v>EPA
United States
Environmental Protection
Agency
Technical Support Document for the 2006
Effluent Guidelines Program Plan
December 2006
EPA-821R-06-018
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Table of Contents
TABLE OF CONTENTS
Page
PARTI: INTRODUCTION I
1.0 BACKGROUND 1-1
1.1 EPA's Clean Water Act Program 1-1
1.2 Background on the Effluent Guidelines Program 1-1
1.3 What are Effluent Guidelines and Pretreatment Standards? 1-2
1.3.1 Best Practicable Control Technology Currently Available
(BPT) - CWA Sections 301(b)(l)(A) & 304(b)(l) 1-4
1.3.2 Best Conventional Pollutant Control Technology (BCT) -
CWA Sections 301(b)(2)(E) & 304(b)(4) 1-5
1.3.3 Best Available Technology Economically Achievable
(BAT) - CWA Sections 301(b)(2)(A) & 304(b)(2) 1-5
1.3.4 New Source Performance Standards (NSPS) - CWA
Section 306 1-5
1.3.5 Pretreatment Standards for Existing Sources (PSES) -
CWA Section 307(b) 1-5
1.3.6 Pretreatment Standards for New Sources (PSNS) - CWA
Section 307(c) 1-6
1.4 Success of EPA's Effluent Guidelines Program 1-6
1.5 What Are EPA's Effluent Guidelines Planning and Review
Requirements? 1-6
2.0 PUBLIC COMMENT s ON THE PRELIMINARY EFFLUENT GUIDELINES PROGRAM
PLAN FOR 2006 AND FINAL EFFLUENT GUIDELINES PROGRAM PLAN FOR 2004... 2-1
3.0 THE EFFLUENT GUIDELINES PLANNING PROCESS 3-1
3.1 Goals of the ELG Planning Process 3-1
3.2 Annual Review of Existing Effluent Guidelines and Pretreatment
Standards 3-1
3.2.1 Factors Considered in Review of Existing Effluent
Guidelines and Pretreatment Standards 3-1
3.2.2 Overview: Review of Existing Point Source Categories 3-5
3.3 Identification of New Categories of Direct Dischargers for Possible
Effluent Guidelines Development 3-7
3.4 Identification of New Categories of Indirect Dischargers for Possible
Effluent Guidelines Development 3-8
3.5 Stakeholder Involvement and Schedule 3-8
3.6 References 3-9
4.0 METHODOLOGY, DATA SOURCES, AND LIMITATIONS 4-1
4.1 Data Sources and Limitations 4-1
4.1.1 SIC Codes 4-2
4.1.2 Toxic Weighting Factors 4-3
4.1.3 Calculation of TWPE 4-3
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4.1.4 Data from TRI 4-3
4.1.5 Data from PCS 4-6
4.2 Methodology Corrections Affecting Both Screening-Level Review
Databases 4-9
4.2.1 Summary of TRIReleases and PCSLoads Database
Methodology Changes 4-9
4.2.2 Summary of TRIReleases and PCSLoads Database
Methodology Comments Resulting in No Changes 4-9
4.2.3 Revisions to TWF Development 4-13
4.2.4 Conclusions 4-17
4.3 Corrections Affecting Only the TRIReleases Databases 4-17
4.3.1 TWF Changes for Compound Groups 4-17
4.3.2 Database Corrections 4-28
4.4 Corrections Affecting Only the PCSLoads Databases 4-28
4.4.1 Database Corrections 4-28
4.4.2 Corrections Made to Steam Electric Power Generating
Facilities PCS Discharges 4-29
4.5 TRI 2002 and 2003 Rankings and PCS 2002 Rankings 4-29
4.5.1 Results of the TRIReleases2002, TRIReleases2003, and
PCSLoads2002 Databases 4-29
4.5.2 Data Quality Review of the TRIReleases2002,
TRIReleases2003, and PCSLoads2002 Databases 4-39
4.6 References 4-43
PART II: RESULTS OF THE 2006 ANNUAL REVIEW OF INDUSTRIAL
CATEGORIES WITH EXISTING ELGS II
5.0 2006 ANNUAL REVIEW OF EXISTING EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS AND RANKING OF POINT SOURCE CATEGORIES 5-1
5.1 Summary of the Results from the 2005 Annual Review 5-1
5.2 Results of the 2006 Screening-Level Review 5-1
5.2.1 Facilities for Which EPA is Currently Developing or
Revising ELGs 5-2
5.2.2 Categories for Which EPA Recently Promulgated or
Revised ELGs 5-2
5.2.3 Categories with One Facility Dominating the TWPE 5-3
5.2.4 Results of the 2006 Screening-Level Review 5-5
5.3 Prioritization of Categories for the 2006 Annual Review 5-5
5.3.1 Detailed Study of Existing ELGs 5-11
5.3.2 Preliminary Review 5-11
5.4 References 5-12
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6.0 COAL BED METHANE SUBCATEGORY OF THE OIL AND GAS EXTRACTION
CATEGORY (40 CFR PART 43 5) 6-1
6.1 Current Applicability of Effluent Limitations Guideline for Oil and
Gas Extraction 6-1
6.1.1 CBM Extraction as a Potential New Subcategory of the Oil
and Gas Extraction Category 6-2
6.1.2 CBM Industry Current Permitting Practices 6-3
6.2 Summary of Comments Received Regarding the Coal Bed Methane
Industry 6-4
6.3 CBM Industry Profile 6-5
6.3.1 Data on CBM-Produced Water Discharges 6-5
6.3.2 Future CBM Basin Exploration 6-8
6.4 Oil and Gas Extraction Category 2005 Annual Review 6-8
6.5 CBM Production 6-8
6.6 CBM-Produced Water Sources and Characteristics 6-11
6.6.1 CBM-Produced Water Pollutants of Concern 6-11
6.6.2 Adverse Impacts from CBM-Produced Water Discharges 6-12
6.7 CBM-Produced Water Treatment and Disposal 6-13
6.7.1 Surface Discharge of CBM-Produced Water 6-14
6.7.2 Storage/Evaporation Ponds for CBM-Produced Water 6-14
6.7.3 Injection of CBM-Produced Water 6-15
6.7.4 Hauling with Commercial Disposal of CBM-Produced
Water 6-16
6.7.5 Technology Options for Beneficial Use and Disposal of
CBM-Produced Water 6-16
6.8 Cost and Affordability of Treatment Technologies for CBM-
Produced Water 6-17
6.9 CBM Industry Trends 6-18
6.9.1 Energy Market Trends 6-18
6.9.2 Economic Structure of CBM Operations 6-20
6.10 CBM Subcategory Conclusions for the 2006 Plan 6-21
6.11 CBM Industry References 6-22
7.0 COAL MINING (40 CFR PART 434) 7-1
7.1 Coal Mining Category Background 7-1
7.1.1 Coal Mining Industry Profile 7-1
7.1.2 40 CFR Part 434 7-3
7.1.3 Surface Mining Control and Reclamation Act of 1977
(SMCRA) 7-4
7.2 Coal Mining Category 2005 Annual Review 7-5
7.2.1 Coal Mining Category 2005 Screening-Level Review 7-5
7.2.2 Coal Mining Category 2005 Pollutants of Concern 7-5
7.3 Coal Mining Category Potential New Subcategories 7-5
7.4 Coal Mining Category 2006 Annual Review 7-6
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7.5 Coal Mining Category Conclusions 7-6
7.6 Coal Mining Category References 7-6
8.0 FERTILIZER MANUFACTURING (40 CFR PART 418) 8-1
8.1 Fertilizer Manufacturing Category Background 8-1
8.1.1 Fertilizer Manufacturing Industry Profile 8-1
8.1.2 40 CFR Part 418 8-3
8.2 Fertilizer Manufacturing Category 2005 Annual Review 8-4
8.2.1 Fertilizer Manufacturing 2005 Screening-Level Review 8-4
8.2.2 Fertilizer Manufacturing Category 2005 Pollutants of
Concern 8-5
8.3 Potential New Subcategories for the Fertilizer Manufacturing
Category 8-5
8.4 Fertilizer Manufacturing Category 2006 Annual Review 8-6
8.4.1 Fertilizer Manufacturing Category Facility Classification
Revisions 8-6
8.4.2 Fertilizer Manufacturing Category TWF and POTW Percent
Removal Revisions 8-6
8.4.3 Fertilizer Manufacturing Category 2006 Screening-Level
Review 8-7
8.4.4 Fertilizer Manufacturing Category 2006 Pollutants of
Concern 8-7
8.5 Fertilizer Manufacturing Category 2006 Top Discharging Facilities 8-9
8.5.1 Wet-Process Phosphoric Acid Process Description 8-9
8.5.2 Wastewater Sources of Fluoride 8-10
8.5.3 Wastewater Treatment of Fluoride 8-10
8.5.4 Top Facility Permit Compliance 8-11
8.6 Fertilizer Manufacturing Conclusions 8-14
8.7 Fertilizer Manufacturing References 8-14
9.0 INORGANIC CHEMICALS MANUFACTURING (40 CFR PART 415) 9-1
9.1 Inorganic Chemicals Category Background 9-1
9.1.1 Inorganic Chemicals Industry Profile 9-1
9.1.2 40 CFR Part 415 9-2
9.2 Inorganic Chemicals 2005 Annual Review 9-3
9.2.1 Inorganic Chemicals 2005 Screening-Level Review 9-3
9.2.2 Inorganic Chemicals Category 2005 Pollutants of Concern 9-3
9.3 Potential New Subcategories for the Inorganic Chemicals Category 9-4
9.4 Inorganic Chemicals Category 2006 Annual Review 9-4
9.4.1 Inorganic Chemicals Category Facility Classification
Revisions 9-5
9.4.2 Inorganic Chemicals Category Dioxin and Dioxin-Like
Compounds Discharge Revisions 9-5
IV
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9.4.3 Inorganic Chemicals Category TWF and POTW Percent
Removal Revisions 9-5
9.4.4 Inorganic Chemicals Category 2006 Screening-Level
Review 9-7
9.4.5 Inorganic Chemicals Category 2006 Pollutants of Concern 9-7
9.5 Inorganic Chemicals Category Dioxin and Dioxin-Like Compounds
Discharges 9-9
9.6 Titanium Dioxide Manufacturing Subcategory 9-11
9.6.1 Titanium Dioxide Manufacturing Industry Profile 9-11
9.6.2 40CFRPart415 Subpart V 9-12
9.6.3 Titanium Dioxide Manufacturing Process Description 9-13
9.6.4 Titanium Dioxide Wastewater Sources of Dioxin and
Dioxin-Like Compounds 9-16
9.6.5 Dioxide and Dioxide-Like Compounds Wastewater
Treatment and Pollution Prevention 9-23
9.7 Inorganic Chemicals Category Conclusions 9-23
9.8 Inorganic Chemicals Category References 9-25
10.0 NONFERROUS METALS MANUFACTURING (40 CFRPART421) 10-1
10.1 NFMM Category Background 10-1
10.1.1 NFMM Industry Profile 10-1
10.1.2 40 CFR Part 421 10-3
10.2 NFMM Category 2005 Annual Review 10-3
10.2.1 NFMM Category 2005 Screening-Level Review 10-3
10.2.2 NFMM Category 2005 Pollutants of Concern 10-3
10.3 Potential New Subcategories for the NFMM Category 10-4
10.4 NFMM Category 2006 Annual Review 10-4
10.4.1 NFMM Category Facility Classification Revisions 10-4
10.4.2 NFMM Category Facility Discharge Revisions 10-6
10.4.3 NFMM Category TWF and POTW Percent Removal
Revisions 10-7
10.4.4 NFMM Category 2006 Screening-Level Review 10-7
10.4.5 NFMM Category 2006 Pollutants of Concern 10-7
10.4.6 NFMM Category 2006 Top Discharging Facilities 10-9
10.5 Primary Aluminum Subcategory 10-9
10.5.1 Primary Aluminum Industry Profile 10-9
10.5.2 40CFRPart421 SubpartB 10-14
10.5.3 Primary Aluminum 2006 Pollutants of Concern 10-14
10.5.4 Primary Aluminum Wastewater Sources of Fluoride 10-16
10.5.5 Primary Aluminum Wastewater Sources of Cyanide 10-17
10.6 NFMM Category Conclusions 10-22
10.7 NFMM Category References 10-22
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11.0 ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS (40 CFR PART
414) 11-1
11.1 OCPSF Category Background 11-1
11.1.1 OCPSF Industry Profile 11-1
11.1.2 40 CFR Part 414 11-2
11.1.3 Previous Detailed Study Findings for the OCPSF
Category 11-2
11.2 OCPSF Category 2005 Annual Review 11-6
11.2.1 OCPSF Category 2005 Screening-Level Review 11-6
11.2.2 OCPSF Category 2005 Pollutants of Concern 11-7
11.3 Potential New Subcategories for the OCPSF Category 11-8
11.4 OCPSF Category 2006 Annual Review 11-8
11.4.1 OCPSF Category Facility Discharge Revisions 11-8
11.4.2 OCPSF Category TWF and POTW Percent Removal
Revisions 11-9
11.4.3 OCPSF Category 2006 Screening-Level Review 11-10
11.4.4 OCPSF Category 2006 Pollutants of Concern 11-10
11.5 OCPSF Category HCB Discharges 11-12
11.5.1 OCPSF Category HCB Discharges in TRI 11-12
11.5.2 OCPSF Category HCB Discharges in PCS 11-12
11.6 OCPSF Category Dioxin and Dioxin-Like Compounds Discharges... 11-14
11.7 OCPSF Category PACs Discharges 11-18
11.7.1 OCPSF Facilities Reporting PACs to TRI 11-19
11.7.2 OCPSF Facilities Reporting Benzo(a)pyrene Discharges
to PCS 11-21
11.8 OCPSF Water Conservation through Mass-Based Permit Limits 11-22
11.9 OCPSF Category Conclusions 11-22
11.10 OCPSF Category References 11-23
12.0 ORE MINING AND DRESSING (40 CFR PART 440) 12-1
12.1 Ore Mining Category Background 12-1
12.1.1 Ore Mining Industry Profile 12-1
12.1.2 40 CFR Part 440 12-1
12.2 Ore Mining Category 2005 Annual Review 12-4
12.2.1 Ore Mining 2005 Screening-Level Review 12-4
12.2.2 Ore Mining Category 2005 Pollutants of Concern 12-4
12.3 Potential New Subcategories for the Ore Mining Category 12-4
12.4 Ore Mining Category 2006 Annual Review 12-4
12.4.1 Ore Mining Category Facility Classification Revisions 12-5
12.4.2 Ore Mining Category 2006 Screening-Level Review 12-5
12.4.3 Ore Mining Category 2006 Pollutants of Concern 12-6
12.5 Ore Mining Category Stormwater Multi-Sector General Permits
(MSGP) 12-6
12.6 Ore Mining Category Conclusions 12-8
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12.7 Ore Mining Category References 12-8
13.0 PESTICIDE CHEMICALS (40 CFR PART 455) 13-1
13.1 Pesticide Chemicals Category Background 13-1
13.1.1 Pesticide Chemicals Industry Profile 13-1
13.1.2 40 CFR Part 455 13-4
13.2 Pesticide Chemicals Category 2005 Annual Review 13-7
13.2.1 Pesticide Chemicals Category 2005 Screening-Level
Review 13-7
13.2.2 Pesticides Chemicals Category 2005 Pollutants of
Concern 13-7
13.3 Potential New Subcategories for the Pesticide Chemicals Category 13-7
13.4 Pesticide Chemicals Category 2006 Annual Review 13-9
13.4.1 Pesticide Chemicals Category 2006 Screening-Level
Review 13-9
13.4.2 Pesticide Chemicals Category 2006 Pollutants of Concern.... 13-9
13.4.3 Pesticide Chemicals Category Picloram Discharges 13-11
13.4.4 Pesticide Chemicals Category Total Carbaryl Discharges ... 13-12
13.5 Pesticide Chemicals Category Conclusions 13-13
13.6 Pesticide Chemicals Category References 13-13
14.0 PETROLEUM REFINING (40 CFR PART 419) 14-1
14.1 Petroleum Refining Category Background 14-1
14.1.1 Petroleum Refining Industry Profile 14-1
14.1.2 40 CFR Part 419 14-3
14.2 Petroleum Refining Category 2005 Annual Review 14-3
14.2.1 Petroleum Refining Category 2005 Screening Level
Review 14-3
14.2.2 Petroleum Refining Category 2005 Pollutants of Concern 14-3
14.3 Potential New Subcategories for the Petroleum Refining Category 14-4
14.4 Petroleum Refining 2006 Annual Review 14-5
14.4.1 Petroleum Refining Category TWF and POTW Percent
Removal Revisions 14-5
14.4.2 Petroleum Refining Category 2006 Screening-Level
Review 14-6
14.4.3 Petroleum Refining Category 2006 Pollutants of Concern 14-6
14.5 Petroleum Refining Category Update on Pollutants of Concern 14-6
14.5.1 Petroleum Refining Category Dioxin and Dioxin-Like
Compound Discharges 14-8
14.5.2 Petroleum Refining Category Polycyclic Aromatic
Compounds (PACs) Discharges 14-10
14.5.3 Petroleum Refining Category Metals Discharges 14-11
14.5.4 Petroleum Refining Category Sulfide Discharges 14-13
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14.5.5 Petroleum Refining Category Pollution Control
Technologies 14-13
14.6 Petroleum Refining Category Conclusions 14-13
14.7 Petroleum Refining References 14-14
15.0 PLASTICS MOLDING AND FORMING (40 CFR PART 463) 15-1
15.1 PMF Category Background 15-1
15.1.1 PMF Industry Profile 15-1
15.1.2 40 CFR Part 463 15-2
15.1.3 40CFRPart63 SubpartUUUU 15-2
15.2 PMF Category 2005 Annual Review 15-3
15.2.1 PMF Category 2005 Screening-Level Review 15-3
15.2.2 PMF Category 2005 Pollutants of Concern 15-4
15.2.3 PMF Category Cellulose Products Facilities 2005 Pollutants
of Concern 15-6
15.3 Potential New Subcategories for the PMF Category 15-6
15.4 PMF Category 2006 Annual Review 15-6
15.4.1 PMF Category Facility Discharge Revisions 15-6
15.4.2 PMF Category TWF and POTW Percent Removal
Revisions 15-7
15.4.3 PMF Category 2006 Screening-Level Review 15-8
15.4.4 PMF Category 2006 Pollutants of Concern 15-8
15.5 Regenerated Cellulose Products Discussion 15-10
15.5.1 Regenerated Cellulose Process Description 15-10
15.5.2 Regenerated Cellulose Facility Information 15-12
15.5.3 Wastewater Sources of Carbon Disulfide 15-15
15.5.4 Regenerated Cellulose Facilities Wastewater Treatment 15-16
15.6 PMF Category Conclusions 15-16
15.7 PMF References 15-17
16.0 PORCELAIN ENAMELING (40 CFR PART 466) 16-1
16.1 Porcelain Enameling Category Background 16-1
16.1.1 Porcelain Enameling Industry Profile 16-1
16.1.2 40 CFR Part 466 16-2
16.2 Porcelain Enameling Category 2005 Annual Review 16-2
16.2.1 Porcelain Enameling Category 2005 Screening-Level
Review 16-3
16.2.2 Porcelain Enameling Category 2005 Facility Classification
Revisions 16-3
16.2.3 Porcelain Enameling Category 2005 Revised Screening-
Level Review 16-4
16.3 Potential New Subcategories for the Porcelain Enameling Category.... 16-5
16.4 Porcelain Enameling Category 2006 Annual Review 16-5
16.5 Porcelain Enameling Category Conclusions 16-8
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16.6 Porcelain Enameling Category References 16-9
17.0 RUBBER MANUFACTURING (40 CFR PART 428) 17-1
17.1 Rubber Manufacturing Category Background 17-1
17.1.1 Rubber Manufacturing Industry Profile 17-1
17.1.2 40 CFR Part 428 17-3
17.2 Rubber Manufacturing Category 2005 Annual Review 17-4
17.2.1 Rubber Manufacturing Category 2005 Screening-Level
Review 17-4
17.2.2 Rubber Manufacturing Category 2005 Pollutants of
Concern 17-4
17.3 Potential New Subcategories for the Rubber Manufacturing
Category 17-4
17.4 Rubber Manufacturing Category 2006 Annual Review 17-5
17.4.1 Rubber Manufacturing Category Facility Discharge
Revisions 17-5
17.4.2 Rubber Manufacturing Category TWF and POTW Percent
Removal Revisions 17-6
17.4.3 Rubber Manufacturing Category 2006 Screening-Level
Review 17-6
17.4.4 Rubber Manufacturing Category 2006 Pollutants of
Concern 17-7
17.5 Rubber Manufacturing Category Conclusions 17-7
17.6 Rubber Manufacturing Category References 17-9
18.0 TEXTILE MILLS (40 CFR PART 410) 18-1
18.1 Textile Mills Point Source Category Background 18-1
18.1.1 Textiles Industry Profile 18-1
18.1.2 40 CFR Part 410 18-2
18.2 Textiles Category 2005 Annual Review 18-5
18.2.1 Textiles Category 2005 Screening-Level Review 18-5
18.2.2 Textiles Category 2005 Pollutants of Concern 18-5
18.3 Potential New Subcategories for the Textiles Category 18-6
18.4 Textiles Category 2006 Annual Review 18-7
18.4.1 Textiles Category TWF and POTW Percent Removal
Revisions 18-7
18.4.2 Textiles Category 2006 Screening-Level Review 18-7
18.4.3 Textiles Category Pollutants of Concern 18-7
18.4.4 Textiles Category Sulfide Discharges 18-9
18.4.5 Textiles Category Chlorine Discharges 18-10
18.5 Textiles Category Conclusions 18-13
18.6 Textiles Category References 18-13
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PART III: REVIEW OF INDUSTRIAL DISCHARGES NOT COVERED BY
CATEGORICAL REGULATIONS Ill
19.0 REVIEW OF INDIRECT DISCHARGERS WITHOUT CATEGORICAL PRETREATMENT
STANDARDS TO IDENTIFY POTENTIAL NEW CATEGORIES FOR PRETREATMENT
STANDARDS 19-1
19.1 Overview of EPA's 2006 Review of Possible New Candidates for
Categorical Pretreatment Standards 19-1
19.2 EPA's Evaluation of "Pass Through Potential" of Toxic and
Nonconventional Pollutants through POTW Operations 19-2
19.3 EPA's Evaluation of "Interference Potential" of Industrial Indirect
Discharges 19-3
19.4 Category-Specific Evaluations 19-4
19.5 Food Service Establishments 19-5
19.5.1 Comments Received 19-5
19.5.2 Industry Profile 19-5
19.5.3 Wastewater Characteristics 19-7
19.5.4 Pass Through and Interference 19-7
19.5.5 Findings of EPA's Review of the Food Services
Establishments Industry 19-9
19.6 Health Services Industry 19-9
19.6.1 Comments Received 19-9
19.6.2 Industry Profile 19-10
19.6.3 Wastewater Characteristics 19-10
19.6.4 Pass Through and Interference Potential 19-11
19.6.5 Findings of EPA's CWA Sections 304(g) and 307(b)
Review of the Health Services Industry 19-11
19.7 Independent and Stand-Alone Laboratories 19-12
19.7.1 Comments Received 19-12
19.7.2 Industry Profile 19-12
19.7.3 Wastewater Characteristics 19-13
19.7.4 Pass Through and Interference Potential 19-13
19.7.5 Findings of EPA's CWA Sections 304(g) and 307(b)
Review of the Independent and Stand-Alone Laboratories
Industry 19-14
19.8 Industrial Container and Drum Cleaning 19-14
19.8.1 Comments Received 19-14
19.8.2 Industry Profile 19-14
19.8.3 Wastewater Characteristics 19-15
19.8.4 ICDC On-Site Wastewater Pretreatment 19-16
19.8.5 Pass Through and Interference Potential 19-17
19.8.6 Findings of EPA's Review of the ICDC Industry 19-17
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19.9 Industrial Laundries 19-18
19.9.1 Comments Received 19-18
19.9.2 Industry Profile 19-19
19.9.3 Wastewater Characteristics 19-19
19.9.4 Pass Through and Interference Potential 19-20
19.9.5 Findings of EPA's Review of the Industrial Laundries
Industry 19-21
19.10 Photoprocessing 19-21
19.10.1 Comments Received 19-21
19.10.2 Industry Profile 19-21
19.10.3 Wastewater Characteristics 19-22
19.10.4 Wastewater Treatment and Pollution Prevention 19-23
19.10.5 Pass Through and Interference Potential 19-23
19.10.6 Findings of EPA's Review of the Photoprocessing
Industry 19-23
19.11 Printing and Publishing 19-24
19.11.1 Comments Received 19-24
19.11.2 Industry Profile 19-24
19.11.3 Wastewater Characteristics 19-25
19.11.4 Wastewater Treatment and Pollution Prevention 19-26
19.11.5 Pass Through and Interference Potential 19-26
19.11.6 Findings of EPA's Review of the Printing and Publishing
Industry 19-26
19.12 Tobacco Products 19-27
19.12.1 Comments Received 19-27
19.12.2 Industry Profile 19-28
19.12.3 Wastewater Characteristics 19-28
19.12.4 Wastewater Treatment 19-29
19.12.5 Pass Through and Interference Potential 19-29
19.12.6 Findings of EPA's Review of the Tobacco Products
Industry 19-30
19.13 References 19-30
20.0 REVIEW OF DIRECT DISCHARGERS WITHOUT EFFLUENT LIMITATIONS GUIDELINES
TO IDENTIFY POTENTIAL NEW REGULATORY CATEGORIES FOR EFFLUENT
GUIDELINES RULEMAKING 20-1
20.1 Liquefied Natural Gas Import Terminals 20-1
20.1.1 Comments Received 20-1
20.1.2 Category/Subcategory Analysis 20-2
20.1.3 Industry Profile 20-2
20.1.4 Economic Profile 20-15
20.1.5 Summary of EPA's Review of the LNG Industry 20-21
20.2 Miscellaneous Foods and Beverages Industry 20-21
20.2.1 Summary of Comments Received 20-22
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20.2.2 Industry Profile 20-22
20.2.3 Wastewater Characteristics 20-24
20.2.4 SIC Code 2075: Soybean Oil Mills 20-25
20.2.5 SIC Code 2082: Malt Beverages 20-29
20.2.6 SIC Code 2085: Distilled, Rectified, and Blended
Liquors 20-30
20.2.7 Summary of Review of Miscellaneous Foods and
Beverages Industry 20-32
20.3 References 20-32
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List of Appendices
LIST OF APPENDICES
Appendix A POINT SOURCE CATEGORY TO SIC CODE CROSSWALK
Appendix B SIC CODES OF FACILITIES WITH DISCHARGE DATA IN TRI AND/OR
PCS THAT EPA IDENTIFIED AS "NOT A CATEGORY"
Appendix C TOXIC WEIGHTING FACTORS FOR CHEMICALS REPORTED AS WATER
DISCHARGES IN THE 2002 TRI, 2003 TRI, OR 2002 PCS
Appendix D POTW REMOVAL RATES FOR TRI CHEMICALS REPORTED AS
DISCHARGED TO POTWS IN THE 2002 AND 2003 TRI
Appendix E MANUAL DATABASE CHANGES MADE TO CREATE TRIReleases2002 v4
Appendix F MANUAL DATABASE CHANGES MADE TO CREATE TRIReleases2003_v2
Appendix G MANUAL DATABASE CHANGES MADE TO CREATE PCSLoads2002 v4
Appendix H 2006 ANNUAL REVIEW RESULTS: 4-DIGIT SIC CODE RANKINGS FOR
TRIReleases2002 v4
Appendix I 2006 ANNUAL REVIEW RESULTS: 4-DIGIT SIC CODE RANKINGS FOR
PCSLoads2002 v4
Appendix J 2006 ANNUAL REVIEW RESULTS: 4-DIGIT SIC CODE RANKINGS FOR
TRIReleases2003 _v2
Appendix K 2006 ANNUAL REVIEW RESULTS: CHEMICAL RANKINGS FOR
TRIReleases2002 v4
Appendix L 2006 ANNUAL REVIEW RESULTS: CHEMICAL RANKINGS FOR
PCSLoads2002 v4
Appendix M 2006 ANNUAL REVIEW RESULTS: CHEMICAL RANKINGS FOR
TRIReleases2003 v2
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List of Tables
LIST OF TABLES
Page
2-1 Comments on the Preliminary 2006 and Final 2004 Effluent Guidelines
Program Plans EPA Docket Number: EPA-HQ-OW-2004-0032 2-2
4-1 Summary of Database Changes Applicable to Both TRIReleases and
PCSLoads Based on Database Methodology Comments 4-10
4-2 Summary of Comments on Database Methodologies Applicable to Both
TRIReleases and PCSLoads for Which EPA Did Not Take Action 4-12
4-3 TWFs Revised in 2006 4-14
4-4 Chemicals with the Largest Change in TWPE in PCSLoads2002 Resulting
from 2006 Revised TWFs 4-15
4-5 Chemicals with the Largest Changes in TWPE for TRI Databases Resulting
from 2006 Revised TWFs 4-16
4-6 Dioxin and Dioxin-Like Compounds and Their Toxic Weighting Factors 4-19
4-7 Chemical Composition of Creosote and Associated TWFs 4-21
4-8 Definition of Polycyclic Aromatic Compounds 4-22
4-9 Calculation of Toxic Weighting Factor for Petroleum PACs 4-24
4-10 Calculation of Toxic Weighting Factor for Wood Preserving P ACs 4-27
4-11 Calculation of Toxic Weighting Factor for Pulp, Paper, and Paperboard
PACs 4-28
4-12 TRIReleases2002_v4 Category Rankings from the 2006 Screening-Level
Review 4-30
4-13 PCSLoads2002_v4 Category Rankings from the 2006 Screening-Level
Review 4-33
4-14 TRIReleases2003_v2 Category Rankings from the 2006 Screening-Level
Review 4-36
4-15 TRI Facility Review 4-40
4-16 Loadings and TWPE from Different Measurement Values for a Subset of
PCS Data 4-42
4-17 Nutrient Analysis Data Quality Issues 4-43
xiv
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List of Tables
LIST OF TABLES (Continued)
Page
5-1 Point Source Categories That Have Undergone a Recent Rulemaking or
Review 5-3
5-2 Point Source Categories with One Facility Dominating the TWPE
Discharges 5-4
5-3 Final PCS 2002 and TRI 2002 Combined Point Source Category Rankings 5-6
5-4 Final TRI 2003 Rankings 5-8
5-5 2006 Annual Review of Categories with Existing ELGs: Level of Review 5-9
6-1 Applicability of Subcategories in the Oil and Gas Extraction Category 6-2
6-2 United States CBM Sources and Production 6-6
6-3 Water Production from CBM Extraction 6-11
6-4 CBM-Produced Water TDS Concentrations 6-12
6-5 Concentration of Pollutants in CBM-Produced Water by Basin 6-13
6-6 Produced Water Disposal Methods in Major CBM Basins 6-14
6-7 Potential Treatment Technologies for Beneficial Use and Disposal for
CBM-Produced Water 6-16
6-8 2006 Estimates of Annualized Costs for Managing CBM-Produced Water in
the Powder River Basin 6-17
6-9 2003 Estimates of Cost and Affordability of Treatment and Disposal
Technologies for CBM-Produced Water in the Powder River Basin 6-19
7-1 Number of Facilities in Coal Mining SIC Codes 7-2
7-2 Number of Permitted U.S. Coal Mining Operations and Production in 2004 7-2
7-3 U.S. Coal Production in 2003 and Predictions to 2030 (In Millions of
Short Tons) 7-3
7-4 Coal Mining ELGs 7-3
7-5 BPT and BAT Effluent Guidelines for Coal Mining Part 434 Subparts
A-F 7-4
7-6 Catastrophic Precipitation Event Exemption of 40 CFR Part 434 7-4
xv
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List of Tables
LIST OF TABLES (Continued)
Page
7-7 Coal Mining Category 2005 Screening-Level Review Results 7-5
8-1 Top Facilities Reporting Under SIC Code 2874 8-2
8-2 Number of Facilities in Fertilizer Manufacturing SIC Codes 8-2
8-3 Fertilizer Manufacturing Category Facilities by Type of Discharge Reported
inTRI2002 8-3
8-4 Subcategories in the Fertilizer Category 8-4
8-5 Fertilizer Manufacturing Category 2005 Screening-Level Review Results21 8-4
8-6 2005 Annual Review: Fertilizer Manufacturing Category Pollutants of
Concern 8-5
8-7 Impact of Changes to TWF and POTW Percent Removal for the Fertilizer
Manufacturing Category 8-7
8-8 Fertilizer Manufacturing Category 2006 Screening-Level Review Results'1 8-7
8-9 2006 Annual Review: Fertilizer Manufacturing Category Pollutants of
Concern 8-8
8-10 2006 Annual Review: Fertilizer Manufacturing Category Top Discharging
Facilities in PCS 8-9
8-11 Fertilizer Manufacturing Category, Top Fluoride Outfalls 8-12
8-12 Fertilizer Manufacturing Category, Permit Flow Requirements 8-13
9-1 Number of Facilities in Inorganic Chemicals Manufacturing SIC Codes 9-2
9-2 Inorganic Chemicals Category Facilities by Type of Discharge Reported in
TRI2002 9-2
9-3 Inorganic Chemicals Category 2005 Screening-Level Review Results 9-3
9-4 2005 Annual Review: Inorganic Chemicals Category Pollutants of Concern 9-4
9-5 Inorganic Chemicals Category Facilities with Discharge Revisions 9-6
9-6 Impact of Changes to TWF and POTW Percent Removal for the Inorganic
Chemicals Category 9-6
9-7 Inorganic Chemicals Category 2006 Screening-Level Review 9-7
xvi
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List of Tables
LIST OF TABLES (Continued)
Page
9-8 2006 Annual Review: Inorganic Chemicals Category Pollutants of
Concerna 9-8
9-9 Inorganic Chemicals Category Facilities Reporting Discharges of Dioxin
and Dioxin-like Compounds to TRI 9-10
9-10 Comparison of TRI TWPE from Dioxin and Dioxin-Like Compounds for
2002 and 2003 for the Titanium Dioxide Subcategory, OCPSF Category,
and CCH Rulemaking 9-11
9-11 United States Titanium Dioxide Manufacturers 9-12
9-12 Titanium Dioxide Subcategory BPT and NSPS Monthly Average
Limitations 9-12
9-13 Titanium Dioxide Manufacturing Processes 9-13
9-14 Titanium Dioxide Facility List and Inventory of Data Available for Dioxin
and Dioxin-Like Compounds 9-18
9-15 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent Samples
(pg/L) for Louisiana Pigments 9-21
9-16 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent Samples
(pg/L) from Two Du Pont Facilities 9-22
9-17 TWPE Comparison for Three Titanium Dioxide Manufacturers 9-23
9-18 Titanium Dioxide Facilities Wastewater Treatment In Place and Pollution
Prevention 9-24
10-1 Number of Facilities in NFMM SIC Codes 10-2
10-2 NFMM Category Facilities by Type of Discharge Reported in TRI 2002 10-2
10-3 NFMM Category 2005 Screening-Level Review Results 10-3
10-4 2005 Annual Review: NFMM Category Pollutants of Concern 10-4
10-5 NFMM Category Facilities Classified in Wrong Category 10-5
10-6 NFMM Category Facilities with Discharge Revisions 10-6
10-7 Impact of Changes to TWF and POTW Percent Removal for the NFMM
Category 10-7
xvn
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List of Tables
LIST OF TABLES (Continued)
Page
10-8 NFMM Category 2006 Screening-Level Review Results 10-7
10-9 2006 Annual Review: NFMM Category Pollutants of Concern 10-8
10-10 2006 Annual Review: NFMM Category Top Discharging Facilities in
PCS 10-10
10-11 Top Discharging NFMM Category Facilities 10-11
10-12 U.S. Primary Aluminum Facilities Owners and Operating Status 10-13
10-13 Primary Aluminum Subcategory BAT Treatment Effectiveness
Concentrations 10-14
10-14 2006 Annual Review: Primary Aluminum Subcategory Pollutants of
Concern 10-15
10-15 Primary Aluminum Facilities with Fluoride Discharges in PCS for 2002 10-18
10-16 Primary Aluminum Facilities, Fluoride Concentrations Reported to PCS
in 2002 10-19
10-17 Primary Aluminum Facilities with Cyanide Discharges in PCS for 2002 10-20
10-18 Primary Aluminum Facilities, Cyanide Concentrations Reported to PCS
in 2002 10-21
11-1 Number of Facilities in OCPSF SIC Codes 11-3
11-2 OCPSF Category Facilities by Type of Discharge Reported in TRI 2002 11-4
11-3 Applicability of Subcategories in the OCPSF Category 11-5
11-4 OCPSF Category 2005 Screening-Level Review Results 11-7
11-5 2005 Annual Review Results: OCPSF Category Pollutants of Concern 11-7
11 -6 Pollutant TWPE for Potential New Subcategories in OCPSF Category 11-8
11 -7 Impact of Changes to TWF and POTW Percent Removal for the OCPSF
Category 11-10
11-8 OCPSF Category 2006 Screening-Level Review Results 11-10
11-9 2006 Annual Review: OCPSF Category Pollutants of Concern 11-11
xvin
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List of Tables
LIST OF TABLES (Continued)
Page
11-10 OCPSF Facilities Reporting HCB Releases to TRI 11-12
11-11 OCPSF Facilities Reporting Discharges of HCB to PCS in 2002 11-13
11-12 OCPSF Facilities Reporting Dioxin Releases to TRI 11-15
11-13 OCPSF Facilities Reporting PACs Releases to TRI 11-20
11-14 OCPSF Facilities for which PCS includes Benzo(a)pyrene 2002 Discharge
Data 11-21
12-1 Number of Facilities in Ore Mining SIC Codes 12-2
12-2 Ore Mining Category Facilities by Type of Discharge Reported in
TRI 2002 12-2
12-3 Ore Mining Category Subcategory Applicability 12-3
12-4 Ore Mining Category 2005 Screening-Level Review Results 12-4
12-5 2005 Annual Review: Ore Mining Category Pollutants of Concern 12-5
12-6 Ore Mining Category 2006 Screening-Level Review Results 12-6
12-7 2006 Annual Review: Ore Mining Category Pollutants of Concern 12-7
13-1 Number of Facilities with Pesticide Chemicals Discharges Listed by Primary
SIC Code 13-3
13-2 Pesticide Chemicals Category Facilities by Type of Discharge Reported in
TRI 2002 13-5
13-3 Applicability of Subcategories in the Pesticide Chemicals Point Source
Category 13-6
13-4 Pesticide Chemical Category 2005 Screening-Level Review Results 13-7
13-5 2005 Annual Review: Pesticide Chemicals Category Pollutants of
Concern 13-8
13-6 Pesticide Chemicals Category 2006 Screening-Level Review Results 13-9
13-7 2006 Annual Review: Pesticide Chemicals Category Pollutants of
Concern 13-10
13-8 Pesticide Chemicals Category Picloram Discharges 13-11
xix
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List of Tables
LIST OF TABLES (Continued)
Page
13-9 Estimated Picloram Concentrations in Dow Chemical Co. Freeport
Facility's Final Effluent 13-12
13-10 Pesticide Chemicals Category Total Carbaryl Discharges in PCS 2002 13-12
14-1 Number of Facilities in Petroleum Refining SIC Codes 14-2
14-2 Petroleum Refining Category Facilities by Type of Discharge Reported in
TRI2002 14-2
14-3 Petroleum Refining Category 2005 Screening-Level Review Results 14-3
14-4 2005 Annual Review: Petroleum Refining Category Pollutants of
Concern 14-4
14-5 Petroleum Refining Category Potential New Subcategories Pollutant
TWPE 14-5
14-6 Impact of Changes to TWF and POTW Percent Removal for the Petroleum
Refining Category 14-5
14-7 Petroleum Refining Category 2006 Screening-Level Review Results 14-6
14-8 2006 Annual Review: Petroleum Refining Category Pollutants of Concern .... 14-7
14-9 Petroleum Refineries that Based Dioxin and Dioxin-Like Compound
Discharges on Analytical Measurement Data 14-9
14-10 Petroleum Refineries that have Detected PACs in Refinery Effluent 14-11
14-11 2000, 2002, and 2003 Dioxin Discharges Reported to TRI by Petroleum
Refineries 14-17
14-12 2000, 2002, and 2003 PACs Discharges Reported to TRI by Petroleum
Refineries 14-20
15-1 Number of Facilities in Plastics Molding and Forming SIC Codes 15-1
15-2 PMF Category 2005 Screening-Level Review Results 15-4
15-3 2005 Annual Review: PMF Category Pollutants of Concern 15-5
15-4 2005 Annual Review: PMF Category Discharges Excluding Cellulose
Products Manufacturers 15-6
15-5 PCS Database Changes for Innovia Films Inc 15-7
xx
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List of Tables
LIST OF TABLES (Continued)
Page
15-6 Impact of Changes to TWF and POTW Percent Removal for the PMF
Category 15-8
15-7 PMF Category 2006 Screening-Level Review Results 15-8
15-8 2006 Annual Review: PMF Category Pollutants of Concern 15-9
15-9 Sealed Air Corporation Cryovac Division Dioxin and Dioxin-Like
Compounds Discharges 15-10
15-10 Cellulose Manufacturers in the United States 15-13
15-11 TRI 2002 and 2003 Discharges for Cellulose Products Manufacturing
Facilities 15-14
15-12 TRI 2002 and 2003 Carbon Disulfide Discharges for Cellulose Products
Manufacturing Facilities 15-14
15-13 PCS 2002 Discharges for Cellulose Products Manufacturing Facilities 15-15
15-14 Cellulose Products Facilities Wastewater Treatment 15-16
16-1 Number of Facilities in Porcelain Enameling SIC Codes 16-2
16-2 Porcelain Enameling Category Subcategory Applicability 16-2
16-3 Porcelain Enameling Category 2005 Screening-Level Review Results 16-3
16-4 2005 Annual Review Results: Number of Facilities in Porcelain Enameling
SIC Codes 16-4
16-5 Porcelain Enameling Category 2005 Revised Screening-Level Review
Results 16-5
16-6 2006 Screening-Level Review Results: Classification of Facilities in
Porcelain Enameling and Metal Finishing Categories 16-6
16-7 Porcelain Enameling Category 2006 Screening-Level Review Results 16-8
17-1 Number of Facilities in Rubber Manufacturing SIC Codes 17-2
17-2 Rubber Manufacturing Category Facilities by Type of Discharge Reported in
TRI 2002 17-2
17-3 Rubber Manufacturing Category Subcategory Applicability 17-3
xxi
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List of Tables
LIST OF TABLES (Continued)
Page
17-4 Rubber Manufacturing Category 2005 Screening-Level Review Results 17-4
17-5 2005 Annual Review: Rubber Manufacturing Category Pollutants of
Concern 17-5
17-6 Impact of Changes to TWF and POTW Percent Removal for the Rubber
Manufacturing Category 17-6
17-7 Rubber Manufacturing Category 2006 Screening-Level Review Results 17-7
17-8 2006 Annual Review: Rubber Manufacturing Category Pollutants of
Concern 17-8
18-1 Number of Facilities in Textiles SIC Major Groups 18-1
18-2 Textiles Category Facilities by Type of Discharge Reported in TRI 2002 18-2
18-3 Applicability of Subcategories in the Textiles Category 18-3
18-4 Pollutants Regulated by Existing Textiles ELGs 18-4
18-5 Textiles Category 2005 Screening-Level Review Results 18-5
18-6 2005 Annual Review: Textiles Category Pollutants of Concern 18-6
18-7 Pollutant Loadings From Potential New Subcategories for the Textile
Category 18-6
18-8 Impact of Changes to TWF and POTW Percent Removal for the Textiles
Category 18-7
18-9 Textiles Category 2006 Screening-Level Review Results 18-7
18-10 2006 Annual Review: Textiles Category Pollutants of Concern 18-8
18-11 Top Facilities Reporting Sulfide Discharges in PCSLoads2002_v4 18-9
18-12 Concentration Data Available for Top Four Facilities Reporting Sulfide
Discharges in PCSLoads2002 for the Textiles Category 18-10
18-13 Facilities With Largest Chlorine Discharges in PCSLoads2002_v4 18-11
18-14 Chlorine Limitations and PCS Concentration Data for Burlington Industries
Cordova, NC Textile Mill 18-12
xxn
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List of Tables
LIST OF TABLES (Continued)
Page
19-1 Industries Included in EPA's 2006 Review of Possible New Candidates for
Categorical Pretreatment Standards 19-1
19-2 Summary of EPA's 2006 CWA Sections 304(g) and 307(b) Review 19-6
19-3 Summary of Wastewater Discharges from the Food Service Establishments
Industry 19-7
19-4 Summary of Wastewater Discharges from the Independent and Stand-Alone
Laboratories Industry 19-13
19-5 Estimated Number of ICDC Facilities, by Discharge and Treatment 19-16
19-6 Estimated Pollutant Loads Discharged by 187 ICDC Facilities 19-17
19-7 Pollutant Discharges from Industrial Laundry Facilities (Measured as
TWPE) 19-20
19-8 Summary of Wastewater Discharges from the Photoprocessing Industry 19-22
19-9 Summary of Wastewater Discharges from the Printing and Publishing
Industry 19-26
20-1 Existing Land-Based and Offshore LNG Import Terminals 20-6
20-2 Approved U.S. Land-Based LNG Import Terminals 20-9
20-3 Proposed U.S. Land-Based LNG Import Terminals 20-11
20-4 Licensed and Proposed U.S. Offshore LNG Import Terminals 20-12
20-5 Existing, Approved, Proposed and Planned U.S. LNG Import Terminals
(2006) 20-14
20-6 Number of Facilities in Miscellaneous Foods and Beverages SIC Codes 20-23
20-7 Miscellaneous Foods and Beverages Facilities by Type of Discharge
Reported in TRI 2002 20-24
20-8 Summary of Data for the Miscellaneous Foods and Beverages Industry 20-24
20-9 TRI and PCS Data Listing for Miscellaneous Foods and Beverages SIC
Codes 20-26
20-10 Pollutants of Concern for the Miscellaneous Foods and Beverages
Industry 20-27
xxin
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List of Tables
LIST OF TABLES (Continued)
Page
20-11 Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2075: Soybean Oil Mills 20-28
20-12 Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2082: Malt Beverages 20-30
20-13 Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2085: Distilled, Rectified, and Blended Liquors 20-31
XXIV
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List of Figures
LIST OF FIGURES
Page
1-1 Regulations of Direct and Indirect Wastewater Discharges Under NPDES 1-4
3-1 Flow Chart of Annual Review of Existing ELGs 3-2
3-2 Flow Chart of Further Review of Existing ELGs 3-3
3-3 Flow Chart of Identification of Possible New ELGs 3-4
6-1 Coal Bed Methane Basins in the United States 6-7
6-2 Profile of a Typical Western CBM Well with Openhole Completion 6-10
6-3 EIA Predicted Natural Gas Production by Source, 1990-2030 (tcf) 6-18
9-1 Basic Diagram of the Chloride and Chloride-Ilmenite Processes for
Titanium Dioxide Manufacture 9-14
9-2 Basic Diagram of the Sulfate Process for Titanium Dioxide Manufacture 9-17
20-1 General Description of LNG Importation 20-3
20-2 Existing and Proposed North American LNG Terminals 20-7
20-3 Potential North American LNG Terminals 20-13
20-4 Existing and Proposed North American LNG Terminals 20-15
20-5 Excess Regas Capacity in the U.S.—Here to Stay 20-18
20-6 Growth in LNG Imports Given Growth in Alaskan and Unconventional
Gas Production 20-20
XXV
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List of Acronyms
2005 SLA Report
ACC
ACWA
API
BAT
Bbl
Bcfd
BCT
BMP
BNR
BOD5
BPJ
BPT
CAFOs
CAS
CBM
CCH
CDDs
CDFs
CFPR
CFR
CMOM
CMP
COD
CSO
CWA
CWT
DAP
DCN
DMR
DOE
BAD
EC
EDC
EDS
EIA
ELGs
EPA
EPCRA
FERC
FOG
HAP
HCB
HpCDD
HpCDF
LIST OF ACRONYMS
2005 Annual Screening-Level Analysis Report
American Chemistry Council
Airport Clean Water Alliance
American Petroleum Institute
Best available technology economically achievable
Barrel
Billion cubic feed per day
Best conventional pollutant control technology
Best management practice
Biological treatment with nutrient removal
Biochemical oxygen demand
Best professional judgment
Best practicable pollutant control technology currently available
Concentrated animal feeding operations
Chemical Abstracts Service
Coal bed methane
Chlorine and chlorinated hydrocarbons
Poly chlorinated dibenzo-p-dioxins
Polychlorinated dibenzofurans
Chemical formulation, packaging, and repackaging
Code of Federal Regulations
Capacity, management, operations, and maintenance
Code of Management Practices
Chemical oxygen demand
Combined sewer overflow
Clean Water Act
Centralized waste treaters
Diammonium phosphate
Document control number
Discharge monitoring report
Department of Energy
Engineering Analysis Division
Electrical conductivity
Endocrine disrupting compound
Effluent data statistics
Energy Information Administration
Effluent limitations guidelines and standards
Environmental Protection Agency
Emergency Planning and Community-Right-to-Know Act
Federal Energy Regulatory Commission
Fats, oil, and grease
Hazardous air pollutant
Hexachl orob enzene
Heptachlorodibenzo-p-dioxin
Heptachl orodib enzofuran
xxvi
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List of Acronyms
HxCDD
HxCDF
ICDC
ICR
IMCC
LNG
MAP
MCES
Mcf
MOD
MGY
ML
MMBtu
MSD
MSGP
NACWA
NAICS
NCASI
NACWA
NEC
NESHAP
NFMM
NOAA
NOT
NOIA
NPDES
NRDC
NSPS
OAQPS
OCDD
OCDF
OCPSF
OECA
OMB
ORV
OSMRE
OSW
PAC
PBST
PBT
PCBs
PCS
PCSLoads
PDS
PE
PeCDD
LIST OF ACRONYMS (Continued)
Hexachlorodibenzo-p-dioxin
Hexachl orodib enzofuran
Industrial container and drum cleaning
Information collection request
Interstate Mining Compact Commission
Liquefied natural gas
Monoammonium phosphate
Metropolitan Council of Environmental Services
Million cubic feed
Million gallons per day
Million gallons per year
Minimum level
Million British thermal units
Metropolitan Sewerage District of Greater Cincinnati
Multi-sector general permit
National Association of Clean Water Agencies
North American Industry Classification System
National Council for Air and Stream Improvement
National Association of Clean Water Agencies
Not elsewhere classified
National Emission Standards for Hazardous Air Pollutants
Nonferrous metals manufacturing
National Oceanic and Atmospheric Administration
Notice of intent
National Ocean Industries Association
National Pollutant Discharge Elimination System
National Resources Defense Council
New sources pollutant standards
Office of Air Quality Planning and Standards
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
Organic chemicals, plastics, and synthetic fibers
Office of Enforcement and Compliance Assurance
Office of Management and Budget
Open rack vaporizers
Office of Surface Mining and Regulatory Enforcement
Office of Solid Waste
Polycyclic aromatic compound
Petroleum bulk station terminals
Persistent bioaccumulative toxic
Polychlorinated biphenyls
Permit Compliance System
EPA database estimating annual pollutant loads based on PCS data
Preliminary data summary
Porcelain enameling
Pentachlorodibenzo-p-dioxin
xxvn
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List of Acronyms
PeCDF
PHC
PMF
POTW
PSES
PSNS
PVC
RIPA
SAR
SBA
SCV
SIC
SILT
SMCRA
SSO
TCDD
TCDF
TCEQ
TCP
TDD
IDS
TEC
TEF
TEQ
TMDL
TOC
TRC
TRI
TRIReleases
TRSA
TSD
TSS
TTB
TWF
TWPE
UIC
USCG
UTSA
VCM
LIST OF ACRONYMS (Continued)
Pentachl orodib enzofuran
Probable hydrologic consequences
Plastics molding and forming
Publicly-owned treatment works
Pretreatment standards for existing sources
Pretreatment standards for new sources
Polyvinyl chloride
Reusable Industrial Packaging Association
Sodium adsorption ratio
Small Business Administration
Submerged combustion vaporizer
Standard Industrial Classification
Significant industrial user
Surface Mining Control and Reclamation Act
Sanitary sewer overflow
Tetrachlorodibenzo-p-dioxin
Tetrachlorodibenzofuran
Texas Commission on Environmental Quality
Trillion cubic feet
Technical development document
Total dissolved solids
Transportation equipment cleaning
Toxic equivalency factor
Toxic equivalent
Total maximum daily load
Total organic carbon
Total residual chlorine
Toxic Release Inventory
EPA database estimating annual pollutant loads based on TRI data.
Textile Rental Service Association
Technical support document
Total suspended solids
U.S. Alcohol and Tobacco Tax and Trade Bureau
Toxic weighting factor
Toxic-weighted pound equivalent
Underground injection control
U.S. Coast Guard
Uniform and Textile Service Association
Vinyl chloride monomer
xxvin
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Part I - Introduction
PARTI: INTRODUCTION
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Section 1.0 - Background
This document provides the data supporting the Final 2006 Effluent Guidelines Program Plan.
It presents the methodology used to perform the reviews of industrial discharges required by the
Clean Water Act and the results of the reviews.
1.0 BACKGROUND
This section explains how the Effluent Guidelines Program fits into the CWA
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 (i.e.,
effluent guideline planning).
1.1 EPA's Clean Water Act Program
EPA's Office of Water is responsible for developing the programs and tools
authorized under the 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.
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. In a
parallel track to water quality standards, EPA also develops technology-based effluent limitation
guidelines and standards, which are factor-based regulations that provide effluent limits based on
current available technologies. These limits are then incorporated into technology-based
permits. 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 Background on the Effluent Guidelines Program
The 1972 CWA marked a distinct change in Congress's efforts "to restore and
maintain the chemical, physical, and biological integrity of the Nation's waters." See CWA §
101(a), 33 U.S.C. § 125 l(a). Prior to 1972, the CWA relied on "water quality standards." This
approach was challenging, however, because it was very difficult to prove that a specific
discharger was responsible for decreasing the water quality of its receiving stream.
Since 1972, the CWA has directed EPA to promulgate effluent guidelines that
reflect pollutant reductions that can be achieved by categories or subcategories of industrial point
1-1
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Section 1.0 - Background
sources. The effluent guidelines are based on specific technologies (including process changes)
that EPA identifies as meeting the statutorily prescribed level of control. See CWA sections
301(b)(2), 304(b), 306, 307(b), and 307(c). Unlike other CWA tools, effluent guidelines are
national in scope and establish pollution control obligations for all facilities that discharge
wastewater within an industrial category or subcategory. In establishing these controls, EPA
assesses: (1) the performance and availability of the best pollution control technologies or
pollution prevention practices that are available for an industrial category or subcategory as a
whole; (2) the economic achievability of those technologies, which can include consideration of
costs, effluent reduction benefits, and affordability of achieving the reduction in pollutant
discharge; (3) non-water-quality environmental impacts (including energy requirements), and (4)
such other factors as the Administrator deems appropriate.
Creating a single national pollution control requirement for each industrial
category based on the best technology the industry could afford was seen by Congress as a way
to reduce the potential creation of "pollution havens" and to set the Nation's sights on attaining
the highest possible level of water quality. Consequently, EPA's goal in establishing national
effluent guidelines is to assure that industrial facilities with similar characteristics, regardless of
their location or the nature of their receiving water, will at a minimum meet similar effluent
limitations representing the performance of the best pollution control technologies or pollution
prevention practices.
Unlike other CWA tools, effluent guidelines also provide the opportunity to
promote pollution prevention and water conservation. This may be particularly important in
controlling persistent, bioaccumulative, and toxic pollutants discharged in concentrations below
analytic detection levels. Effluent guidelines also control pollutant discharges at the point of
discharge from industrial facilities and cover discharges directly to surface water (direct
discharges) and discharges to publicly-owned treatment works (POTWs) (indirect discharges).
For industrial dischargers to POTWs, this can have the added benefit of preventing the untreated
discharge of pollutants to groundwater from leaking sewer pipes or to surface waters due to
combined sewer overflows. Consequently, another of EPA's goals with the effluent guidelines
program is to explore all opportunities for pollution prevention and water conservation.
1.3 What are Effluent Guidelines and Pretreatment Standards?
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.
1. 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.
2. 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
1-2
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Section 1.0 - Background
industry to use these technologies, but rather allow the industry to use any
effective alternatives to meet the numerical pollutant limits.
3. 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.
4. In establishing national effluent guidelines for pollutants, EPA considers
various factors, as described in Section 1.2, 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 the technologies, which can include
consideration of costs, benefits, and affordability of achieving the
reduction in pollutant discharge.
5. National regulations apply to four types of facilities within an industrial
category: 1) existing facilities that discharge directly to surface waters
(direct discharges); 2) existing facilities that discharge to POTWs (indirect
dischargers); and 3) newly constructed facilities (new sources) that
discharge to surface waters either directly 4) or indirectly.
6. 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
through six levels of control: BPT, BAT, BCT, NSPS, PSES, and PSNS. 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), EPA promulgates 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). Figure 1-1 illustrates the relationship between
the regulation of direct and indirect dischargers.
1-3
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Section 1.0 - Background
Direct
Dischargers
Indirect
Dischargers
New
Sources
NSPS
Nonconventional Pollutants
Priority Pollutants (Toxics)
Existing
Sources
PSNS
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
BCT
• Conventional Pollutants
BAT
1 Nonconventional Pollutants
1 Priority Pollutants (Toxics)
PSES
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
BPT
1 Conventional Pollutants
1 Nonconventional Pollutants
1 Priority Pollutants (Toxics)
Figure 1-1. Regulations of Direct and Indirect Wastewater Discharges Under NPDES
1.3.1
Best Practicable Control Technology Currently Available (BPT) - CWA
Sections 301(b)(l)(A) & 304(b)(l)
EPA develops effluent limitations based on BPT 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
1-4
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Section 1.0 - Background
currently in place in an industrial category if the Agency determines that the technology can be
practically applied.
1.3.2 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).
1.3.3 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 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 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.
1.3.4 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.
1.3.5 Pretreatment Standards for Existing Sources (PSES) - CWA Section 307(b)
PSES apply to indirect dischargers, and 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 are technology-
based and are analogous to BAT effluent limitations guidelines.
1-5
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Section 1.0 - Background
The General Pretreatment Regulations, which set forth the framework for
implementing national pretreatment standards, are found at 40 CFR Part 403.
1.3.6 Pretreatment Standards for New Sources (PSNS) - CWA Section 307(c)
Like PSES, PSNS apply to indirect dischargers, and 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.
1.4 Success of EPA's Effluent Guidelines Program
The effluent guidelines program has helped reverse the water quality degradation
that accompanied industrialization in this country. Permits developed using the technology-
based industrial regulations are a critical element of the Nation's clean water program and reduce
the discharge of pollutants that have serious environmental impacts, including pollutants that:
• Kill or impair fish and other aquatic organisms;
• Cause human health problems through contaminated water, fish, or
shellfish; and
• Degrade aquatic ecosystems.
EPA has issued effluent guidelines for 56 industrial categories and these
regulations apply to between 35,000 and 45,000 facilities that discharge directly to the Nation's
waters, as well as another 12,000 facilities that discharge to POTWs. These regulations have
prevented the discharge of more than 1.2 billion pounds of toxic pollutants each year.
1.5 What Are EPA's Effluent Guidelines Planning and Review Requirements?
The CWA also requires EPA to annually review existing effluent guidelines.
EPA reviews all point source categories subject to existing effluent guidelines and pretreatment
standards to identify potential candidates for revision, as required by CWA sections 304(b),
301(d), 304(g) and 307(b). EPA also reviews industries consisting of direct discharging facilities
not currently subject to effluent guidelines to identify potential candidates for effluent guidelines
rulemakings, as required by CWA section 304(m)(l)(B). Finally, EPA reviews industries
consisting entirely or almost entirely of indirect discharging facilities that are not currently
subject to pretreatment standards to identify potential candidates for pretreatment standards
development, as required by CWA sections 304(g) and 307(b). CWA section 304(m) requires
EPA to publish an effluent guidelines program plan every two years. As part of the development
of this plan, the public is provided an opportunity to comment on a "preliminary" plan before it
is finalized. EPA publishes the preliminary plan on a two-year schedule followed by the final
effluent guidelines program plan in the succeeding years. The preliminary plan is published in
odd-numbered years and the final plan is published in even-numbered years.
1-6
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Section 2.0 - Public Comments
2.0 PUBLIC COMMENTS ON THE PRELIMINARY EFFLUENT GUIDELINES PROGRAM
PLAN FOR 2006 AND FINAL EFFLUENT GUIDELINES PROGRAM PLAN FOR 2004
EPA published its Preliminary 2006 Effluent Guidelines Program Plan (2006
Preliminary Plan) on August 29, 2005 (70 FR 51042-51060) and requested comments on various
aspects of its analyses, data, and information to inform its 2006 annual review. In addition, EPA
published its Final 2004 Effluent Guidelines Program Plan (2004 Final Plan) on September 2,
2004 (69 FR 53705-53721) and also requested comments, data and information to inform its
2005 annual review. Comments EPA received on the 2006 Preliminary Plan and on the 2004
Final Plan are located in EPA Docket Number EPA-HQ-OW-2004-0032. This section provides
background information on the list of commenters and issues raised during these comment
periods.
The Agency received 60 comments from a variety of commenters including
industry and industry trade associations, municipalities and sewerage agencies, environmental
groups, other advocacy groups, private citizens, federal agencies, and state government agencies.
Stakeholders' suggestions played a significant role in both the 2005 and 2006 annual reviews.
Table 2-1 lists all commenters as well as a synopsis of the comments.
2-1
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Section 2.0 - Public Comments
Table 2-1. Comments on the Preliminary 2006 and Final 2004 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2004-0032
No.
Commenter Name
EPA
E-Docket
No.
Comment Summary
Chris Sproul
Environmental Advocates
1088
Effluent Guidelines Program Plan violates CWA requirements.
Melanie Shepherdson
Natural Resources Defense
Council
1090
General comments on effluent guidelines planning process and industry-specific information. Focus is on
industries without ELGs or pretreatment standards.
Albert Ettinger
Environmental Law and
Policy Center of the
Midwest
1075
(duplicate
at 1071 and
1066)
Questions use of TRI and PCS databases.
EPA needs to better assess the toxicity of coal mining wastewaters.
ELGs are justified for coal fired power plants and drinking water treatment facilities.
EPA should focus its review on nutrients.
EPA should set pretreatment standards on alkylphenol ethoxylates (used in industrial cleaners).
to
to
Doug Mendoza
Metropolitan St. Louis
Sewer District, MO
1038
Provides DMR data for the rubber, inorganic chemical, industrial laundries, pesticides, and transportation
equipment cleaning point source categories. Also provides names, addresses, and SIC codes of
miscellaneous food and beverage facilities.
L. Kinman
Des Moines Water Works,
IA
1040
Supports designation of CWT for CAFOs.
Drinking water: water utility should not be regulated if a contaminant is removed and ultimately returned
to the same source.
Don Theiler
King County Wastewater
Treatment Division, WA
1042
Supports EPA conclusions that food service, laundries, printing and publishing, and photoprocessing
don't need categorical pretreatment standards.
Health services: worked extensively with dentists and hospitals. Developed effective rules at local levels;
significantly reduced mercury discharges from dentists; additional efforts not justified. Waste and waste
disposal practices change rapidly.
Established a Laboratory Waste Management Guide with BMPs.
Categorical standards are not the correct approach. Recommends BMPs and possibly control documents.
Information on dentists and hospitals including BMP guidance.
-------
Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
Commenter Name
EPA
E-Docket
No.
Comment Summary
Beverly B. Head
Metropolitan Sewer
District of Greater
Cincinnati, Ohio
1051
(duplicate
at 1085)
Provides information on cogeneration and coverage under steam electric, recommending cogeneration
facilities continue to be regulated under local limits or categorical requirements for the primary processes.
Water conservation: EPA should develop a policy that will not lower mass-based limits for those
employing water conservation.
By industrial category, provides a list of the number of facilities, type of treatment, and remaining
pollutants.
Provides information on how they classify various industries, including health services.
POTW pass-through analysis: supports TWPE approach to pass through; recommends considering color
and foam as pollutants.
Provides information on elevated levels of certain chemicals in laundries, ICDC, and OCPSF.
Says that the headspace analysis requirement reduces risk of pass through and interference.
EPA should not issue last-minute changes as it did with CWT.
to
Sherry E. Bagwell
City of Winston-Salem,
NC
1061
City regulates three tobacco processing facilities with no problems; continues to regulate at the local level;
submitted data on flows, treatment technologies in place, and some metals monitoring data.
Bernie Strohmeyer
Hampton Roads Sanitation
District, Virginia
1086
No new PSES categories necessary.
Comment on need for new POTW study as well as some suggestions about current study.
Comments on pulp and paper and steam electric ELGs.
Information and comments on tobacco and health services industries.
Stakeholder involvement early in process is critical.
No new PSES categories necessary.
Flow-normalized mass-based permit limits: adopt flow-normalized mass-based permit limits for all
indirect dischargers to encourage water conservation.
Strategy: agrees with risk approach; focus on revising of existing ELGs, not development of new ones;
good opportunity for collaboration; and agrees with 4 factors (especially that the first one is key).
Technology: consider financial incentives or tax breaks for companies that develop innovative
technologies.
Trading: allow effluent trading for indirect dischargers.
10 Richard Lanyon
Metropolitan Water
Reclamation District of
Greater Chicago
1078
Provides information on SIUs in their region that fall within the detailed and preliminary study categories.
No data on loads or discharges. New PSES categories are unnecessary unless permitting authorities
request guidance.
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
11
12
13
14
15
16
17
18
19
20
Commenter Name
Mary Boatman
Minerals Management
Service
Thomas Bigford
NOAA Fisheries Service
Gary Valasek
Intercontinental Chemical
Corporation
Roger E.Claff
American Petroleum
Institute
G. H. Holliday
Holliday Environmental
Services
Stephan von Tapavicza
Cognis Oilfield Chemicals
Timothy P. Gaughan
Arkema Inc
LindliefHall
Tongue River Water
Users' Association
Gregory E. Conrad
Interstate Mining Compact
Commission (IMCC)
Carl Johnson, Southern
Pressure Treaters
Association and Dave
Webb, Creosote Council
III
EPA
E-Docket
No.
1056
(duplicate
at 1044 &
OW-2002-
0020-0070)
1094
0002
0005 &
0006
0007
through
0011
1041
1045 &
1046
1048
(duplicate
at 1050)
1055 &
1057
1052
Comment Summary
Recommends setting effluent guidelines for "open-loop" LNG import terminals.
Recommends setting effluent guidelines for "open-loop" LNG import terminals.
Provides information on potential Chemical Formulating, Packaging, and Repackaging subcategory of
OCPSF ELG.
Recommends that EPA continue to use the 4-factor strategy to screen new and existing industrial
categories for new or revised effluent guidelines. Provided suggestions for improving EPA's strategy for
selecting industries, and concurs with EPA's decision not to select the petroleum refining effluent
guidelines for revision.
EPA should clarify the Oil and Gas Extraction Point Source Category (40 CFR 435), Offshore
Subcategory BAT and NSPS requirements for the sediment toxicity test for certain synthetic base drilling
fluids. Believes these requirements are not demonstrated, and the variability inherent in the test method
makes it inappropriate as the basis for regulatory compliance.
Provides information on an ester-based synthetic -based drilling fluid.
Provides information on OCPSF and mass-limits issue re: water conservation.
Recommends ELGs for Coal Bed Methane (CBM).
Recommends modifying or deleting Manganese limitations in Coal Mining ELGs (Part 434).
Provides information on Timber Products ELGs (Part 429).
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
21
22
23
24
25
26
27
28
29
30
Commenter Name
S. Noble
Photo Marketing
Association International
Thomas W. Curtis
American Water Works
Association
Robert E. Fronczak
Association of American
Railroads
Norbert Dee
National Petrochemical &
Refiners Association
P. Spencer Davies
Strathkelvin Instruments
Roger E.Claff
American Petroleum
Institute
Betty Anthony (API) &
KimHarb(NOIA)
American Petroleum
Institute and National
Ocean Industries
Association
Amy E. Schaffer
Weyerhaeuser Company
Elizabeth Aldridge
Utility Water Act Group
John Candler
M-I SWACO
EPA
E-Docket
No.
1053
(duplicate
at 1054)
1059 (dup
&OW-
2002-0020-
0072)
1060
1063
1102
1067
1089
1070
1099
(revisions
to 1070)
1083
1084
Comment Summary
Provides information on photoprocessing industry.
EPA should focus on sediments, nutrients, and microbiological contamination in its effluent guidelines -
not discharges from drinking water treatment facilities.
Provides information and comments on methodology including TWFs and POTW removal rates.
Provides information on Petroleum Refining ELGs.
Comments on including cogeneration units in Steam Electric ELGs.
Provides information on his monitoring technology for assessing interference with an activated sludge
POTW.
Provides information on Petroleum Refining ELGs.
Comments on including cogeneration units in Steam Electric ELGs.
TWF methodology comments.
Provides information on synthetic-based drilling fluids and related analytic methods in Part 435.
Provides information on Phase I and Phase II Pulp and Paper facilities.
Provides information on Steam Electric ELGs and methodology comments.
Provides information on synthetic-based drilling fluids and related analytic methods in Part 435.
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
31
32
33
34
35
36
37
Commenter Name
Tracey Norberg
Rubber Manufacturers
Association
Paul Weigand
National Council for Air
and Stream Improvement,
Inc.
Jerry Schwartz
American Forest & Paper
Association
Robert Elam
American Chemistry
Council
Steve C. Curl
R. J .Reynolds Tobacco
Company
Susan Bruninga
National Association of
Clean Water Agencies
Jeff Gunnulfsen
Synthetic Organic
Chemical Manufacturers
Association
EPA
E-Docket
No.
1097
1079
(duplicate
at 1069)
1104
(updates)
1074
0073
(duplicate
at 1068)
1096
1093
1098
Comment Summary
Provides information on Rubber Manufacturing ELGs (Part 428).
Provides information and comments on Pulp and Paper ELGs.
Provides information and comments on Pulp and Paper ELGs.
Comments on possible inclusion of cogeneration units under steam electric ELGs.
Comments on review methodology.
Facility-specific OCPSF comments.
Comments on mass-based versus concentration-based limits.
Provides information on the OCPSF ELGs.
Provides information on their tobacco facilities and environmental studies.
No new PSES categories necessary.
Comment on need for new POTW study as well as some suggestions about current study.
Comments on Pulp and Paper and Steam Electric ELGs.
Provides information and comments on tobacco and health services industries.
Flow-normalized mass-based permit limits: adopt flow-normalized mass-based permit limits for all
indirect dischargers to encourage water conservation.
Strategy: agrees with risk approach; focus on revisions of existing ELGs, not development of new ones;
good opportunity for collaboration; agrees with 4 factors (especially that the first one is key).
Technology: consider financial incentives or tax breaks for companies that develop innovative
technologies.
Trading: allow effluent trading for indirect dischargers.
Provides information on OCPSF and mass- vs. concentration-based limits issue.
to
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
38
39
40
41
42
43
44
45
46
47
48
Commenter Name
Thomas White
Pharmaceutical Research
and Manufacturers of
America
Terrance Rucker
American Public Power
Association
Paul Chu
Electric Power Research
Institute
John Ochs
Perm View Mining, Inc.
T.J.S. Mining, Inc.
Thomas J. Smith, Inc.
Stanley R. Geary
Pennsylvania Coal
Association
David D. Dunlap
Uniform & Textile Service
Association
Jeffrey S. Lynn
International Paper
Kairas Parvez, Sr.
MeadWestvaco
Porcelain Enamel Institute
John M. Ross
NiSource Inc
Mayes Starke
Georgia-Pacific
EPA
E-Docket
No.
1095
1065
1073
1091
1062
(duplicate
at 1100)
1064
1087
1077
(duplicate
at 1092)
1072
1076
1082
Comment Summary
Comments on possible inclusion of cogeneration units under Steam Electric ELGs.
Comments on mass- vs. concentration-based limits issue.
Provides information on Steam Electric ELGs and Detailed Study.
Provides information on Steam Electric ELGs and Detailed Study.
Recommends modifying or deleting manganese limitations in Coal Mining ELGs (Part 434).
Recommends modifying or deleting manganese limitations in Coal Mining ELGs (Part 434).
Supports EPA's two-part evaluation for determining pass-through potential.
TWFs have not been properly vetted and development needs to be more transparent.
EPA should focus its efforts on assisting small POTWs rather than categorical standards.
Information on laundries industry.
Provides information on Pulp and Paper ELGs and Detailed Study.
Provides information on Pulp and Paper ELGs and Detailed Study.
Provides information on Porcelain Enameling ELGs (Part 466).
Comments on the possible inclusion of cogeneration units under Steam Electric ELGs.
Provides information on Pulp and Paper ELGs and Detailed Study.
to
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
49
50
51
52
52
53
54
55
Commenter Name
Kenneth S. Johnson
Constellation Generation
Group
Christine M. Andrews
National Restaurant
Association
Richard Marchi
Airports Council
International - North
America (ACI-NA)
American Association of
Airport Executives
(AAAE)
Airport Clean Water
Alliance (ACWA)
Robert J. King
Lorillard Tobacco
Company
Hugh Wise
George M. Jett
Karl Mueldener
Kansas Department of
Health and Environment
William Creal
Michigan Department of
Environmental Quality
EPA
E-Docket
No.
1080
1081
OW-2002-
0020-0074
{Note that
this is in
the
'Strategy'
Docket}
1105
1047
0003
0004
Comment Summary
Provides information on the Steam Electric ELGs and Detailed Study.
EPA should not establish pretreatment standards for food service establishments.
Seeks assurance that promulgation of an airport deicing regulation will not occur without full
consideration of the complex issues affecting airport deicing issues.
Provides information on the tobacco industry and study.
EPA should recodify ELGs to put them in plain English.
Develop TWFs for oil and grease compounds and nutrients.
Revise the POTW Study.
Implement OMB review of EPA policy making.
Evaluate new industrial categories.
Publish ELG Guidance Documents.
Fix older regulations and implement all regulations.
Commenter provided information on Kansas' program to control discharges from drinking water
treatment facilities.
Strongly supports EPA continuing to revise and update technology -based effluent limitations, which they
believe is one of EPA' s primary responsibilities and a cornerstone of the CWA.
to
I
oo
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Section 2.0 - Public Comments
Table 2-1 (Continued)
No.
56
57
58
59
60
Commenter Name
Allen Gilliam
Arkansas Department of
Environmental Quality
Dave Knight
Washington State
Department of Ecology
Steve Caspers
State of Kansas
Dave Knight
Washington State
Department of Ecology
Benny R. Wampler
VA Department of Mines,
Minerals, and Energy
Kathleen A. McGinty
PA Department of
Environmental Protection
EPA
E-Docket
No.
0678
0680
1036
1049
1101
Comment Summary
Recommends EPA revise the effluent guidelines for the Transportation Equipment Cleaning Point Source
Category (40 CFR 442) due to difficulties in assessing compliance with the current requirements. The
control authority has insufficient knowledge of the practices.
Recommends EPA evaluate pretreatment standards with more focus on small to medium sized POTWs,
who may not be aware of the opportunity to provide comment on rulemaking activities. Industrial
wastewater treatment effectiveness of smaller POTWs may differ from larger POTWs.
Revisit pretreatment standards for Meat and Poultry Products (40 CFR 432), Industrial Laundries (never
promulgated), and Metal Molding and Casting (40 CFR 464) Point Source Categories. Also recommends
EPA study hospitals and dental facilities, with particular focus on emerging pollutants of concern, and
laboratory and pharmaceutical exotics.
Recommends sunsetting existing source standards for new source standards for all industries by a future
date, and removing phenol limits from all pretreatment standards, particularly the Metal Molding and
Casting Point Source Category (40 CFR 464).
Recommends EPA review interference issues associated with UV disinfection equipment at POTWs.
Notes that this issue could also become more prevalent as more cities convert from chlorine to UV for
disinfection.
Comments on TWFs and the TWF Methodology.
Need guidance/tools for emerging contaminants.
Comments on screening-level analysis and TRI/PCS databases.
Need to solicit more information from POTWs on interference.
Supports development of ELGs for dentists.
Review new and existing source definitions.
Remove phenol limits from all PSES for all point source categories.
Recommends modifying or deleting manganese limitations in Coal Mining ELGs (Part 434).
Recommends modifying or deleting manganese limitations in Coal Mining ELGs (Part 434).
to
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Section 3.0 - The Effluent Guidelines Planning Process
3.0 THE EFFLUENT GUIDELINES PLANNING PROCESS
This section provides a general overview of the process EPA used to identify
industrial categories for potential development of new or revised effluent limitations guidelines
and pretreatment standards (ELGs) in 2005 and 2006. This process consists of: (1) annual
review of existing ELGs to identify candidates for revision; (2) identification of new categories
of direct dischargers for possible development of effluent guidelines; and (3) identification of
new categories of indirect dischargers for possible development of pretreatment standards. Each
of these components is illustrated in Figure 3-1 and discussed below.
3.1 Goals of the ELG Planning Process
In the effluent guideline planning process, EPA was guided by the following
goals:
• Restore and maintain the chemical, physical, and biological integrity of
the Nation's waters; and
• Provide transparent decision-making and involve stakeholders early and
often during the planning process.
3.2 Annual Review of Existing Effluent Guidelines and Pretreatment Standards
This section describes the four factors used (Section 3.2.1) and how they are used
(Section 3.2.2) in the annual review of existing effluent guidelines and pretreatment standards.
3.2.1 Factors Considered in Review of Existing Effluent Guidelines and
Pretreatment Standards
EPA uses four major factors in prioritizing existing effluent guidelines or
pretreatment standards for possible revision.
The first factor EPA considers is the amount and type of pollutants in an industrial
category's discharge, and the relative hazard posed by that discharge. This enables the Agency
to set priorities for rulemaking to achieve the greatest environmental and health benefits. EPA
estimates the toxicity of pollutant discharges in terms of toxic-weighted pound equivalents
(TWPE), discussed in detail in Section 4.1.3. To assess the effectiveness of pollution control,
EPA examines the removal of pollutants, in terms of pounds and TWPE.
The second factor EPA considers is the performance and cost of applicable and
demonstrated wastewater treatment technologies, process changes, or pollution prevention
alternatives that could effectively reduce the pollutants in the industrial category's wastewater
and, consequently, reduce the hazard to human health or the environment associated with these
pollutant discharges.
3-1
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Section 3.0 - The Effluent Guidelines Planning Process
PCS&TRI
database
tools
Begin annual
review of existing
ELGs
Preliminary Results of Screening -Level
Review = Combined TRIReleases and
PCSLoads database rankings (Factor 1)
Are ELG
revisions currently
underway?
Stakeholder
recommendations
and comments
further review at
Have ELGs
been developed or
revised within the past 7
years?
further review at
Are only
a very few facilities
responsible for overall
category TWPE?
When ranked
by TWPE, does category
contribute to top 95% of
cumulative TWPE of all
categories?
Do further review \
(see Figure 3-2) I
Possible outcome
- Further review
- BPJ support
- Identify for
possible revision
of existing ELGs
- No action
Are there
identified implementation
and efficiency issues
(Factor 4)?
Not a priority category ; no
further review at this time
Stakeholder
recommendations
and comments
"If EPA is aware of new segment growth within such a category or new concerns are identified , EPA may do further review .
Figure 3-1. Flow Chart of Annual Review of Existing ELGs
3-2
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Section 3.0 - The Effluent Guidelines Planning Process
/Category identified for further \
I review (see Figure 3-1) J
Further Review
- Detailed studies
- Preliminary review
- Continue collecting data (all
four factors)
Not enough
information
Stakeholder input
Are discharges
adequately controlled
by existing ELGs?*
Yes
No further review at this time
No
Are ELGs
potentially the
appropriate
tool?
No
Yes
Identify for possible revision of'
ELGs /
Identify other tools (e.g.,
permit-based support or
guidance)
'Continue further review if not enough data .
Figure 3-2. Flow Chart of Further Review of Existing ELGs
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Section 3.0 - The Effluent Guidelines Planning Process
Stakeholder recommendations
and comments
Begin industry
identification
~^ T >
J t
1
PCS& TRI
database tools
Identify SIC codes
with discharges
not subject to
existing ELGs
w
W
s the SIC code
appropriately
considered a potential
ew subcategory of an
existing ELG?
Include in annual review of
existing category
(see Figure 3-1)
No identification or \
further review necessaryy
Do
discharges interfere
with or otherwise pass
through POTW
operations?*
Are
discharges of toxic
or nonconventional
pollutants
trivial?*
Is the possible new
category all or nearly all
indirect dischargers ?
Identify for possible
new effluent guidelines
or standards
Are ELGs potentially
the appropriate tool ?
No identification or
^
further review necessaryy
Identify other tools
(e.g., perm it-based
support or guidance )
'Continue further review if not enough data
Figure 3-3. Flow Chart of Identification of Possible New ELGs
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Section 3.0 - The Effluent Guidelines Planning Process
The third factor EPA considers is the affordability or economic achievability of
the wastewater treatment technology, process change, or pollution prevention measures
identified using the second factor. If the financial condition of the industry indicates that it
would be difficult to implement new requirements, EPA might conclude that it would be more
cost-effective to develop less expensive approaches to reducing pollutant loadings that would
better satisfy applicable statutory requirements.
The fourth factor EPA considers is an opportunity to eliminate inefficiencies or
impediments to pollution prevention or technological innovation, or opportunities to promote
innovative approaches such as water quality trading, including within-plant trading. This factor
might also prompt EPA, during an annual review, to decide against identifying an existing set of
effluent guidelines or pretreatment standards for revision where the pollutant source is already
efficiently and effectively controlled by other regulatory or nonregulatory programs.
3.2.2 Overview: Review of Existing Point Source Categories
EPA has established ELGs to regulate wastewater discharges from 56 point
source categories and 450 subcategories. EPA must annually review the ELGs for all of these
categories and subcategories. EPA first does a screening-level review of all categories subject to
existing ELGs. EPA then conducts further review of categories prioritized as a result of the
screening level review. This further review consists of either an in-depth "detailed study" or a
somewhat less detailed "preliminary category review." Based on this further review, EPA
identifies existing categories for potential ELGs revision.
3.2.2.1 Screening-Level Review
The screening-level review is the first step in EPA's annual review. Section 4.0
provides details on the database methodology used in the screening-level review. EPA uses this
step to prioritize categories for further review. In conducting the screening-level review, EPA
considers the amount and toxicity of the pollutants in a category's discharge and the extent to
which these pollutants pose a hazard to human health or the environment (Factor 1).
EPA conducts its screening-level review with data from TRI and PCS. TRI and
PCS do not list the effluent guideline(s) applicable to a particular facility. However, they both
include information on a facility's Standard Industrial Classification (SIC) code. Therefore, the
first step in EPA's screening-level review is to assign each SIC code to an industrial category1.
EPA then uses the information reported in TRI and PCS, for a specified year, in combination
with toxic weighting factors (TWFs)2 to calculate the total discharge of toxic and
nonconventional pollutants (reported in units of toxic-weighted pound equivalent or TWPE) for
each facility in a category for that year. For indirect dischargers, EPA adjusts this facility-
specific value to account for removals at the POTW. EPA then sums the TWPE for each facility
in a category to calculate a total TWPE per category for that year. EPA calculates two TWPE
estimates for each category: one based on data in TRI and one based on data in PCS. In its 2005
1 For more information on EPA's assignment of each SIC code to an industrial category, see Section 5.0 of the 2005
Annual Screening-Level Analysis Report (U.S. EPA, 2005).
2 For more information on Toxic Weighting Factors, see Toxic Weighting Factor Development in Support ofCWA
304(m) Planning Process (U.S. EPA, 2006).
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Section 3.0 - The Effluent Guidelines Planning Process
and 2006 reviews, EPA combined the estimated discharges of toxic and nonconventional
pollutants calculated from the TRI and PCS databases to estimate a single TWPE value for each
industrial category. EPA took this approach because it found that combining the TWPE
estimates from the TRI and PCS databases into a single TWPE number offered a clearer
perspective of the industries with the most toxic pollution3.
EPA then ranks point source categories according to their total TWPE discharges.
In identifying categories for further review, EPA prioritizes categories accounting for 95 percent
of the cumulative TWPE from the combined databases. (See Section 5.3). EPA also excludes
from further review categories for which effluent guidelines had been recently promulgated or
revised (within the past seven years), or for which an effluent guidelines rulemaking is currently
underway. EPA chose seven years because this is the time it customarily takes for the effects of
effluent guidelines or pretreatment standards to be fully reflected in pollutant loading data and
TRI reports. EPA also considers the number of facilities responsible for the majority of the
estimated toxic-weighted pollutant discharges associated with an industrial activity. Where only
a few facilities in a category account for the vast majority of toxic-weighted pollutant discharges,
EPA does not prioritize the category for additional review. In this case, EPA believes that
revising individual permits may be more effective in addressing the toxic-weighted pollutant
discharges than a national effluent guidelines rulemaking because requirements can be better
tailored to these few facilities, and because individual permitting actions may take considerably
less time than a national rulemaking.
3.2.2.2 Further Review
Following its screening-level review of all point source categories, EPA
prioritizes certain categories for further review. The purpose of the further review is to
determine whether it would be appropriate for EPA to identify in the final plan a point source
category for potential effluent guidelines revision. EPA typically conducts two types of further
review: detailed studies and preliminary reviews. EPA selects categories for further review
based on the screening-level review and/or stakeholder input.
EPA's detailed studies generally examine the following: (1) wastewater
characteristics and pollutant sources; (2) the pollutants driving the toxic-weighted pollutant
discharges; (3) availability of pollution prevention and treatment; (4) the geographic distribution
of facilities in the industry; (5) any pollutant discharge trends within the industry; and (6) any
relevant economic factors. First, EPA attempts to verify the screening-level results and to fill in
data gaps (Factor 1). Next, EPA considers costs and performance of applicable and
demonstrated technologies, process changes, or pollution prevention alternatives that can
effectively reduce the pollutants remaining in the point source category's wastewater (Factor 2).
Lastly, EPA considers the affordability or economic achievability of the technology, process
change, or pollution prevention measures identified using the second factor (Factor 3).
3Different pollutants may dominate the TRI and PCS TWPE estimates for an industrial category due to the
differences in pollutant reporting requirements between the TRI and PCS databases. The single TWPE number for
each category highlights those industries with the most toxic discharge data in both TRI and PCS. Although this
approach could have theoretically led to double-counting, EPA's review of the data indicates that because the two
databases focus on different pollutants, double-counting was minimal and did not affect the ranking of the top
ranked industrial categories.
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Section 3.0 - The Effluent Guidelines Planning Process
Types of data sources that EPA may consult in conducting its detailed studies
include, but are not limited to: (1) U.S. Economic Census; (2) TRI and PCS data; (3) trade
associations and reporting facilities to verify reported releases and facility categorization; (4)
regulatory authorities (states and EPA regions) to understand how category facilities are
permitted; (5) NPDES permits and their supporting fact sheets; (6) EPA effluent guidelines
technical development documents; (7) relevant EPA preliminary data summaries or study
reports; and (8) technical literature on pollutant sources and control technologies.
Preliminary reviews are similar to detailed studies and have the same purpose.
During preliminary reviews, EPA generally examines the same factors and data sources listed
above for detailed studies. However, in a preliminary review, EPA's examination of a point
source category and available pollution prevention and treatment options is less rigorous than in
its detailed studies. While EPA collects and analyzes hazard and technology performance and
cost information on categories undergoing preliminary review, it assigns a higher priority to
investigating categories undergoing detailed studies.
3.3 Identification of New Categories of Direct Dischargers for Possible Effluent
Guidelines Development
Concurrent with its review of existing point source categories, EPA also reviews
industries not currently subject to effluent guidelines to identify potential new point source
categories. To identify possible new categories, EPA conducts a "crosswalk" analysis based on
data in PCS and TRI. Facilities with data in PCS and TRI are identified by a four-digit SIC code
(Section 4.1.1 provides more details on SIC codes). As with existing sources, EPA links each
four-digit SIC code to an appropriate industrial category (i.e., "the crosswalk")4. This crosswalk
identifies SIC codes that EPA associated with industries subject to an existing guideline. The
crosswalk also identifies SIC codes not associated with an existing guideline. In addition to the
crosswalk analysis, EPA relies on stakeholder comments and data in identifying potential new
point sources categories. TRI and PCS have only limited data on discharges on potential new
categories or subcategories. Section 4.1 discusses the utility and limitations of TRI and PCS in
detail.
For each industry identified through the crosswalk analysis or stakeholder
comments, EPA evaluates whether it constitutes a potential new category subject to
identification in the plan or whether it is properly considered a potential new subcategory of an
existing point source category. To make this determination, EPA generally looks at whether the
industry produces a similar product or performs a similar service as an existing category. If so,
EPA generally considers the industry to be a potential new subcategory of that category. If,
however, the industry is significantly different from existing categories in terms of products or
services provided, EPA considers the industry as a potential new stand-alone category subject to
identification in the plan.
Because the CWA specifies different requirements for potential new categories of
direct and indirect dischargers, EPA examines potential new categories to determine if the
4 For additional information on "the crosswalk," see Section 5.0 of the 2005 Screening-Level Analysis Report (U.S.
EPA, 2005).
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Section 3.0 - The Effluent Guidelines Planning Process
category comprises mostly indirect dischargers or if it comprises both direct and indirect
dischargers. If a category consists largely of indirect dischargers, EPA evaluates the pass-
through and interference potential of the category (see Section 3.4). If a category includes direct
dischargers, EPA evaluates the type of pollutants discharged by the category.
EPA does not identify in the plan industries for which conventional pollutants,
rather than toxic or nonconventional pollutants, are the pollutants of concern. Also, even where
toxic and non-conventional pollutants are present in the discharge, EPA does not identify the
industry in the plan if such pollutants are present only in trivial amounts and thereby present an
insignificant hazard to human health and the environment.
Further, EPA would likely not identify an industrial sector as a candidate point
source category for an effluent guidelines rulemaking when: (1) the industrial category is
currently the subject of an effluent guidelines rulemaking effort (e.g., Airport Deicing
Operations, Drinking Water Treatment Facilities); or (2) direct discharges from point sources
within the industrial sector are not subject to the CWA permitting requirements (e.g., direct
discharges from silviculture operations).
Finally, EPA does not necessarily identify in the plan all potential new categories
subject to identification. Rather, EPA may exercise its discretion to identify only those potential
new categories for which it believes an ELG would be an appropriate tool - and rely on other
CWA tools (e.g., water-quality based effluent limitations or assistance to permit writers in
establishing site-specific technology-based effluent limitations) when such other mechanisms
would be more effective and efficient.
3.4 Identification of New Categories of Indirect Dischargers for Possible Effluent
Guidelines Development
For potential new categories with primarily indirect discharges, EPA evaluates the
potential for the wastewater to "interfere with, pass through, or [be] otherwise incompatible
with" the operation of POTWs. See 33 U.S.C.§ 1371(b)(l). Using available data, EPA reviews
the types of pollutants in an industry's wastewater. Then, EPA reviews the likelihood of those
pollutants to pass through a POTW. For most categories, EPA evaluated the "pass through
potential" as measured by: (1) the total annual TWPE discharged by the industrial sector; and (2)
the average TWPE discharge among facilities that discharge to POTWs. EPA also assesses the
interference potential of the discharge. Finally, EPA considers whether the pollutant discharges
are already adequately controlled by general pretreatment standards and/or local pretreatment
limits. Section 19 of this TSD describes EPA's review of industries with primarily indirect
discharges to determine whether to establish categorical pretreatment standards under CWA
sections 304(g) and 307(b).
3.5 Stakeholder Involvement and Schedule
EPA's goal is to involve stakeholders early and often during its annual reviews of
existing effluent guidelines and the development of the biennial plans. This will likely maximize
collection of data to inform EPA's analyses and provide additional transparency and
understanding of EPA's effluent guidelines priorities identified in the biennial plans.
3-8
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Section 3.0 - The Effluent Guidelines Planning Process
EPA's annual reviews build on reviews from previous years, and reflect a lengthy
outreach effort to involve stakeholders in the review process. In performing its annual reviews,
EPA considers all public comments, information, and data submitted to EPA as part of its
outreach activities. EPA solicits public comment at the beginning of each annual review of
effluent guidelines and on the preliminary biennial plan. In each Federal Register Notice, EPA
requests stakeholder comments on specific industries and discharges as well as any general
comments.
EPA completes an annual review of industrial discharges each year, upon
publication of the Preliminary and Final Effluent Guidelines Program Plans. In odd-numbered
years, EPA publishes its preliminary plan that EPA must publish for public review and comment
under CWA section 304(m)(2). In even-numbered years, EPA publishes its final plan that
incorporates the comments received on the preliminary plan.
EPA intends that these coincident reviews will provide meaningful insight into
EPA's effluent guidelines and pretreatment standards program decision-making. Additionally,
EPA is using an annual publication schedule to most efficiently serve the public as these annual
notices will serve as the 'one-stop shop' source of information on the Agency's current and
future effluent guidelines and pretreatment standards program.
3.6 References
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2005. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m) Planning
Process. Washington, DC. (June). DCN 03196.
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Section 4.0 - Methodology, Data Sources, and Limitations
4.0 METHODOLOGY, DATA SOURCES, AND LIMITATIONS
As discussed in Section 1.0, the CWA requires EPA to conduct an annual review
of existing effluent limitations guidelines and standards (ELGs). It also requires EPA to identify
which unregulated industrial categories are candidates for further review. EPA's methodology
for this annual review and unregulated category identification involves several components.
First, EPA performs a screening-level review of all point source categories subject
to existing ELGs to identify categories discharging high levels of toxic and nonconventional
pollutants relative to other categories. Using the results of the screening-level review, EPA
continues its annual review of priority categories to identify candidate ELGs for revision, as
required by CWA sections 304(b), 301(d), 304(g) and 307(b). The findings of EPA's 2006
annual review are discussed in Part II (Sections 5.0 to 18.0). Second, EPA reviews indirect
discharging industries not currently subject to pretreatment standards to identify potential
candidates for pretreatment standards development, as required by CWA section 307(b). The
findings of this review are discussed in Part III (Section 19.0) of this report. Finally, EPA
reviews direct discharging industries not currently subject to ELGs to identify potential
candidates for ELG development, as required by section 304(m)(l)(B) of the CWA. The
findings of this review are discussed in Part III (Section 20.0) of this report.
In performing the screening-level reviews of existing ELGs and identifying
unregulated industrial categories, EPA relies on data from the Permit Compliance System (PCS)
and Toxic Release Inventory (TRI). This section discusses these databases, related data sources,
and their limitations.
EPA has developed two screening-level tools, the TRIReleases and PCSLoads
databases, to facilitate analysis of TRI and PCS. EPA explains the creation of these screening-
level analysis tools in the report entitled, 2005 Annual Screening-Level Analysis: Supporting the
Annual Review of Existing Effluent Limitations Guidelines and Standards and Identification of
Potential New Categories for Effluent Limitations Guidelines and Standards, dated August 2005
(U.S. EPA, 2005b). The 2005 SLA report provides the detailed methodology used to process
thousands of data records and generate national estimates of industrial effluent discharges. This
section does not revisit the details of creating the database tools. Instead, it lists the methodology
corrections made to the PCS and TRI databases after EPA's 2005 annual review. It also presents
the preliminary category rankings from TRIReleases2002_v4, TRIReleases2003_v2, and
PCSLoads2002_v4.
4.1 Data Sources and Limitations
This subsection provides general information on the use of SIC codes, TWFs, TRI
data, and PCS data. The following reports supplement this section and discuss EPA's
methodology for developing and using these tools:
The 2005 SLA Report (U.S. EPA, 2005b): Documents the methodology
and development ofthePCSLoads2002 and TRIReleases2002 databases,
including (but not limited to) matching SIC codes to point source
categories and using TWFs to estimate TWPE;
4-1
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Section 4.0 - Methodology, Data Sources, and Limitations
• The Draft Toxic Weighting Factor Development in Support of the CWA
304(m) Planning Process (Draft TWF Development Document), dated
July 2005 (U.S. EPA, 2005a): Explains how EPA developed its TWFs;
and
• The Toxic Weighting Factor Development in Support of the CWA 304(m)
Planning Process (Final TWF Development Document) (U.S. EPA,
2006a): Explains how EPA developed the April 2006 TWFs.
4.1.1 SIC Codes
The SIC system was developed to help with the collection, aggregation,
presentation, and analysis of data from the U.S. economy (OMB, 1987). The SIC code is
formatted in the following way:
• The first two digits represent the major industry group;
• The third digit represents the industry group; and
• The fourth digit represents the industry.
For example, major SIC code 10: Metal Mining, includes all metal mining
operations. Within SIC code 10, four-digit SIC codes are used to separate mines by metal type:
1011 for iron ore mining, 1021 for copper ore mining, etc.
The SIC system is used by many 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 (e.g., the economic census) track only the primary SIC code for each
establishment. TRI allows reporting facilities to identify their primary SIC code and up to five
additional SIC codes. PCS includes one 4-digit SIC 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.
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. Therefore, to use databases that
identify facilities by SIC code, EPA linked each 4-digit SIC code to an appropriate point source
category, as summarized in the "SIC/Point Source Category Crosswalk" table (Appendix A).
There are some SIC codes for which EPA has not established national ELGs.
Some of these SIC codes were reviewed because they were identified through stakeholder
comments or other factors. These are discussed in Part III of this document. Appendix B lists
the SIC codes for which facility discharge data are available in TRI and/or PCS, but for which
EPA could not identify an applicable point source category. For a more detailed discussion, see
Section 5.5 of the 2005 Annual Screening-Level Analysis report (U.S. EPA, 2005b).
4-2
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Section 4.0 - Methodology, Data Sources, and Limitations
4.1.2 Toxic Weighting Factors
In developing ELGs, EPA developed a variety of tools and methodologies to
evaluate effluent discharges. Within EPA's Office of Water, the Engineering and Analysis
Division (EAD) maintains a Toxics Database, compiled from over 100 references, containing
aquatic life and human health toxicity data, as well as physical/chemical property data, for more
than 1,900 pollutants. The pollutants in this database are identified by a unique Chemical
Abstracts Service (CAS) number. EPA calculates TWFs from these data to account for
differences in toxicity across pollutants and to provide the means to compare mass loadings of
different pollutants on the basis of their toxic potential. In its analyses, EPA multiplies a mass
loading of a pollutant in pounds per year (Ib/yr) by a pollutant-specific weighting factor to derive
a "toxic-equivalent" loading (Ib-equivalent/yr). The development of TWFs is discussed in detail
in the Draft and Final TWF Development Documents (U.S. EPA, 2005a; U.S. EPA, 2006a).
EPA derives TWFs 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 are compared to benchmark values. EPA
selected copper, a toxic metal commonly detected and removed from industry effluent, as the
benchmark pollutant. The Final TWF Development Document contains details on how EPA
developed its TWFs. Appendix C lists the TWFs for those chemicals in the TRIReleases and
PCSLoads databases for which EPA has developed TWFs.
4.1.3 Calculation of TWPE
EPA weighted the annual pollutant discharges calculated from the TRI (see
Section 4.1.4) and PCS (see Section 4.1.5) databases 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.
4.1.4 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.
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 years
2002 and 2003 includes more than 600 chemicals and chemical categories. For the 2005 and
2006 screening-level reviews, EPA used data for reporting years 2002 and 2003, because they
were the most recent available at the time the review began.
A facility must meet the following three criteria to be required to submit a TRI
report for a given reporting year:
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Section 4.0 - Methodology, Data Sources, and Limitations
(1) SIC Code Determination: Facilities in SIC codes 20 through 39, 16
additional SIC codes outside this range5, and federal facilities are 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 non-PBT chemicals. Generally, threshold quantities are 25,000
pounds for manufacturing and processing activities, and 10,000 pounds for
otherwise use activities. All thresholds are determined per chemical over
the calendar year. For example, dioxin and dioxin-like compounds are
considered PBT chemicals. The TRI reporting guidance requires any
facility that manufactures, processes, or otherwise uses 0.1 grams of
dioxin and dioxin-like compounds to report it to TRI (U.S. EPA, 2000).
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, (e.g., POTWs, commercial waste disposal facilities).
For its screening-level reviews, 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 years 2002 and 2003. For facilities transferring to POTWs, EPA
first adjusted the TRI pollutant loads reported to be transferred to POTWs to account for
pollutant removal that occurs at the POTWs prior to discharge to the receiving stream. Appendix
D lists the POTW removals used for all TRI chemicals reported as transferred to POTWs.
Facilities reporting to TRI are not required to sample and analyze waste streams
to determine the quantities of toxic chemicals released. They may estimate releases based on
mass balance calculations, published emission factors, site-specific emission factors, or other
5 The 16 additional SIC codes are 1021, 1031, 1041, 1044, 1061, 1099, 1221, 1222, 1231, 4911, 4931, 4939, 4953,
5169, 5171, and 7389.
4-4
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Section 4.0 - Methodology, Data Sources, and Limitations
approaches. Facilities are required to indicate, by a reporting code, the basis of their release
estimate. TRI's reporting guidance is that, for most 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. However, for dioxins and dioxin-like compounds, nondetects should
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 its screening-level reviews, EPA used the mid-point of
each reported range to represent a facility's releases, as applicable.
4.1.4.1 Utility of TRI Data
The data collected in TRI are particularly useful for ELG planning 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 to surface
water;
• TRI includes discharge data from manufacturing SIC codes and some
other industrial categories; and
• TRI includes releases of many toxic chemicals, not just those in facility
discharge permits.
4.1.4.2 Limitations of TRI
For purposes of ELG planning, limitations of the data collected in TRI include the
following:
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 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 wastewater 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 most classes have widely varying
toxic effects, the potential toxicity of chemical releases can be
inaccurately estimated.
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Section 4.0 - Methodology, Data Sources, and Limitations
• 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
TRIReleases2002 and TRIReleases2003 were usable for the 2005 and 2006 screening-level
reviews and prioritization of the toxic-weighted pollutant loadings discharged by industrial
categories. The TRI database remains the only data source for national estimates of industrial
wastewater discharges of unregulated pollutants.
4.1.5 Data from PCS
PCS is a computerized information management 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. Among other things, PCS houses discharge data for these facilities.
More than 65,000 industrial facilities and wastewater treatment plants have
permits for wastewater discharges to waters of the United States. To provide an initial
framework for setting permitting 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 pollutant
concentration and quantity values and identification of any types of permit violations.
Minor discharges may, or may not, adversely impact receiving water if not
controlled. 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, conventional parameters (such as BOD5 and total suspended
solids (TSS)), and flow rates. Although other pollutants may be discharged, PCS contains only
4-6
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Section 4.0 - Methodology, Data Sources, and Limitations
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 average pollutant
concentrations.
For the 2005 annual review, EPA used data for reporting year 2002, to correspond
to the data obtained from TRI. For the 2006 annual review, EPA corrected certain aspects of the
2002 data in response to comments (see Section 4.2). EPA also explored the use of PCS
nutrients data but decided not to use nutrients data at this time, because of data quality concerns.
EPA did not use data for reporting year 2003 because, based on comparisons of 2000, 2001, and
2002 PCS data for certain industrial categories, 2003 discharges were not likely to change
significantly from 2002, and also because the creation of the PCSLoads database is labor-
intensive. To develop the PCSLoads2002 database, EPA used its Effluent Data Statistics (EDS)
program, an automated query system, to calculate annual pollutant discharges using the monthly
reports in PCS. The 2005 SLA Report provides details on the methodology and development of
PCSLoads2002 (U.S. EPA, 2005b).
4.1.5.1 Utility of PCS
The data collected in PCS are particularly useful for the ELG planning 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.
• PCS includes data on conventional pollutants for most facilities and for
the nutrients nitrogen and phosphorus for many facilities. However, EPA
did not use the nutrient data because of data quality concerns.
4.1.5.2 Limitations of PCS
Limitations of the data collected in PCS include the following:
• PCS contains data only for pollutants a facility is required by permit to
monitor; the facility is not required to monitor or report all pollutants
actually discharged.
• Some states do not submit all DMR data to PCS, or do not submit the data
in a timely fashion.
• PCS includes very limited discharge monitoring data from minor
dischargers.
4-7
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Section 4.0 - Methodology, Data Sources, and Limitations
• PCS does not include data characterizing indirect discharges from
industrial facilities to POTWs.
• Some of the pollutant parameters included in PCS are reported as a group
parameter and not as individual compounds (e.g., "Total Kjeldahl
Nitrogen," "oil and grease"). Because the individual compounds in the
group parameter may have widely varying toxic effects, the potential
toxicity of chemical releases can be inaccurately estimated.
• In some cases, the PCS database identifies the type of wastewater (e.g.,
process wastewater, stormwater, noncontact cooling water) being
discharged; however, most do not and, therefore, total flow rates reported
to PCS may include stormwater and noncontact cooling water, as well as
process wastewater.
• Pipe identification is not always clear. For some facilities, internal
monitoring points are labeled as outfalls, and PCS may double-count a
facility's discharge. In other cases, an outfall may be labeled as an
internal monitoring point, and PCS may not account for all of a facility's
discharge.
• Facilities provide SIC code information for only the primary operations,
even though data may represent other operations as well. In addition,
some facilities do not provide information on applicable SIC codes.
• 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 reported wastewater discharges.
• PCS was designed as a permit compliance tracking system and does not
contain production information.
• PCS data may be entered into the database manually, which leads to data-
entry errors.
• In PCS, data may be reported as an average quantity, maximum quantity,
average concentration, maximum concentration, and minimum
concentration. For many facilities and/or pollutants, average quantity
values are not provided. In these cases, EPA is limited to estimating
facility loads based on the maximum quantity. Section 4.4.2 discusses the
maximum quantity issue in detail.
Despite these limitations, EPA determined that the data summarized in
PCSLoads2002 were usable for the 2006 screening-level review and prioritization of the toxic-
weighted pollutant loadings discharged by industrial facilities. The PCS database remains the
only data source quantifying the pounds of regulated pollutants discharged directly to surface
waters of the United States.
4-8
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Section 4.0 - Methodology, Data Sources, and Limitations
4.2 Methodology Corrections Affecting Both Screening-Level Review Databases
The 2005 SLA Report provides detailed information on the methodology EPA
used to develop the screening-level review databases (U.S. EPA, 2005b). After publication of
the 2006 Preliminary Plan (see 70 FR 51042-51060, August 29, 2005), EPA received comments
on its methodology, including the development of the TRIReleases2002_v2 and the
PCSLoads2002_v2 databases. This subsection summarizes the comments received and the
actions taken by EPA in response to the comments.
4.2.1 Summary of TRIReleases and PCSLoads Database Methodology Changes
For comments that led to a change in database methodologies, Table 4-1
summarizes pollutants that were identified by commenters, the affected pollutant and database,
the comment or issue, and EPA's responding action. For more detailed information about these
comments, see the memoranda entitled, Response to Comments: Database Methodology Issues
(Bartram, 2006), Comments Received Regarding Toxic-Weighting Factors (Bicknell, 2006b),
and Comments Received Regarding POTW Removals (Bicknell, 2006a).
4.2.2 Summary of TRIReleases and PCSLoads Database Methodology Comments
Resulting in No Changes
EPA received comments in addition to those discussed in Section 4.2.1, but
ultimately found that they did not affect the database results. Typically these comments did not
impact the databases because the subject pollutant was not discharged or was discharged in very
small amounts. For this reason, and for other reasons listed in Table 4-2, EPA did not revise its
database development methodologies in response to these comments. EPA summarized its
analyses of these issues and its findings in a series of memoranda. Table 4-2 lists the comment
issues raised, the reason no action was taken, and the corresponding memoranda.
4-9
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-1. Summary of Database Changes Applicable to Both TRIReleases and PCSLoads Based on Database Methodology
Comments
Pollutant/Issue
Mass
Discharges
without "Less
than" Indicator
Nitrites
Cyanide
Compounds
Nitric Acid
Sodium Nitrite
Dinitrotoluene
(mixed isomers)
Chlorophenols
Chlorine
Database
PCS
PCS
TRI
TRI
TRI
TRI
TRI
TRI
Comment/Issue
PCS includes data for mass discharges
for some facilities without a "less than"
indicator, even when the concentration
included in PCS is labeled as below the
detection limit.
The nitrite ion is unstable in water and
will oxidize to nitrate.
The TWF used for "cyanide
compounds" reported to TRI is too low.
Nitric acid will fully dissociate into
nitrate and hydrogen ions in aqueous
solution.
Sodium nitrite is an ionic salt that will
fully dissociate into nitrite and sodium
ions in aqueous solution. The nitrite
ions are unstable in water and will
oxidize to nitrate.
The POTW removal rate for
dinitrotoluene (mixed isomers) is too
low. The TWF for dinitrotoluene is too
high.
The chlorophenols TWF was based on
the TWF for pentachlorophenol from
August 2004.
The POTW removal rate for chlorine is
unreasonably low (1.87%) based on its
chemistry in water and its addition to
treatment systems as a disinfectant.
Changes to Database
For the facilities named in the comments, EPA corrected the loads in
PCSLoads2002 to treat the mass quantity discharges as below the detection limit.
Assuming nitrite will oxidize to nitrate, EPA calculated the pounds of nitrogen in
the reported nitrite discharges (i.e., nitrite as N) and used the TWF for nitrate as N
(0.0032) to calculate TWPE of nitrites. Previously, EPA used a TWF value of
0.0056.
EPA changed the "cyanide compounds" TWF to the median value of eight cyanide
compounds, 0.0054, because this is consistent with EPA approach for other group
compounds.
EPA changed the POTW removal rate for nitric acid to the POTW removal for
nitrate (90%), and changed the TWF for nitric acid to the TWF for nitrate
(0.000747).
Assuming sodium nitrite will dissociate and the nitrite will oxidize to nitrate, EPA
calculated the pounds of nitrogen in the reported sodium nitrite discharges (i.e.,
sodium nitrite as N) and used the TWF for nitrate as N (0.0032) to calculate TWPE
of sodium nitrite. EPA also used the POTW removal rate for nitrate (90%,
previously 1.87%) to account for the removal of sodium nitrite in POTWs.
EPA has POTW removal rate data for two dinitrotoluene isomers and changed the
POTW removal rate for dinitrotoluene (mixed isomers) to the average of the two
isomer removal rates, 62%. EPA has TWF data for five dinitrotoluene isomers and
changed the dinitrotoluene (mixed isomers) TWF to the median TWF of the five
isomers: 0.043 1. Both of these approaches are consistent with EPA's approach for
other group compounds.
EPA changed the chlorophenols TWF to equal the median value of six
chlorophenols included in the TRI chemical group, 0.0555, because this is
consistent with EPA's approach for other group compounds.
Assuming that chlorine entering POTW will be completely reduced to chloride,
EPA changed the POTW removal rate for chlorine to 100 percent.
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-1 (Continued)
Pollutant/Issue
Hydrogen
Cyanide
Phosphorus
(yellow or
white)
Fumes and Dust
Database
TRI
TRI
TRI
Comment/Issue
The POTW removal rate for hydrogen
cyanide (7%) is low compared to the
POTW removal rate for cyanide
compounds (70%).
Phosphorus (yellow or white) is
insoluble in water.
"Fumes and dusts" are mixtures of
solids and gases and do not exist in
water.
Changes to Database
EPA changed the hydrogen cyanide POTW removal rate to equal the cyanide
compounds POTW removal rate, 70%, because both hydrogen cyanide and cyanide
compounds dissociate in water.
EPA deleted all phosphorus (yellow or white) discharges reported to TRI as
"transferred to POTWs" because facilities incorrectly reported total phosphorus as
elemental phosphorus (yellow or white).
EPA deleted the reported discharges for aluminum (fume or dust) and zinc (fume or
dust) from TRIReleases2002 v4 and TRIReleases2003 v2 because "fumes and
dust" are air pollutants, not water pollutants.
Source: Memoranda Response to Comments: Database Methodology Issues (Bartram, 2006); Comments Received Regarding Toxic-Weighting Factors (Bicknell,
2006b); and Comments Received Regarding POTW Removals (Bicknell, 2006a).
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-2. Summary of Comments on Database Methodologies Applicable to Both
TRIReleases and PCSLoads for Which EPA Did Not Take Action
Issue Raised in Comment
Reason EPA Did Not Take
Action on Comment
Memorandum Describing EPA
Analysis and Findings
Chlorine Dioxide POTW Removal
Phenol Compounds POTW
Removal
Ozone POTW Removal
Pollutant was not discharged or
was discharged in very small
amounts and therefore does not
impact the databases.
Memorandum entitled, Comments
Received Regarding POTW Removals,
dated September 8, 2006 (Bicknell,
2006a).
Hydrazine Sulfate POTW Removal
Titanium Tetrachloride POTW
Removal
Ammonium Sulfate POTW
Removal
Ammonium Nitrate POTW
Removal
Phosphine POTW Removal
Methyl Mercury TWF
PACs TWF
Cyanide TWF
Inorganic Metallic Salts TWFs
Pollutant was not discharged or
was discharged in very small
amounts and therefore does not
impact the databases.
Memorandum entitled, Comments
Received Regarding Toxic- Weighting
Factors, dated September 8, 2006
(Bicknell, 2006b).
Organometallic Compounds TWFs
Chlorine Dioxide TWF
TWFs for Compounds That Do Not
Exist In Water
TWFs For Chemicals Without A
Wastewater Method For Detection
Facilities Reporting the Same
Concentration Each Month
Did not have large impact on the
database.
Use of Maximum Values to
Calculate Annual Loads (also
discussed in Section 4.2.2)
Maximum values are used only
where average values are not
available in PCS.
Response to Comments: Database
Methodology Issues dated November
2006 (Bartram, 2006)
Use of Internal Monitoring Points to
Calculate Annual Loads in PCS
There is no systematic way to
identify internal monitoring
points in the database.
Use of the Hybrid Approach for
Treatment of Measurements Below
the Detection Limit (see the 2005
SLA Report for more details)
EPA believes that this is a valid
approach for the screening-level
review.
Use of Data on Intake Pollutants
Intake pollutants are not typically
reported in PCS.
Batch vs. Continuous Discharges
There is no systematic way to
identify batch discharges in the
database.
4-12
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Section 4.0 - Methodology, Data Sources, and Limitations
4.2.3 Revisions to TWF Development
In addition to comments on database methodology, EPA received comments on
how it develops TWFs. EPA reviewed and incorporated changes, as applicable, to the TWFs for
which it received comments. The Final TWF Development Document, dated June 2006 (U.S.
EPA, 2006a), explains how EPA revised some TWF values from the 2004 Final Plan to the
values used to support the 2006 Final Plan, which are included in the "2006 TWFs" database.
As discussed in the TWF Development Document, EPA has developed TWFs for over 1,000
chemicals. EPA made the following general changes to the TWF database between the 2006
Preliminary Plan and the 2006 Final Plan:
• EPA revised TWFs for 13 chemicals based on data
corrections/improvements;
• EPA developed new TWFs for 12 chemicals that did not previously have
TWFs assigned, such as nicotine; and
• EPA revised TWFs for 12 chemicals based on TWF revisions carrying
through to other chemicals (e.g., the TWF change to nitrate affects the
TWF for chemicals based on nitrate, such as sodium nitrite).
Table 4-3 lists TWFs that changed between the 2006 Preliminary Plan and the
2006 Final Plan, including the new TWFs. Table 4-4 presents the chemicals in PCSLoads2002
with the largest change in TWPE when EPA used the 2006 TWFs compared to the 2004 TWFs6.
The changes in TWF for these chemicals are small; however, because some of the pollutants are
discharged in large quantities, they result in a substantial change in TWPE. For example,
manganese showed the largest and only major increase in TWPE (over 600,000 pound-
equivalents).
Table 4-5 presents the chemicals in TRIReleases2002 with the largest change in
TWPE when EPA used the 2006 TWFs. As with the PCS database, the changes in TWF for
these chemicals are small; however, because some of the pollutants are discharged in large
quantities, they result in a substantial change in TWPE. As with PCS, manganese and
manganese compounds showed the largest change in TWPE, with an increase of over 400,000
pound-equivalents.
6 The 2004 TWFs refer to the December 2004 TWFs that are referenced in the 2005 SLA Report (U.S. EPA, 2005b).
This term does not refer to the August 2004 TWFs, which are also described in the 2005 SLA Report.
4-13
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-3. TWFs Revised in 2006
Pollutant
CAS
Number
2004 TWF
2006 TWF
TWFs Revised by EPA in Response to Comments on the Draft TWF Development Document
Alachlor / Lasso
Ammonia as NH3
Atrazine
Benzo(a)anthracene
Chloroethene
Cyanazine
Dibenzo(a,h)anthracene
Dichloroethene, 1,1-
Fluoranthene
Manganese
Nitrate
Simazine
Tributyltin (TBT)
15972608
7664417
1912249
56553
75014
21725462
53703
75354
206440
7439965
14797558
122349
688733
1.78
0.00151
2.31
36.3
0.0855
0.00572
30.7
0.176
0.829
0.0144
0.0056
0.642
88.9
1.52
0.00111
1.04
30.7
0.23
2.07
30.8
0.471
1.28
0.0704
0.000747
0.308
77.8
New TWFs Developed by EPA
1-nitropyrene
2,6-diethylaniline (alachlor degradation product)
Acetochlor
Bromobenzene
DCPA di-acid degradate
Dibenzo(c,g)carbazole, 7H-
Nicotine
Nitrate (as N)
Nitrogen-total, K, organic (as N)
Perchlorate
Trinitro-triazine, hexahydro-/
Triazines
5522430
579668
34256821
108861
2136790
194592
54115
N
N as N
14797730
121824
Triazines
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.026
0.00537
0.147
0.0166
0.00041
0.0303
0.0016
0.0032
0.00228
0.00206
0.00415
2.46
TWFs Affected by Revisions to Other TWFs
Chlorophenols
Creosote
Cyanide compounds
Dinitrotoluene (mixed isomers)
Manganese compounds
Nitrate compounds
Nitric acid
Nitrites
PACs (Petroleum Refining)
PACs (Pulp and Paper)
PACs (Wood Preserving)
Sodium Nitrite (as N)
N084
8001589
N106
25321146
N450
N511
7697372
14797650
N590
N590
N590
N1000
0.442
1.35
0.00263
0.642
0.0144
0.000062
NA
0.373
26.3
34.2
8.36
0.373
0.0555
1.36
0.0054
0.0431
0.0704
0.000747
0.000747
0.0032
25.4
33.7
8.33
0.0032
Source: Toxic Weighting Factor Development in Support of the CWA 304(m) Planning Process (U.S. EPA, 2006a).
NA - Not applicable; TWFs were not developed for the 2004 analysis.
4-14
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-4. Chemicals with the Largest Change in TWPE in PCSLoads2002 Resulting from 2006 Revised TWFs
Parameter
Manganese
Nitrogen, Nitrite Total (as N)
Nitrogen, Nitrate Total (as N)
Nitrite Plus Nitrate Total 1 Det. (as N)
Nitrogen, Ammonia
Benzo(a)Anthracene
Nitrite Nitrogen, Dissolved (as N)
Nitrogen, Nitrate Total (as NO3)
Ammonia
Fluoranthene
Vinyl Chloride
Nitrogen, Nitrite Total (as NO2)
Dibenzo (a,h) Anthracene
Alachlor (Brand Name-Lasso)
Benzo(ghi)Perylene
Rdx, Total
Lbs/Yr
Reported
Discharged
10,700,000
292,000
18,900,000
7,980,000
24,400,000
320
4,090
56,900
692,000
377
842
254
23
8
0.00714
43
TWF
2004
0.0144
0.373
0.0056
0.0056
0.00151
36.3
0.373
0.0056
0.00151
0.829
0.0855
0.373
30.7
1.78
0.3
2006
0.0704
0.0032
0.0032
0.0032
0.00111
30.7
0.0032
0.000747
0.00111
1.28
0.23
0.0032
30.8
1.52
0.00415
Change in
TWFa
0.056
(0.37)
(0.0024)
(0.0024)
(0.000395)
(5.57)
(0.37)
(0.00485)
(0.000395)
0.456
0.144
(0.37)
0.112
(0.259)
-
-
TWPE
2004
155,000
109,000
106,000
44,700
36,700
11,600
1,530
319
1,040
313
72
95
691
15
0.0021
2006
756,000
933
60,600
25,500
27,100
9,810
13
43
768
485
193
0.81
693
13
0.18
Change in
TWPEa
601,000
(108,000)
(45,500)
(19,200)
(9,640)
(1,780)
(1,520)
(276)
(274)
172
121
(94)
2.5
(2.2)
-
-
Source: PCSLoads2002_v4.
""Decreases in TWF and TWPE are indicated by the values enclosed in parentheses.
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-5. Chemicals with the Largest Changes in TWPE for TRI Databases Resulting from 2006 Revised TWFs
Chemical Name
Manganese and Manganese
Compounds
Sodium Nitrite (as N)
Nitrate Compounds
Dinitrotoluene (Mixed Isomers)
Creosote
Ammonia
Polycyclic Aromatic Compounds
(Petroleum Refining)
Atrazine
Polycyclic Aromatic Compounds
(Pulp and Paper)
Cyanide Compounds
Nitric Acid
Vinyl Chloride
Cyanazine
Simazine
Vinylidene Chloride
Chlorophenols
Alachlor
Polycyclic Aromatic Compounds
(Wood Preserving)
Benzo(g,h,i)Perylene
TWF
2004
0.0144
0.373b
0.000062
0.642
1.35
0.00151
26.3
2.31
34.2
0.00263
0
0.0855
0.00572
0.642
0.176
0.442
1.78
8.36
0.3
2006
0.0704
0.0032
0.00075
0.0431
1.36
0.00111
25.4
1.04
33.7
0.0054
0.000747
0.23
2.07
0.308
0.471
0.0555
1.52
8.33
Change in
TWFa
0.056
(0.37)
0.000685
(0.599)
0.0127
(0.000395)
(0.861)
(1.27)
(0.544)
0.00277
0.000747
0.144
2.06
(0.334)
0.296
(0.386)
(0.259)
(0.026)
TRI 2002
Lbs/Yr
Reported
Discharged
7,180,000
580,000
222,000,000
28,700
11,800
10,700,000
3,290
794
1,420
88,300
282,000
577
28
87
39
20
13
57
2004
TWPE
104,000
217,000b
13,800
18,400
15,800
16,100
86,400
1,830
48,700
232
0
49
0.16
56
6.8
8.8
23
475
2006
TWPE
506,000
1,860
166,000
1,240
1,740
11,900
83,600
826
47,900
477
211
133
58
27
18
1.1
20
473
Change
in
TWPEa
402,000
(215,000)
152,000
(17,200)
(14,100)
(4,230)
(2,830)
(1,010)
(774)
245
211
83
58
(29)
12
(7.7)
(3.4)
(1.5)
TRI 2003
Lbs/Yr
Reported
Discharged
7,210,000
306,000
207,000,000
26,300
8,410
14,200,000
1,290
3,810
1,390
76,100
306,000
384
39
93
10
73
15
40
2004
TWPE
104,000
114,000b
12,800
16,900
11,300
21,300
33,900
8,800
47,500
200
0
33
0.22
60
1.7
32
27
331
2006
TWPE
508,000
980
155,000
1,130
2,220
15,700
32,800
3,960
46,800
411
228
88
81
29
4.6
4.1
23
330
Change
in
TWPEa
404,000
(113,000)
142,000
(15,700)
(9,100)
(5,610)
(1,110)
(4,840)
(756)
211
228
55
81
(31)
2.9
(28)
(3.9)
(1.0)
Source: TRIReleases2002_v4 and TRIReleases2003_v2.
Decreases in TWF and TWPE are indicated by the values enclosed in parentheses.
bFor sodium nitrite, EPA changed the calculation methodology as well as the TWF, in response to comments. The 2004 TWF (0.373) is for sodium nitrite. The 2004 TWPE
(217,000 for TRI 2002 and 114,000 for TRI 2003) represent the new methodology of using the pounds of "sodium nitrite asN" (14.01 molecular weight) instead of sodium nitrite
(NaNO2, or 69.00 molecular weight). See also Section 4.2.1 (Table 4-1).
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Section 4.0 - Methodology, Data Sources, and Limitations
4.2.4 Conclusions
The changes in methodology EPA used to develop PCSLoads2002,
TRIReleases2002, and TRIReleases2003 databases significantly affected the total TWPE
estimated for industrial discharges. The largest change resulted from changes in the TWF and
POTW removal used for sodium nitrite. The estimated TWPE of sodium nitrite discharges
decreased from 1.7 million (TRIReleases2002_v2) to 1,860 (TRIReleases2002_v4). The
manganese and nitrate TWF changes also had significant impacts on the estimates of TWPE
discharges from all the databases because of the large quantities of loadings associated with both
pollutants. Although these changes had significant impacts for certain pollutants and industrial
categories, the methodology changes did not significantly affect the category rankings that EPA
used to prioritize the categories for further review.
4.3 Corrections Affecting Only the TRIReleases Databases
For the 2006 annual review, EPA compiled TRIReleases2002_v4 and
TRIReleases2003_v2, using 2002 and 2003 TRI data, respectively. The 2005 Annual Screening-
Level Analysis Report provides details on the methodology for developing TRIReleases2002;
EPA used the same methodology for the 2003 data (U.S. EPA, 2005b). This section describes
changes made to the TRIReleases database methodology after publication of the 2006
Preliminary Plan.
4.3.1 TWF Changes for Compound Groups
Not all chemicals on the TRI chemical list are individual chemicals. Some are
compound groups, which consist of a group of chemicals that are of similar structure, such as
dioxin and dioxin-like compounds and polycyclic aromatic compounds (PACs) (which are
discussed in this subsection). EPA develops TWFs for specific chemicals and not for these
compound groups. EPA has developed methodologies to assign TWFs to several of the TRI
compound groups, typically using known TWFs for chemicals within the group.
In some cases, EPA calculated industry-specific TWFs for certain chemical
compound categories. EPA created specific TWFs when it had additional information about the
composition of the compound category, as released from specific industries. The remainder of
this subsection describes how EPA developed the TWFs, in the following order:
• Dioxin and dioxin-like compounds;
• Creosote for all industrial categories;
• PACs for all industrial categories, except petroleum refining, wood
preserving, and pulp, paper, and paperboard;
• Petroleum refining PACs;
• Wood preserving PACs; and
• Pulp, paper, and paperboard PACs.
4-17
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Section 4.0 - Methodology, Data Sources, and Limitations
4.3.1.1 Dioxin and Dioxin-Like Compounds
The term 'dioxin and dioxin-like compounds' 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). 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 (U.S. EPA, 2000), though the toxicity of the
congeners varies greatly.
Toxic equivalency factors (TEFs), developed by the World Health Organization,
assess the relative toxicities of the 17 compounds, to simplify risk assessment and regulatory
control of exposures to dioxins. As defined by Van den Berg, et al., a TEF is a relative potency
value that is based on the results of several in vivo and in vitro studies (Van den Berg, 1998).
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.
EPA developed TWFs for each of the 17 dioxin congeners, ranging from 2,021
for octachlorodibenzofuran to 703,584,000 for 2,3,7,8-TCDD, using the methodology discussed
in the TWF TDD (U.S. EPA, 2006a). Due to their toxicity and ability to bioaccumulate, the
various congeners of dioxin have high TWFs relative to most chemicals. Consequently, even
small mass amounts of dioxin and dioxin-like compound discharges translate into high TWPEs.
Table 4-6 presents the TEFs and TWFs used in the 2006 screening-level analysis for each of the
17 dioxin congeners.
Beginning with reporting year 2000, facilities meeting certain reporting criteria
are required to report to TRI the total mass, in grams, of the 17 dioxin and dioxin-like
compounds released to the environment every year. This reporting method does not account for
the relative toxi cities of the 17 compounds. Reporting facilities are given the opportunity to
report a facility-specific congener distribution. Yet even if dioxin and dioxin-like compounds
are released to more than one medium, the facility can report only one distribution. Therefore,
EPA cannot know if the single dioxin congener distribution reported by a facility accurately
reflects the dioxin congener distribution in wastewater. Nevertheless, it is the best available
information, and EPA uses it to calculate the reporting facility's dioxin and dioxin-like
compounds TWPE.
To account for the relative toxi cities of the various dioxin congeners, EPA first
converted the reported discharges of dioxin and dioxin-like compounds discharges from grams to
pounds because the TWPE is associated with pounds and not grams. EPA then estimated the
TWPE of dioxin and dioxin-like compounds using the facility-specific congener distributions for
all facilities that reported a distribution. Based on information provided by facilities, EPA made
corrections to the reported dioxin distributions for several facilities. Section 4.3.2 discusses
these corrections in more detail.
4-18
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-6. Dioxin and Dioxin-Like Compounds and Their Toxic Weighting Factors
CAS
Number
CDDs
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
CDFs
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
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
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-hexachlorodibenzofuran
1,2,3,4,6,7,8-heptachlorodibenzofuran
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
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
Factor
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
Toxic
Weighting
Factor
704,000,000
693,000,000
23,500,000
9,560,000
10,600,000
411,000
6,590
43,800,000
7,630,000
557,000,000
5,760,000
14,100,000
47,300,000
51,200,000
85,800
3,030,000
2,020
Source: EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within the Dioxins and Dioxin-Like
Compounds Category (U.S. EPA, 2000); Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs, for Humans
and Wildlife (Van den Berg, 1998); Toxic Weighting Factor Development in Support of CWA 304(m) Planning
Process (U.S. EPA, 2006a).
EPA calculated an average dioxin distribution for each SIC code that had reported
discharges of dioxin and dioxin-like compounds. For facilities that did not report a dioxin
distribution, EPA used the average SIC code distribution to calculate the facility's dioxin and
dioxin-like compounds TWF. For facilities that did not report a congener distribution and did
not have any facilities within its SIC code that reported a congener distribution, EPA used a
TWF equal to 10,595,840 (the median of the 17 dioxin congener TWFs).
In the 2006 Preliminary Plan, for facilities in the Pulp, Paper, and Paperboard
Point Source Category that did not report a dioxin distribution, EPA calculated an average dioxin
distribution for each regulatory phase, not the SIC code7. However, for the 2006 screening-level
A 1988 legal suit obligated EPA to address discharges of poly chlorinated dibenzo-(p)-dioxins and polychlorinated
dibenzofurans from 104 bleaching pulp mills, including nine dissolving pulp mills. During its response to this suit,
EPA decided to review and revise the Pulp and Paper Category regulations in three "regulatory phases." Phase I is
Subpart B, Bleached Papergrade Kraft and Soda and Subpart E, Papergrade Sulfite. Phase II is categories that do not
bleach chemical pulp with chlorine: Subpart C, Unbleached Kraft; Subpart F, Semi-Chemical; Subpart G,
Groundwood, Chemi-Mechanical, and Chemi-Thermo-Mechanical; Subpart H, Non-Wood Chemical Pulp; Subpart
4-19
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Section 4.0 - Methodology, Data Sources, and Limitations
review, EPA used a different approach. The National Council for Air and Stream Improvement
(NCASI) developed an emission factor for pulp and paper mills to use for estimating dioxin
discharges for reporting to TRI. The emission factor is based on the average mill effluent
concentrations measured from four bleached kraft mills. EPA assumed that all pulp and paper
mills had the same dioxin distribution as the mills used to develop the emission factor. However,
EPA developed facility-specific wastewater dioxin congener distributions when a facility-
specific dioxin congener distribution was available (Matuszko, 2006).
4.3.1.2 Creosote
Creosote is a commonly used wood preservative, comprising many different
chemicals. EPA did not develop a TWF for creosote using creosote toxicity data. Instead, EPA
used the chemical composition of creosote, provided in IARC Monographs, Vol 35, "Coal Tar
and Derived Products," (IARC, 1985), and the TWFs for these individual chemicals to calculate
a TWF for creosote. In developing the TWF for creosote, EPA assumed the chemicals will be
present in wastewater in the same proportion that they are present in the creosote.
Using the data provided in IARC Monographs, Vol 35 (IARC, 1985), EPA
calculated the average percentage that the chemical represents in creosote based on the high and
low values. EPA calculated an adjusted TWF for each chemical by multiplying its chemical-
specific TWF by its average percentage in creosote. EPA summed these values to calculate a
new overall TWF for creosote discharges. The current creosote TWF has been updated since the
2006 Preliminary Plan because several individual chemical TWFs for creosote changed. Table
4-7 lists the chemical composition of creosote, along with the associated TWF of the various
chemicals.
4.3.1.3 Polycyclic Aromatic Compounds (PACs)
PACs, sometimes known as polycyclic aromatic hydrocarbons (PAHs), are a class
of organic compounds consisting of three or more fused aromatic rings. PACs are classified as
persistent, bioaccumulative and toxic (PBT) chemicals. 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. PACs form
as the result of incomplete combustion of organic compounds.
For TRI, facilities that manufacture, process, or otherwise use more than 100
pounds of PACs per year must report the combined mass of PACs released; they do not report
releases of individual compounds. Table 4-8 lists the 21 individual compounds in the PAC
category for TRI reporting, CAS number, and TWF, if available. EPA has TWFs for only 10 of
the 21 PAC chemicals. For the 2006 annual review, EPA revised the TWFs for three PACs
(benzo(a)anthracene, benzo(j,k)fluorene, and dibenzo(a,h)anthracene) and developed new TWFs
for two PACs (7H-dibenzo(e,g)carbazole and 1-Nitropyrene).
I, Secondary Fiber Deink; Subpart J, Secondary Fiber Non-Deink; Subpart K, Fine and Lightweight Papers from
Purchased Pulp; and Subpart L, Tissue, Filter, Non-Woven and Paperboard from Purchased Pulp. Phase III is
Subpart A, Dissolving Kraft, and Subpart D, Dissolving Sulfite.
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-7. Chemical Composition of Creosote and Associated TWFs
Pollutant
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzofluourenes
Biphenyl
Carbazole
Chrysene
Dibenzo(a,h)anthracene
Dibenzofuran
Dimethylnaphthalenes
Fluoranthene
Fluorene
Methylanthracenes
Methylfluorenes
1 -Methy Inaphthalene
2-Methylnaphthalene
Methy Iphenanthrenes
Naphthalene
Phenanthrene
Pyrene
Chemical Percentage
(%)
11.85
4.50
0.21
0.05
1.50
1.20
1.60
2.80
0.03
5.75
2.15
5.25
8.65
3.95
2.65
6.45
6.60
3.00
9.65
18.50
4.75
2006 TWF
0.0326
2.55
30.7
101
0.156
0.0366
0.709
31
30.8
0.492
1.28
0.701
0.0487
0.00622
0.193
0.104
0.0159
0.295
0.0932
Total
Weighted 2006 TWF
0.00386
0.115
0.0645
0.0503
0.00233
0.000439
0.0113
0.868
0.00769
0.0283
0
0.0674
0.0606
0
0.00129
0.000401
0.0127
0.00311
0.00153
0.0545
0.00443
1.36
Source: IARC Monographs, Vol 35, Coal Tar and Derived Products (IARC, 1985); Toxic Weighting Factor
Development in Support of CWA 304(m) Planning Process (U.S. EPA, 2006a).
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-8. Definition of 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)pentaphene
Dibenzo(a,h)acridine
Dibenzo(a j )acridine
Dibenzo(a,h)anthracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(e,g)carbazole
7, 12-Dimethylbenzo(a)anthracene
Indeno( 1,2,3 -cd)pyrene
3 -Methy Icholanthrene
5 -Methy Ichrysene
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
2006 TWF
30.7
31
101
30.7
NA
30.7
1.28
NA
NA
NA
30.8
NA
NA
NA
NA
0.0303
NA
30.7
NA
NA
0.026
Source: EPCRA Section 313: Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds Category
(U.S. EPA, 2001); Toxic Weighting Factor Development in Support of CWA 304(m) Planning Process (U.S. EPA,
2006a).
NA - Not applicable; EPA has not developed a TWF for this chemical.
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Section 4.0 - Methodology, Data Sources, and Limitations
For the analyses supporting the 2004 Final Plan, EPA made a worst-case
assumption that the total mass of PACs reported was benzo(a)pyrene and assigned the TWF of
benzo(a)pyrene to PACs. EPA chose this conservative approach because benzo(a)pyrene is a
pollutant commonly found in wastewater from many industries, including organic chemicals,
plastics, and synthetic fibers, petroleum refining, pulp and paper, nonferrous metals
manufacturing, iron and steel, and other industries. By using the TWF for benzo(a)pyrene, EPA
identified the upper bound of the TWPE for PACs, because the TWF for benzo(a)pyrene
(100.66) is higher than any other PAC. This assumption most likely overestimates the toxicity of
the discharges because PACs are likely a mixture of the compounds listed in Table 4-9, not just
benzo(a)pyrene. In the subsequent development of TRI databases, EPA collected data on the
PACs present, or likely to be present, in wastewater from petroleum refineries, wood preservers,
and pulp and paper mills. As a result, for TRIReleases2002 and TRIReleases2003, EPA
calculated an industry-specific PACs TWF for petroleum refineries, wood preservers, and pulp
and paper mills. For all other industries, EPA continued applying the benzo(a)pyrene TWF. In
future analyses, EPA will develop additional industry-specific PAC TWFs as appropriate.
Petroleum Refining PACs (SIC Codes 2911 and 5171)
Petroleum refining facilities report to TRI the combined mass of PACs released.
In addition, EPA has information on the distribution of PACs in crude oil and petroleum
products. As a result, EPA developed an industry-specific approach to estimate TWPE
associated with PACs from petroleum refineries for the study of the Petroleum Refining Point
Source Category supporting the 2004 Final Plan. This approach is described in detail in Section
3.4.3 of the 2005 SLA Report (U.S. EPA, 2005b) and summarized below.
EPA made the following assumptions in developing the TWF for Petroleum
Refining PACs:
1. PACs will be present in wastewater in the same proportion that they are
present in the crude oil and products throughput at U.S. refineries.
2. If EPA did not have literature data available for a specific PAC
compound, its concentration in the crude oil or product was assumed to be
zero. If a PAC compound was reported as not detected, its concentration
in the crude oil or product was assumed to be zero.
3. Where PAC composition is not available, it can be estimated using the
composition from similar products.
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-9. Calculation of Toxic Weighting Factor for Petroleum PACs
Pollutant
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)pentaphene
Dibenz(a,h)acridine
Dibenz(a j )acridine
Dibenzo(a,h)anthracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(c,g)carbazole
7, 12-Dimethylbenz(a)anthracene
Indeno( 1,2,3 -cd)pyrene
3 -Methy Icholanthrene
5 -Methy Ichrysene
1-Nitropyrene
2006 TWF
30.7
31
101
30.7
NA
30.7
1.28
NA
NA
NA
30.8
NA
NA
NA
NA
0.0303
NA
30.7
NA
NA
0.026
Chemical
Percentage (%)
17.47
46.29
4.17
2.74
0.36
0.7
24.32
0
0
0
0.43
0
0
0
0
0
0
0.01
0
3.5
0
Total
Weighted 2006
TWF
5.36
14.4
4.2
0.84
0.215
0.312
0
0
0
0.132
0
0
0
0
0
0
0.00307
0
0
0
25.4
Source: Petroleum Supply Annual 2000 (EIA, 2001); Data compiled in the American Petroleum Institute's
Transport and Fate of non-BTEXPetroleum Chemicals in Soil and Groundwater (API, 1994); Toxic Weighting
Factor Development in Support ofCWA 304(m) Planning Process (U.S. EPA, 2006a).
NA - Not available.
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Section 4.0 - Methodology, Data Sources, and Limitations
4. For crude oil, representative domestic and foreign oils can be used to
calculate a weighted average PAC composition for crude oil. According
to the EIA (EIA, 2001), 39.1 percent (volumetric basis) of the total
consumed crude oil in the United States in the year 2000 was domestic,
while 60.9 percent (volumetric basis) was imported. EPA selected South
Louisiana Oil as representative of domestic oil and Alberta Oil as
representative of foreign oil, because they had available PAC
compositions. EPA assumed that a weighted average of the composition
of these two crude oils is a reasonable representation of crude oil
composition for the purpose of this study. EPA also used a specific
weight of 0.92 for crude oil to convert PAC concentrations reported as
mg/kg to mg/L.
5. For refined products, EPA assumed a specific weight of 1.0 to simplify the
calculation (i.e., no need to convert between mg/kg and mg/L).
Based on the above assumptions, EPA calculated the proportion of each of the 21
TRI PACs that would be present in refinery wastewater by multiplying each product percentage
by its chemical concentration. EPA then summed all the mass of each PAC, and calculated
percentages for each chemical relative to the total mass of all 21 chemicals, presented in Table
4-9. For example, EPA estimated that 17.47 percent of the total PACs released in refinery
wastewater is attributable to benzo(a)anthracene. The 2006 TWF updates had little impact on
the Petroleum Refining PAC TWF, decreasing it from 26.3 to 25.4.
Wood Preserving PACs (SIC Code 2491)
After EPA identified PAC discharges from facilities in the Timber Products
Processing Point Source Category as a hazard during the 2004 annual review (U.S. EPA, 2004),
industry members stated that PAC discharges resulted from stormwater from creosote wood
preserving facilities. Industry members stated that for TRI reporting prior to 2005, the industry
estimated their PAC releases based on surrogate analytes, such as oil and grease or total organic
carbon, rather than measurement of actual PACs constituents. The industry conducted a
stormwater sampling program to determine the actual concentrations of PACs in stormwater
from creosote wood preserving facilities.
Ten wood preserving facilities participated in a sampling program to determine
the PACs released in their stormwater runoff. Over several months, the facilities collected grab
samples of runoff during rainfall events, for a total of 74 samples from the 10 facilities. In 37 of
these samples, at least one PAC was measured above the detection limit, with six different PACs
being detected overall. Fluoranthene was detected in all 37 of these samples. EPA used the data
from the 37 samples with at least one detected value to calculate a TWF for the PACs discharged
from wood preserving facilities. EPA excluded data from samples where all PACs constituents
were below sample detection limits, because these data do not demonstrate the composition of
PACs, but rather, the relative detection limits for PACs constituents.
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Section 4.0 - Methodology, Data Sources, and Limitations
Using the data provided, EPA calculated the average concentration of the six PAC
compounds measured. Where a pollutant was reported as nondetect, EPA assumed the
concentration to be zero. For each of the six PACs, EPA calculated an average concentration
using each of the measurements from the 37 samples, using zeros as the value for samples that
were not detected. EPA then summed the average concentrations to estimate a total PACs
concentration and calculated the percentage of each compound relative to the total PACs. EPA
calculated a weighted TWF for each compound by multiplying its chemical-specific TWF by its
percentage relative to the total PACs. EPA summed these values to calculate a new overall TWF
value for PACs discharged in the wood preserving SIC code. Table 4-10 presents the TWFs for
all PACs, the percentage of total PACs, and the weighted TWF for each PAC. The 2006 TWF
updates had little impact on this wood preserving PAC TWF, decreasing it from 8.36 to 8.33.
Pulp, Paper, andPaperboardPACs (SIC Codes 2611, 2621, and2631)
NCASI provided guidance to the pulp, paper, and paperboard industry (NCASI,
1998) on how to estimate PAC discharges from pulp and paper mills. The NCASI guidance for
PAC discharges includes a table listing the concentrations of PAC compounds found in
wastewaters for several pulping types (kraft, bisulfite, CTMP, and TMP). Because the vast
majority of mills in the United States are kraft mills, EPA used the kraft mill concentrations to
calculate the pulp and paper PAC TWF8.
NCASI calculated the emission factors for the industry based on six PACs:
benzo(a)anthracene, benzo(a)pyrene, benzo(b+k)fluoranthene, dibenzo(a,h)anthracene,
fluoranthene, and indeno(l,2,3-c,d)pyrene. However, only fluoranthene was detected in kraft
mill effluent. To be consistent with NCASI, and because four of the five other compounds were
detected above the method detection limit for the other pulping types, EPA used one-half the
detection limit for the other five compounds that were not detected in kraft mill wastewaters.
EPA used the concentrations of six PACs to calculate a pulp, paper, and
paperboard PAC TWF. EPA first summed the concentrations to calculate the total concentration
of PACs in the effluent and then calculated the percentage of each chemical relative to the total
PACs in the effluent. After EPA calculated a weighted TWF for each compound by multiplying
its chemical-specific TWF by its percentage relative to the total PACs, EPA summed these
values to calculate an overall TWF value for PACs discharged in the pulp, paper, and paperboard
industry. Table 4-11 presents the TWFs for the six PACs, the percentage of total PACs, and the
weighted TWF for each PAC. The 2006 TWF changes had little impact on this pulp and paper
PAC TWF, decreasing it from 34.2 to 33.7.
The NCASI guidance does not distinguish between effluents from mills with or without bleaching. Therefore, the
calculated TWF applies to all pulp, paper, and paperboard mills.
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-10. Calculation of Toxic Weighting Factor for Wood Preserving PACs
Chemical Name
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)pentaphene
Dibenz(a,h)acridine
Dibenz(aj )acridine
Dibenzo(a,h)anthracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(e,g)carbazole
7, 12-Dimethylbez(a)anthracene
Indeno(a,2,3 -cd)pyrene
3 -Methy Icholanthrene
5-Methylchrysene
1-Nitropyrene
2006 TWF
30.7
31
101
30.7
NA
30.7
1.28
NA
NA
NA
30.8
NA
NA
NA
NA
0.0303
NA
30.7
NA
NA
0.026
Chemical Percentage
(%)
6.73
9.73
0.49
4.98
0
0.78
77.29
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total PACs TWF
Weighted 2006
TWF
2.07
3.02
0.49
1.53
0
0.24
0.99
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8.33
Source: Creosote Wood Treating Industry Storm Water Runoff Study Conducted on Behalf of the Southern Pressure
Treaters Association and Creosote Council III (Rollins, 2005); Toxic Weighting Factor Development in Support of
CWA 304(m) Planning Process (U.S. EPA, 2006a).
NA - Not available.
4-27
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-11. Calculation of Toxic Weighting Factor for Pulp, Paper, and Paperboard PACs
Chemical Name
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b+k)fluoranthene
Benzo(j,k)fluorene(fluoranthene)
Dibenzo(a,h)anthracene
Indeno( 1,2,3 -cd)pyrene
2006 TWF
30.7
101
30.66
1.28
30.8
30.7
Chemical Percentage
(%)
11.74
11.74
11.74
17.84
23.47
23.47
Total PACs TWF
Weighted 2006 TWF
3.60
11.8
3.6
0.23
7.22
7.20
33.7
Source: Handbook of Chemical-Specific Information for SARA Section 313 Form R Reporting (NCASI, 1998);
Toxic Weighting Factor Development in Support ofCWA 304(m) Planning Process (U.S. EPA, 2006a).
4.3.2
Database Corrections
During the review of the TRI data quality, EPA identified inaccuracies in the data
reported to TRI, such as facilities reporting the wrong SIC code or facilities reporting discharges
of chemicals that they did not detect in wastewater. As these inaccuracies were identified, EPA
corrected the data to more accurately reflect the discharges from facilities and their respective
industrial categories. EPA made several corrections to the TRI data during the 2005 annual
review; these corrections are detailed in Table 3-A of the 2005 Annual Screening-Level Analysis
Report (U.S. EPA, 2005b). After the publication of the 2006 Preliminary Plan and during the
2006 annual review, EPA made additional corrections to the TRI data. Appendices E and F list
the changes made to the TRIReleases2002 and TRIReleases2003 databases, respectively, as part
of the 2006 screening-level review.
4.4
Corrections Affecting Only the PCSLoads Databases
For the 2006 annual review, EPA updated the PCSLoads2002_v2 database. The
2005 Annual Screening-Level Analysis Report provides details on the methodology for
developing thePCSLoads2002 database (U.S. EPA, 2005b). This subsection describes the
changes made to the PCSLoads2002 database after publication of the 2006 Preliminary Plan.
4.4.1
Database Corrections
During the review of the PCS data quality, EPA identified inaccuracies in some of
the PCS data, such as facilities reporting the wrong SIC code and errors in the loadings
estimations for pollutant discharges. As these inaccuracies were identified, EPA corrected the
data to more accurately reflect the discharges from facilities and their respective industrial
categories. EPA made several corrections to the PCS data during the 2005 annual review; these
corrections are detailed in Table 2-B of the 2005 Annual Screening-Level Analysis Report (U.S.
EPA, 2005b). After the publication of the 2006 Preliminary Plan, EPA made additional
corrections to the PCS data. Appendix G presents the changes made to the PCSLoads2002
database since the publication of the 2006 Preliminary Plan.
4-28
-------
Section 4.0 - Methodology, Data Sources, and Limitations
4.4.2 Corrections Made to Steam Electric Power Generating Facilities PCS
Discharges
During the Steam Electric Power Generating Point Source Category detailed
study, EPA identified several data quality issues regarding the development of the
PCSLoads2002 database. These include concentration unit issues, data entry errors, internal
monitoring point double-counting issues, and intake pollutant and intermittent discharge
quantification concerns.
During the review of the steam electric PCS data quality, EPA identified the
facilities with the largest discharges in terms of TWPE and contacted the facilities to verify the
discharges. EPA also received comments on the 2006 Preliminary Plan identifying facility-
specific corrections. EPA reports its findings in the memorandum entitled Changes Made to the
PCSLoads2002 Database Based on Facility-Specific Comments, dated October 17, 2006
(Finseth, 2006). As a result of the contacts and comments, EPA made the following types of
changes to the steam electric PCS data:
• Corrected data-entry errors;
• Corrected concentration unit issues;
• Adjusted loads for facilities discharging intermittently;
• Adjusted loads to account for intake pollutants; and
• Adjusted loads to account for internal monitoring points.
4.5 TRI 2002 and 2003 Rankings and PCS 2002 Rankings
After incorporating the changes discussed in Sections 4.2, 4.3, and 4.4, EPA
generated the final versions of the TRI and PCS databases used for the 2006 screening-level
review: TRIReleases2002 v4, PCSLoads2002_v4, and TRIReleases2003_v2. The rankings
represent the results of the three databases and are presented in Section 4.5.1. Section 4.5.2
presents the data quality review issues identified for each database.
4.5.1 Results of the TRIReleases2002, TRIReleases2003, and PCSLoads2002
Databases
Tables 4-12 through 4-14 present the category rankings by TWPE from the
TRIReleases2002_v4, PCSLoads2002_v4, and TPJReleases2003_v2 databases, respectively. The
category rankings presented in these tables reflect all the corrections made during the 2006
screening-level review. Appendices H through J present the four-digit SIC code rankings by
TWPE from the TRIReleases2002_v4, PCSLoads2002_v4, and TRIReleases2003_v2 databases,
respectively. Appendices K through M present the chemical rankings by TWPE from the
TRIReleases2002_v4, PCSLoads2002_v4, and TRIReleases2003_v2 databases, respectively.
4-29
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-12. TRIReleases2002_v4 Category Rankings from the 2006 Screening-Level Review
40CFR
Part
414.1b
430
467
423
455
433
419
414
445/444
415
420
463
440
432
421
429
437
464
454
439
471
424
425
407
Category
Chlorine and Chlorinated Hydrocarbons
Pulp, Paper and Paperboard
Aluminum Forming
Steam Electric Power Generation
Pesticide Chemicals Manufacturing
Metal Finishing
Petroleum Refining
Organic Chemicals, Plastics and Synthetic Fibers
Landfills/Waste Combustors
Inorganic Chemicals
Iron and Steel Manufacturing
Plastic Molding and Forming
Ore Mining and Dressing
Meat and Poultry Products
Nonferrous Metals Manufacturing
Timber Products Processing
Centralized Waste Treaters
Metal Molding and Casting (Foundries)
Gum and Wood Chemicals
Pharmaceutical Manufacturing
Nonferrous Metals Forming and Metal Powders
Ferroalloy Manufacturing
Leather Tanning and Finishing
Fruits and Vegetable Processing
Number of
Direct
Dischargers
33
199
50
340
31
294
250
238
13
69
116
26
31
87
66
80
2
96
7
15
58
5
1
9
Number of
Indirect
Dischargers
9
85
102
15
28
1,795
66
489
26
88
69
104
4
72
30
41
-
83
4
111
107
2
22
17
Number of
Facilities that
Discharge Both
Directly and
Indirectly
2
11
49
21
7
318
36
65
8
38
52
22
-
16
19
25
-
36
1
10
59
1
4
2
Number of
Facilities
Reporting
Releases to Any
Medium
63
509
448
693
124
7,438
928
2,188
113
483
375
1,459
81
307
240
1,012
1
629
26
234
524
15
36
104
Total Pounds
Discharged3
1,290,000
20,300,000
1,170,000
3,060,000
1,760,000
6,450,000
18,400,000
54,000,000
654,000
9,070,000
39,600,000
1,380,000
462,000
61,900,000
2,400,000
65,000
156,000
194,000
25,300
2,440,000
1,260,000
248,000
497,000
7,950,000
TWPE
9,040,000
1,980,000
940,000
833,000
555,000
499,000
467,000
349,000
222,000
186,000
167,000
113,000
70,200
62,400
51,800
48,000
38,100
16,000
13,000
11,100
10,800
9,910
9,880
9,450
J^.
I
o
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-12 (Continued)
40CFR
Part
418
413
NA
NA
469
468
428
406
410
461
434
436
405
426
457
411
417
435
458
446
466
409
460
422
438
Category
Fertilizer Manufacturing
Electroplating
Tobacco Products
Miscellaneous Foods and Beverages
Electrical and Electronic Components
Copper Forming
Rubber Manufacturing
Grain Mills Manufacturing
Textile Mills
Battery Manufacturing
Coal Mining
Mineral Mining and Processing
Dairy Products Processing
Glass Manufacturing
Explosives
Cement Manufacturing
Soaps and Detergents Manufacturing
Oil & Gas Extraction
Carbon Black Manufacturing
Paint Formulating
Porcelain Enameling
Sugar Processing
Hospital
Phosphate Manufacturing
Metal Products and Machinery
Number of
Direct
Dischargers
42
21
2
14
5
38
33
6
16
4
27
42
31
18
10
25
3
-
8
10
2
17
1
14
37
Number of
Indirect
Dischargers
4
414
15
130
91
59
126
12
68
31
-
42
213
47
2
4
83
-
-
57
7
1
-
1
-
Number of
Facilities that
Discharge Both
Directly and
Indirectly
3
35
3
10
10
50
60
6
8
32
-
9
3
15
2
1
5
1
-
7
3
-
-
-
-
Number of
Facilities
Reporting
Releases to Any
Medium
121
643
32
363
188
265
526
123
300
83
82
463
368
260
40
339
209
1
20
499
13
33
3
32
-
Total Pounds
Discharged3
4,980,000
2,130,000
594,000
5,390,000
3,430,000
293,000
771,000
2,550,000
244,000
58,100
155,000
1,860,000
3,580,000
249,000
2,980,000
3,190
125,000
210,000
11
82,900
286,000
497,000
750
82,700
13,600
TWPE
9,060
7,660
7,120
6,860
6,340
6,060
5,100
4,660
3,710
3,150
3,120
2,840
2,830
2,540
2,280
2,030
1,750
700
514
503
398
394
382
300
213
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-12 (Continued)
40CFR
Part
NA
NA
408
NA
443
447
465
427
Category
Printing & Publishing
Independent and Stand Alone Labs
Canned and Preserved Seafood
Drinking Water Treatment
Paving and Roofing Materials (Tars and Asphalt)
Ink Formulating
Coil Coating
Asbestos Manufacturing
Number of
Direct
Dischargers
2
2
6
1
3
1
1
-
Number of
Indirect
Dischargers
56
1
-
1
8
9
51
-
Number of
Facilities that
Discharge Both
Directly and
Indirectly
1
-
-
1
1
-
-
1
Number of
Facilities
Reporting
Releases to Any
Medium
201
6
18
3
256
89
129
1
Total Pounds
Discharged3
16,700
71,100
176,000
274
1,350
21,600
4,050
539
TWPE
209
177
138
128
104
94
39
5.8
J^.
I
to
Source: TRIReleases2002_v4.
aAccounts for estimated POTW removals for indirect discharges.
b414.1 refers to the chlorinated hydrocarbon segment of 414 and the chlor-alkali segment of 415.
NA - Not applicable; no existing ELGs apply to discharges.
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-13. PCSLoads2002_v4 Category Rankings from the 2006 Screening-Level Review
40CFR
Part
454
420
430
418
423
433
414.13
440
414
421
NA
419
410
415
NA
467
445/444
432
436
455
439
422
463
413
409
464
Category
Gum and Wood Chemicals
Iron and Steel Manufacturing
Pulp, Paper and Paperboard
Fertilizer Manufacturing
Steam Electric Power Generation
Metal Finishing
Chlorine and Chlorinated Hydrocarbons
Ore Mining and Dressing
Organic Chemicals, Plastics and Synthetic Fibers
Nonferrous Metals Manufacturing
Miscellaneous Foods and Beverages
Petroleum Refining
Textile Mills
Inorganic Chemicals
Drinking Water Treatment
Aluminum Forming
Landfills/Waste Combustors
Meat and Poultry Products
Mineral Mining and Processing
Pesticide Chemicals Manufacturing
Pharmaceutical Manufacturing
Phosphate Manufacturing
Plastic Molding and Forming
Electroplating
Sugar Processing
Metal Molding and Casting (Foundries)
Major
Dischargers
4
105
349
31
557
130
45
74
238
58
13
122
99
68
19
15
19
47
39
242
34
12
9
30
24
7
Minor
Dischargers
5
66
58
22
345
707
8
37
225
25
110
538
46
127
961
25
242
133
531
23
43
9
116
40
7
52
Total Pounds
3,170,000
2,200,000,000
4,330,000,000
624,000,000
19,500,000,000
105,000,000
1,990,000,000
702,000,000
978,000,000
118,000,000
162,000,000
7,610,000,000
77,500,000
1,240,000,000
59,900,000
13,500,000
76,300,000
76,800,000
999,000,000
122,000,000
114,000,000
87,700,000
28,000,000
5,250,000
110,000,000
732,000
TWPE
3,800,000
1,960,000
1,540,000
1,370,000
982,000
511,000
434,000
410,000
398,000
397,000
337,000
165,000
123,000
107,000
89,000
61,500
58,700
52,200
50,500
50,300
48,600
44,300
20,700
19,100
17,100
9,880
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-13 (Continued)
40CFR
Part
457
424
465
471
469
407
468
437
425
428
411
434
NA
426
NA
429
406
408
438
NA
443
451
417
NA
461
405
466
Category
Explosives
Ferroalloy Manufacturing
Coil Coating
Nonferrous Metals Forming and Metal Powders
Electrical and Electronic Components
Fruits and Vegetable Processing
Copper Forming
Centralized Waste Treaters
Leather Tanning and Finishing
Rubber Manufacturing
Cement Manufacturing
Coal Mining
Printing & Publishing
Glass Manufacturing
Airport Deicing
Timber Products Processing
Grain Mills Manufacturing
Canned And Preserved Seafood
Metal Products and Machinery
Independent and Stand Alone Labs
Paving and Roofing Materials (Tars and Asphalt)
Aquatic Animal Production Industry
Soaps and Detergents Manufacturing
Construction and Development
Battery Manufacturing
Dairy Products Processing
Porcelain Enameling
Major
Dischargers
6
o
J
1
16
6
14
9
6
7
20
7
14
o
J
5
o
3
8
15
7
23
7
4
5
5
1
1
4
2
Minor
Dischargers
9
4
6
28
10
59
17
0
1
97
105
94
15
48
38
141
22
68
86
32
64
109
10
7
5
72
1
Total Pounds
31,700,000
9,570,000
6,340,000
2,560,000
7,770,000
10,900,000
2,110,000
81,200,000
736,000
9,530,000
39,800,000
24,000,000
3,800,000
623,000
1,110,000
11,700,000
19,200,000
286,000,000
1,620,000
1,640,000
287,000
4,330,000
434,000
57,100
16,800
439,000
22,900
TWPE
8,750
7,130
6,390
5,750
5,130
4,350
3,550
3,420
3,260
2,350
2,190
1,910
1,680
1,410
1,160
1,100
964
867
728
610
487
475
270
188
88
43
17
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-13 (Continued)
40CFR
Part
460
NA
435
412
459
NA
Category
Hospital
Tobacco Products
Oil & Gas Extraction
Concentrated Animal Feeding Operations
Photographic
Photo Processing
Major
Dischargers
2
1
2
1
2
2
Minor
Dischargers
110
2
91
72
0
0
Total Pounds
9,760
129,000
1,440,000
229,000
-
-
TWPE
5
2
1
-
-
-
Source: PCSLoads2002_v4.
a414.1 refers to the chlorinated hydrocarbon segment of 414 and the chlor-alkali segment of 415.
NA - Not applicable; no existing ELGs apply to discharges.
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-14. TRIReleases2003_v2 Category Rankings from the 2006 Screening-Level Review
40CFR
Part
414.1b
430
423
414
419
433
455
429
415
420
445/444
463
421
440
437
432
424
464
439
471
418
411
425
454
Category
Chlorine and Chlorinated Hydrocarbons
Pulp, Paper and Paperboard
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic
Fibers
Petroleum Refining
Metal Finishing
Pesticide Chemicals Manufacturing
Timber Products Processing
Inorganic Chemicals
Iron and Steel Manufacturing
Landfills/Waste Combustors
Plastic Molding and Forming
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Centralized Waste Treaters
Meat and Poultry Products
Ferroalloy Manufacturing
Metal Molding and Casting (Foundries)
Pharmaceutical Manufacturing
Nonferrous Metals Forming and Metal
Powders
Fertilizer Manufacturing
Cement Manufacturing
Leather Tanning and Finishing
Gum and Wood Chemicals
Number of
Direct
Dischargers
33
191
353
230
252
249
29
76
75
117
17
33
60
30
2
90
3
89
15
60
42
41
3
7
Number of
Indirect
Dischargers
9
82
17
471
58
1,697
29
34
90
68
27
105
32
2
-
75
2
84
101
98
4
8
22
4
Number of
Facilities that
Discharge Both
Directly and
Indirectly
1
10
19
62
33
325
4
26
36
50
5
20
15
-
-
17
1
36
8
53
3
2
1
1
Number of
Facilities
Reporting
Releases to Any
Medium
62
491
709
2,109
871
7,222
113
987
465
366
112
1,459
221
81
1
297
15
615
220
500
112
441
33
24
Total Pounds
Discharged3
933,000
21,100,000
3,350,000
37,900,000
17,300,000
7,010,000
1,930,000
40,000
8,830,000
35,800,000
589,000
1,490,000
2,760,000
597,000
327,000
68,700,000
438,000
220,000
2,110,000
1,280,000
5,280,000
4,590
368,000
23,700
TWPE
6,970,000
2,880,000
1,060,000
1,020,000
498,000
496,000
485,000
249,000
182,000
155,000
132,000
107,000
78,400
77,600
65,300
55,700
24,500
12,800
12,100
10,600
10,300
10,200
9,250
7,280
J^.
I
ON
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-14 (Continued)
40CFR
Part
407
468
469
NA
413
NA
426
461
428
417
406
405
467
410
436
434
NA
443
446
458
422
435
466
409
NA
438
Category
Fruits and Vegetable Processing
Copper Forming
Electrical and Electronic Components
Tobacco Products
Electroplating
Miscellaneous Foods and Beverages
Glass Manufacturing
Battery Manufacturing
Rubber Manufacturing
Soaps and Detergents Manufacturing
Grain Mills Manufacturing
Dairy Products Processing
Aluminum Forming
Textile Mills
Mineral Mining and Processing
Coal Mining
Drinking Water Treatment
Paving and Roofing Materials (Tars and
Asphalt)
Paint Formulating
Carbon Black Manufacturing
Phosphate Manufacturing
Oil & Gas Extraction
Porcelain Enameling
Sugar Processing
Printing & Publishing
Metal Products and Machinery
Number of
Direct
Dischargers
10
34
5
1
21
15
14
3
30
3
7
33
49
15
45
23
1
7
9
8
12
-
2
16
2
29
Number of
Indirect
Dischargers
15
56
78
15
399
133
46
32
114
82
12
211
92
68
40
-
-
8
52
-
1
-
6
1
53
-
Number of
Facilities that
Discharge Both
Directly and
Indirectly
1
43
10
5
37
10
18
31
59
3
7
4
44
9
7
-
3
2
8
-
-
1
4
-
1
-
Number of
Facilities
Reporting
Releases to Any
Medium
105
249
175
33
631
330
251
85
504
203
123
365
433
305
471
87
5
264
482
19
26
2
15
33
183
-
Total Pounds
Discharged3
7,320,000
172,000
3,780,000
443,000
1,620,000
5,560,000
253,000
38,500
727,000
109,000
1,810,000
4,640,000
958,000
451,000
2,180,000
200,000
9,280
737
88,600
11
65,700
26,400
70,700
339,000
15,400
13,900
TWPE
7,170
6,720
6,630
6,520
5,970
5,440
4,650
4,510
4,400
4,000
3,800
3,620
3,520
3,450
2,890
2,400
823
518
514
483
480
457
363
309
297
231
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-14 (Continued)
40CFR
Part
NA
408
457
465
447
427
Category
Independent and Stand Alone Labs
Canned and Preserved Seafood
Explosives
Coil Coating
Ink Formulating
Asbestos Manufacturing
Number of
Direct
Dischargers
2
8
8
2
1
-
Number of
Indirect
Dischargers
1
-
3
47
8
-
Number of
Facilities that
Discharge Both
Directly and
Indirectly
-
-
2
-
1
1
Number of
Facilities
Reporting
Releases to Any
Medium
4
22
42
126
89
1
Total Pounds
Discharged3
80,100
237,000
27,400
608
5,490
676
TWPE
202
179
47
45
45
5.2
Source: TRIReleases2003_v2.
""Accounts for estimated POTW removals for indirect discharges.
b414.1 refers to the chlorinated hydrocarbon segment of 414 and the chlor-alkali segment of 415.
NA - Not applicable; no existing ELGs apply to discharges.
J^.
I
oo
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Section 4.0 - Methodology, Data Sources, and Limitations
4.5.2 Data Quality Review of the TRIReleases2002, TRIReleases2003, and
PCSLoads2002 Databases
EPA's screening-level review involves the collection and use of existing
environmental data for purposes other than those for which they were originally collected. This
subsection describes some of the data quality issues identified during the 2006 screening-level
review. Section 4.5.2.1 discusses quality issues identified for the TRI databases and Section
4.5.2.2 discusses quality issues identified for the PCS database.
4.5.2.1 TRI Data Quality Review
The primary purpose of the TRI is to collect annual data on storage, releases, and
transfers of certain toxic chemicals from industrial facilities and make the data public to inform
communities and citizens of chemical hazards in their areas. EPA's screening-level review uses
the TRI data to estimate the mass of pollutants discharged by industrial categories and prioritize
the categories for further review. Because this is not the intended purpose of the TRI, EPA
reviewed the quality of the TRI data to verify the accuracy of reported discharges, especially
those contributing the highest TWPE.
EPA reviewed the TRI 2002 data quality during the 2005 annual review, which is
discussed in Section 6.3 of the 2005 Annual Screening-Level Analysis Report (U.S. EPA, 2005b).
During the 2006 annual review, EPA continued to review the TRI 2002 data quality and make
corrections to the database (as described in Section 4.3). The remainder of this subsection
describes the TRI 2003 data quality review and the pulp, paper, and paperboard data issues
identified during the 2006 annual review.
TRI 2003 Quality Review
To review TRI 2003 data, EPA ranked TRI facilities by total TWPE released to
surface waters to identify potential anomalous loads. For this analysis, EPA excluded facilities
that manufacture chlorine and certain chlorinated hydrocarbons, because EPA will evaluate
reported discharges from these facilities as part of the development of the Chlorine and
Chlorinated Hydrocarbons (CCH) rulemaking. After removing these facilities, EPA identified
seven facilities with unusually high chemical releases for their point source category. To verify
the wastewater releases, EPA contacted the seven facilities and asked if the TRI data accurately
reflected what they had reported. EPA also asked whether the reported release was based on
sampling data and whether the pollutant was detected. Table 4-15 presents EPA's TRI facility
review and any corrections made to the TRlReleases2003 database.
4-39
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-15. TRI Facility Review
FacUity Name
ONYX Environmental
Services LLC
Domtar Industries Inc
Ashdown Mill
Cemex Inc Dixon Cement
Plant
Vonroll America
LNVA - North Regional
Treatment Plant
Tower Automotive
Products Co Inc.
Colfax Treating Co. LLC
Facility Location
Port Arthur, TX
Ashdown, AR
Dixon, IL
East Liverpool, OH
Beaumont, TX
Corydon, IN
Pineville, LA
Point Source Category
Landfills/Waste
Combustors
Pulp, Paper, and
Paperboard
Cement Manufacturing
Landfills/Waste
Combustors
Centralized Waste
Treaters
Metal Finishing
Timber Products
Processing
Chemical(s) in Question
Toxaphene, Chlordane,
Heptachlor, Benzidine, and
Hexachlorobenzene
Dioxin and Dioxin-like
Compounds
Dioxin and Dioxin-like
Compounds
Benzidine
Polycyclic Aromatic
Compounds
Sodium Nitrite
Dioxin and Dioxin-like
Compounds, Polycyclic
Aromatic Compounds, and
Creosote
Facility's Response
The facility analyzed its wastewater, but none
of the chemicals were ever detected. The
discharges were based on Vt the detection limit.
The facility analyzed its bleach plant
monitoring location for dioxins in 2003. The
measured concentrations were used to calculate
the reported discharge.
The facility accidentally reported its dioxin and
dioxin-like compounds air releases as water
discharges.
EPA contacted this facility about their 2002
discharges, which are the same as the 2003
discharges. The facility reports its benzidine
release as range code 'B' (11-499). -r^e actual
value the facility calculated was 16.68 Ibs.
However, benzidine was never detected and the
value is based on the detection limit.
The facility has analyzed the effluent from the
treatment plant for each of the PACs and none
have ever been detected. The discharge is
based on Vz the detection limit.
The facility uses an additive that contains 40 to
50% sodium nitrite in its wastewater treatment
process. The discharge is based on the amount
of additive used during the year.
The facility estimates the dioxin and dioxin-like
compounds discharge based on the
pentachlorophenol concentrate that is
discharged, which contains 981 ppm of dioxin
and dioxin-like compounds.
The creosote discharge is estimated as 1% of
the total oil and grease discharge from the
facility.
The PACs discharge is estimated as 2.28% of
the creosote discharge or 0.0228% of the total
oil and grease discharge from the facility.
Load Recommendations
Change the toxaphene, chlordane,
heptachlor, benzidine, and
hexachlorobenzene releases to 0.0.
Do not change the dioxin and
dioxin-like compounds discharge;
however, change the facility
reported dioxin congener
distribution.
Change the dioxin and dioxin-like
compounds discharge to 0.0.
Change the benzidine discharge to
0.0.
Change the polycyclic aromatic
compounds discharge to 0.0.
Do not change the sodium nitrite
discharges from the facility.
Do not change the discharge loads
of dioxin and dioxin-like
compounds, creosote, and PACs.
J^.
I
o
Source: Telephone conversation with Mona Rountree of ONYX Environmental Services LLC., Port Arthur, TX and TJ Finseth of Eastern Research Group, Inc. (Rountree, 2005); Telephone
conservation with William Bertrand of Domtar, Ashdown, AR, and Bryan Lange of Eastern Research Group, Inc. (Bertrand, 2005); Telephone conservation with Lillian Deprimo of Cemex Inc., Dixon,
IL, and Jessica Wolford of Eastern Research Group, Inc. (Deprimo, 2005); Telephone conservation with Becky Dalrymple of Vonroll VTI, East Liverpool, OH, and TJ Finseth of Eastern Research
Group, Inc. (Dalrymple, 2005); Telephone conservation with Jesse Eastep of LNVA North Regional Treatment Plant, Beaumont, TX, and Jessica Wolford of Eastern Research Group, Inc. (Eastep,
2005); Telephone conversation with Roland Berg of Tower Automotive Products Co Inc., Corydon, IN, and Jessica Wolford of Eastern Research Group, Inc. (Berg, 2005); Telephone conversation with
Karen Brignac of PPM Consulting and TJ Finseth of Eastern Research Group, Inc. (Brignac, 2005).
-------
Section 4.0 - Methodology, Data Sources, and Limitations
Pulp, Paper, and Paperboard Data Issues
During the Pulp, Paper, and Paperboard Point Source Category detailed study,
EPA determined that the dioxin and dioxin-like compounds discharges reported to TRI did not
reflect the actual quantity discharged. EPA determined that the majority of the estimated
releases of dioxin and dioxin-like compounds reported to TRI were based on pollutant
concentrations below the Method 1613B minimum levels (MLs), including the congener-specific
measurement data that NCASI used to develop an emission factor for wastewater discharges.
For more information about this issue, see chapter 5 of the Final Report: Pulp, Paper, and
Paperboard Detailed Study (U.S. EPA, 2006b).
4.5.2.2 PCS Data Quality Review
PCS was designed to automate entry, updating, and retrieval of NPDES data and
track permit issuance, permit limits and monitoring data, and other data pertaining to facilities
regulated under NPDES. EPA's screening-level review uses PCS data to estimate the mass of
pollutants discharged by industrial categories and prioritize the categories for further review.
Because this is not the intended purpose of PCS data, EPA reviewed the quality of the PCS data
to verify the accuracy of reported discharges, especially for those contributing the highest
TWPE.
EPA reviewed the PCS 2002 data quality during the 2005 annual review, which is
discussed in Section 6.2 of the 2005 Annual Screening-Level Analysis Report (U.S. EPA, 2005b).
During the 2006 annual review, EPA continued to review the PCS 2002 data quality and make
corrections to the database (as described in Section 4.4). The remainder of this section describes
the use of maximum values for load calculation and nutrient analysis data issues identified
during the 2006 annual review.
Use of Maximum Values to Estimate PCS Loads
To create PCSLoads2002, EPA used the EDS system to calculate the annual
pollutant loads using the PCS data. For a detailed discussion of how EPA calculates annual
loads from the PCS data, see Section 2 of the 2005 Annual Screening-Level Analysis Report
(U.S. EPA, 2005b). EDS calculates pollutant loads using the following five measurement fields
that facilities can report in their discharge monitoring data:
1) Average Quantity;
2) Maximum Quantity;
3) Average Concentration;
4) Maximum Concentration; and
5) Minimum Concentration.
EPA received comments regarding the use of maximum values in calculating
annual loads. Commenters stated that maximum values overestimate discharges and should be
adjusted accordingly. In generating PCSLoads2002., the EDS system used only maximum values
when these represent the maximum of a set of average concentration data (i.e., it is the maximum
value of the weekly average concentrations) or the average quantity or average concentration
data are not reported by the facility (i.e., the maximum values are the best data available).
4-41
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Section 4.0 - Methodology, Data Sources, and Limitations
EPA analyzed a subset of the PCS data to determine how often maximum values
are used in the annual load estimations. EPA determined that maximum concentration values
were used to calculate loads for 42 percent of the TWPE, for the subset of data analyzed. Table
4-16 shows the total pounds discharged, the total TWPE discharged, and the percent of the total
TWPE based on the different measurement fields for the subset of data analyzed. For more
details on this analysis, see the memorandum entitled, Response to Comments: Database
Methodology Issues, dated November 2006 (Bartram, 2006).
Table 4-16. Loadings and TWPE from Different Measurement Values for a Subset of PCS
Data
Measurement Field
Maximum Value (concentration or quantity)
Other Value
Total
Pounds
110,000,000
73,500,000
183,000,000
TWPE
137,000
189,000
326,000
Percent of
Total TWPE
42%
58%
Source: Response to Comments: Database Methodology Issues (Bartram, 2006).
The use of the maximum values may overestimate discharged pollutant loads, and
EPA acknowledges that a significant portion of its pollutant loads may be calculated using
maximum values for flows and/or concentrations. However, EPA is using the best available data
from PCS. EPA calculates annual loads primarily using average values. EPA only uses
maximum values when average values are unavailable.
Nutrients Analysis Data Issues
EPA began an investigation of the nutrients (nitrogen and phosphorus) discharged
by each point source category, estimating the total pounds of nitrogen (nitrate, nitrite, ammonia,
total nitrogen) and phosphorus (phosphates). EPA requested additional information from
industry to confirm the reported discharges of nutrients and discovered several complications in
calculating the nutrient loads. These included difficulties in determining which outfall(s) to
exclude to avoid double-counting effluent flows, assessing intake water pollutant loadings, and
identifying which outfalls represented wastewaters from process operations. For example, some
facilities monitor and report nutrient discharges from landfills and nonprocess-area stormwater
run-off. Because of the data quality issues associated the nutrients data in the PCSLoads2002_v4
database, EPA decided not to continue the analysis for the 2006 annual review. EPA intends to
pursue means for improving the data review for nutrients discharges in future review cycles.
Table 4-17 summarizes the data quality issues identified during the nutrients analysis and EPA's
findings. For more details on this analysis see the memorandum entitled Review of Nitrogen and
Phosphorus Loads Calculated Using 2002 PCS Data, dated November 2006 (Bicknell, 2006c).
4-42
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Section 4.0 - Methodology, Data Sources, and Limitations
Table 4-17. Nutrient Analysis Data Quality Issues
Data Quality Issue
Internal Monitoring
Points
Intake Water
Identification of
Discharge Pipe
Findings from Analysis
EPA conducted a permit review of the top nutrient dischargers and determined that
many of the nutrient loadings are overestimated due to double-counting of loads from
internal monitoring points. EPA zeroed the double-counted loads, when identified.
EPA determined that for many of the large nutrient discharges, the majority of the
load was due to the intake water and not from the industrial process.
EPA determined that many of the nutrient discharges were from nonprocess
wastewater such as landfill leachate, stormwater runoff, or other nonprocess areas.
Source: Review of Nitrogen and Phosphorus Loads Calculated Using 2002 PCS Data (Bicknell, 2006c).
4.6 References
API. 1994. American Petroleum Institute. Transport and Fate of Non-BTEXPetroleum
Chemicals in Soil and Groundwater (API Publication Number 4593, Appendix A, September).
DCN 00407.
Bartram, Deb. 2006. Eastern Research Group, Inc. Memorandum to Carey Johnston and Jan
Matuszko, U.S. EPA. "Response to Comments: Database Methodology Issues." (November).
DCN 04074.
Berg, Roland. 2005. Telephone conversation with Roland Berg of Tower Automotive Products
Co Inc., Cory don, IN, and Jessica Wolford of Eastern Research Group, Inc. "Tower Automotive
Products Co Inc Corydon Facility Sodium Nitrite Releases in TRI." (December 6). DCN 02447.
Bertrand, William. 2005. Telephone conversation with William Bertrand of Domtar, Ashdown,
AR, and Bryan Lange of Eastern Research Group, Inc. "Reported Dioxin Discharge Increased
Significantly from 2002 to 2003." (November 9). DCN 02786.
Bicknell, Betsy and TJ Finseth. 2006a. Eastern Research Group, Inc. Memorandum to Carey
Johnston and Jan Matuszko, U.S. EPA. "Comments Received Regarding POTW Removals."
(September 8). DCN 03676.
Bicknell, Betsy and TJ Finseth. 2006b. Eastern Research Group, Inc. Memorandum to Carey
Johnston and Jan Matuszko, U.S. EPA. "Comments Received Regarding Toxic-Weighting
Factors." (Septembers). DCN 03675.
Bicknell, Betsy. 2006c. Eastern Research Group, Inc. Memorandum to Public Record for the
Effluent Guidelines Program Plan 2005/2006, EPA Docket Number OW-2004-0032. "Review
of Nitrogen and Phosphorus Loads Calculated Using 2002 PCS Data." (November). DCN
04075.
Brignac, Karen. 2005. Telephone conversation with Karen Brignac of PPM Consulting and TJ
Finseth of Eastern Research Group, Inc. "Colfax Dioxin, Creosote, and PACs Discharges to TRI
2003." (December 6). DCN 03742.
4-43
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Section 4.0 - Methodology, Data Sources, and Limitations
Dalrymple, Becky. 2005. Telephone conversation with Becky Dalrymple of Vonroll VTI, East
Liverpool, OH, and TJ Finseth of Eastern Research Group, Inc. "Vonroll East Liverpool
Benzidine Discharges in TRI 2002." (February 15). DCN 01548.
Deprimo, Lillian. 2005. Telephone conversation with Lillian Deprimo of Cemex Inc., Dixon,
IL, and Jessica Wolford of Eastern Research Group, Inc. "Cemex Inc. Dixon Cement Plant
Dioxin Releases in TRI 2003." (December 20). DCN 02546.
Eastep, Jesse. 2005. Telephone conversation with Jesse Eastep of LNVA North Regional
Treatment Plant, Beaumont, TX, and Jessica Wolford of Eastern Research Group, Inc. "LNVA
North Regional Treatment Plant PACs Releases in TRI 2003." (November 28). DCN 02442.
EIA. 2001. Energy Information Administration, Office of Oil and Gas. Petroleum Supply
Annual 2000, Vol. 7, Page 6. (June). DCN 02270.
Finseth, TJ. 2006. Eastern Research Group, Inc. Memorandum to the 2006 Effluent Guidelines
Program Plan Docket, EPA Docket Number OW-2004-0032. "Changes Made to the
PCSLoads2002 Database Based on Facility-Specific Comments." (October 17). DCN 03190.
IARC. 1985. World Health Organization, International Agency on Research for Cancer.
Monographs, Vol 35, pg. 83. "Coal Tar and Derived Products." DCN 03903.
Matuszko, Jan, Betsy Bicknell, and Bryan Lange. 2006. U.S. EPA and Eastern Research Group,
Inc. Memorandum to Public Record for the Effluent Guidelines Program Plan 2005/2006, EPA
Docket Number OW-2004-0032. "Calculation of Category-Specific Toxic Weighting Factor for
'Dioxin and Dioxin-Like Compounds' Reported Released to EPA's Toxic Release Inventory
(TRI) by Pulp, Paper, and Paperboard Mills." (September 12). DCN 03683.
NCASI. 1998. National Council for Air and Stream Improvement, Inc. Handbook of Chemical-
Specific Information for SARA Section 313 Form R Reporting. DCN 01753.
OMB. 1987. Office of Management and Budget. Standard Industrial Classification Manual.
1987.
Rollins, Martin. 2005. H. M. Rollins Company, Inc. Memorandum to Johnston, Carey, U.S.
EPA. "Creosote Wood Treating Industry Storm Water Runoff Study Conducted on Behalf of the
Southern Pressure Treaters Association and Creosote Council III." (May 26). DCN 02077.
Rountree, Mona. 2005. Telephone conversation with Mona Rountree of ONYX Environmental
Services LLC., Port Arthur, TX, and TJ Finseth of Eastern Research Group, Inc. "ONYX
Chlordane, Heptachlor, Toxaphene, Benzidine, and Hexachlorobenzene Discharges in TRI
2003." (Decembers). DCN 03741.
U.S. EPA. 2000. EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within the
Dioxins and Dioxin-Like Compounds Category. EPA-745-B-00-021. Washington, DC.
(December). DCN 01164.
4-44
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Section 4.0 - Methodology, Data Sources, and Limitations
U.S. EPA. 2001. EPCRA Section 313: Guidance for Reporting Toxic Chemicals: Polycyclic
Aromatic Compounds Category. EPA-260-B-01-03. Washington, DC. (August). DCN 01996.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2005a. Draft Toxic Weighting Factor Development in Support ofCWA 304(m)
Planning Process. Washington, DC. June. DCN 02013.
U.S. EPA. 2005b. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2006a. Toxic Weighting Factor Development in Support ofCWA 304(m) Planning
Process. Washington, DC. (June). DCN 03196.
U.S. EPA. 2006b. Final Report: Pulp, Paper, andPaperboardDetailed Study. EPA-821-R-06-
016. Washington, DC. (November). DCN 03400.
Van den Berg, et al. 1998. "Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs, for
Humans and Wildlife." Environ. Health Perspect. 106:775-792. DCN 01259.
4-45
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Part II - Results of the 2006 Annual Review
PART II: RESULTS OF THE
2006 ANNUAL REVIEW OF INDUSTRIAL
CATEGORIES WITH EXISTING ELGS
ii
-------
Section 5.0 - 2006 Annual Review
5.0 2006 ANNUAL REVIEW OF EXISTING EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS AND RANKING OF POINT SOURCE CATEGORIES
For the 2006 annual review, EPA conducted the following activities:
• Updated the reviews from previous years (i.e., revising the 2005 annual
review results with new or corrected data);
• Performed new research: contacting industry to verify discharges,
conducting literature searches, and collecting additional data; and
• Solicited information from stakeholders through comment response and
other stakeholder outreach (e.g., meetings with industry trade groups).
This section summarizes the results from the 2005 annual review (Section 5.1),
presents the results of the 2006 screening-level review (Section 5.2), and presents the
prioritization of categories for the 2006 annual review (Section 5.3).
5.1 Summary of the Results from the 2005 Annual Review
EPA published its 2005 annual review of existing ELGs on August 29, 2005 (70
FR 51042). In the 2005 annual review, EPA identified 13 point source categories that represent
the bulk of the estimated toxic discharges (as measured by TWPE) from existing industrial point
source categories. EPA ranked each point source category by the amount of toxic pollutants in its
discharge (as measured by TWPE) and identified the Steam Electric Power Generating and Pulp,
Paper, and Paperboard Point Source Categories as the two categories with the highest TWPE.
EPA identified 11 additional categories with potentially high TWPE discharge estimates. EPA
collected and analyzed information on the pollutants discharged and wastewater treatment at
these 11 categories but assigned a higher priority to investigating the Pulp, Paper, and
Paperboard and Steam Electric Power Generating Point Source Categories.
In view of the annual nature of its reviews of existing ELGs, EPA believes that
each annual review can and should influence succeeding annual reviews (e.g., by indicating data
gaps, identifying new pollutants or pollution reduction technologies, or otherwise highlighting
industrial categories for more detailed scrutiny in subsequent years). EPA used the findings, data
and comments on the 2005 annual review to inform its 2006 annual review. The 2005 review
built on the previous reviews by continuing to use the screening methodology, incorporating
some refinements to assigning discharges to categories, and updating toxic weighting factors
used to estimate potential hazards of toxic pollutant discharges. Likewise, EPA made similar
refinements to assigning discharges to categories and updating toxic weighting factors used to
estimate potential hazards of toxic pollutant discharges for the 2006 annual review.
5.2 Results of the 2006 Screening-Level Review
For the 2006 screening-level review, EPA combined the results of the
TRIReleases2002_v4 and thePCSLoads2002 v4 databases, which are presented in Section 4.5 of
this document. When combining the results of the databases, EPA made adjustments to the
rankings for the following: discharges from industrial categories for which EPA is currently
5-1
-------
Section 5.0 - 2006 Annual Review
developing or revising ELGs, discharges from point source categories for which EPA has
recently promulgated or revised ELGs, and discharges from facilities determined not to be
representative of their category. Sections 5.2.1 through 5.2.3 discuss the rationale for these
decisions. In addition, EPA created a final ranking using the TRIReleases2003_v2 database,
accounting for the same adjustments. The final combined database rankings represent the results
of the 2006 screening-level review and are presented in Section 5.2.4.
5.2.1 Facilities for Which EPA is Currently Developing or Revising ELGs
EPA is currently considering revisions to ELGs for Organic Chemicals, Plastics,
and Synthetic Fibers (OCPSF) (40 CFR 414) and the Inorganic Chemicals Manufacturing (40
CFR 415) Point Source Categories for facilities that produce chlorine or chlorinated
hydrocarbons (CCH)9. Because the CCH rulemaking is underway, EPA excluded discharges
from these facilities from further consideration under the current planning cycle. EPA subtracted
the TWPE loads from facilities that produce chlorine or chlorinated hydrocarbons from the
OCPSF and Inorganic Chemicals Manufacturing Point Source Category loads. Because facilities
that produce chlorine and chlorinated hydrocarbons are only a subset of the OCPSF and
Inorganic Chemicals Manufacturing Categories, EPA included loads for all other facilities in
these two categories in ints prioritization of categories for further review.
5.2.2 Categories for Which EPA Recently Promulgated or Revised ELGs
For the 2006 annual review and development of category rankings, EPA did not
prioritize point source categories for which ELGs were recently established or revised but not yet
fully implemented, or were recently reviewed. In general, EPA removes a category from further
consideration during a review cycle if EPA established, revised, or reviewed the category's
ELGs within seven years prior to the current annual review. This seven-year period allows time
for the ELGs to be incorporated into NPDES permits. For the 2006 annual review, this equates
to any category with ELGs established or revised after 1999. Table 5-1 lists these categories.
Removing a point source category from further consideration in the development
of the rankings does not mean that EPA eliminates the category from annual review. In cases
where EPA is aware of the growth of a new segment within such category, or where new
concerns are identified for previously unevaluated pollutants discharged by facilities in the
category, EPA would apply closer scrutiny to the discharges from the category in deciding
whether to consider it further during the current review cycle. For example, EPA plans to
conduct a detailed study of the coal mining industry based on comments received on the 2006
Preliminary Plan, although the coal mining ELGs were revised in January 2002.
9 EPA is also currently revising the CAFOs ELG; however, the TWPE associated with this category is low and does
not affect the prioritization of categories based on TWPE.
5-2
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Section 5.0 - 2006 Annual Review
Table 5-1. Point Source Categories That Have Undergone a Recent Rulemaking or Review
40CFRPart
Number
451
432
413, 433, and 438
122, 123, and 412
420
434
435
136 and 437
442
444
136 and 445
Point Source Category
Concentrated Aquatic Animal Production (or Aquaculture)
Meat and Poultry Products
Metal Products and Machinery
(including Metal Finishing and Electroplating)
Concentrated Animal Feeding Operations (CAFOs)
Iron and Steel Manufacturing
Coal Mining (Coal Remining and Western Alkaline Coal Mining)
Oil & Gas Extraction (Synthetic-Based and Other Non- Aqueous
Drilling Fluids)
Centralized Waste Treatment
Transportation Equipment Cleaning
Commercial Hazardous Waste Combustors
Landfills
Date of Rulemaking
August 23, 2004
September 8, 2004
May 13, 2003
February 12, 2003
October 17, 2002
January 23, 2002
February 2 1,2001
December 22, 2000
August 14, 2000
January 27, 2000
January 19, 2000
Source: "Guidelines:
EPA, 2006a).
Final, Proposed, and Under Development" at http://www.epa.gov/waterscience/guide. (U.S.
5.2.3
Categories with One Facility Dominating the TWPE
EPA identified point source categories where only one facility was responsible for
most of the TWPE reported to be discharged (i.e., where one facility's TWPE accounted for
more than 95 percent of the category TWPE). Table 5-2 lists these categories. EPA identified
four facilities that dominated the TWPE in the category to which they belonged. EPA
investigated these facilities to determine if their discharges were representative of the category.
If they were not, EPA subtracted the facility's TWPE from the total category TWPE and
recalculated the category's ranking. EPA performed this analysis separately for each of the three
databases. EPA's investigation of these facilities is detailed in a memorandum, entitled PCS and
TRI Facilities that Dominate the Total Point Source Category TWPE (Kandle, 2006).
5-3
-------
Section 5.0 - 2006 Annual Review
Table 5-2. Point Source Categories with One Facility Dominating the TWPE Discharges
Point Source Category
Gum and Wood Chemicals
Manufacturing
Plastic Molding and Forming
Miscellaneous Foods and
Beverages
Gum and Wood Chemicals
Manufacturing
Aluminum Forming
Gum and Wood Chemicals
Manufacturing
Facility with Over
95% of Category
TWPE
Hercules-Brunswick
Innovia Films
Bacardi Corporation
Hercule s-B runsw ick
Kaiser Aluminum &
Chemical Corporation
Hercule s-B runsw ick
City, State
Brunswick,
GA
Tecumseh,
KS
Catano, PR
Brunswick,
GA
Spokane,
WA
Brunswick,
GA
Data
Source
PCS 2002
PCS 2002
PCS 2002
TRI 2002
TRI 2002
TRI 2003
Pollutant Driving
TWPE
Toxaphene
(3,771,372 TWPE)
Carbon Bisulfide
(19,785 TWPE)
Sulfide
(3 13,970 TWPE)
Carbon Bisulfide
(12,804 TWPE)
Polychlorinated
Biphenyls
(935,924 TWPE)
Carbon Bisulfide
(7, 117 TWPE)
Facility
TWPE
3,800,000
20,300
327,000
12,800
936,000
7,120
% of Total
Category
TWPE
99.9%
98.0%
97.2%
98.8%
99.5%
97.7%
Action
Removed load from
category TWPE
Bid not remove load
from category TWPE
Removed load from
category TWPE
Removed load from
category TWPE
Removed load from
category TWPE
Removed load from
category TWPE
Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2003_v2.
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Section 5.0 - 2006 Annual Review
5.2.4 Results of the 2006 Screening-Level Review
After adjusting the category TWPE totals and rankings as described in Sections
5.2.1 through 5.2.3, EPA consolidated the PCS and TRI rankings into one set using the following
steps:
• EPA combined the two lists of point source categories by adding each
category's PCS TWPE and TRI TWPE. EPA noted that this may result in
"double-counting" of chemicals a facility reported to both PCS and TRI,
and "single-counting" of chemicals reported in only one of the databases.
The combined databases do not count chemicals that may be discharged
but are not reported to PCS or TRI.
• EPA then ranked the point source categories based on total PCS and TRI
TWPE.
Table 5-3 presents the combined PCS 2002 and TRI 2002 rankings. These are the
final category rankings accounting for all corrections made to the databases during the 2005 and
2006 annual reviews and removal of any categories and discharges as discussed in Sections 5.2.1
through 5.2.3.
Table 5-4 presents the final rankings for TRI 2003 excluding the categories for
which EPA is currently developing or revising ELGs, categories for which EPA recently
promulgated or revised ELGs, and discharges from facilities that dominate the category TWPE,
but are not representative of the category. Four of the top five categories by TWPE from the
combined TRI and PCS 2002 data (Table 5-3) are in the top five categories from the TRI 2003
data (Table 5-4), with only the Fertilizer Category not represented at the top of TRI 2003
rankings.
5.3 Prioritization of Categories for the 2006 Annual Review
Based on its screening level review, EPA was able to prioritize for further review
(i.e., a detailed study or preliminary category review) those industrial categories whose pollutant
discharges potentially pose the greatest hazards to human health or the environment because of
their toxicity (i.e., categories that collectively discharge over 95 percent of the total TWPE).
EPA also considered efficiency and implementation issues raised by stakeholders in identifying
candidates for further review. By using this multilayered 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 ELGs revision at this time.
Table 5-5 lists the point source categories with existing ELGs, the level of review
EPA performed as part of the 2006 annual review, and how the category was identified for
further review, if applicable.
5-5
-------
Section 5.0 - 2006 Annual Review
Table 5-3. Final PCS 2002 and TRI 2002 Combined Point Source Category Rankings
40CFRPart
430
423
418
414
419
455
440
421
415
463
410
467
439
436
429
422
464
409
424
471
NA
407
425
469
457
468
428
Point Source Category
Pulp, Paper and Paperboard
Steam Electric Power Generation
Fertilizer Manufacturing
Organic Chemicals, Plastics and Synthetic Fibers
Petroleum Refining
Pesticide Chemicals Manufacturing
Ore Mining and Dressing
Nonferrous Metals Manufacturing
Inorganic Chemicals
Plastic Molding and Forming
Textile Mills
Aluminum Forming
Pharmaceutical Manufacturing
Mineral Mining and Processing
Timber Products Processing
Phosphate Manufacturing
Metal Molding and Casting (Foundries)
Sugar Processing
Ferroalloy Manufacturing
Nonferrous Metals Forming and Metal Powders
Miscellaneous Foods and Beverages
Fruits and Vegetable Processing
Leather Tanning and Finishing
Electrical and Electronic Components
Explosives
Copper Forming
Rubber Manufacturing
PCS 2002 TWPE
1,540,000
982,000
1,370,000
398,000
165,000
50,300
410,000
397,000
107,000
20,700
123,000
61,500
48,600
50,500
1,100
44,300
9,880
17,100
7,130
5,750
9,567
4,350
3,260
5,130
8,750
3,550
2,350
TRI 2002
TWPE
1,980,000
833,000
9,060
349,000
467,000
555,000
70,200
51,800
186,000
113,000
3,710
4,360
11,100
2,840
48,000
300
16,000
394
9,910
10,800
6,860
9,450
9,880
6,340
2,280
6,060
5,100
Total TWPE
3,520,000
1,810,000
1,380,000
747,000
632,000
605,000
480,000
449,000
293,000
134,000
127,000
65,900
59,700
53,300
49,100
44,600
25,900
17,500
17,000
16,500
16,400
13,800
13,100
11,500
11,000
9,610
7,450
Cumulative
Percentage of Total
TWPE
33.00%
50.04%
62.99%
70.00%
75.94%
81.62%
86.13%
90.34%
93.10%
94.35%
95.54%
96.16%
96.72%
97.22%
97.69%
98.10%
98.35%
98.51%
98.67%
98.83%
98.98%
99.11%
99.23%
99.34%
99.45%
99.54%
99.61%
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
-------
Section 5.0 - 2006 Annual Review
Table 5-3 (Continued)
40CFRPart
NA
465
406
411
426
461
405
417
NA
408
NA
443
458
446
466
460
NA
454
447
427
459
NA
Point Source Category
Tobacco Products
Coil Coating
Grain Mills Manufacturing
Cement Manufacturing
Glass Manufacturing
Battery Manufacturing
Dairy Products Processing
Soaps and Detergents Manufacturing
Printing & Publishing
Canned and Preserved Seafood
Independent And Stand Alone Labs
Paving and Roofing Materials (Tars and Asphalt)
Carbon Black Manufacturing
Paint Formulating
Porcelain Enameling
Hospital
Construction and Development
Gum and Wood Chemicals
Ink Formulating
Asbestos Manufacturing
Photographic
Photo Processing
Total
PCS 2002 TWPE
2
6,390
964
2,190
1,410
88
43
270
1,680
867
610
487
-
-
17
5
188
32
-
-
-
-
5,860,000
TRI 2002
TWPE
7,120
39
4,660
2,030
2,540
3,150
2,830
1,750
209
138
177
104
514
503
398
382
-
156
94
6
-
-
4,790,000
Total TWPE
7,130
6,430
5,620
4,210
3,950
3,230
2,870
2,020
1,890
1,000
787
592
514
503
415
387
188
188
94
6
-
-
10,700,000
Cumulative
Percentage of Total
TWPE
99.67%
99.73%
99.79%
99.83%
99.86%
99.89%
99.92%
99.94%
99.96%
99.97%
99.97%
99.98%
99.98%
99.99%
99.99%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
100.00%
Rank
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
Source: TRIReleases2002_v4; PCSLoads2002_v4.
NA - Not applicable; no existing ELGs apply to discharges.
-------
Section 5.0 - 2006 Annual Review
Table 5-4. Final TRI 2003 Rankings
40CFRPart
430
423
414
419
455
429
415
463
421
440
424
464
439
471
418
411
425
407
468
469
NA
NA
426
461
428
417
406
405
467
410
436
443
446
458
422
466
409
NA
NA
408
454
457
465
447
427
Point Source Category
Pulp, Paper and Paperboard
Steam Electric Power Generation
Organic Chemicals, Plastics and Synthetic Fibers
Petroleum Refining
Pesticide Chemicals Manufacturing
Timber Products Processing
Inorganic Chemicals
Plastic Molding and Forming
Nonferrous Metals Manufacturing
Ore Mining and Dressing
Ferroalloy Manufacturing
Metal Molding and Casting (Foundries)
Pharmaceutical Manufacturing
Nonferrous Metals Forming and Metal Powders
Fertilizer Manufacturing
Cement Manufacturing
Leather Tanning and Finishing
Fruits and Vegetable Processing
Copper Forming
Electrical and Electronic Components
Tobacco Products
Miscellaneous Foods and Beverages
Glass Manufacturing
Battery Manufacturing
Rubber Manufacturing
Soaps and Detergents Manufacturing
Grain Mills Manufacturing
Dairy Products Processing
Aluminum Forming
Textile Mills
Mineral Mining and Processing
Paving and Roofing Materials (Tars and Asphalt)
Paint Formulating
Carbon Black Manufacturing
Phosphate Manufacturing
Porcelain Enameling
Sugar Processing
Printing & Publishing
Independent and Stand Alone Labs
Canned and Preserved Seafood
Gum and Wood Chemicals
Explosives
Coil Coating
Ink Formulating
Asbestos Manufacturing
Total Pounds
Released
21,100,000
3,350,000
37,900,000
17,300,000
1,930,000
40,000
8,830,000
1,490,000
2,760,000
597,000
438,000
220,000
2,110,000
1,280,000
5,280,000
4,590
368,000
7,320,000
172,000
3,780,000
443,000
5,560,000
253,000
38,500
727,000
109,000
1,810,000
4,640,000
958,000
451,000
2,180,000
737
88,600
11
65,700
70,700
339,000
15,400
80,100
237,000
23,700
27,400
608
5,490
676
TWPE
2,880,000
1,060,000
1,020,000
498,000
485,000
249,000
182,000
107,000
78,400
77,600
24,500
12,800
12,100
10,600
10,300
10,200
9,250
7,170
6,720
6,630
6,520
5,440
4,650
4,510
4,400
4,000
3,800
3,620
3,520
3,450
2,890
518
514
483
480
363
309
297
202
179
164
47
45
45
5
Source: TRIReleases2003_v2.
NA - Not applicable; no existing ELGs apply to discharges.
5-8
-------
Section 5.0 - 2006 Annual Review
Table 5-5. 2006 Annual Review of Categories with Existing ELGs: Level of Review
40CFR
Part
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
438
439
440
442
Point Source 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
Electroplating
Organic Chemicals, Plastics and Synthetic
Fibers
Inorganic Chemicals
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 and Poultry Products
Metal Finishing
Coal Mining
Oil & Gas Extraction
Mineral Mining and Processing
Centralized Waste Treaters
Metal Products and Machinery
Pharmaceutical Manufacturing
Ore Mining and Dressing
Transportation Equipment Cleaning
Level of Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Preliminary Review
Screening-Level Review
Preliminary Review
Preliminary Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Detailed Study
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Detailed Study
Screening-Level Review
Screening-Level Review
Preliminary Review
Preliminary Review (of Coal
Bed Methane Operations)
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Source of
Identification
for Further
Review
NAa
NAa
NAa
NAa
NAa
TWPE
NAa
NAa
NAa
TWPE
TWPE
NAa
TWPE
TWPE
NAa
TWPE
NAa
TWPE
NAa
NAa
NAa
NAa
TWPE
NAa
TWPE
NAa
NAa
Comments
Comments
NAa
NAa
NAa
NAa
TWPE
NAa
5-9
-------
Section 5.0 - 2006 Annual Review
Table 5-5 (Continued)
40CFR
Part
443
444
445
446
447
451
454
455
457
458
459
460
461
463
464
465
466
467
468
469
471
Point Source Category
Paving and Roofing Materials (Tars and
Asphalt)
Waste Combustors (Commercial
Incinerators Combusting Hazardous Waste)
Landfills
Paint Formulating
Ink Formulating
Aquatic Animal Production Industry
Gum and Wood Chemicals
Pesticide Chemicals Manufacturing
Explosives
Carbon Black Manufacturing
Photographic
Hospital
Battery Manufacturing
Plastic Molding and Forming
Metal Molding and Casting (Foundries)
Coil Coating
Porcelain Enameling
Aluminum Forming
Copper Forming
Electrical and Electronic Components
Nonferrous Metals Forming and Metal
Powders
Level of Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Screening-Level Review
Preliminary Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Screening-Level Review
Source of
Identification
for Further
Review
NAa
NAa
NAa
NAa
NAa
NAa
NAa
TWPE
NAa
NAa
NAa
NAa
NAa
TWPE
NAa
NAa
TWPE
NAa
NAa
NAa
NAa
aFor categories with only a screening-level review, the source of identification is not applicable, as EPA conducts a
screening-level review of all categories subject to existing effluent guidelines. The "source of identification" is only
applicable for those industries selected for further review.
NA - Not available.
5-10
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Section 5.0 - 2006 Annual Review
5.3.1 Detailed Study of Existing ELGs
As a result of its 2005 screening-level review, EPA identified two point source
categories with existing effluent guidelines and pretreatment standards for detailed study because
they ranked first and second in combined TWPE rankings: Pulp, Paper, and Paperboard (Part
430) and Steam Electric Power Generating (Part 423). EPA's detailed studies generally examine
the following: (1) wastewater characteristics and pollutant sources; (2) the pollutants driving the
toxic-weighted pollutant discharges; (3) availability of pollution prevention and treatment; (4)
the geographic distribution of facilities in the industry; (5) any pollutant discharge trends within
the industry; and (6) any relevant economic factors. First, EPA attempts to verify the screening-
level results and to fill in data gaps. Next, EPA considers costs and performance of applicable
and demonstrated technology, process change, or pollution prevention alternatives that can
effectively reduce the pollutants remaining in the industrial category's wastewater. Lastly, EPA
considers the affordability or economic achievability of the technology, process change, or
pollution prevention measures identified above.
Types of data sources that EPA may consult in conducting its detailed studies
include, but are not limited to: (1) U.S. Economic Census; (2) TRI and PCS data; (3) trade
associations and reporting facilities to verify reported releases and facility categorization; (4)
regulatory authorities (states and EPA regions) to understand how category facilities are
permitted; (5) NPDES permits and their supporting fact sheets; (6) EPA effluent guidelines
technical development documents; (7) relevant EPA preliminary data summaries or study
reports; and (8) technical literature on pollutant sources and control technologies.
For more information about the pulp, paper, and paperboard and steam electric
power generating detailed studies, see the Final Report: Pulp, Paper, and Paperboard Detailed
Study and the Detailed Summary Report: Steam Electric Detailed Study (U.S. EPA, 2006c; U.S.
EPA, 2006b).
5.3.2 Preliminary Review
Preliminary reviews are similar to detailed studies and have the same purpose.
During preliminary reviews, EPA generally examines the same items listed above for detailed
studies. However, EPA's preliminary review of a category and available pollution prevention
and treatment options is less rigorous than its detailed studies. While EPA collects and analyzes
hazard and technology-based information on categories undergoing preliminary review, it
assigns a higher priority to investigating categories undergoing detailed studies.
EPA identified 11 point source categories for preliminary review based on their
contribution to the overall TWPE. EPA also identified the coal mining industry and coal bed
methane operations (under the Oil and Gas Extraction Point Source Category) for preliminary
review based on comments on the 2006 Preliminary Plan. The 13 existing preliminary reviews
are listed below along with a reference to where they are discussed in this report:
• Coal Bed Methane (Section 6.0);
• Coal Mining (Section 7.0);
• Fertilizer Manufacturing (Section 8.0);
5-11
-------
Section 5.0 - 2006 Annual Review
Inorganic Chemicals (Section 9.0);
Nonferrous Metals Manufacturing (Section 10.0);
Organic Chemicals, Plastics, and Synthetic Fibers (Section 11.0);
Ore Mining and Dressing (Section 12.0);
Pesticide Chemicals (Section 13.0);
Petroleum Refining (Section 14.0);
Plastics Molding and Forming (Section 15.0);
Porcelain Enameling (Section 16.0);
Rubber Manufacturing (Section 17.0); and
Textile Mills (Section 18.0).
5.4 References
Kandle, Meghan. 2006. Eastern Research Group, Inc. Memorandum to Public Record for the
Effluent Guidelines Program Plan, EPA Docket Number OW-2004-0032. "PCS and TRI
Facilities that Dominate the Total Point Source Category TWPE." (November). DCN 04076.
U.S. EPA. 2006a. Guidelines: Final, Proposed, and Under Development. "Industrial Waters
Pollution Control." Available online at: http://www.epa.gov/waterscience/guide.
U.S. EPA. 2006b. Detailed Summary Report: Steam Electric Detailed Study. EPA-821-R-06-
015. Washington, DC. (November). DCN 03401.
U.S. EPA. 2006c. Final Report: Pulp, Paper, andPaperboardDetailed Study. EPA-821-R-06-
016. Washington, DC. (November). DCN 03400.
5-12
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Section 6.0 - Coal Bed Methane Subcategory
6.0 COAL BED METHANE SUBCATEGORY OF THE OIL AND GAS EXTRACTION
CATEGORY (40 CFR PART 435)
EPA selected the coal bed methane (CBM) industry, a potential new subcategory
of the Oil and Gas Extraction Category, for additional review as part of the 2006 annual review,
because of comments received and changes in the industry since the 2004 annual review. In
2004, EPA determined that discharges from the CBM industry would be adequately controlled
by permit writers using best professional judgment (BPJ). In addition, EPA received comments
during the 2005 annual review from citizens and environmental advocacy groups requesting
development of a regulation. For its 2006 annual review, EPA collected additional data on the
number of U.S. wells producing CBM and their produced water disposal practices. EPA also
gathered additional information on potential treatment technologies for CBM-produced water
discharges. In particular, EPA conducted a site visit in the Powder River Basin, Wyoming and
observed a number of CBM-produced water treatment technologies (U.S. EPA, 2006). This
section summarizes EPA's 2006 annual review of the discharges associated with CBM
production.
In conducting this 2006 annual review, EPA found that it will need to gather more
information to determine whether it would be appropriate to conduct a rulemaking to potentially
revise the effluent guidelines for the Oil and Gas Extraction Category to include limits for CBM.
Therefore, EPA selected the CBM Subcategory for a detailed study in the 2007 and 2008 annual
reviews. EPA intends to submit an Information Collection Request (ICR) to the Office of
Management and Budget (OMB) for their review and approval under the Paperwork Reduction
Act, 33 U.S.C. 3501, et seq.
6.1 Current Applicability of Effluent Limitations Guideline for Oil and Gas
Extraction
As described below, the Oil and Gas Extraction ELGs do not currently regulate
pollutant discharges from CBM extraction operations. EPA promulgated BPT limitations for the
Oil and Gas Extraction Category (40 CFR Part 435) on April 13, 1979 (44 FR 22069). BAT,
BCT, and NSPS limitations were promulgated on March 4, 1993 (58 FR 12454) for Subpart A:
Offshore Subcategory and on December 16, 1996 (61 FR 66086) for Subpart D: Coastal
Subcategory. None of these oil and gas extraction rulemakings considered CBM extraction in
any of the supporting analyses or records. Specifically, EPA did not consider CBM production
in developing the 1979 national technology-based ELGs for Subpart C: Onshore Subcategory
and Subpart E: Agricultural and Wildlife Water Use Subcategory of the Oil and Gas Extraction
Category, because there was no significant CBM production in 1979 (O'Farrell, 1989).
Additionally, EPA did not consider CBM production in developing the Coal
Mining ELGs. EPA established ELGs for coal mine operations based on the use of the "best
practicable control technology currently available" (BPT) for existing sources in the Coal Mining
Category (40 CFR 434) on April 26, 1977 (42 FR 21380). These ELGs 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 pre-existing discharges at coal remining
operations and drainage from coal mining reclamation and other non-process areas in the arid
6-1
-------
Section 6.0 - Coal Bed Methane Subcategory
and semi-arid western United States. None of these coal mining rulemakings considered CBM
extraction in any of the supporting analyses or records.
Table 6-1 lists the existing subcategories for the Oil and Gas Extraction Category
and describes their applicability.
Table 6-1. Applicability of Subcategories in the Oil and Gas Extraction Category
Subpart
A
B
C
D
E
F
G
Subpart Name
Offshore
Reserved
Onshore
Coastal
Agricultural and
Wildlife Water Use
Stripper8
General Provisions*
Subpart Applicability
Applicable to facilities engaged in field exploration, drilling, well production, and well
treatment that are located in waters that are offshore. Offshore is defined as seaward of the
inner boundary of the territorial seas.
Applicable to facilities engaged in field exploration, drilling, well completion, and well
treatment that are located onshore. Onshore is defined as landward of the inner boundary of
the territorial seas.
Applicable to facilities engaged in field exploration, drilling, well production, and well
treatment that are located in coastal waters. Coastal is defined as landward of the inner
boundary of the territorial seas or landward of 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.
Applicable to onshore facilities engaged in field exploration, drilling, well completion, and
well treatment that are located in the United States west of the 98th meridian for which the
produced water has a use in agriculture or wildlife propagation when discharged to
navigable waters.
Applicable to onshore facilities engaged in production and well treatment that produce 10
barrels per well per calendar day or less of crude oil and are operating at the maximum
feasible rate of production.
Prevents oil and gas facilities applicable to 40 CFR Part 435 Subparts A through F from
circumventing the ELGs by moving effluent discharges from one subcategory to another for
disposal under less stringent requirements.
Source: Development Document for Interim Final Effluent Limitations Guidelines and Proposed New Source
Performance Standards for the Oil and Gas Extraction Point Source Category (U.S. EPA, 1976).
aNo pollutants are regulated in Subparts F or G.
6.1.1
CBM Extraction as a Potential New Subcategory of the Oil and Gas
Extraction Category
EPA considers CBM extraction a potential new subcategory of the Oil and Gas
Extraction Category. First, the product extracted by the CBM industry - coal bed natural gas10 -
is virtually identical to the conventional natural gas extracted by facilities subject to the Oil and
Gas Extraction ELGs, both of which consist largely of methane. Reflecting this similarity in
product, both CBM operations and conventional oil and gas extraction operations fall within SIC
code 1311: Crude Petroleum and Natural Gas. CBM operations simply constitute another
process for extracting natural gas, and are therefore reasonably considered part of the Oil and
Gas Extraction Category.
Coal bed methane (CBM) is also referred to as coal bed natural gas (CBNG or CNG). Prior to refining, extracted
natural gas typically consists of methane (approximately 95 percent), ethane (approximately 2.5 percent), and other
gases such as propane, butane, pentane, nitrogen, and carbon dioxide (EIA, 2006a).
6-2
-------
Section 6.0 - Coal Bed Methane Subcategory
EPA also considered whether CBM extraction could be considered a potential
subcategory of the Coal Mining Category. However, the product produced by coal mining - a
solid mineral - is entirely different from the product produced by CBM extraction - a natural
gas. Cf. Amoco Prod. Co. v. S. Ute Indian Tribe, 526 U.S. 865, 887 (finding that the term "coal"
in the Coal Lands Act did not encompass the CBM gas because Congress likely "viewed the
extraction of CBM gas as drilling for natural gas, not mining coal."). Therefore, EPA does not
believe that the CBM industry is appropriately considered a potential new subcategory of the
Coal Mining Category.
6.1.2 CBM Industry Current Permitting Practices
Produced water from CBM is a pollutant subject to regulation under the CWA.
See Northern Plains Resource Council v. Fidelity Exploration and Development Co., 325 F.3d
1155 (9th Cir. 2003). Although EPA considers CBM to be a potential new subcategory of the
Oil and Gas Extraction Category, the ELGs for this category does not currently apply to CBM
discharges. Therefore, because the discharge of produced water from CBM extraction is not
subject to an existing ELG, permit writers must develop technology-based limits on a case-by-
case basis using their BPJ. See 40 CFR 122.44(a)(l). In developing the BPJ-based limits, the
permit writer must take into account the same statutory factors EPA would use in promulgating a
national categorical ELG, as they apply to the particular facility. See 40 CFR 125.3(d).
Currently there exists a wide range of regulatory controls for CBM-produced
waters that vary from state to state and permit to permit. Permit writers often model permit
limits on ELGs for industries considered similar to CBM, which has led to inconsistencies
among permits. One inconsistency is that the permitting authorities of CBM wells in eastern
states do not use the Oil and Gas Extraction ELGs. These ELGs prohibit the discharge of
produced waters east of the 98th meridian. See 40 CFR Part 435.32 and 435.52. Rather, permit
writers east of the 98th meridian rely on the Coal Mining ELGs, which allow discharge of treated
wastewater to surface waters (Veil, 2002). Those in western states (west of the 98th meridian)
have modeled their BPJ permit limits on the Agricultural and Wildlife Water Use Subcategory of
the Oil and Gas Extraction ELGs (Subpart E, 40 CFR Part 435), which allows the discharge of
some produced waters. Onshore facilities regulated by the Oil and Gas Extraction ELGs must
meet the following conditions in order to discharge produced water:
• The produced water must be generated from facilities that are engaged in
production, drilling, well completion, and well treatment in the oil and gas
extraction industry and be located in the continental United States and
west of the 98th meridian (40 CFR 435.50);
• The produced water must be used in agriculture or wildlife propagation
when discharged into navigable waters (40 CFR 435.50); and
• The produced water discharges must not exceed an oil and grease daily
maximum limitation of 35 mg/L (40 CFR 435.52(b)).
6-3
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Section 6.0 - Coal Bed Methane Subcategory
EPA also defined the term "use in agricultural or wildlife propagation" to mean
that "the produced water is of good enough quality to be used for wildlife or livestock watering
or other agricultural uses and that the produced water is actually put to such use during periods
of discharge." [Emphasis added]. See 40 CFR 435.5 l(c).
6.2 Summary of Comments Received Regarding the Coal Bed Methane Industry
EPA received comments on the 2005 annual review from the Tongue River Water
Users' Association and Natural Resources Defense Council (NRDC), both requesting
development of ELGs to regulate CBM-produced water discharge. Specifically, the Tongue
River Water Users' Association requested protection of the Tongue River's existing sodium
levels so that it can continue to be used for irrigation (EPA-HQ-OW-2004-0032-1048). NRDC
cited the need for consistent, national regulations instead of state-determined permitting based on
BPJ (EPA-HQ-OW-2004-0032-1090). Additionally, Cook Inlet Keeper commented on the 2003
annual review that EPA should expand its examination of available data on the impacts of CBM-
produced water discharges (EPA-HQ-OW-2003-0074-0735).
In addition to considering these public comments, EPA collected information
related to four factors of CBM-produced water discharges:
• Factor 1: the amount and type of pollutants in an industrial category' s
discharge, and the relative hazard posed by that discharge.
• Factor 2: the performance and cost of applicable and demonstrated
wastewater treatment technologies, process changes, or pollution
prevention alternatives that could effectively reduce the pollutants in the
industrial category's wastewater.
• Factor 3: the affordability or economic achievability of any technology
identified using the second factor.
• Factor 4: the opportunity to eliminate inefficiencies or impediments to
pollution prevention or technological innovation, or opportunities to
promote innovative approaches such as water quality trading, including
within-plant trading.
EPA's analysis of the CBM industrial sector using these four factors is
summarized in this section and in the record supporting the 2006 Plan (Johnston, 2006).
6-4
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Section 6.0 - Coal Bed Methane Subcategory
6.3 CBM Industry Profile
EPA obtained data on the number of CBM operations in the United States from
the Energy Information Administration (EIA) and oil and gas industry trade groups. Table 6-2
presents the current and potential U.S. sources of CBM, listed by coal basin. Figure 6-1
indicates the location of the key CBM basins in the United States. The EIA recorded that, in
2004, CBM production (1.72 trillion cubic feet, tcf) and proved reserves (18.4 tcf) accounted for
approximately 8.7 and 9.6 percent, respectively, of the total U.S. natural gas production and
reserve capacity (EIA, 2006a).
6.3.1 Data on CBM-Produced Water Discharges
Table 6-2 also indicates if EPA has documented water discharges from the listed
CBM basin. Although CBM-produced water can be disposed of through evaporation/infiltration
impoundments, stock watering ponds, irrigation, and injection, some CBM operators discharge
to surface waters. EPA collected available information on surface discharges in the Black
Warrior Basin in Alabama and the Powder River Basin (primarily in Wyoming), such as by
searching state NPDES permit databases by type of facility. In the Black Warrior Basin, most
operators discharge to surface water, such as the Black Warrior River, although some operators
inject produced water with high total dissolved solids (TDS). In Wyoming in general, surface
discharge is a predominant water disposal method. Wyoming issued over 4,000 NPDES permits
for the discharge of CBM-produced water (WDEQ, 2006). In the much smaller Montana portion
of the Powder River Basin, EPA identified one NPDES permit (for 13 outfalls) allowing surface
discharge of CBM-produced water (MDEQ, 2001).
The New Mexico Oil Conservation Division estimates that approximately 95
percent of produced water from the San Juan and Raton basins is injected, with the other 5
percent stored in impoundments (NMOCD, 2004). The impoundments may or may not
discharge, with any discharge likely in the New Mexico portion of the Raton Basin (U.S. EPA,
2004). EPA identified at least 12 NPDES permits allowing CBM-produced water discharge in
Colorado (Veil, 2002). In the other major commercial basins, operators typically do not
discharge produced water. EPA also observed a number of CBM-produced water management
practices (ERG, 2006a; ERG, 2006b).
In the 2007 and 2008 annual reviews, EPA will collect more information on the
volume and pollutant characteristics of CBM-produced water discharges for the different CBM
basins and formations.
6-5
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-2. United States CBM Sources and Production
CBM Basin
Name
Arkoma-
Cherokee
Black
Warrior
Central and
Northern
Appalachian
Greater
Green River
Gulf Coast
Hanna-
Carbon
Powder
River
Raton
San Juan
Uinta-
Piceance
Wind River
Location
(States)
AR, MO,
NE,OK
AL,MS
KY,MD,
OH, PA,
TN, VA,
WV
CO,WY
AL, AR,
LA, MS,
TX
WY
MT,WY
CO,NM
CO,NM
CO,UT
WY
Development
Status
Commercial
Production
Commercial
Production
Commercial
Production
Exploratory15
Exploratory15
Exploratory1"
Commercial
Production
Commercial
Production
Commercial
Production
Commercial
Production
Exploratory15
All Other CBM Basinsf
Total CBM Production
Number of
Producing
Wells
1,350
3,500
-2,000
200
-20
NA
15,455C
Several
hundred
3,100d
>200e
NA
NA
>26,000
Total CBM
Production3
(bcf)
90
1,418
437
2
<1
<1
878
139
9,464
452
<1
80.3
12,901
Potential
CBM
Production
(tcf)
5
4
13
2.5
3
6
27
4
10
6
2.5
163
EPA Documented CBM-
Produced Water
Discharge
Unknown
Surface Water Discharge
Identified
Unknown
Unknown
Unknown
Unknown
Surface Water Discharge
Identified
Limited Surface Water
Discharge Identified (12
NPDES Permits Identified)
Unknown
Unknown
Unknown
Unknown
Sources: Handbookon Coal Bed Methane Produced Water (ALL, 2003); CBMin the U.S. -Past, Present, and
Future (EIA, 2004); U.S. Lowers-48 Coal and CoalbedResources (GTI, 2000); Coalbed Methane Wells in the
Powder River Basin (WOGCC, 2005); Number of Wells in Black Warrior Basin (OGB, 2006); Coalbed Methane
Permits (WDEQ, 2006).
""Production volume cumulative through December 31, 2002.
bExploratory indicates that the basin may have some gas sales, but the main activity is still exploratory.
Includes wells in Wyoming portion of Powder River Basin only.
dln 2000.
Includes Uinta wells only.
Includes CBM reserves in Alaska and the Illinois Basin.
NA - Not applicable; production has not begun in this basin yet.
6-6
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Section 6.0 - Coal Bed Methane Subcategory
North Central
Montana Basin
Data Source: USGS Open File Report 96-92
Map Production Date: Nov. 12,2002
Map Scale1:32,000,000 Provided by: ALL Consulting
Figure 6-1. Coal Bed Methane Basins in the United States
(ALL, 2003)
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Section 6.0 - Coal Bed Methane Subcategory
6.3.2 Future CBM Basin Exploration
Most of the basins listed in Table 6-1 under "all other CBM basins," have not yet
been extensively explored and are not expected to have substantial commercial potential, except
Alaska. Alaska, which is included in the "all other basins" category, has potentially enormous
reserves coupled with numerous development issues. Alaskan reserves may contain as high as
one quadrillion cubic feet of gas in 13 basins, but the economically recoverable portion has yet to
be determined (ALL, 2003). Alaskan CBM basins may not be exploited due to lack of data, lack
of infrastructure, and high exploration costs (ALL, 2003). However, CBM-produced water in
Alaska would be similar to water from other CBM basins: produced in large quantities, saline,
and possibly containing other pollutants such as metals (Northern Alaska Environmental Center,
2006).
Future CBM Basin exploration may be linked to the ability to manage and dispose
of CBM-produced waters. For example, "after a decade of steady growth in the number of
[CBM] wells and [CBM] gas production in the Powder River Basin (including dramatic growth
from 1998 to 2003), production dropped about 5 percent from 2003 to 2004... [According to
industry representatives, this reduction was apparently due in part to difficulties in managing and
disposing of [CBM-produced] water. Partly as a consequence of these difficulties, industry is
now considering other disposal options including injection and more expensive water treatment
methods. But if difficulties in disposing and/or permitting [CBM-produced] water discharges
were, in fact, the root causes of reduced production in 2004, additional acceptable options for
managing the water will be needed or production may continue to level off or decline"
(Ruckelshaus, 2005).
6.4 Oil and Gas Extraction Category 2005 Annual Review
For the 2005 annual review of this category, EPA used available industry, state,
and EPA literature but did not use PCS or TRI data. EPA selected the Oil and Gas Extraction
Category for further review because of comments received on the Preliminary 2006 Plan and
changes in the CBM portion of the oil and gas industry. The PCS and TRI databases classify
data by SIC codes, which do not distinguish CBM production from traditional oil and natural gas
recovery. Therefore, the 2005 screening-level review of PCS and TRI data did not provide
insight into discharges associated with CBM.
6.5 CBM Production
The geologic process that progressively converts plant material to coal
(coalification) generates large quantities of natural gas that are stored in the coal seams. The
natural gas consists of approximately 96 percent methane, 3.5 percent nitrogen, and trace
amounts of carbon dioxide (U.S. EPA, 2004). The natural gas contained in and removed from
the coal seams is called CBM. The increased pressures from water in the coal seams force the
natural gas to adsorb to the coal (U.S. DOE, 2006).
The softest coals (peats and lignites) are associated with high porosity, high water
content, and biogenic methane. In higher rank coals (bituminous), porosity, water, and biogenic
methane production decreases, but the heat associated with the higher rank coals breaks down
the more complex organics to produce methane. The hardest anthracite coals are associated with
6-8
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Section 6.0 - Coal Bed Methane Subcategory
low porosity, low water content, and little methane generation (ALL, 2003). The most sought-
after coal formations for CBM development, therefore, tend to be mid-rank bituminous coals.
Coal formations in the eastern United States tend to be higher rank, with lower water content
than western coal formations. They also tend to have greater methane content per ton of coal
than western coal formations in the key basins, but often require fracturing to release the
methane because of their low porosity (ALL, 2003).
To extract CBM, operators drill wells into coal-bearing formations. Often, these
formations are not as deep as those containing conventional hydrocarbon reserves, particularly in
western regions. In the Powder River Basin, for example, some of the methane-bearing
formations are shallow, at hundreds to one thousand feet below land surface, compared to
conventional oil and natural gas well depths averaging approximately 6,000 feet (U.S. DOE,
2005). CBM wells can be drilled using water well drilling equipment, not the rigs designed for
conventional hydrocarbon extraction, which are used to drill several thousands of feet into
typical conventional reservoirs (Apache Corporation, 2006).
CBM wells typically have either openhole or perforated/slotted casing
completion, similar to those for conventional oil or gas wells. However, openhole completions,
which are less expensive than perforated or slotted completions, are used more for CBM than for
conventional oil and gas, which can use them only under certain circumstances (NaturalGas.org,
2004). For example, openhole completion is widely used in Wyoming's Powder River Basin
(ALL, 2003). Figure 6-2 shows the profile of a typical western CBM well using openhole
completion.
Extraction of CBM requires drilling and pumping the water from the coal seam,
similar to typical natural gas production. Methane and water are produced at individual wells
and piped to a metering facility, where the amount of production is recorded. The methane then
flows to a compressor station, where the gas is compressed and then shipped via pipeline (De
Bruin, 2001). As at conventional hydrocarbon production facilities, the produced water then
becomes a by-product of the gas extraction process, requiring some form of management (i.e.,
use or disposal).
Removing the water from the formation is necessary to produce CBM. The water
removal from the formation reduces the pressure and allows the CBM to release from the coal to
produce flowing natural gas (Wheaton, 2006; U.S. DOE, 2006). Unlike conventional gas
extraction, which usually produces relatively small amounts of water (removing water is not
necessary to release conventional gas reserves), CBM extraction produces large amounts of
water, sometimes saline.
6-9
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Section 6.0 - Coal Bed Methane Subcategory
Gamma Ray
Type Log
Wafer
'Sump
Figure 6-2. Profile of a Typical Western CBM Well with Openhole Completion
(DeBruin, 2001)
A CBM well's typical lifespan is between 5 and 15 years, with maximum
methane production achieved after one to six months of water removal (Horsley & Witten,
2001). CBM wells go through the following production stages:
• Early stage where large amounts of water are produced to reduce the
underground pressure, which encourages the release of the natural gas;
• Stable stage where the amount of natural gas produced from the well
increases as the amount of water removed from the coal seam decreases;
and
• Late stage where the amount of gas produced declines and water
production remains low (De Bruin, 2001).
As previously stated, EPA will collect more information on the future exploration
of CBM across the United States (e.g., production and number of wells) and the expected
timelines for development.
6-10
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Section 6.0 - Coal Bed Methane Subcategory
6.6
CBM-Produced Water Sources and Characteristics
The production of CBM requires large quantities of water to be removed from
under ground (U.S. EPA, 2004). The quantity and quality of CBM-produced water varies
between basins, within basins, between coal seams, and over a well's lifetime. Generally, the
western basins with their soft coal formations tend to produce more water than the hard-coal
eastern basins. Also, basins with a longer production history, such as the San Juan basin,
produce less total water and less water per well than the more recently developed basins, such as
the Powder River Basin. Table 6-3 presents the amount of water produced in some of the CBM
basins. The Powder River Basin produces the most water, overall and per well.
Table 6-3. Water Production from CBM Extraction
Basin Name
Arkoma-Cherokee
Black Warrior
Powder River
Raton
San Juan
Uinta
Average Water Production per
Well (gal/day)
<900-2,600
1,800
12,600
8,380
800
6,770
Yearly Average Water Production per
Basin (MGD)
ND
1,950
12,600
1,400
900
970
Source: Water Produced with Coal-Bed Methane (USGS, 2000); Handbook on Coal Bed Methane Produced Water:
Management and Beneficial Use Alternatives (ALL, 2003).
ND - No data available.
As previously stated, EPA will collect more information on the volume and
pollutant characteristics on CBM-produced water discharges for the different CBM basins and
formations.
6.6.1
CBM-Produced Water Pollutants of Concern
Total dissolved solids (TDS) is the major pollutant of concern for CBM-produced
water. TDS includes any dissolved minerals, salts, metals, cations, or anions in water. TDS
concentrations in CBM-produced water generally range from 200 mg/L to 4,000 mg/L in the
western United States and from 500 to 27,000 mg/L in the eastern United States, with occasional
concentrations exceeding 50,000 mg/L. For comparison, 500 mg/L TDS is recommended for
potable water and 1,000 to 2,000 mg/L TDS is recommended for irrigation and stock ponds
(USGS, 2000). Table 6-4 presents TDS concentrations for the major CBM basins.
6-11
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-4. CBM-Produced Water TDS Concentrations
Basin
Appalachian
Arkoma-Cherokee
Black Warrior
Green River
Piceance
Powder River
Raton
San Juan
Uinta
Wind River
Minimum TDS Concentration
(mg/L)
<10,000
ND
<50
ND
1,000
244
310
180
6,350
2,000
Maximum TDS Concentration
(mg/L)
>10,000 (>1%)
90,000 (9.0%)
60,000 (0.06%)
>10,000
6,000
8,000a (0.81%)
>3,500 (0.35%)
171,000 (1.7%)
42,700 (4.3%)
11,000
Source: Technical Support Document for the 2004 Effluent Guidelines Program Plan (U.S. EPA, 2004); Guidance
for Developing Technology-Based Limits for Coalbed Methane Operations: Economic Analysis of the Powder River
Basin (U.S. EPA, 2003); Proceedings from the Produced Water Forum in Farmington, NM (NMOCD, 2004);
Handbook on Coal Bed Methane Produced Water: Management and Beneficial Use Alternatives (ALL, 2003);
Analysis of Discharge Data for Six Industry Categories (Bartram, 2003).
Typical maximum TDS concentrations are approximately 8,000 mg/L; however, concentrations as high as 50,000
mg/L have been measured.
TDS - Total dissolved solids.
ND - No data available.
CBM-produced water may also contain trace amounts of metals, volatile and
semivolatile organic compounds, polymers, surfactants, biocides, iron-chelating agents, and
other compounds associated with drilling and production (Bartram, 2003). Table 6-5 presents
the pollutant concentrations from basins that account for approximately 96 percent of the 2002
U.S. production.
There is very limited discharge monitoring information in PCS and TRI for this
industrial sector. In the 2007 and 2008 annual reviews, EPA will collect more information on
the pollutants of concern in CBM-produced waters across the different CBM basins and
formations.
6.6.2
Adverse Impacts from CBM-Produced Water Discharges
CBM-produced water discharges can adversely impact the receiving surface water
and soil. Saline discharges affect streams' aquatic and benthic life and can damage streams used
to irrigate farmland or water livestock (Johnston, 2006). The large volume of water discharged
can also cause stream bank erosion and salt deposition, creating hardpan soil. Long-term
impacts include sodium buildup, reduction of plant diversity, mobilization of salts and other
elements, and alteration of surface and subsurface hydrology (Ruckelshaus, 2005). In addition,
removing large quantities of CBM-produced water can lower aquifers used for drinking water
(Horsley & Witten, 2001).
6-12
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-5. Concentration of Pollutants in CBM-Produced Water by Basin
Pollutant
Barium
Calcium
Chloride
Iron
Magnesium
Potassium
Sodium
Sulfate
Pollutant Concentration by Basin (mg/L)
San Juan Basin
Min
0.7
0
0
0
0
0.6
19
0
Max
63
228
2,350
228
90
770
7,130
2,300
Black Warrior
Basin
Min
ND
ND
40
0.1
ND
ND
60
1
Max
ND
ND
36,000
400
ND
ND
21,500
1,350
Powder River
Basin
Min
0.06
5
3
0.03
1
2
89
0.01
Max
2
200
119
11
52
20
800
1,170
Raton Basin
Min
ND
4
15
0.1
1
1
210
1
Max
ND
24
719
23
8
17
991
204
Uinta Basin
Min
ND
ND
2,300
ND
ND
ND
ND
ND
Max
ND
ND
14,000
ND
ND
ND
ND
ND
Source: Analysis of Discharge Data for Six Industry Categories (Bartram, 2003).
Min - Minimum.
Max - Maximum.
ND - No data available.
Aquatic communities can be adversely impacted (e.g., decrease in species
diversity and density) by the constituents in CBM-produced waters (e.g., IDS, bicarbonate,
chloride, metals, organics) (Mount, 1997; Tietge, 1997; Mount, 1993a). CBM discharges may
adversely impact water quality and aquatic organisms. For example, soil colloids suspended in
runoff may sorb and mobilize metals, soil nutrients, pesticides and other organic contaminants
(Sumner, 1998). Also, the ions that comprise IDS (e.g., chloride) can be toxic to freshwater
organisms if present in sufficiently high concentrations (Mount, 1992; Mount, 1993b, Klarich,
1980; Boelter, Unknown; Horpestad, 2001). Some macroinvertebrates in freshwater systems
appear to be quite sensitive to increasing IDS concentrations. Sensitivity will vary with the
species of aquatic organism and the ionic composition of the IDS. As in-stream IDS
concentrations increase, sensitive aquatic species are eliminated while more TDS-tolerant
species increase in abundance. Thus, while the overall abundance of macroinvertebrates may not
change, the diversity, or taxa richness, of the aquatic community may change.
In the 2007 and 2008 annual reviews, EPA will collect more information on the
potential adverse environmental impacts from the discharge of CBM-produced waters across the
different CBM basins.
6.7
CBM-Produced Water Treatment and Disposal
This subsection describes existing CBM-produced water management: surface
water discharge, evaporation or storage ponds using impoundments, and subsurface injection. It
also describes treatment technologies associated with produced water management and lists
technologies that could allow beneficial use of CBM-produced water. Table 6-6 indicates the
predominant disposal methods currently used in most of the major CBM basins.
6-13
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-6. Produced Water Disposal Methods in Major CBM Basins
Basin
Black Warrior
Appalachian
Powder River
Uinta-Piceance
Raton
San Juan
Arkoma-Cherokee
Predominant Disposal Method
Surface water discharge
Injection
Surface water discharge, impoundments
Injection
Injection
Injection
Injection
Other Methods Noted
Injection
Injection, irrigation, aquifer storage
Evaporation impoundments
Impoundments, surface discharge
Hauling to commercial disposal
Source: Handbook on Coal Bed Methane Produced Water: Management and Beneficial Use Alternatives (ALL,
2003); Guidance for Developing Technology-Based Limits for Coalbed Methane Operations: Economic Analysis of
the Powder River Basin (U.S. EPA, 2003); Water Produced with Coal-Bed Methane (USGS, 2000); Regulatory
Issues Affecting Management of Produced Water from Coal Bed Methane Wells (Veil, 2002).
In the 2007 and 2008 annual reviews, EPA will collect more information on the
produced water treatment and disposal methods across the different CBM basins and formations.
6.7.1
Surface Discharge of CBM-Produced Water
Of all U.S. CBM basins, surface water discharge is most prevalent in the Black
Warrior, Powder River, and Raton Basins. Surface discharge occurs rarely, if at all, in the other
major commercial basins.
In one case study presented in the Handbook on Coal Bed Methane Produced
Water: Management and Beneficial Use Alternatives, an operation in the Black Warrior Basin
discharges to a treatment pond, where the pH is adjusted to precipitate metals (ALL, 2003). The
water is then discharged at a controlled rate to the Black Warrior River. The facility's NPDES
permit limits the rate of discharge and also limits the in-stream TDS concentration to less than
230 mg/L. The permit does not specify whether the treatment pond must be lined.
Operators typically transport CBM-produced water to the discharge location via
buried pipelines. Prior to discharge, facilities often use aeration methods to precipitate iron from
the water 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. Operators may also use spray nozzles,
agitators, and bubble diffusers to aerate the water before discharge.
6.7.2
Storage/Evaporation Ponds for CBM-Produced Water
Many CBM operators in the Powder River Basin use unlined earthen storage
ponds for evaporation and infiltration in conjunction with or instead of surface discharge to
minimize or eliminate the amount of water reaching outfalls to surface water. Ponds also can be
used for livestock watering. They are typically an excavated rectangular pit with sloped sides
and perimeter berms. Water is eliminated via infiltration, evaporation, or transport to irrigated
6-14
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Section 6.0 - Coal Bed Methane Subcategory
cropland and pastureland without return flows to drainages (Oil & Gas Consulting, 2002).
Evaporation rates depend on the size of the pong and its location. In semiarid regions such as
Wyoming, hot dry air moving from land over a water body will cause faster evaporation for
smaller water bodies (Pochop, 1985).
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 (Pochop, 1985; U.S. EPA, 2003). Most of the storage ponds in the Powder River
Basin are off-channel and are designed to contain all CBM-produced water without discharge
(Oil & Gas Consulting, 2002; U.S. EPA, 2003).
6.7.3 Inj ection of CBM-Produced Water
CBM operators can eliminate all surface water discharge of produced water
through underground injection. Prior to the major development of the Powder River Basin,
injection of produced water into Underground Injection Control (UIC) Class II wells was the
predominant (greater than 90 percent by volume) form of CBM-produced water management in
the continental United States (Lawrence, 1993). UIC Class II wells are regulated under the
federal Safe Drinking Water Act by EPA or EPA-approved state UIC programs and are used to
inject fluids associated with the production of oil and natural gas. Operators can inject water
with high TDS into UIC Class II wells without treatment, which cuts down on water
management costs.
Operators install wells by either drilling a new hole or by converting an existing
well such as marginal oil-producing wells, plugged and abandoned wells, and wells that were
never completed (dry holes). Some operational difficulties of injecting CBM-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 by using engineering and operational applications such as treatment chemicals (U.S.
EPA, 1996).
An advantage of using UIC Class II injection wells to dispose of CBM-produced
water is that the injected water is usually better quality, having lower TDS concentrations, than
the water in the injection zone. 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 techniques until injection resumes (Zimpher, 1988).
Pretreatment may include removing iron and manganese by precipitation. Iron
and manganese form oxides upon exposure to air, which may clog 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.
6-15
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Section 6.0 - Coal Bed Methane Subcategory
6.7.4
Hauling with Commercial Disposal of CBM-Produced Water
For CBM operations where produced water generation is low, produced water
may be stored in tanks, which are later hauled to a commercial disposal well. This option is
noted in one case study (ALL, 2003) of an operation in the Arkoma basin where the wells are
producing just a few gallons to not more than 400 gallons per day of water.
6.7.5
Technology Options for Beneficial Use and Disposal of CBM-Produced
Water
Various treatment technologies reduce or eliminate pollutants of concern and
allow for the beneficial use of CBM-produced water or for surface water disposal. Table 6-7
lists technologies that could be used to treat CBM-produced water for beneficial use.
Table 6-7. Potential Treatment Technologies for Beneficial Use and Disposal for CBM-
Produced Water
Treatment Technology and Description
Aeration/oxidation: use of spray nozzles, educators,
bubble diffusers, or aerators to oxygenate water
Reverse osmosis: pressure-driven membrane separation
process
Ion exchange: cation or anion resin removal process
Electrodialysis: electrical current with membrane
separation process
Chemical precipitation: addition of chemical to form
metal hydroxides and subsequent precipitation of the
insoluble hydroxides
Downhole gas/water separation: separation of CBM
from water without pumping water above ground.
Freeze-thaw/evaporation: crystallization process
Harmon SO2 generator
Constructed wetlands
Evaporation pond liners: barrier technology
Potential CBM Application
Precipitates iron.
Removes sodium, chlorides, minerals, and other
pollutants. Fouls if influent water contains particulates.
Removes ionic pollutants: sodium, chlorides, sulfate,
metals.
Removes ionic pollutants: sodium, chlorides, sulfate,
metals.
Removes metals.
Pollution prevention: decreases or eliminates CBM-
produced water volume.
Reduces salinity.
Removes sulfur, increases acidity, reduces salt
formation in soils receiving CBM-produced water.
Removes metals.
Prevents infiltration of water and encourages
evaporation.
Source: Handbook on Coal Bed Methane Produced Water:
2003).
Management and Beneficial Use Alternatives (ALL,
The CBM-produced waters can also be applied in agronomic rates to agricultural
lands (U.S. EPA, 2006). This leads to no direct discharges of CBM-produced waters (i.e., zero
discharge). Soil samples are periodically analyzed to ensure that the application of CBM-
produced waters will not cause plugging or dispersal (and subsequent erosion) of the soil
structure. Analytes include sodium adsorption ratio (SAR), electrical conductivity (EC), pH, and
soil moisture, which help confirm the movement of water through the soil profile. Complete soil
chemistry and hydraulic properties are also analyzed and review on a periodic basis. An
6-16
-------
Section 6.0 - Coal Bed Methane Subcategory
overview of an agricultural use of CBM-produced waters is provided in Chapter 6 (Case Studies)
of the Handbook on Coal Bed Methane Produced Water: Management and Beneficial Use
Alternatives (ALL, 2003).
6.8 Cost and Affordability of Treatment Technologies for CBM-Produced Water
EPA developed capital and operating costs associated with the CBM-produced
water disposal and treatment methods. EPA estimated fixed costs and annual operating and
maintenance costs based on equipment and land needs, for a range of produced water flows.
Unit component costs were based on standard cost references, vendors, and industry contacts and
are expressed in 2004 dollars. Table 6-8 shows the annualized costs estimated for treating CBM-
produced water, considering capital and operating costs over lifetime water production.
Table 6-8. 2006 Estimates of Annualized Costs for Managing CBM-Produced Water in the
Powder River Basin
Water Management Option
Surface discharge after reverse osmosis or ion exchange
Zero discharge using injection or reinjection
Zero discharge using impoundments
Surface discharge (without treatment)
Estimated Annualized $/bbl
$0.15 to $0.51
$0.15 to $1.89
$0.06 to $0.07
$0.03 to $0.05
Source: Computation of Lifetime per Barrel Costs of Disposal for Coal Bed Methane-Produced Water in the
Powder River Basin (Jones, 2006).
After estimating treatment technology costs in 2003, EPA evaluated their
affordability in an economic impact model of CBM production in the Powder River Basin. The
economic analysis uses a financial model based on a discounted cash-flow approach that EPA
has used for the economic analyses of several oil and gas industry-related effluent guidelines.
The general approach uses a number of model projects that are specified on the basis of gas and
water production volumes. 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 are used to estimate costs. EPA used costs of CBM-produced water treatment
and disposal in the model to prepare a number of scenarios, including a baseline (current
practice) scenario against which all other scenarios are compared.
EPA's 2003 study focused on the Powder River Basin, which has some of the
highest water production rates of any basin in the United States. At the time of the study,
wellhead gas prices were greater than $2.50 per mcf, and EPA's analysis showed that many of
the technology options were affordable, including injection (which is one of the more expensive
options). DOE projects that future wellhead gas prices in the Powder River Basin will be
significantly greater than $2.50-$3.00 per mcf, which indicates that the treatment technology
options would continue to be affordable. Also, some of the beneficial use options might also be
affordable in basins where water is currently injected, but where beneficial use opportunities are
welcome.
6-17
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-9 lists the types of treatment and disposal technologies evaluated in the
Powder River Basin study and EPA's findings on their affordability. In the 2007 and 2008
annual reviews, EPA will collect more information on the treatment costs for the CBM-produced
waters across the different CBM basins and formations.
6.9
CBM Industry Trends
This subsection discusses the trends seen in the U.S. energy market and the U.S.
CBM business market.
In the 2007 and 2008 annual reviews, EPA will collect more information on the
energy market trends with respect to the CBM industrial sector for the different CBM basins and
formations.
6.9.1
Energy Market Trends
DOE projects that unconventional gas production, which includes CBM
production, will become the largest source of domestic natural gas production over the next 25
years, as shown in Figure 6-3. The EIA projects CBM production to increase from 1.7 tcf per
year (current) to 8.1 tcf per year (2015) and 9.1 tcf per year (2025) (EIA, 2006c). Currently,
proved reserves of CBM are estimated to total 18.4 tcf, but technically recoverable reserves are
higher. Recent estimates by DOE set this number at 75 tcf (McAllister, 2006). Most of these
reserves are expected in the Rocky Mountain region, and much of this is associated with Powder
River Basin.
•V _ Lower 48 coproduced
with oil
o
Alaska
Lower 43
'unconventional not
co-produced with oil
(includes CBM, tight
sands, and gas shales)
Lower 48
conventional
onshore not
co-pro ducedwitli
oil
Lower 48 offshore not
co-produced with oil
JSSB SLW
SQSO WS&S03Q
Figure 6-3. EIA Predicted Natural Gas Production by Source, 1990-2030 (tcf)
(EIA,2006c)
6-18
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Section 6.0 - Coal Bed Methane Subcategory
Table 6-9. 2003 Estimates of Cost and Affordability of Treatment and Disposal Technologies for CBM-Produced Water in the
Powder River Basin
Technology Evaluated
Surface Discharge
Zero Discharge via Storage
Ponds
Reverse Osmosis
Injection: Shallow Well3
Summary of Engineering
Considerations
Piping, rip-rap, outfall structure
Piping, excavation and
construction, surface runoff
control, rip-rap, land
Evaluation of cost to treat a
portion of CBM-produced water
with reverse osmosis unit
Injection well construction,
piping, tanks and chlorinator,
storage tanks, injection pump,
equipment building, and land
Estimated Cost
Capital
Cost/Well
Served ($000)
~$10
~$19
~$46 (one
example case)
$21 -$72
Operating Cost
($/bbl)
<$0.01
<$0.01
$0.03-$0.05
$0.08-$0.14
Conclusion Regarding Affordability
Surface discharge costs (as the lowest cost
technology) were considered the baseline against
which other options are compared.
Affordable over most gas prices modeled (i.e.,
production changes little from baseline).
Likely to be affordable at current and projected
wellhead gas prices.
Likely to be affordable at current and projected
wellhead gas prices.
VO
Source: Guidance for Developing Technology-Based Limits for Coalbed Methane Operations: Economic Analysis of the Powder River Basin (U.S. EPA, 2003).
aMedium depth and deep injection wells were also investigated, but shallow injection wells are considered the likeliest type of injection well needed in the
Powder River Basin.
-------
Section 6.0 - Coal Bed Methane Subcategory
Drilling activity in the Powder River Basin has been expanding rapidly and is
expected to continue to expand substantially over the next decades. According to ALL
Consulting, as many as 87,000 wells might be drilled in Wyoming and Montana over the next 10
to 20 years (ALL, 2003). This averages to possibly 4,000 to 6,000 wells per year. In the last
year, the Wyoming Oil and Gas Conservation Commission issued nearly 7,000 permits to drill
for CBM (WOGCC, 2006).
The increased drilling activity results from increased gas prices, technology
advancement, and piping infrastructure. DOE predicts that long-run wellhead gas prices (the
price received by the operator of the well) will most likely range from $4 to $6/MMBtu,11 which
is more than twice the recent historic levels of about $2/MMBtu. DOE predicts even higher
short-run prices, forecasting an annual average wellhead price of $7.15/Mcf for 2006, rising to
$8.05/Mcf in 2007 (EIA, 2006b). Also, given that gas prices are twice the recent historic levels,
CBM development will expand in basins just beginning the commercial development process.
The wellhead gas prices in the Powder River Basin tend to be slightly less than
the average wellhead price due to the distance from the Midwest and Northeast gas demand areas
and the relative lack of transmission infrastructure. However, a rapid expansion of infrastructure
is expected in the Powder River Basin, which would increase wellhead gas prices for this area.
For example, a 2 billion cubic foot per day pipeline is being built to carry gas from Wyoming to
Ohio, and several similar projects are also underway (ENR, 2006).
Additionally, new technologies may reduce costs of production as well as increase
the amount of reserves that are considered technically recoverable. For example, DOE predicts
the possibility that multi-seam completions will allow one well to simultaneously extract
methane from several narrow coal seams, lowering the cost of producing from marginally
economic or uneconomic coal seams (U.S. DOE, 2005).
The increased drilling and production in the Powder River Basin and possibly
other nearby basins increases produced water discharges and environmental impacts. On
average, a Powder River Basin CBM well produces 97 bbl water, or over 4,000 gallons per day
(WOGCC, 2006). For the Wyoming portion alone, this results in 67 MGD for all wells
(WOGCC, 2006). If the expected 4,000 to 6,000 wells come on line annually, there will be an
additional 16 to 24 MGD of produced water to be managed in the Powder River Basin. In
Wyoming, a majority of the produced water is surface discharged, and the state may need to
permit more than 2,000 well discharges each year.
6.9.2 Economic Structure of CBM Operations
CBM operators lease properties for exploration and development. The operator
pays for the lease regardless of whether the lease is active. Once the lease produces, the operator
also pays the mineral rights owner (who may or may not be the landowner) a royalty, which is
typically a percentage of production. The mineral rights owner can be a private party, a state, the
Federal Government, or a tribe and varies depending on whether state or federal laws apply
(Phelps, Unknown). Western regions have more complex rights ownership on private lands,
11 1 MMBtu ~ 1 Mcf.
6-20
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Section 6.0 - Coal Bed Methane Subcategory
where the landowner, the water rights owner, and the mineral rights owner(s) (the owner of the
coal can be different from the owner of the CBM) can all differ.
Facilities that are currently subject to the Oil and Gas Extraction ELGs - many of
which also operate CBM extraction facilities - are conventionally divided into independents and
"majors," which are the large, vertically integrated firms with familiar names (e.g.,
ExxonMobil). Independents are involved only in the "downstream" activities of drilling and
producing oil and gas and are not associated with gas distribution, refining, or retail sales.
Independents can be either large or small businesses (as defined by the Small Business
Administration). Utilities, gas transmission firms, and mining firms might also operate CBM
wells (U.S. EPA, 2003).
In the 2007 and 2008 annual reviews, EPA will collect more information on the
energy market trends with respect to the CBM industrial sector for the different CBM basins and
formations.
6.10 CBM Subcategory Conclusions for the 2006 Plan
In conducting this review, EPA found that it will need to gather more specific
information as part of a detailed study of the CBM industry in order to determine whether it
would be appropriate to conduct a rulemaking to potentially revise the Oil and Gas Extraction
ELGs to include limits for CBM. In particular, EPA needs more detailed information on the
characteristics of produced water, as well as the technology options available to address such
discharges. To aid in a better industrial profile of the CBM sector, EPA intends to submit an
ICR to OMB for their review and approval under the Paperwork Reduction Act, 33 U.S.C. 3501,
et seq., in the 2007 and 2008 annual reviews. EPA will use this ICR to collect technical and
economic information from a wide range of CBM operations (e.g., geographical differences in
the characteristics of CBM-produced waters, current regulatory controls, availability and
affordability of treatment technology options). In designing this industry survey EPA expects to
work closely with CBM industry representatives and other affected stakeholders. EPA solicits
comment on the potential scope of this ICR. EPA may also supplement the survey data
collection with CBM site visits and produced water sampling.
Survey questionnaires solicit detailed information specific to individual facilities
that is used to assess the statutory rulemaking factors, particularly technological and economic
achievability of available controls, production processes, and wastewater treatment residuals
disposal practices. To develop a useful survey questionnaire, EPA typically selects the
methodology it would use for estimating the costs of installing or upgrading pollution control
equipment and for financial and economic analyses, and defines the data it would need to
conduct these studies. The necessary data for the CBM ICR will include, among other things:
• NPDES permit information and other regulatory controls;
• Information about CBM formations, CBM production levels and produced
water characteristics, types of CBM drilling, CBM-produced water
treatment and disposal options and practices (including beneficial use);
6-21
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Section 6.0 - Coal Bed Methane Subcategory
• The design, capacity, and operation of current CBM-produced water
treatment technologies and practices;
• The types, amounts, composition, and destination of CBM-produced
waters and wastes generated by the facility and associated costs of
treatment, management, and disposal; and
• Detailed facility and well specific economic and financial data, such as
statements of production, revenues and net income, assets and liabilities,
operating costs and expenses (e.g., depreciation, royalty payments,
severance tax payments), and internal rates of return.12
6.11 CBM Industry References
ALL. 2003. ALL Consulting, LLC. Handbook on Coal Bed Methane Produced Water:
Management and Beneficial Use Alternatives. (July). Available online at: http://www.all-
llc.com/CBM/pdf/CBMBU/CBM%20BU%20Screen.pdf. DCN 03451.
Apache Corporation. 2006. Areas with the Largest Increase in Drilling. (March). Available
online at:
http://www.apachecorp.com/Explore/Explore_Features/20060327^Topic_Report_Areas_with_th
e_Largest_Increase_in_Drilling/. DCN 03452.
Bartram, D., et al., 2003. Eastern Research Group, Inc. Memorandum to Carey Johnston, U.S.
EPA. "Analysis of Discharge Data for Six Industry Categories." (Septembers). DCN 00258.
Boetler, Ann M. et al. Unknown. Wyoming Water Research Center. Environmental Effects of
Saline Oil-field Discharges on Surface Waters. RB93-104. DCN 03424.
De Bruin, R.H. R.M. Lyman, R.W. Jones, and L.W. Cook. 2001. CoalbedMethane in Wyoming
Information Pamphlet 7 (revised). Wyoming State Geological Survey. DCN 03070.
EIA. 2004. Energy Information Administration. CBM in the U.S. -Past, Present, and Future.
(February). Available online at: http://www.eia.doe.gov/oil_gas/rpd/cbmusa2.pdf. Date
accessed: July 13, 2006. DCN 03876.
EIA. 2006a. Energy Information Administration. Natural Gas Gross Withdrawals and
Production. Available online at:
http://tonto.eia. doe.gov/dnav/ng/ng_enr_cbm_a_EPGO_r5 l_Bcf_a.htm;
http: //tonto. ei a. doe. gov/dnav/ng/ng_enr_cbm_a_EPGO_r 5 2_B cf_a. htm;
http://tonto.eia. doe. gov/dnav/ng/ng_enr_sum_dcu_NU S_a.htm;
http://tonto.eia.doe.gov/dnav/ng/ng_prod_sum_dcu_NUS_a.htm. Date accessed: August 16,
2006. DCN 03468.
12 EPA's ICR for the 1996 Oil and Gas Extraction Coastal Subcategory ELG rulemaking provides some examples of
the economic information EPA will likely collect with the CBM ICR in the 2007 and 2008 annual reviews (U.S
EPA, 2003b).
6-22
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Section 6.0 - Coal Bed Methane Subcategory
EIA. 2006b. Energy Information Administration. EIA 's Short-Term Energy Outlook (June).
Available online at: http://www.eia.doe.gov/emeu/steo/pub/jun06.pdf. DCN 03877.
EIA. 2006c. Energy Information Administration. Annual Energy Outlook 2006 With
Projections to 2030. (February). DOE/EIA-0383(2006). Available online at:
http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2006).pdf DCN 03414.
ENR. 2006. Engineering News Record. "$3 Billion Project Planned to Move Rockies Gas
East." (February 16). DCN 03582.
ERG. 2006a. Eastern Research Group, Inc. Final Site Visit Report: CoalbedMethane
Landowners and Environmental Impacts, Gillette, WY. (September 29). DCN 03204.
ERG. 2006b. Eastern Research Group, Inc. Final Site Visit Report: Coalbed Methane
Operators, Gillette, WY. (September 29). DCN 03205.
GTI. 2000. Gas Technology Institute. U.S. Lower-48 Coal and Coalbed Resources. Available
online at: http:/www.eandpnet.com/mapscharts/cbm/ustable.html. Date accessed: July 13,
2006. DCN 03482.
Horpstad, Abe. 2001. Montana Department of Environmental Quality. Water Quality Analysis
of the Effects of CBM Produced Water on Soils, Crop Yields and Aquatic Life. DCN 03555.
Horsley & Witten, Inc. 2001. "Draft Evaluation of Impacts to Underground Sources of
Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs." Prepared for the U. S.
EPA. 2001. DCN 03489.
Hulcher, Richard. 2006. Alabama Department of Environmental Management. Email to Carey
Johnston, U.S. EPA. "Coal Bed Methane NPDES Permit Questions." (September 11). DCN
03680.
Johnston, Carey A. 2006a. U.S. EPA. Memorandum to Public Record for Effluent Guidelines
Program Plan 2005/2006. "Review of Coal Bed Methane for the 2006 Effluent Guidelines
Program Plan." (October 25). DCN 02492.
Johnston, Carey A. 2006b. U.S. EPA. Memorandum to Public Record for Effluent Guidelines
Program Plan 2005/2006. "Incorporation by Reference: Sodic Soils" (November 30). DCN
04113.
Jones, Anne. 2006. Eastern Research Group, Inc. Memorandum to Public Record for Effluent
Guidelines Program Plan 2005/2006. "Computation of Lifetime per Barrel Costs of Disposal for
Coal Bed Methane-Produced Water in the Powder River Basin." (October 13, 2006). DCN
03881.
Klarich, Duane A. and Stephen M. Regele. 1980. Montana Department of Health and
Environmental Sciences. Structure, General Characteristics, and Salinity Relationships of
6-23
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Section 6.0 - Coal Bed Methane Subcategory
Benthic Macroinvertebrate Associations in Streams Draining the Southern Fort Union Coalfield
Region of Southeastern Montana. (November). DCN 03208.
Lawrence, A.W. 1993. Gas Research Institute. "Coalbed Methane Produced-Water Treatment
and Disposal Options." Quarterly Review of Methane from Coal Seams Technology 11:2.
(December). DCN 01146.
McAllister, Ted. 2006. Energy Information Administration. In: Proceedings from the 2006 EIA
Energy Outlook and Modeling Conference. "Unconventional Natural Gas: Industry Savior or
Bridge, Unconventional Gas Production Projections in the Annual Energy Outlook 2006: An
Overview." (March 27). Available online at:
http://www.eia.doe.gov/oiaf/aeo/conf/pdf/mccallister.pdf. DCN 03473.
MBMG. 2003. Montana Bureau of Mines and Geology. Coal Bed Methane-Frequently Asked
Questions. Available online at: http://waterquality.montana.edu/docs/methane/cbmfaq.shtml.
Date accessed: July 12, 2006. DCN 03455.
MDEQ. 2001. Montana Department of Environmental Quality. Authorization to Discharge
Under the Montana Pollution Discharge Elimination System NPDES - MT0030457 - Fidelity
Exploration and Production Company, Decker, MT. Helena, MT. (July 5). DCN 03878.
Mount, David R. et al. 1992. "Use of Laboratory Toxicity Data for Evaluating the
Environmental Acceptability of Produced Water Discharge to Surface Waters." Produced
Water. DCN 03135.
Mount, David R. et al. 1993a. "Discharge of Coalbed Produced Water to Surface Waters -
Assessing, Predicting, and Preventing Ecological Effects." Methane from Coal Seams Monthly.
18-25. (December). DCN 03702.
Mount, David R. et al. 1993b. "Salinity/Toxicity Relationships to Predict the Acute Toxicity of
Produced Waters to Freshwater Organisms." Society of Petroleum Engineers, Inc. SPE 26007.
DCN 03136.
Mount, David R. et al. 1997. "Statistical Models to Predict the Toxicity of Major Ions to
Ceriodaphnia Dubia, Daphina Magna and Pimephales Promelas (Fathead Minnows)." Environ.
Toxicology and Chemistry. 16:2009-2019. DCN 03063.
NMOCD. 2004. New Mexico Oil Conservation Division. In: Proceedings from the Produced
Water Forum in Farmington, NM. (April 1). Available online at: http://octane.nmt.edu/sw-
pttc/proceedings/ProducedWater04Proc/ProceedingsPW.asp. DCN 03879.
NaturalGas.org. 2004. Well Completion. Available online at:
http://www.naturalgas.org/naturalgas/well_completion.asp. Date accessed: August 18, 2006.
DCN 03476.
Northern Alaska Environmental Center. 2006. Coal Bed Methane in Alaska. Available online
at: http://www.northern.org/artman/publish/coalBed.shtml. DCN 03880.
6-24
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Section 6.0 - Coal Bed Methane Subcategory
OGB. 2006. Oil and Gas Board. Number of Wells in Black Warrior Basin. Available online at:
http://www.ogb.state.al.us/. DCN 03981.
O'Farrell, Thomas P., EPA's Industrial Technology Division. Letter to Constance B. Harriman,
Steptoe & Johnson. June 1, 1989. OW-2003-0074, DCN 01191.
Oil & Gas Consulting, Inc. 2002. CBM Producers User Information Survey Results. (January).
DCN 01143. Englewood, CO.
Phelps, Shannon D., James. W. Bauder, Krista E. Pearson. Unknown. Department of Land
Resources and Environmental Sciences, Montana State University-Bozeman. Coal Bed Methane
Ownership and Responsibility: A Summary of Surface, Mineral, and Split-Estate Rights.
Available online at: http://waterquality.montana.edu/docs/methane/splitestate.shtml. DCN
03004.
Pochop, L., K. Warnaka, J. Borrelli, and V. Hasfurther. 1985. Design Information for
Evaporation Ponds in Wyoming. WWRC-85-21. Available online at:
www.wrds.uwyo.edu/library/wrp/85-21/85-21.html. DCN 01140.
Ruckelshaus, William. 2005. Water Production from Coalbed Methane Development in
Wyoming: A Summary of Quantity, Quality, and Management Options. The Ruckelshaus
Institute of Environment and Natural Resources. (December). Available online at:
http://www.uwyo.edu/enr/ienr/CBMWaterFinalReportDec2005.pdf. DCN 03486.
Tietge, Joseph E. et al. "Major Ion Toxicity of Six Produced Waters to Three Freshwater
Species: Application of Ion Toxicity Models and Tie Procedures." Environ. Toxicology and
Chemistry. 16:2002-2008. DCN 03071.
U.S. DOE. 2005. Crude Oil and Natural Gas Development Wells, 1949-2005. Available online
at: http://www.eia.doe.gov/emeu/aer/txt/ptb0407.html. DCN 03459.
U.S. DOE. 2006. Future Supply and Emerging Resources-Coalbed Natural Gas. Available
online at: http://www.netl.doe.gov/technologies/oil-
gas/FutureSupply/CoalBedNG/CoalBed_NG.html. Date accessed: July 12, 2006. DCN 03480.
U.S. EPA. 1976. 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, DC. (September).
U.S. EPA. 1996. 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. (December).
U.S. EPA. 2003. Guidance for Developing Technology-Based Limits for Coalbed Methane
Operations: Economic Analysis of the Powder River Basin. Washington, DC. February.
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Section 6.0 - Coal Bed Methane Subcategory
U.S. EPA. 1993. Coastal Oil and Gas Questionnaire, Parts IVand V, OMB No. 2040-0160.
(July). DCN 04079.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2006. CoalbedMethane Site Visit Report: July 2006, Powder River Basin, WY.
(November 30). DCN 04110.
USGS. 2000. U.S. Geological Survey. Water Produced with Coal-BedMethane. U.S.G.S. Fact
Sheet FS-156-00. (November). DCN 03487.
Veil, John. 2002. Argonne National Laboratory. Regulatory Issues Affecting Management of
Produced Water from Coal Bed Methane Wells. Available online at:
http://www.ead.anl.gov/pub/doc/cbm-prod-water-rev902.pdf. DCN 03450.
Wheaton, John, et al. 2006. Montana Bureau of Mines and Geology. 2005 Annual Coalbed
Methane Regional Ground-water Monitoring Report: Northern Portion of the Powder River
Basin. Open-File Report 538. (Unknown). DCN 03474.
WDEQ. 2002. Wyoming Department of Environmental Quality. Off-channel, Unlined CBM-
produced Water Pit Siting Guidelines for the Powder River Basin. (August 6). DCN 03883.
WDEQ. 2006. Wyoming Department of Environmental Quality. "Coal Bed Methane Permits."
Available online at: http://deq.state.wy.us/wqd/npdes/QLstPermits.asp. DCN 03905.
WOGCC. 2005. Wyoming Oil and Gas Conservation Commission. Coalbed Methane Wells in
the Powder River Basin. Available online at: http://wogcc.state.wy.us/coalbedchart.cfm. DCN
03882.
WOGCC. 2006. Wyoming Oil and Gas Conservation Commission web site. Available online
at: http://wogcc.state.wy.us/. Date accessed: August 18, 2006. DCN 03904.
WYSGS. 2006. Wyoming State Geological Survey. Coalbed Methane Information. Available
online at: http://www.wsgs.uwyo.edu/Coal/CBM_Info.aspx. DCN 03884.
Zimpfer, G.L., E.J. 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
CBM Symposium. Denver, CO: Rocky Mountain Association of Geologists, pp. 183-198. DCN
01190.
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Section 7.0 - Coal Mining
7.0 COAL MINING (40 CFR PART 434)
EPA selected the Coal Mining Category for additional data collection and
analysis because of comments received on the 2006 Preliminary Effluent Guidelines Plan. The
2004 Plan summarizes the results of EPA's previous review of this industry (U.S. EPA, 2004).
This section describes EPA's 2006 annual review of the discharges associated with the Coal
Mining Category.
7.1 Coal Mining Category Background
This subsection provides background on the Coal Mining Category including a
brief profile of the coal mining industry, background on 40 CFR Part 434, and a description of
the Surface Mining Control and Reclamation Act of 1977 (SMCRA).
7.1.1 Coal Mining Industry Profile
The Coal Mining Category includes facilities reporting under SIC industry groups
122: Bituminous Coal and Lignite Mining and 123: Anthracite Mining. Specifically, it includes
the following SIC codes, described below (U.S. Census, 2002):
• 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.
• 1222: Bituminous Coal Underground 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.
• 1231: Anthracite Mining. 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.
7-1
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Section 7.0 - Coal Mining
Table 7-1 lists the three SIC codes with operations in the Coal Mining Category.
The number of coal mining facilities in the PCS and TRI databases accounts for less than 10
percent of the mines recorded in the 2002 U.S. Economic Census. All coal mines discharge their
wastewater directly to surface water, and none discharge to POTWs.
Table 7-1. Number of Facilities in Coal Mining SIC Codes
SIC Code
1221: Bituminous Coal and Lignite, Surface Mining
1222: Bituminous Coal and Lignite, Underground Mining
1231: Anthracite Mining
Total
2002 U.S.
Economic
Census
642
478
0
1120
2002
PCS3
90
18
0
108
2002
TRIb
55
27
0
82
2003
TRIb
64
23
0
87
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v4; TRIReleases2003_v2;
TRIReleases2002_v4.
"Major and minor dischargers.
bReleases to any media.
EPA also obtained information, shown in Table 7-2, on the number of coal mines
and their production from the Office of Surface Mining and Regulatory Enforcement (OSMRE),
a division of the Office of the Interior (OSMRE, 2004). OSMRE provides counts of mine
permits obtained under the SMCRA. In some cases, one mining location may have multiple
SMCRA permits, which is why the mine counts from the 2002 U.S. Economic Census (Table 7-
1) are less than the number of permits tracked by OSMRE (Table 7-2).
Table 7-2. Number of Permitted U.S. Coal Mining Operations and Production in 2004
Mine Type
Surface
Underground
Total
Number of Mine Permits
2048
1105
3,253
Production (Millions of Short Tons)
726
350
1,076
Source: U.S. Coal Production Under the Surface Mining Law for 2004 (OSMRE, 2004).
EPA obtained information on production and production trends from the Energy
Information Administration (EIA), which reports this information by mining region (EIA, 2005).
Table 7-3 presents actual production for 2003 and predicted production for 2004, 2005, 2006,
and 2030. Overall, the EIA predicts a steady increase in coal production by 2030 for the United
States as a whole, with more growth in U.S. coal mining in the west than the east.
7-2
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Section 7.0 - Coal Mining
Table 7-3. U.S. Coal Production in 2003 and Predictions to 2030
(In Millions of Short Tons)
Region
Appalachia
Interior
West
East of the Mississippi
West of the Mississippi
Total
Actual Production
2003
388
146
549
481
603
1083
Predicted Production
2004
403
146
575
497
627
1125
2005
397
155
593
499
646
1145
2006
402
153
611
503
662
1166
2030
412
281
1010
633
1070
1703
Source: Coal Production and Number of Mines by State and Mine Type (EIA, 2005).
7.1.2
40 CFR Part 434
EPA first promulgated ELGs for the Coal Mining Category (40 CFR Part 434) on
October 9, 1985 (50 FR 41305). Table 7-4 presents the eight subcategories for the Coal Mining
ELGs.
Table 7-4. Coal Mining ELGs
Subpart
Subpart A
Subpart B
Subpart C
Subpart D
Subpart E
Subpart F
Subpart G
Subpart H
Subcategory Name
General Provisions
Coal Preparation Plants and Coal
Preparation Plant Associated Areas
Acid or Ferruginous Mine Drainage
Alkaline Mine Drainage
Post-Mining Areas
Miscellaneous Provisions
Coal Remining
Western Alkaline Coal Mining
Type of Limitation Guideline
Definitions and applicability
BPT, BAT, NSPS
BPT, BAT, NSPS
BPT, BAT, NSPS
BPT, BAT, NSPS
Provisions for commingling of waste streams, alternate
effluent limitation for pH, effluent limitations for
precipitation events, procedure and method detection limit
for measurement of settleable solids, and modification of
NPDES permits for new sources
BPT, BAT, BCT, NSPS
BPT, BAT, NSPS
Source: Coal Mining Point Source Category BPT, BAT, BCT Limitations and New Source Performance Standards-
40 CFR Part 434.
The Coal Mining ELGs sets numerical limitations for Subparts A through F, listed
in Table 7-5. The technology basis for these limitations and standards is neutralization, chemical
precipitation, and settling. BAT limitations are the same as BPT limitations.
7-3
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Section 7.0 - Coal Mining
Table 7-5. BPT and BAT Effluent Guidelines for Coal Mining Part 434 Subparts A - F
Parameter
TSS
Settleable Solids3
pH
Iron, Total
Manganese, Totalb
BPT/BAT
30-day Average (mg/L)
35
0.5mL/L
within range of 6 to 9
3.5
2.0
BPT/BAT
Daily Maximum (mg/L)
70
within range of 6 to 9
7.0
4.0
Source: Development Document for Effluent Limitations Guidelines and Standards for the Coal Mining Point
Source Category (U.S. EPA, 1982).
"Limits for settleable solids only apply to Subpart E - Post Mining Areas.
bManganese limits do not apply for Subpart D - Alkaline Drainage Mines.
In addition to the ELGs presented in Table 7-5, Subpart F - Miscellaneous
Provisions contains alternative limitations that apply during catastrophic precipitation events.
These limitations, listed in Table 7-6, 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, the only limitation is that pH remain between 6 and 9.
Table 7-6. Catastrophic Precipitation Event Exemption of 40 CFR Part 434
Parameter
Settleable Solids3
pH
BPT - Daily Maximum
0.5mL/L
within range of 6 to 9
Source: Development Document for Effluent Limitations Guidelines and Standards for the Coal Mining Point
Source Category (U.S. EPA, 1982).
aNo limits on settleable solids when precipitation exceeds the 10-year, 24-hour storm.
For Subpart G - Coal Remining, BPT sets numerical limitations for TSS (35
mg/L), and discharges from remining operations may not exceed pre-existing loading conditions
(baseline loadings) for all other parameters. BAT for Subpart G requires implementation of a
pollution abatement plan. Similarly, for Subpart H, operators must submit and implement a
Sediment Control Plan to maintain sediment discharges at or below premining levels.
7.1.3
Surface Mining Control and Reclamation Act of 1977 (SMCRA)
The ELGs in 40 CFR Part 434 work in concert with SMCRA. The Coal Mining
ELGs apply to discharges from mining areas and do not require reclamation activities such as
regrading and revegetation. Those activities are covered by SMCRA, which is implemented by
OSMRE. Under SMCRA, a permitting process requires mine operators to conduct research to
determine reclamation requirements and obtain bonds to cover reclamation costs before coal
mining can begin.
Mine operators must collect at least one year of baseline surface- and ground-
water monitoring data before applying for a coal mining and reclamation permit under SMCRA.
Permit applicants use these baseline data to generate erosion and sedimentation plans to
7-4
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Section 7.0 - Coal Mining
minimize environmental impacts. Regulatory authorities use these data to perform Probable
Hydrologic Consequences (PHC) evaluations, projecting the hydrologic impacts of the coal
mining and reclamation. Regulators also require protection, mitigation, and rehabilitation plans
as part of the permit application.
Before mining can begin, regulatory authorities must approve the PHC evaluation
and accompanying plans. Under SMCRA, if authorities predict that acid mine drainage will
result from the proposed mine, then a permit is not granted. Authorities also require coal mine
operators to submit bonds that cover the estimated costs of reclaiming and restoring disturbed
areas. Bonds are required in case the operator forfeits the mine before it has been reclaimed.
Authorities review permits, require renewals, and inspect mine activities throughout the life of
the mine, to ensure the use of proper erosion and sedimentation control, treatment of mine
drainage, mitigation, and rehabilitation.
7.2 Coal Mining Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Coal Mining
Category including the screening-level review and category-specific review.
7.2.1 Coal Mining Category 2005 Screening-Level Review
Table 7-7 presents the Coal Mining Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2. The PCS and TRI databases contain data from
approximately only 10 percent of the mines; therefore, the 2005 screening-level analysis of these
data does not reflect national discharges.
Table 7-7. Coal Mining Category 2005 Screening-Level Review Results
Point Source Category
Coal Mining
2002 PCS TWPEa
3,116
2002 TRI TWPEb
1,908
Total TWPE
8,024
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005); PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
7.2.2 Coal Mining Category 2005 Pollutants of Concern
EPA did not identify any pollutants of concern, in terms of TWPE, in the 2005
annual review of the Coal Mining Category. Commenters have raised concerns over manganese,
not because of its toxic-weighted load, but because of the associated expense for its treatment
and removal, especially in discharges from mines that closed long ago.
7.3 Coal Mining Category Potential New Subcategories
EPA did not identify any potential new subcategories for the Coal Mining
Category.
7-5
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Section 7.0 - Coal Mining
7.4 Coal Mining Category 2006 Annual Review
EPA received public comments from states, industry, and a public interest group
on the 2006 Preliminary Plan. These comments urged EPA to consider revisiting the manganese
limitations in 40 CFR Part 434. The state and industry commenters requested that EPA study
whether additional flexibility is warranted with these manganese limitations (EPA-HQ-OW-
2004-0032-1049, 1055, 1062, 1075, 1091, 1101). The public interest group commented that
EPA should start a rulemaking and promulgate more stringent limitations for manganese, other
metals, and other dissolved inorganic pollutants (e.g., chlorides, sulfates, TDS) (EPA-HQ-OW-
2004-0032-1075).
The state and industry commenters cited the following factors in support of their
comments: (1) new, more stringent coal mining reclamation bonding requirements on post-
closure discharges; (2) relatively low toxicity of manganese to aquatic communities as compared
to other toxic metals in the coal mining discharges; and (3) complications associated with
chemical precipitation to treat manganese, especially after a mine is closed. The public interest
group referenced a study by EPA Region 5 on potential adverse impacts of the discharge of
sulfates on aquatic life (OW-2004-0032-DCN 03852, 03853, 03854, and 03855). Table 2-1 in
Section 2.0 of this report summarizes all comments received on the 2006 Preliminary Plan,
including those related to the Coal Mining Category.
7.5 Coal Mining Category Conclusions
At this time, EPA does not have sufficient information to evaluate the merits of
the factors cited by commenters. However, because of the potential for revised ELGs to
encourage proper wastewater treatment, EPA will conduct a detailed study of the Coal Mining
ELGs in the 2007/2008 planning cycle. EPA will focus on issues related to manganese limits
and pollutants not currently regulated by the existing regulations. EPA will reevaluate these
effluent guidelines taking into account, among other things, treatment technologies, toxicity of
discharges, cost impacts to the industry, and bonding requirements.
7.6 Coal Mining Category References
EIA. 2005. Energy Information Administration. Coal Production and Number of Mines by
State and Mine Type. Available online at: www.eia.doe.gov/cneaf/coal/page/acr/tablel.html.
Date accessed: April 2006. DCN 03863.
OSMRE. 2004. U.S. Department of Interior, Office of Surface Mining and Regulatory
Enforcement. U.S. Coal Production Under the Surface Mining Law for 2004. Available online
at: http://www.osmre.gov/coal/2004coal.htm. Date accessed: April 2006. DCN 03982.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1982. Development Document for Effluent Limitations Guidelines and Standards for
the Coal Mining Point Source Category. EPA-440/1-82/009. Washington, DC. (June).
7-6
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Section 7.0 - Coal Mining
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2005. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
7-7
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Section 8.0 - Fertilizer Manufacturing
8.0 FERTILIZER MANUFACTURING (40 CFR PART 418)
EPA selected the Fertilizer Manufacturing Category for additional data collection
and analysis because of the high TWPE identified in the 2005 screening-level review (see Table
V-l, 70 FC 51050, August 29, 2005). The 2004 Plan summarizes the results of EPA's previous
review of this industry (U.S. EPA, 2004). This section summarizes the 2005 annual review and
also describes EPA's 2006 annual review of the discharges associated with the Fertilizer
Manufacturing Category. EPA's 2006 annual review builds on the 2005 annual review. EPA
focused on discharges of fluoride from three facilities in the Phosphate Subcategory, because of
their high TWPE relative to the rest of the Fertilizer Manufacturing Category.
8.1 Fertilizer Manufacturing Category Background
This subsection provides background on the Fertilizer Manufacturing Category
including a brief profile of the fertilizer manufacturing industry and background on 40 CFR Part
418. Additional background on the Fertilizer Manufacturing Category can be found in the 2004
Technical Support Document (U.S. EPA, 2004).
8.1.1 Fertilizer Manufacturing Industry Profile
The fertilizer manufacturing industry includes facilities that produce phosphorus-
and nitrogen-based fertilizers (U.S. EPA, 2005b). Facilities subject to this category typically
report under SIC codes 2873: Nitrogenous Fertilizers, 2874: Phosphatic Fertilizers, and 2875:
Fertilizers, Mixing Only (U.S. EPA, 2005b). Because there may be an overlap for facilities
reporting SIC code 2874: Phosphatic Fertilizers between the Fertilizer Manufacturing Category
and the Phosphate Manufacturing Category, during the 2004 screening-level review, EPA
reviewed operations at the top dischargers reporting SIC code 2874 and determined which
category was most appropriate for their operations (U.S. EPA, 2004). Table 8-1 presents the
findings for facilities reporting SIC code 2874 that EPA identified as subject to the Fertilizer
Manufacturing ELGs.
Table 8-2 lists the three SIC codes with operations in the Fertilizer Manufacturing
Category. Because the U.S. Economic Census reports data by NAICS code, and TRI and PCS
report data by SIC code, EPA reclassified the 2002 U.S. Economic Census data by equivalent
SIC code. The facilities in SIC code 2874 that are possibly subject to the Fertilizer
Manufacturing ELGs do not correlate directly to a NAICS code, and therefore EPA could not
determine the number of facilities in the 2002 U.S. Economic Census for SIC code 2874.
8-1
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Section 8.0 - Fertilizer Manufacturing
Table 8-1. Top Facilities Reporting Under SIC Code 2874
Facility
(Location)
Final Category
Designation in
2004 Screening
Level Review
Description
IMC Phosphates
Uncle Sam
(Uncle Sam, LA)a
Phosphate
Category
Manufactures phosphoric acid and hydrofluoric acid (covered by 40
CFR Part 422 Subpart C - Phosphate Subcategory) and sulfuric acid
by burning elemental sulfur (covered by 40 CFR Part 418 Subpart A
- Phosphate Subcategory). Estimated that 99% of facility's
discharges are from operations subject to Part 422.
IMC Phosphates
Faustina
(Faustina, LA)
Fertilizer
Category
Manufactures ammonia, diammonium phosphate, and
monoammonium phosphate from wet-process phosphoric acid
produced at IMC Phosphates Uncle Sam (covered by 40 CFR Part
418 Subpart A). Previously manufactured wet-process phosphoric
acid.
Mississippi
Phosphates
(Pascagoula, MS)
Fertilizer
Category
Manufactures sulfuric acid, wet-process phosphoric acid, and
diammonium phosphate (covered by 40 CFR Part 418 Subpart A).
Royster-Clark Inc.
(Hartsville, SC)
Fertilizer
Category
Purchases liquids, such as sulfuric acid and wet-process phosphoric
acid, and other by-products and combines them in a rotary drum
(covered by 40 CFR Part 418 Subpart G).
Source: Water Discharge Permit for NPDES LA0029769 - IMC Phosphates Company, Faustina Plant, St. James,
LA (LDEQ, 2004a); Technical Support Document for the 2004 Effluent Guidelines Program Plan (U.S. EPA,
2004).
"During the 2006 annual review, EPA reviewed IMC Phosphates Uncle Sam facility's permit and determined the
facility discharges are regulated by 40 CFR Part 418 Fertilizer Manufacturing, as discussed in Section 8.5.4.
Table 8-2. Number of Facilities in Fertilizer Manufacturing SIC Codes
SIC Code
2873 : Nitrogen Fertilizers
2874: Phosphatic Fertilizers'
2875: Fertilizers, Mixing Only
Total
2002 U.S. Economic
Census
143
NAd
542
>685
2002 PCS3
40
1
5
46
2002 TRIb
61
2
57
120
2003 TRIb
52
3
57
112
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRlReleases2002_v2;
TRIReleases2003_v2.
aMajor and minor dischargers.
bReleases to any media.
Includes only facilities with known discharges subject to the Fertilizer Manufacturing ELGs. During the 2004 and
2005 annual reviews, EPA classified IMC Phosphates Uncle Sam as subject to the Phosphate Manufacturing
Category, so this facility is not included in the 2002 TRI and PCS counts. However, after permit review, EPA
determined the discharges should be included in the Fertilizer Manufacturing Category for the 2006 annual review,
discussed in Section 8.5.4.
dPoor bridging between NAICS and SIC codes. Number of facilities could not be determined.
NA - Not applicable.
8-2
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Section 8.0 - Fertilizer Manufacturing
Fertilizer manufacturing facilities discharge directly to surface water as well as to
POTWs. Table 8-3 presents the types of discharges reported by facilities in the 2002 TRI
database. The majority of facilities reporting to TRI reported no water discharges, but facilities
may be discharging pollutants in wastewater at levels below the TRI-reporting thresholds.
Of the fertilizer manufacturing facilities with wastewater discharges, most discharge directly to
surface water.
Table 8-3. Fertilizer Manufacturing Category Facilities by Type of Discharge Reported in
TRI 2002
SIC Code
2873 : Nitrogen Fertilizers
2874: Phosphatic Fertilizers3
2875: Fertilizers, Mixing Only
Reported Only
Direct
Discharges
33
2
7
Reported Only
Indirect
Discharges
3
0
1
Reported Both Direct
and Indirect
Discharges
2
1
0
Reported No
Water
Discharges
23
0
49
Source: TRIReleases2002_v4.
Includes only facilities with known discharges subject to the Fertilizer Manufacturing ELGs. During the 2004 and
2005 annual reviews, EPA classified IMC Phosphates Uncle Sam as subject to the Phosphate Manufacturing
Category, so this facility is not included in the 2002 TRI and PCS counts. However, after permit review, EPA
determined the discharges should be included in the Fertilizer Manufacturing Category for the 2006 annual review,
discussed in Section 8.5.4.
8.1.2
40 CFR Part 418
EPA first promulgated ELGs for the Fertilizer Manufacturing Category (40 CFR
Part 418) on April 8, 1974 (39 FR 12836) for the Basic Fertilizer Chemicals Segment and on
January 14, 1975 (40 FR 2652) for the Formulated Fertilizer Chemicals Segment. The Fertilizer
Manufacturing ELGs are applicable to process wastewater and contaminated nonprocess
wastewater discharged from the specific subcategories lists in Table 8-4. The seven
subcategories are based on the type of fertilizer produced (U.S. EPA, 2005b). Discussion of the
pollutants regulated for each subcategory can be found in Table 5-25 of the 2004 TSD (U.S.
EPA, 2004).
8-3
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Section 8.0 - Fertilizer Manufacturing
Table 8-4. Subcategories in the Fertilizer Category
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
Related SIC Code(s)
2874: Phosphatic
Fertilizers
2873 : Nitrogenous
Fertilizers
2873 : Nitrogenous
Fertilizers
2873 : Nitrogenous
Fertilizers
2873 : Nitrogenous
Fertilizers
2873 : Nitrogenous
Fertilizers
2875: Fertilizers,
Mixing Only
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 ammonium 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 mixed3 and blendb fertilizer.
Source: Fertilizer Manufacturing Point Source Category - 40 CFR Part 418', Preliminary Review of Prioritized
Categories of Industrial Dischargers (U.S. EPA, 2005b).
aMixed 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."
bBlend fertilizer means "a mixture of dry, straight and mixed fertilizer materials."
8.2
Fertilizer Manufacturing Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Fertilizer
Manufacturing Category including the screening-level review and category-specific review.
8.2.1
Fertilizer Manufacturing 2005 Screening-Level Review
Table 8-5 presents the NFMM Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 8-5. Fertilizer Manufacturing Category 2005 Screening-Level Review Results"
Rank
11
Point Source Category
Fertilizer Manufacturing
2002 PCS TWPEb
143,795
2002 TRI TWPEC
6,403
Total TWPE
150,198
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
""Excludes discharges from IMC Phosphates Uncle Sam. These discharges were excluded from the category because
EPA determined the discharges were subject to the Phosphate Manufacturing Category (U.S. EPA, 2004).
However, after permit review, EPA determined the discharges should be included in the Fertilizer Manufacturing
Category for the 2006 annual review, discussed in Section 8.5.4.
bDischarges include only major dischargers.
Discharges include transfers to POTWs and account for POTW removals.
8-4
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Section 8.0 - Fertilizer Manufacturing
8.2.2
Fertilizer Manufacturing Category 2005 Pollutants of Concern
Table 8-6 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. The top five pollutants account for approximately 99 percent of the TRI and
PCS 2002 combined TWPE. Fluoride contributed 74 percent of the combined 2002 TRI and
PCS TWPE.
Table 8-6. 2005 Annual Review: Fertilizer Manufacturing Category Pollutants of Concern
Pollutant
Fluoride
Aluminum
Nitrate
Ammonia
Cadmium
Dioxin and Dioxin-
Like Compounds
Chlorine
Copper and Copper
Compounds
Ammonia
Atrazine
Fertilizer Category
Total
2002 PCSa'b
Number of
Facilities
Reporting
Pollutants
3
1
13
21
1
Total
Pounds
Released
3,157,912
168,191
1,631,915
4,189,153
267
TWPE
110,527
10,880
9,139
6,306
6,172
Pollutants are not in the top five PCS
2002 reported pollutants.
24
540,486,797
143,795
2002 TRTC
Number of
Facilities
Reporting
Pollutants
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI 2002
reported pollutants.
2
9
11
42
1
48
0.008
2,880
1,383
396,220
186
4,980,379
2,288
1,467
878
596
429
6,403
Source: TRIReleases2002_v2; PCSLoads2002_v2.
""Excludes discharges from IMC Phosphates Uncle Sam. These discharges were excluded from the category because
EPA determined the discharges were subject to the Phosphate Manufacturing Category (U.S. EPA, 2004).
However, after permit review, EPA determined the discharges should be included in the Fertilizer Manufacturing
Category for the 2006 annual review, discussed in Section 8.5.4.
bDischarges include only major dischargers.
Discharges include transfers to POTWs and account for POTW removals.
8.3
Potential New Subcategories for the Fertilizer Manufacturing Category
EPA did not identify any potential new subcategories for the Fertilizer
Manufacturing Category.
8-5
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Section 8.0 - Fertilizer Manufacturing
8.4 Fertilizer Manufacturing Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Fertilizer Manufacturing Category. EPA obtained
additional data and identified:
• Facility classified in the wrong category; and
• Changes in estimates of TWPE for nitrite compounds, nitrate, and
chlorine.
8.4.1 Fertilizer Manufacturing Category Facility Classification Revisions
During the 2004 annual review, EPA contacted the IMC Phosphates Uncle Sam
facility to determine the applicable point source category. IMC Phosphates Uncle Sam produces
sulfuric acid by burning sulfur, and then uses the sulfuric acid to produce phosphoric acid,
defluorinated phosphoric acid, and hydrofluoric acid. The facility confirmed their operations
were included in SIC code 2874 (Oliver, 2003). Based on this information, EPA determined that
the IMC Phosphates Uncle Sam facility discharges were not subject to the Fertilizer
Manufacturing ELGs, but rather were subject to the Phosphate Manufacturing ELGs because the
manufacture of defluorinated phosphoric acid is covered by the Phosphate Manufacturing ELGs.
For the 2005 annual review, EPA continued classifying the IMC Phosphates Uncle Sam facility
as subject to the Phosphate Manufacturing Category. As part of the 2006 annual review,
however, EPA obtained the permit for IMC Phosphates Uncle Sam facility. The permit
identifies IMC Phosphates Uncle Sam facility as a phosphatic fertilizer manufacturing facility
subject to the Fertilizer Manufacturing Category (LDEQ, 2003). As a result, EPA revised its
category designation for this facility and has now included its discharges in the Fertilizer
Manufacturing Category.
8.4.2 Fertilizer Manufacturing Category TWF and POTW Percent Removal
Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, EAD
revised the TWF used for nitrate and nitrate compounds in the TRI and PCS databases to better
reflect the pollutant's properties. The TWF that EAD now applies for nitrate and nitrate
compounds are 0.0032 and 0.000062, respectively (formerly 0.0056 and 0.000747, respectively).
EAD also revised the POTW percent removal value for chlorine to 100 percent (formerly 1.87
percent). Table 8-7 presents the loads before and after corrections to the TWF for nitrate
compounds and nitrate as N and the POTW percent removal for chlorine for the Fertilizer
Manufacturing Category.
8-6
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Section 8.0 - Fertilizer Manufacturing
Table 8-7. Impact of Changes to TWF and POTW Percent Removal for the Fertilizer
Manufacturing Category
Database
TRI 2002
PCS 2002
TRI 2002
Pollutant
Nitrate Compounds
Nitrate as N
Chlorine
Number of Facilities
Reporting Discharges
32
13
9
TWPE from 2005
Review
276
9,139
1,467
TWPE from 2006
Review
3,323
5,222
1,373
Sources: TRIReleases2002_v2; TRIReleases2002_v4; PCSLoads2002_v2; PCSLoads2002_v4.
8.4.3
Fertilizer Manufacturing Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings described in Section 4.2, based on methodology changes described in Section 4.2 and
changes made based on permit review. For the Fertilizer Manufacturing Category, the most
significant changes are also described in Section 8.4.1 and 8.4.2. Table 8-8 shows the 2006
screening-level TWPE estimated for the Fertilizer Manufacturing Category from the 2002 and
2003 TRI and 2002 PCS databases. The TRI TWPE from the 2005 and 2006 screening-level
reviews are similar, but the PCS TWPE from the 2006 screening-level review greatly exceeds
that estimated at the time of the 2005 screening-level review. This is largely due to the change in
category designation for the IMC Phosphates Uncle Sam facility.
Table 8-8. Fertilizer Manufacturing Category 2006 Screening-Level Review Results3
Point Source Category
Fertilizer Manufacturing
2002 PCS TWPEb
1,369,762
2002 TRI TWPEC
9,062
2003 TRI TWPEC
10,268
Source: TRIReleases2003_v4; TRIReleases2002_v4;PCSLoads2002_v4.
Includes discharges from IMC Phosphates Uncle Sam. These discharges were excluded from the 2005 annual
category review because EPA determined the discharges were applicable to the Phosphate Manufacturing Category
(U.S. EPA, 2004). However, after permit review in 2006, EPA determined the discharges should be included in the
Fertilizer Manufacturing Category for the 2006 annual review, discussed in Section 8.5.4.
bDischarges include only major dischargers.
Discharges include transfers to POTWs and account for POTW removals.
8.4.4
Fertilizer Manufacturing Category 2006 Pollutants of Concern
Table 8-9 presents the pollutants of concern for the Fertilizer Manufacturing
Category based on the 2006 annual review. Because fluoride discharges contribute
approximately 98 percent of the combined TWPE from PCS and TRI, EPA focused its remaining
study of this industry on fluoride discharges.
8-7
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Section 8.0 - Fertilizer Manufacturing
Table 8-9. 2006 Annual Review: Fertilizer Manufacturing Category Pollutants of Concern
Pollutant
Fluoride
Aluminum
Cadmium
Nitrate Total (as N)
Ammonia
Nitrate Compounds
Dioxin and Dioxin-
like Compounds
Chlorine
Copper and Copper
Compounds
Ammonia
Fertilizer
Manufacturing
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
4
1
1
13
21
Total
Pounds
Released
38,348,483
168,191
267
1,631,915
4,189,153
TWPE
1,342,197
10,880
6,172
5,222
4,650
Pollutants are not in the top five PCS 2002
reported pollutants.
24
624,125,300
1,369,762
2002 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI
2002 reported pollutants.
32
2
9
11
42
49
4,450,361
0.0080
2,697
1,382
396,219
4,980,784
3,323
2,288
1,373
878
440
9,062
2003 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI 2003
reported pollutants.
33
2
10
10
40
49
4,402,180
0.0093
2,846
1,138
727,893
5,276,210
3,287
2,658
1,449
722
808
10,268
oo
I
oo
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
-------
Section 8.0 - Fertilizer Manufacturing
8.5
Fertilizer Manufacturing Category 2006 Top Discharging Facilities
The PCS discharges account for approximately 99 percent of the combined TRI
and PCS TWPE for 2002. The additional review of the Fertilizer Manufacturing Category
focuses on discharges reported to PCS in 2002. Table 8-10 lists the facilities that contribute over
99 percent of the overall Fertilizer Manufacturing Category TWPE. The vast majority of the
TWPE contributed by these facilities is a result of fluoride discharges. Fluoride is generated in
the manufacture of wet-process phosphoric acid that is used in phosphatic fertilizer
manufacturing (U.S. EPA, 1974). This subsection provides a process description for wet-process
phosphoric acid manufacturing, discusses the wastewater sources of fluoride, wastewater
treatment of fluoride, and presents additional information about the top discharging facilities.
Table 8-10. 2006 Annual Review: Fertilizer Manufacturing Category Top Discharging
Facilities in PCS
Facility Name
IMC Phosphates
Uncle Sam
IMC Phosphates
Faustina
Mississippi
Phosphates
Corporation
Facility Location
Uncle Sam, LA
Donaldsonville,
LA
Pascagoula, LA
Products
Wet-process
Phosphoric Acid
Ammonia, DAP
and MAP using
Phosphoric Acid
from Uncle Sam
Sulfuric Acid,
Phosphoric Acid,
DAP
Top
Pollutant
Discharged
Fluoride
Fluoride
Fluoride
Total Pounds
Discharged
83,638,502
6,791,067
14,720,096
Total
TWPE
1,231,795
81,571
47,286
Percentage of
Fertilizer
Manufacturing
Category PCS
2002 TWPE
89.9%
6.0%
3.5%
Source: PCSLoads2002_v4.
MAP - Monoammonium phosphate (NH4H2PO4).
DAP - Diammonium phosphate ((NH4)2HPO4).
8.5.1
Wet-Process Phosphoric Acid Process Description
In the wet process, phosphate rock is reacted with sulfuric acid and water to
produce phosphoric acid and gypsum. The reaction is as follows:
3 Ca3(PO4)2 (s) + 9 H2SO4 (1) + 18 H2O (1) -» 6 H3PO4 (1) + 9 CaSO4»2 H2O (s)
Phosphate rock + sulfuric acid + water -> phosphoric acid + gypsum
The product phosphoric acid and gypsum solution are mechanically filtered to remove particulate
gypsum. Each pound of phosphoric acid produced generates five pounds of gypsum by-product
(U.S. EPA, 1974).
The phosphoric acid contains between 26 and 30 percent phosphorous oxide
(P2Os) and must be concentrated for sale as phosphoric acid or processed for a final fertilizer
product. The phosphoric acid is concentrated using water evaporation units, which also
volatilize impurities, such as fluoride, and small fractions of the phosphoric acid. The volatilized
8-9
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Section 8.0 - Fertilizer Manufacturing
water, impurities, and phosphoric acid are condensed and sent to wastewater treatment (U.S.
EPA, 1974).
The concentrated phosphoric acid is clarified to remove any solid impurities
before sale or further processing for fertilizer. The fertilizer products manufactured using
phosphoric acid are:
• Manufacture of triple superphosphates (Ca(H2PO4)2»H2O) by reacting the
phosphoric acid with additional phosphate rock and water;
• Manufacture of granular triple superphosphate (Ca(H2PO4)2»H2O) by
reacting lower concentration phosphoric acid with phosphate rock and
evaporating the water to form granules; and
• Manufacture of ammonium phosphates (NH^PC^ or (NH^HPO/t) by
reacting phosphoric acid with ammonia and evaporating the water to form
granules (U.S. EPA, 1974).
8.5.2 Wastewater Sources of Fluoride
The phosphate rock is not a pure compound, but a fluorapitite mineral containing
impurities of fluoride, iron, aluminum, silica, and uranium. The fluoride impurities evolve into
gaseous silicon tetrafluoride (SiF4) or gaseous hydrofluoric acid (HF) throughout the
manufacture of phosphoric acid and the processing of phosphoric acid into triple
superphosphates. The gaseous fluoride compounds are collected in a wet scrubber unit,
generating fluoride-contaminated wastewater. Additional fluoride remains in the gypsum by-
product as a variety of fluoride compounds. The gypsum is combined with contaminated
wastewater and pumped to a storage and disposal area. Wastewater is also generated from
stormwater drainage from the storage and disposal area (U.S. EPA, 1974).
8.5.3 Wastewater Treatment of Fluoride
The basis for the existing BAT ELGs is a two-stage chemical precipitation
process using lime to address pH, fluoride, and phosphorous. This treatment emerged in the
industry in the early 1960s and is commonly used at facilities that manufacture phosphorous-
based fertilizers. It increases the pH of contaminated water to between 3.5 and 4.0 in the first
stage. The following reaction occurs in the first stage of the liming process to remove the
majority of the fluoride:
H2SiF6 + 3 CaO + H2O -» 3 CaF2 (s) + 2 H2O + SiO2
fluosilicic acid + lime + water -> calcium fluoride + water + silicia
After adequate settling time, the wastewater contains 30-60 mg/L fluoride and up to 5,500 mg/L
phosphorous. The second stage of the liming process raises the pH to between 6.0 and 9.0 to
primarily remove the phosphorous compounds. The reaction that occurs in the second stage of
the liming process is:
8-10
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Section 8.0 - Fertilizer Manufacturing
H3PO4 + CaO -» CaHPO4 (s) + H2O
phosphoric acid + lime -^ dicalcium phosphate + water
The second stage also removes some additional fluoride. Precipitation of calcium fluoride and
dicalcium phosphate reduces the concentration of fluoride to 15 mg/L or less and phosphorous to
10 to 40 mg/L (U.S. EPA, 1974). Current technologies are achieving fluoride concentrations at
least as effective, sometimes achieving 2 mg/L effluent fluoride. The chemical precipitation has
improved by using calcium chloride (CaCl2) rather than lime, while solids separation has
improved by using polymers and membrane filters (WC&E, 2006; Ionics, Unknown; GCIP,
2002).
8.5.4 Top Facility Permit Compliance
All of the top facilities in the Fertilizer Manufacturing Category are phosphate
fertilizer manufacturers and are potentially subject to 40 CFR Part 418 Subpart A - Phosphate
Subcategory. Subpart A BAT includes limits on flow-based surge capacity and pollutant
discharge concentrations. The flow-based requirements are:
• Zero discharge of wastewater except from the gypsum storage and
disposal area;
• Maintenance of a surge capacity for a 10-year, 24-hour storm event (BPT)
or a 25-year, 24-hour storm event (BAT) in the gypsum storage and
disposal area;
• If stored wastewater reaches 50 percent of the required surge capacity, the
facility is allowed to discharge treated wastewater;
• If stored wastewater exceeds 50 percent of the required surge capacity, the
facility is required to discharge treated wastewater; and
• During discharge events, facilities are required to meet limitations for
phosphorous, fluoride (25 mg/L monthly average and 75 mg/L daily
maximum), total suspended solids, and pH (U.S. EPA, 1974).
Facilities minimize the volume of wastewater discharged by impounding and
recirculating all direct contact process wastewater, including stormwater runoff from active
gypsum storage and disposal areas. This recirculation leads to an accumulation of fluoride,
phosphorous, and radium in the wastewater with concentrations in excess of 8,500 mg/L
fluoride, 5,000 mg/L phosphorous, and 60 pCi/L radium 226. Additionally, the wastewater is
typically very acidic, between a pH of one to two. Several facilities report that they have not
treated or discharged wastewater for several years. For the 1974 rulemaking, EPA determined
that most facilities would discharge continuously between two and four months of the year (U.S.
EPA, 1974).
8-11
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Section 8.0 - Fertilizer Manufacturing
The applicability of Subpart A excludes certain wet-process phosphoric acid
processes from BPT, BAT, and BCT limitations that were under construction either on or before
April 8, 1974, at plants located in the state of Louisiana. As a result, the IMC Phosphates Uncle
Sam and Faustina facilities are excluded from Subpart A. Permit writers limit discharges from
these facilities using best professional judgment (BPJ) (see 52 FR 28428, July 29, 1987). For
some portion of the discharges from the IMC Phosphates Uncle Sam and Faustina facilities, BPJ
permits incorporate Subpart A requirements (see Table 8-12). All discharges from Mississippi
Phosphates Corporation are permitted based on Subpart A (MDEQ, 2002a; MDEQ, 2002b).
Table 8-11 presents the fluoride discharges reported to PCS in 2002 by outfall and
the corresponding fluoride permit limit for the top three fertilizer manufacturing facilities and the
calculated fluoride discharge based on the permit limits. Table 8-12 presents the discharge flow
restrictions included in each facility's permit.
Table 8-11. Fertilizer Manufacturing Category, Top Fluoride Outfalls
Name
IMC
Phosphates
Uncle Sama
IMC
Phosphates
Faustina
Mississippi
Phosphates
Corporation
Outfall with Fluoride
Discharges
001: Once-through cooling
water, scrubber water, non-
process wastewater, fertilizer
area stormwater, inactive
gypsum storage area, and
active gypsum storage area
001: Active gypsum storage
area, process wastewater,
stormwater, nonprocess
wastewater, and noncontact
cooling water
002: Inactive gypsum storage
area
001 : Noncontact cooling
water and stormwater
Pounds of
Fluoride
Discharged
35,190,572
105,272
1,737,420
1,304,595
TWPE of
Fluoride
Discharges
1,231,670
3,685
60,810
45,661
Permit Limits
Limits for outfall 001
excluding inactive and active
gypsum storage area
discharges:
165.0 Ib/day monthly
average
222.8 Ib/day daily maximum
25 mg/L monthly average
75 mg/L daily maximum
Monitor and report fluoride
discharges
292 Ib/day monthly average
876 Ib/day daily maximum;
based on:
25 mg/L monthly average
75 mg/L daily maximum
Calculated
Maximum
Pounds of
Fluoride Using
Permit Limits
81,322b
131,636C
NA
319,740b
Source: Facility Permits (LDEQ, 2003; LDEQ, 2004a; LDEQ, 2004b; MDEQ, 2002a; MDEQ, 2002b); PCSLoads2002_v4.
aPounds of fluoride using permit limits cannot be calculated because fluoride is not limited for outfall 002.
bPounds of fluoride calculated using the daily maximum fluoride Ib/day permit limit and 365-day per year discharge.
°Pounds of fluoride calculated using the daily maximum fluoride mg/L permit limit, 365-day per year discharge, and the 30-day
maximum flow 7.01 MOD flow (LDEQ, 2004b).
NA - Not applicable. The pounds of fluoride cannot be calculated using the permit limits since flow data are not available.
8-12
-------
Section 8.0 - Fertilizer Manufacturing
Table 8-12. Fertilizer Manufacturing Category, Permit Flow Requirements
Name
IMC Phosphates
Uncle Sanf
IMC Phosphates
Faustina
Mississippi
Phosphates
Corporation13
Permit Findings
Acknowledges exemption of flow requirements; portion of gypsum storage and disposal are
designated inactive; stormwater from inactive storage and disposal area discharged without
treatment; PDF granted to exempt facility from recycling process wastewater by installing
fluoride scrubber; gypsum storage area must meet BAT requirements; optional discharge of
treated wastewater below 50% surge capacity; required discharge of treated wastewater
above 50% storage capacity.
No acknowledgement of exemption of flow requirements; no discharge of process
wastewater; gypsum storage area must meet BAT requirements; optional discharge of
treated wastewater below 50% surge capacity; required discharge of treated wastewater
above 50% storage capacity.
Gypsum storage area must meet BAT requirements; optional discharge of treated
wastewater below 50% surge capacity; required discharge of treated wastewater when
above 50% surge capacity.
Source: Facility Permits (LDEQ, 2003; LDEQ, 2004a; LDEQ, 2004b; MDEQ, 2002a; MDEQ, 2002b);
PCSLoads2002_v4.
""Facility permit includes mass-based fluoride limitations (165.0 Ib/day monthly average, 222.8 Ib/day daily
maximum) for one outfall based on fluoride removal efficiency of the scrubber.
bFacility permit includes mass-based fluoride limitations that were calculated using the ELGs concentrations and the
facility flow rates, as provided in the Permit Rationale (MDEQ, 2002a).
PDF - Fundamentally different factors variance.
IMC Phosphates Uncle Sam reported over 35 million pounds of fluoride to PCS
in 2002; however, using their daily maximum fluoride permit limit and 365 days of discharge,
the facility should only discharge 81,322 pounds of fluoride per year. Mississippi Phosphates
Corporation reported over 1.3 million pounds of fluoride to PCS in 2002; however, using their
daily maximum fluoride permit limit and 365 days of discharge, the facility should only
discharge 319,740 pounds of fluoride per year. Both facilities appear to be exceeding their mass-
based permit limits for fluoride.
IMC Phosphates Faustina reported over 105,000 pounds of fluoride to PCS in
2002; the estimated fluoride discharge using the daily maximum fluoride permit limit and
maximum flow of 7.01 MGD for outfall 001 is 131,636 pounds of fluoride per year (LDEQ,
2004b). The fluoride concentrations that IMC Phosphates Faustina reported from 2002 through
2005 for outfall 001 are within the permitted limits. The estimated fluoride discharge for outfall
002 cannot be calculated since the discharge is not limited. The fact sheet for this facility listed
an estimated discharge of 2.464 MGD intermittently from outfall 002, which is potentially
contaminated stormwater runoff from the inactive calcium sulfate storage pile and is not treated
prior to discharge. The fluoride concentrations from this outfall range from 233 mg/L to 1,116
mg/L, far greater than the treatable concentrations reported in the 1974 Development Document
(U.S. EPA, 1974).
8-13
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Section 8.0 - Fertilizer Manufacturing
8.6 Fertilizer Manufacturing Conclusions
• Previously, EPA identified IMC Phosphates Uncle Sam as subject to the
Phosphate Manufacturing ELGs. After reviewing the facility's permit,
EPA determined that this facility is subject to the Fertilizer Manufacturing
ELGs.
• For the 2006 screening-level review, the high TWPE ranking for the
Fertilizer Manufacturing Category is from fluoride dischargers from three
facilities manufacturing phosphate-based fertilizer from wet-process
phosphoric acid. One facility, IMC Phosphates Uncle Sam, contributes
over 92 percent of the Fertilizer Manufacturing Category fluoride TWPE
reported to PCS in 2002.
• 40 CFR Part 418 regulates fluoride discharges from operations in the
Phosphate-Based Fertilizer Subcategory, requiring zero discharge except
during certain storm events, and treatment of fluoride discharges to 25
mg/L (monthly average) and 75 mg/L (daily maximum).
• High fluoride discharges are from three facilities: IMC Phosphates Uncle
Sam, Mississippi Phosphates Corporation, and IMC Phosphates Faustina.
All three are report continuous, 12-month discharges.
• IMC Phosphates Uncle Sam is exempt from Subpart A, so the permit is
based on BPJ but includes fluoride limits. The facility appears to be
exceeding their fluoride limits.
• Mississippi Phosphates Corporation's permit is based on Subpart A. The
facility appears to be exceeding their fluoride limits.
• IMC Phosphates Faustina is exempt from Subpart A, so the permit is
based on BPJ but includes fluoride limits, monitoring, and reporting
requirements. Fluoride discharges from outfall 001 are within the
permitted limits. Fluoride discharges from outfall 002 are not limited, but
monitored and reported at concentrations greater than the treatable
concentrations reported in the 1974 Development Document (U.S. EPA,
1974).
8.7 Fertilizer Manufacturing References
GCIP. 2002. General Chemical Industrial Products. Chapter 14 - Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. Date accessed:
July 27, 2006. DCN 03761.
Ionics. Unknown. "The EnChem® Process for Fluoride Removal." Wastewater Treatment for
the Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf Date accessed: July 27, 2006. DCN 03760.
8-14
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Section 8.0 - Fertilizer Manufacturing
LDEQ. 2003. Louisiana Department of Environmental Quality. Office of Environmental
Services Water Discharge Permit and Fact Sheet NPDES LA0004847 - IMC Phosphates
Company Uncle Sam Plant, Uncle Sam, LA. Baton Rouge, LA. (June 16). DCN 02764.
LDEQ. 2004a. Louisiana Department of Environmental Quality. Water Discharge Permit for
NPDES LA0029769 - IMC Phosphates Company, Faustina Plant, St. James, LA. Baton Rouge,
LA. DCN 02424.
LDEQ. 2004b. Louisiana Department of Environmental Quality. Water Discharge Permit Fact
Sheet for NPDES LA0029769 - IMC Phosphates Company, Faustina Plant, St. James, LA.
Baton Rouge, LA. DCN 02424.
MDEQ. 2002a. Mississippi Department of Environmental Quality. State of Mississippi Water
Pollution Control Permit to Discharge Wastewater in Accordance with the National Pollution
Discharge Elimination System Fact Sheet NPDES MS0003115 - Mississippi Phosphates
Corporation, Pascagoula, Mississippi. Jackson, MS. (July 8). DCN 02414.
MDEQ. 2002b. Mississippi Department of Environmental Quality. State of Mississippi Water
Pollution Control Permit to Discharge Wastewater in Accordance with the National Pollution
Discharge Elimination System NPDES MS0003115 - Mississippi Phosphates Corporation,
Pascagoula, MS. Jackson, MS. (August 26). DCN 02414.
Oliver, Russell G. 2003. Telephone conversation with Russell G. Oliver of IMC Phosphates,
Uncle Sam, LA, and Bob Southworth of Eastern Research Group. "SIC Code for Uncle Sam and
Faustina Facilities." (November 18). DCN 00560.
Pirkle, Billy. 2004. Telephone conversation with Billy Pirkle of Royster-Clark, Hartsville, SC,
and Arash Hooshangi of Eastern Research Group. "Clarification of Manufacturing Process and
Pollutant Discharges." (January 16). DCN 00735.
Smith, Jim. 2004. Telephone conversation with Jim Smith of Mississippi Phosphates
Corporation, Pascagoula, MS, and Arash Hooshangi of Eastern Research Group, Inc.
"Clarification of Manufacturing Processes and Pollutant Discharges." (January 16). DCN
00734.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U.S. EPA. 1974. 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/l-75/042-a. Washington, DC. (March).
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
8-15
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Section 8.0 - Fertilizer Manufacturing
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Dischargers.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment (FWT)
(HF Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm. Date accessed: July 27. DCN 03759.
8-16
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Section 9.0 - Inorganic Chemicals Manufacturing
9.0 INORGANIC CHEMICALS MANUFACTURING (40 CFR PART 415)
EPA selected the Inorganic Chemicals Manufacturing (Inorganic Chemicals)
Category for additional data collection and analysis because of the high TWPE identified in the
2005 screening-level review (see Table V-l, 70 FR 51050, August 29, 2005). The 2004 Plan
summarizes the results of EPA's previous review of this industry (U.S. EPA, 1982). This section
summarizes the 2005 annual review and also describes EPA's 2006 annual review of the
discharges associated with the Inorganic Chemicals Category. EPA's 2006 annual review builds
on the 2005 annual review.
EPA focused this review on discharges of dioxin and dioxin-like compounds from
the Titanium Dioxide Production Subcategory, because of their high TWPE relative to the rest of
the Inorganic Chemicals Category. EPA is currently reviewing discharges from the Chlor-Alkali
Subcategory as part of the Chlorine and Chlorinated Hydrocarbons (CCH) ELGs rulemaking and
excluded the discharges from that Subcategory from this review (see Table V-l, 70 FR 51050,
August 29, 2005).
9.1 Inorganic Chemicals Category Background
This subsection provides background on the Inorganic Chemicals Category
including a brief profile of the inorganic chemicals manufacturing industry and background on
40 CFR Part 415.
9.1.1 Inorganic Chemicals Industry Profile
The inorganic chemicals manufacturing industry includes facilities that manufacture chemicals
that do not include organic carbon and its derivatives as their principal elements. The industry
includes facilities within the following four SIC codes:
• 2812: Alkalies and Chlorine;
• 2813: Industrial Gases;
• 2816: Inorganic Pigments; and
• 2819: Inorganic Chemicals, Not Elsewhere Classified (NEC).
Table 9-1 lists the four SIC codes with operations in the Inorganic Chemicals
Category.
9-1
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-1. Number of Facilities in Inorganic Chemicals Manufacturing SIC Codes
SIC Code
2812 Alkalies and Chlorine
2813 Industrial Gases
2816 Inorganic Pigments
2819 Inorganic Chemicals, NECC
Total
Final Regulation
(1982 and 1984)
77
223
36
434
770
2002 U.S.
Economic
Census
40
568
105
2,396
3,109
2002
PCS3
6
42
24
123
195
2002
TRIb
7
82
50
348
487
2003
TRIb
8
73
48
336
465
Sources: Development Document for Effluent Limitations Guidelines and Standards for the Inorganic Chemicals
Manufacturing Point Source Category (U.S. EPA, 1982); U.S. Economic Census, 2002 (U.S. Census, 2002);
PCSLoads2002_v2; TPJReleases2002_v2; TPJReleases2003_v2.
3Major and minor dischargers.
bReleases to any media.
°EPA identified certain facilities reporting under SIC code 2819 as subject to the Nonferrous Metals Manufacturing
ELGs (see Section 5.0).
NEC - Not elsewhere classified.
Inorganic chemicals manufacturing facilities discharge directly to surface water as
well as to POTWs. Table 9-2 presents the types of discharges reported by facilities in the 2002
TRI database. The majority of facilities reporting to TRI reported no water discharges, but
facilities may be discharging pollutants in wastewater at levels below the TRI-reporting
thresholds.
Table 9-2. Inorganic Chemicals Category Facilities by Type of Discharge Reported in TRI
2002
SIC Code
2812: Alkalies and Chlorine
2813: Industrial Gases
2816: Inorganic Pigments
2819: Inorganic Chemicals, NEC
Reported Only
Direct
Discharges
0
5
12
52
Reported Only
Indirect
Discharges
0
1
9
78
Reported Both
Direct and
Indirect
Discharges
0
1
7
30
Reported No
Water
Discharges
7
75
22
185
Source: TRIReleases2002_v4.
NEC - Not elsewhere classified.
9.1.2
40 CFR Part 415
EPA first promulgated ELGs for the Inorganic Chemicals Category (40 CFR Part
415) in 1974 and revised then in 1975, 1976, 1982, and 1986. The Inorganic Chemicals ELGs
include 67 subcategories defined by the type of inorganic chemical product manufactured. The
ELGs provide limitations guidelines for BPT, BAT, BCT, and NSPS for all subcategories, and
include pretreatment standards for at least one subcategory. Table 5-6 in the 2004 Plan contains
details on the pollutants regulated by subpart.
9-2
-------
Section 9.0 - Inorganic Chemicals Manufacturing
9.2
Inorganic Chemicals 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Inorganic Chemicals
Category including the screening-level review and category-specific review.
9.2.1
Inorganic Chemicals 2005 Screening-Level Review
Table 9-3 compares the Inorganic Chemicals Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2. The table excludes the amount of TWPE
contributed specifically by the Chlor-Alkali Subcategory.
Table 9-3. Inorganic Chemicals Category 2005 Screening-Level Review Results
Rank
8
Point Source Category
Inorganic Chemicals, Excluding the
Chlor-Alkali Subcategory0
2002 PCS TWPEb
139,682
2002 TRI TWPEC
280,977
Total TWPE
420,659
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°The Chlor-Alkali Subcategory of the Inorganic Chemicals Category includes facilities that conduct chlor-alkali
manufacturing and reported a primary SIC code associated with inorganic chemicals.
EPA is currently considering revisions to ELGs for discharges from facilities that
produce chlorine by the chlor-alkali process. Because a rulemaking for the chlor-alkali sector of
the Inorganic Chemicals Category is underway, discharges from these facilities were excluded
from further consideration for the Inorganic Chemicals Category review under the current
planning cycle.
9.2.2
Inorganic Chemicals Category 2005 Pollutants of Concern
Table 9-4 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. Dioxin and dioxin-like compounds contributed 27 percent of the category
TWPE in TRIReleases2002_v2. Five of the seven facilities that reported dioxin discharges to
TRI in 2002 manufacture titanium dioxide (U.S. EPA, 2001). As a result, most of this section
focuses on discharges of dioxin and dioxin-like compounds.
9-3
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Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-4. 2005 Annual Review: Inorganic Chemicals Category Pollutants of Concern
Pollutant
Dioxin and Dioxin-
Like Compounds
Sodium Nitrite
Chlorine
Lead and Lead
Compounds
Mercury and Mercury
Compounds
Iron
Nitrogen, Nitrite Total
(asN)
Sulfide
Fluoride
Inorganic Chemicals
Category Total
2002 PCS"
Number of
Facilities
Reporting
Pollutant
Total Pounds
Released
TWPE
Pollutants are not in the top five PCS 2002
reported pollutants.
16
16,915
8,612
Pollutants are not in the top five PCS 2002
reported pollutants.
11
o
6
2
10
68C
11,540,889
87,896
2,640
205,338
1,258,006,644
64,629
32,815
7,396
7,187
139,682
2002 TRIb
Number of
Facilities
Reporting
Pollutant
7
7
13
54
14
Total
Pounds
Released
0.07
186,320
77,654
13,148
206
TWPE
74,702
69,560
39,539
29,451
24,164
Pollutants are not in the top five TRI
2002 reported pollutants.
198C
9,315,202
280,977
Source: PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
9.3
Category.
9.4
Potential New Subcategories for the Inorganic Chemicals Category
EPA did not identify any potential new subcategories for the Inorganic Chemicals
Inorganic Chemicals Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Inorganic Chemicals Category. EPA obtained
additional data and identified:
• Facilities classified in the wrong category;
• Changes in estimates of TWPE for dioxin and dioxin-like compounds
discharges for three facilities; and
• Changes in estimates of TWPE for sodium nitrite, chlorine, nitrogen
compounds.
9-4
-------
Section 9.0 - Inorganic Chemicals Manufacturing
9.4.1 Inorganic Chemicals Category Facility Classification Revisions
EPA contacted facilities that reported discharges of dioxin and dioxin-like
compounds to TRI in 2002 and determined that one facility, GB Biosciences in Houston, TX,
manufactures agricultural chemicals and pesticides. The discharges from this facility are subject
to 40 CFR Part 455: Pesticide Chemicals rather than 40 CFR Part 415: Inorganic Chemicals
(Wood, 2006). EPA changed the category classification of this facility in the revised databases,
TRIReleases2002_v4 and PCSLoads2002_v4, as described in Section 4.5 of this TSD.
9.4.2 Inorganic Chemicals Category Dioxin and Dioxin-Like Compounds
Discharge Revisions
As described in Section 4.1, dioxin and dioxin-like compounds include 2,3,7,8-
tetrachlordibenzo-p-dioxin (TCDD) and 16 other dioxin-like congeners. TRI requires facilities
to report the total mass of the 17 congeners and allows facilities to report a single congener
distribution across all media, representing the relevant percentages of each of the 17 congeners.
The reported congener distribution may not represent the distribution of the congeners in
wastewater. EPA contacted the facilities that reported discharges of dioxin and dioxin-like
compounds to TRI in 2002 to determine how they estimated the discharges. Table 9-5 lists the
facilities that EPA contacted, EPA's findings, and the resulting changes to the TRI databases.
9.4.3 Inorganic Chemicals Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, EAD
revised the TWF and POTW percent removal values used for sodium nitrite in the TRI and PCS
databases to better reflect the pollutant's properties. The TWF that EAD applies for sodium
nitrite is now 0.0032 (formerly 0.373) and the POTW percent removal is now 90 percent
(formerly 1.85 percent). EAD also revised the TWF used for nitrite in the TRI and PCS
databases. The TWF that EAD applies for nitrite is now 0.0032 (formerly 0.373). EAD also
revised the POTW percent removal values used for chlorine in the TRI databases. The POTW
percent removal that EAD applies for chlorine is now 100 percent (formerly 1.87 percent).
Table 9-6 presents the loads before and after corrections to the TWF and POTW percent removal
for sodium nitrite, the TWF for nitrite, and the POTW percent removal for chlorine for the
Inorganic Chemicals Category.
9-5
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Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-5. Inorganic Chemicals Category Facilities with Discharge Revisions
TRIID
Facility
Dioxin and Dioxin-Like
Compounds Findings
Resulting Database Change
in TRIReleases2002 v4
21226-SCMCH-3901G
Millennium
Inorganic Chemicals
Inc.
Facility found dioxin and
dioxin-like compounds at
concentrations below sample
detection limits in 2004.
Facility estimated discharges
based on !/2 the detection limit
(Schildt, 2006).
EPA revised the discharges
of dioxin and dioxin-like
compounds to zero pounds.
31404-KMRNC-EAST
Kerr McGee
Pigments
Facility never measured dioxin
and dioxin-like compounds and
estimates discharges based on
!/2 the detection limit (Dolan,
2006).
EPA revised the discharges
of dioxin and dioxin-like
compounds to zero pounds.
38127-DPNTM-2571F
Du Pont Memphis
Plant
Facility analyzed wastewater
for dioxin and dioxin-like
compounds once in 2001 and
detected one congener,
1,2,3,4,7,8,9-
heptachlorodibenzo-p-dioxin at
4.7 pg/L. This measurement is
below the Method 1613B
minimum level. Facility
assumed that undetected
congeners were present at the
detection limit (Zweig, 2006).
EPA revised the discharges
of dioxin and dioxin-like
compounds to 0.0235 pounds
to reflect only the detection
of 1,2,3,4,7,8,9-
heptachlorodibenzo-p-dioxin.
Source: TRIReleases2002 v2; TRIReleases2002 v4\.
Table 9-6. Impact of Changes to TWF and POTW Percent Removal for the Inorganic
Chemicals Category
Database
TRI 2002
PCS 2002
TRI 2002
Pollutant
Sodium Nitrite
Nitrogen, Nitrite Total (as N)
Chlorine
Number of Facilities
Reporting Discharges
6a
3
13
TWPE from
2005 Review
69,560
32,815
39,539
TWPE from
2006 Review
63.5
281
2,440
Sources: TRIReleases2002_v2; TRIReleases2002_v4; PCSLoads2002_v4.
aNumber of facilities reporting discharges of sodium nitrite to TRI in 2002 for the revised database,
TRIReleases2002_v4, increased due to moving U.S. DOE Portsmouth Gaseous Diffusion Plant from the Inorganic
Chemicals Category to the Nonferrous Metals Manufacturing Category.
9-6
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Section 9.0 - Inorganic Chemicals Manufacturing
9.4.4
Inorganic Chemicals Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings based on methodology changes as described in Section 4.2. For the Inorganic
Chemicals Category, the most significant changes are also described in Section 9.4.1 through
9.4.3. Table 9-7 shows the 2006 screening-level TWPE estimated for the Inorganic Chemicals
Category from the 2002 and 2003 TRI and 2002 PCS databases.
Table 9-7. Inorganic Chemicals Category 2006 Screening-Level Review
Point Source Category
Inorganic Chemicals, Excluding the Chlor- Alkali
Subcategory0
2002 PCS
TWPEa
107,159
2002 TRI
TWPEb
186,185
2003 TRI
TWPEb
182,427
Sources: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Values exclude TWPE from the Chlor-Alkali subcategory, because EPA is investigating chlor-alkali discharges as
part of the CCH rulemaking.
9.4.5
Inorganic Chemicals Category 2006 Pollutants of Concern
Table 9-8 presents the pollutants of concern for the Inorganic Chemicals Category
based on the 2006 annual review.
Manganese and Manganese Compounds Discharges
Of the Inorganic Chemicals Category's 2002 manganese and manganese
compounds discharges in TRI, 91 percent were from Kerr McGee Pigments in Savannah, GA.
The facility's permit does not require monitoring for manganese, and the manganese results from
titanium dioxide manufacture using the sulfate process. The facility shut down its sulfate
process in 2004, and its manganese releases should be significantly reduced (Dolan, 2006). The
category's 2002 manganese discharges in TRI without the Kerr McGee Pigments facility account
for only 6,745 TWPE.
Iron Discharges
Of the Inorganic Chemicals Category's 2002 iron discharges in PCS, 99 percent
were from Kerr McGee Pigments in Savannah, GA. The facility's permit requires wastewater
monitoring for iron but does not have limits for iron. EPA contacted the facility and determined
that the iron loads result from titanium dioxide manufacture using the sulfate process. The
facility shut down its sulfate process in 2004, and its iron discharges are significantly reduced
(U.S. Census, 2002). The Inorganic Chemicals Category's 2002 iron discharges in PCS without
the Kerr McGee Pigments facility account for only 801 TWPE.
9-7
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-8. 2006 Annual Review: Inorganic Chemicals Category Pollutants of Concern"
Pollutant
Manganese and
Manganese
Compounds
Lead and Lead
Compounds
Mercury and
Mercury
Compounds
Dioxin and
Dioxin-Like
Compounds
PCBs
Iron
Chlorine
Sulfide
Fluoride
Cadmium
Inorganic
Chemicals
Category Total
2002 PCSb
Number of
Facilities
Reporting
Pollutant
Total Pounds
Released
TWPE
Pollutants are not in the top five PCS 2002
reported pollutants.
10
13
2
10
7
66"
11,540,889
16,915
2,640
205,338
91
1,242,687,564
64,629
8,612
7,396
7,187
2,109
107,159
2002 TRT
Number of
Facilities
Reporting
Pollutant
30
54
14
4
1
Total
Pounds
Released
1,105,758
13,148
206
0.066
0.300
TWPE
77,882
29,451
24,164
21,197
10,210
2003 TRIC
Number of
Facilities
Reporting
Pollutant
31
57
15
5
2
Total
Pounds
Released
1,186,329
3,128
164
0.039
0.314
TWPE
83,557
7,007
19,174
22,404
10,687
Pollutants are not in the top five TRI 2002 reported pollutants.
195d
9,072,771
186,185
201d
8,831,964
182,427
VO
I
oo
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
aValues exclude TWPE from the Chlor-Alkali Subcategory, because EPA is investigating chlor-alkali discharges as part of the CCH rulemaking.
bDischarges include only major dischargers.
Discharges include transfers to POTWs and account for POTW removals.
dNumber of facilities reporting TWPE greater than zero.
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Lead and Lead Compounds Discharges
Of the Inorganic Chemicals Category's 2002 lead and lead compounds discharges
in TRI, 83 percent were from PCS Nitrogen Fertilizers in Geismar, LA. In 2002, this facility
reported 10,862 pounds (24,331 TWPE) and in 2003 reported 140 pounds (314 TWPE). The
difference in TWPE for lead and lead compounds from 2002 to 2003 in the TRI databases, as
shown in Table 9-7, is due to the decrease in reported discharges of lead and lead compounds
from this facility.
Mercury and Mercury Compounds Discharges
Of the Inorganic Chemicals Category's 2002 mercury and mercury compounds
discharges in TRI, 84 percent of the discharges are from Kerr McGee Pigments in Hamilton, MS.
This facility also accounted for 75 percent of the 2003 mercury and mercury compounds
discharges in TRI. EPA contacted the facility and determined that the mercury and mercury
compounds discharges were from the titanium dioxide process. The facility has never analyzed
for mercury in the wastewater (Dolan, 2006), and based its mercury and mercury compounds
discharge estimates on the approximate amount of mercury in the rutile ore and fate and
transport estimates.
Dioxin and Dioxin-Like Compounds Discharges
EPA identified facilities reporting discharges of dioxin and dioxin-like
compounds to TRI in 2002 and 2003 for additional review because of the TWPE associated with
the discharges. Of the four facilities reporting discharges of dioxin and dioxin-like compounds
to TRI in 2002, three facilities manufacture titanium dioxide.
9.5 Inorganic Chemicals Category Dioxin and Dioxin-Like Compounds
Discharges
As described in Section 4.1, dioxin and dioxin-like compounds include 2,3,7,8-
tetrachlordibenzo-p-dioxin (TCDD) and 16 other dioxin-like congeners. Section 9.4.2 describes
the changes made to the TRI 2002 databases based on EPA contact with facilities reporting
discharges of dioxin and dioxin-like compounds. EPA zeroed the dioxin and dioxin-like
compounds discharges for two facilities, Millennium Inorganic Chemicals Inc. and Kerr McGee
Pigments, and corrected the discharge of dioxin and dioxin-like compounds for one facility, Du
Pont Memphis Plant. Table 9-9 lists the facilities reporting discharges of dioxin and dioxin-like
compounds to TRI in 2002 and 2003 with the products the facilities manufacture.
9-9
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-9. Inorganic Chemicals Category Facilities Reporting Discharges of Dioxin and Dioxin-like Compounds to TRI
Facility
(Location)
Du Pont Memphis Plant
(Memphis, TN)
Du Pont De Lisle Plant
(Pass Christian, MS)
Du Pont Edgemoor Plant
(Edgemoor, DE)
Du Pont New
Johnsonville Plant
(New Johnsonville, TN)
Kerr-McGee Chemical,
LLC (Tronox)
(Savannah, GA)
Louisiana Pigment
Company LLC
(Lake Charles, LA)
Millennium Inorganic
Chemicals Inc.
(Baltimore, MD)
Applicable Subcategory
Hydrogen Cyanide
Titanium Dioxide
Titanium Dioxide
Titanium Dioxide
Titanium Dioxide
Titanium Dioxide
Titanium Dioxide
2002 TRT
Pounds Dioxin and
Dioxin-Like Compounds
Released
0.000001
NR
0.03
0.04
0.00
0.0004
0.00
Dioxin and Dioxin-
Like Compounds
TWPE
0.41
NR
60.5
6,849
0.00
14,288
0.00
2003 TRT
Pounds Dioxin and
Dioxin-Like
Compounds Released
0.000001
0.00002
0.002
0.03
0.00
0.0007
0.00
Dioxin and Dioxin-
Like Compounds
TWPE
0.38
1.70
208
4,953
0.00
17,241
0.00
VO
I
o
Source: TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include transfers to POTWs and account for POTW removals.
NR - Not reported.
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Only one facility that reported discharges of dioxin and dioxin-like compounds to
TRI in 2002 and 2003 does not manufacture titanium dioxide. This facility, Du Pont Memphis
Plant in Memphis, TN, was unable to determine the source of the dioxin and dioxin-like
compounds discharges. Chlorine is required to produce dioxin and dioxin-like compounds and
this facility only uses sodium hypochlorite for breakpoint chlorination of its wastewater
treatment system to remove cyanide from the wastewater.
For comparison purposes, Table 9-10 compares the dioxin and dioxin-like
compounds discharges for the Titanium Dioxide Subcategory of the Inorganic Chemicals
Category, the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category, and the
facilities reviewed as part of the CCH rulemaking. Compared with the 2002 TWPE from
discharges from OCPSF and CCH dischargers, the total 2002 TWPE for titanium dioxide
dischargers is significantly less.
Table 9-10. Comparison of TRI TWPE from Dioxin and Dioxin-Like Compounds for 2002
and 2003 for the Titanium Dioxide Subcategory, OCPSF Category, and CCH Rulemaking
Point Source Category/Subcategory
Titanium Dioxide Subcategory of the Inorganic
Chemicals Category
Organic Chemicals, Plastics, and Synthetic Fibers
Category3
Chlorine and Chlorinated Hydrocarbons Rulemaking
Dioxin and Dioxin-Like Compounds TRI TWPE
2002
21,197
115,132
8,667,223
2003
22,404
703,572
6,733,923
Sources: TRIReleases2002_v4; TRIReleases2003_v2.
""Excludes facilities included in the CCH rulemaking.
9.6
Titanium Dioxide Manufacturing Subcategory
The majority of the TWPE associated with dioxin and dioxin-like compounds
discharges in the TRI databases for the Inorganic Chemicals Category results from titanium
dioxide manufacturers. This subsection discusses titanium dioxide manufacturing and provides
more detail on available dioxin and dioxin-like compounds data.
9.6.1
Titanium Dioxide Manufacturing Industry Profile
Nine plants in the United States currently manufacture titanium dioxide. Because
discharges reported by six of these facilities accounted for most of the TWPE from dioxin and
dioxin-like compounds in EPA's 2005 annual review for the Inorganic Chemicals Category,
EPA identified this Subcategory for additional review. All nine facilities discharge their
wastewater directly, and none have permit limits for dioxin and dioxin-like compounds. Table
9-11 lists the nine titanium dioxide manufacturing facilities, type of manufacturing process, and
capacities.
9-11
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-11. United States Titanium Dioxide Manufacturers
Facility Name
Du Pont De Lisle Plant
Du Pont Edge Moor Plant
Du Pont New Johnsonville Plant
Kerr-McGee Chemical, LLC
Kerr-McGee Chemical, LLC (Tronox)b
Louisiana Pigment Company LLC
Millennium Inorganic Chemicals
Lyondell/Millennium Inorganic Chemicals (Plant I)
Lyondell/Millennium Inorganic Chemicals (Plant II)
Location
De Lisle, MS
Edge Moor, DE
Johnsonville, TN
Hamilton, MS
Savannah, GA
Lake Charles, LA
Baltimore, MD
Ashtabula, OH
Ashtabula, OH
Capacity
(tonnes)
280
155
380
200
85
120
104
98
51
Process
Type3
C/I
C/I
C/I
c
c
c
c
c
c
Source: Final Titanium Dioxide Listing Background Document for the Inorganic Chemical Listing Determination
(U.S. EPA, 2001); Final Technical Background Document Identification Description of Mineral Processing Sectors
and Waste Streams (U.S. EPA, 1998); Telephone and e-mail correspondence with Kenneth Wood of Du Pont and
Eleanor Ku Codding of Eastern Research Group, Inc. (Wood, 2006).
aC indicates chloride and C/I indicates chloride-ilmenite process.
bKerr-McGee's Savannah plant operated both a chloride and sulfate process until 2004, when they shut down the
sulfate process.
9.6.2
40 CFR Part 415 Subpart V
ELGs for the Titanium Dioxide Subcategory of the Inorganic Chemicals Category
(40 CFR Part 415 Subpart V) includes facilities that manufacture titanium dioxide by the sulfate
process, the chloride process, and the simultaneous beneficiation-chlorination (chloride-ilmenite)
process. Currently, no titanium dioxide manufacturers discharge to POTWs. The technology
basis for both BPT and NSPS was physical/chemical treatment. Table 9-12 summarizes the BPT
and NSPS limitations for the Titanium Dioxide Subcategory.
Table 9-12. Titanium Dioxide Subcategory BPT and NSPS Monthly Average Limitations
Regulated
Pollutant
TSS
Chromium
Nickel
Iron
BPT
kg/kkg (or Ib per 1,000 Ib)
Sulfate
Process
38
0.21
0.14
NR
Chloride
Process
6.4
0.03
NA
NR
Chloride-
ilmenite
Process
9.6
0.053
0.035
NR
NSPS
kg/kkg (or Ib per 1,000 Ib)
Sulfate
Process
30
0.14
0.095
1.2
Chloride
Process
4
0.012
NA
0.16
Chloride-
ilmenite
Process
2.4
0.002
0.01
0.096
NR - Not regulated.
NA - Not applicable. Nickel is not regulated for discharges from the chloride process.
9-12
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Section 9.0 - Inorganic Chemicals Manufacturing
9.6.3 Titanium Dioxide Manufacturing Process Description
Titanium dioxide is used as a pigment in paints, varnishes, lacquer, paper and
paperboard, plastics, and personal care products (U.S. EPA, 2001). It provides whiteness and
opacity in products ranging from polyvinyl chloride piping to cosmetics and sunscreen. The
United States accounts for most of the world production (USGS, 2006).
Table 9-13 lists the three types of titanium dioxide manufacturing processes that
reflect data reported to TRI and the type of titanium ore used. Manufacturing with lower purity
ore increases the volume of impurities formed during chlorination, such as iron chlorides.
Table 9-13. Titanium Dioxide Manufacturing Processes
Process Type
Chloride
Chloride-Ilmenite
Sulfate3
Type of Ore Used
Rutile or high-grade ilmenite
Ilmenite (low grade acceptable)
Rutile or high-grade ilmenite
Typical Ore Purity
95%
50 - 65%
95%
Source: (U.S. EPA, 2001).
"Only one facility in the United States reportedly uses this process. It reported discharges to TRI in 2002 and 2003,
but shut down its operation in 2004. As a result, EPA is not aware of any facilities in the United States that
currently use this process.
Currently, U.S. facilities manufacture titanium dioxide using the chloride or
chloride-ilmenite process. The last U.S. facility using the sulfate process, Kerr-McGee
Chemical, LLC (Tronox) in Savannah, GA, shut that process down in 2004. This subsection
discusses all three processes, because the sulfate process discharges are reflected in the 2002 and
2003 TRI and 2002 PCS databases.
In 2001, EPA's Office of Solid Waste (OSW) completed a study of titanium
dioxide manufacturers. The information gathered during the OSW study is summarized in the
document entitled Final Titanium Dioxide Listing Background Document for the Inorganic
Chemical Listing Determination (U.S. EPA, 2001). The process descriptions that follow are
based on the descriptions in the OSW listing document, as well as information from additional
OSW reports and the United States Geological Survey Minerals Division.
Titanium Dioxide Chloride Process
Figure 9-1 shows the basics of the chloride process, which are the same as the
chloride-ilmenite process. In the chloride process, facilities convert rutile or high-grade ilmenite
ore into titanium tetrachloride (TiCU) in a chlorinator. Although a fixed-bed chlorinator may be
used, all U.S. facilities use a fluidized bed (U.S. EPA, 1998). Feedstocks include titanium ore,
chlorine, supplied as a gas at approximately 900° C, and petroleum coke (as a reductant) (U.S.
EPA, 2001).
9-13
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Rutile or
Ilmenite
Coke
Cl,
Chlorinator
Crude
TiCl4
Scrubber
Condensation &
Purification
Solids/
Liquids
Coke & Ore
Recovery
Wastewater
Chlorine Returned to
Chlorinator
TiCl4
Oxidation
TiO9
Finishing
Ti02
Product
Wastewater
Wastewater
Treatment
Wastewater
Solid
waste
Figure 9-1. Basic Diagram of the Chloride and Chloride-Ilmenite Processes for Titanium Dioxide Manufacture
(U.S. EPA, 2001)
-------
Section 9.0 - Inorganic Chemicals Manufacturing
The resulting TiCU is volatile and is piped to an oxidizer as a vapor. Impurities of
metal chlorides, unreacted coke, and ore solids are removed with condensers and chemical
treatment. The acidic metal chlorides, including ferric chloride (FeCb), are removed as a liquid
stream. Coke and ore are recovered from this stream, and the remaining solution is sent to
wastewater treatment. Air emissions from the condenser are purified using water and caustic
scrubbers, generating acidic wastewater. Facilities may recover hydrochloric acid from the
acidic scrubber blowdown, either for use on site or for sale (U.S. EPA, 1998).
In the oxidizer, purified TiCU vapor is converted to TiC>2, or titanium dioxide.
Facilities recycle the liberated chlorine gas from the oxidizer back to the chlorinator. The TiC>2
product is conveyed in slurry form to the finisher. At the finisher, facilities grind the TiC>2 and
add surface treatments. Some plants generate wastewater at the finisher, most likely from air
pollution control of particulate matter. Facilities sell the finished TiC>2 as both a dry solid and
water-based slurry (U.S. EPA, 2001).
Titanium Dioxide Chloride-Ilmenite Process
Figure 9-1 shows the basics of the chloride-ilmenite process, which are the same
as the chloride process. Du Pont holds a patent on the chloride-ilmenite process. This process
allows the use of lower-quality ore and easier oxidation (U.S. EPA, 2001). As in the chloride
process, the titanium ore is chlorinated in a fluidized-bed chlorinator, with coke used as a
reducing agent. The gaseous product stream is condensed to separate the TiCUfrom other metal
chloride impurities, including ferric chloride (FeCls). FeCls is present in higher concentrations
than in the chloride process because of the high iron content in the ore (U.S. EPA, 2001).
Impurities are separated via condensation and chemical treatment. The process for converting
TiCU to TiC>2 is similar to that used in the chloride process as are the sources of wastewater:
condenser air pollution control, metal chloride liquid waste, and, potentially, the finisher.
The principal difference between the chloride-ilmenite and chloride processes is
that the Du Pont process can use lower-grade ore. Ilmenite typically contains approximately 65
percent titanium and has more iron than rutile (U.S. EPA, 2001). Du Font's chloride-ilmenite
process beneficiates the ore (U.S. EPA, 1998). There are four steps in ore beneficiation and the
subsequent processing of TiCU (U.S. EPA, 1998):
• Step 1: In the chlorinator, ilmenite ore is mixed with chlorine gas and
coke. Initially, the chlorine reacts with the iron oxide in the ilmenite ore,
producing gaseous iron chlorides and enriched ilmenite ore containing
more than 95 percent titanium. The beneficiated ilmenite changes color
from the iron removal, but is otherwise unaltered.
• Step 2: After the chlorine and iron react, the resulting beneficiated ore
converts to gaseous TiCU in the chlorinator.
• Step 3: A spray condenser collects iron chloride waste acids, which are
sold as a by product or disposed as nonhazardous waste. As with the
chloride process, the liquid metal chloride stream contains hydrochloric
acid, which may be recovered (U.S. EPA, 1998).
9-15
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Section 9.0 - Inorganic Chemicals Manufacturing
• Step 4: TiCU is condensed, purified, and prepared for sale in a finisher,
using the same techniques as the chloride process.
Titanium Dioxide Sulfate Process
Figure 9-2 shows the basics of the sulfate process. In the sulfate process, a
digester dissolves rutile slag in sulfuric acid and water, producing a titanyl sulfate liquor. In the
next step, undissolved ore and solids settle out in a clarification tank. The undissolved ore and
solids are disposed of as Bevill-exempt, nonhazardous waste. The clarified titanium liquor is
concentrated and undergoes hydrolysis, forming titanium dioxide hydrate in solution with ferrous
sulfate and sulfuric acid. The titanium dioxide hydrate is then precipitated and filtered from the
ferrous sulfate and sulfuric acid (H2SO4). The waste acid filtrate from this step is used in
gypsum production. A calciner then heats the hydrated titanium dioxide, forming crystalline
TiC>2 and driving off residual water and H2SO4. The dried titanium dioxide is then finished, using
the same techniques as the chloride process.
Wet air pollution control cleans emissions from both the digester and calciner,
generating wastewater. The finishing process also generates wastewater. The digester scrubber
generates sulfuric acid at a rate up to twice the product weight, and neutralization of this
wastewater is costly. The last U.S. facility using the chloride process, Kerr McGee in Savannah,
Georgia, shut its sulfate process down in 2004.
9.6.4 Titanium Dioxide Wastewater Sources of Dioxin and Dioxin-Like
Compounds
Dioxin and dioxin-like compounds are a by-product of incomplete combustion
and form when chlorine reacts with organic carbon in the presence of a metal at high
temperatures (approximately 400° C) (U.S. EPA, 1994). In titanium dioxide manufacturing,
based on the information obtained to date, EPA concluded that dioxin and dioxin-like
compounds may form in the chloride and chloride-ilmenite processes. In the chlorinator,
titanium ore (containing iron impurities), chlorine gas, and petroleum coke (source of carbon)
react at temperatures around 900° F (U.S. EPA, 2001).
Facility-reported discharges of dioxin and dioxin-like compounds from titanium
dioxide manufacturers are available in TRI. EPA contacted all nine facilities to verify their TRI-
reported values. Table 9-14 presents the TRI data and EPA's findings from the facility contacts.
9-16
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Wastewater
Ti02
Product
Digestion
Sludge
Waste Acid to
Gypsum Plant
Wastewater
Figure 9-2. Basic Diagram of the Sulfate Process for Titanium Dioxide Manufacture
(U.S. EPA, 2001)
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-14. Titanium Dioxide Facility List and Inventory of Data Available for Dioxin and Dioxin-Like Compounds
Facility Name
Du Pont De Lisle
Plant
Du Pont Edgemoor
Plant
Du Pont New
Johnsonville Plant
Kerr-McGee
Chemical, LLC
Kerr-McGee
Chemical, LLC
(Tronox)
Location
De Lisle, MS
Edgemoor, DE
Johnsonville,
TN
Hamilton, MS
Savannah, GA
2002 TRT
g TM-17
NR
13.6
16.4
TWPE
NR
60.5
6,850
2003 TRT
g TM-17
0.0091
0.708
16.4
TWPE
1.70
208
4,953
Facility did not report any dioxin discharges to
water in TRI.
0 (Facility
reported
0.854)a
Oa
0 (Facility
reported
2.00)a
Oa
Did Facility
Detect Dioxin
and Dioxin-
Like
Compounds at
Any Level?
N
Y
Y
N
N
Additional Comments
Facility analyzed wastewater twice in 2003. AH
congeners were below laboratory detection limits
for both samples. Du Pont measured 7.3 pg/L of
1,2,3,4,6,7,8-HpCDF, but the blank for that
sample had a similar result. Du Pont used 1/2
the detection limit to estimate discharges. The
detected values are below the 1613B ML and are
questionable because of the sample blank result.
Facility analyzed wastewater once in 1999 and
twice in 2003. Facility measured four congeners
measured overall (OCDD, OCDF, HpCDF,
HxCDF). Facility used 1/2 the detection limit
for the other congeners.
Facility analyzed wastewater once in 2000 and
once in 2003. Facility measured six congeners
overall.
Facility analyzed wastewater for dioxin and
dioxin-like compounds in their treated
wastewater. All congeners were below
laboratory detection limits.
Facility provided analytical data, which showed
that all congeners of dioxin and dioxin-like
compounds were below laboratory detection
limits in the water. The facility filtered the water
sample and analyzed those solids. Three
congeners were detected in the separated solids;
however, they are all at levels below the
minimum level for EPA Method 1613B.a
VO
I
oo
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-14 (Continued)
Facility Name
Louisiana Pigment
Company LLC
Millennium Inorganic
Chemicals
Lyondell/Millennium
Inorganic Chemicals
(Plant I)
Lyondell/Millennium
Inorganic Chemicals
(Plant II)
Location
Lake Charles,
LA
Baltimore, MD
Ashtabula, OH
Ashtabula, OH
2002 TRT
g TM-17
0.166
0 (Facility
reported
0.47 g)a
TWPE
14,288
Oa
2003 TRT
g TM-17
0.330
0 (Facility
reported
0.32 g)a
TWPE
17,241
Oa
These facilities did not report any water
discharges of dioxin or dioxin-like compounds
to TRI in 2002 or 2003.
Did Facility
Detect Dioxin
and Dioxin-
Like
Compounds at
Any Level?
Y
N
N
N
Additional Comments
Facility measured dioxin and dioxin-like
compounds congeners in treated process
wastewater.
Facility analyzed wastewater for dioxin and
dioxin-like compounds in 2004 and found all
congeners were below laboratory detection
limits.
Facility reported 0.12 g TM-17 released to water
in 2000 using engineering assumptions based on
dioxin and dioxin-like compounds in their solid
waste. Facility measured wastewater in 2001
and found all congeners below laboratory
detection limits.
VO
I
VO
Source: TRIReleases2002_v4; TRIReleases2003_v2.
"These facilities analyzed wastewater for dioxin and dioxin-like compounds, and all measurements were below sample detection limits. The facilities estimated
their water discharges of dioxin and dioxin-like compounds based on one-half the detection limit. For this analysis, EPA set those discharges to zero.
NR - Not reported. Facility did not detect dioxin or dioxin-like compounds in these years.
-------
Section 9.0 - Inorganic Chemicals Manufacturing
All nine facilities analyzed their wastewater for dioxin and dioxin-like
compounds; three of these facilities found measurable concentrations:
• Louisiana Pigments in Lake Charles, LA;
• Du Pont in Edgemoor, DE; and
• Du Pont in New Johnsonville, TN.
Table 9-15 lists the analytical data obtained from the Louisiana Pigment facility,
compares them to the EPA Method 1613B ML, and calculates the annual discharge for
concentrations greater than the 1613B ML. Table 9-16 provides the same information for the
two Du Pont facilities.
Table 9-15 shows that Louisiana Pigments measured concentrations of dioxin and
dioxin-like compounds once above the 1613B minimum level in one sample from one of the
outfalls tested: 109 pg/L of OCDD at Outfall 004. Based solely on this one measurement above
the 1613B minimum level, EPA estimated that Louisiana Pigments discharged 1.9 x 10"10 g-
TEQ/yr and 8.3 x 10'6 TWPE/yr.
Table 9-16 shows that Du Pont measured concentrations of dioxin above the
1613B minimum level once at the Edgemoor facility and twice at the New Johnsonville facility.
For Edgemoor, Du Pont detected 101 pg/L OCDF. Based solely on this one measurement above
the 1613B ML, EPA estimated that the Edgemoor facility discharged 0.000667 g-TEQ/yr and
29.7 TWPE/yr. For New Johnsonville, Du Pont detected approximately 100 pg/L of OCDF and
108 pg/L of OCDD. Based solely on these two measurements above the 1613B ML, EPA
estimated that the New Johnsonville facility discharged 0.0182 g-TEQ/yr and 1,781 TWPE/yr.
Table 9-17 compares the TWPE estimated using all congeners detected versus
only those detected above the 1613B ML, for the three facilities. This table shows that the
majority of the TWPE in the TOI database from dioxin and dioxin-like compounds is estimated
from measurements below the 1613B ML.
9-20
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-15. Concentrations of Dioxin and Dioxin-Like Compounds in Effluent Samples (pg/L) for Louisiana Pigments
Congener
1613B
ML
Outfall 001"
11/18/01
12/25/01
01/22/01
02/06/02
Outfall 002"
11/18/01
12/25/01
02/06/02
10/26/04"
Outfall 004C
11/28/01
01/06/02
02/01/02
10/18/04
Outfall 004
Summary*1
Polychlorinated dibenzo-p-furans (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
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-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
10
50
50
50
50
50
50
50
50
100
ND
ND
ND
1.4
ND
ND
ND
ND
ND
7.7
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.1
6.2
4.5
4.7
4
1.9
1.6
ND
ND
7.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.8
4.1
5.1
5.6
ND
4.3
5.4
5.4
ND
17.1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
16.4
15.3
13.2
24
16.7
19.8
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.8
ND
1.9
2.8
2.8
ND
ND
ND
5.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Polychlorinated dibenzo-p-dioxins (CDDs)
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
10
50
50
50
50
50
100
ND
ND
ND
ND
ND
ND
13.9
ND
ND
ND
ND
ND
ND
21.9
3.9
ND
1.9
3.7
3.4
4.8
30.5
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.9
5.9
6.0
8.0
42.2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
20.8
15.6
ND
ND
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
109e
ND
ND
ND
ND
ND
ND
8.5
ND
ND
ND
ND
ND
3.4
18.5
ND
NA
NA
NA
NA
NA
NA
Grams/year
Grams TEQ/year
TWPE/year
1.9E-06
1.9E-10
8.3E-06
Analytical Data Sources: Data provided by Louisiana Pigments (Frees, 2006).
aOutfall 001 is combined process wastewater from the chlorinator and oxidizer, as well as stormwater, equipment washdown water, hydrostatic testing water, and other wastewater sources.
bOutfall 002 is process wastewater from the finishing plant.
QOutfall 004 is discharge of stormwater from the landfill area, where the facility disposes of process wastes.
dFlow value was estimated based on a monthly stormwater flow of 0.4 million gallons, or 4.8 million gallons per year.
Concentrations greater than Method 1613B minimum level.
ND - Not detected.
ND - No data.
NA - Not applicable. Congener was not analyzed.
9-21
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-16. Concentrations of Dioxin and Dioxin-Like Compounds in Effluent Samples
(pg/L) from Two Du Pont Facilities
Congener
Estimated Flow (MGY) b
1613B ML
Du Pont New Johnsonville
2003a
235,000
Du Pont Edgemoor
2003a
17,400
Polychlorinated dibenzo-p-furans (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
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-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
10
50
50
50
50
50
50
50
50
100
ND
ND
ND
3.32
ND
ND
ND
4.52
2.44
96.9C
ND
ND
ND
2.675
ND
ND
ND
18.27
ND
101.24C
Polychlorinated dibenzo-p-dioxins (CDDs)
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
10
50
50
50
50
50
100
Grams/year
Grams TEQ/year
TWPE/year
ND
ND
ND
ND
ND
5.99
108.33
182
0.0182
1781
ND
ND
ND
ND
ND
ND
7.335
6.67
0.000667
29.7
Source: Telephone conservations with Tammy Burke of Louisiana Pigments and Eleanor Ku Codding of Eastern
Research Group, Inc. (Burke, 2006a; Burke, 2006b).
facilities provided the average of two data points for the year 2003. In the case of 1,2,3,4,6,7,8,9-OCDF for the
New Johnsonville facility, EPA assumes at least one value was greater than 100 pg/L; therefore, this value is greater
than the 1613BML
bFlow values are estimated using 2003 flows reported to PCS.
'Concentrations greater than Method 1613B ML.
ML - Minimum level established for EPA Method 1613B (TIG, 2005).
ND - No data.
9-22
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-17. TWPE Comparison for Three Titanium Dioxide Manufacturers
Facility
Louisiana Pigments Lake Charles, LA
Du Pont Edgemoor, DE
Du Pont New Johnsonville, TN
TRI 2002 TWPE (All
Congeners Detected)
14,288
60.5
6,850
TWPE For Congeners Detected
Above 1613B ML Only
0.0000083
29.7
1,781
Source: TRIReleases2002_v4; Telephone and e-mail correspondence with Kenneth Wood of Du Pont and Eleanor
Ku Codding of Eastern Research Group, Inc. (Wood, 2006); Telephone conversations with Tammy Burke of
Louisiana Pigments and Eleanor Ku Codding of Eastern Research Group, Inc. (Burke, 2006a; Burke, 2006b).
ML - Minimum level established for Method 1613B.
9.6.5
Dioxide and Dioxide-Like Compounds Wastewater Treatment and Pollution
Prevention
When contacting titanium dioxide manufacturing facilities, EPA requested
information on wastewater treatment and pollution prevention. Two facilities indicated they had
implemented changes to reduce dioxin discharges. Although both indicated that the changes
were too facility-specific to be used at other facilities, Du Font's Edgemoor facility reported it
had installed a "PBT Unit" for additional solids removal.
Table 9-18 lists the information available on wastewater treatment in place and
pollution prevention used by the nine U.S. titanium dioxide manufacturers. No data were
available for one facility.
9.7
Inorganic Chemicals Category Conclusions
• During the 2005 annual review, EPA identified sodium nitrite, chlorine,
and nitrite as pollutants of concern. After changes to database
methodology and facility-specific corrections, these pollutants are no
longer the top pollutants in the TRI and PCS databases, based on TWPE.
• The existing ELGs for the Inorganic Chemicals Category were selected for
additional review because of the high TWPE in the 2002 and 2003 TRI
and 2002 PCS databases. While EPA evaluated the other pollutants of
concern identified in the 2006 annual review, EPA focused its additional
review on the discharge of dioxin and dioxin-like compounds from
titanium dioxide manufacturing because they contributed more TWPE
than any other pollutant in the 2005 annual review.
9-23
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Table 9-18. Titanium Dioxide Facilities Wastewater Treatment In Place and Pollution
Prevention
Facility
Du Pont De Lisle Plant
Du Pont Edgemoor Plant
Du Pont New Johnsonville Plant
Kerr-McGee Chemical, LLC
Kerr-McGee Chemical, LLC
(Tronox)
Louisiana Pigment Company LLC
Millennium Inorganic Chemicals
Lyondell/Millennium Inorganic
Chemicals (Plant I)
Lyondell/Millennium Inorganic
Chemicals (Plant II)
Location
De Lisle, MS
Edgemoor, DE
Johnsonville, TN
Hamilton, MS
Savannah, GA
Lake Charles, LA
Baltimore, MD
Ashtabula, OH
Ashtabula, OH
Wastewater Treatment in Place
Neutralization, solids removal, clarification.
Neutralization, solids removal, clarification. Facility
added "PBT Unit" in 2001 to reduce discharge of
chemicals including dioxin and dioxin-like
compounds, polychlorinated biphenyls,
pentachlorophenol, and hexachlorobenzene.
Neutralization, solids removal, clarification.
Neutralization, solids removal, clarification.
No data available.
Neutralization, solids removal, clarification.
Neutralization, solids removal, clarification. Facility
incorporated process changes to reduce generation of
dioxin and dioxin-like compounds in all media and
adjustments to wastewater treatment system to
improve solids removal in 2001.
Neutralization, solids removal, clarification.
Neutralization, solids removal, clarification.
Source: Facility Permits (LDEQ, 2002; MDE, 2003; MDEQ, 2005; MDEQ, 2003; OEPA, 2003a; OEPA, 2003b;
TDEC, 2004); Telephone conversations with Tammy Burke of Louisiana Pigments and Eleanor Ku Codding of
Eastern Research Group, Inc. (Burke, 2006a; Burke 2006b); Telephone conversations with Thomas Dolan of Kerr
McGee, Savannah, GA, and Eleanor Ku Codding of Eastern Research Group, Inc. (Dolan, 2006); Telephone
conversation with Terry Frees of Kerr McGee, Hamilton, MS, and Eleanor Ku Codding of Eastern Research Group,
Inc. (Frees, 2006); Telephone and e-mail correspondence with Kenneth Wood of Du Pont and Eleanor Ku Codding
of Eastern Research Group, Inc. (Wood, 2006).
9-24
-------
Section 9.0 - Inorganic Chemicals Manufacturing
• Dioxin and dioxin-like compounds may form during the chloride and
chloride-ilmenite titanium dioxide manufacturing processes; however,
most of the process wastes that contain dioxin and dioxin-like compounds
are disposed of as solid waste. In some cases, dioxin and dioxin-like
compounds remain in wastewater. Three titanium dioxide manufacturers
reported measurable concentrations of dioxin and dioxin-like compounds
in their treated effluent.
• Tables 9-15 and 9-16 compare EPA Method 1613B ML with the
analytical data available for dioxin and dioxin-like compounds from the
three facilities with measurable congeners of dioxin and dioxin-like
compounds in their effluent. The tables show that only OCDD and OCDF
were measured at levels above the 1613B ML at the three facilities. When
values below the ML are set to zero, the resulting combined TWPE from
dioxin and dioxin-like compounds is less than 1,900 TWPE.
• The Du Pont Edgemoor Plant in Edgemoor, DE installed additional solids
removal in 2003, which has reduced discharges of dioxin and dioxin-like
compounds since 2004. One other facility incorporated process changes
that reduced the generation of dioxin and dioxin-like compounds and their
releases across all media. When this facility measured dioxin and dioxin-
like compounds in its wastewater, all congeners were below laboratory
detection limits. However, titanium dioxide manufacturing facilities in the
United States do not use identical processes, and according to both
facilities, changes made at these two plants would not likely be
appropriate for other facilities.
• Because the TWPE associated with dioxin compounds measured above
the Method 1613B ML is small (1900 TWPE) EPA concludes additional
study and analysis of dioxin discharges from titanium dioxide
manufacturers is not warranted at this time.
9.8 Inorganic Chemicals Category References
Burke, Tammy. 2006a. Telephone conversations with Tammy Burke of Louisiana Pigments and
Eleanor Ku Codding of Eastern Research Group, Inc. "2002 and 2003 TRI Reporting from
Louisiana Pigment's Titanium Dioxide Plant in Lake Charles, LA." (February 16). DCN 03984.
Burke, Tammy. 2006b. Telephone conversations with Tammy Burke of Louisiana Pigments
and Eleanor Ku Codding of Eastern Research Group, Inc. "2002 and 2003 TRI Reporting from
Louisiana Pigment's Titanium Dioxide Plant in Lake Charles, LA." (February 23, March 20,
and April 24). DCN 03983.
Dolan, Thomas. 2006. Telephone conversation with Thomas Dolan of Kerr McGee, Savannah,
GA, and Eleanor Ku Codding of Eastern Research Group, Inc. (February 10). DCN 03985.
9-25
-------
Section 9.0 - Inorganic Chemicals Manufacturing
Frees, Terry. 2006. Telephone conversation with Terry Frees of Kerr McGee, Hamilton, MS,
and Eleanor Ku Codding of Eastern Research Group, Inc. (April 19). DCN 03976.
LDEQ. 2002. Louisiana Department of Environmental Quality. Water Discharge Permit for
NPDES LA0080829 - Louisiana Pigment Company, LP, Westlake, LA. Baton Rouge, LA.
(June 10). DCN 02406.
MDE. 2003. Maryland Department of the Environment. Water Discharge Permit for NPDES
MD0001261 - Millennium Inorganic Chemicals, Baltimore, MD. Baltimore, MD. (February 1).
DCN 02404.
MDEQ. 2005. Mississippi Department of Environmental Quality. State of Mississippi Water
Pollution Control Permit to Discharge Wastewater NPDES MS0002232 - Kerr-McGee Chemical
Corporation, Hamilton, MS. Jackson, MS. (September 22). DCN 02401.
MDEQ. 2003. Mississippi Department of Environmental Quality. State of Mississippi Water
Pollution Control Permit to Discharge Wastewater NPDES MS0027294 - Du Pont De Lisle
Plant, De Lisle, MS. Jackson, MS. (July 9). DCN 02410.
OEPA. 2003a. Ohio Environmental Protection Agency. Authorization to Discharge Under the
National Pollution Discharge Elimination System NPDES OH0000523 - Millennium Inorganic
Chemicals Ashtabula Plant I, Ashtabula, OH. Columbus, OH. (March 20). DCN 02398.
OEPA. 2003b. Ohio Environmental Protection Agency. Authorization to Discharge Under the
National Pollution Discharge Elimination System NPDES OH0000523 - Millennium Inorganic
Chemicals Ashtabula Plant II, Ashtabula, OH. Columbus, OH. (March 20). DCN 02399.
Schildt, Bill. 2006. Millennium Inorganic Chemicals Inc. Letter to Ellie Codding of Eastern
Research Group, Inc. "Re: February 23, 2006 Letter from Jan Matuszko of EPA Regarding 2002
and 2003 TRI Dioxin Reported Discharges." (March 1). DCN 03307.
TDEC. 2004. Tennessee Department of Environment and Conservation. State of Tennessee
National Pollution Discharge Elimination System Permit NPDES TN0001465 - Du Pont New
Johnsonville Plant, New Johnsonville, TN. Nashville, TN. (August 1). DCN 02402.
TIG. 2005. The Innovation Group. Chemical profile for titanium dioxide. Available online at:
http://www.the-innovation-group.com/chemprofile.htm. Date accessed: September 2005. DCN
02541.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1982. Development Document for Effluent Limitations Guidelines and Standards for
the Inorganic Chemicals Manufacturing Point Source Category. EPA-440/1-82/007.
Washington, DC. (June).
9-26
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Section 9.0 - Inorganic Chemicals Manufacturing
U.S. EPA. 1994. Method 1613B Tetra- through Octa-Chlorinated Dioxins and Furans by
Isotope Dilution HRGC/HRMS. Washington, DC. (October). DCN 03977.
U.S. EPA. 1998. Final Technical Background Document Identification and Description of
Mineral Processing Sectors and Waste Streams. Washington, DC. (April). DCN 03330.
U.S. EPA. 2001. Final Titanium Dioxide Listing Background Document for the Inorganic
Chemical Listing Determination. Washington, DC. (October). DCN 03331.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
U.S. EPA. 2005c. The Inventory of Sources and Environmental Releases of Dioxin-Like
Compounds in the U.S.: the Year 2000 Update. EPA/600/P-03/002A. Washington, DC.
(March). Available online at: http://www.epa.gov/ncea/pdfs/dioxin/2k-update.
USGS. 2006. U.S. Geological Survey. USGSMinerals Yearbook. "Titanium and Titanium
Dioxide." Available online at:
http://minerals.usgs.gov/minerals/pubs/commodity/ltitanium/tidiomcs06.pdf. Date accessed:
April 2006. DCN 03978.
Wood, Kenneth. 2006. E-mail correspondence with Kenneth Wood of Du Pont and Eleanor Ku
Codding of Eastern Research Group, Inc. (January and February). DCN 03326.
Zweig, Greg. 2000. Letter to Mr. Akil Al-Chokhachi, City of Memphis, from Greg Zweig, Site
Environmental Coordinator, DuPont Memphis Plant. (March 13). DCN 02675.
9-27
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Section 10.0 - Nonferrous Metals Manufacturing
10.0 NONFERROUS METALS MANUFACTURING (40 CFR PART 421)
EPA selected the Nonferrous Metals Manufacturing (NFMM) Category for
additional data collection and analysis because of the high TWPE identified in the 2005
screening-level review, (see Table V-l, 70 FR 51050, August 29, 2005). The 2004 Plan
summarizes the results of EPA's previous review of this industry (U.S. EPA, 2005a). This
section summarizes the 2005 annual review and also describes EPA's 2006 annual review of the
discharges associated with the NFMM Category. EPA's 2006 annual review builds on the 2005
annual review. EPA identified facilities contributing the most TWPE and reviewed discharges of
fluoride and cyanide from the primary aluminum industry as part of the 2006 review.
10.1 NFMM Category Background
This section provides background on the NFMM Category including a brief
profile of the NFMM industry and background on 40 CFR Part 421.
10.1.1 NFMM Industry Profile
The nonferrous metals manufacturing industry includes facilities that smelt and
refine metals other than steel, such as aluminum, copper, and nickel (U.S. EPA, 2005b).
Although facilities with many SIC codes could perform operations covered by Part 421, the main
SIC codes that are covered by the NFMM ELGs are:
• 3331: Primary Smelting and Refining of Copper;
• 3334: Primary Production of Aluminum;
• 3339: Primary Smelting and Refining of Nonferrous Metals, Except
Copper and Aluminum;
• 3341: Secondary Smelting and Refining of Nonferrous Metals; and
• A portion of 2819: Inorganic Chemicals, Not Elsewhere Classified (NEC).
SIC code 2819 also includes facilities subject to 40 CFR Part 415: Inorganic
Chemicals Manufacturing Point Source Category. In 2004, EPA reviewed the facilities reporting
under SIC code 2819 and identified six facilities that are known to perform NFMM operations,
including the production of refined bauxite, alumina, slug uranium (radioactive), liquid metals,
and several inorganic metals (U.S. EPA, 2004). Because the U.S. Economic Census reports data
by NAICS code, and TRI and PCS report data by SIC code, EPA reclassified the 2002 U.S.
Economic Census data by equivalent SIC code. The facilities in SIC code 2819 that are possibly
subject to the NFMM ELGs do not correlate directly to a NAICS code, and therefore EPA could
not determine the number of facilities in the 2002 U.S. Economic Census for SIC code 2819.
Table 10-1 lists the five SIC codes with operations in the NFMM Category. SIC
code 3334: Primary Production of Aluminum has the largest number of facilities with data in
PCS.
10-1
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-1. Number of Facilities in NFMM SIC Codes
SIC Code
2819: Inorganic Chemicals, NECC
3331: Primary Smelting and Refining of Copper
3334: Primary Production of Aluminum
3339: Primary Smelting of Nonferrous Metals, Except
Copper and Aluminum
3341: Secondary Smelting and Refining of Nonferrous
Metals
Total
2002 U.S.
Economic
Census
NAd
15
41
170
417
>643d
2002 PCS3
3
3
23
11
13
53
2002 TRIb
o
6
6
21
30
182
242
2003 TRIb
4
5
21
29
163
221
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
"Major and minor dischargers.
bReleases to any media.
°EPA identified facilities known to perform NFMM operations.
dPoor bridging between NAICS and SIC codes. Number of facilities could not be determined.
NA - Not applicable.
NEC - Not elsewhere classified.
NFMM facilities discharge directly to surface water as well as to POTWs. Table
10-2 presents the types of discharges reported by facilities in the 2002 TRI database. The
majority of facilities reporting to TRI reported no water discharges, but facilities may be
discharging pollutants in wastewater at levels below the TRI-reporting thresholds.
Table 10-2. NFMM Category Facilities by Type of Discharge Reported in TRI 2002
SIC Code
2819: Inorganic Chemicals, NEC3
3331: Primary Smelting and Refining of
Copper
3334: Primary Production of Aluminum
3339: Primary Smelting of Nonferrous
Metals, Except Copper and Aluminum
3341: Secondary Smelting and Refining of
Nonferrous Metals
Reported
Only Direct
Discharges
3
1
11
7
44
Reported
Only Indirect
Discharges
0
2
0
5
23
Reported
Both Direct
and Indirect
Discharges
0
0
2
3
14
Reported No
Water
Discharges
0
2
8
14
101
Source: TRIReleases2002_v4.
aEPA identified facilities known to perform NFMM operations.
NEC - Not elsewhere classified.
10-2
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.1.2 40 CFR Part 421
EPA first promulgated ELGs for the NFMM Category (40 CFR Part 421) on
March 8, 1984 (49 FR 8790). Below is a brief summary of the category's ELGs. All 31
subcategories have NSPS and PSNS standards. Fourteen subcategories do not have PSES
standards; the Bauxite Refining and Primary Copper Smelting Subcategories are limited to zero
discharge of process wastewater under BPT, BAT, and NSPS; and EPA reserved BPT and BAT
limitations for four subcategories (Secondary Indium, Secondary Mercury, Secondary Nickel,
and Primary Rare Earth Metals). Most NFMM subcategories include limitations guidelines for
lead, chromium, copper, arsenic, and zinc.
Section 5.3.2 of the 2004 TSD lists the regulated priority and nonconventional
pollutants in the NFMM Category (U.S. EPA, 2005b).
10.2 NFMM Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the NFMM Category
including the screening-level review and category-specific review.
10.2.1 NFMM Category 2005 Screening-Level Review
Table 10-3 presents the NFMM Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 10-3. NFMM Category 2005 Screening-Level Review Results
Rank
6
Point Source Category
Nonferrous Metals Manufacturing
2002 PCS TWPEb
450,525
2002 TRI TWPEC
63,694
Total TWPE
514,219
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
10.2.2 NFMM Category 2005 Pollutants of Concern
Table 10-4 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. The estimated TWPE from the PCS database is much greater than the
TWPE from the TRI database. Cadmium contributed 28 percent of the category TRI TWPE for
2002 and approximately 22 percent of the PCS TWPE for 2002.
10-3
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-4. 2005 Annual Review: NFMM Category Pollutants of Concern
Pollutant
Cadmium and
Cadmium Compounds
Chlorine
Silver
PCBs
Molybdenum
Sodium Nitrite
Phosphorous
Arsenic and Arsenic
Compounds
PACs
NFMM Category
Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
20
25
9
6
5
Total Pounds
Released
4,282
178,125
3,028
1.4
237,108
TWPE
98,997
90,694
49,871
48,550
47,763
Pollutants are not in the top five PCS 2002
reported pollutants.
53C
206,294,722
450,525
2002 TRIb
Number of
Facilities
Reporting
Pollutant
7
Total
Pounds
Released
789
TWPE
18,245
Pollutants are not in the top five TRI
2002 reported pollutants.
1
2
15
o
3
114C
21,708
298
1,492
48
2,342,514
8,104
6,266
6,031
4,831
63,694
Source: PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
10.3
10.4
Potential New Subcategories for the NFMM Category
EPA did not identify any potential new subcategories for the NFMM Category.
NFMM Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the NFMM Category. EPA obtained additional data
and identified:
Facilities classified in the wrong category;
Errors in how PCS loads were estimated for four facilities; and
Changes in estimates of TWPE for sodium nitrite.
10.4.1
NFMM Category Facility Classification Revisions
EPA reviewed permits for facilities in the SIC codes covered by the NFMM
Category and determined that discharges from five facilities are not subject to the NFMM ELGs.
EPA changed the category classifications of these facilities in the revised databases,
TRIReleases2002 v4 and PCSLoads2002 v4, as described in Section 4.5 of the TSD. Table
10-5 lists EPA's findings and corrections for these five facilities.
10-4
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-5. NFMM Category Facilities Classified in Wrong Category
TRiro
(NPDES ID)
Facility
Findings
Resulting Database Change
72011-LCRKN-
USfflG
(AR0000582)
ALCOA Bauxite
Discharges result from the reclaimed mine drainage and
maintenance of the closed ALCOA and Reynolds
Metals Bauxite Residue Disposal Areas. Discharges are
regulated by 40 CFR Part 440: Ore Mining and Dressing
(ADEQ, 2005a; ADEM, 2005b).
Incorporated change into PCS and TRI databases. In
PCSLoads2002_v4 and TRIReleases2002_v4, facility loads are now
included under 40 CFR Part 440.
47903-LCLFY-
EASTM
(IN0001210)
ALCOA Lafayette
Works
Facility manufactures fabricated aluminum products.
Discharges are regulated by 40 CFR Part 467:
Aluminum Forming (IDEM, 2002; IDEM, 2001).
Incorporated change into PCS database. lnPCSLoads2002_v4,
facility loads are now included in 40 CFR Part 467 review. NO
changes were made in TRIReleases2002_v4 because the facility
loads were already included under 40 CFR Part 467.
42351-CMMNW-
KYHWY
(KY0002666)
Commonwealth
Aluminum
Discharges are regulated by 40 CFR Part 465: Coil
Coating (KDEP, 2002).
Incorporated change into PCS database. lnPCSLoads2002_v4,
facility loads are now included under 40 CFR Part 465. Facility
reported no water discharges to TRI in 2002, so no changes were
made to TRIReleases2002 v4.
84006-KNNCT-
8362W
(UT0000051)
Kennecott Utah
Facility is an integrated copper mine, smelter, and
refiner producing copper anodes and cathodes, by-
product sulfuric acid, and co-product gold, silver,
selenium, platinum, lead carbonate, and palladium.
Discharges are regulated by 40 CFR Part 440: Ore
Mining and Dressing and by Part 421: Nonferrous
Metals Manufacturing. The majority of the facility's
TWPE are from outfalls regulated by 40 CFR Part 440
(UDEQ, Unknown).
Incorporated change into TRI database. In TRIReleases2002_v4,
facility loads are now included under 40 CFR Part 440. No changes
were made in PCSLoads2002_v4 because the facility loads were
already under 40 CFR Part 440.
37040-SVGZN-
1800Z
(TN0029157)
Pasminco Zinc
Facility manufactures zinc metal, co-product cadmium
metal, sulfuric acid, and metallurigically valuable by-
products. Permit limits are based on 40 CFR Part 421
Subpart H - Primary Zinc and Subpart I - Metallurgical
Acid Plants (TDEC, 2005).
Incorporated change into PCS database. In TRIReleases2002_v4,
facility loads are now included under 40 CFR Part 421 instead of 40
CFR Part 440. No changes were made inPCSLoads2002_v4
because the facility loads were already under 40 CFR Part 421.
Source: TRIReleases2002_v4; PCSLoads2002_v4; Facility Permits and Fact Sheets (IDEM, 2002; IDEM, 2001; ADEQ, 2005a; ADEM, 2005b; KDEP, 2002; UDEQ, Unknown;
TDEC, 2005).
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.4.2
NFMM Category Facility Discharge Revisions
EPA reviewed permits and discharge monitoring reports for four facilities with
discharges contributing a majority of the 2002 PCS TWPE in the SIC codes covered by the
NFMM Category. EPA determined that, because of assigned outfall names, PCSLoads2002_v2
was double counting loads from four facilities. EPA corrected the double counting in the revised
database, PCSLoads2002_v4, as described in Section 4.5 of this TSD. Table 10-6 lists EPA's
findings and corrections for these four facilities.
Table 10-6. NFMM Category Facilities with Discharge Revisions
TRIID
(NPDES ID)
13662-LMNMC-
PARKA
(NY0001732)
NAa
(TN0065081)
65440-BCKMN-
HWYKK
(MO0000337)
62024-LNCRP-LEWIS
(NAb)
Facility
ALCOA Massena
West
ALCOA South Plant
Doe Run Resources
Recycling
Olin Corporation
Double Counting Identified
Outfalls 0 IB, 0 ID, 01E, OIF,
01H, 03 A, and SUM were
included in other outfalls
(NYSDEC, 2003; NYSDEC,
2001).
Outfall 006A was included in
outfall 006 (TDEC, 2004b;
TDEC, 2004a).
Outfall 004 is an in-stream
monitoring location (MDNR,
2004).
Facility manufactures brass for
the automotive, housing,
electronics, coinage, and
ammunition industries (Olin,
2000). Discharges of total
phosphorous were incorrectly
reported to TRI as discharges of
phosphorous (yellow or white)
(Reddington, 2005). Facility
reports to TRI under two IDs.
Resulting Database Change
EPA excluded the discharges
from these outfalls in
PCSLoads2002_v4.
lnPCSLoads2002_v4, EPA
revised the discharges from
outfall 006, reducing the
TWPE by approximately 25
percent.
lnPCSLoads2002_v4, EPA
set the discharges from
outfall 004 to zero.
In TRIReleases2002_v4, EPA
set phosphorous (yellow or
white) discharges to zero.
Source: PCSLoads2002_v2; PCSLoads2002_v4; TRIReleases2002_v2; TRIReleases2002_v4; Facility Permits and
Fact Sheets (MDNR, 2004; NYSDEC, 2003; NYSDEC, 2001; TDEC, 2004b; TDEC, 2004a).
"Facility does not report to TRI.
bFacility does not report to PCS.
NA - Not available.
10-6
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.4.3
NFMM Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, BAD
revised the TWF and POTW percent removal values used for sodium nitrite in the TRI and PCS
databases to better reflect the pollutant's properties. The TWF that BAD applies for sodium
nitrite is now 0.0032 (formerly 0.373), and the POTW percent removal is now 90 percent
(formerly 1.85 percent). Table 10-7 presents the loads before and after corrections to sodium
nitrite TWF and POTW percent removal for the NFMM Category.
Table 10-7. Impact of Changes to TWF and POTW Percent Removal for the NFMM
Category
Database
TRI 2002
Pollutant
Sodium Nitrite
Number of Facilities
Reporting
Discharges
2a
TWPE from 2005
Review
8,104
TWPE from 2006
Review
14
Sources: TRIReleases2002_v2; TRIReleases2002_v4.
aNumber of facilities reporting discharges of sodium nitrite to TRI in 2002 for the revised database,
TRIReleases2002_v4, increased due to moving U.S. DOE Portsmouth Gaseous Diffusion Plant from the Inorganic
Chemicals Category to the NFMM Category.
10.4.4
NFMM Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings based on methodology changes as described in Section 4.2 and changes made based on
permit review. For the NFMM Category, the most significant changes are also described in
Sections 10.5.1 through 10.5.3. Table 10-8 shows the 2006 screening-level TWPE estimated for
the NFMM Category from the 2002 and 2003 TRI and 2002 PCS databases.
Table 10-8. NFMM Category 2006 Screening-Level Review Results
Point Source Category
Nonferrous Metals Manufacturing
2002 PCS TWPEa
394,881
2002 TRI TWPEb
57,093
2003 TRI TWPEb
78,400
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
10.4.5
NFMM Category 2006 Pollutants of Concern
Table 10-9 presents the pollutants of concern for the NFMM Category based on
the 2006 annual review.
10-7
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-9. 2006 Annual Review: NFMM Category Pollutants of Concern
Pollutant
Cadmium and
Cadmium
Compounds
Chlorine
Silver
Molybdenum
Aluminum
Manganese and
Manganese
Compounds
PACs
Lead and Lead
Compounds
Copper and
Copper
Compounds
NFMM Category
Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
12
17
4
5
21
Total
Pounds
Released
4,246
165,958
3,028
237,108
448,672
TWPE
98,153
84,500
49,871
47,763
29,025
Pollutants are not in the top five PCS 2002
reported pollutants.
46C
118,048,210
396,740
2002 TRIb
Number of
Facilities
Reporting
Pollutant
7
Total
Pounds
Released
987
TWPE
22,822
Pollutants are not in the top five TRI 2002
reported pollutants.
20
73
64
112C
83,684
48
2,001
5,494
2,397,391
5,894
4,832
4,483
3,488
51,819
2003 TRIb
Number of
Facilities
Reporting
Pollutant
11
Total
Pounds
Released
1,311
TWPE
30,296
Pollutants are not in the top five TRI 2003
reported pollutants.
19
5
70
58
104C
90,809
168
3,055
6,471
2,755,833
6,396
16,921
6,844
4,108
78,400
oo
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.4.6 NFMM Category 2006 Top Discharging Facilities
The PCS discharges account for approximately 88 percent of the combined TRI
and PCS TWPE for 2002. The remainder of this section focuses on discharges reported to PCS
in 2002. Table 10-10 lists the eight facilities in the NFMM Category with the largest discharges
in PCS for 2002.
EPA obtained permits and detailed PCS data, researched facility operations, and
analyzed the available pollutant discharge data for these top discharging facilities. Table 10-11
presents EPA's findings.
10.5 Primary Aluminum Subcategory
During the 2006 screening-level review, EPA determined that the Primary
Aluminum Subcategory accounted for approximately 34 percent of the NFMM Category TWPE
in PCSLoads2002_v4. EPA noted that two facilities contributing the top pollutant loads in terms
of TWPE for the NFMM Category were primary aluminum manufacturers, leading EPA to
review discharges from all facilities with operations subject to the Primary Aluminum
Subcategory. For this reason, Section 10.5 focuses on the Primary Aluminum Subcategory.
10.5.1 Primary Aluminum Industry Profile
Primary aluminum facilities produce aluminum by the electrolytic reduction of
alumina via the Hall-Heroult Process. In addition to producing aluminum metal and various
aluminum alloys, some primary aluminum facilities carry out an additional refining step to
produce higher purity aluminum.
According to the U. S. Geological Survey's Minerals Industry Surveys of Primary
Aluminum Plants Worldwide (USGS, 2006), conducted in 1998, 23 facilities in the United States
have primary aluminum operations. Table 10-12 lists these facilities along with their current
owners and operating status. All of the facilities are direct dischargers. Two are minor
dischargers: Columbia Falls Aluminum (MT0030066) and ALCOA Mt. Holly (SC0036153).
Primary aluminum manufacturing in the United States has decreased slightly over the past two
years due to increases in energy and alumina costs (Plunkert, 2006).
10-9
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-10. 2006 Annual Review: NFMM Category Top Discharging Facilities in PCS
NPDES ID
TN0029157
IN0001155
MO0000337
LAO 110931
TN0065081
PA0002208
MO0001121
PAOO 12751
Facility Name
Pasminco Zinc
ALCOA
Warrick
Doe Run
Resources
Recycling
CS Metals of
LA Inc.
ALCOA South
Plant
Horsehead
Corporation
Doe Run
Glover Smelter
Zinc
Corporation of
America
Facility
Location
Clarksville,
TN
Newburgh,
TN
Boss, MO
Convent,
LA
Alcoa, TN
Monaca, PA
Annapolis,
MO
Palmerton,
PA
Applicable 40 CFR
Part 421 Subpart
Subpart H - Primary
Zinc; Subpart I -
Metallurgical Acid
Plants
Subpart B - Primary
Aluminum
Subpart M -
Secondary Lead
Subpart T -
Secondary
Molybdenum and
Vanadium
Subpart B - Primary
Aluminum
Subpart G - Primary
Lead
Subpart G - Primary
Lead
Subpart H - Primary
Zinc; Subpart F -
Primary Copper
Total Pounds
Discharged
1,403,459
751,753
5,704,134
543,086
4,500,150
316,657
2,253,820
88,499
Total
TWPE
73,745
71,361
51,375
47,309
26,295
23,274
21,885
13,399
Percentage
of NFMM
Category
PCS 2002
TWPE
18.6%
18.0%
12.9%
11.9%
6.6%
5.9%
5.5%
3.4%
Source: PCSLoads2002 v4.
10-10
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-11. Top Discharging NFMM Category Facilities
Facility
TWPE from
Discharge of
Top Pollutant
(Top Pollutant)
Manufacturing and
Product Information
ELG Used for Permit
Findings
Pasminco
Zinc
62,362
(cadmium)
Manufactures zinc metal,
co-product cadmium
metal, sulfuric acid,
metallurgically valuable
by-products
40CFRPart421SubpartH
- Primary Zinc; Subpart I -
Metallurgical Acid Plants
Process water outfall has a daily maximum cadmium limit of
3.59 Ib/day and a monthly average of 1.44 Ib/day. Facility is
required to report discharge of cadmium from four stormwater
outfalls. All of the measured cadmium concentrations for the
stormwater outfalls are above Tennessee's target storm water
cadmium concentration of 0.0159 mg/L (TDEC, 2005).
ALCOA
Warrick
70,011
(chlorine)
Produces aluminum sheet
using primary aluminum
smelting (ALCOA,
2006d)
40 CFR Part 423: Steam
Electric Power Generating
Point Source Category and
40 CFR Part 421 Subpart B
- Primary Aluminum
(IDEM, 2004)
EPA determined the chlorine discharges, although permitted
under Part 423, should be included in the NFMM Category
since Part 423 does not apply to integrated power generating
plants. However, because the chlorine discharges do not derive
from NFMM operations, EPA will exclude the chlorine load
from further review.
Doe Run
Resources
Recycling
49,556
(silver)
Recycles and recovers
lead from lead-acid
batters and other lead-
bearing wastes with trace
metal recovery, sulfuric
acid manufacturing, and
polyethylene plastic
recycling (Doe Run Co,
2004b)
40 CFR Part 421 Subpart M
- Secondary Lead
Silver discharges are limited to 0.013 mg/L daily maximum for
all the outfalls (MDNR, 2003b; MDNR, 2003a). Discharges of
silver decreased by 99 percent from 2002 to 2005.
CS Metals of
LA Inc.
42,576
(molybdenum)
Recovers molybdenum
oxide, vanadium oxide,
and alumina from
petrochemical catalysts
40 CFR Part 421 Subpart T
- Secondary Molybdenum
and Vanadium
Permit does not include molybdenum limits, but the facility is
required to report discharges (LDEQ, 2002). U. S. GS Mineral
Industry Survey for Vanadium reported the facility closed in
December 2004 (U. S. GS, 2005). Discharges of molybdenum
have decreased tenfold from 2002 to 2005. EPA will exclude
this facility's discharges from future reviews.
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-11 (Continued)
Facility
TWPE from
Discharge of
Top Pollutant
(Top Pollutant)
Manufacturing and
Product Information
ELG Used for Permit
Findings
ALCOA
South Plant
25,441
(aluminum)
Produces aluminum sheet
using primary aluminum
smelting (ALCOA,
2006c)
40 CFR Part 421 Subpart B
- Primary Aluminum
Smelting (q) Direct Chill
Casting Contact Cooling
Permit includes aluminum limits for all outfalls and facility is
required to monitor aluminum in stormwater (TDEC, 2004a),
(TDEC, 2004b). Approximately 98 percent of the aluminum
discharges reported to PCS in 2002 are from stormwater
outfalls and are above Tennessee's target storm water
aluminum concentration of 0.75 mg/L (U.S. EPA, 1989; Janjic,
2006).
Horsehead
Corporation
o
to
13,016
(chlorine)
Manufactures zinc metal
and zinc oxides (PDEP,
200 la)
40 CFR Part 423: Steam
Electric Power Generating
Point Source Category and
40 CFR Part 421
EPA determined the chlorine discharges, although permitted
under Part 423, should be included in the NFMM Category
since Part 423 does not apply to integrated power generating
plants. However, because the chlorine discharges do not derive
from NFMM operations, EPA will exclude the chlorine load
from further review.
Doe Run
Glover
Smelter
20,229
(cadmium)
Produces lead
40 CFR Part 421 Subpart G
- Primary Lead
Operations at the Doe Run Glover Smelter were suspended in
December 2003 due to decreased U.S. lead demand. The
facility is in "care and maintenance" status to ensure it can be
quickly restarted if the demand for lead increases (Doe Run Co,
2004a). The facility has a current NPDES permit but EPA
believes the facility is not currently discharging (MDNR, 2005).
EPA will exclude discharges from this facility from future
review because the facility is not operating.
Zinc
Corporation
of America
11,285
(cadmium)
Produces powder zinc
and copper-based alloys
and concentrated zinc
material for smelting at
other facilities
40 CFR Part 421 Subpart H
- Primary Zinc and Subpart
F - Primary Copper
Cadmium permit limits are 0.20 mg/L daily maximum and 0.10
mg/L monthly average (PDEP, 200 Ib). The facility
consistently discharges cadmium below the permitted levels for
the outfalls with cadmium limits and the monitor-only outfalls.
Source: PCSLoads2002_v2; Facility Permits and Fact Sheets (MDNR, 2003b; MDNR, 2003a; TDEC, 2004b; TDEC, 2004a; TDEC, 2005; IDEM, 2004; LDEQ,
2002; PDEP, 2001a; MDNR, 2005; PDEP, 200Ib); "ALCOA Warrick Operations" (ALCOA, 2006d); "Boss, MO" (Doe Run Co, 2005b); "Vanadium in January
2005" (U.S. GS, 2005); "ALCOA Tennessee Operations" (ALCOA, 2006c); Development Document for Effluent Limitations Guidelines and Standards for the
Nonferrous Metals Manufacturing Point Source Category Vol. //(U.S. EPA, 1989); "Glover, MO" (Doe Run Co, 2004a).
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-12. U.S. Primary Aluminum Facilities Owners and Operating Status
NPDES ID
IN0001155
KY0001821
KY0004278
MD0002429
MOO 105732
MT0030066
NC0004308
NY0000132
NY0001732
OHOO 11550
OR0000060
OR0001708
SC0036153
TN0065081
TX0004715
WA0000299
WA0000680
WA0000086
WA0000876
WA0000931
WA0000540
WA0002950
WV0000779
Facility Name
ALCOA Warrick
Alcan Sebree
National Southwire
Aluminum Hawesville
Eastalco Aluminum
Noranda Aluminum
Columbia Falls Aluminum
ALCOA Badin Works
ALCOA Massena East
ALCOA Massena West
Ormet Hannibal
ALCOA Troutdale
Northwest Aluminum
Specialties
ALCOA Mt. Holly
ALCOA South Plant
ALCOA Point Comfort
Evergreen Aluminum
ALCOA Wenatchee Works
Longview Aluminum
CVB Northwest
Port of Washington
Goldendale Aluminum
Intalco Works
Century Aluminum
Location
Evansville, IN
Sebree, KY
Hawesville, KY
Frederick, MD
New Madrid, MO
Columbia Falls, MO
Badin, NC
Massena, NY
Massena, NY
Hannibal, OH
Troutdale, OR
The Dalles, OR
Mt. Holly, SC
Alcoa, TN
Rockdale, TX
Vancouver, WA
Wenatchee, WA
Longview, WA
Mead, WA
Tacoma, WA
Goldendale, WA
Ferndale, WA
Ravenswood, WA
Company
ALCOA
Alcan
Southwire
ALCOA
Noranda Incorporated
Glencore Group
ALCOA
ALCOA
ALCOA
Ormet Corp.
ALCOA
Northwest Aluminum
Specialties
ALCOA and Century
Aluminum
ALCOA
ALCOA
Glencore Group
ALCOA
Longview Aluminum
Commercial
Development Company
Port of Washington
Goldendale Aluminum
Company
ALCOA
Century Aluminum
Company
Operating
Status3
Reduced capacity
Operating
Operating
Operating
Operating
Reduced capacity
Reduced capacity
Operating
Operating
Operating
Closed
Operating
Operating
Operating
Operating
Closed
Operating
Closed
Reduced capacity
Closed
Closed
Reduced capacity
Operating
Source: "ALCOA Warrick Operations - Evansville" (ALCOA, 2006d); ALCOA Takes Full Ownership of Intalco
and Eastalco Smelters in Washington and Maryland; Signs Agreement for NW Power" (ALCOA, 2006b);
"Aluminum, Alumina, and Bauxite" (Glencore, 2006); ALCOA Badin Works (ALCOA, 2006a); "ALCOA Begins
Troutdale Site Restoration" (ALCOA, 2003); "Smelters Final Hopes Melt" (Forgey, 2004); "Port Prepares to
Demolish Kaiser Smokestack" (Port of Tacoma, 2000).
aClosed means facilities that were idle and facilities that were dismantled. Reduced capacity means facilities that
were not operating at full production capacity.
10-13
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.5.2
40 CFR Part 421 Subpart B
Subpart B of 40 CFR Part 421 regulates direct and indirect discharges from
primary aluminum manufacturers. This subcategory is divided into 17 subparts defined by
production process. Each subpart includes production-normalized BPT and BAT limitations
guidelines. For example, the BAT effluent limitation for aluminum for Subpart (r) - Continuous
Rod Casting Contact Cooling is 0.282 mg/kg of aluminum product from rod casting. Table
10-13 summarizes the BAT treatment effectiveness concentrations used to develop the
limitations in Part 421 Subpart B. Subparts (a) through (m) also include NSPS and PSNS.
Table 10-13. Primary Aluminum Subcategory BAT Treatment Effectiveness
Concentrations
Pollutant
Aluminum
Antimony
Benzo(a)pyrene
Cyanide
Fluoride
Nickel
TSS
One-Day Maximum (mg/L)
7.8
12.0
0.0337
4.5
59.5
2.3
61.5
30-Day Average (mg/L
3.5
5.4
0.0156
2.0
26.4
1.0
27.3
Source: Development Document for Effluent Limitations Guidelines and Standards for the Nonferrous Metals
Manufacturing Point Source Category Fo///(U.S. EPA, 1989).
The basis for the existing BAT ELGs for the Primary Aluminum Subcategory is:
• In-process recycling of air pollution wastewater and contact cooling water;
• Lime precipitation and sedimentation;
• Multimedia filtration; and
Cyanide precipitation (U.S. EPA, 1989).
10.5.3
Primary Aluminum 2006 Pollutants of Concern
Table 10-14 presents the top five pollutants reported to PCS in 2002 by primary
aluminum facilities and the number of facilities for which the 2002 discharge load is greater than
zero. The top five pollutants account for approximately 96 percent of the Primary Aluminum
Subcategory's discharges in PCS for 2002.
Chlorine Discharges
Of the Primary Aluminum Subcategory's 2002 chlorine discharges in PCS,
approximately 98 percent were from the ALCOA Warrick facility. Because these chlorine
discharges do not derive from NFMM operations, as described in Table 10-11, the chlorine load
is excluded from further review.
10-14
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-14. 2006 Annual Review: Primary Aluminum Subcategory Pollutants of Concern
Pollutant
Chlorine
Aluminum
Fluoride
Cyanide
PCB-1248
Number of Facilities with Discharge
Greater than Zero
14
18
19
13
1
Primary Aluminum Subcategory Total
Total
Pounds
Discharged
139,942
446,539
462,328
7,614
0.4
1,603,333
TWPE
71,253
28,887
16,182
8,504
3,527
133,426
Percentage of
Subcategory
TWPE
53.4%
21.7%
12.1%
6.4%
2.6%
Percentage
of Category
TWPE
18.0%
7.3%
4.1%
2.1%
0.9%
32.4%
Source: PCSLoads2002_v4.
Aluminum Discharges
Of the Primary Aluminum Subcategory's 2002 aluminum discharges in PCS, 88
percent were from the ALCOA South Plant. As described in Table 10-11, 98 percent of the
aluminum discharges that the ALCOA South Plant reported to PCS in 2002 are from stormwater
outfalls. EPA determined discharges applicable to the Primary Aluminum Subcategory would
not include stormwater: "... stormwater is or can be segregated from the process wastewater"
(U.S. EPA, 1989). EPA determined stormwater discharges from primary aluminum
manufacturing facilities should be "addressed on a case-by-case basis by the permit writer" (U.S.
EPA, 1989). The ALCOA South Plant facility is required to monitor aluminum in their
stormwater. The reported concentrations of aluminum in the stormwater (1.08 mg/L to 47.3
mg/L for all the stormwater outfalls) are discharged above the Tennessee target stormwater
aluminum concentration of 0.75 mg/L (TDEC, 2004a; TDEC, 2004b). For two of the facility's
stormwater outfalls, the aluminum concentrations are above the Primary Aluminum Subcategory
BAT treatment effectiveness concentration of 7.8 mg/L daily maximum (U.S. EPA, 1989).
Fluoride and Cyanide Discharges
EPA identified the Primary Aluminum Subcategory for additional review, in part,
because of the large number of facilities reporting discharges of fluoride and cyanide. Of the 23
primary aluminum facilities, 21 report discharges of fluoride and 19 report discharges of
cyanide. Section 10.5.4 and 10.5.5 present the results of additional reviews of the fluoride and
cyanide discharges. No one facility discharges a majority of the fluoride or cyanide.
PCB-1248 Discharges
The ALCOA Massena West facility is the only facility in the Primary Aluminum
Subcategory for which PCS includes data for 2002 discharges of PCB-1248. Because the facility
has not reported discharges of PCB-1248 since January 2004, EPA did not collect any additional
information about this pollutant.
10-15
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.5.4 Primary Aluminum Wastewater Sources of Fluoride
This subsection describes the primary aluminum manufacturing process and the
generation of fluoride-containing wastewater. Primary aluminum smelting takes place in
electrolytic cells, in which alumina, the principle ore of aluminum, is dissolved in molten
cryolite (NasAlFe). The cells are heated to approximately 950°F and an electrical current is
passed through the molten cryolite to force the aluminum ions to migrate to the cathode, where
they are reduced to aluminum metal. Because the reduced molten aluminum is heavier than the
molten cryolite, the molten aluminum forms a layer at the bottom of the cell. The electrolytic
cells emit gases containing fluoride compounds that are collected in hoods above the cells. The
collected gases are treated using dry air scrubbing or wet scrubbing processes, which generate
wastewater. The molten aluminum, collected in the bottoms of the cells, is sent for further
refining and alloying. Refining consists of fluxing to remove impurities and degassing to
remove trapped hydrogen gas from the molten aluminum. The refined aluminum is typically
cast into ingots or billets (U.S. EPA, 1989).
In the electrolytic cells, called the pot liner, the anode is made of coal tar pitch
and coke, while the cathode is the carbon lining of the cell. The anodes are consumed when the
negative charge (electrons) is transferred to the aluminum ions to reduce the aluminum.
Therefore, the anodes must be replaced and recycled periodically when they become too small to
be effective. In the recycling process, the anodes are crushed and made into paste, which is
formed into briquettes and baked to create new anodes. The recycled anodes contain impurities
that collect on them in the cells. Fluoride, one of the impurities, is released as gas when the
recycled anodes are baked. The emissions are treated using dry or wet scrubbing processes. The
pot liners can also be reprocessed to reduce the amount of hazardous waste generated. The pot
liners are ground and leached with caustic to solubilize the fluoride deposits. The solids are
removed from the leaching solution using sedimentation. Sodium aluminate (NaAlC^) is added
to the solution to precipitate cryolite (NasAlFe). The resulting cryolite precipitate is recovered
for use in the electrolytic cells. Lime is added to the remaining solution to precipitate calcium
fluoride (CaF2). The remaining solution is then used as the leachate at the beginning of the pot
liner reprocessing (U.S. EPA, 1989).
The air pollutants emitted during primary aluminum smelting are particulates,
sulfur dioxide (862), carbon monoxide (CO), carbon dioxide (€62), tars, oils, and fluoride
compounds. The dry air scrubbing process uses sandy alumina, prior to its use in the electrolytic
cells. The scrubber process removes pollutants from exhaust gases and recovers them for reuse
in the process. Dry air scrubbing cannot be used for the manufacture of high purity alloys
because using the alumina in the scrubber concentrates the impurities, reducing the quality of the
metal produced. The wet air scrubbing process generates large wastewater discharges containing
fluoride and TSS. The wastewater generation can be reduced by adding lithium carbonate to
electrolytic cells. The lithium carbonate reduces the fluoride compound emissions and power
consumption, and it increases aluminum production by controlling the physical properties such
as melting point, electrical conductivity, and density (U.S. EPA, 1989).
10-16
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-15 lists the primary aluminum facilities that reported discharges of
fluoride to PCS in 2002.
EPA obtained additional, detailed PCS concentration data for 14 of the 21
primary aluminum facilities that reported discharges of fluoride to PCS in 2002. The remaining
facilities reported quantities (e.g., pounds per day) of fluoride to PCS in 2002. Table 10-16
presents the reported average concentrations of fluoride discharged by these facilities for outfalls
that were included in PCSLoads2002_v4.
The median fluoride concentrations reported by primary aluminum facilities, as
shown in Table 10-16, are all less than the fluoride BAT treatment effectiveness concentrations
of 26.5 mg/L monthly average (U.S. EPA, 1989). The current treatment technologies perform
better than the "best" treatment (BAT) at the time the existing ELGs were developed.
10.5.5 Primary Aluminum Wastewater Sources of Cyanide
The high temperatures and reducing environment found in aluminum electrolytic
cells induce the formation of cyanide. Cyanide gas is emitted from the cells and treated with
other off gases using dry air scrubbing or wet scrubbing processes. Pot liner reprocessing also
generates cyanide-bearing wastewater (U.S. EPA, 1989).
Table 10-17 lists the primary aluminum facilities with cyanide discharges in PCS
for 2002.
EPA obtained additional, detailed PCS concentration data for 8 of the 19 primary
aluminum facilities with cyanide discharges in PCS for 2002. The remaining facilities reported
discharges of cyanide as quantities (e.g., pounds per day) to PCS in 2002. Table 10-18 presents
the reported average concentrations of cyanide discharged by these facilities.
The median cyanide concentrations reported by primary aluminum facilities, as
shown in Table 10-18, are all well below the cyanide BAT treatment effectiveness
concentrations, 2.0 mg/L monthly average and 4.5 mg/L daily maximum (U.S. EPA, 1989).
10-17
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-15. Primary Aluminum Facilities with Fluoride Discharges in PCS for 2002
NPDES ID
MD0002429
TX0004715
MOO 105732
WV0000779
WA0002950
NY0000132
NY0001732
IN0001155
TN0065081
WA0000540
NC0004308
OH0011550
KY0004278
OR0000060
WA0000931
WA0000299
OR0001708
WA0000680
WA0000876
KY0001821
WA0000086
Facility
Eastalco Aluminum
ALCOA Point Comfort
Noranda Aluminum
Century Aluminum
Intalco Works
ALCOA Massena East
ALCOA Massena West
ALCOA Warrick
ALCOA South Plant
Goldendale Aluminum
ALCOA Badin Works
Ormet Hannibal
National Southwire Aluminum Hawesville
ALCOA Troutdale
Port of Washington
Evergreen Aluminum
Northwest Aluminum Specialties
ALCOA Wenatchee Works
CVB Northwest
Alcan Sebree3
Longview Aluminumb
Location
Frederick
Point Comfort
New Madrid
Ravenswood
Ferndale
Massena
Massena
Newburgh
Alcoa
Goldendale
Badin
Hannibal
Robards
Troutdale
Tacoma
Vancouver
The Dalles
Malaga
Mead
Hawesville
Longview
Total Fluoride Discharges
Pounds
Discharged
89,362
73,776
65,280
52,840
29,401
25,869
20,131
16,727
16,715
15,741
14,681
12,716
12,627
7,110
3,621
3,072
1,770
720
170
0
0
462,328
TWPE
3,128
2,582
2,285
1,849
1,029
905
705
585
585
551
514
445
442
249
127
108
62
25
6
0
0
16,181
Percentage
of Total
Fluoride
TWPE
19.3%
16.0%
14.1%
11.4%
6.4%
5.6%
4.4%
3.6%
3.6%
3.4%
3.2%
2.8%
2.7%
1.5%
0.8%
0.7%
0.4%
0.2%
0.04%
0.0%
0.0%
Source: PCSLoads2002_v4.
"Permit limits fluoride discharges for one outfall that had no discharge in 2002.
bFacility reports concentration of fluoride but does not report outfall flow, so a fluoride load was not calculated in
PCSLoads2002 v4.
10-18
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-16. Primary Aluminum Facilities, Fluoride Concentrations Reported to PCS in 2002
NPDES ID
MOO 105732
WA0002950
OH0011550
WA0000876
MD0002429
WA0000299
WA0000086
NC0004308
NY0000132
IN0001155
TN0065081
WA0000931
WV0000779
OR0000060
Facility Name
Noranda Aluminum
Intalco Works
Ormet Hannibal
CVB Northwest
Eastalco Aluminum
Evergreen Aluminum15
Longview Aluminum13' °
ALCOA Badin Works
ALCOA Massena East
ALCOA Warrick
ALCOA South Plantb'd
Port of Washington
Century Aluminum
ALCOA Troutdale
Minimum Average
Concentration"
(mg/L)
8.90
5.00
9.84
10.45
4.64
3.80
0.40
0.24
0.20
2.02
0.25
1.03
0.05
0.20
Maximum Average
Concentration"
(mg/L)
21.05
26.00
15.20
14.50
18.60
5.50
4.00
33.00
35.00
3.97
20.40
27.40
12.60
2.20
Median Average
Concentration"
(mg/L)
15.00
14.00
13.33
12.48
12.40
4.55
1.40
1.25
0.45
2.90
1.90
2.81
0.91
0.90
Date Range
1/2002 - 3/2006
1/2002 - 2/2003
1/2002 - 3/2004
1/2002 - 1/2003
1/2002 - 2/2006
1/2002 - 2/2003
1/2002 - 2/2003
8/2004 - 2/2006
8/2004 - 3/2006
1/2002 - 8/2004
2/2002 - 4/2006
1/2002 - 2/2003
2/2002 - 9/2002
1/2002 - 4/2003
o
VO
Source: Envirofacts.
"Concentrations are total fluoride, unless otherwise specified. EPA determined discharges reported as "0" and with "<" signs in Envirofacts were nondetects and
excluded them from the facility's concentrations. EPA included fluoride concentrations from all reported outfalls in this analysis.
bConcentrations are reported maximums. Facilities did not report average concentrations.
'Facility reports concentration of fluoride but does not report outfall flow, so a fluoride load was not calculated in PCSLoads2002_v4.
dConcentrations are dissolved fluoride.
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-17. Primary Aluminum Facilities with Cyanide Discharges in PCS for 2002
NPDES ID
NC0004308
WV0000779
OHOO 11550
KY0001821
NY0000132
TN0065081
NY0001732
OR0000060
IN0001155
WA0002950
WA0000299
MD0002429
TX0004715
MOO 105732
OR0001708
WA0000086
WA0000680
WA0000876
WA0000931
Facility
ALCOA Badin Works
Century Aluminum
Ormet Hannibal
Alcan Sebree
ALCOA Massena East
ALCOA South Plant
ALCOA Massena West
ALCOA Troutdale
ALCOA Warrick
Intalco Works
Evergreen Aluminum
Eastalco Aluminum
ALCOA Point Comfort3
Noranda Aluminum3
Northwest Aluminum Specialties3
Longview Aluminum3
ALCOA Wenatchee Works3
CVB Northwest3
Port of Washington3
Location
Badin
Ravenswood
Hannibal
Hawesville
Massena
Alcoa
Massena
Troutdale
Newburgh
Ferndale
Vancouver
Frederick
Point Comfort
New Madrid
The Dalles
Longview
Malaga
Mead
Tacoma
Total Cyanide Discharges
Pounds
Discharged
3,380
2,460
1,181
222
120
85
83
29
28
20
4
2
0
0
0
0
0
0
0
7,614
TWPE
3,775
2,748
1,319
248
134
95
93
33
31
22
5
3
0
0
0
0
0
0
0
8,504
Percentage of
Total Cyanide
TWPE
44.4%
32.3%
15.5%
2.9%
1.6%
1.1%
1.1%
0.4%
0.4%
0.3%
0.1%
0.03%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
Source: PCSLoads2002_v4; Envirofacts; Facility permits (TNRCC, 1996; MDNR, 2004; ODEQ, 2005; WDE, 2002;
WDE, 1997; WDE, 200Ib; WDE, 2000; WDE, 200Ic; WDE, 2002; WDE, Unknown).
"Permits include cyanide limits or monitoring requirements. Discharges of cyanide were reported below the
detection limit or were not provided on Envirofacts for 2002.
10-20
-------
Section 10.0 - Nonferrous Metals Manufacturing
Table 10-18. Primary Aluminum Facilities, Cyanide Concentrations Reported to PCS in 2002
NPDES ID
NC0004308
WV0000779
NY0000132
TN0065081
WA0000299
MD0002429
WA0002950
OH0011550
Facility Name
ALCOA Badin Works
Century Aluminum
ALCOA Massena East
ALCOA South Plantb
Evergreen Aluminum
Eastalco Aluminum0
Intalco Works0
Ormet Hannibald
Minimum Average
Concentration"
(mg/L)
0.003
0.010
0.012
0.005
0.010
0.001
0.001
0.001
Maximum Average
Concentration" (mg/L)
258.4
1.06
6.19
0.033
0.010
0.020
0.002
0.027
Median Average
Concentration" (mg/L)
0.152
0.150
0.025
0.011
0.010
0.003
0.002
0.001
Date Range
8/2004 - 2/2006
1/2002 - 9/2002
1/2002 - 3/2006
3/2002 - 4/2005
4/2003 - 1/2006
1/2002 - 2/2006
2/2002 - 4/2002
1/2002 - 3/2006
Source: Envirofacts.
""Concentrations are total cyanide, unless otherwise specified. EPA determined discharges reported as "0" and with "<" signs in Envirofacts were nondetects and
excluded them from the facility's concentrations. EPA included cyanide concentrations from all reported outfalls in this analysis.
bConcentrations are maximum. Facilities did not report average concentrations.
°Concentrations are cyanide, free (amenable to chlorination).
dConcentrations are cyanide, weak acid dissociable.
-------
Section 10.0 - Nonferrous Metals Manufacturing
10.6 NFMM Category Conclusions
• The NFMM Category ranks high in TWPE because of the number of
facilities with discharges.
• Some facilities discharges were misrepresented in PCS.
• Facilities in the Primary Aluminum Subcategory consistently report
discharges of regulated pollutants, including fluoride and cyanide. EPA
obtained additional data that shows current facility discharge
concentrations are below treatment effectiveness concentrations identified
as BAT in 1984.
• Pasminco Zinc Inc. reported discharges accounting for almost 19 percent
of the NFMM Category's 2002 PCS TWPE. The majority of the facility's
discharges are cadmium discharged from stormwater outfalls that exceed
Tennessee's target stormwater cadmium concentration of 0.0159 mg/L
(TDEC, 2005).
• Two of the top discharging facilities, ALCOA Warrick and Horsehead
Corporation, reported discharges of chlorine accounting for approximately
21 percent of the NFMM Category's 2002 PCS TWPE. The chlorine
discharges are associated with the on-site power generation at the facilities
that are permitted with limits from 40 CFR Part 423: Steam Electric Power
Generating Point Source Category. EPA determined the discharges of
chlorine from the NFMM facilities are not applicable to 40 CFR Part 423
since 40 CFR Part 423 does not apply to integrated power generating
plants. However, the chlorine loads are not from NFMM operations and
were excluded from further review.
• EPA is not identifying the NFMM Category as a hazard priority based on
data available at this time.
10.7 NFMM Category References
ADEQ. 2005a. Arkansas Department of Environmental Quality. Authorization to Discharge
Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air
Pollution Control Act NPDES AR0000582 - ALCOA Bauxite Works, Bauxite, AR. Little Rock,
AR. (May 31). DCN03313.
ADEQ. 2005b. Arkansas Department of Environmental Quality. Authorization to Discharge
Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air
Pollution Control Act Fact Sheet for NPDES AR0000582 - ALCOA Bauxite Works, Bauxite,
AR. Little Rock, AR. (May 23). DCN03313.
10-22
-------
Section 10.0 - Nonferrous Metals Manufacturing
Alcan Inc. 2006. "Find Alcan Around the World - Sebree." About Alcan. Available online at:
http://www.alcan.com/web/publishing.nsf/content/FFOC85ElFOD760B185256E860051BClF7O
penDocument. Date accessed: September 28, 2006. DCN 03728.
ALCOA. 2003. ALCOA Begins Troutdale Site Restoration. (July 16). Available online at:
http://www.alcoa.com/gl obal/en/news/news_details.asp?pageID=23197484 l&newsYear=2003.
Date accessed: July 5, 2006. DCN 03733.
ALCOA. 2006a. ALCOA Badin Works. Available online at:
http://www.alcoa.com/locations/alcoa_location/en/home.asp?code=406. Date accessed:
September 28, 2006. DCN 03729.
ALCOA. 2006b. ALCOA Takes Full Ownership of Intalco and Eastalco Smelters in
Washington and Maryland; Signs Agreement for NW Power. (June 29). Available online at:
http://www.alcoa.com/gl obal/en/news/news_details.asp?pageID=20060629005669en&newsYear
=2006. Date accessed: July 5, 2006. DCN 03730.
ALCOA. 2006c. "ALCOA Tennessee Operations." Available Online at:
http://www.alcoa.com/tn_operations/en/home.asp. Date accessed: July 5, 2006. DCN 03731.
ALCOA. 2006d. "ALCOA Warrick Operations - Evansville." Available online at:
http://www.alcoa.com/locations/usa_warrick/en/home.asp. Date accessed: July 5, 2006. DCN
03732.
Doe Run Co. 2004a. The Doe Run Company. "Glover, MO." Smelting and Refining.
Available online at: http://www.doerun.com/whatwedo/glover.asp. Date accessed: April 12,
2006. DCN 03734.
Doe Run Co. 2004b. The Doe Run Company. "Boss, MO." Recycling. Available online at:
http://www.doerun.com/whatwedo/boss.asp. Date accessed: April 14, 2006. DCN 03735.
Forgey, Pat. 2004. "Smelter's Final Hope Melts." The Daily News. Longview, Washington.
(January 20). Available online at:
http://www.tdn.com/articles/2004/0l/20^area_news/lnewsO 1 .txt. Date accessed: July 5, 2006.
DCN 03736.
Glencore. 2006. Glencore International AG. "Aluminum, Alumina, and Bauxite." Commodity
Departments. Available online at: http://www.glencore.com/pages/aluminum.htm. Date
accessed: July 17, 2006. DCN 03737.
IDEM. 2001. Indiana Department of Environmental Management. Fact Sheet for NPDES
Permit IN0001210 - ALCOA Lafayette Works, Lafayette, IN. Indianapolis, IN. (August).
DCN 02400.
IDEM. 2002. Indiana Department of Environmental Management. NPDES Permit INOOO1210
- ALCOA Lafayette Works, Lafayette, IN. Indianapolis, IN. (October 10). DCN 03314.
10-23
-------
Section 10.0 - Nonferrous Metals Manufacturing
IDEM. 2004. State of Indiana Department of Environmental Management. Authorization to
Discharge under the National Pollutant Discharge Elimination System Permit NPDES
IN0001155 - ALCOA Warrick, Newburgh, IN. Indianapolis, IN. (August 3). DCN 03314.
Janjic, Vojin. Unknown. Tennessee Department of Environment and Conservation, Division of
Water Pollution Control. Permit Rationale for the Tennessee Storm Water Multi-Sector General
Permit for Industrial Activities. DCN 03752.
KDEP. 2002. Commonwealth of Kentucky Department for Environmental Protection.
Kentucky Pollution Discharge Elimination System Permit and Fact Sheet for NPDES
KY0002666 - Commonwealth Aluminum, Lewisport, KY. Frankfort, KY. (July 19). DCN
02405.
LDEQ. 2002. State of Louisiana Department of Environmental Quality. Offices of
Environmental Services Water Discharge Permit NPDES LAO 110931 - CS Metals of Louisiana
Inc., Convent, LA. Baton Rouge, LA. (December 9). DCN 02407.
MDNR. 2003a. State of Missouri Department of Natural Resources. State Operating Permit
Fact Sheet NPDES MO0000337 - Doe Run Resources Recycling, Boss, MO. Jefferson City,
MO. DCN 03315.
MDNR. 2003b. State of Missouri Department of Natural Resources. State Operating Permit
NPDES MO0000337 - Doe Run Resources Recycling, Boss, MO. Jefferson City, MO.
(November 14). DCN 03315.
MDNR. 2005. State of Missouri Department of Natural Resources. State Operating Permit
NPDES MO0001121 - Doe Run, Glover Smelter, Glover, MO. Jefferson City, MO. (August
26). DCN 03317.
MDNR. 2004. State of Missouri Department of Natural Resources. State Operating Permit
NPDES MO0105732 - Noranda Aluminum Inc., New Madrid, MO. Jefferson City, MO.
(January 9). DCN 02505.
NYSDEC. 2001. New York State Department of Environmental Conservation. State Pollutant
Discharge Elimination System Fact Sheet NPDES NY0001732 - ALCOA Massena West,
Massena,NY. Watertown, NY. (July 16). DCN 02494.
NYSDEC. 2003. New York State Department of Environmental Conservation. State Pollutant
Discharge Elimination System Discharge Permit NPDES NY0001732 - ALCOA Massena West,
Massena, NY. Watertown, NY. (June 9). DCN 02494.
ODEQ. 2005. Oregon Department of Environmental Quality. National Pollutant Discharge
Elimination System Waste Discharge Permit NPDES OR0001708 -Noranda Aluminum
Specialties, The Dalles, OR. Bend, OR. (Februarys). DCN 02762.
Olin. 2000. Olin Corporation. "Olin Brass." Business Lines. (April 28). Available online at:
http://www.olin.com/business/brass.asp. Date accessed: July 5, 2006. DCN 03753.
10-24
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Section 10.0 - Nonferrous Metals Manufacturing
PDEP. 200 la. Commonwealth of Pennsylvania Department of Environmental Protection Water
Management Program. Authorization to Discharge under the National Pollutant Discharge
Elimination System Permit NPDES PA0002208 - Horsehead Corporation, Monaca, PA.
Harrisburg, PA. (August 2). DCN 02409.
PDEP. 2001b. Commonwealth of Pennsylvania Department of Environmental Protection Water
Management Program. Authorization to Discharge under the National Pollutant Discharge
Elimination System Permit NPDES PAGO 12751 - Zinc Corporation of America, Palmerton, PA.
Harrisburg, PA. (December 18). DCN 02893.
Plunkert, Patricia A. 2006. U.S. Geological Survey. "Aluminum Mineral Commodity
Summaries." U.S. Geological Survey. (January). DCN 03755.
Port of Tacoma. 2000. Port Prepares to Demolish Kaiser Smokestack: When Will the Kaiser
Smokestack Demolition Blast Happen? Available online at:
http://www.portoftacoma.com/topstory.cfm?sub=69&lsub=847. DCN 03756.
Reddington, Mike. 2005. Olin Corporation. Telephone conversation with Mike Reddington of
Olin Corporation and Jessica Wolford of Eastern Research Group, Inc. "Olin Corp. Main Plant
Facility Phosphorous Releases in TRI 2003 (62024-LNCRP-SHAMR)." (December 20). DCN
02545.
TDEC. 2005. State of Tennessee Department of Environment and Conservation. State of
Tennessee National Pollutant Discharge Elimination System Permit NPDES TN0029157 -
Pasminco Zinc Inc., Clarksville, TN. Nashville, TN. (May 31). DCN 02403.
TDEC. 2004a. State of Tennessee Department of Environment and Conservation. State of
Tennessee National Pollutant Discharge Elimination System Addendum to Rationale NPDES
TN0065081-ALCOA South Plant, Alcoa, TN. Nashville, TN. (January 7). DCN 03319.
TDEC. 2004b. State of Tennessee Department of Environment and Conservation. State of
Tennessee National Pollutant Discharge Elimination System Permit NPDES TN0065081 -
ALCOA South Plant, Alcoa, TN. Nashville, TN. (March 31). DCN 03319.
TNRCC. 1996. Texas Natural Resource Conservation Commission. Permit to Dispose of
Wastes for NPDES TX0004715 - ALCOA Point Comfort, Point Comfort, TX. Austin, TX.
(August 30). DCN 02422.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
10-25
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Section 10.0 - Nonferrous Metals Manufacturing
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Dischargers.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
U. S. EPA. 1989. Development Document for Effluent Limitations Guidelines and Standards for
the Nonferrous Metals Manufacturing Point Source Category. Vol II. U.S. EPA. EPA-440-1-89-
019.2. Washington, DC. (May).
UDEQ. Unknown. Utah Department of Environmental Quality. Statement of Basis for
UT0000051 - Kennecott Utah Copper Corporation. Salt Lake City, UT. DCN 03320.
USEC. 2005. United States Enrichment Corporation Inc. "Portsmouth Gaseous Diffusion
Plant." USEC Facilities. Available online at:
http://www.usec.com/v2001_02/HTML/Facilities_PortsOverview.asp. Date accessed: July 3,
2006. DCN 03758.
USGS. 2005. U.S. Geological Survey. "Vanadium in January 2005." Mineral Industry
Surveys. (April). Available online at: http://minerals.usgs.gov/minerals. DCN 03754.
WDE. 1997. State of Washington Department of Ecology. National Pollutant Discharge
Elimination System Waste Discharge Permit NPDES WA0000680 - ALCOA Wenatchee
Works, Malaga, WA. Olympia, WA. (September 2). DCN 02738.
WDE. 2000. State of Washington Department of Ecology. National Pollutant Discharge
Elimination System Waste Discharge Permit NPDES WA0000876 - CVB Northwest, Mead,
WA. Olympia, WA. (January 1). DCN 02739.
WDE. 200 la. State of Washington Department of Ecology. National Pollutant Discharge
Elimination System Waste Discharge Permit NPDES WA0000931 - Port of Washington,
Tacoma, WA. Olympia, WA. (October 10). DCN 02740.
WDE. 2001b. State of Washington Department of Ecology. Fact Sheet for NPDES Permit
WA0000680 - ALCOA Wenatchee Works, Malaga, WA. Olympia, WA. (November 1). DCN
02738.
WDE. 200 Ic. State of Washington Department of Ecology. National Pollutant Discharge
Elimination System Waste Discharge Permit Fact Sheet NPDES WA0000931 - Port of
Washington, Tacoma, WA. Olympia, WA. (November 29). DCN 02740.
WDE. 2002. State of Washington Department of Ecology. National Pollutant Discharge
Elimination System Waste Discharge Permit NPDES/WA0000086-Longview Aluminum,
Longview, WA. Olympia, WA. (February 1). DCN 02863.
10-26
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Section 10.0 - Nonferrous Metals Manufacturing
WDE. Unknown. State of Washington Department of Ecology. Fact Sheet for NPDES
WA0000876-CVB Northwest, Mead, WA. Olympia, WA. DCN 02739.
10-27
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.0 ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS (40 CFR PART 414)
EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)
Category for additional data collection and analysis because it ranked high in terms of toxic and
nonconventional discharges during EPA's 2005 annual review (see Table V-l, 70 FR 51050,
August 29, 2005). The 2004 Plan summarizes the results of EPA's previous review of this
industry (U.S. EPA, 2004). This section summarizes the 2005 annual review and also describes
the 2006 annual review. EPA's 2006 annual review builds on the 2005 annual review.
EPA is currently reviewing discharges from the Chlorinated Hydrocarbon
Manufacturing Segment of the OCPSF Category as part of the Chlorine and Chlorinated
Hydrocarbons (CCH) effluent guidelines rulemaking. Because a rulemaking for this segment of
the OCPSF category is underway, EPA excluded discharges from these facilities from further
consideration in this review (see Table V-l, 70 FR 51050, August 29, 2005).
11.1 OCPSF Category Background
This section provides background on the OCPSF Category including a brief
profile of the OCPSF industry, background on 40 CFR Part 414, and a summary of findings from
the OCPSF Category detailed study as part of the 2004 Plan.
11.1.1 OCPSF Industry Profile
The OCPSF Category includes many chemical industries producing a wide
variety of end products, such as polypropylene, vinyl chloride and polyvinyl chloride (PVC),
chlorinated solvents, rubber precursors, styrofoam additives, and polyester. Some OCPSF
facilities are extremely complex and produce hundreds of chemicals, while others are simpler,
producing one or two end products. Facilities in the following five SIC codes could perform
operations covered by the OCPSF ELGs:
• 2821: Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers;
• 2823: Cellulosic and Other Man-Made Fibers;
• 2824: Synthetic Organic Fibers, Except Cellulose;
• 2865: Cyclic Crudes and Intermediates, and Organic Dyes and Pigments;
and
• 2869: Industrial Organic Chemicals, Not Elsewhere Classified (NEC).
In addition, EPA is considering including operations from five other SIC codes as potential new
subcategories of the OCPSF Category. See Section 11.3 for the discussion of the potential new
subcategories.
11-1
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-1 lists the five SIC codes with operations in the OCPSF Category and
the five SIC codes included as potential new subcategories to the OCPSF Category.
OCPSF facilities discharge directly to surface water as well as to POTWs. Table
11-2 presents the types of discharges reported by facilities in the 2002 TRI database. The
majority of facilities reporting to TRI reported no water discharges, but facilities may be
discharging pollutants in wastewater at levels below the TRI-reporting thresholds.
11.1.2 40 CFR Part 414
EPA first promulgated ELGs for the OCPSF Category (40 CFR Part 414) on
November 5, 1987 (52 FR 42568). This category consists of eight subcategories that apply to the
manufacture of products and product groups, as shown in Table 11-3 with the corresponding SIC
codes and applicability. Subparts B through H have limitations for BOD5, TSS, and pH. The
regulation also includes limitations and/or pretreatment standards for certain toxic pollutants in
three additional subparts:
• Subpart I - Direct Discharge Point Sources that use End-of-Pipe Biological
Treatment;
• Subpart J - Direct Discharge Point Sources that do not use End-of-Pipe
Biological Treatment; and
• Subpart K - Indirect Discharge Point Sources.
11.1.3 Previous Detailed Study Findings for the OCPSF Category
Previously, EPA conducted a detailed study of the OCPSF Category in support of
the 2004 Plan (see Section 6.0 of the 2004 Plan (U.S. EPA, 2004)). EPA selected the OCPSF
Category for study based on high TWPE from both TRI- and PCS- reported discharges. This
subsection summarizes the findings from the 2004 detailed study.
11-2
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-1. Number of Facilities in OCPSF SIC Codes
SIC Code
2821: Plastic Materials, Synthetic Resins, and
Nonvulcanizable Elastomers
2823: Cellulosic and Other Man-Made Fibers
2824: Synthetic Organic Fibers, Except Cellulosic
2865: Cyclic Crudes and Intermediates, and Organic
Dyes and Pigments
2869: Industrial Organic Chemicals, NEC
OCPSF Category Total0
2002 U.S.
Economic
Census
688
8
94
217
3,215
4,222
2002 PCS3
137
4
9
33
189
372
2002 TRIb
403
5
40
106
469
1,023
2003 TRIb
385
5
42
95
460
987
Potential New Subcategories
2842: Specialty Cleaning, Polishing, and Sanitation
Preparations
2844: Perfumes, Cosmetics, and Other Toilet
Preparations
2891: Adhesives and Sealants
2899: Chemicals and Chemical Preparations, NEC
5169: Chemicals and Allied Products
Potential New Subcategories Total
604
1,586
585
3,582
54,314
60,671
3
10
14
45
20
92
138
43
185
339
464
1,169
135
39
185
330
433
1,122
Source: U.S. Economic Census 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
aMajor and minor dischargers.
bReleases to any media.
'Excludes the potential new Subcategories.
NEC - Not elsewhere classified.
11-3
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-2. OCPSF Category Facilities by Type of Discharge Reported in TRI2002
SIC Code
2821: Plastic Materials, Synthetic Resins,
and Nonvulcanizable Elastomers
2823: Cellulosic and Other Man-Made
Fibers
2824: Synthetic Organic Fibers, Except
Cellulosic
2865: Cyclic Crudes and Intermediates, and
Organic Dyes and Pigments
2869: Industrial Organic Chemicals, NEC
Reported
Only Direct
Discharges
64
2
9
29
107
Reported
Only
Indirect
Discharges
101
0
11
38
134
Reported Both
Direct and
Indirect
Discharges
19
1
2
5
27
Reported No
Water
Discharges
219
2
18
33
198
Potential New Subcategories
2842: Specialty Cleaning, Polishing, and
Sanitation Preparations
2844: Perfumes, Cosmetics, and Other
Toilet Preparations
2891: Adhesives and Sealants
2899: Chemicals and Chemical
Preparations, NEC
5169: Chemicals and Allied Products
1
0
3
17
6
39
21
26
79
40
0
0
1
10
0
98
22
155
233
418
Source: TRIReleases2002_v4.
NEC - Not elsewhere classified.
11-4
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-3. Applicability of Subcategories in the OCPSF Category
Subpart
Subpart Name
Applicable SIC Code(s)
Subpart Applicability
B
Rayon Fibers
2823: Cellulosic Manmade Fibers
Cellulosic manmade fiber (Rayon)
manufactured by the Viscose process.
Other Fibers
2823: Cellulosic Manmade Fibers
2824: Synthetic Organic Fibers, Except
Cellulosic
All other synthetic fibers (except
Rayon) including, but not limited to,
products listed in Section 414.30.
D
Thermoplastic
Resins
28213: Thermoplastic Resins
Any plastic product classified as a
Thermoplastic Resin including, but
not limited to, products listed in
Section 414.40.
Thermosetting
Resins
28214: Thermosetting Resins
Any plastic product classified as a
Thermosetting Resin including, but
not limited to, products listed in
Section 414.50.
Commodity
Organic
Chemicals
2865: Cyclic Crudes and Intermediates,
Dyes and Organic Pigments
2869: Industrial Organic Chemicals,
NEC
Commodity organic chemicals and
commodity organic chemical groups
including, but not limited to, products
listed in Section 414.60.
Bulk Organic
Chemicals
2865: Cyclic Crudes and Intermediates,
Dyes and Organic Pigments
2869: Industrial Organic Chemicals, NEC
Bulk organic chemicals and bulk
organic chemical groups including,
but not limited to, products listed in
Section 414.70.
H
Specialty
Organic
Chemicals
2865: Cyclic Crudes and Intermediates,
Dyes and Organic Pigments
2869: Industrial Organic Chemicals, NEC
All other organic chemicals and
organic chemical groups including,
but not limited to, products listed in
the OCPSF Development Document
(Vol. II, Appendix II-A, Table VII).
Source: Product and Product Group Discharges Subject to Effluent Limitations and Standards for the Organic
Chemicals, Plastics, and Synthetic Fibers Point Source Category - 40 CFR 414, Table 2-2 (U.S. EPA, 2005c).
NEC - Not elsewhere classified.
11-5
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
EPA identified dioxin and dioxin-like compounds as the primary pollutants
responsible for the OCPSF industry's large toxic-weighted pollutant discharge. EPA concluded
that the manufacture of ethylene dichloride, vinyl chloride monomer, and polyvinyl chloride,
referred to collectively as the vinyl chloride manufacturing segment of the OCPSF industry, is
the primary source of dioxin and dioxin-like compounds discharges. EPA found that the largest
discharges of dioxin and dioxin-like compounds occur at large integrated facilities that also
operated chlor-alkali plants. In addition, EPA found that discharges of dioxin and dioxin-like
compounds from stand-alone chlor-alkali plants are significant. As a result, EPA identified vinyl
chloride manufacturing, which is subject to the OCSPF ELGs (Part 414) and chlor-alkali
manufacturing, which is subject to the Inorganic Chemicals Manufacturing ELGs (Part 415), for
possible effluent guidelines revisions. In 2005, EPA's Vinyl Chloride and Chlor-Alkali
rulemaking effort identified other manufacturing processes that operate under similar conditions
to the chlor-alkali and vinyl chloride processes, and therefore have potential to discharge dioxin
and dioxin-like compounds. EPA decided to expand the manufacturing operations considered
for revised ELGs to include all chlorine manufacturing processes and manufacturing processes
for chlorinated hydrocarbons manufactured by direct chlorination, oxychlorination,
dehydrochlorination, or hydrochlorination. Chlorinated hydrocarbons that are regulated under
the Pesticide Chemicals Category (40 CFR Part 455) or under the Pharmaceuticals
Manufacturing Category (40 CFR 439) are not included in the CCH manufacturing segment.
EPA reviewed two additional sectors of the OCPSF Category for the 2004
detailed study: aniline and dye manufacturers and coal tar refiners. Aniline and dye
manufacturers contributed the majority of aniline discharges reported to TRI for 2000. EPA
learned that most of these facilities discharge their wastewater to POTWs. Aniline is highly
treatable in biological systems and receiving POTWs indicated no interference issues with these
discharges. The coal tar refiners contributed the majority of PACs discharges reported to TRI for
2000. EPA learned that the coal tar industry was declining, and that the PACs discharges were at
concentrations near or at treatability levels. As a result, EPA determined that, based on the
information available at that time, it was not appropriate to select the aniline and dye
manufacturing and coal tar refining sectors of the OCPSF Category for possible effluent
guidelines revision.
11.2 OCPSF Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the OCPSF Category
including the screening-level review and category-specific review.
11.2.1 OCPSF Category 2005 Screening-Level Review
Table 11-4 presents the OCPSF Category and the vinyl chloride manufacturing
sector TWPE calculated using TRIReleases2002_v2 and PCSLoads2002_v2. The discharges for
the OCPSF Category in Table 11-4 include loads from facilities in SIC codes EPA determined
are potential new subcategories.
11-6
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-4. OCPSF Category 2005 Screening-Level Review Results
Rank
o
5
NAC
Point Source Category
OCPSF
Vinyl Chlorine Sectord
2002 PCS TWPEb
1,711,005
15,083
2002 TRI TWPEC
627,857
2,796,270
Total TWPE
2,338,862
2,811,353
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005); PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°The rankings presented in Tables 4-12, 4-13, and 4-14 represent the combined TWPE for the Vinyl Chloride and
Chlor-Alkali sectors. The Vinyl Chloride sector was not ranked independently.
dThe vinyl chloride sector of the OCPSF Category was reviewed for the 2005 screening-level review and includes
facilities that manufacture ethylene dichloride, vinyl chloride monomer, and/or polyvinyl chloride and reported a
primary SIC code associated with OCPSF (see Table 11-1). This sector includes some facilities that also perform
chlor-alkali manufacturing operations. Note that EPA expanded the scope of the vinyl chloride manufacturing
segment to include manufacture of chlorinated hydrocarbons for the 2006 review.
11.2.2
OCPSF Category 2005 Pollutants of Concern
Table 11-5 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. Discharges of hexachlorobenzene in PCS for 2002 accounted for 64 percent
of the OCPSF Category 2002 PCS TWPE. Discharges of sodium nitrite and dioxin and dioxin-
like compounds in TRI for 2002 accounted for 64 percent of the OCPSF Category 2002 TRI
TWPE.
Table 11-5. 2005 Annual Review Results: OCPSF Category Pollutants of Concern
Pollutant
Hexachlorobenzene (HCB)
Dioxin and Dioxin-like
Compounds
Chlorine
Lead
Nitrogen, Nitrite Total (as N)
Sodium Nitrite
Dinitrotoluene
OCPSF Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
16
1
60
40
4
Total Pounds
Released
560
0.00025
171,029
29,313
115,292
TWPE
1,090,485
178,624
87,082
65,661
43,042
Pollutants are not in the top five PCS 2002
reported pollutants.
239C
1,053,253,290
1,711,005
2002 TRI"
Number of
Facilities
Reporting
Pollutant
4
9
25
Total
Pounds
Released
30
0.022
58,937
TWPE
59,272
152,200
30,009
Pollutants are not in the top five TRI 2002
reported pollutants.
43
2
792C
670,855
39,985
54,528,174
250,452
25,661
627,857
Source: PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
11-7
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.3
Potential New Subcategories for the OCPSF Category
As part of the 2005 annual review, EPA reviewed industries with SIC codes not
clearly subject to existing ELGs. EPA concluded the processes, operations, wastewaters, and
pollutants of facilities in the SIC codes listed in Table 11-6 are similar to those of the OCPSF
Category. Table 11-6 shows the combined TWPE from TRIReleases2002_v2 and
PCSLoads2002_v2 for each SIC code that is a potential new subcategory. The discharges for the
potential new subcategory SIC codes are a negligible percentage of the total 2002 TWPE for the
OCPSF Category.
Table 11-6. Pollutant TWPE for Potential New Subcategories in OCPSF Category
SIC Code
2842
2844
2891
2899
5169
SIC Description
Specialty Cleaning, Polishing, and Sanitation
Preparations
Perfumes, Cosmetics, and Other Toilet Preparations
Adhesives and Sealants
Chemicals and Chemical Preparations, NEC
Chemicals and Allied Products
Total 2002
TWPE
1,048
6,909
199
59,070
587
Percentage of Total
OCPSF Category
TWPE
0.04
0.30
0.008
2.53
0.03
Source: TRIReleases2002_v2; PCSLoads2002_v2.
NEC - Not elsewhere classified.
11.4
OCPSF Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the OCPSF Category. EPA obtained additional data
and identified:
Pollutant loads reported under wrong parameter code;
Errors in how PCS loads were estimated for two facilities;
Changes in estimates of TWPE for dioxin for one facility; and
Changes in estimates of TWPE for sodium nitrite.
11.4.1
OCPSF Category Facility Discharge Revisions
EPA received comments on the Preliminary 2006 Plan from the American
Chemistry Council (ACC) stating that chlorine was measured upstream of the final outfall prior
to commingling with other treated wastewater for two facilities, Equistar Chemicals LP in
Channelview, TX and Solutia Inc./Equistar Chemicals LP in Alvin, TX (ACC, 2005). EPA set
the discharges of chlorine from the Equistar Chemicals LP facility in Channelview, TX to zero in
the revised 2002 PCS database, PCSLoads2002_v4, after verifying that chlorine was not
measured at the final outfall. EPA was unable to verify the chlorine monitoring location for the
Solutia Inc./Equistar Chemicals LP facility in Alvin, TX and therefore did not change the
chlorine loads in PCSLoads2002 v4.
11-8
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
EPA also received comments on the Preliminary 2006 Plan from the ACC stating
that one facility, Cytec Industries in Belmont, WV, reporting discharges of lead does not monitor
lead and most likely misreported their manganese discharges using the parameter code for lead
(ACC, 2005). EPA reviewed the permit limits for this facility to verify that it does not have
monitoring requirements for lead and revised the reported discharge in PCSLoads2002_v4 to
represent pounds of manganese, not pounds of lead. The correction reduced the OCPSF
Category's discharges of lead by 55,642 TWPE and increased the OCPSF Category's discharges
of manganese by 1,750 TWPE.
EPA reviewed the discharges of chlorinated dibenzo(p) dioxin reported by one
facility, Dover Chemical in Dover, OH, in the PCS 2002 database. For the Preliminary 2006
Plan, EPA used the TWF for the most toxic dioxin congener, 2,3,7,8-
tetrachlorodibenzo(p)dioxin, to estimate the TWPE for Dover Chemical (U.S. EPA, 2005b).
ACC submitted a comment to EPA stating that the parameter that Dover Chemical includes in its
discharge monitoring reports (chlorinated dibenzo-p-dioxin effluent) represents the total mass for
all 17 dioxin and dioxin-like congeners. Therefore, it is appropriate for EPA to apply the median
TWF for the dioxin and dioxin-like congeners to estimate the TWPE for this discharge (ACC,
2005). In response to ACC's comment, EPA applied the median TWF for the 17 dioxin and
furan congeners to recalculate the TWPE for Dover Chemical in the revised 2002 PCS database,
PCSLoads2002_v4. As a result, the TWPE for Dover Chemical's dioxin discharge decreased
from 178,624 TWPE to 2,690 TWPE.
EPA received comments from ACC about the hexachlorobenzene (HCB)
discharges for Honeywell Nylon LLC in Hopewell, VA. ACC stated that the concentrations of
HCB on the facility's 2002 discharge monitoring reports were also reported at the detection
limit. This implies that the facility did not measure HCB at concentrations above the detection
limit. According to EPA's methodology for calculating annual loads using PCS data (see
Section 4.2.1.1), if HCB was not detected in any of facility's 2002 discharge monitoring reports,
then the annual load for HCB should equal zero. In the revised PCS 2002 database,
PCSLoads2002 v4, EPA set the facility loads for HCB to zero.
11.4.2 OCPSF Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, EAD
revised the TWF and POTW removal values used for sodium nitrite and dinitrotoluene, the
POTW percent removal used for chlorine, and the TWF used for nitrite to better reflect the
pollutant's properties. The TWF that EAD applies for sodium nitrite is now 0.0032 (formerly
0.373), and the POTW percent removal is now 90 percent (formerly 1.85 percent). The TWF
that EAD applies for dinitrotoluene is now 0.043077 (formerly 0.64176) and the POTW percent
removal is now 62.005 percent (formerly 47.12 percent). The POTW percent removal for
chlorine is now 100 percent (formerly 1.87 percent). The TWF for nitrite is now 0.0032
(formerly 0.373). Table 11-7 presents the loads before and after corrections to the TWFs and
POTW percent removals for the OCPSF Category.
11-9
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-7. Impact of Changes to TWF and POTW Percent Removal for the OCPSF
Category
Database
TRI 2002
TRI 2002
TRI 2002
PCS 2002
Pollutant
Sodium Nitrite
Dinitrotoluene
Chlorine
Nitrogen, Nitrite Total (as N)
Number of Facilities
Reporting Discharges
43
2
25
4
TWPE from
2005 Review
250,452
25,661
30,009
43,042
TWPE from
2006 Review
292
1,238
28,999
369
Source: TRIReleases2002_v2; TRIReleases2002_v4; PCSLoads2002_v2; PCSLoads2002_v.
11.4.3
OCPSF Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings based on methodology changes as described in Section 4.2 and changes made based on
permit review. For the OCPSF Category, the most significant changes are also described in
Sections 11.4.1 and 11.4.2. Table 11-8 shows the 2006 screening-level TWPE estimated for the
OCPSF Category from the 2002 and 2003 TRI and 2002 PCS databases.
Table 11-8. OCPSF Category 2006 Screening-Level Review Results
Point Source Category
OCPSF Category0
PCS 2002a
397,951
TRI 2002b
349,429
TRI 2003b
1,021,401
Sources: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Values exclude TWPE from facilities included in the chlorinated hydrocarbon manufacturing segment, because
EPA is investigating these facilities as part of the CCH rulemaking.
11.4.4
OCPSF Category 2006 Pollutants of Concern
Table 11-9 presents the pollutants of concern for the OCPSF Category based on
the 2006 annual review.
HCB is a top pollutant in all three databases. Dioxin and dioxin-like compounds
is a top pollutant in the TRI databases with an increase in discharges from 2002 to 2003. In
addition, TWPE estimates for TRI-reported releases of PACs show a large increase from 2002 to
2003 (4,613 TWPE and 67,964 TWPE, respectively). EPA reviewed discharges from facilities
reporting these three pollutants. Section 11.5 discusses EPA's review of facilities that discharge
HCB, Section 11.6 discusses EPA's review of facilities that discharge dioxin and dioxin-like
compounds, and Section 11.7 discusses EPA's review of facilities that discharge PACs.
11-10
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-9. 2006 Annual Review: OCPSF Category Pollutants of Concern
SIC Code
Hexachlorobenzene
(HCB)
Chlorine
Fluoride
Benzo(a)pyrene
Copper
Dioxin and Dioxin-
like Compounds
Nitrate Compounds
Hydroquinone
PACs
PCBs
OCPSF Category
Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
13
58
14
16
100
Total
Pounds
Released
53
106,278
910,270
288
33,629
TWPE
103,420
54,113
31,859
28,990
21,348
Pollutants are not in the top five PCS 2002
reported pollutants.
232C
978,243,371
397,951
2002 TRIb
Number of
Facilities
Reporting
Pollutant
4
25
Total
Pounds
Released
30
56,954
TWPE
59,272
28,999
Pollutants are not in the top five TRI 2002
reported pollutants.
8
131
0.019
44,533,702
13,513
115,132
33,252
17,217
Pollutants are not in the top five TRI 2002
reported pollutants.
791C
53,973,135
349,429
2003 TRIb
Number of
Facilities
Reporting
Pollutant
4
22
Total
Pounds
Released
32
55,810
TWPE
61,656
28,416
Pollutants are not in the top five TRI 2003
reported pollutants.
6
0.440
703,572
Pollutants are not in the top five TRI 2003
reported pollutants.
10
2
762C
675
0.812
37,904,315
67,964
27,627
1,021,401
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.5
OCPSF Category HCB Discharges
EPA identified HCB as a pollutant of concern during the 2005 annual review. For
the 2006 annual review, EPA reviewed HCB dischargers in TRI and PCS. The results of the
2006 annual review show that HCB continues to rank high in terms of TRI and PCS TWPE. The
following subsections discuss EPA's review of OCPSF facilities that report HCB discharges to
TRI and PCS.
11.5.1
OCPSF Category HCB Discharges in TRI
Table 11-10 shows the OCPSF facilities that reported discharges of HCB to
wastewater to TRI for 2002 and 2003. One facility, DuPont Chambers Works in Deepwater, NJ,
contributes 83 percent of the HCB TWPE for 2002 and 79 percent of the HCB TWPE for 2003.
EPA is currently reviewing TRI-reported discharges of HCB from Du Pont Chambers Works to
determine the basis of estimate. The Solutia Inc., Delaware River Plant in Bridgeport, NJ
reported the second largest HCB discharge to TRI, contributing 16 percent of the total HCB
TWPE for 2002 and 20 percent of the total HCB TWPE for 2003. EPA identified the Solutia
Inc., Delaware River Plant, currently owned by Ferro Corporation, as a manufacturer of benzyl
chloride (Olson, 2006). As a result, EPA plans to include this plant in its information collection
under the CCH rulemaking effort (see Section 11.1.3) for the 2007 annual review. EPA plans to
review discharges of several organic compounds, including HCB, during the rulemaking effort.
Table 11-10. OCPSF Facilities Reporting HCB Releases to TRI
Facility Name
Du Pont Chambers Works
Solutia Inc., Delaware River Plant
Sun Chemical Corp.
Clariant LSM (Florida) Inc.
Location
Deepwater, NJ
Bridgeport, NJ
Cincinnati, OH
Gainesville, FL
OCPSF Category Total
TRI 2002a
Pounds of
HCB
Released
25.4
5.00
0.0157
0.0157
30.4
HCB
TWPE
49,472
9,739
30.6
30.6
59,272
TRI 2003a
Pounds of
HCB
Released
25.0
6.20
0.440
0.0157
31.7
HCB
TWPE
48,693
12,076
856
30.6
61,656
Source: TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include transfers to POTWs and account for POTW removals.
11.5.2
OCPSF Category HCB Discharges in PCS
Table 11-11 shows the OCPSF facilities for which PCS includes 2002 discharges
of HCB. No one facility contributes more than 19 percent of the total HCB TWPE in the 2002
PCS database for the OCPSF Category. One facility, Du Pont Chamber Works, reports
discharges of HCB to TRI but does not report discharges of HCB to PCS because the facility
does not have a permit limit or monitoring requirements for HCB.
11-12
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-11. OCPSF Facilities Reporting Discharges of HCB to PCS in 2002
NPDES ID
WV0000868
SC0003557
SC0002798
WV0002496
LA0038890
WV0001112
DE0020001
WV0001279
AL0002097
WV0004588
WV0004740
WV0005169
WV0022047
Facility Name
Flexsys America LP
Honeywell Nylon
LLC/Columbia
Invista
S.A.R.L.^Spartanburg
Ripplewood Phosphorus
U.S. LLC
Nalco Company
Sunoco, Inc. (R & M)
Metachem Products,
LLCb
E I Dupont De Nemours
&Co
Honeywell International
Inc
Koppers Industries Inc
Crompton Corporation
Bayer Materialscience,
LLC
Crompton Corporation
Facility
Location
Nitro
Columbia
Spartanburg
Gallipolis
Ferry
Garyville
Kenova
Delaware
City
Parkersburg
Fairfield
Follansbee
Morgantown
New
Martinsville
Morgantown
Average 2002 HCB
Concentration
(Hg/L)
2.5
5.00a
10.0
4.13a
4.75a
10.0
3.18
0.04
4.01a
0.500
0.550
0.050
0.550
OCPSF Category Total
Pounds of HCB
Discharged
10.0
8.28
7.95
7.20
6.48
5.40
3.25
2.88
0.500
0.360
0.360
0.360
0.0360
53.1
HCB
TWPE
19,537
16,127
15,493
14,024
12,621
10,518
6,335
5,609
982
701
701
701
70.1
103,420
Source: PCSLoads2002_v4.
""Concentration was back-calculated using monthly mass and flow data.
bFacility is no longer active.
11-13
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
EPA reviewed monthly DMR data in the PCS 2002 database and on EPA's
Envirofacts web page for the facilities listed in Table 11-11. Based on this review, EPA suspects
that HCB loads in PCS may be calculated from concentrations that are based on nondetects.
According to EPA Method 1625, the method detection limit for HCB is 10 ug/L. Concentrations
for HCB range from 0.04 to 10 and are all less than or equal to the method detection limit. As
part of the 2007 annual review, EPA will review discharges of HCB from the top four facilities
to determine if the facilities measured HCB at concentrations above the detection limit.
11.6 OCPSF Category Dioxin and Dioxin-Like Compounds Discharges
EPA identified dioxin and dioxin-like compounds as a pollutant of concern during
the 2005 annual review. For the 2006 annual review, EPA analyzed information about the single
facility with "chlorinated dibenzo(p)dioxin effluent" data in PCS. EPA also reviewed
information about facilities that reported discharges of dioxin and dioxin-like compounds to TRI
to determine potential process sources and methods used to estimate reported discharges. The
results of the 2006 annual review show that dioxin and dioxin-like compounds continue to rank
high in terms of TRI TWPE. PCS dioxin TWPE, however, has decreased significantly from the
2005 annual review.
Table 11-12 shows the OCPSF facilities that reported discharges of dioxin and
dioxin-like compounds to TRI in 2002 and 2003 and how the facilities estimated discharges of
dioxin and dioxin-like compounds (based on contact with the facilities) (ERG, 2006). One
facility, BP Solvay Polyethylene in Deer Park, TX contributes over 96 percent of the total dioxin
and dioxin-like compound TRI 2003 TWPE for the OCSPF Category.
Dioxin discharges based on TCEQ sampling at three facilities contribute 99
percent of the dioxin and dioxin-like compounds TWPE for 2002. TCEQ conducted the
sampling to support the total maximum daily load (TMDL) study for the Houston Ship Channel,
which was placed on the Section 303(d) list after the Texas Department of Health issued a
seafood consumption advisory for catfish and blue crabs in the upper portion of the Galveston
Bay and Houston Ship Channel in September 1990. The purpose of the study is to develop a
TMDL for dioxin in the Houston Ship Channel, including upper Galveston Bay, and to develop a
plan for managing dioxin and dioxin-like compounds to correct existing water quality
impairments and maintain good water quality. TCEQ analyzed effluent from the following
facilities for dioxin and dioxin-like compounds: Albermarle, Atofma, Beechnut MUD, BP
Solvay, Clean Harbors, Dow DP, DuPont, Equistar, Exxon, GB Biosciences, Newport MUD,
Oxy Vinyls Battleground, Oxy Vinyls Deer Park, Oxy Vinyls La Porte, Rohm & Haas, Shell
Chemical, Shell Refinery, Valero, Vopak, and several POTWs.
From 1999 to 2003 TCEQ conducted sampling at the facilities outfalls at Atofma,
Shell, and BP Solvay and detected dioxin and dioxin-like compounds. The facilities use the
dioxin congener concentrations measured by TCEQ to estimate the releases of dioxin and dioxin-
like compounds that they report to TRI. Each facility updates its TRI releases each year by
multiplying the same dioxin concentration by the facility's annual flow. Therefore, increases in
TRI-reported releases of dioxin and dioxin-like compounds from year to year reflect increases in
wastewater flow and not necessarily increases in dioxin discharges.
11-14
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-12. OCPSF Facilities Reporting Dioxin Releases to TRI
Facility Name
(Facility Location)
Atofina Petrochemicals Inc.
(La Porte, TX)
BP Solvay Polyethylene N.A.
(Deer Park, TX)
Celanese Acetate Celco Plant
(Narrows, VA)
Cytec Industries Inc.
(Wallingford, CT)
TRI 2002
Pounds of
Dioxin
Discharged
0.00310
NR
0.0000300
0.000198
Dioxin
TWPE
57,489
NR
941
13,460
TRI 2003
Pounds of
Dioxin
Discharged
0.00000992
0.436
NR
0.0000882
Dioxin
TWPE
799
678,344
NR
5,982
Basis of
Estimate
TCEQ
sampling
episode in
1999
TCEQ
sampling
episode in
2002
Worst-case
scenario
engineering
estimate
Engineering
estimate
Was Dioxin
Detected?
TCEQ
detected
1,2,3,4,6,7,8
-HpCDD,
OCDD, and
OCDF
(TCEQ,
2003)
TCEQ
detected
1,2,3,4,6,7,8
-HpCDD,
OCDD, and
1,2,3,4,7,8-
HxCDF
(TCEQ,
2003)
No
Not
monitored
Findings
TCEQ sampling at the final outfall for the facility's NPDES
permit and provided one concentration that represented a
mixture of dioxin congeners. Facility multiplies this
concentration by the total wastewater flow for the outfall.
Facility continues to use the TCEQ dioxin number every year
for their TRI reports.
TCEQ sampling at the final outfall for the facility's NPDES
permit and provided one concentration that represented a
mixture of dioxin congeners. Facility multiplies this
concentration by the total wastewater flow for the outfall.
Facility continues to use the TCEQ dioxin number every year
for their TRI reports.
Facility uses dissolving-grade wood pulp as a raw material.
Celanese had reviewed a study that looked at the dioxin
content of wood pulp and its potential to end up in
stormwater. Wastewater monitoring data for Celanese's
Form 2C application shows all nondetects for dioxin.
Celanese stopped reporting water releases of dioxin to TRI in
2004.
Dioxin water release was based on an engineering estimate
for the operation of an incinerator that was used to dry out
biosolids. This incinerator is no longer in operation and site
did not report dioxin to TRI for 2005.
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-12 (Continued)
Facility Name
(Facility Location)
Dow Chemical Co. Midland
Ops.
(Midland, MI)
Du Pont Chambers Works
(Deepwater, NJ)
Lyondell Chemical Co.
(Westlake, LA)
SasolN.A. Inc.
(Baltimore, MD)
Sasol N.A. Inc. Lake Charles
Chemical Complex
(Westlake, LA)
TRI 2002
Pounds of
Dioxin
Discharged
0.00948
0.00231
0.00250
0.0000372
0.000882
Dioxin
TWPE
25,502
334
219
3.26
17,183
TRI 2003
Pounds of
Dioxin
Discharged
NR
0.000287
NR
NR
0.000882
Dioxin
TWPE
NR
0.580
NR
NR
4,479
Basis of
Estimate
Routine
monitoring
conducted by
facility
Engineering
estimate
Routine
monitoring
conducted by
facility
Routine
monitoring
conducted by
facility
Sampling
results from
studies
conducted
over the years
Was Dioxin
Detected?
Yes-
Reported all
congeners
except
1,2,3,6,7,8-
HxCDF, and
1,2,3,6,7,8-
HxCDD to
TRI for
2002/2003.
Not
monitored
Yes - Did
not report a
distribution
to TRI for
2002.
Yes-
Reported
1,2,3,4,6,7,8
-HpCDD
and OCDD
to TRI for
2002.
Yes-
Reported 17
congeners to
TRI for
2002/2003.
Findings
Dioxin sources include historical process and waste
management units no longer in operation at the site. A very
small amount may also come from an on-site incinerator.
The TRI dioxin water release is a TM 17 value that sums the
average congener concentrations from samples collected
throughout the year. Dow uses EPA Method 1 6 1 3B to
analyze for dioxin and sets all concentrations that are below
the detection limit to zero.
A contaminated ferric chloride additive used for solids
settling in the wastewater treatment plant was the dioxin
source. Du Pont used information from the vendor on the
dioxin composition of the contaminated ferric chloride to
estimate their TRI releases. The site has since stopped using
ferric chloride for settling. The dioxin release included in the
TRI 2004 database will be zero.
A small amount of dioxin is produced by an on-site
hazardous waste incinerator scrubber. The bulk of the dioxin
enters the plant with the source water from the Sabine River.
The site monitors the intake and final effluent for dioxin, then
calculates a balance to report what is discharged, -r^e
balance is reported to TRI.
Facility formerly operated a chlorination process that
generated dioxin. They began sampling process wastewater
and final effluent in 2001 and detected trace amounts of
OCDD. The dioxin release reported to TRI was based on this
single detected congener (concentration was just above the
detection limit). The site stopped monitoring for dioxin in
2003 when the chlorination process was shut down. They no
longer report dioxin water releases to TRI.
Facility receives wastewater from the Georgia Gulf Lake
Charles VCM plant. The VCM process wastewater is the
source of dioxin.
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-12 (Continued)
Facility Name
(Facility Location)
Shell Chemical Co. Deer Park
(Deer Park, TX)
OCPSF Category Total
TRI 2002
Pounds of
Dioxin
Discharged
NR
0.0185
Dioxin
TWPE
NR
115,132
TRI 2003
Pounds of
Dioxin
Discharged
0.00216
0.440
Dioxin
TWPE
13,967
703,572
Basis of
Estimate
TCEQ
sampling
episode in
2003
Was Dioxin
Detected?
TCEQ
detected 10
dioxin
congeners
(TCEQ,
2003)
Findings
TCEQ sampling at the outfall for the facility's chemical plant
and provided dioxin congener concentration data for 17
dioxin congeners. Facility multiplies this concentration by
the total wastewater flow for the outfall. Facility continues to
use the TCEQ dioxin number every year for their TRI reports.
Facility treats wastewater for an Oxy Vinyls EDC/VCM plant,
which is a large source of dioxins in their wastewater.
Facility has also identified other process sources that are
small contributors of dioxin.
Source: TRIReleases2002_v4', TRIReleases2003_v2', Telephone conversations with various OCPSF facility representatives and Meghan Kandle of Eastern Research
Group, Inc. (ERG, 2006).
NR - Not reported.
TCEQ - Texas Commission on Environmental Quality.
TM-17 - Total mass of 17 dioxin and dioxin-like congeners.
EDC - Ethylene dichloride.
VCM - Vinyl chlorine monomer.
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Based on the information in Table 11-12, EPA identified the following sources of
dioxin in OCPSF wastewater:
• Historical Processes - Three facilities, Cytec Industries, Dow Chemical,
and Sasol Baltimore, MD, reported dioxin to TRI based on processes that
are no longer in operation. Dow and Sasol did not report discharges of
dioxin and dioxin-like compounds to TRI for 2003.
• Raw Materials - Two facilities, DuPont Chambers Works and Celanese
Acetate, estimated discharges of dioxin and dioxin-like compounds based
on contamination of raw materials. Celanese's estimate was based on
theoretical contamination of wood pulp and DuPont's estimate was based
on actual contamination of ferric chloride. Celanese stopped reporting
discharges of dioxin and dioxin-like compounds to TRI in 2003, and
DuPont stopped reporting dioxin and dioxin-like compounds to TRI in
2004 (U.S. EPA, 2006).
• Vinyl Chloride Wastewater - Two facilities, Sasol Lake Charles, LA and
Shell Deer Park, TX, treat wastewater from nearby vinyl chloride
monomer plants, which are the major source of the dioxin and dioxin-like
compounds that the facility reports to TRI. As discussed in Section
11.1.3, EPA is reviewing production of vinyl chloride monomer as part of
the CCH rulemaking effort.
• Wet Air Pollution Controls - One facility, Lyondell, stated that an on-
site incinerator is the source of dioxin and dioxin-like compounds that was
reported to TRI for 2002. The facility stated that the amount of dioxin and
dioxin-like compounds discharged by the incinerator scrubber is small
(only 219 TWPE in Table 11-12). Lyondell did not report discharges of
dioxin and dioxin-like compounds to TRI for 2003 or 2004 (U.S. EPA,
2006).
• No Process Source Identified - Facility contacts at Atofma and BP
Solvay could not identify a potential process source for the dioxin and
dioxin-like compounds that TCEQ detected at their outfalls.
11.7 OCPSF Category PACs Discharges
EPA did not identify PACs as a pollutant of concern during the 2005 annual
review. The results of the 2006 annual review show a large increase in TRI TWPE associated
with PACs from 2002 to 2003. In addition, benzo(a)pyrene is a top pollutant in terms of PCS
TWPE for the 2006 review. The following subsections discuss EPA's review of OCPSF
facilities that report PACs discharges to TRI and PCS.
11-18
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.7.1 OCPSF Facilities Reporting PACs to TRI
Table 11-13 lists the OCPSF facilities that reported discharges of PACs to TRI for
2002 and 2003. One facility, DSM Chemicals in Augusta, GA, contributed more than 90 percent
of the PACs TWPE for 2003, but did not report PACs discharges for 2002. EPA contacted DSM
Chemicals to discuss the basis of estimate for the 2003 TRI-reported PACs discharges (Connell,
2006). DSM confirmed that the TRI-reported discharge is based on measured concentrations of
three PACs congeners: benzo(a)pyrene, dibenzo(a,h)anthracene, and indeno-l,2,3-c-pyrene. The
facility samples for PACs and other priority pollutants once per year. Prior to 2003, the
sampling did not include data on PACs concentrations. DSM suspects that the Number 2 fuel oil
used at the site is the source of PACs in their wastewater.
In 2004, EPA reviewed the coal tar refining sector of the OCPSF Category based
on discharges of PACs reported to TRI for 2000. EPA identified three U.S. coal tar refining
companies (10 facilities) operating in 2000: Honeywell International, Inc., Koppers Industries,
Inc., and Reilly Industries, Inc. Seven of these facilities continue to report discharges of PACs to
TRI and are listed in Table 11-13. Since 2000, Honeywell, Inc. closed all three of its coal tar
refining operations, and Reilly Tar & Chemical Company closed its Cleveland, OH facility. As
of 2004, six facilities owned by two companies continued to refine coal tar in the United States.
EPA's review of the coal tar industry concluded that the industry was declining, and that the
PACs discharges were at concentrations near or at treatable levels. As a result, EPA determined
that, based on the information available in 2004, it was not appropriate to select coal tar refining
sector of the OCPSF Category for possible effluent guidelines revision.
In addition to coal tar refiners, Table 11-13 lists four facilities that reported
releases of PACs to TRI for 2002 or 2003:
• DSM Chemicals in Augusta, GA produces caprolactam - a raw material
for the production of nylon-6, cyclohexanone, ammonium sulphate for
fertilizer use, and polyester resins for the powder coating industry (DSM,
2006);
• DuPont Chambers Works produces fluorochemicals, elastomers, and
hytrel polyester elastomer (U.S. EPA, 2004);
• Neutrogena in Los Angeles, CA packages toiletries and soaps (Food &
Drug Packaging, 2004); and
• Sasol NA in Baltimore, MD produces commodity and specialty chemicals
for soaps, detergents and personal care products (Sasol, 2006).
11-19
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Table 11-13. OCPSF Facilities Reporting PACs Releases to TRI
Facility Name
DSM Chemicals
North America Inc.
Du Pont Chambers
Works
Honeywell
International, Incb
Honeywell
International, Incb
Koppers Inc.b
Koppers Industries,
Inc. Follansbee Tar
Plantb
Koppers Industries,
Inc. Woodward Tar
Plantb
Neutrogena Corp.
Reilly Industries,
Inc.b
Reilly Industries,
Inc.b
SasolN.A., Inc.
Facility
Location
Augusta, GA
Deepwater,
NJ
Birmingham,
AL
Ironton, OH
Cicero, IL
Follansbee,
WV
Dolomite,
AL
Los Angeles,
CA
Granite City,
IL
Lone Star,
TX
Baltimore,
MD
Total
TRI 2002
PAC
Discharge
before
POTW
Removal
NA
15.0
6.00
7.00
0.570
4.00
12.6
0.130
16.0
NA
NA
61.3
Total
PAC
Pounds
Released"
NA
15.0
6.00
7.00
0.0420
4.00
12.6
0.00957
1.18
NA
NA
45.8
PAC
TWPE
NA
1,510
604
705
4.22
403
1,268
0.963
119
NA
NA
4,613
TRI 2003
PAC
Discharge
before
POTW
Removal
611
32.0
6.00
NA
0.600
4.00
20.0
0.0100
20.0
5.00
0.300
699
Total
PAC
Pounds
Released"
611
32.0
6.00
NA
0.0442
4.00
20.0
0.000736
1.47
0.368
0.300
675
PAC
TWPE
61,503
3,221
604
NA
4.45
403
2,013
0.0741
148
37.0
30.2
67,964
Source: TRIReleases2002_v4; TRIReleases2003_v2.
Italics denote facilities no longer in operation.
"Discharges include transfers to POTWs and account for POTW removals.
bFacility is a coal tar refiner and was included in EPA's detailed study of the OCPSF Category for the 2004 Plan.
NA - Not applicable. Facility did not report PACs releases for reporting year.
11-20
-------
Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.7.2
OCPSF Facilities Reporting Benzo(a)pyrene Discharges to PCS
Table 11-14 lists the OCPSF facilities that report discharges of benzo(a)pyrene to
PCS for 2002. As shown in Table 11-14, three facilities contribute 74 percent of the total
benzo(a)pyrene TWPE for the OCPSF Category. EPA contacted GE Silicones and Bayer
Cropscience to confirm the benzo(a)pyrene discharges in PCS (Heintzman, 2006; Smith, 2006).
Both facilities stated that benzo(a)pyrene has never been measured at concentrations above its
detection limit. According to Bayer Cropscience, the facility's permit writer directs the facility
to report nondetects at their detection limit concentration and use the detection limit and
wastewater flow to report the mass discharge on its Discharge Monitoring Report (DMR). GE
Silicones contacts stated that they report benzo(a)pyrene as a nondetect on their DMR.
However, the state of West Virginia does not include the less than (<) sign to label the
concentration as a detection limit when it uploads the DMR data into PCS. As shown in Table
11-14, 10 of the 18 facilities for which PCS has discharge data for benzo(a)pyrene are located in
West Virginia. Therefore, EPA suspects that some of the benzo(a)pyrene loads in PCS may be
calculated using detection limit concentrations and not represent actual discharges of
benzo(a)pyrene.
Table 11-14. OCPSF Facilities for which PCS includes Benzo(a)pyrene 2002 Discharge
Data
Facility Name
GE Silicones LLC
Celanese Acetate LLC/Celriver
Bayer Cropscience Institute
Invista S.A.R.L./Spartanburg
E I Dupont De Nemours & Co
Flexsys America LP
Honeywell Nylon LLC/Columbia
Ripplewood Phosphorus U.S. LLC
Nalco Company
Sunoco, Inc. (R & M)
Bayer Materialscience, LLC
Koppers Industries, Inc.
Honeywell International, Inc.
Crompton Corporation
US Filter Operating Services
Crompton Corporation
Facility Location
Friendly, WV
Rock Hill, SC
Institute, WV
Spartanburg, SC
Parkersburg, WV
Nitro, WV
Columbia, SC
Gallipolis Ferry, WV
Garyville, LA
Kenova, WV
New Martinsville, WV
Follansbee, WV
Fairfield, AL
Morgantown, WV
Clinton, IA
Morgantown, WV
Total
Pounds
Discharged
82.5
67.1
64.8
21.2
11.0
10.0
8.28
7.20
6.48
3.60
3.60
1.05
0.504
0.360
0.300
0.0360
TWPE
8,304
6,751
6,523
2,135
1,105
1,010
833
725
652
362
362
106
50.7
36.2
30.2
3.62
28,990
% of Total
TWPE
28.6%
23.3%
22.5%
7.4%
3.8%
3.5%
2.9%
2.5%
2.2%
1.2%
1.2%
0.4%
0.2%
0.1%
0.1%
0.01%
Source: PCSLoads2002 v4.
11-21
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
11.8 OCPSF Water Conservation through Mass-Based Permit Limits
EPA's evaluation of options for promoting water conservation through mass-
based limits is discussed in a memorandum entitled, Options for Promoting Water Conservation
Through the use of Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Mass-based
Limits, dated November 2006 (Johnston, 2006).
11.9 OCPSF Category Conclusions
• The OCPSF Category was selected for detailed review because of high
TWPE in the 2005 and 2006 annual reviews.
• Dioxin and dioxin-like compounds is the highest ranking pollutant in
terms of TWPE in the TRI2002 and 2003 databases. EPA contacted the
facilities that reported discharges of dioxin and dioxin-like compounds to
TRI in either 2002 or 2003 to determine the basis of estimate for the
dioxin and dioxin-like compounds release. EPA concludes the following
based on its conversations with the facilities:
— Currently, no OCPSF facility that reported dioxin and dioxin-like
compounds suspects a manufacturing process as the major source
of dioxin and dioxin-like compounds.
— Facilities that did identify a process source of dioxin and dioxin-
like compounds have stopped operating the dioxin-generating
process.
— Four out of 10 facilities that report dioxin and dioxin-like
compounds to TRI in either 2002 or 2003 stated that they did not
report a dioxin and dioxin-like compounds release to TRI for
subsequent reporting years. Three of these facilities stopped
reporting because the facilities stopped using the operation or
material that was the suspected source of dioxin and dioxin-like
compounds. One facility stopped reporting dioxin and dioxin-like
compounds because the estimate was based on theoretical
contamination from a raw material and the facility has never
detected dioxin in its wastewater.
— Three facilities that report dioxin and dioxin-like compounds
discharge wastewater to the Houston Ship Channel. TCEQ
conducted sampling at these facilities' outfalls and detected dioxin.
The facilities use the dioxin and dioxin-like compounds
concentration measured by TCEQ to estimate the dioxin and
dioxin-like compounds releases they report to TRI. Each facility
updates its TRI releases each year by multiplying the same dioxin
and dioxin-like compounds concentration by the facility's annual
flow. Therefore, increases in estimated dioxin and dioxin-like
11-22
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
compounds releases from year to year reflect increases in
wastewater flow and not necessarily increases in dioxin and
dioxin-like compounds discharges. TCEQ is developing a dioxin
TMDL to address these discharges.
HCB and PACs also rank high in terms of TRI TWPE for the OCSPF
Category. The majority of the TRI TWPE for each pollutant is from one
facility. EPA has contacted these two facilities to determine the basis of
estimate for the TRI-reported discharges. Future OCPSF category review
by EPA could focus on:
— Verification of HCB releases reported to TRI including method of
estimation, effluent concentrations, and review of process sources;
and
— Further review of non-coal-tar-refining facilities reporting
discharges of PACs to TRI including the basis of estimate for the
PACs release and review of process sources.
• HCB was a top pollutant in PCSLoads2002_v2 for the OCPSF Category
for the 2005 annual review. Discharges of HCB decreased from 1,090,000
TWPE to 103,420 TWPE during the 2006 annual review based on
comments from ACC. ACC commented that the loads for the top HCB
discharger were calculated using the HCB detection limit and the facility's
wastewater flow, and that the facility never detected HCB in its
wastewater. EPA's review of the remaining HCB dischargers indicates
that additional HCB loads may be based on concentrations that were
reported at the HCB detection limit. Future review could focus on
verifying HCB discharges in PCS.
• Benzo(a)pyrene is a top pollutant in PCSLoads2002_v4 for the OCPSF
Category. Three facilities contribute 74 percent of the total TWPE. Based
on facility contacts, EPA suspects that some of the benzo(a)pyrene
discharges in PCS may be based on detection limit concentrations and do
not represent actual discharges of benzo(a)pyrene. Future review could
focus on verifying benzo(a)pyrene discharges in PCS and further
evaluating facilities reporting discharges to PCS including information on
effluent concentrations, manufacturing processes, and potential process
sources.
11.10 OCPSF Category References
ACC. 2005. Comment submitted by Bob Elam, Director, Environment, American Chemistry
Council (ACC). "Re: EPA Docket ID Numbers OW-2004-0032 and OW-2002-0020: Notice of
Preliminary 2006 Effluent Guidelines Program Plan; Request for Comments." (November 28).
EPA-HQ-OW-2004-0032-1068.
11-23
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
Connell, Beth. 2006. Telephone conversation with Beth Connell of DSM Chemicals, Augusta,
GA, and Meghan Kandle of Eastern Research Group, Inc. "PACs Discharges reported to TRI for
2003." (August 4). DCN 03704.
DSM. 2006. DSM in the United States. Available online at
http://www.dsm.com/en_US/html/about/location_fmder.htm. Date accessed: June 21. DCN
03708.
ERG. 2006. Eastern Research Group, Inc. Telephone conversations with various OCPSF
facility representatives and Meghan Kandle of Eastern Research Group, Inc. "Basis of
Estimation for Dioxin Releases Reported to TRI." DCN 03706.
Food and Drug Packaging. 2004. "Top 25 Personal Care Packagers." Food and Drug
Packaging. (July). DCN 03709.
Heintzman, Dennis. 2006. Telephone conversation with Dennis Heintzman of GE Silicones,
Friendly, WV, and Meghan Kandle of Eastern Research Group, Inc. "Benzo(a)pyrene
Discharges in PCS for 2002." (Augusts). DCN 03705.
Johnston, Carey. 2006. U.S. EPA. Memorandum to Public Record for the Effluent Guidelines
Program Plan 2005/2006. "Options for Promoting Water Conservation Through the use of
Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Mass-based Limits." (November).
DCN 03702.
Olson, Alan. 2006. Telephone conversation with Alan Olson of Ferro Corporation, Bridgeport,
NJ, and Dan-Tarn Nguyen of Eastern Research Group, Inc. "Information Collection Effort to
Finalize Mailing List for CCH Questionnaire." (July 12). DCN 03707.
Sasol. 2006. Sasol North Americal, Inc. - Baltimore, MD. Available online at
http://www.sasolbaltimore.com. Date accessed: June 21. DCN 03710.
Smith, Gordon. 2006. Telephone conversation with Gordon Smith of Bayer Cropscience,
Institute, WV, and Meghan Kandle of Eastern Research Group, Inc. "Benzo(a)pyrene Discharges
in PCS for 2002" (Augusts). DCN 03703.
TCEQ. 2003. Texas Commission on Environmental Quality. Total Maximum Daily Load
Program. Total Maximum Daily Loads for Dioxins in the Houston Ship Channel. Final Report.
(October). DCN 03712.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Dischargers.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
11-24
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Section 11.0 - Organic Chemicals, Plastics, and Synthetic Fibers
U. S. EPA. 2005c. Product and Product Group Discharges Subject to Effluent Limitations and
Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category - 40
CFR414. Washington, DC. (April). DCN 03711.
11-25
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Section 12.0 - Ore Mining and Dressing
12.0 ORE MINING AND DRESSING (40 CFR PART 440)
EPA selected the Ore Mining and Dressing (Ore Mining) Category for additional
data collection and analysis because of the high TWPE identified in the 2005 screening-level
review, particularly discharges reported to PCS in 2002 (U.S. EPA, 2005b) (see Table V-l, 70
FR 51050, August 29, 2005). The 2004 Plan summarizes the results of EPA's previous review
of this industry (U.S. EPA, 2004). This section summarizes the 2005 annual review and also
describes the results of EPA's 2006 annual review of the discharges associated with the Ore
Mining Category. EPA's 2006 annual review builds on the 2005 annual review.
12.1 Ore Mining Category Background
This subsection provides background on the Ore Mining Category including a
brief profile of the ore mining industry and background on 40 CFR Part 440.
12.1.1 Ore Mining Industry Profile
The ore mining and dressing industry includes facilities that mine, mill, or prepare
23 separate metal ores (U.S. EPA, 2005b). This industry is divided into nine SIC codes, as
shown in Table 12-1. The following SIC codes are not required to report discharges to TRI:
1011: Iron Ores;
• 1081: Metal Mining Services; and
• 1094: Uranium-Radium-Vanadium Ores.
Because the U.S. Economic Census reports data by NAICS code, and TRI and PCS report data
by SIC code, EPA reclassified the 2002 U.S. Economic Census data by equivalent SIC code.
The facilities in SIC code 1081 subject to the Ore Mining ELGS do not translate directly to a
NAICS code, and EPA could not determine the number of facilities in the 2002 U.S. Economic
Census for SIC code 1081.
Of the almost 400 ore mines in the 2002 U.S. Economic Census, only 81 (20
percent) reported to TRI in 2002, because facilities in SIC codes 1011, 1081, and 1094 are not
required to report discharges to TRI. Of the 35 ore mines reporting wastewater discharges in
TRI, most facilities are direct dischargers. Table 12-2 presents the types of discharges reported
by facilities in the 2002 TRI database.
12.1.2 40 CFR Part 440
EPA first promulgated ELGs for the Ore Mining Category (40 CFR Part 440) on
December 3, 1982 (47 FR 54609). This category consists of 12 subcategories, as shown in Table
12-3 with the related SIC codes and descriptions of the subcategories' applicability (U.S. EPA,
1982; U.S. EPA, 1988). BAT limitations are set equal to BPT levels for priority pollutants for
this category. The priority pollutants arsenic, cadmium, copper, lead, mercury, nickel, and zinc,
are regulated in at least one subcategory (U.S. EPA, 2005b). None of the subcategories include
PSES or PSNS limitations.
12-1
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Section 12.0 - Ore Mining and Dressing
Table 12-1. Number of Facilities in Ore Mining SIC Codes
SIC Code
1011: Iron Ores
1021: Copper Ores
1031: Lead and Zinc Ores
1041: Gold Ores
1044: Silver Ores
1061: Ferroalloy Ores, Except Vanadium
1081: Metal Mining Services
1094: Uranium-Radium-Vanadium Ores
1099: Miscellaneous Metal Ores, NEC
Total
2002 U.S.
Economic
Census
24
33
22
180
11
72
NAb
17
39
>398
2002 PCS
6
15
27
28
5
6
0
17
6
110
2002 TRI
NRa
17
13
34
3
7
NRa
NRa
6
80
2003 TRI
NRa
20
12
32
3
7
NRa
NRa
7
81
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
"Facilities in this SIC code are not required to report to TRI.
bPoor bridging between NAICS and SIC codes. Number of facilities could not be determined.
NR - Not reported.
NA - Not applicable.
NEC - Not elsewhere classified.
Table 12-2. Ore Mining Category Facilities by Type of Discharge Reported in TRI 2002
SIC Code
1011: Iron Ores
1021: Copper Ores
1031: Lead and Zinc Ores
1041: Gold Ores
1044: Silver Ores
1061: Ferroalloy Ores, Except
Vanadium
1081: Metal Mining Services
1094: Uranium-Radium-Vanadium Ores
1099: Miscellaneous Metal Ores, NEC
Reported
Only Direct
Discharges
NRa
6
10
8
1
3
NRa
NRa
3
Reported
Only
Indirect
Discharges
NRa
0
0
4
0
0
NRa
NRa
0
Reported Both
Direct and
Indirect
Discharges
NRa
0
0
0
0
0
NRa
NRa
0
Reported No
Water
Discharges
NRa
12
2
22
2
4
NRa
NRa
4
Source: TRIReleases2002_v4.
""Facilities in this SIC code are not required to report to TRI.
NR - Not reported.
NEC - Not elsewhere classified.
12-2
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Section 12.0 - Ore Mining and Dressing
Table 12-3. Ore Mining Category Subcategory Applicability
Sub-
part
A
B
C
D
E
F
G
H
I
J
K
M
Subcategory Title
Iron Ore
Aluminum Ore
Uranium, Radium, & Vanadium
Ores
Mercury Ore
Titanium Ores
Tungsten Ore
Nickel Ore
Vanadium Ore (Mined Alone,
not as By-product)
Antimony Ore
Copper, Lead, Zinc, Gold, Silver,
& Molybdenum Ores
Platinum Ore
Gold Placer Mine
Related SIC Code(s)
1011: Iron Ores
1099: Miscellaneous Metal Ores,
NEC
1094: Uranium-Radium-
Vanadium Ores
1099: Miscellaneous Metal Ores,
NEC
1099: Miscellaneous Metal Ores,
NEC
1061: Ferroalloy Ores, Except
Vanadium
1061: Ferroalloy Ores, Except
Vanadium
1094: Uranium-Radium-
Vanadium Ores
1099: Miscellaneous Metal Ores,
NEC
1021: Copper Ores
1031: Lead and Zinc Ores
1041: Gold Ores
1044: Silver Ores
1061: Ferroalloy Ores, Except
Vanadium
1099: Miscellaneous Metal Ores,
NEC
1041: Gold Ores
Subcategory Applicability
Iron Ore Mines and Mills using Physical or
Chemical Separation or Magnetic &
Physical Separation in the Mesabi Range
Bauxite Mines Producing Aluminum Ore
Open-Pit or Underground Mines and Mills
using Acid Leach, Alkaline Leach, or
Combined Acid & Alkaline Leach to
Produce Uranium, Radium, & By-product
Vanadium
Open-Pit or Underground Mercury Ore
Mines and Mills using Gravity Separation or
Froth-Flotation
Titanium Ore Mines from Lode Deposits
and Mills using Electrostatic, Magnetic &
Physical Separation, or Flotation; Dredge
Mines and Mills for Placer Deposits of
Rutile, Ilmenite, Leucoxene, Monazite,
Zircon, and Other Heavy Metals
Tungsten Mines and Mills using Gravity
Separation or Froth-Flotation
Nickel Ore Mines and Mills
Vanadium Ore Mines and Mills
Antimony Ore Mines and Mills
Copper, Lead, Zinc, Gold, Silver, &
Molybdenum Ore Open-Pit or Underground
Mines, except for Placer Deposits, and Mills
using Froth-Flotation and/or Other
Separation Techniques; Mines and Mills
using Dump, Heap, In-Situ Leach, or Vat-
Leach to Extract Copper from Ores or Ore
Waste Materials; Gold or Silver Mills using
Cyanidation; Except for Mines and Mills
from the Quartz Hill Molybdenum Project in
the Tongass National Forest, Alaska
Platinum Ore Mines and Mills
Placer Deposit Gold Ore Mines, Dredges, &
Mills using Gravity Separation
Source: Development Document for Effluent Limitations Guidelines and Standards for the Ore Mining and Dressing Point
Source Category (U.S. EPA, 1982); Development Document for Effluent Limitations Guidelines and Standards for the Ore
Mining and Dressing Point Source Category Gold Placer Mine Subcategory (U.S. EPA, 1988).
NEC - Not elsewhere classified.
12-3
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Section 12.0 - Ore Mining and Dressing
12.2 Ore Mining Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Ore Mining Category
including the screening-level review and category-specific review.
12.2.1 Ore Mining 2005 Screening-Level Review
Table 12-4 presents the Ore Mining Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 12-4. Ore Mining Category 2005 Screening-Level Review Results
Rank
7
Point Source Category
Ore Mining
2002 PCS TWPEa
406,548
2002 TRI TWPEb
66,544
Total TWPE
473,093
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
Discharges include transfers to POTWs and account for POTW removals.
12.2.2 Ore Mining Category 2005 Pollutants of Concern
Table 12-5 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. The top five pollutants account for approximately 90 percent of the 2002
TRI and PCS combined TWPE.
12.3 Potential New Subcategories for the Ore Mining Category
EPA did not identify any potential new subcategories for the Ore Mining
Category.
12.4 Ore Mining Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Ore Mining Category. EPA obtained additional
data and identified facilities classified in the wrong category.
12-4
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Section 12.0 - Ore Mining and Dressing
Table 12-5. 2005 Annual Review: Ore Mining Category Pollutants of Concern
Pollutant
Molybdenum
Cyanide
Cadmium and Cadmium
Compounds
Lead and Lead
Compounds
Arsenic and Arsenic
Compounds
Vanadium and Vanadium
Compounds
Silver and Silver
Compounds
Ore Mining Category
Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
4
9
29
32
13
Total
Pounds
Released
770,329
109,018
2,360
10,406
3,143
TWPE
155,174
121,764
54,556
23,309
12,701
Pollutants are not in the top five PCS
2002 reported pollutants.
73C
625,769,753
406,548
2002 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI
2002 reported pollutants.
10
24
8
2
1
34C
1,046
5,672
2,562
147,060
250
541,214
24,181
12,705
10,352
5,147
4,118
66,544
Source: TRIReleases2002_v2; PCSLoads2002_v2.
"Discharges include major dischargers only.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
12.4.1
Ore Mining Category Facility Classification Revisions
As part of the 2006 annual review, EPA reviewed permits for facilities in the SIC
codes corresponding to the Nonferrous Metals Manufacturing Category. This review is
discussed in Section 10.4.2. EPA determined that discharges from two facilities it had classified
as nonferrous metals manufacturers, ALCOA Bauxite and Kennecott Utah, were subject to the
Ore Mining ELGS. ALCOA Bauxite's discharges result from the reclaimed mine drainage and
maintenance of the closed ALCOA and Reynolds Metals Bauxite Residue Disposal Areas. The
facility's discharges are regulated by 40 CFRPart 440 (ADEQ, 2005a; ADEQ, 2005b).
Kennecott Utah's discharges are from an integrated copper mine, smelter, and refiner. The
majority of the facility's discharges are from outfalls regulated by 40 CFR Part 440 (UDEQ,
Unknown). EPA changed the category classifications of these facilities in the revised databases,
TRIReleases2002_v4 and PCSLoads2002_v4, as described in Section 4.5 of this document.
12.4.2
Ore Mining Category 2006 Screening-Level Review
The results of the 2006 screening-level review are the TRI and PCS rankings after
the revisions described in Section 4.2 of this document. This accounts for methodology changes
described in Section 4.2 and changes made based on permit review. For the Ore Mining
Category, the most significant changes are also described in Section 12.4.1. Table 12-6 shows
the 2006 screening-level TWPE estimated for the Ore Mining Category from the 2002 and 2003
TRI and 2002 PCS databases.
12-5
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Section 12.0 - Ore Mining and Dressing
Table 12-6. Ore Mining Category 2006 Screening-Level Review Results
Point Source Category
Ore Mining
PCS 2002 TWPEa
410,266
TRI 2002 TWPEb
70,214
TRI 2003 TWPEb
77,649
Sources: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
12.4.3 Ore Mining Category 2006 Pollutants of Concern
Table 12-7 presents the pollutants of concern for the Ore Mining Category
identified in the 2006 annual review. Molybdenum and cyanide discharges from PCS are
responsible for approximately 68 percent of the category's TWPE in PCSLoads2002 _v4. One
facility, North Shore Mining, Silver Bay, MN, is responsible for approximately 93 percent of the
molybdenum TWPE inPCSLoads2002_v4. North Shore Mining reports discharges as SIC code
1011: Iron Ores. Another facility, Zortman Mining Inc., Zortman, MT, is responsible for
approximately 98 percent of the cyanide TWPE in PCSLoads2002_v4. Zortman Mining Inc.
reports discharges as SIC code 1041: Gold Ores.
12.5 Ore Mining Category Stormwater Multi-Sector General Permits (MSGP)
EPA received comments from previous effluent guidelines program plans stating
that discharges from facilities in this category may not be adequately quantified in the PCS and
TRI databases and that these discharges can cause significant water quality impacts (Johnson,
2003). In particular, EPA is evaluating the impact of discharges from waste rock and overburden
piles, which are not now regulated by effluent guidelines, and whether these discharges are
adequately controlled by the Storm Water Multi-Sector General Permits (MSGP).13 See 65 FR
64746 (Oct. 30, 2000 and 70 FR 72116, December 1, 2005).
The MSGP includes very general benchmark values for sampling and general
requirements to develop a Stormwater pollution prevention plan, but does not establish numeric
limits or Stormwater containment/treatment requirements. The MSGP establishes benchmark
monitoring for pollutants including TSS, pH, hardness, arsenic, beryllium, cadmium, copper,
iron, lead, manganese, mercury, nickel, selenium, silver, zinc, and uranium.14 The data from this
sampling are now available due to the 2000 MSGP requirements.
13Mine sites not regulated by the MSGP include: (1) sites with their Stormwater discharges regulated by an
individual permit; and (2) sites without any discharge of Stormwater. A facility has the option of obtaining an
individual permit for Stormwater discharges instead of requesting coverage under the MSGP; however, in practice
this is seldom done. The current MSGP expires this year; however EPA intends to reissue it. Almost all mine sites
discharge Stormwater (e.g., Stormwater discharges from haul roads, process areas, equipment storage areas, mine
waste rock).
14Table G-4 of the MSGP lists what wastewaters from mining activities are covered by Part 440 and what
wastewaters are to be covered by the industrial MSGP. In response to litigation from the National Mining
Association, EPA revised its interpretation of applicability for wastewaters from hard rock mining operations. Under
the revised interpretation, runoff from waste rock and overburden piles is not subject to effluent guidelines unless it
naturally drains (or is intentionally diverted) to a point source and combines with "mine drainage" that is otherwise
subject to the effluent guidelines (65 FR 64774, October 30, 2000).
12-6
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Section 12.0 - Ore Mining and Dressing
Table 12-7. 2006 Annual Review: Ore Mining Category Pollutants of Concern
Pollutant
Molybdenum
Cyanide
Cadmium and
Cadmium
Compounds
Lead and Lead
Compounds
Arsenic and
Arsenic
Compounds
Silver and Silver
Compounds
Vanadium and
Vanadium
Compounds
Ore Mining
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
4
7
26
30
11
Total
Pounds
Released
770,329
109,018
2,360
10,406
3,143
TWPE
155,174
121,764
54,556
23,309
12,701
Pollutants are not in the top five PCS 2002
reported pollutants.
50C
702,310,349
410,266
2002 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI 2002
reported pollutants.
10
25
9
2
3
35C
848
5,526
3,312
500
147,310
462,061
19,603
12,378
13,383
8,235
5,156
70,214
2003 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI 2003
reported pollutants.
9
23
8
2
3
32C
642
5,153
5,882
500
240,200
597,196
14,878
11,542
23,770
8,235
8,407
77,649
to
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include major dischargers only.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 12.0 - Ore Mining and Dressing
Commenters on previous effluent guidelines program plans have requested that
EPA reverse its decision to exclude discharges from waste rock and overburden piles from the
Part 440 applicability definition of "mine drainage." Specifically, commenters suggested that
EPA should conduct a rulemaking to address discharges from waste rock piles, overburden piles,
and other sources of water pollution at mine sites that are not currently covered by Part 440 (see
63 FR 47285, September 4, 1998).
The Agency will review the MSGP data for usefulness in revising the effluent
guidelines, for example, to determine the mass and concentrations of pollutants discharged and
effluent variability associated with these discharges, and to evaluate the performance and
effectiveness of the permit controls (primarily "best management practices") at reducing
pollutants. Additionally, EPA may gather other relevant data (such as cost data) on wastewater
treatment technologies for this category. Preliminary MSGP data indicate high concentrations of
metals in active and inactive mine site runoff. The volumes of discharge can be significant due to
the large land area covered by the mine sites. Additionally, EPA Regions are evaluating whether
states are adequately addressing mine site runoff. Finally, EPA is also investigating the potential
for facilities in this category to contaminate ground water and, through infiltration and inflow,
adversely affect POTW operations (U.S. EPA, 2002).
12.6 Ore Mining Category Conclusions
• The high TWPE ranking for the Ore Mining Category in the 2005 annual
review was due to discharges of molybdenum and cyanide reported to
PCS.
• After EPA revised the databases, the facilities with discharges subject to
the Ore Mining ELGs account for 480,480 TWPE using combined TRI
and PCS data from 2002.
• EPA determined there is incomplete data available for a full analysis of
the Ore Mining Category. EPA intends to continue reviewing the ore
mining industry for the 2007/2008 planning cycle.
12.7 Ore Mining Category References
ADEQ. 2005a. Arkansas Department of Environmental Quality. Authorization to Discharge
Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air
Pollution Control Act Fact Sheet for NPDES AR0000582 - ALCOA Bauxite Works, Bauxite,
AR. Little Rock, AR. (May 23). DCN03313.
ADEQ. 2005b. Arkansas Department of Environmental Quality. Authorization to Discharge
Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air
Pollution Control Act NPDES AR0000582 - ALCOA Bauxite Works, Bauxite, AR. Little Rock,
AR. (May 31). DCN03313.
Johnson, Carey. 2003. U.S. EPA. Memorandum to Public Record for the Effluent Guidelines
Program Plan for 2004/2005. "Description and Results of EPA Methodology to Synthesize
12-8
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Section 12.0 - Ore Mining and Dressing
Screening Level Results for the CWA 304(m) Effluent Guidelines Program Plan for 2004/2005."
(December 23). DCN 00548.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1982. Development Document for Effluent Limitations Guidelines and Standards for
the Ore Mining and Dressing Point Source Category. EPA-440/1-82/061. Washington, DC.
U.S. EPA. 1988. Development Document for Effluent Limitations and Guidelines for New
Source Performance Standards for the Ore Mining and Dressing Point Source Category Gold
Placer Mine Subcategory. EPA-440/1-88-061. Washington, DC.
U.S. EPA. 2002. EPA Issues Draft Discharge Permits and Proposed Variances for Three Silver
Valley Wastewater Treatment Plants. Environmental Fact Sheet. (August). DCN 02090.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Discharger?,.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
UDEQ. Unknown. Utah Department of Environmental Quality. Statement of Basis for
UT0000051 - Kennecott Utah Copper Corporation, Magna, UT. Salt Lake City, UT. DCN
03320.
12-9
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Section 13.0 - Pesticide Chemicals
13.0 PESTICIDE CHEMICALS (40 CFR PART 455)
EPA selected the Pesticide Chemicals Category for additional data collection and
analysis because of the high TWPE identified in the 2005 screening-level review (see Table V-I,
70 FR 51050, August 29, 2005). This section summarizes the 2005 annual review and also
describes EPA's 2006 annual review of the discharges associated with the Pesticide Chemicals
Category (U.S. EPA, 2005b). EPA's 2006 annual review builds on the 2005 annual review.
13.1 Pesticide Chemicals Category Background
This subsection provides background on the Pesticide Chemicals Category
including a brief profile of the pesticide chemicals industry and background on 40 CFR Part 455.
13.1.1 Pesticide Chemicals Industry Profile
The pesticide chemicals industry includes facilities that manufacture pesticide
active ingredients and formulate, package, and repackage pesticide products. Most of the
pollutant loadings that EPA identified in the PCS and TRI databases are associated with pesticide
chemicals manufacturing, not with pesticides formulating, packaging, and repackaging. As a
result, most of Section 13.0 discusses pesticide chemicals manufacturing.
Approximately 100 facilities manufacture pesticide chemicals in the United States
(U.S. EPA, 1993). Of these, approximately half also formulate, package, or repackage pesticides
(although more than 2,000 U.S. facilities formulate, package, or repackage pesticides (U.S. EPA,
1996)). Approximately half of the pesticide chemicals manufacturers also manufacture other
organic chemicals, whose discharges are covered by the Organic Chemicals, Plastics, and
Synthetic Fibers (OCPSF) ELGs. Typically, a facility will manufacture only one pesticide and is
the only facility in the country that manufactures it.
To estimate the pollutant loads associated with the Pesticides Chemicals
Category, EPA included discharges from facilities with a primary SIC code of 2879: Pesticide
and Agricultural Chemicals, Not Elsewhere Classified (NEC), as well as the discharges of
pesticide chemicals from facilities with other primary SIC codes. Although facilities with many
SIC codes could perform operations covered by Part 455, the main SIC code that is covered by
the Pesticide Chemicals ELGs is SIC code 2879. In TRI and PCS, discharges of pesticides result
from facilities with the following primary SIC codes:
• 2048: Prepared Feed and Feed Ingredients for Animals and Fowls, Except
Dogs and Cats;
• 2812: Alkalies and Chlorine;
• 2816: Inorganic Pigments;
• 2821: Plastics Materials, Synthetic Resins, and Nonvulcanizable
Elastomers;
13-1
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Section 13.0 - Pesticide Chemicals
• 2823: Cellulosic Manmade Fibers;
• 2824: Manmade Organic Fibers, Except Cellulose;
• 2834: Pharmaceutical Preparations;
• 2842: Specialty Cleaning, Polishing, and Sanitation Preparations;
• 2844: Perfumes, Cosmetics, and Other Toilet Preparations;
• 2865: Cyclic Organic Crudes and Intermediates, and Organic Dyes and
Pigments;
• 2869: Industrial Organic Chemicals, NEC;
• 2891: Adhesives and Sealants; and
• 2899: Chemicals and Chemical Preparations, NEC.
Nonpesticide discharges from facilities in these SIC codes are regulated by other
point source categories: the Inorganic Chemicals Manufacturing Category; the Pharmaceutical
Manufacturing Category; and the OCPSF Category.15 EPA reviews the nonpesticide discharges
from these facilities with their respective point source categories.
Table 13-1 lists the SIC codes with operations in the Pesticide Chemicals
Category. The majority of facilities in the Pesticide Category report a primary SIC code of 2879
in TRI and 2869 in PCS. Also, in the 1993 rulemaking, EPA identified roughly 100 pesticides
manufacturers, whereas Table 13-1 includes facilities that only package, formulate, package, and
repackage pesticides. Because the U.S. Economic Census reports data by NAICS code, and TRI
and PCS report data by SIC code, EPA reclassified the 2002 U.S. Economic Census data by
equivalent SIC code. The facilities in SIC codes that are possibly subject to the multiple ELGs
(Pesticide Chemicals and others) do not correlate directly to a NAICS code, and therefore EPA
could not determine the number of facilities in the 2002 U.S. Economic Census for these SIC
codes.
15 For the OCPSF Category, discharges from the manufacture of chlorine and chlorinated hydrocarbons are being
reviewed as part of the chlorine and chlorinated hydrocarbons effluent guidelines rulemaking. These facilities'
pesticide chemicals manufacturing discharges are still included in the Pesticide Chemicals Category.
13-2
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Section 13.0 - Pesticide Chemicals
Table 13-1. Number of Facilities with Pesticide Chemicals Discharges Listed by Primary
SIC Code
SIC Code
2879: Pesticides and Agricultural Chemicals,
Not Elsewhere Classified (NEC)C
2048: Prepared Feed and Feed Ingredients for
Animals and Fowls, Except Dogs and Cats0
2812: Alkalies and Chlorine"
2816: Inorganic Pigments0
2821: Plastics Materials, Synthetic Resins, and
Nonvulcanizable Elastomers0
2823: Cellulosic Manmade Fibers0
2824: Manmade Organic Fibers, Except
Cellulose0
2834: Pharmaceutical Preparations0
2842: Specialty Cleaning, Polishing, and
Sanitation Preparations0
2844: Perfumes, Cosmetics, and Other Toilet
Preparations0
2865: Cyclic Organic Crudes and
Intermediates, and Organic Dyes and Pigments0
2869: Industrial Organic Chemicals, NEC0
2891: Adhesives and Sealants0
2899: Chemicals and Chemical Preparations,
NEC0
Chlorine and Chlorinated Hydrocarbons
Rulemaking6
Total
2002 U.S.
Economic
Census
239
NAd
239
2002 PCS3
29
0
7
1
58
0
0
0
1
0
24
76
0
0
0
196
2002 TRIb
124
1
1
0
3
1
0
1
1
0
2
12
1
6
3
156
2003 TRIb
113
0
0
0
3
1
0
1
2
0
2
11
1
6
2
142
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v4; TRIReleases2002_v4;
TRIReleases2003_v2.
aMajor and minor dischargers.
bReleases to any media.
Discharges of pesticides from these facilities are regulated by the Pesticide ELGs. All other dischargers are
regulated under other ELGs.
dPoor bridging between NAICS and SIC codes. Number of facilities could not be determined.
eThese facilities produce chlorine or chlorinated hydrocarbons as well as pesticides, and their nonpesticide
discharges are being reviewed as part of the review for the Chlorine and Chlorinated Hydrocarbons effluent
guidelines rulemaking.
NEC - Not elsewhere classified.
13-3
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Section 13.0 - Pesticide Chemicals
Pesticide chemicals manufacturing facilities discharge directly to surface water as
well as to POTWs. Table 13-2 presents the types of discharges reported by facilities in the 2002
TRI database. The majority of facilities in SIC code 2879 reported no water discharges, but
facilities may be discharging pollutants in wastewater at levels below the TRI-reporting
thresholds.
13.1.2 40 CFR Part 455
The ELGs for the Pesticide Chemicals Category were first promulgated on April
25, 1978 (43 FR 17776) for Subparts A and B. EPA last revised the ELGS for the Pesticide
Chemicals Category Subparts A, B, and D in 1998 (U.S. EPA, 1993; U.S. EPA, 1998), and
promulgated ELGS for pesticide chemicals formulating, packaging, and repackaging (Subparts C
and E) in 1996 (U.S. EPA, 1998). EPA promulgated BPT, BAT, BCT, and NSPS for Subparts A
through E, and Subparts A, C, and E include PSES and PSNS limitations. This category consists
of five subcategories, as shown in Table 13-3 with a description of each subcategory's
applicability. All facilities that manufacture pesticide active ingredients are subject to priority
pollutant limits under Subpart A. In addition, there are numerical limitations for 49 pesticide
active ingredients under BPT. Under Subparts C and E, facilities that formulate, package, or
repackage pesticide products are subject to either a zero discharge limit or a pollution prevention
alternative that allows a small discharge after implementation of specific pollution prevention
techniques and treatment.
13-4
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Section 13.0 - Pesticide Chemicals
Table 13-2. Pesticide Chemicals Category Facilities by Type of Discharge Reported in TRI
2002
SIC Code
2879: Pesticides and Agricultural Chemicals,
Not Elsewhere Classified (NEC)
2048: Prepared Feed and Feed Ingredients for
Animals and Fowls, Except Dogs and Cats3
2812: Alkalies and Chlorine3
2816: Inorganic Pigments3
2821: Plastics Materials, Synthetic Resins, and
Nonvulcanizable Elastomers3
2823: Cellulosic Manmade Fibers3
2824: Manmade Organic Fibers, Except
Cellulose3
2834: Pharmaceutical Preparations3
2842: Specialty Cleaning, Polishing, and
Sanitation Preparations3
2844: Perfumes, Cosmetics, and Other Toilet
Preparations3
2865: Cyclic Organic Crudes and
Intermediates, and Organic Dyes and Pigments3
2869: Industrial Organic Chemicals, NEC3
2891: Adhesives and Sealants3
2899: Chemicals and Chemical Preparations,
NEC3
Chlorine and Chlorinated Hydrocarbons
Rulemaking3
Reported
Only Direct
Discharges
18
0
0
0
1
1
0
0
0
0
2
6
0
1
2
Reported
Only
Indirect
Discharges
13
1
0
0
2
0
0
0
1
0
0
6
1
4
0
Reported
Both Direct
and Indirect
Discharges
5
0
0
0
0
0
0
1
0
0
0
0
0
1
0
Reported No
Water
Discharge
88
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Source: TRIReleases2002_v4.
3EPA identified facilities known to perform pesticide chemicals manufacturing operations.
13-5
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Section 13.0 - Pesticide Chemicals
Table 13-3. Applicability of Subcategories in the Pesticide Chemicals Point Source
Category
Sub-
part
Subpart Title
Subpart Applicability
Organic Pesticide Chemicals
Manufacturing
Discharges resulting from the manufacture of organic and organo-tin
pesticide active ingredients. Intermediates used to manufacture the active
ingredients and active ingredients used solely in experimental pesticides
are excluded from coverage.
B
Metallo-Organic Pesticide
Chemicals Manufacturing
Discharges resulting from the manufacture of metallo-organic pesticide
active ingredients containing mercury, cadmium, arsenic, or copper.
Intermediates used to manufacture the active ingredients are excluded
from coverage.
C
Pesticide Chemicals
Formulating and Packaging
Discharges resulting from all pesticide formulating, packaging, and
repackaging operations except repackaging of agricultural pesticides
performed at refilling establishments. Formulation, packaging, and/or
repackaging of sanitizer products (including pool chemicals),
microorganisms, inorganic wastewater treatment chemicals, specified
mixtures, and liquid chemical sterilant products as defined in the Federal
Food, Drug and Cosmetic Act and in the Federal Insecticide, Fungicide
and Rodenticide Act is excluded. Also excluded is the development of
new formulations of pesticide products and the associated efficacy and
field testing at on-site or stand-alone research and development
laboratories where the resulting pesticide product is not produced for
sale.
D
Test Methods for Pesticide
Pollutants
Analytical test methods that must be used to determine the concentration
of pesticide active ingredients in the wastewater.
Repackaging of Agricultural
Pesticides Performed at
Refilling Establishments
Discharges resulting from all repackaging of agricultural pesticides
performed by refilling establishments whose primary business is
wholesale or retail sales; and where no pesticide manufacturing,
formulating, or packaging occurs. Does not apply to wastewater
discharges from custom application or custom blending and repackaging
of microorganisms or certain specified mixtures, or non-agricultural
pesticide products.
Source: Pesticide Chemicals Point Source Category - 40 CFR 455.
13-6
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Section 13.0 - Pesticide Chemicals
13.2
Pesticide Chemicals Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Pesticides Chemicals
Category including the screening-level review and category-specific review.
13.2.1
Pesticide Chemicals Category 2005 Screening-Level Review
Table 13-4 presents the Pesticide Chemicals Category TWPE calculated using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 13-4. Pesticide Chemical Category 2005 Screening-Level Review Results
Rank
5
Point Source Category
Pesticide Chemicals
2002 PCS TWPEb
50,690
2002 TRI TWPEC
554,485
Total TWPE
605,175
Source: 2005 Annual Screening-Level Analysis Report (U.S. EPA, 2005a); PCSLoads2002_v2;
TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
13.2.2
Pesticides Chemicals Category 2005 Pollutants of Concern
Typically, a pesticide chemicals manufacturing facility manufactures only one
pesticide active ingredient and is the only facility in the country producing that ingredient (U.S
EPA, 1993). As a result, in the TRI and PCS databases, the top pesticide chemicals, in terms of
TWPE, are only reported by one or two facilities. Table 13-5 shows the five pollutants with the
highest TWPE in TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. The estimated TWPE from the TRI database is much greater than the
TWPE from the PCS database. Picloram contributed approximately 90 percent of the category
TRI TWPE.
13.3 Potential New Subcategories for the Pesticide Chemicals Category
EPA did not identify any potential new subcategories for the Pesticide Chemicals
Category.
13-7
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Section 13.0 - Pesticide Chemicals
Table 13-5. 2005 Annual Review: Pesticide Chemicals Category Pollutants of Concern
Pollutant
Picloram
Dichlorvos
Diazinon
Cyfluthrin
Merphos
Carbaryl
Diazinon
Hyxachlorocyclohexane
Chlorine
1 ,3 -Dichloropropene
Pesticide Chemicals
Category Total
2002 PCS3
Number of
Facilities
Reporting
Chemical
Total Pounds
Released
TWPE
Pollutants are not in the top five PCS
2002 reported pollutants
1
1
1
3
76
203C
153
2.1
14.8
1,608
1,097
122,209,015
42,918
1,344
1,038
819
620
50,690
2002 TRIb
Number of
Facilities
Reporting
Chemical
2
1
3
1
1
Total
Pounds
Released
240,111
6.2
12.3
26.0
23.0
TWPE
498,021
34,935
7,685
5,463
1,549
Pollutants are not in the top five TRI
2002 reported pollutants.
64C
1,754,350
554,485
Source: PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
13-8
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Section 13.0 - Pesticide Chemicals
13.4
Pesticide Chemicals Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Pesticide Chemicals Category. EPA's 2006 annual
review of the Pesticide Chemicals Category included reviewing the 2003 TRI data and verifying
facility discharges.
13.4.1
Pesticide Chemicals Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings based on methodology changes as described in Section 4.2. Table 13-6 shows the 2006
screening-level TWPE estimated for the Pesticide Chemicals Category from the 2002 and 2003
TRI and 2002 PCS databases.
Table 13-6. Pesticide Chemicals Category 2006 Screening-Level Review Results
Point Source Category
Pesticide Chemicals
2002 PCS TWPEa
50,299
2002 TRI TWPEb
554,673
2003 TRI TWPEb
485,460
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
13.4.2
Pesticide Chemicals Category 2006 Pollutants of Concern
Table 13-7 presents the pollutants of concern for the Pesticide Chemicals
Category based on the 2006 annual review. In all cases, the top pollutant is reported by only one
or two facilities, which is typical for the industry (U.S. EPA, 1993). The remainder of this
subsection discusses the discharges reported for picloram, the top TRI 2002 and 2003 pollutant
of concern in terms of TWPE, and carbaryl, the top PCS 2002 pollutant of concern in terms of
TWPE.
13-9
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Section 13.0 - Pesticide Chemicals
Table 13-7. 2006 Annual Review: Pesticide Chemicals Category Pollutants of Concern
Pollutant
Picloram
Dichlorvos
Diazinon
Cyfluthrin
Merphos
Carbaryl, Total
Hexachlorocyclo
hexane, Total
Chlorine
Daconil
(C8C14N2)
Pesticide
Chemicals
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five PCS 2002
reported pollutants.
1
2.16
1,344
Pollutants are not in the top five PCS 2002
reported pollutants.
1
1
3
1
48C
153
14.8
1,608
83
122,206,792
42,918
1,038
819
613
50,299
2002 TRIb
Number of
Facilities
Reporting
Pollutant
2
1
3
1
1
Total
Pounds
Released
240,111
6.24
12.4
26
23
TWPE
498,021
34,935
7,685
5,463
1,549
2003 TRIb
Number of
Facilities
Reporting
Pollutant
1
1
3
1
1
Total
Pounds
Released
213,664
1.24
8.35
26
10
TWPE
443,167
6,929
5,196
5,463
674
Pollutants are not in the top five TRI 2002 reported pollutants.
67C
1,757,740
554,673
63C
1,927,344
485,460
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 13.0 - Pesticide Chemicals
13.4.3
Pesticide Chemicals Category Picloram Discharges
Picloram accounts for approximately 90 percent of the category's 2002 TRI
TWPE and approximately 91 percent of the category's 2003 TRI TWPE. Table 13-8 presents
the facilities reporting discharges of picloram to TRI in 2002 and 2003.
Table 13-8. Pesticide Chemicals Category Picloram Discharges
Facility
(Location)
Dow Chemical Co. Freeport Facility
(Freeport, TX)
Dow Chemical Co. Midland Ops.
(Midland, MI)
2002 TRI
Total Pounds
Released"
239,991
120
TWPE
497,772
249
2003 TRI
Total Pounds
Released"
213,664
NA
TWPE
443,167
NA
Source: TRIReleases2002_v4; TRIReleases2003_v2.
"Facilities are direct dischargers so discharges are not transferred to POTWs.
NA - Not applicable. Facility did not report discharges of picloram to TRI in 2003.
The majority of the picloram TWPE in the TRI 2002 and 2003 databases are from
discharges reported by Dow Chemical Co. Freeport Facility. The facility's NPDES permit does
not have limits for picloram discharges, and PCS does not have data on the facility's picloram
discharges (TCEQ, 2002; TCEQ, 2003).
EPA contacted Dow Chemical Co. Freeport Facility to determine how it estimated
its TRI wastewater discharges of picloram and if picloram discharges were being controlled by
the best available technology economically achievable. In letters dated October 26, 2005, and
July 26, 2006, Dow Chemical Co. stated that its Freeport facility manufactures picloram as one
of its many products (Falcon, 2005). The facility recovers picloram for sale, but some picloram
remains in the wastewater because of solubility and filtration inefficiency. Dow's Freeport
Facility measures the total organic carbon (TOC) in the wastewater daily, and estimates the
wastewater picloram content as a percentage of the TOC based on process knowledge, water
chemistry, and the downstream wastewater treatment removal. EPA continues to work with the
facility to determine if picloram is being controlled by the best available technology
economically achievable.
EPA reviewed Dow Chemical Co. Freeport Facility's NPDES permit, but could
not determine which outfall receives the picloram wastewater (TCEQ, 2002; TCEQ, 2003). As a
result, EPA could not estimate the concentration of picloram in the facility's wastewater for a
specific outfall. However, Table 13-9 uses flow data from the entire facility to estimate the
concentration of picloram in the effluent wastewater. EPA considers the estimate in Table 13-9
as a lower bound of the concentration in wastewater from the picloram manufacturing process,
because EPA used an estimated flow that includes wastewater from most of Dow's Freeport
facility's organic chemicals manufacturing processes, off-site wastewater, stormwater,
noncontact cooling water, ground water, and other nonprocess wastewater.
13-11
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Section 13.0 - Pesticide Chemicals
Table 13-9. Estimated Picloram Concentrations in Dow Chemical Co. Freeport Facility's
Final Effluent
Year
2002
2003
Total Facility Flow
(MGY)
108,000
117,000
Outfall Flows
Included for Total
Flow3
001
Pounds of
Picloram Reported
(Ibs/yr)
239,991
213,664
Estimated
Picloram
Concentration
(mg/L)
266
218
"Picloram-containing wastewater most likely discharges through Outfall 001. Outfall 001 receives wastewater from
most of Dow Freeport's organic chemicals manufacturing, as well as off-site wastewater, stormwater, ground water,
and noncontact cooling water. Outfall 002 receives wastewater from inorganic chemicals manufacturing, as well as
utility wastewater, cooling water, treated ground water, and process stormwater. Outfall 003 receives wastewater
from organic chemicals manufacturing such as polycarbonate, styrene, allyl chloride, and epichlorohydrin
wastewater, as well as off-site wastewater, stormwater, noncontact cooling water, boiler blowdown, and utility
wastewater.
Activated carbon is the most effective treatment technology based on the
treatability transfer analysis done for the 1993 rulemaking. In 1997, EPA set a drinking water
Maximum Contaminant Level Goal at 0.5 mg/L for picloram. Picloram is soluble in water at
430 mg/L, at 25° C (Cornell, 2006).
13.4.4
Pesticide Chemicals Category Total Carbaryl Discharges
Total carbaryl accounts for approximately 85 percent of the category's 2002 PCS
TWPE. Table 13-10 presents the facilities reporting discharges of picloram to PCS in 2002.
Table 13-10. Pesticide Chemicals Category Total Carbaryl Discharges in PCS 2002
Facility
(Location)
Bayer Cropscience Institute (Institute, WV)
Total Pounds Released
153
TWPE
42,918
Source: PCSLoads2002_v2.
EPA verified Bayer Cropscience Institute's carbaryl discharges by reviewing the
facility's permit and detailed PCS data and contacting the WV Department of Environmental
Protection to verify the facility's carbaryl loads (WVDEP, 2002). The total carbaryl discharges
from the facility are incorrectly estimated by PCSLoads2002_v4. Based on DMR data, the
facility discharged approximately 5.5 pounds (1,500 TWPE) of total carbaryl in 2002, whereas
thePCSLoads2002_v4 database estimates 153 pounds (42,900 TWPE) because of double-
counting outfalls and data-entry errors. EPA will correct the estimated pollutant load for total
carbaryl in future review cycles.
13-12
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Section 13.0 - Pesticide Chemicals
13.5 Pesticide Chemicals Category Conclusions
• The Pesticide Chemicals Category was selected for detailed review
because of high TWPE in the PCSLoads2002_v4, TRIReleases2002_v4,
and TRIReleases2003_v2 databases.
• Discharges of picloram from Dow Chemical's Freeport, TX facility
account for 99 percent of the category load from the TRI databases. The
facility estimates its picloram discharges as a percentage of TOC in the
wastewater. EPA estimated the concentration of picloram discharged in
final effluent at more than 200 mg/L. Activated carbon is the most
effective treatment technology based on the treatability transfer analysis
done for the 1993 rulemaking (40 CFR 455, Table 10). EPA continues to
work with the facility to better understand the treatment and discharge of
picloram.
• EPA identified an error in the estimation of total carbaryl loads from
Bayer Cropscience Institute in PCSLoads2002_v4. Based on DMR data,
the facility discharged approximately 5.5 Ibs (1,500 TWPE) of total
carbaryl in 2002. Because of data-entry errors and double-counting of
outfalls, PCSLoads2002_v4 estimated approximately 153 Ibs (42,900
TWPE) of total carbaryl discharged. EPA will correct the estimated
pollutant load for total carbaryl in future review cycles, and it is no longer
a pollutant of concern (at less than 3 percent of the category PCS TWPE).
13.6 Pesticide Chemicals Category References
Cornell. 2006. Cornell University Herbicide Profile 10/88. Available online at:
http://extoxnet.orst.edu/pips/picloram.htm. Date accessed: June 12, 2006. DCN 03979.
Falcon, Fran Quinlan. 2005. Letter from Fran Quinlan Falcon, Environmentally Leveraged
Delivery Leader, The Dow Chemical Company, and Audrey Kasenge, Eastern Research Group,
Inc. "EPA Effluent Guideline Review on TRI Chemical Picloram in Response to EPA's e-mail
requests dated June 9, 2005 and October 20, 2005." (October 26). DCN 02670.
TCEQ. 2002. Permit to Discharge Wastes Under Provisions of Section 402 of the Clean Water
Act and Chapter 26 of the Texas Water Code Fact Sheet and Executive Director's Preliminary
Decision NPDES TX00064831 - The Dow Chemical Company, Freeport, TX. Austin, TX.
(November 1). DCN 01897.
TCEQ. 2003. Permit to Discharge Wastes Under Provisions of Section 402 of the Clean Water
Act and Chapter 26 of the Texas Water Code NPDES TX00064831 - The Dow Chemical
Company, Freeport, TX. Austin, TX. (December 19). DCN 01894.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
13-13
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Section 13.0 - Pesticide Chemicals
U.S. EPA. 1993. Development Document for Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance Standards for the Pesticide Chemicals Manufacturing
Point Source Category (Final). EPA-821-R-93-016. Washington, DC. (September).
U.S. EPA. 1996. Development Document for Best Available Technology, Pretreatment
Technology, and New Source Performance Technology for the Pesticide Formulating,
Packaging, and Repackaging Industry-Final. EPA-821-R-96-019. Washington, DC.
(September).
U.S. EPA. 1998. Amendments to the Effluent Limitations Guidelines, Pretreatment Standards,
and New Source Performance Standards for the Organic Pesticide Chemicals Manufacturing
Industry—Pesticide Chemicals Point Source Category; Direct Final Rule and Proposed Rule (see
63 FR 3944, July 22, 1998). Available online at: www.epa.gov/EPA-WATER/1998/July/Day-
22Avl9514.pdf. Date accessed: July 1, 2005.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Discharger?,.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
WVDEP. 2002. West Virginia Department of Environmental Protection, Division of Water
Resources. National Pollution Discharge Elimination System Water Pollution Control Permit
NPDES WV0000086 - Bayer Cropscience Institute, Charleston, WV. Charleston, WV. (June).
DCN 02894.
13-14
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Section 14.0 - Petroleum Refining
14.0 PETROLEUM REFINING (40 CFR PART 419)
EPA selected the Petroleum Refining Category for additional data collection and
analysis because of the high TWPE identified in the 2005 screening-level review (see Table V-l,
70 FR 51050, August 29, 2005). The 2004 Plan summarizes the results of EPA's previous
detailed study of this industry (U.S. EPA, 2004). This section summarizes the 2005 annual
review and also describes EPA's 2006 annual review of the discharges associated with the
Petroleum Refining Category. EPA's 2006 annual review builds on the 2005 annual review.
Because EPA completed a detailed study of this industry in 2004, most of the 2006 annual
review focused on newly identified pollutant discharges (i.e., discharges not reported by a
facility in the data used for the 2004 detailed study).
14.1 Petroleum Refining Category Background
This subsection provides background on the Petroleum Refining Category
including a brief profile of the petroleum refining industry and background on 40 CFR Part 419.
14.1.1 Petroleum Refining Industry Profile
The petroleum refining industry includes facilities that produce 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. This industry is represented by one SIC code, 2911 Petroleum Refining; however,
EPA is considering including operations from four other SIC codes as new subcategories of the
Petroleum Refining Category (see the Potential New Subcategories Section (Section 14.3)).
Table 14-1 presents the number of facilities in the SIC codes that compose the
petroleum refining industry. Because the U.S. Economic Census reports data by NAICS code,
and TRI and PCS report data by SIC code, EPA reclassified the 2002 U.S. Economic Census by
the equivalent SIC code. The facilities in SIC code 5171 do not correlate directly to a NAICS
code and therefore EPA could not determine the number of facilities in the 2002 U.S. Economic
Census for SIC code 5171.
Petroleum refineries discharge directly to surface water as well as to POTWs.
Table 14-2 presents the types of discharges reported by facilities in the 2002 TRI database. The
majority of petroleum refineries reporting to TRI reported discharging directly. The majority of
facilities reporting to TRI in SIC codes classified as potential new subcategories reported no
water discharges, but facilities may be discharging pollutants in wastewater at levels below the
TRI-reporting threshold.
14-1
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Section 14.0 - Petroleum Refining
Table 14-1. Number of Facilities in Petroleum Refining SIC Codes
SIC
2911: Petroleum Refining
2002 U.S.
Economic
Census
199
2002 PCS3
153
2002 TRIb
163
2003 TRIb
163
Potential New Subcategories
2992: Lubricating Oils and Greases
2999: Products Of Petroleum and Coal, NEC
4612: Crude Petroleum Pipelines
5171: Petroleum Bulk Stations and Terminals
Potential New Subcategories Total
407
74
271
NAC
>752
21
17
23
446
507
144
22
0
599
765
139
28
0
541
708
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
aMajor and minor dischargers.
bReleases to any media.
°Poor bridging between SIC codes and NAICS codes. Number of facilities could not be determined.
NA - Not applicable.
NEC - Not elsewhere classified.
Table 14-2. Petroleum Refining Category Facilities by Type of Discharge Reported in TRI
2002
SIC Code
2911: Petroleum Refining
Reported
Only Direct
Discharges
95
Reported
Only
Indirect
Discharges
19
Reported
Both Direct
and Indirect
Discharges
15
Reported No
Water
Discharges
34
Potential New Subcategories
2992: Lubricating Oils and Greases
2999: Products Of Petroleum and Coal, NEC
4612: Crude Petroleum Pipelines
5171: Petroleum Bulk Stations and Terminals
Potential New Subcategories Total
10
6
0
139
250
20
0
0
27
66
4
0
0
17
36
110
16
0
416
576
Source: TRIReleases2002 v4.
14-2
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Section 14.0 - Petroleum Refining
14.1.2 40 CFR Part 419
EPA first promulgated ELGs for the Petroleum Refining Category (40 CFR Part
419) on October 18, 1982 (47 FR 46446). There are five subcategories that all have BPT, BAT,
BCT, PSES, NSPS, and PSNS. EPA established numerical limitations for ammonia as nitrogen,
hexavalent chromium, phenolic compounds, sulfide, and total chromium in at least one
subcategory. Section 7 of the 2004 TSD provides more information on the existing regulations
for the Petroleum Refining Category (U.S. EPA, 2004).
14.2 Petroleum Refining Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Petroleum Refining
Category including the screening-level review and category-specific review.
14.2.1 Petroleum Refining Category 2005 Screening Level Review
Table 14-3 presents the Petroleum Refining Category TWPE calculated, using
TRIReleases2002_v2 and PCSLoads2002_v2. The discharges in Table 14-3 include loads from
facilities in SIC codes EPA determined are potential new subcategories.
Table 14-3. Petroleum Refining Category 2005 Screening-Level Review Results
Rank
4
Point Source Category
Petroleum Refining
2002 PCS TWPEa
166,045
2002 TRI TWPEb
503,802
Total TWPE
669,847
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
14.2.2 Petroleum Refining Category 2005 Pollutants of Concern
Table 14-4 shows the pollutants with the highest TWPE in TRIReleases2002_v2,
as well as the five pollutants with the highest TWPE in PCSLoads2002_v2.
Discharges of dioxin and dioxin-like compounds and PACs contributed
approximately 76 percent of the TWPE in TRIReleases2002_v2. Discharges of metals account
for approximately nine percent of the total TWPE in TRIReleases2002_v2. From
PCSLoads2002_v2, sulfide accounts for approximately 50 percent of the TWPE.
14-3
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Section 14.0 - Petroleum Refining
Table 14-4. 2005 Annual Review: Petroleum Refining Category Pollutants of Concern
Pollutant
Dioxin and Dioxin-
Like Compounds
PACs
Sodium Nitrite
Mercury and Mercury
Compounds
Lead and Lead
Compounds
Sulfide
Chlorine
Fluoride
Silver
Selenium
Petroleum Refining
Category Total
2002 TRT
Number of
Facilities
Reporting
Pollutant
17
61
3
68
97
Total Pounds
Released
0.011
(5.16 grams)
3,309
121,788
124
5,644
TWPE
295,598
88,473
45,468
14,465
12,643
Pollutants are not in the top five TRI 2002
reported pollutants.
352
18,512,185
503,802
2002 PCSb
Number of
Facilities
Reporting
Pollutant
Total Pounds
Released
TWPE
Pollutants are not in the top five PCS 2002
reported pollutants.
77
17
12
7
17
107
29,851
45,011
406,609
769
7,560
7,606,182,343
83,626
22,918
14,231
12,669
8,477
166,045
Source: PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include transfers to POTWs and account for POTW removals.
Discharges include only major dischargers.
14.3
Potential New Subcategories for the Petroleum Refining Category
EPA reviewed industries with SIC codes not clearly subject to existing ELGs.
EPA concluded the processes, operations, wastewaters, and pollutants of facilities in the SIC
codes listed in Table 14-5 are similar to those of the Petroleum Refining Category. See the
Preliminary 2005 Review of Prioritized Categories of Industrial Discharges (U.S. EPA, 2005b).
Table 14-5 shows the combined TWPE from TRIReleases2002_v2 and PCSLoads2002_v2 for
each SIC code that is a potential new subcategory. The discharges for the potential new
subcategory SIC codes are a negligible percentage of the total 2002 TWPE for the Petroleum
Refining Category. Consistent with the conclusions drawn during the 2004 detailed study (U.S.
EPA, 2004), EPA found that large numbers of these facilities discharge no wastewater and only a
small number of facilities discharge significant TWPE.
14-4
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Section 14.0 - Petroleum Refining
Table 14-5. Petroleum Refining Category Potential New Subcategories Pollutant TWPE
SIC Code
2992
2999
4612
5171
SIC Description
Lubricating Oils and Greases
Products of Petroleum & Coal, NEC
Crude Petroleum Pipelines
Petroleum Bulk Stations & Terminals
Total 2002 TWPE
3,836
1,915
247
1,551
Percentage of Total
Petroleum Refining
Category TWPE
0.57%
0.29%
0.04%
0.23%
Source: TRIReleases2002_v2; PCSLoads2002_v2.
14.4
Petroleum Refining 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Petroleum Refining Category. EPA obtained
additional data and identified changes in estimates of TWPE for sodium nitrite and PACs.
14.4.1
Petroleum Refining Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, EPA
revised the TWF and POTW removal values it used for sodium nitrite in the TRI and PCS
databases to better reflect the pollutant's properties. The TWF that EPA applies to sodium nitrite
is now 0.0032 (formerly 0.373), and the POTW removal is now 90 percent (formerly 1.87
percent). As discussed in Section 4.2.3, during its 2006 annual review of the Petroleum Refining
Category, EPA also revised the TWFs for two individual PACs and developed TWFs for two
additional PACs. These TWF revisions resulted in a change to the petroleum refining-specific
TWF for PACs to 26.3 (formerly 25.4). The calculation of the petroleum refining PACs TWF is
discussed in Section 4.3.1. Table 14-6 presents the loads before and after corrections to the
sodium nitrite TWF and POTW percent removal and petroleum refining-specific PACs TWF for
the Petroleum Refining Category. Based on the revised TWPE, sodium nitrite is no longer a
pollutant of concern for the Petroleum Refining Category.
Table 14-6. Impact of Changes to TWF and POTW Percent Removal for the Petroleum
Refining Category
Database
TRI 2002
TRI 2002
Pollutant
Sodium Nitrite
PACs
Number of Facilities
Reporting
Discharges
3
61
TWPE from 2005
Review
45,468
88,473
TWPE from 2006
Review
74
85,642
Sources: TRIReleases2002 v2; TRIReleases2002 v4.
14-5
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Section 14.0 - Petroleum Refining
14.4.2 Petroleum Refining Category 2006 Screening-Level Review
As a result of its 2006 screening-level review, EPA revised the TRI and PCS
rankings as described in Section 4.2, based on methodology changes described in Section 4.2 and
changes made based on contacts with facilities. For the Petroleum Refining Category, the most
significant changes are also described in Section 14.4.1. Table 14-7 shows the 2006 screening-
level TWPE estimated for the Petroleum Refining Category from the 2002 and 2003 TRI and
2002 PCS databases.
Table 14-7. Petroleum Refining Category 2006 Screening-Level Review Results
Point Source Category
Petroleum Refining
2002 PCS TWPEa
165,076
2002 TRI TWPEb
467,009
2003 TRI TWPEb
498,367
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v4.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
14.4.3 Petroleum Refining Category 2006 Pollutants of Concern
Table 14-8 presents the pollutants of concern for the Petroleum Refining Category
identified as part of the 2006 annual review.
Dioxin and dioxin-like compounds contribute approximately 63 percent of the
Petroleum Refining Category TWPE in TRIReleases2002_v4, and approximately 75 percent of
the Petroleum Refining Category TWPE in TRIReleases2003_v2. PACs discharges contribute
approximately 18 percent of the Petroleum Refining Category TWPE in TRIReleases2002_v4
and approximately 7 percent of the TWPE in TRIReleases2003_v2. The 2006 annual review of
the PCS data shows the same results as the 2005 annual review.
14.5 Petroleum Refining Category Update on Pollutants of Concern
EPA completed a detailed study of the Petroleum Refining Category for the 2004
annual review (U.S. EPA, 2004). This subsection summarizes the results of the detailed study
pollutants of concern and the discharges of these pollutants in the PCSLoads2002_v4,
TRIReleases2002 v4, and TRIReleases2003 v2 databases.
14-6
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Section 14.0 - Petroleum Refining
Table 14-8. 2006 Annual Review: Petroleum Refining Category Pollutants of Concern
Chemical
Sulfide
Chlorine
Fluoride
Silver
Selenium
Dioxin and Dioxin-Like
Compounds0
PACs
Mercury and Mercury
Compounds
Lead and Lead Compounds
Nitrate Compounds
Petroleum Refining
Category Total
PCS 2002a
Number of
Facilities
Reporting
Chemical
77
17
12
7
17
Total Pounds
29,851
45,011
406,609
769
7,560
TWPE
83,626
22,918
14,231
12,669
8,477
Pollutants are not in the top five PCS 2002
reported pollutants
118d
7,606,670,158
165,076
TRI2002b
Number of
Facilities
Reporting
Chemical
Total
Pounds
TWPE
Pollutants are not in the top five TRI
2002 reported pollutants
16
61
68
97
62
352d
0.0114
3,309
124
5,644
16,796,417
18,412,828
296,024
85,642
14,465
12,643
12,541
467,009
TRI 2003b
Number of
Facilities
Reporting
Chemical
Total
Pounds
TWPE
Pollutants are not in the top five TRI
2003 reported pollutants
18
59
66
116
61
343d
0.0123
1,291
110
9,882
15,706,670
17,314,282
374,030
32,825
12,912
22,136
11,728
498,367
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°The TWPE for dioxin and dioxin-like compounds for the 2006 annual review changed by less than 0.15 percent from the 2005 annual review due to an
additional dioxin distribution in the SIC code average dioxin distribution. There were no changes made to the reported dioxin and dioxin-like compound
discharge pounds or the individual TWFs for dioxin and dioxin-like compounds.
dNumber of facilities reporting TWPE greater than zero.
-------
Section 14.0 - Petroleum Refining
14.5.1 Petroleum Refining Category Dioxin and Dioxin-Like Compound Discharges
During its 2004 detailed study of the petroleum refining industry, EPA found the
following regarding dioxin and dioxin-like compound dischargers:
• Dioxin and dioxin-like compound discharges reported by 15 of 17
petroleum refining facilities to TRI in 2000 were either not based on
measured concentrations or were estimated using one-half the analytical
detection limit when dioxin and dioxin-like compounds were not detected.
• Catalytic reformer regeneration wastewater is the major source of dioxin
and dioxin-like compounds in petroleum refining wastewaters.
• Based on available analytical data, high concentrations of dioxin and
dioxin-like compounds, including TCDD and TCDF, may be detected in
catalytic reformer regeneration wastewater.
• Based on available analytical data, oil/water separators effectively remove
dioxin and dioxin-like compounds from petroleum refining wastewaters
prior to discharge. Because dioxin and dioxin-like compounds have a low
water solubility and extreme hydrophobicity, the dioxin and dioxin-like
compounds from catalytic regeneration wastewaters most likely partition
to the oily and solid phases in the API separator.
EPA reviewed more recent-TRI reported discharges of dioxin and dioxin-like
compounds by petroleum refineries to see if there were any new data to supplement its earlier
analyses. As was the case with the 2004 detailed study, EPA found that most petroleum
refineries do not monitor for dioxin and dioxin-like compounds. Only 17 refineries reported
dioxin and dioxin-like compounds discharges in TRIReleases2002_v4. Of these, 15 refineries
also reported dioxin and dioxin-like compounds discharges in TRIReleases2000_v4 and 14
reported such discharges in TRIReleases2003_v2. Table 14-11, at the end of this section, lists
the petroleum refineries reporting dioxin and dioxin-like compound discharges in
TRIReleases2000_v4, TRIReleases2002_v4, and TRIReleases2003_v2, their reported discharges,
the basis of estimate for the discharge, whether the facility detected dioxin and dioxin-like
compounds in its wastewater, and any additional information collected.
The majority of the reported dioxin and dioxin-like compound discharge loads are
estimated as flow multiplied by one-half of the detection limit or using industry-derived emission
factors. Only 3 of the 17 dioxin and dioxin-like compound discharges reported for 2002 are
based on analytical data with measurements above the sample detection limit. EPA also
identified two petroleum refineries that reported dioxin and dioxin-like compound discharges
based on analytical measurements to TRI in 2003, but did not report dioxin and dioxin-like
compound discharges to TRI in 2000 or 2002. EPA contacted these refineries to determine how
they estimated their dioxin and dioxin-like compound discharges. Table 14-9 summarizes the
information EPA collected from these five petroleum refineries.
14-8
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Section 14.0 - Petroleum Refining
Table 14-9. Petroleum Refineries that Based Dioxin and Dioxin-Like Compound Discharges on Analytical Measurement Data
Facility
Location
2006 Review
TWPE
Review
Findings
BP Toledo
Oregon, OH
54,100
2004
Detailed
Study
Facility sampled its effluent once in September 2000. The facility detected nine dioxin
congeners, including the most toxic form, 2,3,7,8-TCDD; however, no dioxin and
dioxin-like compounds were detected above the Method 1613B minimum level
(Nelson, 2004).
Tesoro
Northwest
Anacortes, WA
47,000
2004
Detailed
Study
Facility measured its effluent four times between 2000 and 2001, and each sample was
analyzed by two independent analytical laboratories. The facility detected between 6
and 14 dioxin congeners in its final effluent, several of which were detected below the
Method 1613B minimum level. The most toxic congener, 2,3,7,8-TCDD, was detected
by one laboratory for one of the samples (Spurling, 2005).
Conoco Phillips
Wilmington, CA
9,020
2005
Annual
Review
Facility measured discharges from the catalytic reformer regeneration unit in 1992 and
detected all 17 dioxin congeners. The facility sends the catalytic reformer regeneration
waste through a wastewater treatment plant and the treated wastewater discharges to a
POTW (Hamann, 2005).
Shell Chemical
Company
Deer Park, TX
14,600
2006
Annual
Review
Facility has not independently analyzed its wastewaters for dioxin and dioxin-like
compounds; however, in 2003 the Texas Commission on Environmental Quality
(TCEQ), as part of a total maximum daily load program along the Houston Ship
Channel, collected and measured the facility's refinery effluent. The TCEQ analyzed
the dioxin and dioxin-like compounds in the particle-bound fraction and the dissolved
fraction of the refinery effluent. The TCEQ detected six dioxin and dioxin-like
compounds in the particle-bound fraction and 16 dioxin and dioxin-like compounds in
the dissolved fraction, but none were detected above the Method 1613B minimum
level. The most toxic congener, 2,3,7,8-TCDD, was not detected in either fraction
(Brzuzy, 2006).
Tesoro Alaska
Kenai, AK
46
2006
Annual
Review
Facility measured discharges in 2001 and 2003 from its catalytic reformer regeneration
unit after the wastewater passed through a granulated activated carbon filter, but before
the API separators and other wastewater treatment. In 2001, the facility detected 13
dioxin and dioxin-like compounds above the Method 1613B minimum level. The
facility sampled the wastewater again in 2003, and did not detect any of the dioxin and
dioxin-like compounds above the Method 1613B minimum level (Rosin, 2006).
-------
Section 14.0 - Petroleum Refining
Two of the facilities identified in Table 14-9, were analyzed and discussed in the
2004 detailed study. For a complete discussion of EPA's review and conclusions for the BP
Toledo and the Tesoro Northwest facilities, see the 2004 Technical Support Document (U.S.
EPA, 2004). The new information obtained from the other three petroleum refineries supports
the conclusions drawn during the 2004 detailed study. Two of the three facilities based their
final effluent dioxin discharges on analytical data collected of catalytic reformer regeneration
wastewater prior to on-site treatment. The third facility did not detect any dioxin congeners
above the method 1613B minimum level.
14.5.2 Petroleum Refining Category Polycyclic Aromatic Compounds (PACs)
Discharges
During its 2004 detailed study of the Petroleum Refining Category, EPA found
the following regarding PACs dischargers:
• Discharges of PACs reported by 18 of 19 petroleum refineries to TRI in
2000 were either not based on measured concentrations in refinery effluent
or were estimated using one-half the analytical detection limit when
individual PACs were not detected.
• There is no obvious source of PACs releases to refinery wastewaters, other
than potential leaks and spills of crude oil and petroleum products.
• Based on available analytical data, there is little evidence that PACs are
present in concentrations above the detection limit in petroleum refinery
wastewater discharges.
EPA reviewed more recent TRI-reported discharges of PACs by petroleum
refineries to see if there were any new data to supplement its earlier analyses. As was the case
with the 2004 detailed study, EPA found that most petroleum refineries do not monitor for
individual PACs. Thirty-nine refineries reported PACs discharges in TRIReleases2002_v4 or
TRIReleases 2003v2. Of these, 19 refineries reported PACs discharges in TRIReleases2000_v4,
and 34 reported such discharges in TRIReleases2003_v2. Table 14-12, at the end of this section,
lists the petroleum refineries reporting PACs discharges in TRIReleases2000_v4,
TRIReleases2002 v4, or TRIReleases2003_v2, the reported discharges, the basis of estimate for
the discharge, and any additional information collected.
The majority of the reported PACs discharge loads are estimated as flow
multiplied by one-half the detection limit, or using industry-derived emission factors. During the
2004 detailed study, EPA verified that only one facility measured PACs in its refinery effluent
above the method detection level. In the 2005 annual review, EPA verified an additional facility
measured PACs in its refinery effluent above the method detection level. In this 2006 annual
review, EPA verified one additional refinery measured PACs in their effluent above the method
detection level. Therefore, EPA verified that 3 of the 39 PACs discharges reported for 2002 or
2003 are based on analytical data with measurements above the method detection limit. Table
14-10 summarizes the information that EPA has collected from these three facilities.
14-10
-------
Section 14.0 - Petroleum Refining
Table 14-10. Petroleum Refineries that have Detected PACs in Refinery Effluent
Facility
Lyondell
Citgo
Marathon
Ashland
Premcor
Refining
Group
Location
Houston,
TX
Detroit,
MI
Delaware
City, DE
2006
Review
TWPE
3,930
172
81
Review
2004
Detailed
Study
2005
Annual
Review
2006
Annual
Review
Findings
Facility measured five individual PACs above the method
detection limits in its discharge to the Washburn Tunnel
Facility (part of Gulf Coast Waste Disposal Authority);
however, PACs were not detected in the Washburn Tunnel
Facility's discharge to surface water (U.S. EPA, 2004). Gulf
Coast is an industrial POTW designed to treat industrial
discharges without on-site pretreatment.
Facility measured five individual PACs above the method
detection limits in its discharge to the Detroit Wastewater
Treatment Plant (Sheard, 2005). EPA was unable to
determine if the Detroit Wastewater Treatment Plant
measured PACs in its discharge to surface water.
Facility routinely measured its wastewater treatment plant
effluent for PACs from 1999 through 2003. During 2002
and 2003, the facility detected eight individual PACs above
the method detection limits; however, not all of the eight
PACs were detected during each sampling event. The
facility's wastewater treatment plant consists of Coalescing
Plate Interceptor (CPI) and API separators, spill diversion
tanks, equalization tanks, dissolved nitrogen floatation tanks,
two-stage aeration tanks, biotreatment tanks, clarifier tanks,
sand filtration, guard basin, and a final API separator prior to
discharge (Chelpaty, 2006).
The information collected during this 2006 review supports the conclusions drawn
during the 2004 detailed study. EPA determined that most of the PACs discharges reported to
TRI are not based on analytical data. EPA did verify that three facilities have detected PACs in
their refinery effluent; however, this is out of the 163 petroleum refineries that report to TRI. Of
these three facilities, two discharge indirectly to POTWs and receive additional treatment prior to
discharge to surface waters. PAC discharges from the third facility represent 81 TWPE. At this
time, EPA has not identified a source of PACs other than potential leaks and spills of crude oil or
petroleum products.
14.5.3
Petroleum Refining Category Metals Discharges
During its 2004 detailed study of the Petroleum Refining Category, EPA found
the following regarding metals discharges:
• 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 crude depends on the source of the crude.
14-11
-------
Section 14.0 - Petroleum Refining
• The concentration of metal pollutants in refinery wastewaters is at or near
treatable level, leaving little to no opportunity to reduce metals discharges
through conventional end-of-pipe treatment.
For petroleum refineries, the metals TWPE in TRIReleases2003_v2 increased by
38 percent compared to discharges in TRIReleases2002_v4. The three metal pollutants with the
largest TWPE increases are lead, copper, and cadmium, as discussed below:
• Cadmium. Increase of 5000 percent attributed to a single facility,
Sinclair Oil Tulsa Refinery, Tulsa, OK, which reports cadmium discharges
as a range. The range increased from 1 - 10 Ibs to 11 - 500 Ibs. For
database purposes, the discharge increased from 5 to 250 pounds (the
median values of the ranges).
• Lead. Increase is attributed to a single facility, Chalmette Refining LLC,
Chalmette, LA, which increased its reported lead discharge from 16 to
4,992 pounds. EPA is in the process of contacting this facility for
additional information.
• Copper. Increase is attributed to a single facility, Chalmette Refining
LLC, Chalmette, LA, which increased its copper discharge from 32 to
7,603 pounds. EPA is in the process of contacting this facility for
additional information.
Discharges of other metals reported in TRI by petroleum refineries, in terms of
pounds and TWPE, were consistent with the discharges in the 2004 detailed study.
Silver discharges from petroleum refineries reporting to PCSLoads2002_v2
represent the fourth largest pollutant discharge in terms of TWPE. Silver is not currently
regulated under the petroleum refining ELGs, and therefore refineries only monitor for silver if
their permit contains state or water-quality-based limits. PCSLoads2002_v2 shows silver
discharges from seven facilities, for a total of 769 pounds. One facility, Premcor Refining Group
in Port Arthur, TX, was responsible for approximately 98 percent (752 pounds) of the category's
silver discharges. EPA contacted the Premcor Refining Group (now Valero Energy Corporation)
requesting clarification of the reported silver discharge and the source of silver in wastewater.
EPA determined that most of the times the facility analyzed its final effluent for silver, the metal
was not detected above the sample detection limit (0.02 mg/L). The facility stated that since
January 1, 2003, silver was only detected in 2 of 174 analyses (Hughes, 2006).
EPA determined that the conclusions drawn during the 2004 detailed study still
apply because the discharges for most metals did not change from the 2004 detailed study to the
2006 annual review, and for those metals that did change, the change can be attributed to one
facility. Therefore, EPA concludes that metals may be present in petroleum refining
wastewaters, but their concentrations are at or near treatable levels, leaving little to no
opportunity to reduce metals discharges through conventional end-of-pipe treatment.
14-12
-------
Section 14.0 - Petroleum Refining
14.5.4 Petroleum Refining Category Sulfide Discharges
During its 2004 detailed study of the Petroleum Refining Category, EPA found
the following regarding sulfide discharges:
• Based on available analytical data, petroleum refineries are achieving final
effluent concentrations less than baseline values and less than existing
limits at 40 CFR Part 419; and
• Refineries are treating sulfide to concentrations at or near treatable levels.
Sulfide is currently regulated under the existing petroleum refining ELGs, and
therefore, is monitored and reported for many facilities in PCSLoads2002_v4. In 2002, sulfide
was reported by 77 of the 107 major dischargers reporting to PCS. The amount of sulfide
discharged decreased from PCSLoads2000 v6 to PCSLoads2002_v4 by approximately 17
percent; however, the number of facilities reporting discharges of sulfide increased by 10
percent.
EPA determined that the conclusions drawn during the 2004 detailed study still
apply because the amount of sulfide discharged decreased from the 2004 detailed study to the
2006 annual review. Therefore, EPA continues to find that petroleum refineries are achieving
final sulfide concentrations less than baseline values and less than existing 40 CFR Part 419
limits.
14.5.5 Petroleum Refining Category Pollution Control Technologies
During the 2004 detailed study of the petroleum refining industry, EPA
investigated treatment technologies for the control of dioxin and dioxin-like compounds, PACs,
and sulfide. For more information about these control technologies, see the 2004 Technical
Support Document (U.S. EPA, 2004). During the 2006 annual review, EPA did not identify any
new control technologies in use for dioxin and dioxin-like compounds, PACs, metals, or sulfide
in petroleum refinery wastewater. As new treatment technologies and/or pollution prevention
methods become available, EPA will evaluate their treatment effectiveness compared with
current pollutant discharges from petroleum refiners.
14.6 Petroleum Refining Category Conclusions
• EPA previously determined that dioxin and dioxin-like compounds are
produced during catalytic reforming and catalyst regeneration operations
at petroleum refineries. Of the 163 identified U.S. petroleum refineries,
17 report discharges of dioxin and dioxin-like compounds to TRI. Of the
17 refineries reporting discharges in 2002, only five reported dioxin
discharges based on analytical measurements. Only two of these facilities
detected dioxin and dioxin-like compounds above the Method 1613B
minimum level and both of these facilities measured dioxin at the point
immediately following catalytic regeneration and prior to wastewater
treatment.
14-13
-------
Section 14.0 - Petroleum Refining
• Petroleum refineries report PACs discharges to TRI; however, these
discharges are either based on one-half the detection limit multiplied by
the flow or are estimated using emission factors. Out of 39 dischargers
that reported PACs, EPA has verified only three petroleum refineries that
measured PACs in their final effluent. Of these, two discharge indirectly
to POTWs and receive additional treatment prior to discharge to surface
waters and the third reported PAC discharges representing 81 TWPE.
Therefore, there is little evidence that PACs are being discharged to
surface waters in concentrations above the detection limit.
• Sulfide discharges are currently regulated by 40 CFR 419, and facilities
are achieving final effluent concentrations less than baseline values and
less than the existing limits.
• Metals may be present in petroleum refining wastewaters, but their
concentrations are at or near treatable levels, leaving little to no
opportunity to reduce metal discharges through conventional end-of-pipe
treatment.
14.7 Petroleum Refining References
Beener, David. 2005. Telephone conversation with David Beener of ExxonMobil Joliet
Refinery, Channahon, IL, and TJ Finseth of Eastern Research Group, Inc. "ExxonMobil Joliet
Dioxin Discharges in TRI 2002." (June 2). DCN 01905.
Bennett, Toni. 2005. Telephone conversation with Toni Bennett of Calcasieu, Lake Charles,
LA, and TJ Finseth of Eastern Research Group, Inc. "Calcasieu PACs Discharges in TRI 2002."
(May 31). DCN 01908.
Brzuzy, Louis. 2006. Telephone conversation with Louis Brzuzy of Shell, Deer Park, TX, and
TJ Finseth of Eastern Research Group, Inc. "Shell Deer Park Refinery Dioxin and Dioxin-Like
Compound Discharges." (August 30). DCN 03772.
Chelpaty, Heather. 2006. Telephone conversation with Heather Chelpaty of Valero, Delaware
City, DE, and TJ Finseth of Eastern Research Group, Inc. "Valero Delaware City Refinery
Dioxin and Dioxin-Like Compounds and PACs Discharges." (August 7). DCN 03771.
GCA. Unknown. Gulf Coast Waste Disposal Authority. 2003 Peak Performance Award
Application. DCN 04078.
Golden, Jan. 2005. Telephone conversation with Jan Golden of Flint Hills Resources, Corpus
Christi, TX, and TJ Finseth of Eastern Research Group, Inc. "Flint Hills PACs Discharges in
TRI 2002." (May 23). DCN 01904.
14-14
-------
Section 14.0 - Petroleum Refining
Hamann, Ernie, et al. 2005. Telephone conversation with Ernie Hamann and Brian Christlieb of
Conoco Phillips, Wilmington, CA, and TJ Finseth of Eastern Research Group, Inc. "Dioxin
Releases from Conoco Phillips Wilmington, CA to TRI 2002." (June 13). DCN 01906.
Hughes, Steve. 2006. Telephone conversation with Steve Hughes of Valero, Port Arthur, TX,
and TJ Finseth of Eastern Research Group, Inc. "Valero Port Arthur Refinery Silver, Mercury,
and Lead Discharges." (July 12). DCN 03770.
Marton, Reed. 2005. Telephone conversation with Reed Marton of Conoco Phillips Lake
Charles Refinery, Westlake, LA, and TJ Finseth of Eastern Research Group, Inc. "Conoco
Phillips Dioxin and PACs Discharges in TRI 2002 and Sulfide Discharge in PCS 2002." (May
20). DCN 01907.
Nelson, Jim, et al. 2004. Telephone conversation with Jim Nelson of BP Oil Co., Roger Claff of
American Petroleum Institute, Jan Matuszko of U.S. EPA/EAD, and Jill Lucy of Eastern
Research Group, Inc. "Dioxin Discharges from BP Oil Company's Toledo Refinery." (July 26).
DCN 01172.
Pierce, D.W. 2005. Letter to TJ. Finseth, Eastern Research Group, Inc., from D.W. Pierce,
Chevron. "Chevron Dioxin and PACs Wastewater Discharges." (July 22). DCN 01924.
Rosin, Scott. 2006. Telephone conversation with Scott Rosin of Tesoro, Kenai, AK, and TJ
Finseth of Eastern Research Group, Inc. "Dioxin and PAC Discharges Reported to TRI from
Tesoro Alaska." (September 7). DCN 03773.
Sheard, Honor. 2005. Telephone conversation with Honor Sheard of Marathon Ashland,
Detroit, MI, and TJ Finseth of Eastern Research Group, Inc. "Marathon Ashland, Detroit, MI,
Dioxin and PACs Discharges." (Februarys). DCN 01545.
Spurling, Rebecca. 2005. Telephone conversation with Rebecca Spurling of Tesoro Northwest
Co., Anacortes, WA, and TJ Finseth of Eastern Research Group, Inc. "Tesoro Northwest Dioxin
Discharges in TRI 2002." (June 29). DCN 01957.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
14-15
-------
Section 14.0 - Petroleum Refining
Zipf, Lynn. 2004. U.S. EPA. Memorandum to 304(m) Record, EPA Docket Number OW-
2004-0074 from Lynn Zipf, EPA and Jan Matuszko, EPA. "Revisions to TWFs for Dioxin and
its Congeners and Recalculated TWPEs for OCPSF and Petroleum Refining." (August 10).
DCN01166.
14-16
-------
Section 14.0 - Petroleum Refining
Table 14-11. 2000, 2002, and 2003 Dioxin Discharges Reported to TRI by Petroleum Refineries
TRI ID
98221SHLLLWESTM
77590MRTHNFOOTO
70669CNCLKOLDSP
94802CHVRN841ST
90245CHVRN324WE
43616SHLCM4001C
07036XXN 1400P
74603CNCPN1000S
59101CNCBL401SO
08066MBLLCBILLI
00851HSSLVLIMET
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
Bayway Refining Co.
Conoco Inc. Ponca
City Refinery
Conoco Inc. Billings
Refinery
Valero Refining Co.
New Jersey
Hovensa LLC
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
2000 TRI
Grams3
5.20
2
0.54
0.34
0.33
0.286
0.254
0.181
0.162
0.09
0.0693
TWPE"
97,100
272,00
73,400
45,600
30,100
53,200
63,700
24,627
22,000
12,300
9,440
Basis of
Estimate0
M
O
E
O
M
M
M
O
O
O
c
2002 TRI
Grams3
1.63
0.00435
0.539
0.76
0.109
0.36
0.25
0.445
NR
0.088
0.0335
TWPE"
45,500
301
48,600
19,200
11,200
51,200
5,230
30,800
NR
6,100
2,320
Basis of
Estimate0
M
O
O
O
M
M
M
O
NR
O
C
2003 TRI
Grams3
1.70
NR
0.539
0.682
0.344
0.38
NR
0.283
NR
0.088
1.10
TWPE"
47,000
NR
48,600
36,800
35,300
54,100
NR
21,900
NR
6,810
85,200
Basis of
Estimate0
M
NR
O
O
M
M
NR
O
NR
O
C
Did Facility
and Dioxin-
like
Compounds
at Any
Level?
Yes
No
No
No
No
Yes
No
No
No
No
No
Information Collected by EPA on
Dioxin Releases Reported to TRI
in 2000, 2002, and 2003
Facility collected two samples of
final effluent in both 2000 and
2001. Several congeners detected
above the detection limit
(Spurling, 2005).
Because 2002/2003 reported dioxin
discharges are small relative to other
facilities, EPA has not contacted this
facility.
Estimate is based on emission
factors (Marlon, 2005).
Estimate is based on detection limit.
Two samples were analyzed (no
results above sample detection limit)
(U.S. EPA, 2004).
Wastewater effluent was analyzed
for dioxins in 2002. None of the
congeners were detected above the
sample detection limit. Estimate
based on one-half the detection limit
(Pierce, 2005).
One set of samples was collected
and analyzed: 9 congeners were
above the detection limit (Nelson,
2004).
Based on one-half the detection
limit. Treated effluent samples are
all not detected (U.S. EPA, 2004).
Discharge was estimated using non-
refinery-specific data for dioxin in
petroleum products (U.S. EPA,
2004).
Discharge was estimated using non-
refinery-specific data for dioxin in
petroleum products (U.S. EPA,
2004).
Facility reported wastewater release
for 2000 should be 0.0002 grams
(U.S. EPA, 2004).
Estimate based on EPA discharge
factors (U.S. EPA, 2004).
-------
Section 14.0 - Petroleum Refining
Table 14-11 (Continued)
TRIID
80022CNCDN5801B
39567CHVRNPOBOX
62454MRTHNMARAT
00654PHLPSPHILI
70602CTGPTHIGHW
79905CHVRN6501T
90748NCLLS1660W
60434MBLJL INTER
19706TXCDL2000W
77536DRPRK5900H
Refinery
Conoco Denver
Refinery
Chevron Prods. Co.
Pascagoula Refinery
Marathon Ashland
Petroleum LLC
Chevron Phillips
Chemical Puerto Rico
Citgo Petroleum Corp
Chevron USA El Paso
Refinery
Conoco Phillips Co.
La Refinery
Wilmington Plant
ExxonMobil Oil
Corp. Joliet Refinery.
Premcor Refining
Group Inc Delaware
City Refinery
Shell Chemical
Company Deer Park
Location
Denver, CO
Pascagoula,
MS
Robinson, IL
Guayama, PR
Lake Charles,
LA
El Paso, TX
Wilmington,
CA
Channahon, IL
Delaware City,
DE
Deer Park,
TX
2000 TRI
Gramsa
0.06
0.035
0.03
0.00218
0.0016
0.0187
0.320
NR
NR
NR
TWPE"
8,170
4,770
4,080
297
218
2,550
-
NR
NR
NR
Basis of
Estimate0
O
O
O
E
E
O
M
NR
NR
NR
2002 TRI
Gramsa
0.0950
0.086
0.04
NR
0.00257
NR
0.28
0.434
NR
NR
TWPE"
6,580
3,680
2,780
NR
178
NR
22,300
39,600
NR
NR
Basis of
Estimate0
E
O
O
NR
E
NR
M
O
NR
NR
2003 TRI
Grams'1
0.074
0.099
0.0404
0.00596
0.00257
NR
0.0884
0.0007
0.022
0.152
TWPE"
5,730
4,230
3,130
461
199
NR
9,020
64
559
14,600
Basis of
Estimate0
E
O
O
E
E
NR
M
O
O
O
Did Facility
Detect Dioxin
and Dioxin-
like
Compounds
at Any
Level?
No
No
No
No
No
No
Yes
No
No
Yes
Information Collected by EPA on
Dioxin Releases Reported to TRI
in 2000, 2002, and 2003
Based on internally generated
emission factors per corporate policy
(U.S. EPA, 2004).
Facility used monitoring data
collected in 2001 from the catalytic
reformer units to develop an
emission factor (Pierce, 2005).
Because 2002/2003 reported dioxm
discharges are small relative to other
facilities, EPA has not contacted this
facility.
Because 2002/2003 reported dioxin
discharges are small relative to other
facilities, EPA has not contacted this
facility.
Based on EPA discharge factors
(U.S. EPA, 2004).
Based on one-half the detection limit
(U.S. EPA, 2004).
Facility used monitoring data
collected from catalytic reformer
discharge after regeneration.
Facility detected all 17 congeners
(Hamann, 2005).
For 2002, facility had monitoring
data reporting TCDD as not
detected. Discharge estimated based
on one-half detection limit (Beener,
2005).
Facility estimated discharge based
on dioxin and dioxin-like compound
measurements from the co-located
power plant, not from refinery
wastewaters (Chelpaty, 2006).
TCEQ analyzed effluent for dioxin
and dioxin-like compounds and
detected six congeners in the
particle-bound fraction and 16
congeners in the dissolved
fraction. TCDD was not detected
in either fraction (Brzuzy, 2006).
oo
-------
Section 14.0 - Petroleum Refining
Table 14-11 (Continued)
TRI ID
99611TSRLSMILE2
Refinery
Tesoro Alaska -
Kenai Refinery
Location
Kenai, AK
2000 TRI
Gramsa
NR
TWPE"
NR
Basis of
Estimate0
NR
2002 TRI
Gramsa
NR
TWPE"
NR
Basis of
Estimate0
NR
2003 TRI
Gramsa
0.0006
TWPE"
46
Basis of
Estimate0
M
Did Facility
Detect Dioxin
and Dioxin-
like
Compounds
at Any
Level?
Yes
Information Collected by EPA on
Dioxin Releases Reported to TRI
in 2000, 2002, and 2003
Facility used monitoring data
collected from catalytic reformer
discharge after regeneration in
2003. Facility detected 5
congeners; however, none were
detected above the Method 1613B
minimum level (Rosin, 2006).
Refineries Not in EPA's Analysis: No Discharge of Dioxins
48217MRTHN1300S
Marathon Ashland
Petroleum LLC
Detroit, MI
8.06
0
NA"
8.06
0
O
-
-
-
No
Incorrect number reported for 2000
and 2002: should be zero discharge.
Refinery submitted TRI correction
form (Sheard, 2005).
Source: TRIReleases2003_v2; TRIReleases2002_v4; Memorandum: Revisions to TWFs for Dioxin and its Congeners and Recalculated TWPEs for OCPSF and Petroleum Refining (Zipf, 2004).
NR - Not Reported.
"For indirect discharges, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 83% removal of dioxin and dioxin-like compounds by the
POTW.
bThe TWPEs in this table were calculated using the 2006 TWFs (the 2006 dioxin and dioxin-like compound TWFs did not change from the August or December 2004 TWFs).
'Refineries reported basis of estimate in TRI as: M - Monitoring data/measurements; C - Mass balance calculations; E - Published emission factors; and O - Other approaches (e.g., engineering calculations).
''No basis of estimate was reported.
Note: Bolded lines indicate facilities that measured for and detected dioxin and dioxin-like compounds.
-------
Section 14.0 - Petroleum Refining
Table 14-12. 2000, 2002, and 2003 PACs Discharges Reported to TRI by Petroleum Refineries
TRI ID
77592TXSCTLOOP1
94572NCLSNOLDHI
70037LLNCRHIGHW
70669CNCLKOLDSP
96707CHVRN91480
99611TSRLSMILE2
39567CHVRNPOBOX
62454MRTHNMARAT
62084SHLLLRTE11
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
Location
Texas City,
TX
Rodeo, CA
Belle Chasse,
LA
Westlake, LA
Kapolei, HI
Kenai, AK
Pascagoula,
MS
Robinson, IL
Roxana, IL
2000 TRI
Pounds"
64
57
40
22
20
19
17
15
10
TWPE"
14,800
13,100
9,220
5,069
4,610
4,380
3,920
3,460
2,300
Basis of
Estimate'
M
M
O
O
M
O
O
O
0
2002 TRI
Pounds"
69
8
31
31
277
19
110
21
9
TWPE"
1,810
210
815
815
7,280
497
2,890
552
234
Basis of
Estimate'
M
M
M
O
M
O
O
O
0
2003 TRI
Pounds"
NR
NR
34.9
51
261
18.9
115
1
10
TWPE6
NR
NR
887
1,300
6,630
480
2,920
25
254
Basis of
Estimate'
NR
NR
M
O
M
O
O
O
0
Information Collected by
EPA on 2000, 2002, and
2003 PAC Discharge
Estimates
Estimate based on one-half
the detection limit. Qne
sample contained PACs
(U.S. EPA, 2004).
Estimate based on one-half
the detection limit (U.S.
EPA, 2004).
Estimate based on one-half
the detection limit (U.S.
EPA, 2004).
Estimate based on
emission factors (Marlon,
2005).
Estimate based on one-half
the detection limit.
Individual PACs sampled
from 2000 NPDES permit
renewal were all nondetect
(Pierce, 2005).
Facility measured eight
PACs in the refinery
effluent in October 2000.
However, none of the eight
individual PACs were
measured above the
method detection limit
(Rosin, 2006).
Estimates based on EPA's
BAT effluent guidelines
estimate for PACs (Pierce,
2005).
Because the facility reports
the basis of estimate as
"other", EPA has not
contacted this facility.
Estimate based on one-half
the detection limit (U.S.
EPA, 2004).
-------
Section 14.0 - Petroleum Refining
Table 14-12 (Continued)
TRIID
74603CNCPN1000S
84116CHVRN2351N
80022CNCDN5801B
70047TRNSM14902
90744TXCRF2101E
77017LYNDL12000
77506CRWNC111RE
48217MRTHN1300S
79905CHVRN6501T
70606CLCSRWESTE
Refinery
Conoco Inc. Ponca
City Refinery
Chevron USA Prods.
Co
Conoco Denver
Refinery
Orion Refining Corp.
Equilon Enterprises
LLC Los Angeles
Refining
Lyondell-Citgo
Refining L.P.
Crown Central
Petroleum Corp.
Houston Refinery
Marathon Ashland
Petroleum L.L.C.
Chevron USA El Paso
Refinery
Calcasieu
Location
Ponca City,
OK
Salt Lake City,
UT
Commerce
City, CO
New Sarpy,
LA
Wilmington,
CA
Houston, TX
Pasadena, TX
Detroit, MI
El Paso, TX
Lake Charles,
LA
2000 TRI
Pounds"
9
8
5
4
3
175
7
6
4
l.l8
TWPE"
2,070
1,840
1,150
922
732
40,400
1,650
1,370
933
Basis of
Estimate'
0
O
o
c
0
NAf
NAf
NAf
NAf
M
2002 TRI
Pounds"
8
59
9
9
3
163
5
7
2
191
TWPE"
210
1,550
237
237
83
4,290
121
180
46
5,020
Basis of
Estimate'
0
M
O
O
NAf
M
NAf
NAf
NAf
O
2003 TRI
Pounds"
8
59
53
9
0.957
154
NR
6.75
NR
182
TWPE6
203
1,500
1,350
229
24
3,930
NR
172
NR
4,630
Basis of
Estimate'
0
M
O
O
M
O
NR
M
NR
O
Information Collected by
EPA on 2000, 2002, and
2003 PAC Discharge
Estimates
Refinery estimated
discharge using API data
for PACs in petroleum
products (U.S. EPA,
2004).
EPA has not contacted this
facility.
Estimate based on
internally generated
emission factors (U.S.
EPA, 2004).
Estimate based on one-half
the detection limit (U.S.
EPA, 2004).
Because 2002/2003
reported PACs discharges
are small relative to other
facilities, EPA has not
contacted this facility.
Indirect discharger -
PACs were detected in
refinery effluent, but
were not detected in the
POTW effluent (the Gulf
Coast Waste Authority)
(GCA).
Indirect discharger - PACs
were not detected in the
POTW effluent (U.S.
EPA, 2004).
Facility detected five
PACs in final effluent
(Sheard, 2005).
Estimate based on one-half
the detection limit (U.S.
EPA, 2004).
Estimate based on
emission factors (Bennett,
2005).
-------
Section 14.0 - Petroleum Refining
Table 14-12 (Continued)
TRIID
67042TXCRF1401S
00851HSSLVLIMET
78410KCHRFSUNTI
90245CHVRN324WE
19706TXCDL2000W
77590MRTHNFOOTO
70750HLLPTHWY10
74107SNCLR902W2
94802CHVRN841ST
73098KRRMC906SO
Refinery
Frontier
Hovensa L.L.C.
Flint Hills Resources
L.P. West Plant
Chevron USA Inc.
Chevron Prods. Co.
Div.
Premcor Refining
Group
Marathon Ashland
Petroleum L.L.C.
Valero Refining Co.
Louisiana
Sinclair Oil Corp.
Tulsa Refinery.
Chevron Prods. Co.
Richmond Refinery.
Wynnewood Refining
Co.
Location
El Dorado, KS
Christiansted,
VI
Corpus
Christi, TX
El Segundo,
CA
Delaware
City, DE
Texas City,
TX
Krotz Springs,
LA
Tulsa, OK
Richmond, CA
Wynnewood,
OK
2000 TRI
Pounds"
l.l8
2
NR
NR
NR
NR
NR
NR
NR
NR
TWPE"
461
NR
NR
NR
NR
NR
NR
NR
NR
Basis of
Estimate'
0
NAf
NR
NR
NR
NR
NR
NR
NR
NR
2002 TRI
Pounds"
1
NR
1,770
287
1.4
93
19
17
14
10
TWPE"
26
NR
46,500
7,530
37
2,450
499
452
363
263
Basis of
Estimate'
0
NR
M
M
O
M
0
M
M
O
2003 TRI
Pounds"
0.7
NR
8
117
3.2
30.2
19
17.7
14.8
10
TWPE6
18
NR
203
2,970
81
768
483
450
376
254
Basis of
Estimate'
0
NR
M
M
O
M
0
M
M
O
Information Collected by
EPA on 2000, 2002, and
2003 PAC Discharge
Estimates
Not in
TRIReleases2000_v4: 1.1
Ib/yr discharge PACs
based on discharges at
similar refinery reported to
TRI (U.S. EPA, 2004).
Discharge from accidental
spill; monitoring data
indicate zero discharge of
PACs (U.S. EPA, 2004).
Estimate based on one-half
the detection limit.
Facility did not detect any
PACs in final effluent
(Golden, 2005).
In 2002, facility analyzed
wastewater for seven
PACs: all were nondetect.
Estimate based on EPA's
BAT effluent guidelines
estimate for PACs (Pierce,
2005).
In 2002 and 2003, the
facility detected eight
individual PACs in the
refinery effluent from
wastewater treatment
(Chelpaty, 2006).
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
-------
Section 14.0 - Petroleum Refining
Table 14-12 (Continued)
TRIID
59101CNCBL401SO
70723TXCRFFOOTO
79905LPSRF6500T
94553TSCCRAVONR
98221PGTSN600ST
82701WYMNG740WE
08861CHVRN1200S
93420NCLSN2555W
19061BPLCMPOSTR
93307KRNLRRR677
42501THSMR501RE
36611BLCHRVIADU
46394MCLC2815I
70051MRTHNHWY61
70143TNNCL500WE
Refinery
Conoco Phillips
Billings Refinery.
Convent Refinery.
Western Refining Co.
El Paso Refinery.
Tesoro Refining &
Marketing Co.
Shell Oil Prods. U.S.
Puget Sound Refinery.
Wyoming Refining
Co.
Chevron Prods. Co.
Conoco Phillips Santa
Maria Facility
Conoco Phillips Co.
Trainer Refinery.
Kern Oil & Refining
Co.
Somerset Refinery.
Inc.
Trigeant Ep Ltd
BP Products North
America Whiting
Business Unit
Marathon Ashland
Petroleum LLC
Chalmette Refining
LLC
Location
Billings, MT
Convent, LA
El Paso, TX
Martinez, CA
Anacortes,
WA
Newcastle,
WY
Perth Amboy,
NJ
Arroyo
Grande, CA
Trainer, PA
Bakersfield,
CA
Somerset, KY
Chickasaw,
AL
Whiting, IN
Garyville, LA
Chalmette, LA
2000 TRI
Pounds"
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
TWPE"
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Basis of
Estimate'
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
2002 TRI
Pounds"
8
2
2
1.3
1.1
1.1
0.8
0.8
0.4
0.02
0.01
NR
NR
NR
NR
TWPE"
210
61
47
34
28
28
21
21
11
1
0
NR
NR
NR
NR
Basis of
Estimate'
M
0
NAf
M
0
E
0
0
o
NAf
M
NR
NR
NR
NR
2003 TRI
Pounds"
0.4
2
4.01
0.6
0.9
-
0.6
2
0.2
0.0206
0.08
0.000662
1
5
11
TWPE6
10
51
102
15
23
-
15
51
5.08
0.52
2.03
0.017
25
127
280
Basis of
Estimate'
M
0
0
M
0
-
0
0
o
M
M
C
O
C
0
Information Collected by
EPA on 2000, 2002, and
2003 PAC Discharge
Estimates
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
EPA has not contacted this
facility.
-------
Section 14.0 - Petroleum Refining
Table 14-12 (Continued)
TRIID
78408STHWS1700N
Refinery
Flint Hills Resources
L.P. East Plant
Location
Corpus
Christi, TX
2000 TRI
Pounds"
NR
TWPE"
NR
Basis of
Estimate'
NR
2002 TRI
Pounds"
NR
TWPE"
NR
Basis of
Estimate'
NR
2003 TRI
Pounds"
1
TWPE6
25
Basis of
Estimate'
M
Information Collected by
EPA on 2000, 2002, and
2003 PAC Discharge
Estimates
EPA has not contacted this
facility.
Source: TRIReleases2003_v2; TRIReleases2002_v4; TRIReleases2000_v4.
NR - Not Reported.
"For indirect dischargers, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 92.64% removal of PACs by the POTW.
bThe 2000 TWPE was calculated using the August 2004 TWFs.
'Refineries reported basis of estimate in TRI as: M - Monitoring data/measurements; C - Mass balance calculations; E - Published emission factors; and O - Other approaches (e.g., engineering calculations).
dThe 2002 TWPE was calculated using the December 2004 TWFs.
'The 2003 TWPE was calculated using the April 2006 TWFs.
fNo basis of estimate was reported.
8The facility discharge is not in TRIReleases2000_v4; however, industry commented that 1.1 pounds of PACs were reported to TRI in 2000 as discharged.
Note: Bolded lines indicate facilities that measured for and detected PACs.
-^
to
-------
Section 15.0 - Plastics Molding and Forming
15.0
PLASTICS MOLDING AND FORMING (40 CFR PART 463)
EPA selected the Plastics Molding and Forming (PMF) Category for additional
data collection and analysis because of the high TWPE identified in the 2005 screening-level
review (see Table V-l, 70 FR 51050, August 29, 2005). The high TWPE for the PMF Category
is due primarily to carbon disulfide discharges from six cellulose products manufacturers (U.S.
EPA, 2005b). Excluding these discharges from the category reduces the combined PCS and TRI
TWPE for 2002 by approximately 73 percent. This section summarizes the 2005 annual review
and also describes EPA's 2006 annual review of the discharges associated with the PMF
category. EPA's 2006 annual review builds on the 2005 annual review.
15.1
PMF Category Background
This subsection provides background on the PMF Category including a brief
profile of the PMF industry, background on 40 CFR Part 463, and background on 40 CFR Part
63 Subpart UUU, the Cellulose Products National Emission Standards for Hazardous Air
Pollutants (NESHAP).
15.1.1
PMF Industry Profile
The plastics molding and forming industry includes facilities that are engaged in
blending, molding, forming, or other types of processing of plastic materials. These processes
commonly include extrusion, coating and laminating, thermoforming, calendaring, casting,
foaming, cleaning, and finishing (U.S. EPA, 1984). Table 15-1 lists the nine SIC codes with
operations in the PMF Category.
Table 15-1. Number of Facilities in Plastics Molding and Forming SIC Codes
SIC Code
3081: Unsupported Plastics Film & Sheet
3082: Unsupported Plastics Profile Shapes
3083: Laminated Plastics Plate, Sheet, & Profile Shapes
3084: Plastics Pipe
3085: Plastics Bottles
3086: Plastics Foam Products
3087: Custom Compounding of Purchased Resin
3088: Plastics Plumbing Fixtures
3089: Plastics Products, NEC
Total
2002 U.S.
Economic Census
866
670
291
437
403
1,185
579
541
12,689
17,661
2002 PCS3
59
1
4
5
2
6
14
0
34
125
2002 TRIb
78
28
68
25
3
222
200
165
670
1,458
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2.
aMajor and minor dischargers.
bReleases to any media.
NEC - Not elsewhere classified.
15-1
-------
Section 15.0 - Plastics Molding and Forming
15.1.2 40 CFR Part 463
EPA first promulgated ELGs for the PMF Category (40 CFR Part 463) on
December 17, 1984 (49 FR 49040). There are three subcategories, all of which have BPT,
NSPS, PSES, and PSNS limitations.
EPA determined in the 2005 annual review that the facilities responsible for the
majority of the category TWPE in TRIReleases2002 _v2 and PCSLoads2002 v2 manufacture
cellulose film, sponge, and meat casings (U.S. EPA, 2005b). The discharges from these
cellulose products manufacturers are not covered by Part 463. The products are made of
regenerated cellulose using the viscose process. The applicability of the PMF Category excludes
products manufactured from regenerated cellulose, as well as the molding and forming of
regenerated cellulose (U.S. EPA, 1984). Further, the Development Document/or Effluent
Limitations Guidelines and New Source Performance Standards for the Plastics Molding and
Forming Point Source Category states that 40 CFR Part 414, Organic Chemicals, Plastics, and
Synthetic Fibers (OCPSF) Point Source Category, covers only the manufacture of rayon, a
regenerated cellulose fiber, and excludes the manufacture of cellulose film, sponge, and meat
casings (U.S. EPA, 1987; U.S. EPA, 2005c). Thus, wastewater discharges from the manufacture
of cellulose products are not covered by any existing categorical effluent limitations guidelines
or pretreatment standards. Additionally, neither PMF nor OCPSF regulate discharges of carbon
disulfide, the pollutant of concern for the cellulose products manufacturers identified in the 2005
annual review.
15.1.3 40 CFR Part 63 Subpart UUUU
The NESHAP for Cellulose Products Manufacturing (40 CFR Park 63, Subpart
UUUU) was proposed on August 2000 and promulgated on June 11, 2002 (67 FR 40055). The
Cellulose Products Manufacturing NESHAP regulates the following source categories:
• Miscellaneous Viscose Processes. Includes the cellulose food casings,
rayon, cellulosic sponge, and cellophane manufacturing industries.
• Cellulose Ethers Production. Includes the methyl cellulose,
hydroxypropyl methyl cellulose, hydroxypropyl cellulose, hydroxyethyl
cellulose, and carboxymethly cellulose manufacturing industries.
The Cellulose Products Manufacturing NESHAP establishes emissions limits for
hazardous air pollutants HAP, such as carbon disulfide, carbonyl sulfide, ethylene oxide,
methanol, methyl chloride, propylene oxide, and toluene. The Cellulose Products Manufacturing
NESHAP includes requirements for the reduction in HAP emissions from process vents, carbon
disulfide unloading and storage, toluene storage, equipment leaks and wastewater. EPA
determined that wastewater generation for existing sources, for both the Miscellaneous Viscose
Processes and Cellulose Ethers Production source categories, would increase by approximately
2.1 million gallons per year relative to the baseline due to the installation of air pollution control
devices, such as Lo-Cat® scrubbers and carbon adsorbers (see 67 FR 40055, June 11, 2002).
15-2
-------
Section 15.0 - Plastics Molding and Forming
The Cellulose Products Manufacturing NESHAP requires emission reductions for
the cellulose food casing, cellulosic sponge, cellophane, and rayon manufacturing industries in
the Miscellaneous Viscose Process Source Category. These industries are required to reduce
HAP emissions from process vents in the following amounts:
• Cellulose Food Casings. Reduce total uncontrolled sulfide emissions,
reported as carbon disulfide, by at least 25 percent based on a 6-month
rolling average.
• Cellulosic Sponge. Reduce total uncontrolled sulfide emissions, reported
as carbon disulfide, by at least 75 percent based on a 6-month rolling
average.
• Cellophane. Reduce total uncontrolled sulfide emissions, reported as
carbon disulfide, by at least 75 percent based on a 6-month rolling
average.
• Rayon. Reduce total uncontrolled sulfide emissions, reported as carbon
disulfide, by at least 35 percent within three years from the effective date
based on a 6-month rolling average. Additional reductions of total
uncontrolled sulfide emissions are required by at least 40 percent within
eight years from the effective date based on a 6-month rolling average.
Additionally, all cellulose products manufacturing facilities must reduce by at least 83 percent
their uncontrolled carbon disulfide emissions from process vents, unloading and storage
operations, equipment leaks, and wastewater no later than June 13, 2005 for existing sources (see
67 FR 40055, June 11, 2002).
15.2 PMF Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the PMF Category
including the screening-level review and category-specific review.
15.2.1 PMF Category 2005 Screening-Level Review
Table 15-2 presents the PMF Category TWPE calculated using
TRIReleases2002 v2 and PCSLoads2002 v2.
15-3
-------
Section 15.0 - Plastics Molding and Forming
Table 15-2. PMF Category 2005 Screening-Level Review Results
Point Source Category
Plastic Molding and Forming
2002 PCS TWPEa
466C
2002 TRI TWPEb
97,297
Total TWPE
97,762
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
'Excludes discharges from Innovia Films Inc. These discharges were excluded from the category PCS TWPE
because, after initial review, EPA determined the discharges were not representative of the PMF category (U.S.
EPA, 2005a). However, Innovia Films Inc. discharges were included in the 2005 detailed review of the PMF
category, discussed in Section 15.4.
15.2.2
PMF Category 2005 Pollutants of Concern
Table 15-3 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five pollutants with the highest TWPE in
PCSLoads2002_v2. Discharges from Innovia Films Inc. were not included in the 2005
screening-level review category totals presented in Table 15-2, but are included in Table 15-3.
The top five pollutants account for approximately 92 percent of the TRI and PCS 2002 combined
TWPE.
Carbon disulfide contributed 58 percent of the category TRI TWPE for 2002 and
approximately 97 percent of the category PCS TWPE for 2002. EPA reviewed web sites for
facilities reporting carbon disulfide discharges to TRI and PCS in 2002 and determined that all
the facilities manufacture regenerated cellulose products (Devro, Unknown; Innovia Films, 2004;
Spontex, 2004; Viskase, 2002).
One facility, Sealed Air Corporation Cryovac Division, Simpsonville, SC,
reported discharges of dioxin and dioxin-like compounds that contributed 34 percent of the
category TRI TWPE for 2002. Section 15.5.4 presents additional discussion about the dioxin
and dioxin-like compounds discharges.
15-4
-------
Section 15.0 - Plastics Molding and Forming
Table 15-3. 2005 Annual Review: PMF Category Pollutants of Concern
Pollutant
Carbon Bisulfide
Dioxin and Dioxin-Like
Compounds
Sodium Nitrite
Lead and Lead Compounds
Formaldehyde
Magnesium
Sulfate
Nitrogen, Nitrate Total (as N)
Calcium
PMF Category Total
2002 PCS3
Number of
Facilities
Reporting
Chemical
1
Total Pounds
Released
60,041
TWPE
168,125
Pollutants are not reported to PCS.
1
1
1
1
9
1,829,470
197,419,795
144,077
10,333,219
214,533,873
1,583
1,106
807
289
172,483
2002 TRIb
Number of
Facilities
Reporting
Chemical
4
1
1
45
5
Total Pounds
Released
20,252
0.0015
(0.683 g)
13,937
274
191,411
TWPE
56,709
33,452
5,203
614
446
Pollutants are not reported to TRI.
153
1,380,691
97,297
Source: TRIReleases2002_v2; PCSLoads2002_v2.
""Discharges include major dischargers only. Discharges from Innovia Films Inc. are included, so the PMF Category total for 2002 PCS is higher than from the
2005 screening-level review presented in Table 15-2.
bDischarges include transfers to POTWs and account for POTW removals.
-------
Section 15.0 - Plastics Molding and Forming
15.2.3
PMF Category Cellulose Products Facilities 2005 Pollutants of Concern
Table 15-4 separates the discharges from the cellulose products manufacturers
and the rest of the category for TRIReleases2002_v2 and PCSLoads2002_v2. The cellulose
products manufacturers account for 73 percent of the combined 2002 TRI and PCS category
TWPE. Almost all of the TWPE for the cellulose products manufacturers is from discharges of
carbon disulfide.
Table 15-4. 2005 Annual Review: PMF Category Discharges Excluding Cellulose Products
Manufacturers
Cellulose Products Manufacturers
PMF Category Excluding Cellulose Products
Manufacturers
Total
2002 PCS3
Total
Pounds
Discharged
212,796,835
1,737,038
214,533,873
TWPE
172,170
313
172,483
2002 TRIb
Total
Pounds
Discharged
39,830
1,340,861
1,380,691
TWPE
56,879
40,418
97,297
Source: PCSLoads2002_v2; TRIReleases2002_v2.
Discharges include major dischargers only. Discharges from Innovia Films Inc. are included.
bDischarges include transfers to POTWs and account for POTW removals.
15.3
15.4
Potential New Subcategories for the PMF Category
EPA did not identify any potential new subcategories for the PMF category.
PMF Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the PMF Category. EPA obtained additional data and
identified:
• Errors in how PCS loads were estimated for one facility; and
• Changes in estimates of TWPE for sodium nitrite and nitrate.
15.4.1
PMF Category Facility Discharge Revisions
EPA determined that one facility, Innovia Films Inc., responsible for 97 percent
of the PCSLoads2002_v2 TWPE, reported an SIC code in IRffleleases2002_v2 that linked to the
Pulp, Paper, and Paperboard Point Source Category. Innovia Films Inc. manufactures
cellophane, a regenerated cellulose product. EPA concluded that discharges from Innovia Films
Inc. should be included in the PMF Category with the other facilities manufacturing regenerated
cellulose products. The revised TRI database, TRIReleases2002_v4, incorporates this change.
15-6
-------
Section 15.0 - Plastics Molding and Forming
EPA contacted Innovia Films Inc., the only facility reporting discharges of carbon
disulfide for the PMF Category in PCSLoads2002_v2. Innovia Films Inc. provided corrections
to the effluent flow (Martin, 2006), allowing EPA to recalculate the pounds of pollutants
discharged. The TWPE for Innovia Films Inc. were reduced by approximately 88 percent. Table
15-5 lists the changes to the pollutant load for Innovia Films Inc. which is incorporated in the
revised PCS database PCSLoads2002_v4.
Table 15-5. PCS Database Changes for Innovia Films Inc.
Pollutant
Carbon Disulfide
Nitrogen, Nitrate Total (as N)
Calcium
Chlorine
Magnesium
Sulfate
Nitrogen, Ammonia
Toluene
Total
Before Database Corrections,
PCSLoads2002_v2
Pounds Discharged
60,041
144,077
10,333,219
182
1,829,470
197,419,795
10,231
4
212,557,816
TWPE
168,125
807
289
92
1,583
1,106
15
0.02
172,018
After Database Corrections,
PCSLoads2002_v4
Pounds Discharged
7,066
34,173
1,277,219
113
188,815
24,187,480
2,232
4
25,697,102
TWPE
19,785
109
36
58
163
135
3
0.02
20,372
Source: PCSLoads2002 v2; PCSLoads2002 v4.
15.4.2
PMF Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review EAD
revised the TWF and POTW removal values used for sodium nitrite in the TRI and PCS
databases to better reflect the pollutant's properties. The TWF that EAD applies for sodium
nitrite is now 0.0032 (formerly 0.373), and the POTW removal is now 90 percent (formerly 1.85
percent). EAD also revised the TWF for nitrate compounds to better reflect the pollutant's
properties. The TWF that EAD applies for nitrate compounds is now 0.000062 (formerly
0.000747). EPA also developed a TWF of 0.0032 for nitrate as N, a pollutant parameter reported
only to PCS (formerly 0.0056 based on nitrate TWF). Table 15-6 shows the resulting changes in
EPA's estimated sodium nitrite, nitrate compounds, and nitrate as N for the PMF Category.
15-7
-------
Section 15.0 - Plastics Molding and Forming
Table 15-6. Impact of Changes to TWF and POTW Percent Removal for the PMF
Category
Database
TRI 2002
TRI 2002
PCS 2002
Pollutant
Sodium Nitrite
Nitrate Compounds
Nitrate as Na
Number of Facilities
Reporting Discharges
1
10
1
TWPE from 2005
Review
5,203
13
807
TWPE from 2006
Review
0.92
2,199
109
Sources: TRIReleases2002_v2; TRIReleases2002_v4; PCSLoads2002_v2; PCSLoads2002_v4.
aTotal pounds of nitrate as N discharged decreased due to Innovia Films Inc. load corrections.
15.4.3
PMF Category 2006 Screening-Level Review
The results of the 2006 screening-level review are the TRI and PCS rankings after
the revisions described in Section 4.2. This accounts for methodology changes described in
Section 4.2 and changes made based on facility contacts. For the PMF Category, the most
significant changes are also described in Sections 15.4.1 and 15.4.2. Table 15-7 shows the 2006
screening-level TWPE estimated for the PMF Category from the 2002 and 2003 TRI and 2002
PCS databases.
Table 15-7. PMF Category 2006 Screening-Level Review Results
Point Source Category
PMF
2002 PCS TWPEa
20,838
2002 TRI TWPEb
117,741
2003 TRI TWPEb
111,409
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
15.4.4
PMF Category 2006 Pollutants of Concern
Table 15-8 presents the pollutants of concern for the PMF Category as part of the
2006 annual review. After the database corrections, carbon disulfide continues to be the top
PMF Category pollutant, in terms of TWPE. Nitrate compounds discharges are now a pollutant
of concern due to the increase in TWF. Sodium nitrite is no longer a pollutant of concern due to
the decrease in TWF and increase in POTW percent removal. Nitrate as N is also no longer a
pollutant of concern due to the decrease in TWF.
One facility, Sealed Air Corporation Cryovac Division, Simpsonville, SC,
reported dioxin and dioxin-like compounds that contributed 34 percent of the category TRI
TWPE for 2002 and 38 percent of the category TRI TWPE in 2003. Sealed Air Corporation
Cryovac Division manufactures plastic wrap for fresh meats, cheeses, vegetables, and baked
goods. Table 15-9 presents the discharges of dioxin and dioxin-like compounds for 2002 to 2004
for this facility. The total pounds discharged before POTW removal are presented because the
facility is an indirect discharger. The facility's discharges of dioxin and dioxin-like compounds
reported to TRI in 2004 are 91 percent lower than discharges reported to TRI in 2002.
15-8
-------
Section 15.0 - Plastics Molding and Forming
Table 15-8. 2006 Annual Review: PMF Category Pollutants of Concern
Pollutant
Carbon Bisulfide
Dioxin and Dioxin-Like
Compounds
Nitrate Compounds
Lead and Lead
Compounds
Formaldehyde
Magnesium
Copper
Sulfate
Nitrogen, Ammonia
PMF Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
1
Total
Pounds
Released
7,066
TWPE
19,785
Pollutants are not in the top five pollutants
reported to PCS in 2002.
1
3
1
6
9C
188,815
217
24,187,480
116,858
27,998,002
163
138
135
130
20,838
2002 TRIb
Number of
Facilities
Reporting
Pollutant
6
0.0015
(0.683 g)
394,162
274
191,411
Total
Pounds
Released
28,626
33,452
2,207
614
446
TWPE
80,157
33,452
2,207
614
446
Pollutants are not in the top five
pollutants reported to TRI in 2002.
153C
1,385,366
117,741
2002 TRIb
Number of
Facilities
Reporting
Pollutant
6
1
10
54
4
Total
Pounds
Released
23,223
0.0010
(0.474 g)
392,646
395
198,355
TWPE
65,028
41,950
2,199
886
462
Pollutants are not in the top five
pollutants reported to TRI in 2003.
159C
1,492,648
111,409
Source: TRIReleases2002_v4; TRIReleases2003_v2;PCSLoads2002_v4.
""Discharges include major dischargers only.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 15.0 - Plastics Molding and Forming
Table 15-9. Sealed Air Corporation Cryovac Division Dioxin and Dioxin-Like Compounds
Discharges
Year
2000
2001
2002
2003
2004
Basis of Estimate
Monitoring or
Measurements
Monitoring or
Measurements
Monitoring or
Measurements
Other
Monitoring or
Measurements
Total Pounds (Grams)
Discharged to POTW
0.05005
(22.7)
0.04321
(19.6)
0.00886
(4.02)
0.00615
(2.79)
0.00079
(0.36)
Total Pounds (Grams)
Discharged to Surface Water"
0.00851
(3.86)
0.00735
(3.33)
0.00151
(0.68)
0.00105
(0.47)
0.00013
(0.06)
TWPE
288,065
213,739
33,457
41,957
5,414
Source: Envirofacts.
""Discharges to surface water reflect the mass and TWPE estimated by EPA after POTW treatment (i.e., the removal
of dioxin and dioxin-like compounds at the POTW is accounted for).
15.5
Regenerated Cellulose Products Discussion
In 2005, EPA reviewed the PMF Category and determined that carbon disulfide
was the pollutant with the highest TWPE. In the TRI and PCS databases, carbon disulfide
discharges come from facilities that manufacture regenerated cellulose products, such as
cellophane, cellulosic sponge, and meat casings (U.S. EPA, 2005b). As a result, Section 15.5
focuses on facilities manufacturing regenerated cellulose products, and includes a process
description, information about facilities that manufacture cellulose products, wastewater sources
of carbon disulfide, and wastewater treatment at facilities that manufacture cellulose products.
15.5.1
Regenerated Cellulose Process Description
In 2000, EPA's Office of Air Quality Planning and Standards (OAQPS)
completed a study of the cellulose products manufacturing facilities in support of the Cellulose
Products Manufacturing NESHAP. The information gathered during the OAQPS study is
summarized in the memorandum Industry Profile of Cellulose Products Manufacturing Facilities
in the U.S (Schmidtke, 2000). The process description that follows is based on the description in
this memorandum.
The viscose process is used to manufacture cellulose film, sponge, meat casings,
and rayon. In the viscose process, sheets of dissolving-grade cellulose pulp are saturated with
caustic to convert the cellulose into alkali cellulose. The alkali cellulose is pressed to remove the
excess caustic and is shredded to increase the surface area for easier processing. After
shredding, the alkali cellulose resembles "white crumbs." The alkali cellulose partially oxidizes
and degrades by aging in ambient air. The aged alkali cellulose and gaseous carbon disulfide are
mixed in a vessel to form sodium cellulose xanthate, resembling "yellow crumbs." The sodium
cellulose xanthate is dissolved in aqueous caustic solution, creating the viscose solution. The
viscose is ripened, filtered, degassed, and extruded prior to regeneration of the cellulose.
15-10
-------
Section 15.0 - Plastics Molding and Forming
Regenerated cellulose is formed by adding sulfuric acid to the viscose solution (Schmidtke,
2000). The following reactions describe the basic viscose process:
1. Alkali Cellulose
(C6H9O4-OH)X + NaOH -* (C6H9O4-ONa)x + H2O
Cellulose + Sodium Hydroxide -> Alkali Cellulose + Water
2. Sodium Cellulose Xanthate
(C6H9O4-ONa)x + CS2 -> (C6H9O4-O-CS2Na)x
Alkali Cellulose + Carbon Bisulfide -> Sodium Cellulose Xanthate
3. Viscose Solution
(C6H9O4-O-CS2Na)x + NaOH + H2O -* (C6H9O4-O-CS2Na)x«H2O
Sodium Cellulose Xanthate + Sodium Hydroxide + Water -> Viscose Solution
4. Regenerated Cellulose
(C6H9O4-O-CS2Na)x«H2O + H2SO4 -* (C6H9O4-OH)X + CS2 + H2S + S + H2SO4 +
Na2SO4 + CO2
Viscose Solution + Sulfuric Acid -> Regenerated Cellulose + Carbon Bisulfide +
Hydrogen Sulfide + Sulfur + Sulfuric Acid + Sodium Sulphate + Carbon Bisulfide
The manufacture of rayon, cellophane, and meat casings differ in the type of
extrusion dye and the post-regeneration processing. Processes for each product type are
described below.
• Rayon fiber. The viscose is extruded through a spinneret into a bath of
sulfuric acid and zinc sulfate to regenerate the cellulose. After
regeneration, the rayon fiber is washed, bleached, and lubricated with
different chemicals depending on the desired product (Schmidtke, 2000).
• Cellophane. The viscose is extruded through a narrow slit to form a thin
sheet, which passes through a sulfuric acid bath to regenerate the
cellulose. A hot water bath, used to purify the cellophane, is followed by
desulfurization, neutralization, bleaching, washing, and softening. The
cellophane is then dried for packaging (Schmidtke, 2000).
• Food casings. The viscose is extruded through a circular dye or over a
paper substrate as fibrous casing. The extruded viscose is contacted with
sulfuric acid and sometimes ammonium sulfate, depending on the product,
to regenerate the cellulose. The regenerated cellulose passes through wash
tanks, including additional sulfuric acid and warm water. Glycerin is
added to the food casings as a conditioner and dyes may be added as
coloring for the casing prior to drying (Schmidtke, 2000).
15-11
-------
Section 15.0 - Plastics Molding and Forming
The manufacture of cellulosic sponge differs slightly. The sheets of dissolving-
grade pulp are converted into alkali cellulose, followed by xanthation into sodium cellulose
xanthate and formation of the viscose solution. The viscose solution is then mixed with sodium
sulphate crystals, other fibers, and dyes. The mixture is poured into a mold or extruded under
high temperature to melt the sodium sulphate crystals, leaving the pores characteristic of
sponges. The remaining processing of the cellulose sponges includes bleaching, washing,
cutting, and possibly packaging. Some facilities that manufacture sponges do not make viscose
and thus do not use carbon disulfide. Instead they purchase blocks of hardened viscose which
they dissolve to form the softened viscose for processing (Schmidtke, 2000).
15.5.2 Regenerated Cellulose Facility Information
EPA identified cellulose products manufacturers in the United States using the
TRI and PCS databases and data from a study of the cellulose products manufacturing industry
conducted by EPA's OAQPS during their development of NESHAP regulations (Schmidtke,
2000). Table 15-10 lists the eight U.S. cellulose products manufacturers.
Six of the facilities reported wastewater discharges of carbon disulfide to TRI in
2002 and 2003. Table 15-11 lists the total discharges for the regenerated cellulose facilities in
TRIReleases2002_v4 and TRIReleases2003_v2. Table 5-12 lists the discharges of carbon
disulfide in TRIReleases2002 v4 and TRIReleases2003_v2. Table 15-13 lists the total
discharges in PCSLoads2002_v4. The carbon disulfide TWF in the databases is 2.81, while the
POTW removal used in the TRI databases is 84 percent.
15-12
-------
Section 15.0 - Plastics Molding and Forming
Table 15-10. Cellulose Manufacturers in the United States
TRIID
(PCS ID)
5382 l-MCMPN-2 17NO
14150-GNRLM-305SA
66542-FLXLN-6000S
(KS0003204)
NR
38402-SPNTX-SANTA
61832-TPKNC-915NM
37774-VSKSC-EASTL
(TN0001457)
72370-VSKSC-RT198
(AR0036544)
Facility Name
3M Corporation
3M Corporation
Innovia Films
Inc.
Nylogene
Corporation
Spontex Inc.
Teepak L.L.C.
Viskase
Corporation
Viskase
Corporation
Facility
Location
Prairie du Chien,
WI
Tonawanda, NY
Tecumseh, KS
Elyria, OH
Columbia, TN
Danville, IL
Loudon, TN
Osceola, AR
Product Type
Cellulosic
Sponges
Cellulosic
Sponges
Cellophane
Cellulosic
Sponges
Cellulosic
Sponges
Meat Casings
Meat Casings
Meat Casings
Discharge
Type
Indirect
Indirect
Direct
NA
Direct
Indirect
Indirect3
Direct
Permit Notes
Does not report discharges to PCS. Does not
report wastewater discharges to TRI after
2001. No permit available.
Does not report discharges to PCS. No permit
available.
Carbon disulfide monitoring required after
activated sludge basin because it inhibits the
biological process at concentrations above 35
mg/L. Must notify regulators if carbon
disulfide exceeds 17.5 mg/L.
Does not report discharges to PCS. Does not
report wastewater discharges to TRI. No
permit available.
Permit writer used OCPSF Subpart D -
Thermoplastic Resins for BPT, but did not
apply BAT because the facility produced less
than 5 million Ibs of product per year.
Facility only has a general storm water permit.
Permit limits are based on state regulations
and treatability.
Facility is a minor discharge facility.
Source: Company Web Sites (Devro, Unknown; Innovia Films, 2004; Spontex, 2004; Viskase, 2002); TRIReleases2002_4; TRIReleases2003_2; Facility NPDES
Permits (TDEC, 2002; IEPA, 2003; KDHE, 2001; ADEQ, 2000; TDEC, 2005); Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S.
(Schmidtke, 2000).
aEPA believes the facility is an indirect discharger because the facility reports POTW transfers and not surface water releases to TRI. PCS does not contain data
for this facility, although they have a NPDES permit that expires in December 2006. EPA believes they began discharging only to a POTW sometime after 1991.
NA - Not available. EPA is unable to determine if these facilities are direct or indirect dischargers.
NR - Not reported. This facility does not report to TRI or PCS.
-------
Section 15.0 - Plastics Molding and Forming
Table 15-11. TRI 2002 and 2003 Discharges for Cellulose Products Manufacturing
Facilities
Facility Name
Viskase Corporation
Loudon, TN
Innovia Films Inc.
Tecumseh, KS
TeepakL.L.C.
Danville, IL
3M Corporation
Tonawanda, NY
Viskase Corporation
Osceola, AR
Spontex Inc.
Columbia, TN
TRI 2002
Total
Pounds
Discharged
to POTW
77,279
NA
57,600
6,400
NA
NA
Total
Pounds
Discharged
to Stream"
12,383
17,300
14,391
1,024
12,855
201
Total
TWPE
34,639
20,596
20,665
2,867
1,013
563
TRI 2003
Total
Pounds
Discharged
to POTW
80,288
NA
39,700
6,200
NA
NA
Total
Pounds
Discharged
to Stream"
12,865
6,544
12,922
992
9,622
234
Total
TWPE
35,987
13,658
11,255
2,778
862
655
Source: TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include transfers to POTWs and account for POTW removals.
NA - Not applicable. These facilities are direct dischargers and do not report discharges to POTW.
Table 15-12. TRI 2002 and 2003 Carbon Bisulfide Discharges for Cellulose Products
Manufacturing Facilities
Facility Name
Viskase Corporation
Loudon, TN
Innovia Films Inc.
Tecumseh, KS
Teepak L.L.C. Danville,
IL
3M Corporation
Tonawanda, NY
Viskase Corporation
Osceola, AR
Spontex Inc. Columbia,
TN
TRI 2002
Carbon
Disulfide
Pounds
Reported
77,000
NA
46,100
6,400
NA
NA
Carbon
Disulfide
Pounds
Released to
Stream"
12,320
7,350
7,376
1,024
355
201
Carbon
Disulfide
TWPE
34,498
20,581
20,581
2,867
994
562
TRI 2003
Carbon
Disulfide
Pounds
Reported
80,000
NA
25,100
6,200
NA
NA
Carbon
Disulfide
Pounds
Released to
Stream"
12,800
4,877
4,016
922
304
234
Carbon
Disulfide
TWPE
35,842
13,656
11,245
2,778
851
655
Source: TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include transfers to POTWs and account for POTW removals.
NA - Not applicable. These facilities are direct dischargers and do not report discharges to POTW.
15-14
-------
Section 15.0 - Plastics Molding and Forming
Table 15-13. PCS 2002 Discharges for Cellulose Products Manufacturing Facilities
Facility Name
Innovia Films Inc.
Viskase Corporation
3M Corporation
Spontex Inc.
Teepak L.L.C.
Viskase Corporation3
Facility Location
Tecumseh, KS
Osceola, AR
Tonawanda, NY
Columbia, TN
Danville, IL
Loudon, TN
PCS 2002
Total Pounds Discharged
26,021,647
239,019
NA
NR
NA
NA
Total TWPE
20,372
152
NA
NR
NA
NA
Source: PCSLoads2002_v4.
aEPA believes the facility is an indirect discharger because the facility reports POTW transfers and not surface water
releases to TRI. PCS does not contain data for this facility, although they have a NPDES permit that expires in
December 2006. EPA believes they began discharging to a POTW sometime after 1991.
NA - Not applicable. These facilities are indirect dischargers and do not have PCS permits.
NR - Not reported. This facility is a minor direct discharger with a PCS permit, but discharges are not reported in
Envirofacts.
15.5.3
Wastewater Sources of Carbon Disulfide
At cellulose products manufacturing facilities, the main wastewater sources of
carbon disulfide include railcar unloading, carbon disulfide storage, and air pollution control
(Schmidtke, 2000).
Carbon disulfide gas is delivered to most cellulose products facilities by railcar.
Unloading the railcar requires it to be filled with water or nitrogen to displace the carbon
disulfide into the storage tank. Facilities using water displacement generate carbon-disulfide-
saturated wastewater during railcar unloading, which is sent to the facility's wastewater
treatment system. Facilities using nitrogen displacement do not produce the carbon-disulfide-
saturated wastewater during railcar unloading. EPA determined that Spontex Inc. was the only
facility of the eight listed in Table 15-10 that uses water displacement during carbon disulfide
unloading as of 2000 (Schmidtke, 2000).
Carbon disulfide storage tanks are typically submerged under water in a concrete-
lined pool. This allows any carbon disulfide leaks to collect in the bottom of the pool to avoid
atmospheric releases. In addition to the underwater storage, the tanks have a water or nitrogen
padding system to further prevent the contact with oxygen. The padding is in direct contact with
the carbon disulfide to fill the headspace in the tank, creating wastewater saturated with carbon
disulfide if a water padding system is used. The water padding in the storage tank is displaced
into the water pool when the storage tanks are filled. Displaced water in the pool and water
padding is sent to the wastewater treatment system. As of 2000, EPA determined that, of the
facilities listed in Table 15-10, only Teepak L.L.C., 3M Corporation Tonawanda, Spontex Inc,
and Nylogene Corporation use a water padding system (Schmidtke, 2000).
Gaseous by-products in the regeneration of cellulose, including hydrogen sulfide
and carbon disulfide, are off-gassed from the process equipment. Pollutants in the vented gas
can be removed using a wet gas scrubber, which uses an aqueous solution to remove the air
15-15
-------
Section 15.0 - Plastics Molding and Forming
pollutants. The wet scrubber removal efficiency for carbon disulfide is low but the scrubber
effluent may contain some carbon disulfide (Schmidtke, 2000). Discharges reported by Innovia
Films Inc. are due to wet scrubbing of the gaseous by-products (Martin, 2006).
15.5.4
Regenerated Cellulose Facilities Wastewater Treatment
Table 15-14 summarizes the wastewater treatment known to be used by cellulose
products manufacturing facilities.
Table 15-14. Cellulose Products Facilities Wastewater Treatment
Product
Cellophane
Food Casings
Cellulosic
Sponges
Number of
Facilities
1
3
4
Pretreatment Used by
Indirect Dischargers
NA
Neutralization, potential
filtration and settling.
Achieved CS2
concentrations of 5-20
ppm.
Neutralization and
oxidization
Treatment Used by Direct
Dischargers
Neutralization, settling, equalization,
second neutralization, aeration, and
clarification.
Neutralization using lime, equalization,
and clarification.
Equalization, aeration, and clarification.
Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000).
15.6
PMF Category Conclusions
• The high TWPE ranking for the PMF category is due primarily to carbon
disulfide discharges from six cellulose products manufacturers. Excluding
these discharges from the category reduces the combined PCS and TRI
TWPE for 2002 by approximately 73 percent.
• One facility, Sealed Air Corporation Cryovac Division, reported
discharges of dioxin and dioxin-like compounds to TRI in 2002 and 2003.
The number of grams of dioxin and dioxin-like compounds discharges
reported by the facility to TRI in 2004 are 91 percent less than was
reported to TRI in 2002.
• The reduction of HAP emissions required by the NESHAP for the
cellulose products manufacturing industry must be achieved no later than
June 13, 2005. EPA predicted the NESHAP will likely reduce the amount
of carbon disulfide wastewater discharges because facilities will convert
from water to nitrogen displacement and padding systems. EPA also
estimated that facilities will generate an additional 2.1 MGY from wet air
pollution control. However, the wet air pollution control will not increase
wastewater discharges of carbon disulfide because of their limited
effectiveness for removing carbon disulfide. See 67 FR 40055 (June 11,
2002).
15-16
-------
Section 15.0 - Plastics Molding and Forming
• Although wastewater discharges from cellulose products manufacturer are
not covered by an existing ELG, permit writers are basing limitations on
Part 463, Plastics Molding and Forming Point Source Category, and Part
414, Organic Chemicals, Plastics, and Synthetic Fibers. Neither Part 463
nor Part 414 includes limitations for carbon disulfide discharges.
• EPA identified that four of the eight facilities use water displacement
during carbon disulfide unloading or water padding storage system in
2000 (Schmidtke, 2000). EPA believes using nitrogen displacement and
padding instead of water will generate less carbon disulfide in the
wastewater.
• Based on the 2006 annual review, EPA finds that national ELGS are not
the best tools for establishing technology-based limits for this industrial
category because most of the toxic and nonconventional pollutant
discharges are from a few facilities in this industrial category. There are
only eight facilities contributing the bulk of the TWPE for this category
(four are direct discharges and two are indirect discharges) and EPA was
not able to identify the discharge status of two facilities for the 2006
annual review. EPA will consider assisting permitting authorities in
identifying pollutant control and pollution prevention technologies for the
development of technology based effluent limitations based on BPJ on a
facility-specific basis.
15.7 PMF References
ADEQ. 2000. Arkansas Department of Environmental Quality. National Pollution Discharge
Elimination System Permit Application NPDES - AR0036544 - Viskase Corporation, Osceola,
AR. Little Rock, AR. (Month, Day). DCN 02493.
Devro. Unknown. Product Availability. Available online at:
http://www.devro.plc.uk/products/index.htm. Date accessed: June 22, 2005. DCN 02087.
IEPA. 2003. Illinois Environmental Protection Agency Division of Water Pollution Control.
General NPDES Permit for Storm Water Discharges from Industrial Activities. Springfield, IL.
DCN 02540.
Innovia Films. 2004. Company Profile. Available online at:
http://www.innoviafilms.com^corporate/profile.htm. Date accessed: June 22, 2005. DCN
02088.
KDHE. 2006. Kansas Department of Health and Environment. Kansas Water Pollution Control
Permit and Authorization to Discharge Under NPDES KS0003204 - Innovia Films, Tecumseh,
KS. Topeka, KS. DCN 02581.
15-17
-------
Section 15.0 - Plastics Molding and Forming
Martin, Tony. 2006. Telephone conversation with Tony Martin of Innovia Films Inc. and
Jessica Wolford of Eastern Research Group, Inc. "Discussion of Carbon Bisulfide Discharges
for Innovia Films Inc. (KS0003204)." (April 27). DCN 03228.
Schmidtke, Karen and Thomas Holloway. 2000. Industry Profile of the Cellulose Products
Manufacturing Facilities in the U.S. Prepared for U.S. EPA National Emissions Standards for
Hazardous Air Pollutants: Cellulose Products Manufacturing. Gary, NC. (April 11). Docket
EP A-HQ-O AR-2003 -0193 -0004.
Spontex. 2004. MAPA Spontex, Inc. Wiping Products. Available online at:
http://www.spontexusa.com/products.cfm?PRTID=l. Date accessed: June 22, 2005. DCN
02092.
TDEC. 2002. Tennessee Department of Environment and Conservation. State of Tennessee
National Pollutant Discharge Elimination System Permit NPDES TN0001457 - Viskase
Corporation, Loudon, TN. Nashville, TN. DCN 02532.
TDEC. 2005. Tennessee Department of Environment and Conservation. State of Tennessee
National Pollutant Discharge Elimination System Permit NPDES Permit TN0001571 - Spontex
Inc., Columbia, TN. Nashville, TN. 2005. DCN 02533.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1984. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Plastics Molding and Forming Point Source Category. EPA
440/1-84/069. Washington, DC. (December).
U. S. EPA. 1987. Development Document for Effluent Limitations Guidelines and Standards for
the Organic Chemical, Plastics, and Synthetic Fibers Point Source Category - Final. EPA 440-
1-87-009. Washington, DC. (October).
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Dischargers.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
U. S. EPA. 2005c. Product and Product Group Discharges Subject to Effluent Limitations and
Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category - 40
CFR414. Washington, DC. DCN 01812.
Viskase. 2002. Viskase Companies, Inc. Viskase Casing Solutions Worldwide. Available
online at: http://www.viskase.com/. Date accessed: June 22, 2005. DCN 02089.
15-18
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Section 16.0 - Porcelain Enameling
16.0 PORCELAIN ENAMELING (40 CFR PART 466)
EPA selected the Porcelain Enameling Category for additional data collection and
analysis because of the high TWPE identified in the 2005 screening-level review (see Table V-l,
70 FR 51050, August 29, 2005). This section summarizes the 2005 annual review and also
describes EPA's 2006 annual review of the discharges associated with the Porcelain Enameling
Category. EPA's 2006 annual review builds on the 2005 annual review. As part of the 2006
annual review, EPA changed the classification of 174 of 188 facilities in the TRI 2002 and PCS
2002 databases from the Porcelain Enameling Category to the Metal Finishing Category (40
CFR Part 433). As a result of this change, EPA identified that the combined TRI and PCS 2002
TWPE for the Porcelain Enameling Category in the 2006 annual review is 99 percent less than
the combined TWPE in the 2005 annual review. Consequently, the Porcelain Enameling
Category is not identified as a hazard priority based on data available at this time.
16.1 Porcelain Enameling Category Background
This section provides background on the Porcelain Enameling Category including
a brief profile of the porcelain enameling industry and background on 40 CFR Part 466.
16.1.1 Porcelain Enameling Industry Profile
The porcelain enameling industry includes facilities that prepare the surface of a
basis metal and apply a substantially vitreous or glassy inorganic coating bonded to the basis
metal by fusion at a temperature above 800°F (PEI, Unknown). The coatings can be applied by
spraying, dipping, or flow coating (U.S. EPA, 1982). Some of the facilities classified in the
seven SIC codes listed in Table 16-1 conduct porcelain enameling operations. The Porcelain
Enameling Category ELGs apply to the wastewater dischargers from these operations. Most
facilities classified in the seven SIC codes listed in Table 16-1 do not conduct porcelain
enameling operations, but conduct metal finishing operations. The Metal Finishing Category
ELGs apply to the wastewater discharges from nonporcelain-enameling metal finishing
operations, such as electroplating, etching and chemical milling, machining, galvanizing, and
painting (U.S. EPA, 1983) (see 40 CFR Part 433.10(b)). EPA reviewed information about
facilities in the SIC codes listed in Table 16-1 that reported wastewater discharges to TRI and
PCS, to determine whether they conduct porcelain enameling operations.
16-1
-------
Section 16.0 - Porcelain Enameling
Table 16-1. Number of Facilities in Porcelain Enameling SIC Codes
SIC Code
3431: Enameled Iron and Metal Sanitary Ware
3469: Metal Stamping, NEC
3479: Coating, Engraving, and Allied Services, NEC
3631: Household Cooking Equipment
3632: Household Refrigerators and Home and Farm Freezers
3633: Household Laundry Equipment
3639: Household Appliances, NEC
Total
2002 U.S.
Economic
Census
80
2,287
5,255
97
23
18
1,536
9,296
2002 PCS3
1
1
8
0
1
1
1
13
2002 TRIb
4
55
102
6
6
7
4
184
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include major dischargers only.
bReleases to water only.
NEC - Not elsewhere classified.
16.1.2
40 CFR Part 466
EPA first promulgated ELGs for the Porcelain Enameling Category on November
24, 1982 (47 FR 53184). All of the subcategories, except for Subpart D - Copper Basis
Material, have BPT, BAT, NSPS, and PSES/PSNS limitations. Only NSPS and PSNS are
established for the Copper Basis Material Subcategory. The priority pollutants chromium, lead,
nickel, and zinc are regulated in all of the subcategories. This category consists of four
subcategories, as shown in Table 16-2 with a description of the subcategories' applicability.
Table 16-2. Porcelain Enameling Category Subcategory Applicability
Subpart
A
B
C
D
Subcategory Title
Steel Basis Material
Cast Iron Basis Material
Aluminum Basis Material
Copper Basis Material
Subcategory Applicability
Porcelain enameling on steel basis material
Porcelain enameling on cast iron basis material
Porcelain enameling on aluminum basis material
Porcelain enameling on copper basis material
Source: Porcelain Enameling Point Source Category - 40 CFR 466; Development Document for Effluent Limitations
Guidelines and Standards for the Porcelain Enameling Point Source Category (U.S. EPA, 1982).
16.2
Porcelain Enameling Category 2005 Annual Review
In 2005, EPA reviewed the Porcelain Enameling Category and determined that
the majority of facilities identified by the SIC codes listed in Table 16-1 with data in the TRI and
PCS databases did not perform porcelain enameling operations (U.S. EPA, 2005b; Wolford,
2005). As a result, instead of analyzing discharges from this category, the remainder of Section
16.0 focuses on identification of the facilities that are likely to have porcelain enameling
operations that discharge wastewater subject to the Porcelain Enameling ELGs.
16-2
-------
Section 16.0 - Porcelain Enameling
16.2.1 Porcelain Enameling Category 2005 Screening-Level Review
Table 16-3 presents the Porcelain Enameling Category TWPE calculated, using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 16-3. Porcelain Enameling Category 2005 Screening-Level Review Results
Point Source Category
Porcelain Enameling
PCS TWPEa
3,478
TRI TWPEb
88,749
Total TWPE
92,228
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
16.2.2 Porcelain Enameling Category 2005 Facility Classification Revisions
After the 2005 screening-level review, EPA conducted a detailed review of the
category and determined that the Porcelain Enameling Category combined 2002 TRI and PCS
TWPE discharges from many facilities that did not have porcelain enameling operations. EPA
used information from individual company web sites (Wolford, 2005) and information provided
by the main trade association for this industry, the Porcelain Enamel Institute, to determine
which facilities were likely to conduct porcelain enameling operations (PEI, 2006). Facilities
were assumed to have metal finishing operations, but not porcelain enameling operations, if their
facility name contained any of the 46 metal finishing unit operations listed in 40 CFR Part
433.10(a) and they did not identify themselves as porcelain enamelers on their web site or
manufacture products that could be porcelain enameled, such as kitchen appliances. EPA
conducted additional review of facility web sites to determine if facilities performed metal
finishing operations or porcelain enameling operations based on their products (Wolford, 2005).
Table 16-4 presents the number of facilities in the seven SIC codes, separated into facilities
likely to have porcelain enameling operations (Likely PE Facilities) and those with only metal
finishing operations (Non-PE Facilities). The table includes only the facilities reporting
wastewater discharges to TRI and facilities classified as major dischargers in PCS. EPA
concluded that 92.6 percent of the facilities in the seven SIC codes are not likely to conduct
porcelain enameling operations (U.S. EPA, 2005b).
16-3
-------
Section 16.0 - Porcelain Enameling
Table 16-4. 2005 Annual Review Results: Number of Facilities in Porcelain Enameling
SIC Codes
SIC Code
343 1: Enameled Iron and Metal
Sanitary Ware
3469: Metal Stamping, NEC
3479: Coating, Engraving, and Allied
Services, NEC
3631: Household Cooking Equipment
3632: Household Refrigerators and
Home and Farm Freezers
3633: Household Laundry Equipment
3639: Household Appliances, NEC
Total
Likely Porcelain Enameling
Facilities
2002 PCS"
Likely PE
Facilities
1
0
0
0
1
1
1
4C
2002 TRIb
Likely PE
Facilities
4
4
0
6
6
7
3
30C
Non-Porcelain Enameling
Facilities
2002 PCS3
Non-PE
Facilities
0
1
8
0
0
0
0
9
2002 TRIb
Non-PE
Facilities
0
51
102
0
0
0
1
154
Source: Preliminary Review of Priority Categories of Industrial Dischargers (U.S. EPA, 2005b);
PCSLoads2002_v2; TPJReleases2002_v2.
Discharges include only major dischargers.
bReleases to water only.
°There are 30 facilities likely to have porcelain enameling operations: 26 facilities report only to TRI, 1 facility
reports only to PCS, and 3 facilities reported to TRI and PCS in 2002.
NEC - Not elsewhere classified.
PE - Porcelain Enameling.
16.2.3
Porcelain Enameling Category 2005 Revised Screening-Level Review
After identifying facilities likely to have porcelain enameling operations, EPA
recalculated the category TWPE. Table 16-5 presents the recalculated TWPE. The table
compares the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharges for the facilities that are not likely to
manufacture porcelain enameled products (Non-PE Facilities) and those that are (Likely PE
Facilities). Approximately 42 percent of the TWPE for facilities in the porcelain enameling SIC
codes is from facilities likely to have porcelain enameling operations (U.S. EPA, 2005b).
16-4
-------
Section 16.0 - Porcelain Enameling
Table 16-5. Porcelain Enameling Category 2005 Revised Screening-Level Review Results
2002 Total
2002 TRI Non-PE Facilities3
2002 PCS Non-PE Facilities'3
2002 Total Non-PE Facilities
2002 TRI Likely PE Facilities3
2002 PCS Likely PE Facilities'3
2002 Total Likely PE Facilities
Number of Facilities
Reporting TWPE
Greater Than Zero
154
9
30
4
30C
Total Pounds
Discharged
46,479,576
406,178
22,710,347
23,116,525
576,059
38,322
614,381
TWPE
92,228
49,395
3,450
52,845
39,348
28
39,376
Source: Preliminary Review of Priority Categories of Industrial Dischargers (U.S. EPA, 2005b);
TRIReleases2002_v2;PCSLoads2002_v2.
^Discharges include transfers to POTWs and account for POTW removals.
bDischargers include major dischargers only.
°There are 30 facilities likely to have porcelain enameling operations: 26 facilities report only to TRI, 1 facility
reports only to PCS, and 3 facilities reported to TRI and PCS in 2002.
PE - Porcelain Enameling.
16.3 Potential New Subcategories for the Porcelain Enameling Category
EPA did not identify any potential new subcategories for the Porcelain Enameling
Category.
16.4
Porcelain Enameling Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Porcelain Enameling Category. As shown in Table
16-5, during the 2005 annual review, EPA identified 30 facilities that could have operations
subject to the Porcelain Enameling Category ELGs (U.S. EPA, 2005b). Of these 30 facilities, 26
report only to TRI, one reported only to PCS, and three reported to TRI and PCS in 2002 (U.S.
EPA, 2005b). For the 2006 annual review, EPA further investigated the operations conducted at
these facilities. In its comments on the Preliminary Review of Priority Categories of Industrial
Dischargers (U.S. EPA, 2005b), the Porcelain Enamel Institute provided additional information
about some of the facilities likely to perform porcelain enameling operations (PEI, 2005). The
Porcelain Enamel Institute confirmed that 13 facilities reporting to TRI in 2002 and 2 facilities
with 2002 discharge data in PCS have porcelain enameling operations. In addition, the Porcelain
Enamel Institute identified the remaining facilities, 17 facilities reporting to TRI in 2002 and 2
facilities reporting to PCS in 2002, as facilities that do not have porcelain enameling operations.
The Porcelain Enamel Institute identified one facility, Vitco Inc., reporting to TRI in 2002 that
EPA had identified as not likely to have porcelain enameling operations. (PEI, 2005) Additional
information about the facilities with porcelain enameling operations was provided by the
Porcelain Enamel Institute during a meeting with EPA in March 2006 (Johnston, 2006). Table
16-6 lists EPA's findings about the 31 facilities identified in the 2006 screening-level review as
likely to have porcelain enameling operations. EPA determined that only 14 of these facilities
have porcelain enameling operations, and 2 of these facilities closed after 2003.
16-5
-------
Section 16.0 - Porcelain Enameling
Table 16-6. 2006 Screening-Level Review Results: Classification of Facilities in Porcelain
Enameling and Metal Finishing Categories
Facility
American Standard Inc.
American Trim Superior
Metal Prods. Div.
Briggs Industries
Incorporated
Electrolux Home Prods.
Electrolux Home Prods.
Electrolux Home Prods.
Eljer Plumbingware Inc.
GE Appliances
GECo.
GECo. GEABPO
L.L.C.
Hanson Porcelain Co.
Inc.
Kohler Co.
Kohler Co.
Kohler Co. Cast Iron
Div.
Maytag Appliances
Maytag Appliances
Amana Refrigeration
Prods.
Maytag Florence Ops.
Location
Salem, OH
Wapakoneta,
OH
Knoxville, TN
Springfield,
TN
Webster City,
IA
Jefferson, IA
Salem, OH
Louisville,
KY
Decatur, AL
Bloomington,
IN
Lynchburg,
VA
Kohler, WI
Searcy, AR
Kohler, WI
Searcy, AR
Amana, IA
Florence, SC
Data
Sources
TRI
TRI
PCS
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI&
PCS
TRI
Applicable
Category
Porcelain
Enameling
Metal
Finishing
Porcelain
Enameling
Porcelain
Enameling
Metal
Finishing
Metal
Finishing
Metal
Finishing
Metal
Finishing
Metal
Finishing
Metal
Finishing
Porcelain
Enameling
Metal
Finishing
Metal
Finishing
Porcelain
Enameling
Metal
Finishing
Metal
Finishing
Porcelain
Enameling
Additional Facility Information,
where Available
Manufactures bathroom fixtures.
Mostly porcelain enameling operations.
Powdered enamel and wet-process
enamel, painting, and washing
operations. Estimate 90% of
wastewater is from metal finishing
operations.
Facility has closed.
Custom porcelain enameling facility.
Majority of wastewater is from
porcelain enameling.
Porcelain enameling process does not
produce wastewater. Majority of
facility's wastewater is from metal
finishing operations.
Facility has closed.
16-6
-------
Section 16.0 - Porcelain Enameling
Table 16-6 (Continued)
Facility
Maytag Herrin Laundry
Prods.
Maytag Newton Laundry
Maytag P#l Cleveland
Maytag P#3 Cleveland
Roper Corp.
State Inds. Inc.
Vitco Inc.
W.C. Wood Co. Inc.
Whirlpool Corp.
Whirlpool Corp.
Whirlpool Corp.
Whirlpool Corp. Clyde
Whirlpool Corp. Marion
Div.
Whirlpool Corp. Tulsa
Location
Herrin, IL
Newton, IA
Cleveland, TN
Cleveland, TN
Lafayette, GA
Ashland City,
TN
Nappanee, IN
Ottawa, OH
Evansville, IN
Fort Smith,
AR
Findlay, OH
Clyde, OH
Marion, OH
Tulsa, OK
Data
Sources
TRI&
PCS
TRI
TRI
TRI
TRI
TRI&
PCS
TRI
TRI
TRI
TRI
TRI
TRI
TRI
TRI
Applicable
Category
Metal
Finishing
Porcelain
Enameling
Porcelain
Enameling
Porcelain
Enameling
Porcelain
Enameling
Porcelain
Enameling
Porcelain
Enameling
Metal
Finishing
Metal
Finishing
Metal
Finishing
Metal
Finishing
Porcelain
Enameling
Metal
Finishing
Porcelain
Enameling
Additional Facility Information,
where Available
Facility is in the process of closing.
Previously, wastewater was 90% from
metal finishing operations.
Produces home cooking ranges and
ovens. Estimate 90% of wastewater is
from metal finishing operations.
Estimate 95% of wastewater is from
metal finishing operations.
Produces home cooking ranges and
ovens. Estimate 90% of wastewater is
from metal finishing operations.
Produces approximately 14,000 hot
water heaters per day with enameled
interiors. Estimate 50% of wastewater
is from metal finishing operations.
Custom porcelain enameling facility.
Majority of wastewater is from
porcelain enameling.
Estimate 90% of wastewater is from
metal finishing operations.
Estimate 85% of wastewater is from
metal finishing operations.
Source: "Comments of the Porcelain Enamel Institute" (PEI, 2005); "Meeting Minutes of EPA and Porcelain
Enamel Institute (PEI) Discussion of PEI Comments on the Preliminary 2006 Effluent Guidelines Plan (29 March
2006)" (Johnston, 2006).
16-7
-------
Section 16.0 - Porcelain Enameling
As a result of the 2006 screening-level review, EPA determined that the Porcelain
Enameling Category ranked 44th of 49 categories in combined 2002 TRI and PCS TWPE. Table
16-7 presents the TRI and PCS discharges associated with the 14 facilities with porcelain
enameling operations listed in Table 16-6. TRI and PCS discharges from these 14 facilities,
including the two facilities that closed after 2003, represented 412 combined TWPE from
TRIReleases2002 v4 and PCSLoads2002 v4.
Table 16-7. Porcelain Enameling Category 2006 Screening-Level Review Results
Data Source
2002 PCS3
2002 TRIb
2003 TRIb
2002 Category Total
Number of Facilities Reporting
TWPE Greater than Zero
2
13
12C
Total Pounds Discharged
22,943
286,436
70,743
309,378
TWPE
17.1
398.3
362.6
412.4
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
""Discharges include major dischargers only.
Discharges include transfers to POTWs and account for POTW removals.
°Vitco Inc. did not report to TRI in 2003.
16.5
Porcelain Enameling Category Conclusions
• The high TWPE ranking for the Porcelain Enameling Category in the
2005 annual review was due to including discharges from facilities
without porcelain enameling operations. These facilities have the same
SIC code as facilities that produce porcelain enameled products, but they
only have metal finishing operations.
• Review of the Porcelain Enameling Category determined that only 14
facilities with discharges reported in TRI and/or PCS have porcelain
enameling operations, including three that have closed or are in the
process of closing.
• The 14 facilities with discharges subject to the Porcelain Enameling
Category ELGs account for approximately 412 TWPE using combined
TRI and PCS data from 2002.
• Improvements to porcelain enameling technology have reduced or
eliminated the use of water in the process. For example, powder
enameling is a water-free dry enameling process and the amount of
cleaning, generating wastewater, has reduced due to new porcelain enamel
glass compositions (Waggener, 2006).
• EPA is not identifying the Porcelain Enameling Category as a hazard
priority based on data available at this time.
16-8
-------
Section 16.0 - Porcelain Enameling
16.6 Porcelain Enameling Category References
Hackler, Cullen. 2006. Porcelain Enamel Institute. Email to Carey Johnston, U.S. EPA, from
Cullen Hackler, Porcelain Enamel Institute. "Porcelain Enameling Industry Information." (July
7). DCN 03230.
Johnston, Carey. 2006. U.S. EPA. Memorandum to Public Record for the Effluent Guidelines
Program Plan 2005/2006. "Meeting Minutes of EPA and Porcelain Enamel Institute (PEI)
Discussion of PEI Comments on the Preliminary 2006 Effluent Guidelines Plan (29 March
2006)." (March 29). DCN 03229.
PEI. 2005. Porcelain Enamel Institute. Comments of the Porcelain Enamel Institute. Docket
EPA-HQ-OW-2004-0032-1072. (November).
PEI. 2006. Porcelain Enamel Institute. Available online at: http://www.porcelainenamel.com.
PEI. Unknown. Porcelain Enamel Institute. Properties of Porcelain Enamel, Appearance
Properties, Data Bulletin PEI 501. Available online at:
http://www.porcelainenamel.com/pei501.htm. DCN 02091.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1982. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Porcelain Enameling Point Source Category. EPA-440/1-82/072.
Washington, DC.
U. S. EPA. 1983. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Metal Finishing Point Source Category. EPA-440/1 -83/091.
Washington, DC.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary Review of Priority Categories of Industrial Dischargers. EPA-
821-B-05-004. Washington, DC. (August). DCN 02175.
Wolford, Jessica. 2005. Eastern Research Group, Inc. Memorandum to 2006 Effluent
Guidelines Program Plan Docket. "Identification of Facilities for the Porcelain Enameling Point
Source Category." (July 14). DCN 02195.
16-9
-------
Section 17.0 - Rubber Manufacturing
17.0 RUBBER MANUFACTURING (40 CFR PART 428)
EPA selected the Rubber Manufacturing Category for additional data collection
and analysis because of the high TWPE identified in the 2005 screening-level review,
particularly discharges of sodium nitrite reported to TRI in 2002 (U.S. EPA, 2005b) (see Table
V-l, 70 FR 51050, August 29, 2005). This section summarizes the 2005 annual review and also
describes the results of EPA's 2006 annual review of the discharges associated with the Rubber
Manufacturing Category. EPA's 2006 annual review builds on the 2005 annual review. After
corrections to the TRI and PCS databases based on more detailed review and data collection, the
Rubber Manufacturing Category is no longer one of the top categories in terms of TWPE.
17.1 Rubber Manufacturing Category Background
This subsection provides a brief background on the Rubber Manufacturing
Category including a brief profile of the rubber manufacturing industry and background on 40
CFR Part 428.
17.1.1 Rubber Manufacturing Industry Profile
The rubber manufacturing industry includes facilities that manufacture natural,
synthetic, and reclaimed rubber. Manufactured rubber becomes finished goods through a variety
of methods, such as molding, extruding, and fabricating (U.S. EPA, 1974a; U.S. EPA, 1974b).
Because the U.S. Economic Census reports data by NAICS code, and TRI and PCS report data
by SIC code, EPA reclassified the 2002 U.S. Economic Census data by equivalent SIC code.
The facilities in SIC code 3069 do not translate directly to a NAICS code, and EPA could not
determine the number of facilities in the 2002 U.S. Economic Census for SIC code 3069. Table
17-1 lists the seven SIC codes with operations in the Rubber Manufacturing Category.
Rubber manufacturing facilities discharge directly to surface water as well as to
POTWs. Table 17-2 presents the types of discharges reported by facilities in the 2002 TRI
database. The majority of facilities reporting to TRI reported no water discharges, but facilities
may be discharging pollutants in wastewater at levels below the TRI-reporting thresholds.
17-1
-------
Section 17.0 - Rubber Manufacturing
Table 17-1. Number of Facilities in Rubber Manufacturing SIC Codes
SIC Code
2822: Synthetic Rubber (Vulcanizable Elastomers)
3011: Tires and Inner Tubes
3021: Rubber and Plastics Footwear
3052: Rubber and Plastics Hose and Belting
3053: Gaskets, Packing, and Sealing Devices
3061: Molded, Extruded, and Lathe-Cut Mechanical
Rubber Goods
3069: Fabricated Rubber Products, NEC
Total
2002 U.S.
Economic
Census
157
158
62
260
614
608
NAC
>1,859
2002 PCS3
18
23
0
4
4
19
47
118
2002 TRIb
34
72
5
72
58
70
216
527
2003 TRIb
35
69
6
68
56
69
201
504
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
"Major and minor dischargers.
bReleases to any media.
°Poor bridging between NAICS and SIC codes. Numbers of facilities could not be determined.
NA - Not applicable.
NEC - Not elsewhere classified.
Table 17-2. Rubber Manufacturing Category Facilities by Type of Discharge Reported in
TRI 2002
SIC Code
2822: Synthetic Rubber
(Vulcanizable Elastomers)
3011: Tires and Inner Tubes
3021 : Rubber and Plastics
Footwear
3052: Rubber and Plastics Hose
and Belting
3053: Gaskets, Packing, and
Sealing Devices
3061: Molded, Extruded, and
Lathe-Cut Mechanical Rubber
Goods
3069: Fabricated Rubber Products,
NEC
Reported
Only Direct
Discharges
7
8
0
3
1
5
9
Reported Only
Indirect
Discharges
11
17
1
20
11
17
49
Reported Both
Direct and Indirect
Discharges
0
25
0
14
3
8
10
Reported No
Water
Discharges
15
22
4
35
43
40
148
Source: TRIReleases2002_v4.
NEC - Not elsewhere classified.
17-2
-------
Section 17.0 - Rubber Manufacturing
17.1.2
40 CFR Part 428
EPA first promulgated ELGs for the Rubber Manufacturing Category (40 CFR
Part 428) on February 21, 1974 (39 FR 6662). All 11 subcategories have BPT, BAT, NSPS, and
PSNS limitations. The priority pollutants lead, chromium, and zinc are all regulated in at least
one subcategory. Table 17-3 presents the subcategories, the related SIC codes, and descriptions
of the subcategories' applicability (U.S. EPA, 1974a; U.S. EPA, 1974b).
Table 17-3. Rubber Manufacturing Category Subcategory Applicability
Sub-
part
A
B
C
D
E
F
G
H
I
J
K
Subcategory Title
Tire and Inner Tube Plants
Emulsion Crumb Rubber
Solution Crumb Rubber
Latex Rubber
Small-Sized General Molded,
Extruded, and Fabricated
Rubber Plants
Medium-Sized General
Molded, Extruded, and
Fabricated Rubber Plants
Large-Sized General Molded,
Extruded, and Fabricated
Rubber Plants
Wet Digestion Reclaimed
Rubber
Pan, Dry Digestion, and
Mechanical Reclaimed
Rubber
Latex-Dipped, Latex-
Extruded, and Latex-Molded
Rubber
Latex Foam
Related SIC Code(s)
3011: Tires and Inner Tubes
2822: Synthetic Rubber
(Vulcanizable Elastomers)
2822: Synthetic Rubber
(Vulcanizable Elastomers)
2822: Synthetic Rubber
(Vulcanizable Elastomers)
3021 : Rubber and Plastics
Footwear
3052: Rubber and Plastics
Hose and Belting
3053: Gaskets, Packing, and
Sealing Devices
3061: Molded, Extruded, and
Lathe-Cut Mechanical Goods
3069: Fabricated Rubber
Products, NEC
3069: Fabricated Rubber
Products, NEC
3069: Fabricated Rubber
Products, NEC
3069: Fabricated Rubber
Products, NEC
3069: Fabricated Rubber
Products, NEC
Subcategory Applicability
Pneumatic tire and inner tube
Emulsion crumb rubber
excludes acrylonitrile butadiene rubber
Crumb rubber
Latex rubber
Molded, extruded, and fabricated
rubber; foam rubber backing; rubber
cement-dipped goods; and retreaded
tires
Excludes latex-based products and
textiles subject to 40 CFR Part 410
Wet digestion reclaimed rubber
Reclaimed rubber
Excludes wet digestion
Latex-dipped, latex-extruded, and latex-
molded rubber
Excludes textiles subject to 40 CFR Part
410
Latex foam
Excludes textiles subject to 40 CFR Part
410
Source: Rubber Manufacturing Point Source Category - 40 CFR 428', Development Document for Effluent
Limitations Guidelines and New Source Performance Standards for the Fabricated and Reclaimed Rubber Segment
of the Rubber Processing Point Source Category (U.S. EPA, 1974a); Development Document for Effluent
Limitations Guidelines and New Source Performance Standards for the Tire and Synthetic Segment of the Rubber
Processing Point Source Category (U.S. EPA, 1974b).
NEC - Not elsewhere classified.
17-3
-------
Section 17.0 - Rubber Manufacturing
17.2
Rubber Manufacturing Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Rubber
Manufacturing Category including the screening-level review and category-specific review.
17.2.1
Rubber Manufacturing Category 2005 Screening-Level Review
Table 17-4 presents the Rubber Manufacturing Category TWPE calculated, using
TRIReleases2002_v2 and PCSLoads2002_v2.
Table 17-4. Rubber Manufacturing Category 2005 Screening-Level Review Results
Rank
9
Point Source Category
Rubber Manufacturing
2002 PCS TWPEa
2,386
2002 TRI TWPEb
173,304
Total TWPE
175,690
Sources: PCSLoads2002_v2; TRIReleases2002_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTW and account for POTW removals.
17.2.2
Rubber Manufacturing Category 2005 Pollutants of Concern
Table 17-5 shows the five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the five chemicals with the highest TWPE in
PCSLoads2002_v2. The top five pollutants account for approximately 99 percent of the Rubber
Manufacturing Category's 2002 combined TWPE.
17.3
Potential New Subcategories for the Rubber Manufacturing Category
EPA did not identify any potential new subcategories for the Rubber
Manufacturing Category.
17-4
-------
Section 17.0 - Rubber Manufacturing
Table 17-5. 2005 Annual Review: Rubber Manufacturing Category Pollutants of Concern
Pollutant
Sodium Nitrite
PACs
1,3 -Butadiene
Zinc and Zinc
Compounds
Chlorine
Benzidine
Arsenic
Acrylonitrile
Copper
Vanadium
Rubber Manufacturing
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five PCS
2002 reported pollutants
1
2
o
6
8
1
20C
0.24
115
141
266
4,710
9,530,447
677
446
320
169
165
2,386
2002 TRI b
Number of
Facilities
Reporting
Pollutant
12
4
4
166
4
Total
Pounds
Released
316,929
500
250
22,121
1,534
TWPE
118,320
50,293
1,208
1,037
781
Pollutants are not in the top five TRI
2002 reported pollutants.
220C
1,082,214
173,304
Source: PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include major dischargers only.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
17.4
Rubber Manufacturing Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Rubber Manufacturing Category. EPA obtained
additional data and identified:
• Errors in how PCS loads were estimated for one facility; and
• Changes in estimates of TWPE for sodium nitrite.
After EPA made the changes identified during the 2006 annual review, the TWPE
in the TRI and PCS databases is less than 5,000 TWPE for the entire category.
17.4.1
Rubber Manufacturing Category Facility Discharge Revisions
EPA contacted Michelin North America's Ardmore Plant, which reported PACs
to TRI in 2002 as discharges to surface water. The facility indicated that the PACs were not
released to surface water, but were actually transferred to a landfill. Michelin North America's
Ardmore Plant plans to make a correction to previously submitted TRI reports (Dryden, 2005).
To accurately reflect the actual discharges, EPA deleted the discharges of PACs reported to TRI
in 2002 by this facility, resulting in a decrease of 6,747 pounds of PACs.
17-5
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Section 17.0 - Rubber Manufacturing
17.4.2 Rubber Manufacturing Category TWF and POTW Percent Removal
Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, BAD
revised the TWF and POTW removal values used for sodium nitrite, the TWF for nitrate
compounds, and the POTW removal for chlorine in the TRI and PCS databases. During the
2006 annual review, BAD revised the TWF and POTW percent removal values used for sodium
nitrite in the TRI and PCS databases to better reflect the pollutant's properties. The TWF that
BAD applies for sodium nitrite is now 0.0032 (formerly 0.373), and the POTW removal is now
90 percent (formerly 1.85 percent). According to facilities EPA contacted, rubber facilities that
use a molten salt curing process may discharge sodium nitrite. The molten salt, which can
contain sodium nitrite, is removed from the rubber products using a water wash that is
discharged (Dryden, 2005; Hines, 2005; Hough, 2005; Rader, 2005). BAD also revised the TWF
for nitrate compounds to better reflect the pollutant's properties. The TWF that BAD applies for
nitrate compounds is now 0.000747 (formerly 0.000062). Additionally, BAD revised the POTW
removal values used for chlorine in the TRI database to better reflect the water chemistry of
chlorine. The POTW removal is now 100 percent (formerly 1.87 percent). Table 17-6 presents
the loads before and after corrections to the sodium nitrite TWF and POTW percent removal,
nitrate compounds TWF, and chlorine POTW percent removal for the Rubber Manufacturing
Category. Based on the changes described above, the sodium nitrite TWPE dropped by 99
percent and is no longer a pollutant of concern.
Table 17-6. Impact of Changes to TWF and POTW Percent Removal for the Rubber
Manufacturing Category
Database
TRI 2002
TRI 2002
TRI 2002
Pollutant
Sodium Nitrite
Nitrate Compounds
Chlorine
Number of Facilities
Reporting
Discharges
12
20
4
TWPE from 2005
Review
118,320
43
781
TWPE from 2006
Review
22
521
406
Sources: TRIReleases2002 v2; TRIReleases2002 v4.
17.4.3
Rubber Manufacturing Category 2006 Screening-Level Review
The results of the 2006 screening-level review are the TRI and PCS rankings after
the revisions described in Section 4.2. This accounts for methodology changes described in
Section 4.2 and changes made based on contacts to facilities. For the Rubber Manufacturing
Category, the most significant changes are also described in Sections 17.4.1 and 17.4.2. Table
17-7 shows the 2006 screening-level TWPE estimated for the Rubber Manufacturing Category
from the 2002 and 2003 TRI and 2002 PCS databases.
17-6
-------
Section 17.0 - Rubber Manufacturing
Table 17-7. Rubber Manufacturing Category 2006 Screening-Level Review Results
Point Source Category
Rubber Manufacturing
2002 PCS TWPEa
2,350
2002 TRI TWPEb
5,104
2003 TRI TWPEb
4,395
Sources: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTW and account for POTW removals.
17.4.4 Rubber Manufacturing Category 2006 Pollutants of Concern
Table 17-8 presents the pollutants of concern for the Rubber Manufacturing
Category as part of the 2006 annual review. Sodium nitrite is no longer a top pollutant of
concern due to the decrease in TWF and increase in POTW percent removal. With the revised
TWPE, the Rubber Manufacturing Category is no longer ranked high in terms of TWPE.
17.5 Rubber Manufacturing Category Conclusions
• The high TWPE ranking for the Rubber Manufacturing Category in the
2005 annual review was due to discharges of sodium nitrite reported to
TRI. EPA changed the sodium nitrite TWF and POTW percent removal
to better reflect the chemistry in water, and therefore sodium nitrite is no
longer a top pollutant of concern
• After EPA revised the TRI and PCS databases, the facilities with
discharges subject to the Rubber Manufacturing ELGS account for 7,454
TWPE using combined TRI and PCS data from 2002.
• EPA is not identifying the Rubber Manufacturing Category as a hazard
based on data available at this time.
17-7
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Section 17.0 - Rubber Manufacturing
Table 17-8. 2006 Annual Review: Rubber Manufacturing Category Pollutants of Concern
Pollutant
1,3 -Butadiene
Zinc and Zinc
Compounds
Lead and Lead
Compounds
Nitrate Compounds
Chlorine
Benzidine
Arsenic
Acrylonitrile
Copper
Vanadium
Rubber Manufacturing
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
These pollutants are not reported in the
top five PCS 2002 reported pollutants.
1
1
2
7
1
20C
0.24
115
141
266
4,710
9,530,447
667
466
320
169
165
2,350
2002 TRIb
Number of
Facilities
Reporting
Pollutant
4
164
48
20
4
Total
Pounds
Released
250
21,870
249
697,523
798
TWPE
1,208
1,025
558
521
406
These pollutants are not in the top five
TRI 2002 reported pollutants.
218C
770,616
5,104
2003 TRIb
Number of
Facilities
Reporting
Pollutant
2
154
47
18
2
Total
Pounds
Released
65
18,401
258
625,824
555
TWPE
316
863
579
467
283
These pollutants are not in the top five
TRI 2003 reported pollutants.
203C
727,211
4,395
oo
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include major dischargers only.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 17.0 - Rubber Manufacturing
17.6 Rubber Manufacturing Category References
Dryden, Bob. 2005. Telephone conversation with Bob Dryden of GDX Automotive, New
Haven, MO, and Jessica Wolford of Eastern Research Group, Inc. "Clarification of
Manufacturing Process and Pollutant Discharges." (June 13). DCN 02071.
Hines, John. 2005. Telephone conversation with John Hines of Avon Automotive, Cadillac, MI,
and Jessica Wolford of Eastern Research Group, Inc. "Clarification of Manufacturing Process
and Pollutant Discharges." (June 9). DCN 02070.
Hough, Mike. 2005. Telephone conversation with Mike Hough of GDX Automotive, Wabash,
IN, and Jessica Wolford of Eastern Research Group, Inc. "Clarification of Manufacturing
Process and Pollutant Discharges." (June 22). DCN 02072.
Johnston, Carey. 2006. U.S. EPA. Memorandum to Public Record for the Effluent Guidelines
Program Plan 2005/2006. "November 10, 2005, Meeting Between EPA and Rubber
Manufacturers." (February 8). DCN 03227.
Rader, Stacey. 2005. Telephone conversation with Stacey Rader of Cooper Standard
Automotive, Bowling Green, OH, and Jessica Wolford of Eastern Research Group, Inc.
"Clarification of Manufacturing Process and Pollutant Discharges." (June 20). DCN 02069.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U.S. EPA. 1974a. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Fabricated and Reclaimed Rubber Segment of the Rubber
Processing Point Source Category. EPA-440/1 -74/030-a. Washington, DC.
U.S. EPA. 1974b. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Tire and Synthetic Rubber Segment of the Rubber Processing
Point Source Category. EPA-440/1-74-013-a. Washington, DC.
U.S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN 02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Dischargers.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
17-9
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Section 18.0 - Textile Mills
18.0
TEXTILE MILLS (40 CFR PART 410)
EPA selected the Textile Mills (Textiles) Category for additional data collection
and analysis because of the high TWPE identified in the 2005 screening-level review (see Table
V-l, 70 FR 51050, August 29, 2005). The 2004 Plan summarizes the results of EPA's previous
reviews of this industry (U.S. EPA, 2004). This section summarizes the 2005 annual review and
also describes EPA's 2006 annual review of the discharges associated with the Textiles Category
(U.S. EPA, 2005b). EPA's 2006 annual review builds on the 2005 annual review. EPA
identified facilities contributing the most TWPE as part of the 2006 annual review.
18.1
Textile Mills Point Source Category Background
This subsection provides background on the Textiles Category including a brief
industry profile of the textiles industry and background on 40 CFR Part 410.
18.1.1
Textiles Industry Profile
The Textiles Category includes facilities that manufacture and process textile
materials, such as carpets, broad woven fabrics, and knitwear. It also includes facilities using wet
processes, such as scouring, dyeing, finishing, printing, and coating, that discharge contact
wastewater. These facilities are classified under SIC major group 22: Textile Mill Products.
EPA is considering adding three SIC codes from major group 23: Apparel and Other Finished
Products Made from Fabrics and Other Similar Materials as potential new subcategories of the
Textiles Category, as discussed in Section 18.4. Table 18-1 lists the SIC major groups with
operations in the Textiles Category.
Table 18-1. Number of Facilities in Textiles SIC Major Groups
SIC Major Group
22: Textile Mill Products
2002 U.S.
Economic
Census
14,519
2002 PCS3
145
2002 TRIb
284
2003 TRIb
289
Potential New Subcategories
23 : Apparel and Other Finished Products Made
from Fabrics and Other Similar Materials
27,295
0
16
16
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); PCSLoads2002_v2; TRIReleases2002_v2;
TRIReleases2003_v2.
"Major and minor dischargers.
bReleases to any media.
18-1
-------
Section 18.0 - Textile Mills
Textile manufacturers discharge directly to surface water as well as to POTWs.
Table 18-2 presents the types of discharges reported by facilities in the 2002 TRI database. The
majority of mills reporting to TRI reported no water discharges, but facilities may be discharging
pollutants in wastewater at levels below the TRI-reporting threshold.
Table 18-2. Textiles Category Facilities by Type of Discharge Reported in TRI 2002
SIC Major Group
22: Textile Mill Products
Reported Only
Direct Discharges
15
Reported
Only Indirect
Discharges
64
Reported Both
Direct and Indirect
Discharges
8
Reported No
Water
Discharges
183
Potential New Subcategories
23 : Apparel and Other
Finished Products Made
from Fabrics and Other
Similar Materials
1
4
0
11
Source: TRIReleases2002 v4.
18.1.2
40 CFR Part 410
EPA first promulgated ELGs for the Textiles Category (40 CFR Part 410) on
September 2, 1982 (47 FR 38819). There are nine subcategories, all of which have BPT, BAT,
and NSPS limitations. Some subcategories also have PSES and PSNS limitations. Table 18-3
lists the nine subcategories, their related SIC codes, and applicability. Table 18-4 lists the
regulated pollutants for the subcategories. Section 5.4.5 of the 2004 TSD provides more
information on the regulatory background for the Textiles Category (U.S. EPA, 2004).
18-2
-------
Section 18.0 - Textile Mills
Table 18-3. Applicability of Subcategories in the Textiles Category
Subpart
A
B
C
D
E
F
G
H
I
Subpart Name
Wool Scouring
Wool Finishing
Low Water Use
Processing
Woven Fabrics
Finishing
Knit Fabric
Finishing
Carpet Finishing
Stock & Yarn
Finishing
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
Subpart Applicability
Wool scouring, topmaking, and general cleaning of raw
wool
Wool finishers, including carbonizing, fulling, dyeing,
bleaching, rinsing, fireproofing, and other such similar
processes
Yarn manufacture, yarn texturizing, unfinished fabric
manufacture, fabric coating, fabric laminating, tire cord and
fabric dipping, and carpet tufting and carpet backing
Woven fabric finishers, which may include any or all of the
following unit operations: desizing, bleaching, mercerizing,
dyeing, printing, resin treatment, water proofing, flame
proofing, soil repellency application and a special finish
application
Knit fabric finishers, which may include any or all of the
following unit operations: bleaching, mercerizing, dyeing,
printing, resin treatment, water proofing, flame proofing,
soil repellency application and a special finish application
Carpet mills, which may include any or all of the following
unit operations: bleaching, scouring, carbonizing, fulling,
dyeing, printing, resin treatment, waterproofing,
flameproofmg, soil repellency, looping, and backing with
foamed and unfoamed latex and jute
Stock or yarn dyeing or finishing, which may include any or
all of the following unit operations and processes: cleaning,
scouring, bleaching, mercerizing, dyeing and special
finishing
Facilities that primarily manufacture nonwoven textile
products of wool, cotton, or synthetics, singly or as blends,
by mechanical, thermal, and/or adhesive bonding procedures
Facilities that primarily manufacture nonwoven products by
employing fulling and felting operations as a means of
achieving fiber bonding
Source: Textile Mills Point Source Category - 40 CFR 410', Development Document for Effluent
Limitations Guidelines and Standards for the Textile Mills Point Source Category (U.S. EPA, 1979).
18-3
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Section 18.0 - Textile Mills
Table 18-4. Pollutants Regulated by Existing Textiles ELGs
Subpart
A
B
C
D
E
F
G
H
I
Subcategory
Wool Scouring3
Wool Finishing3
Low Water Use
Processing
Woven Fabrics
Finishing3
Knit Fabric
Finishing3
Carpet Finishing3
Stock & Yarn
Finishing3
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
BOD5, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BOD5, COD, TSS, Sulfide,
Phenols, Total Chromium, pH
BOD5, 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
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
BOD5, COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
BOD5, COD, TSS,
Sulfide, Phenols, Total
Chromium, pH
Source: Textile Mills Point Source Category - 40 CFR Part 410.
3Subcategories with wet processing.
18-4
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Section 18.0 - Textile Mills
18.2 Textiles Category 2005 Annual Review
This subsection discusses EPA's 2005 annual review of the Textiles Category
including the screening-level review and category-specific review.
18.2.1 Textiles Category 2005 Screening-Level Review
Table 18-5 presents the Textiles Category TWPE, using TRIReleases2002_v2 and
PCSLoads2002_v2. Table 18-5 includes discharges from facilities in SIC codes EPA determined
are potential new subcategories of the Textiles Category. The estimated TWPE from
PCSLoads2002_v2 far exceeds the TWPE from TRIReleases2002_v2.
Table 18-5. Textiles Category 2005 Screening-Level Review Results
Point Source Category
Textiles Category
2002 PCS TWPEa
124,085
2002 TRI TWPEb
32,765
Total TWPE
156,850
Source: 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a); PCSLoads2002_v2; TRIReleases2002_v2.
"Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
18.2.2 Textiles Category 2005 Pollutants of Concern
Table 18-6 shows the top five pollutants with the highest TWPE in
TRIReleases2002_v2, as well as the top five pollutants with the highest TWPE in
PCSLoads2002_v2. Sulfide contributed 59 percent of the category PCS TWPE in 2002, while
chlorine contributed approximately 25 percent of the TRI TWPE in 2002.
18-5
-------
Section 18.0 - Textile Mills
Table 18-6. 2005 Annual Review: Textiles Category Pollutants of Concern
Pollutant
Sulfide
Chlorine
Arsenic
Toxaphene
Copper and Copper
Compounds
Sodium Nitrite
Chlorine Dioxide
Naphthalene
Textiles Category
Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
66
32
5
1
33
Total Pounds
Released
26,013
59,576
3,989
0.046
1,854
TWPE
72,874
30,334
16,123
1,393
1,177
Pollutants are not in the top five PCS 2002
reported pollutants.
74C
77,500,000
124,085
2002 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutant is not in the top five TRI 2002
reported pollutants.
4
25,316
12,890
Pollutants are not in the top five TRI
2002 reported pollutants.
10
2
1
1
90C
909
44,711
4,613
22,000
311,615
577
16,692
738
349
32,765
Source: PCSLoads2002_v2; TRIReleases2002_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
18.3
Potential New Subcategories for the Textiles Category
EPA reviewed industries with SIC codes not clearly subject to existing ELGs.
EPA concluded the processes, operations, wastewaters, and pollutants discharged by facilities in
the SIC codes listed in Table 18-7 are similar to those of the Textiles Category. These SIC codes
fall under the major SIC major group 23: Apparel and Other Finished Products Made from
Fabrics and Similar Materials. Some apparel manufacturing activities may be similar to textile
mill processes, such as bleaching, dyeing, printing, and other finish applications. Table 18-7
shows the total TRI and PCS combined TWPE for each SIC code that is a potential new
subcategory. As shown in the table, the discharges for the potential new subcategory SIC codes
contribute a negligible percentage to the total Textiles Category TWPE.
Table 18-7. Pollutant Loadings From Potential New Subcategories for the Textile Category
SIC Code
2322: Men's & Boys Underwear & Nightwear
2396: Automotive Trimmings, Apparel
2399: Fabricated Textile Products, NEC
2005 Annual Review
Combined TRI and PCS
TWPE
2.55
0.12
0.08
Percentage of Total
Category TWPE
0.002
O.001
O.001
Source: TRIReleases2002_v2; PCSLoads2002_v2.
NEC - Not elsewhere classified.
18-6
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Section 18.0 - Textile Mills
18.4
Textiles Category 2006 Annual Review
Following EPA's 2005 annual review, EPA continued to review the accuracy of
the data in the PCS and TRI databases for the Textiles Category. EPA obtained additional data
and identified changes in estimates of TWPE for sodium nitrite and chlorine.
18.4.1
Textiles Category TWF and POTW Percent Removal Revisions
As described in Table 4-1 in Section 4.2, during its 2006 annual review, EAD
revised the TWF and POTW percent removal values for sodium nitrite and the POTW percent
removal value for chlorine in the TRI and PCS databases to better reflect the pollutant's
properties. The TWF that EAD applies for sodium nitrite is now 0.0032 (formerly 0.373), and
the POTW percent removal is now 90 percent (formerly 1.95 percent). The POTW percent
removal that EAD applies for chlorine is now 100 percent (formerly 1.87 percent). Table 18-8
presents the loads before and after corrections to the sodium nitrite TWF and POTW percent
removal and the chlorine POTW percent removal for the Textiles Category.
Table 18-8. Impact of Changes to TWF and POTW Percent Removal for the Textiles
Category
Database
TRI 2002
TRI 2002
Pollutant
Sodium Nitrite
Chlorine
Number of Facilities
Reporting Discharges
2
4
TWPE from 2005
Review
16,692
12,890
TWPE from 2006
Review
2.96
552
Sources: TRIReleases2002 v2; TRIReleases2002 v4.
18.4.2
Textiles Category 2006 Screening-Level Review
The results of the 2006 screening-level review are the TRI and PCS rankings after
the revisions described in Section 4.2. This accounts for methodology changes described in
Section 4.2. For the Textiles Category, the most significant changes are also described in
Section 16.4.1. Table 18-9 shows the 2006 screening-level TWPE estimated for the Textiles
Category from the 2002 and 2003 TRI and 2002 PCS databases.
Table 18-9. Textiles Category 2006 Screening-Level Review Results
Point Source Category
Textiles
2002 PCS TWPEa
123,494
2002 TRI TWPEb
3,709
2003 TRI TWPEb
3,447
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
18.4.3
Textiles Category Pollutants of Concern
Table 18-10 presents the pollutants of concern for the Textiles Category based on
the 2006 annual review.
18-7
-------
Section 18.0 - Textile Mills
Table 18-10. 2006 Annual Review: Textiles Category Pollutants of Concern
Pollutant
Sulfide
Chlorine
Arsenic
Toxaphene
Copper and
Copper
Compounds
Chlorine Dioxide
Naphthalene
Chromium and
Chromium
Compounds
Textiles
Category Total
2002 PCS3
Number of
Facilities
Reporting
Pollutant
39
23
2
1
25
Total
Pounds
Released
26,013
59,576
3,989
0.046
1,854
TWPE
72,874
30,334
16,123
1,393
1,177
Pollutants are not in the top five PCS 2002
reported pollutants.
69C
77,497,564
123,494
2002 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
2003 TRIb
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutant is not in the top five TRI 2002 reported pollutants.
4
1,085
552
3
1,019
519
Pollutants are not in the top five TRI 2002 reported pollutants.
10
1
1
9
92C
909
4,613
22,000
4,464
243,597
577
738
349
338
3,709
11
1
1
9
92C
1,124
4,515
11,000
3,175
451,147
713
722
175
240
3,447
oo
I
oo
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
Discharges include only major dischargers.
bDischarges include transfers to POTWs and account for POTW removals.
°Number of facilities reporting TWPE greater than zero.
-------
Section 18.0 - Textile Mills
18.4.4
Textiles Category Sulfide Discharges
EPA reviewed the sulfide discharges from textile mills reporting to PCS in 2002.
Part 410 regulates discharges of sulfide from textile mills, and 39 textile mills report sulfide
discharges to PCS. Table 18-11 lists the 15 mills that contribute the most sulfide TWPE for the
category. Together, they account for 90 percent of the sulfide TWPE in PCS for textile mills.
Table 18-11. Top Facilities Reporting Sulfide Discharges in PCSLoads2002_v4
Facility Name
Mohawk Industries
Galey & Lord/Society Hill
Chargeurs Wool (USA), Inc.
Avondale Mills
Kenyon Industries
Eflex LLC Eflex WWTP
Cramerton Eagle Road
Gold Mills, Inc
King America Fishing
Rabun Apparel, Inc.
Westpoint Stevens
Plains Cotton Cooperative Association
Jockey International
Interface Fabrics Group Finish
Velcorex
Location
Lyerly, GA
Society Hill, SC
Jamestown, SC
Sylacauga, AL
Shannock, RI
Lawndale, NC
Cramerton, NC
Pine Grove, PA
Dover, GA
Rabun Gap, GA
Clemson, SC
New Braunfels, TX
Carlisle, KY
East Douglas, MA
Orangeburg, SC
2002
Flow
(MGY)
569
1,371
75
535
129
48
371
132
476
505
635
128
58
65
218
Pounds of
Sulfide
4,841
3,837
3,300
1,699
1,604
1,511
1,293
1,141
901
765
690
545
530
421
314
Sulfide
TWPE
13,561
10,749
9,245
4,761
4,493
4,233
3,622
3,197
2,525
2,143
1,933
1,526
1,486
1,180
880
Source: PCSLoads2002_v4.
For the four facilities with the largest sulfide discharges, EPA obtained detailed
PCS data, including concentrations, for 2002 to 2006. Together, these four facilities account for
more than 50 percent of the category's sulfide TWPE. Table 18-12 lists EPA's findings from
PCS concentration data. Concentration data were available for two of these four facilities. One
mill reported detecting sulfide in 8 of 14 samples (57 percent). The other mill reported detecting
sulfide in 8 of 48 samples (17 percent).
18-9
-------
Section 18.0 - Textile Mills
Table 18-12. Concentration Data Available for Top Four Facilities Reporting Sulfide
Discharges in PCSLoads2002 for the Textiles Category
Facility Name
Mohawk Industries
Galey&
Lord/Society Hill
Chargeurs Wool
(USA), Inc.
Avondale Mills
Location
Lyerly, GA
Society Hill, SC
Jamestown, SC
Sylacauga, AL
Date Range
9/30/02-1/31/06
5/31/02-2/28/06
12/31/02-1/31/05
4/30/02-1/31/06
Concentration Data Summary
Range
(mg/L)
NAa
O.038-2.1
<1.0-6
NAa
Number
Detected
NAa
8
7
NAa
Total Number
Data Points
NAa
48
14
NAa
Source: Envirofacts; PCSLoads2002_v4.
aOnly quantity data are available in PCS.
NA - Not available.
18.4.5
Textiles Category Chlorine Discharges
EPA reviewed the chlorine discharges from textile mills reporting to PCS in 2002.
Part 410 does not regulate discharges of chlorine from textile mills; however, 32 textile mills
report chlorine discharges to PCS (9 report discharges greater than zero). Table 18-13 lists the
23 mills with chlorine discharges greater than zero in PCSLoads2002_v4. One facility,
Burlington Industries in Cordova, NC, accounts for 87 percent of the category chlorine TWPE.
EPA obtained detailed PCS data for the Burlington Industries Cordova, NC mill,
as well as its NPDES permit (NCDENR, 2004). Table 18-14 summarizes the chlorine
concentrations, as reported in PCS for 2002, and the chlorine limitations in the Burlington
permit. The chlorine concentrations appear to be misreported as mg/L for certain months,
instead of ug/L, which is a consistent pattern for data from the years 2000 through 2005. As a
result, EPA will verify these chlorine discharges as part of its 2007 review of industrial
discharges with existing regulations and correct the PCS database accordingly. Also, the
permitted chlorine limitation of 28 ug/L is a daily maximum value that took effect in March
2006, and the facility's current discharges of chlorine are likely lower than the values for 2002
summarized in Table 18-14.
18-10
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Section 18.0 - Textile Mills
Table 18-13. Facilities With Largest Chlorine Discharges in PCSLoads2002_v4
Facility Name
Burlington Industries Richmond
Pharr Yarns Inc.
Cramerton Eagle Road WWTP
Interface Fabrics Group S Inc. IF
Springs Industries/Grace Complex
Burlington Industries LCC
Spring Industries, Inc.
Glen Touch Yarn Company LLC
Rabun Apparel, Inc.
Chargeurs Wool (USA) Inc.
Westpoint Stevens/Clemson Plant
Dan River Inc. - Schoolfield
Lees Carpets
Mohawk Industries/Rocky River Plant
BBA Fiberweb/Bethune
Burlington Industries BM
West Pt Stevens Inc Wagram Plant
Deroyal Textiles
Kawashima Textile USA Inc.
Guilford Mills Inc. Gulford E Mills
Schneider Mills Inc. Schneider Mills
Cone Mills Corp. Cliffside Plant
CCX Fiberglass Products Division
Location
Cordova, NC
McAdenville, NC
Cramerton, NC
Elkin, NC
Lancaster, SC
Hurt, VA
Griffin, GA
Altamahaw, NC
Rabun Gap, GA
Jamestown, SC
Clemson, SC
Danville, VA
Glasgow, VA
Calhoun Falls, SC
Bethune, SC
Clarksville, VA
Wagram, VA
Camden, NC
Lugoff, SC
Kenansville, SC
Taylorsville, NC
Cliffside, NC
Walterboro, SC
Pounds of
Chlorine
51,606
1,679
1,575
1,267
785
671
486
401
253
192
181
177
89
67
64
28
21
15
14
2
2
1
1
Chlorine
TWPE
26,276
855
802
645
400
342
247
204
129
98
92
90
45
34
33
14
11
8
7
1
1
0
0
Source: PCSLoads2002 v4.
18-11
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Section 18.0 - Textile Mills
Table 18-14. Chlorine Limitations and PCS Concentration Data for Burlington Industries
Cordova, NC Textile Mill
Outfall
001:
Wastewater
treatment
plant
effluent
002:
Cooling
water
Chlorine
Limit (ug/L)
28 (Daily
Maximum,
Effective
March 2006)
28 (Daily
Maximum,
Effective
March 2006)
Flow Limit
(MGD)
1.2
Monitoring
Only
Concentrations As Reported in PCS
Mean
73.3
56.7
66.7
74.3
64.3
68.3
62.7
65.8
50.8
52.7
54.2
50.8
20.0
10.0
20.0
40.0
20.0
20.0
20.0
20.0
30.0
20.0
20.0
10.0
Minimum
40
40
60
60
40
60
40
50
30
40
50
40
20
10
20
40
20
20
20
20
30
20
20
10
Maximum
80
80
80
80
80
80
80
80
80
70
60
60
20
10
20
40
20
20
20
20
30
20
20
10
Units in
PCS
mg/L
ug/L
mg/L
ug/L
mg/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
Date
1/31/2002
2/28/2002
3/31/2002
4/30/2002
5/31/2002
6/30/2002
7/31/2002
8/31/2002
9/30/2002
10/31/2002
11/30/2002
12/31/2002
1/31/2002
2/28/2002
3/31/2002
4/30/2002
5/31/2002
6/30/2002
7/31/2002
8/31/2002
9/30/2002
10/31/2002
11/30/2002
12/31/2002
Source: Envirofacts; Permit to Discharge Wastewater Under the National Pollution Discharge Elimination System
NPDES NC0043320 - Burlington Industries, Inc., Cordova, NC (NCDENR, 2004).
18-12
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Section 18.0 - Textile Mills
18.5 Textiles Category Conclusions
• The Textiles Category was selected for additional review because of high
TWPE in the PCS databases.
• Discharges of sulfide account for 59 percent of the category PCS TWPE.
EPA reviewed PCS concentration data for sulfide discharges from the four
textile mills with the highest TWPE, but only two had concentration data
available. At these two mills, the data show concentrations ranging from
levels below laboratory detection limits to 6 mg/L. For PCS data from
2002 to 2005, sulfide was detected above sample detection limits only 57
and 17 percent of the time.
• Discharges of chlorine account for 25 percent of the category PCS TWPE,
and one facility accounts for 87 percent of the category chlorine TWPE:
Burlington Industries in Cordova, NC. EPA reviewed the Burlington
facility's permit and detailed PCS data and identified a likely error in the
units in which chlorine concentrations are reported in PCS.
• EPA had incomplete data available for a full analysis. Specifically,
further EPA review of this category will include acquiring additional
concentration data from PCS for sulfide discharges, reviewing sulfide
permit limitations, comparing current discharge concentrations and
production-normalized loads, and considering if additional wastewater
treatment would control sulfide discharges.
18.6 Textiles Category References
NCDENR. 2004. North Carolina Department of Environment and Natural Resources. Permit to
Discharge Wastewater Under the National Pollution Discharge Elimination System NPDES
NC0043320 - Burlington Industries, Inc., Cordova, NC. Raleigh, NC. (August 9). DCN 03980.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U.S. EPA. 1979. Development Document for Effluent Limitations Guidelines and Standards for
the Textile Mills Point Source Category. EPA-440/l-79/022b. Washington, DC.
U.S. EPA. 1996. Preliminary Study of the Textile Mills Category. Washington, DC. EPA-HQ-
OW-2003-0074-0616. DCN 00484.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
18-13
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Section 18.0 - Textile Mills
Categories for Effluent Limitations and Standards. EPA-821-B-05-003. Washington, DC.
(August). DCN02173.
U.S. EPA. 2005b. Preliminary Review of Prioritized Categories of Industrial Discharger?,.
EPA-821-B-05-004. Washington, DC. (August). DCN 02175.
18-14
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Part III - Review of Industrial Discharges
PART III: REVIEW OF INDUSTRIAL DISCHARGES
NOT COVERED BY CATEGORICAL REGULATIONS
in
-------
Section 19.0 - Review of Indirect Dischargers
19.0
REVIEW OF INDIRECT DISCHARGERS WITHOUT CATEGORICAL PRETREATMENT
STANDARDS TO IDENTIFY POTENTIAL NEW CATEGORIES FOR PRETREATMENT
STANDARDS
To identify candidates for categorical pretreatment standards under CWA sections
304(g) and 307(b), EPA reviewed eight industries that are composed entirely or almost entirely
of indirect discharge facilities and that are not currently subject to categorical pretreatment
standards. Table 19-1 lists the industries EPA reviewed (in alphabetical order), which were
identified using stakeholder comments and pollutant discharge information.
Table 19-1. Industries Included in EPA's 2006 Review of Possible New Candidates for
Categorical Pretreatment Standards
No.
1.
2.
3.
4.
5.
6.
7.
8.
Industry
Food Service Establishments
Health Services Industry
Independent and Stand-Alone Laboratories
Industrial Container and Drum Cleaning
Industrial Laundries
Photoprocessing
Printing and Publishing
Tobacco Products
19.1
Overview of EPA's 2006 Review of Possible New Candidates for Categorical
Pretreatment Standards
As noted in 40 CFR §403.2, the three principal objectives of the National
Pretreatment Program are to: (1) prevent the wide-scale introduction of pollutants into POTWs
that will interfere with POTW operations, including use or disposal of municipal sludge; (2)
prevent the introduction of pollutants into POTWs that will pass through the treatment works or
will otherwise be incompatible with the treatment works; and (3) improve opportunities to
recycle and reclaim municipal and industrial wastewaters and sludges (U.S. EPA, 1999).
All indirect dischargers are subject to general pretreatment standards (40 CFR
403), which includes a prohibition on discharges causing pass through or interference. See 40
CFR 403.5. The general pretreatment standards are implemented in the form of local limits
developed either by POTWs with approved pretreatment programs, or POTWS that have
experienced interference or pass through. In the United States, there are approximately 1,500
POTWs with approved pretreatment programs and 13,500 small POTWs that are not required to
develop and implement pretreatment programs.
In addition, EPA establishes technology-based national regulations, termed
"categorical pretreatment standards," for categories of industries discharging pollutants to
POTWs that may pass through, interfere with or otherwise be incompatible with POTW
operations. These are analogous to effluent limitations guidelines for direct dischargers.
Generally, categorical pretreatment standards are designed such that wastewaters from direct and
19-1
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Section 19.0 - Review of Indirect Dischargers
indirect industrial dischargers are subject to similar levels of treatment. To date, EPA has
promulgated such categorical pretreatment standards for 35 industrial categories.
The CWA also establishes review requirements for categorical pretreatment
standards. Section 307(b) requires EPA to revise its categorical pretreatment standards for
indirect dischargers "from time to time, as control technology, processes, operating methods, or
other alternatives change." Section 304(g) requires EPA to annually review these categorical
pretreatment standards and revise them "if appropriate."Although section 307(b) only requires
EPA to review existing categorical pretreatment standards "from time to time," section 304(g)
requires an annual review. Therefore, EPA meets its 304(g) and 307(b) review requirements by
reviewing all industrial categories subject to existing categorical pretreatment standards on an
annual basis to identify potential candidates for revision. EPA conducts its annual review of
existing categorical pretreatment standards concurrent with its review of existing effluent
guidelines. These reviews are detailed in Sections 5.0-18.0 of this TSD.
Finally, the CWA also requires EPA to promulgate pretreatment standards for
categories of dischargers that discharge pollutants not susceptible to treatment by POTWs or that
would interfere with the operation of POTWs. However, it does not provide a timing
requirement for the promulgation of such new pretreatment standards. EPA, in its discretion,
periodically evaluates indirect dischargers not subject to categorical pretreatment standards to
identify potential candidates for new pretreatment standards.
The remainder of this section discusses and provides results of EPA's evaluation
of categories of indirect dischargers not currently subject to categorical pretreatment standards.
19.2 EPA's Evaluation of "Pass Through Potential" of Toxic and
Nonconventional Pollutants through POTW Operations
Categorical pretreatment standards are designed to prevent the discharge of
pollutants that "interfere with, pass through, or otherwise [are] incompatible with" the operation
of POTWs. See33U.S.C.§ 1371(b)(l). In establishing pretreatment standards, Congress had
two objectives: (1) that standards for indirect dischargers be equivalent to standards for direct
dischargers, and (2) that the treatment capability and performance of POTWs be recognized and
taken into account in regulating the discharge of pollutants from indirect dischargers. EPA's
approach in establishing categorical pretreatment standards is consistent with both objectives.
Historically, for most categorical pretreatment standard rulemakings, EPA
determines the "pass through potential" by comparing the percentage of the pollutant removed by
well-operated POTWs achieving secondary treatment with the percentage of the pollutant
removed by wastewater treatment options that EPA is evaluating as the bases for categorical
pretreatment standards. See 46 FR 9408 (January 28, 1981). ). If the median percentage
removed by well-operated POTWs is less than the median percentage removed by direct
discharging facilities using BAT, then EPA generally deems the pollutant to "pass through" and
develops pretreatment standards for facilities that indirectly discharge the pollutant.
19-2
-------
Section 19.0 - Review of Indirect Dischargers
For some of the industries evaluated in this review (i.e., ICDC and Tobacco
Products industries), EPA evaluated pass through potential using the traditional method
mentioned above. Specifically, EPA compared each industry's "current loadings" to the
"potential post-regulatory loadings." Current loadings are the pollutant loadings discharged to
surface waters, accounting for POTW removals. Potential post-regulatory loadings are the
pollutant loadings that would be discharged to surface waters upon compliance with pretreatment
standards based on the BAT. EPA relied on wastewater sampling data and site visits to
characterize the toxic pollutant discharges from both industries. Sections 19.5 and 19.9 discuss
EPA's data collection and analyses in more detail.
However, for the remaining six categories, EPA was unable to gather the data
needed for a comprehensive analysis of the availability and performance (e.g., percentage of the
pollutants removed) of treatment or process technologies that might reduce toxic pollutant
discharges beyond that of technologies already in place at these facilities. Instead, EPA evaluated
the "pass through potential" as measured by the total annual TWPE discharged by the industrial
sector and the average TWPE discharge among facilities that discharge to POTWs. EPA relied
on data from TRI, PCS, state pretreatment programs, industry trade groups, and contacts made to
facilities to characterize toxic pollutant discharges from these six industries.
EPA relied on a similar evaluation of pass through potential in its prior decision
not to promulgate national categorical pretreatment standards for the Industrial Laundries
industry. See August 18, 1999 (64 FR 45071). EPA noted in this 1999 final action that, "While
EPA has broad discretion to promulgate such [national categorical pretreatment] standards, EPA
retains discretion not to do so where the total pounds removed do not warrant national regulation
and there is not a significant concern with pass through and interference at the POTW." See 64
FR 45077 (August 18, 1999).
EPA solicited comment on this evaluation for determining the "pass through
potential" for industrial categories comprised entirely or nearly entirely of indirect dischargers.
See 70, FR 51054 (August 29, 2005). In response to this solicitation, EPA only received two
comments on this methodology and both comments were supportive of EPA's approach (see
OW-2004-0032-1042, 1051).
19.3 EPA's Evaluation of "Interference Potential" of Industrial Indirect
Discharges
For each of the eight industries in this review, EPA evaluated the "interference
potential" of the indirect industrial discharges. The term "interference" means a discharge
which, alone or in conjunction with a discharge or discharges from other sources: (1) inhibits or
disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal;
and (2) therefore is a cause of a violation of any requirement of the POTWs NPDES permit
(including an increase in the magnitude or duration of a violation) or of the prevention of sewage
sludge use or disposal in compliance with applicable regulations or permits. See 40 CFR
403.3(i). To determine the interference potential, EPA generally evaluates the industrial indirect
discharges in terms of: (1) the compatibility of industrial wastewaters and domestic wastewaters
(e.g., type of pollutants discharged in industrial wastewaters compared to pollutants typically
found in domestic wastewaters); (2) concentrations of pollutants discharged in industrial
19-3
-------
Section 19.0 - Review of Indirect Dischargers
wastewaters that might cause interference with the POTW collection system (e.g., fats, oil, and
grease (FOG) discharges causing blockages in the POTW collection system, hydrogen sulfide
corrosion in the POTW collection system), the POTW treatment system (e.g., high ammonia
mass discharges inhibiting the POTW treatment system, high oil and grease mass discharges can
also promote the growth of filamentous bacteria that inhibit the performance of POTWs using
trickling filters), or biosolids disposal options; and (3) the potential for variable pollutant
loadings to cause interference with POTW operations (e.g., batch discharges or slug loadings
from industrial facilities interfering with normal POTW operations).
EPA relied on readily available information from the literature and stakeholders
to evaluate the severity, duration, and frequency of interference incidents caused by industrial
indirect discharges. As part of its evaluation, EPA reviewed data from its report to Congress on
one type of interference incidents, blockages in the POTW collection system leading to
combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs) (U.S. EPA, 2004b).
EPA received comments from stakeholders during its review indicating that even
with current authority provided in the general pretreatment regulations, some POTWs have
difficulty controlling interference from some categories of indirect industrial dischargers (see
OW-2004-0032-0020, 1090). EPA notes, however, that to a large extent, interference problems
vary from POTW to POTW. Pollutants that interfere with the operation of one POTW may not
adversely affect the operation of another. These differences are attributable to several factors
including the varying sensitivities of different POTWs and the constituent composition of
wastewater collected and treated by the POTW. See 46 FR 9406 (January 28, 1981).
EPA also notes that the national pretreatment program already provides the
necessary regulatory tools and authority to local pretreatment programs for controlling
interference problems - e.g., categorical pretreatment standards (40 CFR Parts 405-471) and
general pretreatment standards (40 CFR 403). Under the provisions of Part 403.5(c)(l) & (2), in
defined circumstances, a POTW must establish specific local limits for industrial users to guard
against interference with the operation of the municipal treatment works. See 46 FR 9406
(January 28, 1981). Consequently, pretreatment programs must correct interference incidents
with enforcement and oversight activities. The interference incidents identified by commenters
do not necessarily indicate the need for additional categorical pretreatment standards, but they
may indicate the need for additional oversight and enforcement.
19.4 Category-Specific Evaluations
Stakeholder comments and pollutant discharge information have helped EPA to
identify industries that are composed entirely or nearly entirely of indirect dischargers. EPA has
grouped these industries into the following eight possible new categories: Food Service
Establishments; Industrial Laundries; Photoprocessing; Printing and Publishing; Independent and
Stand-Alone Laboratories; Industrial Container and Drum Cleaning; Tobacco Products, and
Health Services Industry. EPA is including within the Health Services Industry the following
activities: Independent and Stand Alone Medical and Dental Laboratories, Offices and Clinics of
Doctors of Medicine, Offices and Clinics of Dentists, Nursing and Personal Care Facilities,
Veterinary Care Services, and Hospitals and Clinics. Data sources for these reviews include
19-4
-------
Section 19.0 - Review of Indirect Dischargers
TRI, PCS16, EPA reports and studies, periodicals and textbooks, EPA pretreatment coordinators
and permitting authorities, and industry-supplied information. The following sections (19.5
through 19.12) summarize the information obtained for each industry reviewed. Table 19-2
below summarizes EPA's conclusions for each industry reviewed and provides the sources of
detailed discussions of the industry reviews.
19.5 Food Service Establishments
Food service establishments include facilities that prepare meals, snacks, and
beverages to customer order for immediate on-premises and off-premises consumption. EPA
reviewed wastewater discharges from the Food Service Establishments industry because of
comments received in response to the 2004 Final Plan and the Preliminary 2006 Plan. This
section briefly discusses EPA's findings on the Food Service Establishments industry.
19.5.1 Comments Received
In response to the 2004 Plan, the Metropolitan Council Environmental Services
(MCES) raised concerns about the interferences caused by FOG discharges from food service
establishments (OW-2003-0074-0670), and the NRDC included food service establishments in a
list of industries that it believes meet the criteria of Section 304(m)(l)(B) and therefore should
have been identified for an effluent guidelines rulemaking (OW-2003-0074-0733). In response
to the 2006 Preliminary Plan, two POTWs and the National Association of Clean Water
Agencies (NACWA) submitted comments that categorical pretreatment standards are not
necessary for the Food Service Establishments industry (OW-2004-0032-1042, 1086, 1078,
1093).
19.5.2 Industry Profile
Food Service Establishments include facilities in SIC codes 5812, Eating Places,
and 5813, Drinking Places. Of the approximately 509,000 food service establishments
(approximately 460,000 eating places and 48,900 drinking places) in the United States, only 57
reported discharges to PCS in 2000 (all minor dischargers). The direct discharge facilities in the
2000 PCS represent 0.01 percent of the industry, supporting the likelihood that most food
establishments are indirect dischargers. No food establishments reported to TRI in 2000
(Matuszko, 2005a).
16 Although PCS only contains information for direct dischargers, this information can be useful in gaining some
understanding of the types of discharges from a particular industry.
19-5
-------
Section 19.0 - Review of Indirect Dischargers
Table 19-2. Summary of EPA's 2006 CWA Sections 304(g) and 307(b) Review
No.
1.
2.
3.
4.
5.
6.
7.
8.
Industry
Food Service
Establishments
Health Services
Industry
Independent and
Stand-Alone
Laboratories
Industrial
Container and
Drum Cleaning
Industrial
Laundries
Photoprocessing
Printing and
Publishing
Tobacco Products
Type of Pass
Through
Evaluation
Abbreviated
Abbreviated
Abbreviated
Traditional
Abbreviated
Abbreviated
Abbreviated
Traditional
Determination
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Not enough
information: Conduct
detailed study
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Low pass through
potential: Categorical
pretreatment standards
unwarranted
Section Including
Summarized
Industry Review
Information
Section 19.5
Section 19.6
Section 19.7
Section 19.8
Section 19.9
Section 19. 10
Section 19. 11
Section 19. 12
Source of Detailed
Information
DCN02103
DCN 02293
DCN 02101
DCN 03415
DCN 02 102
DCN 02096
DCN 02294
DCN 03 3 95
19-6
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Section 19.0 - Review of Indirect Dischargers
19.5.3 Wastewater Characteristics
Food establishments use water for food preparation (washing, cooking, drinking
water, ice, sinks), clean up (dishwashing, floor, and rack washing), sanitation (toilets), and
landscaping (irrigation, parking lot spraying, etc). Using an average wastewater flow range of 3
gallons per day per meal (Tchobanoglous, 1991) and an estimate that Americans eat close to
seven million meals per day from food service establishments (AFTS, 2004), EPA estimates that
the food service industry generates 21 MGD of wastewater nationally, not including toilet waste
(Matuszko, 2005a).
During this study, EPA could not locate nor did commenters provide a readily
available source of discharge data for food service establishments that discharge to POTWs. No
TRI data are available regarding pollutants in treated wastewater from food service
establishments. As a result, EPA obtained data on food service establishments from
PCSLoads2000 v6. Because PCS data are for direct dischargers, they may or may not be
representative of indirect discharging facilities (particularly for conventional pollutants and/or
treatment chemicals such as chlorine). Nevertheless, the data provide some indication of the
level and types of pollutants that may be present in discharges from food service establishments.
From PCSLoads2000_v6, EPA estimates relatively low TWPE per facility (less than 1 TWPE
per year per facility). The pollutants discharged from the industry in the largest amounts, in
terms of TWPE, were total residual chlorine (TRC) (14 TWPE per year) and ammonia as
nitrogen (1.9 TWPE per year). Table 19-3 summarizes data on pollutant discharges reported
from food service establishments.
Table 19-3. Summary of Wastewater Discharges from the Food Service Establishments
Industry
Data Source
PCSLoads2000_v6
Total Annual TWPE
Before POTW
Removal
16
Number of Facilities
Reporting
57
Annual TWPE per
Facility Before POTW
Removal
<1
Source: PCSLoads2000_v6
19.5.4 Pass Through and Interference
Based on the available data on food service establishment wastewater
characteristics, EPA found that the total TWPE discharged from food service establishments to
POTWs is low (<1 TWPE/facility/year). Additionally, EPA expects the main toxic pollutants
identified in food service establishment wastewaters will not pass through POTWs because they
are typically removed through POTW treatment. For example, chlorine, the pollutant discharged
in the largest quantity, has a POTW pollutant removal efficiency of 100 percent. Therefore,
EPA's review of current information indicates that there is little to no pass through potential of
toxic and nonconventional pollutants from the Food Service Establishments.
EPA also collected data about discharges to POTWs through inquiries to EPA
Regional pretreatment coordinators and internet queries. These data sources show that FOG is
19-7
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Section 19.0 - Review of Indirect Dischargers
the predominant pollutant of concern for food service establishments. FOG discharges from the
food service industry can interfere with POTW operations by causing the following:
• Blockages in the POTW collection system leading to combined sewer
overflows (CSOs) and sanitary sewer overflows (SSOs) (U.S. EPA,
2004b);
• POTW treatment interference from Nocardia filamentous foaming; and
• Damage to collection systems from hydrogen sulfide generation (WEF,
2004).
Food service establishments generate FOG as byproducts from food preparation.
FOG captured on site is generally classified into two broad categories: yellow grease and grease
trap waste (Wiltsee, 1998). Yellow grease is derived from used cooking oil and waste greases
that are separated and collected at the point of use by the food service establishment.
Food service establishments can adopt a variety of best management practices
(BMPs) or install interceptor/collector devices to control and capture the FOG material before
discharge to the POTW collection system (ffiAC, 2004b; ASCE, 2004). For example, instead of
discharging yellow grease to POTWs, food service establishments usually accumulate this
material for re-sale or re-use in the manufacture of tallow, animal feed supplements, fuels, or
other products (U.S. EPA, 2004a).
Additionally, food service establishments can install interceptor/collector devices
(e.g., grease traps in sinks and dish washer drain lines) to accumulate grease on site and prevent
it from entering the POTW collection system. Proper design, installation, and maintenance
procedures are critical for these devices to control and capture the FOG (IRAC, 2004a; TDEC,
2002). For example, devices must allow emulsified FOG to cool and separate in a non-turbulent
environment (TDEC, 2002). Additionally, food service establishments must service their
interceptor/collector devices at regular intervals (Wiltsee, 1998; Engle, 2005a; Engle, 2005b;
CAL FOG, 2004). The required maintenance frequency for interceptor/collector devices
"depends greatly on the amount of FOG a facility generates as well as any best management
practices (BMPs) that reduce the FOG discharged into its sanitary sewer system. In many cases,
an establishment that implements BMPs will realize financial benefit through a reduction in their
required grease interceptor and trap maintenance frequency" (WEF, 2004). The annual
production of collected grease trap waste and uncollected grease entering sewage treatment
plants can be significant and ranges from 800 to 17,000 pounds/year per restaurant (Wiltsee,
1998).
Information collected from control authorities and stakeholders indicate that a
growing number of control authorities are using their existing authority (e.g., local limits to
implement general pretreatment standards in Part 403) to establish and enforce more FOG
regulatory controls (e.g., numeric pretreatment limits, best management practices including the
use of interceptor/collector devices) for food service establishments to reduce interferences with
POTW operations. For example, since identifying a 73% non-compliance rate with its grease
trap ordinance among restaurants, New York City instituted a $l,000-per-day fine for FOG
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Section 19.0 - Review of Indirect Dischargers
violations (Engle, 2005a). Other municipal wastewater authorities address FOG discharges, "by
imposing mandatory measures of assorted kinds, including inspections, periodic grease pumping,
stiff penalties, and even criminal citations for violators, along with 'strong waste' monthly
surcharges added to restaurant sewer bills. Surcharges are reportedly ranging from $100 to as
high as $700 and more, the fees being deemed necessary to cover the cost of inspections and
upgraded infrastructure" (Engle, 2005a). Pretreatment programs also develop and use inspection
checklists for both food service establishments and municipal pretreatment inspectors to control
FOG discharges (IRAC, 2004b).
Additionally, EPA identified typical numeric local limits controlling oil and
grease in the range of 50 mg/L to 450 mg/L with 100 mg/L as the most common reported
numeric pretreatment limit (LaDuca, 2001). Finally, EPA expects that blockages from FOG
discharges will decrease as utilities incorporate Capacity, Management, Operations, and
Maintenance (CMOM)17 program activities into their daily practices. Collection system owners
or operators that adopt CMOM program activities are likely to reduce the occurrence of sewer
overflows, improve their operations, and maintain compliance with their NPDES permit (U.S.
EPA, 2005a).
Current information indicates that although FOG may present some interference
potential, local outreach and regulatory controls can address FOG sufficiently. EPA also notes
that under the provisions of Part 403.5(c)(l) & (2), in defined circumstances, a POTW must
correct interference incidents with enforcement and oversight activities.
19.5.5 Findings of EPA's Review of the Food Services Establishments Industry
Based on the available information, EPA found that there was low potential for
pass through of toxic and non-conventional pollutants from food service establishments (as
measured by hazard per facility). In addition, interference from conventional-type pollutants can
be adequately addressed by local limits established to implement the general pretreatment
standards under Part 403 and enforcement of those limits. For these reasons, EPA concludes that
development of categorical pretreatment standards for food service establishments is not
warranted at this time.
19.6 Health Services Industry
The Health Services Industry includes establishments engaged in various aspects
of human health (e.g. hospitals, dentists, medical/dental laboratories) and animal health (e.g.
veterinarians). EPA reviewed wastewater discharges from the Health Services Industry in
response to comments made on the 2004 Final Plan and the 2006 Preliminary Plan. This section
briefly discusses EPA's current findings on the Health Services Industry.
19.6.1 Comments Received
In response to the 2004 Plan, MCES raised concerns about mercury discharges
from dental facilities and suggested that EPA provide guidance regarding amalgam separator
17 EPA has provided guidance to owners/operators of sanitary sewer collection systems through CMOM program
guidelines to reduce sanitary sewer overflows (SSOs) (U.S. EPA, 2005a).
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Section 19.0 - Review of Indirect Dischargers
programs (OW-2003-0074-0670). NRDC included dental facilities in a list of industries that it
believes meet the criteria of Section 304(m)(l)(B) and therefore should have been identified for
an effluent guidelines rulemaking (OW-2003-0074-0733)18. EPA also received stakeholder
comments in response to the 2006 Preliminary Plan. King County Wastewater Treatment
Division, Hampton Roads Sanitation District, and NACWA indicated that discharges from the
Health Services Industry are sufficiently controlled by local limits and general pretreatment
standards (OW-2004-0032-1042, 1086, and 1093); Washington State Department of Ecology
indicated that categorical pretreatment standards are necessary to control discharges from dental
facilities (OW-2004-0032-1036); and Arkansas Department of Environmental Quality
recommended that EPA study hospitals and dental facilities, with particular focus on emerging
pollutants of concern, and laboratory and pharmaceutical "exotics" (OW-2004-0032-0678).
19.6.2 Industry Profile
Health services establishments fall under SIC Major Group 80 Health Services
and Industry Group 074 Veterinary Services. According to the 2002 Census, there are over
475,000 facilities in the Health Services Industry (Mott and Kaplan, 2005). For this study, EPA
included within the Health Services Industry the following six industrial sectors: independent
and stand-alone medical and dental laboratories, offices and clinics of doctors of medicine,
offices and clinics of dentists, nursing and personal care facilities, veterinary care services, and
hospitals and clinics. EPA included medical and dental laboratories in its review of the Health
Services Industry, and not in its review of the Independent and Stand-Alone Laboratories
industry (discussed in Section 19.7), because medical and dental laboratories have similar
wastewater characteristics as hospitals and dental facilities. Additionally, medical and dental
laboratories are often co-located with hospitals and dental facilities.
All six industrial sectors require services to be delivered by trained professionals
for the purpose of providing health care and social assistance for individuals. These entities may
be free standing and perhaps privately owned or may be part of a hospital or health system. The
services can include diagnostic, preventative, cosmetic, and curative health services.
In 1976, EPA promulgated 40 CFR Part 460 which only applies to effluent
discharges to surface water from hospitals with greater than 1,000 occupied beds. 40 CFR Part
460 did not establish pretreatment standards for indirect discharging facilities.
Nearly all facilities within the Health Services Industry are indirect dischargers
(i.e., no discharge data reported in PCS) and few facilities report to TRI (only Federal facilities
in the healthcare industry are required to report to TRI) (U.S. EPA, 2005b). For 2002, PCS only
has data for two facilities which are considered "major" sources of pollutants.
19.6.3 Wastewater Characteristics
EPA obtained relatively little information on the pollutant discharges from the
Health Services Industry during its screening-level reviews because TRI and PCS data for this
industry are sparse. In 1989, EPA published a Preliminary Data Summary (PDS) for the
18 EPA did not identify this industry as a potential new category under section 304(m)(l)(B), as that provision
applies only to direct discharging industries subject to effluent guidelines - not to indirect dischargers.
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Section 19.0 - Review of Indirect Dischargers
Hospitals Point Source Category (U.S. EPA, 1989). Also, EPA's Office of Enforcement and
Compliance Assistance (OECA) published a Healthcare Sector Notebook in 2005 (U.S. EPA,
2005b). In addition, for some portions of this industry such as dental facilities, industry and
POTWs have conducted studies to estimate discharges (Stone, 2004). The memorandum
entitled, "Industry Sectors Being Evaluated under Proposed 'Health Services Industry'
Category" includes a detailed examination of the type of operations performed, pollutants and
wastewaters generated, and available pollution prevention and treatment options for the Health
Services Industry (Johnston, 2005a). This section provides a summary of EPA's findings on the
wastewater characteristics of the Health Services Industry.
Based on preliminary information, the major pollutants of concern in discharges
from health care service establishments include mercury, silver, pharmaceuticals, endocrine-
disrupting compounds, and biohazards (U.S. EPA, 2005b). The majority of the silver originates
from silver-based photographic materials used in photograph and X-ray processing, which may
be discharged in wastewaters from dental clinics and hospitals. The majority of the mercury
originates from the following sources: amalgam used in dental facilities; and medical equipment,
laboratory reagents, and cleaning supplies used in healthcare facilities. (Johnston, 2005a;
Johnston, 2005b) EPA found little to no quantitative information on wastewater discharges of
emerging pollutants of concern such as pharmaceuticals, EDCs and biohazards.
19.6.4 Pass Through and Interference Potential
POTW pollutant removal efficiencies for silver and mercury are relatively high
(88% and 90%, respectively), but EPA only has limited data on the amount of pollutant
discharges from the Health Services Industry and POTW removal efficiencies of other pollutants
of concern, including pharmaceuticals such as antibiotics, hormones, and endocrine-disrupting
compounds. As a result, EPA does not have enough information at this time to determine if the
pollutants discharged from the Health Services Industry are likely to pass through POTWs.
Based on limited data available, EPA did not identify any pollutants discharged
from the Health Services Industry that will interfere with the operations of POTWs. Hospital
laundry facilities discharge a certain amount of organic material, FOG, and an alternating range
of pH (alkaline detergent followed by an acidic sanitizer). Depending upon the processes
employed, the hospital laundry waste stream can have elevated temperatures and pH extremes
and can contain starch, particulate (including lint), proteins (blood products), detergents, and
oxidizers (bleach or other disinfectant). However, these laundry-related wastes are diluted by the
large volume of other hospital wastewater. The majority of hospital wastewater (77 percent)
results from cooling (53 percent) and domestic sewage (24 percent), which do not present
interference problems. Also, BOD and COD concentrations from hospital laundry wastewater
are usually in the normal range for domestic sewage (Johnston, 2005b).
19.6.5 Findings of EPA's CWA Sections 304(g) and 307(b) Review of the Health
Services Industry
EPA found that it does not have readily available information to make an
informed decision as to whether toxic and non-conventional discharges associated with the
health service industries pass through POTWs. For this reason, EPA plans to conduct a detailed
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study of this industry during the 2007-2008 review cycle. In this detailed study, EPA will
attempt to better quantify pollutant discharges in wastewater discharged by health service
facilities including endocrine-disrupting compounds. EPA will also investigate whether there are
technologies, process changes or pollution prevention alternatives that would significantly
reduce discharges to POTWs. Finally, EPA will attempt to evaluate the pass through and
interference potential of such discharges.
19.7 Independent and Stand-Alone Laboratories
Independent and stand-alone laboratories include facilities that conduct
commercial physical and biological research and laboratories that perform various types of
testing. EPA reviewed wastewater discharges from the Independent and Stand-Alone
Laboratories Industry in response to comments made on the 2004 Final Plan and the 2006
Preliminary Plan. This section briefly discusses EPA's findings on the Independent and Stand-
Alone Laboratories industry.
19.7.1 Comments Received
In response to the 2004 Plan, MCES commented that inspections of Independent
and Stand-Alone Laboratories indicate that the wastewater discharges do not warrant regulation
(OW-2003-0074-0670), and NRDC included independent and stand-alone laboratories in a list of
industries that it believes meet the criteria of Section 304(m)(l)(B) and therefore should have
been identified for an effluent guidelines rulemaking (OW-2003-0074-0733)19. EPA received no
stakeholder comments in response to the 2006 Preliminary Plan about the Independent and
Stand-Alone Laboratories industry.
19.7.2 Industry Profile
Independent and stand-alone laboratories are establishments classified under SIC
codes 8731 and 8734. Typical operations at independent and stand-alone laboratories include the
following: contract research in the healthcare, chemical, natural resources, energy, or
manufacturing industries (SIC code 8731); or commercial testing labs in the environmental,
material science, healthcare, industrial hygiene, food, and engineering sectors (SIC code 8734)
(e.g., forensic laboratories, pollution testing, hydrostatic testing, and radiation dosimetry). EPA
did not include medical and dental laboratories in its review of the Independent and Stand-Alone
Laboratories industry. EPA included these laboratories in its review of the Health Services
Industry, as described in Section 19.3, because medical and dental laboratories have similar
wastewater characteristics as hospitals and dental facilities and are often co-located with
hospitals and dental facilities.
According to the 2002 Census, SIC code 8731 included 9,173 facilities, and SIC
code 8734 included 5,488 facilities. Of these 14,661 independent and stand-alone laboratories,
only 0.5 percent (44 facilities) reported discharges to PCS in 2000 (7 major dischargers). Four
laboratories reported to TRI in 2000 (one reported direct-only discharges, one reported indirect-
19 EPA did not identify this industry as a potential new category under section 304(m)(l)(B), as that provision
applies only to direct discharging industries subject to effluent guidelines - not to indirect dischargers.
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Section 19.0 - Review of Indirect Dischargers
only discharges, one reported both direct and indirect discharges, and one reported no discharge)
(Matuszko, 2005b).
19.7.3 Wastewater Characteristics
Laboratory operations typically use low quantities of a wide variety of substances.
Operations are also highly variable. As a result, laboratories typically generate a small quantity
of a large variety of pollutants.
During this study, EPA could not locate nor did commenters provide a readily
available source of discharge data for independent and stand-alone laboratories that discharge to
POTWs. TRI contains information on only a single indirect discharging independent and stand
alone laboratory. As a result, EPA obtained data on independent and stand-alone laboratories
from PCSLoads2000 v6. Because PCS data are for direct dischargers, they may or may not be
representative of indirect discharging facilities (particularly for conventional pollutants and/or
treatment chemicals such as chlorine). Nevertheless, the data provide some indication of the
level and types of pollutants that may be present in discharges from independent and stand-alone
laboratories. From PCSLoads2000_v6, EPA estimates that for SIC codes 8731 and 8734, the
industry discharges approximately 34 TWPE and 1 TWPE per year per facility, respectively.
The average facility TWPE for SIC code 8731 is largely driven by four facilities that contribute
over 95% of the total SIC code 8731 TWPE. If these facilities are considered separately, the
average TWPE for facilities in SIC code 8731 is approximately less than 1 TWPE/year. The
median flow rate for independent and stand-alone laboratories in SIC code 8731 is 57 MGY.
The median flow rate for laboratories in SIC code 8734 is 36 MGY. Table 19-4 summarizes data
from PCSLoads2000 v6. EPA did not include TRI data in Table 19-4 because only three
laboratories had wastewater data in TRIReleases2000 v6 (a fourth laboratory had no reported
water discharges in the 2000 TRI).
Table 19-4. Summary of Wastewater Discharges from the Independent and Stand-Alone
Laboratories Industry
Data Source
PCSLoads2000_v6
Total Annual TWPE
Before POTW
Removal
1,200
Number of Facilities
Reporting
44
Annual TWPE per
Facility Before POTW
Removal
27
Source: PCSLoads2000_v6
From PCSLoads2000 v6, metals (iron, copper, lead, and silver) and chlorine are
the pollutants with the largest discharge in terms of TWPE. Iron is the pollutant with the largest
discharge, in terms of TWPE (68% of total TWPE).
19.7.4 Pass Through and Interference Potential
As indicated above, the main pollutants driving the TWPE reported to PCS in
2000 are metals and chlorine. POTW percent removals for these pollutants range from 77 (lead)
to 100% (chlorine). Accounting for treatment at the POTWs reduces the TWPE associated with
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Section 19.0 - Review of Indirect Dischargers
these pollutants substantially. For the industry, the average annual TWPE would be reduced to 5
TWPE per lab, and for SIC code 8731, it would be reduced to less than 10 TWPE per lab.
EPA did not locate nor did commenters provide any data relating to the
interferences from Independent and Stand-Alone Laboratory discharges.
19.7.5 Findings of EPA's CWA Sections 304(g) and 307(b) Review of the
Independent and Stand-Alone Laboratories Industry
Based on the available information, EPA concludes that overall the pass through
potential of toxic and non-conventional pollutants from independent and stand-alone laboratories
is low (as measured by hazard per facility). For these reasons, EPA concludes that development
of categorical pretreatment standards for independent and stand-alone laboratories is not
warranted at this time.
19.8 Industrial Container and Drum Cleaning
The Industrial Container and Drum Cleaning (ICDC) industry includes facilities
that clean and recondition metal and plastic drums and intermediate bulk containers for resale,
reuse, or disposal. EPA collected data and compiled a Preliminary Data Summary for Industrial
Container Drum Cleaning Facilities (PDS) in 2002 (U.S. EPA, 2002). The PDS identified
approximately 291 ICDC facilities, all of which discharge indirectly to a POTW.
19.8.1 Comments Received
The Metropolitan Sewer District of Greater Cincinnati (MSD) commented on
EPA's Preliminary 2004 and 2006 ELG Plans (OW-2003-0074-0741; OW-2004-0032-1051).
They recommended that EPA evaluate the need for ELGs for the drum reconditioning and tote
recycling industry. They explained that they had consistent compliance problems with all six
drum reconditioning facilities in their district. MSD commented that in discharges from this
industry they had found levels of mercury, petroleum oil and grease, pH and zinc that were
outside of the acceptable local limits. MSD also suggested that EPA's recent promulgation of
ELGs for the Transportation and Equipment Cleaning (TEC) industry changed the operating
procedures for the ICDC industry. They suggested that as a result of these changes totes and
drums are now more attractive shipping containers than tank trucks, because their discharges are
not controlled by an effluent guideline. Washington State Department of Ecology also
commented that the ICDC industry is an appropriate category to study.
19.8.2 Industry Profile
ICDC facilities often report under SIC code 7699: Repair Shops and Related
Services. However, SIC code 7699 encompasses a wide range of operations, of which drum
cleaning and reconditioning is only a small subset (U.S. EPA, 2002). As a result, data for SIC
code 7699 from TRI, PCS and the U.S. Economic Census are not representative of ICDC
facilities and, therefore, are not presented.
Operations at ICDC facilities are classified into three categories:
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Section 19.0 - Review of Indirect Dischargers
• Drum washing;
• Drum burning; and
• Intermediate Bulk Container cleaning/reconditioning.
Drums, which may be constructed of steel or plastic, typically contain oil and
petroleum, industrial chemicals, paint and ink, cleaning solvents, resins, adhesives, food, or
pesticides. Intermediate bulk containers may contain oil and petroleum, chemicals, or food.
Based on 1994 data, there are a total of 291 ICDC facilities in the U.S., of which
173 also clean transportation equipment (U.S. EPA, 2002). Additional information about the
ICDC industry is available from the Reusable Industrial Packaging Association (RIPA), a trade
association which represents the industrial container and reconditioning industry in North
America. The RIPA web page listed 92 reconditioner members as of 2004 (RIPA, 2004). Also,
according to RIPA, the majority of container reconditioners are small businesses as defined by
the SBA for SIC code 7699 (RIPA, 2000).
19.8.3 Wastewater Characteristics
Because neither the PCS nor TRI database contains any information specific to
discharging ICDC facilities, EPA used information from the 2002 PDS to characterize
wastewater generation and pollutants of concern and their concentrations in untreated ICDC
wastewaters. According to the 2002 PDS, the ICDC industry generates approximately 280 to 290
million gallons of wastewater per year. The greatest source of wastewater is rinse water. Other
sources include: interior preflushes and washes; spent cleaning solutions; exterior washwater;
leak testing wastewater; compressor condensate; boiler blowdown; acid washing emissions
scrubber water; and label removal.
EPA conducted site visits at three ICDC facilities in 2000 and analyzed
wastewater samples collected at these facilities. EPA also collected samples of untreated
wastewater (raw wastewater) from four steel drum reconditioning facilities in the 1980s. These
data are the basis for EPA's raw wastewater quality estimates for this industry. EPA did not
analyze any of the samples collected in the 1980's for dioxins20. However, EPA detected dioxins
in wastewater samples collected at all three facilities in 2000.
Using information provided in the PDS, EPA estimated the number of ICDC
facilities and how they manage their wastewater. These estimates are presented in Table 19-5.
20 The term dioxins used in this section refers to polychlorinated dibenzo-p-dioxins (CDDs) and polychlorinated
dibenzofurans (CDFs), a group of persistent, bioaccumulative, and toxic chemicals. The most toxic of this family of
compounds is 2,3,7,8-tetrachlrodibenzo-/>-dioxin, which is often referred to as 'dioxin.' However, there are 16 other
CDDs and CDFs compounds (called congeners) which, like TCDD, include chlorine substitution of hydrogen atoms
at the 2,3,7, and 8 positions on the benzene rings. In this section, EPA uses the term dioxins to refer to all 17 of the
2,3,7,8-substituted CDDs and CDFs.
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Section 19.0 - Review of Indirect Dischargers
Table 19-5. Estimated Number of ICDC Facilities, by Discharge and Treatment
Description
Total number of ICDC facilities
Do not discharge wastewater because they either completely reuse all wastewater
generated or they contract for off-site treatment and disposal.
Discharge to POTWs (total)
Discharge to POTWs (with pretreatment)
Discharge to POTWs (no pretreatment)
Number of Facilities
291
104
187
104
83
Using these assumptions about the number of ICDC facilities that discharge and
pretreat their wastewaters and sampling data summarized in the PDS, EPA estimated the amount
of pollutants discharged to POTWs and to receiving streams. As shown in Tables 19-5 and 19-6,
EPA estimated that 187 facilities discharge 28,445 TWPE to their POTWs, including 12,032
TWPE from dioxins. EPA further estimated that the POTWs remove more than 80% of the
discharged pollutants, so that baseline discharge for the entire ICDC industry to surface water is
approximately 5,000 TWPE. Dioxins account for about 40% (2,000 TWPE) and metals
(particularly lead) account for approximately 58% of the baseline load discharged to surface
water (Matuszko, 2006).
19.8.4 ICDC On-Site Wastewater Pretreatment
EPA's PDS reported that pretreatment used by ICDC facilities generally consists
of oil/water separation or chemical precipitation followed by air flotation (U.S. EPA, 2002).
Because EPA lacks effectiveness data for a wide range of pollutants for these treatment
technologies as applied to ICDC wastewaters, EPA used performance data from facilities in the
Transportation Equipment Cleaning (TEC) Category. EPA used data from TEC facilities that
employ technology equivalent to the basis for the PSES for the tank truck cleaning subcategory
(oil/water separation, chemical oxidation, neutralization, coagulation, clarification). EPA used
these data because ICDC wastewaters are similar to wastewaters from the TEC tank truck
subcategory and ICDC pretreatment is similar to TEC tank truck subcategory pretreatment (U.S.
EPA, 2002).
However, EPA does not have any information from the TEC rulemaking to
characterize the removal of dioxins and furans by this technology basis. In the absence of TEC
data, EPA assumed that pretreatment used by ICDC facilities reduces concentrations of dioxins
to below the limits of detection, which EPA assumed to be zero for these calculations. This
approach reflects conclusions EPA previously made during its 2004 detailed study of the
Petroleum Refining Category.5 During that study, EPA concluded that dioxins can be removed
to non-detect levels from refinery wastewaters using oil/water separators.6
5Results of EPA's detailed study of the Petroleum Refining Category are presented in the Technical Support
Document for the 2004 Effluent Guidelines Program Plan, Section 7 (U.S. EPA, 2004c).
6From Technical Support Document for the 2004 Effluent Guidelines Program Plan pp 7-61 to 7-62 (U.S. EPA,
2004c).
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Section 19.0 - Review of Indirect Dischargers
19.8.5
Pass Through and Interference Potential
EPA used the traditional pass through evaluation described in Section 19.1 to
identify whether there is a significant pass through potential of toxic pollutants and
nonconventional pollutants. Specifically, EPA compared toxic pollutant loadings currently
discharged to POTWs and surface waters (baseline loadings) to toxic pollutant loadings that
would be discharged to POTWs and surface waters upon compliance with pretreatment
standards. EPA assumed that ICDC pollutant concentrations would be equivalent to those
achieved with the PSES technology basis for TEC Subpart A (Tank Trucks Chemical and
Petroleum Cargoes) for all pollutants other than dioxins. As explained above, EPA assumed the
technology basis would reduce dioxin concentrations to less than limits of detection (or zero, for
these calculations). Table 19-6 summarizes the current baseline loads, the resulting loads if all
ICDC facilities pretreated, and the current quantity of toxic pollutants that pass through.
Table 19-6. Estimated Pollutant Loads Discharged by 187 ICDC Facilities
Baseline load discharged to POTWs
Baseline load discharged to surface
water
Load discharged to surface water if all
ICDC wastewaters were pretreated
Additional Pollutants Removed (if all
facilities pretreated)
TWPE without
dioxins
16,413
3,007
125
2,882
TWPE from
dioxins
12,032
2,046
0
2,046
TWPE
(total)
28,445
5,052
125
4,927
TWPE per
facility
152
27.0
0.67
26.3
Source: "Industrial Container and Drum Cleaning Facilities" (Matuszko, 2006).
As shown above, on a per facility basis, EPA estimates ICDC facilities currently
annually discharge approximately 27 TWPE (accounting for POTW removals). As shown in
Table 19-6, if all ICDC facilities pretreated, this would reduce the pass through on a per facility
basis to less than 1 TWPE. EPA performed an analysis of the annual costs to the industry for all
ICDC facilities to pretreat their wastewater prior to discharge to the POTW. EPA found that the
costs to pretreat significantly exceed the incremental pollutant reductions (>$500/TWPE).
As to interference potential, although MSD noted that ICDC facilities discharging
to their treatment system violated local limits, they did not provide information relating to the
interference potential from the ICDC industry. EPA did not identify any other information about
discharges of ICDC facilities interfering with the operations of POTWs.
19.8.6
Findings of EPA's Review of the ICDC Industry
EPA estimates that the pass through potential of the ICDC industry as a whole
approximates 5,000 TWPE annually. EPA performed a pass through analysis assuming all
ICDC facilities would employ treatment technology equivalent to the PSES technology basis for
the TEC Truck Subcategory. EPA found that the incremental pollutant removals would be small
in comparison to the costs of achieving such removals. Furthermore, EPA did not identify any
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Section 19.0 - Review of Indirect Dischargers
significant interference concerns. Consequently, EPA has concluded that pretreatment standards
are not warranted for the ICDC industry at this time because the total incremental toxic pound
reductions for the category as a whole are small and because incremental removals on a per
facility basis are also small relative to the associated treatment costs.
19.9 Industrial Laundries
Industrial laundries include establishments that are engaged in the following:
operating mechanical laundries; or supplying laundered or drycleaned textiles to industrial,
commercial, and government users.
In 1999, EPA concluded rulemaking for facilities in the Industrial Laundries point
source category. See 64 FR 45071 (August 18, 1999). EPA determined that all facilities in this
industry discharge indirectly to POTWs and that indirect discharges from industrial laundries did
not warrant national regulation because of the small amount of pollutants removed by the
pretreatment options that were found to be economically achievable. At that time, EPA
estimated the total annual TWPE for industrial laundries to be 88,000 and that the amount of
pollution that would be removed through pretreatment standards would be less than 32 TWPE
per facility annually (accounting for POTW removals). In addition, EPA found that POTWs
were generally not experiencing problems with discharges from this industry, and that such
discharges were unlikely to present a problem at the national level. EPA found that to the extent
that isolated problem discharges occur, existing pretreatment authority is available to control
these isolated discharges. EPA concluded that for this industry, the best way to control effluent
discharges of certain organic pollutants is to remove the pollutants which are contained on the
laundry items before they are washed, rather than establishing categorical pretreatment standards
for discharges from this industry.
In addition, at the time of EPA's final decision, representatives from this industry
agreed to a voluntary pollutant reduction program. The industry refers to this program as the
Laundry Environmental Stewardship Program or LaundryESP®. The industry designed this
program to encourage improvement in four areas: water usage; energy usage; pollutant
discharges to the sewer; and use of wash chemicals with a more positive environmental profile.
As part of this program, the industry has been collecting information from program participants
in four improvement areas. In 2004, the industry collated this information and provided a
summary of the results to date.
EPA conducted a review of discharges from the Industrial Laundries industry
based on comment received in response to the 2004 Final Plan. EPA used the information from
the 2004 summary information from the LaundryESP® program as the primary information
source to update the data collected for the 1999 final action. This section briefly discusses
EPA's findings on the Industrial Laundries industry.
19.9.1 Comments Received
In response to the 2004 Plan, MCES commented that little benefit would be
attained from categorical standards for industrial laundries (OW-2003-0074-0670), and the
Uniform and Textile Service Association (UTSA) provided information on LaundryESP®, a
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Section 19.0 - Review of Indirect Dischargers
voluntary program that they believe has been successful at raising the environmental
performance of industrial laundries (OW-2003-0074-0720). EPA also received stakeholder
comments in response to the 2006 Preliminary Plan. UTSA and King County Wastewater
Treatment Division agreed with EPA's conclusion that categorical pretreatment standards are not
necessary for the Industrial Laundries industry (OW-2004-0032-1064 and 1042), while the
Arkansas DEQ recommended that EPA revisit pretreatment standards for the industry (OW-
2004-0032-0678).
19.9.2 Industry Profile
Industrial laundries primarily include facilities in SIC codes 7211 and 7218. Brief
descriptions of these SIC codes are as follows:
• 7211: Establishments primarily engaged in operating mechanical laundries
with steam or other power.
• 7218: Establishments primarily engaged in supplying laundered or
drycleaned work uniforms, wiping towels, protective apparel (gloves,
flame resistant clothing, etc.), dust control items (treated mats or rugs,
mops, cloths, etc.), and similar items to industrial, commercial, and
government users.
According to 1997 U.S. Census Bureau data, there are approximately 3,100
industrial laundry facilities in the United States. From data collected for the 1999 Final Action,
there are 1,700 U.S. industrial laundries. No industrial laundry facilities reported to TRI or PCS
in 2000 (Matuszko, 2005c).
19.9.3 Wastewater Characteristics
The LaundryESP® program established goals to reduce water and energy usage by
10 to 25 percent per pound of textile processed, a reduction of 20,000 TWPE of pollutants
discharged, and 10 to 25 percent substitution of wash chemicals with chemicals with a more
positive environmental profile. The results of this program's review are summarized below.
As of 2002, 750 industrial laundry facilities were participating in the
LaundryESP®. According to industry documents, this participation accounts for nearly 70
percent of the industry's revenue (2002). From 1997-2002, the industry conducted three facility
surveys, one pollutant data survey, and three wash chemical surveys (Matuszko, 2005c).
A review of the 2002 LaundryESP® data by the UTSA and the Textile Rental
Service Association (TRSA) indicated that 326 of the 562 reporting facilities (58 percent) used
one or more of the following wastewater treatment systems: air stripping, carbon absorption,
centrifuging, chemical emulsion breaking, dissolved air flotation, induced air flotation,
microfiltration, oil skimming, oil/water separation, pH adjustment, polishing filters, reverse
osmosis, rotary screening, and ultrafiltration (Matuszko, 2005c).
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Section 19.0 - Review of Indirect Dischargers
The LaundryESP® data demonstrate that from 1997 to 2002 the participating
facilities reduced water usage per pound of textile processed by 12.5 percent: from an average of
2.61 gallons/pound of textile processed to an average of 2.28 gallons/pound of textile processed.
In addition, the industry reduced its water usage by 5.5 billion gallons from 1997 to 2002.
Energy usage showed a similar trend with an 11.8 percent reduction in the energy use/pound of
textile processed. The average energy usage dropped from 3,650 btu/lb to 3,219 btu/lb. The
industry also saw a 100 percent increase (from 3 to 6 million Ibs/yr) in the use of peroxide
bleaches as wash chemicals which have fewer toxic byproducts than the standard wash
chemicals (Matuszko, 2005c).
One way facilities have reduced water usage is through installation of tunnel
washers, which have a built-in "reuse cycle" where the final rinse water is automatically cycled
back to the first rinse. According to the industry, there is also an industry-wide increase in
pollution prevention activities such as installation of more efficient washers and extractors, and
use of detergents that allow for lower wash temperatures and a lower pH for the removal of oils
and grease (Matuszko, 2005c).
The LaundryESP® database also demonstrated overall toxic pollutant reductions
from 1998 to 2002. Table 19-7 summarizes the discharges from the industrial laundries industry
as a whole from 1998 to 2002, based on information in the LaundryESP® database1 (Matuszko,
2005c).
Table 19-7. Pollutant Discharges from Industrial Laundry Facilities
(Measured as TWPE)
Year
1998
1999
2000
2001
2002
TWPE
40,677
29,090
32,830
22,277
23,162
19.9.4
Data Source: LaundryESP"; "Industrial Laundries" (Matuszko, 2005c).
Pass Through and Interference Potential
The industrial laundries industry has worked to reduce discharges since EPA's
1999 Final Action. Based on the approximately 750 laundries and 23,000 TWPE estimated for
2002 in Table 19-7, the average annual TWPE is less than 31 TWPE per facility, prior to
treatment at the POTW.
In terms of interference potential, EPA did not locate nor did commenters provide
any updated data relating to the interference potential from the Industrial Laundries industry.
lrThe industry calculated the TWPE estimates using information in its database and TWFs from the 1999 Industrial
Laundries record.
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Section 19.0 - Review of Indirect Dischargers
19.9.5 Findings of EPA's Review of the Industrial Laundries Industry
Based on the industry's 2004 evaluation of the Laundry ESP program, EPA
concludes that pollutant discharges from industrial laundries have decreased since its 1999
decision not to establish categorical pretreatment standards for this industry. Therefore, pass
through and interference potential from industrial laundries continues to be low (as measured in
hazard per facility), and development of categorical pretreatment standards for industrial
laundries continues to be unwarranted at this time.
19.10 Photoprocessing
The Photoprocessing industry includes establishments that are engaged in
providing the following services: portrait photography for the general public; commercial
photography; commercial art or graphic design; or photo finishing.
In 1976, EPA promulgated a final rule establishing BPT for the Photographic
Category (Part 459). BPT regulations under Part 459 limit direct discharges of wastewater for
silver, cyanide, and pH. In 1997 published EPA a Preliminary Data Study for the
Photoprocessing Industry (1997 PDS) (U.S. EPA, 1997). That study noted that most
photoprocessing facilities are small (less than 10 employees), typically discharge less than 1,000
gallons/day of wastewater, and overwhelmingly discharge to POTWs. As a result, EPA reviewed
discharges from photoprocessing facilities as part of the categories composed primarily of
indirect dischargers. This section briefly discusses EPA's findings on the Photoprocessing
industry.
19.10.1 Comments Received
EPA received no stakeholder comments in response to the 2004 Plan about the
Photoprocessing industry. EPA received comments from the King County Wastewater
Treatment Division in response to the 2006 Preliminary Plan, stating that categorical
pretreatment standards are not necessary for the Photoprocessing industry (see OW-2004-0032-
1042).
19.10.2 Industry Profile
The Photoprocessing industry includes facilities in SIC codes 7221, 7335, 7336,
and 7384. The 1987 SIC Code Manual defines these SIC codes as follows:
• 7221: Establishments primarily engaged in still or video portrait
photography for the general public. Included in this classification are
school, home, and transient portrait photographers.
• 7335: Establishments engaged in providing commercial photography
services for advertising agencies, publishers, and other business and
industrial users.
• 7336: Establishments primarily engaged in providing commercial art or
graphic design services for advertising agencies, publishers, and other
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Section 19.0 - Review of Indirect Dischargers
business and industrial users. Included in this classification are producers
of still and slide films.
• 7384: Establishments primarily engaged in developing film and
photographic prints and enlargements. Data for retail outlets (kiosks),
which are owned and operated by photo finishing laboratories for the
pickup and delivery of film, are merged with data for the laboratory which
owns them and are not treated as separate establishments.
The PCS database contains little information on this industry because it consists
primarily of indirect dischargers. The PCS database contains discharge information for only one
facility for the year 2000. No facilities in the photoprocessing industry reported to TRI in 2000
(Matuszko, 2005d). The TRI database contains little information on this industry, in part,
because the majority of photoprocessing facilities have few employees and are not required to
report to TRI.
19.10.3
Wastewater Characteristics
EPA obtained information on the photoprocessing industry's wastewater sources
and characteristics from the 1997 PDS. Process water used in photoprocessing consists of (1)
film and paper wash water; (2) solution make-up water; and (3) area and equipment wash water.
According to the 1997 PDS, photoprocessors typically discharge less than 1,000 gallons of
wastewater per day. The 1997 PDS also documents 296 million square feet of film and 4,130
million square feet of paper processed per year. EPA estimates that the total U.S. wastewater
discharge for the Photoprocessing industry was 2,260 million gallons per year (MGY) in 1994
and 1,840 MGY in 2003 (Matuszko, 2005d).
Silver from silver-halide printing accounts for the majority of the TWPE
associated with photoprocessing wastewater. Table 19-8 summarizes the wastewater discharges
from the photoprocessing industry.
Table 19-8. Summary of Wastewater Discharges from the Photoprocessing Industry
Data Source
Raw Discharges (before
POTW removal)
Treated Discharges (after
POTW removal)
Total Annual TWPEa
2,543,010
300,969
Number of Facilities
Estimated in Industry1"
39,393
39,393
Annual TWPE per
Facility
64.6
7.64
Source: "Photoprocessing" (Matuszko, 2005d).
a2003 estimates (using 1997 PDS pollutant concentrations and 2003 wastewater flows)
Estimates from 2002 U.S. Census Bureau (U.S. Census, 2002)
The industry trend towards digital photography may decrease the discharge of
silver-laden wastewater associated with silver-halide printing. The use of digital photography
and digital printing increased in the U.S. from 2002 to 2004. In 2002, digital cameras were
owned by 18 percent of adults. In 2003, digital cameras were owned in 30 to 50 percent of U.S.
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Section 19.0 - Review of Indirect Dischargers
households. In 2004, shipments of digital still cameras in the U.S. grew by roughly 30 percent,
indicating digital camera use in 60 to 80 percent of U.S. households (Matuszko, 2005d).
Contrarily, pictures from digital cameras can still be printed using silver-halide
technology, for better quality. Although this is not currently an identified trend, film
manufacturers have incentive to establish this trend, to keep their part of the market share
(Matuszko, 2005d).
19.10.4 Wastewater Treatment and Pollution Prevention
EPA estimates that discharges of silver account for 99 percent of the toxic load
discharged by the photoprocessing industry. According to the 1997 PDS, silver recovery is
almost always practiced to some extent at photoprocessing facilities. The most common
methods of silver recovery are metallic replacement and electrolytic recovery.
Many POTWs have stringent silver limits in their NPDES permits or need to
reduce metals concentrations in biosolids. POTWs have identified photographic facilities as a
whole as a major source of silver. In an attempt to provide photoprocessing facilities and
POTWs with a cost-effective alternative to numeric limits and monitoring, in 1997, NACWA
(formerly AMSA), the Silver Council, and two industry groups for the Photographic industry
developed a "Code of Management Practices for Silver Dischargers" (Silver CMP). The Silver
CMP provides recommendations on control technologies and management practices for
controlling silver discharges to POTWs, and encourages pollution prevention technologies such
as water conservation. The recommended practices are defined by a minimum recovery of silver
from silver-rich processing solutions (e.g., 90%, 95%, and 99%). The minimum recovery and
recommended practices vary with the size of the photoprocessor, defined by flow volume of
silver-rich solution and wash water. Four POTWs documented loadings reductions of 20 to 52
percent over historical baselines after CMP implementation (Matuszko, 2005d).
19.10.5 Pass Through and Interference Potential
As described above, pollutant loading estimates based on most recent information
available indicate annual TWPE discharges for the industry are approximately 300,000 (over
99% due to silver). On a per facility basis, accounting for a POTW removal for silver of 88%,
this equates to discharges of less than 10 TWPE per facility per year. As to interference
potential, EPA did not locate nor did commenters provide any updated data relating to the
interference potential from discharges from photoprocessing wastewater.
19.10.6 Findings of EPA's Review of the Photoprocessing Industry
EPA's review of current information indicates that there is not a significant
concern with pass through and interference at POTWs from this industry's discharges. EPA
concludes that categorical pretreatment standards are not warranted for this industry at this time.
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Section 19.0 - Review of Indirect Dischargers
19.11 Printing and Publishing
Printing and publishing establishments are engaged in operations that include five
main printing processes: lithographic printing; screen printing; flexographic printing; letterpress
printing; and gravure printing.
In October of 1983, EPA published a study of the Printing and Publishing
industry, entitled Summary of Available Data on the Levels and Control of Toxic Pollutant
Discharges in the Printing and Publishing Point Source Category (1983 Data Summary) (U.S.
EPA, 1983). At that time, EPA concluded that national pretreatment standards were not
warranted due to the small quantity of toxic pollutant discharges associated with this industry
(0.0021 to 0.914 pounds per day per facility). This section briefly discusses EPA's findings from
the most recent review of the Printing and Publishing industry.
19.11.1 Comments Received
In response to the 2004 Plan, MCES commented that categorical pretreatment
standards are not warranted for the Printing and Publishing industry (OW-2003-0074-0670), and
NRDC suggested that EPA develop regulations for the industry that focus on preventing
pollution by substituting materials, minimizing changeover, and recycling ink (OW-2003-0074-
0733)21. EPA received comments from the King County Wastewater Treatment Division in
response to the 2006 Preliminary Plan stating that categorical pretreatment standards are not
necessary for the Printing and Publishing industry (see OW-2004-0032-1042).
19.11.2 Industry Profile
The Printing and Publishing industry includes facilities in SIC codes 2732, 2752,
2754, 2759, 2761, 2771, 2782, 2789, 2791, 2796, and 7334. Brief descriptions of these SIC
codes are as follows:
2732: Book printing;
2752: Commercial printing, lithographic;
2754: Commercial printing, gravure;
2759: Commercial printing, not elsewhere classified;
2761: Manifold business forms;
2771: Greeting cards;
2782: Blankbooks and looseleaf binders;
2789: Bookbinding and related work;
2791: Typesetting;
2796: Platemaking services; and
7334: Photocopying and duplicating services.
According to the U.S. Census Bureau, there were approximately 49,000 printing
and publishing facilities in 1997 and 43,000 facilities in 2002. Of these facilities, 202 reported to
TRI in 2000. Sixty-two percent of these facilities reported no wastewater discharges, 37 percent
21 EPA did not identify this industry as a potential new category under section 304(m)(l)(B), as that provision
applies only to direct discharging industries subject to effluent guidelines - not to indirect dischargers.
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Section 19.0 - Review of Indirect Dischargers
reported only indirect discharges, and one percent reported both direct and indirect discharges.
Twenty-one printing and publishing facilities reported to PCS in 2000 (two were classified as
major dischargers). The direct dischargers captured in the PCS database represent less than 0.05
percent of the industry. Thus, EPA estimates that the vast majority of printing and publishing
facilities are indirect dischargers (Matuszko, 2005e).
19.11.3 Wastewater Characteristics
The EPA's October 1983 Summary of Available Data on the Levels and Control
of Toxic Pollutant Discharges in the Printing and Publishing Point Source Category (1983 Data
Summary) contains information on wastewater generation. According to the 1983 Data
Summary, wastewater flows in the industry generally range from 26 to 50 gallons per day and
are often not continuous. The 1983 Data Summary also found that the facilities with the largest
flows are direct dischargers and only 3.7 percent of printers discharge more than 5,000 gpd of
wastewater (Matuszko, 2005e).
No establishments reported wastewater flow data to TRI in 2000. In the 2000
PCS database, 21 facilities report direct discharges, and their flows range from 241 to 2.5 million
gallons per day with a median wastewater flow of 0.02 million gallons per day (MGD)
(Matuszko, 2005e).
While PCS data is limited for this industry, these more recent data indicate that
wastewater discharge volumes may have decreased from those presented in the 1983 Data
Summary. This finding is consistent with case studies documenting water reduction practices
(Massachusetts Office of Technical Assistance, Connecticut Department of Environmental
Protection, and the Enviro$en$e Web Page) (Matuszko, 2005e).
EPA obtained discharge data for the untreated wastewater (before POTW
treatment) from the Printing and Publishing industry from reported releases to PCS and TRI in
2000. Based on these data (1,630 TWPE22 discharged from the 76 TRI-reporting facilities in
2000), approximately 21 TWPE is discharged per facility per year.
Eight facilities collectively contribute approximately 81 percent of the total
industry TWPE in treated wastewater based on 2000 TRI data (accounting for POTW
removals)23. Ninety-nine percent of the TWPE discharges from these eight facilities are indirect
discharges of copper, which EPA estimated at approximately 44 TWPE per facility based on an
estimated facility TPWE of 255 (reported ranges of 11 - 499 TWPE) and accounting for POTW
removals. EPA contacted five of these facilities (four companies) to determine the source of
copper. These facilities explained that the gravure printing process involves copper and chrome
22 The 2005 memorandum (Matuszko, 2005e) lists the industry TWPE (before POTW treatment) as 1,907, which
includes 279.98 TWPE of sodium nitrite discharged from the Citiplate, Inc. facility. In response to comments on the
proposed 2006 Plan, EPA revised its methodology for sodium nitrite. See Section 4.2 and DCN 03675. The revised
sodium nitrite TWPE from Citiplate, Inc. (before POTW treatment) is 0.486.
23 The 2005 memorandum (Matuszko, 2005e) lists nine facilities contributing approximately 90 percent of the total
industry TWPE. EPA calculated this industry TWPE including sodium nitrite discharges from the Citiplate, Inc.
facility based on an older methodology described in footnote 4. In addition, in response to comments, EPA updated
the POTW removal rate for sodium nitrite. See Section 4.2 and DCN 03676. The revised sodium nitrite TWPE
from Citiplate, Inc. (accounting for POTW removal) is 0.0486.
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Section 19.0 - Review of Indirect Dischargers
plating of the printing cylinders. The cylinders are de-chromed and de-coppered after every print
job, and then re-plated with chrome and copper for the next image imprinting. Etching,
polishing and rinsing of the copper plated cylinders releases copper into the wastewater. Copper
is also present in the discarded sludge from blue and green inks (Matuszko, 2005e).
Of the five facilities that EPA contacted, all perform gravure printing in addition
to other types of printing. Also, four facilities use analytical data to estimate the range of copper
transferred to the POTW. The fifth facility back calculates the amount transferred based on
copper in filter cake from pretreatment, and the efficiency of the pretreatment system (Matuszko,
2005e).
19.11.4
Wastewater Treatment and Pollution Prevention
Based on the 1983 Data Summary, most printing and publishing facilities do not
perform wastewater treatment on site.
19.11.5
Pass Through and Interference Potential
Seventy six facilities reported discharges to TRI in 2000 from printing and
publishing facilities. After accounting for POTW removals, the majority of these facilities
discharge approximately 1 TWPE per facility annually. TWPE for the eight facilities described
in Section 19.11.3 (including platemaking, gravure printing, lithographic printing, and greeting
card printing facilities) approximate 44 TWPE per facility annually. Table 19-9 presents the
year 2000 TRI discharge data for treated and untreated wastewater.
Table 19-9. Summary of Wastewater Discharges from the Printing and Publishing
Industry
Data Source
TRIReleases2000_v6 (Before
POTW removal)
TRIReleases2000 v6 (After
POTW removal)
Total Annual
TWPEab
1,630
440
Number of Facilities
Reporting"
76
76
Annual TWPE per
Facility
21.4
5.79
Source: "Printing and Publishing" (Matuszko, 2005e)
Includes direct and indirect dischargers.
bAccounts for reduced TWPE from Citiplate, Inc. sodium nitrite discharge as described in footnotes 4 and 5.
Regarding interference potential, EPA did not locate nor did commenters provide
any updated data relating to the interference potential from the printing and publishing industry.
19.11.6
Findings of EPA's Review of the Printing and Publishing Industry
EPA's review of current information indicates that there is not a significant
concern with pass through and interference at POTWs from this industry's discharges. EPA
therefore finds that categorical pretreatment standards are not warranted for this industry at this
time.
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Section 19.0 - Review of Indirect Dischargers
19.12 Tobacco Products
The Tobacco Products industry is composed of facilities that manufacture the
following: cigarettes; cigars; smokeless tobacco (i.e., chewing, plug/twist, and snuff tobacco);
loose smoking tobacco (i.e., pipe and roll-your-own cigarette tobacco); and reconstituted (sheet)
tobacco; as well as facilities engaged in the stemming and redrying of tobacco.
EPA identified the Tobacco Products industry for review because one public
comment on the preliminary 2004 Final Plan suggested that EPA consider developing tobacco
products effluent guidelines. In particular, the commenter expressed concern over the quantity
of toxics and carcinogens that may be discharged in wastewater associated with the manufacture
of cigarettes. At the time of publication of the 2004 Final Plan, EPA was unable to determine,
based on readily available information, whether to identify Tobacco Products as a potential new
category in the Plan. In particular, EPA lacked information on whether Tobacco Products
facilities discharge toxic and nonconventional pollutants in nontrivial amounts, whether the
industry is composed of entirely or almost entirely indirect dischargers, and whether indirect
dischargers in the industry cause pass through or interference with POTWs. In order to
determine whether to identify the tobacco products industrial sector as a potential new point
source category, EPA conducted a detailed study of the pollutant discharges for this industrial
sector.
During its detailed study of this industry, EPA determined that most tobacco
products facilities discharge their wastewater to POTWs. EPA therefore determined that this
category is almost entirely composed of indirect dischargers and is therefore not subject to
identification as a potential new category for effluent guidelines under CWA section
304(m)(l)(B). EPA therefore proceeded to review this industry in its review of indirect
dischargers without categorical pretreatment standards to determine whether to establish such
standards under CWA Sections 304(g) and 307(b).
This section briefly discusses EPA's findings on the Tobacco Products industry.
For a complete discussion of EPA's review, see Final Engineering Report: Tobacco Products
Processing Detailed Study (U.S. EPA, 2006).
19.12.1 Comments Received
As described above, EPA received one comment on its Preliminary 2004 Plan that
it should consider developing ELGS for the tobacco products industry. On its Preliminary 2006
Plan, EPA received four comments that it should not develop ELGs for the tobacco products
industry: one from a POTW association, NACWA; one from the City of Winston-Sal em, NC;
and two from tobacco companies. R. J. Reynolds (Reynolds American) provided information on
its tobacco products processes and study reports on the biodegradability of nicotine (OW-2004-
0032-1096). For an evaluation of these study reports, see Comments on the Four Reports
Submitted by R.J. Reynolds Tobacco Company in Response to Request for Data in the Notice of
Availability of Preliminary 2006 Effluent Guidelines Program Plan (Upgren, 2006). Lorillard
Tobacco Company provided a Sewage Collection and Water Reclamation Plant Report for 2004
for the City of Greensboro (OW-2004-0032-1105.1). The City of Winston-Sal em provided
pollutant concentrations and other information on the wastewater that tobacco products facilities
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Section 19.0 - Review of Indirect Dischargers
discharge to one POTW (OW-2004-0032-1061). NACWA stated that indirect dischargers within
the tobacco products industry are efficiently regulated by local pretreatment programs (OW-
2004-0032-1093).
19.12.2 Industry Profile
This Tobacco Products industry is divided into the following four industry
groups:
• SIC code 2111 (Cigarettes): establishments primarily engaged in
manufacturing cigarettes from tobacco or other materials;
• SIC code 2121 (Cigars): establishments primarily engaged in
manufacturing cigars;
• SIC code 2131 (Smokeless and Loose Chewing Tobacco): establishments
primarily engaged in manufacturing chewing and smoking tobacco and
snuff; and
• SIC code 2141 (Reconstituted Tobacco and Tobacco Stemming and Re-
drying): establishments primarily engaged in the stemming and re-drying
of tobacco or in manufacturing reconstituted tobacco.
Based on information in the 2002 Economic Census and reported in 2004 to the
U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB), EPA estimates there are 149 tobacco
products facilities in the United States. The number of tobacco products processing facilities has
been in decline as facilities consolidate. Of these facilities, EPA has identified three facilities
with active NPDES permits that discharge process wastewater directly to waters of the U.S. and
at least 15 facilities that discharge indirectly to POTWs. The remaining dischargers are either
indirect dischargers or zero dischargers.
19.12.3 Wastewater Characteristics
In conducting its detailed study, EPA conducted outreach to the most significant
dischargers in this category. These companies have provided extensive information on processes,
pollutant discharges and existing permits. Based on information collected to date, EPA believes
that primary processing at cigarette manufacturers and their related reconstituted tobacco
operations are the main source of discharged wastewater pollution in this industrial sector.
EPA conducted site visits at six tobacco product facilities: four cigarette
manufacturing facilities and two dedicated reconstituted tobacco facilities. In addition to
collecting information on processes and wastewater generation, EPA also collected grab samples
of wastewater during these site visits. EPA collected these wastewater samples to: (1) further
characterize wastewater generated and/or discharged at these facilities; and (2) evaluate
treatment effectiveness, as applicable. For the sites visited, EPA also contacted states and
POTWs to obtain existing permits and identify concerns. Finally, EPA reviewed and evaluated
comments from the Preliminary 2006 Plan regarding the tobacco products processing industry.
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Section 19.0 - Review of Indirect Dischargers
EPA's review of effluent data from indirect discharging tobacco products
processing facilities demonstrates that such discharges are generally characterized by low
concentrations of toxic and nonconventional pollutants - primarily metals. One exception is
nicotine, with discharge concentrations ranging from 7,500 ug/L to 31,000 ug/L. Nicotine and
metals discharges account for approximately 93% of the total annual TWPE associated with
indirect tobacco products processing discharges. Source water appears to be the biggest
contributor to metal discharges at both indirect and direct discharging facilities (U.S. EPA,
2006).
19.12.4 Wastewater Treatment
EPA did not identify any indirect discharging tobacco products processing
facilities that operate pretreatment. As a result, EPA also reviewed wastewater discharge data
from direct dischargers in this category. Biological treatment with or without nutrient removal is
the most commonly employed wastewater treatment technology. Treatability data collected from
tobacco products processing facilities demonstrate on site wastewater treatment systems are
highly efficient with BODs and nicotine removals in excess of 99 percent. Resulting discharges
are characterized by low concentrations of toxic and nonconventional pollutants - primarily
metals. However, based on available data, these metal discharges largely result from source
water contributions (U.S. EPA, 2006).
19.12.5 Pass Through and Interference Potential
EPA used the traditional pass through evaluation described in Section 19.1 to
identify whether there is a significant pass through potential of toxic pollutants and
nonconventional pollutants. Specifically, EPA compared toxic pollutant loadings currently
discharged to POTWs and surface waters (baseline loadings) to toxic pollutant loadings that
would be discharged to POTWs and surface waters upon compliance with pretreatment standards
based on biological treatment with nutrient removal (BNR) (potential post-regulatory loadings).
EPA considered BNR treatment technology to be the BAT because both of the direct discharge
tobacco facilities sampled by EPA used this technology and based on influent and effluent data
collected from these two facilities, EPA determined that BNR treatment systems are generally
effective at reducing pollutants in tobacco products wastewater. From this evaluation, EPA
found the annual incremental toxic pollutant removals per facility would be small, approximately
29 TWPE/facility (U.S. EPA, 2006), which are similar to the incremental removals EPA
calculated for the withdrawn Industrial Laundries proposed rulemaking (32 TWPE/facility). See
64 FR 45071 (August 18, 1999). EPA also performed an analysis of the annual costs for
facilities to pretreat using the BNR technology prior to discharge to the POTW. EPA found that
the costs to pretreat were well in excess of the incremental pollutant reductions (>$10,000/TWPE
removed).
EPA also evaluated possible negative effects of discharges from tobacco products
processing facilities to POTWs. As explained above, nicotine and metals account for
approximately 93% of the total annual TWPE associated with indirect discharges from this
category. Based on information obtained in this study, POTWs achieve nicotine removals in
excess of 96%. EPA compared the concentrations of metals found in indirect tobacco products
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Section 19.0 - Review of Indirect Dischargers
processing discharges to those typically found in POTW influent. This comparison demonstrated
that metals concentrations discharged by tobacco products processing facilities are lower than
those found in typical POTW influent. Based on these findings, EPA believes that tobacco
products processing discharges should not have negative impacts on the receiving POTWs (U.S.
EPA, 2006).
To verify this finding, EPA contacted POTWs receiving significant tobacco
products processing discharges. All POTWs contacted indicated they had experienced little to no
problems with such discharges and that they had no problem handling and treating tobacco
products processing discharges.
19.12.6 Findings of EPA's Review of the Tobacco Products Industry
EPA has found that national pretreatment standards are not warranted for this
category at this time because there is low potential for pass through (as measured by incremental
toxic pollutant removal) or interference at POTWs.
EPA also reviewed wastewater discharge data from the three direct dischargers in
this category and found that national effluent guidelines for direct dischargers are unwarranted at
this time, as discharges from these facilities are best addressed through effluent limits established
by permit writers on a case-by-case BPJ basis.
19.13 References
AFTS. 2004. Agri-Food Trade Service. Market Information, United States. Available online
at: http://atn-riae.agr.ca/info/us-e.htm. Date accessed: October 27. DCN 01464.
ASCE. 2004. American Society of Civil Engineers. Sanitary Sewer Overflow Solutions. (April
1). DCN 03046.
CAL FOG. 2004. California Fats, Oils, and Grease TriTAC Workgroup. A Guide for
Developing and Implementing a Fats, Oils, and Grease Control Program for Food Service
Establishments. (September). DCN 03039.
CSIRO. 2004. Australia's Commonwealth Scientific and Industrial Research Organisation.
Endocrine Disrupting Chemicals and Pharmaceuticals and Personal Care Products in Reclaimed
Water in Australia, Australian Water Conservation and Reuse Research Program. (January).
Available online at:
http://www.clw.csiro.au/awcrrp/stagelfiles/AWCRRP_lH_Final_27Apr2004.pdf. DCN 02186.
Engle, David. 2005a. "FOG Bound Food Service: Restaurant Wastewater Requires Painstaking
Care to Circumvent Sewer-rate Surcharges and Drainfield Damage." (October). Available
online at: http://www.onsitewater.com/ow_0509_fog.html. Date accessed: February 10, 2006.
DCN 02616.
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Section 19.0 - Review of Indirect Dischargers
Engle, David. 2005b. FOG Cutters. (December). Available online at:
http://www.gradingandexcavation.com/ow_05ll_fog.html. Date accessed: February 10, 2006.
DCN02610.
Giger, et al. 2003. "Occurrence and Fate of Antibiotics as Trace Contaminants in Wastewaters,
Sewage Sludges, and Surface Waters." Chimia. 57: 485-491. Schweizerische Chemische
Gesellschaft. ISSN 0009-4293. Available online at:
http://www.sach.ch/doc/chimia/sept03/giger.pdf. DCN 02185.
IRAC. 2004a. Interagency Resource for Achieving Cooperation. A Guide to Restaurant Grease
Management: A Regulator's Desk Reference. (September). DCN 03043.
IRAC. 2004b. Interagency Resource for Achieving Cooperation. A Pocket Guide to Best
Management Practices for Restaurant Grease. (September). DCN 03040.
Johnston, Carey. 2005a. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Industry Sectors Being Evaluated under Proposed "Health Services
Industry" Category." (August 4). DCN 02293.
Johnston, Carey. 2005b. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Hospitals and Clinics." (August 11). DCN 03797.
LaDuca, Ann. 2001. TetraTech, Inc. Local Limits Summary. (December 4). DCN 03131.
Matuszko, Jan. 2005a. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Food Service Establishments." (August 11). DCN 02103.
Matuszko, Jan. 2005b. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Independent and Stand-Alone Laboratories." (August 11). DCN
02101.
Matuszko, Jan. 2005c. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Industrial Laundries." (August 11). DCN 02102.
Matuszko, Jan. 2005d. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Photoprocessing." (August 11). DCN 02096.
Matuszko, Jan. 2005e. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Printing and Publishing." (August 11). DCN 02294.
Matuszko, Jan. 2006. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Industrial Container and Drum Cleaning Industry." (September 11).
DCN 03415.
Mott, Jennifer, and Maureen Kaplan. 2005. Eastern Research Group, Inc. Memorandum to
U.S. EPA. "Health Services Industry: Number of Facilities, Companies, and Small Businesses."
(December 20). DCN 02940.
19-31
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Section 19.0 - Review of Indirect Dischargers
RIPA. 2000. Reusable Industrial Packaging Association, as cited in the Preliminary Data
Summary - Industrial Container and Drum Cleaning Industry, June 2002.
RIPA. 2004. Reusable Industrial Packaging Association web site. Available online at:
http://www.reusablepackaging.org/. Date accessed: October 21, 2004. DCN 04065.
Stone, Mark. 2004. "The Effect of Amalgam Separators on Mercury Loading to Wastewater
Treatment Plants." CDA Journal. 32(7):593-600. DCN 02237.
Tchobanoglous, G. 1991. George/Metcalf & Eddy, Inc. Wastewater Engineering: Treatment,
Disposal, and Reuse. 2nd Edition. Irwin/McGrawHill.
TDEC. 2002. Tennessee Department of Environment and Conservation, Division of Water
Pollution Control. Tennessee Oil and Grease Control Guidance Document. (June). DCN
03265.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U.S. EPA. 1983. Summary of Available Data on the Levels and Control of Toxic Pollutant
Discharges in the Printing and Publishing Point Source Category. EPA 440/1-83/400.
(October). DCN 01526.
U.S. EPA. 1989. Preliminary Data Summary for the Hospitals Point Source Category. EPA
440/1-89/060-n. (September). DCN 02231.
U.S. EPA. 1997. Preliminary Data Study for the Photoprocessing Industry. EP A-821 -R-97-
003. DCN 02230.
U.S. EPA. 1999. Introduction to the NationalPretreatmentProgram. EPA-833-B-98-002.
Washington, DC. (February). DCN 01887.
U.S. EPA. 2002. Preliminary Data Summary - Industrial Container and Drum Cleaning
Industry. EPA-821-R-02-011. Washington, DC. (June). DCN 00659.
U.S. EPA. 2004a. Technical Development Document for the Final Effluent Limitations
Guidelines and Standards for the Meat and Poultry Products Point Source Category (40 CFR
432). EPA-821-R-04-011. (July). Available online at:
http://www.epa.gov/waterscience/guide/mpp/.
U.S. EPA. 2004b. Impacts and Controls of CSOs andSSOs. EPA-833-R-04-001. Washington,
DC. (August). Available online at: http://cfpub.epa.gov/npdes/cso/cpolicy_report2004.cfm.
U. S. EPA. 2004c. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
19-32
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Section 19.0 - Review of Indirect Dischargers
U.S. EPA. 2005a. Guide for Evaluating Capacity, Management, Operation, and Maintenance
(CMOM) Programs at Sanitary Sewer Collection Systems. EPA-305-B-05-002. (January).
DCN 02847.
U.S. EPA. 2005b. EPA Office of Compliance Sector Notebook Project-Profile of the
Healthcare Industry. EPA/310-R-05-002. (February). Available online at:
http://www.epa.gov^Compliance/resources/publications/assistance/sectors/notebooks/health.html
. DCN 02183.
U.S. EPA. 2006. Final Engineering Report: Tobacco Products Processing Detailed Study.
EPA-821-R-06-017. (November). DCN 03395.
Upgren, Amy. 2006. U.S. EPA. Memorandum to Jan Matuszko of U.S. EPA. "Comments on
the Four Reports Submitted by R. J. Reynolds Tobacco Company in Response to Request for
Data in the Notice of Availability of Preliminary 2006 Effluent Guidelines Program Plan." (May
18). DCN 02798.
WEF. 2004. Water Environment Federation. The O&M in CMOM: "Operation &
Maintenance" -A Reference Guide for Utility Operators. (September 29). DCN 03045.
Wiltsee, G. 1998. Urban Waste Grease Resource Assessment. NREL/SR-570-26141.
(November 1). DCN 02606.
19-33
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Section 20.0 - Review of Direct Dischargers
20.0 REVIEW OF DIRECT DISCHARGERS WITHOUT EFFLUENT LIMITATIONS
GUIDELINES TO IDENTIFY POTENTIAL NEW REGULATORY CATEGORIES FOR
EFFLUENT GUIDELINES RULEMAKING
CWA Section 304(m)(l)(B) requires EPA to identify in a plan categories of
sources discharging non-trivial amounts of toxic and non-conventional pollutants to waters of the
U.S. Based on stakeholder comment and its own crosswalk analysis (see Section 4.1.1), EPA
found two industries that were potentially subject to identification under section 304(m)(l)(B):
the liquefied natural gas (LNG) import terminals industry and the miscellaneous foods and
beverages industry. This section presents EPA's review of these two industries to determine
whether to identify them as potential new categories in the 2006 Plan. EPA did not find any
other industries that meet the potential identification criteria in section 304(m)(l)(B). See the
memorandum entitled, "Commenter-Identified Industries Not Meeting 304(m)(l)(B) Criteria,"
dated December 1, 2006 (Matuszko, 2006b).
Based on its analysis, EPA is not identifying either of these industries as potential
new categories in the 2006 Plan because EPA does not believe that ELGs would be an
appropriate tool for regulating discharges from either of these industries. In assessing whether
ELGs would be appropriate, EPA is required to considers the various factors in section
304(b)(2)(B) in establishing ELGs for an industrial activity - including the availability of
treatment technology, economic achievability, non-water-quality environmental impacts, and
"such other factors as the Administrator deems appropriate." EPA believes that section
304(m)(l)(B) gives EPA the discretion to identify in the Plan only those new categories for
which EPA believes ELGs may be an appropriate tool. See Norton v. Southern Utah Wilderness
Alliance, 542 US 55, 70 (2004) (holding that a broad statutory mandate is not sufficient to
constrain an Agency's discretion over its internal planning processes). Instead, EPA believes
that discharges from these industries can best be addressed through case by case BPJ-based
permit limits, rather than through categorical ELGs. BPJ is a particularly appropriate tool where
- as here - there is significant site-specific variability in terms of facility design. A BPJ case-by-
case approach would enable permit writers to best capture the technical considerations that might
influence the identification of the appropriate pollutant control technology and effluent limits.
20.1 Liquefied Natural Gas Import Terminals
This subsection discusses the comments received on liquefied natural gas (LNG)
import terminals and presents a brief industry and economic profile.
20.1.1 Comments Received
EPA received two comments in response to the Preliminary 2006 Plan suggesting
that EPA identify LNG import terminals as a potential new category in the Final 2006 Plan.
Specifically, these two commenters suggested that EPA consider establishing
ELGs for pollutant discharges from LNG import terminals that use open-loop re-gasification
systems, specifically offshore facilities in the Gulf of Mexico. These commenters cited potential
impacts on the marine environment from discharges that contain anti-biofouling agents and
thermal pollution (cold wastewater). These commenters suggested that EPA consider
20-1
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Section 20.0 - Review of Direct Dischargers
promulgating effluent guidelines for this industrial sector based on closed-loop re-gasification
technologies (EPA-HQ-OW-2004-0032-1094 and 1056).
20.1.2 Category/Subcategory Analysis
The LNG import terminal industry is not currently subject to a categorical ELGs.
To determine whether this industry is subject to identification under CWA section 304(m)(l)(B),
EPA first assessed whether this industry was properly considered a stand-alone category, or
whether it should be considered a potential new subcategory of an existing category and
reviewed under CWA section 304(b). EPA reviewed the ELGs for the existing 56 industrial
point source categories to determine whether the LNG industry could be considered a potential
new subcategory of any of these categories. EPA found that some of the minor wastestreams
from LNG import terminals (e.g., deck drainage, gray water, and sanitary water) are similar to
wastewaters regulated by the Oil and Gas Extraction ELGs (see 40 CFR part 435, Subpart A),
and therefore considered whether the LNG industry could be considered a potential new
subcategory of this industrial category.
However, EPA found that LNG import terminals perform an entirely different
service than facilities in the Oil and Gas Extraction Category, and therefore should not be
considered a potential new subcategory. Specifically, while facilities in the Oil and Gas
Extraction Category engage in the extraction of raw materials, LNG import terminals process (or
"regasify") the raw material after it has been extracted, liquefied, and delivered to the facility.
Thus, the service performed by LNG import terminals is analogous to the Petroleum Refining
Category (40 CFR Part 419) - also a stand-alone category that processes a raw material (in that
case, oil) extracted by oil and gas extraction facilities. Moreover, the wastewaters associated
with the open-loop re-gasification industrial processes performed by LNG facilities are
significantly different than the wastewaters associated with facilities in the Oil and Gas
Extraction Category. Consequently, EPA determined that this industry constitutes a potential
stand-alone category within the meaning of CWA section 304(m)(l)(B). EPA therefore
proceeded to analyze whether ELGs would be an appropriate tool for addressing discharges from
this category, as discussed below.
20.1.3 Industry Profile
After natural gas has been extracted and liquefied (through cooling to about minus
260°F), it is transported by vessels to LNG import terminals for processing (known as "re-
gasification.") Figure 20-1 (Chinloy, 2005) depicts the function of LNG import terminals in the
overall context of natural gas production - from extraction to distribution to consumers.
20-2
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Section 20.0 - Review of Direct Dischargers
PRODUCTION
LIQUEFACTION PLANT SHIPPING
LNG
storage Loadln9
RECEIVING TERMINAL
LNG
Unloading storage Regas Plant
Markets - End Users
Local Gas Distribution
Electric Utilit
Gas Marketiiia/Trad/na
^Transmission 8. i
" Distribution
Figure 20-1. General Description of LNG Importation
(Chinloy, 2005)
Interest in LNG imports has been rekindled by higher U.S. natural gas prices in
recent years, as well as increased competition and technological advances that have lowered
costs for liquefaction, shipping, storing, and re-gasification of LNG (U.S. DOE, 2004).
However, although LNG imports exceeded historical highs in 2003, even at the current pace they
represent only about 2.7 percent of U.S. consumption and 13 percent of imports. In a 2006
report, the U.S Department of Energy (DOE) estimated that total capacity at U.S. LNG facilities
will increase from 1.4 trillion cubic feet (tcf) to 4.9 tcf in 2015, when net LNG imports are
expected to total 3.1 tcf (imports are thus 58 percent of capacity) (EIA, 2006). DOE then
predicts that LNG construction will slow after 2015. Capacity in 2030 is expected to be 5.8 tcf,
with imports totaling 4.4 tcf (76 percent of capacity). DOE revised its projections of LNG
downward from its 2005 report (which reported that DOE expected LNG exports to be 6.4 tcf in
2025) because it believes that more rapid growth in worldwide demand for natural gas than
predicted in 2005 will reduce the availability of LNG supplies, raise worldwide gas prices, and
make LNG less economical in U.S. markets. Thus, LNG is expected to meet 16 percent of U.S.
natural gas demand in 2030. U.S. demand for natural gas is expected to total 27 tcf at that time.
The range of uncertainty for this estimate of LNG imports in 2030 is large. DOE's low and high
estimates range from 1.3 tcf (a flat growth scenario) to more than double the reference case
estimate (9.6 tcf). Despite DOE's downward adjustment to projected LNG imports, imports are
still expected to grow under DOE's reference case assumptions.
EPA identified two major factors that affect the pollutant discharges and potential
pollutant control technology options for this industrial sector:
• Type of re-gasification technology used (i.e., open-loop or closed-loop);
and
• Location of the facility (i.e., onshore or offshore) is the cost to liquefy the
gas.
20-3
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Section 20.0 - Review of Direct Dischargers
20.1.3.1 Type of Re-gasification Technology Employed
During the re-gasification process, the LNG is warmed from minus 260°F to 40°F
and increases three fold in volume. Re-gasification of LNG is an endothermic process and
requires a heat source. The LNG is pumped through a heating system, where it absorbs heat and
vaporizes, or regasifies, into natural gas. EPA considered the two main types of re-gasification
technologies (open-loop vs. closed-loop) because the type of re-gasification technology directly
influences the amount and toxicity of the potential pollutant discharges. The CWA gives the
Agency authority to consider process changes to evaluate technology-based controls of industrial
wastewater pollutants (see "process changes" at CWA 304(b)).
LNG import terminals that use open-loop re-gasification extract heat energy from
surface water withdrawals in a once-through warming process. There are a number of open-loop
re-gasification technologies that include open rack vaporizers (ORV) and shell and tube
vaporizers that withdraw and discharge large quantities of surface waters (e.g., 100 to 200 MGD)
for the endothermic process. Antibiofouling chemicals (e.g., sodium hypochlorite, total residual
chlorine (TRC), or copper) are typically added to efficiently transfer heat between the surface
water withdrawals and the LNG. The industrial wastewater discharge typically contains both
conventional and nonconventional pollutants, including total suspended solids (TSS) (including
biological matter), antibiofouling chemicals, and thermal pollution (cold wastewater). Thermal
pollution (cold wastewater) is a "pollutant," as discussed in recent EPA guidance: "[t]he CWA
defines 'effluent limitation' to mean 'any restriction on rates, quantities, or concentrations of
chemical, physical, biological, or other constituents which are discharged.' The thermal energy
of a discharge (i.e., as measured in British Thermal Units (BTUs)) is a physical constituent of the
discharge, and, as such, may appropriately be addressed by an effluent limitation" (U.S. EPA,
2006a). EPA's estimate of pollutant discharges from open-loop re-gasification technologies as
part of the 2004 Plan can be found in Table 4 of a memorandum entitled, "Overview of
Liquefied Natural Gas (LNG) Import Terminals for CWA Section 304(m) Effluent Guidelines
Planning", dated August 19, 2004 (Johnston, 2004).
LNG import terminals that use closed-loop re-gasification do not use surface
water in a once-through (open-loop) warming process. Some examples of the method of closed-
loop re-gasification heat source generation are using:
• Combustion of 1.0 to 1.5 percent of the imported LNG cargo;
• Air heat exchange with or without an intermediary fluid flow loop; and
• Waste heat from nearby industrial facilities.
These closed-loop re-gasification technologies do not use surface water and discharge only a
very small fraction of the wastewater and pollutants, in amount and toxicity of discharged
pollutants, compared to open-loop re-gasification pollutant discharges. For example, see the
estimate of pollutant discharges from the Cabrillo Port LNG import terminal NPDES permit
application (U.S. EPA, 2006b).
20-4
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Section 20.0 - Review of Direct Dischargers
20.1.3.2 Onshore Versus Offshore
The location of the LNG import terminal (i.e., onshore vs. offshore) influences the
range of available technology options for pollutant removals. Offshore LNG import terminals
may have significant space limitations that could significantly increase the costs and economic
impacts and affect the technical feasibility of implementing the technology options that may be
available for onshore facilities. Moreover, one technology option for onshore facilities,
employing waste heat from nearby industrial facilities, is not available for offshore facilities.
Consequently, EPA separately evaluated the potential pollutant discharges and potential
technology options for the onshore and offshore subsectors of this industry. The CWA gives the
Agency authority to consider geographic factors to evaluate technology-based controls of
industrial wastewater pollutants (see "such other factors as the Administrator deems appropriate"
at CWA 304(b)).
All existing, approved, and proposed onshore LNG import terminals are using or
plan to use closed-loop re-gasification. There is one existing offshore LNG import terminal,
which is licensed to operate in the open-loop mode, but can operate its shell and tube heat
exchanger vaporizers in the open-loop (6 days to offload at 0.5 Bcfd) or closed-loop mode (7.5
days to offload at 0.4 Bcfd) (USCG, 2003). Most of the approved or proposed offshore LNG
facilities are proposing to use closed-loop re-gasification.
20.1.3.3 Number of Facilities
EPA identified the existing, approved, and proposed LNG import terminals.
Existing LNG Import Terminals
There are six existing LNG import terminals operating in the U.S. Table 20-1 and
Figure 20-2 present more detailed information about each of the facilities.
• Onshore: Five onshore LNG import terminals are currently operating in
the U.S. These onshore terminals use a variety of closed-loop re-
gasification technologies. EPA did not identify any significant pollutant
discharges associated with the re-gasification processes at these facilities
as compared to facilities with open-loop re-gasification.
• Offshore: One offshore terminal began operating in 2005. This offshore
terminal both transports and re-gasifies the LNG onboard. This terminal is
licensed for operation in the Gulf of Mexico in the open-loop mode and
has the operational flexibility to operate its shell and tube heat exchanger
vaporizers in the open-loop (6 days to offload at 0.5 Bcfd) or closed-loop
mode (7.5 days to offload at 0.4 Bcfd). EPA's estimate of pollutant
discharges from this facility can be found in Table 4 of a memorandum
entitled, "Overview of Liquefied Natural Gas (LNG) Import Terminals for
CWA Section 304(m) Effluent Guidelines Planning", dated August 19,
2004 (Johnston, 2004).
20-5
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Section 20.0 - Review of Direct Dischargers
Table 20-1. Existing Land-Based and Offshore LNG Import Terminals
Location
Lake Charles, LA
(Onshore)
Cove Point, MD
(Onshore)
Everett, MA
(Onshore)
Elba Island, GA
(Onshore)
Gulf of Mexico Energy
Bridge (Offshore)
Guayanilla Bay, Puerto Rico
(Onshore)
2004 LNG
Imports (Bcf)
163.T
209.3
173.8
105.2
6b
24d
2006 LNG Sendout
Capacity (Bcfd)
2.1
1.0
1.035
1.2°
0.5
0.1
LNG Storage
Capacity
(Bcf)
6.3
5.0
3.5
4.0e
0
NA
Re-gasification System
Closed-Loop: SCV
Closed-Loop: SCV
Closed-Loop: SCV
Closed-Loop: SCV
Open-Loop: Shell & Tube Heat
Exchanger0
Closed-Loop: Shell & Tube Heat
Exchanger
Operator
Southern Union
Dominion
Distrigas (SUEZ)
El Paso/ Southern LNG
Excelerate Energy
EcoElectrica, LP
to
o
Sources: U.S. Natural Gas Importers by Point of Entry: Liquefied Natural Gas Volumes (EIA, 2006b); Figure 20-3; U.S. LNG Markets and Uses: June 2004
Update (EIA, 2004); Application for Deepwater Port Liscence (El Paso Energy Bridge GOM LLC, 2002); E-mail communication between Andy Flower and
Karrie-Jo Shell, U.S. EPA Region 4 (Flower, 2006a); Spreedsheed attachment to E-mail communication between Andy Flower and Karrie-Jo Shell, U.S. EPA
Region 4 (Flower, 2006b); Final Environmental Assessment of the El Paso Energy Bridge Gulf of Mexico LLC Deepwater Port Liscence Application (USCG,
2003).
aSendout capacity for Lake Charles includes a 0.6 Bcfd expansion approved by FERC (FERC, 2006a). This expansion is expected online mid-2006 (Panhandle
Energy, 2006).
b Available for 2005 only as this facility delivered its first LNG load of nearly 3 Bcf on April 6, 2005 (Excelerate Energy, LLC, 2005). Estimated on the basis of
two deliveries and the capacity of the ships used by Excelerate Energy (roughly 3 Bcf) (Pan EurAsian Enterprises, Inc., 2006; Excelerate Energy, LLC, 2005).
°This terminal is licensed for operation in the Gulf of Mexico in the open-loop mode and has the operational flexibility to operate its shell and tube heat
exchanger vaporizers in the open-loop (6 days to offload at 0.5 Bcfd) or closed-loop mode (7.5 days to offload at 0.4 Bcfd) (USCG, 2003).
Available for 2002 only (EIA, 2003).
eThe Elba Island facility has applied for FERC authorization to expand sendout and storage capacity (FERC, 2006b).
NA - Not available; Information was not available at time of Final 2006 Plan.
SCV - Submerged combustion vaporizer.
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Section 20.0 - Review of Direct Dischargers
FERC
Existing and Proposed
North American LNG
Terminals
As of October 19, 2006
" US f?f
US Jurisdiction
O FERC
O MARAD/USCG
Office of Energy Projects
CONSTRUCTED
A. Everett. MA : 1.035 Brfd (SUE2V'TrdCosbe - DOMAC)
B. Cove Point, HD : 1.0 Bdc' dtoninta- - Cove Point LNG)
C. Elba Island. GA ; 1.: Bcfd i'E: Pas:. - Sc.ther- L',G;
D, Lake Charles, LA : 2.1 Bcfd (Southern Union -Trunkline LNG)
E. Gulf of Mexico: 0.5 Bcfd (Guf G=te*=y E^erc.v 3::cc= - E*ceie-=te Enei-y'i
APPROVED BY FERC
1. Hackberry, LA ; 1.5 Bcfd (Camera" LNG - Semens Energy)
2. Bahamas : 0.84 Bcfc (AES Ocean Express)*
3. Bahamas : 0,83 Bdt (Calypso TiacieMl'l*
4. Freeport, TX : :.S Brfd (Chs-ieie,''Fieepbr L',5 De'-.l
5. Sabine. LA ; 2.6 Brfd (Sabine PdSS C-eniere LNG'I
6. Corpus Christi, TX: 2.6 Bcftd (C-eniere LNG)
7. Corpus Christi, TX : 1.1 Brfd (Visa Del So -Exxo-Mobi)
S. Fall Riyer. MA : 0.8 Bcfd (Weaver's Cove Ene'ay'Hess LNG'i
9. Sabine, TX : 2.0 Bcfd (Golde- Pass - EiJtonMobil)
10. Corpus Christi. TX: 1.0 Bcfc ;]--.|es>c Enerc.\. - Qccide-t-l Energy Vent-iesi
11. Logan Township, NJ : 1.2 Bcfd (Crown Landing LNG - BP)
12. Port Arthur, TX: 3,0 Bcfd [Semp-s)
13. Cove Point MD : 0.3 Bcfd (Da-ni-ion)
14. Cameron, LA: 3,3 BA (Crec e Tra I LNG - Chenie-e LNGJ
15. Sabine, LA: ;/ Ecfd (Sabin^ Pass Cheniere l^JG - Expansion)
16. Freeport, TX: 2.5 Bcfd (C-eniere/FreepO't LNG Dev. - Expansion)
APPROVED BY HARADJCOAST GUARD
17. Port Pelican: :.6 Ed2 I'Chevi'c- Tex=cc''
18. Louisiana Offshore : 1.0 Brfd (Gulf Landi-Ci - SrellJ
CANADIAN APPROVED TERMINALS
19. St, John. NB: 1,0 Bcfd (Cdnaioit - living Oi)
20. Point Tupper, HS 1.0 Brf.'d [Bea-Head LNG - A-idaiko]
21. Kitimat, BC: 0.61 Bcfd (Galvesto- LNQ;
MEXICAN APPROVED TERMINALS
22. Altamira, Tamulipas : C.7 Bcfd 'She l-'Total/MicsJ]
23. Baja California, MX : :,0 Bcfd (Energy Cosca Azul - Serrpiaj
24. Baja California - Offshore : 1.4 Bcfd (O'evron Texaco)
PROPOSED TO FERC
25. Long Beach, CA : 0.7 Brfd, I'M tsub shi/ConocoPhilrps - Sound Eneigy Soudons;
26. LI Sound, NY: 1.0 Bcfd 'B-oadwacet Energy -Tra-sCanada/SJiell)
27. Pascagoula. MS: 1.3 Bcfd ^GJf L',G Ene-gy LLC)
28. Bradwood. OR: 1.0 Brfd (Northern Star LNG - No'thern Star Natural Gas LLC)
29. Pascagoula, MS: 1.3 Bcfd {C=sotte Landi-3 - Che'/icnTe:* = :o'
30. Port Lavaca, TX: 1,0 Bcfd (Calhoun LNG -GufCodSt LNG P=it.is-s;
31. Hackberry, LA : 1.15 Brfd (Carnero- LNG - Sensia Ene--gy - ExpdnsionJ
32. Pleasant Point, ME : 2.0 Bcfd (Q.oddy Bay, U.C)
33. Robbinston, ME: 0.5 Bcfd (Don-east LUG - Kestrel Ene'gy)
34. Elba Island, GA; 0.5 Bdd 'Ł Paso - Southern LNG)
35. Baltimore. MD: 1.5 Brfd (AES Spai-o*s Poi-t - AES Corp.}
36. Coos Bay. OR: 1,0 BcTj ,Joir = n Cove E-eigy Project"!
PROPOSED TO MARADJCQAST GUARD
37. Offshore California : l.E Bri X.-3r o PC t - B-P E Ira-':
38. Offshore California : 0.5 3A. i'C s=nwter Port LLC - 'lOrthe'nSta- NG LLC)
39. Offshore Louisiana : 1.0 Brfd (Main Pass McMoRa- Exp.)
40. Gulf of Mexico: 1.5 Bcfd (Beacon Pet Cean Ene^ay Ter-ni-al - ConocoPhillips)
41. Offshore Boston: 0.4 Bcfd fNept.ne LNG - SLEZ LNG)
42. Offshore Boston: 0.8 Bcfd ,Notheast Gateway - ExceWate Energy)
43. Gulf of Mexico: 1.4 Birc I'Bierville Offshore Energy Terminal - TORP)
44. Offshore Florida: ' Bcfd (SUEZ Calypso - SUEZ L'-S;~'
45. Offshore California: 1,2 B
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Section 20.0 - Review of Direct Dischargers
• Offshore: In addition to the one existing offshore facility, only one offshore
terminal is currently licensed for operation.1 However, the operator has yet to
start construction on the terminal (Gulf Landing). The Gulf Landing LNG
import terminal is proposing to use an open loop re-gasification technology
(open rack vaporizers). EPA's estimate of pollutant discharges from this
facility can be found in Table 4 of a memorandum entitled, "Overview of
Liquefied Natural Gas (LNG) Import Terminals for CWA Section 304(m)
Effluent Guidelines Planning", dated August 19, 2004 (Johnston, 2004).
Proposed LNG Import Terminals
There are 23 proposed LNG import terminals in the U.S. Table 20-3, Table 20-4, and
Figure 20-2 present more detailed information about each of these facilities.
• Onshore: As of November 9, 2006, 13 onshore are awaiting FERC approval
of their license application to operate. These land-based terminals propose to
use closed-loop re-gasification technologies. EPA did not identify any
significant pollutant discharges associated with the re-gasification processes at
these facilities as compared to facilities with open-loop re-gasification.
• Offshore: As of November 9, 2006, 10 offshore terminals are awaiting
regulatory approval of their license application to operate (U.S. Coast Guard
in Federal waters and FERC in State waters).2 EPA has learned that only one
operator is proposing to use open-loop re-gasification technology (Bienville
Offshore Energy Terminal). The remaining nine terminals are proposing to
use closed-loop re-gasification technologies.
Planned LNG Import Terminals
There are eight planned LNG import terminals in the U.S. Figure 20-3 presents the
potential facilities. As of November 9, 2006, five onshore and three offshort terminals are planned,
but have not yet applied for a license to operate. Details on these terminals are not available at the
time of the Final 2006 Plan.
1 EPA notes that one operator has indefinitely suspended activities to construct an offshore terminal that received
approval for its Deepwater Port Act license (Port Pelican). See 70 FR 57885 (4 October 2005).
2 EPA also notes that three applicants have withdrawn their Deepwater Port Act license application for their offshore
terminals (Brinkmann, P.E., 2005; Cornelius, 2006a; Cornelius, 2006b).
20-8
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Section 20.0 - Review of Direct Dischargers
Table 20-2. Approved U.S. Land-Based LNG Import Terminals
No.
1
2
3
4
5
6
Project Name/ Operator/ FERC
Docket No.
Freeport LNG Project
Cheniere/Freeport
CP03 -75-000 (Phase I)
CP05-361-000 (Phase II)
Phase I:
$400 million facility cost
Sabine Pass LNG and Pipeline Project
Cheniere
CP04-3 8-000
CP04-47-000
$600 million facility cost
Cheniere Corpus Christi LNG Terminal
and Pipeline Project
Cheniere
CP04-37-000
CP04-44-000
$450 million facility cost
Golden Pass LNG Terminal and Pipeline
Project
ExxonMobil
PF04- 1-000
$600 million facility cost
Vista del Sol LNG Terminal Project
ExxonMobil
PF04-3-000
PF04-9-000
$600 million facility cost
Ingleside Energy Center LNG Project
Occidental
PF04-9-000
Location
Freeport, TX
Cameron Parish,
LA (across from
Sabine Pass)
Corpus Christi, TX
Sabine, TX
Corpus Christi, TX
Corpus Christi, TX
Storage Capacity
Phase I:
320,000 cubic meters
(m3) (2 tanks each with
160,000 m3)
Phase II:
480,000 cubic meters
(m3) (3 tanks each with
160,000 m3)
480,000 m3 (3 tanks
each with 160,000m3)
480,000 m3 (3 tanks
each with 160,000m3)
Phase I: 480,000 m3 (3
160,000 m3 tanks)
Phase II: 800,000 m3 (5
160,000 m3 tanks)
480,000 m3 (3 tanks
each with 160,000m3)
320,000 m3 (2 tanks
each with 160,000m3)
Sendout
Capacity
Phase I: 1.5
Bcf/d
Phase II: 4.0
Bcf/d
2.6 Bcf/d
2.6 Bcf/d
Phase I: 1
Bcf/d
Phase II: 2
Bcf/d
Phase I: 1
Bcf/d
1 Bcf/d
Vaporizer Design
Closed-Loop:
Air heat exchanger
(heating tower)
Supplemental gas-
fired heater for cold
weather
Closed-Loop:
Gas-fired heater
Closed-Loop:
Gas-fired heater
Closed-Loop:
Gas-fired heater
Closed-Loop:
Gas-fired heater
Closed-Loop:
Water heat exchanger
(waste water from the
chemical plant)
LNG Ship
Frequency
Phase I: 200
ships/year
Phase II: 400
ships/year
300 ships/year
300 ships/ year
Phase I: 1 ship/4
days (91 ships/
year)
Phase II: 1 ship/2
days (183 ships/
year)
1 ship/4 days (91
ships/year)
1 ship/3 days
to
o
-------
Section 20.0 - Review of Direct Dischargers
Table 20-2 (Continued)
No.
7
8
9
10
11
Project Name/ Operator/ FERC
Docket No.
Cameron LNG, LLC
Sempra Energy
CP02-374-000
CP02-376-000
CP02-377-000
CP02-378-000
$700 million facility cost
Weaver's Cove LNG
CP04-36-000
$250 million facility cost
Creole Trail LNG
Cheniere LNG
PF05-8
Port Arthur LNG Receiving Terminal
Project
Sempra
Docket No. PF04-1 1-000
BP Crown Landing LNG
PF04-2-000
PF04-5-000
$500 million facility cost
Location
Hackberry, LA
Fall River, MA
Cameron, LA
Port Arthur, TX
Logan Township,
NJ
Storage Capacity
480,000 m3 (3 tanks
each with 160,000m3)
200,000 m3 (1 tank)
640,000 m3
480,000 m3 (3 tanks
each with 160,000m3)
450,000 m3
Sendout
Capacity
1.5 Bcf/d
0.4 Bcf/d
3.3 Bcf/d
1.5 Bcf/d
1.2 Bcf/d
Vaporizer Design
Closed-Loop
Closed-Loop: Gas-
fired heater
Closed-Loop: Gas-
fired heater
Closed-Loop: Gas-
fired heater
Closed-Loop: Gas-
fired heater
LNG Ship
Frequency
210 ships/year
50-70 ships/ year
300-400 ships/year
150 ships/year
100 ships/year
to
o
Source: Dockets for each project available at http://elibrarv.ferc.gov/industries/lng/indus-act/terminals/exist-prop-lng.asp: EIA's Current View on LNG Imports
into the United States (Martin, 2004).
Note: Not listed in this table are expansions at existing or other approved terminals, and two terminals to be sited in the Bahamas.
-------
Section 20.0 - Review of Direct Dischargers
Table 20-3. Proposed U.S. Land-Based LNG Import Terminals
No.
1
2
3
4
5
6
7
Project Name/ Operator/ FERC Docket No.
Sound Energy Solutions
Mitsubishi/ConocoPhillips
PF03-06 and PF04-58 (see FR Vol. 69, No. 27, p.
6277-6278)
Gulf Energy
Gulf Energy LNG LLC
PF05-05 (see FR Vol. 70, No. 46, p. 11960-11961)
Northern Star LNG
Northern Star Natural Gas, LLC
PF05-10 (see FR Vol. 70, No. 181, p. 55123-55125)
Casotte Landing
Chevron
PF05-09 (see FR Vol. 70, No. 70, p. 19433-19435)
CalhounLNG
Gulf Coast LNG Partners
CP05-91 (see FR Vol. 70, No. 148, p. 44616-44618)
Pleasant Point
Quoddy Bay, LLC
PF06-ll(seeFRVol. 71, No. 54, p. 14200-14203)
Downcast LNG
Kestrel Energy
PF06-13 (see FR Vol. 71, No. 54, p. 14196-14198)
Location
Long Beach, CA
Pascagoula, MS
Bradwood, OR
Pascagoula, MS
Port Lavaca, TX
Pleasant Point, ME
Robbinston, ME
Storage
Capacity
320,000 m3
320,000 m3
320,000 m3
480,000 m3
320,000 m3
480,000 m3
160,000 m3
Sendout
Capacity
l.OBcf/d
l.OBcf/d
l.OBcf/d
1.3 Bcf/d
l.OBcf/d
0.5 Bcf/d
0.5 Bcf/d
Vaporizer Design
Closed Loop: Shell
and tube gas-fired
vaporizers
Not specified
Closed-Loop:
Ambient air
vaporizers
Closed-Loop:
Refinery cooling
water
Not specified
Closed-Loop: Gas-
fired heater
Closed-Loop: Gas-
fired heater
LNG Ship
Frequency
120 ships/year
115 ships/year
125 ships/year
166 ships/year
120 ships/year
90 ships/year
50 ships/year
to
o
Source: Dockets for Port Arthur, BP Crown Landing, and Creole Trail are available at http://elibrarv.ferc.gov/industries/lng/indus-act/terminals/exist-prop-
Ing.asp: Notice of Intent from Federal Register Notices as presented in the table and 71 FR 30128-30129, May 25, 2006 for Casotte Landing; EIA's Current
View on LNG Imports into the United States (Martin, 2004).
Note: Not included here are the most recently proposed LNG terminals in Sparrows Point, Baltimore, MD, and Coos Bay, OR (see Figure 20-3) and expansions
at existing or approved facilities. Also does not include a terminal to be located in Long Island Sound, which considered an offshore terminal and is presented in
Table 20-4.
-------
Section 20.0 - Review of Direct Dischargers
Table 20-4. Licensed and Proposed U.S. Offshore LNG Import Terminals
No.
1
2
3
4
5
6
7
8
9
10
11
Company
(Facility Name)
Shell
(Gulf Landing) (DPA License
Issued)
BHP Billiton
(Cabrillo Port) (Proposed)
Freeport Energy
(Main Pass Energy Hub) (Proposed)
Crystal Energy
(Clearwater Port) (Proposed)
Excelerate Energy
(Northeast Gateway) (Proposed)
SUEZ
(Neptune LNG) (Proposed)
TransCanada/Shell
(Broadwater Energy) (Proposed)
SUEZ
(Calypso Energy) (Proposed)
TORP Technology AS
(Bienville Offshore Energy
Terminal) (Proposed)
Woodside Natural Gas
(Ocean Way Secure Energy)
Atlantic Sea Island Group LLC
(Safe Harbor Energy)
Offshore Location
West Cameron Block 213 - GOM
38 miles south of LA
Offshore Oxnard, CA
14 miles from CA
Main Pass Block 299 - GOM
16 miles from LA
Offshore Ventura County, CA
12.6 miles from CA
Offshore MA
13 miles south-southeast of Gloucester,
MA
Offshore MA
22 miles northeast of Boston, MA
Long Island Sound, NY
9 miles from NY and 1 1 miles from CT
Offshore FL
10 miles east of Port Everglades, FL
Main Pass Block 258 - GOM
63 miles south of Dauphin Island, AL
Offshore Los Angeles, CA
28.3 miles from CA
Offshore NY/NJ
13.5 miles south of Long Beach, NY
and
19 miles east of Sandy Hook, NJ.
Proposed Re-
gasification
System
Open-Loop: ORV
Closed-Loop:
SCV
Closed-Loop:
SCV
Closed-Loop:
SCV
Closed-Loop:
Shell and Tube
Closed-Loop:
Shell and Tube
Closed-Loop:
Shell and Tube
Closed-Loop:
Shell and Tube
Open-Loop: Hi-
Load Shell and
Tube
Closed-Loop: Air
Heat Exchange
Closed-Loop: Air
Heat Exchange
USCG Deepwater
Port Licensing
Information
(Docket No.)a
Yes
(16860)
Yes
(16877)
Yes
(17696)
Yes
(TBD)
Yes
(22219)
Yes
(22611)
No (FERC lead, see
Docket Numbers PF05-
04 and CP06-54)
Yes
(TBD)
Yes
(24644)
Yes
(TBD)
Yes
(TBD)
Indicates whether the company has applied for a deepwater port license.
The USCG docket for each Deepwater Port license application can be accessed using the docket number and the following website:
http://www.uscg.mil/hq/g-m/mso/mso5.htm. This table was compiled using documents available on the USCG docket, with the
following exceptions: (1) information about Clearwater Port is from presentations and press releases, most of which are available at
http://www.crvstalenergyllc.com: (2) Broadwater Energy is from http://www.broadwaterenergy.comA (3) Calypso Energy is from
http://www.suez.com/upload/up 1527.pdf and Calypso LNG LLC, Deepwater Port License Application (Public), Volume I, Calypso LNG
Project, Page 3, February 2006; (4) the vaporizer technology for Woodside Ocean Way Secure Energy came from
http://www.oceanwaysecureenergy.com/marinelife.html. Additionally, the Port Pelican, Pearl Crossing, Compass Port, and Beacon Port
LNG import terminals are not included in this table. Port Pelican's licensee suspended construction activities (Poten & Partners, 2004)
(70 FR 57885; 4 October 2005). Pearl Crossing, Compass Port, and Beacon Port all withdrew their Deepwater Port Act license
applications (70 FR 73059, 8 December 2005; Brinkmann, 2005; Cornelius, 2006b). The Atlantic Sea Island Group proposes to
construct a man-made island about 13.5 miles offshore southern side of LI, New York, in approximately 60 feet of water in the Atlantic
Ocean. The facility-proposed design will include four 180,000 m3 storage tanks with a send-out capacity of 2 Bcf/d and a proposed in-
service date of 2010 (source: http://www.safeharborenergy.com/. Final Environmental Impact Statement for the Crown Landing LNG
Project and Logan Lateral Project, FERC Docket Nos. CP04-411-000 and CP04-416-000, TABLE 3.2.2-2,
elibrary.fere.gov/idmws/common/OpenNat.asp?fileID=l 1013835, and MARAD website:
http://www.marad.dot.gov/DWP/LNG/port_news/news_detail.asp?ID=25&from=home).
Note: This table does not include the Tidelands Oil & Gas Esperanza Energy or Excelerate's Pacific or Southeast Gateway offshore LNG
import terminals as these facilities have not applied for a Deepwater Port operation license. The Esperanza Energy is focusing its
evaluation on several potential sites up to 12 miles offshore of the greater Long Beach area and use of the open-loop (Hi-Load Shell and
Tube) re-gasification technology (California Energy Commission, 2006). Excelerate's Pacific and Southeast Gateway LNG import
terminals will use a similar design as Excelerate Energy's other LNG import terminals and these two terminals are planned for
development off of the coasts of Northern California and Florida, respectively (California Energy Commission, 2006;
http://www.excelerateenergy.com/activities.php).
TBD — To be determined.
ORV - Open-rack vaporizers.
SCV - Submerged combustion vaporization.
20-12
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Section 20.0 - Review of Direct Dischargers
FERC
Potential North American
LNG Terminals
As of October 19, 2006
US Jurisdiction
QFERC
QMARAD/USCG
POTENTIAL U.S. SITES IDENTIFIED BV PROJECT SPONSORS
46. Offshore California: 0.7^ Bcfd. I'Chevron Texacoi
47, St. Helens. OR: 0.7 Bcfd fPo-t Westward LNG LLC)
48. Philadelphia. PA: 0,6 Bee ^Freedon Energv Center- POW)
49. Astoria. OR: 1.0 Bcfd ;skip«'on LNG - Calpt'ne)
50. Boston, MA: 0,S Bcfd (AES Bat»>y Rock I±C - AES Co-p.)
51. Calais, ME: ? Bcrd JBP Co-suit ng LLC;
52. Offshore New York: 2.0 Brfd (Safe Hsifcor Energy - ASK, LLC)
53. Offshore California: 0.6 Bcfd (Pacific Gateway - Excele'ate Energy)
54, Offshore California: ? Bcfd (Espe anzd E-e>gy - Tideldncsl
POTENTIAL CANADIAN SITES IDENTIFIED BY PROJECT SPONSORS
55, Quebec City, QC : 0.5 B
-------
Section 20.0 - Review of Direct Dischargers
Table 20-5. Existing, Approved, Proposed and Planned U.S. LNG Import Terminals (2006)
Status
Existing
Approved (FERC)
Approved (CG)
Proposed (FERC)
Proposed (CG)
Planned (FERC/CG)
Total
Total Throughput
(Bcfd)
5.84
25.30
1.60
13.55
10.30
4.45
61.04
Annual Throughput
(tcf/yr)
2.13
9.23
0.58
4.95
3.21
1.62
22.27
Percentage of Total
9.80%
42.5%
2.70%
22.8%
14.8%
7.5%
100%
Source: Existing LNG Terminals (FERC, 2006a); Existing LNG Terminals (FERC, 2006c).
Note: Table includes only planned facilities as of as of November 9, 2006 where a throughput estimate is available.
The Port Pelican, Pearl Crossing, Compass Port, and Beacon Port LNG import terminals are not included in this
table. Port Pelican's licensee has indefinitely suspended construction activities (Poten & Partners, 2004) (70 FR
57885; 4 October 2005). Pearl Crossing, Compass Port, and Beacon Port withdrew their Deepwater Port Act license
applications (see 70 FR 73059, 8 December 2005; Brinkmann, 2005; Cornelius, 2006a, Cornelius, 2006b).
20-14
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Section 20.0 - Review of Direct Dischargers
D Planned
D Pending - Coast Guard
• Pending - FERC
• In-Service and Approved
In-Service Pending - Pending -
and FERC Coast
Approved Guard
Planned
20.1.4
Figure 20-4. Existing and Proposed North American LNG Terminals
(FERC, 2004)
Economic Profile
United States and foreign companies are competing to build LNG import
terminals in many regions of North America because of the perceived opportunity in the growing
LNG industry (Kelly, 2004). According to industry analysts, the cost of LNG at the point of
U.S. delivery is approximately $3/MMBtu (Greenspan, 2005). Below is a rough breakdown of
this cost (Economides, 2005):
• $l/MMBtu is the cost of the feedstock gas at the exporting location;
• $l/MMBtu is the cost to liquefy the gas;
• $0.30/MMBtu is the cost to regasify the LNG (open-loop) or
$0.375/MMBtu (closed-loop);3 and
• $ 1/MMBtu is the cost to transport the LNG.4
3 EPA estimated the incremental cost of using closed-loop regasification instead of open-loop (i.e., $0.375 - $0.300
= $0.075 MMBtu), based on information from the Gulf Landing facility. EPA assumed a $5.00/MMBtu price of gas
in 2009 (when Gulf Landing comes on-line) through 2029, and assumed the higher end of the incremental gas usage
found in the literature (increment of 1.5 percent of the LNG cargo). EPA then estimated that the additional energy
cost to Gulf Landing for the closed-loop regasification system ($27.4 million in 2009) is the major cost differential
between open-loop and closed-loop regasification. In 2010, therefore, the operating cost differential between open-
loop and closed-loop regasification for this facility might be roughly $0.075/MMBtu processed (= $27.4 million/365
million MMBtu).
4 This is a conservative estimate for the transportation of LNG to the United States, as the longer the distance of the
LNG supply to the United States, the higher the shipping costs. Approximately, 0.25 percent of the LNG is
consumed in transit due to the "boil-off process, which is necessary for maintaining LNG temperature.
20-15
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Section 20.0 - Review of Direct Dischargers
The long-range U.S. wellhead price of gas expected through 2030 ranges roughly
from $4.00-$6.00/MMBtu in 2004 dollars (EIA, 2006a).
Financing Models for LNG Import Terminals
An important factor in evaluating the potential economic impact of various
pollutant control technologies (e.g., using closed-loop re-gasification in lieu of open-loop re-
gasification) is to identify whether the LNG import terminal operates at a profit (profit center) or
at cost (or loss) in support of a larger, profit-making line (cost center). Profit centers are
analyzed at the facility level; since changes in cash flow can be properly interpreted (a change
from positive to negative cash flow due to a rule is usually counted as a regulatory closure). Cost
centers (or captive facilities, for which some or all revenues are accounted for higher up in the
corporate structure) cannot be analyzed at the facility level; impact must be measured at a higher
level in the corporate hierarchy. At the higher level, a rule-induced change from positive cash
flow to negative cash flow or change in profitability considered significant denotes a regulatory
closure or other impact. This economic analysis reviewed the four basic financing models by
which LNG terminals might operate (Chinloy, 2005):
• Tolling: A fixed fee is charged and the supply of LNG is set through
contracts. The fixed fee typically covers the capital and operating costs,
while allowing for reasonable returns on investment. Land-based facilities
such as the Lake Charles LNG import terminal include as part of their fee
a percentage of gas to operate their closed loop re-gasification system.
Tolling is the preferred approach for most U.S. LNG terminals (Chinloy,
2005). This type of facility is a stand-alone operation (i.e., profit center).
• Integrated: Contracts or integrated investments establish a chain of LNG
supply. Integrated investments have recently been used by integrated
majors, e.g., Shell's Gulf Landing, LNG import terminal. This model may
entail linkages from production, through liquefaction, transportation, re-
gasification, and distribution. The integrated investments approach is
becoming more prevalent in the United States. This type of facility is
likely to be a cost center.
• Rate-based: The terminal is owned by a regulated utility (e.g., gas
distribution or electric). This type of facility is likely to be a cost center.
• Merchant: The terminal operates primarily without contracts in place. It is
subject to substantial volume and price risk (Chinloy, 2005). This model
is unlikely to be able to arrange financing (Chinloy, 2005). This type of
facility is a stand-alone operation (i.e., profit center).
This economic impact analysis considered the two most prevalent and applicable
factors to determine which business model—tolling or integrated— is more applicable for
various LNG import terminals operated by large, integrated oil and gas firms:
20-16
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Section 20.0 - Review of Direct Dischargers
• The tolling model in which a company acts as a service provider with
tolling arrangements provides much lower returns on investment than
those from the integrated model (Deutsche Bank, 2005).
• An integrated model allows operators to take advantage of significant
price differentials (arbitrage) between foreign gas prices or the cost of
producing gas in foreign locations and the price of gas in the United States
(or elsewhere in the LNG importing regions of the world). These
differentials, even with the cost of liquefaction, transport, and re-
gasification, are significant and can provide enormous profits.
For example, the operating earnings for an integrated model on each MMBtu are
estimated to total $1.70 ($5.00 price of gas in the United States minus the $3.30 anticipated cost
of delivering gas via LNG importation, assuming that open-loop re-gasification technology is
used). This is a 34.0 percent operating margin. With closed-loop re-gasification technology, an
additional 1.5 percent of gas throughput is used, costing $0.075 ($5.00*0.015 = $0.075); thus,
the earnings per MMBtu are slightly smaller ($1.625 = $1.70 - $0.075), representing a 32.6
percent margin. It appears that, to the extent possible, most LNG import terminals owned by
integrated majors would process their own LNG and that stand-alone profitability would unlikely
be the main objective of the terminals' operation.
Number of New Facilities Expected
EPA considered whether the potential growth of this industrial sector might add
significantly to the estimate of facilities requiring NPDES permits with effluent limits for open-
loop re-gasification wastewaters. EPA examined whether the present trend of LNG import
terminal proposals will continue or expand (see Figures 20-2 and 20-3). EPA concluded that, for
several reasons, the significant growth in LNG import terminal proposals would most likely not
continue at the pace shown in recent years. The major factors limiting the importation of LNG to
the U.S. consumer include not the lack of LNG re-gasification terminals in the United States, but
the following economic and supply-side related issues:
• Most industry analysts note that over-capacity is a major issue for this
industrial sector (Deutsche Bank, 2005; A.G. Edwards, 2005; Credit
Suisse First Boston, 2005; Citigroup Smith Barney, 2004; EIA, 2006a;
EIA, 2006b; ERG, 2006; Chinloy, 2005). In 2005, the existing terminals
operated only at 40 percent capacity (GPO, 2005) and capacity utilization
is expected to remain roughly in the 50 percent to 70 percent range
(Deutsche Bank, 2005; see Figure 20-5) over the next decade or longer,
even while demand for LNG grows and several new LNG terminals are
constructed.
20-17
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Section 20.0 - Review of Direct Dischargers
2004 2005
=lba Eland
"-Bepcrl
Golden Pass LNg
I lla«»rjjri«
•• 6, f Satavay
' 'i^-* -jnding
I Mngleside-NS
oire
oabire Pass
Cameron LNG
npcrt Fcrecasl
Figure 20-5. Excess Regas Capacity in the U.S.—Here to Stay
(U.S. DOE, EIA, as cited in Deutsche Bank, 2005)
• LNG supplies are tight, due to the significantly greater cost of constructing
liquefaction infrastructure and political instability in many potential LNG
exporting regions (Deutsche Bank, 2005). For example, a shortage of
feedstock gas has recently led to a number of global liquefaction projects
operating at less than full capacity due to, among other things, declining
reserves and political unrest in LNG-producing countries (LNGLawblog,
2006e). This constraint in liquefaction capacity, not re-gasification
terminal capacity, will remain a major constraint for North American LNG
imports (North American National Gas Group, 2005).
• Demand for natural gas worldwide is growing (EIA, 2006b), particularly
in Europe and the Far East, which are also expanding their LNG re-
gasification infrastructure (GSI, 2005). EIA indicates that more rapid
growth in worldwide demand for natural gas than that predicted in 2005
will reduce the availability of LNG supplies, raise worldwide gas prices,
and make LNG less economical in U.S. markets (EIA, 2006b).
• Many other LNG-importing countries have fewer alternatives to LNG for
their gas needs and are willing to pay a much higher price than U.S.
consumers for that LNG. Price differences between the U.S. and other
foreign markets competing for limited LNG supplies are often measured in
dollars.5 It is this price differential that will determine where LNG
suppliers send their cargos.6 LNG owners are diverting cargos from the
United States to other more profitable markets. According to FERC, LNG
import terminals in the U.S. are "operating at less than 40 percent
5 For example, the Cove Point LNG terminal in Maryland competed in the global market with a netback of
$6.53/MMBtu for LNG supplier (Trinidad), while Lake Charles yielded only $5.5 1/MMBtu, compared to Spain's
$9.02/MMBtu netback (LNGlawblog.com, 2006e).
6 See the assessment of James W. Duncan, Director of Structured Products for ConocoPhillips Gas & Power, "LNG
is a growing and dynamic market, but there are going to be new players in the marketplace, which is going to
prohibit and inhibit the amount of LNG that is available to come here. What will drive that market will be price.
Molecules flow to dollars. It's not a mystery. I think it has been mentioned that Spain paid the equivalent of
$14/MMBtu last summer.. .and the molecule [not] surprisingly went there and did not come here. Those price
dynamics are coming to fruition" (Rigzone, 2006). _
20-18
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Section 20.0 - Review of Direct Dischargers
capacity" (Rosenberg, 2006). When asked why, Mr. Kelliher, the FERC
chairman, replied, "It's because we have to compete with foreign demand.
LNG comes to this country either by long-term contract or in spot
shipments. We've been losing out on a lot of spot shipments to Europe. If
prices are higher elsewhere, that's where the spot shipments are going to
go ... The world has twice the capacity to import LNG as it has to make
LNG. That gives developers of the liquefaction facilities more choices
when it comes to what markets they prefer to use" (Rosenberg, 2006). For
example, in November 2005, an LNG transport ship traveling from
Nigeria and bound for a U.S. LNG import terminal idled in the Gulf of
Mexico for a week - during which prices soared in Europe - before sailing
back across the Atlantic Ocean to Spain to unload its cargo (Gold, 2006).
More recently, LNG cargos destined for Lake Charles, LA, and Cove
Point, MD, were diverted to Mexico and Spain, respectively
(LNGlawblog.com, 2006f).
Last year saw very low imports (GPO, 2006). Platts and industry analysts
attribute the low U.S. imports to intense Asian and European competition
for LNG coupled with mild winter weather in the United States
(LNGlawblog.com, 2006a). Figure 20-6 shows the impacts of U.S.
alternatives on LNG imports. Future growth of LNG imports is projected
to level out after 2015 as unconventional sources of gas, such as CBM
(ENR, 2006) and Alaska gas become more available (EIA, 2006a; EIA,
2006b). Furthermore, several LNG import terminals are planned for
Mexico and Canada (Smith, 2005). Gas from these terminals would reach
California and New England. Mexico expects to be a net exporter of
natural gas to the United States by 2010, or even earlier, as oversupply
appears to be developing there (LNGlawblog, 2006b, 2006c).
20-19
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Section 20.0 - Review of Direct Dischargers
Growth in Alaskan Production
Growth in
Non-Associated Unconventional
Base Production (all sources)
Figure 20-6. Growth in LNG Imports Given Growth in Alaskan and
Unconventional Gas Production
(EIA, 2006b)
Given these economic and supply-side related issues, DOE and others predict that
U.S. demand for LNG will constrain imports and that very few of the approved, proposed, or
planned terminals will be built over the next 10 years or longer (EIA, 2006a; EIA, 2006b;
Deutsche Bank, 2005; A.G. Edwards, 2005; Credit Suisse First Boston, 2005; Citigroup Smith
Barney, 2004; Chinloy, 2005; Greenspan, 2005). DOE projects two land-based facilities under
construction, two expansions at existing land-based facilities, and four other facilities that will be
built. These terminals are expected to serve the Gulf Coast, Southern California, Florida, and
New England (EIA, 2006a). Of these four, two might not be U.S.-based (Southern California
and New England might be served by terminals currently in advanced planning stages in Mexico
and Canada—see Figure 20-3; also see Chinloy, 2005).
In summarizing the current U.S. LNG import terminal market, Chinloy sees
expansions at existing facilities, the two terminals under construction, and a third terminal in
advanced stages in Mexico (which is planned, in part, to serve Southern California) as leaving a
1.9 Bcfd "gap" in the predicted 28.1 tcf per year of U.S. natural gas demand in 2015 (which is
about 80 Bcfd) (Chinloy, 2005). The "gap" is only 2 percent of projected demand for natural gas
in 2015. Chinloy sees a need for at most only six additional LNG import terminals in the next 10
years. Given that several approved or proposed terminals would each be larger than this 1.9
Bcfd gap, the next decade may see very few additional terminals being constructed (see Table 5).
Finally, analysts predict a shakeout in LNG terminal plans in the next few years,
as those terminals closest to completion send signals to the market that the LNG supply gap has
been filled (Van Praet, 2004; NGI, 2006). EPA has already seen four offshore projects, for
example, that either had construction activities suspended (Port Pelican) (Poten & Partners,
20-20
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Section 20.0 - Review of Direct Dischargers
2004; 70 FR 57885, October 4, 2005), or the applicant has withdrawn the terminal from proposal
(Pearl Crossing and Compass Port).
20.1.5 Summary of EPA's Review of the LNG Industry
Based on its review of the LNG import terminal industry, EPA is not identifying
this industry for ELGs rulemaking at this time. First, out of existing LNG import terminals, all
but one use closed-loop re-gasification. Discharges from closed-loop re-gasification likely
present a low hazard to human health and the environment. Second, out of all of the approved,
proposed, or planned LNG import terminals, few are likely to be built due to economic and
supply-side issues. Moreover, even fewer are projected to use open-loop re-gasification. As
noted above, no potential new onshore facilities and only three possible new offshore LNG
import terminals have proposed to use "open-loop" re-gasification. Because the hazard
associated with this industry is attributable to only a few facilities (one existing facility and
possibly two new facilities), EPA believes that discharges from this industry can best be
addressed through case by case BPJ-based permit limits, rather than through a categorical ELGs.
BPJ is a particularly appropriate tool where - as here - there is significant site-specific
variability in terms of facility design. A BPJ case-by-case approach would enable permit writers
to best capture the technical considerations that might influence the identification of the
appropriate pollutant control technology and effluent limits.
Therefore, EPA is exercising its discretion to not identify LNG in the 2006 Plan
because it does not believe categorical ELGs would be an appropriate tool to regulate discharges
from this category. The Supreme Court in Norton v. Southern Utah Wilderness Alliance
explicitly recognized the importance of Agency discretion over its internal planning processes,
finding that the statutory mandate at issue was not sufficiently specific to require the Agency to
include certain provisions in its plan. In this case, the CWA requires all NPDES permits to
contain technology-based effluent limitations - but also specifically allows those limitations to
be developed using best professional judgment under CWA section 402(a)(l), rather than
pursuant to ELGs. See CWA section 304(b)(2)(B). Significantly, section 301(b)(3)(B) was
enacted contemporaneously with section 304(m) and its planning process, suggesting that
Congress contemplated the use of both tools, with the choice of tools in any given 304(m) plan
left to the Administrator's discretion. Like the statutory mandate in Norton, the CWA
requirement that EPA develop an effluent guidelines plan - when coupled with the direction to
establish technology-based limitations either through ELGs or site-specific BAT decision-
making - cannot be read to constrain the Agency's discretion over what it includes in its plan.
20.2 Miscellaneous Foods and Beverages Industry
During its 2005 annual review, EPA identified 26 SIC codes related to the
manufacture of a variety of food and beverage products that were not covered by any existing
ELGs. EPA found that industries in these 26 SIC codes were properly considered a potential
new stand-alone category based on the similarity of products produced as well as the similarity
of their operations and wastewater characteristics. EPA's finding is supported by the fact that
EPA had previously considered many of these industries to be part of a stand-alone category -
the Miscellaneous Foods and Beverages Point Source Category - when it began ELGs
rulemaking for this industry in the 1970s.
20-21
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Section 20.0 - Review of Direct Dischargers
EPA's analysis of this industry for its 1970's rulemaking is detailed in its "Draft
Development Document for Effluent Limitations Guidelines and New Source Performance
Standards for the Miscellaneous Foods and Beverages Point Source Category" (U.S. EPA,
1975a). At that time, EPA determined it was appropriate to subcategorize the industry into five
segments: vegetable oil processing and refining; beverages; bakery and confectionary products;
pet foods; and miscellaneous and specialty products. EPA concluded that the major parameters
of significance discharged from this industry were conventional parameters (BOD5, TSS, oil and
grease, and pH) and that such discharges did not contain toxic pollutants (U.S. EPA, 1975a; U.S.
EPA, 1975b). While EPA recommended establishing effluent guidelines limitations for
conventional parameters from direct dischargers in certain sub categories, it did not recommend
pretreatment standards for indirect dischargers because it concluded that none of the constituents
in miscellaneous foods and beverage wastewaters would interfere with or pass through a POTW
(U.S. EPA, 1975a). EPA did not continue its efforts to establish ELGs for this category because
it changed the focus of its ELGs program to toxics shortly after completion of its analysis of this
industry.
For purposes of assessing whether to identify the miscellaneous foods and
beverages industry as a potential new category in the 2006 Plan, EPA again reviewed the
discharges from this industry to determine whether ELGs would be an appropriate tool for
addressing the hazard associated with this industry, as discussed below.
20.2.1 Summary of Comments Received
In response to the Preliminary 2004 Plan, the Natural Resources Defense Council
(NRDC) commented that EPA should identify the following industries in the Plan as new
categories for effluent guidelines rulemaking: SIC code 2075: Soybean Oil Mills, SIC code
2082: Malt Beverages, and SIC code 2085: Distilled and Blended Liquors (EPA-HQ-OW-2003-
0074-0733).
20.2.2 Industry Profile
In reviewing data for the industries identified by NRDC, EPA identified
additional industries related to food processing that are not covered by existing ELGs. In total,
EPA found 26 SIC codes that could properly be considered part of a potential new Miscellaneous
Foods and Beverages Category. Table 20-6 lists the counts of facilities in the 26 SIC codes from
data in the U.S. Census (2002), TRI (2002 and 2003), and PCS (2002). The U.S. Census shows
127,000 establishments in the miscellaneous foods and beverages industry in 2002; however, less
than 1 percent reported to TRI (0.286 percent) and PCS (0.097 percent).
20-22
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Section 20.0 - Review of Direct Dischargers
Table 20-6. Number of Facilities in Miscellaneous Foods and Beverages SIC Codes
SIC Code
2032: Canned Specialties
2034: Dehydrated Fruits, Vegetables, Soups
2038: Frozen Specialties, NEC
205 1 : Bread & Other Bakery Products
2052: Cookies & Crackers
2053 : Frozen Bakery Products
2064: Candy & Other Confection Products
2066: Chocolate & Cocoa Products
2067: Chewing Gum
2068: Salted & Roasted Nuts & Seeds
2074: Cottonseed Oil Mills
2075: Soybean Oil Mills
2076: Vegetable Oil Mills, Except Corn
2079: Shortening, Table Oils, Margarine
2082: Malt Beverages
2083: Malt
2084: Wines, Brandy & Brandy Spirit
2085: Distilled, Rectified, & Blended Liquors
2086: Bottled & Canned Soft Drinks &
Carbonated Water
2087: Flavor Extract & Flavor Syrups, NEC
2095: Roasted Coffee
2097: Manufactured Ice
2098: Macaroni, Spaghetti, Vermicelli, Noodles
2099: Food Preparations, NEC
5144: Poultry & Poultry Products
5 182: Wine & Distilled Alcoholic Beverages
Total
2002 Census
Data
1,804
2,196
415
3,305a
259
1,602
1,234
518
163
341a
682
27
l,271a
764
2,425
281
492
193
4,602
39,425
64,637
127,000
2002 PCSb
7
2
4
3
3
1
1
3
2
1
2
15
2
3
10
1
3
28
7
7
1
2
3
9
1
2
123
(13 majors)
2002 TRIC
11
9
26
7
17
7
5
4
1
0
15
60
8
22
22
2
15
6
31
16
2
10
1
65
1
0
363
2003 TRT
14
9
25
9
14
6
6
5
1
0
14
57
10
17
23
2
13
6
23
15
2
6
1
51
1
0
330
Source: 2005 Annual Screening-Level Analysis: Supporting the Annual Review of Existing Effluent Limitations
Guidelines and Standards and Identification of New Point Source Categories for Effluent Limitations Guidelines
and Standards (U.S. EPA, 2005); U.S. Economic Census (U.S. Census, 2002).
aDue to the poor bridging between NAICS and SIC codes, the number of facilities for certain SIC codes could not be
determined for the 2002 Census.
bMajor and minor dischargers.
'Releases to any media.
20-23
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Section 20.0 - Review of Direct Dischargers
EPA obtained data on the number of facilities reporting direct and indirect
discharges from the miscellaneous foods and beverages industry from TRIReleases2002_v4.
Table 20-7 presents the number of facilities in the TRI database, by discharge type. Less than 1
percent of the facilities in the miscellaneous foods and beverages industry report to TRI. Of
these, approximately 58 percent report no water discharge, 37 report discharges to POTWs, and
5 percent report discharges to surface water. As shown in Table 20-6 above, 123 facilities report
direct discharges to PCS.
Table 20-7. Miscellaneous Foods and Beverages Facilities by Type of Discharge Reported
in TRI 2002
SIC Code
Miscellaneous Foods and
Beverages
Reported Only
Direct
Discharges
14
Reported Only
Indirect
Discharges
130
Reported Both
Direct and Indirect
Discharges
10
Reported No
Water Discharges
209
Source: TRIReleases2002 v4.
20.2.3
Wastewater Characteristics
Table 20-8 summarizes the pollutant loads data for the miscellaneous foods and
beverages industry from IRIReleases2003_v02, TRIReleases2002 v04, and PCSLoads2002 v04.
Table 20-8. Summary of Data for the Miscellaneous Foods and Beverages Industry
Data Source
TRI 2003a
TRI 2002a
PCS 2002b
Number of Facilities
Reporting Discharges
Greater than Zero
158
154
13
Annual Pounds
5,560,000
5,390,000
16,200,000
Annual TWPE
5,440
6,860
337,000
Annual
TWPE/Facility
34.5
44.6
168,000
Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2003_v2.
"Includes transfers to POTWs and account for POTW removals.
blncludes major dischargers only.
20-24
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Section 20.0 - Review of Direct Dischargers
Table 20-9 lists the pollutant loads data in PCSLoads2002_v4,
TRIReleases2002 v04, and TRIReleases2003 v02 by SIC code. The facility-specific TWPEs are
generally low (e.g. using TRI2000 data, the average TWPE/facility for each SIC code is
approximately 17). EPA's literature review and its earlier consideration of this industry support
these data. Although the available quantitative data are limited, based on available literature and
its previous study, EPA would expect a low level of toxics in the wastewaters from the
miscellaneous foods and beverages industry. The pollutants expected in greatest quantities
include BOD, TSS, and oil and grease. Possible other wastewater pollutants from this industry
may include organics, nutrients, suspended solids, dissolved solids (including chlorides),
solvents, detergents, and pesticides originating from the processing of the foods and beverages
and the cleaning of process equipment (U.S. EPA, 1975; EBRD, 2006; UNEP, 2004; Triangular
Wave, 2006).
Table 20-10 lists the pollutants of concern identified for the miscellaneous foods
and beverages industry based on reported discharges to PCS and TRI. The top industry pollutant
as reported in PCS in 2002 is sulfide. One facility within SIC code 2085 contributes 100 percent
of the industry sulfide TWPE. The top two industry pollutants as reported to TRI in 2002 and
2003 are nitrate compounds and chlorine. The majority of the TWPE for these pollutants results
from facilities within SIC codes 2075 and 2082. Due to the higher TWPE contributions from
SIC code 2075, 2082, and 2085 (see Table 20-4 for total TWPE contributions from these SIC
codes), and relatively low TWPE of the other SIC codes, the remainder of this section focuses on
these three SIC codes.
20.2.4 SIC Code 2075: Soybean Oil Mills
Establishments included in SIC code 2075 are primarily engaged in
manufacturing the following soybean products:
• Lecithin, soybean;
• Soybean flour and grits;
• Soybean oil, cake, and meal;
• Soybean oil, deodorized;
• Soybean protein concentrates; and
• Soybean protein isolates.
Establishments in this SIC code also process purchased soybean oil into products
other than edible cooking oils. Establishments primarily engaged in refining soybean oil into
edible cooking oils are classified under SIC code 2079: Shortening, Table Oils, Margarine
(Bicknell, 2004).
At soybean oil mills raw soybeans are 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 (Bicknell, 2004).
20-25
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Section 20.0 - Review of Direct Dischargers
Table 20-9. TRI and PCS Data Listing for Miscellaneous Foods and Beverages SIC Codes
SIC
Code
2032
2034
2038
2051
2052
2053
2064
2066
2067
2074
2075
2076
2079
2082
2083
2084
2085
2086
2087
2095
2097
2099
5144
PCS 2002
Facility
Countb
1
1
1
3
7
Total Pounds
180,000
1,220,000
12
1,630,000
159,000,000
TWPE
Oa
oa
oa
9,540
327,000
TWPE/
Facility
0
0
0
3,150
46,800
TRI 2002
Facility
Count
7
2
13
1
1
3
4
2
5
42
5
9
17
1
2
2
6
5
2
1
23
1
Total
Pounds
51,900
149
49,100
0.000174
220
7,810
42,300
2,130
3.66
1,710,000
0.752
22,200
3,129,000
1,000
40,900
3,870
37,800
25,800
31,800
2,140
236,000
16.0
TWPE
40.3
1.88
51.6
0.00741
0.24
8.70
31.6
2.06
0.129
2,927
0.0265
537
2,356
1.11
45.4
58.7
38.6
18.6
432
2.37
308
0.0119
TWPE/
Facility
5.75
0.939
3.97
0.00741
0.244
2.90
7.89
1.03
0.026
69.7
0.00530
59.6
139
1.11
22.7
29.4
6.43
3.71
216
2.37
13.4
0.0119
TRI 2003
Facility
Count
10
1
12
o
5
i
4
5
2
4
40
7
8
20
1
2
2
4
7
2
22
1
Total
Pounds
74,500
72.9
45,800
4,220
220
4,830
68,400
1,950
2.70
2,060,000
5,170
13,200
2,620,000
1,150
290,000
5,330
43,100
69,000
37,900
209,000
15.9
TWPE
57
1.55
49.6
4.69
0.244
4.02
53.8
1.88
0.0951
1,750
4.26
269
1,980
1.28
322
69.1
47.8
73.5
484
272
0.0119
TWPE/
Facility
5.72
1.55
4.13
1.56
0.244
1.01
10.8
0.942
0.0238
43.7
0.609
33.7
98.9
1.28
161
34.5
12.0
10.5
242
12.4
0.0119
to
o
to
a\
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
aThere is no TWPE associated with the pollutants in PCS for the SIC code.
bMajor dischargers only.
Blanks indicate that the databases contain no data for the SIC code. Bold indicates SIC codes contributing the majority of the total industry TWPE.
-------
Section 20.0 - Review of Direct Dischargers
Table 20-10. Pollutants of Concern for the Miscellaneous Foods and Beverages Industry
Pollutant
Sulfide
Chlorine
Copper
Manganese
TKN
Nitrate Compounds
Propylene Oxide
Ammonia
Nickel and Nickel
Compounds
N-Hexane
Industry Total
2002 PCS
Number of
Facilities
Reporting
Pollutant"
1
2
2
2
2
Total Pounds
Released
112,074
17, 722
9,373
21,553
551,783
TWPE
313,970
9,023
5,950
1,518
1,258
Pollutants are not in the top five PCS 2002
reported pollutants.
13
161,581,216
336,924
2002 TRI
Number of
Facilities
Reporting
Pollutant
Total Pounds
Released
TWPE
Pollutants are not in the top five TRI
2002 reported pollutants.
4
3,780
1,925
Pollutants are not in the top five TRI
2002 reported pollutants.
29
2
51
10
4,959,303
19,850
337,301
1,994
3,703
421
374
217
Pollutants are not in the top five TRI
2002 reported pollutants.
154
5,391,632
6,862
2003 TRI
Number of
Facilities
Reporting
Pollutant
Total
Pounds
Released
TWPE
Pollutants are not in the top five TRI
2003 reported pollutants.
3
423
215
Pollutants are not in the top five TRI
2003 reported pollutants.
32
2
58
4,840,031
22,109
611,879
3,614
469
679
Pollutants are not in the top five TRI
2003 reported pollutants.
48
158
3,898
5,560,811
137
5,444
to
o
to
Source: PCSLoads2002_v4; TRIReleases2002_v4; TRIReleases2003_v2.
"Discharges include only majors.
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Section 20.0 - Review of Direct Dischargers
Conventional wastewater pollutants from this industry include BOD, suspended
solids, and fats, oils, and greases. Soybean oil mills employ conventional biological wastewater
treatment preceded by oil/water separation of high oil concentration wastewaters (Bicknell,
2004).
Table 20-11 lists the pollutants of concern based on data from
TRIReleases2003_v2 and IRIReleases2002_v4 for SIC code 2075. For this SIC code, the total
TWPE from data in PCSLoads2002_v4 is zero, and EPA has PCS data for only one major
discharger. As a result, EPA excluded PCS data from Table 20-6.
Table 20-11. Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2075: Soybean Oil Mills
Pollutants with
Greatest TWPE
Chlorine
Nitrate Compounds
N-Hexane
Nickel and Nickel
Compounds
Ammonia
Sodium Nitrite (as N)
SIC Code Total
Annual TWPE
TRI 2003
Annual TWPE
NR
l,514b
137
57.4
30.0
10.2
1749.1
Percent of SIC
Code Total Annual
TWPE
NA
86.6%
7.8%
3.3%
1.7%
0.6%
NA
TRI 2002
Annual TWPE
l,553a
1,250
22
65.6
29.4
7.1
2927.4
Percent of SIC
Code Total Annual
TWPE
53.0%
42.7%
0.8%
2.2%
1.0%
0.2%
NA
Source: TRIReleases2002_v4; TRIReleases2003_v2.
aTWPE result from one facility: Bunge Milling, Inc., Danville, IL, TRI Facility ID: 61832-LHFFG-321EA.
b99.8% of TWPE results from one facility: Solae L.L.C., Pryor, Oklahoma, TRI Facility ID: 74362-PRTNT-
HUNTS
NA - Not applicable.
NR - Not reported.
Based on data from TRIReIeases2002_v4, all of the chlorine TWPE for SIC code
2075 is from one facility, Bunge Milling, Inc., Danville, IL, TRI Facility ID: 61832-LHFFG-
321EA. This facility did not report any TRI chemical releases to water in 2003.
Nitrate compounds are the greatest contributor to the TWPE for this SIC code.
Based on data from TRIReleases2003_v2, 99.8 percent of the nitrate compounds TWPE results
from one facility, Solae L.L.C., Pryor, Oklahoma, TRI Facility ID: 74362-PRTNT-HUNTS.
20-28
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Section 20.0 - Review of Direct Dischargers
20.2.5 SIC Code 2082: Malt Beverages
Establishments included in SIC code 2082 are primarily engaged in
manufacturing the following malt beverages:
Ale;
• Beer (alcoholic beverage);
• Brewers' grain;
• Liquors, malt;
• Malt extract, liquors, and syrups;
• Near beer (nonalcoholic beverage);
• Porter (alcoholic beverage); and
• Stout (alcoholic beverage).
The malt beverage industry uses the following basic unit processes: grinding of
rice, corn, and malt (soaked and germinated grain); brewing (cooking); filtration; fermenting;
aging; vessel clean-up; and packaging (Bicknell, 2004).
Conventional wastewater pollutants from this industry include BOD, and
suspended solids. Malt beverages processing plants employ conventional biological wastewater
treatment. Spent grain (mash) is typically recovered for use as animal feed (Bicknell, 2004).
Table 20-12 lists the pollutants of concern based on data from
TRIReleases2003_v2, TRIReleases2002 v4, andPCSLoads2002 v4 for SIC code 2082.
Based on data from PCSLoads2002_v4, all of the chlorine TWPE is discharged
from one facility, the Miller Brewing Company, Eden, NC, NPDES ID: NC0029980. Likely, the
facility adds chlorine as a disinfectant for water treatment.
Nitrate compounds contribute over 97 percent of the TPWE for SIC code 2982.
Based on data from TRIReleases2002_v4, 94.2 percent of the nitrate compounds TWPE results
from one facility: Anheuser-Busch, Inc., Baldwinsville, NY, TRI Facility ID: 13027-NHSRB-
2885B.
20-29
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Section 20.0 - Review of Direct Dischargers
Table 20-12. Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2082: Malt Beverages
Pollutants with
Greatest TWPE
Nitrate Compounds
Ammonia
Sodium Nitrite
SIC Code Total
Annual TWPE
Chlorine
Nitrite/Nitrate (as N)
Copper
Nitrogen, Ammonia
Zinc
Fluoride
Cyanide
SIC Code Total
Annual TWPE
Data Source
Used for
Identification
TRI
TRI
TRI
TRI
PCS
PCS
PCS
PCS
PCS
PCS
PCS
PCS
TRI 2003
Annual
TWPE
l,928.0a
44.6
6.0
1978.6
NA
NA
NA
NA
NA
NA
NA
NA
Percent of SIC
Code Total
Annual TWPE
97.4%
2.3%
0.3%
NA
NA
NA
NA
NA
NA
NA
NA
NA
2002 Data
Annual
TWPE
2,301.6a
49.6
5.3
2356.6
8.995.2b
291.4
85.0
84.8
54.2
14.8
7.4
9537.5
Percent of SIC
Code Total
Annual TWPE
97.7%
2.1%
0.2%
NA
94.3
3.1
0.9
0.9
0.6
0.2
0.1
NA
Source: PCSLoads2002
a94.2% of TWPE result
NHSRB-2885B.
bTWPE result from one
NA - Not available.
_v4; TRIReleases2002_v4; TRIReleases2003_v2.
from one facility: Anheuser-Busch, Inc., Baldwinsville, NY, TRI Facility ID: 13027-
facility: Miller Brewing Company, Eden, NC, NPDES ID: NC0029980
20.2.6
SIC Code 2085: Distilled, Rectified, and Blended Liquors
Establishments included in SIC code 2085 are primarily engaged in the following
processes: manufacturing alcoholic liquors by distillation; and manufacturing cordials and
alcoholic cocktails by blending processes or mixing liquors and other ingredients (Bicknell,
2004).
The distilled and blended liquors industry uses the following basic unit processes:
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 (Bicknell, 2004).
Conventional wastewater pollutants from this industry include BOD and
suspended solids. Molasses distillery wastes include nitrogen and phosphates. Distilled and
blended liquor facilities typically employ conventional biological wastewater treatment
(Bicknell, 2004).
Table 20-13 lists the pollutants of concern based on data from PCSLoads2002_v4
for SIC code 2085. For this SIC code, the total TWPE from data in TRIReleases2002 v4 and
TRIReleases2003_v2 is less than 70. As a result, EPA excluded TRI data from Table 20-13.
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Section 20.0 - Review of Direct Dischargers
Table 20-13. Pollutants of Concern for the Miscellaneous Foods and Beverages Industry,
SIC Code 2085: Distilled, Rectified, and Blended Liquors
Pollutants with Greatest TWPE
Sulfide
Copper
Manganese
Nitrogen, Kjeldahl Total (As N)
Phenol & Phenolics
Silver
Cadmium
Zinc
Fluoride
Thallium
Lead
Arsenic
Selenium
SIC Code Total Annual TWPE
PCS 2002
Annual TWPE
3 13,970. la
5,864.9
1,517.4
1,255.9
1,012.0
803.4
680.6
464.3
428.8
389.3
355.2
210.7
207.3
327,357
Percent of SIC Code Total
Annual TWPE
95.9%
1.8%
0.5%
0.4%
0.3%
0.2%
0.2%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
NA
Source: PCSLoads2002_v04.
aTWPE results from one facility: Bacardi Corporation, Puerto Rico, NPDES ID: PR0000591
NA - Not available.
Based on data from PCSLoads2002_v4, over 95 percent of the total SIC code total
annual TWPE is from sulfide discharges from one facility, the Bacardi Corporation, Puerto Rico,
NPDES ID: PR0000591. EPA reviewed the permit limits and monthly reporting data of the
Bacardi facility and contacted both the facility and the EPA Region 2 office regarding Bacardi's
discharges.
The Region 2 office identified that the Bacardi facility discharges sulfide, BOD,
oil and grease, and other pollutants at levels exceeding permit limits. It currently operates an
anaerobic system for treatment of its wastewaters prior to discharge. The Bacardi facility is
under a compliance schedule to meet the sulfide limit of 2 ug/L, which is a water quality-based
limit. This compliance schedule will expire soon. The Bacardi facility has requested that the
Puerto Rico Environmental Quality Board consider a change in the sulfide limit that takes into
account mixing zone implications (Matuszko, 2006a). Based on a previous Caribbean Rum
Study and recent NPDES permits for similar facilities, the Bacardi facility is the only known rum
producer that discharges directly to waters of the U.S. and employs an anaerobic treatment
system. Because sulfide is produced during anaerobic treatment, EPA concludes that its sulfide
discharges are unique and not representative of other facilities in this sector.
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Section 20.0 - Review of Direct Dischargers
20.2.7 Summary of Review of Miscellaneous Foods and Beverages Industry
EPA previously considered establishing ELGs for the miscellaneous foods and
beverages industry in the 1970s. EPA did not establish ELGs for this industry at that time
because of the relatively low amounts of toxics in wastewater discharges associated with this
industry and its conclusion that constituents in miscellaneous foods and beverage wastewaters
would not interfere with or pass through a POTW.
Based on its review of current available data and literature, EPA again found that
discharges from miscellaneous foods and beverages are primarily comprised of conventional
pollutants (BOD5, TSS, and Oil and Grease) and contain few toxics. Therefore, the overall
hazard associated with this industry (as measured in TWPE) is low.
The bulk of the hazard (measured as TWPE) reported to TRI and PCS from
wastewater discharges associated with this industry are from five facilities discharging nitrate
compounds, chlorine, and sulfide.
• Two facilities (Solae L.L.C. in SIC code 2075, Anheuseur-Busch in SIC
code 2082) account for almost all of the TWPE associated with nitrate
compounds reported to TRI.
• Two facilities (Bunge Milling, Inc. in SIC code 2075, Miller Brewing Co.
in SIC code 2082) account for almost all of the TWPE associated with
chlorine reported to TRI in 2002 - with the Bunge Milling facility
reporting no water discharges to the 2003 TRI.
• One facility (Bacardi Corp. in SIC code 2085) accounts for nearly all the
sulfide TWPE in PCSLoads2002_v04. EPA concluded these sulfide
discharges are unique to the wastewater treatment system at Bacardi and
not representative of other facilities in this sector.
Because of the low overall hazard associated with discharges from this industry,
Miscellaneous Foods and Beverages does not constitute a priority for effluent guidelines
rulemaking at this time. Moreover, because of the small number of facilities accounting for the
toxics, EPA believes that site-specific effluent limits established by permit writers on a BPJ basis
are an appropriate tool to address discharges from this industry at this time. For the reasons
discussed in Section 20.1.5 of this TSD, EPA believes that Section 304(m)(l)(B) gives EPA the
discretion to identify in the Plan only those new categories for which EPA believes an effluent
guideline may be an appropriate tool. See Norton v. Southern Utah Wilderness Alliance, 542 US
55, 70 (2004) (holding that a broad statutory mandate is not sufficient to constrain an Agency's
discretion over its internal planning processes).
20.3 References
A.G.Edwards. 2005. LNG: Filling the Long-Term U.S. Supply Gap. Available online at:
http://agedwards.com/. (June 14). EPA-HQ-OW-2004-0002, DCN 9-3560.
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Section 20.0 - Review of Direct Dischargers
Bicknell, Betsy, et al. 2004. Eastern Research Group, Inc. Memorandum to U.S. EPA.
"Background on Commenter-Identified New Point Source Categories." (June 11). DCN 00801.
Brinkman, P.E. 2005. Letter from Pearl Crossing LNG Terminal, LLC, to Robert D. Lawrence,
U.S. EPA Region 6. (October 19). EPA-HQ-OW-2004-0002, DCN 9-3576.
California Energy Commission. 2006. West Coast LNG Projects and Proposals. (October 20).
Available on-line at: http://www.energy.ca.gov/lng/projects.html.
Chinloy, Richard. 2005. "Financing LNG Receiving Terminals." Presented at LNG Access
Workshop, Sacramento, CA. (June 1 and 2). EPA-HQ-OW-2004-0002, DCN 9-3506.
Citigroup Smith Barney. 2004. LNG in North America. (August 27). EPA-HQ-OW-2004-
0002, DCN 9-3561.
Cornelius. 2006. Letter from S.L. Cornelius, President, ConocoPhillips Global Gas, to Admiral
Thad W. Allen, Commandant, U.S. Coast Guard. (November 3). USCG-2005-21232-237.
Available on-line at: http://dms.dot.gov/search/searchFormSimple.cfm.
Credit Suisse First Boston. 2005. Gas Insights: LNG to the Rescue for Gas Consumers.
(September 21). EPA-HQ-OW-2004-0002, DCN 9-3558.
Deutsche Bank. 2005. Global LNG: Waiting for the Cavalry. (Decembers). EPA-HQ-OW-
2004-0002, DCN 9-3559.
EBRD. 2006. European Bank for Reconstruction and Development. Sub-Sectoral
Environmental Guidelines. Available online at: http://www.ebrd.com/about/policies/enviro/
sectoral/food.pdf Date accessed: September, 2006. DCN 03885.
Economides, M.J. 2005. "The Economics of Gas to Liquids Compared to Liquefied Natural
Gas." World Energy Magazine. 8(1): 136-140. Available online at:
http://www.worldenergvsource.com/articles%2Fpdf%2Feconomides%5FWE%5Fv8nl%2Epdf
Date Accessed: October 2006. EPA-HQ-OW-2004-0002, DCN 9-3568.
EIA. 2003. Energy Information Administration, U.S. Department of Energy. The Global
Liquefied Natural Gas Market: Status and Outlook. (December). Available online at:
http://www.eia.doe.gov/oiaf/analvsispaper/global/pdf/eia_0637.pdf. EPA-HQ-OW-2004-0002,
DCN 9-3565.
EIA. 2004. Energy Information Administration, U.S. Department of Energy. U.S. LNG
Markets and Uses: June 2004 Update. (June). Available online at:
http://www.eia.doe.gov/pub/oil gas/natural gas/feature articles/2004/lng/lng2004.pdf. EPA-
HQ-OW-2004-0002, DCN 9-3553.
EIA. 2006a. Energy Information Administration, U.S. Department of Energy. Annual Energy
Outlook. Available online at: www.eia.doe.gov/oiaf/aeo/pdf/trend 4.pdf. EPA-HQ-OW-2004-
0002, DCN 9-3501.
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Section 20.0 - Review of Direct Dischargers
EIA. 2006b. Energy Information Administration, U.S. Department of Energy. U.S. Natural
Gas Importers by Point of Entry: Liquefied Natural Gas Volumes. Available online at:
http://www.tonto.eia.doe.gov/dnav/ng/ng_move_poel_a_EOGO_IML_Mmcf_a.htmttp://www.pa
nhandleenergy.com/newsreleases_dtl.asp?page=NR_040506.htm. EPA-HQ-OW-2004-0002,
DCN 9-3500.
El Paso Energy Bridge GOM, LLC. 2002. Application for Deepwater Port License. (December
20). Available online at: http://dmses.dot.gov/docimages/pdf84/219001_web.pdf
ENR. 2006. "$3 Billion Project Planned to Move Rockies Gas East." Engineering News
Record. (February 13). EPA-HQ-OW-2004-0002, DCN 9-3502.
ERG. 2006. Eastern Research Group, Inc. Memorandum to Carey Johnston, U.S. EPA. "LNG
Re-gasification Projections." (January 6). EPA-HQ-OW-2004-0002, DCN 9-3510.
Excelerate Energy, LLC. 2005. Exclerate Energy Announces the Successful Innauguration of
the Energy Bridge™ System and Commercial Operation of a New Generation of LNG
Technology. (April 5). EPA-HQ-OW-2004-0002, DCN 9-3520.
FERC. 2004. U.S. Federal Energy Regulatory Commission. LNG Briefing. (April). Available
online at: http://www.ferc.gov/for-citizens/lng-briefmg.pps. EPA-HQ-OW-2004-0002, DCN 9-
3555.
FERC. 2006a. U.S. Federal Energy Regulatory Commission. Existing LNG Terminals.
(October 19). Available online at: http://www.ferc.gov/industries/lng/indus-act/terminals/exist-
term/lake-charles.asp. (update version of EPA-HQ-OW-2004-0002, DCN 9-3596).
FERC. 2006b. Southern LNG Files for Expansion of Elba Island Storage and Sendout Capacity.
(October 10). FERC Docket No. CP06-470-000. Available online at
http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=l 1159659.
FERC. 2006c. U.S. Federal Energy Regulatory Commission. Existing LNG Terminals.
(October 19). Available online at: http://www.ferc.gov/industries/lng/indus-act/terminals/exist-
term/everett.asp. (updated version of EPA-HQ-OW-2004-0002, DCN 9-3548).
Flower, Andy. 2006a. E-mail communication between Andy Flower and Karrie-Jo Shell, U.S.
EPA Region 4. (May 8). EPA-HQ-OW-2004-0002, DCN 9-3604.
Flower, Andy. 2006b. Spreadsheet attachment to E-mail communication between Andy Flower
and Karrie-Jo Shell, U.S. EPA Region 4. (May 8). EPA-HQ-OW-2004-0002, DCN 9-3605.
Gold, Russell. 2005. "Bidding War Chills U.S. Plan to Import Natural Gas." The Wall Street
Journal. (December 19). Available online at:
http://www.postgazette.com/pg/05353/624855.stm. EPA-HQ-OW-2004-0002, DCN 9-3507.
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Section 20.0 - Review of Direct Dischargers
GPO. 2005. Government Printing Office. Economic Report of the President. Available online
at: http://www.gpoaccess.gov/eop/2005/2005 erp.pdf. EPA-HQ-OW-2004-0002, DCN 9-3557.
Greenspan. 2005. Remarks by Chairman Alan Greenspan. (April 5). Available online at:
http://www.federalreserve.gov/boarddocs/speeches/2005/20050405/default.htm. EPA-HQ-OW-
2004-0002, DCN 9-3562.
GSI. 2005. Gas Technology Institute. LNG World Trade, 2005. EPA-HQ-OW-2004-0002,
DCN 9-3586
Henry, Larry R. 2003. Email to Carey Johnston, U.S. EPA, from Larry R. Henry, Chevron
Texaco. "SIC Code 1321 and Natural Gas Processing." (May 24). EPA-HQ-OW-2003-0074,
DCN 01123.
Johnston, Carey. 2004. U.S. EPA. Memorandum to the Public Record for the Effluent
Guidelines Program Plan for 2004/2005. "Overview of Liquefied Natural Gas (LNG) Import
Terminals For CWA Section 304(m) Effluent Guidelines Planning." (August 19). EPA-HQ-
OW-2003-0074, DCN 01227.
Kelly, Suedeen G. 2004. "The Challenge of Natural Gas Interchangeability and Quality."
Presented by Suedeen G. Kelly, Commissioner of the Federal Energy Regulatory Commission,
to the Natural Gas Roundtable of Washington. Washington, D.C. (February 24). Available
online at: http://www.ferc.gov/press-room/sp-current/02-24-04-kelly.pdf EPA-HQ-OW-2004-
0002, DCN 9-3554.
LNGlawblog.com. 2006a. U.S. LNG Imports Decline in First Quarter. (May 5). (citing Platts
LNG Daily, May 4, 2006). Available online at: http://www.lnglawblog.com/05052006decrease/.
EPA-HQ-OW-2004-0002, DCN 9-3508.
LNGlawblog.com. 2006b. Mexico May Export LNG to the U.S. (April 26). (citing Platts LNG
Daily, April 25, 2006). EPA-HQ-OW-2004-0002, DCN 9-3504.
LNGlawblog.com. 2006c. Demand Reduction May Lead to Mexican Gas Exports to U.S. (May
3). (citing World Gas Intelligence, May 3, 2006). http://www.lnglawblog.com/05032006mexico.
EPA-HQ-OW-2004-0002, DCN 9-3505.
LNGlawblog.com. 2006d. U.S. Sees Decreased LNG Imports in September. (September 28).
(citing World Gas Intelligence, September 2006). Available online at:
http://www.lnglawblog.com/09282006spotmarket/.
LNGLawblog, 2006e. Shortage of Natural Gas Leading to Inactive Liquefaction Projects.
(October 18). (citing World Gas Intelligence, October 2006). Available at
http://lnglawblog.com/10182006feedstock.
Martin, Phyllis, 2006. EIA. EIA's Current View on LNG Imports into the United States.
Available online at: http://www.eia.doe.gov/oiaf/aeo/conf/pdf/martin.pdf. EPA-HQ-OW-2004-
0002, DCN 9-3594.
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Section 20.0 - Review of Direct Dischargers
Matuszko, Jan. 2006a. Memorandum to 2006 Effluent Guidelines Plan Record. "Telephone
Conversations with John Chang-Chen, U.S. EPA Region II." (September 7). DCN 03888.
Matuszko, Jan. 2006b. Memorandum to 2006 Effluent Guidelines Plan Record. "Commenter-
Identified Industries Not Meeting 304(m)l(B) Criteria." (December 1).
NGI. 2006. "Consultant Predicts 'Great Shakeout' in LNG Projects This Year or Early 2007."
(March 29). EPA-HQ-OW-2004-0002, DCN 9-3509.
North American National Gas Group. 2005. Northeast LNG Overview. (June 5). Available
online at: http://www.iroquois.com/new-Internet/igts/images/Northeast%20LNG.pdf. EPA-HQ-
OW-2004-0002, DCN 9-3537.
Pan EurAsian Enterprises, Inc. 2006. Special Summary Report: U.S Natural Gas and LNG
Review for 2005. (March 8). EPA-HQ-OW-2004-0002, DCN 9-3521.
Panhandle Energy. 2006. Southern Union to Upgrade LNG Terminal. (April 5). Available
online at: http://www.panhandleenergy.com/newsreleases_dtl.asp?page=NR_040506.htm. EPA-
HQ-OW-2004-0002, DCN 9-3597.
Poten & Partners, Inc. 2004. ChevTex Finalizes Capacity Deal at Sabine Pass. (December 23).
EPA-HQ-OW-2004-0002, DCN 9-3513.
Rigzone. 2006. "U.S. LNG Proliferation Slowed by Global Competition, Market Dynamics,"
http://www.rigzone.com/news/article.asp7a id=36181. (September 15). DCN 3757.
Rosenberg, Martin. 2006. Building Up Gas. EnergyBiz Magazine. DCN 04081.
Smith, Lawrence, and Bennett, Jones. 2005. Deliverability of Supply Considerations for
Imports of LNG through Canada and Mexico. Presented to California Energy Commission,
Sacramento, CA. (June 2). Available online at:
http://www.energy.ca.gov/lng_docket/documents/2005-06-01_workshop/presentations_2005-06-
02/Smith Lawrence 2005-06-02.pdf. EPA-HQ-OW-2004-0002, DCN 9-3503.
Triangular Wave. 2006. Triangular Wave Technologies, Inc. Chemical-Free Food Processing
Treatment Applications. Available online at: http://www.triangularwave.com/hl2.htm. Date
accessed: September, 2006. DCN 03887.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U.S. EPA 1975a. Draft Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Miscellaneous Foods and Beverages Point Source
Category. (February). DCN 04087.
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Section 20.0 - Review of Direct Dischargers
U.S. EPA. 1975b. Draft Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Addendum for the Hydrolyzed Vegetable Protein Segment
of the Miscellaneous Foods and Beverages Point Source Category. (May). DCN 02250.
U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, DC. (August). DCN 01088.
U.S. EPA. 2005. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New Point Source
Categories for Effluent Limitations Guidelines and Standards. EPA-821 -B-05-003.
Washington, DC. (August). DCN 02173.
U.S. EPA. 2006a. Memorandum from Benjamin H. Grumbles, Assistant Administrator for
Water, to EPA Regional Administrators. "Deepwater Liquefied Natural Gas Terminals and
Clean Water Act Technology-Based Limitations and Conditions." (April 3). EPA-HQ-OW-
2004-0002, DCN 9-3546.
U.S. EPA. 2006b. EPA Region 9, Fact Sheet for the Cabrillo Deepwater Port Project (Revised).
(September 14). Available online at: http://www.epa.gov/region9/liq-natl-gas/index.html.
UNEP. 2004. United Nations Environment Programme. Fact Sheet 6: Food Manufacturing
Series. (October 1). Available online at: http://www.gpa.uq.edu.au/CleanProd/
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USCG. 2003. U.S. Coast Guard. Final Environmental Assessment of the El Paso Energy
Bridge Gulf of Mexico LLC Deepwater Port License Application. (November). Available
online at: http://dmses.dot.gov/docimages/pdf88/261100_web.pdf.
Van Praet, Nicholas. 2004. "Next Best Thing to Oil." Montreal Gazette. (September 18).
Available online at: http://www.energvprobe.org/energvprobe/print.cfm?ContentID=l 1441.
EPA-HQ-OW-2004-0002, DCN 9-3512.
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