterization and Pollutant Sources
Wastewater pollutant loads depend on the base material and the production
process used. Table 5-121 illustrates the processes and the associated pollutants.
Table 5-121. Sources of Process Wastewater in Coil Coating and Canmaking
Process
Cleaning
Conversion coating
Finishing
Camnaking
Wastewater Pollutants
Metals, suspended solids, oil
Metals, suspended solids
Suspended solids
Metals, oil, toxic organics, suspended solids
Sources: EPA, Development Document for Effluent Limitations Guidelines and Standards for the Coil Coating Point
Source Category (Phase J) [Final] (EPA 440-1-82-071), 1982 and Development Document for Effluent Limitations
Guidelines and Standards for the Coil Coating Point Source Category (Canmaking Subcategory) -Final (EPA 440-
1-83-071), 1983.
5-161
-------
Section 5 - Existing Industry Review
Pollutants Discharged
As indicated previously, no major coil coating and canmaking facilities reported
discharging to PCS in 2000. Therefore, EPA has no information in PCSLoads2000 on pollutants
discharges from this industry. Table 5-122 lists the pollutants reported to TRI as discharged
directly or indirectly for coil coating and canmaking facilities that reported to TRI for 2000.
Indirect discharging facilities reported transfers to POTWs. Using average POTW removal
efficiencies, EPA estimated the amount of pollutant discharged to surface water (see DCN
00618, Evaluation of RSEIModel Runs, for more information). Therefore, the TWPE estimates
in this table have been adjusted to account for POTW treatment. Of the 42 TRI reporting
facilities, a single indirect discharging facility contributes 99 percent of the toxic-weighted
pounds.
Table 5-122. Pollutant Discharges Reported to PCS and TRI
Pollutant Category and
Primary Pollutants
All Pollutants
Nonconventional
Sodium Nitrite
Manganese
Conventional
Priority
PCS
(Pound s/yr)
-
-
-
-
-
-
PCS TWPE/yr
-
-
-
-
-
-
TRI
(Pounds/yr)
32,803
32,803
3 1,2 10 (95%)
1,592 (5%)
-
-
TRI TWPE/yr
11,763
11,763
11,652(99%)
112(1%)
-
-
Relative to other industries evaluated, TWPE discharges in TRI for this industry
are low. Discharges from a single facility contribute over 99 percent of the total TWPE. For
comparison purposes, Tables 5-123 and 5-124 present the TWPE for the coil coating industry
along with the industries reporting the highest discharges in each database. Table 5-123 presents
the information reported to PCS and Table 5-124 presents the information reported to TRI. For a
description of the derivation of the values in these tables, see the memorandum in the public
dcoket titled Description and Results of EPA Methodology to Synthesize Screening Level Results
for the Effluent Guidelines Program Plan for 2004, which is available through Edocket at
document number OW-2003-0074-0391.
Table 5-123. Coil Coating TWPE Reported to PCS Compared to Industries Reporting
10 Highest Discharges
40CFR
Part
423
414
422
415
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
PCS-Reported
TWPE/yr
2,933,209
1,805,928
1,095,321
85.1,568
PCS Rank
1
2
3
4
5-162
-------
Section 5 - Existing Industry Review
Table 5-123 (Continued)
40CFR
Part
421
440
410
419
455
418
465
Point Source Category
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Fertilizer Manufacturing
Coil Coating
PCS-Reported
TWPE/yr
434,925
383,560
296,601
198,251
178,977
116,464
0
PCS Rank
5
6
7
8
9
10
Table 5-124. Coil Coating TWPE Reported to TRI Compared to Industries Reporting
10 Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
434
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Rubber Manufacturing
Plastic Molding and Forming
Coil Coating
TRI Reported
TWPE/yr
7,303,782
1.856.645
978,450
628,785
624,250
404,926
385,347
324,393
166,343
106,189
11,763
TRI Rank
1
2
3
4
5
6
7
8
9
10
25
5.5.4.4 Treatment Technology and Pollution Prevention
Coil Coating
Standard treatment for coil coating may include chemical precipitation and
sedimentation, oil removal, cyanide removal, chromium reduction, or filtration.
Canmaking
Standard treatment for canmaking may include chemical precipitation and
sedimentation, oil removal, filtration, neutralization, chemical emulsion breaking, or dissolved
5-163
-------
Section 5 - Existing Industry Review
air flotation. Oil skimming was used as the technology basis for TTO removal for the
canmaking subcategory. Since toxic organics detected in canmaking wastewater are similar to
those in aluminum forming and coil coating wastewater, EPA used the removal rate from
aluminum forming plants to predict the organics removal for canmaking. On average, aluminum
forming plants achieve a 97-percent removal of organics by oil skimming.
Pollution Prevention
Recycle and reuse, and use of alternative cleaning or conversion coating agents
are the focus of current pollution prevention activities. Some facilities have achieved zero
discharge by evaporating wastewater to leave a dry residue. Separating waste streams can
increase the efficiency of the wastewater treatment system and reduce the pounds of chemicals
added for treatment. Table 5-125 lists pollution prevention alternatives for this industry.
Table 5-125. Water Conservation and Pollution Prevention Alternatives
Process
Aluminum coil
coating
Cleaning
Conversion
coating
Finish coating
Can coating
Water Conservation/Pollution Prevention Alternatives
Install ultrafiltration units to remove aluminum etchings from cleaning solutions. This
extends the life of cleaning solutions, thus reducing use of cleaning solvents, and reduces
discharges of aluminum in effluent.
Reduce dragout.
Reuse of alkaline cleaning rinse water as make-up to the alkaline cleaning tank.
Multistage countercurrent rinses.
Use a chromium regeneration system.
Recycle and reuse rinse water.
Recycle quench water.
Use cyanide-free chromating solutions.
Use zinc -free sealing rinses.
Use no-rinse conversion coating in place of chromate conversion coating.
Use solvent -free wax to reduce organic emissions, reduce gas consumption formerly required
to dry the wax/solvent mixture, and reduce combustion by-products from drying and
oxidation process.
Use radiation-cured coatings to reduce VOC emissions and eliminate/reduce the need for
carrier solvents.
Source: EPA, Development Document for Effluent Limitations Guidelines and Standards for the Coil Coating Point
Source Category (Phase I) [Final] (EPA 440-1-82-071), 1982 and. Development Document for Effluent Limitations
Guidelines and Standards for the Coil Coating Point Source Category (Canmaking Subcategory) -Final (EPA 440-
1-83-071), 1983 and industry web sites.
5.5.4.5
Industry Trends
U.S. Economic Census data indicate a decrease in the number of metal canmaking
facilities by 15 percent between 1992 and 1997 (see Table 5-126). The value of goods shipped
has also declined by less than 1 percent during the same time period.
5-164
-------
Section 5 - Existing Industry Review
In Table 5-127, advance comparative statistics for 1997 to 2002 forNAICS code
332 (Fabricated Metal Product Manufacturing) show a continuing decrease in the number of
establishments of almost 3 percent, but just over a 1-percent increase in the value of shipments
(not adjusted for inflation). Table 5-128 illustrates the increase in can shipments since 1982.
Table 5-126. 1992 and 1997 Census Data
SIC
Code
3411
Industry
Segment
Metal Cans
Number of Establishments
1997
274
1992
324
Percent
Change
-15
Value of Goods Shipped
(in billions of dollars)
1997
12.0
1992
12.1
Percent
Change
-0.6
Source: 1997 U.S. Economic Census.
Table 5-127. 1997 and 2002 Census Data
NAICS
Code
332
Industry Segment
Fabricated Metal
Product Mfr.
Number of Establishments
2002
60,602
1997
62,384
Percent
Change
-2.8
Value of Goods Shipped
(billions of dollars)
2002
245
1997
242
Percent
Change
1.2
Source: 2002 U.S. Economic Census.
Table 5-128. Can Shipments by Category
Year
1982
1992
2002
Can Shipments in Billions of Cans
Food
27.6
30.9
31.3
Beverage
57.9
95.7
100.5
General Line
3.8
4.1
4.4
Source: CanCentral.com.. Accessed on July 6, 2004.
5.5.4.6 Stakeholder and Regional Issues
This subsection discusses stakeholder and Regional issues. EPA primarily
received input from stakeholders and EPA Regional staff prior to the Preliminary Effluent
Guidelines Plan. EPA did not receive any comments on the Preliminary Plan pertaining to the
coil coating and canmaking industry.
5-165
-------
Section 5 - Existing Industry Review
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the process of the 2004 annual review
provided input on the Coil Coating category and the Canmaking subcategory. Their suggestions
are summarized below.
Consultations with Permitting Authorities (Section 2.5 of the "Factor 4 Analysis:
Implementation and Efficiency Considerations - Status of Screening Level Review Phase "
(Edocket OW-2003-0074-0329))
EPA permit writers and pretreatment coordinators note that the industry has
changed since the effluent guidelines were promulgated in 1983. The industry is using
completely different solvents than those assessed during the development of the existing
guidelines. However, EPA has received no data to support this observation. EPA permit writers
and pretreatment coordinators are also concerned about the costs associated with monitoring
requirements for pollutants that are no longer used by the industry. In addition, permitting
authorities in EPA Regions 2 and 5 and stakeholders in Alabama and Tennessee have identified
applicability issues. Questions focused on facilities with multiple processes that also perform
coal coating, most recently aluminum forming facilities.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. In the event that stakeholders provide additional
data and supporting information on these or any of the issues identified above, EPA will
reevaluate them at that time.
EPA notes that, for direct dischargers, permit writers can reduce the frequency of
required monitoring through the provisions described at 40 CFR Part 122.44(1)(2) "monitoring
waivers for certain guideline-listed pollutants." (This is not available during the term of the first
permit.) For indirect discharges, the Office of Wastewater Management plans to finalize (in
December 2004) a waiver provision for "pollutants not present" under the National Pretreatment
Program's streamlining regulation. That regulation is projected to be final in December 2004.
5.5.4.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from coil coating
and canmaking operations are low relative to other industrial categories. Discharges from a
single facility contribute over 99 percent of the total TWPE.
Stakeholders and EPA staff identified various issues associated with discharges
from coil coating and canmaking plants. The information in the docket on the 2004 annual
review does not at this time support the concerns raised. In the event that stakeholders provide
additional data and supporting information during subsequent review cycles, EPA will reevaluate
them at that time.
5-166
-------
Section 5 - Existing Industry Review
5.5.5 Dairy Products Processing (Part 405)
During the screening-level review phase of the 2004 annual review, dairy
processing was one of eight industrial categories identified solely through Factor 4 concerns.
Issues driving the concerns include overloading of POTWs and small streams (for direct
dischargers) receiving wastewater from this industry with nutrients and conventional pollutants
such as BOD and oil and grease.
5.5.5.1 Industry Description
The Dairy Products Processing Point Source Category is regulated at 40 CFR Part
405. This point source category includes facilities reporting under SIC industry group 202,
Dairy Products. Specifically, it includes SIC codes 2021 (Creamery Butter), 2022 (Natural,
Processed, and Imitation Cheese), 2023 (Dry, Condensed, and Evaporated Dairy Products), 2024
(Ice Cream and Frozen Desserts), and 2026 (Fluid Milk). No specific subcategories were
identified during the Factor 4 analysis. Below is a description of these SIC codes:
• SIC code 2021 - Creamery Butter. Establishments primarily engaged in
manufacturing creamery butter.
• SIC code 2022 - Natural, Processed, and Imitation Cheese.
Establishments primarily engaged in manufacturing natural cheese (except
cottage cheese), processed cheese, cheese foods, cheese spreads, and
cheese analogs (imitations and substitutes). These establishments also
produce by-products, such as raw liquid whey. Establishments primarily
engaged in manufacturing cottage cheese are classified in SIC code 2026,
and those manufacturing cheese-based salad dressings are classified in
SIC code 203 5.
• SIC code 2023 -Dry, Condensed, and Evaporated Dairy Products.
Establishments primarily engaged in manufacturing dry, condensed, and
evaporated dairy products. Included in this industry are establishments
primarily engaged in manufacturing mixes for the preparation of frozen
ice cream and ice milk and dairy and nondairy base cream substitutes and
dietary supplements.
• SIC code 2024 - Ice Cream and Frozen Desserts. Establishments
primarily manufacturing ice cream and other frozen desserts.
Establishments primarily engaged in manufacturing frozen bakery
products, such as cakes and pies, are classified in SIC code 2053.
• SIC code 2026 - Fluid Milk. Establishments primarily engaged in
processing (e.g., pasteurizing, homogenizing, vitaminizing, bottling) fluid
milk and cream and related products, including cottage cheese, yogurt
5-167
-------
Section 5 - Existing Industry Review
(except frozen), and other fermented milk. Establishments primarily
engaged in manufacturing dry mix whipped toppings are classified in SIC
code 2023; those producing frozen whipped toppings are classified in SIC
code 2038; and those producing frozen yogurt are classified in SIC code
2024.
Facility Counts
EPA obtained information on the number of facilities in the Dairy Products
Processing category from three sources: the 1997 U.S. Economic Census, TRIReleases2000, and
PCSLoads2000. The 2000 TRI database includes facilities reporting discharges to any media.
In contrast, the 2000 PCS database includes only facilities that are permitted for discharge to
surface waters. Table 5-129 lists the number of facilities from these sources.
Table 5-129. Number of Facilities in the Dairy Products Processing Category
SIC
Code
2021
2022
2023
2024
2026
1997 U.S.
Economic
Census
34
525
215
451
613
PCS
Total
4
27
15
6
29
Major
Dischargers
0
2
2
0
1
Minor
Dischargers
4
25
13
6
28
TRI
Total
Reporters
18
141
52
20
94
No Reported
Discharge
2
37
11
8
40
Direct
Discharge
2
22
7
0
1
Indirect
Discharge
14
82
34
11
53
Both Direct
& Indirect
0
0
0
1
0
Source: EPA. PCSLoads2000 and. TRIReleases2000.
Of the 220 reporting facilities, over 50 percent are located in four states: Wisconsin (48
facilities), California (28 facilities), Minnesota (21 facilities), and New York (18 facilities). The
rest are located in 30 other states. Almost 50 percent of the reporting facilities are part of SIC
code 2022 (Natural, Processed, and Imitation Cheese).
5.5.5.2
Regulatory Background
The current ELGS for the Dairy Products Point Source Category, 40 CFR Part
405, contain 12 subcategories (Subpart A - L). EPA promulgated final versions of the effluent
limitations in 1974. Table 5-130 summarizes the current ELGS. The technology basis of
existing regulations was:
In-plant control:
Establishing a plant management improvement program to adopt water
conservation practices, installing waste monitoring equipment, improving
plant maintenance, improving production scheduling practices, improving
quality control, finding alternative uses for products currently wasted to
drain, and improving housekeeping and product-handling practices.
5-168
-------
Section 5 - Existing Industry Review
End-of-Pipe Control: For large plants- biological treatment system (activated sludge, trickling
filter, or aerated lagoon).
For small plants- anaerobic digestion- stabilization lagoon system, and
irrigating with wastewater by spray or ridge and furrow where land is
available and it is economically feasible.
For all sub categories, EPA did not establish PSES or PSNS. In addition, for all subcategories,
EPA set BCT equal to BPT.
Table 5-130. Effluent Guidelines for Dairy Products Processing Part 405
Effluent
Characteristic
BOD,
(Ibs per 100 Ibs
of BOD5 input)
TSS
(Ibs per 100 Ibs
of BOD5 input)
pH
Subpart
A
BandC
D
E
F
G
H
I
J
K and L
A
B
C
D
E
F
G
H
I
J
K
L
All
BPT
Daily Maximum1
0.048-0.063
0.338-0.450
0.138-0.183
0.670-0.893
0.073-0.098
0.220-0.293
0.460-0.613
0.345-0.460
0.163-0.218
0.100-0.130
0.071-0.094
0.551-0.675
0.506-0.675
0.206-0.274
1.005-1.339
0.109-0.146
0.330-0.439
0.690-0.919
0.518-0.690
0.244-0.328
0.150-0.195
0.150-0.195
6-9
Monthly
Average
Maximum1
0.019-0.313
0.135-0.225
0.055-0.091
0.268-0.446
0.029-0.049
0.068-0.146
0.184-0.306
0.138-0.230
0.065-0.109
0.040-0.065
0.029-0.469
0.203-0.338
0.203-0.338
0.083-0.137
0.402-0.669
0.044-0.073
0.132-0.219
0.276-0.459
0.207-0.345
0.098-0.164
0.060-0.098
0.060-0.098
6-9
NSPS
Daily
Maximum
0.010
0.074
0.016
0.148
0.016
0.048
0.094
0.076
0.036
0.022
0.013
0.093
0.093
0.020
0.185
0.020
0.060
0.118
0.095
0.045
0.028
0.023
6-9
Monthly
Average
Maximum
0.005
0.037
0.008
0.074
0.008
0.024
0.047
0.038
0.018
0.011
0.006
0.046
0.046
0.010
0.093
0.010
0.030
0.059
0.048
0.023
0.014
0.014
6-9
The range of values represent limits for different size operations.
5-169
-------
Section 5 - Existing Industry Review
5.5.5.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-131 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for dairy products processing facilities. Facilities not
reporting a flow were not included in the median calculation. Data presented in Table 5-131 are
based on major dischargers reporting to PCS for 2000.
Table 5-131. Wastewater Flows
SIC
2022
2023
2026
Number of Major Facilities
Reporting Nonzero Flows
2
2
1
Median Facility
Flow In 2000
(MGY)
88
202
250
Range of Facility
Flows In 2000
(MGY)
68-109
71-333
NA
Total Flow In
2000 (MGY)
177
404
250
Source: EPA, PCSLoads2000.
NA - No range calculated: only one facility reported a nonzero flow.
Most dairy plants discharge their wastewater to POTWs. The primary pollutants
found in dairy processing plant wastewater are organics and TSS; additional pollutants include
phosphorus, nitrogen, chlorides, and heat. Effluent guidelines are not set for these additional
pollutants; however, control and treatment of the primary pollutants (organics and TSS) help to
maintain these additional pollutants at an acceptable level. Dairy processing wastewater
experiences daily and seasonal fluctuations in temperature, flow, and pollutants. Table 5-132
presents sources of process wastewater and the associated pollutants.
Table 5-132. Sources of Process Wastewater in Dairy Products Processing
Process
Washing, cleaning, and sanitizing of all pipe lines, pumps, processing
equipment, tanks, tank trucks and filling machines
Processing losses, such as start-up, product change-over and shut down of
high temperature short time (HTST) and ultra high temperature (UHT)
pasteurizers
Loss in filling operations through equipment jams, leaks, and broken
packages
Lubrication of casers, stackers, and conveyors that ends up in the
wastewater from washing
Wastewater Pollutant
BOD, TSS, pH, detergents
BOD, TSS, pH, detergents
BOD, TSS, pH
BOD, TSS, pH, detergents, oil
and grease
Sources: EPA. Development Document for Dairy Products Processing. 1974 and. Dairy Food Plant Wastes and
Waste Treatment Practices. 1971.
5-170
-------
Section 5 - Existing Industry Review
Pollutants Discharged
Table 5-133 lists the pollutants reported to PCS for dairy processing facilities that
reported discharges to PCS by major dischargers in 2000. In addition, Table 5-133 lists the
pollutants reported to TRI as discharged directly or for dairy products processing facilities that
reported to TRI for 2000. This table presents the number of facilities that reported each
chemical and the total pounds of chemical discharged to surface waters. Indirect discharging
facilities reported transfers to POTWs. Using average POTW removal efficiencies, EPA
estimated the amount of pollutant discharged to surface water (see DCN 00618, Evaluation of
RSE1Model Runs, for more information). Therefore, the TWPE estimates in this table have been
adjusted to account for POTW treatment.
Table 5-133. Pollutant Discharges Reported to PCS and TRI
Pollutant Category
& Primary Pollutants
All Pollutants
Nonconventionals
Chlorine, Total Residual
Nitrogen, Nitrate Total (As N)
Ammonia as Nitrogen
Conventional
TSS
BOD5
Oil and Grease
Priority
Toluene
PCS
(Pounds/yr)
224,891
81,912
-
7,644
1,878
142,979
97,972
42,037
2,969
0
0
PCS
TWPE/yr
4
4
-
0.5
3 (80%)
0
0
0
TRI
(Pounds/yr)
3,326,527
3,326,522
11,437
3,228,359
37,160
0
5
5
TRI
TWPE/yr
5,829
5,829
5,570 (96%)
200 (3%)
56
0
0
0
Relative to other industries evaluated, TWPE discharges in PCS and TRI are low.
A single facility contributes over 96 percent of the overall TWPE for this industry. For
comparison purposes, Tables 5-134 and 5-135 present the TWPE for dairy products processing
along with the industries reporting the highest discharges in each database. Table 5-134 presents
the information reported to PCS and Table 5-135 presents the information reported to TRI. For a
description of the derivation of the values in these tables, see the memorandum in the public
docket titled Description and Results of EPA Methodology to Synthesize Screening Level Results
for the Effluent Guidelines Program Plan for 2004, which is available through Edocket at
document number OW-2003-0074-0391.
5-171
-------
Section 5 - Existing Industry Review
Table 5-134. Dairy Products Processing TWPE Reported to PCS Compared to
Industries Reporting Highest Discharges
40CFR
Part
423
414
422
415
421
440
410
419
455
418
405
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Fertilizer Manufacturing
Dairy Products Processing
PCS-Reported
TWPE/yr
2,933.209
1,805.928
1,095,321
853,568
434,925
383.560
296,601
198,251
178,977
116,464
5
PCS Rank
1
2
->
j
4
5
6
7
8
9
10
39
Table 5-135. Dairy Products Processing TWPE Reported to TRI Compared to
Industries Reporting Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
405
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Rubber Manufacturing
Plastic Molding and Forming
Dairy Products Processing
TRI-Reported
TWPE/yr
7,303,782
1,856,645
978,450
628,785
624.250
404.926
385.347
324.393
166,343
106,189
5,827
TRI Rank
1
2
->
j
4
5
6
7
8
9
10
30
5-172
-------
Section 5 - Existing Industry Review
5.5.5.4 Treatment Technology and Pollution Prevention
Standard treatments include activated sludge, trickling filters, aeration lagoons,
stabilization ponds, land application, and anaerobic digestion. The 1974 development document
(1) suggested pretreatment practices of anaerobic digestion, high-rate trickling filter and
activated sludge systems, stabilization ponds, aerated ponds, and chemical treatment. Direct
discharging plants may disinfect wastewater with chlorine prior to discharge. Advanced
treatment would replace chlorine disinfection with ozone or ultraviolet light. Most advances are
water conservation and other pollution prevention practices.
Water conservation and pollution prevention practices reduce pollutant loads.
Table 5-136 presents some pollution prevention alternatives for this industry.
5-173
-------
Section 5 - Existing Industry Review
Table 5-136. Pollution Prevention Alternatives for Dairy Products Processing
Type of Technique
Process/equipment
modification
Operational and
housekeeping changes
Recycling/reuse
Material substitution and
elimination
PoDution Prevention Alternatives
Replace traditional faucets with low-flow models.
Shut off water during breaks.
Install water control units.
Install flow meters.
Reduce exterior area water use.
Place catch pans under potential overflows/leaks to reduce cleanup.
Cover outside storage areas.
Conduct inspections and preventive maintenance of potential discharge areas.
Install secondary containment.
Monitor liquid fill machines to prevent overflows.
Cover outside drain during loading and unloading.
Cover inside floor drains (in nonproduction areas only).
Prevent spills and conduct regular inspections of potential spill sites.
Conduct precleaning and dry cleanup.
Install screening.
Minimize pests to reduce the need for chemical pest control.
Use countercurrent washes.
Reuse process water.
Install water recirculation units.
Use recirculating water to chill products.
Recycle refrigerants.
Reduce/recycle/reuse packaging.
Control general inventory to minimize disposal of outdated materials.
Use alternative refrigerants.
Source: Multimedia Environmental Compliance Guide for Food Processors, EPA, 1999.
5.5.5.5
Industry Trends
1997 U.S. Economic Census data indicates the change in the number of the
number of dairy products processing facilities between 1992 and 1997, as shown in Table 5-137.
Although the number of facilities may have increased or decreased, depending on sector, the
value of goods shipped increased by as much as 33 percent during the same time period.
Advance comparative statistics for 1997 to 2002 for the broader category represented by NAICS
code 311 (food manufacturing including grains, fruits and vegetables, dairy, meats, seafood, and
miscellaneous food) shows a very small increase in the number of establishments (less than 1
5-174
-------
Section 5 - Existing Industry Review
percent) and an 8-percent increase in the value of shipments (not adjusted for inflation), as
shown in Table 5-138.
Table 5-137. 1992 and 1997 Census Data
SIC
Code
2021
2022
2023
2024
2026
Industry Sector
Creamery Butter
Natural, Processed, and
Imitation Cheese
Dry, Condensed, and Evap.
Dairy Products
Ice Cream and Frozen
Desserts
Fluid Milk
Number of Establishments
1997
34
525
215
451
613
1992
31
573
214
456
746
Percent
Change
9.7
-8.4
0.5
-1.1
-17.8
Value of Goods Shipped
(billions of dollars)
1997
1.4
20.3
9.2
5.9
22.2
1992
1.0
16.9
7.5
5.3
21.9
Percent
Change
32.9
20.1
21.9
11.6
1.4
Source: 1997 U.S. Economic Census.
Table 5-138. 1997 and 2002 Census Data
NAICS
Code
311
Industry Segment
Food Manufacturing
Number of Establishments
2002
26,374
1997
26,302
Percent
Change
0.27
Value of Goods Shipped
(billions of dollars)
2002
457
1997
422
Percent
Change
8.4
Source: 2002 U.S. Economic Census.
5.5.5.6
Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and EPA regional issues. EPA primarily
received input from stakeholders and EPA Regional staff prior to the Preliminary Effluent
Guidelines Plan. EPA did not receive any comments to the Preliminary Plan pertaining to the
dairy products processing industry.
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the 2004 annual review provided input
on the Dairy Products Processing category. Each group and their suggestions are summarized
below.
5-175
-------
Section 5 - Existing Industry Review
Previous Suggestions (Section 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
In the fall of 1999 and again in the spring of 2001, EPA requested suggestions
from Headquarters, Regional, and state staff charged with the task of implementing effluent
guidelines to follow up on concerns and to gather recommendations regarding which effluent
guidelines the Agency might develop or revise. Responders identified dairy products processing
based on concerns over the discharge of nutrients. They were also concerned about overloading
POTWs and small streams (for direct dischargers) with conventional pollutants such as BOD.
Another issue identified included a concern for copper in relation to dairies; however, follow-up
identified this issue to be a miscommunication.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. Some stakeholders identified nutrient discharges
from dairy processing plants as a concern. Information in PCS and TRI does not indicate that
dairy processing plants are discharging significant quantities of nutrients relative to other
industrial categories. In the event that stakeholders provide additional data and supporting
information on these or any of the issues identified above, EPA will reevaluate them at that time.
5.5.5.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from dairy
processing plants are low relative to other industrial categories. Total residual chlorine
discharges from a single facility contributes over 96 percent of the overall TWPE for this
industry.
Stakeholders and EPA staff identified various issues associated with discharges
from dairy processing plants. The information in the docket at this time does not support the
concerns raised. In the event that stakeholders provide additional data and supporting
information during subsequent review cycles, EPA will reevaluate them at that time.
5.5.5.8 References
1. U. S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Dairy Product Processing Point Source
Category. EPA-440/1-74-021-a. Washington, D.C. May 1974.
5.5.6 Electrical and Electronic Components (Part 469)
During the screening-level review phase of the 2004 annual review, electrical and
electronic components was one of eight industrial categories identified solely through Factor 4
concerns. Issues driving the concerns include: 1) significant process changes resulting in
5-176
-------
Section 5 - Existing Industry Review
changes in the typical pollutants discharged, including a shift from aluminum to copper, and
2) confusion over applicability of effluent guidelines for metal finishing.
5.5.6.1
Industry Description
The Electrical and Electronic Components Point Source Category is regulated at
40 CFR Part 469. This point source category includes facilities reporting under SIC major group
36, Electronic and Other Electrical Equipment and Components, Except Computer Equipment.
Specifically, it includes facilities in SIC code 3671, Electron Tubes, and SIC code 3674,
Semiconductors and Related Devices. No specific subcategories were identified during the
Factor 4 analysis. Below is a description of the SIC codes:
• SIC code 3671: Electron Tubes. Establishments primarily engaged in
manufacturing electron tubes and tube parts. Establishments primarily
engaged in manufacturing X-ray tubes and parts are classified in SIC code
3844.
• SIC code 3674: Semiconductors mid Related Devices. Establishments
primarily engaged in manufacturing semiconductors and related solid-state
devices. Important products of this industry are semiconductor diodes and
stacks, including rectifiers, integrated microcircuits (semiconductor
networks), transistors, solar cells, and light sensing and emitting
semiconductor (solid-state) devices.
Facility Counts
Information on the number of facilities in the Electrical and Electronic
Components Point Source Category was obtained from three sources: the 1997 U.S. Economic
Census, TRIReleases2000, and PCSLoadslOOO. TRI includes facilities reporting discharges to
any media. In contrast, PCS includes only facilities that are permitted for discharge to surface
waters. The number of facilities from these sources is listed in Table 5-139.
Table 5-139. Number of Facilities in the Electrical and Electronic Components Category
SIC
Code
3671
3674
1997
Census
159
1099
PCS
Total
5
13
Major
Dischargers
1
4
Minor
Dischargers
4
9
TRI
Total
Reporting
1
150
No Reported
Discharge
4
51
Direct
Discharge
0
4
Indirect
Discharge
4
91
Both Direct
and Indirect
5
4
Source: EPA, PCSLoads2000, TRIReleases2000.
The 111 reporting facilities are located in 22 states, with the highest concentrations in California
(20 percent), Texas (17 percent), Arizona (11 percent), Oregon (9 percent), and Pennsylvania (9
percent).
5-177
-------
Section 5 - Existing Industry Review
5.5.6.2 Regulatory Background
When promulgated, the ELGS for the Electrical and Electronic Components Point
Source Category, 40 CFRPart 469, contained 21 subcategories. Seventeen of these
subcategories were excluded from regulation under Paragraph 8 of the Revised Settlement
Agreement. The following four categories (A - D) may apply to discharges from electrical and
electronic components facilities:
• Semiconductor Subcategory: EPA promulgated ELGS for BPT, BAT,
BCT, NSPS, PSES, and PSNS (Subpart A) in 1983.
• Electronic Crystals Subcategory: EPA promulgated ELGS for BPT,
BAT, BCT, NSPS, PSES, and PSNS (Subpart B) in 1983.
Cathode Ray Tube Subcategory: EPA promulgated ELGS for NSPS,
PSES, and PSNS in 1984. Existing direct dischargers in this Subcategory
were excluded from regulation under Paragraph 8 of the Revised
Settlement Agreement. The only direct discharger in this Subcategory
discharged less than two pounds per day after treatment.
• Luminescent Materials Subcategory: EPA promulgated NSPS and PSNS
in 1984. Existing dischargers in this Subcategory were excluded from
regulation under Paragraph 8 of the Revised Settlement Agreement. The
two direct dischargers in this Subcategory each discharged less than one
pound per day after treatment. The indirect dischargers were excluded on
the basis that their toxic discharges to POTWs were insignificant.
Existing regulations do not include limits on conventional parameters for any of
the four subcategories. BOD and oil and grease were detected at concentrations below
treatability. Fecal coliform was not present in the discharges from any of the subcategories. In
addition, the existing regulations do not include limits on copper.
EPA established limitations for TTO for new and existing sources in the
semiconductors and electronic crystals subcategories. EPA detected several toxic organics in
process wastes resulting from solvent cleaning and developing and stripping photoresist. TTO is
the sum of the mass of each of the following toxic organic compounds that are found at a
concentration greater than 0.010 mg/1:
• 1,2,4-Trichlorobenzene; • Chloroform;
• 1,2-Dichlorobenzene; • 1,3-Dichlorobenzene;
• 1,4-Dichlorobenzene; • Ethylbenzene;
• 1,1,1-Trichloroethane; • Methylene chloride;
• Naphthalene; • 2-Nitrophenol phenol;
• Bis (2-ethylhexyl) phthalate; • Tetrachloroethylene;
5-178
-------
Section 5 - Existing Industry Review
Toluene;
2-Chlorophenol;
4-Nitrophenol;
Di-n-butyl phthalate;
1,2-Diphenylhydrazine;
Butyl benzyl pthalate;
2,4,6-Trichlorophenol;
1,2-Dichloroethane;
Dichlorobromom ethane.
Trichloroethylene;
2,4-Dichlorophenol;
Pentachlorophenol;
Anthracene;
Isophorone;
1,1 -Dichloroethylene;
Carbon tetrachloride;
1,1,2-Trichloroethane; and
Performance standards for TTO were established for new sources in the cathode
ray tubes subcategory. EPA detected six toxic organics in process wastes resulting from the use
of solvents for cleaning and degreasing operations, and from the application of toluene-based
laquer coatings. TTO is the sum of the mass of each of the following toxic organic compounds
that are found at a concentration greater than 0.010 mg/1: 1,1,1 -trichloroethane; chloroform;
methylene chloride; bis(2-ethylhexyl)phthalate; toluene; and trichloroethylene.
The technology basis for the limitations in each subcategory are:
• Semiconductors, neutralization, solvent management, in-plant
precipitation of concentrated fluoride stream;
• Electronic Crystals Manufacturing, neutralization, solvent management,
and end-of-pipe precipitation/clarification;
• Cathode Ray Tubes, solvent management, neutralization, and end-of-pipe
precipitation/clarification; and
• Luminescent Materials Manufacturing, neutralization, precipitation/
clarification.
Table 5-140 presents the effluent guidelines for the semiconductors and electronic crystals
subcategories. Table 5-141 presents the guidelines for cathode ray tubes and luminescent
materials manufacturing.
Table 5-140. Effluent Guidelines for Semiconductors and Electronic Crystals
Manufacturing (Concentration-Based)
Pollutant
TTO
pH
30-day Average Limits (mg/L)
BPT
1.371
within the range
of 6 to 9
BAT
1.371
NA
BCT
1.371
within the range
of 6 to 9
NSPS
1.371
within die range
of 6 to 9
PSES & PSNS
1.37'
NA
5-179
-------
Section 5 - Existing Industry Review
Table 5-140 (Continued)
Pollutant
TSS
Fluoride
Arsenic
30-day Average Limits (mg/L)
BPT
232
17.43
0.834
BAT
NA
17.4
0.83d
BCT
232
NA
NA
NSPS
232
17.4
0.834
PSES & PSNS
NA
NA
0.834
Source: EPA, Development Document for Phase I, 1983.
NA - No limit.
TTO - Total Toxic Organics.
'The limit for TTO represents a daily maximum value.
2Limits for TSS only apply to the electronic crystals subcategory.
3There is no BPT limit for fluoride for the semiconductor subcategory.
4Limits for arsenic only apply to facilities with gallium or indium arsenide crystal manufacturing operations.
Table 5-141. Effluent Limitations and Standards for Cathode Ray Tubes and Luminescent
Materials Manufacturing (Concentration-Based)
Pollutant
TTO
pH
TSS
Cadmium
Chromium2
Lead2
Zinc
Fluoride
Antimonv3
30-Day Average Limit (mg/L)
NSPS
1.58
within the range of 6 to 9
18 to 31
0.03 to 0.26
0.26
0.27
0.33 to 0.67
18
0.04
PSES1
NA
NA
NA
0.03
0.30
0.41
0.56
18
NA
PSNS
NA
NA
NA
0.03 to 0.26
0.26
0.27
0.33 to 0.67
18
0.04
Source: EPA, Development Document for Effluent Limitations Guidelines for the Electrical and Electronic
Components Point Source Category - Phase II (EPA 440-1-84-075), 1984.
NA - No limit.
TTO - Total Toxic Organics.
'PSES limits only apply to the cathode ray tubes subcategory.
2Limits for chromium and lead only apply to the cathode ray tubes subcategory.
3Limits for antimony only apply to die luminescent materials subcategory.
5-180
-------
Section 5 - Existing Industry Review
Related Effluent Guidelines
EPA believes that semiconductor manufacturing can be divided into two sections
for the purposes of applying the requirements of 40 CFR Part 469 and Part 433: Metal Finishing.
Metal finishing comprises the following processes:
Electroplating;
Electroless plating;
Anodizing;
Coating (chromating, phosphating, and coloring);
Chemical etching and milling; and
Printed circuit board manufacture.
For some semiconductor manufacturing operations, ELGS for the Electrical and
Electronic Components category (Part 469) may be effective and applicable to wastewater
discharges from Metal Finishing (Part 433) listed above. In such cases, the Part 433 limits will
not apply and the Part 469 regulations will apply. EPA clarified this overlap in a memorandum
dated April 21, 1998 (1). New technologies in semiconductor manufacturing include
electroplating-type operations that add microscopic amounts of metal to selective portions of the
wafer. These operations are distinguished from the electroplating operations that occur in the
final assembly process, which is separate from wafer fabrication. EPA concluded that processes
performed in a fab cleanroom before final assembly, including the electroplating-type operations,
are to be regulated under 40 CFR Part 469. Part 433 applies only to processes after wafer
fabrication, in which a layer of metal is deposited onto the surface of the wafer to provide
contact points for final assembly.
5.5.6.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-142 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for electrical and electronic component facilities. Facilities
not reporting a flow were not included in the median calculation. Data presented in Table 5-142
are based on major dischargers reporting to PCS for 2000.
Table 5-142. Wastewater Flows
SIC
Code
3671
3674
Number of Major
Facilities Reporting
Nonzero Flows
1
4
Median Facility Flow
In 2000 (MGY)
191
1.651
Range of Facility
Flows In 2000
(MGY)
NA
59 - 15.493
Total Flow In 2000
(MGY)
191
18.853
Source: EPA, PCSLoads2000.
NA - No range calculated; only one facility reported a nonzero flow.
5-181
-------
Section 5 - Existing Industry Review
Table 5-143 presents sources of process wastewater and the associated pollutants
identified in the 1983 and 1984 Development Documents, organized by the four subcategories in
the effluent guidelines.
Table 5-143. Sources of Process Wastewater in Electrical and Electronic Components
Category
Wastewater
Pollutants
Semiconductors
Acid wastes from etching and cleaning
Water rinses
Equipment cleaning waste
Scmbber wastes
Stripper quench rinses
Chemical mechanical planarization
(CMP)
Fluoride, low pH, toxic organics
Fluoride (low levels), toxic organics
Toxic organics. may have high pH if caustic cleaning agent is used.
Toxic organics
Toxic organics
Copper
Electronic Crystals
Crystal growing operations
Etching
Manufacture of gallium or indium
arsenic crystals
Cutting and grinding operations
Equipment cleaning
Sodium hydroxide, sodium carbonate
Fluoride, toxic organics
Arsenic
Suspended solids
Toxic organics
Cathode Ray Tubes
Glass panel wash
Mask degrease
Photoresist application
Phophor application
Glass funnel and mount cleaning
Tube coating
Tube Salvage
Fluoride
Toxic organics
Chromium
Cadmium, zinc
Fluoride
Suspended solids from graphite emulsions
Lead, cadmium, zinc, fluoride, chromium, suspend solids
Luminescent Materials
Lamp phosphor process
Blue and green phosphor process
Antimony, fluoride, suspended solids
Cadmium, zinc, suspended solids
Sources: EPA, Development Documents for Electrical and Electronic Components Phases I and II, 1983 & 1984;
Maag et al.. Assessing the Environmental Impact of Copper CA'IP, 2000.
5-182
-------
Section 5 - Existing Industry Review
Pollutants Discharged
Table 5-144 lists the pollutants reported to PCS for electrical and electronic
component facilities that reported discharges to PCS by major dischargers in 2000. In addition,
this table lists the pollutants reported to TRI as discharged directly or for electrical and electronic
component facilities that reported to TRI for 2000. This table lists the number of facilities that
reported each chemical and the total pounds of chemical discharged to surface waters. Indirect
discharging facilities reported transfers to POTWs. Using average POTW removal efficiencies,
EPA estimated the amount of pollutant discharged to surface water (see DCN 00618, Evaluation
of RSE1 Model Runs, for more information). Therefore, the TWPE estimates in this table have
been adjusted to account for POTW treatment.
Table 5-144. Pollutant Discharges Reported to PCS and TRI
Pollutant Category
and Primary Pollutants
All Pollutants
Priority
Silver
Lead
Arsenic
Copper
Nonconventional
Total Fluoride
Manganese
Ammonia as Nitrogen
Ethylene Glycol
Nitrogen, Nitrate Total (As N)
Conventionals
BOD5
TSS
Oil and Grease
PCS
(Pounds)
9,094,696
18,612
786
15
642
2,946
8,893,786
145,775
73,775
0
0
182,297
77.341
74.414
30.542
PCS TWPE
23,714
18,340
12,941 (71%)
34
2.228 (12%)
1,847 (10%)
5,374
5.102 (95%)
135 (3%)
0
0
1
-
-
-
TRI
(Pounds)
4,205,438
6,243
0
2,569
389
206
4,199,195
0
18,957
405,891
186.118
3,441,214
0
-
-
-
TRI TWPE
9,800
7,372
0
5,754 (78%)
1,349 (18%)
129
2,428
0
1,335 (55%)
611 (25%)
249 (10%)
213 (9%)
0
—
—
-
Source: EPA, PCSLoads2000 and TRIRe/eases2000.
Relative to other industries evaluated, TWPE discharges in PCS and TRI are low.
Generally, a few facilities contribute the bulk of the TWPE estimates from both TRI and PCS.
For comparison purposes, Tables 5-145 and 5-146 present the TWPE for electrical and electronic
component facilities along with the industries reporting the highest discharges in each database.
Table 5-145 presents the information reported to PCS and Table 5-146 presents the information
reported to TRI. For a description of the derivation of the values in these tables, see the
5-183
-------
Section 5 - Existing Industry Review
memorandum in the public docket titled Description and Results of EPA Methodology to
Synthesize Screening Level Results for the Effluent Guidelines Program Plan for 2004, which is
available through Edocket at document number OW-2003-0074-0391.
Table 5-145. Electrical and Electronic Components TWPE Reported to PCS Compared to
Industries with the 10 Highest Discharges
40CFR
Part
423
414
422
415
421
440
410
419
455
418
469
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Fertilizer Manufacturing
Electrical and Electronic Components
PCS-Reported TWPE
2,933,209
1,805.928
1,095.321
853.568
434,925
383,560
296,601
198,251
178,977
116,464
23,714
PCS Rank
1
2
o
j
4
5
6
7
8
9
10
17
Table 5-146. Electrical and Electronic Components TWPE Reported to TRI Compared to
Industries with the 10 Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
469
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp. Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Rubber Manufacturing
Plastic Molding and Forming
Electrical and Electronic Components
TRI-Reported TWPE
7,303,782
1,856,645
978,450
628,785
624,250
404,926
385,347
324,393
166,343
106,189
9,789
TRI Rank
1
2
->
j
4
5
6
7
8
9
10
27
5-184
-------
Section 5 - Existing Industry Review
5.5.6.4 Treatment Technology and Pollution Prevention
Control of toxic organics is achieved through solvent management. End-of-pipe
treatment generally consists of neutralization and precipitation/clarification.
Facilities that manufacture electrical and electronic components use large
amounts of ultra-pure water (UPW) in their processes. Since production of UPW is expensive,
pollution prevention efforts in this industry have focused on water efficiency and reuse. Table
5-147 presents water conservation and pollution prevention alternatives for this industry.
Table 5-147. Water Conservation and Pollution Prevention Alternatives for the Electrical
and Electronic Components Category
Process
Rinsing
Water reclamation/
materials recovery
Once-through
cooling
Water Conservation/Pollution Prevention Alternatives
• Evaluate number of rinses and duration based on level of contamination to eliminate
unnecessary rinses.
• Use countercurrent or spray rinsing to improve efficiency.
• Switch from continuous flow to on-demand rinsing.
• Use membrane technologies (microfiltration, ultrafiltration, reverse osmosis, and
electrodialysis) to recycle and recover process water.
• Recover reusable materials, such as copper and chromium, from process wastewater.
• Treat spent rinse water at the DI water generating plant and reuse in process.
• Use air-cooled models to eliminate water-usage for single-pass cooling.
Source: Energy and Water Efficiency for Semiconductor Manufacturing, Pacific Northwest Pollution Prevention
Resource Center, 2000.
5.5.6.5 Industry Trends
As shown in Table 5-148, U.S. Economic Census data indicate that, between
1992 and 1997, there was an almost 16-percent decrease in the number of electron tube
manufacturing facilities and an almost 20-percent increase in the number of facilities
manufacturing semiconductors and related devices. Value of goods shipped increased in both
sectors, by almost 23 percent for electron tubes and by 144 percent for semiconductors. As
shown in Table 5-149, advance comparative statistics for 1997 to 2002 for the broader category
represented by NAICS code 334 (facilities that manufacture computer and electronic products)
show an almost 10-percent decrease in the number of establishments and a 19-percent decrease
in the value of shipments (not adjusted for inflation).
5-185
-------
Section 5 - Existing Industry Review
Table 5-148. 1992 and 1997 Census Data
SIC
Code
3671
3674
Industry Sector
Electron Tubes
Semiconductors &
related devices
Number of Establishments
1997
159
1,099
1992
189
920
Percent
Change
-15.9
19.5
Value of Shipped Goods
(billions of dollars)
1997
3.9
0.079
1992
3.1
0.032
Percent
Change
22.7
144
Source: 1997 U.S. Economic Census.
Table 5-149. 1997 and 2002 Census Data
NAICS
Code
334
Industry Segment
Computer and Electronic
Product Manufacture
Number of Establishments
2002
15,698
1997
17,435
Percent
Change
-9.96
Value of Goods Shipped
(billions of dollars)
2002
354
1997
439
Percent
Change
-19.4
Source: 2002 U.S. Economic Census.
5.5.6.6
Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and EPA regional issues. EPA primarily
received input from stakeholders and EPA Regional staff prior to the Preliminary Effluent
Guideline Plan. EPA did not receive any comments to the Preliminary Plan pertaining to the
electrical and electronic component industry.
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the 2004 annual review provided input
on the Electrical and Electronic Components category. Their suggestions are summarized
below.
Permitting Authorities (Section 2.5 of the "Factor 4 Analysis: Implementation
and Efficiency Considerations - Status of Screening Level Review Phase " (Edocket OW-2003-
0074-0329))
EPA permitting authorities suggest that these guidelines need to be revised due to
significant changes since they were promulgated. EPA permitting authorities also suggest that
the semiconductor manufacturing portion of this industry be evaluated because there have been
major changes in the industry. Two new circumstances in this portion of the industry raise
concerns: 1) the industry is moving from aluminum to the more toxic copper to build internal
components; and 2) the industry is increasingly using new process operations, one of which is
5-186
-------
Section 5 - Existing Industry Review
chemical-mechanical planarization (CMP) (a polishing step resulting in the abrasive removal of
metals), which generates more or different pollution than the processes considered during the
development of the existing ELGS.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments its receives, EPA cannot address
thesesuggestions without adequate supporting data. Information in PCS and TRI does not
indicate that electrical and electronic component facilities are discharging significant quantities
of copper relative to other industries (Tables 5-150 and 5-151). In the event that stakeholders
provide additional data and supporting information on these or any of the issues identified above,
EPA will reevaluate them at that time.
Table 5-150. Copper Discharges Reported to TRI by Electrical and Electronic Component
Manufacturing Facilities
SIC
Code
3671
3674
Sector
Electron Tubes
Semiconductors and
Related Devices
# Facilities
1
1
1
2
Pollutant
Copper Compounds
Copper Compounds
Copper
Copper Compounds
Discharge
Status
Direct
Indirect
Indirect
Indirect
Pounds
31
14
1.4
160
TWPE
19
8.6
0.86
100
Source: EPA, TRIReleases2000.
Table 5-151. Copper1 Discharge Data in PCS for Electrical and Electronic Component
Manufacturing Facilities
SIC
Code
3671
3674
Sector
Electron Tubes
Semiconductors and Related Devices
# Facilities
1
3
Pounds
45
2,901
TWPE
28
1,819
Source: EPAPCSLoads2000.
'Copper is reported as Copper, Total as Cu.
5-187
-------
Section 5 - Existing Industry Review
5.5.6.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from electrical
and electronic component facilities are low relative to other industrial categories. In addition,
generally, a few facilities contribute the bulk of the TWPE estimates from both TRI and PCS.
Stakeholders and EPA staff identified various issues associated with discharges
from electrical and electronic component facilities. The information in the docket on the 2004
annual review does not at this time support the concerns raised. In the event that stakeholders
provide additional data and supporting information during subsequent review cycles, EPA will
reevaluate them at that time.
5.5.6.8 References
1. Pendergast, James F. and Sheila E. Frace. Permitting Guidance for
Semiconductor Manufacturing Facilities. Memorandum to regional water
management division directors. April 1998.
5-188
-------
Section 5 - Existing Industry Review
5.5.7 Metal Molding and Casting (Part 464)
During the screening-level review phase of the 2004 annual review, metal
molding and casting was one of eight industrial categories identified solely through Factor 4
concerns. Issues driving the concerns include: 1) discharges of phenol, 2) changes to the
industry since the guidelines promulgated, 3) applicability to aluminum die casters, and 4)
discrepancies between limits set for these guidelines and those set for the same pollutants by the
guidelines for metal finishing.
5.5.7.1 Industry Description
The Metal Molding and Casting Point Source Category is regulated at 40 CFR
Part 464. This point source category includes facilities reporting under SIC industry group 33:
Primary Metal Industries, and the subgroups 332: Iron and Steel Foundries and 336: Nonferrous
Foundries. Specifically, it includes SIC codes 3321 (Gray and Ductile Iron Foundries), 3325
(Steel Foundries Not Elsewhere Classified), 3364 (Nonferrous Die-Castings, Except Aluminum),
3365 (Aluminum Foundries), 3366 (Copper Foundries), and 3369 (Nonferrous Foundries Except
Aluminum and Copper). No specific subcategories were identified during the Factor 4 analysis.
Below is a description of the SIC codes for this category:
• SIC code 3321- Gray and Ductile Iron Foundries. Establishments
primarily engaged in manufacturing gray and ductile iron castings,
including cast iron pressure and soil pipes and fittings.
• SIC code 3322 - Malleable Iron Foundries. Establishments primarily
engaged in manufacturing malleable iron castings.
• SIC code 3324 - Steel Investment Foundries. Establishments primarily
engaged in manufacturing steel investment castings.
• SIC code 3325 - Steel Foundries, Not Elsewhere Classified.
Establishments primarily engaged in manufacturing steel castings, not
elsewhere classified.
• SIC code 3364 - Nonferrous Die-Castings, Except Aluminum.
Establishments primarily engaged in manufacturing nonferrous metal die-
castings, except aluminum.
5-189
-------
Section 5 - Existing Industry Review
• SIC code 3365 -AluminumFoundries. Establishments primarily engaged
in manufacturing aluminum (including alloys) castings, except die-
castings.
• SIC code 3366 - Copper Foundries. Establishments primarily engaged in
manufacturing copper (including alloys) castings, except die-castings.
• SIC code 3369 - Nonferrous Foundries, Except Aluminum and Copper.
Establishments primarily engaged in manufacturing nonferrous metal
castings (including alloys), except all die-castings and other castings of
aluminum or copper.
Facility Counts
EPA obtained Information on the number of facilities in the Metal Molding and
Casting Point Source Category from three sources: the 1997 U.S. Economic Census,
TRIReleases2000, and PCSLoads2000. TRI includes facilities reporting discharges to any
media. In contrast, PCS includes only facilities that are permitted for discharge to surface
waters. Table 5-152 lists the number of facilities from these sources.
Table 5-152. Number of Facilities in the Metal Molding and Casting Category
SIC
Code
3321
3322
3324
3325
3364
3365
3366
3369
1997 U.S.
Economic
Census
669
28
159
288
279
626
312
141
PCS
Total
31
4
2
8
6
14
0
6
Major
Dischargers
4
0
0
2
0
2
0
0
Minor
Dischargers
27
4
2
6
6
12
0
6
TRI
Total
Reporters
200
8
43
99
20
74
72
58
No Reported
Discharge
137
5
23
72
14
60
49
32
Direct
Discharge
28
2
3
15
0
8
10
6
Indirect
Discharge
22
1
10
8
6
4
8
14
Both Direct
& Indirect
13
0
7
4
0
2
5
6
Source: EPA, PCSLoads2000, TRIReleases2000.
Of the 189 facilities reporting discharges to PCS or TRI, over 50 percent (95) are concentrated in
six states: Ohio (21), Pennsylvania (17), Wisconsin (16), Indiana (14), Michigan (14), and
Alabama (13). The rest are located in 30 states around the country.
5.5.7.2
Regulatory Background
The current ELGS for the Metal Molding and Casting Point Source Category, 40
CFR Part 465, contain four subcategories (Subparts A - D). Effluent limitations were first
proposed November 1982. Final versions of the effluent limitations for Subparts A - D were
5-190
-------
Section 5 - Existing Industry Review
promulgated October 30, 1985. EPA established no limitations for the magnesium casting
subcategory as the Agency determined they were not achievable economically for existing
plants. BCT was reserved for all subparts (A-D). NSPS are equal to BAT; PSNS are equal to
PSES.
Effluent limitations guidelines are mass-based on the basis of metric ton (kkg) of
metal poured or sand reclaimed, or standard cubic meters (Sm3) of air scrubbed. Limitations
were established based on a subcategorization and production process segmentation scheme.
Separate limitations were developed for facilities with intermittent or noncontinuous discharge.
Table 5-153 presents the 30-day averages for BPT and for BAT/NSPS/PSES/PSNS.
The technology basis of existing regulations is recycle, lime precipitation and
sedimentation for BPT and recycle, lime precipitation and sedimentation, and filtration for BAT,
NSPS, PSES and PSNS. "No discharge of process wastewater" is the basis of limitations for 3
of the 28 regulated process segments. These processes are the grinding scrubber process for the
aluminum, copper, and ferrous casting subparts.
Table 5-153. Effluent Guidelines for Metal Molding and Casting - Continuous Direct
Dischargers (kg/kkg)
Pollutant Parameter
TSS
Oil and Grease
Total Phenols1
Total Toxic Organics
Copper
Lead
Zinc
pH
BPT
30-day Averages
0.13-165
0.0864-110
0.0026-1.17
not regulated for BPT
0.036-4.63
0.0034-4.3
0.0037-6.17
7.0-10.0
BAT/NSPS/PSES/PSNS
30-day Averages
0.104-1652
0.0864-1 102
0.0026-1. 173
0.0064-8.294
0.0036-4.633
0.0022-4.33
0.0025-4.743
Not regulated
'Phenols not regulated at BPT for casting cleaning and quench, investment casting, mold cooling, or slag quench.
2NSPS.
3BAT, NSPS, PSES, PSNS.
4PSES and PSNS.
5.5.7.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge outfall flow rates. Table
5-154 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for metal molding and casting facilities. Facilities not
reporting a flow were not included in the median calculation. Data presented in Table 5-154 are
based on major dischargers reporting to PCS for 2000.
5-191
-------
Section 5 - Existing Industry Review
Table 5-154. Wastewater Flows in Metal Molding and Casting
SIC
Code
3321
3322
3324
3325
3364
3365
3366
3369
Number of Major Facilities
Reporting Nonzero Flows
4
NA
NA
2
NA
2
NA
NA
Median Facility
Flow in 2000
(MGY)
709
NA
NA
431
NA
90
NA
NA
Range of Facility
Flows in 2000
(MGY)
315-7008
NA
NA
57-805
NA
89-92
NA
NA
Total Flow in 2000
(MGY)
8,740
NA
NA
862
NA
180
NA
NA
Source: EPA. PCSLoads2000.
NA - PCS data were not available for the SIC code.
Wastewater pollutant loads from facilities in this industry depend on water usage,
type of metal being cast, and the production process used. Suspended solids and metals loading
are higher in scrubber wastewaters than in mold cooling wastewaters. Oil and grease and
organic priority pollutant loadings are higher in die casting wastewaters than in casting quench
wastewaters. A major portion of the wastewater from die casting operations is water used as a
carrier solution for oily die casting lubricants. Table 5-155 presents the sources of process
wastewater in this category. Approximately 80 percent of the regulated wastewater from this
industry is generated by wet air pollution control devices
Table 5-155. Sources of Process Wastewater in Metal Molding and Casting
Process
Casting cleaning
Casting quench
Die casting
Dust collection scrubber
Grinding scrubber
Investment casting
Melting furnace scrubber
Mold cooling
Slag quench
Wet sand reclamation
Wastewater Pollutants
Metals, suspended solids, oil and grease, toxic organics
Metals, suspended solids, oil and grease, toxic organics
Metals, suspended solids, oil and grease, toxic organics, phenols
Metals, suspended solids, oil and grease, toxic organics, phenols
Metals, suspended solids, oil and grease, total toxic organics
Metals, suspended solids, oil and grease, toxic organics
Metals, suspended solids, oil and grease, toxic organics, phenols
Metals, suspended solids, oil and grease, toxic organics
Metals, suspended solids, oil and grease, toxic organics
Metals, suspended solids, oil and grease, toxic organics, phenols
Source: EPA. Development Document for Effluent Limitations Guidelines and Standards for the Metal Molding and
Casting (Foundries) Point Source Category (Final) (EPA 440-1-85-070). 1985
5-192
-------
Section 5 - Existing Industry Review
Pollutants Discharged
Table 5-156 lists the pollutants reported to PCS for metal molding and casting
facilities that reported discharges to PCS by major dischargers in 2000. In addition, Table 5-156
lists the pollutants reported to TRI as discharged directly or for metal molding and casting
facilities that reported to TRI for 2000. This table presents the number of facilities that reported
each chemical and the total pounds of chemical discharged to surface waters. Indirect
discharging facilities reported transfers to POTWs. Using average POTW removal efficiencies,
EPA estimated the amount of pollutant discharged to surface water (see DCN 00618, Evaluation
of RSE1 Model Runs, for more information). Therefore, the TWPE estimates in this table have
been adjusted to account for POTW treatment
Table 5-156. Pollutant Discharges Reported to PCS and TRI
Pollutant Category
& Primary Pollutants1
All Pollutants
Nonconventionals
Sodium Nitrite
Chlorine, Total Residual
Molybdenum
Conventional
Oil and Grease
TSS
BOD5
Priority
Lead
Polychlorinated Biphenyls
Copper
PCS
(Pounds)
2,253,343
2,008,818
-
817
517
233,663
133,461
91,425
8,777
10,862
1.714
0.053
532
PCS TWPE
5,834
561
-
398 (71%)
104 (19%)
0
-
-
-
5,273
3,840 (73%)
677 (13%)
333 (6%)
TRI
(Pounds)
284,419
257,189
78,062
2,600
-
0
-
-
-
27,230
3.173
-
8,380
TRI TWPE
45,182
31,399
29.143 (93%)
1,266 (4%)
-
0
-
-
-
13,783
7.108 (52%)
-
5,254 (38%)
The majority of each pollutant type is discharged by facilities in SIC code 3321.
Relative to other industries evaluated, TWPE discharges in PCS and TRI are low.
Generally, a few facilities contribute the bulk of the TWPE estimates from both TRI and PCS.
For comparison purposes, Tables 5-157 and 5-158 present the TWPE for metal molding and
casting along with the industries reporting the highest discharges in each database. Table 5-157
presents the information reported to PCS and Table 5-158 presents the information reported to
TRI. For a description of the derivation of the values in these tables, see the memorandum in the
public docket titled Description and Results of EPA Methodology to Synthesize Screening Level
Results for the Effluent Guidelines Program Plan for 2004, which is available through Edocket
at document number OW-2003-0074-0391.
5-193
-------
Section 5 - Existing Industry Review
Table 5-157. Metal Molding and Casting TWPE Reported to PCS Compared to
Industries Reporting Highest Discharges
40CFR
Part
423
414
422
415
421
440
410
419
455
418
464
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Fertilizer Manufacturing
Metal Molding and Casting
PCS-Reported TWPE
2,933,209
1.805,928
1,095,321
853,568
434,925
383,560
296,601
198,251
178.977
116,464
5,834
PCS Rank
1
2
3
4
5
6
7
8
9
10
26
Source: EPA, PCSLoads2000.
Table 5-158. Metal Molding and Casting TWPE Reported to TRI Compared to
Industries Reporting Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
464
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Rubber Manufacturing
Plastic Molding and Forming
Metal Molding and Casting
TRI-Reported TWPE
7,303,782
1,856,645
978.450
628,785
624,250
404.926
385,347
324,393
166.343
106,189
45,173
TRI Rank
1
2
3
4
5
6
7
8
9
10
16
Source: EPA, TRIReleases2000.
5-194
-------
Section 5 - Existing Industry Review
5.5.7.4
Treatment Technology and Pollution Prevention
Standard treatment may include chemical precipitation and sedimentation, oil
removal, and filtration. Pollution prevention activities focus on reducing waste sand, waste
electric arc furnace dust and desulfurization slag, and increasing energy efficiency. Table 5-159
presents water conservation and pollution prevention alternatives for this industry.
Table 5-159. Water Conservation and Pollution Prevention Alternatives for the Metal
Molding and Casting Category
Processes To
Reduce
Water Conservation/Pollution Prevention Alternatives
Solid Waste
or
Air Pollution
Use vacuum molding, which holds die sand hi the shape of the pattern after pattern is
removed. No sliakeout equipment required and almost no waste sand is generated.
Reclaim and reuse waste sand and metal through waste segregation, screening, dry
scrubbing, or thermal reclamation.
Improve furnace efficiency.
Install induction furnaces, which are 75-80% energy efficient and emit 75% less dust and
fumes.
Minimize metal melting by reducing excess melted metal.
Use alternative furnace fuels (e.g., natural gas, lower grade/low sulfur or low nitrogen
fuel-oil).
Maintain furnaces properly to reduce air emissions.
Recycle electric arc furnace (EAF) dust to original process or reuse outside original
process.
Use charge material containing lower concentrations of lead, zinc, and cadmium (e.g.,
charge modification program to develop reliable sources of high-grade scrap metal).
Minimize hazardous desulfurizing slag (e.g., alternative desulfurization agents).
Water Uses
and/or
Water Pollution
Reduce phenols by substituting synthetic oils or water-based materials, segregating waste
streams at point of generation.
Use cooling water recycling systems.
Optimize deburring operations to minimize total suspended solids.
Use fewer additives, such as biocides, or additives containing no VOCs or HAPs.
Use alternative die lubricants.
Source: OECA Sector Notebook: Profile of the Metal Casting Industry, 1998.
5.5.7.5
Industry Trends
As shown in Table 5-160, U.S. Economic Census data indicate an overall increase
in the number of metal molding facilities between 1992 and 1997. Value of goods shipped has
also increased by 15 percent or more for bituminous coal during the same time period. As
shown in Table 5-161, advance comparative statistics for 1997 to 2002 for NAICS code 331
(industries that smelt and/or refine metals using electrometallurgical processes) show a 17.6-
percent increase in the number of establishments and a 19-percent decrease in the value of
shipments (not adjusted for inflation).
5-195
-------
Section 5 - Existing Industry Review
Table 5-160. 1992 and 1997 Census Data
SIC
Code
3321
3322
3324
3325
3364
3365
3366
3369
Industry Sector
Gray and Ductile Iron Foundries
Malleable Iron Foundries
Steel Investment Foundries
Steel Foundries. Not Elsewhere
Classified
Nonferrous Die-Casting, Except
Aluminum
Aluminum foundries
Copper Foundries
Nonferrous Foundries, Except
Aluminum & Copper
Number of Establishments
1997
669
28
159
288
279
626
312
141
1992
709
24
152
287
263
591
329
119
Percent
Change
-6
17
5
0.3
6
6
-5
19
Value of Goods Shipped
(billions of dollars)
1997
11.9
0.35
2.3
2.9
2.0
3.9
0.86
0.96
1992
7.7
0.25
1.7
2.1
1.0
1.9
0.74
0.46
Percent
Change
53
42
35
40
101
101
15
109
Source: 1997 U.S. Economic Census.
Table 5-161. 1997 and 2002 Census Data
NAICS
Code
331
Industry
Segment
Primary Metal
Manufacturing
Number of Establishments
2002
5,952
1997
5,059
Percent
Change
17.6
Value of Goods Shipped
(billions of dollars)
2002
136
1997
168
Percent
Change
-19
Source: 2002 U.S. Economic Census.
5.5.7.6
Stakeholder and EPA Regional Issues
This subsection discusses stakeholder and EPA Regional issues. EPA primarily
received input from stakeholders prior to the Preliminary Effluent Guidelines Plan. EPA
received one comment on the Preliminary Plan pertaining to the metal molding and casting
industry. This commenter expressed concern that the final regulation and technical development
document had inconsistencies. However, the commenter did not provide any specifics on these
inconsistencies.
5-196
-------
Section 5 - Existing Industry Review
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the 2004 annual review provided input
on the Metal Molding and Casting category. Their suggestions are summarized below.
Comments on the Draft Strategy (Section 2.2 of the "Factor 4 Analysis:
Implementation and Efficiency Considerations - Status of Screening Level Review Phase "
(Edocket OW-2003-0074-0329))
A stakeholder asserts that the effluent guidelines should be reevaluated to address
the discrepancy of metals limits between this category and those in the Metal Finishing ELGS.
The ELGS for the Metal Molding and Casting category are production-based, and when the
appropriate values are applied and calculations performed to convert these into equivalent
concentration limits, the resulting discharge limits for metals are orders of magnitude lower than
the metal finishing ELGS. This suggests there is a problem either with the metal finishing
regulations (which EPA recently reviewed during development of the MP&M regulation
development) or ELGS for the Metal Molding and Casting category.
Previous Suggestions (Section 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
Specific activities of concern identified by responders include fastener
manufacturing, job shop galvanizers, and jewelry manufacturing. Phenol was identified as a
pollutant of concern.
Permitting Authorities (Section 2.5 of the "Factor 4 Analysis: Implementation
and Efficiency Considerations - Status of Screening Level Review Phase " (Edocket OW-2003-
0074-0329))
EPA permitting authorities have found cyanide to be an issue when molten slag is
allowed to come into contact with the quench water in the quenching process. EPA permitting
authorities also identified the following concerns with implementing the guidelines for the
aluminum die casters subcategory: 1) the ELGS are confusing (e.g., the applicability of the
regulations cover only part of the casting process); 2) the ELGS should allow permit writers to
determine additional fundamentally different factors (PDF); and 3) permit writers have problems
calculating limits attainable by permitted facilities using the formulas provided in the guidelines
(specifically for total phenols and oil and grease). Expanding on this last item, EPA permitting
authorities explain that the building-block method for determining allowances, when applied to
small facilities, results in a low limit on total phenols. EPA permitting authorities assert that it is
difficult to find a technology to meet these low limits, resulting in a number of facilities being
unable to meet a limit that was neither reasonable nor necessary to protect the POTW. Although
protecting POTWs is not one of the 304(m) evaluation criteria, EPA permitting authorities note
that the resulting noncompliance forces control authorities to choose between escalating
5-197
-------
Section 5 - Existing Industry Review
enforcement actions for a relatively minor infraction or ignoring the violation if they are
convinced that all reasonable efforts have been made to meet the limits. Possible solutions to the
problem could include: 1) using production as a limiting factor to provide relief to smaller
facilities, and 2) allowing control authorities to apply concentration-based standards, similar to
the approach used in Porcelain Enameling (40 CFR Part 466). Permitting authorities also
asserted that EPA removed the phenol limits from the pretreatment standards of the Organic
Chemicals, Plastics, and Synthetic Fibers effluent guidelines (40 CFR Part 414) after finding that
phenol did not pass through POTWs (i.e., indirect dischargers do not need to meet stringent
phenol limits).
AMSA andASIWPCA (Section 2.6 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
ASIWPC A stakeholders identified several effluent guidelines that are out of date
relative to available technology, including those for metal molding and casting.
Additional Concerns Identified Post-Proposal
In addition, in an e-mail collection of suggestions, four state pretreatment
coordinators discussed implementation and efficiency issues. One coordinator noted that having
die casting limits based on production results in a lot of small shops often being out of
compliance because they can't meet the limits at their low production volumes. A second
coordinator reported that die casters have constant problems with the total phenols and oil and
grease limits. During follow-up discussions, an additional pretreatment coordinator explained
that the problem usually occurs in small facilities where their only allowance for phenol came
from the tiny amount provided for die casting, which is insufficient to account for background
levels of phenol.
Another coordinator noted that casting cleaning operations (listed in the
aluminum casting and ferrous casting subcategories) does not occur and cannot occur given the
definitions and conditions of the regulation. All subcategories have a casting quench operation,
but the definitions make it clear that the standard applies only to precooling operations. Because
of the way the definitions are written at 464.02 (a) "Aluminum Casting" and 464.02 (b) "Ferrous
Casting," cleaning operations are not captured by the regulation. A simple solution is to correct
the general definitions, as suggested below. Another option is to eliminate the allocations for
casting cleaning from these subcategories since it applies to an operation that cannot exist under
this regulation the way it is written.
For the aluminum casting definition, insert the underlined text "Processing
operations following the cooling of castings not covered under aluminum forming, except for
grinding scrubber operations and casting cleaning operations, which are covered here, are
covered under electroplating and metal finishing point source categories (40 CFR Part 413 &
433)." For the ferrous casting definition, insert the underlined text "Except for grinding scrubber
5-198
-------
Section 5 - Existing Industry Review
operations and casting cleaning operations which are covered here, processing operations
following the cooling of castings are covered under electroplating and metal finishing point
source categories (40 CFR Part 413 & 433)."
A fourth coordinator noted that in the aluminum forming subcategory, production
standards result in extremely low permit limits. Whenever production changes by as little as 20
percent, permit limits have to be changed accordingly. Concentration-based standards would
save the endless modification and the associated administrative burden. It also seems
inconsistent to require metal finishers to discharge a pollutant at the ppm level while the
production based industry is required to meet a ppb level.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. Some stakeholders noted that metal molding and
casting limitations are often more stringent than metal finishing limitations. EPA notes that
limitations and standards for each industrial category consider the best available technology
economically achievable for a particular subcategory of a particular industry. As a result of
differences in wastewater characteristics, treatment and pollution prevention technologies, and
economic considerations, limitations vary from one industrial category to the next. In the event
that stakeholders provide additional data and supporting information, on these or any of the
issues identified above, EPA will reevaluate them at that time. EPA notes that in some cases
commenters raised implementation issues rather than guideline revision issues. EPA will
continue to consider implementation issues raised by these stakeholders.
5.5.7.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from metal
molding and casting facilities are low relative to other industrial categories. In addition,
generally, a few facilities contribute the bulk of the TWPE estimates from both TRI and PCS.
Stakeholders and EPA staff identified various issues associated with discharges
from metal molding and casting facilities. The information in the docket on the 2004 annual
review does not at this time support the concerns raised. In the event that stakeholders provide
additional data and supporting information during subsequent review cycles, EPA will reevaluate
them at that time.
5.5.8 Mineral Mining and Processing (Part 436)
During the screening-level review phase of the 2004 annual review, mineral
mining and processing was one of eight industrial categories identified solely through Factor 4
concerns. Issues driving the concerns include: 1) pollutants not covered by the guidelines
(specifically TSS), and 2) consistent application of the guidelines by permit writers.
5-199
-------
Section 5 - Existing Industry Review
5.5.8.1 Industry Description
The Mineral Mining Point Source Category is regulated at 40 CFR Part 436. This
point source category includes facilities reporting under two SIC industry groups: 14 - Mining
and Quarrying of Nonmetallic Minerals, except fuels, and 32 - Stone Clay, Glass, and Concrete
Products. See Attachment C for the applicability and regulatory background. Specifically, the
category includes SIC codes 1422 (Crushed and broken limestone), 1442 (Construction sand and
gravel), 1459 (Clay, ceramic, and refractory minerals not elsewhere classified), 1475 (Phosphate
rock), 1479 (Chemical and fertilizer mineral mining not elsewhere classified), 1481 (Nonmetallic
minerals services, except fuels), and SIC 3295 (Minerals and Earths, Ground or Otherwise
Treated). All of these SIC codes are represented by dischargers reporting to the PCS but not
TRI. It also includes SIC code 3275 (Gypsum Products), which was reported in PCS and was
the only SIC code represented in the TRI. No specific subcategories were identified during the
Factor 4 analysis; however, two subcategories were discussed in comments on the Preliminary
Plan: Crushed Stone Subcategory B (40 CFR Part 436.20), and Construction Sand and Gravel
Subcategory C (40 CFR Part 436.30), covered by SIC 1442.
• SIC code 1411 - Dimension Stone. Establishments primarily engaged in
mining or quarrying dimension stone. Also included are establishments
engaged in producing rough blocks and slabs. Establishments primarily
engaged in mining dimension soapstone or in mining or quarrying and
shaping grindstones, pulpstones, millstones, burrstones, and sharpening
stones are classified in SIC code 1499. Establishments primarily engaged
in dressing (shaping, polishing, or otherwise finishing) blocks and slabs
are classified in Manufacturing, SIC code 3281. Nepheline syenite mining
operations are classified in SIC code 1459.
• SIC code 1422 - Crushed and Broken Limestone. Establishments
primarily engaged in mining or quarrying crushed and broken limestone,
including related rocks, such as dolomite, cement rock, marl, travertine,
and calcareous tufa. Also included are establishments primarily engaged
in the grinding or pulverizing of limestone, but establishments primarily
engaged in producing lime are classified in Manufacturing, SIC code
3274.
• SIC code 1423 - Crushed and Broken Granite. Establishments primarily
engaged in mining or quarrying crushed and broken granite, including
related rocks, such as gneiss, syenite, and diorite.
• SIC code 1429 - Crushed and Broken Stone, Not Elsewhere Classified.
Establishments primarily engaged in mining or quarrying crushed and
broken stone, not elsewhere classified.
5-200
-------
Section 5 - Existing Industry Review
SIC code 1442 - Construction Sand and Gravel. Establishments primarily
engaged in operating sand and gravel pits and dredges, and in washing,
screening, or otherwise preparing sand and gravel for construction uses.
SIC code 1446 - Industrial Sand. Establishments primarily engaged in
operating sand pits and dredges, and in washing, screening, and otherwise
preparing sand for uses other than construction, such as glassmaking,
molding, and abrasives.
SIC code 1455 - Kaolin and Ball Clay. Establishments primarily engaged
in mining, milling, or otherwise preparing kaolin or ball clay, including
china clay, paper clay, and slip clay.
SIC code 1459 - Clay, Ceramic, and Refractory Minerals, Not Elsewhere
Classified. Establishments primarily engaged in mining, milling, or
otherwise preparing clay, ceramic, or refractory minerals, not elsewhere
classified.
SIC code 1474 -Potash, Soda, and Bor ate Minerals. Establishments
primarily engaged in mining, milling, or otherwise preparing natural
potassium, sodium, or boron compounds. Establishments primarily
engaged in mining common salt are classified in SIC code 1479.
SIC code 1475 - Phosphate Rock. Establishments primarily engaged in
mining, milling, drying, calcining, sintering, or otherwise preparing
phosphate rock, including apatite. Establishments primarily engaged in the
production of phosphoric acid, super-phosphates, or other manufactured
phosphate compounds or chemicals are classified in manufacturing, SIC
major group 28.
SIC code 1479 - Chemical and Fertilizer Mineral Mining, Not Elsewhere
Classified. Establishments primarily engaged in mining, milling, or
otherwise preparing chemical or fertilizer mineral raw materials, not
elsewhere classified. Establishments primarily engaged in milling,
grinding, or otherwise preparing barite not in conjunction with mining or
quarry operations are classified in Manufacturing, SIC code 3295; similar
establishments preparing other minerals of this industry are included here.
Establishments primarily engaged in producing salt by evaporation of sea
water or brine are classified in Manufacturing, SIC code 2899.
SIC code 1481 - Nonmetallic Minerals Services, Except Fuels.
Establishments primarily engaged in the removal of overburden, strip
mining, and other services for nonmetallic minerals, except fuels, for
others on a contract or fee basis. Establishments primarily engaged in
5-201
-------
Section 5 - Existing Industry Review
performing hauling services are classified in Division E, Transportation
and Public Utilities.
• SIC code 1499 - Miscellaneous Nonmetallic Minerals, Except Fuels.
Establishments primarily engaged in mining, quarrying, milling, or
otherwise preparing nonmetallic minerals, except fuels. This industry
includes the shaping of natural abrasive stones at the quarry.
Establishments primarily engaged in the production of blast, grinding, or
polishing sand are classified in SIC code 1446, and those calcining
gypsum are classified in Manufacturing, SIC code 3275.
• SIC code 3275 - Gypsum Products. Establishments primarily engaged in
manufacturing plaster, plasterboard, and other products composed wholly
or chiefly of gypsum, except articles of plaster of paris and papier-mache.
• SIC code 3295 -Minerals and Earths, Ground or Otherwise Treated.
Establishments operating without a mine or quarry and primarily engaged
in crushing, grinding, pulverizing, or otherwise preparing clay, ceramic,
and refractory minerals; barite; and miscellaneous nonmetallic minerals,
except fuels. These minerals are the crude products mined by
establishments of Industry Groups 145 and 149, and by those of SIC code
1479 mining barite. Also included are establishments primarily crushing
slag and preparing roofing granules. The beneficiation or preparation of
other minerals and metallic ores, and the cleaning and grading of coal, are
classified in Division B, Mining, whether or not the operation is
associated with a mine.
Facility Counts
EPA obtained information on the number of facilities in the Mineral Mining Point
Source Category from three sources: the 1997 U.S. Economic Census, TRIReleases2000, and
PCSLoads2000. TRI includes facilities reporting discharges to any media. In contrast, PCS
includes only facilities that are permitted for discharge to surface waters. Table 5-162 lists the
number of facilities from these sources.
5-202
-------
Section 5 - Existing Industry Review
Table 5-162. Number of Facilities
SIC
Code1
1411
1422
1423
1429
1442
1446
1455
1459
1474
1475
1479
1481
1499
3275
3295
1997
Economic
Census
178
1435
290
459
2367
140
35
132
27
20
45
172
216
208
388
PCS
Total
8
173
14
39
139
17
7
23
2
22
9
1
34
11
31
Major
Dischargers
0
6
0
0
4
0
0
3
0
18
3
1
0
0
0
Minor
Dischargers
8
167
14
39
135
17
7
20
2
4
6
0
34
11
31
TRI
Total
0
0
0
0
1
0
0
0
0
0
0
0
0
18
50
No Reported
Discharge
0
0
0
1
1
0
0
0
0
0
0
0
0
17
44
Direct
Discharge
0
0
0
0
0
0
0
0
0
0
0
0
0
1
3
Indirect
Discharge
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
Both Direct
and Indirect
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
Source: PCSLoads2000, TRIReleases2000.
'Facilities in SIC code 14. (Mining and Quarrying of Nonmetallic Minerals Except Fuels) are not required to report to TRI. Facilities in SIC
codes 3275 and 3295 that meet the employee requirements and chemical use thresholds are required to report.
Of the 42 reporting facilities, 48 percent (20) are located in Florida. Another 17
percent (7) are located in Michigan. The rest are located in Alabama, Arizona, Georgia,
Missouri, North Carolina, South Carolina, New York, Ohio and Wisconsin.
5.5.8.2
Regulatory Background
The current ELGS for the Mineral Point Source Category, 40 CFR Part 436,
contain 38 subcategories (Subparts A - AL). Interim final regulations were published on
October 16, 1975 for Subparts E, F, G, J, K, L, N, O, S, V, W, X, Y, Z, AF, and AL. Proposed
regulations were issued June 10, 1976 for Subparts B, C, D, E, F, G, J, K, L, M, N, O, R, S, V,
W, X, Y, Z, AF, and AL. The effluent limitations for Subparts B, C, D, and R were promulgated
July 1979. National amendments were made to the effluent guidelines on December 28, 1979.
Limitations for BAT are the same as for BPT for all subcategories except
industrial sand FIF floatation; rock salt; sulphur (frasch process, salt dome operations); feldspar
flotation; and talc (heavy media and flotation). Limitations for NSPS are the same as for BAT.
EPA established no requirements for PSES or PSNS.
The following processes are required to achieve no discharge of process-
generated wastewater pollutants to navigable waters:
5-203
-------
Section 5 - Existing Industry Review
• A. Dimension Stone;
• B. Crushed Stone (dry process only);
• C. Construction Sand and Gravel (dry process only);
• D. Industrial Sand (dry process only);
• E. Gypsum;
• F. Asphaltic Minerals:
— Bituminous limestone,
— Oil impregnated diatomite, and
— Gilsonite;
• G. Asbestos and Wollastonite;
• H. Lightweight Aggregates:
— Perlite,
— Pumice, and
— Vermiculite;
• I. Mica and Sericite:
— Mica and sericite (dry process),
— Mica (wet process, grinding process), and
— Mica (wet beneficiation process);
• J. Barite (dry process only);
• K. Fluorspar (heavy media separation process only);
• M. Borax;
• N. Potash;
• O. Sodium Sulfate;
• P. Trona;
• S. Sulfur (anhydrite only);
• T. Mineral Pigments;
• V. Bentonite;
• W. Magnesite;
• X. Diatomite;
Y.Jade;
• Z. Novaculite;
AA. Fire Clay;
AB. Fuller's Earth (montmorillonite and attapulgite);
AC. Kyanite;
AD. Shale and Common Clay;
AE. Aplite;
AF. Tripoli;
AG. Kaolin (general purpose grade);
AH. Ball Clay;
AI. Feldspar (nonflotation processes); and
AJ. Talc Group (dry and washing processes).
The concentration-based limitations presented in Table 5-163 apply to discharges
from wet processes, flotation processes, mine dewatering, and dredging for the crushed stone,
5-204
-------
Section 5 - Existing Industry Review
construction sand and gravel, and industrial sand subcategories of 40 CFR Part 436. Dry
processes for these subcategories are required to achieve no discharge of process wastewater.
Table 5-164 presents concentration-based limits for other subcategories of Part 436.
Table 5-163. Effluent Guidelines for Crushed Stone, Construction Sand and Gravel, and
Industrial Sand Subcategories of Part 436
Parameter
TSS1
pH
BPT 30-day Averages (mg/L)
25
within range of 6 to 9
BPT Daily Maximum (mg/L)
45
within range of 6 to 9
'BPT limits for industrial sand HF flotation for TSS are 0.023kg/kkg (monthly avg) and 0.046 kg/kkg (daily
maximum), and 0.003 kg/kkg (monthly avg) and 0.006 kg/kkg (daily maximum) for fluoride. BAT requires no
discharge.
Table 5-164. Effluent Guidelines for Other Subcategories of Part 4361
Parameter
TSS
Total iron2
Sulfide3
Zinc4
BPT 30-day Averages (mg/L)
10 to 50
1 to 3.5
Ito5
0.25
BPT Daily Maximum (mg/L)
20 to 100
2 to 7
2 to 10
0.50
'Subcategories include barite mine dewatering, phosphate rock, sulfur (frasch, salt dome operations), fire clay acid
mine drainage, kaoline (wet process), talc (mine dewatering), and graphite.
2Total iron limits for barite mine dewatering, fire clay acid mine drainage, and graphite only.
3Sulfide limits for sulfur (frasch, salt dome operations) only. BAT limits for sulfur are 1 to 2 mg/L (monthly avg)
and 2 to 4 mg/L (daily maximum).
4Zinc limits for kaolin wet processing only.
The limitations guidelines in Table 5-165 are normalized on the basis of metric ton (kkg) of raw
material.
5-205
-------
Section 5 - Existing Industry Review
Table 5-165. Normalized Effluent Guidelines for Subcategories of Part 4361
Parameter
TSS"
Fluoride"
Dissolved fluoride2'
BPT 30-day Averages (kg/kkg)
0.02 to 1.5
0.175
0.2
BPT Daily Maximum (kg/kkg)
0.04 to 3.0
0.35
0.4
1 Subcategories include feldspar floatation: talc, steatite, soapstone, and pyrophyllite (heavy media separation and
flotation); mica wet beneficiation process (ceramic grade clay by-product): fluorspar flotation: and rock salt.
2BAT limits for TSS for talc (heavy media and flotation) are 0.3 kg/kkg (monthly avg) and 0.6 kg/kkg (daily
maximum).
3BAT limits for TSS for rock salt are 0.002 kg/kkg (monthly avg) and 0.004 kg/kkg (daily maximum).
"Fluoride limits for feldspar flotation only. BAT limits for fluoride are 0.13 kg/kkg (monthly avg) and 0.26 (daily
maximum).
'Dissolved fluoride limits for fluorspar flotation only.
5.5.8.3
Wastewater Characteristics and Pollutant Sources
Most major facilities reporting to PCS report discharge pipe flow rates. Table
5-166 presents the total annual flow (in millions of gallons) for 2000, median annual discharge
flow, and the range of annual flows for mineral mining facilities. Facilities not reporting a flow
were not included in the median calculation. Data presented in Table 5-166 are based on major
dischargers reporting to PCS for 2000.
Table 5-166. Wastewater Flows
SIC
Code
1422
1442
1459
1475
1479
1481
Number of Major
Facilities Reporting
Nonzero Flows
5
3
3
15
2
1
Median Facility Flow
In 2000 (MGY)
2,644.20
1,334.96
241.49
429.20
8,845.50
4.802.40
Range of Facility
Flows In 2000 (MGY)
913-8499
2-3291
100-950
3-3072
8,044-9,647
NA
Total Flow In 2000
(MGY)
19,175.60
4,628.54
1,291.73
10,839.13
17,691.00
4,802.40
Source: EPA, PCSLoads2000.
NA - No range was calculated because only one facility reported a nonzero flow.
Wastewater quantities and content vary day to day, and are affected by rainfall
and exposure to surface and underground water. Composition of the wastewater depends on the
mineral being mined and the raw materials required for processing. The most important
pollutant parameter for this industry is suspended solids.
5-206
-------
Section 5 - Existing Industry Review
Many facilities achieve zero discharge by recycling wastewater through the
process. Most facilities use settling ponds to control TSS. Aside from pH adjustment, chemical
treatment is not common for this industry.
There are three major classifications of wastewater from mining operations:
• Mine dewatering;
• Process water; and
• Rain water runoff.
Process wastewater includes water used to transport minerals from one operation to another,
water used in separation processes such as flotation and heavy media separation, air pollution
control, and dust control. The pollutants of concern for mineral mining wastewater are
suspended and dissolved solids. Table 5-167 presents sources of wastewater for each step of the
mining process.
Table 5-167. Process Sources of Wastewater
Mining Process
Mineral Extraction
Mineral Transportation
Mineral Processing
Wastewater
Surface runoff, groundwater seepage
Transport water
Transport water, wash water, dust control water,
media separation water, flotation water, solution
water, floor wash down
classification water, heavy
water, air emissions control
Source: Sector Notebook for Non-Fuel, Non-Metal Mining, 1995.
Pollutants Discharged
Table 5-156 lists the pollutants reported to PCS for mineral mining facilities that
reported discharges to PCS by major dischargers in 2000. In addition, Table 5-168 lists the
pollutants reported to TRI as discharged directly or for mineral mining facilities that reported to
TRI for 2000. This table presents the number of facilities that reported each chemical and the
total pounds of chemical discharged to surface waters. Indirect discharging facilities reported
transfers to POTWs. Using average POTW removal efficiencies, EPA estimated the amount of
pollutant discharged to surface water (see DCN 00618, Evaluation of RSEIModel Runs., for
more information). Therefore, the TWPE estimates in this table have been adjusted to account
for POTW treatment.
5-207
-------
Section 5 - Existing Industry Review
Table 5-168. Pollutant Discharges Reported to PCS and TRI
Pollutant Category and Primary Pollutants
All Pollutants
Nonconventionals
Total Dissolved Solids
Total Fluoride
Barium
Nitrogen, Nitrate Total (As N)
Conventional s
Total Suspended Solids
Oil and Grease
Priority
Lead
Zinc
Copper
Chromium
PCS (Pounds)
95,892,593
91,767,088
67,076,047
759,269
0
32
4,116,305
4,082,539
33.766
9,200
200
8,764
100
0
PCS
TWPE
29,402
28,215
0
26,574
0
0
0
99%
1%
1,187
449
410
63
0
TRI
(Pounds)
479,076
477,573
0
0
17,793
443,398
0
-
-
1,503
184
312
750
257
TRI
TWPE
1,137
109
0
0
35
27
0
-
-
1,029
412
15
470
132
Source: EPA, PCSLoads2000 and TRIReleases2000.
Relative to other industries evaluated, TWPE discharges reported in PCS and TRI
are low. Generally, a few facilities contribute the bulk of the TWPE estimates from both TRI
and PCS. For comparison purposes, Tables 5-169 and 5-170 present the TWPE for mineral
mining along with the industries reporting the highest discharges in each database. Table 5-169
presents the information reported to PCS and Table 5-170 presents the information reported to
TRI. For a description of the derivation of the values in these tables, see the memorandum in the
public docket titled Description and Results of EPA Methodology to Synthesize Screening Level
Results for the Effluent Guidelines Program Plan for 2004, which is available through Edocket
at document number OW-2003-0074-0391.
Table 5-169. Mineral Mining TWPE Reported to PCS Compared to Industries Reporting
Highest Discharges
40CFR
Part
423
414
422
415
421
Point Source Category
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Phosphate Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
PCS-Reported TWPE
2,933,209
1,805,928
1,095,321
853,568
434,925
PCS Rank
1
2
3
4
5
5-208
-------
Section 5 - Existing Industry Review
Table 5-169 (Continued)
40CFR
Part
440
410
419
455
418
436
Point Source Category
Ore Mining and Dressing
Textile Mills
Petroleum Refining
Pesticide Chemicals Manufacturing, Formulating
Fertilizer Manufacturing
Mineral Mining
PCS-Reported TWPE
383,560
296,601
198,251
178,977
116,464
29,402
PCS Rank
6
7
8
9
10
15
Source: EPA. PCSLoads2000.
Table 5-170. Mineral Mining TWPE Reported to TRI Compared to Industries
Reporting Highest Discharges
40CFR
Part
414
423
421
430
415
429
419
455
428
463
436
Point Source Category
Organic Chemicals, Plastics and Synthetic Fibers
Steam Electric Power Generation
Nonferrous Metals Manufacturing
Pulp, Paper and Paperboard (Phase II)
Inorganic Chemicals Manufacturing
Timber Products Processing
Petroleum Refining
Pesticide Chemicals Manufacturing. Formulating
Rubber Manufacturing
Plastic Molding and Forming
Mineral Mining
TRI-Reported TWPE
7,303,782
1,856,645
978,450
628,785
624,250
404,926
385,347
324,393
166,343
106,189
1,137
TRI Rank
1
2
3
4
5
6
7
8
9
10
33
Source: EPA, TRIReleases2000.
5.5.8.4 Treatment Technology and Pollution Prevention
Solids Removal
The predominant treatment technique for solids removal is settling ponds. Other
treatment technologies that may be used include flocculation, filters, clarifiers, and thickeners.
5-209
-------
Section 5 - Existing Industry Review
Neutralization/Chemical Precipitation
This treatment technology is often used to remove dissolved solids such as
fluoride, iron, sulfides, and zinc.
Recycle
Facilities recycle settled wastewater to the process.
Pollution Prevention
Table 5-171 lists water conservation and pollution prevention alternatives for this
industry.
Table 5-171. Water Conservation and Pollution Prevention Alternatives
Process
Surface runoff
Dust control
Groundwater seepage
Water Conservation/Pollution Prevention Alternatives
Use diversion systems to channel runoff away from exposed mine pits and waste
dumps.
Reuse contaminated wastewater for dust elimination in the mineral extraction
process.
Use subsurface drainage systems and barriers to collect or deflect groundwater prior
to contact with exposed mine pits.
Source: Sector Notebook for Non-Fuel, Non-Metal Mining, 1995.
5.5.8.5 Industry Trends
U.S. Economic Census data presented in Table 5-172 illustrates industry trends in
number of establishments and value of goods shipped between 1992 and 1997. Depending on
the sector, changes in the number of establishments range from a 36-percent increase to a
36-percent decrease. The change in the value of good shipped also varied by sector, and in
general increased.
NAICS code 212 covers mining (except oil and gas) of metallic minerals and
nonmetallic minerals, including coal. As shown in Table 5-173, advance comparative statistics
for 1997 to 2002 for NAICS code 212 show a 2-percent decrease in the number of
establishments and a 6-percent increase in the value of shipments (not adjusted for inflation).
5-210
-------
Section 5 - Existing Industry Review
Table 5-172. 1992 and 1997 Census Data
SIC
Code
1411
1422
1423
1429
1442
1446
1455
1459
1474
1475
1479
1481
1499
3275
Industry Segment
Dimension Stone
Crushed and Broken Limestone
Crushed and Broken Granite
Crushed and Broken Stone, NEC,
Construction Sand and Gravel
Industrial Sand
Kaolin and Ball Clay
Clay, Ceramic, and Refractory
Minerals. NEC.
Potash, Soda, and Borate
Minerals
Phosphate Rock
Chemical and Fertilizer Mineral
Mining, NEC.
Nonmetallic Minerals Services,
Except Fuels
Misc. Nonmetallic Minerals,
Except Fuels
Gypsum Products
Number of Establishments
1997
178
1,435
290
459
2.367
140
35
132
27
20
45
172
216
208
1992
NA
1,322
247
428
2.430
149
NA
148
NA
NA
70
NA
270
153
Percent
Change
NA
8.5
17.4
7.2
-2.6
-6.0
NA
-10.8
NA
NA
-35.7
NA
-20.0
35.9
Value of Goods Shipped
(billions of dollars)
1997
0.13
4.5
1.5
1.3
3.5
0.51
0.94
0.619
1.7
1.0
0.36
0.191
0.632
4.4
1992
0.10
3.2
0.90
0.93
2.8
0.41
0.78
0.620
1.5
1.2
0.42
0.189
0.596
2.1
Percent
Change
27.0
40.7
69.0
35.5
26.2
24.5
20.3
0.1
12.4
-14.5
-14.5
1.1
6.0
109.0
Source: 1997 U.S. Economic Census.
NA - Comparable data were not available.
Table 5-173. 1997 and 2002 Census Data
NAICS
Code
212
Industry Segment
Mining (except oil
& gas)
Number of Establishments
2002
7,173
1997
7,348
Percent
Change
-2
Value of Goods Shipped
(billions of dollars)
2002
54
1997
51
Percent
Change
6
Source: 2002 U.S. Economic Census.
5-211
-------
Section 5 - Existing Industry Review
5.5.8.6 Stakeholder and EPA Regional Issues
This section discusses stakeholder and EPA Regional issues. EPA primarily
received input from stakeholders prior to the Preliminary Effluent Guidelines Plan. In addition,
EPA received comments on the Preliminary Plan asserting that the existing ELGS are adequate.
Concerns Identified Pre-Proposal
Several groups surveyed by the Agency in the 2004 annual review provided input
on the Mineral Mining and Processing category. Each group and their suggestions are
summarized below.
Previous Suggestions (Sec. 2.4 of the "Factor 4 Analysis: Implementation and
Efficiency Considerations - Status of Screening Level Review Phase" (Edocket OW-2003-0074-
0329))
Responders suggested the need for more complete ELGS, including the addition
of TSS limits, and were concerned that the existing guidelines are inconsistently applied.
Concerns Identified in Comments to Proposal
For the crushed stone subcategory and the construction sand and gravel
subcategory, a commenter asserted that the existing effluent guidelines established by the EPA
for the aggregates industry are adequate. The pollutants discharged from aggregate operations
are limited, and no new processes have developed within the aggregates industry over the past
several decades that would increase the amount of pollutants discharged. These conclusions are
supported by the findings of two reports that indicate that the existing guidelines are adequate:
1) the National Stone Association (NSA) April 1993 report, An Analysis of the EPA Effluent
Guidelines and Standards For the Mineral Mining Industrial Category as Related to the
Requirements of the EPA NPDES Storm Water Regulations and 2) U.S. EPA's June 1982 report
from the Office of Water & Waste Management, The Effects of Discharges from Limestone
Quarries on Water Quality and Aquatic Biota.
EPA appreciates all comments and suggestions provided by the stakeholders and
EPA Regional staff. However, as with any comments it receives, EPA cannot address these
suggestions without adequate supporting data. The major issue raised concerned a lack of TSS
limitations. Contrary to this stakeholder's assertion, the effluent guidelines for the Mineral
Minding category contain TSS limits for 3 of the 21 subcategories. For 16 of the remaining 18
subcategories, limits are set at no discharge of process wastewater with the exception of
stormwater and certain cases (see Part 436). The sand and gravel subcategory and the industrial
sand category have limits only for pH. In the event that stakeholders provide additional data and
supporting information on these or any of the issues identified above, EPA will reevaluate them
at that time.
5-212
-------
Section 5 - Existing Industry Review
5.5.8.7 Conclusions
Based on information reported to TRI and PCS, toxic discharges from mineral
mining facilities are low relative to other industrial categories. In addition, generally only a few
facilities contribute most of the TWPE estimates in both TRI and PCS.
Stakeholders and EPA staff identified various issues associated with discharges
from mineral mining facilities. The information in the docket at this time does not support the
concerns raised. In the event that stakeholders provide additional data and supporting
information during subsequent review cycles, EPA will reevaluate them at that time.
5.5.9 Oil and Gas Extraction (40 CFR Part 435)
5.5.9.1 Industry Description
The Oil and Gas Extraction Point Source Category (40 CFR Part 435) comprises
facilities in the following SIC codes:
• SIC code 1311 - Crude Petroleum and Natural Gas. Establishments
primarily engaged in operating oil and gas field properties. Such activities
may include exploration for crude petroleum and natural gas; drilling,
completing, and equipping wells; operation of separators, emulsion
breakers, desilting equipment, and field gathering lines for crude
petroleum; and all other activities in the preparation of oil and gas up to
the point of shipment from the producing property. This industry includes
the production of oil through mining and extraction of oil from oil shale
and oil sand and the production of gas and hydrocarbon liquids through
gasification, liquefaction, and pyrolysis of coal at the mine site. Also
included are establishments that have complete responsibility for
operating oil and gas wells for others on a contract or fee basis.
• SIC code 1381 - Drilling Oil and Gas Wells. Establishments primarily
engaged in drilling wells for oil or gas field operation for others on a
contract or fee basis. This industry includes contractors that specialize in
spudding in, drilling in, redrilling, and directional drilling.
• SIC code 1382 - Oil and Gas Field Exploration. Establishments primarily
engaged in performing geophysical, geological, and other exploration
services for oil and gas on a contract or fee basis.
• SIC code 1389 - Oil and Gas Field Services, Not Elsewhere Classified.
Establishments primarily engaged in performing oil and gas field services,
not elsewhere classified, for others on a contract or fee basis. Services
included are excavating slush pits and cellars; grading and building of
5-213
-------
Section 5 - Existing Industry Review
foundation at well locations; well surveying; running, cutting, and pulling
casings, tubes, and rods; cementing wells; shooting wells; perforating well
casings; acidizing and chemically treating wells; and cleaning out, bailing,
and swabbing wells.
EPA had difficulty in estimating pollutant discharges from this industrial sector.
The oil and gas extraction industry does not report discharges to TRI.6 Additionally, there is
very little information in PCS about discharges from facilities in this industry as most are
regulated under general permits. Overall, discharge monitoring data for this sector is not
incorporated into PCS. Table 5-174 lists the facilities in the oil and gas extraction industry as
reported in PCS and TRI. As shown in Tables 5-175 and 5-176, EPA previously estimated the
number of offshore and coastal oil and gas extraction wells and facilities. These estimates are
significantly higher than the number of facilities that report to either PCS or TRI. At the current
time, EPA is unable to accurately estimate the pollutant loadings associated with this industrial
sector using TRI or PCS.
Table 5-174. Number of Facilities in the Oil and Gas Extraction Category
SIC
Code
1311
1381
1382
1389
Total
1997
Census
7,784
1,628
1,197
6.082
16,691
PCS
Total
178
0
1
11
190
Major
Dischargers
5
0
0
0
5
Minor
Dischargers
173
0
1
11
185
TRI
Total
Reporting
to TRI
1
0
0
0
0
No
Reported
Discharge
1
0
0
0
0
Direct
Discharge
1
0
0
0
0
Indirect
Discharge
0
0
0
0
0
Both direct
and hi direct
0
0
0
0
0
Source: PCSLoads2000 and TRIReleases2000.
6 EPA identified that oil and gas extraction is believed to conduct significant management activities that involve
EPCRA section 313 chemicals. In its proposed rule (June 27, 1996; 61 FR 33592), EPA deferred action on this
industry group "because of questions regarding how particular facilities should be identified." EPA further stated
that ''EPA will be addressing these issues in the future."
5-214
-------
Section 5 - Existing Industry Review
Table 5-175. Number of Wells Drilled Annually, 1995 - 1997, by Geographic Area
Data Source
Shallow Water
(<1,000 ft)
Development
Exploration
Deep Water
(> 1,000 ft)
Development
Exploration
Total
Wells
Gulf of Mexico1
MMS: 1995
1996
1997
Average Annual
RRC
Total Gulf of Mexico
557
617
726
640
5
645
314
348
403
355
3
358
32
42
69
48
NA
48
52
73
104
76
NA
76
975
1,080
1,302
1,119
8
1,127
Offshore California1
MMS: 1995
1996
1997
Average Annual
4
15
14
11
0
0
0
0
15
16
14
15
0
0
0
0
19
31
28
26
Coastal Cook Inlet1
AOGC: 1995
1996
1997
Average Annual
12
5
5
7
0
1
2
1
0
0
0
0
0
0
0
0
12
6
7
8
Source: Technical Development Document for the Final Phase I 316(b) Cooling Water Intake Structure Regulations,
EPA-821-R-01-036, Chapter 6, November 2001.
NA -Not applicable.
MMS - Mineral Management Sendee.
'Gulf of Mexico figures do not include wells within state bay and inlet waters (considered "coastal" under 40 CFR
Part 435) and state offshore waters (0-3 miles from shore). In August 2001, mere were 1 and 23 drilling rigs in bay
and inlet waters of Texas and Louisiana, respectively. There were also 19 and 112 drilling rigs in state offshore
waters (0-3 miles from shore), respectively.
Table 5-176. Identification of Oil and Gas Extraction Fixed Facilities in the Gulf of
Mexico Outer Continental Study
Category
All structures
Abandoned structures
Structures classified as production structures ( i.e., with no
well slots and production equipment)
Structures known not to be in production
Structures with missing information on product type (oil or
gas or both)
Count
5.026
1.403
245
688
309
Remaining Count
5.026
3.623
3,378
2,690
2,381
5-215
-------
Section 5 - Existing Industry Review
Table 5-176 (Continued)
Category
Structures whose drilled well slots are used solely for
injection, disposal, or as a water source
Count
0
Remaining Count
2,381
Source: Technical Development Document for the Final Phase I 316(b) Cooling Water Intake Structure Regulations,
EPA-821-R-01-036. Chapter 6, November 2001.
Note: These figures do not include mobile offshore drilling units that are also subject to the oil and gas effluent
guidelines. Depending on drilling activity, there are approximately between 100 to 200 of these facilities in the Gulf
of Mexico.
Note: Most offshore oil and gas extraction facilities are located in the Gulf of Mexico. Additionally, there are 37 oil
and gas extraction facilities offshore of California and 17 oil and gas extraction facilities in Cook Inlet, Alaska.
EPA will attempt to better quantify discharges from these facilities in future
annual reviews. In particular, EPA will coordinate its annual reviews of effluent guidelines with
the Integrated Compliance Information System (ICIS).7 This new system will integrate data that
is currently located in more than a dozen separate data systems including the PCS database.
ICIS will feature desktop access and real-time entry and retrieval of discharge monitoring data.
The current schedule is to expand core enforcement and compliance data to support a broader
range of CWA programmatic needs by 2006. For example, EPA will add state and federal CWA
permitting and state enforcement data, include data requirements for new programs, and develop
permit application and calculation tools.
5.5.9.2 Regulatory Background
EPA promulgated BPT limitations on April 13, 1979 (44 FR 22069) for this point
source category. The Agency promulgated BAT and BCT limitations and NSPS for the offshore
subcategory (March 4, 1993; 58 FR 12454) and coastal subcategory (December 16, 1996; 61 FR
66086). More recently, EPA established BAT limitations and NSPS for nonaqueous drilling
fluids within the offshore and coastal subcategories (January 22, 2001; 66 FR 6850). These
recent effluent guidelines revisions did not consider any other wastestreams (e.g., produced
waters, drilling cuttings associated with aqueous drilling fluids) in these two subcategories. The
applicability of these effluent guidelines includes:
• SubpartA: Offshore Subcategory. The provisions of this subpart are
applicable to those facilities engaged in field exploration, drilling, well
production, and well treatment in the oil and gas industry that are located
in waters that are seaward of the inner boundary of the territorial seas
("offshore") as defined in section 502(g) of the Clean Water Act.
7 See http://www.epa.gov/oeca/planning/data/modeniization/index.html.
5-216
-------
Section 5 - Existing Industry Review
Subpart C: Onshore Subcategory. The provisions of this subpart are
applicable to those facilities engaged in the production, field exploration,
drilling, well completion, and well treatment in the oil and gas extraction
industry which are located landward of the inner boundary of the
territorial seas as defined in 40 CFRPart 125.1(gg) and which are not
included within Subparts D, E, or F, provided, however, that the
applicability of this subpart to (a) facilities in existence on April 13, 1979
or thereafter engaged in the production, field exploration, drilling, well
completion, and well treatment in the oil and gas extraction industry
which are located on land and which would have been considered
"coastal" as defined under the interim final regulations for this industry
(40 CFR Part 435.41, 41 FR 44942, October 13, 1976) or which are (b)
located in the Santa Maria Basin of California is suspended.
Subpart D: Coastal Subcategory. The provisions of this subpart are
applicable to those facilities engaged in field exploration, drilling, well
production, and well treatment in the oil and gas industry in areas defined
as "coastal." The term "coastal" shall mean:
— Any location in or on a water of the United States landward of the
inner boundary of the territorial seas, or
— Any location landward from the inner boundary of the territorial
seas and bounded on the inland side by the line defined by the
inner boundary of the territorial seas eastward of the point defined
by latitude and longitude boundaries listed in the regulation.
Subpart E: Agricultural and Wildlife Water Use Subcategory. The
provisions of this subpart are applicable to those onshore facilities located
in the continental United States and west of the 98th meridian for which
the produced water has a use in agriculture or wildlife propagation when
discharged into navigable waters. These facilities are engaged in the
production, drilling, well completion, and well treatment in the oil and gas
extraction industry.
Subpart F: Stripper Subcategory. The provisions of this subpart are
applicable to those onshore facilities which produce 10 barrels per well
per calendar day or less of crude oil and which are operating at the
maximum feasible rate of production and in accordance with recognized
conservation practices. These facilities are engaged in production, and
well treatment in the oil and gas extraction industry. There are no effluent
guidelines for facilities in this Subcategory.
5-217
-------
Section 5 - Existing Industry Review
• Subpart G: General Provisions. This subpart is intended to prevent oil
and gas facilities, for which effluent limitations guidelines and standards,
new source performance standards, or pretreatment standards have been
promulgated under this part, from circumventing the effluent limitations
guidelines and standards applicable to those facilities by moving effluent
produced in one subcategory to another subcategory for disposal under
less stringent requirements than intended by this part.
EPA also evaluated whether industrial operations not currently regulated by
existing effluent guidelines should be addressed as a potential additional subcategory under an
existing point source category rather than as a new industrial category. EPA compared the
processes, operations, wastewaters, and pollutants addressed by each existing point source
category to the processes, operations, wastewaters, and pollutants of the potential additional
subcategory. If these processes, operations, wastewaters, and pollutants were sufficiently
similar, EPA included those similar industrial operations not currently regulated by existing
effluent guidelines in the Agency's review of existing effluent guidelines. Due to the similar
processes, operations, and wastewater sources, EPA reviewed coalbed methane (CBM)
extraction as part of the Oil and Gas Extraction Point Source Category review. Section 5.5.9.7
provides more information on this review.
5.5.9.3 Wastewater Characteristics and Pollutant Sources
The primary wastestreams in the oil and gas industry are those associated with
drilling wastes and produced water. Drilling wastes are cuttings (rock fragments) and muds that
are brought to the surface in the drilling fluid. Produced water is the water brought to the surface
with the oil.
Produced water is the largest volume waste produced by oil and gas extraction.
Nearly 8 barrels of produced water are brought to the surface for every one barrel of oil
produced. The pollutants present in produced water vary from region to region and depend of
the depth of the production zone and the age of the well, among other factors. Typically,
produced water contains:
• High concentrations of chloride, sodium, magnesium, potassium;
• Organic compounds such as benzene, naphthalene, toluene, phenanthrene,
and oxygen-demanding compounds;
• Inorganics such as lead, arsenic, barium, antimony, sulfur and zinc; and
• Radionuclides including uranium, radon, and radium.
Table 5-177 lists the processes and associated wastewaters produced in the oil and
gas extraction industry.
5-218
-------
Section 5 - Existing Industry Review
Table 5-177. Process Wastewater Sources for the Oil and Gas Extraction Industry
Process
Well Development
Production
Maintenance
Abandoned Wells, Spills, and
Blowouts
Process Wastewater
Drilling muds, organic acids, alkalis, diesel oil, crankcase oils, acidic
stimulation fluids (hydrochloric and hydrofluoric acid).
Produced water possibly containing heavy metals, radionuchdes, dissolved
solids, oxygen-demanding organic compounds, and high level of salts. Also,
may contain additives including biocides, lubricants, corrosion inhibitors.
Wastewater containing glycol, amines, salts, and untreatable emulsions.
Completion fluid, wastewater containing well-cleaning solvents (detergents
and degreasers), paint, stimulation agents.
Escaping oil and brine.
Source: Profile of the Oil and Gas Extraction Industry, EPA Office of Compliance Sector Notebook Project.
EPA/310-R-99-006. October 2000.
Produced water has been found to be anoxic and contain high concentrations of
oxygen-demanding pollutants. Both soluble and dispersed oil that is contained in produced
water have been found to contribute oxygen-demanding pollutants to receiving waters.8'9 The oil
contained in produced water is also a major source of total organic carbon and chemical oxygen
demand in the discharge (1). Metabolic pathways utilized to degrade hydrocarbons by different
organisms include oxidative phosphorylation or respiration by heterotrophic bacteria, fungi, and
heterotrophic phytoplankton, nitrate reduction by denitrifying bacteria, and sulfate reduction.10
The oil contained in produced water is also a major source of Total Organic Carbon and
Chemical Oxygen Demand (COD) in the discharge (1). Produced water has been found to have
concentrations of COD and BOD in the ranges of 400 to 3,000 mg/L and 370 to 1,920 mg/L,
respectively (1).
5.5.9.4 Pollutants of Concern Identified
As previously mentioned, PCS and TRI contain limited information for this
industrial sector. Table 5-178 presents the available pollutant information from the PCS and TRI
databases for the pollutants composing the top 95 percent of the TWPE for this industry.
8 Stephenson, M, A Survey of Produced Water Studies, Produced Water, Edited by J. Ray and F. Engelhart,
Plenium Press, New York, 1992.
9 Development Document for Interim Final Effluent Limitations Guidelines and Proposed New Source Performance
Standards for the Oil and Gas Extraction Point Source Category, EPA 440/1-76/055-a, United States Environmental
Protection Agency, September, 1976.
10 National Research Council, Oil in the Sea in, Inputs, Fates, and Effects, The National Academies, 2002.
5-219
-------
Section 5 - Existing Industry Review
Table 5-178. Pollutant Discharges Reported to PCS and TRI for 2000
SIC
Code
Pollutant
Number of
Facilities
Reporting
Pollutant
Total Load
(lbs/yr)
Total
TWPE/yr
Percentage of
Total SIC
Code TWPE
Cumulative
Percentage of
Total SIC
Code TWPE
PCS Data
1311
Chlorine.
total residual
PCS Total
4
5
527
597,255
256
267
96%
96%
TRI Data
1311
1311
1311
Benzene
Toluene
Xylene
(mixed
isomers)
TRI Total
1
1
1
1
255
255
255
1,020
4.7
1.4
1.1
7.6
62%
19%
14%
62%
81%
95%
Source: EPA, TRIReleases2000soAPCSLoads2000.
EPA also reviewed the Technical Development Documents for the offshore and
coastal effluent guidelines and the following two documents to identify pollutants of concern for
this category: (1) A White Paper Describing Produced Water from Production of Crude Oil,
Natural Gas, and Coal Bed Methane, U.S. DOE, Veil et al., 2004; and (2) Bioaccum illation in
Marine Organisms: Effect of Contaminants from Oil Well Produced Water, Battelle, J.M. Neff,
2002. EPA will continue to evaluate these and other data sources in the next annual effluent
guidelines review to identify pollutants of concern.
5.5.9.5
Offshore Subcategory (Subpart A)
This subsection discusses available data and technology options for the offshore
subcategory of the oil and gas extraction industry.
Data Summary
Because of the limited PCS data obtained during the screening-level review, EPA
requested offshore oil and gas PCS data from the four EPA Regional offices that issue permits
for the Outer Continental Shelf (e.g., EPA Regions 4, 6, 9, and 10). As a result of this data
collection effort (see DCN 00929, 00930, 00931, 00932, or 00952; section 3.01), only one
facility, Union Oil Company of California (NPDES permit GMG290128), provided data, which
are presented in Table 5-179.
5-220
-------
Section 5 - Existing Industry Review
Table 5-179. 2000 Discharge Monitoring Report (DMR) Data for the Union Oil
Company of California.
Parameter
Produced Water, Radium 226, Total
Produced Water, Radium 228, Total
Produced Water Toxicity 7 Day NOEC
Drilling Fluid Toxicity
Well Fluids, Oil and Grease
Cadmium (Cd). in Barite. Dry Weight
Mercury (Hg) in Barite, Dry Weight
Drilling Fluids, Free Oil
Drilling Fluids, Discharge Rate
Drill Cutting, Free Oil
Deck Drainage, Free Oil
Produced Water. Oil and Grease
Produced Water, Flow
Well Fluids, Free Oil
Sanitary Waste. Solids
Domestic Waste, Solids
Misc. Free Oil in Western GOM
Unit
pci/1
pci/1
ppm
ppm
mg/L
mg/kg
mg/kg
days
barrel/hr
days
days
mg/L
MOD
days
days
days
davs
Reported Measurement Values
Average
360
261
5,391
591,573
16
0.7
0.5
0.03
346
0
0.02
27
0.1
0
0
0
0
Range
0 - 1,540
0 - 1,145
0 - 43.200
0 - 1,000,000
0 - 457
0-2
0- 1
0-1
0 - 875
0
0-1
0 - 109
0-0.8
0
0
0
0
Technology Options
In the 1993 rulemaking for this subcategory, EPA set the BAT limitations and
NSPS for produced water [oil and grease limits for produced water at 29 mg/L (maximum
average of daily values for one month) and 42 mg/L (daily max)] based on improved operating
performance of gas flotation technology. At the time it promulgated these ELGs, EPA rejected
setting BAT limitations and NSPS for produced water based filtration systems as these
technologies were still under development and not in widespread use.
However, new technologies, including filtration systems, are now available for
produced water treatment, in which produced waters are treated by a secondary treatment
process before final discharge overboard. More stringent regulation of oil and gas extractions
wastes (including produced water) in other countries has led to the development of many
5-221
-------
Section 5 - Existing Industry Review
advances in cuttings and produced water treatment technologies and management options. For
example, the Norwegian sector of the North Sea is moving towards "zero discharge" of harmful
materials.
This subsection summarizes preliminary information on potential technology
treatment options for produced water. Three produced water treatment technologies are
currently used by industry in the U.S.: (1) Macro Porous Polymer Extraction System (MPPE);
(2) Symons Adsorption Media (SAM); and (3) Cetco's Polishing System. Other produced water
treatment technologies are used in other countries and include: (1) CTour Process; (2) Epcon
CPU; (3) Mare's Tail®; and (4) Total Oil Remediation and Recovery (TORR®). Two produced
water treatment technologies (CTour and Epcon CPU) are scheduled for installation on oil and
gas extraction facilities after full-scale field trials.
Macro Porous Polymer Extraction System (MPPE)
In this system, the hydrocarbon contaminated water is passed through a column
packed with MPPE particles.11'12 An extraction liquid within the column removes the
hydrocarbons from the water in a single pass. The purified water then passes out to be reused or
discharged.
The extraction liquid is regenerated periodically using low-pressure steam. The
process removes the hydrocarbons the MPPE particles by steam stripping and retains the
extraction liquid in the pores of the polymer. After condensing, the waste stream divides into an
organic and an aqueous phase in a gravity separator. The aqueous condensate is returned to the
extraction column and the organic phase is separated for reuse or removal. The use of two
interchangeable columns allows a continuous process (one performing extraction and one
undergoing regeneration). There is no flow rate restriction in this technology. The MPPE
system removes 99.9 percent of hydrocarbons from water.
Symons Adsorption Media (SAM)
Symons developed a state-of-the-art media adsorption system to remove dispersed
and emulsified hydrocarbons as well as heavy metals from produced water.13
11 Azko Nobel. Macro Porous Polymer Extraction System. 2004. See:
http://www.environmental-center.com/technology /akzonobel/mppe.htm#process.
12 Meijer, D.T. and C.A.T. Kuijvenhoven. May 2001. Field-Proven Removal of Dissolved Hydrocarbons from
Offshore Produced Water by the Macro Porous Polymer Extraction Technology. Presented at the 2001 Offshore
Technology Conference in Houston, TX. See:
http ://www. environmental-center, com/articles/article 105 8/article 105 8 .htm.
13SymonLtd. Produced Water Treatment Polishing System. 2003. See: http://www.symons.co.uk/PWT.pdf.
5-222
-------
Section 5 - Existing Industry Review
Symons absorption media is granular, organic material with a surfactant. This
media material can adsorb about 50 to 200 percent of its own weight of oil and 99 percent of all
emulsified and dissolved oils in one pass. The media is contained in canisters that have extended
axial flow paths, which offer a deeper adsorption bed. The spent media can be used as fuel.
Benefits of SAM over activated carbon are: (1) up to 10 times the adsorption capacity; and (2)
one-third to one-half the cost of activated carbon. SAM can be used to remove aromatics, free
oil, emulsified oil, PCBs, PAHs and phenols.
Cetco's Polishing System
Cetco developed a media adsorption system to remove dispersed and emulsified
hydrocarbons and dissolved heavy metals from produced water.14 This technology includes a
resin, polymer, and clay media packed in canisters. The Cetco polishing system consists of the
following components:
• Solids filtration and chemical treatment: Prior to contact with the
canisterized adsorption media, the produced water is passed through
conventional filtration to remove solids such as scale, sand, silt, clay, and
chemical flocculants. The water is also chemically treated to prevent scale
or build-up within the mechanical filtration equipment.
• Canisters: The standard filter for polishing produced water is an 11' X
11' canister, which is filled with about 25 pounds of adsorbent media.
The canister is designed for radial flow through an exterior filter cloth, the
media bed, and an inner filter cloth. A large accumulation area at the top
of each vessel collects coalesced oil droplets that accumulate on the
exterior filter cloth. Entrained gases, which also accumulate in the top
region, are removed during the purge phase.
• Adsorption Media: The patented Crudesorb® adsorption media is of the
organoclay family and can adsorb oil molecules when oily salt water flows
through the media. As the oil molecules start coating the surface of the
media granules, surrounding water molecules are displaced. Various
forces hold the oil molecules to the surface of the media, thus making it an
irreversible process. The spent media passes the EPA Toxicity
Characteristics Leaching Procedure and can be classified as oilfield or
nonhazardous waste.
14 Darlington, J.W. and J. J. Smith. Produced Water Polishing: Filtration and Filter Monitoring System Promotes
Compliance During Conventional Treatment Upsets. Presented at EPA's Best Available Technology Conference in
February 2003. See:
http://www.muddog.net/papers/CETCO%20PAPER%20FOR%20EPA%20BEST%20AVAIL.%20TECH.%20CON
FERENCE%20Feb.%202003 .pdf.
5-223
-------
Section 5 - Existing Industry Review
• Smart Canister™ Technology: The "smart canister™" continually
monitors media adsorption capacity and alerts the platform operators when
the media is nearly spent. The smart canister™ contains an embedded
probe that electrically measures the media adsorption and relays the
information to a nearby alarm panel.
Cetco's polishing system can reduce water soluble organics by more than 50
percent.
CTour Process
The CTour technology is a liquid-liquid extraction process.15 In this process, a
liquid condensate is used to extract liquid for the dissolved components in produced water. The
condensate also helps remove dispersed oil by coalescing with small oil droplets.
The CTour process includes the following steps:
• Harvest a suitable condensate stream from production;
• Inject condensate in liquid form into the produced water stream;
• Mix and disperse the condensate into the water;
• Allow for adequate contact time between condensate and water;
• Separate the contaminated condensate from the water in a separation
process; and
• Cycle the condensate, containing contaminants, back to the production
stream.
Field trials have been performed on the Ctour process. The process can remove
approximately 70 percent of dispersed oil and PAHs, as well as up to 70 percent of most phenols.
Epcon CFU
The Epcon Compact Floatation Unit (CFU) technology can remove hydrocarbons,
hydrophobic substances, and particles.10 The Epcon CFU acts as a 3-phase water/oil/gas
separator and is based on the principal of oil coalescence. Centrifugal forces and gas floatation
techniques aid in the oil-water separation process. The Epcon CFU is a vertical vessel that has a
15 Knudsen, B.L. et al. Meeting the Zero Discharge Challenge for Produced Water. Presented at Society of
Petroleum Engineers Conference in March 2004 in Calgary, Canada.
5-224
-------
Section 5 - Existing Industry Review
pipe suspended from the top of the vessel to extract gas, oil, and some water. Treated water
exists the vessel at the bottom of the vessel.
Field trials have shown that the Epcon CPU system can produce a 50 to 75
percent reduction in dispersed oil, 32 to 44 percent reduction of PAHS, and a 17 percent
reduction in naphthalene.
Mare's Tail®
Opus Plus Ltd. has patented a technology called Mare's Tail®, which is basically
an inline coalescer consisting of polypropylene media upstream of a hydrocylcone.10 The Mare's
Tail® process coalesces small dispersed oil droplets in the produced water, thus providing better
working conditions for the hydrocyclone process, which is a commonly used process for
removing dispersed oil in offshore produced water.
A field trial of the Mare's Tail® demonstrated that the reduction of oil in water
from a hydrocyclone can be increased by 25 percent with Mare's Tail®. The Mare's Tail®
technology also enhances the removal efficiency of naphthalene, PAHs, and alkylated phenols.
Total Oil Remediation and Recovery (TORR®^
In the TORR® process, the oil-water emulsion to be treated flows through beds of
reusable petroleum adsorbent (RPA) separated by gravity settling compartments.16 The number
of beds may vary from 6 to 12 per system. The oil droplets adhere to the free surface of the RPA
and also coalesce with each other. As more oil droplets are retained, they are stripped from the
RPA. The droplets are entrapped in the interbed compartments where they settle on the top.
This is a continuous process that does not end even when the media is completely saturated with
oils; therefore, it does not generate oil-saturated wastes or other by-products.
The TORR process can remove oil from water to achieve effluent concentrations
of 10 mg/L oil content.
5.5.9.6 Coastal Subcategorv (Subpart D)
This subsection discusses available data and technology options for the Coastal
subcategory of the oil and gas extraction industry. EPA received comments on the Preliminary
Effluent Guidelines Plan from two Cook Inlet native villages and Cook Inlet Keeper stating that
EPA should eliminate the existing exemption from zero discharge for facilities in Cook Inlet,
Alaska. In addition, these commenters requested that EPA extend this subcategory to include the
Lower Cook Inlet, which is in the Offshore subcategory (Subpart A). EPA reviewed data
16 Le Foil, P. et al. Field Trials for a Novel Water Deoiling Process for the Upstream Oil and Gas Industry.
Presented at the Society of Petroleum Engineers Conference in March 2004 in Calgary, Canada.
5-225
-------
Section 5 - Existing Industry Review
submitted by these commenters for the 2004 annual review of these effluent guidelines and
consulted with representatives from the two Cook Inlet native villages.
Data Summary
All facilities regulated by the Coastal subcategory effluent guidelines, except for
facilities in Cook Inlet, AK, are prohibited from discharging drill cuttings, produced waters, and
all other drilling wastes. Based on the record for the 1996 Coastal effluent guidelines, EPA
determined that onsite injection and other zero discharge options were not feasible throughout
Cook Inlet, Alaska.17 Consequently, EPA determined in 1996 that zero discharge for drill
cuttings and produced waters was not BAT and set the effluent guidelines for operators in
Coastal Cook Inlet as equivalent to the effluent guidelines for operators in the Offshore
Subcategory (Subpart A of 40 CFR Part 435). The rationale is described in a Federal Register
Notice (see 61 FR 66125, Dec. 16, 1996). Therefore, only oil and gas extraction facilities in
Cook Inlet are currently allowed to discharge drill cuttings and produced water.
EPA used DMR data for 2001 and 2002 to estimate pollutant discharges for Cook
Inlet facilities. As shown in Table 5-180, EPA used these data to estimate pollutant loads in
pounds and TWPE (see Section 4.2.3 and 4.2.4 for a description of how EPA estimated TWPE).
Table 5-180. Estimated TWPE from Oil and Gas Extraction Facilities in Cook Inlet, AK
Operator
Unocal
Facility
Anna Platform
Baker Platform
Bruce Platform
Dillon Platform
Dolly Varden Platfonn
Granite Pt. Platform
Granite Pt. Prod. Fac.
Grayling Platfonn
King Salmon Platfonn
Monopod Platfonn
Steelhead Platform
Trading Bay Tnnt. Fac
2001 TWPE1
Produced
Water
243
10
4
521
0
0
2
0
0
0
0
9,198
Drilling
Waste
554
2,217
Total
243
10
4
521
0
0
2
0
0
554
2,217
9,198
2002 TWPE1
Produced
Water
173
8
3
487
0
0
6
0
0
0
0
9,521
Drilling
Waste
398
Total
173
8
3
487
0
0
6
0
0
398
0
9,521
17 Coastal Technical Development Document, EPA-82 l-R-96-023, Section 5.10.3.
5-226
-------
Section 5 - Existing Industry Review
Table 5-180 (Continued)
Operator
XTO
Energy
Phillips
Oil
Forest Oil
Total
Facility
East Foreland Treatment
Facility
Platform A
Platform C
Tyonek A Platform
Osprey PF- NRs
2001 TWPE1
Produced
Water
195
No data
10,172
Drilling
Waste
290
0
3,061
Total
195
290
0
13,233
2002 TWPE1
Produced
Water
195
0
0
10,394
Drilling
Waste
0
1,755
217
2,370
Total
195
0
1,755
0
217
12,763
'A zero indicates that the facility reported zero discharge to PCS. A blank field indicates that the facility did not
report any toxic pollutants.
Drilling Fluids and Drill Cuttings
This section summarizes the technical and economic considerations for 40 CFR
Part 435, Subpart D, for BAT and NSPS for drilling fluids and drill cuttings in Cook Inlet, AK.
Rationale EPA Used in the Coastal Effluent Guidelines to Reject Zero Discharge
for BAT/NSPS
EPA examined several technologies to achieve zero discharge of drilling fluids
and drill cuttings in Cook Inlet: (1) grinding and injection; (2) annular disposal; and (3) onshore
disposal. EPA estimated that 89,000 barrels of drilling wastes would be generated annually from
coastal Cook Inlet facilities.18
The first technology involves grinding the drilling fluid, drill cuttings, and
dewatering effluent into a slurry that can be injected into a dedicated disposal well. To use this
option, however, operators must have different formation zones available with appropriate
porosity and permeability to accept the injected wastes. These formation zones cannot be the
producing formations because the injected wastes may interfere with hydrocarbon recovery. The
North Slope, Alaska, and the coastal region along the Gulf of Mexico have subsurface geology
containing relatively porous substrata and formations for injection that are readily available. In
contrast, the geology in Cook Inlet is highly fragmented. EPA received comments on the
proposed rule that provided several examples where attempts to grind and inject drilling wastes
and annular disposal failed in the Cook Inlet area and information in the record indicates that
formations for injection may not be available throughout Cook Inlet (61 FR 66096).
: See December 16, 1996. 61 FR 66093.
5-227
-------
Section 5 - Existing Industry Review
At promulgation of the Coastal effluent guidelines, two operators in Cook Inlet
had access to on-land disposal sites for drilling wastes. Other operators had no access to on-land
disposal sites in Alaska, and EPA estimated the costs for transport and disposal of drilling wastes
at an on-land oil and gas waste disposal site in Oregon. These costs considered the limited
storage space available on platforms and harsh safety- and weather-related conditions for
transport.
EPA did not select injection because formations may not be available throughout
Cook Inlet. EPA considered the onshore disposal as not economically achievable.
Current Review of Zero Discharge
As detailed in Table 5.4.9-2, the declining fields in coastal Cook Inlet means that
fewer wells are being drilled and reconditioned than in 1996. This also means that few drill
cuttings are being generated now than projected in the Coastal effluent guidelines. Based on the
Discharge Monitoring Report data submitted to EPA for 2001 and 2002, less than 14,000 barrels
of drilling wastes are generated annually.
As previously discussed, EPA did not identify injection of drill cuttings as the
basis for BAT limitations or NSPS because of the uncertainties regarding the availability of
geologic formations suitable for injection. While the Cook Inlet geology has not changed, newer
geological prospecting techniques may make it possible to better identify suitable formations.
Newer technology may also make injection of drill cuttings more available.
Specifically, Unocal (Bruce Platform, 2002) and Marathon (Kenai Gas Field,
1999) recently opened grind and inject facilities. Additionally, recent technological
developments to prevent injection well plugging might mean that it is more feasible to inject
drilling wastes. EPA also reviewed a U.S. Department of Energy report on slurry injection
projects, Evaluation of Slurry Injection Technology for Management of Drilling Wastes., May
2003. This report describes several ways in which drilling wastes have been injected into
underground formations for permanent disposal and focuses on injection at pressures exceeding
the fracture pressure (referred to as slurry injection). The report details how these slurry
injection projects are conducted and monitored, the geological conditions that favor slurry
injection, and typical costs. The report includes a database describing more than 330 actual
slurry injection jobs including four in coastal Cook Inlet. This report states that it is the most
comprehensive publicly available source of information on the drilling waste slurry injection
jobs. Oilfield wastes injected at these four slurry injection projects include: (1) water-based
cuttings (very large particle size); (2) oil-based cuttings; and (3) deck drainage. Volume of
material injected ranges from 20,000 to 221,400 barrels of slurry waste at injection rates of 1 to 4
barrels per minute.
In the 2001 synthetic-based drilling fluids (SBF) effluent guidelines, EPA
identified that, under most circumstances, operators in coastal Cook Inlet are able to achieve zero
discharge with their wastes associated with nonaqueous drilling fluids, drill cuttings, and
dewatering effluent. Consequently, under most normal circumstances, operators in coastal Cook
5-228
-------
Section 5 - Existing Industry Review
Inlet are required to meet the same standards (zero discharge) for nonaqueous drilling fluids,
drill cuttings, dewatering effluent as other operators regulated by the Coastal subcategory.19
EPA established a three-test procedure in the SBF effluent guidelines for allowing the discharge
of SBF drill cuttings in coastal Cook Inlet. Operators in Cook Inlet are prohibited from
discharging SBF drill cuttings except when they are unable to dispose of their SBF cuttings
through: (1) on-site injection (annular disposal or Class IIUIC); (2) injection using a nearby
coastal or offshore Class II UIC disposal well; or (3) onshore disposal using a nearby Class II
UIC disposal well or land application. Coastal Cook Inlet operators are required to demonstrate
to the NPDES permit authority that none of the above three disposal options are technically
feasible in order to qualify for the alternate BAT limitation (see January 22, 2001; 66 FR 6867).
Operators that qualify for the alternate BAT limitation are allowed to discharge SBF drill
cuttings at the same BAT limitations as operators in the Offshore subcategory.
With respect to economic factors associated with a zero discharge requirement for
drill cuttings, existing oil and gas extraction projects are unlikely to be in better financial
condition in 2004 than they were in 1996 when the coastal effluent guidelines were promulgated.
Although oil and gas prices have undergone a recent spike, the fields have experienced eight
years of declining production associated with depleting a natural resource. Comparing the
production figures from 1995 (the baseline for the Coastal Cook Inlet analysis) and historic and
projected data from the state of Alaska (with 2002 as the last full year of historic data) shows the
following:
• Trading Bay Field production has declined about 92 percent;
• Granite Point Field production has declined at least 70 percent;
• Middle Ground Field production has declined about 17 percent; and
• Tyonek production (counted with Kenai Field onshore production) has
declined at least 75 percent from 1995.
In the Coastal effluent guidelines, EPA estimated that one platform would shut-in
(close) under a zero discharge option. However, EPA's review of current economic information
indicates that all Cook Inlet facilities should now be considered marginal due to declining
production. Since promulgation of the Coastal effluent guidelines, no new coastal oil and gas
disposal sites have opened in the Cook Inlet. Therefore, the costing assumptions for transporting
the wastes to a disposal site in the contiguous U.S. not changed since 1996; however, the volume
of drilling waste is lower than projected in 1996.
19 Development Document for Final Effluent Limitations Guidelines and Standards for Synthetic-Based Drilling
Fluids and Other Non-Aqueous Drilling Fluids in the Oil and Gas Extraction Point Source Category,
EPA-821-B-00-013, Chapter VII.5.4 (Page VII-62) and Chapter X.3.3.1 (Page X-3),
http://www.epa.gov/waterscience/guide/sbf/final/eng.html, December 2000.
5-229
-------
Section 5 - Existing Industry Review
With respect to existing coastal Cook Inlet oil and gas extraction facilities, EPA
does not know how widely new injection techniques and technologies can be used across all
Cook Inlet facilities. Moreover, given that all existing coastal Cook Inlet oil and gas extraction
facilities are considered marginal, it is unclear whether the incremental compliance costs
associated with a zero discharge requirement would cause these facilities to shut in. EPA will
examine the economic and technological progress of these injection technologies in future
annual reviews of this industrial sector.
Additionally, since promulgation of the Coastal effluent guidelines, there is only
one new oil and gas facility in Cook Inlet. The Osprey Platform is the first new platform
established in Cook Inlet in about 16 years and currently disposes of its drilling wastes through
annular disposal or Class II injection in approved wells. Thus, EPA has determined zero
discharge of drilling wastes to be economically and technically achievable for this project. Part
of that decision might rest on the availability of a suitable formation for disposal at that site. As
previously discussed, EPA does not know how widely these new zero discharge techniques and
technologies for drill cuttings can be used across all Cook Inlet facilities.
Given the 16-year lag between NSPS projects, the ability of the permit writer to
require an operator to demonstrate that zero discharge is not technically feasible for a specific
project, and the relatively low toxicity of the discharges, EPA decided not to revise effluent
guidelines for drill cuttings discharges in this subcategory at this time.
Produced Water
This subsection summarizes the technical and economic considerations for 40
CFR Part 435, Subpart D for BAT and NSPS for produced water in Cook Inlet, AK.
Rationale EPA Used in the Coastal Effluent Guidelines to Reject Zero Discharge
for BAT/NSPS
EPA examined injection technology to achieve zero discharge of produced water
in Cook Inlet in the 1996 Coastal effluent guidelines. As previously mentioned, Cook Inlet is
different from other coastal regions in that the production formation is usually the only formation
available for the injection of produced water. For existing projects in Cook Inlet, EPA estimated
the costs of piping produced water from existing production facilities to existing waterflood
injection sites. EPA's economic analysis in the Coastal effluent guidelines estimated that 1 of 13
platforms would close and 2 additional platforms would incur severe economic impacts.
Consequently, EPA rejected zero discharge in the Coastal effluent guidelines as not
economically feasible for Cook Inlet.
EPA rejected zero discharge of produced water for NSPS for Cook Inlet because
of uncertainties regarding the availability of geologic formations suitable for receiving injected
produced water. Because the location and availability of formations for a new source in Cook
5-230
-------
Section 5 - Existing Industry Review
Inlet are unknown, EPA could not estimate the maximum cost associated with piping produced
water from the wellhead to the nearest injection well.
Current Review of Zero Discharge
As mentioned previously, Osprey is the first new platform set in Cook Inlet in
about 16 years. It is the first platform in Cook Inlet designed to reinject all produced water from
the platform.20 Thus, EPA has determined zero discharge of drilling wastes to be economically
and technically achievable for this project. Part of that decision might rest on the availability of
a suitable formation for disposal at that site. In addition, the Osprey platform qualified for a
special royalty reduction incentive offered by the state of Alaska. The reduced royalty is 5
percent (in contrast to the more typical 12.5 percent) and production must have started by
January 1, 2004.21 If zero discharge of produced water is technically feasible for a new project,
whether it is economically feasible will depend on the royalty rates, potential incentives offered
by the state, and oil and gas prices at that time.
Newer injection technology might also make injection of produced water more
available. However, EPA does not know how widely these newer technologies can be used
across all Cook Inlet facilities. EPA will examine the progress of these technologies in future
annual reviews. Given the 16-year lag between NSPS projects, the ability of the permit writer to
require an operator to demonstrate that zero discharge is not technically feasible for a specific
project, and the relatively low toxicity of the discharges, EPA decided not to revise effluent
guidelines for produced water in this subcategory at this time.
Summary
At this time, EPA concluded it should not identify these effluent guidelines for
revision in the current effluent guidelines plan. EPA will examine the progress of newer zero
discharge technologies for drill cuttings and produced waters in future annual reviews.
Additionally, in response to public comments that it should revise the
applicability section of the Coastal subcategory, EPA has decided not to reclassify lower Cook
Inlet as part of the Coastal subcategory because that would change a long-standing definition
relying on "the inner boundary of the territorial seas" as a line between coastal and offshore. See
EPA's Response to Public Comments on Effluent Limitations Guidelines and Standards for the
Coastal Subcategory of the Oil and Gas Extraction category, October 30, 1996 ("EPA Response
to Comments"), R. IIJB.(c) 1, Topic Code H, pp. H-l - H-17. Rather than revise the
applicability criteria for these effluent guidelines, EPA will evaluate available and affordable
technologies for
20 K. Nelson, "Money, time, an assist from the Legislature were all required to bring Redoubt Shoal online,
Petroleum News, Vol. 7, No. 52. December 2002. www.ptroleumnews.com/pnarchpop/021229-12.html.
21 See http://www.dog.dnr.state.ak.us/oil/products/publications/otherreports/2002_annual_report/
2002_annual_report.pdf.
5-231
-------
Section 5 - Existing Industry Review
facilities in upper Cook Inlet (regulated by the Coastal effluent guidelines) and in lower Cook
Inlet (regulated by the Offshore effluent guidelines). Currently, there are no oil and gas
extraction facilities in lower Cook Inlet.
5.5.9.7 Coal Bed Methane Extraction
This section discusses a potential additional subcategory of the oil and gas
extraction industry, coalbed methane (CBM) extraction. EPA determined that CBM extraction is
appropriately considered an additional subcategory of the Oil and Gas Extraction category (Part
435). EPA based this determination on the similarity of processes, operations, wastewater, and
treatment technology options of CBM extraction to those of oil and gas extraction regulated by
the existing ELG. EPA did not consider CBM production in developing the 1979 national
technology-based effluent limitations guidelines for the Onshore and Agricultural and Wildlife
Water Use subcategories of the Oil and Gas Extraction category (40 CFR Part 435, Subparts C
and E) because there was no significant CBM production in 1979.22
Additionally, EPA did not consider CBM production in developing the coal
mining effluent guidelines. EPA established effluent guidelines for coal mining operations based
on the use of BPT for existing sources in the Coal Mining Point Source Category (40 CFR Part
434) on April 26, 1977 (42 FR 21380). These effluent guidelines were revised on October 9,
1985 (50 FR 41296). More recently, EPA revised these ELGs again on January 23, 2002 (67 FR
3370) by adding two new subcategories to address preexisting discharges at coal remining
operations and drainage from coal mining reclamation and other nonprocess areas in the arid and
semi-arid western United States. None of these rulemakings considered coalbed methane
extraction in any of the supporting analyses or records.
Therefore, permit writers develop technology-based limits for the CBM NPDES
discharge permits using a best professional judgment (BPJ) basis (see 40 CFR Part 125.3(c)(2)).
NPDES permit writers can develop BPJ limits by using one of two different methods. A permit
writer can either transfer numerical limitations from an existing source such as from a similar
NPDES permit or an existing set of effluent guidelines, or derive new numerical limitations.
Impacts to surface water from discharge of CBM water can be severe depending
upon the quality of the CBM water. Neil et al. (1980) report that saline discharges have variable
effects depending on the biology of the receiving stream and the instream concentration of
produced water. Some water bodies and watersheds may be able to absorb the discharged water
while others are sensitive to large amounts of low-quality CBM water. Aquatic and benthic
communities can be adversely impacted (e.g., decrease in species diversity, density) by the
constituents in CBM water (e.g., TDS, chloride, metals, organics). Discharge of this water may
also cause erosion and in some cases irreversible soil damage from high TDS concentrations.
This may limit future agricultural and livestock uses of the water and watershed.
22 Letter from Thomas P. O'Farrell, EPA's Industrial Technology Division, to Constance B. Harriman, Steptoe &
Johnson. June 1, 1989.
5-232
-------
Section 5 - Existing Industry Review
In outreach and in public comments, environmental advocacy groups and surface
rights groups (e.g., farmers, ranchers) requested that EPA establish effluent guidelines for this
industry.
Industry Description
As plant material is progressively converted to coal, large quantities of methane-
rich gas are generated that are stored within the coal. Coalbed methane is held in place in the
coal seam by the water pressure of natural underground aquifers. Drilling and pumping these
aquifers is necessary to reduce the water pressure exerted by the aquifers and produce coalbed
methane. By pumping the aquifers, the methane is separated from the water in the borehole and
flows to the pipeline. The natural gas consists of approximately 96 percent methane, 3.5 percent
nitrogen, and trace amounts of carbon dioxide (CO2).
Exploration costs for CBM are low, and the wells are cost-effective to drill.
Methane occurs in most coals, and the location of the Nation's coal resources is already well
known. Table 5.4.9-8 identifies the most significant sources of current CBM production.
Large amounts of water, sometimes saline, are produced from CBM wells.
Coalbed gas wells have a distinctive production history characterized by an early stage, in which
large amounts of water are produced to reduce reservoir pressure, which in turn encourages
release of gas; a stable stage, in which quantities of produced gas increase as the quantities of
produced water decrease; and a late stage, in which the amount of gas produced declines and
water production remains low. In addition, EPA notes that recent court actions confirm that
CBM water is a pollutant subject to regulation under the CWA.23
Table 5-181. Current Sources of CBM Production
Basin Name
Black Warrior
San Juan
Powder River
Wind River
Greater Green River
Year of
Initial
Production
1980
1979
1993
recent
1999
States
AL
MM, CO
WY, MT
WY
WY, CO
Total Number of
CBM Wells
(1999)
2,989
3.311
1,657
0
2
Cumulative Production
1981 - 1999
(billion cubic feet)
1,079.02
6,648.44
119.78
0
1.93
23 In August 2002. the Federal District Court in Montana granted summary judgment dial CBM-produced water is
not a pollutant within the meaning of die CWA (Fidelity Exploration Co. v. Northern Plains Resource Council). In
April 2003, the 9th Circuit Court of Appeals reversed diis decision and reaffirmed that, "unaltered groundwater
produced in association with methane gas extraction, and discharged into the river, is a pollutant within the meaning
of the CWA." In October 2003, the U.S. Supreme Court declined to review the decision by the Court of Appeals.
This action lets stand the decision of the 9th Circuit Court of Appeals (i.e., "The plain language of the CWA requires
the conclusion mat CBM water is a pollutant subject to regulation under the CWA.").
5-233
-------
Section 5 - Existing Industry Review
Table 5-181 (Continued)
Basin Name
Raton
Uinta-Piceaiice
Central Appalachian Coal
Basin
Northern Appalachian
Coal Basin
Western Interior Coal
Region
Western Washington Coal
Regions
Year of
Initial
Production
1995
-1995
N/A
N/A
N/A
N/A
States
CO. MM
CO, UT
KY, TN, VA,
WV
PA, WV,
OH, KY, MD
AK, OK. KS,
MO, NE, IA
WA,OR
Total Number of
CBMWeUs
(1999)
405
410
N/A
N/A
N/A
N/A
Cumulative Production
1981 - 1999
(billion cubic feet)
67.77
156.05
5,000'
61,000'
>15,000'
300 - 24,000'
Sources:
North American Coalbed Methane Resource Map (Gas Technology Institute. 2001).
Draft Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed
Methane Reservoirs, Horsley & Witten, Inc., September 19, 2001.
N/A - Not available.
'Figure represents estimated amount of CBM and not cumulative production.
Note: EPA also summarized available information on coalbed methane operations in Alaska.
Pollutants of Concern
The principal environmental problem associated with production of CBM is
disposal of large quantities of produced water (i.e., billions of gallons per year). The major
pollutant of concern is total dissolved solids (TDS) and the sodium adsorption ratio (SAR).
CBM- produced water TDS concentrations range from below 500 to 30,000 mg/L. Table 5-182
presents the estimated raw pollutant loadings and discharged pollutant loadings from CBM
operations.
Table 5-182. Estimated CBM Industry Pollutant Loadings
Pollutant
Total Nonconventional
TDS
Iron
Chloride
Sodium
Calcium
Raw Waste Loadings
(Thousand Ib/yr)
347,830 - 10,294,325
222,833 - 5,245,180
57,917-2,169,780
38,101 - 1,427,405
26,170 - 1,007,104
1,696-68,119
(Thousand
TWPE/yr)
327 - 12,240
NA
324-12,150
0.9 - 35
0.1 -6
0.05 - 2
Discharge Loadings
(Thousand Ib/yr)
95,660 - 4,746,985
68,667 - 2,348.250
10-15,152
2,043 - 1,166,996
22.433 - 852,012
1,532-59,037
(Thousand
TWPE/yr)
1.2-142
NA
0.06 - 85
0.05 - 28
0.1 -5
0.04 - 2
5-234
-------
Section 5 - Existing Industry Review
Table 5-182 (Continued)
Pollutant
Potassium
Magnesium
Sulfate
Barium
Raw Waste Loadings
(Thousand Ib/yr)
671-23,719
346 - 18,446
59-332,511
35-2,061
(Thousand
TWPE/yr)
0.7 - 25
0.3 - 16
0.0003 - 2
0.07 - 4
Discharge Loadings
(Thousand Ib/yr)
603-6,143
310-15,378
45 - 283,486
17 - 535
(Thousand
TWPE/yr)
0.6-6
0.3 - 13
0.0003 - 2
0.03 - 1
Priority and conventional pollutants are not present in CBM water in significant quantities.
Source: U.S. EPA, 2003. Analysis of Discharge Data for Six Industry Categories. DCN 00632, Section 3.0.
NA - Not applicable.
Wastewater Treatment and Disposal
Water management options may include several zero discharge options (e.g.,
injection, discharge to evaporation ponds, irrigation) and treatment and discharge to surface
waters. Injection wells, which require suitable formations for disposal, are the preferred method
of disposal in the San Juan Basin and central Appalachian basin24, whereas discharge into
surface streams, after treatment in ponds to meet water-quality regulations, occurs in the Black
Warrior basin, Alabama.25
This section summarizes preliminary information on potential technology
treatment and disposal options for produced water. Treatment and disposal methods used to
treat, dispose, or otherwise manage CBM-produced water include: surface-water discharge with
beneficial reuse, storage/evaporation ponds, injection into a subsurface aquifer, iron oxidation,
reverse osmosis, ion exchange, electrodialysis, precipitation, downhole gas/water separation,
freeze/thaw evaporation, and the Harmon SO2 Generator.
EPA developed capital and operating costs associated with these water disposal or
treatment methods and used them in an economic impact model of CBM production in the
Powder River Basin26. The economic analysis uses a financial model based on a discounted
cash-flow approach that has been used for the economic analyses of several oil and gas industry-
related effluent guidelines. The general approach takes a number of model projects that are
24 Rice, 1995.
25 Rogers, 1994.
-" EPA prepared a draft report "Guidance for Developing Technology -Based Limits for Coalbed Methane
Operations: Economic Analysis of the Powder River Basin" to provide guidance for EPA Region 8 to use for its
"best professional judgment" to prepare CWA NPDES permits on Indian lands that are under Region 8 jurisdiction.
5-235
-------
Section 5 - Existing Industry Review
specified on the basis of gas and water production volumes, using data and assumptions about
costs of gas production, royalty and severance tax rates, price of gas, costs of project
construction, number of wells per project, and other information. Costs of CBM-produced water
management are used in the model to prepare a number of scenarios, including a baseline
(current practice) scenario against which all other scenarios are compared. For more information
about costing, please see DCN 01093, Section 3.01.
Surface Discharge
Surface discharge is the most common and least costly practice to dispose of
CBM-produced water in the Powder River Basin. Controls on the discharge of produced water
are often selected and approved by the regulatory agencies based on the quality and volume of
water produced. Facilities typically transport the wastewater to the discharge location via buried
flowlines. Facilities often use surface discharge in combination with aeration methods to
precipitate iron from the water in order to reduce or eliminate staining in the stream beds and
preserve the aesthetic quality of the receiving stream. Water typically flows over rip-rap before
entering the stream bed to reduce erosion and further precipitate iron from the water. Facilities
may also use spray nozzles, educators, and bubble diffusers to aerate the water before discharge.
Storage/Evaporation Ponds
Many CBM operators in the Powder River Basin use unlined earthen storage
ponds for evaporation and infiltration in conjunction with surface discharge to minimize the
amount of water reaching outfalls to surface water. Ponds are typically constructed by
excavating a rectangular pit with sloped sides and berms around the perimeter. Water is
eliminated via infiltration, evaporation, and transport to irrigated cropland and pasture land
without return flows to drainages.27 Evaporation rates depend largely upon the characteristics of
the pond. Evaporation from small shallow ponds is usually quite different than from large
reservoirs due to the differences in heating and cooling rates of the water. In semi-arid regions
such as Wyoming, hot dry air moving from a land surface over a water body will result in higher
evaporation for smaller water bodies.28
Two types of storage ponds are used: in-channel and off-channel. In-channel
ponds are located within an existing drainage basin, including all perennial, intermittent, and
ephemeral defined drainages, lakes, reservoirs, and wetlands. Off-channel ponds are located on
upland areas, outside of natural drainages and alluvial deposits associated with these natural
drainages.22 Most of the storage ponds in the Powder River Basin are off-channel and are
designed to contain all CBM-produced water without discharge to Class 2 waters.23
27 O&G Environmental Consulting. 2002. Coalbed methane producers information survey results. O&G
Environmental Consulting, Englewood, CO. January.
28 Pochop, L., K. Warnaka, J. Borrelli, and V. Hasfurther. 1985. Design information for evaporation ponds in
Wyoming. WWRC-85-21. See: www.wrds.uwyo.edu/library/wrp/85-21/85-21.html.
5-236
-------
Section 5 - Existing Industry Review
When groundwater and soil contamination from lower quality CBM-produced
water are a concern, impervious barriers or liners can be used to reduce seepage through the
pond bottom and sides. Soil that is at least 10 percent clay can be compacted with a sheepsfoot
roller to create a suitable impervious barrier. If the soil is not at least 10 percent clay, a liner or
soil amendment could be used to achieve impermeable barrier restrictions. The following site
conditions may also require seepage reduction beyond what is provided by compacting the
natural soil: a shallow underlying aquifer, an underlying aquifer that is ecologically important or
used as a domestic water source, or highly permeable underlying bedrock or soil. Three options
are available to provide additional seepage reduction: the soil can be mixed with bentonite or a
soil dispersant and then compacted; clay can be imported and compacted along the bottom and
side walls; or concrete or synthetic materials such as geomembranes or geosynthetic liners can
be used. Concrete and synthetic liners are usually the most expensive. The method chosen to
line the pond depends on the type of soil, site geography and location, available materials, and
costs of alternatives. Ponds with liners, however, will have to be significantly larger than
unlined ponds because no infiltration into the substrate occurs. Evaporation becomes the only
mechanism for reducing the water levels in these lined, impermeable storage ponds.
Injection
Injection of produced water from oil and gas operations into Underground
Injection Control (UIC) Class II wells is the predominant (greater than 90 percent by volume)
form of produced-water management in the continental United States.29 Class II wells are
regulated by the UIC and are used to inject fluids associated with the production of oil and
natural gas. Injection into UIC Class II wells is also the predominant disposal option for CBM-
produced water in the San Juan Basin because of high TDS.
An injection well may be installed by either drilling a new hole or by converting
an existing well. The types of existing wells that may be converted include: marginal oil-
producing wells, plugged and abandoned wells, and wells that were never completed (dry holes).
Drilling a new injection well may be similar to drilling a CBM-production well except that
injection wells may need to be drilled deeper.
In the conventional oil and gas industry, well conversions are most commonly
performed as part of an enhanced recovery (water flood) project, and on wells whose
hydrocarbon production rates have or soon will diminish to the point where they are no longer
economical to operate as production wells (i.e., they have been depleted). Wells that were never
completed (dry holes) and old plugged and abandoned wells may also be used, but may require
more work at greater expense.30 The most common method of conversion involves recompleting
29 Lawrence, A.W. 1993. Coalbed methane produced-water treatment and disposal options. Quarterly Review of
Methane From Coal Seams Technology 11:2. Gas Research Institute. December.
30 Wyoming Department of Environmental Quality. No date. Draft recommended off-channel, unlined CBM
produced water pit siting guidelines.
5-237
-------
Section 5 - Existing Industry Review
the well at a shallower depth into a nonhydrocarbon-producing formation. In such a case, the
lower portion of the well is cemented and sealed off.
Some of the technical issues that may be associated with subsurface injection of
produced water include formation plugging and scaling, formation swelling, corrosion, and
incompatibility of injected produced waters with receiving formation fluids. In general, these
issues can be avoided or remedied through engineering and operational applications such as the
use of treatment chemicals.31
An advantage of using Class II injection wells for disposal of CBM-produced
water is that the water is returned to a geologic zone in which the natural quality of the water is
usually worse than the injected produced water. If the well is properly designed, maintained, and
operated, there is little risk of ground-water contamination from produced water. A potential
disadvantage of using Class II injection wells is the possible need for pretreatment to prevent
plugging of the injection well. It is also necessary to periodically clean crusted material from the
injection well perforations. Well cleanings require temporary suspension of injection operations,
and nearby temporary storage or alternative disposal facilities.32
Pretreatment may include removing iron and manganese by precipitation. Iron
and manganese form oxides upon exposure to air, which may lead to clogging in the well.
Settling tanks with splash plates are used to aerate the produced water, which will oxidize iron
and manganese to insoluble forms that can precipitate in the tank. The water can then be
injected. Biocides may also be added to the produced water prior to injection to control
biological fouling.
Iron Oxidation
CBM-produced water often has a high concentration of iron (e.g., 2 mg/L), which
can be treated by exposing the water to air. As the water mixes with air, ferric/ferrous iron is
oxidized to the ferrous/ferric state and precipitate out as a red/orange solid. Iron oxidation,
however, can cause aesthetic problems when the produced water is discharged. To prevent this
problem, iron oxidation can be enhanced before the discharge point by using simple oxidation
methods such as spray nozzles, educators, bubble diffusors, and surface aerators to help
oxygenate the water and precipitate the iron before the CBM effluent stream reaches surface
waters. Chemical oxidation methods may also be used to remove iron. CBM operators in the
Powder River Basin often use iron oxidation methods to eliminate staining of the receiving
streams.
31 U.S. EPA. 1996a. Development document for final effluent limitations guidelines and standards for the coastal
subcategory of the oil and gas extraction point source category. EPA/821/R-96/023. Washington, DC.
32 Zimpfer, G.L., EJ. Harmon, and B.C. Boyce. 1988. Disposal of production waters from oil and gas wells in the
northern San Juan Basin, Colorado. In: Fassett, J.E. Fassett, ed. Geology and coal-bed methane resources of the
northern San Juan Basin, New Mexico and Colorado, 1988 Coalbed Methane Symposium. Denver, CO: Rocky
Mountain Association of Geologists, pp. 183-198.
5-238
-------
Section 5 - Existing Industry Review
Reverse Osmosis
Reverse osmosis is a pressure-driven membrane separation process that can
separate dissolved solutes from a solvent, usually water. The solute may be organic or inorganic
and range in size from 1 to 10 Angstroms or less. Reverse osmosis membranes may consist of
cellulose acetate, polyamides, or other polymers. The ability of reverse osmosis membranes to
reject organic substances depends upon the molecular weight, geometry of the solute, and other
factors. A well-designed reverse osmosis system can remove 90 to 99 percent of most dissolved
organic and inorganic compounds. Most current reverse osmosis applications are related to
water treatment for commercial, industrial, municipal, agricultural, and military facilities.33
The process of reverse osmosis is based on the principal that when a salt solution
is separated from demineralized water by a semipermeable membrane, the higher osmotic
pressure of the salt solution causes demineralized water to flow into the salt solution
compartment. Water will continue to flow and rise in the salt solution compartment until the
increase in water height equals the osmotic pressure of the salt solution. If pressure is exerted on
the salt solution compartment, water can be made to flow in the reverse direction; this is called
osmotic pressure. Other membrane separation processes, such as microfiltration, nanofiltration,
and ultrafiltration, use physical separation of solutes and all insoluble compounds based on
membrane pore size, not osmotic pressure.
In a typical reverse osmosis system, a pump applies pressure to the feed stream
(e.g., CBM-produced water) to move water from the more concentrated to the less concentrated
side of a membrane. The influent stream is separated into a permeate stream of treated water and
a reject stream containing the concentrated salts. The reject stream is often disposed of through
deep well injection and the permeate stream is often surface discharged.
The greatest challenge in constructing a reverse osmosis system is packaging the
greatest area of a fragile membrane in a relatively inexpensive housing that can operate at
differential pressures of up to 1,000 psig. Two element designs, spiral wound elements and
hollow fine fiber elements, have been developed to address this challenge. The spiral wound
element consists of two sheets of membrane separated by a porous support material. This
material supports the membrane against the operating pressure and provides a flow path for the
product water. This unit is sealed around three sides with glue while the fourth edge is sealed to
a hollow plastic tube that has perforations inside the edge seal area so that product can be
removed from the porous support material. The units are rolled up about the central tube along
with a mesh spacer that separates the membrane surfaces and promotes turbulence of the feed
water as it passes through the element. Up to six elements may be connected in series and
housed in a single pressure vessel.28 Reverse osmosis units can be constructed on mobile
platforms to allow operators to relocate the units after water production declines in any particular
area.
33 Desalination Systems, Inc. 1986. Technical bulletin: reverse osmosis fundamentals. Desalination Systems, Inc.
October.
5-239
-------
Section 5 - Existing Industry Review
The most critical problem confronting operators of reverse osmosis systems is
fouling. Foulants consist of four major classes of substances: metal hydrozides (e.g., iron,
manganese, aluminum hydroxides); colloidal and particulate foulants; precipitates of sparingly
soluble salts (e.g., calcium carbonate, calcium sulfate); and biological or organic foulants (e.g.,
bacteria, bacterial by-products). Colloidal and metal hydroxide foulants enter in the feedwater
and are driven to membrane surfaces by the permeate flow. Organic foulants and bacteria also
enter in the feedwater. Given a suitable substrate, bacteria are capable of attaching and growing
on membrane surfaces. Precipitates form when the solubility of sparingly soluble salts is
exceeded within the system.28
Membrane cleaning is usually effective in removing the majority of foulants, but
it is not 100 percent effective in removing all foulant deposits and some cleaners may, with
frequent use, cause a loss in salt rejection. However, with adequate pretreatment, reverse
osmosis systems should not have to be cleaned more than several times per year and membranes
should last approximately three years.28
Although reverse osmosis has not often been used to treat large amounts of CBM-
produced water for high TDS content, it has been and continues to be pilot-tested by CBM
operators and is currently being used in Utah. Talon Resources is currently operating a reverse
osmosis treatment unit in the Perron Coalbed Gas Fairway in Orangeville, Utah. This unit is
processing about 15,000 gallons of CBM-produced water per day and surface discharging about
10,000 gallons per day. In the San Juan Basin, Phillips installed a reverse osmosis system at a
pilot plant in 1992 at Pump Mesa. The pilot plant operated for only two months and was shut
down due to delays in obtaining a surface discharge permit.34 BP is currently working with US
Filter and Hydrometrics to develop pilot-scale reverse osmosis treatment. Pilot tests are also
expected to begin in the Powder River Basin.
Ion Exchange Technology
The Higgins Loop ion exchange system uses cation and/or anion resins to remove
sodium, chloride, sulfate, and other ions from CBM water. The CBM water must be degassed of
methane prior to entering the system facility for personal safety reasons. This can be
accomplished using a gas separator or a small receiving pit. The CBM water enters a small
influent tank used as a feed tank to the system. Once the water enters the system, it moves
through the adsorption zone, where a strong acid cation exchange resin (Dow G-26 resin) is used
to remove the cations from CBM water. The cations in the CBM water are replaced by
hydronium ions from the resin beads. This lowers the pH level of the CBM water and
bicarbonate ions begin to react with the hydronium ions to form carbon dioxide gas. The treated
water is then discharged to a neutralizing bed where the excess hydronium ions and residual
bicarbonate ions (or carbon dioxide gas in solution, depending the pH) can react with selected
calcium minerals to achieve the desired final pH. The selection of the neutralizing agent varies
34 Cox, D.O., A.D. Decker, and S.H. Stevens. 1993. Analysis of fruitland water production treatment and disposal,
San Juan Basin. Prepared by Advanced Resources International, Inc., for Gas Research Institute. June.
5-240
-------
Section 5 - Existing Industry Review
with the desired final pH and the intended use of the treated water. Typically, limestone is used
as the neutralizing agent.35
As the CBM water is being treated, cations are removed from the resin in the
regeneration section of the system. Hydrochloric or sulfuric acid is injected into the system,
which moves countercurrent to the resin. This regeneration process restores the resin to its
hydronium form. The hydrochloric acid is transported to the treatment facility and stored in poly
tanks designed for hydrochloric acid containment and have a vapor scrubber in line. A chemical
feed pump is used to pump the hydrochloric acid into the ion exchange system. Once the acid
enters the system, it is diluted down to 14 percent and introduced directly into the regeneration
phase of the system. The regenerated resin is rinsed with water to remove any residual acid
before reentering the adsorption zone. This process generates a concentrated brine, which is
removed for disposal.30
The concentrated brine volumes range from 0.8 percent to 2 percent of the
influent CBM water volume, depending on the cation loading that is removed from the treated
water. The concentrated brine is typically stored on site until there is enough for a truck load.
Then, it is transported to a commercial disposal facility, where it is disposed using an injection
well.30
As the upper layer of the adsorption zone becomes loaded with sodium, the ion
exchange system is designed to interrupt the flow to the system to allow the resin to pulse in the
opposite direction of the water flow. Once the resin pulsing is completed, the water flow into the
system is restarted. In addition, the system is designed to backwash any solids out of the resin.
The solids and small amounts of resin are backwashed into the resin recovery tank. Periodically,
the operator will remove the resin from this tank and add it back into the system. If silts
accumulate in the resin recovery tank, the operator removes them.30
This system is effective at reducing total dissolved solids (TDS) levels of 1,600 to
1,800 milligrams per liter (mg/L) to below 500 mg/L. The limitations of the system are
determined by the total cation load of the CBM water. The system is engineered to operate at
optimum with cation levels at a sodium equivalency of 500 mg/L but is efficient to any level
below 500 mg/L and up to levels above 1,500 mg/L. The life span of the ion exchange system is
typically 15 to 20 years. The system is capable of treating CBM water with 13 percent solids;
therefore, pretreatment is not required.30
The Higgins Loop™ has been a viable system for many years and has a history of
97 percent or greater up time or continuous runtime. The design of the system allows for most of
the required maintenance (e.g., replacement of small control valves) to be replaced during
operation. Most of the down time that has been experienced is related to temperature generator
power failure.30
35 EMIT (2003), Report on Coal Bed Natural Gas Produced Water Treatment Utilizing Continuous Countercurrent
Ion Exchange (CCIX) Technology. EMIT Water Discharge Technology, LLC. September.
5-241
-------
Section 5 - Existing Industry Review
Electrodialysis
Electrodialysis is a membrane technology that can remove ionic constituents in
CBM- produced water. In electrodialysis, salts and minerals are removed from a stream of saline
water through special plastic membranes by the action of a direct electrical current. These salts
and minerals pass through the membrane in the form of positively and negatively charged ions.
The water from which these ions have been removed flows between the membranes and is
collected as a partially demineralized product by manifolds cut through the membranes. The
salts and minerals removed from the product screen pass through the membranes into another
stream of water that continuously washes the other side of each membrane and emerges through
manifolds as a more concentrated waste stream. The amount of electrical current and membrane
surface required to desalt a given quantity of water by electrodialysis and the cost depends on the
amount and type of mineral to be removed.36
An electrodialysis cell consists of alternating anion-permeable and cation-
permeable membranes that form compartments. Cations pass through the cation-permeable
membrane toward the cathode and are trapped by the membrane, which is permeable only to
anions. The anions travel in the opposite direction toward the anode and are trapped by the
cation-permeable membrane. The feed stream becomes depleted of ions as they become trapped
between the anion- and cation-specific membranes.
Although electrodialysis is technically capable of treating CBM-produced water
with a high TDS content, no commercial applications of this technology are known for treating
this type of wastewater.
Precipitation
Chemical precipitation is a separation technology in which adding chemicals
during treatment causes insoluble solid precipitates to form from the organic or inorganic
compounds in the wastewater. Chemical precipitation is generally carried out in four phases: (1)
addition of the chemical to the wastewater; (2) rapid (flash) mixing to distribute the chemical
evenly into the wastewater; (3) slow mixing to promote growth by various flocculation
mechanisms; and (4) filtration to remove the flocculated solid particles. Precipitation is caused
by adding chemical reagents that adjust the pH of the water to the minimum solubility of the
metal. The standard reagents include lime (calcium hydroxide), caustic (sodium hydroxide),
magnesium hydroxide, soda ash (sodium carbonate), trisodium phosphate, sodium sulfide, and
ferrous sulfide. These reagents precipitate metals as hydroxides, carbonates, phosphates, and
36 Corbitt, R.A. 1990. Standard handbook of environmental engineering. New York: McGraw-Hill, Inc. R.R.
Donnelley & Sons Company.
5-242
-------
Section 5 - Existing Industry Review
sulfides. Metals commonly removed from solution by precipitation include arsenic, barium,
cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, and zinc.37
In a typical precipitation process, a chemical precipitant is added to the metal-
containing water in a stirred reaction vessel. The dissolved metals are converted to an insoluble
form by a chemical reaction between the soluble metal and the precipitant. The suspended
particles are then flocculated and either settled in the batch tank or passed to a membrane filter.
Granular media filtration can be used to remove any suspended metal precipitates that do not
settle in the reaction tank.
Hydroxide precipitation is the most common type of chemical precipitation.
Hydroxide precipitation normally uses calcium hydroxide (lime), sodium hydroxide (caustic), or
magnesium hydroxide as a precipitant to remove metals as insoluble metal hydroxides. The
effluent metals concentration achieved by hydroxide precipitation depends upon the metals
present, precipitant used, the reaction conditions (especially pH), and the presence of other
materials that may inhibit precipitation. Hydroxide precipitation can achieve effluent metal
concentrations of less than 1 mg/L, and sometimes less than 0.1 mg/L. The solubility of the
metal is directly related to the pH of its environment. Many metals can form low solubility
hydroxides in the pH range of 8.5 to 11.5. Removal of precipitated metals typically involves
adding flocculating agents or polymers to destabilize the hydrodynamic forces that hold the
particles in suspension.32
CBM operators are not currently using chemical precipitation to treat produced
water. This technique, however, could be combined with another treatment option if metal
contaminants in the water are identified as a problem.
Downhole Gas/Water Separation
Downhole gas/water separation (DGWS) is an emerging technology for managing
and disposing of produced water. This type of technology separates the water and gas below the
surface and disposes of the water in a nonproduction zone without bringing the water to the
surface. DGWS can reduce produced water management costs and increase the productive life
and profitability of a well. This technology is not currently being used by CBM operators.
DGWS requires a disposal zone that is isolated from the production zone so that
the injected water will not interfere with gas production. The disposal zone must also be capable
of handling the quantities of water pumped during gas production. A study of DGWS by Radian
International38 that looked at 53 DGWS installations in conventional gas fields in the United
37 U.S. EPA. 2000a. Development document for the proposed effluent limitations guidelines and standards for the
iron and steel manufacturing point source category. EPA/821/B-00/011. Washington, DC. December.
38 Gas Technologies Information. 1999. Technology Assessment and Economic Evaluation of Downhole Gas/Water
Separation and Disposal Tools. GPJ-99/0218, report prepared for the Gas Research Institute by Radian
International.
5-243
-------
Section 5 - Existing Industry Review
States and Canada showed mixed results. Poor performance was due to low injectivity in the
disposal zone, insufficient zone isolation (recycling the water through the production zone), and
poor well-bore integrity. Additional studies show that DGWS systems perform better when
installed in a well with a competent cement sheath, minimal sand production, soft water, water
production of at least 25 to 50 barrels per day, disposal costs of greater than $25 to $50 per day,
and a low-pressure, high-injectivity disposal zone below the producing interval.39
Freeze-Thaw/Evaporation Process
Freezing is a crystallization process that can be used to purify water. When salts
or other constituents are dissolved in water, the freezing point of the solution is lowered below
32°F, the freezing point of pure water. Partial freezing occurs when the solution is cooled to a
point below 32°F but still above the freezing point of the solution. At this point, relatively pure
ice crystals form, along with an unfrozen brine. The brine has a higher density than the ice and
is readily separated. The relatively pure water that results when the ice melts can be directly
utilized for a variety of beneficial uses, or discharged with a NPDES permit.40
To allow more widespread application, the freezing technique has been coupled
with evaporation to allow year-round application. Although EPA does not endorse any specific
technology or vendor, the U.S. Department of Energy, Gas Research Institute, and several oil
and gas operators have been conducting research since 1992 to develop a commercial, natural
freeze-thaw/evaporation purification process for produced waters. This technology is being
tested as part of an automated produced-water treatment and disposal facility in northwestern
New Mexico's San Juan Basin. The tests show that the process has potential in areas where costs
for conventional disposal is high or where the treated water or concentrated brine is of value.34
A freeze-thaw/evaporation process is suitable for portions of the country with climates that range
below freezing.
Harmon SO2 Generator
Harmon Systems International, LLC developed an SO2 generator which can be
used to treat CBM production water.41'42 The Harmon SO2 Generator is a sulfur burner that
controls and maintains pH, carbonates, bicarbonates, and sodium absorption ratio (SAR) in water
and soil. The system oxidizes sulfur into sulfur dioxide gas (SO2) by burning elemental sulfur
with a propane torch in the presence of pressurized water and air. The sulfur dioxide gas is
combined with the CBM produced water to produce sulfurous acid (H2SO3). Sulfurous acid
39 Rudolph, J. 2001. Downhole produced water disposal improves gas rate. GasTIPS 7(3).
40 Gas Research Institute. 1997. Treating produced waters in the San Juan Basin with the freeze-thaw/evaporation
process. See: www.gri.org.
41 Memorandum from Gong, T.R. of Harmon Systems International to Carey Johnston of EPA. May 19, 2004.
42 Harmon Systems International, LLC website. See: http://www.harmonso2generators.com.
5-244
-------
Section 5 - Existing Industry Review
neutralizes the buffering effects of bicarbonates and carbonates in the water, reducing the
alkalinity of the water. The water produced as a result of this process is slightly acidic, similar
to rain water, and can be land applied as irrigation for crops. Since the alkalinity of the water
has been lowered, and bicarbonates and carbonates have been reduced, lime will no longer form
in the soil. Also, additional acidity can be released as the water reacts with bacteria, organic
matter, and dissolved oxygen in the soil. This additional acidity allows lime native to the soils to
dissolve and promote deeper water infiltration in the soil. Salts leach to deeper depths,
preventing salt accumulation on the surface soil.
Summary
At this time, EPA concluded it should not identify this industry for an effluent
guidelines rulemaking. EPA is developing a guidance document for its permitting
responsibilities on Indian lands in Region 8. This guidance will be available for state permitting
authorities to consider using in their permitting efforts. EPA believes that, at this time, the best
approach to controlling pollutant discharges from CBM operations is through use of this
guidance document. This approach will allow EPA to gather additional data on this industry in
order to better assess the hazards and risks associated with these discharges. The guidance
document might also result in pollutant reductions in the near term as compared to pollutant
reductions that may occur at the end of an effluent guideline rulemaking, which typically takes
three to five years. If EPA receives new information on this industry in the future, it will
reconsider this decision as part of future annual reviews.
5.5.9.8 References
1 U.S. EPA. Development Document for Interim Final Effluent Limitations
Guidelines and Proposed New Source Performance Standards for the Oil and
Gas Extraction Point Source Category. EPA-440/l-76/055-a. Washington, D.C.
September 1976.
5.6 Group V Industries
Group V industries are those for which EPA has promulgated new or revised
effluent guidelines within the past seven years. EPA suspects that many categories with effluent
guidelines that have recently been promulgated, but not yet implemented, will appear on the lists
of categories generated in the screening level analysis. In these instances, unless EPA has
information indicating that the specific sources that are driving the identification were not
addressed by the new guidelines, further study of these categories would not be a priority.
Therefore, to focus its inquiry during the 2004 annual review, EPA generally excluded
categories for which it promulgated effluent guidelines within the past seven years. EPA chose
seven years because of the time it takes for effluent guidelines to be incorporated as enforceable
effluent limitations into NPDES permits when they are renewed, which could be up to five years
after the effluent guidelines are promulgated. This time period also allows for the pollutant
reductions associated with recently-promulgated guidelines to be reflected in discharge
monitoring data and
5-245
-------
Section 5 - Existing Industry Review
TRI reports, so that the Agency can assess the potential for remaining risks or hazards. Table
5-183 lists the Group V industries.
However, as explained in the Preliminary Effluent Guidelines Plan, in cases
where EPA is aware of the growth of a new segment within a category for which EPA had
recently revised effluent guidelines, or where new concerns are identified for pollutants
discharged by facilities within the industrial category, EPA may review a recently promulgated
industrial category. Stakeholders raised issues relating to the Metal Products and Machinery
(MP&M) (Part 438), Metal Finishing (Part 433), and Electroplating (Part 413) rulemakings.
Finally, Commenters also raised issues on Subparts D and E of the Pulp and Paperboard ELG
(Part 430). As a result, EPA reviewed the aforementioned recently promulgated regulations as
part of its 2004 review. Each of these are discussed below.
Table 5-183. Effluent Guidelines Recently Established, Revised, or Reviewed
CFR
Part
Title
Promulgation Date
(FR Citation)
Subparts
Established/Revised/Reviewed
451
Aquatic Animal
Production
June 30. 2004
(69 FR 51891)
BMPs for Subpart A (Flow-through and Recirculating
Systems) and Subpart B (Net Pen) were established
forBPT.BAT, and NSPS.
432
Meat and Poultry
Products
February 26, 2004
The following subparts were revised:
Subparts A-D: Meat First Processors (Non-small)
Subparts F-I: Meat Further Processors (Non-small)
Subpart J: Independent Renderers
Subpart K: Poultry First Processors
Subpart L: Poultry Further Processors
438
Metal Products &
Machinery
May 13, 2003
(68 FR 25686)
The following subpart was established within this
new point source category:
Subpart A: Oily Waste
The following industry sectors were reviewed:
Railroad Line Maintenance
Facilities (no effluent guidelines)
Shipbuilding Dry
Docks (no effluent guidelines)
Metal Finishing (Part 433)
Electroplating (Part 413)
5-246
-------
Section 5 - Existing Industry Review
Table 5-183 (Continued)
CFR
Part
Title
Promulgation Date
(FR Citation)
Subparts
Established/Revised/Reviewed
412
Concentrated
Animal Feeding
Operations
February 12, 2003
(68 FR 7176)
The following subpart was revised:
Subpart A: Horses and Sheep
The following subpart was reviewed:
Subpart B: Ducks
The following subparts were established:
Subpart C: Dairy Cows and Cattle Other
Than Veal Calves
Subpart D: Swine, Poultry, and Veal
Calves
Note: Subparts C and D were previously included in
Subpart A
420
Iron & Steel
October 17. 2002
(67 FR 64216)
The following subpart was established within this
existing point source category:
Subpart M: Other Operations
The following subparts were revised within this
existing point source category:
Subpart A: Cokemaking
Subpart B: Sintering
Subpart C: Iromnaking
Subpart D: Steehnaking
The following subparts were reviewed within this
existing point source category:
Subpart E: Vacuum Degassing
Subpart F: Continuous Casting
Subpart G: Hot Forming
Subpart H: Salt Bath Descaling
Subpart I: Acid Pickling
Subpart J: Cold Forming
Subpart K: Alkaline Cleaning
Subpart L: Hot Coating
434
Coal Mining
January 23, 2002
(67 FR 3370)
The following subparts were established within this
existing point source category:
Subpart G: Coal Remining
Subpart H: Western Alkaline Coal
Mining
435
Oil and Gas
Extraction
January 22, 2001
(66 FR 6850)
BAT limitations and NSPS for nonaqueous drilling
fluids were revised within the following subcategories
within this existing point source category:
Subpart A: Offshore
Subpart D: Coastal
5-247
-------
Section 5 - Existing Industry Review
Table 5-183 (Continued)
CFR
Part
Title
Promulgation Date
(FR Citation)
Subparts
Established/Revised/Reviewed
437 Centralized Waste
Treatment
December 22, 2000
(65 FR 81242)
The following subparts were established within this
new point source category:
Subpart A: Metals Treatment and
Recovery
Subpart B: Oils Treatment and Recovery
Subpart C: Organics Treatment and
Recovers'
Subpart D: Multiple Wastestreams
442
Transportation
Equipment
Cleaning
August 14, 2000
(65 FR 49666)
The following subparts were established within this
new point source category:
Subpart A: Tank Trucks and Intennodal
Tank Containers Transporting
Chemical and Petroleum
Cargos
Subpart B: Rail Tank Cars Transporting
Chemical and Petroleum
Cargos
Subpart C: Tank Barges and Ocean/Sea
Tankers Transporting
Chemical and Petroleum
Cargos
Subpart D: Tanks Transporting Food
Grade Cargos
444
Waste
Combustors
January 27, 2000
(65 FR 4360)
The following subpart was established within this
new point source category:
Subpart A: Commercial Hazardous
Waste Combustor
445
Landfills
January 19.2000
(65 FR 3007)
The following subparts were established within this
new point source category:
Subpart A: RCRA Subtitle C Hazardous
Waste Landfill
Subpart B: RCRA Subtitle D
Nonhazardous Waste Landfill
441
Industrial
Laundries
August 18, 1999
(64 FR 45072)
The following point source category was reviewed:
Facilities that launder industrial textile items from off
site as a business activity.
439
Pharmaceutical
Manufacturing
September 21, 1998
(63 FR 50388)
The following subparts were revised within this
existing point source category:
Subpart A: Fermentation Products
Subpart B: Extraction Products
Subpart C: Chemical Synthesis
Subpart D: Mixing/Compounding and
Formulation
5-248
-------
Section 5 - Existing Industry Review
CFR
Part
430
Title
Pulp, Paper, and
Paperboard
Promulgation Date
(FR Citation)
April 15, 1998
(63 FR 18504)
Subparts
Established/Revised/Reviewed
The following subparts were revised within this
existing point source category:
Subpart B: Bleached Papergrade Kraft and
Soda
Subpart E: Papergrade Sulfite
5.6.1 Metal Products and Machinery, Metal Finishing, and Electroplating (Parts
438, 413, and 433)
5.6.1.1 Background
The metal finishing effluent guidelines (40 CFR Part 433) were promulgated in
1983 and regulate a wide variety of industries performing various metal finishing operations.
EPA estimates that there are approximately 44,000 facilities performing various metal finishing
operations that discharge process wastewater directly to surface waters or indirectly to surface
waters through POTWs.43 Most of these 44,000 facilities are indirect dischargers and are
regulated by the metal finishing effluent guidelines. EPA recently reviewed these effluent
guidelines as part of the MP&M effluent guidelines (see May 13, 2003; 68 FR 25686). Due to a
variety of factors identified in the preamble to the final MP&M rule, EPA did not revise the
metal finishing effluent guidelines.
A number of POTWs and metal finishing facilities suggested in public comments
on the Preliminary Plan (see December 31, 2003; 68 FR 75515) that iron phosphate conversion
coating should excluded from the list of core operations in the metal finishing effluent
guidelines. Phosphate conversion coating is defined as a "core"operation under the metal
finishing effluent guidelines (Part 433.10(a)). Facilities that perform a core operation are subject
to the metal finishing effluent guidelines. Consequently, metal finishing facilities performing
phosphate conversion coating operations are currently subject to the metal finishing effluent
guidelines.
The metal finishing effluent guidelines do not distinguish among the various types
of phosphate conversion coating operations (e.g., iron, zinc, nickel). All phosphate conversion
coating operations are regulated as a "core"operation under the metal finishing effluent
guidelines (Part 433.10(a)). However, some phosphate conversion coating baths contain high
concentrations of toxic metals (e.g., zinc or nickel) while other phosphate conversion coating
processes use a phosphoric acid or phosphate salt solution that contain much lower
concentrations of toxic metals. The rinses from iron phosphate conversion coating operations
contain very low concentrations of toxic metals and are often well below the metal finishing
effluent guidelines.
43Metal Products and Machinery Final Rule, Technical Development Document, EPA-821-B-03-001, Page 4-2.
5-249
-------
Section 5 - Existing Industry Review
5.6.1.2 Public Comments
A number of POTWs and metal finishing facilities suggested in public comments
on the Preliminary Plan that iron phosphate conversion coating should be excluded from the list
of core operations in the metal finishing effluent guidelines. Commenters cite EPA's more recent
MP&M rulemaking record (including analytical wastewater sampling data) that identifies iron
phosphate conversion coating as an industrial operation with low concentrations of metals. EPA
documented for the MP&M rulemaking that iron phosphate conversion coating does not require
metals treatment (e.g., chemical precipitation and settling) and can be adequately treated by oily
wastewater treatment (e.g., emulsion breaking and oil-water separation).
Commenters cited several benefits for taking such an action. First, commenters
suggest a pollution prevention benefit. If EPA were to exclude iron phosphate conversion
coating from the list of regulated "core"operations under the metal finishing effluent guidelines,
some metal finishing facilities might wish to lower their monitoring and record-keeping costs
and switch from zinc or nickel phosphate conversion coating to iron phosphate conversion
coating. This switch would have an added benefit of potentially reducing metals discharges.
Second, commenters suggest that revising the list of core metal finishing operations might help
lower the oversight burden for POTW pretreatment control program and focus more of their
inspection and monitoring budgets on facilities with higher toxic pollutant loadings. The third
benefit identified by commenters is that POTWs would not necessarily be required to develop a
pretreatment control program if they accept iron phosphate conversion coating wastewaters.
Commenters suggest that this may help focus more attention on facilities with higher toxic
pollutant loadings and help lower the state and EPA oversight burden of POTW pretreatment
control programs.
5.6.1.3 EPA Review of Available Data
EPA attempted to quantify the number of metal finishing facilities that perform
iron phosphate conversion coating and whether the wastewaters from these facilities are directly
or indirectly discharged to surface waters. EPA reviewed unit processes (UP) data from the
MP&M database to answer the following questions:
1. What are the national estimates of direct and indirect discharging facilities
subject to metal finishing and/or electroplating (Part 413 or 433)
performing: (1) iron phosphate conversion coating; and (2) other
phosphate conversion coating (e.g., zinc, nickel)?
2. What are the national volume estimates of wastewater (MGY) associated
with the following operations: (1) iron phosphate conversion coating; and
(2) other phosphate conversion coating (e.g., zinc, nickel)?
3. What are the national estimates of POTWs accepting wastewaters from:
(1) iron phosphate conversion coating; and (2) other phosphate conversion
coating (e.g., zinc, nickel)?
5-250
-------
Section 5 - Existing Industry Review
There were significant data limitations in reviewing MP&M data. Specifically,
only 5 of the 196 MP&M survey sites performing conversion coating without chromium (UP-14)
responded in a way that allowed EPA to differentiate between iron phosphate conversion coating
and other types of phosphate conversion coating. All five of these MP&M survey sites are
indirect dischargers. EPA estimates that some of the remaining 191 sites also perform iron
phosphate conversion coating. Consequently, the answers to the above three questions are
provided below as a ranges.
National Estimates of Metal Finishers Performing Conversion Coating Without
Chromium
Using information from the 196 MP&M survey sites, EPA estimates that
nationally there are 3,617 facilities regulated by either Part 413 or 433 that perform conversion
coating without chromium (UP-14). Of these 196 survey sites, 180 are indirect dischargers and
16 are direct dischargers. EPA estimates that these 180 and 16 survey sites represent national
estimates of 3,420 indirect dischargers and 197 direct dischargers, respectively. As previously
stated, none of the five MP&M survey sites clearly identified as performing iron phosphate
conversion coating were direct dischargers. However, it is possible that some of the 16 survey
sites (197 national estimate) perform only iron phosphate conversion coating. Using information
from the 180 indirect discharging MP&M survey sites, the national estimate of metal finishing
indirect dischargers performing iron phosphate conversion coating ranges between 213 and
3,420 facilities.
National Volume Estimates of Wastewater
For both direct and indirect dischargers at the national level (3,617 facilities),
EPA estimates 6,100 MGY of process and rinse wastewater are generated from conversion
coating without chromium (UP-14). Using information from the 180 indirect discharging
MP&M survey sites, the national wastewater estimate from metal finishing indirect dischargers
performing iron phosphate conversion coating ranges between 96 MGY and 6,100 MGY. EPA
was unable to estimate the national wastewater estimate from metal finishing direct dischargers
performing iron phosphate conversion coating, as EPA did not clearly identify any metal
finishing direct dischargers performing iron phosphate conversion coating.
National Estimates of POTWs Accepting Conversion Coating Without Chromium
Wastewater
To estimate the number of POTWs accepting wastewater from iron phosphate
conversion coating operations, EPA used a conservative assumption that each metal finisher
discharges to a separate POTW (i.e., one POTW per metal finisher). This assumption will likely
overestimate the number of POTWs accepting wastewater from iron phosphate conversion
coating operations but does help provide an upper bound estimate. Using information from the
180 indirect discharging MP&M survey sites, the national estimate of POTWs accepting
5-251
-------
Section 5 - Existing Industry Review
wastewater from iron phosphate conversion coating operations ranges between 213 and 3,420
POTWs.
5.6.1.4 Conclusions
As previously stated, EPA did not clearly identify any metal finishing direct
dischargers perform iron phosphate conversion coating. However, it appears that most metal
finishing facilities performing iron phosphate conversion coating are indirect dischargers.
Consequently, EPA will address the issue of iron phosphate conversion coating and potential
revisions to the Metal Finishing (Part 433) effluent guidelines in its CWA Section 304(g)
pretreatment standards planning process.
5.6.2 Pulp and Paperboard (Part 430)
5.6.2.1 Technology Basis for Phase I
EPA promulgated effluent limitations guidelines and standards for Phase I of the
Pulp, Paper, and Paperboard category in 1998. Phase I includes Subpart B, Bleached
Papergrade Kraft and Soda, and Subpart E, Papergrade Sulfite. EPA divided Subpart E into
three segments. The technology basis of promulgated regulations for the calcium-, magnesium-,
or sodium-based sulfite segment was totally chlorine free (TCP) bleaching.
The technology basis of promulgated regulations for Subpart B, Bleached
Papergrade Kraft and Soda was elemental chlorine free (ECF) bleaching, consisting of
conventional pulping followed by complete substitution of chlorine dioxide for elemental
chlorine, as well as the following nine elements:
(i) Adequate chip thickness control;
(ii) Closed brownstock pulp screen room operation, such that screening
filtrates are returned to the recovery cycle;
(iii) Use of dioxin- and furan-precursor-free defoamers (i.e., water-based
defoamers or defoamers made with precursor-free oils);
(iv) Effective brownstock washing, i.e., washing that achieves a soda loss of
less than or equal to 10 kg Na2SO4 per ADMT of pulp (equivalent to
approximately 99 percent recovery of pulping chemicals from the pulp);
(v) Elimination of hypochlorite, i.e., replacement of hypochlorite with
equivalent bleaching power in the form of additions of peroxide and/or
oxygen to the first extraction stage and/or additional chlorine dioxide in
final brightening stages;
5-252
-------
Section 5 - Existing Industry Review
(vi) Oxygen- and peroxide-enhanced extraction, which allows elimination of
hypochlorite and/or use of a lower kappa factor in the first bleaching
stage;
(vii) Use of strategies to minimize kappa factor and dioxin- and furan-
precursors in brownstock pulp;
(viii) High shear mixing during bleaching to ensure adequate mixing of pulp
and bleaching chemicals; and
(ix) Efficient biological wastewater treatment, achieving removal of
approximately 90 percent or more of influent BOD5.
EPA considered another technology option, Option B, which was identical to the
basis of the promulgated BAT, with the addition of extended delignification (oxygen
delignification and/or extended cooking). EPA also considered a TCP option for BAT and
NSPS.
EPA determined that no technology option other than the promulgated BAT was
both available and economically achievable or resulted in greater reductions in effluent loadings
for dioxin, furan and other significant pollutants of concern.
EPA estimated that the cost of the promulgated BAT was $966 million vs $2.1
billion for Option B (1995 dollars) . EPA estimated the costs for a TCP option ranged from $3
billion to $5.6 billion.
EPA concluded that neither Option B nor a TCP option was economically
achievable for the Bleached Papergrade Kraft and Soda subcategory as a whole. However, in
addition to BAT, EPA promulgated voluntary alternative BAT limitations and PSES based on
Option B and TCP bleaching processes in order to encourage mills to use these technologies
whenever possible.
5.7 Group VI Industries
Group VI industries are those that ranked low in terms of potential hazard or risk
in EPA's screening-level analysis. In addition, none of these industries were identified by
stakeholders during EPA's 2003 effluent guidelines review. For its 2004 effluent guidelines
review, EPA considered whether it had any reason to believe that the information it relied upon
in its 2003 annual review had changed significantly. EPA determined that it didn't have any
reason to believe the information has changed, nor did commenters or stakeholders provide any
rationale for revising its earlier conclusions. Therefore, EPA did not conduct any additional
analysis with respect to these Group VI industries in its 2004 annual review. Table 5-184 lists
the Group VI industries.
5-253
-------
Section 5 - Existing Industry Review
Table 5-184. Low Ranked Industries Not Identified by Stakeholders
Industrial Category
Aluminum Forming
Asbestos Manufacturing
Battery Manufacturing
Carbon Black Manufacturing
Cement Manufacturing
Copper Forming
Explosives Manufacturing
Ferroalloy Manufacturing
Glass Manufacturing
Grain Mills Manufacturing
Gum and Wood Chemicals
Flospitals
Ink Formulating
Leather Tanning and Finishing
Nonferrous Metals Forming and Metal
Powders
Paint Formulating
Paving and Roofing Materials
Pesticide Chemicals
Photographic
Plastic Molding and Forming
Porcelain Enameling
Rubber Manufacturing
Soaps and Detergent Manufacturing
Sugar Processing
40CFR
Part
467
427
461
458
411
468
457
424
426
406
454
460
447
425
471
446
443
455
459
463
466
428
417
409
TRI
TWPE
25,000
6
8,000
0
11,000
22,000
381
22,000
1,900
8,900
50
720
51
29,000
100,000
920
35
320,000
N/A
1 10,000
92,000
170,000
360
280
TRI Point
Source Category
Ranking
19
44
29
45
26
23
35
22
31
28
39
NA
38
18
12
34
40
8
N/C
10
13
9
36
37
PCS
TWPE
100,000
N/A
0
N/A
15,000
5,600
5,600
8,800
0
479
42,000
5
N/A
5,500
15,000
N/A
710
180,000
0
3,700
54,000
8,700
164
16,000
PCS Point Source
Category
Ranking
11
N/C
40
N/C
22
27
28
24
42
35
14
NA
N/C
29
23
N/C
34
9
41
31
13
25
37
21
NA - Rank not applicable. Point source category excluded because ELG recently developed.
N/A - Not available.
N/C - Not calculated due to lack of PCS or TRI data.
However, EPA notes that, as part of this review, it considered developing
additional subcategories for three of the above regulations: Soaps and Detergent Manufacturing
(417), Paint formulating (446), and Ink Formulating (447). As part of its review of OCPSF, EPA
reviewed the chemical formulator packaging and repackaging (CFPR) industry. EPA studied
this industry in 1997. At the time of that study, EPA included SIC codes 2841, 2851, and 2893
5-254
-------
Section 5 - Existing Industry Review
because a portion of the facilities reporting these SIC codes are not specifically included in
existing applicabilities of Parts 417, 446, or 447 and could be considered part of the CFPR
industry. Due to data limitations, EPA had no way to differentiate facilities that were included in
existing point source categories and facilities that were part of CFPR. Therefore, EPA included
all facilities reporting SIC codes 2841, 2851, and 2893 in the 1997 CFPR study. However, for
this review, EPA considered any operations outside of the current applicability of existing
effluent guidelines as potential new subcategories of the respective category. Consequently,
these SIC codes were included in the review of Parts 417, 446, and 447 and not considered part
of the CFPR industry evaluated as part of the OCPSF review.
EPA notes that the total TWPE estimates for Parts 417, 446, and 447 include all
facilities that report SIC codes 2841, 2851, or 2893, respectively. Therefore, the TWPE
estimates for these categories include discharges from facilities that may not be specifically
included in the existing applicabilities of Parts 417, 446, and 447. As indicated above, even with
these potential new facilities, these categories rank low in terms of potential toxic wastewater
pollutant indicating additional subcategorization is not warranted. EPA recommends permit
writers subject such facilities to the applicable existing limitations on a BPJ basis. Permit
writers may also want to review and consider pollution prevention alternatives described in
EPA's Pollution Prevention (P2) Guidance Manual: Implementing the P2 Alternative (EPA-
821-B-98-017, June 1998) developed for Pesticide Formulating Packaging and Repackaging
(PFPR) facilities. Because many of the operations and wastewater sources at these facilities are
similar to those at PFPR facilities, EPA believes the pollution prevention practices identified for
PFPR facilities may also be applicable.
Medical and Dental Laboratories
Stakeholders in previous outreach identified independent and stand alone
laboratories for new ELG development. This industry may be identified by various SIC codes
including 8071, 8072, 8731, and 8734. The SIC code description for each is described below:
• SIC code 8071: Medical Laboratories. Establishments primarily engaged
in providing professional analytic or diagnostic services to the medical
profession, or to the patient on prescription of a physician.
• SIC code 8072: Dental Laboratories. Establishments primarily engaged
in making dentures, artificial teeth, and orthodontic appliances to order for
the dental profession. Establishments primarily engaged in manufacturing
artificial teeth, except to order, are classified in SIC code 3843, and those
providing dental X-ray laboratory services are classified in SIC code
8071.
• SIC code 8731: Commercial Physical and Biological Research.
Establishments primarily engaged in commercial physical and biological
research and development on a contract or fee basis. Noncommercial
research establishments funded by endowments, grants, or contributions
5-255
-------
Section 5 - Existing Industry Review
are classified in SIC code 8733. Separate establishments of aircraft,
guided missile, or spacecraft manufacturers primarily engaged in research
and development on these products are classified in Manufacturing, SIC
Major Group 37.
• SIC code 8734: Testing Laboratories. Establishments primarily engaged
in providing testing services. Establishments primarily engaged in
performing clinical laboratory testing for the medical profession are
classified in SIC code 8071.
EPA reviewed the applicability of existing ELGs to determine if discharges from
stand- alone and independent laboratories were already subject to existing ELGs. EPA found
that there are no ELGs that currently apply to discharges from stand-alone and independent
laboratories.
Next, EPA evaluated whether discharges from medical laboratory facilities (SIC
code 8071) and dental laboratory facilities (SIC code 8072) should be addressed as a potential
new subcategory under Hospitals (40 CFR Part 460). Part 460 applies to the wastewater
discharges from a variety of activities at hospitals including on-site medical laboratories.
Operations included as part of SIC code 8071, medical laboratories, are health care related.
Many of the operations present at these facilities are similar to operations present at hospitals (x-
rays, blood analysis, etc). Operations classified as part of SIC code 8072, dental laboratories,
produce mercury as the main pollutant of concern. Mercury is also a pollutant of concern for
hospital wastewater. Therefore, EPA determined medical and dental laboratories are
appropriately considered as a potential new subcategory of 40 CFR Part 460.
In this review, EPA also considered whether it should consider develop
limitations and standards for additional subcategories of this ELG for medical laboratory
facilities (SIC code 8071) and dental laboratory facilities (SIC code 8072). EPA concluded it
was not appropriate to develop new ELGs for these subcategories because discharges rank low
relative to other industrial categories.
5-256
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
SECTION 6 ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS
DETAILED REVIEW
6.1 Introduction
EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)
Point Source Category (40 CFR Part 414) for further review because it ranked highest among all
point source categories in toxic, priority, and nonconventional pollutant discharges (in pounds)
in the screening-level analysis for 2000. Also in the screening-level analysis, EPA found that, by
far, the toxic pollutant loadings are driven by three pollutants: polycyclic aromatic compounds
(PACs), aniline, and dioxin. EPA reviewed the facilities that reported discharging these
pollutants and identified groups of facilities with common manufacturing processes that
discharged the same pollutants. In the case of PACs, EPA identified coal tar refiners; for aniline,
EPA identified aniline and dye manufacturers; and for dioxin, EPA identified vinyl chloride
manufacturers and other organic chemicals manufacturers.
For the detailed review of OCPSF, EPA further verified Toxic Release Inventory
(TRI) and Permit Compliance System (PCS) data, collected and analyzed additional industry
data, reviewed the existing regulations for this industrial category, and evaluated potential new
subcategories to be considered. In addition, for the three groups of facilities identified above,
EPA analyzed current discharges, treatment in place, and industry trends.
EPA also analyzed data associated with facilities that formulate, package, and
repackage chemicals into products for end use or for further processing to determine if new
subcategories of OCPSF should be identified and further studied for this sector.
This section discusses EPA's analysis of the OCPSF category and its conclusions
in the following order:
• Section 6.2 discusses data sources used, EPA's verification of the data,
and the data source limitations;
• Section 6.3 discusses the OCPSF industry profile and EPA's identification
of three focus industries;
• Section 6.4 discusses the current OCPSF effluent limitations guidelines
and standards (40 CFR Part 414);
• Section 6.5 discusses other federal regulations affecting OCPSF;
• Section 6.6 discusses EPA's analysis and findings for coal tar refiners;
• Section 6.7 discusses EPA's analysis and findings for aniline dischargers;
6-1
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Section 6.8 discusses EPA's analysis and findings for dioxin dischargers;
• Section 6.9 discusses control of dioxin-laden wastewater, including
pollution prevention and wastewater treatment technologies;
• Section 6.10 discusses EPA's findings on chemical formulating,
packaging, and repackaging (CFPR) operations; and
• Section 6.11 includes the list of references.
6.2 Data Sources
This section discusses the following data sources specifically as they pertain to
the OCPSF detailed review:
• Section 6.2.1 discusses TRI data limitations and verification;
• Section 6.2.2 discusses PCS data limitations and verification;
• Section 6.2.3 discusses data obtained from the Chlorine Chemistry
Council;
• Section 6.2.4 discusses data obtained from the Vinyl Institute;
• Section 6.2.5 discusses data obtained from EPA's Office of Solid Waste
(OSW) rule on chlorinated aliphatics manufacture;
• Section 6.2.6 discusses data obtained from EPA's Office of Air and
Radiation (OAR) rule on mercury emissions from mercury cell chlor
alkali plants; and
• Section 6.2.7 discusses other sources that EPA used for this review.
Section 4.2 of this Technical Support Document discusses TRI and PCS. Section
4.2.4 discusses the calculation of toxic-weighted pound equivalents (TWPE) for certain data
sources.
6.2.1 Toxic Release Inventory (TRI)
All OCPSF facilities that meet the employee criterion (i.e., 10 or more
employees) and the chemical threshold(s) must submit reports to EPA's TRI program. Of the
1,570 OCPSF facilities operating in the United States (U.S.) in 2000 (1), 992 (63 percent)
reported to TRI in 2000. EPA used data reported to TRI to estimate pollutant loadings and
identify treatment in place for this category.
6-2
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
For the OCPSF detailed review, EPA verified TRI data, particularly for those
facilities and pollutants with high TWPE. For example, facilities may estimate releases in a
number of ways when reporting to TRI. If a chemical is not detected in the effluent, facilities
may estimate the discharge by using one-half of the detection limit. This may overestimate the
amount of chemical discharged, which particularly affected the amount of PACs discharges
reported for the OCPSF industry, as discussed below.
Facilities report some chemicals as groups to TRI, including the 21 chemicals
included in the PAC category. Facilities are required to report the combined mass of PACs
released to TRI. They do not identify which compounds are released and they do not report
releases of individual PAC compounds to TRI. EPA looked to other data sources to identify the
individual PACs that may be present in OCPSF discharges. Benzo(a)pyrene was the only PAC
reported in PCS by OCSPF facilities. Therefore, to calculate the TWPE of the PACs reported in
TRI, EPA used the toxicity weighting factor (TWF) for benzo(a)pyrene to represent all PACs.
Because the TWF for benzo(a)pyrene is higher than any other PAC, this represents a worst-case
scenario.
Another TRI chemical group that contributes significantly to EPA's estimate of
toxic pounds discharged is dioxin. Facilities are required to report the combined mass of dioxin
and dioxin-like compounds released, and they are given the opportunity to report a facility-
specific congener distribution. The congener distribution provided by the facility represents
releases of dioxin to all media (e.g., air and solids) and may not accurately reflect the specific
congeners discharged to surface water. Section 6.8 of this section discusses dioxin TWPE for
OCPSF Focus Group 3 (Dioxin Dischargers) in more detail. See also Section 4.2.4.2 for a more
detailed discussion on dioxins and the calculation of TWPE for dioxin.
To verify the data reported to TRI, EPA performed the following activities:
• Contacted certain facilities to discuss reported discharges, discussed in
Section 6.2.1.1;
• Reviewed comments submitted in response to the December 31, 2003
Preliminary Effluent Guidelines Program Plan, FRN FRL-7604-7,
discussed in Section 6.2.1.2;
• Removed TWPE from polychlorinated biphenyls (PCBs) and pesticides,
discussed in Section 6.2.1.3; and
• Used industry-provided data to compare pollutant discharges, discussed in
Section 6.2.4 (Chlorine Chemistry Council Data).
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.2.1.1 Facility-Specific Verification of TRI Data
For facilities that contributed significantly to the overall TWPE estimate for this
industry or for facilities for which EPA received specific comment, EPA verified the TRI data.
ExxonChemical reported the following releases of PACs to surface water from its
Baton Rouge plant: 1,801 pounds (7.7 million TWPE) in 2000 and 8,324.9 pounds (36 million
TWPE) in 2001. EPA contacted ExxonChemical to 1) verify the discharge of PACs for 2000
and 2001 and determine what caused the increase and 2) determine the primary constituents in
the PACs discharges from this facility.
As stated in a letter dated August 21, 2003 in response to EPA's questions,
ExxonChemical analyzed wastewater samples collected in 2000 and 2001 (see DCN00336) for
PACs, but never detected these compounds. Although analytical data demonstrate PACs were
not detected in wastewater from this facility, the facility chose to calculate the PAC discharge
using one-half of the detection limit for the concentration estimates. As explained in Section
4.2.1, this is consistent with guidance provided by EPA in reporting to TRI.
Based on this information, for the purpose of this analysis, EPA set the PAC
pounds released to surface water from ExxonChemical's Baton Rouge plant to zero for 2000 and
2001 in TRIReleases2000. (TRIReleases2000 is the database that EPA created for analyses for
the 2004 annual review. Please see Section 4.2.1 of this TSD for more information.)
6.2.1.2 Data Submitted with Comments
EPA published a Preliminary Effluent Guidelines Program Plan on December 31,
2003 for public comment. EPA received no TRI-related data from commenters and no
comments from facilities requesting corrections to 2000 TRI data. EPA did receive comments
that OCPSF facilities reduced their pollutant discharges since 2000, and that 2002 data would
more accurately reflect the current discharges. Also, EPA received dioxin data from some
facilities in the Chlorine Chemistry Council under the National Program Chemicals Division,
which is discussed in Section 6.2.4.
6.2.1.3 Correction for PCBs and Pesticides
For the screening-level analysis, EPA assigned pollutant loadings to point source
categories based on the primary SIC code that facilities reported. Facilities might have mainly
OCPSF operations, but also some co-located pesticide operations. Some facilities reported
discharges of picloram and total carbaryl, but discharges from picloram and total carbaryl
manufacturing are subject to Effluent Limitations Guidelines for the Pesticides Chemical Point
Source Category (40 CFR Part 455). For the detailed analysis, EPA included the pollutant loads
associated with these pesticides with the Pesticide Chemicals category instead of OCPSF.
6-4
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
PCBs are no longer in commerce, and the mass reported discharged to TRI is
most likely not being generated by current processes. Therefore, EPA removed all TWPE
associated with PCBs in TRIReleases2000 for this analysis.
6.2.2 Permit Compliance System (PCS)
As explained in Section 4.2.2, states submit data from facilities' discharge
monitoring reports (DMRs) to EPA's PCS. The data from each DMR will vary depending on the
facility's National Pollutant Discharge Elimination System (NPDES) permit requirements.
Two of the pollutants with the highest TWPE - dioxins and aniline - are not
currently regulated by 40 CFR Part 414. Monitoring of these pollutants is not generally required
by NPDES permits. Therefore, EPA only has PCS data from facilities where additional state or
local limits apply, as discussed in Sections 6.7 and 6.8.
To verify the data reported to PCS, EPA performed the following activities:
• Reviewed comments submitted in response to the December 31, 2003
Preliminary Effluent Guidelines Program Plan, FRN FRL-7604-7,
discussed in Section 6.2.2.1, and
• Removed TWPE from polychlorinated biphenyls (PCBs) and pesticides,
discussed in Section 6.2.2.2.
6.2.2.1 Data Submitted with Comments
In response to the December 31, 2003 Preliminary Effluent Guidelines Program
Plan., EPA received a request from the American Chemistry Council (ACC) for corrections to
PCS data for the Celanese Acetate LLC plant in Rock Hill, South Carolina (NPDES Permit ID
SC0001783). ACC provided information from the facility verifying that all data except for
ammonia and two metals (nickel and zinc) were reported as not detected, and that Celanese
Acetate previously submitted a request for correction to PCS. In this case, EPA corrected the
PCSLoads2000 database to reflect the facility-verified data.
General Electric and DuPont submitted comments that they generally disagreed
with EPA's methodology regarding concentrations measured below detection limits in PCS. The
commenters stated that EPA's methodology overestimated PCS loads because of detection limit
considerations. For example, as explained in Section 4.2.2, if a facility never detects a pollutant
in a year, EPA sets the load to zero for that pollutant in PCSLoads2000. However, if a pollutant
is detected at any point during the year, EPA calculates annual pollutant loads using the detected
values and one half the method detection limit for months with no detects. Although DuPont and
General Electric provided qualitative data, they did not provide analytical data to support their
assertions. These commenters instead gave general information (e.g., all pollutant loads, except
for ammonia and nickel, should be zero for their OCPSF facilities). In these cases, where
6-5
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
companies did not provide specific monitoring data, EPA did not change the PCSLoads2000
database.
6.2.2.2 Correction for PCBs and Pesticides
For the screening-level analysis, as with TRI data, EPA assigned pollutant
loadings to point source categories based on the primary SIC code that facilities reported.
Facilities may have mainly OCPSF operations, but also some co-located pesticide operations.
Some facilities reported discharges of picloram and total carbaryl, but discharges from picloram
and total carbaryl manufacturing are covered by Effluent Limitations Guidelines for the
Pesticides Chemical Point Source Category (40 CFR Part 455). For this analysis of PCS data,
EPA included the pollutant loads associated with these pesticides with the Pesticide Chemicals
category instead of OCPSF.
PCBs are no longer in commerce, and the mass reported discharged to PCS is
most likely residual - not being generated by current processes. Therefore, EPA removed all
TWPE associated with PCBs in PCSLoads2000.
6.2.3 Economic Census
The 1997 U.S. Economic Census provides an upper bound on the number of
facilities performing operations that fall under the OCPSF category. The census may overstate
the number by including nonproduction facilities, such as sales locations. For these reasons, EPA
used census data only as a point of reference in the OCPSF detailed review.
6.2.4 The Chlorine Chemistry Council
As stated on its web page (http://www.c3.org), the Chlorine Chemistry Council
(CCC) is a national trade association representing the manufacturers and users of chlorine and
chlorine-related products. It is also a business council of the ACC. Members of the CCC
provide media-specific data to the public on their dioxin discharges on the CCC web page, in
part because the CCC is concerned that TRI reporting requirements overstate the amount of
dioxin discharged. As of June 2004, the CCC posts data for 2000, 2001, and 2002.
Facilities provided media-specific dioxin release data to the CCC. The congener
distribution can greatly affect the estimated toxicity of a dioxin discharge. For example, the
2,3,7,8-tetrachlorodibenzo(p)dioxin (2,3,7,8-TCDD) congener (TWF = 421,600,000) is much
more toxic than the 1,2,3,4,6,7,8,9-octachlorodibenzofuran (OCDF) congener (TWF = 67,367).
Also, the congener distribution of dioxin in air can differ greatly from that in water, and the
media-specific data can differ greatly from the TRI congener distribution that is intended to
apply to all media. EPA revised the TWFs for dioxins in 2004. The memorandum entitled
Revisions to TWFs for Dioxin and its Congeners and Recalculated TWPEs for OCPSF and
Petroleum Refining (available in the docket) presents the estimated TWPE for OCPSF facilities
using the revised TWFs.
6-6
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
For this detailed review, EPA used all available CCC dioxin data, which included
facility-specific data from the following companies:
• Dow Chemical;
• Occidental Chemical (as well as joint ventures Oxy Vinyls and Oxychem);
PPG;
• Vulcan;
• Formosa;
• Georgia Gulf; and
• Borden Chemicals and Plastics.
In addition, the CCC voluntarily provided more specific, verified dioxin discharge
data to EPA's National Program Chemicals Division (NPCD) for the 2000 EPA Dioxin
Inventory. Section 6.8, the Dioxin Dischargers section, discusses these data in more detail.
6.2.5 The Vinyl Institute
According to its web site (http://www.vinylinstitute.org). the Vinyl Institute is a
U.S. trade association representing the leading manufacturers of vinyl, vinyl chloride monomer
(VCM), vinyl additives and modifiers, and vinyl packaging materials. The Vinyl Institute
published a report entitled, "The Vinyl Institute Dioxin Characterization Program" on July 1,
2002. From this report, EPA identified the facilities that manufacture ethylene dichloride
(EDC), VCM, and polyvinyl chloride (PVC). EPA also used data presented in the report from an
industry study that tested wastewater from EDC/VCM and PVC manufacturing and PVC resins
for dioxin, presented in Section 6.8. The study concluded that PVC products such as pipes do
not contain dioxin and are safe to use, but that dioxin may be found in wastewater from EDC,
VCM, and PVC manufacture.
6.2.6 Office of Solid Waste Chlorinated Aliphatics Rule
EPA's Office of Solid Waste (OSW) promulgated a hazardous waste rule on
Chlorinated Aliphatics Production Wastes on November 8, 2000. As part of the analysis
supporting the rulemaking, OSW collected sampling data on six types of waste (19):
• Wastewaters generated from the production of VCM using mercuric
chloride catalyst in an acetylene-based process (VCM-A wastewaters, not
listed);
• Wastewaters from the production of chlorinated aliphatic hydrocarbons,
except for wastewaters generated from the production of VCM using
mercuric chloride catalyst in an acetylene-based process (proposed as
K173 waste but not listed);
• Wastewater treatment sludges from the production of VCM using
mercuric chloride catalyst in an acetylene-based process (listed as K175);
6-7
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Wastewater treatment sludges from the production of EDC or VCM (listed
as K174);
• Wastewater treatment sludges from the production of methyl chloride (not
listed); and
• Wastewater treatment sludges from the production of allyl chloride (not
listed).
OSW sampled untreated wastewater effluent at the point of entry into biological
treatment for K173 waste (chlorinated aliphatic hydrocarbons). In the Best Demonstrated
Available Technology (BDAT) report, OSW presents the results for the plants that had
EDC/VCM wastewater (15). EPA used these data in the OCPSF detailed review to determine
the source of dioxin in OCPSF wastewater.
6.2.7 Office of Air and Radiation NESHAPs Rule for Mercury Cell Chlor-Alkali
Plants
On December 19, 2003, EPA's Office of Air and Radiation (OAR) promulgated
National Emission Standards for Hazardous Air Pollutants: Mercury Emissions from Mercury
Cell Chlor-Alkali Plants. As part of this rule, OAR collected manufacturing data from chlor-
alkali plants in the United States. EPA used the manufacturing information about the chlor-
alkali plants in the OCPSF detailed review.
6.2.8 Other Data Sources
In addition to those sources discussed above, EPA also used the following:
• Company web pages available on the Internet;
• The June 2003 Chlorine Institute publication entitled, North American
Chlor-Alkali Industry Plants and Production Data Report;
• National Safety Council's "Chemical Backgrounders," available via its
web site (http://www.nsc.org):
• The Innovation Group (TIG) Chemical Profiles, available via its web site
(http://www.the-innovation-group.com/welcome.htm): and
• Other related web pages available on the Internet, such as news web
pages, economic statistics web pages, and state and local regulatory
agency web pages.
6-8
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.3 General Industry Profile and Identification of Focus Industries
EPA's initial review of the OCPSF category used data from the Development
Document for Effluent Limitations Guidelines, New Source Performance Standards, and
Pretreatment Standards for the Organic Chemicals and the Plastics and Synthetic Fibers Point
Source Category (October 1987) (17), the TRIReleases2000 database, and the PCSLoads2000
database. Initially, EPA identified OCPSF facilities by their primary SIC code.
As EPA continued its review, it became clear that analyzing discharges by
primary SIC code was insufficient to support a detailed review. EPA realizes that the OCPSF
category is a large group of many industries. To simplify the review, EPA identified segments
of the industry with common processes and/or wastewater characteristics. Next, EPA identified
focus industries: those groups of facilities with common manufacturing processes that reported
discharge of the pollutants with the highest TWPE. The remainder of this section describes the
OCPSF category in general, and the identification of focus industries in the following order:
• Section 6.3.1 presents a general overview of the facilities in the OCPSF
category, including the types of products manufactured;
• Section 6.3.2 discusses the manufacturing processes used by OCPSF
facilities;
• Section 6.3.3 discusses general wastewater characteristics and treatment;
• Section 6.3.4 discusses the identification of focus industries and SIC code
analysis; and
• Section 6.3.5 discusses EPA's decision not to further consider facilities
reporting SIC codes 2823 and 2824 in the detailed review.
6.3.1 General Overview of the OCPSF Category
The OCPSF category includes many chemical industries producing hundreds of
end products, such as polypropylene, vinyl chloride and PVC, chlorinated solvents, rubber
precursors, styrofoam additives, and polyester (to name a few). Some OCPSF facilities are
extremely complex and produce hundreds of chemicals, where others are simpler, producing one
or two end products (17).
Wastewater discharges from OCPSF operations are regulated under 40 CFR Part
414. In 1989, EPA promulgated Best Practicable Control Technology Currently Available
(BPT) for subcategories based on product type, which is similar to the SIC code structure. Table
6-1 lists the subcategories identified for BPT regulation. EPA also promulgated BAT and PSES
for subcategories based on type of wastewater treatment, not product type, in Subparts I, J, and
K. Section 6.4 discusses the regulation in more detail.
6-9
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-1. OCPSF Subcategories for BPT (40 CFR Part 414)
Subpart
A
B
C
D
E
F
G
H
Name
General
Rayon Fibers
Other Fibers
Thermoplastic Resins
Thermosetling Resins
Commodity Organic
Chemicals
Bulk Organic
Chemicals
Specialty Organic
Chemicals
Description
General definitions
Manufacture of rayon fiber by the viscose process only
Manufacture of products classified under SIC 2823, except rayon, and SIC
2824 (specific list provided)
Manufacture of products classified under SIC 28213 - thermoplastic resins
(specific list provided)
Manufacture of products classified under SIC 28214 - thermosetting resins
(specific list provided)
Manufacture of specific commodity organic chemicals and chemical
groups classified under SIC 2865 and 2869 (specific list provided)
Manufacture of specific bulk organic chemicals and chemical groups
classified under SIC 2865 and 2869 (specific list provided)
Manufacture of specific organic chemicals and chemical groups not
defined as commodity or built classified under SIC 2865 and 2869
The OCPSF industry includes establishments engaged in manufacturing organic
chemicals, plastics, and synthetic fibers, but does not include rubber manufacturing, gum and
wood chemicals manufacturing, pesticide chemicals manufacturing or formulating/packaging/
repackaging, or miscellaneous plastics (e.g., plastics molding and forming). Table 6-2 lists
examples of chemicals produced by the OCPSF industry.
Table 6-2. Examples of Chemicals Produced by OCPSF Facilities
Organic Chemicals
Derivatives of benzene, toluene, naphthalene, anthracene,
pyridine, carbazole, and other cyclic chemical products
Synthetic organic dyes and pigments
Cyclic (coal tar) crudes, such as light oils and light oil
products, coal tar acids, products of medium and heavy oil
(e.g., creosote oil), aniline
Noncyclic organic chemicals (e.g., acetic acid, metallic
salts, formaldehyde)
Solvents (e.g., amyl, butyl, and ethyl alcohols, carbon
disulfide)
Polyhydric alcohols and their esters, amines, etc.
Synthetic perfume and flavoring materials
Plastics and Synthetic Fibers
Cellulose acetate, phenolic, and other tar acid
resins
Urea and melamine resins, vinyl acetate resins,
polyethylene resins, polypropylene resins, rosin
modified resins
Cellulosic man-made fibers, including cellulose
acetate, rayon, triacetate fiber, styrenes
Noncellulosic synthetic organic fibers, including
acrylic, fluorocarbon, nylon, olefm, polyester, and
polyvinyl
Silicones
Other Products Manufactured from Purchased
Refinery Products
Benzene
6-10
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-2 (Continued)
Organic Chemicals
Rubber processing chemicals and plasticizers
Synthetic tanning agents
Fatty and other acids
Plastics and Synthetic Fibers
Toluene
Mixed xylenes
Aliphatic hydrocarbons
The OCPSF category includes the following five SIC codes:
1. SIC 2821: Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers;
2. SIC 2823: Cellulosic Man-Made Fibers;
3. SIC 2824: Synthetic Organic Fibers, Except Cellulosic;
4. SIC 2865: Cyclic Crudes and Intermediates, Dyes, and Organic Pigments;
and
5. SIC 2869: Industrial Organic Chemicals, Not Elsewhere Classified.
The organic chemicals sector is geographically diverse, with high concentrations
in the Gulf States, Great Lakes area, and New Jersey. For the majority of organic chemicals,
production has increased between 2 and 30 percent since 1992. In the synthetic fibers sector,
however, cellulosic fiber production has dropped almost 10 percent since 1992. Production of
noncellulosic fiber has stayed essentially the same since 1992 (2).
The plastics sector has a presence in every state, but the top 10 states in 2001
accounting for almost 60 percent of employment were: California, Ohio, Michigan, Texas,
Illinois, Pennsylvania, Indiana, New York, North Carolina, and Wisconsin (13). The plastics
materials and resins industry is concentrated on the Gulf Coast, which has abundant raw
materials and an excellent petrochemical infrastructure. Texas tops the list in employment for
this sector. Plastics production increased 2 to 3 percent compared to late 1980s and about 5
percent since 1992 (2).
OCPSF facilities reporting to TRI discharge directly and indirectly, and some
have zero water discharge. Table 6-3 lists the number of facilities in each SIC code, based on
data sources available.
6-11
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-3. SIC Codes in OCPSF
SIC
Code
2821
2823
2824
2865
2869
Total
1997 U.S.
Economic
Census
529
6
100
195
740
1,570
TRI 2000
Direct
Dischargers
93
4
8
36
139
280
Indirect
Dischargers
135
1
7
56
147
346
Both
17
1
0
7
24
49
No Water
Discharge
Reported
218
1
7
22
167
415
Total
Reporting to
TRI
429
5
22
107
429
992
PCS 2000
Direct
(Majors)
92
4
5
24
118
243
6.3.2
OCPSF Manufacturing Processes
Because of the complexity of the OCPSF category, EPA focused the detailed
review of manufacturing processes on certain industries. Section 6.3.4 discusses how EPA
identified the focus industries. Sections 6.6, 6.7, and 6.8 describe the manufacturing processes
of these focus industries. The remainder of this section discusses general production information
for the OCPSF category.
OCPSF facilities range in size and production type. Some facilities produce large
volumes of chemicals in continuous processes; others produce small volumes of specialty
chemicals in batch processes (17). Facilities use a variety of feedstocks and process types.
Product mixes may change on a weekly or daily basis, depending on customer specifications
(17). Table 6-4 below lists the generic processes used by OCPSF facilities, as identified in the
1987 TDD.
Table 6-4. Examples of Generic OCPSF Processes Identified in the 1987 TDD
Alkoxylation
Condensation
Halogenation
Oxidation
Polymerization
Hydrolysis
Hydrogenation
Esterification
Pyrolysis
Ainination (ammonolysis)
Nitration
Sulfonation
Ainmoxidation
Carbonylation
Hydrohalogenation
Dehydration
Dehydrohalogenation
Oxyhalogenation
Phosgenation
Extraction
Distillation
Hydration
Hydrodealkylation
Dehydrogenation
Catalytic cracking
Alkylation
Hydrofluorination
6-12
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
OCPSF facilities use feedstock from petroleum refineries, cokemaking plants,
pulp mills, and other sources (17). Table 6-5 lists some of the primary feedstocks and associated
end products identified in the 1987 TDD.
Table 6-5. Examples of Feedstock and End Products Identified in the 1987 TDD
Example Feedstock
Benzene
Propylene
Cellulose
Ethylene
Methane
Propylene
Toluene
Xvlenes
End Product
Nitrobenzene, aniline, maleic anhydride, cyclohexane, cyclohexanone, caprolactam,
cyclohexanol. adipic acid, cumene, phenol, bisphenol A. acetone, propylene oxide,
styrene, ethylbenzene, chlorophenols, chlorobenzenes
Polypropylene resins, polypropylene fiber
Rayon fiber, cellulose acetate, cellulose acetate fiber
Ethylbenzene, styrene, acetaldehyde, acetic acid, acetic anhydride, ethylene oxide,
ethylene glycol, ethoxylates, EDC, VCM, tetrachlorethylene, carbon tetrachloride,
1,1,1-trichloroethane, ethyl acrylate, ethanol
Methyl chloride, methylene cliloride. clilorofonn, carbon tetrachloride, methanol,
fonnaldehyde. acetic acid, methyl acrylate, methyl methacrylate
Cumene, phenol, propylene oxide, acetone, methacrylic acid, propylene glycol,
polyethers, isopropanol, n-butanol, b-butyl acrylate, acrylic acid, n-butyraldehyde,
2-ethylhexanol, 2-ethylhexyl acrylate, allyl cliloride, epiclilorohydrin, acrolein, allyl
alcohol, glycerin, acrylonitrile
Dinitrotoluene. toluene diamine. tolylene diisocyanate, trinitrotoluene
Terephtlialic acid, dimethylterephthalate
6.3.3
General Wastewater Characteristics and Treatment
This section discusses general wastewater characteristics (Section 6.3.3.1) and
wastewater treatment (Section 6.3.3.2) from data provided in the 1987 TDD, the 2000 TRI, and
2000 PCS. Sections 6.6, 6.7, and 6.8 provide more detail on the manufacturing processes and
wastewater characteristics of the focus industries.
6.3.3.1
General Wastewater Characteristics
The 1987 TDD contains flow and pollutant information on untreated wastewater.
The average per facility flow rate for direct dischargers was 1.31 million gallons per day (MOD),
and the average per facility flow rate for indirect dischargers was 0.25 MGD. Table 6-6 presents
untreated wastewater concentrations for direct and indirect dischargers.
6-1:
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-6. Untreated Wastewater Characteristics for Direct and Indirect Dischargers in
the OCPSF Category
Pollutant
BOD,
COD
TOC
TSS
Toxic organic pollutants
Raw Pollutant Concentrations (1987)
Direct Dischargers (mg/L)
1,088
2.908
1.041
579
Indirect Dischargers (mg/L)
1,784
4,571
973
624
See Technical Development Document. Table V-46
Source: EPA, 7987 TDD, Volume I.
The 1987 TDD linked certain products with the discharge of certain priority
pollutants. For example, wastewater sampling data showed that manufacturing acetone from
benzene and propylene feedstocks generates aromatic priority pollutants. Table 6-7 lists some
additional examples of the types of pollutants found in wastewater from the manufacturing of
certain products.
Table 6-7. Examples of Pollutants Discharged from the Manufacturing of Certain
Products
Product
Acetone
Acrylic fibers
Acrylic resins (latex)
Aniline
Caprolactam
Carbon tetrachloride
Cellulose acetate
Polyester
High density polyethylene resin
Methylene chloride
Trichloroethylene
Toluene (from coal tar light oil)
Styrene - butadiene resin
Vinyl chloride
Priority Pollutants Detected in Process Wastewater
Aromatics
Acrylonitrile
Acrylonitrile, acrolein
Aromatics
Aromatics
Chloromethanes, chlorinated C2s
Isophorone
Phenol, aromatics
Aromatics
Chloromethanes, chlorinated C2s
Chlorinated C2s, Chloromethanes
Aromatics, polyaromatics, phenols, cyanide
Aromatics
Chlorinated C2's, Chloromethanes
Source: EPA, 1987 TDD, Volume I.
Notes:
Chlorinated C2s: Long-chain hydrocarbons with 40-49 percent chlorination by weight.
6-14
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
EPA used TRI and PCS data to evaluate annual pollutant loads discharged to
surface water, using the methodology described in Section 4.2.4 of this Technical Support
Document to estimate TWPE. Table 6-8 lists the estimated pounds and TWPE for each SIC
code.
Table 6-8. OCPSF Pollutant Load Discharged to Surface Water in 2000 by SIC Code1
SIC
Code
2821
2823
2824
2865
2869
SIC Code Name
Plastic Materials, Synthetic Resins, and
Nonvulcanizable Elastomers
Cellulosic Man-Made Fibers
Synthetic Organic Fibers. Except
Cellulosic
Cyclic Crudes and Intermediates, Dyes,
and Organic Pigments
Industrial Organic Chemicals, Not
Elsewhere Classified
Total Reported TWPE for OCPSF Category
TRI
Pounds
5,000,000
438,000
1.740.000
2,470,000
44,400,000
54,000,000
TWPE
112,000
29,200
2.420
950,000
6,110,000
7,200,000
PCS
Pounds
252,000,000
499,000,000
13.100,000
54,100,000
1,590,000,000
2,410,000,000
TWPE
489,000
60,700
3,290
324,000
1,280,000
2,110,000
Sources: PCSLoads2000 and TRIReleases2000.
Notes: Numbers updated from SIC code totals from the proposed Notice, 12/31/03, because of data corrections
described in Section 2.0 of this section.
'The pollutant load discharged to surface water was estimated by TRI Re/eases 2000 using pollutant releases directly
to surface water and transfers to publicly-owned treatment works (POTWs), taking POTW removals into account.
EPA also used PCS data to determine the volume of wastewater discharge (which
is not reported in TRI); however, the total flow rates reported to PCS may include stormwater
and noncontact cooling water, as well as process wastewater. In some cases, the PCS database
identifies the type of wastewater being discharged; however, most reported flow rates do not
indicate the type of wastewater. Table 6-9 lists the flows reported for each SIC code.
Table 6-9. OCPSF Annual Wastewater Flows by SIC Code as Reported to PCS in 2000
SIC
Code
2821
2823
2824
2865
SIC Code Name
Plastic Materials, Synthetic
Resins, and Nonvulcanizable
Elastomers
Cellulosic Man-Made Fibers
Synthetic Organic Fibers,
Except Cellulosic
Cyclic Crudes and
Intermediates, Dyes, and
Organic Pigments
Number
of
Facilities1
91
4
5
22
Range of Facility
Flows, MGY
(MGD)
0.648 to 168,489
(0.002 to 462 )
0.0000108 to 9,926
(O.001 to 27.2)
32.4 to 60,020
(0.09 to 164)
14.1 to 33, 176
(0.039 to 90.9 )
Median
Facility Flow,
MGY
(MGD)
619
(1.69)
4,692
(12.9)
543
(1.49)
360
(0.987 )
A\7erage
Facility Flow,
MGY
(MGD)
4.961
(13.6)
4,828
(13.2)
12,352
(33.8 )
3.570
(9.78 )
Total for
SIC code,
MGY
451,444
19,310
61,762
78,534
6-15
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-9 (Continued)
SIC
Code
2869
SIC Code Name
Industrial Organic
Chemicals. Not Elsewhere
Classified
Number
of
Facilities1
113
Range of Facility
Flows, MGY
(MGD)
1.20 to 367, 185
(0.003 to 1,006 )
Median
Facility Flow,
MGY
(MGD)
1202
(3.29 )
Average
Facility Flow,
MGY
(MGD)
12,378
(33.9 )
Total for
SIC code,
MGY
1,398,663
Notes:
Source: PCS Loads 2000.
MGY - Million gallons per year.
1 Number of Major Facilities Reporting Nonzero Flows.
The median per facility flows range from 0.987 MGD for facilities in SIC code
2865 to 12.9 MGD for facilities in SIC code 2823. These flows are somewhat higher than the
average flow for direct dischargers reported in the 1987 TDD (1.31 MGD). This suggests either
that facilities have greater water use than in 1987 (perhaps concurrent with greater production)
or that flows reported to PCS include nonprocess wastewaters such as noncontact cooling water
and stormwater runoff.
6.3.3.2
General Wastewater Treatment
EPA collected on-site wastewater treatment data from the 2000 TRI. Table 6-10
summarizes this information.
Table 6-10. Wastewater Treatment Operations Reported by OCPSF Facilities
TRI Reporting Year 2000
Wastewater Treatment Process
Biological Treatment
Settling/Clarification
Equalization
Neutralization
Filtration
Stripping (air and steam)
Chemical precipitation
Adsorption
Number of Facilities Reporting Use
Direct1 (213 facilities)
207
136
120
101
75
50
42
32
Indirect1 (176 facilities)
60
59
65
90
34
54
31
33
Source: TRlReleases2000.
'Of the facilities that provided information on their wastewater treatment operations in TRI 2000. 213 facilities
reported direct releases. 176 facilities reported transfers to POTWs. and 20 facilities reported both direct releases and
transfers to POTWs.
6-16
-------
6.3.4
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Focus Industry Identification and SIC Code Analysis
For the screening-level analysis, EPA examined the pollutant discharges reported
to TRI and PCS for the five SIC codes in the OCPSF category (see Table 6-8). After the
screening analysis, EPA focused the detailed review of the OCPSF category on the most toxic
pollutant discharges as measured by TWPE. Section 6.3.4.1 discusses how EPA identified three
focus industries with the most toxic pollutant discharges. Section 6.3.4.2 discusses how EPA
identified two SIC codes that would not be further investigated at this time: 2823 and 2824 (the
fiber manufacturers).
6.3.4.1
Focus Industry Identification
Using 2000 TRI and PCS data, EPA determined which pollutants were discharged
with the greatest TWPE for the OCPSF category. Table 6-11 shows the most toxic pollutants, by
TWPE, for the OCPSF category:
Table 6-11. Top Pollutants Reported Discharged in 2000 for the OCPSF Category
Pollutant Reported
Dioxin and dioxin-like compounds
Polycyclic aromatic compounds
Aniline
Data Source
TRI
TRI
TRI
Pounds Reported
3.27 (1.480 grams)
2,020
85.600
TWPE Reported
5,700.000
941,000
120,400
Source: TRIRe1eases2000.
EPA examined the highest pollutant discharges at the SIC code level and
determined that:
• In SIC code 2865, the facilities that reported PACs to TRI all perform coal
tar refining;
• In SIC code 2865, the facilities that reported aniline to TRI either
manufacture aniline or produce dyes; and
• In SIC codes 2821 and 2869, the facilities that reported releases of dioxin
and dioxin-like compounds are mainly manufacturers of EDC/VCM/PVC,
with some also having co-located chlor-alkali plants.
EPA reviewed in more detail these three groups of facilities, referred to as
OCPSF focus industries: coal tar refiners, aniline dischargers, and dioxin dischargers. Sections
6.6, 6.7, and 6.8 of this section discuss the focus industries in greater detail.
6-17
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.3.4.2 No Further Consideration of SIC Codes 2823 and 2824: Fiber Manufacturers
In reviewing the reported pollutant dischargers for 2000, EPA noted that the fiber
manufacturing process does not discharge as many toxic pounds of chemicals as other OCPSF
manufacturing processes (17). Based on 2000 TRI and PCS data, facilities in SIC codes 2823
(Cellulosic Man-Made Fibers) and 2824 (Synthetic Organic Fibers, Except Cellulosic) contribute
less than 3 percent of the TWPE reported discharged by the OCPSF category. Both fiber
manufacturing SIC codes (2823 and 2824) have fewer facilities in the 1997 U.S. Census and
fewer pounds and toxic pounds of pollutants reported to TRI and PCS, compared with other
OCPSF SIC codes.
Synthetic Fiber Production
Facilities in SIC codes 2823 and 2824 manufacture cellulosic and other man-
made fibers, as opposed to naturally occurring fibers such as cotton, wood, or silk. Synthetic
fibers produced using cellulose (wood- or other plant-based) feedstock fall in SIC code 2823;
those produced from petroleum or other chemical feedstocks fall in SIC code 2824. Synthetic
cellulosic fibers include rayon (including Tencel® and Lyocell) and acetate. Synthetic
noncellulosic fibers include (26):
• Nylon;
• Modacrylic;
Olefm;
• Acrylic;
• Acrylonitrile rubber;
• Polyester;
• Vinyon;
• Saran;
• Spandex;
• Aramid;
• Polybenzimidazole (FBI); and
Sulfar.
The manufacturing process for fiber production varies per type of fiber.
Manufacturing of cellulosic fibers such as rayon begins with production of viscose, a syrupy
liquid made from cellulose in sodium hydroxide solution. The viscose is passed through fine
holes to become threads, collected in a dilute acidic medium, such as sulfuric acid. For nylon
manufacturing, a petroleum-based synthetic fiber, adipic acid is reacted with hexamethylene
diamine to form an amide structure polymer. The resulting polyamide is forced through fine
holes, forming threads of nylon (Tools for Teaching).
Facilities in SIC Codes 2823 and 2824
Table 6-12 lists all facilities that reported SIC codes 2823 or 2824 as their
primary SIC codes in the 2000 TRI and/or PCS 2000.
6-18
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-12. Facilities in SIC Codes 2823 and 2824 in the 2000 TRI and/or PCS 2000
Facility Name
Location
SIC Code 2823: Cellulosic Man-Made Fibers
Acordis Cellulosic Fibers Inc.
BASF Enka
Celanese Acetate Celriver Plant
Eastman Chemical Co. Tennessee Operations
North American Fibers Corporation
Lenzing Fibers Corporation
Axis, AL
Enka, NC
Rock Hill, SC
Kingsport, TN
Elizabethton. TN
Lowland, TN
SIC Code 2824: Synthetic Organic Fibers, Except Cellulosic
Solutia Inc.
Hexcel Corporation
Solutia Inc.
Sterling Fibers. Inc.
Globe Manufacturing Corporation
Honeywell International Inc.
DuPont Fibers Kinston
Arteva Specialties/KOSA
Globe Manufacturing Corporation
BASF Corporation Clemson Site
DuPont Camden-May Plant
Arteva Specialties/KOSA
Wellman Inc. /Palmetto Plant
BASF Corporation Fiber Products Division
Du Pont Chattanooga Plant
Poly loom Corporation Of America
Hexcel Corporation
Du Pont Spruance Plant
Honeywell International Inc.
Decatur. AL
Decatur, AL
Cantonment, FL
Pace, FL
Fall River, MA
Moncure, NC
Kinston. NC
Salisbury, NC
Gastonia, NC
Central, SC
Camden, SC
Spartanburg, SC
Darlington, SC
Anderson. SC
Chattanooga, TN
Dayton. TN
Salt Lake City, UT
Richmond, VA
Hopewell, VA
Sources: PCSLoads2000 and TRIReleases2000.
Table 6-13 lists the four facilities that reported their primary SIC code as 2821
(Plastic Materials, Synthetic Resins, and Nonvulcanizable Elastomers) in TRI but are classified
as SIC code 2824 (Synthetic Organic Fibers, Except Cellulosic) in PCS.
6-19
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-13. Facilities with Primary SIC Code 2824 in PCS and 2821 in TRI
Facility Name
DuPont Fibers Kinston
DuPont Camden-May Plant
Sterling Fibers, Inc.
Welknan Inc. /Palmetto Plant
Location
Kinston, NC
Carnden, SC
Pace, FL
Darlington, SC
Primary SIC Code
TRI
2821
2821
2821
2821
PCS
2824
2824
2824
2824
Sources: PCSLoads2000 and TRIReleases2000.
Table 6-14 lists the five facilities classified as SIC codes 2821 (Plastic Materials,
Synthetic Resins, and Nonvulcanizable Elastomers), 2869 (Other Organic Chemicals, NEC),
2281 (Yarn Spinning Mills) or 5169 (Chemical Wholesale Distributors) in PCS but that reported
their primary SIC code as 2824 to TRI.
Table 6-14. Facilities with Primary SIC Code 2824 in TRI and Other in PCS
Facility Name
Arteva Specialties S. A.R.L. (dba Kosa Spartanburg)
BASF Corporation Fiber Producers
BASF Corporation, Clemson Site
Honeywell International, Inc.
Solutia
Location
Spartanburg, SC
Anderson, SC
Central, SC
Moncure, SC
Cantonment, FL
Primary SIC Code
TRI
2824
2824
2824
2824
2824
PCS
2821
2281
2821
5169
2869
Sources: PCSLoads2000 and TRIReleases2000.
For the screening-level review, EPA included discharge loads as they were
reported. For example, the DuPont Kinston plant TRI-reported releases were included in the
totals for SIC code 2821, while the PCS-reported discharges were included in SIC code 2824.
For more information on how SIC code totals were calculated, see Section 4.2.4 in this Technical
Support Document.
Some facilities that reported to TRI are not in PCS Loads 2000, because they are
either indirect dischargers or minor direct dischargers.
Pollutants of Concern for SIC Codes 2823 and 2824
The 1987 TDD sampling data show that effluent from synthetic fiber
manufacturers contained the following priority pollutants at significant concentrations:
acrylonitrile, isophorone, phenol, and other aromatics. The sampling data showed that effluent
from other OCPSF operations, such as plastics and commodity, bulk, and specialty organic
chemicals manufacturing, contained greater numbers of priority pollutants at significant
6-20
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
concentrations compared to synthetic fiber manufacturers. The 1987 TDD also shows that
wastewater effluent from synthetic fiber manufacturers contained pollutants in lower
concentrations compared to wastewater from other OCPSF manufacturing processes.
Table 6-15 lists the pollutants with the highest TWPE for both synthetic fiber SIC
codes based on 2000 TRI data. For both SIC codes, the discharges of each pollutant (except
carbon disulfide) are from only one facility, and one facility accounts for the majority of the
discharged TWPE:
SIC code 2823
— Eastman Chemical, Kingsport, TN accounts for 76 percent of the
TRI TWPE, and
— Acordis Fibers, Axis, AL accounts for 94 percent of the PCS
TWPE.
SIC code 2824
— Solutia, Cantonment, FL accounts for 57 percent of the TRI
TWPE, and
— Solutia, Decatur, AL accounts for 93 percent of the PCS TWPE.
Table 6-15. Pollutants with Highest TWPE Based on 2000 TRI Data
Pollutants With
Highest TWPE
Pounds/Year
TWPE/Year
Percentage of Total
TWPE for SIC Code
Number of Facilities
Reporting Pollutant
SIC Code 2823: Cellulosic Man-Made Fibers
Lead compounds
Aniline
Arsenic compounds
Carbon disulfide
Quinone
Manganese compounds
2,400
3,600
810
1,730
1,400
18,000
5,376
5,061
2,810
4,844
1,742
1,268
18%
17%
10%
16%
6%
4%
1
1
1
2
1
1
SIC Code 2824: Synthetic Organic Fibers, Except Cellulosic
Copper
Cadmium
Vanadium compounds
Ammonia
Nitrate compounds
1,403
260
795
79,000
1,500,000
880
679
495
119
93
36%
28%
20%
5%
4%
1
1
1
1
1
Source: TRIReIeases2000.
Table 6-16 lists the pollutants with the highest TWPE for both SIC codes based
on PCS data.
6-21
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-16. Pollutants with Highest TWPE Based on PCS 2000 Data
Pollutants With
Highest TWPE
Pounds/Year
TWPE/Year
Percentage of Total
TWPE for SIC Code
Number of Facilities
Reporting Pollutant
SIC Code 2823: Cellulosic Man-Made Fibers
Carbon disulfide
Total zinc
19,250
41.225
53,900
1,927
89%
3%
1
1
SIC Code 2824: Synthetic Organic Fibers, Except Cellulosic
Total manganese
Total recoverable iron
Ammonia as nitrogen
Total cyanide
Total iron
13,151
151,124
306,443
430
37,489
926
846
561
463
210
28%
26%
17%
14%
6%
1
1
1
1
1
Source: PCSLoads2000.
From the data presented in Tables 6-15 and 6-16, EPA was unable to identify a
pollutant of concern discharged by a significant number of facilities, at high volume, or with
high TWPE relative to the rest of the OCPSF category.
6.3.4.3
Decision for No Further Investigation
SIC codes 2823 (Cellulosic Man-Made Fibers) and 2824 (Synthetic Organic
Fibers, Except Cellulosic) represent a relatively small part of the OCPSF category, by number of
facilities, pounds of pollutant discharged, and TWPE discharged. Furthermore, a single facility
in each SIC code drives the estimate of the total TWPE discharged for all facilities in each SIC
code. Therefore, EPA did not further analyze these SIC codes for this review. Rather, EPA may
offer permit support for the few facilities driving the TWPE estimates.
6.4
Current Effluent Limitations Guidelines and Standards
Effluent limitations guidelines and pretreatment standards for the OCPSF
category, codified at 40 CFR Part 414, were promulgated in 1987 and amended in 1992. Table
6-17 summarizes the existing regulations.
6-22
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-17. Summary of Existing Effluent Limitations Guidelines and Pretreatment
Standards (40 CFR Part 414)
Pollutants Controlled
BPT, NSPS
BODS
TSS
pH
(For all
subcategories)
BCT
Reserved
BAT, NSPS
List of 62 priority pollutants (for
Subcategory I)
List of 58 priority pollutants (for
Subcategory J)
Implementation
PSES, PSNS
List of 45 priority pollutants (for
Subcategory K)
Limitations are concentration-based.
Each plant's limits are derived from formulae that prorate limitations based on production in each subpart.
BAT is applicable only to operations producing >5 million pounds of OCPSF products per year.
Subcategories
B. Ray on Fibers
C, Other Fibers
D. Thermoplastic Resins
E. Thermosetting Resins
F. Commodity Organic Chemicals
G. Bulk Organic Chemicals
H. Specialty Organic Chemicals
I. Direct Discharge Point Sources That Use End-of-Pipe Biological
Treatment
J. Direct Discharge Point Sources That Do Not Use End-of-Pipe
Biological Treatment
K. Indirect Discharge Point Sources
See 40 CFR Part 414, Subparts I, J, and K for the BAT chemical-specific
limitations.
The technology basis for the BPT limitations (conventional pollutants only) is
biological treatment with clarification, preceded by appropriate in-plant process controls and
treatment.
EPA promulgated Best Available Technology Economically Available (BAT)
limitations for two subcategories: facilities with biological treatment and facilities without
biological treatment. For BAT Subcategory I, the wastewater treatment technology basis was
end-of-pipe biological treatment with in-plant controls such as steam stripping (for volatile and
semi-volatile pollutants), activated carbon (for certain base/neutral priority pollutants),
hydroxide precipitation (for metals), and alkaline chlorination for cyanide. For BAT
Subcategory J, the wastewater treatment technology was physical/chemical end-of-pipe
treatment, with the same in-plant controls listed for Subcategory I.
The technology basis for the Pretreatment Standards for Existing Sources (PSES)
and Pretreatment Standards for New Sources (PSNS) limitations is the same as the technology
basis for BAT Subcategory J: facilities without biological treatment. New Source Performance
Standards (NSPS) limitations are based on BAT Subcategory I: facilities with biological
treatment.
6-23
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.5 Other Regulations Affecting OCPSF Facilities
EPA's sector notebook, Profile of the Organic Chemical Industry 2nd Edition,
2002 (22) lists regulations affecting OCPSF facilities. The OCPSF category is regulated by
nearly all federal environmental statutes, as well as state and local regulations (not listed here).
6.5.1 Resource Conservation and Recovery Act (RCRA)
Over 50 materials generated in OCPSF manufacturing processes are listed
hazardous waste from specific sources (K wastes). Additional OCPSF wastes are nonspecific
hazardous wastes (F wastes) or hazardous waste by characteristic (D wastes). Some OCPSF
wastes are banned from land disposal (land disposal restrictions are set forth at 40 CFR Part
268). RCRA regulates hazardous waste generation, transport, storage, and disposal at 40 CFR
Part 262.
Depending on the quantity and type of hazardous waste generated, facilities are
classified as either small or large quantity generators. If facilities store hazardous wastes beyond
set RCRA accumulation time limits (e.g., 90 or 180 days), RCRA regulates them as treatment,
storage, and disposal facilities (TSDFs). TSDFs have additional permit requirements (40 CFR
Part 262.34).
The remainder of this section discusses the listed hazardous waste pertaining to
the focus industries. For the dioxin-discharging focus industry, the following are listed
hazardous waste:
• KOI9 - Heavy ends from EDC distillation columns;
• K020 - Heavy ends from VCM distillation columns;
• K071 - Brine purification muds from chlor-alkali plants (listed for
mercury constituent);
• K073 - Chlorinated hydrocarbon waste from diaphragm cell purification
(listed for chlorinated hydrocarbon constituents);
• K106 - Mercury cell wastewater treatment sludge (listed for mercury
constituent);
K174 - Wastewater treatment sludge from EDC, EDC/VCM, or VCM
processes (listed for dioxins and furans constituents); and
• K175 - Wastewater treatment sludge from VCM produced from acetylene
gas (listed for mercury constituent).
6-24
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
In 1999, EPA proposed listing K173 (wastewater from the EDC, EDC/VCM, and
VCM wastewater processes). For the final RCRA Chlorinated Aliphatics Rule promulgated in
2000, however, EPA ultimately decided that the risk from K173 waste was not high enough to
require listing it as hazardous waste.
For coal tar refiners, the following wastes are listed hazardous waste:
• K147 - Tar storage tank residues from coal tar refining; and
• K148 - Residues from coal tar distillation, including but not limited to,
still bottoms.
For aniline dischargers, the following wastes are listed hazardous waste:
• K083 - Distillation bottoms from aniline production;
• K103 - Process residues from aniline extraction from the production of
aniline; and
• K104 - Combined wastewater streams generated from nitrobenzene/
aniline production.
6.5.2 Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA)
Part of CERCLA regulates underground storage tanks (USTs), which may be in
place at OCPSF facilities. The UST regulations apply to facilities with either petroleum products
or hazardous substances (but not hazardous waste) identified under CERCLA. The UST
regulations require tanks made of certain materials, record keeping, and monitoring.
6.5.3 Clean Air Act (CAA)
The CAA regulates air emissions from both unit operations at OCPSF and supporting equipment
(e.g., boilers, storage tanks) under New Source Performance Standards (NSPS), the National
Emissions Standards for Hazardous Air Pollutants (NESHAPs), and the State Implementation
Plans (SIP). Also, new or modified sources that are considered "major" under the CAA are
subject to new source review (NSR).
For OCPSF operations, the following emission points may be regulated,
depending on the characteristics of each unit operation and the applicability requirements of each
rule:
• Process vents;
6-25
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Volatile organic liquid storage vessels (regulates applicable storage tanks
containing volatile organic liquids, including petroleum liquid storage
vessels);
• Equipment leaks (vapor leaks from pumps, valves, connectors, etc.);
• Transfer operations;
• Heat exchangers;
• Wastewater processes; and
• Benzene waste operations.
The following sections discuss the air regulations that apply to OCPSF facilities:
NESHAPs program, NSPS, Consolidated Air Rule, State Implementation Plans, New Source
Review, and Title VI Stratospheric Ozone Protection.
6.5.3.1 NESHAPs Program
The NESHAPs program sets standards to control toxic air releases. HON is one
of many NESHAPs but is the predominant rule that will affect most facilities in the synthetic
organic chemical manufacturing industry (SOCMI). HON regulations (40 CFRPart 63 Subparts
F, G, H, and I) cover emissions of hazardous air pollutants from process vents, transfer
operations, storage vessels, wastewater, and equipment leaks at certain high-volume chemical
processes. Like all NESHAPs, the HON applies to "major sources," which are defined as
facilities that emit or have the potential to emit 10 tons per year or more of any hazardous air
pollutant (HAP) or 25 tons per year or more of any combination of HAPs.
The Miscellaneous Organic NESHAP (MON) regulates OCPSF unit operations
that are not regulated by the HON: batch processes and small volume organic chemicals. Also,
there are NESHAPs that apply to polymer and resin manufacturing, cooling towers, and
boilers/process heaters (The final rule for boilers/heaters has been signed but had not appeared in
the Federal Register as of August 2004).
The HON, MON, polymer, and boiler NESHAPs are all technology-based air
standards, and typically are referred to as Maximum Achievable Control Technology (MACT)
standards. These are all codified at 40 CFR Part 63. Other NESHAPs that cover emissions from
OCPSF facilities are based on preventing risks to public health. The risk-based NESHAPs that
apply to OCPSF facilities are:
• Vinyl chloride manufacturers (40 CFR Part 61 subpart F);
• Benzene equipment leaks (40 CFR Part 61 subpart J);
• Equipment leaks (fugitive emission sources) (40 CFR Part 61 subpart V);
• Benzene storage vessels (40 CFR Part 61 subpart Y);
6-26
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Benzene transfer operations (40 CFR Part 61 subpart BB); and
Benzene waste operations (40 CFR Part 61 subpart FF).
6.5.3.2 NSPS
The NSPS program sets emission standards for new, modified, or reconstructed
sources of criteria pollutants. The standards reflect the degree of emission reduction achievable
through application of best demonstrated control technology, considering the cost and any nonair
health and environmental impacts and energy requirements. For OCPSF, the NSPS regulate
volatile organic compound emissions from process vents, storage tanks, and equipment leaks at
synthetic organic chemical and polymer manufacturing plants. The NSPS also regulate NOx,
SO2, and PM emissions from boilers.
6.5.3.3 Consolidated Air Rule (CAR}
The CAR is an optional rule aimed to reduce the burden and potential confusion
of complying with multiple air regulations for the same process equipment. The purpose of the
CAR, codified at 40 CFR Part 65, is to consolidate overlapping regulatory requirements of the
SOCMI NSPS, HON, and the Part 61 risk-based NESHAP into a single set of regulatory
requirements that will satisfy all these rules, while achieving equivalent or better emission
reduction. Facilities can choose to comply with the CAR in lieu of the following rules:
40 CFR Part 60, subparts A, Ka, Kb, VV, ODD, III, NNN, and RRR;
40 CFR Part 61, subparts A, V, Y, and BB; and
40 CFR Part 63, subparts A, F, G, and H.
6.5.3.4 State Implementation Plans (SIP)
An OCPSF facility also may be required to comply with SIP regulations. The SIP
regulations contain emission standards adopted by each state to ensure compliance with National
Ambient Air Quality Standards (NAAQS). NAAQS has been established for sulfur dioxide,
nitrogen dioxide, particulate matter, carbon monoxide, lead, and ozone (SIPs regulate volatile
organic compounds and nitrogen oxides to control ozone).
6.5.3.5 New Source Review
New source review is a preconstruction permit program that is designed to ensure
that industrial growth does not cause new air pollution problems. New or modified major
sources that are located in areas that comply with the NAAQS must obtain a Prevention of
Significant Deterioration (PSD) permit. Sources in nonattainment areas must obtain a more
stringent Nonattainment NSR permit. Among other requirements, these permits require
installation of state-of-the-art emission controls, which are determined on a case-by-case basis
by the permitting authority.
6-27
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.5.3.6 Title VI Stratospheric Ozone Protection
Many organic chemical facilities operate industrial process refrigeration units,
such as chillers for chlorine dioxide plants. For those units that utilize ozone-depleting
chemicals, such as chlorofluorocarbons (CFCs), facilities are required under Title VI to follow
leak repair requirements.
6.5.4 Toxic Substances Control Act (TSCA)
Under TSCA, EPA collects data on chemicals to evaluate, assess, mitigate, and
control risks that may be posed by their manufacture, processing, and use. Pesticides, defined in
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), are not included in the
definition of a "chemical substance" when manufactured, processed, or sold for use as a
pesticide. TSCA affects many OCPSF chemicals, including new chemicals currently under
development.
The following list includes some of the TSCA regulations that affect OCPSF
facilities:
• Section 4: High Production Volume Rule. One example is EPA's
analysis of the use and manufacture of polybrominated diphenyl ether
compounds (40 CFR Parts 766, 790-799);
Section 5: Premanufacture Notices (40 CFR Parts 700, 720-725, 747);
• Section 6: Regulates or bans the chemical uses that present unreasonable
risks, such as asbestos, chlorofluorocarbons (CFCs), lead, and PCBs (40
CFR Parts 747, 749, 761, and 763);
Section 8: Inventory Update Rule (IUR) (40 CFR Parts 710-717);
• Section 8(a): The Preliminary Assessment Information Rule (PAIR),
which requires facility information on manufacturing or importing any
chemicals listed in 40 CFR Part 712.30 for commercial purposes;
• Section 8(c): Allegations of Significant Adverse Reactions Rule;
• Section 8(d): Unpublished Health and Safety Studies Rule;
• Section 8(e): Substantial Risk Information Requirement;
• Section 12: TSCA chemical exporter requirements; and
• Section 13: Chemical importer requirements (40 CFR Part 707 and 19
CFR Parts 12.118-12.128).
6-28
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.5.5 Emergency Planning and Community Right-To-Know Act (EPCRA)
EPCRA includes TRI reporting (Section 313), emergency planning (Section 304),
and emergency notification of extremely hazardous substance release (Section 302(a)). Most
OCPSF facilities are required to report to TRI annually (see also Section 4.2.1 of this Technical
Support Document). Under Section 302(a), OCPSF facilities that produce, use, or store
"hazardous substances" must report information to the state. Under Section 304, OCPSF
facilities that unintentionally spill or release a reportable quantity of an extremely hazardous
substance must report that release to the state emergency planning commission and the local
emergency planning commission.
6.5.6 Pending and Proposed Regulatory Requirements
Additional regulations affecting facilities in the OCPSF category are not yet
finalized. The NSPS for SOCMI wastewater is proposed to control air emissions of VOCs from
wastewater treatment operations. Under RCRA, EPA may create a Standardized Permit for
RCRA Hazardous Waste Management Facilities for facilities that generate waste and routinely
manage the waste at their site in tanks, containers, and containment buildings. The goal of the
standardized permit is to streamline the permit process.
6.6 Focus Group 1: Coal Tar Refiners
Coal tar refiners distill tar from by-product cokemaking operations. The end
products from coal tar refining include industrial pitches and other by-product chemicals. This
section discusses EPA's findings on the coal tar refining industry in the following subsections:
• Section 6.6.1 presents the facilities identified as coal tar refiners;
• Section 6.6.2 describes the process of coal tar refining and the sources and
type of wastewater generated by coal tar refiners;
• Section 6.6.3 lists the pollutants of concern identified based on available
data;
• Section 6.6.4 lists the wastewater treatment in place based on available
data;
• Section 6.6.5 describes industry trends; and
• Section 6.6.6 presents EPA's conclusions.
6.6.1 Facilities
EPA identified three U.S. coal tar refining companies (10 facilities) operating in
2000. Table 6-18 lists these facilities.
6-29
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-18. Coal Tar Refiners in the United States
Company
Honeywell
Inc.
Koppers
Industries
Inc.
Reilly Tar
&
Chemical
Co.
Location
Birmingham, AL
Iron ton, OH
Detroit, MI
Clairton, PA
Follansbee, WV
Cicero, IL
Dolomite, AL
Granite City. IL
Cleveland, OH
Lone Star. TX
Facility Operations/Status
Coal tar refiner. Facility closed June 2003.
Coal tar refiner. Facility closed 2002.
Coal tar refiner. Facility closed January 2004.
Coal tar refiner, producing creosote, naphthalene, and
industrial pitches. Primary SIC code in TRI is 2865.
Coal tar refiner, producing creosote, naphthalene, and
industrial pitches. Primary SIC code in TRI is 2865.
Location also known as Stickney. Coal tar refiner,
producing creosote, naphthalene, and industrial pitches.
Primary SIC code in TRI is 2865.
Location also known as Woodward Plant. Coal tar refiner,
producing roofing pitch and tar sealer.
Coal tar refiner.
Coal tar refiner. Facility closed (date believed to be 2000).
Coal tar refiner.
Discharge
Status
Direct/Major
Direct/Major
Indirect/Minor
Direct/Minor
Direct/Major
Indirect
Direct/Major
Indirect
Indirect
Indirect
Sources: PCSLoads2000 and TRIReleases2000, American Coke and Coal Chemicals Company web page, and
company web pages.
Italics denote facilities no longer in operation.
Since 2000, Honeywell, Inc. closed all three of its coal tar refining operations,
and Reilly Tar & Chemical Company closed one of its locations. As of the date of this report,
six facilities owned by two companies continue to refine coal tar in the United States.
6.6.2
Process Description and Wastewater Sources
Coal tar refiners process tar from by-product cokemaking through a distillation
column. The tar is formed as a by-product during coking, which is producing metallurgical coke
from baking coal at high temperatures. The primary product of coking is coke, but heating of the
coal also forms coke oven gas, light oil, coal tar, and other by-products.
Coal tar refiners pass the coal tar through a still, and recover the bottoms as
industrial pitches. Applications for coal tar pitches include the following:
• Binder for petroleum coke to make pre-baked anodes for primary
aluminum manufacturers;
• Tar-based road binders;
• Roofing;
6-30
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Damp-proofing (e.g., for waterproofing basement walls);
• Waterproofing; and
• Hot-applied tar-based coatings (pipeline enamels).
In addition, coal tar refiners may recover naphthalene, creosote, and other
chemicals from higher up in the still or after further processing. Figure 6-1 shows a simplified
process flow diagram for coal tar refining (4).
Distillate Stream to Wastewater Treatment w
Coal
Coal Tar from
Byproduct
Cokemaking
Tar
Distillation
Tower
Byproduct Chemicals
Recovered for Sale,
Including Naphthalene
and Creosote
Steam
T
Industrial Pitch
Figure 6-1. Coal Tar Refining Process Flow Diagram
Wastewater is generated from the distillate stream, which is passed through a
decanter. Light oil is decanted in this step, and the liquor, or decant bottoms, are sent to
wastewater treatment. The following coal tar residues (e.g., sludges) are listed hazardous waste:
• K148: Residues from coal tar distillation, including but not limited to, still
bottoms; and
6-31
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• K147: Tar storage tank residues from coal tar refining.
The coal tar residues are K-listed because they fail the toxicity characteristic for
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene,
dibenzo(a,h)anthracene, and indeno(l,2,3-cd)pyrene (40 CFRPart 261), all of which are
included in the TRI PACs chemical category.
6.6.3
Pollutants of Concern
EPA used TRI and PCS data to determine the pollutants of concern for the
OCPSF Focus Group 1 facilities: coal tar refiners.
6.6.3.1
TRI Data
Five of the 10 facilities listed in Table 6-18 reported PACs releases to wastewater
or transfers to POTWs in 2000 and/or 2001. (See Section 4.2.4.3 for a list of the 21 individual
PACs compounds). Of the other five facilities, four did not report wastewater PACs releases but
reported releases of other chemicals. The remaining facility, Reilly Tar & Chemical Company in
Cleveland, shut down, and no TRI data are available for that facility after 1999. PACs account
for more than 99.9 percent of the TWPE of wastewater releases reported to TRI by these
facilities. Table 6-19 shows the PACs releases reported to TRI in 2000 and 2001, talcing POTW
removals into account, and the corresponding TWPE calculated by EPA. As explained in
Section 6.2.1, EPA used the TWF for benzo(a)pyrene to calculate TWPEs for the TRI PAC
category. Because coal tar residues also contain other individual PAC constituents and because
benzo(a)pyrene is the most toxic individual PAC constituent, this results in an overestimate.
Table 6-19. PACs Water Discharges Reported to TRI for 2000 and 2001
Company
Koppers Industries Inc.
Woodward Plant
Koppers Industries Inc.
Honeywell Inc.
Honeywell Inc.
Reilly Tar & Chemical Co.
Location
Dolomite, AL
Follansbee, WV
Birmingham. AL
Ironton, OH
Granite City, IL
2000 Discharges
Pounds
63
0
6
120
0.591
TWPE
269,864
0
25,701
514,027
2,522
2001 Discharges
Pounds
16
5
6
102
0.771
TWPE
68.537
21.418
25.701
436,923
3,298
Percent
Change from
2000
-75%
NA
0%
-15%
31%
Source: TRIReleases2000.
NA - Not applicable. Koppers in Follansbee reported discharging zero pounds of PACs in 2000.
'The pounds of PACs discharged for Reilly Industries reflects POTW treatment. EPA estimated that the POTW
removed 93 percent of the PACs generated at the facility.
6-32
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.6.3.2
PCS Data
PCS data were available for four coal tar refining facilities; the other facilities are
either indirect dischargers (five) or minor dischargers (one). Generally, NPDES permits require
facilities to monitor for individual pollutants, rather than the group of pollutants, PACs, as
reported to TRI. Of the four facilities with PCS data, three reported discharging any of the
individual PACs at detectable levels for 2000. The fourth facility, Honeywell's Birmingham
facility, did not detect any individual PACs in their wastewater in 2000. Table 6-20 shows the
PCS PACs discharge data for 2000. Each of the three facilities listed in Table 6-20 reported
more pounds of PACs to TRI than of individual PACs in their monitored discharges, suggesting
that the PACs reported to TRI may be over-estimated.
Table 6-20. PACs Wastewater Discharges Reported to PCS in 2000
Company
Koppers Industries Inc.
Koppers Industries. Inc.
Woodward Tar Plant
Honeywell Inc.
Honeywell Inc.
Location
Follansbee, WV
Dolomite. AL
Ironton, OH
Birmingham, AL
Chemical
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(a)anthracene
Benzo(k)fluoranthene
Chrysene
Fluoranthene
Pyrene
Benzo(a)pyrene
Chrysene
Fluoranthene
Benzo(a)anthracene
Benzo(k)fluoranthene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
Indeno( 1,2,3 -cd)pyrene
Benzo(a)anthracene
Dibenzo(a,h)anthracene
Fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
Fluoranthene
Benzo(a)anthracene
2000 Discharges
Pounds
2.1
2.0
0.83
1.0
1.3
1.3
1.4
0
0
0
0
0.26
0
0
0
0
0
0
0
2.6
0
0
0
0
0
TWPE
9,148
854
151
42
2.7
1.0
0.15
0
0
0
0
11
0
0
0
0
0
0
0
2.1
0
0
0
0
0
Source: PCSLoads2000.
6-33
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-21 presents the range and median concentrations of PACs reported to
PCS in 2000. These pollutants were discharged at concentrations below the minimum level -
generally an order of magnitude lower. The concentration of PACs in OCPSF Focus Group 1
wastewaters is at or near BAT concentrations. EPA did not identify additional wastewater
treatment capable of further reducing PAC concentrations.
Table 6-21. Concentrations of PACs Reported to PCS
Chemical
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(a)anthracene
B enzo (k)fluoranthene
Chrysene
Fluoraiithene
Concentration Range,
mg/L
0-0.00367
0 - 0.00352
0-0.00135
0 - 0.00350
0 - 0.00202
0.00220 - 0.00400
Median
Concentration,
mg/L
0.00183
0.00176
0.000676
0.00181
0.00101
0.00310
Effluent
Limitation,
mg/L1
0.023
0.023
0.022
0.022
0.022
0.025
Minimum
Level mg/L2
0.020
0.020
0.020
0.020
0.020
0.020
NA - Not applicable.
'BAT effluent limitation for Subcategory I, direct dischargers with biological treatment in place.
2Source: EPA, Development Document for the Central Waste Treatment Point Source Category. 2000.
For the five facilities listed in Tables 6-19 and 6-20, EPA reviewed TRI and PCS
data for additional pollutants discharged by the facilities (pollutants of concern). These
pollutants, listed in Table 6-22, account for 95 percent of the TWPE for Focus Group 1.
Table 6-22. Pollutants of Concern for Coal Tar Refiners
Pollutant
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE
for Source
Number of
Facilities
Reporting
Pollutant
Median per
Facility
Load
(lb/yr)
TRI Data
Polycyclic Aromatic Compounds
190
812,115
99.94%
4
35
PCS Data
Benzo(a)pyrene
Benzo(b)fluoranthene
Acrylonitrile
3 ,4-Benzofluoranthene
Cyanide, Total (As CM)
2.1
2.0
414
0.68
210
9,148
854
353
285
226
80.7%
7.5%
3.1%
2.5%
2.0%
1
1
1
1
3
NA
NA
NA
NA
64
Sources: TRIReleases2000 wAPCSLoads2000.
6-34
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
All of the pollutants of concern in Table 6-22 are regulated by the existing
OCPSF effluent guideline, except for PACs. Some individual PACs compounds are regulated by
OCPSF.
6.6.4
Wastewater Treatment
EPA obtained wastewater treatment data from the TRI database for coal tar
refiners. Of the nine coal tar refining facilities that reported to TRI for 2000, six reported
wastewater treatment. All six reported having biological treatment. Also, EPA contacted four of
these six facilities and asked what type of biological wastewater treatment was in place. These
four facilities use conventional biological treatment, including primary clarification, activated
sludge systems, and secondary clarification. See the telecons in the docket for complete
documentation of the phone conversations.
6.6.5
Industry Trends
Four of the 10 plants presented in Table 6-18 have shut down since 2000, and
other data indicate a decline by-product cokemaking in the United States. Koppers authored two
similar articles documenting the declining availability of coal tar in North America, entitled,
Developing Coal Tar Pitches and Strategies for a Declining North American Coal Tar Supply.
Table 6-23 shows the Koppers estimates of coal tar raw material availability for 1997 - 1999,
and the Koppers projected trends for 2000, 2001, and 2003.
Table 6-23. Production Trend for Cokemaking and Coal Tar Pitch
Year
1997
1998
1999
2000
2001
2003
North American Coal Tar Available,
1,000 metric tons/year
1302
1141
1141
1141
1027
1027
Source: Koppers.
In its articles, Koppers also reports on the possibility of switching feedstock from
coking coal tar to a blend of coking and petroleum coal tar. The articles conclude that coal tar
pitch quality is not affected by switching to a coke/petroleum coal tar blend, but different ratios
will affect burning temperature. Although the availability of coal tar may be declining, the
demand for coal tar pitch may be met with new feedstocks. Therefore, the coal tar refining
industry may not decrease its production, but the changed feedstock may generate different
pollutants.
6-35
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.6.6 Conclusions
The screening-level analysis showed high TWPE discharges from this industry
group, based on releases of PACs reported to TRI. However, PCS data show that discharge
concentrations for individual PACs are at levels close to or less than the minimum level and less
than the current BAT limitations. The BAT limitations are already close to the minimum level,
and EPA would likely not be able to lower them once analytical variability is taken into account.
Furthermore, this industry is currently declining. Therefore, based on the pollutants of concern
identified and their low discharge concentrations, the small number of facilities currently
operating, and the apparent decline in the industry, EPA has determined that it should not revise
effluent limitations guidelines and standards (ELGs) for the coal tar refining sector of the
OCPSF industry at this time. If EPA receives data during subsequent annual reviews that
indicate otherwise, EPA might reconsider this sector of OCPSF for revision at that time.
6.7 Focus Group 2 - Aniline Dischargers
Aniline releases were reported to TRI by 15 facilities that manufacture aniline or
dyes, particularly diazo dyes. Aniline (C6H5NH2) is a benzene molecule with an amino
substitution. Aniline is not a priority pollutant, and there is no OCPSF limitation or standard for
aniline. This section discusses EPA's findings on the aniline dischargers in the following
subsections:
• Section 6.7.1 presents the facilities identified as aniline dischargers;
• Section 6.7.2 describes the process of aniline manufacturing and dye
manufacturing and the sources and type of wastewater generated by
aniline and dye manufacturing;
• Section 6.7.3 lists the pollutants of concern identified based on available
data;
• Section 6.7.4 lists the wastewater treatment-in-place based on available
data; and
• Section 6.7.5 presents EPA's conclusions.
6.7.1 Facilities
EPA estimates that 8 facilities manufacture aniline (11) and 38 facilities
manufacture dyes (1). EPA obtained discharge data from 15 facilities that reported discharging
aniline to TRI in 2000. (The remaining facilities did not report aniline discharges to TRI).
These facilities report under SIC code 2865, Cyclic Organic Crudes and Intermediates, and
Organic Dyes and Pigment. EPA determined the types of products manufactured at each facility
through telephone calls and searches of company web pages, in addition to the National Safety
Council (NSC) Chemical Backgrounder on aniline (which lists aniline manufacturers). Two
6-36
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
facilities reported aniline discharge information to PCS. Table 6-24 lists the facilities with TRI
data (which includes the two facilities with PCS data).
Table 6-24. OCPSF Aniline Dischargers in the United States
Company
BASF Corporation
Buffalo Color Corporation
Chicago Specialties LLC
Sun Chemical Corporation
Muskegon Plant
Crompton Colors Inc.
CIBA Specialty Chemicals
Corporation
H & S Chemical Company Inc.
First Chemical Corporation
Orient Corporation of America
Aristech Chemical Corporation
Bayer Corporation Bushy Park
Plant
Nation Ford Chemical Co.
Morton International Inc.
Paterson Facility
MerisolUSALLC
Location
Huntington, WV
Buffalo, NY
Chicago, IL
Muskegon, MI
Newark, NJ
Newport, DE
Wellington, NJ
Pascagoula, MS
Seaford, DE
Haverhill. OH
Goose Creek. SC
Fort Mill, SC
Paterson, NJ
Houston, TX
Product Type1
Alkali blue.
Dyes and pigments.
Styrene, printing ink and
pigments, organic dyes and
pigments, nitriles, aromatics.
Organic pigments, cosmetics,
plastics, printing inks.
Olefins and styrenic additives;
petroleum additives.
Commodity organic chemicals:
phenol, acetone, bis-phenol(a).
No longer manufacture aniline
(did in 2000). No manufacture of
pigments, inks, or dyes at this
location.
Pigments, dyes, other organic
chemicals.
DuPont runs this plant.
Manufactures aniline,
nitrotoluene (various isomers),
and other specialty and
commodity chemicals.
Pigments, dyes, other organic
chemicals.
Aniline, other organic chemicals.
Pigments, dyes, other organic
chemicals.
Pigments and dyes, mainly
carbazole violet pigment #23 and
diazo dyes. Also isopropyl
alcohol.
Pigments, dyes, other organic
chemicals.
Pigments, dyes, other organic
chemicals.
Discharge Status
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Direct
Direct
Indirect
Indirect
Direct
6-37
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-24 (Continued)
Company
Lomac LLC
Location
Muskegon, MI
Product Type1
Pigments, dyes, other organic
chemicals.
Discharge Status
Indirect
Source: TRIReleases2000.
'EPA determined the type of product made at each facility through telephone calls, searches of company web pages,
and the National Safety Council Chemical Backgrounder for aniline.
6.7.2
Process Description and Wastewater Sources
Aniline discharges result from the manufacture of aniline as well as the
manufacture of certain dyes, azo dyes in particular. Section 6.7.2.1 discusses aniline production
and Section 6.7.2.2 discusses azo dye production.
6.7.2.1
Aniline Production
The most common method for industrial production of aniline is nitrobenzene
hydrogenation. The reaction may be carried out in a liquid- or vapor-phase.
Nitrobenzene Hydrogenation Reaction:
+ 3H,
Nitrobenzene
Aniline
+ 2H,O
In the vapor-phase process, nitrobenzene (C6H5NO2) vapor and hydrogen are fed
into a fluidized bed reactor. Copper or copper on silica are typical catalysts for this reaction. A
filter at the top of the reactor recovers catalyst particles from the product. The nitrobenzene
hydrogenation reaction produces a gas containing aniline, water vapor, and residual hydrogen.
The gas is condensed and sent to a phase separator. Residual hydrogen is recycled, and the
water phase is sent to wastewater treatment. The aniline is fed to a distillation column for further
purification (3). Figure 6-2 presents the vapor-phase process for producing aniline.
6-38
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Hydrogen Recycle
Filter
Fluidized
Bed
Reactor
6
Condenser
Aniline
Product
Phase
Seperator
Nitrobenzene •••••. W
Hydrogen ••••-
Key
Gas stream
Liquid stream
Wastewater stream
Distilktion
I w Tars
~ (K083)
Reaction Water to
Wastewater Treatment
Figure 6-2. Vapor-Phase Aniline Manufacturing Process
DuPont produces aniline in a liquid-phase reaction, using nitric acid (HNO3) and
benzene as feedstocks. As a first step, nitric acid and benzene react to form mononitrobenzene
(MNB). DuPont has a unique dehydrating system to remove the water that is produced from the
reaction. An inert gas passes through the reactor and removes the reaction water. The
humidified gas stream is condensed to remove the water, and the inert gas is recycled through
the reactor. Crude MNB is washed and distilled. Residual benzene is removed during this
distillation step and recycled to the feed. MNB and hydrogen are fed into a plug flow reactor.
Typically, noble metal catalysts, such as platinum or palladium, are used in this reaction. The
product stream is sent to a dehydration column to remove water formed during the reaction. A
second column removes heavy ends from the aniline product (Hydrocarbon Processing). Sources
of wastewater in this process include inert gas condensates, MNB wash water, and reaction water
removed in the dehydration column. Figure 6-3 presents the DuPont/KBR liquid-phase process.
In aniline production, the following waste streams are listed as hazardous wastes:
• K083: Distillation bottoms from aniline production;
6-39
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Benzene
k-
Nitric i
Acid •
1
Dehydrating
Nitration
System
Inert Gas
Benzene Recycle
Cooler
Condenser
Mononitrobenzene
(MNB)
Key
Gas stream
Liquid stream
Wastewater stream
Distillation
MNB
Plug
Flow
Reactor
Dehydration
Hydrog'en Gas
Aniline
Product
Distilktion
Tars
(K083)
Wastewater to Treatment (K104 Waste)
Figure 6-3. Dupont/KBR Liquid-Phase Aniline Process
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• K103: Process residues from extraction of aniline during aniline
production; and
• K104: Combined wastewater streams generated from nitrobenzene/aniline
production.
These wastes were listed because they failed the toxicity characteristic for aniline,
diphenylamine, nitrobenzene, and phenylenediamine (all three wastes), and K104 also failed for
benzene. RCRA requires facilities to manage their K104 wastewater in certain ways. For
example, wastewater treatment systems used to treat K104 waste may need permitting, and
facilities must ensure no media transfer of pollutants occurs. However, the RCRA regulation of
K104 waste does not apply to effluent wastewater quality, which is regulated by Clean Water
Act regulations, including the ELGs for OCPSF.
6.7.2.2
Azo Dye Manufacturing
Azo dyes are formed by diazotization and coupling reactions. In the diazotization
reaction, an aromatic amine and nitrous acid react to form a diazonium salt. An example of these
reactions is shown below using 4-nitroaniline as the aromatic amine and 2-naphthol as the
nucleophilic reagent.
Diazotization and Coupling Reactions:
NH,
N=N
2-Naphthol
OH
HO
O2N
•N=N
NO2 NO2
4-Nitroaniline Diazonium Salt
Diazo Dye
In the dye manufacturing process, shown in Figure 6-4, the diazotization reaction
takes place in a liquid-phase reactor. The reactor effluent is treated in a clarifier prior to the
coupling reactor, where the diazonium salt is converted to a diazo dye by a nucleophilic
substitution reaction. Depending on the specific dye being produced, the product stream from
the coupling reaction might be sent through esterification or isolation. A filter press removes
water from the dye product. The final processing steps involve grinding and packaging the dye.
Sources of wastewater include spent scrubber liquid, mother liquor, plant run-off, and equipment
washdown (16).
6-41
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Vent
A
Feed
to
Product
Drying, Grinding,
and Packaging
Spent Scrubber Liquid
Esterification
Press Cake
Filter Press
Key
Gas stream
Liquid stream
Wastewater stream
Solid
Vent
A
Liquid
Wastewater
Treatment
System
Figure 6-4. Azo Dye Manufacturing Process
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.7.3
Pollutants of Concern
EPA obtained aniline discharge data, presented in Table 6-25, from 15 facilities
that reported to TRI 2000. PCS includes aniline discharge information for two facilities: Buffalo
Color and Aristech Chemical. The other facilities either do not have permit limits for aniline
(there is no OCPSF limitation or standard for aniline) or are indirect dischargers.
Table 6-25. Aniline Discharges Reported to TRI and PCS in 2000 for SIC Code 2865
Name
BASF Corporation
Buffalo Color Corporation
Chicago Specialties LLC
Sun Chemical Corporation,
Muskegon Plant
Crompton Colors Inc.
CIBA Specialty Chemicals
Corporation
H & S Chemical Co. Inc.
First Chemical Corporation
Orient Corporation of
America
Aristech Chemical
Corporation
Bayer Corporation, Bushy
Park Plant
Nation Ford Chemical Co.
Morton International Inc.,
Paterson Facility
MerisolUSALLC
Lomac LLC
Location
Huntington, WV
Buffalo, NY
Chicago, JL
Muskegon, MI
Newark, NJ
Newport, DE
Wallington, NJ
Pascagoula, MS
Seaford. DE
Haverhill, OH
Goose Creek, SC
Fort Mill, SC
Fort Mill, SC
Paterson, NJ
Houston, TX
Muskegon, MI
TRI
Obs/yr)1'2
37,223
16,394
255
6,478
2,610
2,432
2,179
225
216
51
22
2
1
1
1
1
1
TRI
(TWPE/yr)1'2
52,332
23,049
359
9,107
3,670
3,419
3,064
316
304
72
31
3
2
1
2
1
1
PCS3
(Ibs/yr)
594
0
PCS3
(TWPE/yr)
835
0
Source: PCSLoads2000 and TRIReleases2000.
'The TWPE loads presented for indirect dischargers represent die estimated discharge to the receiving stream. For
indirect dischargers, EPA estimated that POTWs would remove 92.1 percent of aniline in wastewater.
2Two facilities, Buffalo Color and National Ford Chemical, reported both direct and indirect discharges.
3Only two facilities reported aniline discharges in PCS, and one of these discharges was reported as zero.
Italics denote facilities no longer in operation.
Table 6-26 presents the aggregated TRI data.
6-43
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-26. Aniline Discharges Reported to TRI
Direct Dischargers
Indirect Dischargers2
Total
Number of Facilities1
3
12
15
Aniline TWPE
35
118,000
119,000
Total TWPE
1,380
121,000
123,000
Source: TRlReleases2000.
'Two direct dischargers reported some indirect discharge of aniline to TRI, which was insignificant compared to the
direct discharge amount.
2The TWPE loads presented here represent the estimated discharge to the receiving stream. For indirect dischargers,
EPA estimated that POTWs would remove 92.1 percent of aniline in wastewater.
As discussed in Section 6.3.4.1, EPA determined that aniline was the pollutant
with the third largest TWPE in the OCPSF category. In addition, all 15 aniline dischargers were
in SIC code 2865 and manufactured either aniline or dyes. For the 15 facilities in Table 6-21,
EPA determined the other pollutants of concern that were reported as discharged to TRI and
PCS. Table 6-27 shows the pollutants reported with the highest TWPE, noted as the pollutants
of concern for Focus Group 2 - Aniline Dischargers. Note that the PCS data for Focus Group 2
show that benzo(a)pyrene, reported by one direct discharge facility, contributes 84 percent of the
TWPE for Focus Group 2, whereas aniline is an insignificant part (less than 0.1 percent) of the
TWPE. These data show that besides aniline, these facilities do not discharge a uniform set of
pollutants of concern with high TWPE.
Table 6-27. Pollutants of Concern for Aniline Dischargers
Pollutant
Discharge
(lb/yr)
TWPE
Percentage of
Total TWPE
Number of
Facilities
Reporting
Pollutant
Median per
Facility Load
(lb/yr)
TRI Data
Aniline
84,745
119,143
97.0%
15
216
PCS Data
Benzo(a)pyrene
3 ,4-Benzofluoranthene
Aniline
25
25
2
106,385
10,465
35
83.8%
8.2%
0.1%
1
1
1
NA
NA
NA
Source: PCSLoads2000 and TRIReleases2000.
6.7.4
Wastewater Treatment
Most Focus Group 2 facilities are indirect dischargers, meaning their wastewater
goes through a municipal wastewater treatment plant that uses biological treatment.
Approximately 80 percent (12 out of 15) of the facilities reporting aniline releases to TRI in
2000 reported indirect discharges. Biological treatment is expected to effectively remove greater
6-44
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
than 90 percent of aniline in wastewater, as confirmed in the U.S. EPA National Risk
Management Research Labs (NRMRL) treatability database (20) and vendor information.
EPA generally establishes pretreatment standards if a pollutant interferes with or
passes through POTWs. In previous effluent guidelines, EPA found that aniline did not require
pretreatment standards. For example, for the pharmaceuticals industry effluent guideline, based
on biological treatment, EPA found that aniline does "not pass through POTWs or interfere with
the treatment works." (63 FR 50387 to 50437, September 21, 1998).
To determine if aniline discharges from OCPSF operations caused problems at
POTWs, EPA contacted five POTWs that receive discharges of aniline from seven of the aniline-
discharging facilities. EPA selected the POTWs that receive the greatest pounds of aniline
reported to TRI. These included both large and small POTWs. EPA asked the POTWs what
aniline discharges they were aware of receiving, and if any of these discharges interfere with
POTW operation. Table 6-28 lists the facilities that discharge indirectly and their respective
POTWs. EPA received responses from all five POTWs. All five POTWs reported that, although
aniline is detected in wastewater from dye and aniline manufacturers (at concentrations ranging
from approximately 300 to 1,200 mg/L), they have not had interference problems, and the aniline
appears adequately treated.
Table 6-28. Facilities That Discharge Indirectly and Their Respective POTWs
Company
BASF Corporation
Buffalo Color Corporation
Chicago Specialties LLC
Sun Chemical Corporation
Muskegon Plant
Crompton Colors Inc.
CIBA Specialty Chemicals
Corporation
H & S Chemical Co. Inc.
First Chemical Corporation
Orient Corporation of America
Nation Ford Chemical Co.
Morton International Inc. Paterson
Facility
Location
Huntington, WV
Buffalo, NY
Chicago, IL
Muskegon, MI
Newark, NJ
Newport, DE
Wallington, NJ
Pascagoula, MS
Seaford, DE
Fort Mill, SC
Paterson, NJ
POTW Name
Huntington POTW
Buffalo POTW
Chicago POTW
Muskegon County
POTW
Passaic Valley POTW
Wilmington, DE
POTW
Passaic Valley POTW
Pascagoula POTW
Seaford POTW
Rock Hill POTW
Passaic Valley POTW
POTW
Flow
(MGD)
14
0.54
32
65
NA
83
NA
4.4
1.1
8.8
NA
Information
Request Sent to
POTW?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
6-45
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-28 (Continued)
Company
Lomac LLC
Location
Muskegon, MI
POTW Name
Muskegon County
POTW
POTW
Flow
(MGD)
65
Information
Request Sent to
POTW?
Sources: TRIReleases2000 and PCSLoads2000 (for POTW flow data).
NA - Indicates that no POTW flow data were available in PCS.
Note: Three facilities reported discharges to the Passaic Valley POTW. and two reported discharges to the
Muskegon POTW.
6.7.5
Conclusions
The screening-level analysis showed high TWPE discharges from OCPSF Focus
Group 2 relative to other OCPSF discharges, and the TWPE was driven by aniline discharges.
Most of these facilities are indirect dischargers. EPA contacted five POTWs who receive
discharges from some of the facilities in Table 6-24, and three of these POTWs reported no
known interferences with their treatment systems. Because of the high treatability of aniline and
the lack of POTW interference, EPA determined that it should not consider revising pretreatment
standards for the aniline-discharging focus group (i.e, aniline manufacturers and dye
manufacturers) of the OCPSF industry at this time.
In addition, because only three facilities discharge aniline directly and because
these discharges appear to be low relative to the other facilities in this sector, EPA determined
that it should not consider revising direct discharge requirements for the aniline discharging
focus group at this time.
EPA notes, however, that if it receives data during subsequent annual reviews that
indicate otherwise, EPA may reconsider this sector of OCPSF for revision at that time.
6.8
Focus Group 3: Dioxin Dischargers
Based on analysis of TRI and PCS data, as well as information from industry
studies, EPA identified the manufacture of the following products as possible sources of dioxin
discharges: ethylene dichloride (EDC), vinyl chloride monomer (VCM), and polyvinyl chloride
(PVC). EPA refers to these collectively as vinyl chloride manufacturing. Further, EPA found that
the largest dioxin discharges (97 percent of the toxic pound equivalents) occur at large integrated
facilities that also operate chlor-alkali plants. Wastewaters from chlor-alkali plants are subject to
the Inorganic Chemicals effluent guidelines (Part 415). Dioxin discharges are also significant at
facilities that manufacture vinyl chloride without co-located chlor-alkali plants and at stand-
alone chlor-alkali plants. EPA also found that some reported dioxin discharges are associated
with organic chemicals manufacturing processes other than vinyl chloride manufacturing and
chlor-alkali plants, including chlorinated solvents production.
6-46
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
EPA identified various products manufactured by OCPSF facilities that discharge
dioxins. EPA found that most dioxin dischargers manufactured one or more of three products: 1)
chlor-alkali, 2) EDC/VCM, and 3) PVC. Therefore, for Focus Group 3, EPA reviewed those
facilities with chlor-alkali, EDC/VCM, and/or PVC manufacturing processes.
This section discusses EPA's findings on the dioxin dischargers in the OCPSF
category in the following subsections:
• Section 6.8.1 presents the facilities identified as chlorine manufacturers
(including those with chlor-alkali plants), EDC/VCM manufacturers, PVC
manufacturers, and manufacturers of other organic chemicals including
chlorinated solvents;
• Section 6.8.2 describes the chlor-alkali, EDC/VCM, and PVC processes;
• Section 6.8.3 describes sources and type of wastewater generated by
chlor-alkali, EDC/VCM, and PVC processes;
• Section 6.8.4 lists the pollutants of concern identified based on available
data;
• Section 6.8.5 lists the wastewater treatment-in-place based on available
data; and
• Section 6.8.6 describes industry trends.
6.8.1 Facilities
EPA identified the manufacturing processes of the following products as sources
of dioxin:
Chlor-alkali;
EDC/VCM;
PVC; and
• Other organic chemicals including chlorinated solvents.
EPA identified facilities in Focus Group 3 from the TRI and PCS databases and
the CCC web page, as well as reports from the Vinyl Institute and Chlorine Institute. EPA
identified the following manufacturing groups and the number of facilities in each group:
• Stand-alone chlor-alkali facilities: 24;
• Integrated chlor-alkali and EDC/VCM facilities (may also produce PVC):
12;
6-47
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Stand-alone EDC/VCM facilities (may also produce PVC): 2; and
Stand-alone PVC facilities: 18.
Table 6-29 lists facilities in Focus Group 3 and the products they manufacture.
Note that OCPSF facilities that reported the highest discharges of dioxin to TRI have multiple
operations, including chlor-alkali plants and EDC/VCM operations.
Table 6-29. OCPSF Dioxin Dischargers in the United States
Company
Ashta
Bayer
Certainteed Corporation
Colorite Specialty Resins
Dow Chemical
DnPont
Formosa Plastics
GE Plastics
Geismar Vinyls
Georgia Gulf
Georgia Pacific
Keysor Century
Kuehne
Location
Ashtabula, OH
Baytown, TX
Westlake, LA
Burlington, NJ
Freeport. TX2
Plaquemine, LA
Texas City, TX
Niagara Falls, NY
Baton Rouge, LA
Delaware City, DE
Illiopolis, IL3
Point Comfort, TX
Burkville, AL
Mount Vernon, IN
Geismar, LA4
Aberdeen, MS
Oklahoma City, OK
Plaquemine. LA
Westlake, LA
Green Bay. WI
Muskogee, OK5
Rincoa GA
Geismar, LA6
Kearny, NJ
Product Type
Chlorine
Chlorine
PVC
PVC
Chlorine, EDC
Chlorine, EDC
PVC
Chlorine
Chlorine, EDC, VCM, PVC
PVC
PVC
Chlorine, EDC, VCM, PVC
Chlorine
Chlorine
EDC, VCM, PVC
PVC
PVC
Chlorine, EDC, VCM, PVC
EDC,
Chlorine
Chlorine
Chlorine
PVC
Chlorine
Discharge Status
No reported discharge1
Direct/Major
Direct/Major
Direct/Major
Direct/Major
Direct/Major
Indirect
Direct/Major
Direct/Major
Direct'/Major
Direct/Major
Direct/Major
Direct1 /Major
Direct/Major
Direct/Major
Indirect
Direct/Major
Direct/Major
Transfer to Sasol North
America
Direct'/Major
Direct/Major
Direct/Major
Indirect
Direct'/Minor
6-48
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-29 (Continued)
Company
Occidental Chemical
Company
Olin
Oxy Vinyls
Oxychem
Pioneer
Polyone Corporation
PPG Industries, Inc.
Shintech Inc.
Vulcan
Vygen
Location
Convent LA
Delaware City, DE
Ingleside, TX
Hahnville. LA
Mobile, AL
Niagara Falls, NY
Pottstown. PA
Augusta, GA
Charleston, TN
Mclntosh, AL7
Niagara Falls, NY
Deer Park, TX*
LaPorte. TX
Louisville, KY
Pasadena, TX
Pedricktowa NJ
Muscle Shoals, AL
Henderson, NV
St. Gabriel, LA
Tacoma, WA9
Burlington, NJ10
Henry, IL
Lake Charles, LA
Natrium, WV
Addis. LA11
Freeport. TX
Geismar, LA
Port Edwards, WI
Wichita, KS
Ashtabula, OH12
Product Type
Chlorine, EDC
Chlorine
Chlorine, EDC
Chlorine
Chlorine
Chlorine
PVC
Chlorine
Chlorine
Chlorine
Chlorine
Chlorine, EDC, VCM, PVC
Chlorine, EDC, VCM, PVC
PVC
PVC
PVC
Chlorine
Chlorine
Chlorine
Chlorine
PVC
PVC
Chlorine, EDC
Chlorine
PVC
PVC
Chlorine, EDC
Chlorine
Chlorine
PVC
Discharge Status
Direct/Major
Direct/Major
Direct/Major
Direct/Major
Direct'/Major
Both /Major
Indirect
Direct/Minor
Direct/Major
No reported discharge1
Direct'/Major
Direct/Major
Direct'/Major
No reported discharge1
Direct/Major
Direct/Major
Direct'/Major
Direct'/Major
Direct
Direct'/Major
Direct' '/Minor
No reported discharge'
Direct
Direct
Direct'/Major
Direct/Minor
Direct
No reported discharge1
No reported discharge'
No reported discharge1
6-49
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-29 (Continued)
Company
Westlake Monomers
Location
Calvert City, KY
Pensacola, FL13
Product Type
Chlorine, EDC
PVC
Discharge Status
Direct'/Major
No reported discharge1
Sources: Chlorine Chemistry Council web page, Chlorine Institute Report, Vinyl Institute Report, Innovation Group
web page. Chemical Backgrounders web page, TRIRe/eases2000 and PCSLoads2000. and individual company web
pages.
Italics indicate that the facility has been idled or closed.
'No releases of TRI chemicals to surface water or transfers to POTWs were reported to TRI for 2000.
2Dow Chemical Oyster Creek is considered part of the Freeport plant.
'Formosa Plastics purchased the Illiopolis plant from Borden in 2002.
4Giesmar Vinyls, an affiliate of Westlake Group, purchased Borden's vinyl operations. Plants were idled in 2002.
•The Georgia Pacific Muskogee, OK plant was idled, according to a phone conversation with Steve Landers, 6/9/04.
6Keysor Century closed in 2003.
7Oliif s Mclntosh, AL site also includes the Sunbelt joint venture chlor-alkali plant.
8The Oxy Vinyls Deer Park, TX chlor-alkali plant was idled December 2001.
9The Pioneer Tacoma, WA plant was idled February 2002 according to Chlorine Institute.
'"Polyone's Burlington, NJ site appears to be a vinyl compounding site. It was closed in 2002.
1 'Shintech purchased Borden's Addis plant in 2002.
12The Vygen Ashtabula plant appears to be shut down as of 1993.
13The Westlake Pensacola plant appears to be shut down.
EPA also identified 11 OCPSF facilities reporting dioxin discharges that
manufacture organic chlorine chemicals other than EDC, VCM, or PVC. The products made by
the facilities listed in Table 6-30 could not be classified into a single group. The total dioxin
TWPE from these 11 facilities is 120,000 Ib-equivalent, which is less than 1 percent of the 5.7
million TWPE from Focus Group 3 (based on 2000 TRI data).
EPA also conducted economic analyses of portions of the OCPSF industry. For
information about EPA's small business analysis of the chlor-alkali and vinyl chloride industries,
see the August 3, 2004 Memorandum entitled OCPSF: Number of Small Businesses in Chlor-
Alkali and Vinyl Chloride Industries (located in the docket). For information about EPA's
economic analysis of OCPSF dioxin dischargers, see the August 13, 2004 Memorandum entitled
Organic Chemicals, Plastics, and Synthetic Fiber Focus Group 3: Dioxin Dischargers—Industry
Profile (located in the docket).
Table 6-30. Facilities Reporting Dioxin Discharges to TRI that Manufacture Other
Organic Chemicals in the United States
Company
Atofina Petrochemicals
Celanese Acetate
Condea Vista
Location
La Porte, TX
Narrows, VA
Baltimore,MD
Product Type
Polypropylene.
Cellulose acetate, flake, filament, tow.
Aluminum chloride LAB, muriatic acid
(hydrochloric acid), specialty alkylates.
Discharge
Status
Direct/Major
Direct/Major
Both/Minor
6-50
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-30 (Continued)
Company
Cytec Industries
Dover Chemical
Dow Chemical
DuPont Chamber
Works
Oxychem
Sasol North America,
Inc.
Velsicol Chemical
Location
Wallingford, CT
Dover, OH
Midland, MI
Deepwater, NJ
Castle Hayne, NC
Lake Charles, LA
Westlake, LA
Memphis, TN
Product Type
Aliphatic isocyanate resins, polyurethane,
meta diisopropenybenzene, adhesion
polymers, formaldehyde resins, crosslinking
monomers, aerosol surfactants, coating
chemicals.
Chlorinated paraffins, surfactants, and
lubricants.
Wide range of chemical products.
Fluorochemicals, elastomers, Hytrel
polyester elastomer.
Copper chromated arsenate.
Ethylene and propylene and by-products
including crude butadiene, pyrolysis
gasoline, hydrogen.
Alcohols, alumina, ethylene, LAB, solvents,
paraffins, ethoxylates.
Benzoate esters, polymerics, and
monomerics.
Discharge
Status
Direct/Major
No reported
discharge1
Direct/Major
Direct/Major
Direct/Major
No reported
discharge1
Direct/Major
Indirect
Sources: TRIReleases2000.
'No water discharges were
, individual company web pages.
reported to TRI for 2000.
6.8.2
6.8.2.1
Process Descriptions
This section discusses the processes used to manufacture the following products:
Chlor-alkali;
EDC/VCM; and
PVC.
Chlor-Alkali
The chlor-alkali process is the most common method of producing chlorine,
accounting for more than 95 percent of the world chlorine production (28). In addition to the
chlor-alkali process, chlorine may also be produced as a co-product or by-product by four other
methods (21):
• Downs Sodium Process: Molten salts, instead of brine, are electrolytically
converted to chlorine;
• Uhde HC1 Decomposition Process: HC1, instead of brine, is
electrolytically converted to chlorine;
6-51
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Potassium Nitrate Production: Nonelectrolytic nitric acid/salt process
produces chlorine as a co-product; and
• Magnesium Production: Electrolytic process produces chlorine as a by-
product.
Since chlor-alkali accounts for the majority of chlorine production, and has been
identified as a source of dioxin, the remainder of this section will focus on the chlor-alkali
process. The process produces chlorine gas and sodium hydroxide (caustic) by passing an
electric current through a sodium chloride brine solution. Although less common, potassium
chloride may also be used as the feed stock to produce chlorine and potassium hydroxide. The
chlor-alkali process uses three electrolytic technologies: mercury cell, asbestos diaphragm cell,
and membrane cell. The diaphragm cell is the predominant technology used in the United States
(5, 28).
The mechanism for separating chlorine and sodium products depends on the type
of cell used (14). In the mercury cell process, mercury forms an amalgam with the sodium. The
amalgam flows from the cell to the decomposer, where it reacts with water to form sodium
hydroxide, hydrogen gas, and mercury. Figure 6-5 shows the chlor-alkali process using a
mercury cell.
In the asbestos diaphragm process, sodium ions selectively permeate an asbestos
barrier. The membrane cell process is similar to the diaphragm cell process except that an ion
exchange membrane replaces the diaphragm. In both processes, sodium ions react with water to
form sodium hydroxide and hydrogen gas. Figure 6-6 shows the chlor-alkali process using a
diaphragm or membrane cell.
Prior to its use in the electrolytic cell, the sodium chloride brine is treated to
remove any metal impurities. The metals are precipitated using caustic solutions and exit the
brine preparation system as a slurry. This slurry is filtered, and the water is sent to wastewater
treatment (21). The solid waste is called "brine muds" and is a listed hazardous waste for
mercury and diaphragm cells. In the chlorine production process, the following wastes are listed
hazardous wastes:
• K071: Brine purification muds from the mercury cell process in chlorine
production, where separately prepurified brine is not used;
• K073: Chlorinated hydrocarbon waste from the purification step of the
diaphragm cell process using graphite anodes in chlorine production; and
6-52
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Chlorine „, . .
>„.„.,. w Chloni
• Punfication >• prndu
Demister System
t
^ Condensates 1 ^_^_^
"^ Indirect
(Cooler) Het
A
.-^
1 """ Electrolytic Cell -w
f^ ^__ Na+Cl + Hg ->Na:HG + %C12 ^ Decompose
Na+ OH" + /zH
Mercury -J
s
•<— 1
^ Heat ^ Brine ^
"^ Exchanger "^ Preparation ^
Acid ^ ^ Caustic Solutions,
Metal . Bnne Slurry (added to raise pH
Precipitates ~ Filtration System
1
KRV
^^M
- Liquid or sas stream Cell Room Sump
• Wastewater stream Waters
le
ct
Indirect
3 Cell -^ Contact H.E.
(Cooler)
> k
-1- Mr,
M
Caustic
Filtration
System
of Brine)
x X ^
Hydrogen TT ,
TT, -r *• ^^ Hydrogen
Punfication 9 „ „ , .
„ , ^ By-Product
System
A
•w Caustic
Product
H
s
s-
f
Wastewater Treatment — ^-Effluent
' — ^ Sludge (Kl 06)
Figure 6-5. Mercury Cell Chlor-Alkali Process
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Chlorine
Purification System
Chlorine
Product
Condensates
Brine Feed
Metal
Precipitates
Brine
Preparation
Brine Slurry
Filtration i
Cooling
Anode
Brine
Dechlorination
5
Hydrogen
Purification
System
•w Hydrogen
"^ By-Product
Cathode
Caustic
Purification
System
Cell Room Sump
Waters
I
Wastewater Treatment
Effluent
Caustic
Product
Key
Gas stream
Liquid stream
Wastewater stream
Figure 6-6. Membrane or Diaphragm Cell Chlor-Alkali Process
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• K106: Wastewater treatment sludge from the mercury cell process in
chlorine production.
6.8.2.2 Ethylene Dichloride and Vinyl Chloride Monomer
More than 80 percent of the EDC produced in the U.S. is used for the production
of VCM. The process of producing VCM, where EDC production is an intermediate step, is
known as the "balanced process," shown in Figure 6-7. In the balanced process, EDC is
produced by direct chlorination and oxychlorination:
1) Direct Chlorination:
C12 + C2H4 -> C2H4C12
Chlorine Ethylene EDC
2) Oxychlorination:
C2H4 + O2 + HC1 -> C2H4C12 + H2O
Ethylene Oxygen Hydrochloric Acid EDC Water
In direct chlorination, ethylene is reacted with chlorine gas in the presence of a
catalyst (usually iron chloride) at temperatures ranging from 50°C to 70°C (25). This reaction
typically occurs in a liquid-phase reactor.
In oxychlorination, the reaction utilizes the HC1 by-product from VCM
production, conserving the use of raw materials such as chlorine gas. Reactors are typically
fixed or fluidized beds with a copper chloride catalyst. The exothermic reaction is carried out in
three steps at temperatures exceeding 200°C (9):
1) Chlorination of ethylene:
2CuCl2 + C2H4 -> 2CuCl + C2H4C12
2) Oxidation of CuCl:
2CuCl + 1/2O2 -> Cu2OCl2
3) Rechlorination with HC1:
2HC1 + Cu2OCl2 -> 2CuCl2 + H2O
The reactor effluent is quenched and condensed before combining with the EDC
produced from direct chlorination. The combined crude EDC product is fed through a series of
distillation columns before it is sent to the EDC cracking furnace to produce VCM. All VCM
plants using the EDC cracking reaction are integrated with EDC production facilities (25). The
EDC cracking reaction (dehydrochlorination), shown below, is carried out in a furnace at
temperatures ranging from 450°C to 650°C (25):
6-55
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Chlorine
Ethylene-
Oxygen
Tars to Heavy
Ends Storage on
HC1 Recovery
(K019)
Key
C =
R =
EDC =
VCM =
Condenser
Reboiler
Ethylene Dichloride
Vinyl Chloride Monomer
Gas stream
^^_ Liquid stream
— Wastewater stream
EDC Recycle to
EDC Purification
• Effluent
Sludge
(K174)
Figure 6-7. Flow Diagram for EDC/VCM Balanced Process
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Dehydrochlorination:
C2H4C12 -> C2H3C1 + HC1
EDC VCM Hydrochloric Acid
The dehydrochlorination reaction produces a gas containing vinyl chloride,
unconverted EDC, and HC1. This gas is quenched and condensed before passing through a series
of distillation columns. HC1 is removed in the first column and recycled to the oxychlorination
reaction. Unconverted EDC is removed in the second column and recycled through EDC
purification before reentering the cracking furnace.
The heavy and light ends from the distillation columns in the EDC and VCM
purification trains contain halogenated hydrocarbons. Most of this waste is incinerated on site,
but a portion is transferred to nonvinyl facilities for by-product recovery. Chlorinated solvents,
such as perchloroethylene and trichloroethylene, are manufactured from these hydrocarbon
byproducts that are recovered from the EDC/VCM process (25).
In the EDC/VCM process, the following wastes are listed hazardous wastes:
• K174: Wastewater treatment sludges from ethylene dichloride or vinyl
chloride monomer production from the balanced process; and
• K175: Wastewater treatment sludges from vinyl chloride monomer
production using an acetylene-based process (not discussed in this report).
6.8.2.3 Polvvinvl Chloride
Purified VCM is fed to a polymerization step to produce PVC. Polymerization
processes that are used in the U.S. to produce PVC include:
• Suspension;
• Dispersion (emulsion);
• Bulk (mass); and
• Solution.
Since suspension polymerization accounts for approximately 87 percent of U.S.
production (25), the remainder of this section focuses on that process.
In PVC production, polymerization is induced by adding free radical initiators.
The initiators are soluble in VCM and typically include peresters, peroxycarbonates, peroxides,
or azo compounds. The polymerization reaction, shown below, occurs in a batch reactor at
temperatures ranging from 52° to 70°C (12).
6-57
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
H H HH HH HHHH
II II II I I I I
I C= C -*• I - C- C- + C= C -*> I - C- C- C- C-
II II II I I I I
H Cl H Cl H Cl H Cl H Cl
(VCM) (PVC)
The reactor effluent contains residual VCM and a PVC slurry. Residual VCM
might be in a gas or liquid phase or trapped in the PVC resin. Steam stripping can remove
residual VCM which is recovered and recycled through the polymerization process. The PVC
slurry is mixed with other PVC batches and sent through a dewatering process, where the
polymer is separated from the process water. Water might be either recycled through the process
or sent to wastewater treatment. As a last step, the PVC product is dried and screened to remove
oversize and undersize particles. Figure 6-8 shows the PVC process.
6.8.3 Wastewater Sources
The chlor-alkali process involves three major purification pathways: chlorine
purification, caustic purification, and hydrogen gas by-product purification. The wastewaters
from these steps are combined prior to treatment. EPA did not identify any major sources of
contact wastewater in the hydrogen gas purification steps. The caustic product from the mercury
cell process is filtered to remove any residual mercury, and backwash from this filtration step is
a source of wastewater. The chlorine gas stream exiting the mercury cell is cooled in an indirect
contact heat exchanger followed by a wet demister. Dioxin might form as chlorine gas reacts
with organic impurities in the process equipment (14). Thus, EPA believes the chlorine
condensate wastewater stream is the main source of dioxin discharged from the chlor-alkali
process.
The EDC/VCM process can produce dioxin during the oxychlorination reaction
(14). This reaction can produce dioxin by combining hydrochloric acid as a source of chlorine,
ethylene as the organic matter, temperatures over 200°C, the CuCl2 catalyst, and oxygen as a
reactant. EPA concludes that the most likely source of dioxins released to wastewater is the post-
oxychlorination quenching step, when the gaseous product stream comes into contact with
quench water.
6-58
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
VCM and
Initiators
>
VCM to Recovery w
I
' wl Polvmnriyation 1
VCMR
Sysl
Reactor
vo
PVC
Steam
Stripper
Key
VCM = Vinyl Chloride Monomer
PVC =Polyvinyl Chloride
^^— Liquid or gas stream
^^~ Wastewater stream
Dewatering/
Centrifuge /
7
Wastewater to Recycle
" or Treatment
PVC Product to
Storage
Figure 6-8. Process Flow Diagram for Suspension PVC Productions
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Wastewater sources in the PVC process include the polymer dewatering operation
and VCM recovery. The Vinyl Institute Dioxin Characterization program detected dioxin in
wastewater from facilities that produce only PVC (see Section 6.8.4.2). Therefore, EPA has also
identified the vinyl chloride polymerization step as another potential source of dioxin.
6.8.4
Pollutants of Concern
This section discusses the pollutants of concern for Focus Group 3. By far, dioxin
is the most toxic pollutant in wastewater discharges from this group. Other toxic pollutants also
discharged by Focus Group 3 that rank high in terms of toxic-weighted pounds, include sulfide,
total residual chlorine, and hexachlorobenzene. Section 6.8.4.1 presents the pollutants of
concern identified for each product group. Section 6.8.4.2 focuses on dioxin discharges.
6.8.4.1
Pollutants of Concern by Product Group
EPA reviewed pollutant discharges reported to TRI and PCS, and ranked
pollutants based on TWPE estimates for the following groups of facilities:
• Stand-alone chlor-alkali manufacturers;
• Stand-alone manufacturers of EDC/VCM (may also produce PVC);
• Integrated chlor-alkali and EDC/VCM manufacturers (may also produce
PVC); and
• Stand-alone manufacturers of PVC.
Tables 6-31 through 6-34 present the pollutants that rank high in terms of toxic-
weighted pounds for each group.
EPA identified 36 facilities that produce chlorine using the chlor-alkali process.
Of these facilities, 24 are not integrated with a vinyl chloride process. Table 6-31 presents the
most toxic pollutant discharges reported by these facilities to TRI and PCS for 2000.
Table 6-31. Pollutants of Concern for 24 Stand-Alone Chlor-Alkali Manufacturers1
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE
for Source
Pollutant
Median per
Facility Load
(Ib/yr)
TRI Data
Dioxin and dioxin-like
compounds
Mercury
Chlorine
0.0086
69
3,578
98,618
8,078
1,742
89
7
2
3
5
2
0.0019
12
1,789
6-60
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-31 (Continued)
Sodium nitrite
2000 Discharges
Pounds
3,000
TWPE
1,120
Percentage of
Total TWPE
for Source
1
Pollutant
1
Median per
Facility Load
(Ib/yr)
NA
PCS Data
Sulfide, Total as S
Total residual chlorine
Mercury, Total as Hg
Chloride
Benzo(a)pyrene
Copper, Total as Cu
21,944
46,043
165
166,221,615
0.90
3,705
61,456
22,422
19,314
4,047
3,855
2,322
53
19
17
4
3
2
1
10
8
3
1
7
NA
328
20
39,583.393
NA
76
Sources: PCSLoads2000 and TRIReleases2000.
NA - A median load was not calculated because only one facility reported the pollutant.
'May manufacture additional chemicals, but do not manufacture EDC, VCM, or PVC.
EPA identified 14 facilities that produce EDC/VCM. Of these facilities, two are
not integrated with a chlor-alkali process. Table 6-32 presents the most toxic pollutant
discharges reported by these nonintegrated facilities to TRI and PCS for 2000.
Table 6-32. Pollutants of Concern for Stand-Alone EDC/VCM Manufacturers (No Chlor
Alkali)
Pollutant
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE for
Source
Number of
Facilities
Reporting
Pollutant
Median per
Facility Load
(Ib/yr)
TRI Data
Dioxin and dioxin-like
compounds
Chlorine
0.0013
347
2,477
169
89
6
1
1
NA
NA
PCS Data
Copper, Total as Cu
Chromium, Total as Cr
Zinc, Total as Zn
51
102
108
32
8
5
71
17
11
1
1
1
NA
NA
NA
Sources: PCSLoads2000 and TRIReIeases2000.
NA - A median load was not calculated because only one facility reported the pollutant.
EPA identified 12 chlor-alkali/EDC/VCM integrated sites. Table 6-33 presents
the most toxic pollutant discharges reported by these integrated facilities to TRI and PCS for
2000.
6-61
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-33. Pollutants of Concern for Integrated Chlor-Alkali and Vinyl Facilities
(Manufacturers of Chlor-Alkali and EDC/VCM, May Also Produce PVC)
Pollutant
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE
for Source
Number of
Facilities
Reporting
Pollutant
Median per
Facility Load
(lb/yr)
TRI Data
Dioxin and dioxin-like
compounds
Hexachlorobenzene
Chlorine
Copper compounds
3.24
41
9,399
3,345
5,576,624
29,691
4,577
2,097
>99
0.53
0.08
0.04
9
3
6
4
0.051
18
568
163
PCS Data
Total residual chlorine
Vinyl chloride
Chromium, hexavalent
Copper, total as Cu
Phenolics, total recoverable
Mercury, total recoverable
Mercury, total as Hg
Lead, total as Pb
Chloride
43,608
49.982
10,614
5,060
82,460
12.2
11.7
582
46.191,749
21,237
5,793
5,433
3,172
2.309
1,425
1,368
1,303
1.125
46
13
12
7
5
-5
j
3
3
2
9
1
1
11
1
1
o
J
4
1
723
NA
NA
228
NA
NA
1.9
81
NA
Sources: PCSLoads2000 and TRIReleases2000.
NA - A median load was not calculated because only one facility reported the pollutant.
EPA identified 18 facilities that operate a stand-alone PVC process. Table 6-34
presents the most toxic pollutant discharges reported by these facilities to TRI and PCS for 2000.
None of the 18 stand-alone PVC manufacturers reported dioxin discharges to TRI in 2000. The
Vinyl Institute, however, reported dioxin discharges to wastewater from PVC manufacturing (see
Table 6-34).
Table 6-34. Pollutants of Concern for Stand-Alone Manufacturers of Polyvinyl Chloride
Pollutant
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE
for Source
Number of
Facilities
Reporting
Pollutant
Median per
Facility Load
(lb/yr)
TRI Data
Hydroquinone
Acetaldehyde
Butyraldehyde
Vinyl Chloride
71
7,509
2,823
94
90
15
12
11
58
10
8
7
1
2
1
8
NA
3,755
NA
9.5
6-62
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-34 (Continued)
Pollutant
2000 Discharges
Pounds
TWPE
Percentage of
Total TWPE
for Source
Number of
Facilities
Reporting
Pollutant
Median per
Facility Load
(Ib/yr)
PCS Data
Benzo(a)pyrene
Mercury, total as Hg
Benzo(b)fluoranthene
Benzo(a)anthracene
Copper, total as Cu
0.396
1.80
0.396
0.396
102
1,696
211
167
71.7
63.7
70
9
7
•5
3
->
j
1
1
1
1
2
NA
NA
NA
NA
50.8
Sources: PCSLoads2000 and TRIReleases2000.
NA - A median load was not calculated because only one facility reported the pollutant.
6.8.4.2
Dioxin as a Pollutant of Concern
Based on information in TRI and information obtained in industry studies, EPA
estimates that OCPSF facilities discharged 22 million toxic weighted pounds of dioxin in 2000.
This section discusses dioxin reporting and how TWPE were calculated for dioxin and presents
the dioxin discharge data obtained from TRI, PCS, the Vinyl Institute, the CCC, EPA's Office of
Solid Waste's study of chlorinated aliphatics manufacturing, and industry responses to EPA's
2004 request for dioxin data.
Dioxin Reporting
Dioxin reporting is discussed in detail in Section 4.2.4.2. The term "dioxins"
refers to 17 poly chlorinated dibenzo-p-dioxins (CDDs) and poly chlorinated dibenzofurans
(CDFs), referred to as dioxin congeners. The toxicity of the congeners varies greatly. In this
report, the term "dioxins" is used to refer to all 17 of the 2,3,7,8-substituted CDDs and CDFs.
EPA uses Toxic Equivalency Factors (TEFs) to simplify risk assessment and regulatory control
of exposures to dioxins and still account for the relative toxicities of the 17 compounds. TEFs
are order-of-magnitude estimates of the toxicity of a compound relative to 2,3,7,8-TCDD. EPA
uses TEFs, along with the measured concentration of dioxin congeners, to calculate toxic
equivalent (TEQ) concentrations.
For OCPSF Focus Group 3, EPA estimated TWPE for data from TRI, PCS, the
CCC, and industry responses to EPA's 2004 information request. Data from these various
sources are provided differently (TM17, TEQ, measured congener concentrations). Where
possible for each data source, EPA calculated the TWPE using the EPA TWFs for the 17 dioxin
congeners. EPA revised the TWFs for dioxins in 2004. The memorandum entitled Revisions to
TWFs for Dioxin and its Congeners and Recalcuated TWPEs for OCPSF and Petroleum
Refining (available in the docket) presents the estimated TWPE for OCPSF facilities using the
6-63
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
revised TWFs. The following paragraphs discuss the method used to calculate dioxin TWPE
using each data source. Later in the section, the resulting TWPE are presented.
For TRI, facilities report the total mass of the 17 dioxin and dioxin-like
compounds released to the environment every year. This combined mass is referred to as TM-
17. This reporting method does not account for the relative toxicities of the 17 compounds.
However, reporting facilities are given the opportunity to report a facility-specific congener
distribution. Note that the dioxin congener distribution for a facility is not media specific: it
reflects the distribution for all air, water, and solid waste releases from the facility.
For facilities reporting a congener distribution to TRI, EPA used the reported
distribution to estimate the mass of each congener in the facility's wastewater releases. EPA
calculated dioxin TWPE by multiplying the estimated mass of each congener by its TWF. If no
congener distribution was reported, EPA used an average congener distribution to calculate the
mass of each congener. EPA calculated an average congener distribution for each of the four
Focus Group 3 product groups: stand-alone chlor-alkali manufacturers, chlor-alkali/EDC/VCM
manufacturers, stand-alone EDC/VCM manufacturers (may also produce PVC), and stand-alone
PVC manufacturers.
Only one nonzero dioxin discharge load was included in PCS 2000 for an OCPSF
facility. This was 0.00011 Ibs of "chlorinated dibenzo-p-dioxins, effluent" for Dover Chemical
Corporation. This facility manufactures chlorinated paraffins, surfactants, and lubricants (6),
and EPA considers it as part of the "Other Organics" dioxin discharging facilities. To calculate
the TWPE, EPA applied the average congener distribution derived from TRI data for the "Other
Organics" product group to estimate the mass of each congener in the reported PCS discharge.
EPA then applied the TWF of each congener to calculate the TWPE discharged by the Dover
Chemical facility.
Data from the CCC are reported as grams TEQ, and no congener distribution is
available. Because the grams TEQ unit represents the toxicity of all dioxin congeners detected
relative to 2,3,7,8-TCDD (24), EPA used the TWF for 2,3,7,8-TCDD to calculate the TWPE.
Section 4.2.4.2 of this TSD discusses TEQ, TEF, and TWPE for dioxin in more detail.
In response to EPA's 2004 information request, seven OCPSF Group 3
companies provided measured dioxin discharge data. These data included the concentration of
each of the 17 dioxin congeners measured in wastewater samples and the flow of the sampled
discharge. To calculate the TWPE associated with these reported discharges, EPA used the
congener-specific TWF. No assumption on congener distribution was necessary.
6-64
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
TRI Dioxin Data
Table 6-35 presents the TRI-reported dioxin wastewater discharges for 2000 and
2001 and TWPE estimates for all OCPSF Focus Group 3 facilities: chlor-alkali, EDC, VCM,
PVC manufacturers, and facilities that manufacture other organic chemicals. Some of these
facilities reported zero dioxin discharge to TRI for 2001, but others reported increased dioxin
discharges. Table 6-43 at the end of Section 6.8 lists data in conjunction with product type by
facility.
Table 6-35. Dioxin Releases Reported by OCPSF Facilities to TRI for 2000 and 2001,
Adjusted for POTW Removals
Company
Atofina
Petrochemicals
Celanese Acetate
Condea Vista
Cytec Industries
Dow Chemical
DuPont Chamber
Works
Formosa Plastics
Geismar Vinyls
(Borden)
Georgia Gulf
Occidental
Chemical
Occidental
Chemical
Corporation
Oxy Vinyls La
Porte VCM Plant
PPG Industries,
Inc.
Location
La Porte, TX
Narrows. VA
Baltimore, MD
Waffingford, CT
Freeport. TX
Midland, MI
Plaquemine, LA
Deepwater, N.T
Point Comfort,
TX
Baton Rouge, LA
Geismar. LA
Plaquemine, LA
Convent, LA
Ingleside, TX
Hahnville, LA
Niagara Falls, NY
La Porte, TX
Lake Charles, LA
Natrium, WV
Discharge
Status
Direct
Direct
Direct
Indirect
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Indirect
Direct
Direct
Direct
2000
gTM17
0.079
0.014
0.010
0.0034
3.00
562.12
5.69
745.86
0.20
0.61
0.0018
0.61
82.78
0.80
1.60
0.86
0.24
0.00054
2.33
74.79
2.81
TWPE
1,161
200
147
50
44,092
1,774,442
52,421
1,553,042
2,939
1,563
7.1
2,477
872,310
34,502
2,734
8,127
2,265
5.1
41,958
1,296,066
88221
2001
gTM17
0
0
0
0
1.00
708
2
512
0
0
0
0
0
0
1
14
0
0
1
42
2
TWPE
0
0
0
0
20,729
2,424,883
9,773
1,103,903
0
0
0
0
0
0
2,090
761,115
0
0
36,022
683,841
62,874
2000 Basis for
Estimate
O
C,M, O
M, O
M, O
M, O
M, O
C,M,O
M, O
M, O
M
M, O
C,M, O
M, O
O,M
M
M, O
M, O
M, O
M, O
M, O
M
6-65
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-35 (Continued)
Company
Sasol North
America, Inc.
Velsicol Chemical
Corporation
Location
Westlake, LA
Memphis, TN
Discharge
Status
Direct
Indirect
2000
gTM17
0.20
4.14
TWPE
2,974
16,872
2001
gTM17
0
5
TWPE
0
24,901
2000 Basis for
Estimate
E,M,O
DNR
Source: TRIReleases2000 and 2001 National TRI Data.
Notes:
DNR indicates that the facility did not respond to this question in the 2000 TRI.
M— Estimate is based on monitoring data or measurements.
C— Estimate is based on mass balance calculations, such as calculation of the amount of wastes entering and
leaving process equipment.
E— Estimate is based on published emission factors, such as those relating release quantity to through-put or
equipment type (e.g., air emission factors).
O— Estimate is based on other approaches such as engineering calculations (e.g., estimating volatilization using
published mathematical formulas) or best engineering judgment. This would include applying an estimated removal
efficiency to a treatment, even if the composition of the waste before treatment was fully identified through
monitoring data.
PCS Dioxin Data
Four facilities in Focus Group 3 are required by their NPDES permits to monitor
their effluent for 2,3,7,8-TCDD, and one facility is required to monitor for chlorinated dibenzo-
p-dioxins. According to PCSLoads2000, 2,3,7,8-TCDD was never detected in 2000. Table 6-36
presents the data obtained from the PCSLoads2000 database for dioxin. Of the four facilities in
Table 6-36, only Dow, Midland has data both in the PCS and TRI databases. For TRI, the
Midland facility reported 5.69 grams total for all 17 dioxin congeners. For PCS, they reported
no 2,3,7,8-TCDD detected.
Table 6-36. Dioxin Loads Reported by OCPSF Facilities to PCS for 2000
Facility
Formosa Plastics Corporation La
Porte, TX
Dow Chemical Midland, MI
Oxychem Lake Charles Plant
Dover Chemical Corporation
Parameter
2,3,7.8-TCDD
2,3,7,8-TCDD
2,3,7,8-TCDD
2,3,7,8-TCDD
Chlorinated Dibenzo-p-dioxins, Effluent
Ibs/yr
ND
ND
ND
ND
0.00011
PCS TWPE
ND
ND
ND
ND
418
Source: PCSLoads2000.
ND - Not detected.
6-66
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Vinyl Institute Dioxin Data
In April and May of 1995, The Vinyl Institute conducted a Dioxin
Characterization Program. Treated wastewater samples were taken from one integrated
EDC/VCM/PVC site, three integrated EDC/VCM sites, and six PVC-only sites. Dioxins were
detected in all four of the samples taken from integrated sites and in two of the samples taken
from PVC-only sites. The Vinyl Institute developed wastewater "mean emission factors" to
estimate how much dioxin is generated in wastewater from these manufacturing processes. The
Vinyl Institute used production rates for EDC and PVC from 1995 to calculate a total release
estimate. Table 6-37 summarizes the results presented in the final report.
Table 6-37. Wastewater Emission Factors and Estimated Releases for PVC-Only and
EDC/VCM/PVC Manufacturing Facilities
Product
Basis of
Estimate
PVC
EDC
Mean Emission
Factor1
(ug I-TEQDF/ 1,000
metric tons product)2
2.3 to 29
2.9 to 15
1995
Production
(1,000 metric
tons)
5,212
11,115
Estimated 1995 Dioxin
Release
(gI-TEQDF)2
0.011 to 0.15
0.032 to 0.17
Estimated 1995
TWPE (Based on
1995 Production)2
10,000 to 140,000
30 ,000 to 160,000
Source: Vinyl Institute Dioxin Characterization Program, 2001.
'Mean emission factors were derived from treated wastewater samples.
2I-TEQDF means "International Toxic Equivalents, dioxin and furan." The range of I-TEQDF values represent
emission factors estimated based on ND = 0 and ND = !/2 method detection limit (MDL). The MDLs for all
congeners except octachlorodibenzo dioxin (OCDD) and octachlorodibenzo furan (OCDF) were 10 pg/L or less.
MDLs for OCDD and OCDF were 50 pg/L or less.
Chlorine Chemistry Council (CCC) Dioxin Data
The CCC is a national trade association for manufacturers and users of chlorine
and chlorine-related products. The CCC web page provides dioxin release data for major
industrial producers and users of chlorine. The data represent releases of dioxin reported to TRI
for 2000 in grams toxic-equivalents (TEQ) for each media release (air, water, and solid waste).
In addition to providing more specifics on TRI data, the CCC and independent consultants
performed site visits and further data verification at 16 facilities, to re-estimate dioxin releases to
air, water, and land for the year 2000. Table 6-38 presents CCC data for 25 facilities, with the
further-verified data for 16 facilities in bold.
6-67
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-38. CCC Data for Dioxin Discharges from Facilities Manufacturing Chlorine or
Chlorine-Related Products for 2000
Company
Dow Chemical
Dow Chemical
Dow Chemical
Formosa Plastics
Formosa Plastics
Formosa Plastics Corporation Louisiana
Geismar Vinyls
Georgia Gulf
Georgia Gulf Lake Charles LLC
Occidental Chemical
Occidental Chemical Company
Occidental Chemical Corporation and
Oxymar
Occidental Chemical Corporation
Occidental Chemical Corporation
Occidental Chemical Corporation
Oxy Vinyls, Deer Park Chlor-alkali Plant
Oxychem
Oxychem
OxyChem
Oxy Vinyls, Battleground Chlor-alkali Plant
Oxyvinyls, Deer Park VCM
Oxyvinyls. La Porte VCM Plant
PPG Industries, Inc.
PPG Industries, Inc.
Vulcan Chemical
Location
Plaquemine, LA
Freeport, TX
Midland, MI
Delaware City, DE
Point Comfort, TX
Baton Rouge, LA
Geismar, LA
Plaquemine, LA
Westlake. LA
Convent, LA
Delaware City, DE
Ingleside. TX
Hahnville, LA
Mobile, AL
Niagara Falls, NY
Deer Park, TX
Muscle Shoals, AL
Castle Hayne, NC
Grand Island. NY1
LaPorte, TX
Deer Park, TX
La Porte. TX
Lake Charles, LA
Natrium/New Martinsville, WV
Geismar, LA
Wichita, KS
Dioxin
Water
Release
(gTEQ)
7.71
6.91
0.037
0
0
0
0
0.023
0
0.00204
0.00013
0.181
1.08
0.000036
0.01
0.54
0.000000087
0
0
0.000483
0.0308
0.00643
8.98
0.193
0
0
TWPE
7,165,568
6,425,964
34,359
0
0
0
0
21,177
0
1,894
120
168,434
1,003,972
34
9,296
501,774
0.0804
0
0
449
28,649
5,979
8,345,703
178,978
0
0
Sources: CCC web page, individual CCC reports.
'The Oxychem Grand Island facility is not included in the OCPSF Dioxin Discharging Group because it is an R&D
center. The facilirv was closed in December 2001.
6-68
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Office of Solid Waste (OSW) Dioxin Data
In 1999, EPA proposed to list, but did not list, wastewaters from the production of
chlorinated aliphatic hydrocarbons as hazardous waste (K173). EDC/VCM process wastewaters
from distillation and purification processes, scrubbers, washings, phase separation, rainwater,
and equipment washdowns would have been classified as Kl 73. EPA did not promulgate
regulations for these wastes; however, OSW analyzed untreated wastewater from eight facilities
manufacturing EDC and VCM, testing the wastewater for toxicity characteristics (TC). Table
6-39 shows the dioxin congeners that were detected in the raw wastewater, demonstrating that
EDC and/or VCM manufacturing generates dioxin in wastewater. Also, using the TEFs, EPA
calculated that the toxicity of the mixture relative to 2,3,7,8-TCDD, was 1,537,000 pg (0.0015
mg) TEQ for each liter of wastewater generated (based on the maximum concentration detected).
Table 6-39. Dioxin Congeners Detected in Raw Wastewater from EDC/VCM Operations1
Dioxin Congener Detected
1.2,3.4,6,7.8-HpCDD
1.2,3.4,6,7.8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
2,3,4,7,8-PeCDF
2,3,7,8-TCDD
2,3,7,8-TCDF
Maximum Concentration2 (pg/L)
880.000
43,000,000
12,000,000
52,000
91,000
110,000
5,300,000
1,200,000
1,200,000
430,000
230,000
17,000
82,000
Toxic Equivalency of Mixture, maximum (pg TEQ/L)
Toxic Equivalency Factor3
0.01
0.01
0.01
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.5
1
0.1
1,537,000
'Source: EPA, Best Demonstrated Available Technology (BOAT) Background Document for Chlorinated Aliphatics
Production Wastes-K173, K174, K175. OSW, July 1999 (16).
2Maximum concentration detected in wastewater from six facilities. EPA OSW sampled the influent to biological
treatment from chlorinated aliphatics manufacturers, all of which manufacture EDC/VCM in addition to other
chlorinated aliphatics. The samples were analyzed using EPA Method 1613.
3Toxic Equivalency Factors, TEFs, are a relative potency value that is based on the results of several in vivo and in
vitro studies. TEFs are order of magnitude estimates of the toxicity of a compound relative to 2,3,7,8-TCDD. TEFs
along with the measured concentration of dioxin congeners are used to calculate toxic equivalent (TEQ)
concentrations (24).
6-69
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Industry-Supplied Data
In May 2004, EPA requested process information and wastewater dioxin and flow
data from eight companies that operate 20 facilities in Focus Group 3. As of August 11, EPA
had received responses from eight companies (19 facilities). Thirteen of the 19 facilities
provided analytical data on dioxin in treated effluent wastewater: some provided analytical data
from a single sampling episode, and others provided multiple years of data. Nine facilities
reported flows corresponding to the analytical data. Dioxin congeners were detected in the
effluent wastewater of all thirteen facilities providing analytical data.
Nine facilities provided data on dioxin in untreated process wastewater. Four
companies (six facilities) claimed their data as confidential business information (CBI), and EPA
omitted data from presentations in this document where necessary, to protect CBI. See DCNs
00897 - 00899, 01027, and 01034-01037 for detailed facility data and DCN 01046 for EPA
calculation methodology, all in Section 4.4 of the docket. Table 6-40 shows the range and
median concentrations of dioxin in untreated and treated wastewater by process type, as well as
the associated wastewater flows reported.
Table 6-40. Focus Group 3 Industry Analytical Data on Dioxin in Wastewater
Type of Wastewater
Number of
Facilities
with Data
Concentration, pg-TEQ/L
Range
Median
Range of Flows,
MGD1
Raw Wastewater
Chlorine gas condensates, prior to
wastewater treatment
EDC quench water, prior to wastewater
treatment
9
2
238 - 35,674
10,231-18,537
6,198
14,384
0.008-0.217
0-0.194
Treated Effluent Wastewater
Treated process wastewater effluent,
including chlor-alkali wastewater only
Treated process wastewater effluent,
including chlor-alkali, EDC, VCM, and
other organics operations
Treated process wastewater effluent
including EDC. VCM, and other organic
operations
Treated process wastewater effluent,
including PVC operations only
8
2
6
1
0.508 - 535
0.000104- 110
3.12-174
0.333
120
55.2
34.3
NA
1.49-17.2
11.6
0.77 - 39.4
NA
Source: Industry Responses to May 2004 EPA Data Request.
NA - when only one value is presented, the range and median are not provided.
'Flows from four facilities were excluded from flow ranges to protect confidential business information. Also, some
facilities providing flow data did not provide dioxin concentration data, and visa versa.
6-70
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
For the nine facilities that submitted analytical and flow data on dioxin in effluent
wastewater, EPA calculated the grams of dioxin released per year and the associated TWPE. In
all cases, EPA had actual congener concentrations and used the congener-specific TWF to
calculate TWPE. For facilities with multiple years of data, EPA presents the mean annual dioxin
discharge. See DCN 01046 in Section 4.4 of the docket for details on how EPA calculated the
annual dioxin discharge. Table 6-41 presents the estimated dioxin TWPE by product group.
Table 6-41. Wastewater Dioxin Discharges from Focus Group 3 Based On Industry Data
Product Type
Stand-alone manufacturers of
chlor-alkali
Stand-alone manufacturers of
EDC, VCM, and other organic
operations
Integrated manufacturers of chlor-
alkali, EDC, VCM, and other
organics operations
Manufacturers of PVC only
Number of Facilities
with Data
2
0
7
0
Total Annual Dioxin Discharge
grams TEQ
1.76
NR
10.1
NR
TWPE1
285,000
NR
2.1 million
NR
Source: Industry Responses to May 2004 EPA Data Request.
NR - none reported.
'TWPE were calculated using measured congener concentrations: therefore, the grams TEQ were not used to
calculate the TWPE. For concentrations below detection limits, EPA assumed the concentration to be zero.
6.8.5
Comparison of Dioxin Release Data for OCPSF Focus Group 3
As discussed in Section 6.8.4, EPA has dioxin discharge data for OCPSF Focus
Group 3 from the TRIReleases2000, CCC, and industry responses to EPA's May 2004 data
request. TRI and CCC data represent 2000 dioxin discharges. In response to EPA's 2004 data
request, industry provided data representing various years. EPA used the reported data to
calculate an annual average. Table 6-42 compares the estimated grams and TWPE discharged
per year for each of these data sources. In all three data sets, the integrated chlor-alkali and
EDC/VCM product group accounts for more than 87 percent of the OCPSF Focus Group 3
dioxin discharges. The total TWPE estimated for OCPSF Focus Group 3 from dioxin ranges
from 2.4 - 24 million TWPE (depending on the source). EPA notes that the number and identity
of facilities contributing to the TWPE estimates from each data source in Table 6-42 are not the
same.
6-71
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-42. Comparison of Wastewater Dioxin Discharges from Focus Group 3
Product Type
Stand-alone
chl or- alkali
Stand-alone
EDC/VCM
Integrated chlor-
alkali and
EDC/VCM
Stand-alone
PVC
Total
TRI (2000 Data)
Number of
Facilities
Reporting
3
1
9
0
13
g
TM-17
3.91
0.61
1,470
0
1,480
TWPE
98,618
2.477
5.6
million
0
5.7
million
CCC (2000 Data)
Number of
Facilities
Reporting
7
2
11
0
21
gTEQ
1.28
0
24
0
26
TWPE
1.2
million
0
23
million
0
24
million
Industry Responses1
Number of
Facilities
Reporting
2
0
7
0
9
gTEQ
1.76
NC
10.1
NC
12
TWPE2
285,000
NC
2.1
million
NC
2.4
million
Sources: TRIReleases2000. CCC, Industry Responses to May 2004 EPA Data Request.
NC - not calculated. The facilities providing concentration data did not provide flows: therefore, grams of dioxin discharged could not be
estimated.
'Some facilities provided one year of data (not necessarily for 2000), and others provided multiple years of data. See DCN 01046 in the docket
for details on how EPA calculated annual discharge.
2TWPE were calculated using measured congener concentrations; therefore, the grams TEQ were not used to calculate the TWPE.
Table 6-43 lists all OCPSF Focus Group 3 facilities, grouped by product type:
• Stand-alone chlor-alkali manufacturers;
• Chlor-alkali and EDC/VCM manufacturers (may also manufacture PVC);
Stand-alone EDC/VCM manufacturers (may also manufacture PVC); and
Stand-alone PVC manufacturers.
To protect CBI, EPA can not present the facility-specific industry response data.
However, Table 6-43 presents the reported TRI and CCC data (where available) by facility.
6.8.6
Wastewater Treatment in Place
Nine of the facilities in OCPSF Focus Group 3 reported wastewater treatment
information to TRI. Of these, five reported having biological treatment for their dioxin-
containing wastestream in conjunction with other treatment, such as solids removal.
From the CCC, EPA obtained general wastewater treatment in place data from
three facilities: a chlor-alkali plant, an integrated chlor-alkali/EDC/VCM plant, and a stand-alone
EDC/VCM plant. All of these facilities are direct dischargers and are discussed in the following
subsections.
6-72
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-43. List of Facilities Manufacturing Chlor Alkali, EDC, VCM, and PVC
Site Name
Location
Discharge
Type
Product(s) Manufactured
Chlor Alkali
(Na and Cl)
Potassium
and
Chlorine
(K and Cl)
Recover
Chlorine by
Other
Means
EDC
VCM
PVC
Dioxin and Dioxin-Like Compounds Reported
for 2000
TRI
g/yr
TWPE/yr
ccc
g/yr TEQ
TWPE/yr
Comments
Stand-Alone Chlor-AIkali Manufacturers
Ashta
Bayer
DuPont
GE Plastics
GE Plastics
Kuehne
Occidental
Chemical
Company
Occidental
Chemical
Corporation
Occidental
Chemical
Corporation
Occidental
Chemical
Corporation
Olin
Olm
Ashtabula, OH
Baytown, TX
Niagara Falls, NY
Burkville, AL
Mount Vemon, IN
Keamy, N.T
Delaware City.
DE
Hahnville. LA
Mobile, AL
Niagara Falls, NY
Augusta, GA
Charleston, TN
Direct
Direct
Direct and
Indirect
(dioxin
reported as
indirect)
Membrane &
HC1 cells
Diaphragm &
membrane cells
Diaphragm cell
Membrane cell
Mercury cell
Diaphragm &
membrane cell
Membrane cell
Diaphragm cell
Mercury cell
Mercury cell
Mercury
cell
Membrane
cell
Downs
sodium
0.86
0.24
8.127
2,270
0.00013
1.08
0.0000364
0.01
120
1.003,972
34
9,296
Additional products:
plastics, coatings,
polyurethanes and
industrial chemicals
Chlorine Institute lists
location as Delaware City,
DE, but environmental
data only exist for Keamy,
N.T.
Location also noted as Tafl
on CCC web site.
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-43 (Continued)
Site Name
Olin
Sunbelt/din
Olin
Oxychem
Pioneer
Pioneer
Pioneer: IDLED
2002
PPG Industries.
Inc.
Vulcan
Vulcan
Georgia Pacific
Georgia Pacific
Georgia Pacific
Location
Mclntosh, AL
Mclntosh, AL
Niagara Falls. NY
Muscle Shoals.
AL
Henderson, NV
St. Gabriel, LA
Tacoma, WA
Natrium/New
Martinsville. WV
Port Edwards, WI
Wichita, KS
Green Bay, WI
Muskogee. OK
Rincon. GA
Discharge
Type
Direct
Direct
Produces) Manufactured
Chlor Alkali
(Na and Cl)
Diaphragm cell
Membrane cell
Mercury cell
Diaphragm cell
Mercury cell
Diaphragm &
membrane cell
Diaphragm &
mercury cell
Mercury cell
Diaphragm &
membrane cells
Diaphragm cell
Membrane cell
Membrane cell
Potassium
and
Chlorine
(K and Cl)
Mercury
cell
Recover
Chlorine by
Other
Means
EDC
VCM
PVC
Dioxin and Dioxin-Like Compounds Reported
for 2000
TRI
g/yr
2.81
TWPE/yr
0.00000008
65
88.221
ccc
g/yr TEQ
0.193
0
TWPE/yr
0.0804
178.978
0
Comments
Co-located with the jointly
ventured Olin/PolyOne
Mclntosh plant.
Co-located with the jointly
ventured Olin/PolyOne
Mclntosh plant.
Idled 02/02 according to
Chlorine Institute.
Chlor-Alkali and EDC/VCM Manufacturers (May Also Manufacture PVC)
Dow
Dow
Georgia Gulf
PPG
Plaquemine, LA
Freeport. TX
Plaquemine. LA
Lake Charles, LA
Direct
Direct
Direct
Direct
Diaphragm cell
Diaphragm &
membrane cells
Diaphragm cell
Diaphragm &
mercury cells
Magnesium
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
747
563
82.87
75
1.553.042
1.774.442
872.310
1.296,066
7.71
6.91
0.0228
8.98
7.165.568
6.425.964
21.177
8.345,703
Dow Chemical at Oyster
Creek is considered part of
the Freeport Plant.
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-43 (Continued)
Site Name
Occidental
Chemical
Corporation and
Oxymar
Occidental
Chemical
Formosa Plastics
Formosa Plastics
Corporation
Louisiana
Oxy Vinyls. La
Porte VCM Plant
Oxy Vinyls.
Battleground
Chlor Alkali Plant
Oxy Vinyls. Deer
Park PVC Plant
Oxy Vinyls, Deer
Park VCM
Oxy Vinyls, Deer
Park Chlor Alkali
Plant
Vulcan
Vulcan/Mitsui
Westlake
Monomers
Location
Ingleside, TX
Convent. LA
Point Comfort, TX
Baton Rouge, LA
La Porte. TX
Deer Park. TX
Geismar, LA
Carvert City, KY
Discharge
Type
Direct
Direct
Direct
Direct
Direct
No reported
discharge
Direct
Direct
Direct
Produces) Manufactured
Chlor Alkali
(Na and Cl)
Diaphragm cell
Diaphragm cell
Membrane cell
Diaphragm cell
Diaphragm cell
Yes
Diaphragm cell
Membrane cell
Membrane cell
Potassium
and
Chlorine
(K and Cl)
Recover
Chlorine by
Other
Means
EDC
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
VCM
Yes
Yes
Yes
Yes
Yes
Yes
PVC
Y Yes
Yes
Yes
Dioxhi and Dioxin-Like Compounds Reported
for 2000
TRI
g/yr
1.60
0.80
0.61
0.0018
2.33
TWPE/yr
2.734
34.502
1.563
7
41,958
ccc
g/yr TEQ
0.181
0.002
0
0
0.00643
0.000483
0.0308
0.540
0
TWPE/yr
168,434
1,896
0
0
5.979
449
28,649
501,774
0
Comments
Occidental and Oxymar
are the same plant located
in Gregory, TX, (Corpus
Chrisli or Ingleside, TX -
all listings are the same
location). EDC Plant
temporarily idled since
June 2001.
Plants are co-located
Plants are co-located.
Clilor-alkali plant idled
since December 27, 2001.
Formerly a Goodrich
Facility.
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-43 (Continued)
Site Name
Location
Discharge
Type
Produces) Manufactured
Chlor Alkali
(Na and Cl)
Potassium
and
Chlorine
(K and Cl)
Recover
Chlorine by
Other
Means
EDC
VCM
PVC
Dioxm and Dioxin-Like Compounds Reported
for 2000
TRI
g/yr
TWPE/yr
ccc
g/yr TEQ
TWPE/yr
Comments
Stand-Alone EDC/VCM Manufacturers (May Also Manufacture PVC)
Borden Chemical
(Geismar Vinyls)
Georgia Gulf,
Lake Charles LLC
Geismar, LA
Westlake, LA
Direct
Transfer to
Sasol N.A.
Yes
Yes
Yes
Yes
Yes
0.61
2.477
0
0
0
0
Geismar Vinyls purchased
Borden's EDC/ VCM/ PVC
plant in 2003.
Also known as Condea
Vista Chemical
Coiporation and Vista
Chemical. Location
sometimes listed as Lake
Charles. Discharges to
Sasol N.A.
Staud-Alone PVC Manufacturers
Certainteed
Coiporation
Colorite Specialty
Resins
Dow Chemical,
Texas City Plant
Formosa Plastics
Formosa Plastics
Georgia Gulf
Georgia Gulf
Chemicals &
Vinyls LLC
Occidental
Chemical
Coiporation
Oxy Vinyls
Oxy Vinyls
Westlake. LA
Burlington. N.T
Texas City, TX
Delaware City,
DE
Illiopolis, IL
Aberdeen, MS
Oklahoma City,
OK
Pottstowu, PA
Louisville, KY
Pedricktown, N.T
Direct
Direct
Indirect
No reported
discharge
Direct
Indirect
No reported
discharge
Indirect
No reported
discharge
Direct
Yes
Yes
Y'es
Y'es
Yes
Yes
Yes
Yes
Yes
Yes
0
0
Same plant as Geon and
Polyone in Burlington.
Formerly Union Carbide -
merged with Dow in 200 1 .
Also known as Georgia
Gulf.
Purchased from Borden in
2002.
Formerly PolyOne.
Formerly PolyOne.
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-43 (Continued)
Site Name
Oxy Vinyls L.P.,
Pasadena PVC
Plant
Polyone
Corporation
Polyone
Corporation
Shin tech Inc.
Shintech Inc.
Vygen
Westlake PVC
Corporation
Westlake PVC
Corporation
Location
Pasadena, TX
Burlington, N.T
Henry, IL
Addis, LA
Freeport, TX
Ashtabula, OH
Calvert City, KY
Pensacola. FL
Discharge
Type
Direct
No reported
discharge
No reported
discharge
Direct
Direct
No reported
discharge
Direct
No reported
discharge
Produces) Manufactured
Chlor Alkali
(Na and Cl)
Potassium
and
Chlorine
(K and Cl)
Recover
Chlorine by
Other
Means
EDC
VCM
PVC
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Dioxhi and Dioxin-Like Compounds Reported
for 2000
TRI
g/yr
TWPE/yr
CCC
g/yr TEQ
TWPE/yr
Conunents
Vinyl compounding site -
closed in 2002.
Also known as Geon.
Purchased from Borden in
2002.
Appears to be closed as of
1993.
Appears to be closed.
ON
Sources: TRIReleases2000; CCC; internet searches; Vinyl Institute's The Vinyl Institute Report Dioxin Characterization Program. May 15, 2001; EPA. Memorandum: Review of Total
TWPE Loads for Dioxin/Dioxin-Like Compounds for the Inorgam'c Chemicals Manufacturing Category, September 18, 2003; and personal correspondence.
Cl - Chlorine
K - Potassium
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.8.6.1 Chlor-Alkali
The PPG plant in Natrium, WV is an example of a chlor-alkali manufacturing site
that does not produce vinyl chloride. The plant produces chlorine and caustic using diaphragm
cell and mercury cell technologies. Treatment of the wastewaters from the diaphragm cell
process includes neutralization and chemical precipitation. Wastewaters from the mercury cell
process are treated using chemical precipitation followed by polishing with activated carbon for
mercury removal. (See DCN 01035 in the docket).
6.8.6.2 Integrated Chlor-Alkali/EDC/VCM
Dow Chemical in Freeport, TX is an example of an integrated chemical plant that
produces chlorine and caustic using diaphragm and membrane cells, ethylene, EDC using two
oxychlorination units, VCM, chlorinated solvents, and other chemical products. The wastewater
treatment facility operates a physical/chemical and biological wastewater treatment system with
effluent filtration for combined process wastewaters from chlor-alkali, EDC/VCM, and chlor-
hydrin processes. As of 2001, VCM process wastewater is filtered after steam stripping and
prior to biological treatment. Wastewater treatment plant sludges, spent oxychlorination EDC
catalyst, asbestos from chlor-alkali diaphragm cell operations, and other solid wastes are
disposed of in an on-site landfill. (See DCN 00899 in the docket).
6.8.6.3 EDC/VCM
The Oxy Vinyls LaPorte VCM plant is an example of a stand-alone EDC/VCM
plant. In 2000, the facility produced EDC using a combination of direct chlorination and
oxychlorination. The facility shut down its high temperature direct chlorination EDC process in
April 2002. EDC/VCM process wastewaters are treated using steam stripping followed by
biological treatment. Wastewater treatment plant sludges and spent oxychlorination EDC
catalyst are disposed of off-site in secure landfills. (See DCN 01034 in the docket).
6.8.7 Industry Trends
This section discusses the trends that EPA observed in the industry based on
available data. Section 8.7.1 discusses the trend of dioxin discharges from the industry, and
Section 8.7.2 discusses the production trend of the chlorine industry.
6.8.7.1 Dioxin Discharge Trends
The CCC)reviewed information from select CCC member plants to develop year
2000 release estimates of dioxin for use in EPA's dioxin reassessment1. If plants had made
significant changes, the CCC also presented release estimates for 2002 as indicators of future
'EPA is currently collecting data as part of the dioxin reassessment effort, which updates the 1995 Dioxin Inventory.
For more information, see http://cfpub.epa.gov/ncea/cfm/dioxin.cfm?ActType=default.
6-78
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
releases. Table 6-44 compares the CCC data from 2000 and 2002. The data show an overall
reduction of approximately 16 grams TEQ (15,000,000 Ib-eq) of dioxin in water releases from
2000 to 2002.
Table 6-44. Vinyl Manufacturing and Chlor-Alkali Facility Dioxins in Wastewater
Facility
PPG Industries
Dow Chemical Co.
Dow Chemical Co.
PPG Industries
Occidental Chemical Corporation
Dow Chemical Co.
Occidental Chemical Corporation
Georgia Gulf
Occidental Chemical Corporation
Occidental Chemical Corporation
Occidental Chemical Corporation
Location
Lake Charles, LA
Plaquemine, LA
Freeport, TX
Natrium, WV
Ingleside, TX
Midland, MI
Deer Park, TX
Plaquemine, LA
LaPorte. TX
Convent, LA
Mobile, AL
2000 g TEQ
8.98
7.71
6.91
0.193
0.181
0.037
0.0308
0.0228
0.00643
0.00204
0.0000364
2002 g TEQ
0.653
2.74
3.76
NC
0.187
NC
NC
0.024
NC
NC
NC
Percent
Change
-93
-64
-46
NA
3
NA
NA
4
NA
NA
NA
Source: CCC Data provided to Dwain Winters, April 2004. All concentrations reported as grams TEQ.
NA - Percent change could not be calculated because comparable data were not available.
NC - 2002 release estimated were not calculated because they are not expected to be significantly different from
2000 release estimates.
CCC observed the largest reductions at the PPG plant in Lake Charles, LA and
the Dow Chemical facilities in Freeport, TX and Plaquemine, LA. In the CCC report, the PPG
Lake Charles plant attributes their 93-percent reduction of dioxin water releases to
environmental control projects implemented since 2000 (see DCN 00899 in the docket). PPG
expects further reductions of dioxin releases as the plant continues to implement new
environmental projects.
In 1995, Dow Chemical announced its plans to implement a program to reduce
global dioxin releases from its manufacturing plants to air and water by 90 percent by the year
2005. So far, reductions of approximately 75 percent have been achieved across all media (7).
The Dow Freeport, TX plant upgraded its oxychlorination EDC technology in 2001. Both Dow
facilities (Freeport, TX and Lake Charles, LA) installed filtering equipment for partially treated
EDC/VCM wastewaters. This new treatment, and other process improvements made in 2001
and 2002, account for the reduction of dioxin water releases (see DCN 00899). Note that
although the TM-17 dioxin value for Dow Freeport increased from 2000 to 2001 (see Table 6-
35), the dioxin release for 2002 is less than 2000, based on site-verified CCC data.
6-79
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.8.7.2
Chlorine Industry Trends
End uses of chlorine manufactured in the U.S. include chemical production, vinyl
products, water disinfection, and the pulp and paper industry. Approximately 40 percent of the
chlorine manufactured in the U.S. is used to produce EDC (8).
The Chlorine Institute tracks the U.S. domestic production of chlorine. Table
6-45 lists the production for the last 10 years. In general, production increased from 1993 to
2000. In 2001, however, production slowed because companies closed or idled chlor-alkali
plants. Since 2001, seven chlor-alkali plants have either been closed or idled, which accounts for
approximately 10 percent of the U.S. production (8). Demand for chlorine has decreased over
the last decade. A large portion of the decrease is attributed to the recycle of HC1 for the
oxychlorination process in EDC production. Companies have found additional sources of by-
product HC1, which lowered the chlorine requirements for EDC production. In addition,
chlorine use in the pulp and paper industry has decreased over the past ten years in response to
environmental pressures (8).
Table 6-45. Chlorine Production in the United States
Year
2002
2001
2000
1999
1998
1997
1996
1995
1994
1993
Annual Production, tons/year
12,666,629
12.604.865
14.057.698
13.807.739
13,532,559
13,685,360
13,168,384
12,990,066
12,612,760
11,983,420
Source: Chlorine Institute, 2003.
6.8.8
Conclusions
Findings of EPA's detailed study of OCPSF Focus Group 3, dioxin dischargers,
are summarized below.
• The term "dioxins," or polychlorinated dibenzo-p-dioxins (CDDs) and
poly chlorinated dibenzofurans (CDFs), refers to the 17 individual
compounds (congeners) with chlorine substitution of hydrogen atoms at
the 2, 3, 7, and 8 positions on the benzene rings.
6-80
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Dioxins are persistent, bioaccumulative and toxic (PBT) pollutants,
associated with a range of adverse human health effects, including cancer.
EPA's human health-based water quality criterion (water + organism) for
the most toxic dioxin isomer, 2,3,7,8-tetrachlorodibenzo-p-dioxin
(dioxin), is 0.005 pg/L (5xlO'9 ug/L) (24). Due to their toxicity and ability
to bioaccumulate, the various congeners of dioxin have high toxic
weighting factors (TWFs). Consequently, even small mass amounts of
dioxin discharges translate into high toxic weighted pounds equivalents
(TWPEs).
OCPSF Focus Group 3 includes facilities that manufacture chlor-alkali,
EDC/VCM, and/or PVC. Some integrated facilities manufacture several
of these products.
Using data reported to TRI for 2000, EPA estimated that dioxin
contributes 92 percent of the TWPE for stand-alone chlor-alkali
manufacturers, stand-alone EDC/VCM manufacturers, and integrated
chlor-alkali and vinyl facilities. None of the 18 stand-alone PVC
manufacturers reported dioxin discharges to TRI for 2000.
For OCPSF Focus Group 3, EPA has facility-specific dioxin water
discharge data from the following data sources: TRIReleases2000, the
CCC, and industry responses to EPA's 2004 information request.
For the TRI, U.S. industrial facilities were first required to report dioxin
releases for 2000, and facilities report the total mass of the 17 congeners
released and the congener distribution. For TRI data, EPA calculated
TWPE of dioxins released using facility-reported congener distributions.
If a facility did not report a congener distribution, EPA used the product
group-specific average distribution to calculate the mass of each congener
released. Using TWFs for each congener and TRI data as reported
(accounting for POTW removals), EPA estimated that 14 OCPSF
Focus Group 3 facilities discharged 1,500 grams TM-17 of dioxin (5.7
million TWPE).
In 2000, none of the facilities in Focus Group 3 are required by their
NPDES permits to monitor their effluent for 2,3,7,8-TCDD or dioxins as a
group. However, EPA is aware of one facility, Dow Freeport, that has a
2003 permit monitoring requirement for dioxins as 2,3,7,8-TCDD TEQ.
Therefore, no PCS data were available for facilities in Group 3 at the time
of this report.
For 2000 CCC data, which generally included data verification, facilities
reported the total grams TEQ released, which represents the total grams
relative to the toxicity of 2,3,7,8-TCDD. No congener distribution is
6-81
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
available. Because the grams TEQ reflects the toxicity of all dioxin
congeners detected relative to 2,3,7,8-TCDD, EPA used the TWF for
2,3,7,8-TCDD to calculate the TWPE. EPA estimated that 21 OCPSF
Group 3 facilities discharged 26 grams TEQ of dioxin (24 million
TWPE).
The CCC also provided 2002 data for some facilities. Out of 11 facilities
with 2000 data, five provided 2002 data. Comparing 2000 with 2002 data,
three facilities had significant reductions in dioxin, two had slight
increases, and six did not provide 2002 data because they did not expect
that the numbers would be different from 2000. The 2002 CCC data
show an overall reduction of approximately 16 grams TEQ of dioxin
(15 million TWPE). Accounting for these reductions, approximately
10 grams TEQ (9 million TWPE) remain.
For industry responses to EPA's 2004 information request, 18 facilities
reported concentrations of dioxin detected in the wastewater by congener,
and usually the associated flow. To calculate the dioxin TWPE discharge
from facilities, EPA used the congener-specific TWF. No assumption on
congener distribution was necessary. If facilities provided concentration
data over multiple years (e.g., 1996 - 2000), EPA averaged the reported
concentrations to calculate the amount of dioxin released per year. EPA
estimated that nine OCPSF Group 3 facilities discharged 11.9 grams
TEQ of dioxin (2.4 million TWPE).
EPA also obtained discharge data from the Vinyl Institute, which
performed a study of dioxin releases from EDC, VCM, and PVC
manufacturing. The Vinyl Institute detected dioxin in all four wastewater
samples from facilities with EDC/VCM manufacturing (one facility also
manufactured PVC). The Vinyl Institute detected dioxin in two of six
wastewater samples from PVC manufacturers. The Vinyl Institute
estimated that for 1995, 0.011 - 0.15 grams of dioxin (10,000 - 140,000
TWPE) were released from PVC manufacturers and 0.032 - 0.17 grams of
dioxin (30,000 to 160,000 TWPE) were released from EDC/VCM
manufacturers.
EPA's OSW also studied dioxin concentrations in raw wastewater from
EDC/VCM processes and detected 13 of 17 dioxin congeners. OSW
detected concentrations of 2,3,7,8-TCDD at up to 17,000 pg/L and
1,2,3,4,6,7,8-HpCDF at up to 43,000,000 pg/L in raw wastewater.
Industry response to EPA's 2004 information request included measured
concentrations of dioxin in process wastewater. Industry data indicate
dioxin, including 2,3,7,8-TCDD, is detected in chlorine gas condensates
from the chlor-alkali manufacturing process and in EDC quench water.
6-82
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Industry data indicate that dioxin is not generated in the VCM and PVC
manufacturing processes Of the 13 OCPSF Group 3 facilities that
provided analytical effluent data, dioxin congeners were detected in
the final effluent of all 13 facilities.
• OCPSF Group 3, by far, contributes the most significant TWPE compared
with other industry groups. For example, the OCPSF Group 3 TWPE
from just dioxin is 24 million TWPE using CCC data (5.7 million TWPE
using TRI data). The total TWPE from all other industries combined, for
all pollutants, is just 14.4 million TWPE.
Based on information from the detailed review, EPA concludes that dioxins are
generated during manufacture of chlor-alkali and EDC. EPA further concludes that dioxins are
discharged in treated effluent of facilities that manufacture chlorine by the chlor-alkali process,
EDC, and/or VCM. Given the toxicity of dioxins and the tendency for bioaccumulation, EPA
concludes that dioxin discharges from the manufacture of chlor-alkali and EDC warrant further
study.
6.9 Control of Dioxin in Wastewater
This section discusses the wastewater treatment options identified by EPA to
minimize dioxin in wastewater. Section 6.9.1 discusses new treatment technologies, and Section
6.9.2 discusses the cost data available on these technologies.
6.9.1 Treatment Technologies for Control of Dioxin in Wastewater
EPA identified technologies to minimize the amount of dioxin in wastewater from
data collected in previous effluent guidelines, vendors, and industry. These technologies include
pollution prevention, in-process wastewater treatment, and end-of-pipe add-on wastewater
treatment. Section 6.9.1.1 discusses pollution prevention techniques. Section 6.9.1.2 discusses
in-process wastewater treatment technologies. Section 6.9.1.3 discusses end-of-pipe add-on
wastewater treatment technologies.
6.9.1.1 Pollution Prevention
EPA requested data on pollution prevention from eight companies that
manufacture chlor alkali, EDC, and VCM. The eight companies responded, providing analytical
and treatment data; however, no facilities identified pollution prevention methods. For example,
no facility identified feedstock substitution or process modification to prevent dioxin formation.
6.9.1.2 In-Process Wastewater Treatment
As discussed in Section 6.8.5, most of the dioxin dischargers, including those
producing chlor alkali, EDC, VCM, and/or PVC, have end-of-pipe biological treatment in place.
Most of the chlor-alkali and vinyl manufacturing facilities produce many chemicals, and
6-83
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
wastewater from the entire plant is typically commingled prior to biological treatment. End-of-
pipe flows are large, ranging from 0.36 to 40 MGD, and segregating dioxin-containing
wastewater streams allows for targeted dioxin removal.
Facilities can control dioxin-containing segregated wastewater streams by
removing solids or the using granular activated carbon. For the chlor-alkali and vinyl
manufacturing industry, EPA identified that the following wastewater streams that might contain
dioxin (see industry responses to EPA's 2004 information request, DCNs 00897 - 00899, 01027,
and 01034-01037 in the docket):
• Chlorinated gas condensates;
• EDC quench water; and
• EDC spent catalyst regeneration water.
Dioxin is hydrophobic and adheres to solids; therefore removing solids or sludges
is an effective technique to remove dioxin from wastewater (20, 24). (Sludge from wastewater
treatment of EDC/VCM wastewater is K174 hazardous waste (15)). Some solids removal
technologies that could be added in process include sand filtration, multimedia filtration,
ultrafiltration, and clarification. For example, a facility could pass chlorine gas condensates
through filter cartridges prior to commingling them with other wastewater.
Similarly, granular activated carbon removes dioxin from wastewater. One
facility reported passing chlorine gas condensates through granular activated carbon units prior
to biological treatment, removing an average greater than 90 percent of the dioxin in the chlorine
gas condensates (see DCN 01035 in Section 4.4 of the docket). Other facilities reported solids
removal technologies to remove dioxin prior to end-of-pipe treatment as well.
6.9.1.3 End-of-Pipe Wastewater Treatment
EPA also considered what add-on end-of-pipe treatment technologies would
remove dioxin. Solids removal and granular activated carbon would remove dioxin, but the
large volume of end-of-pipe wastewater may make their application cost prohibitive. Improved
end-of-pipe treatment could include: PACT® treatment (adding of powdered activated carbon to
activated sludge systems) or optimized (chemically assisted) clarification.
6.9.2 Summary of Available Treatment Cost Data and Justification for Not
Estimating Costs
To estimate the cost of implementing an in-process or end-of-pipe wastewater
treatment technology, flow and pollutant concentration data are needed. For example, to size a
sand filter for a waste stream, the solids content must be known. To design a granular activated
carbon unit (either bed or canister), flow and chemistry of the influent wastewater determine the
size and number of units needed. EPA requested data on flow and chemistry of in-process and
end-of-pipe wastewater from eight companies with chlor-alkali, EDC, VCM, and PVC
operations. EPA received responses with flow and chemistry data from six companies in July,
6-84
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
one month prior to publication of this report. Therefore, at the time of the writing of this report,
EPA had insufficient data for estimating costs.
6.10 Chemical Formulators, Packagers, and Repackagers
In conjunction with the detailed review of the OCPSF category, EPA also
analyzed data from facilities that formulate, package, and repackage chemicals into products for
end use or for further processing but are not covered by existing point source categories, to
determine if new subcategories of OCPSF should be identified for further study.
This section discusses a potential new subcategory referred to as Chemical
Formulating, Packaging, and Repackaging (CFPR). CFPR operations are those that mix or blend
chemicals without intended chemical reaction, and those that package or repackage chemicals
into products for end use or further packaging. This section discusses EPA's findings on this
potential subcategory in the following subsections:
• Section 6.10.1 presents the facilities identified as having CFPR
operations;
• Section 6.10.2 describes the processes and sources of wastewaters at
CFPR operations;
• Section 6.10.3 lists the pollutants of concern identified based on available
data;
• Section 6.10.4 describes the wastewater treatment at CFPR facilities; and
• Section 6.10.5 explains EPA's next action for this group of facilities.
6.10.1 CFPR Industry Description
In the 1997 EPA Chemical Formulating, Packaging, and Repackaging Industry
Special Study (1997 CFPR Study), EPA identified the following industries within major SIC
group 28 (Chemical and Allied Products) as CFPR industries:
• SIC 2841 - Soap and Detergents, Except Specialty Cleaners;
• SIC 2842 - Specialty Cleaning, Polishing and Sanitation Preparation;
• SIC 2844 - Perfumes, Cosmetics, and Other Toilet Preparations;
• SIC 2851 - Paints, Varnishes, Lacquers, Enamels, and Allied Products;
SIC 2891 - Adhesives and Sealants;
SIC 2893 - Printing Ink; and
• SIC 2899 - Chemicals and Chemical Preparations, not elsewhere
classified.
6-85
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
EPA conducted this study to determine whether it should develop ELGs for the
CFPR industry, or some sectors of the industry. The study fulfilled EPA's obligations under
section 304(m) of the CWA.
Three of the SIC codes included in the 7997 CFPR Study contain facilities that
are covered by existing effluent limitation guidelines:
SIC 2841 - 40 CFR Part 417, Soap and Detergent Manufacturing;
SIC 2851 - 40 CFR Part 446, Paint Formulating; and
SIC 2893 - 40 CFR Part 447, Ink Formulating.
EPA included SIC codes 2841, 2851, and 2893 in the 7997 CFPR Study because
some facilities reporting these SIC codes are not specifically regulated under Parts 417, 446, or
447 and could be considered part of the CFPR industry. Due to data limitations, EPA could not
differentiate facilities that were included in existing point source categories and facilities that
were part of CFPR. Therefore, EPA included all facilities reporting SIC codes 2841, 2851, and
2893 in the 7997 CFPR Study. However, EPA did not consider facilities in SIC codes 2841,
2851, and 2893 in this detailed review, which applies to operations being considered only as a
new subcategory of OCPSF. Instead, EPA is including these SIC codes in the review of Parts
417, 446, and 447. EPA considered any operations in these SIC codes but outside of the current
applicability of these categories as potential new subcategories of the respective category. This
detailed review of CFPR facilities covers only facilities reporting SIC codes 2842, 2844, 2891,
or 2899. See the documents in the docket entitled, "Toxic Weighted Pound Equivalent (TWPE)
Loads by Facility and By Pollutant for SIC Code 2841, Soaps and Other Detergents, Except
Specialty Cleaners, July 21, 2004"; TWPE Loads By Facility and By Pollutant for SIC Code
2851, Paints, Varnishes, Lacquers, Enamels, and Allied Products, July 14, 2004"; and "TWPE
Loads By Facility and By Pollutant for SIC Code 2893, Printing Ink, July 14, 2004."
EPA identified facilities included in the potential new CFPR subcategory of the
OCPSF ELG based on their primary SIC codes, as reported to TRI and PCS. Therefore, data
limitations of the reported SIC codes are particularly relevant to this set of facilities. The
diversity of the chemical products manufactured and operations used at these facilities makes it
often difficult to characterize a facility's discharges under a single point source category.
Applicable SIC codes for some facilities can span multiple potential point source categories.
Facilities may also report under different SIC codes for different databases or reporting years.
For example, Dow Chemical in Midland, MI has several applicable SIC codes.
Two of the applicable SIC codes are 2899 and 2869. SIC code 2899 is part of the potential new
CFPR subcategory; SIC 2869 is included in the OCPSF category. Dow Midland reported SIC
code 2899 to TRI in 2000 as its primary SIC code and SIC code 2869 as its secondary SIC code,
and reported SIC 2869 to PCS in 2000. Because EPA determined that the toxic pollutants
associated with dioxin discharge are derived from OCPSF (SIC code 2869) operations, EPA
included discharges from Dow Midland in the dioxin-discharging group of OCPSF (discussed in
Section 6.8). Therefore, Dow Midland is not included in the CFPR discussion.
6-86
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
EPA obtained information on the number of facilities in the SIC codes identified
as CFPR industries from three sources: the 1997 U.S. Economic Census, the 2000 TRI database,
and the 2000 PCS database. The 2000 TRI database includes reports of discharges to any media
from all facilities that meet TRI reporting requirements. In contrast, the 2000 PCS database
includes only facilities that are permitted for discharge to surface waters. Table 6-46 lists the
number of CFPR facilities from these sources. The number of facilities reporting discharge to
TRI for 2000 represents only about 6 percent of the CFPR industry based on the total number of
facilities in the 1997 U.S. Economic Census. Of the facilities reporting discharge to TRI, 84
percent are indirect dischargers. The number of facilities reporting discharges to PCS for 2000
represents about 2 percent of the total industry. Only 14 of the PCS facilities (17 percent of the
total PCS facilities) are major facilities with loads estimated from PCS data.
Table 6-46. Counts of CFPR Facilities
SIC
Code
2842
2844
2891
2899
Total
Facility
Count
(1997 U.S.
Economic
Census)
727
737
694
1,157
3,315
2000 PCS
Total
6
12
17
47
82
Major
1
1
2
10
14
Minor
5
11
15
37
68
2000 TRI
Total
97
39
158
284
578
No
Reported
Discharge
57
19
123
174
373
Direct
Discharge
0
0
3
15
18
Indirect
Discharge
39
20
31
82
172
Both Direct
and
Indirect
Discharge
1
0
1
13
15
Sources: PCSLoads2000 and TRIReleases2000.
Based on information presented in the 1997 study, CFPR operations are located
across the United States with the largest number of facilities in California, Illinois, New Jersey,
Ohio, and Texas. Moderate numbers of facilities are located in the Midwest, Indiana, and
Georgia.
6.10.2
Process Descriptions and Wastewater Sources
This subsection discusses the processes and the wastewater sources present at
CFPR operations.
6.10.2.1
CFPR Processes
CFPR operations formulate, package, and repackage a very large variety of
chemical products. Because of the large number of products a facility may handle, most CFPR
facilities operate on the principle of "just-in-time" production, which bases production on
customer demand, to reduce the space needed to keep large inventories on hand. However,
because the products that are formulated, packaged, or repackaged can vary from day to day and
from hour to hour, facilities often dedicate an equipment line (e.g., a liquid formulating line) to
6-87
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
make multiple products over the course of a day, week, or month. Some facilities, typically
those producing large volumes of certain products, operate long production campaigns and keep
some inventory on site. Facilities that run long campaigns tend to generate less wastewater from
product changeover. However, as customer demands change, such facilities may switch some or
all production to "just-in-time" operations.
Operations at CFPR facilities may include:
• Liquid Formulating - Mixing several raw materials, including a base
solvent, fragrances, and other inert ingredients such
as emulsifiers or surfactants;
• Dry Formulating - Mixing powders, dusts, granules, block,
impregnated solids, compounds that are formed into
a solid shape, or microencapsulated dusts or
granules;
• Liquid Packaging - Transferring the liquid final product into a package;
• Dry Packaging - Transferring the dry final product into a package;
• Aerosol Packaging - Placing the product in spray cans that are
pressurized, and adding a propellant; and
• Repackaging - Transferring a formulated and packaged product
into a new container.
6.10.2.2 CFPR Process Wastewater
Process wastewater in CFPR industries result from cleaning production
equipment and related process areas. The typical process wastewaters found in the CFPR
industry include:
• Interior equipment cleaning rinsate;
• Floor wash;
• Exterior equipment cleaning rinsate;
• Bulk tank rinsate;
• Drum/shipping container rinsate;
• Department of Transportation leak test bath water (for aerosol products);
• Leak and spill cleanup water;
• Air or odor pollution control scrubber water;
• Contact cooling water; and
• Safety equipment wash water.
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.10.3
Pollutants of Concern
This section presents PCS and TRI data pollutant data and discussions of the
pollutants of concern in each CFPR sector (SIC codes 2842, 2844, 2891, and 2899).
6.10.3.1
PCS and TRI Data for the CFPR Industry
Table 6-47 lists the pollutants reported to TRI as discharged directly or indirectly,
which account for 95 percent of the total TWPE for CFPR facilities that reported to TRI for
2000. This table presents the number of facilities that reported each chemical, total pounds of
chemical discharged to surface waters, and the direct, indirect, and total TWPE for each
chemical. Indirect discharging facilities reported transfers to POTWs. Using average POTW
removal efficiencies, EPA estimated the amount of pollutant discharged to surface water (see
DCN 00618, Evaluation of RSEIModel Rims, for more information). Therefore, EPA adjusted
the TWPE estimates in this table to account for POTW treatment. As explained in Section 2.1,
the 2000 TRI database does not include all CFPR facilities or TRI-listed chemicals that are used
or produced at levels below reporting thresholds.
Table 6-47. Chemical Releases to Surface Water Reported to TRI for 2000
Pollutant
Number
of
Facilities
Reporting
TRI
Total
(Ibs/yr)
TRI
Direct
TWPE
TRI
Indirect
TWPE1
TRI
Total
TWPE
Percentage of
Total SIC
Code TWPE
Cumulative
Percentage of
Total SIC Code
TWPE
SIC 2842 - Specialty Cleaning, Polishing, and Sanitation Preparation
Sodium Nitrite
Chlorine
Total
2
2
2,924
741
31,943
-
-
<1
1,091
361
1,480
1,091
361
1,480
74%
24%
74%
98%
SIC 2844 - Perfumes, Cosmetics, and Other Toilet Preparations
Sodium Nitrite
Total
2
18,455
29,395
-
-
6,890
6.908
6,890
6,908
99.7%
99.7%
SIC 2891 - Adhesives and Sealants
Manganese
Compounds
Polycyclic
Aromatic
Compounds
Copper
compounds
Ammonia
Chromium
compounds
Vinyl acetate
Zinc
Compounds
n-Hexaue
Total
1
1
1
5
2
9
4
2
2,825
0.4
70
27,164
61
4,011
181
294
39,173
-
81
-
10
-
-
<1
8
105
199
44
31
31
16
8
<1
342
199
81
44
41
31
16
8
8
446
45%
18%
10%
9%
7%
4%
2%
2%
45%
63%
73%
82%
89%
92%
94%
96%
6-89
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-47 (Continued)
Pollutant
Number
of
Facilities
Reporting
TRI
Total
(Ibs/yr)
TRI
Direct
TWPE
TRI
Indirect
TWPE1
TRI
Total
TWPE
Percentage of
Total SIC
Code TWPE
Cumulative
Percentage of
Total SIC Code
TWPE
SIC 2899 - Chemicals and Chemical Preparations, Not Elsewhere Classified
Sodium Nitrite
Copper
compounds
Total
11
16
169,267
1,424
952,412
57,765
86
58,388
5,428
807
8,969
63,193
893
67,357
94%
1%
94%
95%
Source: TRIReleases2000.
'TWPE transferred to POTW that are ultimately discharged to surface waters. Accounts for POTW removals.
Table 6-48 lists the pollutants reported to PCS, which account for 95 percent of
the total TWPE for CFPR facilities that reported discharges to PCS for 2000.
Table 6-48. Pollutant Discharges Reported to PCS for 2000
Pollutant
Number of
Facilities
Reporting
PCS Total
(Ibs/yr)
PCS
TWPE
Percentage
of Total
SIC Code
TWPE
Cumulative
Percentage of
Total SIC
Code TWPE
SIC 2842 - Specialty Cleaning, Polishing, and Sanitation Preparation
Total
NA
NA
SIC 2844 - Perfumes, Cosmetics, and Other Toilet Preparations
Copper, Total (as Cu)
Nitrogen, Nitrate Total (as N)
Nitrogen Ammonia, Total (as NH3)
Zinc, Total (as Zn)
Total
1
1
1
1
0.2
1,620
31
0.7
47,998
0.2
0.1
0.05
0.03
0.3
48%
29%
13%
10%
48%
77%
90%
100%
SIC 2891 - Adhesives and Sealants
Chlorine, Total Residual
Barium, Total (as Ba)
Nitrogen, Ammonia Total (as NH3)
Total
1
1
1
120
21,667
6,404
1,950,573
58
43
12
118
49%
37%
10%
49%
86%
96%
SIC 2899 - Chemicals and Chemical Preparations, Not Elsewhere Classified
Benzo(a)pyrene
Benzo(b)fluoranthene (3,4-benzo)
Copper, Total (as Cu)
Benzo(a)anthracene
Chlorine (as Cl)
Total
1
1
5
3
4
6
6
1,923
6
23,329,838
53,423,544
27,753
2,730
1,206
1,173
568
35,086
79%
8%
3%
3%
2%
79%
87%
90%
94%
95%
Source: PCSLoads2000.
NA - Not applicable; this facility reported no flow to PCS in 2000.
6-90
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
6.10.3.2 Pollutants of Concern for SIC Code 2842
As shown in Table 6-47, pollutants of concern in SIC code 2842 include sodium
nitrite and chlorine. Both pollutants were reported in indirect discharges by two facilities. More
than 99 percent of the TRI TWPE for SIC 2842 is from indirect releases and less than 1 TWPE
was reported from direct dischargers.
Only one major facility reported to PCS in 2000 for this industry (see Table 6-
48). This facility reported zero flow; therefore, EPA estimated no loads from this facility.
6.10.3.3 Pollutants of Concern for SIC Code 2844
The TRI pollutant of concern in SIC code 2844 is sodium nitrite, as presented in
Table 6-47. All of the reported TWPE in this industry are from indirect dischargers.
Only one major facility reported to PCS in 2000 for SIC 2844. As shown in
Table 6-48, the PCS pollutants of concern for this facility are copper, nitrogen, ammonia, and
zinc and amounted to 0.3 TWPE/yr.
6.10.3.4 Pollutants of Concern for SIC Code 2891
The TRI pollutants of concern in SIC code 2891 include manganese compounds,
polycyclic aromatic compounds (PACs), copper compounds, ammonia, chromium compounds,
vinyl acetate, zinc compounds, and n-hexane (shown in Table 6-47). Most (77 percent) of the
TWPE from this industry was reported in indirect discharges. Of the facilities that reported
water discharges to TRI, 91 percent are indirect dischargers.
Only two major facilities reported to PCS in 2000 for SIC code 2891. Only one
facility reported some pollutant discharge. The PCS pollutants of concern for this facility are
chlorine, barium, and ammonia.
A 1984 study of the adhesives and sealants industry prepared by E.G. Jordan Co.
entitled Summary of Findings: Water and Waste Management for the Adhesives and Sealants
Manufacturing Point Source Category presents pollutant data from a 1978 sampling effort.
(The January 22, 2004 memorandum Summary of Adhesives and Sealants Industry Study, DCN
00726, Section 4.17 presents a more detailed review of this study). The pollutants estimated to
have the highest annual loads in raw wastewater in the 1978 sampling effort include:
• Zinc;
• Pentachlorophenol;
• Butylbenzyl phthalate;
• Bis(2-ethylhexyl)phthalate;
• Di-n-butyl phthalate;
• Phenol;
• Chromium;
6-91
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Toluene;
• 1,1,1-trichloroethane;
• Benzene;
• Trichloroethylene; and
• Di ethyl phthalate.
However, the pollutant estimates presented in the 1984 study were complicated
by several fundamental problems including analytical problems in determining concentrations, a
lack of common industry-wide characteristics that could be used as an industry baseline, a lack
of complete data for every segment of the industry, and day-to-day and plant-to-plant pollutant
concentration variations.
6.10.3.5 Pollutants of Concern for SIC Code 2899
As shown in Table 6-47, the TRI pollutants of concern in SIC code 2899 are
sodium nitrite (94 percent of the total TWPE) and copper compounds (1 percent of the total
TWPE). The TRI TWPE for SIC code 2899 is dominated by one facility; 3M in Cottage Grove,
MN represents 75 percent of the total CFPR industry TWPE (see Section 6.10.4.1 for a
discussion of this facility's permit).
The PCS pollutants of concern include benzo(a)pyrene, benzo(b)fluoranthene
(3,4-benzo), copper, benzo(a)anthracene, and chlorine. The PCS TWPE for SIC code 2899 is
dominated by one facility; Ondeo Nalco in Garyville, LA represents 91 percent of the total
CFPR TWPE (see Section 10.4.1 for a discussion of this facility's permit). Ondeo Nalco
discharges most of the reported releases of PACs. EPA contacted this facility to verify its
various PACs discharges reported to PCS for 2000. The facility did not detect the compounds;
the reported discharges were estimated to be half the detection limit. EPA obtained Ondeo
Nalco monitoring data, which verified that the compounds were not detected during wastewater
sampling.
6.10.3.6 Total TWPE for CFPR Operations
Table 6-49 presents the total PCS and TRI TWPEs by SIC code for all CFPR
sectors. As shown in the table, SIC code 2899 accounts for about 88 percent of the total TRI
TWPE and greater than 99 percent of the total PCS TWPE. Also, SIC code 2899 is the only
industry reporting more direct discharges than indirect discharges to TRI.
The TRI pollutants of concern for the entire CFPR industry are sodium nitrite,
copper, manganese, and chlorine. The PCS CFPR pollutants of concern are benzo(a)pyrene,
benzo(b)fluoranthene, and copper.
As explained above, the TRI TWPE for SIC 2899 is dominated by a single facility
(accounting for 75 percent of the total TWPE). Similarly, the PCS TWPE is dominated by a
separate, single facility (accounting for 91 percent of the total TWPE). See Section 10.4.2 for
more information on these two facilities.
6-92
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
Table 6-49. PCS and TRI TWPEs by SIC Code for CFPR Sectors
SIC
Code
2842
2844
2891
2899
Total
Number of
Major
PCS
Facilities
Reporting
1
1
2
10
14
PCS
TWPE
0
0.3
118
35.086
35,204
Number of
TRI
Facilities
Reporting
40
20
35
110
205
TRI
Total
TWPE
1480
6980
446
67,357
76,191
Number of
TRI Direct
Facilities
Reporting1
1
0
4
28
33
TRI
Direct
TWPE
<1
0
105
58,388
58,492
Number of
TRI
Indirect
Facilities
Reporting1
40
20
32
95
187
TRI
Indirect
TWPE
1,480
6,980
342
8,969
17,699
Includes facilities that report both direct and indirect discharge.
6.10.4 Wastewater Treatment/Best Management Practices
This section discusses the wastewater treatment and BMPs in place at CFPR
operations.
6.10.4.1 CFPR Wastewater Treatment
Facilities can report wastewater treatment practices to TRI. In 2000, CFPR
facilities reported almost 40 different types of wastewater treatment to TRI. Table 6-50 lists the
types of treatment reported most frequently.
Table 6-50. Wastewater Treatment Practices at CFPR Facilities
Treatment
Neutralization
Settling/Clarification
Chemical Precipitation - Lime or Sodium Hydroxide
Filtration
Equalization
Sludge Dewatering (nonthermal)
Biological Treatment - aerobic
Chemical Precipitation- other
Other Chemical Treatment
Number of Direct
Facilities Reporting
Treatment
10
11
7
6
3
4
8
3
0
Number of Indirect
Facilities Reporting
Treatment
54
32
23
18
16
14
8
7
7
Pollution prevention, recycle, and reuse practices are widely used in CFPR
operations. These practices include:
6-93
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
• Dedicating equipment to one product, to reduce cleaning requirements;
• Storing of rinsates for reuse in subsequent batches;
• Using water conservation equipment;
• Packaging directly into product containers;
• Scheduling production to minimize cleanouts; and
• Using good housekeeping practices to prevent and quickly clean up leaks
and spills.
6.10.4.2 Permit Review Summary
EPA obtained surface water discharge permits for 3M, Cottage Grove, MN, and
Ondeo Nalco, Garyville, LA. These facilities are direct dischargers with manufacturing
operations in SIC codes that are included in the potential new CFPR subcategory. The following
summarizes of the basis used to develop the permit limits as described in the permit documents.
For more detailed information, please see the May 14, 2004 memorandum Review of Top
Chemical Formulating, Packaging, and Repackaging Facilities.
Both facilities report SIC code 2899.
• Permit limitations for both facilities were based on the OCPSF effluent
guidelines.
• The highest TWPE pollutant reported by 3M Cottage Grove, MN to TRI
for 2000 is sodium nitrite.
— Limits for nitrite and sodium nitrite are not included in 3M's
permit, and
— Due to the diversity of chemical manufacturing operations in place
at this facility, it is unclear if sodium nitrite discharges result from
CFPR processes.
• The highest TWPE pollutants reported by Ondeo Nalco Garyville, LA to
PCS for 2000 are individual PACs.
— Permit limits are assigned for the reported PACs, and
— Monitoring data show that PACs were not detected in the facility's
wastewater, but were reported at one half the method detection
6-94
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
limit to PCS. Therefore, PCS data overestimate the facility's
TWPEby 31,9471b-eq.
6.10.5 Conclusions
The screening-level review showed that the majority of facilities reporting to TRI
reported no wastewater discharge. Of the facilities that reported discharge, most transferred their
wastewater to a POTW. Only 0.5 percent of the facilities in the 1997 U.S. Economic Census
reported direct wastewater discharge to TRI. Two facilities generate most of the TWPE in this
industry, and NPDES permits for these facilities are based on OCPSF effluent limitations
guidelines. Because of the small number of CFPR facilities that discharge significant toxic-
weighted pounds to waters of the United States, EPA concludes it is not appropriate to develop a
new CFPR subcategory under the OCPSF ELG at this time. If EPA receives data during
subsequent annual reviews that indicate otherwise, EPA may reconsider this sector of OCPSF for
development at that time.
EPA recommends that permit writers prepare permits for those facilities that
discharge high TWPE based on existing OCPSF limitations on a BPJ basis. Permit writers might
also want to review and consider pollution prevention alternatives described in the Pollution
Prevention (P2) Manual: Implementing the P2 Alternative (23) developed for Pesticide
Formulating Packaging and Repackaging (PFPR) facilities. Because many of the operations and
wastewater sources at CFPR facilities are similar to those at PFPR facilities, EPA believes the
pollution prevention practices identified for PFPR facilities are applicable to CFPR facilities.
6.11 References
1. 1997 U.S. Census. Available online at: http://www.census.gov.
2. American Plastics Council and International Institute of Synthetic Rubber
Producers. Available online at: http://pubs.acs.org/cen/coverstory/8127/pdf/
8127/fandf_production.live.pdf
3. Amini, B. and S. Lowenkron. 2003. Aniline and Its Derivatives. Kirk Othmer
Encylopedia.
4. Baron, J, C. Kraynik, and R. Wombles. Strategies for a Declining North
American Coal Tar Supply. Koppers Industries Inc., Technical Center,
Pittsburgh, PA. 1998.
5. Chlorine Institute. North American Chlor-Alkali Industry Plants and Production
Data Report 2003.
6. Dover Chemicals Web page, http://www.doverchem.com.
7. Dow Chemical Web page, http://www.dow.com.
6-95
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
8. The Innovation Group Web Page, Chemical Profiles. Available online at:
http://www.the-innovation-group.com/chemprofile.htm.
9. Lamberti, C., Prestipino, C., Bonino, F., Capello, L., et al. Chemistry of the
Oxychlorination Catalyst: An In Situ, Time-Resolved, Dispersive Xanes Study.
Accessed at: http://www.esrf.fr/UsersAndScience/Publications/Highlights/
2002/XASMS/SAXMS2/ on February 9, 2004.
10. Man Made Organic Materials - Part I, Innovision India Web page,
http://home.att.net/~cat6a/org_mat-I.htm.
11. National Science Council Chemical Backgrounder for Aniline. Available online
at: http://www.nsc.org/library/chemical/aniline.htm.
12. Oxy Vinyls Web page, http://www.oxyvinyls.com.
13. The Society of the Plastics Industry (SPI),
http://www.plasticsdatasource.org/impact.htmtftopten.
14. Thornton, J. Environmental Impacts ofPolyvinyl Chloride (PVC) Building
Materials. U.S. Green Building Council Briefing Paper for Center for Maximum
Potential Building Systems and The Healthy Building Network. Columbia Earth
Institute, Columbia University. 2002.
15. U.S. EPA. Best Demonstrated Available Technology (BDAT) Background
Document for Chlorinated Aliphatics Production Wastes -K173, K174, K175.
Washington, D.C. July 1999.
16. U.S. EPA. Best Demonstrated Available Technology (BDAT) Background
Document For Dye and Pigment Production Wastes - Deferred Wastes K167 and
K168. Washington, D.C. June 11, 1999.
17. U.S. EPA. Development Document for Effluent Limitations Guidelines, New
Source Performance Standards, and Pretreatment Standards for the Organic
Chemicals and the Plastics and Synthetic Fibers Point Source Category.
Washington, D.C. October 1987.
18. U.S. EPA. Emergency Planning and Community Right-to-Know Act Section 313
Guidance for Reporting Toxic Chemicals within the Dioxin and Dioxin-Like
Compound Category. Washington, D.C. December 2000.
19. U.S. EPA. Listing Background Document for the Chlorinated Aliphatics Listing
Determination (FinalRule). Washington, D.C. June 30, 2002.
6-96
-------
Section 6 - Organic Chemicals, Plastics, and Synthetic Fibers Detailed Review
20. U.S. EPA. National Risk Management Research Laboratory Treatability
Database.
21. U.S. EPA. Hazardous Air Pollutant Emissions from Mercury Cell Chlor-Alkali
Plants: Background Information Document/or Proposed Standards.
EPA-4531R-02-007. Washington, D.C. February 2002.
22. U.S. EPA. Office of Compliance Sector Notebook Project. Profile of the
Organic Chemical Industry 2nd Edition. EPA/310-R-02-001. Washington, D.C.
November 2002.
23. U.S. EPA. Pollution Prevention (P2) Guidance Manual for the Pesticide
Formulating, Packaging, and Repackaging Industry: Implementing the P2
Alternative. EPA-821-B-98-017. Washington, D.C.
24. Van den Berg, et al. "Toxic Equivalency Factors (TEFs) for PCBs, PCDDs,
PCDFs, for Humans and Wildlife." Environ. Health Perspect. 106:775-792.
1998.
25. Vinyl Institute. The Vinyl Institute Dioxin Characterization Program. Final
Report. May 15,2001.
26. Whole Earth Magazine, http://www.wholeearthmag.com/ArticleBin/113.html.
27. Wombles, Robert H. (Koppers Industries, Inc.) and Melvin D. Kiser (Marathon
Ashland Petroleum Company). Developing Coal Tar/Petroleum Pitches. Koppers
Industries Company web site, http://www.koppers.com.
28. World Chlorine Council. Turning Salt into Chlorine and Caustic Soda:
Chlor-Alkali Manufacturing Processes. Accessed at
http://www.worldchlorine.com. 2002.
29. Zipf, Lynn, U.S. EPA. Revisions to TWFsfor Dioxin and its Congeners and
Recalculated TWPEsfor OCPSF and Petroleum Refining. (EPA Docket Number
OW-2003-0074). August 10, 2004.
6-97
-------
Section 7 - Petroleum Refining
SECTION 7 PETROLEUM REFINING
7.1 Introduction
The petroleum refining industry corresponds to Standard Industrial Classification
(SIC) code 2911 - Petroleum Refining., defined as establishments engaged in producing gasoline,
kerosene, distillate fuel oils, residual fuel oils, and lubricants, through fractionation or straight
distillation of crude oil, redistillation of unfinished petroleum derivatives, cracking, or other
processes. EPA is also considering including operations in SIC code 5171 - Petroleum Bulk
Stations and Terminals as a new subcategory in the Petroleum Refining Point Source Category.
EPA selected the Petroleum Refining category for further review because it
ranked fourth highest among all point source categories for toxic and nonconventional pollutant
discharges for 2000 in the screening-level analysis (see the December 31, 2003 Notice of the
Preliminary Effluent Guidelines Program Plan, FRN [FRL-7604-7]). The effluent guidelines,
limitations, and standards (ELGs) for the Petroleum Refining category are codified at 40 CFR
Part 419 (last revised in 1982). In the screening-level analysis, EPA found that the toxic and
nonconventional pollutant loadings are driven by three groups of pollutants: poly cyclic aromatic
compounds (PACs), polychlorinated dibenzo-para (p)- dioxins and polychlorinated
dibenzofurans (referred to as "dioxins" in this report), and metals (specifically vanadium,
mercury, and selenium). EPA analyzed the reported discharges and specific process sources
discharging these pollutants.
For the detailed review of the Petroleum Refining category, EPA verified Toxic
Release Inventory (TRI) and Permit Compliance System (PCS) data, analyzed additional
industry data, reviewed current regulations affecting this industrial category, and identified
pollution prevention and treatment technologies for wastewater discharges.
EPA also analyzed data from petroleum bulk stations and terminals (PBSTs) to
determine if a new subcategory of the Petroleum Refining category should be identified and
further studied. Currently, states determine whether process discharges from PBST operations
are regulated. Section 7.12 discusses EPA's findings on this investigation.
This section discusses EPA's analysis of the Petroleum Refining category and
conclusions in the following order:
• Section 7.2 discusses data sources used, EPA's verification of the data,
and the data source limitations;
• Section 7.3 discusses the petroleum refining industry profile and discharge
status;
• Section 7.4 discusses the current petroleum refining ELGs (40 CFR Part
419) and other major regulations affecting petroleum refineries;
7-1
-------
Section 7 - Petroleum Refining
• Section 7.5 discusses wastewater sources, pollutant loadings, and current
treatment in place at refineries;
• Section 7.6 discusses EPA's analysis and findings for PACs discharges
from petroleum refineries;
• Section 7.7 discusses EPA's analysis and findings for dioxin discharges
from petroleum refineries;
• Section 7.8 discusses EPA's analysis and findings for metals discharges
from petroleum refineries;
• Section 7.9 discusses EPA's analysis and findings for other
nonconventional and conventional pollutant discharges from petroleum
refineries;
• Section 7.10 discusses control of wastewater discharges from petroleum
refineries, including pollution prevention and wastewater treatment
technologies;
• Section 7.11 lists references for the petroleum refining detailed study; and
• Section 7.12 discusses EPA's findings on PBSTs.
7.2 Data Sources
This section describes the data sources used for the petroleum refining industry
detailed study, as well as data quality limitations and data verification activities performed.
Sections 4.2.1, 4.2.2, and 4.1.3 of this document describes TRI, PCS, and U.S. Economic Census
data sources, respectively. This section discusses data sources as they pertain specifically to the
petroleum refining industry detailed review.
7.2.1 Toxic Release Inventory (TRI)
All petroleum refineries that meet the employee criteria (i.e., 10 or more
employees) and the chemical threshold(s) must submit reports to EPA's TRI program. Of the
163 petroleum refineries operating in the U.S. in 2000, 154 (94 percent) reported to TRI in 2000.
EPA used 2000 TRI data, as reported, to estimate pollutant loadings, determine if stormwater
discharges were an industry issue, and identify treatment in place.
To estimate pollutant loadings and toxic-weighted pound equivalents (TWPEs),
EPA developed the TRIReleases2000 database (35); this database includes all data as reported to
TRI in 2000. The pollutant loadings estimated by TRIReleases2000 uses pollutant releases and
transfers to publicly-owned treatment works (POTWs), taking POTW removals into account.
7-2
-------
Section 7 - Petroleum Refining
Section 4.2.1 discusses the TRIReleases2000 database in further detail. Section 4.2.4 discusses
TWPE calculations.
For the petroleum refining industry detailed review, EPA verified data as reported
to TRI in 2000, particularly for those facilities and pollutants with high TWPEs. For example,
refineries may estimate TRI-reported releases in a number of ways: monitoring data, emissions
factors, mass balances, and other engineering calculations. If a chemical is not detected in the
effluent, refineries may estimate the discharge by using one-half of the detection limit. By using
one-half the detection limit, refineries may overestimate the amount of chemical discharged,
which particularly affected PACs and dioxin discharges reported for petroleum refineries.
The list of chemicals reportable to TRI includes individual chemicals and
chemical categories (i.e., group of similar chemicals). The TRI chemical categories commonly
reported by petroleum refineries include the PACs category (21 individual chemicals; see
Section 7.6 for more detail), dioxins and dioxin-like chemicals category (17 individual
chemicals; see Section 7.7 for more detail), and metal compound categories (e.g., mercury
compounds, vanadium compounds).
Refineries are required to report the combined mass of PACs and dioxins
released. To calculate the TWPE of PACs as reported to TRI in 2000, EPA calculated a toxicity
weighting factor (TWF) specific to the petroleum refining industry (see Section 7.6.2).
For dioxins, refineries are given the opportunity to report a refinery-specific
congener distribution. To calculate the TWPE of dioxins as reported to TRI in 2000, EPA
calculated a TWF specific to a petroleum refinery based on the reported congener distribution
(see Section 7.2). Note that the dioxin congener distribution for a refinery may not accurately
reflect the distribution across all media. See also Section 4.2.4.2 for a more detailed discussion
on dioxins and the calculation of TWPE for dioxin discharges.
Refineries report only the elemental metal portion of discharges for metal
compounds (e.g., a refinery reports only the pounds discharged of vanadium for all vanadium
compounds). Therefore, EPA used the metal TWFs to calculate the TWPE.
To verify the data reported to TRI, EPA performed the following activities:
• Verified that facilities reporting as SIC code 2911 were petroleum
refineries and linked each refinery's data with data from the PCS and the
Energy Information Administration (EIA), discussed in Section 7.2.1.1;
• Verified data reported to TRI for two refineries, discussed in Section
7.2.1.2;
• Met with representatives of a refinery and industry trade associations to
discuss pollutant loadings estimated using TRI and PCS data, discussed in
Section 7.2.1.3; and
7-3
-------
Section 7 - Petroleum Refining
• Reviewed comments submitted in response to the December 31, 2003
Notice of the Preliminary Effluent Guidelines Program Plan, FRN [FRL-
7604-7], discussed in Section 7.2.1.4.
7.2.1.1 Identification of Petroleum Refineries Operating in 2000
EPA linked refineries reporting to TRI and PCS with EIA's list of refineries
operating in 2000. See Section 7.2.4 for a brief description of EIA' s Refinery Capacity Data
(21), used in this review. For refineries not included in EIA's list, EPA investigated whether the
facilities were actually petroleum refineries. EPA found that eight facilities that reported to TRI,
nine facilities that reported to PCS, and one that reported to both, were not operating refineries.
A number of these facilities were closed in or prior to year 2000. Others turned out to be
chemical manufacturers, PBSTs, or other nonrefinery operations. Table 7-1 lists these facilities
and the rationale for excluding each facility from the list of existing petroleum refineries in this
detailed review. The 18 facilities listed in Table 7-1 were excluded from the petroleum refining
industry detailed review and reclassified in TRIReleases2000.
7.2.1.2 Refinery-Specific Verification of TRI Data
EPA contacted the Lyondell-Citgo refinery in Houston, TX to verify the data as
reported to TRI in 2000. Lyondell-Citgo representatives confirmed that the refinery discharged
2,380 pounds of PACs to a POTW in 2000. In addition, the refinery submitted the individual
PAC concentrations in the refinery effluent (untreated wastewater and stormwater) (15). The
refinery discharges the wastewater to the Gulf Coast Waste Disposal Authority's Washburn
Tunnel Facility for biological treatment. EPA also received effluent data from the Washburn
Tunnel Facility's 2003 Peak Performance Award Application (9).
The Marathon Ashland Petroleum LLC refinery in Detroit, MI submitted a
request-for-withdrawal form to EPA to correct the reported releases of dioxins in 2000. The
refinery incorrectly reported 8.0613 grams of dioxins discharged to a POTW. The request-for-
withdrawal stated that the refinery discharged zero grams of dioxins in 2000. EPA updated the
TRIReleases2000 database to reflect this reporting change.
7-4
-------
Section 7 - Petroleum Refining
Table 7-1. Facilities Reporting to TRI and PCS Under SIC Code 2911 that are Not Operating Refineries
Facility Name
Buckeye Refining Co. L.L.C.
Pennzoil-Quaker State Co. Rouseville Refinery &
Packaging
Calumet Lubricants Co. Rouseville Plant
International Petroleum Corp.
Merichem Chemicals & Refinery Services L.L.C.
Two Waste-water Treatment Unit
Golden West Refining Co.
Chevron Products Co. Richmond Beach Asphalt
Refinery
Total Petroleum Inc.
Penreco
American Western Refining
Longview Refining Assoc. Inc.
Gulf Chemical Corporation
Commonwealth Oil Petrochemical
Cenco Refining Company
The Carbide/Graphite Group Inc.
Berry Petroleum Co. - Stephens
Neches River Treatment Corporation Lower Neches
Valley
Facility Location
Indianola, PA
Rouseville. PA
Rouseville. PA
Plant City, FL
Tuscaloosa, AL
Oregon, OH
Santa Fe Springs,
CA
Seattle, WA
Arkansas City, KS
Karns City, PA
Lawrenceville, IL
Longview, TX
Penuelas, PR
Penuelas, PR
Santa Fe Springs.
CA
Seadrift, TX
Stephens, AR
Beaumont, TX
Database
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
PCS
PCS
PCS
PCS
PCS
PCS
PCS
PCS
PCS
TRI, PCS
Rationale for Exclusion as Refinery
Facility is a petroleum bulk terminal.
Facility should be classified as SIC code 2999 and was shut down
in January 2000.
Facility should be classified as SIC code 2999 and was shut down
in 2001.
Facility is a waste oil recycling plant.
Facility is a chemical processing plant.
Facility is a wastewater treatment facility for Sunoco Inc.
(R&M): NPDES Permit Number 43616SNRFN1819W.
Facility ceased operations in 1992.
Facility is an asphalt plant.
Facility was closed in 1996.
Facility is a petrochemical manufacturing facility.
Facility was closed in 1995.
Facility is closed and is a Superfund site.
Facility is a chemical processing plant.
Facility is not an active refinery; currently a petroleum bulk
terminal.
Facility was shut down.
Facility manufactures calcium and graphite.
Facility was shut down in February 2000 and last operated in July
1999.
Facility is a centralized waste treatment facility'.
-------
Section 7 - Petroleum Refining
7.2.1.3 Meetings with Representatives from Refinery and Trade Associations
EPA met with representatives of the American Petroleum Institute (API) and
National Petrochemical and Refiners Association (NPRA) on February 11, 2004. Prior to the
meeting, API and NPRA sent a list of questions concerning the petroleum refining detailed
review to EPA. These questions and topics discussed during the meeting included the detailed
review work plan (Section 3.06, DCN 00701, EPA Docket OW-2003-0074), factors considered
for the review, use of the 1996 Preliminary Data Summary, dioxin TWFs, pollutant loading
estimates, and the review of PB STs. See the memorandum entitled Meeting Between EPA and
Representatives of American Petroleum Institute and National Petrochemical and Refiners
Association (5).
EPA met with representatives of Lyondell-Citgo Refining, LP on March 12, 2004
to discuss the operation and wastewater discharges of their Houston, TX refinery.
Representatives from the refinery presented an overview of the refinery and its wastewater
discharges. The refinery discharges to the Washburn Tunnel facility, a POTW operated by the
Gulf Coast Waste Disposal Authority. The Lyondell-Citgo refinery and one other refinery
contribute about 50 percent of the wastewater flow to the Washburn Tunnel. Gulf Coast Waste
Disposal Authority has never detected PACs in the effluent from the Washburn Tunnel facility.
EPA explained how the TPJReleases2000 database estimates the refinery's pollutant discharge
of PACs by assuming the POTW (Washburn Tunnel) removes 92 percent of mass as reported to
TRI. See the memorandum entitled Meeting Between EPA and Representatives of Lyondell-
Citgo Refining, LP (6).
7.2.1.4 Comments Received in Response to the Federal Register Notice of the 2004/2005
Preliminary Effluent Guidelines Program Plan
EPA received comments specific to petroleum refining from NPRA, API, and the
County Sanitation Districts of Los Angeles County. The comments are summarized below.
NPRA submitted comments regarding EPA's use of data as reported to TRI for
screening purposes. NPRA stated that an investigation of TRI reporting basis should be
performed before using the values in a screening assessment. NPRA submitted refinery-specific
comments on TRI data that EPA used to estimate TWPE for PACs and dioxins. Based on EPA's
TRI Reporting Forms and Instructions, refineries may estimate releases of nondetected
pollutants using one-half the detection limit to avoid under-reporting. See Sections 7.6.5 and
7.7.4.4 for specific industry comments on PACs and dioxins.
API submitted comments regarding EPA's use of TRI data for screening purposes
and provided information on how its member refineries estimated the discharges of PACs and
dioxins for TRI. Most refineries do not detect PACs and dioxins in the effluent, but use the
detection limit (or other methods) to estimate the mass of pollutant releases to wastewaters. See
Sections 7.6.5 and 7.7.4.4 for specific comments on PACs and dioxins. API agreed with EPA
that using the benzo(a)pyrene TWF for TWPE calculations (used for the screening-level
analysis) is a worst-case scenario. In its comments, API used EPA's revised TWF (based on
7-6
-------
Section 7 - Petroleum Refining
distribution of PACs in refinery products) to recalculate PAC loadings. API also submitted
effluent data from 10 refineries performing activated sludge treatment that were collected during
1993-1994 in conjunction with EPA Office of Solid Waste (see Section 7.6.4.3).
The County Sanitation Districts of Los Angeles County (a group of 27 Districts)
provided comments regarding the questions posed by EPA in the December 31, 2003 FRN.
Thirteen refineries discharge wastewater to District facilities. The Districts' comments include a
discussion of its analytical data for PACs, dioxins, and metals (selenium and vanadium). As
noted in the comments, the Districts submitted analytical data (1984-1993) to EPA as part of the
1996 Preliminary Data Summary. Since the 1996 Preliminary Data Summary, the Districts have
found that refinery wastewater quality has not varied greatly, except for a decrease in the
concentrations of methyl tertiary-butyl ether (MTBE) and benzene, toluene, ethylene, and xylene
(BTEX). The MTBE concentration decrease can be attributed to the ban of MTBE in gasoline in
the state of California. The BTEX concentration decrease can be attributed to the promulgation
of the Clean Air Act (CAA) National Emission Standards for Hazardous Air Pollutants
(NESHAP) regulations in 1992 (3).
The Gulf Coast Waste Disposal Authority submitted comments on the December
31, 2003 FRN concerning the PACs TWPE discharges calculated by EPA (10). The comments
note that PACs have never been detected in the effluent from the Washburn Tunnel Facility
(which receives petroleum refining wastewater from the Lyondell-Citgo Refinery in Houston,
TX and the Crown-Central Petroleum Refinery in Pasadena, TX). Gulf Coast Waste Disposal
Authority submitted PAC discharge concentrations for 2000 through 2003. EPA verified the
TRI discharges reported by the Lyondell-Citgo Refinery (see Section 7.2.1.2). For both
refineries, EPA estimated the TWPE discharged to surface waters using its standard percent
removal calculation (discussed in Section 4.2.4).
7.2.2 Permit Compliance System (PCS)
PCS is a computerized management information system maintained by EPA's
Office of Enforcement and Compliance Assurance (OECA). This system contains only permit-
required monitoring data for direct-discharging facilities. States may submit data from
refineries' discharge monitoring reports (DMRs) to PCS. The data from each DMR will vary
depending on the refinery's NPDES permit requirements. Refineries that discharge to a POTW,
or that transfer their wastewater to a private waste treater, do not submit DMRs; therefore, their
data are not in PCS. In addition, PCS typically does not include data for refineries that states
classify as "minor sources."
The Effluent Data Statistics System (EDSS) is a system that EPA developed to
estimate mass loadings based on data stored in PCS. EDSS uses PCS-reported mass loading
values or calculates loadings using concentration and flow rate data, taking into account the
various units of concentration and flow rates. EDSS and PCS are the major sources of data for
the PCSLoads2000 database. EPA selected permit facility data, parameter limits data, and
measurement/violation data for major facilities to develop PCSLoads2000 (34). Section 4.2.2
discusses the PCSLoads2000 database in further detail.
7-7
-------
Section 7 - Petroleum Refining
The 2000 PCS includes data from 104 (63 percent) of the 163 refineries operating
in the U.S. in 2000. To verify the data reported to PCS, EPA performed the following activities:
• Verified that facilities reporting as SIC code 2911 were petroleum
refineries and linked each refinery's data with data from TRI and EIA,
discussed in Section 7.2.1.1;
• Met with representatives of industry trade associations to discuss pollutant
loadings estimated using data as reported to TRI and PCS, discussed in
Section 7.2.1.3; and
• Reviewed comments submitted in response to the December 31, 2003
Federal Register notice of the Preliminary Effluent Guidelines Program
Plan, FRN [FRL-7604-7], discussed in Section 7.2.1.4.
7.2.3 The U.S. Economic Census
The U.S. Economic Census of 1997, described in Section 4.1.3, provides data on
the number of facilities by SIC code, but does not include a list of the facilities. The U.S.
Economic Census of 1997 includes refineries that by 2000 were shut down or no longer
operating and might also include nonproduction facilities. In contrast, EIA, which is part of the
U.S. Department of Energy (DOE), publishes annual updates of the number of operating
refineries, their capacities, and operations. EPA used EIA data for this detailed review, because
the data provide more accurate and detailed data on each refinery. Consequently, EPA did not
use census data in its analysis of the petroleum refining industry.
7.2.4 Data Sources Specific to the Petroleum Refining Industry
EPA used the following data sources specific to the petroleum refining industry in
its detailed study.
• Energy Information Administration (EIA) - EIA tracks the number of
operating refineries, their capacities, and operations. EPA downloaded
capacity data from the EIA web site (21) and linked each refinery's crude
petroleum operating capacity to the discharges reported to TRI and PCS.
EPA also used data from EIA to identify the types of catalytic reforming
at each refinery.
• Oil & Gas Journal - Provides general information about the petroleum
industry and publishes worldwide refinery-specific capacities each year
(12).
• Washington Department of Ecology - EPA reviewed dioxin study reports
DOE required from four Washington State refineries (18, 36) and Water
1-1
-------
Section 7 - Petroleum Refining
Pollution Prevention Opportunities in Petroleum Refineries (37), a report
of a state-funded study.
• Dioxin Source Investigation Pursuant to Cease and Desist Order No. 95-
151, Final Report - Study prepared by Tosco Refining Company Avon
Refinery to identify all sources of dioxins contributing to refinery's final
effluent dioxin load (19). The report, based on 150 samples collected in
1996, provides source information and granulated activated carbon (GAC)
treatment system percent removals for dioxins. The report does not
provide detailed treatment performance data (e.g., influent and effluent
concentrations).
• EPA/EAD 1996 Preliminary Data Summary for the Petroleum Refining
Category (24) - Report describes the industry, pollutant discharges,
environmental issues, regulatory standards, treatment technologies, and
economic profile using data collected during 1992 and 1993.
• Contacts with treatment technology vendors - EPA contacted treatment
technology vendors to gather information on new options to reduce
pollutant concentrations in petroleum refining wastewater.
• Industry-provided information/comments - Discussed in Section 7.2.1.4.
7.3 Industry Description
The petroleum refining industry purifies (or refines) crude petroleum into various
petroleum products. Products include gasoline, kerosene, distillate fuel oils, residual fuel oils,
and lubricants. Refineries use various processes, such as fractionation, distillation, and cracking,
to refine the crude petroleum. The industry is classified by SIC code 2911 (North American
Industry Classification System (NAICS) code 32411).
7.3.1 Number of Refineries
In 2000, there were 163 petroleum refineries operating in the United States. EIA
lists the industry capacity on January 1, 2001 as 16.6 million barrels of crude petroleum per day,
with individual refinery capacities ranging from 880 to 508,000 barrels per day. EIA's Refinery
Capacity Data as of January 1, 2001 and the Oil and Gas Journal's "2001 Worldwide Refining
Survey" list all the petroleum refineries, along with their capacities and other pertinent process
information. (12, 21)
Refineries are located in 31 states, with most (43 percent) located in Texas,
Louisiana, and California.
7-9
-------
Section 7 - Petroleum Refining
7.3.2
Discharge Status for Petroleum Refineries
EPA determined the discharge status of all petroleum refineries using data
reported to TRI and PCS in 2000. Table 7-2 lists the discharge status for the 163 petroleum
refineries operating in the U.S. during 2000.
In the PCS data system, facilities may be classified as major1 or minor
dischargers. States are not required to provide discharge data for minor facilities to PCS, and so
reports for minor facilities are incomplete. For this reason, EPA did not use data from minor
facilities in this review. Thirty two petroleum refineries are identified as minor dischargers in
PCS.
Table 7-2. 2000 Discharge Status for Petroleum Refineries
EIA
Number
of
Refineries
163
TRI 2000
Direct
Dischargers
94
Indirect
Dischargers
21
Both
13
No Water
Discharge
Reported
26
PCS 2000
Majors
Dischargers
103
Minor
Dischargers
32
Sources: TRIReleases2000 andPCSLoads2000.
7.3.3
Overview of Refinery Operations
To refine the crude petroleum, refineries begin by desalting the crude and
distilling it into its various components (or fractions). The next step is to convert the distillation
fractions into petroleum products. These processes include cracking, coking (term refers to by-
product coke (solid carbon with varying impurities) formed during the process), reforming, and
alkylation. Other support operations include reformer catalyst regeneration, sulfur recovery,
additive production, and product blending. This section presents descriptions of these
operations, as detailed in EPA's Industry Sector Notebook: Profile of the Petroleum Refining
Industry (32).
All refineries perform distillation operations; however, the extent and variety of
processes used to convert distilled fractions into petroleum products varies greatly by refinery.
"Topping" refineries perform only distillation operations - some perform only atmospheric
distillation.
Many refinery operations generate sour waters. Sour waters generally result from
water brought into direct contact with a hydrocarbon stream (e.g., when water is used as a
washing medium or steam is used as a stripping or mixing medium). Sour waters contain
sulfides, ammonia, phenols, and other organic chemical constituents of the crude oil.
'Facilities are classified as "'major" based on many factors, including effluent design flow, physical and chemical
characteristics of the waste stream, and location of discharge.
7-10
-------
Section 7 - Petroleum Refining
7.3.3.1 Crude Petroleum Processing
The first steps in the petroleum refining process are to desalt the crude petroleum
and separate the crude into its various petroleum fractions (i.e., unrefined product streams) using
distillation. Each of these processes and resulting wastewater streams is discussed below.
Desalting
Petroleum refineries remove corrosive salts from the crude petroleum by mixing
heated crude with water. The salt, along with some metals, suspended solids, and other water-
soluble compounds, dissolves in the water. The refinery then separates the crude petroleum and
desalter water using electrostatic separation and demulsification to break the emulsion and
separate the two phases (oil/water separation). The desalter water is then discharged to the
refinery treatment system. The raw water used for desalting is often untreated or partially treated
wastewater from elsewhere at the refinery.
Distillation
Petroleum refineries use two types of distillation towers: 1) atmospheric
distillation separates the lighter petroleum fractions, and 2) vacuum distillation separates the
heavier petroleum fractions. Petroleum fractions separated using atmospheric distillation include
naphtha, gasoline, kerosene, light fuel oil, diesel oils, gas oil, lube distillate, and heavy bottoms
(further separated by steam strippers or vacuum distillation). The uncondensed refinery fuel gas,
or sour gas, leaving from the top of the distillation tower contains primarily methane and ethane,
along with hydrogen sulfide and ammonia. The refinery will treat the sour gas to recover the
methane and ethane which is then used to heat furnaces at the refinery. Most refineries
performing vacuum distillation use vacuum pumps and surface condensers; however, they may
also use barometric condensers. The wastewater from distillation includes condensed steam
from the tower (called oily sour water), which contains hydrogen sulfate and ammonia, and oily
wastewater if barometric condensers are used for vacuum distillation.
7.3.3.2 Refining of Petroleum Fractions - Cracking. Coking. Hydrotreating/
Hydroprocessing. Alkylation. Polymerization, and Isomerization
The petroleum fractions from the distillation step might be further refined at the
refinery using a variety of processes. These processes modify the hydrocarbon molecular
structure either by breaking them into smaller molecules, joining them into large molecules, or
reshaping the molecules for higher quality. Process types include thermal cracking
(visbreaking), catalytic cracking, catalytic hydrocracking, coking, hydrotreating, alkylation,
isomerization, polymerization, and catalytic reforming (discussed on Section 7.3.3.3). Refineries
might use multiple operations, discussed below.
Thermal cracking (visbreaking) breaks heavy gas oils and residues from
distillation into smaller, lighter molecules using heat and pressure. Operations include
preheating, reactor, cooling to stop the cracking reaction, flasher chamber (reduces pressure and
7-11
-------
Section 7 - Petroleum Refining
draws off lighter products), and fractionating tower (separates various petroleum fractions). The
cooling step uses part of the heavy bottoms from the fractionating tower to cool the incoming
process stream. Wastewater includes sour water from the fractionating tower.
Catalytic cracking breaks light and heavy oils from distillation into smaller,
lighter molecules (primarily gasoline with some fuel oil and light gases) using heat, pressure, and
a catalyst. Because catalytic cracking produces higher octane gasoline and less heavy fuel oils
and light gases, it has largely replaced the thermal cracking process at petroleum refineries. The
most common reactor types used for catalytic cracking are fluidized beds and moving beds (both
with continuous catalyst regeneration); other types include fixed-bed reactors and once-through
units. Catalysts are mixtures of crystalline, synthetic silica-alumina (zeolites) and amorphous,
synthetic silica-alumina. Wastewater includes sour water from the fractionating tower.
During catalytic cracking, coke collects on the catalyst surface. To maintain
catalyst properties, refineries need to regenerate the catalyst (either continuously or periodically).
Catalyst regeneration involves burning the coke off the catalyst. Steam used to purge and
regenerate catalysts might become wastewater contaminated with metal impurities from the feed
stream.
Refineries use catalytic hydrocracking for petroleum fractions that are most
difficult to crack (middle distillates, cycle oils, residual fuels oils, and reduced crudes) to
produce gasoline. Catalytic hydrocracking typically uses a fixed-bed reactor under high pressure
(1,200 to 2,000 psig) in the presence of hydrogen (increases gasoline yield). Prior to
hydrocracking, feedstocks typically undergo hydrotreatment to remove impurities (hydrogen
sulfide and ammonia) that might foul the catalyst during the process and water removal using
silica gel or a molecular sieve dryer. The catalyst is typically a mixture of zeolites with small
amounts of rare earth metals. Sour gas and sour water are both generated from the fractionating
tower; however, hydrotreating the feedstock prior to cracking results in relatively low levels of
impurities in both waste streams. Hydrocracking catalyst regeneration is typically performed off
site.
Coking is a cracking process that breaks residual fuel oils into gasoline and
diesel. A by-product of the process is petroleum coke (solid carbon with varying impurities).
Refineries use two types of coking operations: 1) delayed coking and 2) fluid coking. The
delayed coking process steps are the same as thermal cracking except the feed stream reacts
longer without cooling. The heavy materials from the fractionating tower are fed into a coke
drum (insulated vessel) to form petroleum coke. The coking process includes steam injection to
the coke drum to remove hydrocarbon vapors (lighter products, hydrogen sulfide, and ammonia)
and cooling water injection to cool the coke. The hydrocarbon vapors are fed back to the
fractionating tower where they are removed as product streams or part of the sour gas.
Wastewater from the coking drum includes any condensed steam, cooling water, and water used
to remove the coke (high-pressure water jets).
Hydrotreating and hydroprocessing remove impurities (e.g., sulfur, nitrogen,
oxygen, halides, and trace metals) from the feedstock to prevent fouling of the catalyst during
7-12
-------
Section 7 - Petroleum Refining
cracking and assist in forming higher-quality or lighter products in a fixed-bed reactor. Using
catalysts, high pressure, high temperature, and hydrogen, the processes separate the treated
product stream from the light fuel gas stream, hydrogen sulfide, and ammonia. The treated
product stream is then cooled and the hydrogen-rich gas is recycled back to the reactor. The
refinery treats the light fuel gas stream with the sour gas and the hydrogen sulfide at the sulfur
recovery unit. Catalysts are cobalt or molybdenum oxides on alumina that might also contain
nickel and tungsten; these are regenerated off site.
Alkylation forms a high octane gasoline blending stock (alkylates such as
propane and butane) from isobutane. The isobutane feedstock is formed primarily during
catalytic cracking and coking operations. The process uses either a sulfuric acid or hydrofluoric
acid catalyst. A solution of potassium hydroxide is used to extract hydrofluoric acid catalyst
from the hydrocarbon stream. Hydrofluoric acid might be regenerated on site, resulting in a
waste oil containing dissolved polymerization products. The sulfuric acid must be regenerated in
a sulfuric acid plant, usually located off site.
Polymerization (similar to alkylation) converts propene and butene to high
octane gasoline blending stock using high pressure and a phosphoric acid catalyst. The catalyst
is typically not regenerated. Prior to the reactor, the feedstock undergoes a caustic wash to
remove mercaptans, which contain sulfur; an amine solution wash to remove hydrogen sulfide; a
water wash to remove caustics and amines; and drying. Sulfur, bases, and oxygen can negatively
impact the reaction. The wastewater generated includes caustic wash and sour water containing
amines and mercaptans.
Isomerization alters the arrangement of the hydrocarbon molecules using high
temperatures (200-400°F) and a platinum-based catalyst in a hydrogen environment. Typically,
isomerization converts paraffins (butane or pentane) to isoparaffins with higher octane.
Catalysts are replaced approximately every two to three years. The platinum in the spent catalyst
is recovered off site. Sour gas and sour water are generated from the process.
One catalyst type requires the continuous addition of organic chlorides. The
organic chlorides are converted to hydrogen chloride. The refinery uses caustic to neutralize any
entrained hydrochloric acid in the light fuel gas stream. This results in a caustic wash waste
stream, containing calcium chloride (or other salts).
7.3.3.3 Refining of Petroleum Fractions - Catalytic Reforming and Reformer Catalyst
Regeneration
In December 1988, the Ontario Ministry of the Environment confirmed that
dioxins were present in internal wastewater from Ontario petroleum refineries. The Ministry
determined that catalyst regeneration operations for the catalytic reforming process were the
source of the dioxins (24, Page G-l). Additional work by EPA confirmed that reformer catalyst
regeneration wastewater was the major source of dioxins in refinery process wastewater (24).
7-13
-------
Section 7 - Petroleum Refining
Catalytic Reforming
Catalytic reforming units are designed to reform naphthas into higher octane
aromatics, varying temperature and pressure to promote dehydrogenation, isomerization, and
hydrogenolysis reactions.
The reforming process uses a platinum or bimetallic (platinum and rhenium)
catalyst material. The catalyst is designed to be highly active and selective, and to promote
dehydrogenation reactions with maximum surface area exposed to the feedstock. Ideally, the
platinum ions are dispersed on the surface of an alumina or silica-alumina support. Chlorine
promotes the activity of a platinum-alumina catalyst, and is stripped from the surface of the
catalyst as hydrogen chloride during the reactions. As these reactions occur, the activity of the
catalyst slows until it needs to be regenerated or replaced to be effective.
Dehydrogenation reactions are favored by low pressure and high temperature.
However, coke is also formed at low pressure, which also tends to deactivate the catalyst and
reduce yields. Coke formation can be reduced by operating under high hydrogen pressure.
Catalyst Regeneration
There are three general types of catalytic reforming processes, distinguished by
the way in which catalyst is regenerated: semi-regenerative, cyclic, and continuous. A refinery
might have more than one reformer, using different processes. Table 7-3 presents the number of
refineries performing each type of regeneration. Because a refinery might have more than one
reformer, using different processes, the sum of the refineries with each type of process exceeds
the total number of refineries with catalytic reforming.
Table 7-3. Reformer Catalyst Regeneration Processes in 2000
Type of Regeneration Process
Semi-regenerative
Cyclic
Continuous
Not specified
Total
Number of Refineries
33
21
74
10
122
Percentage of Refineries
With Catalytic Reforming
27%
17%
61%
8%
Source: U.S. Department of Energy, Petroleum Supply Annual 2000, Volume 1. Energy Information
Administration; and Oil & Gas Journal, "2001 Worldwide Refining Survey." Volume 99.52, December 24, 2001.
The following description of the three types of catalytic reforming processes is
taken from Appendix G of the 1996 Preliminary Data Summary.
The semi-regenerative process generally has three reactors. After the catalyst's
activity is depleted, all three reactors are taken out of service and undergo one of several
7-14
-------
Section 7 - Petroleum Refining
regeneration processes. Figure 7-1 shows a typical schematic for this type of regeneration. In
2000, 27 percent of U.S. catalytic reforming units used the semi-regenerative process (20).
[^"""l^^ Compressor
Preheater 1
Caustic •
Makeup Water •
Figure 7-1. Semi-Regenerative Catalytic Reforming Process
The reactors are purged with nitrogen, the reactor bed temperature is raised to 750
to 850° F and the coke is burned off the catalyst with controlled oxygen concentration and
pressures. Hydrogen chloride, chlorine, catalyst particles, carbon dioxide, oxides of sulfur and
nitrogen, and organic compounds (including dioxins) might make up the composition of the off-
gases. Scrubbing these acidic off-gases in the separator to neutralize the gases to protect the
equipment generates wastewaters. Caustic or water might be used in scrubbing the off-gases, or,
in some cases, the off-gases may be vented directly to the atmosphere. When the burn is
complete, the catalyst is reactivated with either chlorine gas or chlorinated organic compounds.
The cyclic catalytic reforming process is similar to the semi-regenerative process
except an additional reactor is available to replace one that is ready for regeneration. This allows
for continued production during regeneration. While the semi-regenerative reformers are
designed for long on-stream periods by using higher hydrogen pressure to reduce coke build-up,
cyclic reformers are designed for lower operating pressure. Yields are much higher, but these
cyclic reformers must be regenerated more frequently (daily to monthly). Figure 7-2 shows the
regeneration process, which consists of the same operations as those used in the semi-
regenerative process. In 2000, 17 percent of U.S. catalytic reforming units used the cyclic
catalytic reforming process (20).
7-15
-------
Section 7 - Petroleum Refining
Compressor
Preheater
Step 1. N2
Step 2. Air
Gases to Stack
i
Cooler
Makeup Water
Separator
Effluent to
Wa stew ate r
Treatment
Figure 7-2. Cyclic Catalytic Reforming Process
The continuous catalytic reforming process is designed to operate at lower
hydrogen pressures, which increases yield. However, operating at these low pressures results in
more rapid coke buildup. To maintain performance, the unit is designed for continuous catalyst
regeneration. Figure 7-3 shows a schematic of this process. In 2000, 61 percent of U.S. catalytic
reforming units used the continuous process (20).
Feed
Reform ate
Figure 7-3. Continuous Catalytic Reforming Process
7-16
-------
Section 7 - Petroleum Refining
The only wastewater sources from the continuous reforming process are from
scrubbing the off-gases; usually, the off-gases are vented and/or flared directly to the
atmosphere. The regeneration off-gas vent might have a bag filter to capture catalyst fines,
which are reprocessed to recover valuable catalyst material (platinum). In its 1990-91 study,
EPA did not identify any facilities scrubbing off-gases from continuous regeneration reformers;
therefore, the Agency did not include the continuous regeneration process in the wastewater
sampling program.
7.3.3.4 Refining of Petroleum Product Properties
Petroleum refineries use further refining operations to enhance certain product
properties. This subsection describes these operations (solvent extraction, chemical treating,
dewaxing, and propane deasphalting).
To improve viscosity, oxidation resistance, color, and gum formation, refineries
remove aromatics from the lube oil feedstock. Solvent extraction is the dissolving of the
aromatics within a packed tower or rotating disc contactor, usually with furfural and phenol
solvents. Solvents are recovered through distillation and steam stripping. The wastewater
stream from the solvent recovery step contains oil and solvents.
To remove or modify properties associated with certain impurities (sulfur,
nitrogen, or oxygen), refineries perform one of two chemical treating processes: 1) extraction or
2) oxidation (or sweetening). For example, refineries may remove sulfur, which gives the
products an offensive odor. A possible waste stream is an oily disulfide stream.
To alter viscosity properties, refineries might dewax lubricating oil base stocks.
Dewaxing processes include solvent dewaxing and selective hydrocracking. Solvents used
include propane and mixtures of methyl ethyl ketone (MEK) with methyl isobutyl ketone
(MIBK), or MEK with toluene. Wastewater is generated from solvent recovery. Selective
hydrocracking uses one or two zeolite catalysts to selectively crack the wax paraffins. See
Section 7.3.2.2 for more details on catalytic hydrocracking.
Propane deasphalting is an extraction process using propane to produce
lubricating oil base stocks from vacuum distillation residuals. During propane recovery,
wastewater contaminated with propane is produced.
7.3.3.5 Supporting Operations at Petroleum Refineries
Supporting operations at petroleum refineries include sulfur recovery, additive
production, and product blending. Petroleum refineries recover sulfur from the sour gas to meet
air emission limits of sulfur oxides (SOx) and to sell elemental sulfur. Sulfur recovery includes
the following steps: 1) separating fuel gases (methane and ethane) from the hydrogen sulfide and
2) removing sulfur from the hydrogen sulfide. To either improve performance or meet
environmental requirements, refineries might produce additives for motor fuels, such as MTBE
and tertiary amyl methyl ether (TAME). Product blending consists of mixing petroleum
7-17
-------
Section 7 - Petroleum Refining
products to meet customer specifications (e.g., vapor pressure, specific gravity, sulfur content,
viscosity, octane rating).
7.4 Regulatory Background
Effluent limitations guidelines and pretreatment standards found in 40 CFR Part
419 are applicable to discharges from the petroleum refining industry. Sections 7.4.1 through
7.4.4 discuss these regulations in detail. In addition, Section 7.4.5 summarizes the Clean Water
Act (CWA) stormwater requirements and Spill Prevention, Control, and Countermeasure
(SPCC) requirements and two other major statutes with which petroleum refineries must comply:
1) the Resource Conservation and Recovery Act (RCRA) and 2) the Clean Air Act (CAA).
7.4.1 Effluent Guidelines History
In 1974, EPA promulgated standards for Best Practicable Control Technology
Currently Available (BPT), Best Available Technology Economically Available (BAT), New
Source Performance Standards (NSPS), Pretreatment Standards for Existing Sources (PSES) and
Pretreatment Standards for Existing Sources (PSNS) for the Petroleum Refining category. BAT
was remanded after legal challenge in 1976, and EPA continued to study BAT. This study
included a survey of 1976 industry treatment practices. In 1982, EPA repromulgated BAT,
setting it equal to BPT (i.e., the 1976 level of control). In 1985, EPA revised BAT for phenol and
chromium, based on additional flow reduction and lower attainable concentrations for these two
pollutants.
EPA conducted a review of the petroleum refining industry from 1992 to 1996 to
determine whether revisions to the ELGs were warranted. For this evaluation, EPA reviewed
data primarily from TRI and PCS. In addition, EPA collected sampling data during visits to six
refineries. The Agency published the results of this review in the Preliminary Data Summary for
the Petroleum Refining Category, April 1996 (24). The study provides a general description of
the industry, treatment technologies used, water usage, analysis of dioxins in catalytic reformer
wastewater, estimated pollutant discharges, environmental issues, and economic profile.
7.4.2 Subcategorization and Applicability
The effluent guidelines for the Petroleum Refining category are divided into five
subcategories, described below:
• Topping Refineries (Subcategory A) - The effluent guidelines for this
subcategory apply to discharges from any facility that produces petroleum
products using topping and catalytic reforming, whether or not the facility
includes any process in addition to topping and catalytic reforming. This
subcategory does not apply to facilities that include thermal processes
(coking, thermal cracking (visbreaking), etc.) or catalytic cracking.
Topping refineries separate crude oil by atmospheric and/or vacuum
distillation, solvent deasphalting, and catalytic reforming. Existing
7-18
-------
Section 7 - Petroleum Refining
guidelines for the topping subcategory include allowances for ballast
water. Ballast is defined as the flow of waters, from a ship, that is treated
along with refinery wastewaters in the main treatment system.
Cracking Re fineries (Subcategory B) - The effluent guidelines for this
subcategory apply to all discharges from any facility that produces
petroleum products using topping and cracking, whether or not the facility
includes any process in addition to topping and cracking. However, this
subcategory is not applicable to facilities that meet the definition of
Subcategories C, D, or E.
Petrochemical Refineries (Subcategory C) - The effluent guidelines for
this subcategory apply to all discharges from any facility that produces
petroleum products using topping, cracking, and petrochemical operations
whether or not the facility includes any process in addition to topping,
cracking, and petrochemical operations. However, this subcategory is not
applicable to facilities that meet the definition of Subcategories D or E.
Petrochemical operations meet one of the two following definitions:
— Produce of second-generation petrochemicals (e.g., alcohols,
ketones, cumene, and styrene), or
— Produce of first-generation petrochemicals and isomerization
products (e.g., benzene, toluene, xylenes, olefms, and
cyclohexane) when 15 percent or more of the total refinery
production is as first-generation petrochemicals and isomerization
products.
Lube Refineries (Subcategory D) - The effluent guidelines for this
subcategory apply to all discharges from any facility that produces
petroleum products using topping, cracking, and lube oil manufacturing
processes, whether or not the facility includes any process in addition to
topping, cracking, and lube oil manufacturing processes. However, this
subcategory is not applicable to facilities that meet the definition of
Subcategories C or E.
Integrated Refineries (Subcategory E) - The effluent guidelines for this
subcategory apply to all discharges resulting from any facility that
produces petroleum products using topping, cracking, lube oil
manufacturing processes, and petrochemical operations, whether or not
the facility includes any process in addition to topping, cracking, lube oil
manufacturing processes, and petrochemical operations.
7-19
-------
Section 7 - Petroleum Refining
7.4.3 Technical Basis of Regulation
The BPT basis includes the following in-plant controls:
• Sour water strippers to reduce sulfide and ammonia entering the
wastewater treatment plant;
• Elimination of once-through barometric condenser water;
• Sewer segregation, to keep unpolluted stormwater run-off and once-
through cooling water separate from process wastewater (and out of the
wastewater treatment plant); and
• Elimination of polluted once-through cooling water by properly
maintaining surface condensers or using wet and dry recycle systems.
The BPT and NSPS basis includes the following end-of-pipe treatment:
• Equalization and stormwater diversion;
• Oil and solids removal (API separator and/or baffle plate separator);
• Dissolved air flotation (DAF) to remove additional oil;
• Biological treatment to reduce biochemical oxygen demand (BOD) and
chemical oxygen demand (COD) (activated sludge, aerated lagoons,
oxidation ponds, or trickling filter); and
• Effluent polishing (polishing ponds or sand, dual-media, or multimedia
filters).
In 1982, EPA confirmed the above technology basis for setting BAT effluent
limitations. EPA based PSES and PSNS on oil/water gravity separators and in-plant sour water
stripping for ammonia control.
7.4.4 Regulated Pollutants
BPT, BAT, and NSPS established production-based mass limitations for the
following pollutants based on the treatment technologies described in Section 7.4.3:
• Ammonia as nitrogen;
5-day BOD;
• COD (or total organic compounds (TOC) for high-chloride effluents);
• Hexavalent chromium;
• Oil and grease;
7-20
-------
Section 7 - Petroleum Refining
pH;
• Phenolic compounds;
Sulfide;
• Total chromium; and
• Total suspended solids (TSS).
In 1982, EPA used new data to revise its BAT flow model and developed more stringent
limitations for chromium and total phenolics. The limitations for these pollutants are listed in 40
CFR Part 419. The mass limitations are based on feedstock production (pounds pollutant per
1,000 barrel feedstock), and specific refinery limitations are based on size factors (1,000 barrels
feedstock per stream day), process configuration factors, and processes.
EPA established the following daily maximum pretreatment standards for existing
sources in all subcategories:
Oil and grease: 100 milligrams per liter (mg/L); and
Ammonia as nitrogen: 100 mg/L.
EPA established the following daily maximum pretreatment standards for new
sources in all subcategories:
• Oil and grease: 100 mg/L;
• Ammonia as nitrogen: 100 mg/L; and
• Total chromium for cooling tower discharge: 1 mg/L.
7.4.5 Other Regulations Affecting Petroleum Refineries
In addition to the effluent limitations guidelines and standards at 40 CFR Part
419, petroleum refineries are also subject to other regulations. This subsection describes a few
of the major regulations also affecting the petroleum refining industry. These include solid and
hazardous waste regulations (RCRA), hazardous air pollutant regulations (CAA), and CWA
stormwater regulations and SPCC requirements.
7.4.5.1 RCRA
RCRA addresses solid (Subtitle D) and hazardous (Subtitle C) waste management
activities. Subtitle C (40 CFR Parts 260-299) governs the handling of hazardous waste from the
point of generation to disposal. Regulations for hazardous waste include waste accumulation,
manifesting, and record-keeping standards. Permits under Subtitle C include facility
contingency plans, emergency procedures, and unit-specific standards. Petroleum refineries
typically generate the following listed and characteristic hazardous wastes:
• K051 - API separator sludge;
• K049 - Slop oil emulsion solids;
• K048 - Dissolved air flotation floats;
7-21
-------
Section 7 - Petroleum Refining
• F037 - Other primary oil/water separator sludge, bar screen debris;
• F038 - All other sludge, floats, and used filter bags;
• D004 - Wastes containing arsenic;
• D007 - Wastes containing chromium;
• D008 - Wastes containing lead;
• D009 - Wastes containing mercury; and
• DO 10 - Wastes containing selenium.
To meet land disposal restrictions, facilities typically incinerate these wastes.
7.4.5.2 CAA National Emission Standards for Hazardous Air Pollutants (NESHAPs)
Refineries are subject to NESHAP if they are a major source of hazardous air
pollutants (HAP) and emit 10 tons per year of a single HAP or 25 tons per year of a combination
of HAPs. The 1995 Petroleum Refinery NESHAP requires controls for wastewater streams
containing benzene above specified threshold amounts (e.g., 10 parts per million (ppm) by
weight). By August 1998, refineries were required to comply with the benzene NESHAP 40
CFR Part 61 Subpart FF, which requires reducing benzene mass emissions by 99 percent using
suppression followed by another treatment process (e.g., steam stripping or biotreatment); and
reducing emissions from vents from stream strippers, other waste management, or treatment
units by 95 percent with a control device or to 20 ppm (by volume) at the outlet of the control
device. Suppression includes "hard piping" and using enclosed tanks and oil/water separators,
vented to vapor collection.
7.4.5.3 Other CWA Requirements
Under the CWA, EPA developed stormwater regulations to control the discharge
of stormwater associated with an industrial activity (i.e., stormwater discharge directly related to
manufacturing, processing, or raw material storage areas) (40 CFR Part 122.26(b)(14)). These
regulations apply to stormwater from Category ii - Manufacturing, one of the 11 industrial
activity categories defined at 40 CFR Part 122.26. This category specifically lists facilities
classified as SIC code 29, which includes petroleum refineries.
The stormwater regulations require regulated refineries to obtain coverage under a
NPDES stormwater permit and implement stormwater pollution prevention plans (SWPPPs) or
stormwater management programs to effectively reduce or prevent the discharge of pollutants
into receiving waters. Both the SWPPPs and stormwater management programs use best
management practices (BMPs).
The SPCC requirements were also developed under the CWA. SPCC requires
refineries meeting applicability requirements to prepare and implement spill prevention plans to
avoid oil spills into navigable waters or adjoining shorelines of the United States. The SPCC
plan must identify operating procedures in place and control measures installed to prevent oil
spills, and countermeasures to contain, clean up, or mitigate the effects of any oil spills that
occur.
7-22
-------
Section 7 - Petroleum Refining
7.5 Wastewater Characterization
As detailed in the U.S. Department of Energy's Water Use in Industries of the
Future: Petroleum Industry., the petroleum refining industry consumes approximately 65 to 90
gallons of water for every barrel of crude petroleum it refines. Most of this water is used for
steam production and cooling towers. Approximately 10 percent of this supply water (plus
additional blowdown flows from the steam production and cooling tower systems) is used for
process units, where it might be contaminated with pollutants (22). The process water is either
evaporated or treated (on or off site) as wastewater. This section describes the wastewater
generated, treated, and discharged from the petroleum refining industry, including wastewater
sources, types of pollutants, treatment, discharge volumes, and pollutant loadings.
7.5.1 Wastewater Sources
The major wastewaters from petroleum refineries are sour water from multiple
processes, scrubber water from reformer catalyst regeneration, spent potassium hydroxide stream
from alkylation, desalting wastewater, and caustic wash water from isomerization. Table 7-4
lists the major refining processes, types of wastewaters, and wastewater flow estimates as
reported in the U.S. DOE's Water Use in Industries of the Future: Petroleum Industry. The
table does not include the following wastewaters (described below):
Reformer Catalyst Regeneration Wash Water - Regeneration of spent catalyst
from the reforming process is a potential source of dioxins. Catalyst burning generates dioxins
(along with other combustion products). In addition to dioxins, the off-gases from the
regeneration reactor contain hydrogen chloride, chlorine, catalyst particles, carbon dioxide,
sulfur oxides, nitrogen compounds, and organic compounds. A caustic or water wash neutralizes
the acidic off-gases (i.e., scrubs the off-gas). Some refineries directly vent the off-gases to the
atmosphere. The wash stream is recycled with a blowdown of spent caustic (24). As shown in
Table 7-20, the volume of wastewater generated during catalyst regeneration at three
Washington State refineries ranged from 2,200 to 360,000 gallons per cycle.
Quench Wastewater - Petroleum refineries use direct contact "quench" water to
cool products quickly. The quench water is recirculated, and to maintain water quality, a
blowdown stream is sent to wastewater treatment (22).
Leaks - Includes any cooling water leaking into the hydrocarbon stream of the
heat exchanger (22).
7-23
-------
Section 7 - Petroleum Refining
Table 7-4. Process Wastewater at Petroleum Refineries
Process
Distillation
Fluid catalytic
cracking
Catalytic reforming
Alkylation
Crude desalting
Thermal cracking/
Visbreaking
Catalytic
hydrocracking
Coking"
Isomerization
Additive production:
ethers manufacture
Catalytic
hydrotreating
Chemical treating:
swee tening/Merox
process
Sulfur removal/Claus
process
Lubricating oil
manufacture
TOTAL
Wastewater Description (Possible
Pollutants)
Sour water (hydrogen sulfide, ammonia.
suspended solids, chlorides, mercaptans,
and phenol)
Sour water (hydrogen sulfide, ammonia,
suspended solids, oil, phenols, and
cyanides)
Sour water (hydrogen sulfide, ammonia,
suspended solids, mercaptans, oil)1
Spent potassium hydroxide stream
(hydrofluoric acid)
Desalting wastewater (salts, metals,
solids, hydrogen sulfide, ammonia, and
phenol)
Sour water (hydrogen sulfide, ammonia,
suspended solids, dissolved solids, and
phenol)
Sour water (hydrogen sulfide, ammonia,
and suspended solids)
Sour water (hydrogen sulfide, ammonia,
and suspended solids)
Sour water (hydrogen sulfide and
ammonia) and caustic wash water
(calcium chloride or other chloride salts)
Pre treatment wash water (nitrogen
contaminants)
Sour water (hydrogen sulfide, ammonia,
suspended solids, and phenol)
Sour water (hydrogen sulfide and
ammonia)
Steam stripping wastewater (oil and
solvents) and solvent recovery
wastewater (oil and propane)
Wastewater Flow Rate
(gallon/barrel of crude
petroleum)
26.0
15.0
6.0
2.6
2.1
2.0
2.0
1.0
1.0
<1.0
1.0
<1.0
<1.0
58.7
Percentage of
Total Wastewater
Flow Rate
44%
26%
10%
4%,
4%
3%
3%
2%
2%
2%
100%
Source: U.S. DOE. Water Use in Industries of the Future: Petroleum Industry. July 2003.
'Additional pollutants identified in EPA's Industry Sector Notebook: Petroleum Refining, September 1995.
2Fluid coking produces little or no effluents.
3Little or no wastewater generated.
7-24
-------
Section 7 - Petroleum Refining
7.5.2 Discharge Volumes
7.5.2.1 Discharge Volumes from the 1996 Preliminary Data Summary
Refinery process wastewater flow rates reported in EPA's 1996 Preliminary Data
Summary range from 0.4 to 8.1 million gallons per day (MGD) (150 to 3,000 million gallons per
year (MGY)). The median flow rate for a refinery was 1.5 MGD (average: 2.3 MGD). (24)
7.5.2.2 Discharge Volumes from All Refineries Reported to 2000 PCS
EPA reviewed the discharge volumes from all refineries reported to PCS in 2000;
however, the total flow rates reported to PCS might include stormwater and noncontact cooling
water, as well as process wastewater. In some cases, the PCS database identifies the type of
wastewater being discharged; however, most reported flow rates do not indicate the type of
wastewater. Total wastewater flow rates reported to PCS in 2000 range from 0.15 to 1,240
MGD (54 to 454,000 MGY). The median flow rate was 4.26 MGD (1,560 MGY) (34).
To isolate the process wastewater flow rate in the values reported to PCS, EPA
calculated the refinery discharge volume for only those outfalls where the refinery must monitor
for five-day BOD (BOD5). Refinery permits include limitations for BOD5 and/or ammonia for
process wastewater, but not for stormwater or noncontact cooling water. EPA calculated the
wastewater flow rates from outfalls with nonzero discharges of BOD5 or ammonia. These flow
rates range from 0.09 to 1,240 MGD (33 to 454,000 million gallons per year). The median flow
rate is 2.1 MGD (765 million gallons per year) (34). These flows are significantly greater than
the range and median refinery wastewater flow rates reported in the 1996 Preliminary Data
Summary. Since EPA has not received or obtained any information during this detailed review
to indicate process flows have increased since the 1996 Preliminary Data Summary, EPA
concludes that the higher volumes reflect EPA's inability to completely distinguish between
process wastewater discharges and nonprocess wastewater discharges in PCS.
7.5.3 Pollutant Loadings
For its screening-level analysis, EPA estimated current discharges (as TWPE) to
surface water from 56 industries currently covered by existing effluent guidelines. EPA used
data reported to TRI and PCS to estimate direct discharges, and used data reported to TRI,
reduced by a typical POTW percent removal, to estimate indirect discharges. EPA applied
TWFs to the TRI and PCS data to calculate the TWPE for each pollutant reported discharged by
petroleum refineries. The petroleum refining industry ranked fourth in pollutant discharges based
on 2000 TRI data and fourteenth in pollutant discharges based on 2000 PCS data. See the
Federal Register notice on the December 31, 2003 Preliminary Effluent Guidelines Program
Plan, FRN [FRL-7604-7]. See 4.2.4 for more discussion of EPA's calculation of TWPE.
Based on further review of the available data for this detailed study and comments
submitted in response to the December 31, 2003 Federal Register notice on the Preliminary
Effluent Guidelines Program Plan, EPA revised the list of refineries, the calculation of PACs and
7-25
-------
Section 7 - Petroleum Refining
dioxin TWPEs, and estimates of the current discharges to surface water from the petroleum
refining industry. EPA used these pollutant loadings to compare the Petroleum Refining
category to other industrial point source categories, and identify trends in wastewater discharges.
7.5.3.1
Pollutant Loadings Calculated Using TRI Data
Refineries report both direct discharges (i.e., mass of pollutant released directly to
receiving streams) and indirect discharges before treatment (i.e., mass of pollutant transferred to
POTWs) to TRI. For direct discharges, EPA used the reported mass to calculate TWPEs. For
indirect discharges, EPA first estimated pollutant mass removed by the POTW (i.e., pollutant
percent removal) and then used the resulting mass of pollutant after treatment to calculate
TWPEs discharged to the POTW's receiving stream. EPA calculated the reduction in pollutant
mass for indirect discharges using average POTW removal efficiencies (see DCN 00618,
Evaluation of RSEIModel Runs).
Using data as reported to TRI in 2000, the reported releases of PACs, dioxins, and
metals (predominantly vanadium) comprise 90 percent of the petroleum refining industry's toxic
releases. Refineries reporting to TRI discharge 328,000 TWPEs. Table 7-5 presents the pounds
(and TWPE) discharged by direct and indirect dischargers as reported to TRI for dioxins, PACs,
and metals.
Table 7-5. Discharges Reported to the 2000 TRI for the Petroleum Refining Industry -
Pollutants Comprising Approximately 90 Percent of the TWPE
Pollutant
Dioxins1
PACs2
Metals (Top 5)3
(Vanadium Only)
TOTAL
Total
Pounds
Discharged
0.02
487
98,200
139,000
Total TWPE
Discharged
139,000
112,000
76,000
(55,000)
328,000
Percentage
of Total
TWPE
Discharged
37%
30%
20%,
(15%)
87%,
TWPE Range
per Reporting
Refinery
42 - 52,000
460 - 40,400
0.96 - 25,076
(3.7-25,076)
A\7erage
TWPE per
Reporting
Refinery
8,200
5,900
1316
(3,946)
Number of
Reporting
Refineries
17
19
42
(14)
53
Source: TRIReleases2000.
'See Section 7.7.2 for a discussion on the calculation of TWPE.
2See Section 7.6.2 for a discussion on the calculation of TWPE.
3Top 5 metals include: vanadium, mercury, selenium, chromium, and lead.
EPA reviewed whether stormwater discharges are commonly reported to TRI.
When reporting discharges to surface water for TRI, facilities may report the percentage of the
pollutant discharge attributed to stormwater. Based on a review of the data reported to the 2000
TRI, all reported discharges of dioxins and PACs are from process wastewater (not stormwater).
Most vanadium discharges are also from process wastewater. Table 7-6 presents the stormwater
data reported to the 2000 TRI for petroleum refining.
7-26
-------
Section 7 - Petroleum Refining
Table 7-6. Stormwater Discharges Reported to the 2000 TRI
Pollutant
Dioxins
PACs
Vanadium
Number of
Refineries Reporting
Pollutant
17
19
14
Number of Refineries
Reporting Percent
Stormwater for Direct
Discharges
7
14
8
Number of Refineries
Reporting All Discharges as
Process Wastewater
(0 Percent Stormwater)
7
14
7
Source: TRIReleases2000.
7.5.3.2
Pollutant Loadings Calculated Using PCS Data
Refineries report direct discharges to PCS. For direct discharges, EPA used the
reported mass to calculate TWPEs. As discussed in Section 7.2.2, PCS includes only results of
permit-required monitoring for direct discharging facilities. Even though toxic pollutants may
be present in a refinery's discharge, they will not be reported unless required by permit.
Using PCS data, the reported releases of sulfide comprise over 50 percent of the
petroleum refinery industry's toxic releases. Refineries reporting to PCS discharge 193,000
TPWEs. PCS has little discharge data for PACs and dioxins, and sulfide is not reportable to
TRI. Table 7-7 presents the pounds (and TWPE) discharged by direct dischargers as reported to
PCS for the 10 most toxic discharged pollutants (by TWPE). These pollutants compose over 90
percent of the total industry TWPE.
Table 7-7. Discharges Reported to the 2000 PCS for the Petroleum Refining Industry -
Top 10 Pollutants Composing 91 Percent of the TWPE
Pollutant
Sulfide, Total1
Chlorine, Total Residual2
Fluoride, Total (as F)
Selenium, Total (as Se)
Aluminum, Total (as AL)
Phenolics, Total
Recoverable
Arsenic, Total (as As)
Nitrogen, Ammonia Total
(asN)
Cyanide, Total (as CN)
Total
Pounds
Discharged
35,969
52,069
462,807
7,856
120,235
261,985
1,277
1,917,492
1,956
Total
TWPE
Discharged
100,734
25,357
16,198
8,802
7,754
7,336
4,430
3,509
2,107
Percentage
of Total
TWPE
Discharged
52%
13%
8%
4%
4%
4%
2%
2%
1%
TWPE Range
per Reporting
Refinery
3-12341
14 - 12323
8 - 6069
1 -3291
64-7115
0.07 - 6954
4-2122
0.16-772
3-801
Median TWPE
per Reporting
Refinery
521
130
1092
303
241
2
257
14
89
Number of
Reporting
Refineries
70
13
11
13
5
68
7
86
10
7-27
-------
Section 7 - Petroleum Refining
Table 7-7 (Continued)
Pollutant
Mercury, Total (as Hg)
Total PCS Pollutants3
Total
Pounds
Discharged
16
331,931,974
Total
TWPE
Discharged
1,908
192,862
Percentage
of Total
TWPE
Discharged
1%
TWPE Range
per Reporting
Refinery
10-1685
Median TWPE
per Reporting
Refinery
32
Number of
Reporting
Refineries
7
104
Source: PCSLoads2000.
'Includes Sulfide Total (as Sulfur).
2Total residual chlorine is often reported as a maximum value. Pollutant loadings may be overestimated.
3Total includes all pollutants reported to PCS, including BOD5 and TSS, which do not have TWFs and do not
contribute to the TWPE.
7.5.4
Treatment In Place
Petroleum refineries treating process wastewater on site typically use the
following technologies:
• Steam stripping to remove hydrogen sulfide, other sulfur compounds, and
ammonia for sour water pretreatment;
• Oil and solids separation using API separator, corrugated plate interceptor,
or other type of separator followed by DAF or settling ponds to remove
emulsified oils;
• Biological treatment via activated sludge units, trickling filters, or rotating
biological contactors; and
• Polishing the effluent via activated carbon, anthracite coal, or sand filters.
Indirect dischargers typically separate the oil and solids and then discharge the
wastewater to a POTW.
Facilities reporting TRI releases also provide information on their wastewater
treatment operations. Table 7-8 lists the treatment processes used by petroleum refineries as
reported to the 2000 TRI.
7-28
-------
Section 7 - Petroleum Refining
Table 7-8. Wastewater Treatment Operations Reported By Petroleum Refineries,
TRI Reporting Year 2000
Wastewater Treatment Technology
Steam stripping - in-process treatment that removes ammonia and
mercaptans from sour waters.
API separator - operated for oil recovery. Considered process step.
Separator effluent is the influent to the end-of-pipe wastewater
treatment (count is for P 15 oil skimming).
Dissolved air flotation - removes oils and paniculate material prior to
biological treatment. DAF float is a listed hazardous waste.
Biological treatment - most refineries use aerobic biological treatment
(activated sludge or aerated basins) to reduce wastewater organic
carbon (BOD and COD) load. Biological treatment can also remove
phenolic compounds.
Sedimentation - always follows activated sludge basins. Separate
clarification might also follow aerated basins (count is for PI 1 settling/
clarification).
Polishing - sand, dual media, or multimedia filtration removes fine
paniculate (count is forP12 filtration).
Activated carbon adsorption - removes soluble organic material and
some metals.
Number of Refineries Reporting
Use
Direct1
(93 refineries)
30
86
66
1001
78
33
14
Indirect1
(18 refineries)
6
23
17
9
13
6
1
Source: TRIReleases2000.
'In TRIReleases2000, of the refineries that provided information on their wastewater treatment operations, 93
reported direct releases, 18 reported transfers to POTWs, and 9 reported both direct releases and transfers to
POTWs. Therefore, the total refineries reporting a treatment technology might exceed the total number of direct or
indirect dischargers.
7.6
Polvcvclic Aromatic Compounds
PACs, sometimes known as polycyclic aromatic hydrocarbons (PAHs), are a class
of organic compounds consisting of two or more fused aromatic rings. This section includes the
following subsections:
• Section 7.6.1 - Identification and description of PACs;
• Section 7.6.2 - Estimation of TWPE for petroleum refineries;
• Section 7.6.3 - PAC sources at petroleum refineries;
• Section 7.6.4 - Reported PAC discharges;
7-29
-------
Section 7 - Petroleum Refining
7.6.1
• Section 7.6.5 - Further analysis of PACs (including release estimation
methods for TRI reporting and PAC concentrations in refinery final
effluents);
• Section 7.6.6 - PAC control technologies; and
• Section 7.6.7 - Detailed study findings on PACs.
Identification and Description of PACs
Table 7-9 lists the 21 individual compounds in the PAC category for TRI
reporting, Chemical Abstract Service (CAS) number, and related data.
Table 7-9. Individual Polycyclic Aromatic Compounds
PAC Compound
Benzo(a)anthracene
Benzo(a)phenanthrene
(chrysene)
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j )fluoranthene
Benzo(k)fluoranthene
Benzo(j ,k)fluorene
(fluoranthene)
Benzo(r,s,t)pentapheue
Dibenz(a,h)acridiiie
Dibenz(a.j )acridine
Dibenzo(a,h)authracene
Dibenzo(a.e)fluoranthene
Dibenzo(a.e)pyrene
Dibeiizo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(e,g)carbazole
7, 1 2-Dimelhylbenz(a)anthracene
Indeno(l,2.3-cd)pyrene
CAS
Number
56-55-3
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
226-36-8
224-42-0
53-70-3
5385-75-1
192-65-4
189-64-0
191-30-0
194-59-2
57-97-6
193-39-5
Toxic
Weighting
Factor
180.9752
2.1038
4283.5600
421.3560
42.1356
0.8030
1693.0160
1.1388
Potential
Carcinogen?1
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Priority
Pollutant?
/
/
/
/
/
/
/
/
Properties2
Solubility: 0.0000014 g/100 mL
Partition Coefficient: 5.61
Solubility: 0.00000018 g/100 mL
Solubility: 0.00000038 g/100 mL
Partition Coefficient: 6.04
Solubility: 0.00000012 g/100 mL
Partition Coefficient: 6. 12
Solubility: 0.000000055 g/100 mL
Partition Coefficient: 6.84
Solubility: 0.0000265 g/100 mL
Solubility: 0.00000005 g/100 mL
Partition Coefficient: 6.5
Solubility: <0.1 g/100 mL at 18 C
Solubility: 0.0000062 g/100 mL
Partition Coefficient: 6.58
7-30
-------
Section 7 - Petroleum Refining
Table 7-9 (Continued)
PAC Compound
3-Methylcholanthreue
5-Methylchryseiie
1-Nitropyrene
CAS
Number
56-49-5
3697-24-3
5522-43-0
Toxic
Weighting
Factor
Potential
Carcinogen?1
/
Priority
Pollutant?
Properties2
Solubility: <0.01 g/100 mLat 18
Solubility: <0.1 g/100 mL at 18 C
'Source: U.S. Department of Health and Human Services. Report on Carcinogens. Tenth Edition. Public Health Service. National Toxicology
Program. December 2002.
2For comparison, benzene's solubility is 0.18 g/100 mL and partition coefficient is 2.13.
The partition coefficient is presented as log Kow.
Source for solubilities: http://www.chemfiuder.com.
7.6.2
Estimation of TWPE
For TRI, facilities must report the combined mass of PACs released, not releases
of individual compounds. To calculate the TWPE for PAC discharges, EPA developed a
refinery-specific PAC TWF based on the concentration of individual PACs in petroleum
products and amount of products. The calculated TWF equals 230.43. See the Memorandum:
Toxic Weighting Factor for Petroleum Refining Polycyclic Aromatic Compounds, 12/11/2003,
DCN 00646 for further details (33).
Some petroleum refineries are required to report the discharge of individual PACs
as a condition of their NPDES permits. These reported discharges are included in the PCS
database. In these cases, EPA used the TWFs for the individual PACs to calculate their TWPE.
Petroleum refineries are also sometimes required by permit to report discharges of "Polynuclear
Aromatic Hydrocarbons per Method 610." Method 610 is a wastewater analytical method for 16
compounds, eight of which are included on the TRI list of PACs. EPA does not have a TWF for
PAHs, and therefore did not include Method 610 discharges in the TWPE calculation.
7.6.3
Sources at Petroleum Refineries
PACs are likely present in petroleum products such as crude oil, fuel oil, diesel
fuel, gasoline, and paving asphalt (bituminous concrete) and refining by-products such as heavy
oils, crude tars, and other residues. PAHs form due to incomplete combustion of organic
compounds. PACs might be generated during the production of synthetic fuels and products
from coal, petroleum, and other feedstocks at refineries (23, 30). Refinery process sources of
PACs include cracking operations (thermal and catalytic) and crude petroleum storage when
refineries remove PAC-containing water from tanks (37). Table 7-10 lists individual PACs and
sources from petroleum refinery operations.
7-31
-------
Section 7 - Petroleum Refining
Table 7-10. Individual PACs and Petroleum Refinery Sources
PAC Compound
Beiizo(a)anthracene
Benzo(a)phenanthrene (chrysene)
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoraiithene
Benzo(k)fluoranthene
Benzo(j,k)fluorene (fluorantliene)
Beiizo(r,s,t)pentaphene
Dibeiiz(a,h)acridine
Dibeiiz(a,j)acridine
Dibenzo(a,h)anthracene
Dibeiizo(a,e)fluoranthene
Dibeiizo(a.e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(e,g)carbazole
7, 12-Dimethylbenz(a)antliracene
Indeno( 1 ,2,3 -cd)pyrene
3-Methylcholantlirene
5-Methylclirysene
1-Nitropyrene
CAS
Number
56-55-3
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
226-36-8
224-42-0
53-70-3
5385-75-1
192-65-4
189-64-0
191-30-0
194-59-2
57-97-6
193-39-5
56-49-5
3697-24-3
5522-43-0
Sources at Petroleum Refineries
Product of incomplete combustion; fossil fuels
Product of incomplete combustion; fossil fuels: coke plant
exhaust
Product of incomplete combustion; fossil fuels: coal tar,
municipal incinerator emissions
Product of incomplete combustion; fossil fuels
Product of incomplete combustion; fossil fuels: coal tar
Product of incomplete combustion; fossil fuels; coal tar:
lubricating oils, crude oils
Product of incomplete combustion; fossil fuels; coal tar
Product of incomplete combustion; fossil fuels; coal tar
Product of incomplete combustion (particularly coal
burning processes)
Product of incomplete combustion (particularly coal
burning processes); petroleum refinery incinerator
effluents
Product of incomplete combustion; fossil fuels; coal tar,
gasoline engine exhaust tar
Product of incomplete combustion
Product of incomplete combustion; fossil fuels
Product of incomplete combustion; fossil fuels; coal tar
Product of incomplete combustion; fossil fuels; coal
gasification
Coal burning processes; coal tar and coal distillates
Produced in small quantities as a research chemical, not
formed during combustion
Product of incomplete combustion; fossil fuels; coal tar:
petroleum asphalt
Produced in small quantities as a research chemical, not
formed during combustion
Product of incomplete combustion; crude oil
Diesel and gasoline engines; coal fired energy conversion
plants; aluminum smelter stack gases
Sources: U.S. Department of Health and Human Sendees, Report on Carcinogens, Tenth Edition, Public Health
Service, National Toxicology Program, December 2002. and D. Aronson and P.H. Howard, Sources of Individual
PAHs Listed in the PBT Chemical Pool, January 2000 (as listed in U.S. EPA, Emergency Planning and Community
Right-to-Know Act - Section 313: Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds
Category, EPA 260-B-01-03, August 2001.
7-32
-------
Section 7 - Petroleum Refining
7.6.4 Reported PAC Discharges
The estimated PACs loadings for the petroleum refining industry are based on
data as reported to TRI for 2000. Nineteen refineries2 reported wastewater releases of PACs to
TRI. Seven refineries reported discharges of individual PACs to PCS, but none of them reported
detecting concentrations above analytical detection limits. As stated in Section 7.2.1, 94 percent
of the refineries report to TRI; however, refineries report the releases of PACs only if they r
exceed the reporting threshold. Refineries report PAC discharges to PCS only if required by
their permits. This subsection discusses the following:
• Section 7.6.4.1 - TRI discharges reported by petroleum refineries;
• Section 7.6.4.2 - PCS discharges reported by petroleum refineries; and
• Section 7.6.4.3 - PAC data, including measurement data from activated
sludge units and POTW final effluents, provided in comments regarding
the Preliminary Plan.
7.6.4.1 TRI Discharges
As noted in Section 7.6.2, refineries report PAC discharges as a total category
amount, not by individual compound. Table 7-11 presents the data reported to TRI and the
calculated TWPE. Note that current guidance for reporting to TRI suggests using one-half the
detection limit to estimate releases based on "nondetects"; therefore, the total discharges may be
overestimated. This is confirmed by discussions with staff from EPA's Office of Environmental
Information (16) and comments from API and NPRA (1, 11).
7.6.4.2 PCS Discharges
For six California refineries, listed in Table 7-12, discharges of PAHs were
included in PCS (see discussion in Section 7.6.2). For two of these six refineries, reported PAH
concentrations were above the method detection limit. Because EPA does not have a TWF for
this parameter, it did not calculate TWPEs for these discharges.
In addition, American Western Refining, Lawrenceville IL (NPDES IL0004219),
is required to report polynuclear aromatics (polyram), but did not detect the pollutant in 2000.
2Two additional refineries, Calcasieu (Lake Charles, LA) and Frontier (El Dorado, KS) each reported releases to
surface water of 1.1 pounds of PACs in 2000. However, these refinery releases were not included in
TRIReleases2000.
7-33
-------
Section 7 - Petroleum Refining
Table 7-11. Petroleum Refineries Reporting Releases of PACs to the 2000 TRI1
TRI ID Number
77592TXSCTLOOP1
94572NCLSNOLDHI
70037LLNCRHIGHW
70669CNCLKOLDSP
96707CHVRN91480
99611TSRLSMILE2
39567CHVRNPOBOX
62454MRTHNMARAT
62084SHLLLRTE11
74603CNCPN1000S
84116CHVRN2351N
80022CNCDN5801B
70047TRNSM14902
90744TXCRF2101E
00851HSSLVLIMET
77017LYNDL12000
77506CRWNC111RE
48217MRTHN1300S
79905CHVRN6501T
Refinery
Valero Refining Co. Texas
Tosco San Francisco Refinery
Tosco Refining Co. Alliance Refinery
Conoco Lake Charles Refinery
Chevron Prods. Co. Hawaii Refinery
Tesoro Alaska Co. Kenai Refinery
Chevron Prods. Co. Pascagoula Refinery
Marathon Ashland Petroleum LLC
Tosco Wood River Refinery
Conoco Inc. Ponca City Refinery
Chevron USA Prods. Co
Conoco Denver Refinery
Orion Refining Corp.
Equilon Enterprises LLC Los Angeles Refining
Hovensa L.L.C.
Lyondell-Citgo Refining L.P.
Crown Central Petroleum Corp. Houston Refinery
Marathon Ashland Petroleum L.L.C.
Chevron USA El Paso Refinery
Refinery Location
Texas City, TX
Rodeo, CA
Belle Chasse, LA
Westlake, LA
Kapolei, HI
Kenai. AK
Pascagoula. MS
Robinson, IL
Roxana, IL
Ponca City, OK
Salt Lake City, UT
Commerce City, CO
New Sarpy. LA
Wilmington. CA
Christiansted, VI
Houston, TX
Pasadena. TX
Detroit, MI
El Paso. TX
Direct
Discharge
(lb/yr)
64
57
40
22
20
19
17
15
10
9
8
5
4
2
2
--
--
--
--
Direct
Discharge
(TWPE)
14,748
13,135
9,217
5.069
4,609
4,378
3,917
3,456
2,304
2,074
1.843
1,152
922
461
461
--
--
--
--
To POTW
(lb/yr)
--
--
--
--
--
--
--
--
--
--
--
--
--
16
--
2.380
97
81
55
After POTW
(lb/yr)2
--
--
--
--
--
--
--
--
--
--
--
--
--
1
--
175
7
6
4
After POTW
(TWPE)
--
--
--
--
--
--
--
--
--
--
--
--
--
270
--
40,360
1,644
1,374
932
Source: TRIReleases2000.
'Two additional refineries, Calcasieu, Lake Charles, LA and Frontier, El Dorado, Kansas each reported 1.1 Ib/year PAC released to surface water. However, EPA did not include these releases in
TRIReleases2000.
2Mass transferred to POTW that is ultimately discharged to surface waters. Accounts for POTW removals.
-------
Section 7 - Petroleum Refining
Table 7-12. California Refineries Reporting PAH Discharges
NPDES Permit
Number
CA0000051
CA0004961
CA0005053
CA0005134
CA0005789
CA0055387
Refinery Name
Conoco
Tesoro Refining & Marketing Co.
Tosco Refining Company
Chevron Products Company
Shell Oil Products US
Mobil Oil Corp.
Location
Arroyo Grande, CA
Martinez, CA
Rodeo, CA
Richmond, CA
Martinez, CA
Torrance, CA
Table 7-13
Refinery
Number
61
r-
73
PAHs, Ib/yr
0
0.13
0
1.5
0
0
Source: PCSLoads2000.
'Refinery also monitors for the individual PAC, benzo(j,k)fluorene (fluoranthene). See Table 7-13.
2Refinery also monitors for eight individual PACs (see Table 7-13), none of which were detected in 2000.
Table 7-13 lists the PACs that each of the seven refineries shown in the table
must monitor as required by their NPDES permits. However, none of the refineries reported
discharge concentrations above method detection limits in 2000.
Table 7-13. Individual PACs Reported in 2000 PCS
Pollutant
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Benzo(b)fluoranthene
Benzo(a)antliracene
Benzo(k)fluoranthene
Benzo(a)phenantlirene (clirysene)
Indeno( 1 ,2,3 -cd)py rene
Benzo(j,k) fluorene (fluoranthene)
Refinery Number (see bottom of table)
1
/
/
/
/
/
/
/
/
2
/
/
/
/
/
/
/
/
3
/
/
/
/
/
4
/
/
/
/
/
/
5
/
/
/
/
/
/
6
/
7
/
1 . Chevron (Richmond. C A) NPDES Permit C A0005 1 3 4
2. Valero Refining (Benecia. CA) NPDES Permit CA0005550
3 . Bay way Refinery (Linden, NJ) NPDES Permit NJOOO 1511
4. Conoco Phillips (Borger, TX) NPDES Permit TX0009148
5. Murphy Oil (Superior, WI) NPDES Permit WI0003085
6. Conoco Phillips (Aroyo Grande, CA) NPDES Permit CA000005 1
7. Mobil Oil (Torrance, CA) NPDES Permit CA0055387
7-35
-------
Section 7 - Petroleum Refining
7.6.4.3
Data Provided in Comments Regarding Preliminary Plan
As discussed in Section 7.2.1.4, API provided effluent data for activated sludge
units at 10 refineries. These data, collected from 1993 to 1994, show that individual PACs were
never measured above detection limits. Table 7-14 includes the PAC measurement data from
API's comment (1).
Table 7-14. PAC Measurement Data from Activated Sludge Units at 10 Refineries
PAC Compound
Benzo(a)anthracene
Benzo(a)phenanthrene (chrysene)
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(j,k)fluorene (fluoranthene)
Dibenz(a,h)acridine
Dibenzo(a.h)anthracene
Dibenzo(a.e)pyrene
7. 12-Dimethylbenz(a)anthraeene
Indeno( 1 ,2.3 -cd)pyrene
3 -Methylcholanthrene
Number of
Samples
26
26
26
26
26
26
1
26
1
2
25
24
Minimum
<0.1
<0.2
<0.2
<0.2
0.2
O.6
O.I
O.3
<25
<10
0.2
<10
Median
<10
<10
<10
<10
<10
<10
O.I
<10
<25
<10
<10
<10
Maximum
<11
<11
<11
<11
<11
<11
O.I
<11
<25
<10
<11
<11
Number of
Samples >
Detection
Limit
0
0
0
0
0
0
0
0
0
0
0
0
Source: American Petroleum Institute,
March 18, 2004.
Comments Re. Notice of Preliminary Effluent Guidelines Program Plan,
The County Sanitation Districts of Los Angeles County (the Districts) provided
sampling results (1984-1993) from 13 refineries forEPA's 1996 Preliminary Data Summary.
EPA published the results of the sampling in Table 6-2 of the 1'996 Preliminary Data Summary.
Benzo(a)phenanthrene (chrysene) was detected once, slightly above the method detection level,
at a concentration of 10.5 ug/L (24).
The Districts' comments (3) also state that currently no PACs are found in the
final effluent or biosolids from the Joint Water Pollution Control Plant (JWPCP). The JWPCP
currently receives wastewater from 10 refineries. The Districts' NPDES permit requires
monitoring for the following 13 individual PAHs (five included in the PAC category):
7-36
-------
Section 7 - Petroleum Refining
Acenaphthylene;
Anthracene;
1,2-benzanthracene;
3,4-benzofluoranthene;
Benzo(k)fluoranthene (PAC
chemical);
1,12-benzoperylene;
Pyrene;
Benzo(a)pyrene (PAC chemical);
Benzo(a)phenanthrene (chrysene)
(PAC chemical);
Dibenzo(a,h)anthracene (PAC
chemical);
Flourene;
Indeno(l,2,3-cd)pyrene (PAC
chemical); and
Phenanthrene
The Districts also reviewed the data reported to TRI in 2000 for the 10 refineries
discharging to the JWPCP and found that none reported releases of PACs. The Districts noted
that the refinery discharges have little particulate matter. Since PACs tend to accumulate in the
solids, the low discharges of particulate matter may explain the absence of PACs in releases to
the POTW. The Districts have not performed any screening analysis for trace quantities of
PAHs.
7.6.5
Further Analysis of PACs
EPA performed further analysis of PAC discharges to determine if effluent
limitations and guidelines would be appropriate for this pollutant. As discussed in Section
7.2.1.4, EPA received comments from NPRA and API concerning the TRI estimates of PACs
discharges. The comments explained that 2000 was the first year industry was required to report
releases of PACs to TRI. The comments further noted that even if refineries do not detect PACs
in the effluent, they may estimate the mass released based on one-half the detection limit, and
thus over-report PAC discharges to TRI. Table 7-15 summarizes the refinery-specific comments
concerning PAC discharge estimates reported to the 2000 TRI. Table 7-15 also presents the
basis for the facility estimate of PAC releases reported to TRI. EPA confirmed that PACs were
measured above method detection limits in Lyondell Citgo's discharge to the Washburn Tunnel
Facility (part of the Gulf Coast Waste Disposal Authority); however, PACs are not detected in
the Washburn Tunnel Facility's discharge to surface water (10, 14). EPA could not confirm that
PACs were measured in the discharges of any other refinery reporting PACs releases to TRI in
2000.
EPA estimated the concentration of PACs in refinery effluents using the
discharges reported to TRI and process wastewater flow rate reported to PCS3, and compared
these estimated concentrations to Method 1625 analytical detection limits for individual PACs.
If a refinery reporting to TRI did not report a flow rate to PCS, or if the reported flow rate
3EPA calculated the wastewater flow rates from outfalls discharging BOD5 and/or ammonia to estimate refinery
process wastewater flows, because PCS does not consistently identify which discharges are process wastewater.
Effluent limitations guidelines apply to BOD5 and ammonia in refinery process wastewater discharges, but not
cooling water and stormwater.
7-37
-------
Section 7 - Petroleum Refining
Table 7-15. NPRA and API Comments on PAC Discharge Estimates Reported to the 2000 TRI
TRI ID
77592TXSCTLOOP1
94572NCLSNOLDHI
70037LLNCRHIGHW
70669CNCLKOLDSP
96707CHVRN91480
99611TSRLSMILE2
39567CHVRNPOBOX
62454MRTHNMARAT
62084SHLLLRTE11
74603CNCPN1000S
84116CHVRN2351N
16344PNNZL2MAIN
80022CNCDN5801B
70047TRNSM14902
90744TXCRF2101E
00851HSSLVLIMET
77017LYNDL12000
77506CRWNC111RE
Refinery
Valero Refilling Co. Texas
Tosco San Francisco Refinery
Tosco Refining Co. .Alliance
Refinery
Conoco Lake Charles Refinery-
Chevron Prods. Co. Hawaii
Refinery
Tesoro Alaska Co. Kenai Refinery
Chevron Prods. Co. Pascagoula
Refinery
Marathon Ashland Petroleum LLC
Tosco Wood River Refinery
Conoco Inc. Ponca City Refinery
Chevron USA Prods. Co
Calumet Lubricants Co. Rouseville
Plant
Conoco Denver Refinery
Orion Refining Corp.
Equilon Enterprises LLC Los
Angeles Refining
Hovensa L.L.C.
Lyondell-Citgo Refining L.P.
Crown Central Petroleum Corp.
Houston Refinery
Refinery Location
Texas City, TX
Rodeo, CA
Belle Cliasse, LA
Westlake, LA
Kapolei. HI
Keuai, AK
Pascagoula, MS
Robinson, IL
Roxaua, IL
Ponca City, OK
Salt Lake City, UT
Rouseville, PA
Commerce City,
CO
New Saipy. LA
Wilmington, CA
Christiansled. VI
Houston. TX
Pasadena, TX
TRI1 PAC
Discharge
(Ib/yr)
64
57
40
22
20
19
17
15
10
9
8
5
5
4
3
2
2.380
97
Measured
PACs?
No
No
No
No
Unknown
No
No
No
No
No
No
No
No
No
No
No
Yes
Unknown
Basis of
Estimate for
TRI Releases
20002
M
M
0
O
M
O
O
0
O
O
0
O
0
c
O
0
NA
NA
NPRA and API Comments on PAC Discharge
Estimate
Estimate based on ' 2 the detection limit. One sample
contained PACs.
Estimate based on V2 the detection limit.
Estimate based on '4 the detection limit.
No comments.
No comments.
No change to estimate.
No comments.
No comments.
Estimate based on ' 4 the detection limit.
Refinery estimated discharge using API data for PACs in
petroleum products.
No comments.
Closed January 1, 2002. Not a refinery (SIC code 2999
Petroleum Products NEC).
Estimate based on internally generated factors.
Estimate based on W the detection limit.
No comments.
Discharge from accidental spill; monitoring data indicate
zero discharge of PACs.
Indirect discharger - PACs were not detected in the
POTW effluent.
Indirect discharger - PACs were not detected in the
POTW effluent.
^1
oo
-------
Section 7 - Petroleum Refining
Table 7-15 (Continued)
TRIID
48217MRTHN1300S
79905CITVRN6501T
70606CLCSRWESTE
67042TXCRF1401S
Refinery
Marathon Ashland Petroleum
L.L.C.
Chevron USA El Paso Refinery
Calcasieu
Frontier
Refinery Location
Detroit, MI
El Paso, TX
Lake Charles, LA
El Dorado, KS
TRI1 PAC
Discharge
(lb/yr)
6
56
1.1
1.1
Measured
PACs?
Unknown
No
Unknown
Unknown
Basis of
Estimate for
TRI Releases
20002
NA
NA
M
O
NPRA and API Comments on PAC Discharge
Estimate
No comments.
Estimate based on '4 the detection limit.
Not in TRIReleases2000: 1. 1 lb/yr discharge PACs
reported to TRI.
Not in TRIReleases2000: 1.1 lb/yr discharge PACs based
on discharges at similar refinery reported to TRI.
'Mass transferred to POTW that is ultimately discharged to surface waters. Accounts for POTW removals.
2Refineries reported basis of estimate in 2000 TRI as: M - Monitoring data/measurements; C - Mass balance calculations: E - Published emission factors; and O - Other approaches (e.g.. engineering
calculations). NA means the refinery did not report the basis of its estimate.
-------
Section 7 - Petroleum Refining
seemed unreasonably high, EPA did not calculate PAC concentrations for that refinery. To
compare concentrations to detection limits, EPA had to estimate concentrations for individual
compounds, even though refineries report the total mass of PACs released to TRI. To do this,
EPA assumed the distribution of individual PACs reported released was proportional to the
concentration of individual PACs in petroleum products and the amount of the various products
processed by the refining industry. EPA used this same distribution to calculate the PAC TWF
for the petroleum refining industry (see Section 7.6.2). Table 7-16 lists the calculated
concentrations of individual PACs in the refinery wastewater. The table also lists each
compound's detection limit for Method 1625 as a comparison. As shown in the table, the
individual PAC concentrations in the effluent are much lower than individual PAC detection
limits, suggesting that individual PACs are not present in treated refinery wastewater above
method detection limits.
For some pollutants, one refining process may be the primary source of the
pollutant loadings to the treatment system. The in-process wastewater stream from this one
process may contain high concentrations of the pollutant before dilution occurs with other
refinery wastewater. In these cases, dedicated pretreatment might be effective in removing the
pollutant. Based on the data for the detailed review, EPA did not identify an in-process waste
stream with high concentrations of PACs or an in-process PAC source that could be controlled.
Because of the low water solubility and high octanol water partition coefficient of
PACs, they are likely to partition from water to oily and solids phases. Subsequently, PACs are
removed with oils and solids from the refinery wastewater through existing on-site treatment (oil
in oil/water separators, solids in biological treatment, and sludge in clarifiers and polishing
units).
7.6.6 PAC Control Technologies
Based on the information collected to date, EPA concludes that the PAC
concentration in refinery wastewater is typically below treatable levels; however, refineries can
use pollution prevention opportunities to reduce the possible contamination of refinery
wastewaters by PACs. The main pollution prevention steps that refineries can take are to
identify and correct any leaks quickly and to have controls in place to prevent petroleum spills
from reaching any sewers or other waters.
If a refinery identifies any oily wastewater streams with high levels of PACs, it
can treat the wastewater in an oil/water separator. PACs generally partition into the oil phase.
The oil may then be reused at the refinery or managed as waste. Refineries can also use granular
activated to remove water-phase PACs from pretreated wastewater.
7-40
-------
Section 7 - Petroleum Refining
Table 7-16. Estimated Concentration of PACs in Petroleum Refining Effluent
Refinery Information
State
TRI
Reported
Pounds
Discharged"
Flowb
(Mgal/yr)
Detection Limits' (ug/L)
AK
CA
CO
HI
IL
IL
LA
MS
OK
TX
LIT
19
57
5
20
10
15
22
17
9
64
8
138
850
727
1,171
2,439
1,615
1.343
2.238
991
766
290
Estimated Individual PAC Concentration in Effluent (ug/L)
Fluoran-
thene
10
4.00
1.95
0.20
0.50
0.12
0.27
0.48
0.22
0.27
2.44
0.80
Benz(a)
anthracene
10
2.88
1.40
0.14
0.36
0.09
0.19
0.34
0.16
0.19
1.75
0.58
Chrysenc
10
7.62
3.72
0.38
0.95
0.23
0.52
0.91
0.42
0.50
4.64
1.53
Benzo(h)
flnoranthene
10
0.45
0.22
0.02
0.06
0.01
0.03
0.05
0.02
0.03
0.27
0.09
Benzo(j)
fluoranthene
10
0.06
0.03
<0.00
0.01
<0.00
<0.00
0.01
<0.00
<0.00
0.04
0.01
Benzo(k)
fluoranthene
10
0.12
0.06
0.01
0.01
<0.00
0.01
0.01
0.01
0.01
0.07
0.02
Benzo(a)
pyrene
10
0.69
0.34
0.03
0.09
0.02
0.05
0.08
0.04
0.05
0.42
0.14
Indeno(l,2,3-
cd)pyrene
20
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
<0.00
Dibenz(aji)
anthracene
20
0.07
0.03
--0.00
0.01
<0.00
<0.00
0.01
<0.00
<0.00
0.04
0.01
Source: ERG. Memorandum: Estimated Concentrations for the Petroleum Refining Industry.
'Total pounds reported by each refinery is distributed to individual compounds using PAC compositions obtained in the Memorandum: Toxic Weighting Factor for Petroleum Refining Polycyclic
Aromatic Compounds, 12/11/2003. DCN 00646.
2Flow is obtained from PCS and is only for outfalls with nonzero discharges of ammonia or BOD5.
'Source: EPA Method 1625, Semivolatile Organic Compounds by Isotope Dilution GC/MS.
-------
Section 7 - Petroleum Refining
7.6.7 Detailed Study Findings on PACs
Below is a summary of the findings of EPA's detailed study of refinery PACs.
• PACs are a group of 21 individual compounds, some of which are present
in petroleum products. U.S. industrial facilities were first required to
report PAC releases to TRI for reporting year 2000. Using TRI data as
reported (and accounting for POTW removals), EPA estimated that
petroleum refineries released 487 pounds of PACs to surface water in
2000.
• EPA calculated the TWPE of PACs released from petroleum refineries
using an industry-specific TWF, based on the concentration of individual
PACs in petroleum products and the amount of products processed by the
refining industry. Using TRI data, EPA estimated that refineries
discharged 112,329 TWPE of PACs in 2000.
• For TRI reporting year 2000, 19 refineries reported PAC releases to
wastewater. EPA determined that most of the reported releases were not
based on measured concentrations in refinery effluents. Even where
effluent concentrations were measured and individual PACs were not
detected, refineries estimated releases using one-half the analytical
detection limit and refinery effluent flow rate.
• EPA confirmed that PACs were measured above method detection limits
in the discharge of Lyondell Citgo to the Washburn Tunnel Facility (part
of the Gulf Coast Waste Disposal Authority); however, PACs are not
detected in the Washburn Tunnel Facility's discharge to surface water.
EPA could not confirm that PACs were measured in the discharges of any
other refinery reporting PACs releases to TRI in 2000.
• Ten refineries have NPDES permit limits for PAHs (16 compounds
measured by Method 610) or individual PACs. Eight individual PAH
compounds are also included in the PAC compounds category reportable
to TRI. In 2000, none of the refineries reporting to PCS measured
individual PACs above detection limits. Two of six refineries required to
monitor for PAHs (Chevron Products Company in Richmond, CA and
Tesoro Refining & Marketing Company in Martinez, CA) reported PAH
concentrations above detection limits. The Chevron Products Company
(Richmond, CA) also monitors for eight individual PACs, none of which
were detected in 2000.
• In comments submitted on the 2003 annual review, API provided effluent
data collected at 10 refineries in 1993-1994. These data show individual
PACs were never measured above analytical detection limits.
7-42
-------
Section 7 - Petroleum Refining
• EPA estimated concentrations of PACs using discharges as reported to
TRI and process wastewater flow rate from PCS and compared these
estimated concentrations to Method 1625 analytical detection limits for
individual PACs. In all cases, estimated compound concentrations were
much lower than Method 1625 detection limits.
• EPA did not identify an in-process wastestream with high concentrations
of PACs, and so it similarly did not identify appropriate in-process
treatment technology.
Based on these findings, EPA concludes that other than potential leaks and spills
of crude oil and petroleum products, there is no obvious source of PAC releases to refinery
wastewaters. EPA also concludes that there is little evidence that PACs are present in
concentrations above the detection level in refinery wastewater discharges.
7.7 Dioxins
The term 'dioxins' refers to poly chlorinated dibenzo-p-dioxins (CDDs) and
polychlorinated dibenzofurans (CDFs). These groups of chemicals are termed 'dioxin-like,'
because they have similar chemical structure, similar physical-chemical properties, and invoke a
common battery of toxic responses. CDDs and CDFs must have chlorine substitution of
hydrogen atoms at the 2, 3, 7, and 8 positions on the benzene rings (29). This section includes
the following subsections:
• Section 7.7.1 - Identification and description of dioxins;
• Section 7.7.2 - Estimation of TWPE for petroleum refineries;
• Section 7.7.3 - Dioxin sources at petroleum refineries;
• Section 7.7.4 - Reported dioxin discharges;
• Section 7.7.5 - Compilation and discussion of measured effluent dioxin
concentrations;
• Section 7.7.6 - Dioxin control technologies; and
• Section 7.7.7 - Detailed study findings for dioxins.
7.7.1 Identification and Description of Dioxins
Table 7-17 lists the 17 individual compounds (congeners) included in the TRI
dioxin and dioxin-like category, and their CAS numbers. See Section 4.2.4.2 for more
discussion of dioxins.
7-43
-------
Section 7 - Petroleum Refining
Table 7-17. Individual Dioxin Congeners
CAS Number
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Chemical Name
CDDs
2,3,7,8-tetrachlorodibenzo-p-dioxin
1,2,3,7,8-pentachlorodibenzo-p-dioxiri
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
1.2,3.6,7,8-liexachlorodibenzo-p-dioxin
1.2,3,7,8,9-liexachlorodibenzo-p-dioxin
1.2, 3,4,6, 7,8-heptachlorodibenzo-p-dioxin
1,2, 3,4,6, 7,8, 9-octachlorodibenzo-p-dioxin
CDFs
2,3 ,7.8-tetrachlorodibenzofiiran
1 ,2,3 ,7,8-pentaclilorodibenzofiiran
2,3,4.7,8-pentachlorodibenzofiiran
12347 8-liexachlorodibenzofuran
1.2,3.6,7,8-hexachlorodibenzofuran
1.2,3.7,8,9-hexachlorodibenzofuran
2.3,4.6,7,8-hexaclilorodibenzofuran
1.2,3.4,6,7.8-lieptachlorodibenzofuran
1,2,3,4,7,8.9-heptachlorodibenzofuran
1,2,3,4,6,7.8.9-octachlorodibenzofuran
Abbreviated Name
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2.3,6.7.8-HxCDD
1,2.3,7.8,9-HxCDD
1,2.3,4.6.7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2.3,7,8-TCDF
1.2,3,7.8-PeCDF
2.3,4,7.8-PeCDF
12347 8-HxCDF
1,2.3,6.7.8-HxCDF
1,2.3,7.8.9-HxCDF
2,3.4,6.7.8-HxCDF
1,2.3,4.6.7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
Because of their extremely low water solubility and hydrophobicity, dioxins most
often associate with particulate matter in wastewater matrices (24).
7.7.2
Estimation of TWPE
Facilities report to TRI the combined mass of dioxin-like compounds released to
the environment. As discussed in 4.2.4.2, facilities also report the distribution of each individual
chemical (congener) in the dioxin category. Facilities report only a single distribution to TRI,
even though dioxins might be released to more than one medium, and may be distributed
differently in different media. Lacking other information, EPA assumed the distribution reported
applies to the wastewater discharges.
EPA has TWFs for each of the 17 dioxin congeners. Seventeen petroleum
refineries reported water discharges of dioxins, but only five reported the distribution of the 17
congeners. For each refinery reporting congener distribution, EPA used the reported distribution
to estimate the mass of each congener in the refinery's wastewater releases. EPA calculated
7-44
-------
Section 7 - Petroleum Refining
dioxin TWPEs by multiplying the estimated mass of each congener by its TWF4. If no congener
distribution was reported, EPA used the refinery industry average distribution to calculate the
mass of each congener.
7.7.3 Dioxin Sources at Petroleum Refineries
Dioxin and dioxin-like compounds are not manufactured, but are generated as by-
products of certain chemical and combustion processes. As discussed in Section 7.3.3.3, EPA
identified catalyst regeneration operations for the catalytic reforming process as the source of
dioxins generated at petroleum refineries (24, page G-l). Smaller quantities of dioxins might be
generated in isomerization units (37). See Section 7.3.3.3 for a detailed description of reforming
catalyst wastewater generation.
7.7.4 Reported Dioxin Discharges
Seventeen refineries reported wastewater releases of dioxins to TRI in 2000, but
PCS includes results of NPDES-permit-required monitoring for only three refineries (all three
monitor for 2,3,7,8-TCDD, the most toxic form, or TCDD equivalents (TEQ)). EPA obtained
additional information on refinery dioxin discharges from EPA's 1996 Preliminary Data
Summary, Washington State Department of Ecology sampling data, BP Amoco, Toledo
Refinery, and Tosco Refining Company Avon Refinery's Dioxin Source Investigation. Each of
these sources is described below.
7.7.4.1 TRI Discharges
As noted in Section 7.7.2, refineries report the dioxin discharges as a total
category amount with the option to also report a congener distribution. Sixteen petroleum
refineries reported releases of dioxins to surface water in 2000. One refinery reported dioxin
transfers to a POTW. Note that current guidance for reporting to TRI suggests using one-half
the detection limit to estimate releases based on "nondetects"; therefore, the total discharges
might be overestimated. Table 7-18 presents the data reported to TRI and the calculated TWPE.
4EPA revised the TWFs for dioxins in 2004. The memorandum entitled Revisions to TWFsfor Dioxin and its
Congeners and Recalculated TWPEs for OCPSF and Petroleum Refining (available in the docket) presents the
estimated TWPE for petroleum refineries using the revised TWFs.
7-45
-------
Section 7 - Petroleum Refining
Table 7-18. Petroleum Refineries Reporting Releases of Dioxins to 2000 TRI
TRI ID
98221SHLLLWESTM
77590MRTHNFOOTO
70669CNCLKOLDSP
94802CHVRN841ST
90245CHVRN324WE
43616SHLCM4001C
07036XXN 1400P
74603CNCPN1000S
59101CNCBL401SO
08066MBLLCBILLI
00851HSSLVLIMET
80022CNCDN5801B
39567CHVRNPOBOX
62454MRTHNMARAT
00654PHLPSPHILI
70602CTGPTHIGHW
79905CHVRN6501T
Refinery Name
Tesoro Northwest Co.
Marathon Ashland Petroleum LLC
Conoco Lake Charles Refinery
Chevron Products Co. Richmond
Refinery
Chevron USA Prods. Co.
BP Oil Co. Toledo Refinery
Bayway Refining Co.
Conoco Inc. Ponca City Refinery
Conoco Inc. Billings Refinery
Valero Refining Co. NJ
Hovensa LLC
Conoco Denver Refinery
Chevron Prods. Co. Pascagoula
Refinery
Marathon Ashland Petroleum LLC
Chevron Phillips Chemical Puerto
Rico
Cilgo Petroleum Corp
Chevron USA El Paso Refinery
Refinery
Location
Anacortes. WA
Texas City, TX
Westlake, LA
Richmond, CA
El Segundo, CA
Oregon, OH
Linden. NJ
Ponca City, OK
Billings. MT
Paulsboro, NJ
Christiansted, VI
Denver, CO
Pascagoula, MS
Robinson, IL
Guayama. PR
Lake Charles, LA
El Paso. TX
Direct
Discharge
(grams/yr)
2
5.2
0.5392
0.339997
0.329997
0.285997
0.253997
0.180878
0.161558
0.089999
0.069341
0.059999
0.035
0.03
0.00218
0.0016
-
Direct
Discharge
(TWPE)
19,264
52,202
14,074
6,785
5,477
14,188
10,322
4.721
4.217
2,349
1,810
1,566
914
783
57
42
-
To POTW
(grams/yr)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.11
After
POTW1
(grams/yr)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0.0186998
After
POTW1
(TWPE)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
488
Did Refinery
Report Dioxin
Congener
Distribution?
/
-
-
/
/
/
/
-
-
-
-
-
-
-
-
-
-
^1
ON
Source: TRIReleases2000.
'Mass transferred to POTW that is ultimately discharged to surface waters. Accounts for POTW removals.
-------
Section 7 - Petroleum Refining
7.7.4.2
PCS Discharges
Three petroleum refineries, listed in Table 7-19, have NPDES permits in 2000
that required them to monitor their effluent for 2,3,7,8-TCDD or TCDD equivalents. One
refinery (Tesoro Refining, Martinez, CA) detected dioxins in its effluent in 2000. The Tesoro
refinery reports dioxin concentrations as TCDD equivalents. See Section 7.7.4.4 for further
discussion of dioxin concentrations measured in petroleum refinery final effluents.
Table 7-19. Petroleum Refineries Reporting 2,3,7,8-TCDD to the 2000 PCS
NPDES ID
AL0055859
CA0004961
WI0003085
Refinery Name
Shell Oil Mobile
Tesoro Refining
Murphy Oil USA Inc
Refinery Location
Saraland, AL
Martinez, CA
Superior, WI
Direct Discharge
(milligram s/yr)
0
0.6641
0
Direct Discharge
(TWPE/yr)
0
617.24
0
Source: PCSLoads2000.
'Refinery reports TCDD equivalents.
7.7.4.3 In-Plant Monitoring
Washington State Department of Ecology' Sampling
In NPDES permits it recently issued, Washington State Department of Ecology
required four petroleum refineries to collect samples of catalytic reformer regeneration
wastewaters, final effluent, and API separator sludge, and to analyze these samples for dioxins
using EPA Method 1613b for wastewater and Method 8290 for sludge. Table 7-20 provides
information on each of the refineries and samples.
EPA Sampling in Support of 1996 Preliminary Data Summary (PDS)
In the early 1990s, EPA conducted three sampling episodes at California
petroleum refineries. Tables 6.8 through 6.9 of the 1996 Preliminary; Data Summary (24)
present chlorinated dioxin and furan analytical data obtained from this sampling program. The
Agency collected samples of regeneration wastewater from Chevron (Richmond, CA); Tosco
(Martinez, CA); and Unocal (Rodeo, CA). EPA conducted the study, in part, so that it could
develop dioxin analytical methods for analyzing refinery wastewaters. The Chevron samples
were analyzed for dioxins by Method 8290 and the samples from the other two refineries were
analyzed by Method 1613.
7-47
-------
Section 7 - Petroleum Refining
Table 7-20. Dioxin Sampling Data from Washington State Refineries (2000-2003)
Refinery
Tesoro Northwest Co.
U.S. Oil & Refining Co.
ARCO Cherry Point
Refinery (was BP)
Shell Oil Products USA
Location
Anacortes. WA
Tacoma, WA
Blame, WA
Anacortes. WA
Type of
Regeneration
Cyclic
Semi-regenerative
Semi-regenerative
Semi-regenerative
Regeneration
Capacity
(barrels/day)
24,300
5,750
60,480
32,200
Regeneration Episode/Sample Name
Regeneration wastewater: Round 1
Regeneration wastewater: Round 2
Final effluent: Round 1
Final effluent: Round 2
API sludge: Round 1
API sludge: Round 2
Regeneration wastewater: CRU1-1
Regeneration wastewater: CRU1-2
Regeneration wastewater: CRU2- 1
Regeneration wastewater: CRU2-2
Final effluent: CRU1
Final effluent: CRU2
API separator sludge: CRU1
API separator sludge: CRU12
Reformer #1 (May 2000)
Reformer #1 (April 2001)
Reformer #2 (Sept 2000)
Reformer #2 (March 2001)
Final effluent (May 2000)
Final effluent (Oct 2000)
Final effluent (Mar 2001)
Final effluent (April 2001)
API separator sludge (May 2000)
API separator sludge (Oct 2000)
API separator sludge (April 4, 2001)
API separator sludge (April 11, 2001)
Caustic Water Wash: CRU2 (Jan 2003)
Caustic Water Wash: CRU1 (Mar 2003)
Caustic Water Wash: CRU2 (Jan 2004)
Caustic Water Wash: CRU1 (Mar 2004)
Final Effluent: CRU2 (Jan 2003)
Final Effluent: CRU1 (Jan 2003)
Final Effluent: CRU2 (Jan 2004)
API Sludge (Jan 2003)
API Sludge (Mar 2003)
Discharge
(gallons/min)
22
22
-
-
-
-
120
128
290
303
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Discharge
(gallons)
293.000
364.000
3,073,000
2,088,000
11 6,000 dry Ibs
unavailable
2.217
2.574
2,955
2,951
304.416
419.184
37,000 dry Ibs
40,000 dry Ibs
226.800
215.000
470,250
618,100
22,860
26,670
22.860
26.670
Tune for
Regeneration
(hours)
222
276
-
-
-
-
45 (CRU1-1 plus
CRU1-2)
48(CRU2-lplus
CRU2-2)
31.5
28
27
34
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
^1
oo
Source: Washington State Department of Ecology. Letter of Transmittal. December 11. 2003 (DCN 00711): Tesoro Northwest study. May 2001. Cherry Point Refinery study. July 2001. and U.S. Oil &
Refining study. August 15. 2003; and Shell Oil Products U.S. Puget Sound Refinery, Dioxin Study Report (NPDES Permit WA-000294-1), June 2004.
-------
Section 7 - Petroleum Refining
Table 7-21 summarizes in-plant sampling data obtained from Washington
Department of Ecology and EPA's 1990-91 sampling program reported in the 1996 Preliminary
Data Summary. The table also includes the dioxin concentrations in API separator sludge and
treated final effluent obtained from the Washington refineries. EPA converted all detected
congeners to TCDD equivalents and assumed results reported as less than the analytical
detection limit to equal zero.
Table 7-21. TCDD Equivalents in Petroleum Refinery Wastes
TCDD Equivalents (assuming nondetects = 0)
Median
Range
Catalyst Reformer Regeneration Wastewater
Concentration
Loadings
Pg/L
mg/cycle
2,975
5.64
0 to 394,000
Oto84
API Separator Sludge
Concentration (mass based)
ng/kg sludge
13.61
3 to 356
Treated Final Effluent
Concentration
Pg/L
0
0 to 15.5
Sources: Washington State Department of Ecology. Letter of Transmittal. December 11, 2003 (DCN 00711); U.S.
EPA, 1996 Preliminary Data Summary. Shell Oil Products U.S. Puget Sound Refinery, Dioxin Study Report
(NPDES Permit WA-000294-1), June 2004; and ERG, Toxic Equivalents for Dioxins Reported in 2000 to TRI
(Calculation Sheet).
High concentrations of dioxins, including 2,3,7,8-TCDD and 2,3,7,8-TCDF, were
detected in catalytic reformer regeneration wastewaters. EPA calculated the mass of TCDD
equivalents discharged per regeneration cycle, using reported wastewater flows. The median
loading was 5.64 milligrams per regeneration cycle.
In contrast to the catalytic reformer regeneration wastewater results, none of the
Washington refineries detected either 2,3,7,8-TCDD or 2,3,7,8-TCDF in their treated final
effluent. Two of the four Washington refineries detected no dioxins in their treated final effluent
(see Table 7-23). The Tesoro Northwest sampling results included split samples taken in March
2000 and analyzed by two laboratories; five congeners were detected in the treated final effluent
(by one or both laboratories). In the August 30, 2000 sampling episode for Tesoro Northwest,
nine congeners were detected in the treated final effluent (by one or both laboratories). The
congener, 1,2,3,4,6,7,8-HpCDF, was detected in both sampling episodes by both laboratories.
Shell Oil Products Puget Sound Refinery detected one congener (OCDD) in its final effluent for
the January 2003 sampling episode.
Catalytic reformer regeneration wastewaters are routed to the refinery wastewater
treatment system through the API oil/water separator. Because of the low water solubility and
extreme hydrophobicity of dioxins, at least some of the dioxins from catalytic reformer
regeneration wastewaters partition to the oil and solids phases in the API separator and
7-49
-------
Section 7 - Petroleum Refining
accumulate in the sludges. As expected, all of the Washington state refineries detected dioxins
in their API separator sludge.
7.7.4.4 Industry Comments About Dioxins
As discussed in Section 7.2.1.4, EPA received comments from NPRA and API
concerning the TRI estimates of dioxin discharges. The comments explained that 2000 was the
first year industry was required to report releases of dioxins to TRI. NPRA and API noted that
refineries may over-report dioxin discharges to TRI by using one-half the detection limit to
estimate releases of dioxins when not detected in the effluent. Table 7-22 summarizes the
refinery-specific comments concerning dioxin discharge estimates reported to the 2000 TRI.
NPRA and API provided comments on 12 of the 15 refineries5 that reported discharging dioxins
to TRI. Of those 12 refineries, four based their reported discharges on measurements of effluent
dioxin concentration. Tesoro Northwest (Anacortes, WA) detected dioxins in multiple effluent
samples, as discussed in Section 7.7.4.3. BP Oil Company Toledo Refinery (Oregon, OH)
collected and analyzed one set of samples and measured nine dioxin congeners above detection
limits. For the TRI reported releases in 2001 and 2002, the refinery set nondetects equal to zero;
however, for 2002, the refinery modified its estimation method to set nondetects equal to one-
half the detection limit. Bay way Refining (Linden, NJ) and Chevron (El Segundo, CA) did not
detect dioxins in their effluent, but estimated the mass released based on one-half the detection
limit.
7.7.5 Compilation and Discussion of Measured Effluent Dioxin Concentrations
Table 7-23 summarizes dioxin concentrations measured in final effluent from
eight U.S. petroleum refineries. Data presented include concentrations reported in PCS, the
Washington State permit-required dioxin study results (18, 36), a special report prepared by the
Tosco Refinery in Martinez, CA (now owned by Tesoro) in April 1997 (19), data summarized in
EPA's 1996 Preliminary Data Summary (24), and data submitted to EPA by BP Oil Company
Toledo Refinery (2). Data in these various sources have different nomenclature. For example,
some sources provide results as TEQ; others only provide discharge information for 2,3,7,8-
TCDD. See Section 4.2.4.2 for additional discussion on dioxin nomenclature. In order to
compare these results, Table 7-23 also provides the associated TWPE. EPA did not include
refinery TRI data in Table 7-23, because refineries do not report concentrations to TRI.
However, as discussed above only two of the four facilities that based their TRI-reported dioxin
discharges on actual measurements detected dioxin in their effluent. EPA has concentration data
from these two facilities from other sources and has included those data in Table 7-23.
5 A 16th refinery, Marathon Ashland Petroleum (Detroit, MI) originally reported discharging 8.06 grams of dioxins in
2000. The refinery submitted a TRI correction form, and EPA changed the reported discharge to 0 grams for this
analysis.
7-50
-------
Section 7 - Petroleum Refining
Table 7-22. NPRA and API Comments on Dioxin Discharge Estimates Reported to the 2000 TRI
TRI ID Number
98221SHLLLWESTM
77590MRTHNFOOTO
70669CNCLKOLDSP
94802CHVRN841ST
90245CHVRN324WE
43616SHLCM4001C
07036XXN 1400P
74603CNCPN1000S
59101CNCBL401SO
08066MBLLCBILLI
00851HSSLVLIMET
80022CNCDN5801B
39567CHVRNPOBOX
62454MRTHNMARAT
00654PHLPSPHILI
Refinery
Tesoro Northwest Co.
Marathon Ashland Petroleum LLC
Conoco Lake Charles Refinery
Chevron Prods. Co. Richmond
Refinery
Chevron USA Prods. Co.
BP Oil Co. Toledo Refinery
Bay way Refining Co.
Conoco Inc. Ponca City Refiner}'
Conoco Inc. Billings Refinery
Valero Refining Co. New Jersey
Hovensa LLC
Conoco Denver Refinery
Chevron Prods. Co. Pascagoula
Refinery
Marathon Ashland Petroleum LLC
Chevron Phillips Chemical Puerto
Rico
Refinery
Location
Anacortes, WA
Texas City, TX
Westlake, LA
Richmond, C A
El Segundo, CA
Oregon, OH
Linden, N.T
Ponca City, OK
Billings, MT
Paulsboro, NJ
Christiansted, VI
Denver, CO
Pascagoula, MS
Robinson, IL
Guayama, PR
TRI Reieases 20001
Dioxin Discharge
(gram/yr)
5.199947
2
0.5392
0.339997
0.329997
0.285997
0.253997
0.180878
0.161558
0.089999
0.069341
0.059999
0.035
0.03
0.00218
Basis of Estimate
for TRI Releases
20002
M
O
E
0
M
M
M
0
O
0
C
0
O
O
E
NPRA and API Comment on
Dioxin Releases Reported to TRI
2001 discharge = 1.6 grams, 2002
discharge =1.7 grams
No comment.
No comment.
Based on detection limit. Two
samples analyzed (no values above
detection limit).
Based on detection limit. Only
OCDD was detected.
One set of samples collected and
analyzed: 9 congeners above the
detection limit.
Based on !/2 the detection limit.
Treated effluent samples are all ND.
Estimated discharge using
nonrefinery-specific data for dioxin
in petroleum products.
Estimated discharge using
nonrefinery-specific data for dioxin
in petroleum products.
Reported wastewater release was
0.0002 grams.
Based on EPA discharge factors .
Internally generated factors per
corporate policy.
No comment.
No comment.
No comment.
-------
Section 7 - Petroleum Refining
^1
to
Table 7-22 (Continued)
TRI ID Number
70602CTGPTHIGHW
79905CHVRN6501T
Refinery
Citgo Petroleum Corp
Chevron USA El Paso Refinery
Refinery
Location
Lake Charles, LA
El Paso, TX
TRI Releases 20001
Dioxin Discharge
(gram/yr)
0.0016
0.109999
Basis of Estimate
for TRI Releases
20002
E
O
NPRA and API Comment on
Dioxin Releases Reported to TRI
Based on EPA discharge factors.
Based on %_ the detection limit.
Refineries Not in EPA's Analysis: No Discharge of Dioxins
48217MRTHN1300S
Maratlion Asliland Petroleiun LLC
Detroit, MI
8.061218
NA
Incorrect number reported: should
be zero discharge. Refinery
submitted TRI correction form.
'Mass transferred to POTW mat is ultimately discharged to surface waters. Accounts for POTW removals.
2Refineries reported basis of estimate in 2000 TRI as: M - Monitoring data/measurements; C - Mass balance calculations; E - Published emission factors; and O - Other
approaches (e.g., engineering calculations).
-------
Section 7 - Petroleum Refining
Table 7-23. Dioxin Concentrations Measured in U.S. Petroleum Refinery Final Effluent
Facility
Tesoro Northwest
Company
Ariacortes, WA
ARCO Cherry Point
Refinery
Blame, WA
U.S. Oil & Refining Co.
Tacoma. WA
Shell Oil Products US
Puget Sound Refinery
Anacortes, WA
Shell Oil Mobile
Saraland, AL
Murphy Oil USA Inc.
Superior. WI
Tesoro Refining
(Previously Tosco)
Avon Refinery
Martinez, CA
Source
(1)
(1)
(1)
(2)
(3)
(3)
(3)
(4)
Results
March 8, 2000 - Split sample analyzed by two labs. Results shown
average two results. Five congeners detected by at least one lab, including
1,2,3,4,6,7,8-HpCDF by both labs.
August 30, 2000 - split sample analyzed by two labs. Results shown
average two results. Nine congeners detected by at least one lab,
including 1,2,3,4.6.7,8-HpCDF bv both labs.
May 3, 2000 - No congeners detected.
October 1, 2000 - No congeners detected.
April 6, 2001 - No congeners detected.
April 13, 2001- No congeners detected.
July 16-17, 2002 - No congeners detected.
June 23 -24, 2002 - No congeners detected.
January 2003 - Only OCDD detected.
March 2003 - No congeners detected.
January 2004 - No congeners detected.
1998 to 2000 - permit requires yearly monitoring for 2,3,7,8-TCDD.
Never detected.
February 29, 2000 - permit requires monitoring for 2.3,7,8-TCDD
March 31, 2000
June 30, 2000
October 31, 2000
permit requires quarterly reporting TCDD-equivalents.
Discharge is 98% nonprocess, 2% process.
January - December, 1996- Outfall to bay - Results reported as TCDD
TEQ. Individual congeners not reported. Outfall includes process and
nonprocess sources of dioxins. Result shown is 12 month average.
June 1996 - GAC outlet. Treated process wastewater.
August 1996 - GAC outlet. Treated process wastewater
2,3,7,8-
TCDD
(pg/L)
<3
<4
<10
<10
<10
<10
ND
ND
ND
ND
ND
ND
<2.7
NR
NR
NR
NR
NR
NR
TEQ
(pg/L)
3.11021.3'
15.5 to
37.91
0
0
0
0
0
0
0.012
0
0
0
0
0.00028
0.30
0.09
0.47
0.012
0.00
Measured
TWPE
(Ib-eq)
29.9 to
1962
0
0
0.81 to
7412
0
0
12.8
NC
(Si
OJ
-------
Section 7 - Petroleum Refining
Table 7-23 (Continued)
Facility
Tesoro Refining
(Previously Tosco)
Avon Refinery
Martinez, CA
BP Oil Company Toledo
Refining
Oregon. OH
Source
(5)
(6)
Results
ca 1989 -Outfall to bay. 13 ppq TCDF detected; not found when sample
reanalyzed.
Re-analyzed sample. Only OCDD detected
2000 - 9 congeners detected
2,3,7,8-
TCDD
(pg/L)
ND
ND
0 to 0.843
TEQ
(pg/L)
1.3
0.12
0 to 4.293
TOTAL MEASURED DIOXTN DISCHARGE:
Measured
TWPE
(Ib-eq)
NC
Oto
24,8003
43.5 to
25,800
Sources:
(1) Washington State Department of Ecology. Letter of Transmittal. December 11. 2003 (DCN 00711).
(2) Shell Oil Products U.S. Puget Sound Refinery. Dioxin Study Report (NPDES Permit WA-000294-1). June 2004.
(3) U.S. EPA. PCSLoads2000.
(4) Tosco Refining Company Avon Refinery. Dioxin Source Investigation Pursuant to Cease and Desist Order No. 95-151, Final Report.
(5) U.S. EPA, 1996 Preliminary Data Summary, Table 6.9.
(6) BP Oil Company. Water Samples for PCDD/PDCFfor the BP Oil Company Toledo Refinery. Performed by Batelle. November 9, 2000.
NC - Not calculated, reporting data for 2000 used to calculate TWPE for refinery.
ND - Not detected, detection limit not reported.
NR - Not reported.
'Low value assumes ND = 0: high value assumes ND = detection limit.
2Total year 2000 discharges. Low value assumes ND = 0; high value assumes ND = detection limit.
3A11 concentrations reported by BP were less than low end of calibration curve. Low value assumes all results were ND, and ND = 0. High value assumes
detected results present at reported concentration and ND = detection limit.
-------
Section 7 - Petroleum Refining
As shown in Table 7-23, only one refinery (BP Toledo Refinery) detected the
most toxic form of dioxin, 2,3,7,8-TCDD, in its final effluent. Four of the eight refineries did
not detect any dioxins in their final effluent. The four refineries that detected dioxins in their
effluent were Tesoro (previously Tosco) (Martinez, CA); Tesoro Northwest (Anacortes, WA);
Shell Puget Sound Refinery (Anacortes, WA); and BP Toledo Refinery (Oregon, OH).
Table 7-24 summarizes the petroleum refinery treated effluent data for individual
dioxin and furan congeners measured at three of the four facilities that detected dioxins in their
final effluent (Tesoro Northwest, Shell Puget Sound, and BP Toledo). All results are presented
in picograms per liter (pg/L). EPA did not present the data for the fourth refinery because the
refinery provided only summary results.
In 1997, the Tesoro (Martinez, CA) refinery completed an extensive study to find
the source of dioxin in its wastewaters (see DCN 710) The study determined that stormwater is
the largest source of dioxin in the final effluent (50 percent) with the coke pond and clean canal
forebay as the second largest (45 percent) (19). The refinery reported that the wastewater
treatment plant (i.e., treated process wastewater) contributed 2 percent of the dioxins in the final
effluent (19). The facility collected and analyzed two samples of fully treated process wastewater
for this study. The analytical results were 0.000 pg/L TCDD-equivalents and 0.012 pg/L TCDD-
equivalents (19). These concentrations equate to 12.8 Ib-equivalents. In comparison, the
calculated TCDD-equivalents of the concentrations detected in the final effluent in 2000 were
0.00028, 0.30, and 0.09 pg/L (34).
The Tesoro Northwest Refinery (Anacortes, WA) sampled its effluent on two
occasions, during batch discharges of treated wastewater generated during the regeneration of
catalytic reformer spent catalyst. Each sample was analyzed by two independent analytical
laboratories. Tesoro Northwest detected between 6 and 11 dioxin congeners in its final effluent
(36). However, two compounds were present in the corresponding laboratory blank,. Several
other compounds were detected below the lower calibration limit. OCDF and 1,2,3,4,6,7,8-
HpCDF were detected about the method minimum level by both laboratories and in both
samples. The most toxic dioxin forms (2,3,7,8 -TCDD and 2,3,7,8-TCDF) were not detected in
any samples (36). The refinery has not done an additional study to identify the sources of dioxin
in its final effluent (17). At this point, because the dioxin concentrations in the upstream source
(catalytic reformer regeneration wastewaters) are also high, EPA assumes the spent caustic/wash
water from catalytic reformer regeneration is the source of the dioxins in the final effluent.
These effluent measurements equate to 29.9 to 196 TWPE (low value assumes nondetects equal
zero and high value assumes nondetects equal the detection limit).
The Shell Puget Sound Refinery (Anacortes, WA) sampled its effluent on three
occasions, corresponding to the regeneration of catalytic reformer spent catalyst. Shell Puget
Sound detected OCDD at a concentration of 120 pg/L in its final effluent during the January
2003 sampling episode. For the March 2003 and January 2004 sampling episodes, the refinery
7-55
-------
Section 7 - Petroleum Refining
Table 7-24. Treated Effluent Dioxin/Furan Sample Results, pg/L
Dioxin Congener
Method
1613b ML
pg/L
Tesoro Northwest
(Anacortes, WA)
3/2000
Lab A
LabB
8/2000
Lab A
LabB
Shell Puget Sound Refinery
(Anacortes, WA)
1/2003
3/2003
1/2004
BP Toledo
(Oregon, OH)
9/2000
CDDs
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
12147 8-HxCDD
1,2,3,6,7,8-HxCDD
12378 9-HxCDD
1.2,3.4,6,7,8-HpCDD
OCDD
10
50
50
50
50
50
100
ND
ND
ND
ND
ND
39b
lOOb
ND
ND
ND
ND
ND
35j
110
ND
ND
ND
ND
ND
153
1160b
ND
ND
ND
ND
ND
35j
130
ND
ND
ND
ND
ND
ND
120
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.84J
1.12J
ND
ND
ND
1.62J
15.12J
CDFs
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
10
50
50
50
50
50
50
50
50
ND
ND
ND
35
17a
13a
9.7a
100
34
ND
ND
ND
43
ND
ND
ND
130
40
ND
Ilia
20.2a
83.6
57.6
46.5
38.7
412
145
ND
ND
ND
33j
ND
ND
ND
110
38i
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.09J
1.52J
1.63J,
ND
ND
ND
6.97J
ND
-~J
o\
-------
Section 7 - Petroleum Refining
Table 7-24 (Continued)
Dioxin Congener
OCDF
Method
1613b ML
pg/L
100
Tesoro Northwest
(Anacortes, WA)
3/2000
Lab A
200
LabB
270
8/2000
Lab A
935
LabB
200
Shell Puget Sound Refinery
(Anacortes, WA)
1/2003
ND
3/2003
ND
1/2004
ND
BP Toledo
(Oregon, OH)
9/2000
1.28J
Sources: Washington State Department of Ecology. Letter of Transmittal. December 11, 2003 (DCN 00711); Shell Oil Products U.S. Puget Sound Refinery.
Dioxin Study Report (NPDES Permit WA-000294-1). June 2004: and BP Oil Company. Water Samples for PCDD/PDCFfor the BP Oil Company Toledo
Refinery. Performed by Batelle. November 9, 2000.
ML - Minimum Level.
a/j - Compound present, detected below the lower calibration limit.
b - Detected in method blank.
-------
Section 7 - Petroleum Refining
detection no dioxins in its final effluent (18). These measurements equate to 0.81 to 741 TWPE
(low value assumes nondetects equal zero and high value assumes nondetects equal the detection
limit).
The BP Toledo Refinery (Oregon, OH) sampled its effluent once in September
2000. It has a continuous discharge of wastewater from its catalytic reforming regeneration. BP
Toledo detected nine congeners, including the most toxic form, 2,3,7,8-TCDD, in its final
effluent. However, no dioxins were detected above the lower calibration limit or the method
minimum level. Although these compounds were below the lower calibration limit, they were
probably present in the sample. EPA estimates treated effluent TWPE range from 0 to 25,800
(low value assumes nondetects equal zero and high value assumes nondetects equal the detection
limit). (2)
EPA notes that many of the detected dioxin concentrations at these refineries are
close to the analytical minimum level and that some sample-specific detection levels and
detected concentrations are below the Method 1613b minimum level. Method 1613b is the
analytical method EPA specifies for compliance when it establishes 2,3,7,8-TCDD limits in the
effluent guidelines program. The minimum level is the is the smallest quantity that the method
can reliably measure. Also, EPA has historically regulated dioxins as 2,3,7,8-TCDD and
establishes the limit as below the minimum level. All of information from the eight facilities that
measured for dioxins (including BP Toledo) indicates 2,3,7,8-TCDD is below the minimum level
of lOpg/L.
Data from these eight refineries indicate that while dioxins may be generated
during catalyst regeneration operations, dioxin concentrations measured at the effluent are close
to the minimum level or below the minimum level. This indicates that the dioxins are being
removed from the wastestream prior to discharge. Because dioxins have a low water solubility
and extreme hydrophobicity, EPA expects that the dioxins from catalytic reformer regeneration
wastewaters partition to the oily and solids phases in the API separator and accumulate in the
sludges.
Finally, EPA notes that the total TWPE based on measured discharged by
refineries is 43.5 to 25,800 TWPE (low value assumes nondetects equal zero and high value
assumes nondetects equal the detection limit) compared to the 139,258 TWPE calculated using
the 2000 TRI data, as reported.
7.7.6 Dioxin Control Technologies
As described in the 1996 Preliminary Data Summary, after reviewing data
collected in its 1990-91 refinery sampling program, EPA noted that greater than 90 percent of
the TEQ were associated with solids-phase samples. This indicated that dioxins might be treated
at the source by filtration technology prior to commingling the regeneration wastewater with
wastewaters from other refinery operations (24, page G-22).
7-58
-------
Section 7 - Petroleum Refining
To control dioxins in wastewater, Shell Canada (Sarnia, Ontario Canada)
implemented carbon filtration pretreatment of spent caustic from the catalytic reformer. The
pretreatment system consists of two carbon filters (165 pounds each) connected in series with a
flow rate of five gallons per minute. After pretreatment, the refinery treats the wastewater in its
end-of-pipe biological treatment system. The 1996 Preliminary Data Summary did not discuss
the effectiveness of this treatment. (24)
As described in Dioxin Source Investigation Pursuant to CDO No. 95-151, Final
Report (19), the Tesoro Avon Refinery (owned by Tosco at the time of the report) operates both
a continuous catalytic reformer and a semi-regenerative catalytic reformer. Off-gases from the
continuous catalyst regeneration pass through a caustic scrubbing solution. A slipstream of
washwater is constantly purged to the oily sewer at a rate of four gallons per minute. In 1993,
the refinery installed a granular activated carbon (GAC) treatment system that successfully
removed 95 to 99 percent of the dioxins found in the washwater from this wastestream. The
refinery analyzed two samples of GAC effluent and reported the results as 0.012 pg/L TEQ for
one sample and 0.00 pg/L TEQ for the other sample.
Tesoro's semi-regenerative catalytic reformer is shut down approximately once
per year for regeneration. Washwater from this process contains dioxins. The refinery
determined that allowing particulate in the catalyst regeneration wastewater to settle in tanks for
a minimum of one week allows the dioxin concentrations in the liquid portion to drop to nearly
zero. The settled liquid is pumped through a 1-micron filter sock prior to discharge to the oily
sewer. The refinery disposes of the filter socks and collected particulate matter as dioxin-
containing hazardous waste (19).
7.7.7 Detailed Study Findings for Dioxins
Below is a summary of the findings of EPA's detailed study of refinery dioxins.
• The term "dioxins," or polychlorinated dibenzo-p-dioxins (CDDs) and
poly chlorinated dibenzofurans (CDFs), refers to the 17 individual
compounds (congeners) with chlorine substitution of hydrogen atoms at
the 2, 3, 7, and 8 positions on the benzene rings. U.S. industrial facilities
were first required to report dioxin releases to TRI in 2000. Facilities
report the total mass of the 17 compounds released to the environment and
the congener distribution of these releases. Using 2000 TRI data as
reported (and accounting for POTW removals), EPA estimated that
petroleum refineries released 9.60 grams of dioxins to surface water
in 2000.
• EPA calculated the TWPE of dioxins released from petroleum refineries
using facility-reported congener distributions. If a refinery did not report a
congener distribution, EPA used the refining industry-specific average
distribution to calculate the mass of each congener released. Using TWFs
for each congener and 2000 TRI data (accounting for POTW removals),
7-59
-------
Section 7 - Petroleum Refining
EPA estimated that refineries discharged 139,258 TWPE of dioxins in
2000.
• Using only final effluent data where dioxin discharges were measured
analytically, EPA estimated that refineries discharged between 43.5 and
25,800 TWPE of dioxins in 2000 (over 80 percent less than the TWPE
estimated using the TRI data as reported).
• In 1988, dioxins were identified in catalyst regeneration wastewater from
Ontario petroleum refineries. In the early 1990s, EPA confirmed that
reformer catalyst regeneration wastewater was the major source of dioxins
in refinery process wastewater. In 2000, 122 refineries performed
catalytic reformer regeneration.
• For this detailed study, EPA reviewed in-plant dioxin monitoring data
from four sources:
— Washington Department of Ecology permit-required sampling:
results of sampling and analysis provided by three Washington
refineries from 2001-2003.
— Washington Department of Ecology permit-required sampling:
results of sampling and analysis provided by Shell Oil Products
U.S. Puget Sound Refinery from 2003 - 2004.
— EPA-conducted sampling in support of its 1996 Preliminary Data
Summary: results of sampling at three California refineries in the
early 1990s.
— BP Oil CompanyToledo Refinery sampling data from 2000.
• From the four sources above, high concentrations of dioxins, including
2,3,7,8-TCDD and 2,3,7,8-TCDF, were detected in catalytic reformer
regeneration wastewaters at all eight refineries:
— 2,975 pg/L - Median TCDD-equivalent concentration, and
— 5.64 mg/cycle - Median loading per regeneration cycle.
• From the four sources above, four of the eight refineries detected dioxins
in their final effluent.
One of three refineries with NPDES permit limits for TCDD or TCDD-
equivalents detected dioxins in their final effluent in 2000:
7-60
-------
Section 7 - Petroleum Refining
— Tesoro Refining (Martinez, CA) reported 0.00028, 0.09, and 0.3
pg/L in its final effluent.
— This refinery identified stormwater and coke pond water as
contributing 95 percent of the mass discharged. Treated process
wastewater contributed two percent of the mass. Sampling of
treated process wastewater yielded 0.000 pg/L TCDD-equivalents
and 0.012 pg/L TCDD-equivalents. This equates to 12.8 TWPE.
For TRI reporting year 2000, 17 refineries reported wastewater dioxin
releases.
— For 15 of the 17 dioxin-reporting refineries, reported releases were
either not based on measured concentrations, or when dioxin
congeners were not detected, releases were estimated using one-
half the analytical detection limit and refinery effluent flow.
— For 2 of the 17 dioxin-reporting refineries, the reported releases
appear to have been based on measured concentrations in refinery
effluents.
BP Oil Company Toledo Refinery (Oregon, OH) - EPA
received the 2000 analytical data report from the refinery.
All concentrations reported by BP were less than the low
end of calibration curve. Although the concentrations of
these compounds were below the method minimum level,
they were probably present in the sample. EPA estimates
treated effluent TCDD-equivalents concentrations range
from 0 to 4.29 pg/L, or 0 to 24,800 TWPE.
• Tesoro Northwest (Anacortes, WA) - EPA received further
data for this refinery as part of the Washington Department
of Ecology permit requirements (see below).
Four Washington refineries provided permit-required final effluent
sampling results.
— Dioxins were not detected in the treated final effluent of two of
these refineries.
— EPA estimates treated effluent TCDD-equivalent concentrations at
Tesoro Northwest (Anacortes, WA) are between 3.1 and 37.9 pg/L.
The process wastewater (spent caustic/wash water) from catalytic
reformer regeneration contains high concentrations of dioxins.
Most dioxins settle with the solids and become part of the API
7-61
-------
Section 7 - Petroleum Refining
separator sludge; however, the refinery effluent still contains
dioxins above detection limits. The most toxic form of dioxins
were not detected in any effluent samples. Dioxin in treated
effluent equate to 29.9 to 196 TWPE.
— EPA estimates treated effluent TCDD-equivalents concentrations
at Shell Puget Sound Refinery (Anacortes, WA) are between 0 and
0.012 pg/L, or 0.81 to 741 TWPE. The process wastewater
(caustic water wash) from catalytic reformer regeneration contains
high concentrations of dioxins; however, almost all of the dioxins
settle with the solids and become part of the API separator sludge.
The refinery detected only one congener in the final effluent in one
of the three sampling episodes.
• Four Washington refineries provided permit-required API separator sludge
sampling results. Dioxins were detected in the sludge from all four of
these refineries, including the two refineries with no dioxins in their final
effluent.
• Tesoro Refinery in Martinez, CA practices in-plant treatment of
segregated catalytic reforming catalyst regeneration wastewater.
— GAC removes 95 to 99 percent of the dioxins in continuous
catalytic reformer off-gas scrubber blowdown.
— Settling and solids filtration removes dioxins from semi-
regenerative catalytic reformer regeneration wash water.
Based on the information collected during the detailed review, EPA concludes
that dioxins might be produced in high concentrations at petroleum refineries during reformer
catalyst regeneration processes. While some dioxin congeners might be present in the treated
effluent at some refineries, the most toxic congeners, 2,3,7,8-TCDD and 2,3,7,8-TCDF, have
only been detected in the final effluent at one petroleum refinery at a concentration below the
method minimum level. TWPE estimates from eight facilities that sampled their treated effluent
for dioxins ranges from 43.5 to 25,800 TWPE. EPA notes that these TWPE estimates are based
on dioxin concentrations close to the analytical minimum level. In addition, the highest
estimated TWPE (24,800 TWPE at the BP Toledo Refinery) was calculated for an effluent
sampled only once, with all detected congener concentrations below the Method 1613b
minimum level.
Contamination of API separator sludge with dioxins suggests that at least some of
the dioxins from catalytic reformer regeneration wastewater partition to the oily and solid phases
in the API separator and accumulate in the sludge. API separator sludges are managed as
hazardous wastes.
7-62
-------
Section 7 - Petroleum Refining
In-process control technology effectively removes dioxins from segregated
catalytic reforming catalyst regeneration wastewater. This control technology consists of solids
removal and/or GAC adsorption. Permit writers should consider the use of these technologies as
they develop permit limits that reflect their "Best Professional Judgement" (BPJ) of what
constitutes BAT for an individual refinery.
7.8
Metals
Petroleum refinery wastewater contains a number of metal pollutants. In 2000,
petroleum refineries reported wastewater releases of over 20 metals6 to TRI and refineries in
PCS monitored their effluent for discharges of over 30 metals.
7.8.1
Identification and Description of the Metals Discharged in Petroleum
Refinery Wastewater
Table 7-25 provides information on the metals commonly found in discharges
from petroleum refineries, and identifies if the metal is reportable to TRI or is a CWA priority
pollutant. Petroleum refinery effluent limitations guidelines found in 40 CFR Part 419 include
limitations for hexavalent and trivalent chromium.
Table 7-25. Metals in Petroleum Refining Wastewater
Pollutant
Aluminum
Arsenic
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Vanadium
Zinc
Reportable to TRI?
[
/
/
/
/
/
/
/
/
/
Priority Pollutant?
/
/
/
/
/
/
/
-
/
Limits in 40 CFR Part 419?
/
'Aluminum is only reportable to TRI in its fume or dust form.
7.8.2
Sources of Metals at the Petroleum Refinery
Crude petroleum is the major source of metals at petroleum refineries. Metals
found in crude petroleum, and their concentrations, depend on the origin of the crude oil. For
example, selenium is contained in some crude oils, particularly from parts of California (3).
Tor this review, two nomnetallic elements, arsenic and selenium, are included with metals.
7-63
-------
Section 7 - Petroleum Refining
Other sources of metals in refinery wastewater include pipe corrosion (e.g., chromium), catalyst
additives, other refinery raw materials, cooling water biocide (e.g., chromium),and supply water
(37).
Desalter wastewater will most likely have the largest concentration of metals,
especially mercury. Another process wastewater source of metals is wash water from other
refining steps (37).
7.8.3
Reported Metal Discharges
EPA estimated metal loadings for the petroleum refining industry using data
reported to TRI and PCS in 2000. In addition, EPA used metals discharge data for 23 refineries
from the 1996 Preliminary Data Summary (24) and for 10 refineries from API (1).
7.8.3.1
Mass Discharges: TRI and PCS
Table 7-26 presents the pollutant loadings for metals estimated using discharges
reported to TRI for 2000. Metals account for 22 percent of the total industry TWPE discharge
estimated with TRI data when PAC and dioxin discharges are included. However, as discussed
in Sections 7.6 and 7.7, EPA has little evidence that PACs and dioxin releases reported to TRI
reflect measurable concentrations in refinery effluents. Metals make up almost 70 percent of the
TRI TWPE when PACs and dioxins are not included in the total, and 17 percent of the PCS
TWPE.
Table 7-26. Metals Discharges as Percentage of Total TWPE
Pollutant
Total TWPE Discharged
Percentage of Total TWPE
Discharged
TRI Loads
Metals
Total
84,368
373,177
22%'
PCS Loads
Metals
Total
33,547
192,862
17%
Source: TRIReleases2000 and PCSLoads2000.
'Metals compose 70 percent of the TRI TWPE if PACs and dioxins are excluded.
As shown in Table 7-27, based on data reported to both the TRI and PCS, a few
metals contribute most of the TWPE. Table 7-28 presents information from TRIReleases2000,
showing the five metals with the highest estimate of TWPE released to surface waters in 2000.
Vanadium comprises most of the TWPE in releases reported to TRI in 2000; 14 refineries
reported releasing more than 55,000 TWPE of vanadium, or 65 percent of the metal TWPE.
7-64
-------
Section 7 - Petroleum Refining
Table 7-27. Top Five Metals as Percentage of Total Metal TWPE
Pollutant
Total Metals
Top 5 Metals1
Top 5 as percentage of total
metals
PCS
Total Pounds
Discharged
202,860
130,684
64%
Total TWPE
Discharged
33,547
26,042
78%
TRI
Total Pounds
Discharged
182,265
98,215
54%
Total TWPE
Discharged
83,266
75,961
91%
Source: TRIReleases2000 and PCSLoads2000.
'Top five TRI metals include vanadium, mercury, selenium, chromium and lead. Top five PCS metals include
selenium, aluminum, arsenic, mercury and lead.
Table 7-28. Five Metals with Highest Estimated TWPE (TRI)
Pollutant
Vanadium
Mercury
Selenium
Chromium
Lead
TRI
Number of Refineries
14
20
2
13
14
Total Pounds
Discharged
88.778
100
2.655
5,049
1,632
Total TWPE
Discharged
55.240
11.768
2,975
2,322
3,656
Source: TRIReIeases2000.
The federal effluent limitations and guidelines for petroleum refineries include
metal limits only for chromium (total and hexavalent); however, state and local permits may
require refineries to monitor for other metal compounds. Table 7-29 presents information from
PCSLoads2000, showing the five metals with the highest estimate of TWPE discharged to
surface waters in 2000. Selenium comprises most of the TWPE in discharges calculated using
PCS data; 18 refineries reported selenium discharges, accounting for more than 9,000 TWPE of
selenium, or 27 percent of the metal TWPE.
7-65
-------
Section 7 - Petroleum Refining
Table 7-29. Five Metals with Highest Estimated TWPE (PCS)
Pollutant
Selenium
Aluminum
Arsenic
Mercury
Lead
PCS
Number of Refineries
18
5
10
7
10
Total Pounds
Discharged
8,068
120,235
1,663
16
701
Total TWPE
Discharged
9,041
7,754
5,769
1,908
1,571
Source: PCSLoads2000.
7.8.3.2
Additional Metals Data (Concentrations)
EPA reviewed additional petroleum refinery metals discharge data and compared
these concentrations to baseline values and promulgated effluent guidelines. Each of the data
sources is discussed below and Table 7-30 presents these data.
Preliminary Data Summary
As part of the study described in EPA's 1996 Preliminary Data Summary (24),
EPA visited and collected effluent data from six refineries. Table 7-30 presents the range of
effluent metals concentrations collected from these refineries. No data on concentrations of
arsenic, mercury, or vanadium were available for these refineries.
EPA also obtained one-year average concentration data collected during Ontario's
Seven Refineries Study, conducted in 1989 (24). Table 7-30 presents these average
concentrations. No data on concentrations of mercury or vanadium were available for these
refineries.
API Supplied Data
EPA received comments from API on the December 31, 2003 Notice of the
Preliminary Effluent Guidelines Program Plan for 2004 2005. API provided a set of petroleum
refining effluent data that were previously collected by its members in conjunction with EPA's
Office of Solid Waste (1). Data were collected from refineries following activated sludge
treatment. Most of the metals with high TWPE discharges as reported to TRI were not detected
above analytical detection limits. The exceptions were nickel, selenium, and vanadium. Table
7-30 presents the median of the analytical results.
7-66
-------
Section 7 - Petroleum Refining
Calculated PCS Concentrations
As described in Section 7.2.2, EPA used data reported to PCS to estimate annual
pollutant mass discharges. As further described in Section 7.5.2, EPA used PCS data to estimate
annual process wastewater flow rates. EPA assumed that flows from effluent outfalls with
limitations for BOD5 and/or ammonia (as nitrogen) were process-related. For each refinery
discharging metals as reported to PCS (in pounds), EPA estimated the metal concentration by
dividing the mass discharged by the flow rate (and correcting the units). Table 7-30 presents the
median of estimated metal concentrations.
Baseline Values
Table 7-30 also presents baseline values for metal pollutants to compare to the
metals concentrations measured at petroleum refineries. EPA develops method-specific "baseline
values" for analyzing measurement data collected for effluent guidelines development. In most
cases, the baseline value is the "nominal quantitation limit" stipulated for the specific method
used to measure a particular pollutant. In general, the term "nominal quantitation limit" describes
the smallest quantity of an analyte that can be measured reliably. The baseline values shown in
Table 7-30 were taken from Chapter 15 of the Development Document for Centralized Waste
Treaters (CWT) Point Source Category (26).
Comparison of Concentrations
As shown in Table 7-30, the concentrations of arsenic, copper, lead, mercury, and
nickel did not exceed the baseline value or method detection level in any of the data sources. As
a result, EPA concludes that TWPEs calculated for these pollutants reflect concentrations below
the method detection level multiplied by the refinery effluent flow rate. Chromium, selenium,
vanadium, and zinc, however, were detected above the baseline value/method detection level in
at least one data source. Each of these metals is discussed in more detail below.
Chromium concentrations exceeded the baseline value for one or more of the six
refineries visited for the 1996 Preliminary Data Summary. However, the highest concentration
detected in samples taken for the 1996 Preliminary Data Summary was 0.02 mg/L, slightly
greater than the baseline value (0.01 mg/L) but less than the long-term average of the BPT/BAT
technology (0.25 mg/L). Concentrations from the other data sources were all less than the
method detection level. These data collectively demonstrate that chromium is rarely discharged
above the method detection level or the BAT treatment performance concentration.
7-67
-------
Section 7 - Petroleum Refining
Table 7-30. Pollutant Discharge Concentrations for Metals at Petroleum Refineries
Pollutant
Source
Arsenic
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Vanadium
Zinc
PDS Site Visit
Data
(6 refineries)
Range, mg/L
1
NA
0.015-0.02
0.01-.013
0.001-0.012
NA
0.033-0.039
0.006-0.06
NA
0.04-0.147
Canada Study Data
(7 refineries)
Average, mg/L
2
0.009
0.0068
0.0048
0.0041
NA
0.0034
0.005
NA
0.29
1993/1994
Wastewater
Treatment Effluent
Data
(10 refineries)
Median, mg/L
3
<0.1(allND)
< 0.01
< 0.01 (all ND)
< 0.05 (all ND)
< 0.0002
(all ND)
0.04
0.012
0.26
<0.02
2000 PCS
Concentration
Median, mg/L
4
0.0084
0.0067
0.0066
0.0031
0.00002
0.023
0.015
0.015
0.04
Baseline Values
(EPA Method
Number 1620),
mg/L
5
0.01
0.01
0.025
0.050
0.0002
0.040
0.005
0.05
0.020
Comparison to
Concentration Basis of
Existing Regulation or Other
Recently Promulgated
Regulations, mg/L
-
-
0.251
-
-
-
-
NA
NA
1.48 (40 CFR Part 433)
0.42 (40 CFR Part 437)
0.26 (40 CFR Part 464 -
Ferrous Subcategory)
0.1 8 (40 CFR Part 464-
Nonferrous Subcategory)2
ON
OO
Sources:
1. 1996 Preliminary Data Summary. Table 4-4.
2. 1996 Preliminary Data Summary, Table 4-5, taken from BAT for Ontario Petroleum Refining Sector, August 1991.
3. API Comment, Table 4, 1993-94 data collected in conjunction with EPA/OSW.
4. Calculated using BOD5-associated flow, andPCSLoads2000 estimated annual mass discharge.
5. Development Document for Centralized Waste Treaters (CWT) Point Source Category. Attachment 15-1.
NA - Not available.
ND - Not detected.
'BPT/BAT-equivalent concentration for existing regulation (40 CFR Part 419) as listed in U.S. EPA^s Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Petroleum Refining Point Source Category. April 1974.
240 CFR Part 433; 40 CFR Part 437.31: Organics Treatment and Recovery Subcategory; and U.S. EPA Development Document for Final Effluent Limitations Guidelines and
Standards for the A fetal A folding and Casting (Foundry) Point Source Category (40 CFR Part 464).
-------
Section 7 - Petroleum Refining
Selenium concentrations also exceeded the baseline value for one or more of the
six refineries visited for the 1996 Preliminary Data Summary. In addition, the median
concentrations provided in the API comments and calculated from PCS 2000 exceeded the
baseline value. Selenium is present in crude petroleum, especially from parts of California. In
the 1990's, California permitting authorities conducted a selenium treatability study. As a result
of the study, many California refineries shifted their crude supplies so that they received low
selenium crude. In addition, for five refineries in the Los Angeles Basin, the LA County
Sanitation Districts began implementing source control requirements for selenium. The control
requirements are driven by local requirements for the disposal of the Districts' biosolids. The
LA County Sanitation Districts commented that the General Pretreatment Regulations (40 CFR
Part 403) and their local Wastewater Ordinance provides adequate control of selenium
discharges by refineries (3).
EPA notes that it has historically not established national categorical limitations
or standards for selenium in any existing ELGs. EPA did promulgate selenium limitations and
standards in 40 CFR Part 437 based on primary chemical precipitation, liquid/solid separation,
secondary precipitation, clarification, and sand filtration, but re-promulgated the regulation to
delete these limitations. EPA found that selenium removal was achieved only on the last stage of
the treatment technology basis, sand filtration, and that these removals were not consistent or
predictable. See 68 FR 71014-71026.
The median concentration of vanadium provided in the API comments exceeded
the baseline value; however, the more recent data from the 2000 PCS show concentrations below
the baseline value. Vanadium is one of the metals that facilities are required to report to TRI. It
is not limited in the existing effluent guideline. PCS contains little data on vanadium indicating
that refinery discharge permits do not include vanadium requirements and that it has not been
identified as a water quality issue.
For zinc, the median concentration calculated from PCS, the average
concentration from the Canadian study, and the maximum of the range provided in the 1996
Preliminary Data Summary exceeded the baseline value. EPA compared the zinc concentrations
from petroleum refineries to BAT limitations (or basis) for three promulgated regulations:
1) Metal Finishing (40 CFR Part 433) - EPA recently evaluated the Metal
Finishing Category when developing the Metal Products and Machinery
regulations (40 CFR Part 438). EPA decided not to revise the Metal
Finishing limitations for zinc (1.48 milligrams per liter, monthly average).
The concentrations of zinc in refinery effluents are well below the Metal
Finishing standard.
2) Centralized Waste Treatment - Organics Treatment and Recovery Subpart
C (40 CFR Part 437.31) - EPA based the BPT monthly average limitation
for zinc (0.420 milligrams per liter) on biological treatment. The
concentrations of zinc in refinery effluents are below the standard
7-69
-------
Section 7 - Petroleum Refining
established for the Organics Treatment and Recovery Subcategory of the
Centralized Waste Treatment regulations.
3) Metal Molding and Casting (40 CFR Part 464) - The treatment technology
that serves as the basis for BAT limitations for Metal Molding and Casting
is lime precipitation and sedimentation, followed by filtration. This
effective metal control technology can achieve 30-day effluent
concentrations of zinc equal to 0.26 milligrams per liter (ferrous
subcategory) and 0.18 milligrams per liter (nonferrous subcategory). The
median zinc concentrations for U.S. refineries are below even the
concentrations achieved using lime precipitation and sedimentation,
followed by filtration technology.
7.8.4 Metals Control Technologies
The metal concentrations in refinery final effluents are typically below treatable
levels; however, permit writers may identify refinery-specific problems. Permit writers should
use BPJ to evaluate available pollution prevention and treatment technologies when establishing
NPDES permit limitations.
Metals are found in crude petroleum and petroleum products. The main pollution
prevention steps that refineries can take are to quickly identify and correct any leaks and to
maintain controls to prevent petroleum spills from reaching any sewers or other waters. In
addition, refineries can monitor the amount of metals (especially mercury) present in incoming
crude oil and reject shipments that exceed the refinery's acceptable levels.
Selenium and vanadium are two metal pollutants that have been identified in
some refinery discharges. Vanadium can be removed from wastewater through sulfide
precipitation. Typically the reaction is carried out with a pH of 7.0 to 9.0 (38). Existing control
of selenium generally consists of source control requirements. However, selenium has been
demonstrated to be removed from wastewater through sulfide precipitation at a pH of 6.5 (8).
7.8.5 Detailed Study Findings for Metals
Below is a summary of findings of EPA's detailed study of refinery metals.
• Metals that may be present in petroleum refining wastewater include
aluminum, arsenic, chromium, copper, lead, mercury, nickel, selenium,
vanadium, and zinc. Crude petroleum is the primary source of metals in
refinery wastewater. The concentration of a metal in the crude depends on
the source of the crude.
• Using TRI data as reported (and accounting for POTW removals), EPA
estimated that refineries discharged 182,265 pounds (83,266 TWPE) of
7-70
-------
Section 7 - Petroleum Refining
metals in 2000. Vanadium discharges from 14 refineries compose 65
percent of the TWPE (> 55,000 TWPE).
• Using PCS data as reported, EPA estimated that refineries discharged
202,860 pounds (33,547 TWPE) of metals in 2000. Selenium discharges
from 18 refineries compose 27 percent of the TWPE (9,000 TWPE).
• EPA identified concentration data from the 1996 Preliminary Data
Summary (from site visits and from the Canadian study BAT for Ontario
Petroleum Refining Sector} and API comments. In addition, EPA
calculated metals concentrations using PCS mass discharges and flow
rates. Median concentrations of arsenic, copper, lead, mercury, and nickel
did not exceed the baseline value or method detection level. This
indicates that the refineries discharge these pollutants below detectable or
treatable concentrations.
• The median concentrations of chromium, selenium, vanadium, and zinc
exceed baseline values in at least one data source. These four metals are
discussed below:
— The effluent guidelines at 40 CFR Part 419 include limitations for
chromium. The concentrations of chromium in any refinery
wastewater evaluated are well below the concentration upon which
current limitations were based. In addition, chromium was
detected in only one data source at a concentration slightly above
the baseline value.
— Local limits are currently used to regulate selenium discharges
from refineries.
— EPA has not historically regulated selenium and vanadium
discharges in existing ELGs due to difficulties in obtaining optimal
removals using traditional wastewater treatment technologies.
— In evaluated data, the zinc concentrations in U.S. refinery effluents
are below previously promulgated limitations (Metal Finishing, 40
CFR Part 433 and Centralized Waste Treatment, 40 CFR Part 437)
and BAT basis concentrations (Metal Molding and Casting, 40
CFR Part 464).
Based on data as reported to PCS and TRI, metals contribute 17 to 22 percent of
the TWPE reported released by petroleum refineries in 2000. Based on the information for the
detailed review, EPA concludes that the concentration of metal pollutants in refinery
wastewaters is at or near treatable levels, leaving little to no opportunity to reduce metals
discharges through conventional end-of-pipe treatment. Further, EPA did not identify an in-
7-71
-------
Section 7 - Petroleum Refining
process waste stream with high concentrations of metals and, similarly, could not identify an
appropriate in-process treatment technology.
7.9
Conventional and Nonconventional Pollutants
Conventional pollutants found in petroleum refinery wastewater include BOD5,
total suspended solids (TSS), oil and grease, and pH. Nonconventional pollutants found in
petroleum refining wastewater include ammonia as nitrogen (N), chemical oxygen demand
(COD), cyanide, phenols, and sulfide. The current petroleum refining regulations (40 CFRPart
419) include limitations for all the conventional pollutants listed above, as well as ammonia as
N, COD, phenols, and sulfide. 40 CFR Part 419 does not limit cyanide discharges from
petroleum refineries.
7.9.1
Reported Conventional and Nonconventional Pollutant Discharges
The estimated conventional and nonconventional pollutant loadings for the
petroleum refining industry are based on PCS data. In 2000, 104 refineries reported wastewater
releases of conventional pollutants to PCS, and 102 refineries reported wastewater releases of
nonconventional pollutants to PCS. In addition, EPA has discharge data for conventional and
nonconventional pollutants for 138 refineries from the 1996 Preliminary Data Summary.
7.9.1.1
Mass Discharges: PCS
Table 7-31 presents the pollutant loadings for conventional and nonconventional
pollutants (excluding metals), and, for comparison, the metal loadings, estimated using
discharges reported to PCS in 2000. Nonconventional pollutants (excluding metals) account for
83 percent of the total TWPE discharged by the industry using PCS data.
Table 7-31. Conventional and Nonconventional Pollutant Discharges in PCS
Pollutant
Total Pounds
Discharged
(millions)
Total TWPE
Discharged
Percentage of Total
TWPE Discharged
PCS Loads
Conventional pollutants
Nonconventional pollutants (excluding metals)
Metals
Total
45
287
0.202
332
i
159,315
33,547
192,862
i
83%
17%
Source: PCSLoads2000.
'EPA does not have TWFs for conventional pollutants, therefore, it cannot calculate TWPEs for these pollutants.
7-72
-------
Section 7 - Petroleum Refining
Tables 7-32 and 7-33 present the pollutant loadings for certain conventional and
nonconventional pollutants estimated using discharges reported in 2000. EPA does not assign
TWF to conventional pollutants. The nonconventional pollutant, sulfide, accounts for 63 percent
of the total TWPE using PCS data; 70 refineries reported discharging more than 100,000 TWPE
of sulfide.
Table 7-32. Conventional Pollutants with Highest Estimated Pounds Discharged (PCS)
Pollutant
Total suspended solids
Oil and grease, freon extr-grav method
BOD, 5-day
BOD, carbonaceous 5-day
Oil and grease
PCS Top 5 Conventional Pollutants
Number of
Refineries
97
69
93
6
21
Total Million
Pounds Discharged
27
7.5
6.7
0.76
0.63
Total TWPE
Discharged
-
-
-
-
-
Source: PCSLoads2000.
Table 7-33. Nonconventional Pollutants with Highest Estimated TWPE (PCS)
Pollutant
Sulfide, total1
Chlorine, total residual
Fluoride, total (as F)
Phenolics, total recoverable
Nitrogen, ammonia, total2
PCS Top 5 Nonconventional Pollutants (except metals)
Number of
Refineries
70
13
11
68
87
Total Million Pounds
Discharged
0.036
0.052
0.46
0.26
2.0
Total TWPE
Discharged
100,734
25,357
16,198
7,336
3,581
Source: PCSLoads2000.
'Sulfide, Total includes Sulfide, Total (as S).
2
Nitrogen, Ammonia Total includes "Nitrogen Ammonia Total (AS N)" and "Nitrogen Ammonia Total (AS NH4).'
7.9.1.2
Conventional and Nonconventional Pollutant Concentrations
EPA reviewed concentration data for petroleum refinery conventional and
nonconventional pollutants and compared these concentrations to baseline values and
promulgated effluent guidelines. The data sources for this data are discussed in the following
section and Table 7-34 presents these data.
7-73
-------
Section 7 - Petroleum Refining
Table 7-34. Pollutant Discharge Concentrations for Conventional and Nonconventional Pollutants at Petroleum Refineries
Pollutant
Source
TSS
Oil and grease
Ammonia (as N)
COD
Phenols, total
Sulfide, total
Preliminary
Data Summary
Site Visit Data
(6 refineries)
Range, mg/L
I
8.75-12
2.7-4.2
0.94-1.43
51-59.5
0.005-0.012
0.018-0.14
Canada Study
Data (7
refineries)
Average, mg/L
2
22
2.17
1.7
49.2
0.0110
0.08
1993/1994
Wastewater
Treatment Effluent
Data (10 refineries)
Median, mg/L
3
10
NA
NA
55.2
NA
0.08
2000 PCS
Concentration
Median, mg/L
4
12.71
3.54
1.28
71.50
0.018
0.026
EPA
Method
Number
5
160.2
1664
350.2
410.1
420.2
D4658
Baseline
Values, mg/L
6
4.0
5.0
0.05
5.0
0.05
1.0
Comparison to
Concentration Basis of
Existing Regulation or
Other Recently
Promulgated
Regulations, mg/L
101
5'
42
86 - 8563
O.I1
O.I1
Pollutants without Limitations at 40 CFR Part 419
Cyanide, total
Fluoride, total
Chlorine, total
residual
NA
NA
NA
0.007
NA
NA
0.01
NA
NA
0.014
3.8
0.082
335.2
340.1
4500
0.02
0.1
0.1
NR
NR
NR
NA - Not available.
NR - Not regulated.
Sources:
1. U.S. EPA, 1996Preliminary Data Summary, Table 4-4.
2. U.S. EPA, 1996 Preliminary Data Summary, Table 4-5, taken from BAT for Ontario Petroleum Refining Sector, August 1991.
3. API Comment, Table 4, 1993-94 data collected in conjunction with EPA/OSW.
4. Calculated using BOD5-associated flow, andPCSLoads2000 estimated annual mass discharge.
5 &6. U.S. EPA, Development Document for Centralized Waste Treaters (CWT) Point Source Category, Table 15-1. And for Total Residual Chlorine: U.S. EPA, Alternative
Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014). Office of Water. April 1999.
^PT/BAT-equivalent concentration for existing regulation (40 CFR Part 419) as listed in U.S. EPA, Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Petroleum Refining Point Source Category, April 1974.
2Monthly average ammonia limitation recently promulgated in Meats Subcategory (40 CFR Part 432).
'Monthly average COD limitation promulgated in 1998 for the Pharmaceutical Manufacturing Category (40 CFR Part 439).
-------
Section 7 - Petroleum Refining
Preliminary Data Summary
As part of the study described in EPA's 1996 Preliminary Data Summary (24),
EPA visited and collected effluent data from six refineries. Table 7-34 presents the range of
effluent concentrations collected from these refineries for selected conventional and
nonconventional pollutants. The data did not include cyanide concentrations.
EPA also obtained one-year average concentration data collected during Ontario's
Seven Refineries Study, conducted in 1989. Table 7-34 presents these average concentrations
(24).
API Comments
EPA received comments from API on the December 31, 2003 Notice of the
Preliminary Effluent Guidelines Program Plan for 2004/2005. API provided a set of petroleum
refining effluent data that were previously collected by its members in conjunction with EPA's
Office of Solid Waste (1). Data were collected from refineries that use activated sludge
treatment. Table 7-34 presents the median of the analytical results. The data did not include
concentrations for oil and grease, ammonia, or phenol.
Calculated PCS Concentrations
As described in Section 7.2.2, EPA used data reported to PCS to estimate annual
pollutant mass discharges. As further described in Section 7.5.2, EPA used PCS data to estimate
annual process wastewater flow rates. EPA assumed that flows from effluent outfalls with
limitations for BOD5 and/or ammonia (as nitrogen) were process-related. For each refinery
discharging conventional and nonconventional pollutants as reported to PCS (in pounds), EPA
estimated the pollutant concentration by dividing the mass discharged by the flow rate (and
correcting the units). Table 7-34 presents the range of estimated pollutant concentrations.
Baseline Values
Table 7-34 also presents baseline values for the conventional and
nonconventional pollutants to compare to the pollutant concentrations measured at petroleum
refineries. Section 7.8.3.2 describes baseline values in further detail.
Comparison of Concentrations
As shown in Table 7-34, with the exception of total suspended solids (TSS), the
median concentrations of conventional and nonconventional pollutants are below the
concentrations used as the basis for the limitations in 40 CFR Part 419. Median concentrations
of four pollutants (TSS, ammonia (as N),COD, and total fluoride) were above the baseline
values. The existing petroleum BPT/BAT limitations are based on wastewater equalization and
stormwater diversion, multistage oil and solids removal, biological treatment, and effluent
7-75
-------
Section 7 - Petroleum Refining
polishing. EPA did not identify any additional treatment technologies to further reduce
concentrations conventional and nonconventional pollutants in refinery wastewater.
Total Suspended Solids. Two of the six refineries visited as part of the 1996
Preliminary Data Summary had TSS concentrations in the final effluent above BPT/BAT levels.
Ninety-one petroleum refineries reported TSS to the 2000 PCS and 54 (59 percent) had TSS
concentrations in the final effluent above BPT/BAT levels.
Ammonia (as N). This pollutant contributes 3,581 TWPE to surface water
discharges from petroleum refineries. The current concentrations of ammonia (as N) are below
the monthly average ammonia limitation (4 mg/L) recently promulgated for the Meats and
Poultry Products Category (40 CFR Part 432).
Total Phenols. This pollutant contributes 7,336 TWPE to surface water
discharges from petroleum refineries. Petroleum refineries are currently achieving final effluent
concentrations less than baseline values and less than existing limits at 40 CFR Part 419.
Total Sulfides. This pollutant contributes 100,734 TWPE to surface water
discharges from petroleum refineries. Petroleum refineries are currently achieving final effluent
concentrations less than baseline values and less than existing limits at 40 CFR Part 419. Only
one of the six refineries visited for the 1996 Preliminary Data Summary exceeded the BPT/BAT
basis concentration for total sulfide.
Total Fluoride. This pollutant contributes 16,198 TWPE to surface water
discharges from petroleum refineries. Petroleum refineries are currently discharging
concentrations of total fluoride above the baseline value. EPA currently does not regulate this
pollutant for the petroleum refining industry.
Total Residual Chlorine. This pollutant contributes 25,357 TWPE to surface
water discharges from petroleum refineries. Petroleum refineries are currently achieving final
effluent concentrations less than the baseline value. EPA currently does not regulate this
pollutant for the petroleum refining industry.
7.9.2 Detailed Study Findings for Conventional and Other Nonconventional
Pollutants
Below is a summary of the findings of EPA's detailed study of refinery
conventional and nonconventional pollutants.
• Regulations at 40 CFR Part 419 establish limitations for all conventional
pollutants, except fecal coliform. EPA also established limitations for the
nonconventional pollutants ammonia as nitrogen, COD, total phenols, and
total sulfide.
7-76
-------
Section 7 - Petroleum Refining
• Using PCS data, EPA estimated that refineries discharged 45 million
pounds of conventional pollutants and 287 million pounds (159,315
TWPE) of nonconventional pollutants in 2000. Sulfide discharges from
70 refineries compose 63 percent of the TWPE (> 100,000 TWPE).
• EPA identified concentration data for TSS, oil and grease, ammonia as N,
COD, total cyanide, total phenols, and total sulfide from the 1996
Preliminary Data Summary (from EPA site visits and from the Canadian
study BAT for Ontario Petroleum Refining Sector (13)) and from data
supplied in API comments. In addition, EPA calculated concentrations
using PCS mass discharges and flow rates. With the exception of total
suspended solids, the median pollutant concentrations were below 40 CFR
Part 419 limitations or pollutant baseline values. Although certain
pollutants (e.g., sulfide) contribute the large majority of TWPE discharged
by petroleum refineries, the data demonstrate that refineries are currently
discharging nonconventional pollutants at concentrations at (or near)
treatable levels.
Therefore, based on the information for the detailed review, EPA concludes that
refineries are treating nonconventional pollutants to concentrations at or near treatable levels.
7.10 Pollution Control
Additional pollution reduction may include both pollution prevention and end-of-
pipe treatment, although as highlighted in the EPA Office of Compliance sector notebook,
Profile of the Petroleum Refining Industry: "Pollution prevention techniques are often more cost-
effective than pollution reduction through end-of-pipe treatment" (32). Wastewater pollution
prevention strategies are presented below. Additional opportunities in the area of general
operating and maintenance practices and procedures, and design revisions and modifications to
various refining processes are described in EPA's Profile of the Petroleum Refining Industry
(32), Washington Sate Department of Ecology's Water Pollution Prevention Opportunities in
Petroleum Refineries (37), and DOE Office of Energy Efficiency and Renewable Energy's
Water Use in Industries of the Future: Petroleum Industry (22).
• Process or equipment modifications:
— Reduce cooling tower blowdown by minimizing TDS in the
cooling water. This can be achieved by removing calcium
carbonate in the makeup water (or on a side stream of the cooling
tower recycle system) by cold lime softening, reverse osmosis, or
electrodialysis treatment. (32)
— Increase sensible heat transfer and therefore minimize evaporative
losses using improved cooling tower designs (22).
7-77
-------
Section 7 - Petroleum Refining
— Use high-pressure water to remove entrained solids from heat
exchanger bundles. Separate the solids at the source or use
antifoulants on the bundles to reduce scaling. (32)
— Limit surfactant use in cleaning operations; surfactants can
increase the generation of emulsions and sludges (32).
— Destroy dioxins in flue gases in a furnace firebox, or capturing in a
filter, rather than transferring them to scrubber water (37).
• Waste segregation:
— Segregate relatively clean runoff from process sewers, which
results in more efficient process wastewater treatment (32).
— Control solids entering sewers to reduce generation of oily sludges
(32).
• Material substitution:
— Use mercury-free caustic in FCC air emission scrubbers (32).
— Replace chromate-based anticorrosives with less toxic alternatives,
such as phosphates, in cooling towers and heat exchangers (32).
• Re-use:
— Reuse steam-stripped sour water or other treated wastewater as
desalter make-up (32). The steam-stripped sour water contains a
high concentration of phenolic compounds that are returned to the
crude when used as desalter water makeup (22).
— Slowdown from the steam systems including oily condensate may
be used as desalter water makeup (22).
— Reuse boiler blowdown, treated wastewater or stormwater runoff
as makeup water to the cooling tower (22).
— Use treated wastewater from off-site locations as makeup water.
7.11 Petroleum Refining References
1. American Petroleum Institute. Comments Re. Notice of Preliminary Effluent
Guidelines Program Plan. March 18,2004.
7-78
-------
Section 7 - Petroleum Refining
2. BP Oil Company. Water Samples for PCDD/PDCF for the BP Oil Company
Toledo Refinery, Performed by Batelle. November 9, 2000.
3. The County Sanitation Districts of Los Angeles County. Comments for the
Preliminary Effluent Guidelines Program Plan for 2004/2005. James F. Stahl.
Whittier, CA. March 5, 2004.
4. Eastern Research Group, Inc. Memorandum: Estimated PAC Concentrations for
the Petroleum Refining Industry. July 12,2004.
5. Eastern Research Group, Inc. Memorandum: Meeting Between EPA and
Representatives of American Petroleum Institute and National Petrochemical &
Refiners Association. DCN: 00809. February 16, 2004.
6. Eastern Research Group, Inc. Memorandum: Meeting Between EPA and
Representatives of Lyondell-Citgo Refining, LP. March 12, 2004.
7. Eastern Research Group, Inc. Toxic Equivalents for Dioxins Reported in 2000 to
TRI (Calculation Sheet). April 13,2004.
8. Eckenfelder, W. Wesley, Jr. Principles of Water Quality Management. CBI
Publishing Company, 1980. Page 491.
9. Gulf Coast Waste Disposal Authority (GC A). 2003 Peak Performance Award
Application.
10. GCA. Comments on the Notice of the Preliminary Effluent Guidelines Program
Plan for 2004/2005 (68 Fed. Reg. 75515, December 31, 2003), Docket Number
OW-2003-0074.
11. National Petrochemical & Refiners Association. Comments by the National
Petrochemical & Refiners Association (NPRA) on "Notice of Preliminary Effluent
Guidelines Plan, " Published on December 31, 2003 (68 FR 75515). Norbert Dee.
Washington, D.C. March 15, 2004.
12. Oil & Gas Journal. "2001 Worldwide Refining Survey." Volume 99.52.
December 24, 2001.
13. Ontario Ministry of the Environment. Best Available Technology Options for the
Ontario Petroleum Refining Sector. Municipal/Industrial Strategy for Abatement
(MISA) Program, ISBN 0-7729-9778-0. DCN 00398. August 1991.
7-79
-------
Section 7 - Petroleum Refining
14. Personal Communication, Chris Matthews, Lyondell-Citgo Refining, Houston,
Texas. February 26, 2004.
15. Personal Communication, Christopher Abshire, Lyondell-Citgo Refining,
Houston, Texas. March 2004.
16. Personal Communication, Gail Froiman, EPA Office of Environmental
Information. November 13, 2003.
17. Personal Communication, Nancy Kmet, Washington (State) Department of
Ecology. June 30, 2004.
18. Shell Oil Products U.S. Puget Sound Refinery. Diaxin Study Report (NPDES
Permit WA-000294-1). June 2004.
19. Tosco Refining Company Avon Refinery. Dioxin Source Investigation Pursuant
to Cease and Desist Order No. 95-151, Final Report. April 1, 1997.
20. U.S. Department of Energy (DOE). Petroleum Supply Annual 2000, Volume 1.
Energy Information Administration.
21. U.S. DOE. Refinery Capacity Data as of January 1, 2001. Data compiled from
EIA-820, "Annual Refinery Report," Energy Information Administration.
http://www.eia. doe. gov/oil_gas/petroleum/data_publications/refinery_capacity_d
ata/refcapacity. html
22. U.S. DOE. Water Use in Industries of the Future: Petroleum Industry. Office of
Energy Efficiency and Renewable Energy. Washington, D.C. July 2003.
23. U.S. Department of Health and Human Services. Report on Carcinogens, Tenth
Edition. Public Health Service, National Toxicology Program. December 2002.
24. U.S. EPA. 1996 Preliminary Data Summary for the Petroleum Refining Category.
DCN 00402. Washington, D.C. April 1996.
25. U.S. EPA. Alternative Disinfectants and Oxidants Guidance Manual. EPA-815-
R-99-014. Washington, D.C. April 1999.
26. U.S. EPA. Development Document for Centralized Waste Treaters (CWT) Point
Source Category. EPA-821-00-020. Washington, D.C. August 2000.
27. U.S. EPA. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Petroleum Refining Point Source
Category. October 1982.
7-80
-------
Section 7 - Petroleum Refining
28. U.S. EPA. Development Document for Final Effluent Limitations Guidelines and
Standards for the Metal Molding and Casting (Foundry) Point Source Category.
EPA-440-1-85-070. October 1985.
29. U.S. EPA. Emergency Planning and Community Right-to-Know Act Section 313
Guidance for Reporting Toxic Chemicals within the Dioxin and Dioxin-Like
Compound Category. EPA-745-B-00-021. December 2000.
30. U.S. EPA. Emergency Planning and Community Right-to-Know Act - Section
313: Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds
Category. EPA-260-B-01-03. August 2001.
31. U.S. EPA. Exposure and Human Health Reassessment of 2,3,7,8-TCDD and
Related Compounds. Draft Final Report. EPA-600-P-00-001Bb. September
2000.
32. U.S. EPA. Industry Sector Notebook: Profile of the Petroleum Refining Industry.
EPA-310-R-95-013. September 1995.
33. U.S. EPA. Memorandum: Toxic Weighting Factor for Petroleum Refining
Polycyclic Aromatic Compounds. DCN 00646. December 11, 2003.
34. U.S. EPA. PCSLoads2000. Engineering and Analysis Division, 2004.
35. U.S. EPA. TRIReleases2000. Engineering and Analysis Division, 2004.
36. Washington State Department of Ecology (WA DOE), Letter of Transmittal.
December 11, 2003 (DCN 00711): Tesoro Northwest study, May 2001; Cherry
Point Refinery study, July 2001; and U.S. Oil & Refining study, August 15, 2003.
37. WA DOE. Water Pollution Prevention Opportunities in Petroleum Refineries.
DCN 00405. November 2002.
38. Palmer, Breton, Nunno, Sullivan, and Surprenant. Metal/Cyanide Containing
Wastes: Treatment Technologies. Noyes Data Corporation, page 390. 1988.
7.12 Petroleum Bulk Stations and Terminals
7.12.1 Introduction
In conjunction with the detailed review of the Petroleum Refining category, EPA
also analyzed data associated with the Petroleum Bulk Stations and Terminals (PBST) Industry,
SIC code 5171. Because of similarity of operations and wastewater characteristics, EPA studied
PBSTs as a potential new subcategory of the Petroleum Refining category (40 CFR Part 419).
This Section builds upon EPA's earlier study of the industry titled Draft Profile of the Petroleum
7-81
-------
Section 7 - Petroleum Refining
Bulk Stations and Terminals (PBST) Industry, March 3, 2003, which can be found at the EPA E-
Docket. The earlier study is divided into several Adobe Acrobat files with Document ID
numbers OW-2003-0074-0494, OW-2003-0074-0495, OW-2003-0074-0496, and OW-2003-
0074-0497.
For this review, EPA verified TRI and PCS data from the year 2000, examined
comments to the Preliminary 2004/2005 Effluent Guidelines Plan, contacted state and regional
permitting and compliance authorities, conducted site visits, and met with industry groups in
order to consider possible pollution prevention and wastewater treatment methods for PBSTs.
7.12.2 Data Sources
This section describes the data sources EPA used for the PBST study. This
section also describes data quality limitations and verification activities. Section 4.2 of this
document provides a general description of TRI, PCS, and U.S. Economic Census data sources.
Section 4.2.4 discusses the calculation of toxic-weighted pound equivalents (TWPE) for certain
data sources. This section discusses data sources specifically as they pertain to the PBST
industry review.
7.12.2.1 Toxic Release Inventory
All PBST facilities with more than 10 employees that meet certain chemical
threshold criteria must report to EPA's TRI program. Of the 9,104 PBSTs operating in the
United States (1997 U.S. Census and other sources), 502 (5.5 percent) reported to TRI in 2000,
with only 167 (1.8 percent) reporting discharges to POTWs and surface waters of the United
States. As reported to TRI, the total estimated TWPE discharge in 2000 by PBSTs was 8,010
TWPE. Of the 167 PBST facilities reporting pollutant discharges to water, 125 discharged
wastewaters directly and 27 discharged indirectly through POTWs, with the remaining 15 being
both direct and indirect dischargers. The 125 solely direct dischargers accounted for 5,325
TWPE discharged, while the solely indirect discharging facilities discharged 8 TWPE. The 15
facilities that were both direct and indirect dischargers accounted for 2,677 TWPE discharged.
As with other industries studied, EPA used TRI information to estimate pollutant loadings and to
identify treatment technologies used within the industry. (1)
EPA reviewed TRI data, particularly for those facilities and pollutants which
contributed significantly to the total TWPE estimate. For example, facilities may estimate
releases in a number of ways, when reporting to TRI. If a chemical is not detected in the
effluent, facilities may estimate the discharge by using one-half of the detection limit. This may
overestimate the amount of chemical discharged.
Facilities report some chemical groups, including the 21 chemicals included in the
PAC category to TRI. Facilities are required to report the combined mass of PACs released.
They do not report releases of individual PAC compounds to TRI. For PBSTs, to calculate the
TWPE of PACs reported in TRI, EPA used the toxicity weighting factor (TWF) for
benzo(a)pyrene. See Section 4.4.4.3 for a more detailed discussion on PACs.
7-82
-------
Section 7 - Petroleum Refining
To verify the data reported to TRI, EPA performed the following activities:
• Confirmed that facilities reporting in SIC code 5171 were, in fact, PBSTs,
through, for example, contacts with the relevant permit writers; and
• Reviewed comments submitted in response to the December 31, 2003
Preliminary Effluent Guidelines Program Plan.
Facility Specific Verification of TRI Data
The PBST reporting the largest TWPE discharges in the 2000 TRI database is the
Coastal Oil of New England facility in South Boston, MA (NPDES ID MA0004405). The
facility's discharges totaled 3,290 TWPE, driven by PACs and other petroleum hydrocarbons.
These discharges total approximately 40 percent of the total TRI reported TWPE discharges for
2000. Through contact with Region 1, EPA learned that Coastal Oil ceased operations in 2000
(2). Since EPA's baseline for the industry's review was 2000, Coastal Oil's data are still in
EPA's description of the industry. Nevertheless, the facility's current status significantly
influenced EPA's final decision regarding effluent guidelines development for the industry.
Comment Received on the 2004/2005 Preliminary Effluent Guidelines Program
Plan Pertaining to TRI
EPA received one facility-specific TRI-related comment from ConocoPhillips
relevant to PBSTs. ConocoPhillips noted that its Kansas City Terminal, which reported
discharges of more than 2,600 TWPE and ranked second in TWPE discharged in 2000, is co-
located with the Kansas City Refinery, and shut down in 1983. Site remediation of the old
refinery site includes groundwater remediation and discharge under an NPDES permit held by
the Kansas City Terminal. ConocoPhillips asserted that the discharge of the treated groundwater
accounts for the toxic discharges reported by the facility, as no process wastewater is discharged
by the terminal and the only discharge associated with the terminal was stormwater.
ConocoPhillips concluded by stating that the Kansas City Terminal's discharge of wastewater
associated with site remediation should be eliminated from EPA's consideration of effluent
guidelines for PBSTs.
After excluding the Kansas City Terminal's discharges from the PBST TWPE,
ConocoPhillips explained that 61 percent of the TWPE discharge came from one facility and 94
percent from three facilities. Therefore, EPA should develop individual permits rather than
national categorical ELGs.
Commenters also provided general comments on the TRI data itself. The
Independent Liquid Terminals Association stated that TRI data show toxic discharges from
PBSTs are minuscule, and five facilities accounted for 97 percent of the TWPE discharges. The
American Petroleum Institute (API) noted that only six facilities in TRI reported the discharge of
PACs, accounting for 99 percent of the industry's estimated TWPE discharges. In addition, API
noted that 85 percent of the TRI TWPE discharges were due to two facilities in Massachusetts.
7-83
-------
Section 7 - Petroleum Refining
7.12.2.2 Permit Compliance System
States may submit data from PBSTs' discharge monitoring reports (DMRs) to
PCS. The data from each DMR will vary depending on the PBST's NPDES permit
requirements. Refineries that discharge to a POTW, or that transfer their wastewater to a private
waste treater, do not submit DMRs; therefore, their data are not in PCS. In addition, PCS
typically does not include data for refineries that states classify as "minor sources." Of the 9,104
PBSTs operating in the U.S. in 2000, data from eight (0.1 percent) PBSTs were included in the
2000 PCS. These eight facilities discharged 5,389 TWPE in 2000, with two reporters, Exxon
Mobil's terminals in East Provide, RI (NPDES ID RI0001333) and Everett, MA (NPDES ID
MA0000833) accounting for more than 99 percent of the reported TWPE discharges. (1)
To verify the data reported to PCS, EPA performed the following activities:
• Confirmed that facilities reporting in SIC code 5171 were, in fact, PBSTs,
through, for example, contacts with the relevant permit writers and cross-
checks with other databases; and
• Reviewed comments submitted in response to the December 31, 2003
Preliminary Effluent Guidelines Program Plan.
Facility Specific Validation of PCS Data
One of the eight PCS major facilities identified early in the screening process was
Lyondell Chemical Company in Texas (NPDES ID TX0069493). EPA's contacts with the Texas
Commission on Environmental Quality's (TCEQ) water permits office suggested that the facility
was not, in fact, a PBST. EPA examined the Enforcement and Compliance History Online
(ECHO) database, which reported that the facility was a PBST. EPA then reviewed the facility's
TRI reports from 1997 to 2001 and the only reported SIC codes were 2865 and 2869. Given
what EPA learned from TCEQ and older TRI reports, EPA concluded that the facility was not a
PBST. As a result, EPA removed the PCS loads for Lyondell Chemical Company from the
PBST industry's total loadings.
A similar discovery was made regarding the Texaco Guayanilla Terminal
(NPDES ID PR0021024). As with the Lyondell Chemical facility, EPA concluded after cross-
checking ECHO and the TRI reports from 1997 to 2001 that the facility was not a PBST. EPA,
thereafter, removed its contribution to the 2000 PCS loadings for the PBST industry.
Comment Review
EPA received no PCS-related data from commenters and no comments from
facilities requesting corrections to 2000 PCS data.
As with respect to the 2000 TRI data, however, commenters did address the PCS
data itself. ILTA stated that, of the PCS majors, only two PBSTs discharge large amounts of
7-84
-------
Section 7 - Petroleum Refining
toxic organics and that both facilities are listed among the TRI reporting facilities. In addition,
they asserted that these two facilities represent only 0.00187 percent and 0.0005 percent,
respectively, of the total TRI loadings of 8,010 TWPE. As a result, they concluded that the toxic
releases from those facilities are trivial.
API also addressed the PCS data by noting that, since only eight facilities are
major dischargers, the majority of the industry is made up of minor dischargers. Moreover, they
noted that the PCS data for major facilities show average discharge concentration of 16.9 mg/L
of total conventional pollutants, 48 mg/L for total nonconventional pollutants, and 0.068 mg/L
for total priority pollutants. API asserted that these concentrations are very low and reflect very
effective wastewater treatment and low pollutant discharges. Finally, API concluded by stating
that these effluent concentrations indicated that individual effluent discharges do not present a
potential risk to human health and the environment.
7.12.2.3 Other Data Sources
EPA also collected data from several other sources, listed below:
• Contacts ~with regional and state permitting and compliance authorities -
EPA contacted control authorities in the regions and states that contained
the largest dischargers reporting to the 2000 TRI and PCS databases. EPA
inquired about permitting issues for the industry, wastewater
characteristics, how the industry handles its wastewater, and industry
trends (3);
• Contacts ~with treatment technology vendors - EPA contacted treatment
technology vendors to gather information on new options to reduce
pollutant concentrations in PBST wastewater;
• Industry-provided information/comments - In response to the December
31, 2003 notice of the Preliminary Effluent Guidelines Program Plan, EPA
received comments from ILTA, API, the Regional Citizens' Advisory
Council for Prince William Sound (RCAC), Alyeska Pipeline, the
Petroleum Marketers Association of America (PMAA), the New England
Fuel Institute, the Independent Fuel Terminal Operators Association
(TFTOA), the Department of the Navy, Amerada Hess Corporation, and
ConocoPhillips.
• Site visits - EPA conducted site visits at two PBSTs, one at
ConocoPhillips's Manassas, VA facility and one at Petroleum Fuel &
Terminal Company's facility in Baltimore, MD.
• Industry/trade association meetings - EPA met with API and the
Department of the Navy and several trade groups, including ILTA and
PMAA (4).
7-85
-------
Section 7 - Petroleum Refining
7.12.3 Industry Description
The PBST industry is one part of the petroleum production, refining, and
distribution system. These facilities are categorized by SIC code 5171 Wholesale Trade -
Nondurable Goods, Petroleum Products, Petroleum Bulk Stations and Terminals. The PBST
industry comprises establishments primarily engaged in the wholesale distribution of crude
petroleum and petroleum products from bulk liquid storage facilities. Petroleum products
handled by PBSTs include crude oil, gasoline, aviation gasoline, jet fuel (JP-4), diesel fuel, fuel
oil, kerosene, naphtha, and lubricating oils. Specific types of PBSTs include:
• Bulk gasoline stations;
• Bulk petroleum stations;
• Crude oil terminals;
• Fuel oil bulk stations and terminals;
• Gasoline bulk stations and terminals;
• Heating oil dealers;
• Liquified petroleum gas (LPG) bulk stations and terminals;
• Lubricating oils and greases bulk stations and terminals; and
• Oil, petroleum, and petroleum products bulk stations and terminals.
Bulk stations and terminals are part of the wholesale trade industry sector.
Wholesale is an intermediate step in the distribution of the crude petroleum and petroleum
products. The wholesale industry sells or arranges the sale of crude petroleum and petroleum
products for resale by other wholesalers or retailers or for further production (intermediate
materials). Establishments that sell crude petroleum and petroleum products directly include
wholesale merchants, distributors, jobbers, drop shippers, import/export merchants, and sales
branches. Establishments that arrange for the sale of crude petroleum and petroleum products
(on a commission basis) include agents and brokers, commission merchants, import/export
agents, and representatives of brokers, auction companies, and manufacturers. One commenter
to the Preliminary Plan, ILTA, also noted that some PBSTs lease the use of their tanks to
customers who own the stored product.
7.12.3.1 Industry Groups
Several groups represent facilities in SIC code 5171, many of whom commented
on the Preliminary Plan. API represents the major oil companies and wholesale terminals, with
about 400 members. PMAA is an umbrella organization representing small, independent bulk
station owners and has 44 state and regional trade associations as members, representing about
8,000 marketers nationwide. PBSTs represented by PMAA typically have capacities ranging
from 30,000 to 150,000 gallons. ILTA, another trade association, represents approximately 75
companies of all sizes, with about 500 facilities.
7-86
-------
Section 7 - Petroleum Refining
7.12.3.2 Industry Statistics
According to the 1997 Economic Census (Census), there are 7,690 PBSTs
(defined under North American Industrial Classification System (NAICS) code 422710), 813
heating oil dealers (NAICS code 454311), and 601 LPG dealers (NAICS code 454312). SIC
code 5171 includes all three NAICS codes, for a total of 9,104 facilities. In order to eliminate
confusion, from this point onward, all 9,104 facilities will be referred to as 'PBSTs' in this
report, unless otherwise noted. The Census data include statistics for three types of facilities:
• Merchant wholesalers - manufacturing sites that sell their own products;
• Manufacturers' sales branches and sales offices - offices that sell products
manufactured in the United States by their parent company; and
• Agents, brokers, and commission merchants - agents and brokers sell
products from offices but do not handle or own the products; commission
merchants sell and handle products on a consignment basis but do not own
the products.
A majority (60 percent) of PBSTs have less than 10 employees and 99 percent
have less than 100 employees. Over 90 percent of the facilities are corporations, with the
remaining consisting of proprietorships and other entities.
The following table presents the geographical distribution of PBSTs (NAICS
code 422710) reporting to the Census. Table 7-35 shows the petroleum storage capacity for the
top 10 U.S. states, which account for over 50 percent of the total US. storage capacity. Similar
data are unavailable for the 1,414 heating oil and LPG dealers.
7-87
-------
Section 7 - Petroleum Refining
Table 7-35. Geographic Distribution of PBSTs, per 1997 Economic Census
State
Texas
California
Louisiana
Missouri
North Carolina
Florida
Georgia
Illinois
Ohio
Indiana
EPA
Region
6
9
6
7
4
4
4
5
5
5
Total for Top 10 States
Total for All States
Bulk Stations
(except LPG)
598
359
230
262
233
194
215
217
168
169
2,645
6,045
Bulk Terminals
(except LPG)
120
103
42
15
31
52
45
33
47
33
521
1,225
LPG Bulk
Stations and
Terminals
44
24
11
4
10
26
12
14
9
16
170
420
Total
762
486
283
281
274
272
272
264
224
218
3,336
7,690
PBSTs range in size from about 10,000 gallons to in excess of one million
gallons, with the New England Fuel Institute noting in its comments to the Preliminary Plan that
PBSTs typically handle on the order of 50,000 gallons of refined petroleum products. PBSTs
may be co-located with refineries and may be located along coastlines to accept and treat large
volumes of ballast water. Independent facilities are also reported to be widespread, with ILTA
reporting that it represents approximately 500 facilities in the United States and 39 other
countries (their American membership was not specified). PMAA, in its comments to the
Preliminary Plan, reported that its membership of 44 state and regional trade associations
represented nearly 8,000 independent petroleum marketers. The New England Fuel Institute
asserted that it represented more than 1,000 stand-alone facilities not associated with any
refinery. Along with privately operated PBSTs, the Federal Government operates bulk terminals
as well. The Department of the Navy reported in an information submission to EPA that it
operates 18 PBSTs across the United States (no facility, tank, or wastewater volumes were
provided). In addition, in its comments to the Preliminary Plan, the Department of the Navy
suggested that a more appropriate volume threshold for PBSTs would be between 50,000 or
100,000 gallons, noting that the definition for SIC code 5171 often encompasses the size of
individual tanks at many Department of Defense facilities that serve as mobile fueling stations.
7.12.3.3
Discharge Status
EPA determined the discharge status of the PBST industry using TRI and PCS
data. Table 7-36 lists the discharge status for PBSTs operating in the United States during 2000
and reporting to TRI or PCS.
-------
Section 7 - Petroleum Refining
Table 7-36. Facilities Reporting to TRI and PCS in 2000 and Their Discharge Status
Database
TRI
PCS
Facilities
Reporting
502
8
Facilities Discharging
to Water
167
8
Direct
Dischargers
125
8
Indirect
Dischargers
27
-
Direct and Indirect
Dischargers
15
-
In the PCS data system, facilities may be classified as major or minor dischargers.
States are not required to provide discharge data for minor facilities to PCS, so reports for minor
facilities are incomplete. For this reason, EPA did not use data from minor facilities in this
review and did not include them in the pollutant loadings estimates.
This table indicates that the vast majority of PBSTs do not discharge wastewater
to waters of the United States.
7.12.3.4
Overview of Operations and Potential Wastewater Sources
The main function of PBSTs is to collect, store, and/or distribute product within
the petroleum industry. As part of these operations, PBSTs may also perform tank cleaning,
vehicle and equipment washing and maintenance, hydrostatic testing, product heating, and
blending operations (i.e., adding additives to petroleum products). The product is collected from
refineries or preliminary gathering stations and terminals using three means: pipelines, water
transport, and rail transport. Pipeline systems are believed to be the most common, transporting
the greatest volume of product nationwide through pipes of various sizes and capacities. Barges
with divided sealed compartments transport product on rivers, canals, lakes, and oceans.
Although not as common, rail transport is also a means of product delivery. Rail tank cars are
often used for low-volume products (e.g., chemicals and lubricants) and typically have capacity
for 20,000 to 40,000 gallons. PBSTs off-load materials and store the product in above ground
storage tanks7 (ASTs) until distribution by tank trucks to service stations or other industrial and
commercial operations.
Product Transfer Operations
The two main processes occurring at PBSTs are product collection and product
distribution. Because product transfer areas and loading/unloading racks are areas susceptible to
product leaks and spills, which could lead to violations of EPA's Spill Prevention, Control, and
Countermeasures (SPCC) rules, they are specifically designed to minimize environmental
release. They have sloped concrete floors that drain into a spill containment system and
canopies that minimize rainfall entry into the transfer area. These precautions prevent accidental
Underground storage tanks (USTs) may be used for loading rack spill containment and drainage systems. An UST
system is a tank (or combination of tanks) and connected piping having at least 10 percent of their combined volume
underground. UST regulations apply only to underground tanks and piping storing either petroleum or certain
hazardous substances. EPA's Office of Underground Storage Tanks (OUST) web site provides further regulatory
information. These regulations do not apply to ASTs.
7-89
-------
Section 7 - Petroleum Refining
spills from spreading beyond the transfer areas and minimize stormwater contact with product
residues on the loading/unloading racks, thereby minimizing the volume of contaminated water
in the spill containment system. Even with these precautions in place, most facilities also
incorporate stormwater tank basins (i.e., stormwater collection tanks) with the capacity to
contain any contaminated stormwater resulting from an accidental overflow or equipment
failure.
Loading equipment such as piping, valves, and fittings are designed to be
compatible with the type of product being handled and durable enough to withstand the stress of
pressure and exposure to the elements. The pumps and loading devices are designed to allow
appropriate flow of the type of product being transferred. Trained personnel or an automatic
control system (or both) minimizes the spills and overflows that occur during product transfer.
Product Collection
PBSTs that receive product by pipeline use a network of pipes equipped with
valves and pumps to transfer the product into storage tanks. Although the overall percentage of
PBSTs receiving their products by pipeline was not known at the time of this report, a survey of
57 PBSTs conducted by API in 1988, showed that 63 percent received product by pipeline.
Barges and tankers delivering product are usually equipped with high-volume
pumps and hoses for transferring product into the storage tanks via fill nozzles. Safe pressure is
maintained during product transfer using bypasses or relief valves. The results of the 1988 API
survey show that approximately 30 percent of facilities receive product from barges or tankers .
Rail tank car transfers take place in loading/unloading racks equipped with filling
hoses or pipes that can be connected directly from the rail car to the storage tanks. Pressure
relief systems are provided for the pumping system and the rail car itself. Rail tank cars are
typically used to deliver more viscous products, such as lube oil; therefore, only a small portion
of PBSTs typically receive product this way.
Product Distribution
Product is distributed from the storage tanks to service stations or other end-use
facilities using tank trucks. Tank trucks typically have capacity for 5,000 to 12,000 gallons.
Tank truck transfers occur in loading/unloading racks equipped with filling hoses or pipes and
pump islands between the truck bays. Product can be transferred from the storage tank to the
tank trucks using either top loading or bottom loading methods. There are two types of top
loading methods: splash loading and submerged fill pipe loading. Significant turbulence and
vapor/liquid contact occur during the splash loading method because the fill pipe dispensing the
cargo is lowered only part way into the cargo tank. Liquid turbulence is relatively controlled
during submerged loading because the fill pipe extends almost to the bottom of the cargo tank.
The level of vapor generation and loss during submerged fill pipe loading is therefore much less
than during splash loading. Top loading is most applicable for distillate products and asphalt
7-90
-------
Section 7 - Petroleum Refining
(more viscous products), and is discouraged for flammable liquids due to the potential to
generate more vapors.
PBSTs most commonly use the bottom loading method because of reduced air
emissions and improved safety. When product enters from the bottom of the tank, liquid
turbulence, and therefore air emissions, are minimized. Furthermore, most bottom loading
systems have vapor recovery systems in place to capture vapors and pipe recovered product back
to the storage tank or to a thermal oxidation unit where the vapor is combusted. Approximately
10 to 30 percent of the displaced vapors never reach the recovery system due to collection
system leaks; however, 90 to 99 percent of the product in the vapors that reach the vapor
recovery system is recovered.
Product Storage
Between the product collection and distribution processes, the product is stored.
PBSTs typically store product in vertical ASTs. Vertical tank storage capacities range from 500
to 300,000 barrels (bbls), or 21,000 to 12.6 million gallons. PBSTs also use horizontal tanks, or
drums, for low-volume storage. For example, horizontal tanks are often used to store gasoline
additives.
Depending on the volume and type of product stored, facilities use vertical tanks
with a variety of roof designs and bottom constructions. Tank roofs can be fixed or floating, and
tank bottoms can be cone-shaped, crown-shaped, or flat.
To control air emissions and to prevent product losses, product contamination,
and fires, vertical tanks are equipped with one of the following roof types:
• Fixed roof - cover attached to the top of the tank, usually cone- or dome-
shaped; includes a breather valve that allows the tank to operate at a slight
internal pressure or vacuum;
• Fixed roof with internal floating roof - attached cover and internal roof
that floats on the surface of the petroleum, rising and falling with the
liquid level;
• Fixed roof with vapor recovery system - attached cover where volatile
emissions (vapors) are captured and recovered;
• External floating roof- roof floats on the surface of the petroleum, rising
and falling with the liquid level; and
• External floating roof with weather covers (aluminum domes) - cover is
not attached to the tank, but provides additional protection.
7-91
-------
Section 7 - Petroleum Refining
Tanks with fixed roofs are closed vessels, and stormwater cannot typically enter
these tanks. However, when product is placed in a fixed-roof tank, air must be released and
treated to allow room for the product and prevent the tank from building too much internal
pressure. Conversely when product is removed from a fixed-roof tank, air must be pumped in to
fill its place and prevent the tank from collapsing. Fixed roof tanks are therefore a potential
source of air emissions, but not water emissions.
Although floating roof tanks do not require removing and adding air during
product transfer, they are more likely to allow stormwater to enter. Most of the stormwater
collecting on the tank roof is drained through a tank drain; however, during heavy precipitation,
or if a drain clogs, water may penetrate the roof seal and enter the tank. Floating roof tanks are
therefore a contributor to the generation of tank bottom water, a source of contaminated
wastewater.
Tank bottom water is not typically present at PBSTs in large volumes, but it is
believed to be the major source of dissolved contaminants. Because there is much more product
than water in a storage tank, the water can become highly concentrated with water-soluble
materials in the product. The most common pollutants and bulk parameters/indicators in tank
bottom water are as follows:
• Oil and grease;
• Total petroleum hydrocarbons (TPH);
• Biochemical oxygen demand (BOD);
• Chemical oxygen demand (COD);
• Total organic carbon (TOC);
• Ammonia;
• Total suspended solids (TSS);
• Phenols;
• Total dissolved solids (TDS);
• Naphthenic acids;
• Aromatics: benzene, toluene, ethyl benzene, and xylene (BTEX); and
• Surfactants.
The volume of tank bottom water generated is facility specific and depends on
several factors such as number of tanks, tank volumes, the amount of precipitation, the products
handled, and the temperature. Commenters and the industry noted that, since no general
canvassing of the industry has ever been performed, estimating tank bottoms water volume is
very difficult. In its 1988 study, API estimated that a moderate-size PBST has seven large
storage tanks (100 foot diameter), and that one inch of water will accumulate in the bottom of the
tank during a typical year. This converts to approximately 655 cubic feet of water (roughly
5,000 gallons) per year. If the concentration of a particular pollutant is 10,000 mg/L (0.084
pounds of pollutant per gallon of tank bottom water), almost 3,000 pounds of the pollutant needs
treatment at the facility annually (approximately 420 pounds per tank). Most PBSTs will not
attempt to handle this load all at once, and, in some cases, control authorities report that PBSTs
7-92
-------
Section 7 - Petroleum Refining
will, instead, draw the tank bottom water into an equalization tank and then gradually feed the
water through a wastewater treatment system.
Many commenters to the Preliminary Plan noted that PBSTs often ship their tank
bottoms water off site for treatment. Amerada Hess, PMAA, and the New England Fuel Institute
stated that facilities will often send their wastes to others for treatment. In addition, ILTA and
the County Sanitation Districts of Los Angeles County also noted that some PBSTs send their
tank bottoms to refineries for reclamation of their petroleum fractions.
Tank Cleaning
Although not a frequent process at PBSTs, tanks are occasionally cleaned to
remove accumulated sludge and residual product. While not usually emptied specifically for
cleaning purposes, a storage tank may be cleaned if it is emptied for maintenance or if it is
needed to store a different product. Tank cleaning requires removing and disposing of
accumulated sludge, recovery and/or treatment of any tank bottom water, and treating of any
detergents used for cleaning.
Vehicle and Equipment Washing and Maintenance
Vehicles and other product transferring equipment are sometimes washed on site
at a designated area, resulting in wastewater contaminated with detergents and a small amount of
product. Facilities handle this wastewater separately from other process wastes because of the
potential to form emulsions when detergents and oil are mixed. Vehicle and equipment
maintenance is also occasionally done on site, resulting in wastewater containing oil, antifreeze,
brake fluid, or other vehicle fluids. This wastewater is also handled separately from other
process wastes.
The percentage of PBSTs expected to use detergents to wash vehicles or
equipment or to use brake fluid, antifreeze, lubricants, and other oils onsite for vehicle and
equipment maintenance could not be estimated, given the data collected from industry and
control authorities. As a result, an estimate of contributions toward total wastewater generation
is not possible to make. However, of interest is Amerada Hess's comment to the Preliminary
Plan stating that, of the nonstormwater component of PBST wastewaters, equipment and vehicle
washing and maintenance waters are a primary fraction.
Hydrostatic Testing
Equipment at PBSTs is periodically checked for leaks by hydrostatic testing.
This process involves filling the pipes or tanks with water, applying pressure, and searching for
leaks. A high volume of water is discharged at the completion of the testing. Clean hydrostatic
test water is discharged directly to a storm drain, but if hydrostatic test water is contaminated
with product from the storage equipment, it typically undergoes treatment before it is discharged.
7-93
-------
Section 7 - Petroleum Refining
Neither control authorities nor commenters were able to provide any data to
establish the volume of this type of flow. Amerada Hess and the County Sanitation Districts of
Los Angeles County identified this as a possible contributor to PBSTs waste streams, but did not
provide numerical data.
Product Heating
A PBST that stores heavy products (e.g. asphalt) needs to keep the product hot to
maintain its fluidity. Steam coils placed in the product tank can heat the product with steam
generated by a boiler. Most boiler feed water contains bicarbonate ions, resulting in the
formation of acidic steam (carbon dioxide dissolves in condensed steam to make carbonic acid).
The steam condensate is therefore corrosive and necessitates the use of chemicals, typically
amines, to control the corrosion. As a result, amines may be present in the boiler wastewater
stream. If the amines are not used and the steam coils corrode, steam may leak into the tank,
come into contact with product, and become a source of tank bottom water.
Ballast Water Handling
PBSTs located along coastlines often also off-load ballast water from tankers
transporting petroleum products, resulting in wastewater that is often contaminated with product.
These wastewaters are normally rather dilute and very large in volume and usually undergo
treatment before discharge. EPA is aware of one PBST that handles large volumes of ballast
water as a result of comments submitted to the Preliminary Plan by Alyeska Pipeline and RCAC.
Alyeska's facility treats and discharges approximately 10 million gallons per day of oily (0.5 to
1.0 percent oil) ballast water. The facility treats the wastewater with oil/water separation,
dissolved air flotation, biological treatment, and, as needed, polishes with air stripping. The
effluent concentration of oil and grease is typically 3-5 mg/L.
Wastewater Remediation Activities
Soil and/or groundwater under a PBST may be contaminated as a result of past
terminal operations, current operations, or off-site contamination that has migrated on site.
Groundwater is typically contaminated with dissolved hydrocarbons and is pumped to the
surface, treated, and discharged. Soil may have total petroleum hydrocarbon contamination,
requiring air sparging or soil washing. Control authorities in New England pointed to this as a
widespread problem at PBSTs in their part of the U.S., though were unable to estimate
wastewater flows as a result. In the case of New England PBSTs, many are very old and may
have inadequate and compromised tanks. As a result, in many areas, mobile petroleum
hydrocarbons like MTBE may find their way into the groundwater, rendering a need for
remediation (5). As a consequence of these remediation activities, many PBSTs in the Northeast
are moving to include granular activated carbon as a polishing step in their treatment systems.
7-94
-------
Section 7 - Petroleum Refining
Stormwater
Stormwater is defined as the portion of precipitation that becomes surface runoff
(precipitation minus percolation and evaporation). The amount of Stormwater generated at a
PBST is dependent on several variables, including the size of the site (and more specifically the
size of the process area), climatic conditions (taking into account spatial and temporal
considerations), and the extent of pollution prevention practices in place to minimize the
contamination of Stormwater. Although most facilities use covered loading/unloading racks and
geographical barriers (e.g., berms) to avoid contact between Stormwater and contaminants in the
process area, Stormwater remains an issue for PBSTs because it represents the greatest volume of
wastewater generated at most facilities. According to API's 1988 study, the average amount of
Stormwater generated annually per site (where more than 75 percent were less than 20 acres, and
the remaining 25 percent were larger, typically covering 60 to 80 acres) was 20 million gallons.
API also attempted to quantify the average amount of Stormwater at PBSTs of
varying size and location, using the following assumptions: precipitation ranges from 10 to 50
inches per year, 100 percent of precipitation is runoff (no percolation or evaporation), and
PBSTs occupy between 2 and 20 acres. Using these assumptions, API calculated that the
smallest PBSTs (2 acres) in the driest regions (10 inches net precipitation annually) incur
approximately 0.54 million gallons of Stormwater per year, and the largest PBSTs (20 acres) in
regions with the most precipitation (50 inches of net precipitation annually) experience
approximately 27 million gallons of Stormwater per year. Accordingly, the volume of
Stormwater is very site specific and year specific.
Although Stormwater discharge volumes are site-specific, many commenters on
the Preliminary Plan noted the overwhelming contribution of Stormwater to PBST wastewater
flows. Amerada Hess noted that Stormwater runoff is the primary wastewater source at PBSTs,
at nearly 95 percent of total wastewater discharge. The New England Fuel Institute stated that
the only discharge from its member facilities to surface water is Stormwater. IFTA, in its
comments, asserted that PBSTs only discharge rainwater containing no more than trace amounts
of oil, grease, and other pollutants.
Contaminated Stormwater
Stormwater that has come into direct contact with product (e.g., runoff from
contaminated surfaces or loading/unloading racks) is contaminated, and therefore collected and
treated before being discharged. API estimated that 0.6 percent of all Stormwater (3,200 to
162,000 gallons per site annually, using the estimated volumes of 0.54 million gallons and 27
million gallons of Stormwater per year) is contaminated.
Not all facilities have sufficient wastewater treatment facilities on site, and must
send this contaminated Stormwater off site to adjoining refineries, to waste disposal companies,
or to regional treatment centers for treatment. Even if the Stormwater is clean as it enters a tank
basin, it may become contaminated in the event of an accidental product leak or spill into the
basin. Facilities may treat this contaminated water by removing the floating oil alone, or may
7-95
-------
Section 7 - Petroleum Refining
need to remove dissolved contaminants, depending on the extent of contamination and the permit
and/or POTW requirements. Floating oil is removed with floating skimmers or rope skimmers
before any water is drained. Basin water containing dissolved contaminants is removed from the
basin and treated as soon as possible to prevent migration of the contaminants to soil or
groundwater (especially if the basin is comprised of permeable soil). Some PBSTs pump the
contaminated basin water to a storage tank reserved for such situations. Other PBSTs may not
have a spare storage tank onsite and instead pump the contaminated basin water into the bottom
of a product tank for temporary storage.
Uncontaminated Stormwater
Stormwater that has not come into contact with product is said to be
uncontaminated. If a facility determines that Stormwater from a particular area onsite (i.e., the
facility yard) has relatively no chance of contamination, it typically discharges the Stormwater
without collection and treatment, unless required by an NPDES or other discharge permit. API
estimated that 98.3 percent of all Stormwater (0.53 to 26.5 million gallons per site annually,
using the best case and worst case volumes calculated above) is classified as having little chance
of contamination because it runs over uncontaminated areas such as lawns, driveways, building
roofs, parking lots, or undeveloped land.
If a facility determines that Stormwater (or any other wastewater) collected in a
tank basin is "clean" (i.e., has not come into contact with product or other contaminants), it can
be discharged separately to a POTW or surface waters without treatment, or it can be combined
with other treated wastewaters prior to discharge. Direct discharge to surface waters tends to be
the easier and cheaper option if the water can be gravity drained to the final outfall. However, if
the water must be pumped out of the facility, it is typically more cost effective to combine it with
other treated waste streams for discharge to a POTW.
7.12.4 Regulatory Background
At this point in time, no national effluent guidelines regulate the discharge of
pollutants from PBSTs. There are, however, several other EPA regulations that PBSTs have to
comply with, and they are as follows:
• Clean Water Act Requirements;
• Clean Air Act Requirements;
• Resource Conservation and Recovery Act Requirements;
• Emergency Planning and Community Right-to-Know Act Requirements;
• Safe Drinking Water Act Requirements; and
• Regional and State Programs.
The following sections summarize these regulations.
7-96
-------
Section 7 - Petroleum Refining
7.12.4.1 Clean Water Act
PBSTs that discharge or have the potential to discharge wastewater containing
regulated pollutants or other wastes (e.g., process wastewater, secondary containment water, and
stormwater) must operate under the terms of federal, state, and/or local permits which include
NPDES permits or POTW pretreatment agreements. These permits typically require wastewater
monitoring, including amount of water volume discharged and generalized wastewater
parameters (e.g., pH or specific pollutant concentrations).
In response to the 1987 CWA amendments, EPA established a program to address
stormwater discharges. EPA developed NPDES stormwater permit application regulations to
control the discharge of stormwater associated with an industrial activity (i.e., stormwater
discharge directly related to manufacturing, processing, or raw material storage areas) (40 CFR
Part 122.26(b)(14)). These regulations apply to stormwater from one of the 11 industrial activity
categories defined at 40 CFR Part 122.26. 40 CFR Part 122.26(b)(14)(viii), listing transportation
facilities of various types specifically lists facilities classified as SIC code 5171.
NPDES stormwater regulations require regulated facilities to obtain coverage
under a NPDES stormwater permit and implement stormwater pollution prevention plans
(SWPPPs) or stormwater management programs to effectively reduce or prevent the discharge of
pollutants into receiving waters. Both the SWPPPs and stormwater management programs use
best management practices (BMPs).
According to the U.S. EPA Integrated Compliance Information System (ICIS)
retrieval component, the Online Tracking Information System (OTIS), over 700 facilities
classified as SIC code 5171 have NPDES permits. NPDES permits for PBSTs usually regulate
the discharge of oil and grease, naphthalene, toxicity, benzene, toluene, ethylbenzene, and
xylene.
SPCCPlan
The SPCC rule (40 CFR Part 112) requires certain facilities to develop and
implement oil spill prevention, control, and countermeasure plans. As part of the SPCC plan,
facilities must install containment systems and other countermeasures to prevent oil spills from
reaching navigable waters. If a facility is unable to provide secondary containment (e.g., berms
around storage tanks), facilities must develop a spill contingency plan as part of the SPCC plan.
On July 17, 2002, EPA issued a final rule to amend the Oil Pollution Prevention
regulation, specifically addressing requirements for SPCC plans. Changes to the SPCC rule
include eliminating duplicate regulation, exempting certain small facilities and most wastewater
treatment facilities, and requiring consideration of industry standards in prevention plans.
Industry standards represent good engineering practice and generally are environmentally
protective. Under the SPCC rule, EPA allows permit writers to apply industry standards where
the standards are both specific and objective and their application may reduce the risk of
discharges to and impacts to the environment. EPA allows the application of industry standards
7-97
-------
Section 7 - Petroleum Refining
due to technology advances and resulting specific standard changes. However, if industry
standards change in a way that would increase the risk of discharge, EPA will apply and enforce
standards and practices that protect the environment, rather than the less protective industry
standard. Industry standards that may be used for the SPCC rule have been developed by
organizations listed in the July 17, 2002 Federal Register, 67 FR 47058 (40 CFR Part 112). The
changes to the SPCC rule are expected to reduce regulatory burden by approximately 55,000
facilities (40 percent).
The revised SPCC rule applies to PBST owners and operators with the following
exemptions:
• Completely buried storage tanks subject to all of the technical requirement
of the Underground Storage Tank (UST) regulations (40 CFR Part 280,
281);
• Portions of facilities used exclusively for wastewater treatment;
• Storage containers of less than 55 gallons (de minimis container size); and
• Aboveground storage tanks (ASTs) with capacity of 1,320 gallons or less
(replacing the 660-gallon threshold).
On July 17, 2002, EPA issued a final rule addressing some requirements of SPCC
plans and issued a schedule for facilities to come into compliance. As a consequence of
litigation, on Junel7, 2004, EPA proposed an extension to several of the compliance dates. A
link to the Federal Register notice may be found at the following address:
http://www.epa.gov/oilspill/pdfs/fr061704.pdf
7.12.4.2 Clean Air Act
Facilities storing crude petroleum and petroleum products generate air emissions
during loading and unloading operations and from normal tank breathing losses (collectively
known as "working losses").
The Clean Air Act (CAA) and the Clean Air Act Amendments (CAAA) of 1990
direct EPA to establish national standards for ambient air quality and enforce the standards
through a variety of mechanisms. Regulations under the CAA and CAAA that may apply to
storage terminals include the following:
• Title V permitting;
• New Source Performance Standards (NSPS); and
• National Emission Standards for Hazardous Air Pollutants (NESHAP).
7-98
-------
Section 7 - Petroleum Refining
According to EPA's OTIS database, the following number of facilities classified
as SIC code 5171 have CAA permits:
• 546 major sources;
• 395 synthetic minor sources; and
• 191 federally reportable minor sources.
Major sources are defined by the CAA as stationary facilities that emit or have the
potential to emit ^10 tons of any one toxic air pollutant or >25 tons of more than one toxic air
pollutant per year.
NESHAP
Facilities are subject to NESHAP if they are a major source of hazardous air
pollutants (HAP) and emit 10 tons per year of a single HAP or 25 tons per year of a combination
of HAPs. NESHAPs that apply to PBSTs include the following:
• 40 CFR Part 63 Subpart R: Standards for Gasoline Distribution Facilities
(Bulk Gasoline Terminals and Pipeline Breakout Stations), promulgated
December 1994; and
• 40 CFR Part 63 Subpart Y: Standards for Marine Tank Vessel Loading
Operations, promulgated September 1995.
7.12.4.3 Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) of 1976 addresses solid
(Subtitle D) and hazardous (Subtitle C) waste management activities. Items to note regarding
RCRA and PBSTs include the following:
• According to the Toxics Release Inventory (TRI) database, PBST releases
include the RCRA hazardous wastes that are commercial chemical
products designated with the code "P" and "U". 40 CFR Part 261.33
defines these wastes as acute hazardous wastes (code P) or toxic wastes
(code U).
• EPA's OTIS database includes 2,301 facilities classified as SIC code
5171; these facilities have obtained RCRA permits.
• RCRA enforcement authority (Part 7003) is usually used to clean up
petroleum plumes beneath storage terminals.
Subtitle C (40 CFR Parts 260-299) governs the handling of hazardous waste from
the point of generation to disposal. Regulations for hazardous waste include waste
7-99
-------
Section 7 - Petroleum Refining
accumulation, manifesting, and recordkeeping standards. Permits under Subtitle C include
general facility standards including the following:
• Contingency plans;
• Emergency procedures;
• Recordkeeping and reporting requirements;
• Financial assurance mechanisms; and
• Unit-specific standards.
RCRA requirements generally do not apply to specific industries, but rather apply
to any facility that transports, treats, stores, or disposes hazardous wastes. In addition, RCRA
also provides for the cleanup of hazardous waste releases or solid waste management unit
releases (40 CFR Part 264, Subpart S and Part 264.10).
Possible RCRA wastes at PBSTs include tank bottoms water, oil/water separator
sludge, and other wastewater treatment sludges. Under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), PBSTs must report any hazardous waste
release exceeding the reportable quantity and becomes liable for the release cleanup. Note the
definition of a hazardous waste under the RCRA statute does not include pollutants that are oil
(of any kind, or in any form) or synthetic gases used for fuel. However, oil mixed with a
hazardous substance is classified as a hazardous waste under RCRA.
At PBSTs, water may be found in contact and transported along with petroleum
products. The fact that the water accompanies the petroleum product does not make the mixture
of the two a waste, even though the water will ultimately be separated from the product and
disposed of as a waste. The RCRA regulations define the point of waste generation as being "
the point just beyond the step in which product is separated. Therefore, mixtures of petroleum
products and water, "even if mostly water, can be classified as product, so long as there is
legitimate recycling of product from the mixture".
Most wastewater from PBSTs are not classified as hazardous wastes under
RCRA. However, in 1990, EPA issued regulations (40 CFR Part 261.24) which classified any
solid waste containing more than 0.5 mg/L of extractable benzene under conditions of the
Toxicity Characteristics Leaching Procedure (TCLP) as a hazardous waste. In addition, water
which contains more than 0.5 mg/L dissolved benzene is potentially classified as a hazardous
waste. Typically, tank bottoms water from gasoline tanks and other sources at PBSTs contain
more than 0.5 mg/L benzene, a component of gasoline. Exceeding the 0.5 mg/L limit for
benzene requires PBSTs to handle and dispose of the waste in accordance with RCRA
requirements. Note that RCRA regulations apply only to hazardous wastes, not to products.
In addition to benzene, there are also other contaminants that could be present in
tank bottoms water, causing the water to potentially be classified as a RCRA hazardous waste at
the concentrations listed in Table 7-37.
7-100
-------
Section 7 - Petroleum Refining
Table 7-37. Concentrations That Would Render Tank Bottoms Water a RCRA
Hazardous Waste
Tank Bottoms Water Contaminant
Arsenic
o-Cresol
m-Cresol
p-Cresol
Cresols
Lead
Selenium
RCRA Limit (mg/L)
5.0
200
200
200
200
5.0
1.0
PBST Contaminant Sources
Found in crude oils, water-soluble
Made in refining, water-soluble
Made in refining, water-soluble
Made in refining, water-soluble
Made in refining, water soluble
Used as a gasoline additive
Found in crude oils, water-soluble
Wastewater that contains any of these contaminants above the RCRA limit
concentration requires handling and disposal in accordance with RCRA requirements.
In addition to wastewater, there are also solid hazardous wastes that might be
generated at PBSTs. These wastes will have the following characteristics as described in API's
Minimization, Handling, Treatment, and Disposal of Petroleum Products Terminal Wastewater-s:
• Ignitability. If the waste is ignitable (flash point less than 140°F) under
the RCRA test conditions, then it will be hazardous. Some product-
contaminated sludges may fall in this category.
• Reactivity. If the waste contains sufficient cyanide or sulfide to release
more than the regulated amount of hydrogen cyanide or hydrogen sulfide
when acidified, it will be hazardous. It is unlikely that PBSTs will
generate reactive wastes from normal operations. However, since
anaerobic biological activity converts sulfate to sulfide (by sulfate-
reducing bacteria), it is possible that alkaline tank bottoms water stored for
long periods of time might accumulate enough sulfide to fail the reactivity
standard.
• Corrosivity. If the pH of the waste is less than 2.0, or more than 12.5, it
will be classified as corrosive. Such wastes should be rare at PBSTs.
• Leachability. If more than regulated amounts of any chemical constituents
are leached from the waste when it is subjected to specified leaching tests,
it is hazardous. The regulated materials include toxic heavy metals and
selected organic constituents. Possible materials that would fail this test
are tank bottom sludge and wastewater treatment sludge. However, since
heavy metals are not common at PBSTs and most of the regulated organic
compounds are not expected to be in any petroleum products or wastes,
PBST sludges will most likely pass this test. If wastes are derived from
7-101
-------
Section 7 - Petroleum Refining
leaded product storage tanks, or from removal of lead-based paint (e.g.,
spent blasting sand), then the waste could fail the lead teachability test.
Also, benzene may appear in solid wastes at excessive levels as well as in
wastewater (the wastewater disposal exclusions do not apply to
nonaqueous wastes).
7.12.4.4 Emergency Planning and Community Right-to-Know Act
The Emergency Planning and Community Right-To-Know Act (EPCRA)
provides community access to information about chemical hazards and facilitates the
development of chemical emergency response plans by state and local governments. EPCRA
regulations include the following types of reporting requirements for facilities that store or
manage specified chemicals:
• Section 302 - facilities must notify the state emergency response
commission (SERC) and local emergency planning committee (LEPC) of
the presence of any extremely hazardous substances (listed at 40 CFR Part
355) above the substance's threshold planning quantity.
• Section 304 - facilities must notify the SERC and LEPC in the event of a
nonexempt release exceeding the reportable quantity of a CERCLA
hazardous substance or an EPCRA extremely hazardous waste.
• Sections 311 and 312 - facilities must submit material safety data sheets
(MSDSs) and hazardous chemical inventory forms (Tier I and II forms) to
the SERC, LEPC, and local fire department for hazardous chemicals in
amounts exceeding a chemical use threshold. The list of hazardous
chemicals is defined by the Occupational Safety and Health Agency
(OSHA).
• Section 313 - facilities must submit an annual toxic chemical release form
to EPA's Toxic Release Inventory (TRI) for a specified list of chemicals
and chemical categories if the amount of chemical manufactured,
processed, or otherwise used exceeds reporting thresholds. Only facilities
in certain SIC codes (including SIC code 5171) and that employ 10 or
more employees are required to report.
TRI requires facilities in SIC code 5171 to report the releases, transfers, and
treatment of listed chemicals. This industry was added to TRI reporting beginning in 1998.
Additional information on the types of pollutants and reporting criteria are available in the
guidance document EPCRA Section 313 Industry Guidance: Petroleum Terminals and Bulk
Storage Facilities, available on EPA's TRI web site: http://www.epa.gov/tri/industry.htm.
7-102
-------
Section 7 - Petroleum Refining
Based on number of employees, a majority of the PBSTs would not meet the first
reporting criteria; therefore, the TRI database contains only a subset of the PBST industry.
Recall that, in the TRI database for reporting year 2000, 502 PBSTs reported chemical releases.
7.12.4.5 Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) authorizes EPA to establish health-based,
national standards for drinking water. Part of the SDWA includes regulation of underground
injection of waste fluids (liquids, gases, or slurries). Underground injection technology includes
placing water, wastewater, or water mixed with chemicals into porous rock formations, injection
wells, or other similar conveyance systems.
The SDWA classifies drywells or septic systems where PBSTs inject nonsanitary
(i.e. nonsewage type) waste into the ground as Class V wells. To operate Class V wells normally
does not require individual permits; however, users must submit inventory information to
regulators (see 40 CFR Parts 144.24, 144.25, and 144.26). In addition, the water disposed of
must not have the potential to cause contamination of the groundwater beneath the well where it
becomes unfit for drinking, if used as or may be used as drinking water.
7.12.4.6 Regional and State Programs
As part of this study, EPA searched state web sites to evaluate current state
NPDES permit regulations and to establish the availability of data on current PBST industry
practices. The technology for treating PBST discharges typically includes oil/water separators to
treat stormwater from secondary containment areas. Based on permits and regulations obtained
for this analysis, states and regions apply a wide range of limitations and pollutant monitoring
requirements to the PBST industrial category.
The following summaries describe the relevant NPDES general and individual
permits that have been issued by EPA Regions and delegated states for PBSTs. Data are
publicly available through state and EPA web sites.
Region 1
Connecticut:
Connecticut Department of Environmental Protection - Marine Terminals
Program
The Department of Environmental Protection (DEP) Bureau of Waste
Management licenses petroleum bulk storage facilities that receive product from, or dispense to,
ships or barges. The application for this license requires detailed site information.
7-103
-------
Section 7 - Petroleum Refining
New Hampshire:
New Hampshire Department of Environmental Services - Application for the
Construction of New and Substantially Modified Petroleum Aboveground
Storage Tank Facility
The New Hampshire Department of Environmental Services requires a spill
prevention plan for new and substantially modified petroleum stations and terminals. In addition
to a spill prevention plan (SPP), the applicant must specify the manufacturer of the containment
sump for aboveground piping over surface waters (marinas) and describe all secondary
containment, including how stormwater will be handled.
Region 4
North Carolina:
North Carolina Department of Environment General Permit No. NCG080000 to
Discharge Stormwater under NPDES
The North Carolina Department of Environment issues general stormwater
permits through its Health and Natural Resources, Division of Water Quality. These permits
cover stormwater point source discharges associated with activities that have vehicle
maintenance areas (including vehicle rehabilitation, mechanical repairs, painting, fueling,
lubrication, and equipment cleaning operation areas) associated with activities classified by
specific SIC codes, including SIC 5171, with total petroleum storage capacity of less than one
million gallons.
Table 7-38 presents limitations for oil/water separators and PBSTs:
Table 7-38. Sample Limits in North Carolina's Stormwater General Permit
Parameter
pH
Oil and grease
Total suspended solids
Total rainfall
Storm event duration
Total flow
Limitation and Units
6.0 to 9.0 s.u.
30 mg/1
100 mg/1
Inches (report)
Minutes (report)
Million gallons (report)
Monitoring Frequency
Annually
Annually
Annually
Annually
Annually
Annually
7-104
-------
Section 7 - Petroleum Refining
South Carolina:
South Carolina Department of Health and Environmental Control NPDES
General Permit for Discharges From Bulk Petroleum Storage Activities
(SCG340000)
General permits issued by the South Carolina Department of Health and
Environmental Control for discharges from bulk petroleum storage activities cover stormwater
runoff from secondary containment structures (e.g., dikes and berms), stormwater and pad wash-
down water from loading racks, and vehicle wash-down water. The only numerical permit
limitation is for oil and grease. However, the permittee must monitor once per quarter for the
following parameters:
• Flow;
• Ethylbenzene;
• Naphthalene;
• Copper;
TOC;
• Toluene;
Methyl Tertiary Butyl Ether (MTBE);
pH;
• Benzene;
• Total xylenes; and
• Surfactants (only for vehicle washing).
Toxicity testing also must be conducted once per year using a 48-hour static acute
toxicity test performed using a control and 100-percent effluent. The test is conducted on
Ceriodaphnia according to South Carolina procedures for pass/fail modifications to EPA's
standard methods.
Region 5
Ohio:
Environmental Protection Agency - Effluent Limitations and Monitoring
Requirements for Petroleum Bulk Storage Facilities
Ohio EPA established a monitoring program to characterize discharges from
petroleum bulk storage terminals or similar facilities (i.e., large industrial facilities, airports,
etc.). Petroleum bulk storage facilities are subcategorized as follows:
• Type A - Terminals with product loading/unloading racks.
• Type B - Terminals without loading racks (usually referred to as tank
farms). Product transport is via pipelines only. Discharge of tank bottoms
water is a potential.
7-105
-------
Section 7 - Petroleum Refining
• Type C - Terminals that are bulk crude oil storage and pipeline facilities.
Crude oil arrives and leaves via pipeline; there is no loading or unloading
of product or tank bottoms water.
Table 7-39 presents the parameters considered by Ohio EPA for developing
permit requirements for each type of facility. Monitoring frequency is recommended to be once
per month for all parameters, except phenol and naphthalene, which are recommended once per
quarter.
Table 7-39. Parameters Considered by Ohio While Developing Permits
Parameter
Benzene
Toluene
Ethylbenzene
Xylene
BOD
COD
O&G
TSS
TOC
Phenol
Naphthalene
Weather (report)
Precipitation (report)
Annual organic pollutant scan
Facility Type
A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
B
X
X
X
X
X
X
X
X
X
X
X
X
C
X
X
X
X
X
X
X
X
The only numeric limitations recommended are for oil and grease: 15 mg/1
monthly average, 20 mg/1 daily maximum.
Wisconsin:
Wisconsin Department of Natural Resources Petroleum Contaminated Water -
WPDES General Permit No. WI-0046531-3
These WPDES general permits apply to point source discharges of wastewater
that have been contaminated with petroleum, including, but not limited to: gasoline, diesel fuel,
aircraft fuel, jet fuel, heating oils, and lubrication oils. Discharges are categorized into the
following three types:
7-106
-------
Section 7 - Petroleum Refining
• Petroleum contact water (excluding tank bottom water) - technology-
based limits assume use of adequately sized, designed, and functioning
oil/water separator;
• Tank bottoms water - technology-based limits assume removal of
dissolved or emulsified petroleum products from water including
stripping, chemical addition, dissolved air floatation, activated carbon,
activated clays, thermal treatment, and distillation; and
• Scrap and waste storage area oily water - technology-based limits assume
the same treatment as for tank bottom water.
Discharges to groundwater and surface water have separate limitations for each of
the three types of discharges, as shown in Table 7-40.
Table 7-40. Limitations by Discharge Type
Parameter
Flow
O&G
Total BTEX
PAH
Naphthalene
Benzo(a)pyrene
Benzene
Ethylbenzene
Toluene
TSS
BOD
Petroleum Contact
Water
Ground-
water
Estimate
15 mg/1
Monitor
Monitor
-
-
-
-
-
-
-
Surface
Water
-
-
-
-
-
-
-
-
-
-
Monitor
Tank Bottoms Water
Ground-
water
-
-
750 ug/1
0. lug/1
8 ug/1
0.02 ug/1
0.5 ug/1
140 ug/1
200 ug/1
-
-
Surface
Water
-
-
-
-
-
0.1 ug/1
50 ug/1
-
-
-
Monitor
Scrap and Waste Storage Area
OUy Water
Ground-
water
-
-
-
-
8 ug/1
0.02 ug/1
0.5 ug/1
140 ug/1
200 ug/1
40 mg/1
-
Surface
Water
-
-
-
-
70 ug/1
0.1 ug/1
50 ug/1
-
-
Monitor
Region 6
Arkansas:
Arkansas Department of Environmental Quality Authorization to Discharge
Under the NPDES and the Arkansas Water and Air Pollution Control Act
(ARG340000)
This authorization by the Arkansas Department of Environmental Quality applies
to any facility that stores, in one or more stationary bulk storage tanks, petroleum and petroleum
products; and subsequently transfers, distributes, or sells the petroleum and petroleum products
7-107
-------
Section 7 - Petroleum Refining
in large quantities, via pipeline, marine transportation, tank car, or tank truck, to the wholesale or
commercial market. Six outfall types in the general permit with limitations as specified below:
• 101 Secondary containment areas (dikes) surrounding petroleum
storage tanks;
• 201A Petroleum loading and transfer areas;
• 20IB Petroleum loading and transfer areas and tank bottom water;
nondischarge of tank bottom water directly to the diked area;
• 301 Petroleum tank truck wash water;
• 401 Petroleum tank truck garages located adjacent to petroleum storage
and transfer areas; and
• 601 Containment stormwater runoff covered by or commingled with
the above discharges.
Table 7-41 lists the above outfalls and applicable limitations.
Table 7-41. Arkansas Limits by Outfall Type
Parameter
O&G
Flow
pH
Total BTEX
TDS
Ammonia (as
Nitrogen)
Benzene
Cyanide
Lead
Naphthalene
Outfall
101
No free
oil
201A
201B
301
401
10 mg/1 (daily avg)
15 mg/1 (daily max)
601
No free
oil
Report
6.0 - 9.0 s.u
-
-
-
-
-
-
-
-
-
-
0.1 mg/1
500 mg/1
1 mg/1 (daily average)
2 mg/1 (daily max)
0.05 mg/1
0.005 mg/1 (daily
average)
0.009 mg/1 (daily max)
0.0006 nig/1 (daily
average)
0.00 12 mg/1 (daily max)
Report
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
7-108
-------
Section 7 - Petroleum Refining
Table 7-41 (Continued)
Parameter
Acute Toxicity
COD
TSS
Outfall
101
201A
201B
>50% survival for 24-hr
test on 100% effluent
(I/month)
301
50 mg/1
(daily
average)
75 mg/1
(daily max)
35mg/l
(daily
average)
53 mg/1
(daily max)
401
601
Texas/EPA Region 6:
Final NPDES General Permit for Discharges from Petroleum Bulk Stations and
Terminals (TXG340000)
NPDES general permits issued by EPA Region 6 for the state of Texas apply to
discharges of facility wastewater and contact storm water from petroleum bulk stations and
terminals and establishments primarily engaged in the cooperative or wholesale distribution of
refined petroleum products or petroleum fuels from bulk liquid storage facilities. Table 7-42
lists the permit limitations.
Table 7-42. Texas General Permit Limits
Parameter
Flow
Total petroleum hydrocarbons
Benzene
BTEX
Lead
PH
Daily Limit
Estimate (report)
15 mg/1
0.05 mg/1
0.5 mg/1
0.25 mg/1
6.0 - 9.0 s.u.
In addition, discharges are analyzed once per year for the following parameters
that have monthly average and daily maximum limitations:
• Arsenic;
• Barium;
• Cadmium (inland and tidal limits);
7-109
-------
Section 7 - Petroleum Refining
• Chromium;
• Copper;
• Manganese;
• Mercury;
• Nickel;
• Selenium (inland and tidal limits);
• Silver; and
• Zinc.
An acute toxicity test also must be conducted once per year using a 24-hour
standard test on both Daphnia pulex and fathead minnows. Greater than 50-percent survival is
required using 100-percent effluent.
Region JO
Oregon:
Oregon Department of Environmental Quality General Permit 1300-J
The Oregon Department of Environmental Quality general permits cover facilities
storing, transferring, formulating, and/or packaging bulk petroleum products or vegetable oils,
and other facilities with oily stormwater runoff and/or tank bottoms water. There are
approximately 22 active facilities covered by these permits.
Stormwater discharges from bulk petroleum storage sites do not require permits if
the total storage capacity at the site does not exceed 150,000 gallons and if the discharge from
the containment area is treated by an oil/water separator. The discharge may not exceed water
quality standards for oil and grease of 10 mg/1 (monthly average) and 15 mg/1 (daily maximum).
Facilities that are required to obtain an NPDES permit must meet the same oil and
grease limitations. In addition, Oregon uses benchmark concentrations, shown in Table 7-43, to
assess the site's Stormwater Pollution Control Plan.
Table 7-43. Oregon Stormwater Pollution Control Plan benchmarks
Parameter
Total Copper
Total Lead
Total Zinc
TSS
Floating Solids
O&G
PH
Benchmark
0.1 mg/1
0.4 mg/1
0.6 mg/1
130 mg/1
No visible discharge
No visible sheen
6.0 - 9.0 s.u.
7-110
-------
Section 7 - Petroleum Refining
7.12.5
Wastewater Characterization
This section presents wastewater characterization data based on TRI and PCS
submissions for 2000. Using these data, EPA estimated total discharges from PBSTs and
compared them to discharges from other industries.
7.12.5.1
TRI Data
Facilities report both direct discharges (i.e., mass of pollutant released directly to
receiving streams) and indirect discharges before treatment (i.e., mass of pollutant transferred to
POTWs) to TRI. For direct discharges, EPA used the reported mass to calculate TWPEs. For
indirect discharges, EPA first estimated the reduction in pollutant mass accomplished by the
POTW (i.e., pollutant percent removal) and then used the resulting mass of pollutant after
treatment to calculate TWPEs discharged to the POTWs receiving stream. EPA calculated the
reduction in pollutant mass for indirect discharges by using average POTW removal efficiencies
(see DCN 00618, Evaluation of RSEIModel Runs}.
The reported releases of PACs, n-hexane, and benzene comprise nearly 99 percent
of the PBST industry's total toxic releases of 8,010 TWPE. Table 7-44 presents the pounds (and
TWPE) discharged by direct and indirect dischargers as reported to TRI for the PACs, n-hexane,
and benzene.
Table 7-44. TWPE Discharges of Individual Pollutants Based on 2000 TRI Data
Parameter
PACs
n-Hexane
Benzene
Facilities
Reporting
5
74
109
Total Pounds
Discharged
35.293
4,949
4,033
TWPE
Discharged
7.741.21
117.71
63.53
Cumulative Percentage of Total
TWPE Discharged (8,010)
96.6
98.1
98.9
7.12.5.2
PCS Data
Facilities report direct discharges (i.e., mass of pollutant released directly to
receiving streams) to PCS. For direct discharges, EPA used the reported mass to calculate
TWPEs. As discussed in Section 7.12.2.2, PCS includes only results of permit-required
monitoring for direct discharging facilities. Even though toxic pollutants may be present in a
refinery's discharge, they will not be reported unless required by permit.
The reported release of benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,
h)anthracene, and benzo(a)anthracene comprise more than 98 percent of the industry toxic
releases of 5,389 TWPE, as reported to PCS. Table 7-45 presents the pounds (and TWPE)
discharged by PCS major reporters for the four pollutants listed earlier.
7-111
-------
Section 7 - Petroleum Refining
Table 7-45. TWPE Discharges of Individual Pollutants Based on 2000 PCS Data
Parameter
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Benzo(a)anthracene
Facilities
Reporting
->
j
->
j
->
j
3
Total
Pounds
Discharged
0.58
2.39
0.58
4.64
TWPE
Discharged
2,467.78
1,007.76
975.35
839.2
Cumulative Percentage of Total
TWPE Discharged (5,389)
45.8
64.5
82.6
98.2
7.12.5.3
Stormwater Contributions to TRI and PCS Data
When reporting to the TRI, sites complete a Form R for each chemical exceeding
the reporting threshold. Each chemical's Form R includes the pounds per year discharged in
wastewater to receiving streams and water bodies for direct discharges (Section 5.3 of Form R).
Sites also report discharges to POTWs and other off-site locations for wastewater treatment;
however, only discharges to receiving streams or water bodies include reporting of the "% From
Stormwater." Therefore, this analysis only applies to direct discharges. Moreover, this
assessment will focus on those facilities whose TRI TWPE discharges ranked highest. The
following four facilities discharged 96 percent of the 8,010 TWPE calculated from the 2000 TRI
data:
Coastal Oil of New England, South Boston, MA;
Phillips Pipeline Co. Kansas City Terminal, Kansas City, KS;
Irving Oil Terminals, Inc., Searsport, ME; and
Noco Energy Corp., Tonawanda, NY.
Coastal Oil of New England did not provide any data linking toxic discharges to
storm events. The other three facilities did, with Table 7-46 listing Stormwater contributions to
the discharge of various pollutants.
Table 7-46. Percent Discharges to Surface Waters Due to Stormwater for 2000
TRI Reporters
Parameter
1 ,2,4-trimethylbenzene
Benzene
Ethylbenzene
n-Hexane
Methyl tert-butyl ether
Percent Discharged to Surface Waters Due to Stormwater
Phillips Pipeline,
Kansas City, PCS
22
22
22
22
22
Irving Oil Terminals,
Inc., Searsport, ME
100
100
100
100
100
Noco Energy Corp.,
Tonawanda, NY
100
100
100
100
100
7-112
-------
Section 7 - Petroleum Refining
Table 7-46 (Continued)
Parameter
PACs
Toluene
Xylene (mixed isomers)
Percent Discharged to Surface Waters Due to Stormwater
Phillips Pipeline,
Kansas City, KS
22
22
22
Irving Oil Terminals,
Inc., Searsport, ME
100
100
100
Noco Energy Corp.,
Tonawanda, NY
100
100
100
Of the eight PCS majors, four also reported to TRI in 2000. They are as follows:
• Exxon Mobil, East Providence, RI;
• ConocoPhillips, East Boston, MA;
Shell Co., San Juan, PR; and
• Exxon Mobil, Everett, MA.
Exxon Mobil's East Providence, RI facility and Shell Co. reported no Stormwater
contributions to toxic discharges to surface waters. ConocoPhillips's East Boston, MA facility
and Exxon Mobil's Everett, MA facility reported that Stormwater was responsible for 100
percent of toxic discharges to surface waters for the following pollutants: benzene, ethylbenzene,
methyl tert-butyl ether, toluene, and xylene (mixed isomers). In addition, Exxon Mobil's
Everett, MA terminal also reported that 100 percent of n-hexane discharges to surface waters
took place due to Stormwater.
7.12.5.4
Wastewater Handling
The various types of wastewater are often handled differently. Any wastewater
that has come into contact with product, particularly oil and grease and total petroleum
hydrocarbons, is collected and treated in some fashion, sometimes on-site (oil/water separation,
some form of primary and/or secondary treatment, e.g., biological treatment followed by
granular activated carbon treatment), and disposal to a publicly owned treatment works (POTW),
a lined lagoon, or direct discharge to surface waters. Several commenters to the Preliminary
Plan stated that oil/water separation is widely used at those facilities that treat their wastewaters.
ILTA went so far as to say that virtually all PBSTs that treat wastewater on site have oil/water
separators. According to several control authorities, facilities that perform on-site treatment are
generally larger. Their size and attendant economics make it easier for them to install and
operate a treatment system. Many smaller facilities, on the other hand, have their wastes
collected and shipped for off-site treatment at adjoining refineries or treatment facilities (3). The
use of this practice was also widely reported by commenters.
Wastewater requiring primary and/or secondary treatment (because it is
contaminated with oil and grease and total petroleum hydrocarbons) is typically tank bottom
water, loading/unloading rack water, a portion of the tank basin water, wastewater generated
during remediation, and water used for hydrostatic testing, if it is contaminated (if hydrostatic
7-113
-------
Section 7 - Petroleum Refining
test water is not contaminated, it is normally released to a storm drain). In the case of tank
bottoms water, commenters report that it is normally sent off site for treatment. For example,
Amerada Hess reported that all of its terminals ship tank bottoms water off site for treatment.
Wastewater that contains surfactants or other types of cleaning agents is not commingled with
other oily wastewaters to prevent the formation of emulsions; therefore, wastewater from vehicle
and equipment washing and maintenance, as well as wastewater from lavatories, is typically
discharged separately to the POTW. Stormwater runoff from the facility yard, roofs, and drives,
as well as some of the tank basin water, is either collected and examined (visual inspection
and/or chemical testing), or released to the environment without collection if the facility ensures
that the water has had no contact with product or other pollutants. If collected stormwater is
clean, it is sent to a storm drain; otherwise, it is sent through oil/water separation and other
necessary treatment measures before being discharged to a POTW, a lined lagoon, or to surface
waters.
7.12.6 Pollution Prevention Practices
Pollution prevention practices reduce pollution at the source. This includes any
practice that reduces the amount of pollutants entering any waste stream or otherwise released
into the environment prior to recycling, treatment, or disposal and reduce the hazards to public
health and the environment. Pollution prevention practices include equipment or technology
modifications, process or procedure modifications, reformulation or redesign of products,
substitution of raw materials, and improvements in housekeeping, maintenance, training, or
inventory control. As discussed in Section 7.12.3, there are several sources of wastewater at
PBST facilities; however, there are also many pollution prevention practices that can be
implemented to reduce or eliminate these sources of wastewater. In addition to the
environmental benefits of pollution prevention, PBST facilities can benefit from implementing
pollution prevention practices by doing the following:
• Reducing the size of downstream wastewater treatment equipment;
• Providing a permanent solution for eliminating pollutants;
• Eliminating costs associated with managing wastewater; and
• Providing more reliable methods for eliminating pollutants.
This section describes the following pollution prevention practices that can be
implemented to reduce or eliminate wastewater generation at PBSTs:
• Section 7.12.6.1 discusses the pollution prevention practices that minimize
stormwater contamination;
• Section 7.12.6.2 discusses pollution prevention practices that minimize
generation of wastewater; and
• Section 7.12.6.3 discusses pollution prevention practices for reducing
other wastewater sources.
7-114
-------
Section 7 - Petroleum Refining
7.12.6.1 Stormwater Pollution Prevention Practices
Stormwater is the major source of wastewater volume at most PBST facilities.
Stormwater can be divided into three categories - uncontaminated, potentially contaminated, and
contaminated - based on the type of area from which the Stormwater is generated. To minimize
the amount of wastewater that requires treatment, PBSTs should segregate Stormwater from
sources of contamination and take preventive measures to minimize potential Stormwater
contamination.
Stormwater Segregation
To minimize the amount of wastewater generated, PBSTs should segregate
Stormwater from sources of contamination so that it can be discharged with minimal or no
treatment. Two methods to segregate Stormwater from potential sources of contamination are
geographical segregation and roof design. Both of these methods help prevent contamination of
Stormwater by pollutants from PBST facilities and dilution of contaminated water.
Geographical Segregation
Geographical segregation prevents mixing of different categories of Stormwater
(i.e., uncontaminated, potentially contaminated, and contaminated), using a combination of the
following methods:
• Grading: moving dirt to form land slopes such that water flows in the
desired direction;
• Berms: elevated barriers used to contain and control surface water
movement;
• Interceptor drains: collection channels (e.g., ditches or sewers) that
capture a type of runoff before it can mix with another type; and
• Curbs: elevated barriers to contain and control surface water movement
that are low enough to allow for personnel and equipment to move over
them.
To implement geographical segregation, the facility must identify which plant
areas generate each of the three types of Stormwater. If a facility determines that different types
of Stormwater are commingling, it can use the geographical segregation methods listed above to
segregate the Stormwater, enabling the facility to reduce the amount of Stormwater that requires
treatment.
7-115
-------
Section 7 - Petroleum Refining
Roof Design
Facilities can provide roofs over potential sources of contamination, with the
runoff from the roofs sent to a less-contaminated area. The primary use of roofs is on storage
tanks because tank bottoms water is highly contaminated, but has very low flow if stormwater is
segregated. For tanks that contain water-soluble materials (e.g., gasoline oxygenates and fuel
and lubricant additives), fixed roofs are recommended because water mixing with such materials
can significantly contaminate and degrade product quality.
Roofs (or canopies) can also be used over transfer racks to segregate stormwater
from small product spills that result when making and breaking hose connections to transport
vehicles. These canopies also protect personnel from the elements and keep stormwater out of
the transport vehicle. To prevent stormwater runoff from flowing over the facility slab, roof
drains should be routed away from the slab and the slab should be surrounded by rollover curbs .
In addition, this area should have a drainage and containment system which drains to a sump and
is routed to the proper treatment system. This system should also be designed to hold the
maximum capacity of the largest compartment of a tank car or truck used at the facility in the
event of tank rupture or accidental overflow.
Pump stations are considered contaminated areas because of pump seal leaks and
pump maintenance discharges. PBSTs can place a roof or canopy over the pump station to
eliminate stormwater collection and treatment from the pump station slab. These roofs are
similar to the roofs placed over transfer racks.
A novel possibility of this type is the use of green roofs. Green roofs, sometimes
called roof gardens, are a surface treatment for rooftops involving the addition of several layers
of growth media and plants to create a contained green space. Current green roof design is
generally comprised of four components: a waterproof membrane, a drainage layer, a growth
medium, and vegetation. Variations in these components, including the addition of a vegetation
support layer above the growth medium can greatly affect the water flow and thermal
characteristics of the green roof. Proponents of green roofs have claimed numerous benefits
including improved air quality, stormwater attenuation, reduction of the "heat island effect," and
aesthetic value (6). While EPA is unaware of any PBSTs that use this technology, EPA is aware
of other industrial structures in the United States that use green roofs. The most prominent of
these is the Ford Automobile Company's Rouge Center in Michigan, which installed a green
roof approximately two years ago. While Ford is, as yet, unable to provide performance data,
the possibility remains intriguing. In the case of PBSTs, the technology is probably not
appropriate for direct usage on tank roofs, but might be used on canopy roofs. A potential
hurdle, from the standpoint of design, is adequate load-bearing capacity.
Minimizing Stormwater Contamination
Potentially contaminated stormwater is collected and subjected to minimal
treatment before discharge; if it becomes contaminated, it must be treated more extensively. To
7-116
-------
Section 7 - Petroleum Refining
reduce the amount of contaminated stormwater, steps can be taken to reduce the probability of
contamination.
Stormwater at PBSTs may be contaminated by accidental release of materials to
the ground, including leaks in piping or tanks, overfilling the tanks, accidentally opening tank
nozzles, or tank cleanout activities. See Section 7.12.6.2 for descriptions of methods to
minimize these releases. When such releases do occur, there are preventative measures that can
minimize the likelihood of stormwater contamination.
Petroleum tanks are surrounded by a containment area, bounded by dikes or
walls. It is a general rule that the containment area is able to hold the volume of the largest tank
in the area without spillover. Rainwater is removed from the contained area via drainage pipes
with shutoff valves that are placed through the dikes or walls. The shutoff valves should be
closed at all times except during attended rainwater drainage. If a product spill occurs at the
same time that rainwater accumulates in the tank basin, then the clean water can be drained using
"turndown ells" on the basin end of the pipe. These devices allow water to drain while
minimizing entrainment of floating product.
7.12.6.2 Minimizing Generation of Wastewater
There are several ways that product can become mixed with waste water at a
PBST, including petroleum product discharges into wastewater, product/water emulsion, and
tank bottoms water accumulation. Pollution prevention practices are available to reduce or
eliminate product contamination in wastewater streams.
Petroleum Product Discharges
Product discharges can enter wastewater through petroleum product tank bottoms
draws, waste product discharge, equipment drainage, sampling episodes, leaks, tank
deterioration, and product transfer mishaps. Using appropriate pollution prevention practices
can reduce or eliminate all of these sources of product discharge.
Removal of Tank Bottoms Water
Water from various sources collects in the bottoms of petroleum product tanks
(see Section 7.12.5.2). This wastewater must be removed to ensure that water is not being mixed
with product as it is pumped from the tank; this method is termed product tank bottoms draw.
Once it is removed, this wastewater is sent to a collection tank for oil separation and treatment.
Facilities should use methods such as water volume determination, water/product interface
detection, and product entrainment prevention that maximize the withdrawal of water while
minimizing the withdrawal of product.
The facility should first determine the amount of water in the tank to ensure that
the minimum amount of water is drawn. One way is by gauging the tank with a tape or stick
coated on its lower end with water-indicating paste, which changes color when it comes in
7-117
-------
Section 7 - Petroleum Refining
contact with water. Another way is to position closely spaced try cock valves on the side of the
tank. These valves should be situated where the water accumulation is expected. Facility
personnel can determine the water level by opening the trycock valves (starting with the lowest
one) to assess the highest one that delivers water.
A third method for detecting the water/product interface is using sight glasses
mounted on the side of the tank. The upper end nozzle of the sight glass should be placed lower
than the level of the product; otherwise, there will be no correlation between the interface level
in the sight glass and the interface level in the tank. Calibration curves (or tank strappings) show
the relationship between tank water level and tank water volume and can be used to determine
the volume of water to remove once the level is known. Manual control is another method of
interface detection, where the water draw valve is manually opened, the drawn substance is
sampled, and once product is detected, the valve is manually closed.
There are more reliable methods of detection that rely on the properties that
distinguish water from product, such as detectors based on electrical conductivity or capacitance
and devices using a float of exact specific gravity to control a shutoff valve. If the volume of the
water in the tank is known, facilities can use a device that meters the draw volume and operates a
shutoff valve when the determined wastewater volume is reached. Unfortunately, fouling could
be a concern for these three methods. Another technique is to draw water through a canister of
material that swells when contacted by hydrocarbon, and consequently blocks the flow once
product is drawn.
Product entrainment is defined by API to be the carryover of droplets of product
in a water draw flow. Facilities can minimize product entrainment using proper design
guidelines and operating procedures. For example, a water sump can be situated in the tank
bottom next to the water drain nozzle and the nozzle to the tank interior can be connected with a
turndown ell. This method ensures that the water is taken from the lowest possible elevation (i.e.,
farthest away from the water/product interface). Facilities can also use vortex eliminators or
vortex barriers to keep the product from being pulled down in a swirling vortex. Another
method is to place the product draw nozzle at the highest possible elevation because if there is a
large separation between the product and water draws, then some water can remain in the tank to
avoid drawing in some product. In addition, facilities can control product entrainment by the
water draw rate. Product entrainment and overshooting the water/product interface is more
probable at high water flow rates. Facilities should also reduce the water draw frequency.
Discharge of Waste Product
Slop oil (or waste product) is any petroleum product that does not meet product
specifications and cannot be used or distributed as is. Slop oil systems can eliminate waste
product discharge into wastewater sewers. PBST facilities can use these systems to collect waste
product and reuse it. Slop oil systems are comprised of collection points that are situated at all
sources where waste product is generated. If small volumes of waste product are generated, the
slop oil system may be a collection drum. If facilities generate large volumes of waste product,
then they should use a direct pipe connection from the system. For intermediate volumes, an oil
7-118
-------
Section 7 - Petroleum Refining
sump can be placed at a lower elevation than where product is released to enable gravity
drainage. Water should not enter the slop oil system. The waste product can be transported for
further processing using piping, vacuum truck, or truck transport of filled slop oil drums, where
it can be converted into a useful product by separating and removing the water.
Equipment Drainage
When equipment is taken out of service for maintenance, it is typically drained.
Equipment usually contains large amounts of product, so draining this product into sewers can
cause wastewater contamination. The most common pollution prevention practices for
minimizing product drainage into sewers are design factors, including avoiding pocketing, using
drain nozzles, and providing a collection point.
To avoid pocketing (i.e., product trapped in low points in the piping that is not
able to drain in either direction), when a process is stopped, the product in the equipment should
flow out of the system through existing equipment. For example, vessels should have drain lines
at their low points with connections that enable the contents to be pumped or gravity drained to
other parts of the system. In addition, piping should not have pockets that cannot be drained by
gravity in either direction. If there are pockets in the system, then drain nozzles should be used
with a shutoff valve at the pocket. The drained product can be used, rather than washed into a
sewer. One way to recover the drained product is to run hoses from the drain nozzles to a below-
grade product collection sump. The product can be transferred from the sump to the slop oil
system by vacuum truck or with a sump pump and piping system. An alternative method is to
connect the drain nozzle directly to a vacuum truck suction hose.
Product Sampling
PBSTs typically use sampling nozzles and stations to collect samples at different
points. Because the sample nozzle piping normally has no flow (i.e., dead volume), it is general
sampling protocol to open the sample valve and allow the substance to flow long enough to
purge the piping of dead volume to obtain a representative sample. This dead volume is
sometimes discharged into the oily wastewater sewer, which contaminates the wastewater with
product. Installing a sampling loop or a sample trough can eliminate this discharge.
A sampling loop is a loop of piping where the pipe's upstream end is connected to
the normal sample collection point and its downstream end to a lower pressure region of the
same process. When a sample is taken, the sample loop is purged by opening the sample loop
line valves, and then the sample nozzle is opened to collect the sample. Another pollution
prevention practice is using a sample trough, which is a collection sink or trough at the sample
nozzle, connected to the slop oil system.
7-119
-------
Section 7 - Petroleum Refining
Leaks
Leaks can be a major source of product in wastewater and stormwater. There are
various types of leaks, such as pump seal leaks, valve seal leaks, and piping leaks, for which
pollution prevention practices can be implemented.
Pump seals are found on the rotating shaft in rotating pumps and on the piston in
piston pumps. A certain amount of leakage is required to lubricate the seal for many rotating
seals. Pollution prevention practices to minimize leakage include considering product leaks as a
factor in pump selection, selecting mechanical seals instead of packing seals, and selecting seal-
less pumps over ones that use seals. In addition, pump seals should be maintained in good
condition; therefore, when product leakage from seals becomes excessive, they should be
tightened, repaired, or replaced.
Valve seals are used to minimize process fluid leakage along the stem that
connects the internal parts with the external actuator. These seals can leak, so to minimize
product release, PBSTs should choose valve designs that minimize leakage and maintain valve
seals in good condition.
Unlike pumps and valves, piping leaks are not inherent to the equipment design
and typically result from improper assembly or corrosion. To prevent piping leakage, PBSTs
should hydrotest equipment that is taken down for maintenance before returning it to service. In
addition, if buried piping is metal, it should have a protective wrapping and coating. Cathodic
protection may also be necessary. For aboveground pipes, facilities should post signs and inform
drivers at the facility about the presence of these pipes to avoid accidental spills from collisions .
Tank Deterioration
Tanks can deteriorate over time causing leaks and rupture, so they should be
designed correctly and inspected periodically. As described in the SPCC requirements, tanks
should be selected based on their suitability for the material being stored and the storage
conditions. Industry standards should be followed for the construction, material, installation, and
use of the tank. Fiberglass tanks should be used underground because they do not corrode. If
metal underground storage tanks (USTs) are used, then they should have corrosion resistant
coating, cathodic protection, or another effective method of protection from corrosion. Trained
personnel should inspect aboveground storage tanks (ASTs) to detect leaks or other
deterioration. Inspectors may use X-ray or radiographic analysis to determine the wall thickness
and detect cracks and crevices in metal; ultrasonic analysis to measure the shell metal thickness;
hydrostatic testing to identify leaks caused by pressure; visual inspection to detect cracks, leaks,
or holes; and magnetic flux eddy current test and ultrasonic analysis to detect pitting. Corrosion
can be prevented in metal ASTs by using dielectric coatings, cathodic protection, and double-
bottom tanks.
7-120
-------
Section 7 - Petroleum Refining
Product Transfer Mishaps
Wastewater and stormwater can become contaminated by-product transfer
mishaps, such as tank overfilling and accidental opening of nozzles. Gauging the tank before it
is filled and monitoring the tank while it is being filled can prevent tank overfilling. High-level
alarms and automatic shutoffs can also prevent tank overfilling. Establishing a policy to keep
blind flanges or caps over all pipe openings and unconnected valve ends can minimize accidental
releases caused by accidentally opening tank nozzles.
Controlling Emulsions
An emulsion is the dispersion of product in water or vice versa. The phase in
which the droplets are dispersed is the continuous phase and the droplets comprise the dispersed
phase. Since petroleum product is separated from wastewater by gravity separation, there are
serious adverse effects on wastewater quality when product cannot be gravity separated from
wastewater. Emulsions typically accumulate at the product/water interface because their density
is in between the densities of the product and water. The PBST industry typically refers to these
emulsions as rag or cuff. Pollution prevention practices that minimize product/water emulsions
involve product droplet control, surfactant control, and fine solids control.
Product Droplet Control
Emulsions are stabilized by small oil droplets because they are inherently slower
to separate from the continuous phase. Small oil droplets are formed by agitation of oil and
water, which is caused by pumping product/water mixtures or turbulent flow of product/water
mixtures. Centrifugal pumps are frequently used by PBST facilities and generate emulsions
because the material pumped is subject to high agitation in the pump. To minimize emulsions,
facilities should use positive displacement pumps (e.g., gear pumps, piston pumps, diaphragm
pumps, and Archimedes screw pumps) because they produce less agitation and therefore less
emulsions. Emulsions are also formed by turbulent flow of product/water mixtures, which can
be caused by high velocities of fluid flow in pipes or ditches. Pollution prevention practices
such as increasing pipe diameter, restricting the gravity gradient, and avoiding sudden changes in
elevation avoid turbulence in oily wastewater streams by maintaining low velocities.
Surfactant Control
Emulsions are also stabilized by surfactants (e.g., detergent and soaps) collecting
at the product/water interface, which reduce the surface tension and inhibit phase separation.
Natural surfactants are present in crude oil; however, manufactured detergents used for cleanup
or as gasoline or lube oil additives are of most concern at PBST facilities.
PBSTs use detergents to clean oily equipment. To minimize the formation of
emulsions, facilities should use the minimum amount of detergent necessary. Another method is
to use nondetergent alternatives, such as dry cleaning methods (e.g., solvents or absorbent
materials for spilled product) or steam cleaning.
7-121
-------
Section 7 - Petroleum Refining
Gasoline additives can contain detergents that keep vehicle fuel systems free from
deposits. To prevent emulsions from forming, gasoline additives or gasoline containing
additives should not come into contact with water; therefore, PBSTs should keep these
substances in waterproof tanks.
Some PBSTs accept water-containing, off-specification products with additives
(which aid in the formation of emulsions) from service stations. For this source, pollution
prevention practices include keeping these products separate from other products until all water
is separated; using a low-flow tank if the recovered product is sent to a product tank; and not
mixing the water separated from haulback material with oily wastewater.
Fire foam systems are tested occasionally at PBSTs. Releasing foaming agent
surfactants dissolved in water can cause product/water emulsions to form. Physically cleaning
up the foam (instead of washing it down), selecting a foaming agent that is compatible with the
treatment system (e.g., it is biodegradable if biotreatment is used), and segregating the foam
wastewater from oily wastewater can minimize the release of these surfactants and thereby
reduce the possibility of forming emulsions.
Fine Solids Control
Fine solids can generate product/water emulsions by contacting and being
saturated with product and water simultaneously. Fine solid sources include soil, powdered
materials, and corrosion products.
Soil erosion is a common source of fine solids at PBSTs, and clay soils produce
very fine particles. To prevent emulsions from forming from this source, facilities should
minimize the erosion of soil into wastewater collection systems by segregating runoff areas,
planting groundcover plants, paving the drainage area, and using geofabrics.
PBSTs occasionally use powdered materials, such as spent blasting sand. To
prevent emulsions from forming from this source, facilities should properly store these materials
to prevent them from entering stormwater and wastewater sewers. If these materials are
deposited on paved areas, they should be removed by dry methods, such as sweeping instead of
washing it down.
Fine solids can also be generated from sulfide corrosion of steel, which creates
very fine iron sulfide. Facilities should remove these fines from process equipment without
mixing product, water, and solids.
In general, to keep solids from entering oily wastewater streams, facilities should
use closed sewer or pipes instead of open ditches to convey wastewater. Also, facilities should
segregate sanitary wastes from oily wastewater because these wastes contain biosolids and
detergents that stabilize emulsions. To do this, facilities can send sanitary waste to a municipal
sanitary sewer, a septic tank, or other dedicated sanitary treatment system, or mix the sanitary
waste with oily wastewater only after oil/water separation.
7-122
-------
Section 7 - Petroleum Refining
Tank Bottoms Water Accumulation
According to API, product tank bottoms water is the most expensive wastewater
to treat because it is by far the most contaminated wastewater generated at PBST facilities.
Therefore, it is important to minimize this source of wastewater by reducing the tank bottoms
flow, the amount of entrained product water, tank breathing and condensation, rainwater, and
other sources.
Reduction of Tank Bottoms Flow
A pollution prevention practice that can be implemented at PBST facilities is
reducing the flow of tank bottoms water to minimize the amount of contaminant transfer from
petroleum products. This method affects wastewater contaminants in different ways depending
on the solubility of the contaminant. Entrained contaminants are drained along with the water;
therefore, reducing the amount of wastewater will proportionately reduce the discharge of
entrained product. Saturated contaminants are present at high concentration in products and are
not readily soluble in water. Because these contaminants will have the same concentration
regardless of the amount of water and product, the mass flow of these contaminants is directly
proportional to the water flow. Extractable contaminants are somewhat soluble in both water
and product. These contaminants are able to partition in both the product and water phases;
therefore, reducing the wastewater flow, can reduce the discharge of these contaminants. Water-
borne (or water-soluble) contaminants are not expected to be soluble in products; therefore, these
contaminants are not affected by reducing tank bottoms flow rates. To reduce this type of
contaminant, facilities should reduce the source of water-soluble contaminants into the tank.
Reduction of Water Entrained in Product
A significant source of tank bottoms water is water entrained in the products.
This water is highly contaminated with water-soluble contaminants. Some procedures that can
minimize entrained water at PBSTs include reducing water in products delivered from tankage,
establishing distribution chain procedures, setting product specifications, and requiring take-back
of delivered water. In addition, there are some techniques that can be used to reduce or eliminate
entrainment of water.
PBSTs can reduce or eliminate entrainment of water in products delivered from
tankage using the same methods for reducing the amount of water drawn from a tank. These
methods include installing nozzles that draw the product as high as possible above the maximum
water level expected, keeping the tank water level as low as possible, removing tank water
before removing product, and using turned-up water nozzles that minimize entrainment of water.
Establishing distribution chain procedures from the refinery through the product
distribution chain can also minimize water content in product. In addition, PBSTs can set
product specifications for water or contaminants in product received at the terminal. PBSTs can
also return water delivered with the product to the originator, which gives originators incentive
to reduce the amount of water entrained in the products.
7-123
-------
Section 7 - Petroleum Refining
Reduction of Tank Breathing and Condensation
According to API, tank breathing air and condensation are minor sources of water
in tanks, and it is difficult to minimize or remove these water sources.
Reduction of Rainwater
Rainwater is a major source of tank bottoms water. It can be reduced or
eliminated by installing fixed roofs on the tanks. If floating roofs are used, then the roof seals
should be replaced or repaired periodically and floating roof drains should be cleared of
blockage.
7.12.6.3 Pollution Prevention Practices for Reducing Other Sources of Wastewater
Rack cleanup water is generated when product spills, product drips, and
accumulated dirt are rinsed from the equipment and/or slab. Facilities can reduce this source of
wastewater by using dry cleaning methods, such as absorbent granules or fabrics and wiping or
sweeping equipment. If washing is the only feasible option, then the minimal amount of water
should be used. Additionally, PBSTs should minimize the use of detergents by tracking the
amount of detergent used by each operator to avoid forming emulsions. Selected detergents
should have minimal impact.
To minimize vehicle wash water, vehicles can be taken offsite and washed at a
commercial vehicle washing facility. This will prevent the detergents from mixing with oily
wastewaters and forming emulsions. PBSTs can also discharge wash water into municipal
sewers to avoid mixing with other oily wastewaters. If vehicles are washed onsite, the amount of
detergent used should be minimized and vehicle wash water should be segregated from other
oily wastewaters.
Most vehicle maintenance wastes are comprised of vehicle fluids (e.g., brake fluid
and antifreeze), which contain additives that stabilize emulsions. Facilities should haul these
wastes offsite for recovery or disposal and not discharge them to the wastewater treatment
system. Collection drums should be located in vehicle maintenance areas for each type of fluid.
Cryogenic vapor recovery systems chill the air that is displaced when filling tanks
to remove hydrocarbon vapors. This method also condenses the humidity in the air, which
becomes saturated with hydrocarbons. Because this wastewater contains high concentrations of
hydrocarbons, the condensates are discharged to product tanks or slop oil tanks to recover
product; therefore, this source is not typically managed as a wastewater stream. If there is a
large amount of vapor recovery water, then there likely is an air leak into the aspiration system,
which must be fixed to prevent explosions.
Haulback material water bottoms are generated by water entering service station
tanks through leaks. To encourage service stations to fix such leaks and minimize the amount of
haulback material water bottoms, PBSTs can charge service stations for the cost of hauling and
7-124
-------
Section 7 - Petroleum Refining
treating haulback materials. If the water originates from the product delivered from the PBST,
then the PBST should minimize the entrainment of water as discussed previously.
The purpose of hydrostatic testing is to detect leaks in vessels and pipelines. This
process requires large amount of water at high flow rates. To minimize the contamination of this
water, PBSTs should clean the vessel or pipeline being tested thoroughly before the hydrotest.
Steam systems (or boilers) are used to heat heavy products to keep them fluid.
The steam generated for heating becomes contaminated by corrosion inhibitors that are added to
the boiler. To minimize wastewater generation, PBSTs should collect condensate from steam
traps, return it to the boiler, and fix any leaks. In addition, internal steam-heating coils used in
heavy products tanks may corrode, which can lead to leaks. To minimize this corrosion, PBSTs
can use external heating coils on insulated tanks.
Implementing the following methods can minimize laboratory wastewater flow
and contamination: using a vacuum pump or recycle water aspirator; disposing separately or
reprocessing spent solvents and test samples; not using regulated solvents; placing solids and
wastewater contaminated with regulated pollutants into collection drums for disposal; and
washing laboratory glassware in a water-saving dishwasher, minimizing the use of detergents in
cleaning.
Tanks accumulate sludge, which needs to be periodically removed by cleaning.
During cleaning, none of the oily sludge should come in contact with the ground around the tank.
In addition, having a contractor clean the tank and dispose the wastes generated off site can
minimize tank cleaning wastewaters. Dry-cleaning methods can also be used to minimize the
use of detergents. This wastewater should not come in contact with rainwater or oily
wastewater.
7.12.6.4 Conclusions
EPA's primary source of wastewater discharge information for PBSTs is TRI and
PCS. These sources contain discharge information for only a small portion of this industry,
however. Less than 1 percent of the number of PBSTs (as determined from the 1997 Census) are
in the PCS system, while only 5.5 percent reported to TRI in 2000.
Based on the information in TRI and PCS, pollutant discharges from PBSTs are
small in comparison to those of other industrial categories, including refineries. Using
information reported to TRI, EPA estimates that PBSTs discharge 8,010 TWPE to waters of the
U.S. A few facilities contribute the overwhelming majority of this total TWPE. TRI
information also indicates that the vast majority of these TWPEs are associated with stormwater
discharges. Of the few facilities contributing to the overall TWPE, one (contributing 3,290
TWPEs) ceased operations in 2000. Discharges from a second facility (contributing more than
2,600 TWPE), are from a now-closed refinery that also performed PBST operations and are
attributed to groundwater remediation activities only. Similarly, two facilities contribute the
large majority of the 5,389 TWPE reported to PCS. Information from the PCS reporting
7-125
-------
Section 7 - Petroleum Refining
facilities that also report to TRI indicates that stormwater discharges are a significant source of
the toxic pollutants discharged.
Information collected from permit and control authorities, site visits, and
comment responses supports the conclusions reached from the TRI and PCS data. With few
exceptions, discharges from PBSTs appear to be primarily stormwater with low concentrations
of toxic pollutants. In addition, these stormwater discharges are subject to general or individual
stormwater permits. Moreover, commenters and control authorities widely reported that tank
bottoms water, the source of the most toxic waters produced at PBSTs are, by and large,
transferred off site for treatment.
Therefore, based on this review, EPA has concluded that most PBSTs do not
discharge toxic pollutants to waters of the United States. Of those that discharge, most discharge
only stormwater which is subject to general or individual stormwater permitting requirements.
For the few PBSTs that EPA identified as discharging toxic pollutants, EPA concludes it is
reasonable to provide individual facility permit support, rather than an effluent guidelines
rulemaking.
While EPA is deferring the development of effluent guidelines for PBSTs as a
new subcategory under 40 CFR Part 419, it will continue to examine this industrial activity in
future review cycles.
7.12.7 PBST References
1. Siddiqui, M.A., U.S. EPA. Memorandum to the Effluent Guidelines Planning
Docket. Discharge Status of PBST Facilities, as Enumerated by TRI and PCS
Databases. March 10, 2004.
2. Siddiqui, M.A., U.S. EPA. Telephone conversation regarding PBSTs with
George Papadopoulos, U.S. EPA Region 1. April 29, 2004.
3. Siddiqui, M.A., U.S. EPA. Memorandum to the Effluent Guidelines Planning
Docket. Summary of Discussions with Permit Writers About PBST Facilities.
April 29, 2004.
4. Siddiqui, M.A., U.S. EPA. Memorandum to the Effluent Guidelines Planning
Docket. Meeting with PBST Stakeholders. August 8, 2004.
5. Siddiqui, M.A., U.S. EPA. Telephone discussion regarding PBSTs with Jim Ball
and Eric Beck, Rhode Island Department of the Environment, Providence, Rhode
Island. April 29, 2004.
6. Pennsylvania State University. Thesis submitted in partial completion of Master
of Science degree requirements by Julia DeNardo.
7-126
-------
Section 8 - Nutrient Criteria Analysis
SECTION 8 NUTRIENT ANALYSIS
8.1 Introduction
Nutrients entering surface waters can cause many problems for aquatic ecosystem
conditions. Excess nutrients can lead to eutrophication resulting in algal blooms, depleted
oxygen levels, fish kills, and reduced biodiversity. In its annual review of effluent guidelines
under Section 304(b) of the Clean Water Act, EPA examined the potential water quality impacts
of nutrient discharges from facilities in the two industries for which EPA performed detailed
studies (petroleum refining and OCPSF) to surface waters (4). This analysis is described in the
following sections.
8.2 Reference Conditions
EPA's recommended Section 304(a) ecoregional water quality criteria for
nutrients were developed with the aim of reducing and preventing cultural eutrophi cation (i.e.,
over enrichment of surface waters associated with human activities) on a national scale. The
criteria were empirically derived to represent conditions of surface waters that are minimally
impacted by human activities and protective of aquatic life and recreational uses. The nutrient
criteria are numerical values for both causative (phosphorus and nitrogen) and response
(chlorophyll a and turbidity) variables associated with the prevention and assessment of
eutrophic conditions. They are not laws or regulations, but they represent EPA's
recommendations as a starting point for states and tribes to use in establishing (with assistance
from EPA) more refined nutrient criteria. While cultural eutrophication occurs in all parts of the
country, specific levels of overenrichment leading to these problems vary from one region of the
country to another due to geographical variations in watershed characteristics such as
geographical variations in geology, vegetation, climate, and soil types. EPA has, therefore,
developed its recommended nutrient criteria on an ecoregional basis.
Ecoregions are geographical areas based on similarities of natural
geomorphological and biological characteristics and land use patterns. Ecoregions can be defined
at multiple scales. For example, EPA has defined 14 nutrient ecoregions and 84 Level III
subecoregions in the United States. Nutrient ecoregions are aggregations of Level III
subecoregions where the landscape characteristics affecting nutrient levels are expected to be
similar.
For this analysis, EPA determined reference conditions for total nitrogen and total
phosphorous in rivers and streams for the 14 aggregate nutrient ecoregions. The reference
conditions represent the least impacted conditions for a given ecoregion. The reference
conditions were statistically determined by EPA following analyses of EPA's STOrage and
RETrieval (STORET) legacy data, USGS National Stream Quality Accounting Network
(NASQAN) data, USGS National Water-Quality Assessment (NAWQA) data, and other relevant
nutrient data from EPA regions, states, and universities. EPA used readily available data
collected between January 1990 and December 1999. For each stream for which data existed
within an ecoregion, EPA calculated the median nutrient concentrations in that stream for each
8-1
-------
Section 8 - Nutrient Criteria Analysis
season of the year. Then, EPA took those median concentrations for each stream and calculated
the 25th and 50th percentiles for the entire ecoregion during each of the four seasons. More
information on the calculation of the reference conditions can be found in EPA's published 14
ecoregional documents for rivers and streams available at http://www.epa. gov/waterscience/
criteria/nutrient/ecoregions/rivers/index.html (3). The aggregate reference conditions for each
ecoregion were then calculated as the median value of the 25th percentiles and the 50th percentiles
of the four seasons. The reference conditions representing the 25th and 50th percentiles were used
in the stream dilution modeling as described in Section 8.4.
8.3 Decay Coefficients
Several processes, such as denitrification, uptake by aquatic biota, and
sedimentation, occur naturally in streams and rivers to reduce the available levels of nitrogen and
phosphorus. Research indicates that the total effect of these processes can be modeled using a
first-order decay reaction. As discussed in an analysis of the effects of nutrient export between
subwatersheds that accounts for nutrient decay by Wickham, et al (8), the amount of nitrogen
and phosphorus delivered to a point downstream is an exponential function of travel time and a
decay coefficient. Smith et al (2) developed decay coefficient values for nitrogen and phosphorus
to be used in the Spatially Referenced Regressions on Watershed Attributes (SPARROW)
model. The values were developed using data from over 380 USGS NASQAN stations. The
decay coefficients were developed for use with three stream flowrate categories: <1,000 ft3/s,
1,000 - 10,000 ft3/s, and >10,000 ft3/s and are shown in Table 8-1. These values were also used
in the development of the environmental assessment for Concentrated Animal Feeding
Operations (see Estimation of National Economic Benefits Using the National Water Pollution
Control Assessment Model to Evaluate Regulatory Options for Concentrated Animal Feeding
Operations (CAFOs, EPA-821-R-03-009) December, 2002). For this analysis, 21 of the 68
modeled petroleum refining facilities and 70 of the 190 modeled OPCSF facilities were located
on streams with a mean flow rate of greater than 10,000 ft3/s.
These decay coefficients (Table 8-1) were used in the stream dilution modeling.
8-2
-------
Section 8 - Nutrient Criteria Analysis
Table 8-1. Decay Coefficients for Nitrogen and Phosphorus, Segregated by Stream
Flowrate
Flowrate
(ft3/s)
< 1,000
LOGO - 10,000
>10,000
Decay Coefficients (d ')*
Nitrogen
0.3842
0.1227
0.0408
Phosphorus
0.2680
0.0956
0.0156
* Values were taken from the Filial Model Bootstrap Coefficient column reported in Tables 1 and 2 from Smith et al
(1997). The report did not develop a phosphorus decay coefficient for flowrates >10,000 ftVs, so the Final Model
Lower 90 percent Confidence Interval for flowrates between 1,000 and 10,000 ftVs is being applied. This application
is reasonable as the faster the flow rate, the longer it would take for the decay process to occur. Therefore, it is
assumed that the lower 90 percent confidence is representative of the higher flow rates (i.e., those close to 10,000
ff/s).
8.4
Methodology for Developing Total Nitrogen and Total Phosphorous Loads
This section describes the methodology that was applied to calculate total
nitrogen and phosphorus loads for OCPSF facilities and petroleum refineries.
8.4.1
Total Nitrogen Load
The PCS database contains approximately 50 different parameters that may be
reported for nitrogen compounds, and the TRI database includes discharge data for three
nitrogen compounds. Table 8-2 presents the nitrogen compounds that are reported to TRI and
PCS by OCPSF and petroleum refining facilities. The following assumptions were made
regarding the parameters in Table 8-2:
• Total Nitrogen is the sum of organic nitrogen, ammonia, nitrite, and
nitrate;
• Total Inorganic Nitrogen is the sum of ammonia, nitrite, and nitrate;
• Total Kjeldahl Nitrogen (TKN) is the sum of organic nitrogen and
ammonia; and
• Unionized ammonia is a subset of total ammonia.
8-3
-------
Section 8 - Nutrient Criteria Analysis
Table 8-2. Nitrogen Compounds Reported to TRI and PCS by OCPSF and Petroleum
Refining Facilities
PRAM Code or CAS Number
Compound
In PCS Database:
00600
00605
00610
00615
00619
00620
00625
00630
00640
34726
61574
Nitrogen, Total (As N)
Nitrogen, Organic Total (As N)
Nitrogen, Ammonia Total (As N)
Nitrogen, Nitrite Total (As N)
Ammonia, Unionized
Nitrogen, Nitrate Total (As N)
Nitrogen, Kjeldahl Total (As N)
Nitrite pins Nitrate Total 1 DET (As N)
Nitrogen, Inorganic Total
Nitrogen, Ammonia, Total (As NH3)
Ammonia (As N) + Unionized Ammonia
In TRI Database:
7632000
7664417
N511
Sodium Nitrite
Ammonia
Nitrate Compounds
Loads of compounds that are not reported as nitrogen, such as sodium nitrite,
nitrate compounds, or ammonia, were converted to pounds of nitrogen using the following
equation:
Lbs Nitrogen = Lbs Compound * (Molecular Weight (MW) Nitrogen / MW Compound)
The data obtained from the PCS and TRI databases required manual modification
to avoid overestimating the nitrogen loads. For some facilities, a single NPDES number
matched multiple TRI Ids, and vice versa. In the case where a single NPDES number matched
multiple TRI Ids, the PCS loads were divided among the TRI Ids. In the case where a single TRI
Id matched multiple NPDES numbers, the TRI releases were divided among the NPDES
numbers.
The following hierarchy was applied for calculating the total nitrogen load:
1. Use PC S PRAM 00600, if reported, to represent total Nitrogen.
8-4
-------
Section 8 - Nutrient Criteria Analysis
2. If PCS PRAM 00600 is not reported, use the sum of TKN, Nitrite, and
Nitrate.
3. If neither of the first two rules apply, use the sum of Organic Nitrogen,
Ammonia, Nitrite, and Nitrate.
4. Where applicable, use TRI data to fill in for missing PCS parameters in
the total nitrogen calculation.
5. If no nitrogen compounds are reported to PCS, use the sum of Ammonia,
Sodium nitrite, and Nitrate compounds reported to TRI.
The final loads table presents the TRI ID, NPDES number, total nitrogen load, REACH number,
and the latitude/longitude coordinates for each facility.
8.4.2 Total Phosphorus Load
The total phosphorus load was calculated using PCS data. The TRI database only
includes discharge data for elemental phosphoais, which is not reported by any of the facilities in
OCSPF or Petroleum Refining. Table 8-3 presents the phosphorous parameters that are reported
to PCS by OCPSF and petroleum refining facilities.
Table 8-3. Phosphorus Parameters Reported to PCS by OCPSF and Petroleum Refining
Facilities
PRAM Code
00665
00662
00650
70507
71888
Phosphorus Parameter
Phosphorus,
Phosphorus.
Total (As P)
Total Recoverable
Phosphate, Total (As PO4)
Phosphorus,
Phosphorus,
in Total Orthophosphate
Total Soluble (As PO4)
All discharges that were reported as phosphate were converted to pounds of
phosphorus using the following equation:
Lbs Phosphorus = Lbs Phosphate * (MW Phosphorus / MW Phosphate).
The data obtained from the PCS database required manual modification to avoid
overestimating the phosphorus loads. For some facilities, a single NPDES number matched
multiple TRI Ids. For these facilities, the PCS loads were divided among the TRI Ids.
The following hierarchy was applied for selecting PCS parameters to represent
the total phosphorus load:
8-5
-------
Section 8 - Nutrient Criteria Analysis
1. Use PCS PRAM 00665, if reported, to represent total Phosphorus.
2. If PCS PRAM 00665 is not reported, use the Total Recoverable
Phosphorus load.
3 . If neither of the first two rules apply, use the Phosphate load.
4. If no other Phosphorus parameters are reported, use the Soluble Phosphate
load.
The final loads table presents the TRI ID, NPDES number, total phosphorus load, REACH
number, and the latitude/longitude coordinates for each facility.
8.5 Stream Dilution Modeling
EPA incorporated exponential decay loss for total nitrogen and total phosphorus
into a simplified stream dilution model by projecting the concentration, under 7Q10 low flow
(lowest consecutive seven-day average flow during any 10-year period) and mean receiving
stream flow conditions, at a distance (1,000 m) downstream from 68 petroleum refining facilities
discharging to 57 receiving streams and 190 OCPSF facilities discharging to 153 receiving
streams (Equations 1 and 2). Facilities discharging to estuaries^ays were not evaluated.
xCF B,. 1
IS FF+SF
C -C e~^ Eq. 2
^ds~^isc M
where
Cis = instream pollutant concentration (milligrams per liter [mg/L])
L = facility pollutant loading (pounds per year [lbs/yr])
OD = facility operating days (days per year [days/yr])
FF = facility effluent flow (million gallons per day [MOD])
SF = receiving stream flow (million gallons per day [MGD])
CF = conversion factors for units
Cfc = in-stream pollutant concentration 1,000 meters downstream (milligrams
per liter [mg/L])
k = decay coefficient (days'1)
t = time to travel 1,000 meters (days)
Receiving stream flow data were obtained from the W.E. Gates study data which is contained in
EPA's GAGE File (5). Facility effluent flow data were obtained from EPA's Permit Compliance
System (PCS) (1) or Industrial Facilities Discharge (IFD) File (6). All facilities were assumed to
be in operation 365 days per year. The 1,000 m distance represents the maximum distance that
the stream flow rates and velocities for a particular reach were considered applicable. EPA then
estimated the travel time required in the exponential decay equation by dividing the travel
8-6
-------
Section 8 - Nutrient Criteria Analysis
distance (1,000 m) by the reach velocity (available from EPA's GAGE File). The estimated
instream concentrations were then compared to the appropriate total nitrogen and total
phosphorous aggregate reference condition values to estimate the effects on the environment at
current discharge levels. Each of the modeled facilities was assigned to one of the 14 nutrient
ecoregions based on locational information and the use of Arc View GIS software. EPA
identified the locations of facilities on receiving streams using the U.S. Geological Survey
(USGS) cataloging and stream segment (reach) numbers contained in EPA's REACH File (RF1)
(7). Estimated instream concentrations were compared directly to the 25th and 50th percentile
aggregate reference condition values to determine impacts. To determine a water quality
excursion, EPA divided the projected instream concentration by the reference condition value. A
number greater than 1.0 indicated an excursion.
8.6 Results
The results of this analysis indicate the potential water quality impacts of nutrient
discharges from petroleum refining and OCPSF facilities. Tables 8-4 and 8-5 present a summary
of the results. This analysis is not designed to predict actual instream concentrations, but instead
evaluate, at a screening level, the relative impacts of facilities under current conditions.
8.6.1 Petroleum Refining
Under current discharge levels, in the absence of all other sources of nitrogen and
phosphorus, and assuming 7Q10 low flow stream conditions, nitrogen concentrations in 12
receiving streams (out of 57 modeled) would exceed the upper 25th percentile reference condition
of'least impacted' streams due to petroleum refining discharges. (Table 8-4. As noted above,
EPA's recommends that states and tribes use the upper 25th percentile reference condition of
'least impacted' streams as a starting point for establishing more refined nutrient criteria.)
Petroleum refining discharges would result in 11 receiving streams having estimated instream
nitrogen concentrations higher than the 50th (i.e., median) percentile reference conditions. Under
mean flow conditions, one receiving stream is projected to exceed both the 25th percentile
reference condition of 'least impacted' streams and 50th (i.e., median) percentile reference
conditions (Table 8- 4). When modeled similarly, phosphorus discharges from petroleum
refining plants do not result in any streams having concentrations higher than the upper 25th
percentile reference condition of 'least impacted' streams. (Table 8-4). EPA notes that, by
definition, many receiving streams exceed the 25th and 50th percentile reference conditions, even
in the absence of petroleum refining facility discharges, but this screening-level analysis
demonstrates the potential for petroleum refining nutrient discharges to affect water quality.
3-7
-------
Section 8 - Nutrient Criteria Analysis
Table 8-4. Summary of Screening-level Nutrient Analysis for Petroleum Refining Direct
Discharge Facilities
Total Nitrogen
7Q10 Flow
Mean Flow
Total Phosphorus
7Q10 Flow
Mean Flow
25th Percentile
Current
Stream (No.)
Magnitude
12
1.3-9.4
1
7.0
0
NA
0
NA
50th Percentile
Current
Stream (No.)
Magnitude
11
1.2-5.4
1
4.8
0
NA
0
NA
Note: Magnitude represents the range in the extent of the excursions (i.e., ratio of instream concentrations to
criteria >1.0)
25th and 50ttl percentiles aggregate seasons and nutrient ecoregion reference conditions
Number of streams evaluated = 57 and number of facilities = 68
Assumes operating days = 365
May 2004, Loadings File
8.6.2 OCPSF
Under current discharge levels, in the absence of all other sources of nitrogen and
phosphorus, and assuming 7Q10 low flow stream conditions, nitrogen concentrations in 19
receiving streams (out of 153 modeled) would exceed the upper 25th percentile reference
condition of 'least impacted' streams due to OCPSF discharges. (Table 8-5. As noted above,
EPA's recommends that states and tribes use the upper 25th percentile reference condition of
'least impacted' streams as a starting point for establishing more refined nutrient criteria.)
OCPSF discharges would result in 14 receiving streams having estimated instream nitrogen
concentrations higher than the 50th (i.e., median) percentile reference conditions. Under mean
flow conditions, four receiving streams are projected to exceed both the 25th and 50th percentile
reference conditions (Table 8-5). When modeled similarly, phosphorus discharges from OCPSF
plants do not result in any streams having concentrations higher than the upper 25th percentile
reference condition of 'least impacted' streams. (Table 8-5). EPA notes that, by definition, many
streams exceed the 25th and 50th percentile reference conditions, even in the absence of OCPSF
facility discharges, but this screening-level analysis demonstrates the potential for OCPSF
nutrient discharges to affect water quality.
-------
Section 8 - Nutrient Criteria Analysis
Table 8-5. Summary of Screening-level Nutrient Analysis for OCPSF Direct Discharge
Facilities
Total Nitrogen
7Q10 Flow
Mean Flow
Total Phosphorus
7Q10 Flow
Mean Flow
25th PercentUe
Current
Stream (No.)
Magnitude
19
1.0-355
4
1.9-75
0
NA
0
NA
50th PercentUe
Current
Stream (No.)
Magnitude
14
1.0-252
4
1.2-53
0
NA
0
NA
Note: Magnitude represents the range in the extent of the excursions (i.e., ratio of instream concentrations to criteria
>1.0)
25th and 50th percentiles aggregate seasons and nutrient ecoregion reference conditions
Number of streams evaluated = 153 and number of facilities = 190
Assumes operating days = 365
May 2004, Loadings File
8.7
References
Permit Compliance System (PCS). Estimated Using the Effluent Data Statistics
System (EDSS). Washington, D.C. April 1996.
Smith R.A., G.E. Schwartz, and R.B. Alexander. "Regional Interpretation of
Water-Quality Monitoring Data." Water Resources Research 33:2781 -2798.
1997.
U. S. EPA. Ecoregional Nutrient Criteria Documents for Rivers and Streams.
Available online at: http://www.epa.gov/waterscience/criteria/nutrient/
ecoregions/rivers/index.html. Washington, D.C. Accessed October 2003.
U.S. EPA, Office of Water, Engineering and Analysis Division. Petroleum
Refining and OCPSF Loadings File. Washington, D.C. 2004.
U.S. EPA, Office of Wetlands, Oceans, and Watersheds. GAGE File. Washington,
D.C. Downloaded February 2000.
U.S. EPA, Office of Wetlands, Oceans and Watersheds. Industrial Facilities
Discharge (IFD) File. Washington, D.C. Downloaded November 1998.
8-9
-------
Section 8 - Nutrient Criteria Analysis
7. U.S. EPA, Office of Wetlands, Oceans, and Watersheds. REACH File (RF1).
Washington, D.C. Downloaded February 2000.
8. Wickham J.D., T.G. Wade, K.H. Riitters, R.V. O'Neill, J.H. Smith, E.R. Smith,
K.B. Jones, and A.C. Neale. "Upstream-to-Downstream Changes in Nutrient
Export Risk." Landscape Ecology, 18:195-208. 2003.
8-10
-------
Section 9 - Industries Identified as New By Commenters
SECTION 9 INDUSTRIES IDENTIFIED AS NEW BY COMMENTERS
This section discusses EPA's identification of new industrial categories for
effluent guidelines rulemaking. Section 304(m)(l)(B) of the Clean Water Act requires EPA to
identify categories of sources discharging toxic and nonconventional pollutants in nontrivial
amounts, for which effluent guidelines under Section 304(b)(2) and new source performance
standards under Section 306 have not yet been published. EPA identified two industrial
activities that meet the criteria specified in Section 304(m)(l)(B): airport deicing operations and
drinking water supply and treatment facilities. EPA is identifying both of these activities in the
2004 Final Effluent Guidelines Program Plan. This section provides information on the basis for
EPA's identification of these two new categories.
9.1 Airport Deicing Operations
EPA did not identify the airport deicing discharges (SIC code 4581) as a potential
candidate for effluent guidelines development in the Preliminary Plan. At that time, EPA noted
that it had inadequate data to determine if airport deicing discharges were nontrivial. Public
comments on the Preliminary Plan suggested that EPA consider developing effluent guidelines
for this industrial sector due to the potential for facilities in this industrial sector to discharge
nontrivial amounts of nonconventional and toxic pollutants. In particular, commenters stated
that airport deicing fluid (ADF) is not properly recaptured and re-used or properly treated before
discharge. Commenters noted that these discharges can cause significant harm to natural
resources such as fish kills, algae blooms, and contamination of surface or ground waters.
Following the Preliminary Plan, EPA collected additional information and
revisited the information in its docket. EPA's primary source of wastewater discharge
information for this industry is its Preliminary Data Summary: Airport Deicing Operations.,
which was published in August 2000 (EPA-821-R-00-016). This study focused on
approximately 200 U.S. airports with potentially significant deicing/anti-icing operations. The
major source of pollutant discharges from deicing operations is deicing agent contaminated
stormwater which typically contains water, glycols, and additives. However, the study showed
that there was great disparity among airports in terms of permit requirements. Some airports,
generally those with stringent stormwater discharge permits, had made great strides in terms of
wastewater collection, containment, pollution prevention and/or recycling/treatment programs.
Other airports, however, did much less to manage their stormwater.
At the time of the study, annual discharge estimates to surface waters were 21
million gallons of ADF. EPA also estimated that full implementation of stormwater permits
would reduce these discharges to 17 million gallons annually. Finally, the study also estimated
possible reductions in ADF discharges if effluent limitations guidelines and standards were
implemented for discharges resulting from airport deicing operations. Using results from
technologies and pollution prevention practices employed at some of the better performing
airports, EPA estimated annual surface water discharges could be reduced to 4 million gallons.
9-1
-------
Section 9 - Industries Identified as New By Commenters
A review of current and proposed discharge permits for over 20 airports indicates
that while some airports have more stringent permits and have reduced their ADF discharges
since EPA's earlier study was conducted, there is still significant disparity among discharge
requirements. For example, some are only required to implement BMPs and sample on a limited
basis for a few conventional pollutants while others have instituted significant BMPs, collection,
and/or treatment to comply with a 2 mg/L ADF discharge limitation. Based on the information
in its study and a review of this permit information, EPA concludes that it is appropriate to
identify discharges from airport deicing operations in this Final Plan, and to take final action on
effluent guidelines within three years.
For information about EPA's economic analysis and small business
considerations of this sector, see the August 16, 2004 Memorandum entitled Airport Industrial
Discharges—Industry Profile and the August 6, 2004 memorandum entitled Airport Industrial
Discharges: Number of Small Entities (located in the docket).
9.2 Drinking Water Supply & Treatment
EPA did not identify the drinking water supply and treatment industrial sector
(SIC code 4941) as a potential candidate for effluent guidelines development in the Preliminary
Plan. At that time, EPA concluded that almost all of the hazard posed by this industrial sector
was due to a few facilities. In particular, EPA's analysis showed that a single facility was
contributing over 97% of the TWPE discharges for the entire industrial sector. Public comments
on the Preliminary Plan suggested that EPA consider developing effluent guidelines for this
industrial sector due to the potential of facilities in this industrial sector to discharge nontrivial
amounts of nonconventional and toxic pollutants (e.g., metals and salts). In particular,
commenters stated that many drinking water facilities have the potential to discharge significant
quantities of conventional and toxic pollutants. These commenters noted that the source of these
pollutants can include drinking water treatment sludges and reverse osmosis reject wastewaters.
Consequently, EPA attempted to collect additional information and re-evaluated the information
in the docket supporting the 2004 Final Plan.
Based on information in the 1997 Economic Census, EPA estimates there are
3,700 drinking water treatment and supply facilities in the United States. For information about
EPA's economic analysis and small business considerations of this sector, see the August 11,
2004 Memorandum entitled Drinking Water Facilities Profile and the August 4, 2004
memorandum entitled Estimated Number of Small Entities Owning Drinking Water Facilities
(located in the docket).
EPA's primary source of wastewater data for this industry is EPA's Permit
Compliance System (PCS). This database contains information required by the NPDES Permit
Program for major dischargers across the country, including discharge flows and pollutant
9-2
-------
Section 9 - Industries Identified as New By Commenters
concentrations1. EPA was therefore able to analyze this information for the 16 drinking water
supply and treatment facilities with major permits for the year 2000. However, EPA does not
require states to include such data for other dischargers (e.g., minor and indirect dischargers) in
PCS, so little information is available about industries dominated by minor and indirect
dischargers. PCS lists approximately 900 drinking water supply and treatment facilities as
having minor permits for the year 2000, but does not include data on discharge flows or pollutant
concentrations. Consequently, EPA was unable to quantify discharges from these minor and
indirect discharging facilities.
The TWPE for the sixteen facilities ranged from significant to very low. Total
residual chlorine and metals (e.g., manganese and aluminum) represent most of the TWPE
discharges from these sixteen facilities. The TWPE estimate for these sixteen facilities is largely
related to the wastewater discharges from three facilities. For the remaining 13 facilities, PCS
data indicate that pollutants are being discharged at or near the detection levels raising concerns
about further treatability of these pollutants using end-of-pipe treatment. More recent PCS
information suggests the TWPE discharges at some of these sixteen facilities have decreased. In
particular, the top two hazard discharging facilities for the year 2000 have added technology to
properly de-water their wastewater treatment sludges and are likely to reduce their wastewater
discharges by 85 percent or more. Further, one of the two facilities no longer discharges any
wastewater associated with drinking water operations. Analysis of PCS data from 2003 indicates
that the sixteen facilities with quantitative data are currently discharging approximately 20,500
TWPEs.
While this PCS data suggests that some drinking water supply and treatment
facilities with direct discharging permits are not discharging pollutants in significant
concentrations, it also supports commenters' statements that other drinking water treatment and
supply facilities may discharge nontrivial amounts of toxic and nonconventional pollutants,
which EPA considers in deciding whether EPA should develop effluent guidelines for an
industry that is not yet regulated by effluent guidelines. Therefore, EPA has identified the
drinking water supply and treatment industry as a possible new category in the 2004 Final Plan
and will take final action on potential effluent guidelines for this category within three years.
See CWA Section 304(m)(l)(C).
'A major discharger is any NPDES facility or activity classified as such by the Regional Administrator, or, in the
case of approved State Programs, the Regional Administrator in conjunction with the State Director. Major
industrial facilities are determined based on specific ratings criteria developed by EPA and approved State Programs.
9-3
------- |