«EPA
United States
Environmental Protection
Agency
The 2013 Annual Effluent
Guidelines Review Report
September 2014
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U.S. Environmental Protection Agency
Office of Water (43 03 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA-821-R-14-003
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TABLE OF CONTENTS
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PART I: INTRODUCTION I
1. 2013 ANNUAL REVIEW EXECUTIVE SUMMARY 1-1
1.1 References for 2013 Annual Review Executive Summary 1-4
2. BACKGROUND 2-1
2.1 The Clean Water Act and the Effluent Guidelines Program 2-1
2.2 Effluent Guidelines Review and Planning Process 2-2
2.2.1 Effluent Guidelines Review and Prioritization Factors 2-2
2.2.2 Annual Review Process 2-3
2.2.3 Effluent Guidelines Program Plans 2-11
2.3 References for Background 2-11
PART II: EPA's 2013 ANNUAL REVIEW METHODOLOGY AND ANALYSES II
3. 2013 ANNUAL REVIEW DATA SOURCES, LIMITATIONS, AND QUALITY REVIEW 3-1
3.1 Methodology Change to the 2013 TRA 3-2
3.2 Data Sources and Limitations 3-3
3.2.1 SIC Codes 3-3
3.2.2 NAICS Codes 3-3
3.2.3 Toxic Weighting Factors 3-5
3.2.4 Data from PCS and ICIS-NPDES 3-5
3.2.5 Data from TRI 3-8
3.2.6 TRI and DMR Comparative Analysis 3-10
3.3 2011 DMR and TRI Data Quality Review 3-10
3.3.1 Data Quality Review and Corrections to the 2011 DMR Data 3-11
3.3.2 Data Quality Review and Corrections to the 2011 TRI Data 3-18
3.4 References for 2013 Annual Review Data Sources, Limitations, and
Quality Review 3-24
4. FINAL 2013 ANNUAL REVIEW TOXICITY RANKING ANALYSIS METHODOLOGY
AND RESULTS 4-1
4.1 Methodology for Generating the Final 2013 Point Source Category
Rankings 4-1
4.1.1 Categories for Which EPA Has Recently Considered Developing
or Revising ELGs or Has Recently Promulgated or Revised ELGs 4-2
4.1.2 Discharges Not Categorizable 4-2
4.2 Results of the 2013 Toxicity Rankings Analysis 4-3
4.3 EPA's Review of SIC Code Classifications for Previously Unclassified
Facilities 4-7
4.4 References for the Final 2013 Annual Review TRA Methodology and
Results 4-7
5. EPA's 2013 PRELIMINARY CATEGORY REVIEWS 5-1
5.1 Prioritization of Categories for Preliminary Category Review 5-1
iv
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TABLE OF CONTENTS (Continued)
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5.1.1 Concentrated Aquatic Animal Product!on (40 CFR Part 451) 5-2
5.1.2 Meat and Poultry Products (40 CFR Part 432) 5-2
5.1.3 Oil and Gas Extract!on (40 CFR Part 435) 5-2
5.1.4 Ore Mining and Dressing (40 CFR Part 440) 5-2
5.1.5 Pesticide Chemicals (40 CFR Part 455) 5-3
5.1.6 Fertilizer Manufacturing (40 CFR Part 418) 5-3
5.1.7 Sugar Processing (40 CFR Part 409) 5-3
5.1.8 References for the Prioritization for Categories for Preliminary
Category Review 5-4
5.2 Coal Mining (40 CFR Part 434) 5-5
5.2.1 Coal Mining Category Toxicity Rankings Analysis 5-5
5.2.2 Coal Mining Manufacturing Category Pollutants of Concern 5-6
5.2.3 Coal Mining Category Iron Discharges inDMR 5-7
5.2.4 Coal Mining Category Mercury Discharges inDMR 5-7
5.2.5 Coal Mining Category Sulfate Discharges in DMR 5-8
5.2.6 Coal Mining Category Manganese Discharges in DMR 5-9
5.2.7 Coal Mining Category Findings 5-12
5.2.8 References for Coal Mining Category 5-13
5.3 Drinking Water Treatment (Potential New Category) 5-15
5.3.1 DWT Industrial Category 2013 Toxicity Rankings Analysis 5-15
5.3.2 DWT Industrial Category Pollutants of Concern 5-16
5.3.3 DWT Industrial Category Total Residual Chlorine Discharges in
DMR 5-17
5.3.4 DWT Industrial Category Aluminum Discharges in DMR 5-19
5.3.5 DWT Industrial Category Copper, Mercury, and Lead Discharges
inDMR 5-21
5.3.6 DWT Industrial Category Findings 5-23
5.3.7 References for DWT Industrial Category 5-24
5.4 Inorganic Chemicals Manufacturing (40 CFR Part 415) 5-26
5.4.1 Inorganic Chemicals Category 2013 Toxicity Rankings Analysis 5-26
5.4.2 Inorganic Chemicals Category Pollutants of Concern 5-27
5.4.3 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound
Discharges in TRI 5-28
5.4.4 Inorganic Chemicals Category Manganese and Manganese
Compound Discharges in TRI 5-30
5.4.5 Inorganic Chemicals Category Polychlorinated Biphenyl (PCB)
Compound Discharges in TRI 5-31
5.4.6 Inorganic Chemicals Category Findings 5-32
5.4.7 References for Inorganic Chemicals Category 5-33
5.5 Iron and Steel Manufacturing (40 CFR Part 420) 5-35
5.5.1 Iron and Steel Manufacturing Category 2013 Toxicity Rankings
Analysis 5-35
5.5.2 Iron and Steel Manufacturing Category Pollutants of Concern 5-36
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TABLE OF CONTENTS (Continued)
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5.5.3 Iron and Steel Manufacturing Category Fluoride Discharges in
DMR 5-37
5.5.4 Iron and Steel Manufacturing Category Aluminum Discharges in
DMR 5-40
5.5.5 Iron and Steel Manufacturing Category Cyanide Discharges in
DMR 5-43
5.5.6 Iron and Steel Manufacturing Category Total Residual Chlorine
Discharges in DMR 5-45
5.5.7 Iron and Steel Manufacturing Category Findings 5-46
5.5.8 References for Iron and Steel Manufacturing Category 5-48
5.6 Metal Finishing (40 CFR Part 433) 5-50
5.6.1 Summary of Metal Finishing ELGs 5-50
5.6.2 History of EPA Reviews of the Metal Finishing Category 5-52
5.6.3 References for Metal Finishing Category 5-56
5.7 Nonferrous Metals Manufacturing (40 CFR Part 421) 5-57
5.7.1 NFMM Category 2013 Toxicity Rankings Analysis 5-57
5.7.2 NFMM Category Pollutants of Concern 5-58
5.7.3 NFMM Category Cadmium Discharges in DMR 5-58
5.7.4 NFMM Category Copper Discharges in DMR 5-60
5.7.5 NFMM Category Mercury Discharges in DMR 5-61
5.7.6 NFMM Category PCB Discharges in DMR 5-62
5.7.7 NFMM Category Lead Discharges in DMR 5-63
5.7.8 NFMM Category Findings 5-65
5.7.9 References for NFMM Category 5-66
5.8 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414) 5-68
5.8.1 OCPSF Category 2013 Toxicity Rankings Analysis 5-68
5.8.2 OCPSF Category Pollutants of Concern 5-69
5.8.3 OCPSF Category Hexachlorobenzene Dischargers in DMR 5-69
5.8.4 OCPSF Category Total Residual Chlorine Dischargers in DMR 5-70
5.8.5 OCPSF Category PCB Dischargers in DMR 5-71
5.8.6 OCPSF Category Findings 5-72
5.8.7 References for OCPSF Category 5-72
5.9 Petroleum Refining (40 CFR Part 419) 5-75
5.9.1 References for Petroleum Refining Category 5-79
5.10 Pulp, Paper, and Paperboard (40 CFR Part 430) 5-80
5.10.1 Pulp and Paper Category 2013 Toxicity Rankings Analysis 5-80
5.10.2 Pulp and Paper Category Pollutants of Concern 5-81
5.10.3 Pulp and Paper Category Dioxin Discharges in DMR and TRI 5-82
5.10.4 Pulp and Paper Category Sulfide Discharges in DMR 5-85
5.10.5 Pulp and Paper Category Manganese and Manganese Compound
Discharges in TRI 5-87
5.10.6 Pulp and Paper Category Findings 5-88
5.10.7 References for Pulp and Paper Category 5-89
5.11 Timber Products Processing (40 CFR Part 429) 5-91
VI
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TABLE OF CONTENTS (Continued)
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5.11.1 Timber Products Category 2013 Toxicity Rankings Analysis 5-91
5.11.2 Timber Products Category Pollutants of Concern 5-92
5.11.3 Timber Products Category Total Residual Chlorine Discharges in
DMR 5-92
5.11.4 Timber Products Category Copper Discharges in DMR 5-94
5.11.5 Timber Products Category Arsenic Discharges in DMR 5-95
5.11.6 Timber Products Category Findings 5-96
5.11.7 References for Timber Products Category 5-96
PART III: RESULTS OF EPA's 2013 ANNUAL REVIEW Ill
6. RESULTS OF THE 2013 ANNUAL REVIEW 6-1
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LIST OF TABLES
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Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total
2013 Combined TWPE 1-1
Table 3-1. Nomenclature and Format of NAICS and SIC Codes 3-4
Table 3-2. Results of 2011 DMR Data Completeness Check 3-11
Table 3-3. Summary of 2011 DMR Facility Data Quality Review 3-13
Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through
2011 3-18
Table 3-5. Summary of 2011 TRI Facility Review 3-20
Table 4-1. Point Source Categories That Have Undergone Recent Rulemaking or Review 4-2
Table 4-2. Final 2013 Combined Point Source Category Rankings 4-4
Table 4-3. Summary of EPA's Review of SIC Code Classifications for the Top
Previously Unclassified Facilities 4-8
Table 5-1. Coal Mining Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews 5-5
Table 5-2. Coal Mining Category Top DMR Pollutants 5-6
Table 5-3. Top 2011 DMR Iron Discharging Mines 5-7
Table 5-4. Seneca Mine's 2011 DMR Original and Corrected Iron Discharges 5-7
Table 5-5. Top 2011 DMR Mercury Discharging Mines 5-8
Table 5-6. Spartan Mine's 2011 DMR Original and Corrected Mercury Discharges from
Outfall 001 5-8
Table 5-7. Top 2011 DMR Sulfate Discharging Mines 5-9
Table 5-8. Peabody's 2011 Original and Corrected Monthly Sulfate and
Flow Discharges from Outfall 003 5-9
Table 5-9. Top 2011 DMR Manganese Discharging Facilities 5-10
Table 5-10. Nubay's 2011 Original and Corrected Monthly Manganese and
Flow Discharges 5-10
Table 5-11. Texas Westmoreland's Yearly Manganese DMR Discharges 5-11
Vlll
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LIST OF TABLES (Continued)
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Table 5-12. Texas Westmoreland's 2011 Monthly Manganese and Flow Discharge Data,
NPDES Manganese Permit Limits, and Coal Mining ELGs Subpart C
Manganese Limits 5-12
Table 5-13. DWT Industrial Category TRI and DMR Facility Counts and Discharges for
the 2011 and 2013 Annual Reviews 5-15
Table 5-14. DWT Industrial Category Top DMR Pollutants 5-16
Table 5-15. DWT Industrial Category Count of Facilities for 2011 Top DMR Pollutants 5-16
Table 5-16. Top 2011 DMR Total Residual Chlorine Discharging Facilities 5-17
Table 5-17. PRASA Vieja Ponce's 2011 DMR Original and Corrected Flow and Total
Residual Chlorine Discharges for Outfall 001 5-18
Table 5-18. PRASA Sabana Grande's 2011 DMR Original and Corrected Flows for
Outfall 001 5-18
Table 5-19. 2011 DMR Total Residual Chlorine Concentrations (mg/L) 5-19
Table 5-20. Top 2011 DMR Aluminum Discharging Facilities 5-19
Table 5-21. Sanford Springs 2011 DMR Original and Corrected Flows for Outfall 001 5-20
Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001 5-20
Table 5-23. 2011 DMR Aluminum Concentrations (mg/L) 5-21
Table 5-24. 2011 DMR Copper and Lead Concentrations (mg/L) 5-22
Table 5-25. 2011 DMR Mercury Concentrations (mg/L) 5-23
Table 5-26. Inorganic Chemicals Category TRI and DMR Facility Counts and
Discharges for the 2011 and 2013 Annual Reviews 5-26
Table 5-27. Inorganic Chemicals Category Top TRI Pollutants 5-27
Table 5-28. Top 2011 TRIDioxin and Dioxin Like Compound Discharging Facilities 5-28
Table 5-29. Millennium Plant I's Yearly Dioxin and Dioxin-like Compound TRI
Discharges 5-29
Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum
Levels 5-29
Table 5-31. Top 2011 Manganese and Manganese Compound Discharging Facilities 5-30
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LIST OF TABLES (Continued)
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Table 5-32. Millennium Plant II's Yearly Manganese and Manganese Compound
TRI Discharges 5-31
Table 5-33. Top 2011 PCB Discharging Facilities 5-31
Table5-34. DuPont Johnsonville's Yearly PCB TRI Discharges 5-32
Table 5-35. Iron and Steel Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews 5-35
Table 5-36. Iron and Steel Manufacturing Category Top DMR Pollutants 5-37
Table 5-37. Top 2011 DMR Fluoride Discharging Facilities 5-37
Table 5-38. Arcelormittal's 2011 DMR Original and Corrected Fluoride Discharges 5-38
Table 5-39. USS Gary Works' 2011 Monthly Fluoride Discharge and Flow Data 5-39
Table 5-40. Weirton Steel Corporation's 2011 Monthly Fluoride Discharge and Flow
Data 5-40
Table 5-41. Top 2011 DMR Aluminum Discharging Facilities 5-41
Table 5-42. Nucor Steel's 2011 Monthly Aluminum Concentration and Flow Data 5-42
Table 5-43. Top 2011 DMR Cyanide Discharging Facilities 5-43
Table 5-44. USS Clairton Plant Outfall 183 2011 Monthly Cyanide and
Flow Discharge Data 5-44
Table 5-45. Mountain State Carbon's 2011 Monthly Cyanide and Flow Discharge Data 5-45
Table 5-46. Top 2011 Total Residual Chlorine Discharging Facilities 5-46
Table 5-47. USS Clairton Plant's 2011 Monthly Total Residual Chlorine and Flow
Discharge Data for Outfall 038 5-46
Table 5-48. Unit Operations Regulated by ELGs for the Metal Finishing Category 5-51
Table 5-49. Applicability, Regulated Pollutants, and ELG Limits for the
Metal Finishing Category 5-51
Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and
Proposed Part 438 5-53
Table 5-51. Metal Finishing Category Top DMR Pollutants 5-55
Table 5-52. Metal Finishing Category Top TRI Pollutants 5-55
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LIST OF TABLES (Continued)
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Table 5-53. NFMM Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews 5-57
Table 5-54. 2011 NFMM Category Top DMR Pollutants 5-58
Table 5-55. Top 2011 DMR Cadmium Discharging Facilities 5-59
Table 5-56. Nyrstar's 2011 DMR Monthly Cadmium Discharges 5-59
Table 5-57. Top 2011 DMR Copper Discharging Facilities 5-60
Table 5-58. Alcoa's 2011 DMR Original and Corrected Monthly Copper Discharges 5-61
Table 5-59. Top 2011 DMR Mercury Discharging Facilities 5-62
Table 5-60. Top 2011 DMR PCB Discharging Facilities 5-62
Table 5-61. U.S. Enrichment Corporation's 2011 PCB Discharge and Flow Data 5-63
Table 5-62. Top 2011 DMR Lead Discharging Facilities 5-63
Table 5-63. Nyrstar's 2011 DMR Monthly Lead Discharges 5-64
Table 5-64. 2011, 2012, and 2013 Lead Discharges from Sanders Lead Company, Inc 5-65
Table 5-65. OCPSF Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews 5-68
Table 5-66. OCPSF Category Top DMR Pollutants 5-69
Table 5-67. Top 2011 DMR Hexachlorobenzene Discharging Facilities 5-70
Table 5-68. Top 2011 DMR Total Residual Chlorine Discharging Facilities 5-70
Table 5-69. 2011 DMR PCB Discharging Facility 5-71
Table 5-70. Petroleum Refining Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews 5-76
Table 5-71. Petroleum Refining Category Top DMR Pollutants 5-76
Table 5-72. Petroleum Refining Category Top TRI Pollutants 5-77
Table 5-73. Petroleum Refining Metals DMR Discharges 5-77
Table 5-74. Pulp and Paper Category TRI and DMR Facility Counts and Discharges for
2011 and 2013 Annual Reviews 5-80
Table 5-75. Pulp and Paper Category Top DMR Pollutants 5-81
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LIST OF TABLES (Continued)
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Table 5-76. Pulp and Paper Category Top TRI Pollutants 5-82
Table 5-77. Top 2011 DMR TCDD Discharging Facilities 5-82
Table 5-78. Top 2011 TRI Dioxin and Dioxin-Like Compound Discharging Facilities 5-83
Table 5-79. 2011 and 2012 Concentrations of Dioxin and Dioxin-Like Compounds from
Simpson Tacoma (pg/L) and EPA Method 1613B Minimum Levels 5-85
Table 5-80. Top 2011 DMR Sulfide Discharging Facilities 5-86
Table 5-81. 2002-2011 Manganese and Manganese Compound Discharges in TRI and
DMR 5-88
Table 5-82. Timber Products Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews 5-91
Table 5-83. Timber Products Category Top DMR Pollutants 5-92
Table 5-84. Top 2011 DMR Total Residual Chlorine Discharging Facilities 5-93
Table 5-85. Cahaba Timber's 2011 DMR Total Residual Chlorine and
Flow Discharge Data 5-93
Table 5-86. Top 2011 DMR Copper Discharging Facilities 5-94
Table 5-87. EdArey's2011 DMR Copper and Flow Discharge Data 5-95
Table 5-88. Top 2011 DMR Arsenic Discharging Facilities 5-95
Table 5-89. Free State Lumber's 2011 DMR Original and Corrected Arsenic Discharges 5-95
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LIST OF FIGURES
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Figure 2-1. Odd-Year Annual Review of Existing ELGs 2-7
Figure 2-2. Odd-Year Identification of Possible New ELGs 2-8
Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of
Possible New ELGs 2-9
Figure 2-4. Further Review of Industrial Categories Identified During Odd- and
Even-Year Annual Reviews 2-10
Figure 5-1. 2009-2013 Sulfide Concentrations for Smurfit-Stone Mill 5-87
xni
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PART I: INTRODUCTION
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Section 1—2013 Annual Review Executive Summary
1.
2013 ANNUAL REVIEW EXECUTIVE SUMMARY
Effluent limitations guidelines and standards (ELGs) are an essential element of the
nation's clean water program, which was established by the 1972 Clean Water Act (CWA).
ELGs are technology-based regulations used to control industrial wastewater discharges. EPA
issues ELGs for new and existing point source categories that discharge directly to surface
waters, as well as those that discharge to publicly owned treatment works (POTWs). These ELGs
are applied in permits to limit the pollutants that facilities may discharge. To date, EPA has
established ELGs to regulate wastewater discharges from 58 point source categories. This
regulatory program substantially reduces industrial water pollution and continues to be a critical
aspect of the effort to clean the nation's waters.
In addition to developing new ELGs, the CWA requires EPA to revise existing ELGs
when appropriate. Over the years, EPA has revised ELGs in response to developments such as
advances in treatment technology and changes in industry processes. To continue its efforts to
reduce industrial wastewater pollution and fulfill CWA requirements, EPA has established an
annual review and effluent guidelines planning process with three main objectives: (1) review
existing ELGs to identify candidates for revision, (2) identify new categories of direct
dischargers for possible development of effluent guidelines, and (3) identify new categories of
indirect dischargers for possible development of pretreatment standards. To achieve these
objectives, EPA conducts a two-step review. First, EPA screens industrial discharges based on
the relative hazard they pose to human health and the environment. Then, for those categories
identified as a hazard priority, EPA conducts a more detailed evaluation to determine if the
category is a candidate for new or revised ELGs.
For the 2013 Annual Review, EPA conducted a toxicity rankings analysis (TRA) of all
industrial categories, including those subject to existing ELGs and those not currently regulated
by ELGs, to prioritize for further review those whose pollutant discharges may pose the greatest
hazards to human health or the environment because of their toxicity. To identify these industrial
categories, EPA calculated the industrial categories cumulative percent of the total toxic-
weighted pound equivalents (TWPE) discharged. As shown in Table 1-1, EPA identified and
focused its review on the 17 industrial categories that collectively discharge over 95 percent of
the total TWPE.
Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total
2013 Combined TWPE
40CFR
Part
414
430
419
NA
440
420
418
415
Point Source Category
Organic Chemicals, Plastics, and Synthetic Fibers
Pulp, Paper, and Paperboard
Petroleum Refining
Drinking Water Treatment
Ore Mining and Dressing
Iron and Steel Manufacturing
Fertilizer Manufacturing
Inorganic Chemicals Manufacturing
Total TWPE
1,690,000
1,690,000
1,430,000
1,390,000
1,340,000
1,250,000
606,000
469,000
Cumulative
Percentage of
Total TWPE
13.1%
26.3%
37.4%
48.2%
58.6%
68.4%
73.1%
76.7%
Rank
1
2
3
4
5
6
7
8
1-1
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Section 1—2013 Annual Review Executive Summary
Table 1-1. Point Source Categories Collectively Discharging Over 95% of the Total
2013 Combined TWPE
40CFR
Part
421
455
409
433
451
434
432
429
435
Point Source Category
Nonferrous Metals Manufacturing
Pesticide Chemicals
Sugar Processing
Metal Finishing
Concentrated Aquatic Animal Production
Coal Mining
Meat and Poultry Products
Timber Products Processing
Oil and Gas Extraction
Total 2013 Point Source Category Rankings
Total TWPE
426,000
393,000
374,000
317,000
292,000
189,000
158,000
131,000
106,000
12,900,000
Cumulative
Percentage of
Total TWPE
80%
83.1%
86%
88.5%
90.7%
92.2%
93.4%
94.5%
95.3%
Rank
9
10
11
12
13
14
15
16
17
Based on the annual review process, data sources, and historical data changes, EPA
determined that seven of the 17 categories did not warrant a detailed preliminary category review
as part of the 2013 Annual Review. For these seven categories, many of which have been
reviewed in detail in prior annual reviews, EPA found that the majority of the TWPE for these
categories resulted from an easily identifiable error (e.g., incorrect reporting units) associated
with one or two facilities. For TWPE not associated with data entry errors, EPA did not identify
any new information to alter the findings made during previous annual reviews (see Section 5.1
for more information). These industrial categories include:
• Concentrated Aquatic Animal Production (40 CFR Part 451);
• Meat and Poultry Products (40 CFR Part 432);
• Oil and Gas Extraction (40 CFR Part 435);
• Ore Mining and Dressing (40 CFR Part 440);
• Pesticide Chemicals (40 CFR Part 455);
• Fertilizer Manufacturing (40 CFR Part 418); and
• Sugar Processing (40 CFR Part 409).
For the remaining 10 of the 17 industrial categories that collectively discharge over 95
percent of the total TWPE, EPA did not initially identify obvious data entry errors and/or
determined that the TWPE was attributed to multiple pollutants and facilities. Therefore, EPA
completed detailed preliminary category reviews for the following categories (see Sections 5.2
through 5.11 for more information):
• Coal Mining (40 CFR Part 434);
• Drinking Water Treatment (potential new category);
• Inorganic Chemicals Manufacturing (40 CFR Part 415);
• Iron and Steel Manufacturing (40 CFR Part 420);
• Metal Finishing (40 CFR Part 433);
1-2
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Section 1—2013 Annual Review Executive Summary
• Nonferrous Metals Manufacturing (40 CFR Part 421);
• Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414);
• Petroleum Refining (40 CFR Part 419);
• Pulp, Paper, and Paperboard (40 CFR Part 430); and
• Timber Products Processing (40 CFR Part 429).
From the 10 detailed preliminary category reviews, EPA identified two for which further
review and study is appropriate: Metal Finishing (40 CFR Part 433) and Petroleum Refining (40
CFR Part 419).
• Metal Finishing (40 CFR Part 433). During the 2012 Annual Review, EPA's
review of the Targeted National Sewage Sludge Survey, combined with available
indirect discharge data from TRI identified the Metal Finishing Point Source
Category as potentially discharging high concentrations of metals, particularly
chromium, nickel, and zinc, to POTWs. Additionally, this category ranked high,
in terms of TWPE in the 2013 TRA.
• Petroleum Refining (40 CFR Part 419). During the 2011 Annual Review, EPA
selected the Petroleum Refining Category (40 CFR Part 419) for a preliminary
category review because it ranked high, in terms of TWPE (U.S. EPA, 2012). At
that time, EPA found that the TWPE was largely due to Toxics Release Inventory
reported discharges of dioxin and dioxin-like compounds, polycyclic aromatic
compounds, and discharge monitoring report-reported discharges of sulfides,
chlorine, and metals. EPA continued to review this category during the 2012
Annual Review to verify facilities' discharges and confirmed the 2011 Annual
Review results (U.S. EPA, 2014a). EPA also reviewed new air pollution control
regulations to identify whether the regulations could result in new wastewater
streams. Additionally, this category ranked high, in terms of TWPE in the 2013
TRA.
For the remaining eight detailed preliminary category reviews, EPA determined that
further category review was not warranted at this time for one, or more, of the following reasons:
• High category TWPE was a result of data entry errors at one or more facilities.
After correcting these reporting errors, the category TWPE was significantly
reduced and the category was removed from the top 95 percent of the toxicity
rankings.
• High category TWPE was from one or two facilities that do not represent the
category discharges as a whole and may be most appropriately controlled by
facility-specific permitting action.
• High category TWPE was a result of discharges that are below facility-specific
permit limitations or available treatment technology concentrations.
This report details EPA's methodology for its 2013 Annual Review and supports EPA
Office of Water's Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S.
1-3
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Section 1—2013 Annual Review Executive Summary
EPA, 2014b). The Plans, pursuant to Section 304(m) of the Clean Water Act (CWA),1 discuss
the findings of the 2011, 2012, and 2013 Annual Reviews and detail EPA's proposed actions and
follow-up. The Plans also identify any new or existing industrial categories selected for effluent
guidelines rulemaking and provide a schedule for such rulemaking.
1.1 References for 2013 Annual Review Executive Summary
1. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195.
2. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07933.
3. U.S. EPA. 2014b. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
Available at: http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/.
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Section 2—Background
2. BACKGROUND
This section explains how the Effluent Guidelines Program fits into EPA's National
Water Program, describes the general and legal background of the Effluent Guidelines Program,
and summarizes EPA's process for making effluent guidelines revision and development
decisions (i.e., effluent guidelines planning), including details of its annual review process.
2.1 The Clean Water Act and the Effluent Guidelines Program
The Clean Water Act (CWA) is based on the principle of cooperative federalism, with
distinct roles for both EPA and the states, in which the goal is to restore and maintain the
chemical, physical, and biological integrity of the nation's waters. To that end, the act is
generally focused on two types of controls: (1) water-quality-based controls, based on water
quality standards, and (2) technology-based controls, based on effluent limitations guidelines and
standards (ELGs).
The CWA gives to the states primary responsibility for establishing, reviewing, and
revising water quality standards. Water quality standards consist of the following elements: (1)
designating uses for each water body (e.g., fishing, swimming, supporting aquatic life), (2)
establishing criteria that protect the designated uses (numeric pollutant concentration limits and
narrative criteria, e.g., "no objectionable sediment deposits"), and (3) developing an anti-
degradation policy. EPA develops recommended national criteria for many pollutants, pursuant
to CWA section 304(a), which the states may adopt or modify as appropriate to reflect local
conditions.
EPA is responsible for developing technology-based ELGs, based on currently available
technologies for controlling industrial wastewater discharges. Permitting authorities (states
authorized to administer the National Pollutant Discharge Elimination System (NPDES) permit
program, and EPA in the few states that are not authorized) then must incorporate these
guidelines and standards into discharge permits as technology-based effluent limitations, where
applicable (U.S. EPA, 2010).
While technology-based effluent limitations in discharge permits are sometimes as
stringent as, or more stringent, than necessary to meet water quality standards, the effluent
guidelines program is not specifically designed to ensure that the discharges from each facility
meet the water quality standards of its receiving water body. For this reason, the CWA also
requires authorized states to establish water-quality-based effluent limitations, where necessary
to meet water quality standards. Water-quality-based limits may require industrial facilities to
meet requirements that are more stringent than those in a national effluent guideline regulation.
In the overall context of the CWA, effluent guidelines must be viewed as one tool in the broader
set of tools and authorities Congress provided to EPA and the states to restore and maintain the
quality of the nation's waters.
The 1972 CWA directed EPA to promulgate effluent guidelines that reflect pollutant
reductions that can be achieved by categories or subcategories of industrial point sources through
the implementation of available treatment and prevention technologies. 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
2A
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Section 2—Background
307(c)). See Appendix A of this report for more information on the CWA and an explanation of
the different levels of control for ELGs.
Unlike other CWA tools, effluent guidelines are national in scope and establish pollution-
control obligations for all facilities within an industrial category or subcategory that discharge
wastewater. In establishing these controls, under the direction of the statute, EPA assesses, for
example, (1) the performance and availability of the best pollution-control technologies or
pollution-prevention practices for an industrial category or subcategory as a whole; (2) the
economic achievability of those technologies, which can include consideration of the
affordability of achieving the reduction in pollutant discharge; (3) the cost of achieving effluent
reductions; (4) non-water-quality environmental impacts (including energy requirements); and
(5) such other factors as the EPA Administrator deems appropriate.
Congress saw creating a single national pollution-control requirement for each industrial
category, based on the best technology the industry can afford, as a way to reduce the potential
creation of "pollution havens" and to set the nation's sight on eliminating the discharge of
pollutants to waters of the US. Consequently, EPA's goal in establishing national effluent
guidelines is to ensure 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.
In addition to establishing technology-based effluent limits, effluent guidelines 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. ELGs also control pollutant discharges from
industrial facilities and cover discharges directly to surface water (direct discharges) and
discharges to publicly owned treatment works (POTWs) (indirect discharges).
2.2 Effluent Guidelines Review and Planning Process
In addition to establishing new regulations, the CWA requires EPA to review existing
effluent guidelines annually. EPA reviews all point source categories subject to existing effluent
guidelines and pretreatment standards to identify potential candidates for revision, consistent
with CWA sections 304(b), 301(d), and 304(g). EPA also reviews industries consisting of direct-
discharging facilities not currently subject to effluent guidelines to identify potential candidates
for effluent guidelines rulemakings, pursuant to 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 under CWA section 307(b).
2.2.1 Effluent Guidelines Review and Prioritization Factors
In its annual reviews, EPA considers four major factors for prioritizing existing effluent
guidelines or pretreatment standards for possible revision, or identifying new industries of
concern through alternate analyses. These factors were developed in EPA's draft National
Strategy, described at http://water.epa.gov/scitech/wastetech/guide/strategy/fs.cfm.
2-2
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Section 2—Background
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 its rulemaking that will achieve significant environmental and health benefits.
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 concentrations of pollutants in the industrial
category's wastewater and consequently, reduce the hazard to human health or the environment
associated with these pollutant discharges.
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 not be
affordable to implement expensive and stringent new requirements, EPA might conclude a less
stringent, less expensive approach to reduce pollutant loadings would better satisfy applicable
statutory requirements.
The fourth factor EPA considers is 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. This factor
might also prompt EPA, during annual reviews, to decide against revising an existing set of
effluent guidelines or pretreatment standards where the pollutant source is already efficiently and
effectively controlled by other regulatory or non-regulatory programs.
2.2.2 Annual Review Process
EPA has instituted a two-step annual review process. In the odd-year reviews, EPA
screens industrial dischargers through a toxicity ranking analysis (TRA) that identifies and ranks
those categories whose pollutant discharges pose a substantial hazard to human health and the
environment (the first draft National Strategy factor). For the TRA, EPA relies on discharge
monitoring report (DMR) and Toxics Release Inventory (TRI) data to rank and prioritize for
review industrial discharge categories based on toxic-weighted pound equivalents (TWPE)
released. EPA relies on facility and state contacts, permits, and publicly available data sources to
review top ranking industrial categories (see Section 2.2.2.1 for an overview of the odd-year
annual review and Part II of this report for the specific methodology EPA used for the 2013
TRA).
In the even years, EPA reviews additional hazard data sources and conducts alternate
analyses to enhance the identification of industrial categories for which new or revised ELGs
may be appropriate, beyond those that traditionally rank high in the TRA. This is consistent with
the Government Accountability Office's (GAO's) recommendation that EPA's annual review
approach include additional industrial hazard data sources to augment its screening-level review
of discharges from industrial categories.2 Furthermore, EPA recognizes the need to consider in
the screening phase the availability of treatment technologies, process changes, or pollution-
GAO published its recommendations for the review of additional hazard data sources in its September 2012 report
Water Pollution: EPA Has Improved Its Review of Effluent Guidelines But Could Benefit from More Information on
Treatment Technologies, available online at: http://www.gao.gov/assets/650/647992.pdf.
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Section 2—Background
prevention practices that can reduce the identified hazards (the second and fourth draft National
Strategy factors). See Section 2.2.2.2 for an overview of the even-year annual review.
Using the TRA in the odd-year review in conjunction with additional analyses and hazard
data in the even-year review, EPA is considering more cohesively and comprehensively the
factors laid out in its draft National Strategy. This approach allows the Agency to prioritize
existing effluent guidelines or pretreatment standards for possible revision or identify new
industries of concern through alternate analyses.
EPA also conducts a more detailed preliminary category review of those industrial
discharge categories that rank highest in terms of TWPE (i.e., pose the greatest hazard to human
health and the environment) in the TRA or are identified as warranting further review during the
even-year analyses. If EPA determines that further review is warranted for an industrial category,
EPA may complete a preliminary or detailed study of the point source category (see Section
2.2.2.4), which may eventually lead to a new or revised guideline.
2.2.2.1 Overview of the Toxicity Ranking Analysis and Odd-Year Annual Reviews
In the odd-year annual reviews, EPA conducts a TRA using data from the TRI and data
from DMRs contained in the Permit Compliance System (PCS) and the Integrated Compliance
Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES).
Figure 2-1 details how EPA uses the TRA to identify existing ELGs that may warrant revision;
Figure 2-2 addresses how EPA identifies new categories that may warrant regulation.
TRI and DMR data do not identify the effluent guideline(s) applicable to a particular
facility. However, TRI includes information on a facility's North American Industry
Classification System (NAICS) code, while DMR data include information on a facility's
Standard Industrial Classification (SIC) code. Thus, the first step in EPA's TRA is to relate each
SIC and NAICS code to an industrial category.3 The second step is to use the information
reported in TRI and DMR for a specific year to calculate the pounds of pollutant discharged to
U.S. waters. These calculations are performed for toxic, nonconventional, and conventional
pollutants. For indirect dischargers, EPA adjusts the facility discharges to account for removals
at the POTW. The third step is to apply toxic weighting factors (TWFs)4 to the annual pollutant
discharges to calculate the total discharge of toxic pollutants as TWPE for each facility. 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 estimate based on data in
TRI and one estimate based on DMR data. EPA combines these two estimates to generate a
single TWPE value for each industrial category. EPA takes this approach because it found that
3 For more information on how EPA related each SIC and NAICS code to an industrial category, see Section 5.0 of
the 2009 Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of
Potential New Point Source Categories (U.S. EPA, 2009).
4 For more information on TWFs, see Toxic Weighting Factor Development in Support ofCWA 304(m) Planning
Process (U.S. EPA, 2006).
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Section 2—Background
combining the TWPE estimates from TRI and DMR data into a single TWPE number offered a
clearer perspective of the industries with the most toxic pollution.5
EPA then ranks point source categories according to their total TWPE discharges. To
identify categories for further review, EPA prioritizes categories accounting for 95 percent of the
cumulative TWPE from the combined DMR and TRI data. As illustrated in Figure 2-1, EPA
typically excludes from further review categories for which an effluent guidelines rulemaking is
currently underway or for which effluent guidelines have been promulgated or revised within the
past seven years.6 EPA also excludes categories in which only a few facilities account for a large
majority of toxic-weighted pollutant discharges. EPA generally does not prioritize such a
category for additional review, but suggests that individual permits may be more effective in
addressing the toxic-weighted pollutant discharges than a national effluent guidelines
rulemaking. For more information on the results of the 2013 Annual Review, see Section 6.
As illustrated in Figure 2-2, EPA may also evaluate discharges in the odd-year TRA that
are associated with SIC or NAICS codes that are not currently regulated or that may be a
potential new subcategory of an existing ELG. EPA evaluates these discharges to determine if
new ELGs are warranted for the new industrial category (or subcategory). Similarly, EPA can
supplement this information with findings from new analyses conducted in the even-year annual
review and review of treatment technology performance data to identify new industrial
categories that may warrant ELGs (see Section 2.2.2.2).
2.2.2.2 Overview of Even-Year Annual Reviews
In the even-year annual reviews, EPA identifies additional hazard data and reviews
treatment technologies to augment the TRA completed in each odd-year review. EPA prioritizes
the review of these additional hazard data sources based on (1) the likelihood of identifying
unregulated industrial discharges, (2) the utility of identifying new wastewater treatment
technologies or pollution prevention alternatives, and (3) representativeness of the data for an
industrial category. These new analyses take into account a broader set of hazard data and
advancements in treatment technologies. In addition to the new hazard data sources, the even-
year reviews will include information from the public comments received on the Preliminary
Plan and any continuing preliminary category reviews identified during the odd-year review, as
illustrated in Figure 2-3. The specific methodologies and analyses of the 2012 Annual Review
are described in more detail in Section 3 of the EPA'sFinal 2012 Effluent Guidelines Program
Plan and Preliminary 2014 Effluent Guidelines Program Plan (U.S. EPA, 2014).
2.2.2.3 Preliminary Category Reviews
For the industrial categories with the highest hazard potential identified in the TRA, or
identified as a priority from any of the even-year review analyses, EPA may conduct a
5 Different pollutants may dominate the TRI and DMR TWPE estimates for an industrial category due to the
differences in pollutant reporting requirements between the TRI and DMR databases. The single TWPE number for
each category highlights those industries with the most toxic discharge data in both TRI and DMR. Although this
approach could theoretically lead to double-counting, EPA's review of the data indicates that, because the two
databases typically focus on different pollutants, double-counting is minimal and does not affect the order of the top-
ranked industrial categories.
6 EPA chose seven years because this is the typical length of time for the effects of effluent guidelines or
pretreatment standards to be fully reflected in pollutant loading data and TRI reports.
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Section 2—Background
preliminary category review, particularly if it lacks sufficient data to determine whether
regulatory action would be appropriate. EPA will complete preliminary category reviews as part
of the odd- or even-year review cycle depending on the industrial categories warranting further
review at that time. In its preliminary category reviews EPA typically examines 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. In executing preliminary category reviews, EPA first
attempts to verify the toxicity ranking results and fill in data gaps. These assessments provide an
additional level of quality assurance on the reported pollutant discharges and number of facilities
that represent the majority of toxic-weighted pollutant discharge. After the ranking results are
verified, EPA next considers costs and performance of applicable and demonstrated
technologies, process changes, or pollution-prevention alternatives that can effectively reduce the
pollutants in the point source category's wastewater. Finally, and if appropriate based on the
other findings, EPA considers the affordability or economic achievability of the technology,
process change, or pollution prevention measure identified using the second factor.
During a preliminary category review, EPA may consult data sources including, but not
limited to: (1) the U.S. Economic Census, (2) TRI and DMR data, (3) trade associations and
reporting facilities that can verify reported releases and facility categorization, (4) regulatory
authorities (states and EPA regions) that can clarify 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.
2.2.2.4 Preliminary and Detailed Studies
After conducting the preliminary category reviews, as shown in Figure 2-4, EPA may
next conduct either a preliminary or detailed study of an industrial category. Typically these
studies profile an industry category, gather information about the hazards posed in its wastewater
discharges, gather information about availability and cost of treatment and pollution prevention
technologies, assess economic achievability, and investigate other factors in order to determine if
it would be appropriate to identify the category for possible effluent guidelines revision. During
preliminary or detailed studies, EPA typically examines the factors and data sources listed above
for preliminary category reviews. However, during a detailed study, EPA's examination of a
point source category and available pollution prevention and treatment options is generally more
rigorous than the analyses conducted during a preliminary category review or a preliminary
study and may, if appropriate, include primary data collection activities (such as industry
questionnaires and wastewater sampling and analysis) to fill data gaps.
2-6
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Section 2—Background
Begin odd-year review
of existing ELGs
Preliminary results of Toxicity Rankings Analysis
= Combined Tfi/fiefeasesand DMRLoads
database rankings (Factor 1)
DMR&TRI
database
tools
Stakeholder
recommendations
and comments
Evaluation of treatment technology performance data
Stakeholder recommendations and comments
Not a priority category,
no furtherreview at this time
Not a priority
category, no
further
rev lew at this time
AreELG revisions
currently
underway?
Have
ELGs been
developed or revised
/vithinthe past 7
ears?
Not a priority
category, no further
review at this time*
Are
non-representative
facilities responsible for
overall category
TVVPE?
Not a priority
category,
but may recommend
permitting support
forindividual facilities
When ranked
byTWPE, does category
contribute to top 95% of
cumulative TVVPE of all.
categories?
Furtherreview
(see Figure 2-4)
Possible outcome
-Furtherreview
-BPJ support
-Identify for
possible
revision of
existing
ELGs
-No action
identified implementation
and efficiency
_ssues (Factor4
No
* If EPA is aware of new segment growth within such a category or new concerns are identified, EPA may do further review.
Figure 2-1. Odd-Year Annual Review of Existing ELGs
2-7
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Section 2—Background
Stakeholder recommendations
and comments
Identify SIC/NAICS codes
with discharges not subject
to existing ELGs
Is the SIC/NAICS code
appropriately considered a
potential new sufrcategory
of an existing ELG?
Include in annual review
of
existing category
(seeFiQure 2-5)
Begin industry
identification
TRAdat abases
No identification or ^\
further rev i ew wcss s any/
Do
discharges interfere
with or otherwise pass
througriPQTv%
operations'?
Are pollutants
potentially present at
significant
concert rations'?'
res / Is the possible new
category all or nearly all
indirect discliargers'*
No identification or
further review
necessary
Identify other tools
(e.g permit-based
support or guidance
Further rev lew
iswfiqure 2-4}
1 Sigmheart concentration-s include levels above minimum levels from 40 CFR Part 136 cr other EPA-approved method*.,
levels above treatabiiity levels, or at levels of concern to human health and toxicity
Figure 2-2. Odd-Year Identification of Possible New ELGs
2-8
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Section 2—Background
Begin even-year review
of hazard data sources and
treatment technology
performance data
Continued review from
Q€id-year(as necessary)
Identify industries with
pollutant
discharges not previously
reviewed
Collect additional data from
industry groups, published
"•eporfs from EPA, and peer-
review publications
Stakeholder
recommendations
and comments
Are pollutants
potentially present at
significant
concentrations'?"
Determine i fan
existing industry point source
category is applicable
to discharges
Do ELGs
appropriately
regulate all pollutant
discharges identified?
Not apriority
category, no
further
review at this time
Further review
(see Figure 2-4)
Not a priority
category, no further
review at this lime
'Signi (leant concentrations include levels above minimum levels from 40 CFR Part 136 or other EPA-approved methods,
levels above trealability levels, or at levels of concern to human health and toxicity.
Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of
Possible New ELGs
2-9
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Section 2—Background
Category identified for further
review (see Figures 2-1, 2-2, and 2-3),
Not enough
information
Stakeholder
input
Further Rev Jew
- Preliminary category
review
- Preliminary or detailed
study
(continue collecting data
covering all four factors)
Incorporate findings from
treatment technology
Are discharges
adequately controlled
by existing ELGs?
No further review at this time
Identify for possible
promulgation or revision
ofELGs
Are ELGs potentially
the appropriate tool?
Identify othertools (e. g.
permit-based support or guidance)
Figure 2-4. Further Review of Industrial Categories Identified During Odd- and
Even-Year Annual Reviews
2-10
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Section 2—Background
2.2.3 Effluent Guidelines Program Plans
CWA section 304(m)(l)(A) requires EPA to publish an Effluent Guidelines Program
Plan (Plan) every two years that establishes a schedule for the annual review and revision, in
accordance with section 304(b), of the effluent guidelines that EPA has promulgated under that
section. EPA publishes the results of the TRA and preliminary category reviews conducted
during the odd-year review in a Preliminary Plan and takes public comment. In the even-year
following publication of the Preliminary Plan, EPA identifies and evaluates additional data
sources and hazard analyses to supplement the TRA. EPA then publishes a Final Plan in the
even-year. The Final Plan presents the compilation of the odd- and even-year reviews and public
comments received on the Preliminary Plan. EPA may initiate, continue, or complete preliminary
category reviews, or in-depth studies during the odd- or even-year reviews, depending upon
when it identifies a category warranting further review. Additionally, EPA may publish the
findings from these studies as part of the Preliminary or Final Plan, based on when during the
planning cycle the study or review is completed.
EPA is coordinating its annual reviews under section 304(b) with publication of Plans
under section 304(m) for three reasons. First, the annual reviews are inextricably linked to the
planning effort because the results of each year of review can inform the content of the
Preliminary and Final Plans (e.g., by identifying candidates for effluent guidelines revision for
which EPA can schedule rulemaking in the plans, or by identifying point source categories for
which EPA has not promulgated effluent guidelines). Second, even though it is not required to
do so under either section 304(b) or section 304(m), EPA believes it can serve the public interest
by periodically describing to the public the annual reviews (including the review process used)
and the results of the reviews. Doing so at the same time as publishing the Preliminary and Final
Plans makes both processes more transparent. Third, by requiring EPA to review all existing
effluent guidelines each year, Congress appears to have intended for each successive review to
build on the results of earlier reviews.
2.3 References for Background
1. U. S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, D.C. (June). EPA-HQ-OW-2004-0032-1634.
2. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, D.C. (October). EPA-HQ-OW-2008-0517-0515.
3. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers'Manual. Washington, D.C.
(September). EPA-833-K-10-001. Available online at:
http ://cfpub. epa.gov/npdes/writermanual. cfm?program_id=45.
4. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
2-11
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PART II: EPA's 2013 ANNUAL REVIEW
METHODOLOGY AND ANALYSES
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3. 2013 ANNUAL REVIEW DATA SOURCES, LIMITATIONS, AND QUALITY REVIEW
The Clean Water Act (CWA) requires EPA to conduct an annual review of existing
effluent limitations guidelines and standards (ELGs). It also requires EPA to identify industrial
categories without applicable ELGs. This section summarizes the process EPA used in the 2013
Annual Review to identify industrial categories for potential development of new or revised
ELGs. This section also discusses the data sources used to complete this review and their
limitations.
Consistent with its odd year review methodology, EPA performed a toxicity ranking
analysis (TRA) of all industrial categories, including those subject to existing ELGs and those
not currently regulated by ELGs, to identify categories discharging high levels of toxic pollutants
relative to other categories. In performing the TRA, EPA relied on discharge monitoring report
(DMR) data, contained in EPA's Permit Compliance System (PCS), the Integrated Compliance
Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES),
and the Toxics Release Inventory (TRI).
In previous years in which it conducted a TRA, EPA generated two databases to facilitate
the analysis of DMR and TRI data: TRIReleases andDMRLoads. The creation of these databases
is explained in the Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories (U.S. EPA, 2009), also
known as the 2009 Screening-Level Analysis (SLA) Report.
In 2010 EPA launched the DMR Pollutant Loading Tool (the Loading Tool), an online
application that calculates pollutant loadings from permit and DMR data from PCS and ICIS-
NPDES. The Loading Tool ranks discharges, industries, and watersheds based on pollutant mass
and toxicity. It also includes wastewater pollutant discharge data from TRI.7 For the 2013
Annual Review, instead of generating the industrial rankings using the TRIReleases and
DMRLoads databases as it had in past reviews, EPA relied on the industrial rankings provided in
the "Top Industrial Dischargers of Toxic Pollutants" area of the Loading Tool.8 The Loading
Tool's industrial rankings are calculated using the same methodology presented in the 2009 SLA
Report (U.S. EPA, 2009), except for one change to the selection of DMR measurement data from
PCS and ICIS-NPDES, described in Section 3.1. The calculations specific to the Loading Tool
are documented in the Technical Users Background Document for the Discharge Monitoring
Report (DMR) Pollutant Loading Tool (U.S. EPA, 2012a). The data sources, and associated
limitations, used by the Loading Tool to calculate industrial rankings are discussed in Section
O O
3.2.
As a first step, EPA downloaded the DMR and TRI industrial rankings data from the
Loading Tool and performed a quality review of the data, as discussed in Section 3.3. EPA
incorporated any corrections identified during this review into the Loading Tool. EPA then
downloaded the corrected DMR and TRI data from the Loading Tool and used these data to
generate the final point source category rankings (see Section 4.2) and identify industrial
categories for further review (see Section 5).
7 See a full overview of the DMR Pollutant Loading Tool here: http://cfpub.epa.gov/dmr/index.cfm.
8 See the DMR Pollutant Loading Tool page, http://cfpub.epa.gov/dmr/everydav searches.cfm which presents the
top industrial dischargers of toxic pollutants. EPA used this section of the DMR Pollutant Loading Tool to inform its
2013 TRA.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
This section of the report does not revisit the details of the Loading Tool calculations, but
instead outlines the change in TRA methodology from previous annual reviews as well as the
data sources, limitations, data quality review, and the Loading Tool output data for EPA's 2013
Annual Review.
3.1 Methodology Change to the 2013 TRA
The industrial rankings provided in the "Top Industrial Dischargers of Toxic Pollutants"
area of the Loading Tool,9 used to inform the TRA for the 2013 Annual Review, are calculated
using the same methodology presented in the 2009 SLA Report (U.S. EPA, 2009), except for one
change to the selection of DMR measurement data from PCS and ICIS-NPDES, as discussed in
this section.
As described in Section 3.2 of the Technical Users Background Document for the
Discharge Monitoring Report (DMR) Pollutant Loading Tool, the Loading Tool calculates DMR
pollutant loadings using a quantity or concentration value, reported in the DMR data, and a
wastewater flow. There are a total of two quantity and three concentration data fields that can be
populated in the DMR data (i.e., five measurement value fields):
• Quantity 1;
• Quantity 2;
• Concentration 1;
• Concentration 2; and
• Concentrations.
These five measurement fields can represent average or maximum quantity values or
minimum, average, or maximum concentration values. EPA's goal for calculating pollutant loads
is to characterize the average pollutant loading; therefore, the Loading Tool selects the
appropriate DMR measurement data field using a hierarchy that gives priority to the average
values.
In previous reviews, because the load calculation using the quantity value necessitated
fewer variables in the calculation, EPA prioritized average quantities over average
concentrations. However, the pollutant loading calculation methodology in the Loading Tool
selects the same DMR measurement as the permit limit, which could be either concentration or
quantity, to calculate the pollutant load and load over limit estimates. As a result, because EPA
relied on the Loading Tool outputs for the 2013 Annual Review, the pollutant loadings are
calculated by prioritizing measurements that are the same measurement as the permit limit
(concentration or quantity). Even with this change to selecting measurement type, the Loading
Tool still prioritizes average measurements over minimum and/or maximum measurements. See
Section 3.2.2 of the Technical Users Background Document for the Discharge Monitoring
Report (DMR) Pollutant Loading Tool for more specific information on the calculations (U.S.
EPA, 2012a).
9 See the DMR Pollutant Loading Tool page: http://cfpub.epa.gov/dmr/everyday_searches.cfm, which presents the
top industrial dischargers of toxic pollutants. EPA used this section of the DMR Pollutant Loading Tool to inform its
2013 TRA.
3-2
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3.2 Data Sources and Limitations
This section provides general information on the use and limitations of Standard
Industrial Classification (SIC) and North American Industry Classification System (NAICS)
codes, toxic weighting factors (TWFs), TRI data, and DMR data to calculate the industrial
category rankings in the Loading Tool.
3.2.1 SIC Codes
The SIC code system was developed to help with the collection, aggregation,
presentation, and analysis of data from the U.S. economy (OMB, 1987). The different parts of
the SIC code signify the following:
• The first two digits represent the major industry group.
• The third digit represents the industry group.
• The fourth digit represents the industry.
For example, major SIC code 26 (Paper and Allied Products) includes all pulp, paper, and
paperboard manufacturing operations. Within SIC code 26, the three-digit SIC codes are used to
distinguish the type of facility: 263 for paperboard mills, 265 for paperboard containers and
boxes, etc. Within SIC code 265, the four-digit SIC codes are used to separate facilities by
product type: 2652 for setup paperboard boxes, 2653 for corrugated and solid fiber boxes, etc.
Although developed to track economic data, 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 track only the primary SIC code for each establishment. PCS
and ICIS-NPDES include one four-digit SIC code, reflecting the principal activity causing the
discharge at each facility.
EPA does not define the applicability of its ELGs by SIC code, but by industry and
process descriptions. For this reason, 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 data that identify facilities by SIC code (e.g., PCS and ICIS-NPDES), EPA
mapped each four-digit SIC code to an appropriate point source category, as summarized in the
"SIC/Point Source Category Crosswalk" table (Table B-l in Appendix B).
EPA has not established national ELGs for all SIC codes. Table B-2 in Appendix B lists
the SIC codes for which facility discharge data are available in PCS and ICIS-NPDES, but for
which EPA could not identify an applicable point source category. For a more detailed
discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
3.2.2 NAICS Codes
In 1997, the U.S. Census Bureau introduced the NAICS code system, to better represent
the economic structure of countries participating in the North American Free Trade Agreement
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
and to remedy deficiencies of the SIC code system. The nomenclature and format of NAICS and
SIC codes are presented in Table 3-1.
Table 3-1. Nomenclature and Format of NAICS and SIC Codes
NAICS
2-digit
3 -digit
4-digit
5 -digit
6-digit
Sector
Subsector
Industry Group
NAICS Industry
U.S. Industry
SIC
Letter
2-digit
3 -digit
4-digit
N/A
Division
Major Group
Industry Group
Industry
N/A
For example, below are the SIC and NAICS codes for the folding paperboard box
manufacturing industry.
In the SIC code system, the classification is less stratified:
• 26: Paper and Allied Paper Products;
— 265: Paperboard Containers and Boxes;
o 2657: Folding Paperboard Boxes, Including Sanitary (except
paperboard backs for blister or skin packages).
In the NAICS code system the classification is more stratified:
• 32: Manufacturing;
— 322: Paper Manufacturing;
o 3222: Converted Paper Product Manufacturing;
• 322212: Folding Paperboard Box Manufacturing.
The NAICS system is used for industrial classification purposes at many government
agencies, including EPA. As 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 NAICS code.
EPA does not define the applicability of its ELGs by NAICS code, but by industry and
process descriptions. For this reason, regulations for an individual point source category may
apply to one NAICS code, multiple NAICS codes, or a portion of the facilities in an NAICS
code. Therefore, to use data that identify facilities by NAICS code (e.g., TRI), EPA mapped each
six-digit NAICS code to an appropriate point source category, as summarized in the
"NAICS/Point Source Category Crosswalk" table (Table B-3 in Appendix B). This table was
based on the SIC/Point Source Category Crosswalk table (Table B-l in Appendix B) and the
NAICS/SIC Code Crosswalk that EPA developed for past comparisons.
There are some NAICS codes for which EPA has not established national ELGs. Table
B-4 in Appendix B lists the NAICS codes for which facility discharge data are available in TRI,
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
but for which EPA could not identify an applicable point source category. For a more detailed
discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
3.2.3 Toxic Weighting Factors
As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and
methodologies to evaluate effluent discharges. Among these tools is a Toxics Database compiled
from over 100 references for more than 1,900 pollutants. The Toxics Database includes aquatic
life and human health toxicity data, as well as physical and chemical property data. Each
pollutant in this database is identified by a unique Chemical Abstract Service (CAS) number.
EPA uses the Toxics Database to calculate a pollutant-specific TWF that accounts for differences
in toxicity across pollutants and allows comparison of mass loadings of different pollutants. The
TWFs are used in the Loading Tool to calculate a "toxic-equivalent" loading (in pounds-
equivalent per year). The Loading Tool multiplies a mass loading of a pollutant in pounds per
year by the TWF to derive a toxicity weighted pound equivalent (TWPE). The Draft and Final
TWF Development Documents discuss the use and development of TWFs in detail (U.S. EPA,
2005, 2006).
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. In the TWF method
for assessing water-based effects, these aquatic life and human health toxicity levels are
compared to a benchmark value that represents the toxicity level of a specified pollutant. EPA
chose copper, a metal commonly detected and removed from industrial effluent, as the
benchmark pollutant. The Final TWF Development Document contains details on how EPA
developed its TWFs (U.S. EPA, 2006). During the 2013 Annual Review, EPA did not revise any
TWFs or develop TWFs for chemicals that had not previously had TWFs. Table B-5 in
Appendix B lists the TWFs for those chemicals in the Loading Tool for which EPA has
developed TWFs.
3.2.4 Data from PCS and ICIS-NPDES
EPA has used data reported to PCS as a part of its TRA of existing effluent guidelines
since the 2003 Annual Reviews (68 FRN 75515). Since 2002, EPA has been working to
modernize PCS by creating a new data system called ICIS-NPDES. In 2006, some states began
transitioning their DMR reporting from PCS to ICIS-NPDES. At the time EPA downloaded the
data from the Loading Tool, 56 of the 71 states and territories/tribes had completely migrated to
ICIS-NPDES. Therefore, for the 2013 Annual Review, EPA's view of nationwide discharges
was split between two sets of data. The Loading Tool combines the two systems (PCS and ICIS-
NPDES) and generates industrial category rankings for all U.S. states and territories/tribes. Both
PCS and ICIS-NPDES automate entering, updating, and retrieving NPDES data and track permit
issuance, permit limits, monitoring data, and other data pertaining to facilities regulated by the
NPDES program under the CWA.
More than 190,000 industrial facilities and 17,000 wastewater treatment plants have
NPDES individual or general permits10 for wastewater discharges to waters of the U.S. To
10 A NPDES individual permit is written to reflect site-specific conditions of a single discharger based on
information submitted by that discharger in a permit application. An individual permit is unique to that discharger.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
provide an initial framework for setting permitting priorities, EPA developed a major/minor
classification system for industrial and municipal wastewater discharges. Major discharges
usually have the capability to impact receiving waters if not controlled and, therefore, have
received more regulatory attention than minor discharges. Permitting authorities classify
discharges as major based on an assessment of six characteristics (U.S. EPA, 2010):
• Toxic pollutant potential;
• Discharge flow: stream flow ratio;
• Conventional pollutant loading;
• Public health impact;
• Water quality factors; and
• Proximity to coastal waters.
Facilities with major discharges must report compliance with NPDES permit limits via
monthly DMRs submitted to the permitting authority. The permitting authority enters the
reported DMR data into PCS or ICIS-NPDES, including pollutant concentration and quantity
values and identification of any types of permit violations. During the 2013 Annual Review,
EPA identified approximately 6,200 facilities (including sewerage systems) with major
discharges for which PCS and ICIS-NPDES have extensive records.
Minor discharges may, or may not, adversely impact receiving water if not controlled.
Facilities with minor discharges must report compliance with NPDES permit limits via monthly
DMRs submitted to the permitting authority; however, EPA does not require the permitting
authority to enter data in the PCS and ICIS-NPDES databases. For this reason, the PCS and
ICIS-NPDES databases include data only for a limited set of minor discharges (i.e., if the state or
other permitting authority chooses to include these data). During the 2013 Annual Review, EPA
identified approximated 25,000 facilities with minor discharges for which PCS and ICIS-NPDES
have extensive records.
Parameters in PCS and ICIS-NPDES include water quality parameters (such as pH and
temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand
and total suspended solids), and flow rates. Although other pollutants may be discharged, PCS
and ICIS-NPDES contain data only 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.
3.2.4.1 Utility of PCS and ICIS-NPDES
The data collected in the PCS and ICIS-NPDES data systems are particularly useful for
the ELG planning process for the following reasons:
• PCS and ICIS-NPDES combined are national in scope, including data from all 50
states and 21 U.S. territories/tribes.
NPDES general permits are written to cover multiple dischargers with similar operations and types of discharges
based on the permit writer's professional knowledge of those types of activities and discharges (U.S. EPA, 2007).
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
• Discharge reports included in PCS and ICIS-NPDES are based on effluent
chemical analysis and metered flows using known analytical methods.
• PCS and ICIS-NPDES include discharge data for facilities in any SIC code.
3.2.4.2 Limitations of PCS and ICIS-NPDES
Limitations of the data collected in the PCS and ICIS-NPDES data systems include the
following:
• The data systems contain 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.
• The data systems include limited discharge monitoring data from minor
dischargers.
• The data systems do not include data characterizing indirect discharges from
industrial facilities to POTWs.
• In some cases, the data systems identify the type of wastewater (e.g., process
wastewater, stormwater, noncontact cooling water) being discharged. Many do
not, though, so total flow rates reported to PCS and ICIS-NPDES 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 and ICIS-NPDES may double-count a
facility's discharge. In other cases, an outfall may be labeled as an internal
monitoring point, and PCS and ICIS-NPDES may not account for all of a
facility's discharge.
• Facilities do not always report the duration of discharge in their DMRs; therefore,
some pollutant loadings are calculated using continuous discharge assumptions
(365 days per year), which may overestimate the toxic releases.
• 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.11
• PCS and ICIS-NPDES were designed as a permit compliance tracking system and
do not contain production information that would benefit the review of discharges
compared to production-based limitations.
• PCS and ICIS-NPDES data may be entered into the data systems manually, which
leads to data entry errors.
• In PCS and ICIS-NPDES, data may be reported as an average quantity, maximum
quantity, average concentration, maximum concentration, and/or 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
11 ICIS-NPDES includes a data field for applicable ELGs; however, completion of this field is not required and it is
typically not populated.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the
maximum quantity issue in detail (U.S. EPA, 2009).
Despite these limitations, EPA determined that the PCS and ICIS-NPDES data
summarized in the Loading Tool were usable for the TRAs and prioritizations of the toxic-
weighted pollutant loadings discharged by industrial facilities. The combined PCS and ICIS-
NPDES databases remain the only data source quantifying the pounds of regulated pollutants
discharged directly to surface waters of the U.S.
3.2.5 Data from TRI
Section 313 of the Emergency Planning and Community Right-to-Know Act requires
facilities meeting specified thresholds to report their annual releases and other waste
management activities for listed toxic chemicals to the TRI. Facilities must report the quantities
of toxic chemicals recycled, collected, and combusted for energy recovery, treated for
destruction, or otherwise disposed of. Facilities must complete a separate report for each
chemical manufactured, processed, or used in excess of the reporting threshold. For the 2013
TRA, EPA used TRI data for reporting year 2011 because they were the most recent available at
the time the review began.
A facility must meet three criteria to be required to submit a TRI report for a given
reporting year:
1. NAICS Code Determination. The facility's primary NAICS code determines if
TRI reporting is required. The primary NAICS code is associated with the
facility's revenues, and may not relate to its pollutant discharges (71 FR 32464).
The TRI-covered industries include:
• 212, Mining;
• 221, Utilities;
• 31-33, Manufacturing;
• All other miscellaneous manufacturing (includes 1119, 1131,2111, 4883,
5417,8114);
• 424, Merchant Wholesalers, Non-durable Goods;
• 425, Wholesale Electronic Markets and Agent Brokers;
• 511,512, 519, Publishing;
• 562, Hazardous waste; and
• Federal facilities.
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 who 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 NAICS 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. It 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
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
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, non-PBT chemical threshold quantities
are 25,000 pounds for manufacturing and processing activities and 10,000 pounds
for other use activities. All thresholds are determined per chemical over the
calendar year. For example, mercury compounds are considered PBT chemicals.
The TRI reporting guidance requires any facility that manufactures, processes, or
otherwise uses 10 grams or more of mercury 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. Facilities must report onsite releases or
disposal to air, receiving streams, land, underground wells, and several other categories. They
must also report the amount of toxic chemicals in wastes transferred to offsite locations, (e.g.,
publicly owned treatment works (POTWs), commercial waste disposal facilities).
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
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 half the detection limit to estimate
the mass released. However, TRI guidance indicates that for dioxins and dioxin-like compounds,
non-detects 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, TRI
allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and
500 to 999 pounds. If a facility reports a range for a direct or indirect discharge, TRI uses the
middle of the range for the TRI output (U.S. EPA, 2013).
3.2.5.1 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/tribes.
TRI includes releases to POTWs, not just direct discharges to surface water.
TRI includes discharge data from manufacturing NAICS codes and some other
industrial categories.
TRI includes releases of many toxic chemicals, not just those in facility discharge
permits.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3.2.5.2 Limitations of TRI
For purposes of ELG planning, limitations of the data collected in TRI include the
following:
• Small establishments (fewer than 10 employees) are not required to report, nor are
facilities that do not 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. Due to TRI
guidance, they may overstate releases, especially at facilities with large
wastewater flows.
• Certain chemicals (e.g., polycyclic aromatic compounds (PACs), dioxin and
dioxin-like 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.
• Facilities are identified by NAICS code, not point source category. For some
NAICS codes, it may be difficult or impossible to identify the point source
category that is the source of the toxic wastewater releases.
• TRI only requires facilities to report certain chemicals; therefore, all pollutants
discharged from a facility may not be captured.
Despite these limitations, EPA determined that the TRI data presented in the Loading
Tool were usable for the 2013 toxicity rankings analysis and prioritization of the toxic-weighted
pollutant loadings discharged by industrial categories.
3.2.6 TRI and DMR Comparative Analysis
To facilitate EPA's understanding of the usefulness and limitations of the DMR and TRI
data, the Loading Tool has a comparison feature that highlights the differences in discharges in
DMR and TRI at the pollutant and facility level. For example, EPA can compare DMR and TRI
data to identify the following for an industrial category:
• Overestimations in TRI pollutant loadings (identified by comparing reported TRI
discharges and DMR discharges for the same facility/pollutant loading).
• Pollutants not currently regulated or permitted for discharge (identified by TRI
pollutant loadings for facilities and pollutants that are absent from the DMR data).
3.3 2011 DMR and TRI Data Quality Review
EPA evaluated the quality of the 2011 DMR and TRI data from the Loading Tool to
identify any data corrections prior to generating the final 2013 point source category rankings
(see Section 4.2) and further investigating industrial categories for possible effluent guidelines
revisions (see Section 5). This evaluation considered data completeness, comparability, accuracy,
and reasonableness. The Environmental Engineering Support for Clean Water Regulations
Programmatic Quality Assurance Project Plan (PQAPP) describes the quality objectives in
more detail (ERG, 2013).
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3.3.1 Data Quality Review and Corrections to the 2011 DMR Data
To evaluate completeness, comparability, accuracy, and reasonableness of the 2011 DMR
data, EPA performed the following checks:
Completeness. EPA compared counts of 2011 DMR reporting facilities in the Loading
Tool to counts in DMRLoads2009 to confirm the completeness of the 2011 DMR data, as shown
in Table 3-2. Because the numbers of major and minor facilities reporting DMR data are similar
between 2009 and 2011, EPA determined that the 2011 DMR dataset contained in the Loading
Tool was complete for the purpose of use in the 2013 Annual Review.
Table 3-2. Results of 2011 DMR Data Completeness Check
Number of Major Dischargers
DMR 2009
1,944
DMR 2011
1,908
Number of Minor Dischargers
DMR 2009
15,565
DMR 2011
14,530
Sources: DMRLTOutput2011_vl andDMRLoads2009_v2.
Comparability. EPA compared the 2011 DMR data from the Loading Tool to
DMRLoads2009 to identify pollutant discharges or wastewater flows that differed more than the
year-to-year variation of other chemicals and facilities. EPA used this comparison to determine if
quantity, concentration, or flow corrections were appropriate for facility discharges with the
highest TWPE. If the comparison was unavailable (e.g., the pollutant was not previously
reported), EPA contacted the facility or permitting authority. For a summary of the facility-
specific reviews, see Table 3-3. All of the data corrections identified as part of this review were
incorporated into the Loading Tool before EPA calculated the final point source category
rankings.
Accuracy and Reasonableness. To evaluate the accuracy and reasonableness of the 2011
DMR data, EPA reviewed the facility and pollutant discharges that had the greatest impact on
total category loads and rankings in the 2011 DMR Loading Tool, based on toxic-weighted
pounds discharged. For each identified facility, EPA used the following steps to review the
accuracy and reasonableness of the loads calculated from PCS and ICIS-NPDES data:
1. Reviewed database corrections from previous TRAs to determine whether
corrections made during previous reviews should apply to the 2011 DMR
discharges.
2. Reviewed 2011 DMR facility SIC code information (including the facility's
NPDES permit and permit fact sheet) to determine if the facility was assigned to
the point source category that best applied to the majority of its discharges, or
identified pollutant-level point source category assignments where facilities have
operations subject to more than one point source category.
3. Reviewed the Loading Tool's 2011 DMR facility loading calculations, compared
Loading Tool data to data available in EPA's online Envirofacts data system or
from the facility's NPDES permit and permit fact sheet, hand-calculated annual
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
pollutant loads, and compared the results to the 2011 DMR Loading Tool output
data to verify the accuracy of the calculated facility loads.
4. Reviewed PCS and ICIS-NPDES pipe description information available in PCS,
EPA's online Envirofacts data system, ICIS-NPDES supporting tables, or the
facility's NPDES permit and permit fact sheet to identify monitored pollutant
discharges that are:
— Intermittent (e.g., tidal, seasonal, or occurring after a storm);
— Internal monitoring locations from which wastewater is combined with
other waste streams and monitored again, resulting in double-counting
loads; and
— Not representative of category discharges (e.g., stormwater runoff from
nonprocess areas, noncontact cooling water, or wastewater related to
operations in another point source category).
5. Reviewed PCS and ICIS-NPDES output data for pollutants that should be
excluded from the 2011 DMR load calculation because they are in units that
cannot be converted to quantities (e.g., kilograms per day) or concentrations (e.g..
milligrams per liter).12
6. Contacted the state permitting authority or facility to determine if the data were
reported and transcribed correctly.
Table 3-3 presents EPA's facility review of the 2011 DMR data. In addition to this
review, EPA reviewed historical data changes identified during previous TRAs to determine if
they are still applicable to the 2011 DMR data. Table C-l in Appendix C of this report lists all
corrections EPA made to the 2011 DMR data before generating the Final 2013 Point Source
Category Rankings.
12 Table A-5 in Appendix A in the Technical Users Background Document for the Discharge Monitoring Report
(DMR) Pollutant Loading Tool lists pollutants excluded from the Loading Tool (U.S. EPA, 2012a). Examples
include: temperature, pH, fecal coliform, and whole effluent toxicity.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-3. Summary of 2011 DMR Facility Data Quality Review
Facility
Elkem Metals
Company
St. Louis Co.
Water
Doe Run Company
Fletcher Mine/Mill
Armour Creek
Landfill
Location
Alloy, WV
St. Louis, MO
Viburnum, MO
Bunker, MO
Nitro, WV
Point Source
Category
Ferroalloy
Manufacturing
Drinking Water
Treatment
Ore Mining and
Dressing
Ore Mining and
Dressing
Landfills/Waste
Combustors
Pollutant(s)
in Question
Cadmium, lead,
selenium, arsenic,
chromium, nickel,
vanadium, antimony, and
aluminum
Iron, total residual
chlorine
Lead, cadmium, zinc,
copper
Lead
2,3,7,8-TCDD
Review Findings
July through November 20 1 1 metal
concentrations were six orders of
magnitude higher than December
concentrations for all outfalls. Facility
contact confirmed that July through
November concentrations needed to be
divided by 1,000,000 (Wagner, 2013).
All 20 1 1 iron concentration values for
outfalls 001, 002, and 003 range from
11,300 to 322,000 mg/L. All 2011 total
residual chlorine concentration values
for outfalls 001 and 002 range from 840
to 2,300 mg/L. The state contact
confirmed that iron and total residual
chlorine concentration values are in
ug/L, not mg/L (Abernathy, 2013).
March through September 201 1 lead,
cadmium, zinc, and copper
concentrations for outfalls 001, 002, and
003 are 100 to 1,000 higher than
December 201 1 and all 2009
concentrations. June and September
20 1 1 flows for outfall 002 are six orders
of magnitude higher than March and
December 201 1 flows.
201 1 lead concentrations for outfall 001
are high. State contact confirmed that
201 1 lead concentrations are in ug/L,
not mg/L (Abernathy, 2013).
State contact confirmed that 201 1
TCDD concentration for outfall 01 1 is
non-detect (Mullins, 2013).
Action Taken/
Database Correction
Divided July through
November metal
concentrations by
1,000,000.
Divided outfall 00 1,002,
and 003 iron
concentrations by 1,000
and divided outfall 001 and
002 total residual chlorine
concentrations by 1,000.
Divided March through
September 20 11 lead,
cadmium, zinc, and copper
concentrations by 100 or
1,000, as appropriate, for
outfalls 00 1,002, and 003.
Divided outfall 002 June
and September flows by
1,000,000.
Divided 20 11 lead
concentrations for outfall
001 by 1,000.
Zeroed 20 11 TCDD
discharge for outfall Oil.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-3. Summary of 2011 DMR Facility Data Quality Review
Facility
Bullitt County
Landfill
Brushy Creek
Mine/Mill
Doe Run Co. West
Fort Facility
Alcoa Inc. — North
Plant
IMC Phosphates
Company —
Faustina
Location
Lebanon Junction,
KY
Bunker, MO
Bunker, MO
Alcoa, TN
Donaldsonville,
LA
Point Source
Category
Landfills/Waste
Combustors
Ore Mining and
Dressing
Ore Mining and
Dressing
Aluminum Forming
Inorganic Chemicals
Pollutant(s)
in Question
Flow
Lead, cadmium, zinc,
copper
Lead, cadmium, zinc,
copper
PCB, cyanide
Fluoride
Review Findings
February, March, June, July, November,
and December 201 1 flows for outfalls
001 and 002 are 10,000 to 100,000 times
higher than other months' flows. EPA
contacted the state during the 2010
Annual Review and confirmed that large
flows were reported as GPD, not MOD.
Because the 201 1 flows are off by the
same order of magnitude, EPA assumes
the same correction applies (Becker,
2010).
2011 lead, cadmium, zinc, and copper
concentrations for outfall 001 are high.
State contact confirmed that 201 1 lead,
cadmium, zinc, and copper
concentrations are in ug/L, not mg/L
(Abernathy, 2013).
April 2011 lead, cadmium, zinc, and
copper concentrations for outfall 004 are
high. State contact confirmed that April
2011 lead, cadmium, zinc, and copper
concentrations are in ug/L, not mg/L, for
outfall 004 (Abernathy, 2013).
State contact confirmed that October
201 1 PCB discharge for outfall N06 is
non-detect. State contact also confirmed
that the April 201 1 cyanide
concentration for outfall SW1 should be
0.01 mg/L, not 0.1 mg/L (Waits, 2013).
State contact identified that the June
201 1 fluoride quantity for outfall 002
was incorrect as a result of a data entry
error (Peterson, 2013).
Action Taken/
Database Correction
Divided February, March,
June, July, November, and
December 20 1 1 flows for
outfalls 00 land 002 by
10,000 or 100,000, as
appropriate.
Divided 20 11 lead,
cadmium, zinc, and copper
concentrations for outfall
001 by 1,000.
Divided April 20 11 lead,
cadmium, zinc, and copper
concentrations for outfall
004 by 1,000.
Zeroed October 201 1 PCB
discharge for outfall N06.
Corrected April 20 11
cyanide discharge to 0.01
mg/L for outfall SW1.
Revised June 201 1 fluoride
quantity for outfall 002
from 73 9,000 kg/day to
1,360 kg/day.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-3. Summary of 2011 DMR Facility Data Quality Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Reverse Osmosis
Treatment Facility
Brighton, CO
Drinking Water
Treatment
Sulfide
The September 2011 sulfide
concentration is five orders of
magnitude higher than the other reported
concentrations for outfall Oil.
Divided the September
2011 concentration by
100,000.
Palm Coast WTP
#3—Membrane C
Palm Coast, FL
Drinking Water
Treatment
Hydrogen sulfide
Hydrogen sulfide concentration values
range from 168 to 300 mg/L for outfall
001. Facility was contacted as part of the
2011 Annual Review and it was
determined that the units for hydrogen
sulfide were in LB/1000GA instead of
mg/L (Sedano, 2011).
Converted the hydrogen
sulfide concentrations to
mg/L from LB/1000GA
(pounds per 1000 gallons
of water) using
conversions from the 2011
Annual Review.
Forest View MHP
Wooster, OH
Landfills/Waste
Combustors
Ammonia as N
January through July 2011 ammonia as
N concentrations for outfall 001 are four
to seven orders of magnitude higher than
permit limitations.
Divided ammonia as N
concentrations by 10,000
or 10,000,000, as
appropriate.
Honeywell
International
Incorporated
Baton Rouge, LA
Inorganic Chemicals
Hexachlorobenzene,
PACs
Facility contact confirmed that all
hexochlorobenzene and polycyclic
aromatic compounds (PACs) are
measured below the minimum
quantification level (MQL). The facility
permit states that "if any individual
analytical test result is less than the
MQL listed in the permit, a value of zero
may be used for that individual result for
the DMR calculations and reporting
requirements." Previously, the facility
reported concentrations below the MQL
as zero. However, for the 2010 and 2011
DMRs, the facility decided to take a
more conservative approach in reporting
and did not list zero for values below the
MQL (Campesi, 2013).
Revised 2011
hexachlorobenzene and
PACs discharges to be 0
pounds per year.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-3. Summary of 2011 DMR Facility Data Quality Review
Facility
Alcan Rolled
Products, LLC
Marion Co.
Sanitary Landfill
U.S. DOEPaducah
Proj ect — Paducah
Remediation
Services, LLC
Climax
Molybdenum
Company
Arkema, Inc.
Solutia, Inc. —
Anniston Plant
Conservation
Chemical
Company
Location
Ravenswood, WV
Lebanon, KY
West Paducah,
KY
Climax, CO
Carrollton, KY
Anniston, AL
Kansas City, MO
Point Source
Category
Aluminum Forming
Landfills/Waste
Combustors
Inorganic Chemicals
Ore Mining and
Dressing
Inorganic Chemicals
Inorganic Chemicals
Inorganic Chemicals
Pollutant(s)
in Question
Lead
All pollutants
PCB
All pollutants
Tin
PCB-1242
PCB
Review Findings
EPA contacted the state as part of the
201 1 Annual Review and confirmed that
all 2009 lead measurements were non-
detect for outfall 002. Because the 201 1
lead concentration values for outfall 002
are similar to 2009, EPA assumes the
same correction applies (Clevenger,
2011).
June 201 1 flow for outfalls 001 and 002
is five orders of magnitude higher than
the March 20 11 flow.
State contact confirmed the 201 1 PCB
discharges for outfall 019 (Hokanson,
2013).
May through July 201 1 flows for outfall
001 are high. State contact confirmed
the 201 1 flows for outfall 001 (Morgan,
2013).
State contact confirmed the 201 1 tin
discharges for outfall 001 (Hokanson,
2013).
During the 201 1 Annual Review, EPA
contacted the facility to confirm similar
PCB-1242 concentrations and flows for
outfall 012. The facility contact
confirmed the data for outfall 012. The
20 1 1 DMR data for outfall 0 12 are
similar in order of magnitude to 2009
DMR data (Warren, 20 11).
All 201 1 PCB concentrations are below
the permit limitations.
Action Taken/
Database Correction
Zeroed 20 11 lead
discharges for outfall 002.
Divided June 201 1 flow
for outfalls 001 and 002 by
100,000.
No change.
No change.
No change.
No change.
No change.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-3. Summary of 2011 DMR Facility Data Quality Review
Facility
Huber, J.M.
Corporation
Kennecott
Corporation-
Smelter & Refinery
Pogo Mine
Mobile Pulley and
Machine Works
Wise Alloys,
LLC— Alloys Plant
Location
Havre de Grace,
MD
Magna, UT
Delta Junction,
AK
Mobile, AL
Muscle Shoals,
AL
Point Source
Category
Inorganic Chemicals
Ore Mining and
Dressing
Ore Mining and
Dressing
Ferroalloy
Manufacturing
Aluminum Forming
Pollutant(s)
in Question
Sodium sulfate
Arsenic, cadmium,
copper
Arsenic
All pollutants
Aluminum
Review Findings
All 201 1 sodium sulfate quantities are
below the permit limitations.
EPA reviewed arsenic, cadmium,
copper, and flow values for all outfalls.
No outlier data identified.
March 201 1 arsenic concentration is
three orders of magnitude higher than
the other reported concentrations for
outfall Oil.
March 201 1 flows for outfalls 001, 002,
and 004 are three to four orders of
magnitude higher than other months'
flows.
201 1 aluminum concentrations and flow
rates for outfall 004 are high. State
provided copies of the DMRs for outfall
004 (Pinson, 2013).
Action Taken/
Database Correction
No change.
No change.
Divided March 20 11
arsenic concentration by
1,000 for outfall 001.
Divided March 20 1 1 flows
for all outfalls 00 1,002,
and 004 by 1,000.
Updated 2011 aluminum
concentrations and flow to
match the state-provided
DMRs for outfall 004.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3.3.2 Data Quality Review and Corrections to the 2011 TRIData
To evaluate completeness, comparability, accuracy, and reasonableness of the 2011 TRI
data, EPA performed the following checks:
Completeness. EPA compared counts of 2011 TRI reporting facilities in the Loading
Tool to counts in TRIReleases2009, TRIReleases2008, TRIReleases2007, TRIReleases2005,
TRIReleases2004, TRIReleases2003, TRIReleases2002, and TRIReleases2000 to evaluate the
completeness of the 2011 TRI data in the Loading Tool, as shown in Table 3-4. Additionally,
EPA compared the counts of the number of facilities reporting 2011 TRI discharges, per NAICS
code grouping, to the number of facilities reporting 2009 discharges. This comparison showed
that for 72 percent of the NAICS code groupings, the number of facilities reporting wastewater
discharges changed by less than 25 percent from 2009 to 2011. EPA also determined that most
NAICS codes exhibiting a large percentage change did so because only a few facilities in these
NAICS codes reported discharges (e.g., a change from one facility to three facilities is equivalent
to a 200 percent increase).
Because the number of facilities reporting is similar between 2009 and 2011, EPA
determined that the 2011 TRI dataset contained in the Loading Tool was complete for the
purpose of its use in the 2013 Annual Review.
Table 3-4. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2011
Reporting Year
2002
2003
2004
2005
2006
2007
2008
2009
2011
Total Number of Facilities
Reporting to TRI
24,379
23,811
23,675
23,461
22,880
21,965
21,694
20,797
18,391
Number of Facilities Reporting
Discharges to TRI
8,291
8,051
7,930
7,837
7,506
6,572
6,891
7,012
6,855
Comparability. EPA compared the 2011 TRI data from the Loading Tool to
TRIReleases2009 and previous years' discharges to identify annual pollutant loadings that
differed more than the year-to-year variation of other chemicals and facilities. EPA used this
comparison to determine if corrections were appropriate for facility discharges with the highest
TWPE. If the comparison was unavailable (e.g., the pollutant was not previously reported), EPA
contacted the facility. For a summary of the facility-specific reviews, see Table 3-5. EPA
incorporated all of the data corrections identified through this review into the Loading Tool
before calculating the final point source category rankings.
Accuracy and Reasonableness. EPA reviewed facility and pollutant discharges that had
the greatest impact on total category loads and rankings in terms of TWPE discharged. For the
identified facilities, EPA used the following steps:
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
1. Reviewed database corrections from previous TRAs to determine whether
corrections made during previous reviews should apply to the 2011 TRI
discharges.
2. Reviewed discharges reported to TRI for other reporting years (i.e., 2000, 2002,
2003, 2004, 2005, 2007, 2008, and 2009) and compared them to discharges
reported to TRI for reporting year 2011 to identify trends in the discharges.
3. Reviewed 2011 TRI NAICS code information to determine if the facility was
assigned to the point source category that best applied to the majority of its
discharges, or identified pollutant-level point source category assignments where
facilities have operations subject to more than one point source category.
4. Reviewed 2011 DMR data, if available, and hand-calculated annual pollutant
loads to compare to discharges reported to TRI for reporting year 2011.
5. Verified that the Loading Tool excluded pollutants that should not have an
associated pollutant load (e.g., yellow or white phosphorus). See Section 3.4.2 in
EPA's 2011 Annual Review Report (U.S. EPA, 2012b).
6. Contacted the facility to verify whether the pollutant discharges are reported
correctly.
Table 3-5 presents EPA's detailed facility review and corrections made to the 2011 TRI
data. In addition to this review, EPA also reviewed historical data changes identified during
previous TRAs to determine if they are still applicable to the 2011 TRI data. Table C-2 in
Appendix C of this report lists all corrections EPA made to the 2011 TRI data before generating
the Final 2013 Point Source Category Rankings.
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-5. Summary of 2011 TRI Facility Review
Facility
S. D. Warren Co.
Mountain State
Carbon LLC
Carolina Pole
Leland
Domtar Paper Co.
Abibow US Inc. —
Calhoun Operations
Location
Skowhegan,
ME
Follansbee,
WV
Leland, NC
Bennettsville,
SC
Calhoun, TN
Point Source
Category
Pulp, Paper, and
Paperboard
Iron and Steel
Timber Products
Processing
Pulp, Paper, and
Paperboard
Pulp, Paper, and
Paperboard
Chemical(s) in
Question
Dioxin and dioxin-like
compounds
PACs
Dioxin and dioxin-like
compounds
Dioxin and dioxin-like
compounds
Dioxin and dioxin-like
compounds
Review Findings
Facility contact provided corrected 2011
dioxin distribution (Schwartz and Wiegand,
2013).
During the 20 1 1 Annual Review, EPA
contacted the facility to confirm the PAC
discharge. The facility contact provided
PAC sampling data, which provide a
distribution for the PAC compounds to
create a facility-specific TWF (Smith,
2011). The 2011 PAC load is similar in
order of magnitude to the 2009 PAC load;
therefore, EPA will apply the same change
to the facility-specific TWF.
Facility contact provided 2010 dioxin
sampling data, which were used in
combination with 20 1 1 rainfall data to
calculate the 2011 TRI load (Rouse, 2013).
The facility-provided dioxin distribution
does not match the 201 1 TRI dioxin
distribution.
Based on the non-detect results provided as
part of the 20 1 1 Annual Review, the dioxin
data can be zeroed for 20 1 1 (U. S. EPA,
2012b).
Based on the non-detect results provided as
part of the 201 1 Annual Review, the dioxin
data can be zeroed for 20 1 1 (U. S. EPA,
2012b).
Action Taken/
Database Correction
Revised dioxin
distribution.
Revised PACs annual load
(Ib/y)from330to 169.
Calculated TWPE using
facility-specific TWF.
Revised dioxin distribution
to match facility-provided
sampling data.
Zeroed dioxin load.
Zeroed dioxin load.
3-20
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-5. Summary of 2011 TRI Facility Review
Facility
Graftech
International
Holdings Inc.
St. Paul Park
Refining Co., LLC
Columbian
Chemicals Co.
Sasol North
America Inc. Lake
Charles Chemical
Complex
Exxonmobil
Chemical Baton
Rouge Chemical
Plant
Location
Columbia, TN
Saint Paul
Park, MN
Centerville,
LA
Westlake, LA
Baton Rouge,
LA
Point Source
Category
Carbon Black
Manufacturing
Petroleum Refining
Carbon Black
Manufacturing
Organic Chemicals,
Plastics, and Synthetic
Fibers
Organic Chemicals,
Plastics, and Synthetic
Fibers
Chemical(s) in
Question
PACs
Dioxin and dioxin-like
compounds
PACs
Dioxin and dioxin-like
compounds
PACs
Review Findings
During the 2010 Annual Review, EPA
contacted the facility to confirm the PAC
discharge. The facility contact provided
PAC sampling data, which provide a
distribution for the PAC compounds to
create a facility-specific TWF (Aslinger,
2010). The 2011 PAC load is similar in
order of magnitude to the 2008 PAC load;
therefore, EPA will apply the same change
to the facility-specific TWF.
Facility contact confirmed that an error was
identified in their 201 1 dioxin load
calculations (Owen, 2013).
Facility confirmed all 201 1 PAC discharges
are non-detect (Reasoner, 2013).
Facility contact provided dioxin compound
sampling data. Facility contact stated that
distribution and load were calculated using
half the detection limit for values that were
non-detect (Hookanson, 2013). These data
matched the dioxin data requested during
the 20 1 1 Annual Review.
Facility contact confirmed 201 1 TRI PAC
discharges were estimated from monthly
sampling results and that all results are non-
detect (Labat, 2013).
Action Taken/
Database Correction
Revised PACs annual load
(Ib/y) from 371 to 134.
Calculated TWPE using
the facility-specific TWF.
Revised dioxin distribution
and load.
Zeroed PAC load.
Revised dioxin load (Ib/y)
from 0.0009 to 0.0006, and
revised the dioxin
distribution.
Zeroed PAC load.
3-21
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-5. Summary of 2011 TRI Facility Review
Facility
Location
Point Source
Category
Chemical(s) in
Question
Review Findings
Action Taken/
Database Correction
Hovensa, LLC.
Christiansted,
VI
Petroleum Refining
Dioxin and dioxin-like
compounds
The facility was contacted as part of the
2011 Annual Review. The contact stated
that the dioxin discharges are estimated
using literature values associated with
dioxin formation from reformer catalyst
regeneration (Vernon, 2011). Hovensa did
not analyze its wastewater for dioxin or
furans; therefore, EPA is not certain dioxins
and furans are actually present in the
wastewater at concentrations above the
Method 1613B Minimum Level. As a
result, EPA concluded that although
Hovensa's estimate of releases follows TRI
program guidance, it may not represent
actual wastewater discharges (U.S. EPA,
2014).
No action.
Exxonmobil
Refining & Supply
Baton Rouge
Refinery
Baton Rouge,
LA
Petroleum Refining
Mercury and mercury
compounds
The facility actually detected 0.022 ppm of
mercury and mercury compounds because
LDEQ published new lower MQLs for
metals as part of the water quality standards
(historically the mercury discharges were
non-detect because LDEQ had higher
MQLs (Labat, 2013).
No action.
Boise White Paper,
LLC
Wallula, WA
Pulp, Paper, and
Paperboard
Dioxin and dioxin-like
compounds
The facility confirmed the 2011 dioxin
distribution and total grams and stated that
the same calculation process as previous
years was used. The reason some congeners
were detected in 2009 and not in 2011 was
that in 2009 one-half the detection limit was
used for the congeners that were reported by
the testing lab as non-detect. Since 2009,
these values have been reported as zero
(Schwartz and Wiegand, 2013). No data
corrections.
No action.
3-22
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
Table 3-5. Summary of 2011 TRI Facility Review
Facility
Eastman Chemical
Co., Tennessee
Operations
Location
Kingsport, TN
Point Source
Category
Pesticide Chemicals
Chemical(s) in
Question
Arsenic and arsenic
compounds, mercury
and mercury
compounds,
hydroquinone
Review Findings
The facility contact confirmed that the
facility uses coal boilers and gasification
units onsite. The mercury and arsenic
compounds are constituents in the coal and
must be reported for TRI, however,
sampling indicated that all mercury and
arsenic discharges were non-detect. Per
EPA direction, mercury and arsenic
discharges will be removed to new
subcategory under steam and the
concentrations will be zeroed. The facility
confirmed hydroquinone discharge and
stated that the data are modeled based on
influent manufacturing data. No data
corrections to hydroquinone discharges
(Smith, 2013).
Action Taken/
Database Correction
Mercury and arsenic
discharges moved to a new
subcategory under steam;
discharges zeroed.
3-23
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
3.4 References for 2013 Annual Review Data Sources, Limitations, and Quality Review
1. Abernathy, Travis. 2013. Telephone Communication with Travis Abernathy, Missouri
Department of Natural Resources, and Kimberly Bartell, Eastern Research Group, Inc.,
Re: 2011 DMR Concentration Values and Units for Fletcher Mine, Brushy Creek Mine,
Doe Run Co. West Fork Facility, and St. Louis Co. Water. (January 4). EPA-HQ-OW-
2014-0170. DCN 07777.
2. Aslinger, Julia. 2010. Email Communication between Julia Aslinger, Center for
Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research
Group, Inc. RE: PAC Discharge Summary. (March 22). EPA-HQ-OW-2008-0517. DCN
07253.
3. Becker, Jory. 2010. Notes from Telephone Conversation between Jory Becker, KY DEP,
and Jessica Wolford, Eastern Research Group, Inc. "RE: Review of DMR data and
Permits for Bullitt County Landfill (KY0091651) and Reed Duplex Apt. Bldg.
(KY0095036)." (February 22). EPA-HQ-OW-2008-0517. DCN 07254.
4. Campesi, Brad. 2013. Telephone and Email Communication with Brad Campesi,
Honeywell International Incorporated, and Kimberly Bartell, Eastern Research Group,
Inc., Re: 2011 DMR Concentration Values and Units. (February 5). EPA-HQ-OW-2014-
0170. DCN 07942.
5. Clevenger, Renee. 2011. Telephone Communication Between Renee Clevenger, West
Virginia Department of Environmental Protection (WVDEP), and Kimberly Landick,
Eastern Research Group, Inc., Re: 2009 DMR Lead Discharges. (May 5). EPA-HQ-OW-
2010-0824. DCN 07561.
6. ERG. 2013. Eastern Research Group, Inc. Environmental Engineering Support for Clean
Water Regulations Programmatic Quality Assurance Project Plan (PQAPP). Chantilly,
VA. (October). EPA-HQ-OW-2010-0824. DCN 07754.
7. Hokanson, Shawn. 2013. Telephone and Email Communication with Shawn Hokanson,
Kentucky Division of Water, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
2011 DMR Clarification Needed for Kentucky Facilities. (January 9). EPA-HQ-OW-
2014-0170. DCN 07943.
8. Hookanson, Steve. 2013. Telephone and Email Communication with Steve Hookanson,
Sasol North America, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 TRI
Dioxin Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07944.
9. Labat, Stan. 2013. Telephone and Email Communication with Stan Labat, Exxonmobil,
and Elizabeth Sabol, Eastern Research Group, Inc., Re: 2011 TRI Mercury and PACs
Discharges. (January 22). EPA-HQ-OW-2014-0170. DCN 07956.
10. Morgan, Kelly. 2013. Telephone Communication with Kelly Morgan, Colorado
Department of Public Health and Environment, and Elizabeth Sabol, Eastern Research
Group, Inc., Re: DMR Discharge Flows. (January 9). EPA-HQ-OW-2014-0170. DCN
07945.
3-24
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
11. Mullins, Gladys. 2013. Email Communication with Gladys Mullins, West Virginia
Department of Environmental Protection, and Elizabeth Sabol, Eastern Research Group,
Inc., Re: TCDD and Manganese DMR Discharges. (January 9). EPA-HQ-OW-2014-
0170. DCN 07955.
12. OMB. 1987. Office of Management and Budget. Standard Industrial Classification
Manual. Washington, DC. (Unknown). EPA-HQ-OW-2008-0517.
13. Owen, Herbert. 2013. Telephone and Email Communication with Herbert Owen, St. Paul
Park Refining Co., LLC, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011
TRI Dioxin Discharges. (January 7). EPA-HQ-OW-2014-0170. DCN 07946.
14. Peterson, Kelly. 2013. Telephone and Email Communication with Kelly Peterson,
Louisiana Department of Environmental Quality, and Kimberly Bartell, Eastern Research
Group, Inc., Re: 2011 DMR Concentration Values and Units. (January 4). EPA-HQ-OW-
2014-0170. DCN 07947.
15. Pinson, Theo. 2013. Telephone and Email Communication with Theo Pinson, Alabama
Department of Environmental Management (ADEM), and Kimberly Bartell, Eastern
Research Group, Inc., Re: 2011 DMR Concentration Values and Units for Wise Alloys
LLC. (January 7). EPA-HQ-OW-2014-0170. DCN 07948.
16. Reasoner, Michael. 2013. Telephone and Email Communication with Michael Reasoner,
Columbian Chemicals Co., and Kim Wagoner, Eastern Research Group, Inc., Re: 2011
TRIPAC Discharges. (January 17). EPA-HQ-OW-2014-0170. DCN 07949.
17. Rouse, Mike. 2013. Telephone and Email Communication with Mike Rouse, Carolina
Pole Leland, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 TRI Dioxin
Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07950.
18. Schwartz, Jerry and Paul Wiegand. 2013. Telephone and Email Communication Between
Jerry Schwartz, American Forest and Paper Association, Paul Wiegand, National
Council for Air and Stream Improvement, and Kimberly Bartell, Eastern Research
Group, Inc., Re: 2011 TRI Pulp and Paper Dioxin Dischargers. (March). EPA-HQ-OW-
2014-0170. DCN 07929.
19. Sedano, Monica. 2011. Telephone and E-mail Communication with Monica Sedano,
Florida Department of Environmental Protection (FL DEP), and Elizabeth Sabol, Eastern
Research Group, Inc. Re: Hydrogen Sulfide, Unionized Concentrations in DMR 2009.
(February 24). EPA-HQ-OW-2010-0824. DCN 07687.
20. Smith, Patrick, 2011. Telephone and E-mail Communication with Patrick Smith,
Mountain State Carbon, and Kimberly Landick, Eastern Research Group, Inc. "RE: 2009
TRIPAC Discharges". (January 21). EPA-HA-OW-2010-0824. DCN 07688.
21. Smith, Fredna. 2013. Telephone and Email Communication with Fredna Smith, Eastman
Chemical Co., Tennessee Operations, and Kim Wagoner, Eastern Research Group, Inc.,
Re: 2011 TRI Arsenic, Mercury, and Hydroquinone Discharges. (January 16). EPA-HQ-
OW-2014-0170. DCN 07951.
3-25
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Section 3—2013 Annual Review Data Sources, Limitations, and Quality Review
22. 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). EPA-HQ-OW-2003-0074-1150.
23. U.S. EPA. 2005. Draft Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-0857.
24. U.S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.
25. U.S. EPA, 2009. Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories. EPA-821-R-09-
007. Washington, D.C. (October). EPA-HQ-OW-2008-0517-0515.
26. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers' Manual. Washington, DC.
(September). EPA-833-K-10-001. Available online at:
http ://cfpub. epa.gov/npdes/writermanual. cfm?program_id=45.
27. U.S. EPA. 2012a. Technical Users Background Document for the Discharge Monitoring
Report (DMR) Pollutant Loading Tool. Available online at:
http://cfpub.epa.gov/dmr/docs/Technical_Users_Background_Doc.pdf. EPA-HQ-OW-
2014-0170. DCN 07952.
28. U.S. EPA. 2012b. The 2011 Annual Effluent Guidelines Review Report. Washington,
D.C. (December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
29. U.S. EPA. 2013. Toxics Release Inventory Basic Plus Data File Format Documentation
v!2. Washington, D.C. (July 11). EPA-HQ-OW-2014-0170. DCN 07957.
30. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
31. Vernon, Kent. 2011. Telephone and Email Communication Between Kent Vernon,
Hovensa, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Request for 2009 TRI
Data Clarification. (January 10). EPA-HQ-OW-2010-0824. DCN 07621.
32. Wagner, Roger. 2013. Telephone Communication with Roger Wagner, Elkem Metals
Company, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 DMR
Concentration Values and Units. (March 7). EPA-HQ-OW-2014-0170.DCN 07954.
33. Waits, Dana. 2013. Telephone Communication with Dana Waits, Tennessee Department
of Environment and Conservation, and Kimberly Bartell, Eastern Research Group, Inc.,
Re: 2011 DMR Concentration Values and Units. (January 4). EPA-HQ-OW-2014-0170.
DCN 07953.
34. Warren, Lee. 2011. Telephone and E-mail Communication between Lee Warren, Water
Division of the Alabama Department of Environmental Management, and Kimberly
Landick, Eastern Research Group, Inc. RE: 2009 DMR Chlorine Discharges at Solutia,
Inc. (February 24). EPA-HA-OW-2010-0824. DCN 07692.
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
4. FINAL 2013 ANNUAL REVIEW TOXICITY RANKING ANALYSIS METHODOLOGY AND
RESULTS
This section presents the methodology and results for the 2013 Toxicity Rankings
Analysis (TRA) along with EPA's review of facilities not reporting a Standard Industrial
Classification (SIC) code in the 2011 discharge monitoring report (DMR) data.
4.1 Methodology for Generating the Final 2013 Point Source Category Rankings
After incorporating the corrections discussed in Section 3.3, EPA downloaded the DMR
and Toxics Release Inventory (TRI) data from the Loading Tool to a set of databases used for the
2013 Annual Review: DMRLTOutput2011 vl and TRILTOutput2011 vl. The databases are
designed to preserve the integrity of the data and subsequent analyses supporting the 2013
Annual Review: they are static, while the Loading Tool is based on a dynamic dataset that can
change over time. (For example, evolving reporting requirements may affect the population of
facilities reporting to the Permit Compliance System (PCS) or the Integrated Compliance
Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES) and
facilities may report data corrections as they are identified.) EPA used the static data in the
databases to generate the combined Final 2013 Point Source Category Rankings (see Section 4.2)
and inform its preliminary category reviews (see Section 5).
See Appendix D of this report for the DMR and TRI category rankings by toxic-weighted
pound equivalents (TWPE). Specifically, Tables D-l and D-2 in Appendix D present the
category rankings by TWPE from the TWOutput2011 vl andDMRLTOutput2011 vl databases,
respectively. These tables reflect all the corrections described in Section 3.3. Tables D-3 and D-4
in Appendix D present the six-digit North American Industry Classification System (NAICS)
code rankings by TWPE from TRIOutput2011 vl and the four-digit SIC code rankings by
TWPE from DMRLTOutput2011 vl, respectively. Tables D-5 and D-6 in Appendix D present
the chemical rankings by TWPE from TRIOutput2011 vl and DMRLTOutput2011 vl,
respectively.
For the 2013 TRA, EPA consolidated the 2011 DMR and TRI point source category
rankings into one dataset using the following steps:
• EPA combined the two lists of point source categories by adding each category's
DMRLTOutput2011 vl TWPE and TRILTOutput2011 vl TWPE.13
• EPA ranked the point source categories based on the total DMRLTOutput2011 vl
and TRILTOutput2011 vl TWPE.
Additionally for the 2013 TRA, EPA eliminated from further consideration the results for
the following:
• Discharges from industrial categories for which EPA recently considered
developing or revising effluent limitations guidelines and standards (ELGs), or for
13 Combining DMR and TRI loads may result in "double-counting" of chemical discharges if a facility reported to
bothPCS/ICIS-NPDES and TRI, and "single-counting" of chemicals reported in only one of the data sources.
Further, the combined TWPE do not count chemicals that may be discharged but are not report to PSC/ICIS-NPDES
or TRI.
-------
Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
which EPA has recently promulgated or revised ELGs (within the past seven
years).
• Discharges from facilities that require a NPDES permit but do not fall into an
existing or new point source category or subcategory (e.g., Superfund sites).
Sections 4.1.1 and 4.1.2 discuss the rationale for these decisions. The final combined
database rankings represent the results of the 2013 TRA and are presented in Section 4.2.
4.1.1 Categories for Which EPA Has Recently Considered Developing or Revising ELGs or
Has Recently Promulgated or Revised ELGs
EPA did not consider industrial categories for which it has recently considered
developing or revising ELGs, because it has thoroughly reviewed these categories separately
from the annual review process. These categories include the Organic Chemicals, Pesticides, and
Synthetic Fibers (40 CFR 414) and Inorganic Chemicals Manufacturing (40 CFR 415) point
source categories for facilities that produce chlorine and chlorinated hydrocarbons, as well as the
coalbed methane extraction industry. See Section 5 of EPA's Final 2012 and Preliminary 2014
Plan (U.S. EPA, 2014) for details on EPA's determinations related to these categories.
Similarly, EPA's 2013 Annual Review excluded point source categories for which ELGs
were recently established or revised but are not yet fully implemented, as well as categories that
were recently reviewed in a rulemaking context, but for which EPA decided to withdraw the
proposal or choose "no action." In general, EPA removed an industrial point source category
from further consideration during a review cycle if it had established, revised, or reviewed the
category's ELGs within seven years prior to the Annual Review. This seven-year period allows
time for the ELGs to be incorporated into NPDES permits. Table 4-1 lists the categories EPA
excluded from the 2013 Annual Review due to this seven-year period.
Table 4-1. Point Source Categories That Have Undergone Recent Rulemaking or Review
40 CFR Part
450
122 and 4 12
449
Point Source Category
Construction and Development
Concentrated Animal Feeding Operations (CAFOs)
Airport Deicing
Date of Rulemaking
December 1, 2009
November 20, 2008
May 16, 2012
EPA also did not consider industrial categories for which it is currently engaged in a
rulemaking process. These include steam electric power generation, dental amalgam, and oil and
gas extraction, specifically shale gas extraction. See Section 5.2 of the Final 2012 and
Preliminary 2014 Plans (U.S. EPA, 2014) for details on the rulemaking status for these
categories.
4.1.2 Discharges Not Categorizable
EPA identified discharges that are not categorizable into existing or new point source
categories or subcategories. In particular, EPA reviewed high-TWPE discharges from a
Superfund site (Auchterlonie, 2009). Direct discharges from Superfund sites, whether made
onsite or offsite, are subject to NPDES permitting requirements (U.S. EPA, 1988a, 1988b). For
4-2
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
the reasons discussed below, EPA determined that these discharges do not fall into a single point
source category and excluded these TWPE from the point source category rankings.
EPA determined that discharges from Superfund sites are too varied to be categorized
into a single point source category. In particular, they vary by:
• Contaminants (e.g., metals, pesticides, dioxin).
• Treatment technologies (e.g., air stripping, granular activated carbon,
chemical/ultraviolet oxidation, aerobic biological reactors, chemical
precipitation).
• Types of facilities causing groundwater contamination (e.g., wood treatment
facilities, metal finishing and electroplating facilities, drum recycling facilities,
mine sites, mineral processing facilities, radium processing facilities).
Moreover, the duration and volume of these direct discharges vary significantly due to
differences in aquifer characteristics and the magnitude, fate, and transport of contaminants in
aquifers and vadose zones. Currently at Superfund sites, permit writers determine technology-
based effluent limits using their best professional judgment. EPA selects the remedial technology
and derives numerical effluent discharge limits. The permit must also contain more stringent
effluent limitations when required to comply with state water quality standards. EPA finds that
the current site-specific best professional judgment approach is workable and flexible within the
context of a Superfund cleanup.
4.2 Results of the 2013 Toxicity Rankings Analysis
Table 4-2 presents the combined DMRLTOutput2011 vl and TRILTOutput2011_vl
rankings. These are the Final 2013 Point Source Category Rankings that support EPA's 2013
Annual Review, accounting for all corrections to the data discussed in Section 3.3 and removal
of any categories and discharges discussed in Section 4.1.
4-3
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
Table 4-2. Final 2013 Combined Point Source Category Rankings
40CFR
Part
414
430
419
NA
440
420
418
415
421
455
409
433
451
434
432
429
435
463
NA
445
417
424
436
458
Point Source Category
Organic Chemicals, Plastics, and Synthetic Fibers
Pulp, Paper, and Paperboard
Petroleum Refining
Drinking Water Treatment
Ore Mining and Dressing
Iron and Steel Manufacturing
Fertilizer Manufacturing
Inorganic Chemicals Manufacturing
Nonferrous Metals Manufacturing
Pesticide Chemicals
Sugar Processing
Metal Finishing
Concentrated Aquatic Animal Production
Coal Mining
Meat and Poultry Products
Timber Products Processing
Oil and Gas Extraction
Plastics Molding and Forming
Miscellaneous Foods and Beverages
Landfills
Soap and Detergent Manufacturing
Ferroalloy Manufacturing
Mineral Mining and Processing
Carbon Black Manufacturing
TRILTOutput2011 vl
TWPE
148,000
651,000
681,000
1,640
1,230,000
82,900
6,670
327,000
42,900
374,000
430
51,700
NA
564
39,100
32,300
NA
69,200
4,900
42,900
2,370
8,990
2,950
27,900
DMRLTOutput2011 vl
TWPE
1,540,000
1,030,000
752,000
1,380,000
110,000
1,170,000
599,000
142,000
383,000
19,300
373,000
265,000
292,000
189,000
119,000
98,600
106,000
26,700
57,400
19,300
47,100
27,300
31,200
0.201
Total TWPE
1,690,000
1,690,000
1,430,000
1,390,000
1,340,000
1,250,000
606,000
469,000
426,000
393,000
374,000
317,000
292,000
189,000
158,000
131,000
106,000
95,900
62,300
62,200
49,500
36,300
34,100
27,900
Cumulative
Percentage of
Total TWPE
13.1%
26.3%
37.4%
48.2%
58.6%
68.4%
73.1%
76.7%
80%
83.1%
86%
88.5%
90.7%
92.2%
93.4%
94.5%
95.3%
96%
96.5%
97%
97.4%
97.7%
97.9%
98.2%
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
4-4
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
Table 4-2. Final 2013 Combined Point Source Category Rankings
40CFR
Part
464
410
471
428
438
422
406
457
469
437
460
468
467
439
411
407
405
413
466
444
NA
425
426
442
Point Source Category
Metal Molding and Casting (Foundries)
Textile Mills
Nonferrous Metals Forming and Metal Powders
Rubber Manufacturing
Metal Products and Machinery
Phosphate Manufacturing
Grain Mills
Explosives Manufacturing
Electrical and Electronic Components
Centralized Waste Treatment
Hospital
Copper Forming
Aluminum Forming
Pharmaceutical Manufacturing
Cement Manufacturing
Canned and Preserved Fruits and Vegetables
Processing
Dairy Products Processing
Electroplating
Porcelain Enameling
Waste Combustors
Printing and Publishing
Leather Tanning and Finishing
Glass Manufacturing
Transportation Equipment Cleaning
TRILTOutput2011 vl
TWPE
9,670
1,070
17,900
10,200
7,950
193
10,500
17.4
3,580
2,350
NA
6,180
1,300
2,350
652
4,420
3,770
4,100
27.8
88.2
388
1,900
246
0.013
DMRLTOutput2011 vl
TWPE
16,300
22,300
3,440
7,320
7,670
13,600
2,810
11,800
8,180
7,860
9,420
2,610
6,960
4,520
5,960
1,060
593
NA
2,730
2,650
1,890
8.2
1,560
1,700
Total TWPE
26,000
23,400
21,300
17,500
15,600
13,800
13,300
11,800
11,800
10,200
9,420
8,790
8,270
6,870
6,620
5,480
4,360
4,100
2,760
2,740
2,280
1,910
1,800
1,700
Cumulative
Percentage of
Total TWPE
98.4%
98.5%
98.7%
98.8%
99%
99.1%
99.2%
99.3%
99.4%
99.4%
99.5%
99.6%
99.6%
99.7%
99.7%
99.8%
99.8%
99.9%
99.9%
99.9%
99.9%
99.9%
99.9%
100%
Rank
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
4-5
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
Table 4-2. Final 2013 Combined Point Source Category Rankings
40CFR
Part
443
461
NA
408
427
454
465
446
NA
NA
NA
447
NA
459
Point Source Category
Paving and Roofing Materials (Tars and Asphalt)
Battery Manufacturing
Independent and Stand Alone Labs
Canned and Preserved Seafood Processing
Asbestos Manufacturing
Gum and Wood Chemicals Manufacturing
Coil Coating
Paint Formulating
Food Service Establishments
Industrial Laundries
Tobacco Products
Ink Formulating
Photo Processing
Photographic
Total
TRILTOutput2011 vl
TWPE
1,060
870
4.47
74.2
NA
33.6
75
86.5
NA
NA
12.5
3.61
NA
NA
3,920,000
DMRLTOutput2011 vl
TWPE
581
298
756
686
518
360
250
3.05
45.6
12.6
NA
2.22
0.0628
0.0628
8,930,000
Total TWPE
1,640
1,170
761
761
518
394
325
89.5
45.6
12.6
12.5
5.84
0.0628
0.0628
12,900,000
Cumulative
Percentage of
Total TWPE
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Rank
49
50
51
52
53
54
55
56
57
58
59
60
61
62
Sources: DMRLTOutput2011_vl cmdTRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
4-6
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
4.3 EPA's Review of SIC Code Classifications for Previously Unclassified Facilities
During the 2013 Annual Review, EPA identified 437 facilities that did not report an
associated SIC code in the 2011 DMR data, corresponding to 6,200,000 TWPE. As a result, the
TWPE from these facilities was not assigned to and considered as part of the discharge from the
relevant industrial point source categories. For the 2013 Annual Review, EPA reviewed 10
facilities that made up the top 99 percent of the TWPE associated with unclassified facilities to
assign applicable SIC codes/point source categories. Table 4-3 presents EPA's review of these
top facilities. EPA plans to incorporate these SIC code changes and data corrections into future
annual reviews.
4.4 References for the Final 2013 Annual Review TRA Methodology and Results
1. Auchterlonie, Steve. 2009. Notes from Telephone Conversation between Steve
Auchterlonie, Front St. Remedial Action, and Chris Krejci, Eastern Research Group, Inc.
"RE: Verification of magnitude and basis of estimate for dioxin and dioxin-like
compounds discharges in PCS." (March 13). EPA-HQ-OW-2008-0517-0076.
2. Lopez, Victor. 2013. Telephone and Email Communication Between Victor Lopez,
California Water Resources Control Board, and Kimberly Bartell, Eastern Research
Group, Inc., Re: DMR Data and Permit Information for CA8000409. (July 12). EPA-HQ-
OW-2014-0170. DCN 07958.
3. Patridge, Michael. 2013. Telephone and Email Communication Between Michael
Patridge, Illinois EPA, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011
DMR Data. (November 25). EPA-HQ-OW-2014-0170. DCN 07959.
4. U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. EPA-
540-G-89-006. OSWER Publication 9234.1-01. Washington, DC. (August). Available
online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf
5. U.S. EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites. OSWER Directive 9283.1-2. EPA-540-G-88-003. (December).
Available online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf
6. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
4-7
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
Table 4-3. Summary of EPA's Review of SIC Code Classifications for the Top Previously Unclassified Facilities
Facility
Latham Water
Treatment Plant
Gosnold Arms
Inc.
North End
Association
Regional Water
Recycling Plant
No. 5
East Capitol
Island
Partnership
Jasper Wyman &
Sons
Cullman Filter
Plant
Location
Latham, IL
New Harbor,
ME
Southport,
ME
Chino, CA
Southport,
ME
Cherryfield,
ME
Cullman, AL
TWPE
4,110,000
667,000
517,000
323,000
279,000
138,000
41,800
Review Findings
Assigned
SIC Code
4951
7011
8811
4952
6541
2033
4941
SIC Description
Water Supply
Hotels and
Motels
Private
Household
Sewerage System
Operators of
Dwellings Other
Than Apartments
Canned, Frozen,
and Preserved
Fruits, and Food
Specialties
Water Supply
Assigned
PSC Code
501
NA
NA
NA
NA
407
501
PSC
Description
Drinking
Water
Treatment
NA
NA
NA
NA
Canned and
Preserved
Fruits and
Vegetables
Processing
Drinking
Water
Treatment
Action Taken/Database Correction
EPA contacted Illinois EPA and determined that flow
values and concentrations were incorrect for total
residual chlorine and iron discharges (Patridge, 2013).
Incorporating the corrections, the facility TWPE is
reduced to 0.047.
High TWPE results from discharges of chlorine. EPA
identified a flow error for outfall 001. Dividing the
flows by 1,000,000 reduces the facility TWPE to
0.667.
High TWPE results from discharges of chlorine. EPA
identified a flow error for outfall 001. Dividing flows
by 1,000,000 reduces the facility TWPE to 0.517.
High TWPE results from discharges of copper and
aluminum. The California Water Board confirmed
that the units for copper and aluminum were incorrect
and should be divided by 1,000 (Lopez, 2013).
Incorporating this change the facility TWPE drops to
2,000.
High TWPE due to discharges of chlorine. EPA
identified a flow error for outfall 001. Dividing flows
by 1,000,000 reduces the facility TWPE to 0.279.
High TWPE due to discharges of chlorine. EPA
identified a flow error for outfall 001. Dividing flows
by 1,000,000 reduces the facility TWPE to 0.138.
High TWPE due to discharges of aluminum and
chlorine. EPA identified a flow error for outfall 001.
Dividing flow values by 100 reduces the facility
TWPE to 445.
4-8
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Section 4—Final 2013 Annual Review Toxicity Ranking Analysis Methodology and Results
Table 4-3. Summary of EPA's Review of SIC Code Classifications for the Top Previously Unclassified Facilities
Facility
North Marshall
Water Treatment
Plant
Atlantic Blanket
Company Inc.
St. Linden
Terminal LLC
Location
Grant, AL
Northport,
ME
Linden, NJ
TWPE
38,400
24,600
15,000
Review Findings
Assigned
SIC Code
4941
2392
5171
SIC Description
Water Supply
House
Furnishings, Exc
Curtains
Petroleum Bulk
Station and
Terminal
Assigned
PSC Code
501
NA
419
PSC
Description
Drinking
Water
Treatment
NA
Petroleum
Refining
Action Taken/Database Correction
High TWPE due to discharges of aluminum and
chlorine. EPA identified a flow error for outfall 001.
Dividing the flow values by 100 reduces the facility
TWPE to 413.
High TWPE due to copper and chromium discharges.
EPA identified a flow error for outfall 00 1 . Dividing
the flow values by 1,000,000 reduces the facility
TWPE to 0.0248.
High TWPE due to copper and zinc discharges. EPA
identified a flow error for outfall 001. Dividing the
flow values by 1,000,000 reduces the facility TWPE
to 0.123.
4-9
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Section 5—EPA's 2013 Preliminary Category Reviews
5.1—Prioritization of Categories for Preliminary Category Review
5. EPA's 2013 PRELIMINARY CATEGORY REVIEWS
Based on its toxicity rankings analysis, EPA was able to prioritize for further review (see
Section 2.2.2) those industrial categories whose pollutant discharges potentially pose the greatest
hazards to human health or the environment because of their toxicity. To identify these industrial
categories, EPA calculated the industrial categories cumulative percent of the total toxic-
weighted pound equivalents (TWPE). As shown in Table 4-2, EPA identified and focused its
review on the 17 industrial categories that collectively discharge over 95 percent of the total
TWPE.
5.1 Prioritization of Categories for Preliminary Category Review
Based on its knowledge of the annual review process; data from the Permit Compliance
System (PCS), the Integrated Compliance Information System for the National Pollutant
Discharge Elimination System (ICIS-NPDES), and the Toxics Release Inventory (TRI); and
historical data changes, EPA determined that seven of the 17 categories did not warrant a
detailed preliminary category review as part of the 2013 Annual Review. For these seven
categories, many of which have been reviewed in detail in prior annual reviews, EPA found that
the majority of the TWPE resulted from an easily identifiable error (e.g., incorrect reporting
units) associated with one or two facilities. For TWPE not associated with data entry errors, EPA
did not identify any new information to alter the findings made during previous annual reviews.
These industrial categories, and the reasons for excluding them from further preliminary review,
are briefly discussed below.
For the remaining 10 of the 17 industrial categories that collectively discharge over 95
percent of the total TWPE, EPA did not initially identify obvious data entry errors and/or
determined that the TWPE was attributed to multiple pollutants and facilities. Therefore, EPA
completed a detailed preliminary review for these categories to identify whether data corrections
were necessary or whether the discharges are more appropriately regulated by facility-specific
permitting action, or may warrant revisions to effluent limitations guidelines and standards. The
findings from EPA's preliminary category reviews are discussed in the following subsections of
this report. The 10 industrial categories identified for detailed preliminary category reviews are
listed below and discussed in Sections 5.2 through 5.11:
• Coal Mining (40 CFR Part 434);
• Drinking Water Treatment (potential new category);
• Inorganic Chemicals Manufacturing (40 CFR Part 415);
• Iron and Steel Manufacturing (40 CFR Part 420);
• Metal Finishing (40 CFR Part 433);
• Nonferrous Metals Manufacturing (40 CFR Part 421);
• Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414);
• Petroleum Refining (40 CFR Part 419);
• Pulp, Paper, and Paperboard (40 CFR Part 430); and
• Timber Products Processing (40 CFR Part 429).
5-1
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Section 5—EPA's 2013 Preliminary Category Reviews
5.1—Prioritization of Categories for Preliminary Category Review
5.1.1 Concentrated Aquatic Animal Production (40 CFR Part 451)
The Concentrated Aquatic Animal Production (CAAP) Category total TWPE is
composed entirely of 2011 discharge monitoring report (DMR) discharges. The 2011 DMR top
pollutant is copper. EPA identified one facility, Clear Springs Food Inc. in Buhl, ID, which
accounts for over 99 percent of the 2011 DMR copper TWPE for the CAAP Category. As part of
the 2013 Annual Review, EPA contacted the state of Idaho to confirm Clear Spring Foods Inc.'s
copper discharges. The DMRs that the state provided confirmed that the copper concentrations
were incorrect and that actual discharges did not occur (Gebhardt, 2013). Zeroing the copper
discharges for the Clear Spring Foods Inc. facility reduces the CAAP Category's 2011 copper
TWPE from 289,000 to 2,740 and the total 2011 DMR TWPE from 292,000 to 5,130. The
category is no longer a priority for the 2013 Annual Review.
5.1.2 Meat and Poultry Products (40 CFR Part 432)
For the Meat and Poultry Products (Meat and Poultry) Category, the 2011 DMR TWPE
accounts for 75 percent of the combined DMR and TRI TWPE. As a result, EPA focused on
2011 DMR data. The top 2011 DMR pollutant is lead. EPA identified one facility, Equity Group
Eufaula Div LLC in Eufaula, AL, that accounts for over 99 percent of the 2011 DMR lead
TWPE for the Meat and Poultry Category. As part of the 2013 Annual Review, EPA contacted
this facility to confirm its lead discharges. The facility contact indicated that a reporting error had
been made and all metal concentrations should be divided by 1,000 (Cline, 2013). Correcting this
error reduces the Meat and Poultry Category's total 2011 DMR TWPE from 119,000 to 13,700.
The category is no longer a priority for the 2013 Annual Review.
5.1.3 Oil and Gas Extraction (40 CFR Part 435)
For the Oil and Gas Extraction (Oil and Gas) Category, the 2011 DMR TWPE accounts
for 100 percent of the combined DMR and TRI TWPE. As a result, EPA focused on 2011 DMR
data. EPA determined that four facilities account for 93 percent of the total 2011 DMR TWPE.
EPA reviewed these facilities and determined that they are offshore facilities in the Gulf of
Mexico, regulated by 40 CFR Part 435, Subpart A (Offshore Subcategory). Discharges from
these facilities are subject to a general permit (GMG290000), issued by EPA Region 6. Through
facility review, EPA determined that the top pollutants, mercury in barite, in dry weight, and
cadmium in barite, also in dry weight, should be excluded from the 2011 DMR pollutant loading
calculations because they are not associated with wastewater discharges. These pollutants are
associated with solid barite stock used to generate drilling mud (40 CFR Part 435 §435.13) at
these facilities. The facilities are required to test the solid barite stock to determine if they can
discharge drilling fluids. Drilling fluids to which barite has been added (if such barite contains
mercury in excess of 1.0 milligrams per kilogram dry weight, or cadmium in excess of 3.0
milligrams per kilogram dry weight), have a zero discharge permit requirement. Removing these
pollutant discharges reduced the Oil and Gas Category's total 2011 DMR TWPE from 106,000
to 8,130. The category is no longer a priority for the 2013 Annual Review.
5.1.4 Ore Mining and Dressing (40 CFR Part 440)
For the Ore Mining Category, the 2011 TRI TWPE accounts for 92 percent of the
combined DMR and TRI TWPE. As a result, EPA focused on TRI data. The top pollutants in the
2011 TRI database are arsenic and arsenic compounds and copper and copper compounds. One
5-2
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Section 5—EPA's 2013 Preliminary Category Reviews
5.1—Prioritization of Categories for Preliminary Category Review
facility, Jerritt Canyon Mine in Elko, NV, accounts for more than 99 percent of the arsenic and
arsenic compound and copper and copper compound discharges in the 2011 TRI database. As
part of the 2013 Annual Review, EPA contacted Jerritt Canyon Mine to confirm the arsenic and
arsenic compound and copper and copper compound discharges. The facility contact indicated
that a reporting error had been made: all the metal concentrations were supposed to be in parts
per million but had not been divided by 1,000,000, so they were a factor of six higher than they
should have been (Barta, 2013). Correcting this error reduces the Ore Mining Category's 2011
total TRI TWPE from 1,230,000 to 73,000. The category is no longer a priority for the 2013
Annual Review.
5.1.5 Pesticide Chemicals (40 CFR Part 455)
For the Pesticide Chemicals Category, the 2011 TRI TWPE accounts for 95 percent of
the combined DMR and TRI TWPE. As a result, EPA focused on TRI data. The top pollutants in
the 2011 TRI database are toxaphene and chlordane. EPA identified one facility, Weylchem U.S.
Inc. (Weylchem) in Elgin, SC, that accounts for 100 percent of the 2011 TRI toxaphene and
chlordane TWPE for the Pesticide Chemicals Category. Weylchem's heptachlor discharges were
reviewed in the 2011 Annual Review Report. As part of the 2011 Annual Review, EPA
compared Weylchem's 2009 heptachlor TRI discharges to 2009 heptachlor DMR discharges and
determined that 2009 heptachlor DMR discharges were non-detect. Therefore, EPA revised the
heptachlor TRI load to zero (see Table 3-3 in the 2011 Annual Review Report, U.S. EPA, 2012).
As part of the 2013 Annual Review, EPA followed similar steps for Weylchem's toxaphene and
chlordane discharges. EPA compared Weylchem's 2011 toxaphene and chlordane TRI
discharges to 2011 toxaphene and chlordane DMR discharges and determined that 2011
toxaphene and chlordane DMR discharges were non-detect. Therefore, EPA revised the
toxaphene and chlordane TRI load to zero. Incorporating these corrections decreases the
Pesticide Chemicals Category's 2011 TRI TWPE from 374,000 to 19,300. The category is no
longer a priority for the 2013 Annual Review.
5.1.6 Fertilizer Manufacturing (40 CFR Part 418)
The Fertilizer Manufacturing Category total TWPE is composed almost entirely of DMR
discharges and the top 2011 DMR pollutant is fluoride. EPA identified one facility, Mosaic
Fertilizer LLC, in Uncle Sam, LA, which accounts for over 98 percent of the 2011 DMR fluoride
TWPE for the Fertilizer Manufacturing Category. Mosaic Fertilizer LLC is a phosphate fertilizer
manufacturer. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A,
"Phosphate Subcategory." The facility was reviewed as part of the 2010 and 2011 Annual
Reviews. During those reviews, EPA determined that, in accordance with 40 CFR Part 418, the
facility is exempt from Subpart A and that permit limits are based on facility-specific permitting
(U.S. EPA 2011, 2012). Further, fluoride discharges for the facility have decreased from
discharge years 2009 to 2011 (816,000 TWPE in 2009, 534,000 TWPE in 2011). Therefore, EPA
makes similar conclusions as previous annual reviews: Mosaic Fertilizer LLC does not represent
the Fertilizer Category as a whole because it is exempt from Part 418 (see 52 FR 28428, July 29,
1987). The category is no longer a priority for the 2013 Annual Review.
5.1.7 Sugar Processing (40 CFR Part 409)
The Sugar Processing Category total TWPE is composed entirely of DMR discharges and
the top 2011 DMR pollutant is methylmercury. EPA identified one facility, C&H Sugar Co. Inc.
5-3
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Section 5—EPA's 2013 Preliminary Category Reviews
5.1—Prioritization of Categories for Preliminary Category Review
in Crockett, CA, that accounts for 100 percent of the 2011 DMR methylmercury TWPE for the
Sugar Processing Category. As part of the 2013 Annual Review, EPA contacted the state of
California to confirm C&H Sugar Co.'s methylmercury discharges. The state indicated that the
methylmercury concentrations were incorrect; 2011 concentrations were measured in units of
micrograms per liter, not milligrams per liter as listed on the DMRs (Vasquez, 2013). EPA found
a similar error with this facility during the 2011 review of the Sugar Processing Category and
came to similar conclusions (U.S. EPA, 2012). Correcting this error reduces the Sugar
Processing Category's 2011 methylmercury TWPE from 368,000 365 and the total 2011 DMR
TWPE from 373,000 to 5,930. The category is no longer a priority for the 2013 Annual Review.
5.1.8 References for the Prioritization for Categories for Preliminary Category Review
1. Barta, John. 2013. Telephone Communication with John Barta, Jerritt Canyon Mine, and
Julia Kolberg, Eastern Research Group, Inc. "Re: 2011 TRI Discharges." (December 11).
EPA-HQ-OW-2014-0170. DCN 07962.
2. Cline, Randy. 2013. Telephone and Email Communication with Randy Cline, Equity
Group Eufaula Div LLC, and Kimberly Bartell, Eastern Research Group, Inc. "Re: 2011
DMR Discharges." (December 13). EPA-HQ-OW-2014-0170. DCN 07960.
3. Gebhardt, Chris. 2013. Telephone and Email Communication with Chris Gebhardt, Idaho
DEQ, and Julia Kolberg, Eastern Research Group, Inc. "Re: 2011 DMR Discharges."
(December 13). EPA-HQ-OW-2014-0170. DCN 07961.
4. U. S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-0517. DCN
07320.
5. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
6. Vasquez, Gil. 2013. Telephone and Email Communication with Gil Vasquez, State Water
Resources Control Board of California, and Julia Kolberg, Eastern Research Group, Inc.
"Re: 2011 DMR Discharges for C&H Sugar Co." (December 13). EPA-HQ-OW-2014-
0170. DCN 07963.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
5.2 Coal Mining (40 CFR Part 434)
EPA selected the Coal Mining Category for preliminary review because it continues to
rank high, in terms of toxic-weighted pound equivalents (TWPE), in point source category
rankings. EPA previously reviewed this industry in the Effluent Guidelines Program Plans from
2004 to 2006 and in 2011 (U.S. EPA, 2004, 2005, 2006, 2012). EPA also conducted a detailed
study of the Coal Mining Category during the 2007 and 2008 Annual Reviews (U.S. EPA, 2008).
This section summarizes the results of the 2013 Annual Review pertaining to the Coal Mining
Category. EPA focused on discharges of iron, mercury, sulfate, and manganese because of their
high TWPE relative to other pollutants in the Coal Mining Category. Iron and manganese,
reviewed as part of the 2011 Annual Review, continue to be top pollutants of concern. For the
2013 Annual Review, available discharge data also showed significant contributions of mercury
and sulfate to the Coal Mining Category TWPE.
5.2.1 Coal Mining Category Toxicity Rankings Analysis
Table 5-1 compares the toxicity rankings analysis (TRA) results for the Coal Mining
Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but
instead reviewed additional data sources as part of the even-year annual review, as discussed in
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As
discussed in this section, EPA's review of the Coal Mining Category identified several data
errors that affected the 2011 Discharge Monitoring Report (DMR) data and TWPE. The bottom
row of Table 5-1 shows the corrected data resulting from this review.
Table 5-1. Coal Mining Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
Coal Mining Category Facility Counts
Total TRI
Facilities
24
17
Total DMR
Major Facilities
8
13
Total DMR
Minor Facilities"
158
199
Coal Mining Category
TRI
TWPEb
1,010
564
564
DMR
TWPEC
25,600
189,000
55,900
Total
TWPE
26,600
190,000
56,500
Source: 2011 Annual Review Report (for 2009aDMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_vl
(for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2009 data after corrections made during the 2011 Annual Review.
e 2011 data after corrections made during the 2013 Annual Review.
As shown in Table 5-1, the total TWPE (incorporating data corrections) increased from
2009 to 2011. During that period, the number of major and minor DMR facilities increased,
while the number of TRI facilities decreased.
It is important to note that discharges for the majority of coal mines are not included in
the TRI or DMR data. There are over 1,200 active coal mines in the U.S. (U.S. EIA, 2012). TRI
contains data for facilities in certain SIC codes, including those for coal mining (1221, 1222, and
5-5
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
1231). However, only coal mines with at least 10 full-time employees or their equivalent, and
that manufacture, use, or otherwise process certain chemicals at or above an activity threshold
report to TRI (U.S. EPA, 2009). The 2008 Coal Mining Detailed Study found that only 21 coal
mines had data in TRI (U.S. EPA, 2008); only 17 coal mines had data in the 2011 TRI database
(TRlLTOutput2011 _v7). For DMR data, many states classify coal mines as "minor dischargers"
and, as a result, do not enter DMR data into EPA's ICIS-NPDES or PCS systems.14 EPA's 2008
Detailed Study for the Coal Mining Point Source Category found that fewer than one-fourth of
the coal mines were represented in the EPA's DMR storage system (U.S. EPA, 2008).
5.2.2 Coal Mining Manufacturing Category Pollutants of Concern
For its 2013 annual review, EPA's review of the Coal Mining Category focused on the
2011 DMR discharges because the 2011 DMR data dominate the category's combined TWPE.
Table 5-2compares the five pollutants with the highest contribution to the 2011 DMR TWPE.
Table 5-2 also presents the 2011 DMR TWPE after EPA corrected errors identified in this
preliminary category review (discussed in the sections below). In addition, as a point of
comparison, Table 5-2 shows the 2009 DMR TWPE for these top five pollutants based on the
results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012).
Iron, mercury, sulfate, and manganese contribute approximately 92 percent of the total
2011 DMR TWPE. EPA's investigations of reported discharges of the top four pollutants are
described in Sections 5.3 to 5.6. EPA did not investigate the other pollutants as part of the 2013
Annual Review, including total residual chorine, because they represent approximately 8 percent
of the 2011 DMR TWPE for the Coal Mining Category.
Table 5-2. Coal Mining Category Top DMR Pollutants
Pollutant
Iron
Mercury
Sulfate
Manganese
Total Residual Chlorine
Top Pollutants, Total
Coal Mining Category, Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
192
16
68
96
10
NA
212C
Original
TWPE
57,100
50,900
42,500
22,900
4,260
178,000
189,000
Corrected
TWPE
12,200
11,000
880
16,500
4,260b
44,900
55,900
2009 DMR Data3
TWPE
6,460
6,190
1,960
8,240
28.9
22,900
25,600
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012)
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Total residual chlorine discharges contribute 2 percent of the 2011 category DMR TWPE. Therefore, EPA did not
review total residual chlorine discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
14 The 2011 DMR database has data for 13 major and 205 minor coal mines (DMRLTOutput2011_vl). Because EPA
does not ask the permitting authority to enter data for minor facilities into the DMR database, this is a small
percentage of the over 1,000 active coal mines in the U.S. For further details on major and minor discharges in DMR
data, see Sections.2.4 of this report.
5-6
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
5.2.3 Coal Mining Category Iron Discharges in DMR
EPA's investigation of the iron discharges revealed that Seneca Mine, in Hayden, CO,
accounts for 79 percent of the 2011 DMR iron discharges (shown in Table 5-3). EPA did not
investigate the remaining mines discharging iron.
Table 5-3. Top 2011 DMR Iron Discharging Mines
Facility Name
Seneca Mine (Seneca Coal Co.)
Facility Location
Hayden, CO
All other iron dischargers in the Coal Mining Category3
Total
Pounds of Pollutant
Discharged
8,020,000
2,180,000
10,200,000
Pollutant
TWPE
44,900
12,200
57,100
Facility Percent of
Category TWPE
79%
21%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 191 other mines that have iron discharges in the 2011 DMR data.
Seneca Mine in Hayden, CO discharges iron from nine outfalls. The facility no longer
operates as a mine, but monitoring of discharges continues as the surrounding areas undergo
remediation (Cochran, 2013). As part of the 2013 Annual Review, EPA contacted the mine about
their 2011 iron discharges. Seneca Mine provided corrected discharge concentrations after
identifying a unit error for seven outfalls (Cochran, 2013). Table 5-4 presents Seneca Mine's
2011 original and corrected yearly average iron concentrations, along with the average flow
values reported in the DMR Pollutant Loading Tool for the nine outfalls. Using these corrected
values, Seneca Mine's iron TWPE decreases from 44,900 to 46.5, reducing the Coal Mining
Category's iron TWPE from 57,100 to approximately 12,200, as shown in Table 5-2.
Table 5-4. Seneca Mine's 2011 DMR Original and Corrected Iron Discharges
Outfall
005
006
008
010
Oil
012
013
016
017
Original Average Flow
(MGD)
0.245
0.587
0.357
0.483
0.069
0.188
0.021
0.362
1.08
Original Average Iron
Concentration (mg/L)
643
255
0.170
243
251
293
0.233
635
580
Corrected Concentration
(mg/L)
0.643
0.255
0.170
0.243
0.251
0.365
0.233
0.635
0.578
Source: DMRLTOutput2011_vl; Cochran, 2013.
5.2.4 Coal Mining Category Mercury Discharges in DMR
EPA's investigation of the mercury discharges revealed that Spartan Mine in Sparta, IL
accounts for 78 percent of the 2011 DMR mercury compound discharges (shown in Table 5-5).
EPA did not investigate the remaining mines discharging mercury.
5-7
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
Table 5-5. Top 2011 DMR Mercury Discharging Mines
Facility Name
Spartan Mine (Alpena Vision Resources)
Facility
Location
Sparta, IL
All other mercury dischargers in the Coal Mining Category3
Total
Pounds of
Pollutant
Discharged
341
94
435
Pollutant
TWPE
39,900
11,000
50,900
Facility Percent of
Category TWPE
78%
22%
100%
Source: DMRLTOutput2011_vl.
a There are 15 remaining mines that have mercury discharges in the 2011 DMR data.
Spartan Mine in Sparta, IL, is the top mercury discharging mine. The mine closed in
1998; since closing, its activities are limited to reclamation. Spartan Mine discharges acid mine
drainage from coal refuse piles. Discharges from Outfall 001 contain mercury and flow into a
pond that serves as a tributary to Mary's River (IL EPA, 2010). During the quarter when the
pond is discharging, the mine collects and analyzes pollutant concentrations from a minimum of
nine grab samples (IL EPA, 2010). As part of the 2013 Annual Review, EPA contacted the mine
about their 2011 mercury concentrations and received corrected discharge concentrations. The
facility contact indicated that the 2011 mercury concentrations were reported in units of
micrograms per liter instead of nanograms per liter, as they were measured (Voshel, 2013). Table
5-6 presents the original and corrected concentrations, and average flow rates from the mine.
Using the corrected concentrations, the mine's mercury TWPE decreases from 39,900 to 0.11,
reducing the Coal Mining Category's mercury TWPE from 50,900 to 11,000, as shown in Table
5-2.
Table 5-6. Spartan Mine's 2011 DMR Original and Corrected Mercury Discharges
from Outfall 001
Monitoring Period
31 -Jan- 11
31-May-ll
31-Dec-ll
Average Flow (MGD)
0.86
0.86
0.36
Original Average Iron
Concentration (mg/L)
0.69
0.58
0.0000054
Corrected Concentration
(mg/L)
0.00000069
0.00000058
0.0000054
Sources: DMRLTOutput2011_vl; Voshel, 2013.
5.2.5 Coal Mining Category Sulfate Discharges in DMR
EPA's investigation of the sulfate discharges revealed that Peabody Midwest Mining,
LLC (Peabody) in Ridge Farm, IL accounts for 98 percent of the 2011 DMR sulfate discharges
(shown in Table 5-7). EPA did not investigate the remaining mines discharging sulfate.
5-8
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
Table 5-7. Top 2011 DMR Sulfate Discharging Mines
Facility Name
Peabody Midwest Mining, LLC
Facility Location
Ridge Farm, IL
All other sulfate dischargers in the Coal Mining Category3
Total
Pounds of
Pollutant
Discharged
7,440,000,000
150,000,000
7,590,000,000
Pollutant
TWPE
41,700
841
42,500
Facility Percent of
Category TWPE
98%
2%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 67 remaining mines that have sulfate discharges in the 2011 DMR data.
Peabody in Ridge Farm, IL, discharges sulfate from outfall 003. In reviewing the
concentration of the mine's 2011 sulfate discharges, EPA noted that the March 2011
concentration was 10,000 times greater than other months (see Table 5-8). As part of the 2013
Annual Review, EPA requested Peabody's 2011 DMR reports from the Illinois Environmental
Protection Agency (IL EPA). The discharge and concentration information provided by the state
listed a monthly minimum for March 2011 of 498 mg/L and a monthly maximum of 647 mg/L
(IL EPA, 2013), which is consistent with the order of magnitude of the sulfate discharges
reported for the other months. As a result, EPA assumed that the unusually high sulfate
concentration was a unit reporting error, and corrected the value by dividing the March 2011
sulfate concentration by 10,000. Table 5-8 presents Peabody's 2011 original and corrected
monthly sulfate concentrations along with the flow discharges for outfall 003. Using the
corrected value of 586 mg/L for the March 2011 sulfate concentration, Peabody's sulfate TWPE
decreases from 41,700 to 39.1, reducing the Coal Mining Category's sulfate TWPE from 42,500
to 880, as shown in Table 5-2.
Table 5-8. Peabody's 2011 Original and Corrected Monthly Sulfate and
Flow Discharges from Outfall 003
Monitoring Period
Date3
31-Jan-ll
28-Feb-ll
31-Mar-ll
31-Apr-ll
31 -May- 11
30-June-ll
31-Oct-ll
30-Nov-ll
31 -Dec- 11
Original Average Flow
(MGD)
4.92
12.6
4.91
19.4
4.73
6.84
0.38
0.38
1.37
Original Sulfate
Concentration (mg/L)
677
500
5,856,667
486
292
398
789
789
969
Corrected Sulfate
Concentration (mg/L)
677
500
586
486
292
398
789
789
969
Source: DMRLTOutput2011_vl.
a The mine reported no flow for July, August, and September 2011. Therefore, sulfate concentrations were not
reported for those months.
5.2.6 Coal Mining Category Manganese Discharges in DMR
EPA's investigation of the manganese discharges revealed that Nubay Mining LLC
(Nubay Mining) in Galatia, IL, and Texas Westmoreland Coal Co. (Texas Westmoreland) in
5-9
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
Jewett, TX, account for 41 percent of the 2011 DMR sulfate discharges (shown in Table 5-7).
EPA did not investigate the remaining mines discharging manganese.
Table 5-9. Top 2011 DMR Manganese Discharging Facilities
Facility Name
Nubay Mining LLC
Texas Westmoreland Coal Co.
Facility Location
Galatia, IL
Jewett, TX
All other manganese dischargers in the Coal Mining Category3
Total
Pounds of
Pollutant
Discharged
93,800
40,700
193,000
327,000
Pollutant
TWPE
6,570
2,850
13,500
22,900
Facility Percent of
Category TWPE
29%
12%
59%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 94 remaining mines that have manganese discharges in the 2011 DMR data.
Nubay Mining
Nubay Mining in Galatia, IL, discharges manganese from outfalls 002, 005, and 009. In
reviewing 2011 DMR manganese discharges from the mine, EPA noted that the September 2011
average flow from outfall 002 and the April 2011 average flow from outfall 009 were 1,000
times higher than other flows from these outfalls. As shown in Table 5-10, EPA concluded that
these reported flows were in error and corrected the average flow from these outfalls.
Incorporating the data correction, Nubay Mining's manganese TWPE decreases from 6,570 to
129, reducing the Coal Mining Category's manganese TWPE from 22,900 to 16,500, as shown
in Table 5-2.
Table 5-10. Nubay's 2011 Original and Corrected Monthly Manganese and
Flow Discharges
Outfall
002
002
002
002
002
005
005
005
005
005
009
009
Monitoring
Period Date3
30-Apr-ll
31-May-ll
30-June-ll
30-Sep-ll
31-Dec-ll
31 -Jan- 11
28-Feb-ll
31-Mar-ll
30-Sep-ll
31-Dec-ll
30-Apr-ll
31-May-ll
Original Average Flow
(MGD)
0.4
1.72
1.72
1,730
1.72
3.45
1.72
1.72
3.45
3.45
500
0.3
Corrected Average Flow
(MGD)
0.4
1.72
1.72
1.73
1.72
3.45
1.72
1.72
3.45
3.45
0.5
0.3
Original Manganese
Concentration (mg/L)
0.75
0.75
1.76
0.19
0.65
.002
.001
0.21
0.002
0.19
0.079
0.074
5-10
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
Table 5-10. Nubay's 2011 Original and Corrected Monthly Manganese and
Flow Discharges
Outfall
009
009
Monitoring
Period Date3
30-Nov-ll
31-Dec-ll
Original Average Flow
(MGD)
0.3
0.3
Corrected Average Flow
(MGD)
0.3
0.3
Original Manganese
Concentration (mg/L)
0.002
0.032
Source: DMRLTOutput2011_vl.
a The mine reported no flow for January, February, March, July, August, October and November 2011 from outfall
002; April, May, June, July, August, October and November from outfall 005; and January, February, March, June,
July, August, September, and October 2011 from outfall 009. Therefore, manganese concentrations were not
reported for those months.
Texas Westmoreland
Texas Westmoreland in Jewett, TX, discharges manganese from outfalls 001, 003, and
004. The mine is a surface mine for bituminous coal and lignite (Envirofacts). As shown in Table
5-11, EPA did not identify any obvious reporting errors or data corrections; manganese
discharges have remained consistent from 2007-2011.
Table 5-11. Texas Westmoreland's Yearly Manganese DMR Discharges
Year of Discharge
2007
2008
2009
2010
2011
Total Manganese Pounds
Discharged
34,300
48,300
21,200
31,700
40,700
Total Manganese TWPE
Discharged
2,400
3,380
1,480
2,220
2,850
Source: DMRLTOutput2011_vl.
According to ICIS-NPDES, Texas Westmoreland's NPDES permit limits the
concentration of manganese in the mine's discharges to not more than 1 milligram per day
monthly average and 2 milligrams per day daily maximum for all three outfalls (DMR Pollutant
Loading Tool). Table 5-12 presents the mine's reported 2011 manganese discharges. Table 5-12
also presents the mine's NPDES permit limits and the Coal Mining effluent limitations
guidelines and standards (ELGs) limits for manganese for the Acid or Ferruginous Mine
Drainage subcategory (Subcategory C). See Section 4 of the Coal Mining Detailed Study for
additional details on the Coal Mining ELGs (U.S. EPA, 2008). As shown in Table 5-12, the
mine's reported 2011 manganese discharges do not exceed its permit limits or the Coal Mining
ELGs.
5-11
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
Table 5-12. Texas Westmoreland's 2011 Monthly Manganese and Flow Discharge Data,
NPDES Manganese Permit Limits, and Coal Mining ELGs Subpart C Manganese Limits
2011 Monthly Manganese and
Flow Discharge Data
Outfall
001
001
001
001
001
001
001
001
003
003
003
003
003
003
003
003
003
004
Monitoring
Period Date a
31 -Jan- 11
28-Feb-ll
31 -Mar- 11
30-Apr-ll
31-May-ll
31-Jul-ll
30-Sep-ll
31 -Dec- 11
31 -Jan- 11
28-Feb-ll
31 -Mar- 11
30-Apr-ll
31-May-ll
30-Jun-ll
31-Jul-ll
30-Sep-ll
31 -Dec- 11
31-May-ll
Average
Flow
(MGD)
34.8
22.7
28.4
30.1
31.8
23.6
40.7
33.5
14.1
11
2.9
2.91
2.9
14.8
0.84
4.53
34.7
4.8
Average
Manganese
Discharge
(mg/L)
0.96
0.2
0.71
0.53
0.64
0.11
0.44
0.73
0.06
0.05
0.14
0.08
0.79
0.12
0.16
0.01
0.02
0.03
NPDES Manganese
Permit Limits
Daily
Maximum
(mg/L)
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Monthly
Average
(mg/L)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Coal Mining ELGs
Subpart C Manganese
Limits
Daily
Maximum
(mg/L)
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
Monthly
Average
(mg/L)
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Source: DMRLTOutput2011^yl; Coal Mining Point Source Category BPT, BAT, BCT Limitations and New Source
Performance Standards—40 CFR Part 434.
BAT: Best available technology economically achievable.
BPT: Best practicable control technology.
NSPS: New source performance standards.
a The mine reported no flow for June, August, October and November 2011 from outfall 001; August, October and
November 2011 from outfall 003; and January, February, March, April, June, July, August, September, October,
November and December 2011 from outfall 004. Therefore, manganese concentrations were not reported for those
months.
5.2.7 Coal Mining Category Findings
The estimated toxicity of the Coal Mining Category discharges resulted from iron,
mercury, sulfate, and manganese discharges. From the 2013 Annual Review, EPA has identified
the following:
• One facility, Seneca Mine, contributes the majority of the iron discharges to the
2011 DMR data. EPA identified a significant error in the concentration data for
iron for six of the nine outfalls discharging iron. With these errors corrected, the
mine's iron TWPE decreases from 44,900 to 46.5, reducing the Coal Mining
Category's iron TWPE from 57,100 to 12,200.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
• One facility, Spartan Mine, contributes the majority of the mercury discharges to
the 2011 DMR data. EPA identified an error in the concentrations reported for the
mine, which the facility contact corrected. With this error corrected, the mine's
mercury TWPE decreases from 39,900 to 0.11, reducing the Coal Mining
Category's mercury TWPE from 50,900 to 11,000.
• One facility, Peabody Midwest Mining, LLC, contributes the majority of the
sulfate discharges to the 2011 DMR data. EPA identified a significant error in the
sulfate concentration reported in March 2011. With this error corrected, the
mine's TWPE decreased from 41,700 to 39.1, reducing the Coal Mining
Category's sulfate TWPE from 42,500 to 880.
• Two mines, Nubay Mining LLC and Texas Westmoreland Coal Co., contribute
the majority of the manganese discharges in the 2011 DMR data. EPA confirmed
manganese discharges for the Texas Westmoreland facility were below NPDES
permit limits, as well as under the Coal Mining ELGs. EPA identified an error in
the reported flow rates for Nubay Mining LLC. With this error corrected, the
mine's TWPE decreased from 6,570 to 129, reducing the Coal Mining Category's
manganese TWPE from 22,900 to 16,500.
• Correcting the reporting errors identified during the 2013 Annual Review
decreases the 2011 Coal Mining Category TWPE from 190,000 to 56,500. This
change would drop the category outside the top 95 percent that EPA prioritized
for preliminary review as part of the 2013 Annual Review.
5.2.8 References for Coal Mining Category
1. Cochran, John. 2013. Telephone Communication with John Cochran, Peabody
Investment Corporation (Parent Company of Seneca Mine), and Julia Kolberg, Eastern
Research Group, Inc. Re: 2011 DMR Iron Discharges. (December 19). EPA-HQ-OW-
2014-0170. DCN 07872.
2. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 434 - Coal Mining. (March). EPA-HQ-OW-
2014-0170. DCN 07884.
3. IL EPA. 2010. Illinois Environmental Protection Agency. NPDES Permit: Alpena Vision
Resources LLC, Spartan Mine, Sparta, IL. (February 1). EPA-HQ-OW-2014-0170. DCN
07873.
4. IL EPA. 2013. Illinois Environmental Protection Agency. DMR Data for IL0074802 -
Peabody Midwest Mining LLC. Available online at:
http://dataservices.epa.illinois.gov/dmrdata/dmrsearch.aspx. Accessed: December 9.
EPA-HQ-OW-2014-0170. DCN 07874.
5. U.S. EIA. 2012. United States Energy Information Administration. 2012 Historic Coal
Production Data. Available online at: http://www.eia.gov/coal/data.cfnrfproduction.
Accessed: February 7, 2014. EPA-HQ-OW-2014-0170. DCN 07875.
6. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.2—Coal Mining (40 CFR Part 434)
1. U.S. EPA. 2005. Preliminary 2005Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0016.
8. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
9. U.S. EPA. 2008. Coal Mining Detailed Study. EPA-821-R-08-012. Washington, D.C.
(August). EPA-HQ-OW-2006-0771-1695.
10. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.
11. U.S.EPA.2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
12. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
13. Voshel, Anne. 2013. Telephone Communication with Anne Voshel, Alpena Vision
Resources - Spartan Mine, and Julia Kolberg, Eastern Research Group, Inc. Re: 2011
DMR Mercury Discharges. (December 31). EPA-HQ-OW-2014-0170. DCN 07876.
5-14
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
5.3 Drinking Water Treatment (Potential New Category)
EPA selected the Drinking Water Treatment (DWT) industrial category for preliminary
review because it continues to rank high, in terms of toxic-weighted pound equivalents (TWPE),
in the point source category rankings. The DWT industrial category is not currently regulated by
national effluent limitations guidelines and standards (ELGs); however, EPA reviewed these
discharges to determine if a new regulatory category is appropriate for controlling wastewater
discharges.
EPA reviewed discharges from the DWT industrial category as part of the 2004 Annual
Review, because at that time DWT ranked high in terms of TWPE relative to the other categories
and was identified as a potential category of concern by public commenters (U.S. EPA, 2004). In
2011, EPA published the results of the industrial category review, which included a literature
review, site visits, and a survey of the DWT industry. A summary of the information collected as
part of the review can be found in EPA's Drinking Water Treatment Plant Residuals
Management Technical Report: Summary of Residuals Generation, Treatment, and Disposal at
Large Community Wastewater Systems (the 2011 DWT Report) report (U.S. EPA, 2011). As
stated in the 2011 DWT Report, EPA determined that NPDES permits (individual and general)
best control discharges from these facilities.
This section summarizes the results of the 2013 Annual Review pertaining to the DWT
industrial category. EPA focused on discharges of total residual chlorine and metals, which were
also the focus of prior reviews, because of their high TWPE relative to the other pollutants
discharged by establishments in this industrial category.
5.3.1 D WT Industrial Category 2013 Toxicity Rankings Analysis
Table 5-13 compares the toxicity rankings analysis (TRA) results for the DWT Category
from the 2011 and 2013 Annual Reviews. As discussed in this section, EPA's review of the
DWT Category identified data errors that affect the 2011 DMR data and TWPE. The bottom row
of Table 5-13 shows the corrected data resulting from this review.
Table 5-13. DWT Industrial Category TRI and DMR Facility Counts and Discharges for
the 2011 and 2013 Annual Reviews
Year of
Discharge
2009
2011
2011d
Year of
Review
2011
2013
2013
DWT Category Facility Counts
Total TRI
Facilities
3
2
Total DMR
Major
Facilities
7
18
Total DMR
Minor
Facilities"
854
1,005
DWT Category TWPE
TRI
TWPEb
132
1,640
1,640
DMR
TWPEC
408,000
1,380,000
974,000
Total
TWPE
408,000
1,390,000
976,000
Sources: DMRLTOutput2011_vl (for 2011 DMR), TRILTOuptut2011_vl (for 2011 im),DMRLoads2009_v2 (for
2009 DMR), and TRIReleases2009_v2 (for 2009 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2011 data after corrections made during the 2013 Annual Review.
5-15
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
5.3.2 D WT Industrial Category Pollutants of Concern
EPA's 2013 Annual Review of the DWT industrial category focused on 2011 DMR
discharges because the 2011 DMR data account for the majority of the industrial category's
combined TWPE (over 99 percent). Table 5-14 lists the five pollutants with the highest
contribution to the 2011 DMR TWPE. Table 5-14 also presents the 2011 DMR TWPE after EPA
corrected errors identified in this preliminary category review (discussed in the sections below).
As a point of comparison, Table 5-14 provides the 2009 DMR TWPE for these top five
pollutants. Consistent with the 2011 industry review of DWT facilities, for the 2013 Annual
Review, EPA identified that total residual chlorine, aluminum, and copper contributed the
highest amount of TWPE to DWT discharges. However, as shown in Table 5-14, the 2011 DMR
TWPE for the DWT industrial category (after corrections identified during this annual review)
has more than doubled since 2009.
Table 5-14. DWT Industrial Category Top DMR Pollutants
Pollutant
Total Residual Chlorine
Aluminum
Copper
Mercury
Lead
Top Pollutant Total
DWT Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
644
250
137
52
98
NA
l,023a
Original
TWPE
416,000
346,000
127,000
113,000
110,000
1,110,000
1,380,000
Corrected
TWPE
181,000
171,000
127,000
113,000
110,000
701,000
974,000
2009 DMR Data3
TWPE
131,000
214,000
12,300
159
1,640
359,000
408,000
Sources: DMRLTOutput2011_vl w&DMRLoads2009_v2.
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Number of facilities reporting TWPE greater than zero.
As shown in Table 5-15, increases in total residual chlorine, copper, mercury, and lead
are driving the increase in the category's TWPE. Table 5-15 also shows that the total number of
facilities reporting DMR discharges for the top five pollutants has increased by more than 60
percent for copper, mercury, and lead from 2009 to 2011.
Table 5-15. DWT Industrial Category Count of Facilities for 2011 Top DMR Pollutants
Pollutant
Total Residual Chlorine
Aluminum
Copper
Mercury
Lead
Number of Facilities Reporting
Pollutant in 2009 DMR Data
Major
5
1
5
1
2
Minor
542
233
79
30
57
Total
547
234
84
31
59
Number of Facilities Reporting
Pollutant in 2011 DMR Data
Major
10
2
12
6
7
Minor
634
248
125
46
91
Total
644
250
137
52
98
Total Facility
Count Percent
Increase
18%
7%
63%
68%
66%
Source: DMRLTOutput2011_vl aadDMRLoads2009_v2.
5-16
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
For the 2013 Annual Review of the DWT industrial category, EPA investigated all top
five DMR pollutants for the category. However, because of the large number of facilities in the
DWT industrial category, EPA only reviewed the top facilities reporting total residual chlorine
and aluminum discharges to verify reported data and identify anomalous data points that might
need correction. The results of EPA's 2013 Annual Review are presented in sections 5.3.3
through 5.3.5.
5.3.3 D WT Industrial Category Total Residual Chlorine Discharges in DMR
EPA identified 644 drinking water treatment facilities with 2011 DMR total residual
chlorine discharges. Two facilities, PRASA WTP PTA Vieja Ponce and PRASA WTP Sabana
Grande, account for 58 percent of the 2011 DMR total residual chlorine discharges (shown in
Table 5-16). EPA did not investigate the remaining facilities discharging total residual chlorine
as part of the 2013 Annual Review.
Table 5-16. Top 2011 DMR Total Residual Chlorine Discharging Facilities
Facility Name
PRASA WTP PTA Vieja Ponce
PRASA WTP Sabana Grande
Facility Location
Ponce, PR
Sabana Grande, PR
Remaining Facilities Reporting Total Residual Chlorine
Discharges3
Total
Pounds of
Pollutant
Discharged
397,000
80,700
353,000
831,000
Pollutant
TWPE
199,000
40,400
177,000
416,000
Facility Percent of
Category TWPE
48%
10%
42%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 642 remaining facilities that have total residual chlorine discharges in the 2011 DMR data.
PRASA WTP PTA Vieja Ponce
PRASA WTP PTA Vieja Ponce (PRASA Vieja Ponce) in Ponce, Puerto Rico, discharges
total residual chlorine from outfall 001. In reviewing the facility's 2011 DMR total residual
chlorine data, EPA noted that the October 2011 flow and total residual chlorine concentration
were at least one order of magnitude higher than the other 2011 flows and concentrations. As
shown in Table 5-17, EPA determined that the reported October 2011 flow and concentration
were in error and corrected these values. These corrections decreased the facility's total residual
chlorine TWPE from 199,000 to 3,700. This change reduced the 2011 DMR total residual
chlorine TWPE by 195,000. Additionally, the facility has a total residual chlorine permit limit of
0.5 mg/L (DMR Pollutant Loading Tool). PRASA Vieja Ponce exceeded its permit limit nine
months out of the year. Therefore, facility-specific permitting action may be appropriate to
address total residual chlorine discharges from PRASA Vieja Ponce.
5-17
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
Table 5-17. PRASA Vieja Ponce's 2011 DMR Original and Corrected Flow and Total
Residual Chlorine Discharges for Outfall 001
Monitoring Period
Date
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-Jul-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Original Average
Flow (MGD)
0.34
0.41
0.52
0.26
1.48
0.75
1.33
0.89
0.52
53.6
0.73
0.61
Corrected
Average Flow
(MGD)
0.34
0.41
0.52
0.26
1.48
0.75
1.33
0.89
0.52
5.36
0.73
0.61
Original Average Total
Residual Chlorine
Concentration (mg/L)
0.57
1.31
2.1
4.1
4.8
1.87
0.46
0.73
0.49
28.4
0.51
0.46
Corrected Average
Total Residual
Chlorine
Concentration (mg/L)
0.57
1.31
2.1
4.1
4.8
1.87
0.46
0.73
0.49
2.84
0.51
0.46
Source: DMRLTOutput2011_vl.
PRASA WTPSabcina Grande
PRASA WTP PTA Vieja Ponce (PRASA Sabana Grande) in Sabana Grande, Puerto
Rico, discharges total residual chlorine from outfall 001. In reviewing the facility's 2011 DMR
total residual chlorine data, EPA noted that the reported February 2011 flow was at least three
orders of magnitude higher than the other 2011 flows. As shown in Table 5-18, EPA determined
that the reported February 2011 flow was in error and corrected the flow. This correction
decreased the facility's total residual chlorine TWPE from 40,400 to 52.6. This change reduced
the 2011 DMR total residual chlorine TWPE by 40,300.
Table 5-18. PRASA Sabana Grande's 2011 DMR Original and Corrected Flows for
Outfall 001
Monitoring Period Date
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-Jul-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Original Average Flow (MGD)
0.079
500
0.105
0.107
0.064
0.057
0.091
0.11
0.032
0.084
0.202
0.17
Corrected Average Flow (MGD)
0.079
0.05
0.105
0.107
0.064
0.057
0.091
0.11
0.032
0.084
0.202
0.17
Source: DMRLTOutput2011_vl.
5-18
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
Further Review of 2011 DMR Total Residual Chlorine Discharges
Additionally, EPA reviewed the information on total residual chlorine discharges
collected as part of the 2011 review of the DWT industrial category. As shown in Table 4-3 of
EPA's 2011 DWT Report (U.S. EPA, 2011), EPA reviewed general and individual NPDES
permits for total residual chlorine permit limitations from 21 states. During the 2011 review of
the DWT industrial category, EPA determined that the majority of the permits reviewed
contained monthly average total residual chlorine permit limitations ranging from 0.01 mg/L to
l.Omg/L.
For the 2013 Annual Review, EPA identified the minimum, maximum, and median 2011
DMR total residual chlorine facility average concentrations and compared those values to the
maximum monthly average permit limitation identified in EPA's 2011 DWT Report (1.0 mg/L).
As shown in Table 5-19, the median of the facility average DMR total residual chlorine
concentrations for 2011 is well below the maximum monthly average permit limitation identified
in the 2011 DWT Report. Further, 93 percent of the facilities reporting total residual chlorine
have average concentrations below the maximum monthly average permit limitation identified in
the 2011 DWT Report.
Table 5-19. 2011 DMR Total Residual Chlorine Concentrations (mg/L)
Maximum
Monthly
Average Permit
Limitation
(mg/L)
1.0
Minimum
Reported 2011
Average
Concentration
(mg/L)
0.00001
Maximum
Reported 2011
Average
Concentration
(mg/L)
102,000
Median
Reported 2011
Average
Concentration
(mg/L)
0.06
Total Number of
Facilities
Discharging
Total Residual
Chlorine
644
Count (Percent) of
Facilities over
Maximum
Monthly Average
Permit Limitation
42 (7%)
Sources: 2011 DWT Report (U.S. EPA, 2011) and DMRLTOutput2011_vl.
5.3.4 D WT Industrial Category Aluminum Discharges in DMR
EPA identified 250 drinking water treatment facilities with 2011 DMR aluminum
discharges. EPA's investigation of the aluminum discharges revealed that two facilities, Sanford
Springs WTP and Dekalb Jackson WTP, account for 51 percent of the 2011 DMR aluminum
discharges (shown in Table 5-20). EPA did not investigate the remaining facilities' aluminum
discharges as part of the 2013 Annual Review.
Table 5-20. Top 2011 DMR Aluminum Discharging Facilities
Facility Name
Sanford Springs WTP
Dekalb Jackson WTP
Facility Location
Piedmont, AL
Flat Rock, AL
Remaining Facilities Reporting Aluminum Discharges3
Total
Pounds of
Pollutant
Discharged
1,930,000
984,000
2,840,000
5,760,000
Pollutant
TWPE
116,000
59,100
171,000
346,000
Facility Percent
of Category
TWPE
34%
17%
49%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 248 remaining facilities that have aluminum discharges in the 2011 DMR data.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
Sanford Springs WTP
Sanford Springs WTP (Sanford Springs) in Piedmont, AL, discharges aluminum from
outfall 001. EPA contacted the facility to confirm its aluminum discharges. The facility contact
stated that the 2011 flow values, presented in Table 5-21, should be in units of gallons per
minute, not million gallons per day. The facility contact explained that outfall 001 is a
backwash/flush outfall for the facility and only discharges for ten minutes per day; therefore, the
flow rate is low (Ransom, 2013). This correction decreased the facility's aluminum TWPE from
116,000 to 1.16.
Table 5-21. Sanford Springs 2011 DMR Original and Corrected Flows for Outfall 001
Monitoring Period Date
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-M-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Original Average Flow (MGD)
1,076
865
870
1,029
1,231
1,540
1,443
1,441
1,220
1,163
991
901
Corrected Average Flow (MGD)
0.011
0.009
0.009
0.010
0.012
0.015
0.014
0.014
0.012
0.012
0.010
0.009
Source: DMRLTOutput2011_vl.
Dekalb Jackson WTP
Dekalb Jackson WTP (Dekalb) in Flat Rock, AL, discharges aluminum from outfall 001.
As part of the 2013 Annual Review, EPA contacted the facility to confirm its aluminum
discharges. The facility contact stated that the 2011 flow values, presented in Table 5-22, were
incorrect and should be divided by 1,000 (Rose, 2013). This correction decreased the facility's
aluminum TWPE from 59,100 to 59.1.
Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001
Monitoring Period Date
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-Jul-2011
31-Aug-2011
Original Average Flow (MGD)
159
155
146
142
151
181
168
158
Corrected Average Flow (MGD)
0.159
0.155
0.146
0.142
0.151
0.181
0.168
0.158
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
Table 5-22. Dekalb 2011 DMR Original and Corrected Flows for Outfall 001
Monitoring Period Date
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Original Average Flow (MGD)
142
145
147
156
Corrected Average Flow (MGD)
0.142
0.145
0.147
0.156
Source: DMRLTOutput2011_vl.
Further Review of 2011 DMR Aluminum Discharges
Similar to total residual chlorine, EPA reviewed the information on aluminum discharges
collected as part of the 2011 review of the DWT industrial category. As shown in Table 4-3 of
EPA's 2011 DWT Report (U.S. EPA, 2011), EPA reviewed general and individual NPDES
permits for aluminum limitations from 21 states. During the DWT industrial category review,
EPA determined that the majority of permits reviewed contained monthly average aluminum
permit limitations ranging from 0.75 mg/L to 4 mg/L.
For the 2013 Annual Review, EPA identified the minimum, maximum, and median 2011
DMR aluminum facility average concentrations and compared those values to the maximum
monthly average permit limitation identified in EPA's 2011 DWT Report (4 mg/L). As shown in
Table 5-23, the median of the facility average DMR aluminum concentrations for 2011 is well
below the maximum monthly average permit limitation. Further, 95 percent of the facilities
reporting aluminum have average concentrations below the maximum monthly average permit
limitation identified in the 2011 DWT Report.
Table 5-23. 2011 DMR Aluminum Concentrations (mg/L)
Maximum
Monthly
Average Permit
Limitation
(mg/L)
4
Minimum
Reported 2011
Average
Concentration
(mg/L)
0.0016
Maximum
Reported 2011
Average
Concentration
(mg/L)
1,680
Median
Reported 2011
Average
Concentration
(mg/L)
0.25
Total Number of
Facilities
Discharging
Aluminum
250
Count (Percent) of
Facilities over
Maximum
Monthly Average
Permit Limitation
12 (4.8%)
Sources: 2011 DWT Report (U.S. EPA, 2011) and DMRLTOutput2011_vl.
During the 2011 review of the category, EPA determined that discharges from some
drinking water treatment plants include certain pollutants because they are present in the source
water (concentrated when removed from drinking water) and/or are the result of chemical
treatment (including the presence of chemical impurities and disinfection by-products). As
shown in Table 8-2 in the 2011 DWT Report, aluminum is listed as a source water contaminant
removed from drinking water and is present in treatment chemicals (U.S. EPA, 2011).
5.3.5 DWT Industrial Category Copper, Mercury, and Lead Discharges in DMR
For 2011 DMR copper, mercury, and lead discharges, EPA focused its review on
comparing the reported 2011 DMR discharge data to the permit limitations summarized in
5-21
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
EPA's 2011 DWT Report to determine if the discharge concentrations, on average, are higher
than the permit limitations.
As with its review of total residual chlorine and aluminum, for the 2013 Annual Review
EPA identified the minimum, maximum, and median 2011 DMR copper and lead facility
average concentrations and compared those values to the maximum monthly average permit
limitations listed in the 2011 DWT Report. As shown in Table 4-3 of EPA's 2011 DWT Report
(U.S. EPA, 2011), EPA's review of general and individual NPDES permits identified seven
states that include permit limitations for copper ranging from 0.0031 mg/L to 0.007 mg/L.
Additionally, EPA identified four states that include permit limitations for lead ranging from
0.003 mg/L to 0.0081 mg/L.
As shown in Table 5-24, the median of the facility average DMR copper concentrations
for 2011 is greater than the maximum monthly average permit limitation identified in the 2011
DWT Report (0.007 mg/L). Additionally, EPA determined that only 26 percent of the facilities
reporting copper have average concentrations below the maximum monthly average permit
limitation.
Table 5-24 also shows that the median of the facility average DMR lead concentrations
for 2011 is less than the maximum monthly average permit limitation identified in the 2011
DWT Report (0.0081 mg/L). For 2011 DMR lead discharges, EPA determined that 87 percent of
facilities reported lead concentrations lower than the maximum monthly average permit
limitation.
Table 5-24. 2011 DMR Copper and Lead Concentrations (mg/L)
Pollutant
Copper
Lead
Maximum
Monthly
Average
Permit
Limitation
(mg/L)
0.007
0.0081
Minimum
Reported 2011
Average
Concentration
(mg/L)
0.000017
0.00004
Maximum
Reported 2011
Average
Concentration
(mg/L)
4.8
0.26
Median
Reported 2011
Average
Concentration
(mg/L)
0.012
0.0015
Total Number
of Facilities
Discharging
Pollutant
137
98
Count (Percent)
of Facilities over
Maximum
Monthly
Average Permit
Limitation
102 (74.5%)
13 (13.3%)
Sources: 2011 DWT Report (U.S. EPA, 2011), andDMRLTOutput2011_vl.
Mercury is not listed as a common regulated pollutant in Section 4.2 of the 2011 DWT
Report. Therefore, for this analysis, EPA compared the DMR average mercury concentrations
for 2011 presented in Table 5-25 to available wastewater treatment data for mercury. As an
initial point of comparison, EPA compared the 2011 DMR average mercury concentrations to
concentrations achieved by granular media filtration (GMF). This treatment technology was
tested at a petroleum refinery to meet NPDES permit limitations. The study found that GMF
could achieve effluent limitations ranging from 0.003 |ig/L to 0.0167 |ig/L (Pulliam et al., 2010).
As shown in Table 5-25, 71 percent of the facilities reported mercury concentrations within that
comparable treatability range.
5-22
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
Table 5-25. 2011 DMR Mercury Concentrations (mg/L)
Pollutant
Mercury
Maximum
GMF
Treatability
Concentration
(mg/L)
0.0000167
Minimum
Reported
2011 Average
Concentration
(mg/L)
0.0000019
Maximum
Reported
2011 Average
Concentration
(mg/L)
0.09
Median
Reported 2011
Average
Concentration
(mg/L)
0.0000077
Total Number
of Facilities
Discharging
Mercury
52
Count (Percent)
of Facilities over
Maximum GMF
Treatability
Concentration
(Percent)
15 (28.8%)
Sources: Pulliam et al., 2010 and DMRLTOutput2011_vl.
During EPA's 2013 Annual Review of the DWT industrial category, EPA identified at
least 137 facilities reporting discharges of copper, mercury, and lead; however, only three
facilities contribute a majority of the TWPE for these pollutants. Though EPA did not evaluate
any of the facility discharges of these pollutants in detail, similar to the findings for total residual
chlorine and aluminum, EPA expects that some of the TWPE may be a result of data entry errors
coupled with the large number of facilities reporting discharges.
During the 2013 Annual Review, EPA also reviewed the 2011 DWT Report to determine
if copper, mercury, and lead are present in the source water or treatment chemicals at drinking
water treatment plants. As shown in Table 8-2 in the 2011 DWT Report, all three pollutants are
listed as source water contaminants removed from drinking water, and are present in treatment
chemicals (U.S. EPA, 2011).
5.3.6 D WT Industrial Category Findings
The estimated toxicity of the DWT industrial category discharges resulted from total
residual chlorine and metals. From the 2013 Annual Review, EPA has identified the following:
• The DWT industrial category DMR TWPE doubled from 2009 to 2011; however,
the top pollutants (total residual chlorine and metals) stayed the same.
Additionally, the number of facilities reporting each of the top pollutants
increased from 2009 to 2011.
• EPA reviewed the top four dischargers of total residual chlorine and aluminum
(which contributed more than 50 percent of the TWPE for each of these
pollutants) and determined the following:
1. One facility, PRASA Vieja Ponce, had errors in their 2011 DMR flow and
total residual chlorine concentration values. EPA also determined that
PRASA Vieja Ponce is exceeding its permit limitations for total residual
chlorine. Therefore, facility-specific permitting action may be appropriate
to address total residual chlorine discharges from PRASA Vieja Ponce.
2. Additionally, EPA determined that the remaining three facilities each had
errors in their reported flows for the 2011 DMR data. EPA made
corrections to the flow and concentration data, which resulted in a
decrease of the DWT industrial category TWPE from 1,390,000 to
976,000 TWPE.
5-23
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
• Additionally, EPA compared 2011 DMR average facility concentrations of total
residual chlorine, aluminum, copper, and lead to monthly average permit
limitations summarized in Section 4.2 of the 2011 DWT Report. Because mercury
is not listed as a common regulated pollutant in Section 4.2 of the 2011 DWT
Report, as an initial point of comparison, EPA compared the 2011 DMR
concentrations to concentrations achieved by GMF (though not applied to
drinking water treatment wastewater). EPA determined that the majority of
concentrations reported for total residual chlorine, aluminum, mercury, and lead
were below the maximum monthly average permit limitations or within the GMF
mercury treatability range. However, EPA determined that the majority of copper
concentrations exceeded the maximum monthly average permit limitation
identified in the 2011 DWT Report.
• During the 2011 review of the category, EPA determined that discharges from
some drinking water treatment plants include certain pollutants because they are
present in the source water and from treatment chemicals. Source water and
treatment chemical pollutants include aluminum, copper, mercury, and lead (see
Table 8-2 in the 2011 DWT Report (U.S. EPA, 2011). Because of the different
source water contributions and treatment chemicals at each plant (among other
reasons), EPA determined that NPDES permits (general and individual) best
control discharges from these facilities during the 2011 review of the category.
• Therefore, EPA does not consider the remaining top metals (aluminum, copper,
lead, and mercury) as hazard priorities because the majority of the average facility
concentrations are below the monthly average pollutant concentrations presented
in the 2011 DWT Report. In addition, all of the pollutants were identified as
potential source water contributions or treatment chemicals. EPA does not
consider total residual chlorine discharges a hazard priority at this time because
over 90 percent of the 2011 DMR average facility concentrations are below the
maximum monthly average permit limitation.
5.3.7 References for D WT Industrial Category
1. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for PSC 501 - Drinking Water Treatment. (March). EPA-HQ-OW-2014-
0170. DCN 07978.
2. Pulliam, Greg et al. (2010). A Coordinated Approach to Achieving NPDES Permit
Compliance for Mercury and Selenium in a Refinery Effluent. Paper presented at
WEFTEC 2010, Water Environment Federation. New Orleans, LA. EPA-HQ-OW-2014-
0170. DCN 07973.
3. Ransom, Tim. 2013. Telephone communication with Tim Ransom, Sanford Spring Water
Treatment Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re: 2011 DMR
Discharges for Sanford Springs Water Treatment Plant. (December 13). EPA-HQ-OW-
2014-0170. DCN 07974.
5-24
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Section 5—EPA's 2013 Preliminary Category Reviews
5.J—Drinking Water Treatment (Potential New Category)
4. Rose, Chris. 2013. Telephone and email communication with Chris Rose, Dekalb
Jackson Water Treatment Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re:
2011 DMR Discharges for Dekalb Jackson Water Treatment Plant. (December 13). EPA-
HQ-OW-2014-0170. DCN 07975.
5. U. S. EPA. 2011. Drinking Water Treatment Plant Residuals Management Technical
Report: Summary of Residuals Generation, Treatment, and Disposal at Large Community
Wastewater Systems (EPA 820-R-l 1-003). Washington, D.C. (December). EPA-HQ-
OW-2014-0170. DCN 07976.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
5.4 Inorganic Chemicals Manufacturing (40 CFR Part 415)
EPA selected the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Category
for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalents (TWPE), in the point source category rankings. EPA also reviewed discharges from
the Inorganic Chemicals Category in each of its Annual Reviews from 2004 through 2011,
(except for 2008) (U.S. EPA, 2004a, 2005, 2006, 2007, 2009, 2011, 2012). This section
summarizes the results of the 2013 Annual Review pertaining to the Inorganic Chemicals
Category. EPA focused on discharges of dioxin and dioxin-like compounds, manganese and
manganese compounds, and polychlorinated biphenyls (PCBs) from the toxic release inventory
(TRI) because of their high TWPE relative to the rest of the pollutants discharged by the
Inorganic Chemicals Category. Dioxin and dioxin-like compounds and manganese and
manganese compounds, reviewed as part of the 2011 Annual Review, continue to be top
pollutants of concern. Discharge data available for the 2013 Annual Review also showed that
PCBs contribute significantly to the Inorganic Chemicals Category TWPE.
5.4.1 Inorganic Chemicals Category 2013 Toxicity Rankings Analysis
Table 5-26 compares the toxicity rankings analysis (TRA) results for the Inorganic
Chemicals Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in
2012, but instead reviewed additional data sources as part of the even-year annual review, as
discussed in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA,
2014). During the 2013 Annual Review, EPA did not identify any data corrections for the
Inorganic Chemicals Category.
Table 5-26. Inorganic Chemicals Category TRI and DMR Facility Counts and
Discharges for the 2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
Year of
Review
2011
2013
Inorganic Chemicals Category Facility
Counts
Total TRI
Facilities
153
153
Total DMR
Major
Facilities
45
62
Total DMR
Minor
Facilities"
84
96
Inorganic Chemicals Category TWPE
TRI TWPEb
60,900
327,000
DMR
TWPEC
51,300
142,000
Total TWPE
112,000
469,000
Sources: 2011 Annual Review Report (for 20091JDMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_vl
(for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2009 data after corrections made during the 2011 Annual Review.
As shown in Table 5-26, the TWPE for both TRI and DMR increased from 2009 to 2011.
During that period, the number of TRI facilities has remained constant; however, the number of
facilities in DMR has increased by 23 percent.
5-26
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
5.4.2 Inorganic Chemicals Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the Inorganic Chemicals Category focused
on 2011 TRI discharges because the 2011 TRI data dominate the category's combined TWPE.
Table 5-14 compares the five pollutants with the highest contribution to the 2011 TRI TWPE. In
addition, as a point of comparison, Table 5-14 shows the 2009 TRI TWPE for these top five
pollutants, based on the results of (and corrections identified in) the 2011 Annual Review (U.S.
EPA, 2012). During the 2013 Annual Review, EPA did not identify any data corrections for the
Inorganic Chemicals Category.
Dioxin and dioxin-like compounds, manganese and manganese compounds, and PCBs
account for approximately 92 percent of the total 2011 TRI TWPE in this industrial category.
Dioxin and dioxin-like compounds and manganese and manganese compounds have consistently
accounted for the majority of the Inorganic Chemicals Category TWPE in EPA's previous
Annual Reviews:
• Dioxin and dioxin-like compounds are the top TRI-reported pollutant in 2011 and
ranked second in 2009 for the Inorganic Chemicals Category (U.S. EPA, 2012).
Dioxin and dioxin-like compounds were also the top TRI-reported pollutant in
2002 (U.S. EPA, 2006).
• Manganese and manganese compounds ranked second among TRI-reported
pollutants in 2011 and ranked first in 2004, 2008, and 2009 for the Inorganic
Chemicals Category (U.S. EPA, 2011).
EPA's investigations of reported discharges of the top three pollutants are presented in
Sections 5.3.3 to 5.4.5. EPA investigated neither nitrate compounds, nor mercury and mercury
compounds in the 2013 Annual Review because they represent only approximately 8 percent of
the 2011 TRI TWPE for this category.
Table 5-27. Inorganic Chemicals Category Top TRI Pollutants
Pollutant
Dioxin and Dioxin-Like Compounds
Manganese and Manganese Compounds
Polychlorinated Biphenyls (PCBs)
Nitrate Compounds
Mercury and Mercury Compounds
Top Pollutant Total
Inorganic Chemicals Category Total
2011 TRI Data
Number of Facilities
Reporting Pollutant
6
21
2
49
13
NA
153C
TWPE
279,000
14,100
7,010
5,070b
4,250b
310,000
327,000
2009 TRI Data
TWPE
2,170
35,800
Oa
3,910
3,510
45,400
60,900
Sources: TRILTOutput2011_vl (for 2011 TPJ TWPE); 2011 Annual Review Report (for 2009 TRI TWPE) (U.S.
EPA, 2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a No facilities reported discharges of PCBs to TRI in 2009. Therefore, EPA did not review these discharges.
b Nitrate compounds and mercury and mercury compounds combined contribute 3 percent of the 2011 category TRI.
Therefore, EPA did not review nitrate compound or mercury and mercury compound discharges as part of the 2013
Annual Review.
0 Number of facilities reporting TWPE greater than zero.
5-27
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
5.4.3 Inorganic Chemicals Category Dioxin and Dioxin-Like Compound Discharges in TRI
EPA's investigation of the dioxin and dioxin-like compound discharges revealed that
Millennium Inorganic Chemicals, Inc., Plant I (Millennium Plant I), in Ashtabula, OH accounts
for 98 percent of the 2011 TRI dioxin and dioxin-like compound discharges (shown in Table
5-16). EPA did not investigate other facilities in this category discharging dioxin and dioxin-like
compounds.
Table 5-28. Top 2011 TRI Dioxin and Dioxin Like Compound Discharging Facilities
Facility Name
Millennium Inorganic Chemicals, Inc. Plant I
Facility
Location
Ashtabula, OH
Remaining Facilities Reporting Dioxin and Dioxin-Like
Compound Discharges3
Total
Pounds of
Pollutant
Discharged b
0.00245
0.00581
0.00826
Pollutant
TWPE
273,000
6,110
279,000
Facility Percent of
Category TWPE
98%
2%
100%
Source: TRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 5 remaining facilities that have dioxin and dioxin-like compound discharges in the 2011 TRI data.
b Dioxin TWPE values are calculated using a dioxin distribution submitted by the facility. Each dioxin congener
making up the dioxin distribution has a different TWF. As a result, though facilities may discharge a greater amount
of pounds of dioxin, the associated total pollutant TWPE may be less.
Millennium Plant I produces titanium dioxide using a chloride process (U.S. EPA, 2001).
During this process, the facility converts rutile or high-grade ilmenite ore into titanium
tetrachloride (TiCU) in a fluidized bed chlorinator. The resulting TiCU is piped to an oxidizer as
a vapor. In the oxidizer, purified TiCU vapor is converted to TiC>2, or titanium dioxide (U.S.
EPA, 2006). For further information on titanium dioxide manufacturing, see Section 9.6 in the
Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006).
EPA contacted the facility about their dioxin and dioxin-like compound discharges. The
facility contact stated that the formation of dioxin compounds occurs within an extremely narrow
temperature range immediately following the chlorination process (Schmude, 2014). The facility
measures the dioxin compounds based on quarterly sampling at the final effluent. The facility
contact stated that in 2011, the non-detect data were inadvertently reported using the minimum
detection limit. For other reporting years, the facility has reported non-detect data as zero
(Schmude, 2014). The facility provided the 2011 flow rate and the 2012 grams of dioxin
discharged. Table 5-29 presents Millennium Plant I's dioxin and dioxin-like compound
discharges for discharge years 2007-2012. As shown, the discharge quantity for 2011 is
significantly greater than other reporting years.
15 The TRI ID for Millennium Inorganic Chemicals, Inc. Plant I in Ashtabula, OH, is 44004SCMCH2900M. This
facility is not to be confused with the Millennium Inorganic Chemicals, Inc. Plant II, also in Ashtabula, OH, which
is discussed in Section 5.3.5.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 5-29. Millennium Plant I's Yearly Dioxin and Dioxin-like Compound TRI Discharges
Year of Discharge
2007
2008
2009
2010
2011
2012
Total Dioxin and Dioxin-like
Compounds Grams Discharged
0
0
0.03
0.16
1.09
0.14
Total Dioxin and Dioxin-like
Compounds TWPE
0
0
0.76
2,396
273,040
NA
Source: TRILTOutput2011_vl; Schmude, 2014.
NA: Not Applicable. The Facility contact provided the total grams of dioxin discharged for 2012 but did not provide
the dioxin congener distribution. Therefore, the dioxin TWPE for 2012 was not calculated.
Since Millennium Plant I reported its 2011 dioxin and dioxin-like compound discharges
in error and did not provide a corrected 2011 quantity, EPA used the 2011 flow provided by the
facility contact and the facility's TRI reported 2011 congener distribution to calculate its dioxin
and dioxin-like compound discharge concentrations. Table 5-30 presents Millennium Plant I's
calculated dioxin and dioxin-like compound discharges for 2011 and the EPA Method 1613B
minimum levels (MLs) (U.S. EPA, 2004b). As shown, all 2011 dioxin and dioxin-like compound
discharges are below EPA's Method 1613B MLs. EPA has limited confidence in dioxin
concentrations measured below the Method 1613B ML. Further, Millennium Plant I is one of the
few remaining U.S. facilities that manufactures titanium dioxide. Its dioxin and dioxin-like
compound discharges do not represent discharges across the category as a whole.
Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum Levels
Congener
TWF
1613B ML (pg/L)
Flow (MGY)b
Calculated 2011
Concentration (pg/L)a
868
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
43,819,553.68
7,632,640
557,312,000
5,760,000
14,109,440
51,204,160
47,308,800
85,760
3,033,984
2,020.96
10
50
50
50
50
50
50
50
50
100
4.8
23.8
24.0
24.2
24.4
24.3
24.0
26.1
24.3
6.8
Polychlorinated dibenzo p dioxins (CDDs)
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
703,584,000
692,928,000
23,498,240
10
50
50
4.9
23.8
24.0
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 5-30. 2011 Concentrations of Dioxin and Dioxin-Like Compounds in Effluent
Samples (pg/L) from Millennium Plant I and EPA Method 1613B Minimum Levels
Congener
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
TWF
9,556,480
10,595,840
411,136
6,585.6
1613B ML (pg/L)
50
50
50
100
Calculated 2011
Concentration (pg/L)a
24.1
24.4
24.5
6.5
Source: TRILTOutput2011_vl, U.S. EPA, 2004b.
ML: Minimum level established for EPA Method 1613B (U.S. EPA, 2004b).
a Concentrations calculated using the facility's reported congener distribution and flow in 2011.
b 2011 facility flow from facility contact (Schmude, 2014).
5.4.4 Inorganic Chemicals Category Manganese and Manganese Compound Discharges in
TRI
EPA's investigation of the manganese and manganese compound discharges revealed that
Millennium Inorganic Chemicals, Inc. Plant II (Millennium Plant II), in Ashtabula, OH16
accounts for 39 percent of the 2011 TRI manganese and manganese compound discharges
(shown in Table 5-31). EPA did not investigate the remaining facilities discharging manganese
and manganese compounds.
Table 5-31. Top 2011 Manganese and Manganese Compound Discharging Facilities
Facility Name
Millennium Inorganic Chemicals, Inc. Plant II
Facility
Location
Ashtabula, OH
Remaining Facilities Reporting Manganese and Manganese
Compound Discharges3
Total
Pounds of
Pollutant
Discharged
79,000
122,000
201,000
Pollutant
TWPE
5,530
8,540
14,100
Facility Percent
of Category
TWPE
39%
61%
100%
Source: TRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 20 remaining facilities that have manganese and manganese compound discharges in the 2011 TRI data.
Similar to Millennium Plant I, discussed in Section 5.3.3, Millennium Plant II produces
titanium dioxide using the chloride process (U.S. EPA, 2001). For further information on
titanium dioxide manufacturing, see Section 9.6 in the Technical Support Document for the 2006
Effluent Guidelines Program Plan (U.S. EPA, 2006).
Table 5-32 presents Millennium Plant II's manganese and manganese compound
discharges for discharge years 2007-2012. As shown, the discharge quantity for 2011 is higher
than other reporting years. EPA contacted the facility about their 2011 manganese and
manganese compound discharges. The facility contact confirmed the 2011 discharge quantity
16 The TRI ID for the Millennium Inorganic Chemicals, Inc. Plant II in Ashtabula, OH is 44004SCMCH2426M.
This facility is not to be confused with the Millennium Inorganic Chemicals, Inc. Plant I also located in Ashtabula,
OH, discussed in Section 5.4.3.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
and stated that the reported TRI discharge is based on direct sampling of the final effluent. The
facility contact also stated that the increase in the manganese and manganese compound
discharge in 2011 was due to a slight increase in flow. The increase in flow was said to result
from many factors, including process rate, process conditions, and volume of stormwater. The
facility contact also provided 2012 discharge quantity for comparison, and the discharges have
subsequently decreased in 2012 (Schmude, 2014).
Millennium Plant II is one of the few remaining U.S. facilities that manufacture titanium
dioxide. Its manganese and manganese compound discharges are not representative of facility
discharges across the category as a whole.
Table 5-32. Millennium Plant IPs Yearly Manganese and Manganese Compound
TRI Discharges
Year of Discharge
2007
2008
2009
2010
2011
2012
Total Manganese and Manganese
Compounds Pounds per Year Discharged
36,000
55,000
23,000
38,000
79,000
53,500
Total Manganese and Manganese
Compounds TWPE
2,520
3,850
1,610
2,660
5,530
3,740
Source: TRILTOutput2011_vl; Schmude, 2014.
5.4.5 Inorganic Chemicals Category Poly/chlorinated Biphenyl (PCB) Compound Discharges
in TRI
EPA's investigation of the PCB compound discharges revealed that DuPont Johnsonville
Plant (DuPont Johnsonville), in New Johnsonville, TN, accounts for 97 percent of the 2011 TRI
PCB compound discharges (shown in Table 5-33). EPA did not investigate DuPont Edgemoor in
Edgemoor, DE, which accounts for the remaining 2 percent of the discharges.
Table 5-33. Top 2011 PCB Discharging Facilities
Facility Name
DuPont Johnsonville Plant
DuPont Edgemoor
Facility Location
New Johnsonville, TN
Edgemoor, DE
Total
Pounds of
Pollutant
Discharged
0.2
0.00607
0.206
Pollutant
TWPE
6,810
207
7,010
Facility Percent of
Category TWPE
97%
3%
100%
Source: TRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
DuPont Johnsonville produces titanium dioxide using the chloride-ilmenite process (U.S.
EPA, 2001). The chloride-ilmenite process is similar to the chloride process discussed in Section
5.3.3. The primary difference between the two processes is that the chloride-ilmenite process
allows the use of lower-quality ore and easier oxidation than the chloride process (U.S. EPA,
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
2006). For further information on titanium dioxide manufacturing, see Section 9.6 in the
Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006).
EPA contacted DuPont Johnsonville about their PCB discharges. The facility contact
confirmed the discharges and stated that small amounts of fine solids in the wastewater discharge
(resulting from the chlorination process) are the source of the PCB compounds (Martin, 2013).
Table 5-34 presents the facility's PCB discharge quantity for years 2007-2011. As shown in
Table 5-34, the facility's PCB discharges have doubled from 2010 to 2011. Therefore, facility-
specific permitting action may be appropriate to address PCB discharges from the DuPont
Johnsonville facility.
Table 5-34. DuPont Johnsonville's Yearly PCB TRI Discharges
Year of Discharge
2007
2008
2009
2010
2011
Total PCB Pounds Discharged
0.1
0.1
0
0.1
0.2
Total PCB TWPE
3,400
3,400
0
3,400
6,810
Source: TRILTOutput2011_vl.
5.4.6 Inorganic Chemicals Category Findings
The estimated toxicity of the Inorganic Chemicals Category discharges resulted from TRI
dioxin and dioxin-like compounds, manganese and manganese compounds, and PCB discharges.
From the 2013 Annual Review, EPA has identified the following:
• One facility, Millennium Inorganic Chemicals, Inc. Plant I, contributes the
majority of the category's 2011 TRI dioxin and dioxin-like compound discharges.
EPA determined that the facility inadvertently reported 2011 dioxin and dioxin-
like compound discharges using the minimum detection limit, when historically
they have reported non-detect data as zero. In evaluating the data as reported, the
2011 concentrations for all congeners are below EPA's Method 1613B ML.
Therefore, further review of the facility's dioxin and dioxin-like compound
discharges is not warranted at this time.
• One facility, Millennium Inorganic Chemicals, Inc. Plant II, accounts for 39
percent of the category's 2011 TRI manganese and manganese compound
discharges. EPA determined that the 2011 manganese and manganese compound
TRI discharge for the facility is an anomaly due to an increase in flow at the
facility during 2011. This determination is supported by a decrease in the
discharge in 2012. Therefore, further review of the facility's manganese and
manganese compound discharges is not warranted at this time.
• One facility, DuPont Johnsonville Plant, accounts for the majority of the
category's 2011 TRI PCB discharges. EPA determined that the facility's 2011
PCB discharges were accurate and increased from previous years. Therefore,
facility-specific permitting action may be appropriate to address PCB discharges
from this facility.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
• For the Inorganic Chemicals Category, EPA determined the data do not support
the need to review further the Inorganic Category as a whole.
5.4.7 References for Inorganic Chemicals Category
1. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 415 - Inorganic Chemicals. (March). EPA-HQ-
OW-2014-0170. DCN 07888.
2. Martin, Gregg. 2013. Telephone and Email Communication between Gregg Martin,
DuPont Johnsonville Plant, and Kimberly Bartell, Eastern Research Group, Inc. Re: 2011
TRIPCB Discharges. (January 8). EPA-HQ-OW-2014-0170. DCN 07886.
3. Schmude, Robert. 2014. Telephone and Email Communication between Robert Schmude,
Millennium Inorganic Chemicals, Inc., and Kimberly Bartell, Eastern Research Group,
Inc. Re: 2011 TRI Dioxin and Manganese Discharges. (January 8). EPA-HQ-OW-2014-
0170. DCN 07885.
4. U. S. EPA. 2001. Final Titanium Dioxide Listing Background Document for the Inorganic
Chemical Listing Determination. Washington, D.C. (October). EPA-HQ-OW-2004-0032-
2419. DCN 03331.
5. U.S. EPA. 2004a. Technical Support Document for the 2004Effluent Guidelines
Program Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-
0074-1346 through 1352.
6. U.S. EPA. 2004b. Method 1613B: Tetra- Through O eta-Chlorinated Dioxins andFurans
by Isotope Dilution HRGC/HRMS. Washington, D.C. (October). EPA-HQ-OW-2004-
0032-2653.
7. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0053.
8. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
9. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
10. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
11. U. S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN
07320.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.4—Inorganic Chemicals Manufacturing (40 CFR Part 415)
12. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
13. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
5-34
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
5.5 Iron and Steel Manufacturing (40 CFR Part 420)
EPA selected the Iron and Steel Manufacturing Category for preliminary review because
it ranks high, in terms of toxic-weighted pound equivalents (TWPE), in the point source category
rankings. EPA previously reviewed discharges from the Iron and Steel Manufacturing Category
as part of the 2011 Annual Review (U.S. EPA, 2012). This section summarizes the results of the
2013 Annual Review, which focused on discharges of fluoride, aluminum, cyanide, and total
residual chlorine, due to their high TWPE relative to the other pollutants in the Iron and Steel
Manufacturing Category. These four pollutants, reviewed as part of the 2011 Annual Review,
continue to be top pollutants of concern. For further background on the Iron and Steel
Manufacturing Category, including an industry profile, see The 2011 Annual Effluent Guidelines
Review Report (U.S. EPA, 2012).
5.5.1 Iron and Steel Manufacturing Category 2013 Toxicity Rankings Analysis
Table 5-35 compares the toxicity rankings analysis (TRA) results for the Iron and Steel
Manufacturing Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the
TRA in 2012, but instead reviewed additional data sources as part of the even-year annual
review, as discussed in the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
(U.S. EPA, 2014). As discussed below, EPA's review of the Iron and Steel Manufacturing
Category identified several data errors that affect the 2011 DMR data and TWPE. The bottom
row of Table 5-35 shows the corrected data resulting from this review.
Table 5-35. Iron and Steel Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
Iron and Steel Facility Counts
Total TRI
Facilities
227
222
Total DMR
Major
Facilities
73
76
Total DMR
Minor
Facilities"
49
45
Iron and Steel Category TWPE
TRI
TWPEb
96,200
82,900
82,900
DMR
TWPEC
108,000
1,220,000
214,000
Total
TWPE
205,000
1,300,000
297,000
Sources: 2011 Annual Review Report (for 20091JDMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_vl
(for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2009 data after corrections made during the 2011 Annual Review.
e 2011 data after corrections made during the 2013 Annual Review.
The DMR TWPE for the Iron and Steel industrial category increased from discharge year
2009 to 2011 by approximately 98 percent (after data corrections were made to the 2011 DMR
data). As shown in Table 5-35, there has not been a significant increase in the total number of
facilities reporting DMR data.
5-35
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
5.5.2 Iron and Steel Manufacturing Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the Iron and Steel Manufacturing Category
focused on the 2011 DMR discharges because the 2011 DMR data account for 94 percent of the
category's combined TWPE. Table 5-36 compares the five pollutants with the highest
contribution to the 2011 DMR TWPE. Table 5-36 also presents the 2011 DMR TWPE after EPA
corrected errors identified in this preliminary category review (discussed in the sections below).
In addition, as a point of comparison, Table 5-36 shows the 2009 DMR TWPE for these top five
pollutants based on the results of (and corrections identified in) the 2011 Annual Review (U.S.
EPA, 2012).
During EPA's review of the Iron and Steel Manufacturing Category, one facility (US
Steel Mon Valley Works, Edgar Thomson Plant, in Braddock, PA) was identified as responsible
for the majority of 2011 DMR TWPE in all top pollutant categories. The facility accounted for
99 percent of iron discharges, 97 percent of zinc discharges, and 98 percent of manganese
discharges. During EPA's 2007 Annual Review, EPA identified an error in the 2004 DMR flow
values. At that time, the facility contact indicated that the facility measures pollutant
concentrations in their stormwater prior to commingling with noncontact cooling water (U.S.
EPA, 2007), but the flow reported in the DMR was for the commingled stream. To reflect
loading estimates accurately in the 2004 DMR data, EPA developed and applied a flow
correction factor using the 2004 facility data to calculate the volume of stormwater in the total
outfall flow (Belack, 2007). For the 2007 Annual Review and subsequent annual reviews, EPA
used the corrected flow rate with the reported concentration to calculate the total mass load
discharged from the facility. During the 2013 Annual Review, EPA determined that this
correction should have been carried through for the 2011 DMR data. EPA subsequently made
this data correction, which decreased the total Iron and Steel Category 2011 DMR TWPE from
1,220,000 to 290,000, and removed iron, zinc, and manganese as top pollutants discharged from
this category.
Also during the course of EPA's review of the Iron and Steel Manufacturing Category,
one facility submitted data corrections to their DMRs (Republic Conduit Manufacturing in
Louisville, KY), which subsequently affected the top pollutants for this category. Prior to this
data correction, the facility was identified as responsible for more than 98 percent of DMR
hexavalent chromium discharges. However, the facility underwent an audit in the spring of 2013
and realized that their flow values had been submitted with the incorrect units on the facility's
2011 DMR (Gaylord, 2013). Incorporating this data correction further decreased the total Iron
and Steel Category 2011 DMR TWPE from 290,000 to 246,000 and removed hexavalent
chromium as a top pollutant.
After the data corrections discussed above were incorporated into the 2011 DMR data for
the Iron and Steel Manufacturing Category, the top five pollutants with the highest contribution
to the 2011 DMR TWPE, presented in Table 5-36, were fluoride, aluminum, cyanide, total
residual chlorine, and silver. These contribute more than 69 percent of the total 2011 DMR
TWPE for this category. EPA's investigations of reported discharges of the top four pollutants
are presented in Sections 5.5.3 to 5.5.6. EPA did not investigate the other top pollutants as part of
the 2013 Annual Review, including silver, because they account for 31 percent of the 2011 DMR
TWPE for the Iron and Steel Manufacturing Category. As shown in Table 5-36, EPA's
5-36
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
investigations of the top four pollutants identified additional data corrections, which further
affected the category's TWPE.
Table 5-36. Iron and Steel Manufacturing Category Top DMR Pollutants
Pollutant
Fluoride
Aluminum
Cyanide
Total Residual Chlorine
Silver
Top Pollutants, Total
Iron and Steel Manufacturing
Category, Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
17
18
26
29
4
NA
146C
Original TWPE
47,800
37,500
34,100
28,600
15,900
164,000
246,000d
Corrected
TWPE
34,200
18,400
34,100
28,600
15,900b
131,000
214,000
2009 DMR Data3
TWPE
11,500
9,660
27,400
9,810
1,400
59,800
108,000
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Silver discharges contribute 6 percent of the 2011 category TWPE. Therefore, EPA did not review silver
discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
d The Iron and Steel Category Total 2011 DMR TWPE value includes the corrections to the Edgar Thompson Plant
and Republic Conduit Manufacturing data, described above. These corrections decreased the TWPE from 1,220,000,
as presented in Table 5-35, to 246,000. EPA identified further corrections to the data, which are reflected in the
Corrected TWPE in this table.
5.5.3 Iron and Steel Manufacturing Category Fluoride Discharges in DMR
EPA's investigation of fluoride discharges in this category revealed that three facilities
account for approximately 73 percent of the 2011 DMR fluoride discharges from iron and steel
manufacturers (shown in Table 5-37). EPA did not investigate the remaining facilities
discharging fluoride as part of the 2013 Annual Review.
Table 5-37. Top 2011 DMR Fluoride Discharging Facilities
Facility Name
Arcelormittal Indiana Harbor LLC
USS Gaiy Works
Weirton Steel Corporation
Facility Location
East Chicago, IN
Gary, IN
Weirton, WV
Remaining Facilities Reporting Fluoride Discharges3
Total
Pounds of Pollutant
Discharged
500,000
339,000
331,000
422,000
1,590,000
Pollutant
TWPE
15,000
10,200
9,940
12,700
47,800
Facility Percent of
Category TWPE
31%
21%
21%
27%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are fourteen remaining facilities that have fluoride discharges in the 2011 DMR data.
5-37
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Fluoride is not a regulated pollutant in the Iron and Steel Manufacturing Category
effluent limitations guidelines and standards (ELGs). During previous annual reviews, EPA
researched treatment technologies that were capable of removing fluoride (not specific to iron
and steel wastewater discharges). From this review, EPA determined that current technologies
are achieving effluent fluoride concentrations between 2 mg/L and 15 mg/L (WC&E, 2006;
Ionics, n.d.; GCIP, 2002). EPA used these effluent fluoride concentrations as benchmarks for
initial comparison of fluoride discharges from iron and steel manufacturing facilities.
Arcelormittal Indiana Harbor LLC
Arcelormittal Indiana Harbor LLC (Arcelormittal) in East Chicago, IN, discharges
fluoride from outfalls 009, 010, and 011. In reviewing the facility's 2011 DMR fluoride
concentrations, EPA noted that the May 2011 fluoride concentration from Outfall 010 was 100
times higher than the other concentrations from that outfall, and from the other outfalls. As
shown in Table 5-17, EPA assumed that the reported concentration was in error and corrected the
concentration from this outfall. This correction decreased the facility's fluoride TWPE from
15,000 to 1,440, reducing the Iron and Steel Category's fluoride TWPE from 47,800 to 34,200,
as shown in Table 5-36. Further, all of the 2011 DMR fluoride concentrations for Arcelormittal
are below the comparable treatability levels achievable by current technologies.
Table 5-38. Arcelormittal's 2011 DMR Original and Corrected Fluoride Discharges
Outfall
009
009
009
010
010
010
Oil
Oil
Oil
Monitoring
Period Date
31-Mar-2011
31-May-2011
30-Sep-2011
31-Mar-2011
31-May-2011
30-Sep-2011
31-Mar-2011
31-May-2011
30-Sep-2011
Original Average Flow
(MGD)
34.1
34.1
34.1
45.1
44.9
44.9
18.6
32.8
35.7
Original Average Fluoride
Concentration (mg/L)
0.4
0.36
0.28
0.46
36
0.29
1.6
0.82
0.84
Corrected
Concentration (mg/L)
0.4
0.36
0.28
0.46
0.36
0.29
1.6
0.82
0.84
Source: DMRLTOutput2011_vl.
USS Gary Works
USS Gary Works in Gary, IN, discharges fluoride from outfalls 005, 028 and 030 to the
Grand Calumet River (IDNR, 2007). Outfall 005 discharges cooling water and condensate from
many operations, along with stormwater runoff (IDNR, 2007). Outfalls 028 and 030 are
discharges from lagoons containing continuous caster non-contact cooling water, cooling tower
blowdown, stormwater runoff, steam condensate, plate mill scale pit, slab spray cooling water,
and vacuum degasser overflow. The facility's permit calls for monitoring of fluoride discharges
from outfalls 005, 028, and 030, but does not include fluoride limits (IDNR, 2007).
Table 5-39 presents the facility's fluoride discharge data for 2011. EPA calculated the
fluoride concentrations using the quantity and average monthly flows. The fluoride
concentrations range from 0.417 mg/L to 3.77 mg/L. For its initial comparison of the discharges,
5-38
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
EPA determined that fluoride concentrations for USS Gary Works are generally below those
achievable by current technologies described above.
Table 5-39. USS Gary Works' 2011 Monthly Fluoride Discharge and Flow Data
Outfall
005
005
005
005
005
005
005
005
005
005
005
005
028
028
028
028
028
028
028
028
028
028
028
028
030
030
030
030
030
030
030
030
030
030
030
030
Monitoring
Period Date
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-M-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
Dec-31-2011
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-Jul-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-M-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Average Flow (MGD)
51.1
49.7
46.9
51.6
43.5
46.3
48.3
54.3
47.7
45.9
42.1
46.3
7.2
6.7
7.6
7
6.7
6.48
5.4
5.8
5.6
7.5
6.7
9.5
19.4
21.3
22.8
22.2
21.1
19.5
17.5
19.6
19.0
21.5
21.4
20.7
Fluoride Quantity
(kg/day)
82.1
113
82.5
100
82.5
92.9
94.3
85.7
78.4
82.9
83.4
90.7
79.3
74.0
84.3
79.8
80.2
72.6
77.1
74.8
69.8
97.5
73.9
126
210
268
240
237
240
228
244
253
266
285
254
279
Calculated Fluoride
Concentrations (mg/L)
0.424
0.601
0.465
0.512
0.501
0.531
0.516
0.417
0.434
0.477
0.523
0.518
2.91
2.92
2.93
3.01
3.16
2.96
3.77
3.41
3.29
3.43
2.91
3.50
2.86
3.32
2.79
2.83
3.01
3.09
3.69
3.41
3.70
3.50
3.13
3.57
Source: DMRLTOutput2011_vl.
5-39
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Weirton Steel Corporation
Weirton Steel Corporation in Weirton, WV, discharges fluoride from outfalls 003 and
004 into the Ohio River and Harmon Creek, respectively (WVDEP, 2008a). The facility
discharges cooling water, stormwater runoff, and process water from both outfalls. The facility's
permit calls for monitoring of fluoride discharges from outfall 003, but does not include fluoride
limits (WVDEP, 2008a). The fluoride permit limit for outfall 004 is 1.4 mg/L on an average
monthly basis and 2.2 mg/L daily maximum (WVDEP, 2008a).
Table 5-40 presents the facility's fluoride discharge data for 2011. As described above,
EPA determined that current wastewater technologies (not specific to iron and steel) are
achieving effluent fluoride concentrations between 2 mg/L and 15 mg/L. For its initial
comparison, EPA determined that 2011 fluoride concentrations from outfall 004 are below the
facility's permit limit and below those achievable by current technologies, as shown in Table
5-40. However, the fluoride concentrations from outfall 003 are significantly higher than outfall
004, by an order of magnitude. Additionally, the September 2011 concentration exceeds the
concentration range that can be achieved by current treatment technologies, described above.
Therefore, facility-specific permitting action may be appropriate to address fluoride discharges
from the Weirton Steel Corporation facility.
Table 5-40. Weirton Steel Corporation's 2011 Monthly Fluoride Discharge and Flow Data
Outfall
003
003
003
003
004
004
004
004
004
004
004
004
004
004
004
004
Monitoring Period
Date
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Jan-2011
28-Feb-2011
31-Mar-2011
30-Apr-2011
31-May-2011
30-Jun-2011
31-Jul-2011
31-Aug-2011
30-Sep-2011
31-Oct-2011
30-Nov-2011
31-Dec-2011
Average Flow
(MGD)
7.86
11.0
10.8
6.50
2.49
2.38
3.14
3.37
3.39
2.47
1.23
1.04
0.790
0.580
1.30
1.14
Fluoride
Concentration
(mg/L)
8.00
8.32
22.0
5.82
0.190
0.260
0.230
0.320
0.240
0.507
0.730
0.430
0.480
0.530
0.360
0.370
Facility Permit Limits
Monthly Average
(mg/L)
Monitoring Only
Monitoring Only
Monitoring Only
Monitoring Only
1.4
1.4
1.4
1.4
1.4
1.4
1.4
1.4
1.4
1.4
1.4
1.4
Daily Maximum
(mg/L)
Monitoring Only
Monitoring Only
Monitoring Only
Monitoring Only
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
Source: DMRLTOutput2011_vl.
5.5.4 Iron and Steel Manufacturing Category Aluminum Discharges in DMR
EPA's investigation of aluminum discharges revealed that one facility, Nucor Steel
Decatur LLC (Nucor Steel) in Trinity, AL, accounts for 76 percent of the 2011 DMR aluminum
5-40
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
discharges (shown in Table 5-41). EPA did not investigate the remaining facilities discharging
aluminum as part of the 2013 Annual Review.
Table 5-41. Top 2011 DMR Aluminum Discharging Facilities
Facility Name
Nucor Steel Decatur LLC
Facility Location
Trinity, AL
Remaining Facilities Reporting Aluminum Discharges3
Total
Pounds of Pollutant
Discharged
477,000
148,000
625,000
Pollutant
TWPE
28,600
8,890
37,500
Facility Percent of
Category TWPE
76%
24%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 17 remaining facilities that have aluminum discharges in the 2011 DMR data.
Nucor Steel discharges aluminum through ten outfalls. Outfall 002 discharges stormwater
runoff from the scrap yard, north and south scrap bays, and slag yards associated with the
manufacture of hot rolled steel and non-contact blowdown. Outfalls 003, 012, and 013 discharge
stormwater runoff associated with the manufacture of hot rolled steel. Outfalls 004, 006, 008,
and 010 discharge stormwater associated with transportation equipment parking and storage.
Outfalls 007 and Oil discharge stormwater runoff, non-contact cooling water blowdown, reverse
osmosis concentrate, softener backwash, and carbon filter backwash (Bullard, 2014). The facility
permit calls for monitoring on a quarterly or semi-annual basis for aluminum discharges for all
outfalls listed above (ADEM, 2008), but does not have aluminum limits.
Table 5-42 presents Nucor's original aluminum discharge data for 2011. As part of the
2013 Annual Review, EPA contacted Nucor Steel to confirm the aluminum discharges. The
facility contact confirmed the 2011 discharges and stated that the December 2011 aluminum
concentration reading for outfall Oil of 775 mg/L was taken immediately following a major
precipitation event. Therefore, it did not represent typical daily discharges during the 92 day
monitoring period. The facility performed additional sampling on January 26, 2012, and
provided EPA a revised value of 0.463 mg/L for aluminum at outfall Oil (Bullard, 2014). EPA
recalculated the facility aluminum discharge using the revised value for outfall Oil. This resulted
in a reduction of the facility's 2011 DMR aluminum TWPE from 28,600 to 9,530, reducing the
Iron and Steel Category's aluminum TWPE from 37,500 to 18,400.
Aluminum is not a regulated pollutant in the Iron and Steel Manufacturing Category
ELG. However, during the 2002 rulemaking EPA evaluated the treatment of aluminum in
wastewater from steelmaking. At that time, EPA evaluated two-stage metals precipitation, which
achieved a long-term average concentration (LTA) of aluminum of 0.229 mg/L (U.S. EPA, 2002,
Appendix D). The facility's discharge concentrations, presented in Table 5-42, are all higher than
this achievable level. Therefore, facility-specific permitting action may be appropriate to address
this facility's aluminum discharges.
5-41
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Table 5-42. Nucor Steel's 2011 Monthly Aluminum Concentration and Flow Data
Outfall
002
002
002
002
003
003
004
004
004
004
006
006
006
006
007
007
007
007
008
008
008
008
010
010
010
010
Oil
Oil
Oil
Oil
012
012
013
013
Monitoring Period Date
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
30-Jun-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
30-Jun-2011
31-Dec-2011
30-Jun-2011
31-Dec-2011
Average Flow (MGD)
1.33
6.61
8.35
1.27
0.810
0.780
0.057
0.120
0.150
0.060
0.075
0.180
0.230
0.091
0.026
0.052
0.066
0.025
0.028
0.056
0.071
0.027
0.015
0.030
0.039
0.015
0.260
0.670
0.840
0.530
0.260
0.840
1.44
4.57
Aluminum Concentration
(mg/L)
1.59
4.99
5.65
0.804
0.22
28.4
14.3
24.3
12.4
21.5
23.1
0
7.68
10.4
0.690
1.49
2.47
0.810
5.16
3.68
11.7
9.78
14.8
12.2
4.06
4.27
1.33
3.58
3.14
775a
1.28
4.02
5.69
3.89
Source: DMRLTOutput2011_vl; Bullard, 2014.
a The facility contact stated that the December 2011 concentration reading for outfall Oil was taken immediately
following a major precipitation event. The facility performed additional sampling on January 26, 2012, and provided
a revised value of 0.463 mg/L.
5-42
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
5.5.5 Iron and Steel Manufacturing Category Cyanide Discharges in DMR
EPA's investigation of the cyanide discharges revealed that two facilities, USS Clairton
Plant in Clairton, PA (USS Clairton Plant), and Mountain State Carbon Follansbee Plant in
Follansbee, WV, account for 60 percent of the 2011 DMR cyanide discharges (shown in Table
5-43). EPA did not investigate the remaining facilities discharging cyanide as part of the 2013
Annual Review.
Table 5-43. Top 2011 DMR Cyanide Discharging Facilities
Facility Name
USS Clairton Plant
Mountain State Carbon Follansbee Plant
Facility Location
Clairton, PA
Follansbee, WV
Remaining Facilities Reporting Cyanide Discharges3
Total
Pounds of
Pollutant
Discharged
12,100
6,340
12,300
30,700
Pollutant
TWPE
13,500
7,040
13,600
34,100
Facility Percent of
Category TWPE
39%
21%
40%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are twenty-four remaining facilities that have cyanide discharges in the 2011 DMR data.
Both of the top two facilities are cokemaking plants, i.e., they produce carbon-coke from
coal for use in steelmaking. Cokemaking operations generate wastewater containing cyanide as
part of the byproduct recovery process. For further information on cokemaking plants in the
U.S., see section 9.4 of the 2011 Annual Review Report (U.S. EPA, 2012).
During the 2002 Iron and Steel rulemaking, EPA established production-based limits for
cyanide as best available technology (BAT) for the cokemaking subcategory (40 CFR Part 420
Subpart A). The BAT production-based limits are based on an LTA of 2.965 mg/L, and a
variability factor of 1.49 (U.S. EPA, 2002, Appendices D and E).
USS Clairton Plant
USS Clairton Plant discharges cyanide in cokemaking wastewater from outfall 183. This
facility's cyanide discharges were also reviewed as part of the 2011 Annual Review (U.S. EPA,
2012). Table 5-44 presents U.S. Steel's 2011 monthly cyanide and flow discharge data for outfall
183. The cyanide permit limits for outfall 183 are 5.5 mg/L or 118 pounds per day (Ibs/day)
average monthly and 10 mg/L or 216 Ibs/day daily maximum. The facility's cyanide permit
limits became effective in February 2002 and were extended to cover 2011 discharges (PA DEP,
2006).
As shown in Table 5-44, the facility's discharge concentrations do not exceed permit
limits and are below the LTA for cyanide calculated during the 2002 rulemaking. The facility's
high cyanide TWPE is likely the result of the large amount of industrial activity at the site. This
facility has historically been the top coke producer in the U.S. (U.S. EPA, 2002).
5-43
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Table 5-44. USS Clairton Plant Outfall 183 2011 Monthly Cyanide and
Flow Discharge Data
Monitoring
Period Date
31-Jan-ll
28-Feb-ll
31 -Mar- 11
30-Apr-ll
31-May-ll
30-Jun-ll
31-Jul-ll
31-Aug-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31-Dec-ll
Average Cyanide
Discharge
(kg/day)
9.36
11.1
12.2
13.6
16.3
13.7
12.3
11.7
8.94
23.8
24.1
23.1
Average Flow
(MGD)
2.21
2.47
2.48
2.6
2.46
2.31
2.43
2.38
2.26
2.31
2.47
2.57
Average Cyanide
Concentrations
(mg/L)
1.12
1.19
1.30
1.38
1.75
1.57
1.34
1.30
1.05
2.72
2.58
2.37
Facility Permit Limits
Monthly
Average (mg/L)
5.5
5.5
5.5
5.5
5.5
5.5
5.5
5.5
5.5
5.5
5.5
5.5
Daily Maximum
(mg/L)
10
10
10
10
10
10
10
10
10
10
10
10
Source: DMRLTOutput2011_vl; PADEP, 2006.
Mountain State Carbon Follansbee Plant
Mountain State Carbon discharges cyanide from outfalls 005 and 205. Mountain State
Carbon discharges sanitary water, cooling water, and process water from outfall 005, and treated
process wastewater, ground water, and stormwater from the biological treatment plant through
outfall 205.
This facility's cyanide discharges were also reviewed as part of the 2011 Annual Review
(U.S. EPA, 2012). Table 5-45 presents Mountain State Carbon's 2011 DMR monthly cyanide
and flow discharge data for outfalls 005 and 205. The facility's cyanide permit limits for outfall
005 are 0.0114 mg/L monthly average and 0.0284 mg/L daily maximum. These permit
limitations are well below the cyanide LTA calculated during the 2002 rulemaking (2.965 mg/L).
The facility's cyanide permit limits for outfall 205 are 24.5 Ib/day (11.1 kg/day) monthly average
and 34.9 Ibs/day (15.8 kg/day) daily maximum (WVDEP, 2008b). As shown in Table 5-45, from
February through June 2011, and again in December 2011, discharges of cyanide from outfall
005 exceed the facility's permit limits. However, these concentrations are not above the cyanide
LTA calculated during the 2002 rulemaking. Additionally, the January 2011 and November 2011
quantity from outfall 205 exceed the mass-based facility permit limit. Therefore, facility-specific
permitting or compliance action may be appropriate to address cyanide discharges from
Mountain State Carbon.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Table 5-45. Mountain State Carbon's 2011 Monthly Cyanide and Flow Discharge Data
Outfall
005
005
005
005
005
005
005
005
005
005
005
005
205
205
205
205
205
205
205
205
205
205
205
205
Monitoring
Period Date
31 -Jan- 11
28-Feb-ll
31 -Mar- 11
30-Apr-ll
31-May-ll
30-Jun-ll
31-Jul-ll
31-Aug-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31 -Dec- 11
31 -Jan- 11
28-Feb-ll
31-Mar-ll
30-Apr-ll
31-May-ll
30-Jun-ll
31-Jul-ll
31-Aug-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31-Dec-ll
Average
Cyanide
Discharge
(kg/day)
0.293
0.293
0.423
0.383
0.646
0.830
0.256
0.505
0.378
0.509
0.398
2.70
12.2a
4.17
10.4
3.58
7.88
3.40
9.07
6.62
6.25
4.98
12.2a
5.44
Average
Flow
(MGD)
8.70
6.45
6.58
8.44
12.2
13.7
14.1
14.2
14.7
13.3
13.8
10.5
0.82
0.87
0.84
0.72
0.71
0.71
0.69
0.74
0.76
0.69
0.73
0.69
Average
Cyanide
Concentration
(mg/L)
0.009
0.0123
0.0173
0.0123
0.0143
0.0163
0.005
0.009
0.007
0.010
0.008
0.068b
3.93
1.27
3.27
1.31
2.93
1.27
3.47
2.36
2.17
1.91
4.42
2.08
Facility Permit Limits
Monthly
Average
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
0.0114
11.1
11.1
11.1
11.1
11.1
11.1
11.1
11.1
11.1
11.1
11.1
11.1
Daily
Maximum
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
0.0284
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
Facility
Permit Limit
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
kg/day
Source: DMRLTOutput2011_vl; WVDEP, 2008b.
a Cyanide concentration or quantity exceeds monthly average permit limitation.
b Cyanide concentration or quantity exceeds both monthly average and daily maximum permit limitations.
5.5.6 Iron and Steel Manufacturing Category Total Residual Chlorine Discharges in DMR
EPA's investigation of total residual chlorine discharges revealed that one facility, USS
Clairton Plant in Clairton, PA, accounts for 49 percent of the 2011 DMR total residual chlorine
discharges (shown in Table 5-46). EPA did not investigate the remaining facilities discharging
chlorine as part of the 2013 Annual Review.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Table 5-46. Top 2011 Total Residual Chlorine Discharging Facilities
Facility Name
USSClairton Plant
Location
Clairton, PA
Remaining Facilities Reporting Total Residual Chlorine
Discharges3
Total
Total Residual
Chlorine
Pounds
Discharged
28,000
29,200
57,200
Total
Residual
Chlorine
TWPE
14,000
14,600
28,600
Facility Percent of
Total Residual
Chlorine Category
TWPE
49%
51%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are twenty-eight remaining facilities that have total residual chlorine discharges in the 2011 DMR data.
The USS Clairton Plant is the top cokemaking facility in the U.S. and discharges total
residual chlorine in cokemaking wastewater from outfall 038. Table 5-47 presents USS
Clairton's 2011 DMR monthly total residual chlorine and flow discharge for outfall 038. The
chlorine permit limit for outfall 038 is 0.5 mg/L monthly average (PA DEP, 2006). As shown in
Table 5-47, the facility's discharges do not exceed permit limits. Similar to the facility's cyanide
discharges, discussed above, the high chlorine discharges are the result of the large amount of
industrial activity at the facility.
Table 5-47. USS Clairton Plant's 2011 Monthly Total Residual Chlorine and
Flow Discharge Data for Outfall 038
Monitoring
Period Date
31-Jan-ll
28-Feb-ll
31-Mar-ll
30-Apr-ll
31 -May- 11
30-Jun-ll
31-Jul-ll
31-Aug-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31-Dec-ll
Average Flow (MGD)
36.8
41.8
39.0
41.7
62.0
70.4
63.2
66.2
71.5
61.1
50.7
42.9
Average Total Residual
Chlorine Concentrations (mg/L)
0.11
0.11
0.05
0.08
0.05
0.18
0.47
0.12
0.09
0.04
0.45
0.26
Monthly Average
Permit Limit (mg/L)
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Source: DMRLTOutput2011_vl.
5.5.7 Iron and Steel Manufacturing Category Findings
The estimated toxicity of the Iron and Steel Manufacturing Category discharges results
from fluoride, aluminum, cyanide, and total residual chlorine discharges. From the 2013 Annual
Review, EPA has identified the following:
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
Three facilities, Arcelormittal Indiana Harbor LLC, USS Gary Works and
Weirton Steel Corporation, account for 73 percent of the category's fluoride 2011
DMR discharges. EPA determined the following:
— Arcelormittal Indiana Harbor LLC had an error in their 2011 DMR
fluoride discharges. This correction decreased the facility's fluoride
TWPE from 15,000 to 1,320, reducing the Iron and Steel Category's
fluoride TWPE from 47,800 to 34,200. Fluoride discharges from outfalls
009, 010, and Oil are below comparable concentrations achieved by
current treatment technologies (not specific to iron and steel
manufacturing).
— The USS Gary Works 2011 DMR fluoride discharge data also do not
exceed comparable concentrations achieved by current treatment
technologies.
— Weirton Steel Corporation's permit calls for fluoride monitoring of two
outfalls discharging fluoride; one outfall also has numeric limits. EPA
found that discharge from the latter outfall, which has monitoring
requirements only, may exceed the comparable concentration ranges
achieved by current treatment technologies. Therefore, facility-specific
permitting action may be appropriate to address fluoride discharges from
the Weirton Steel Corporation facility.
One facility, Nucor Steel Decatur LLC, contributes the majority of the aluminum
discharges for the Iron and Steel Manufacturing Category. The facility confirmed
the 2011 discharges, but noted that the reading from outfall 011 in December did
not accurately represent the average discharge from the facility. Based on data re-
submitted by Nucor Steel Decatur, EPA recalculated the 2011 aluminum loadings.
This resulted in a reduction of the facility's 2011 DMR aluminum TWPE from
28,600 to 9,530, reducing the Iron and Steel Category's aluminum TWPE from
37,500 to 18,400.
Two facilities, USS Clairton Plant and Mountain State Carbon, LLC, contribute
the majority of the cyanide discharges for the Iron and Steel Manufacturing
Category. EPA reviewed cyanide discharges and found:
— The USS Clairton Plant 2011 DMR cyanide discharge data do not exceed
permit limits and are below the cyanide LTA calculated during the 2002
rulemaking. The facility's high cyanide TWPE is likely the result of the
large amount of industrial activity at the facility, as they historically have
been the top coke producer in the U.S.
— Several months of cyanide discharges from two different outfalls at
Mountain State Carbon exceed the facility's mass-based permit limit;
therefore facility-specific permitting action may be appropriate to address
cyanide discharges from this facility.
One facility, USS Clairton Plant, is responsible for the majority of the total
residual chlorine discharges. The facility's discharge data do not exceed permit
limits. Similar to cyanide discharges for USS Clairton Plant, the high chlorine
547
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
discharges are likely the result of the large flows from the facility; it is the top
cokemaking facility in the U.S.
• Correcting the database errors identified during the 2013 Annual Review
decreases the 2011 Iron and Steel Category TWPE from 1,220,000 to 214,000
TWPE. In addition, EPA identified several facilities for facility-specific
permitting action.
5.5.8 References for Iron and Steel Manufacturing Category
1. ADEM. 2008. Alabama Department of Environmental Management. Draft NPDES
Permit: Nucor Steel Decatur LLC, Trinity, AL. (February 1). EPA-HQ-OW-2014-0170.
DCN 07893.
2. Belack, Dan. 2007. Notes from E-mail Communication Between Dan Belack, US Steel,
and Jan Matuszko, U.S. EPA. Re: DMR Clarification Needed for U.S. Steel. (May 7).
EPA-HQ-OW-2006-0771-0480.
3. Bullard, Carey. 2014. Notes from Telephone and E-mail Communication Between Carey
Bullard, Nucor Steel LLC, and Julia Kolberg, Eastern Research Group, Inc. Re: DMR
Clarification Needed for Nucor Steel LLC. (January 23). EPA-HQ-OW-2014-0170. DCN
07889.
4. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 420 - Iron and Steel. (March). EPA-HQ-OW-
2014-0170. DCN 07902.
5. Gaylord, Bruce. 2013. Notes from E-mail Communication Between Bruce Gaylord,
Republic Conduit, and Carey Johnston, U.S. EPA. Re: DMR Clarification Needed for
Republic Conduit. (May 23). EPA-HQ-OW-2014-0170. DCN 07892.
6. GCIP. 2002. General Chemical Industrial Products. Chapter 14 - Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. EPA-
HQ-OW-2004-0032-2606.
7. IDNR. 2007. Indiana Department of Natural Resources. NPDES Permit Fact Sheet: USS
Gary Works, Gary, IN. (August 1). EPA-HQ-OW-2014-0170. DCN 07890.
8. Ionics, n.d. "The EnChem® Process for Fluoride Removal." Wastewater Treatment for
the Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf. EPA-HQ-OW-2004-0032-2605.
9. PA DEP. 2006. Commonwealth of Pennsylvania Department of Environmental
Protection, Water Management Program. NPDES Permit: U.S. Steel Corporation-
Clairton Works, Clairton, PA. (December 27). EPA-HQ-OW-2010-0824. DCN 07598.
10. U. S. EPA. 2002. Development Document for Final Effluent Limitations Guidelines and
Standards for the Iron and Steel Manufacturing Point Source Category. Washington, DC.
EPA-821-R-02-004. EPA-HQ-OW-2010-0824. DCN 07720.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.5—Iron and Steel Manufacturing (40 CFR Part 420)
11. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
12. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
13. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-1070. DCN
07756.
14. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment
(FWT) FTP Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm.EPA-HQ-OW-2004-0032-2604.
15. WVDEP. 2008a. West Virginia Department of Environmental Protection. NPDES
Permit: Arcelormittal Weirton Inc. (Weirton Steel Corporation), Weirton, WV. (July 28).
EPA-HQ-OW-2014-0170. DCN 07891.
16. WVDEP. 2008b. West Virginia Department of Environmental Protection. NPDES
Permit: Mountain State Carbon, Follansbee, WV. (January 15). EPA-HQ-OW-2010-
0824. DCN 07601.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
5.6 Metal Finishing (40 CFR Part 433)
During the 2012 Annual Review, EPA's review of the Targeted National Sewage Sludge
Survey (TNSSS), combined with available indirect discharge data from the toxics release
inventory (TRI), identified the Metal Finishing Category (40 CFR Part 433) as potentially
discharging high concentrations of metals, particularly chromium, nickel, and zinc, to publicly
owned treatment works (POTWs). These metals could transfer to sewage sludge and diminish its
beneficial use. Further, the Metal Finishing Category ranked high, in terms of toxic-weighted
pound equivalents (TWPE), in the 2013 toxicity rankings analysis (TRA). As a result, EPA is
continuing a preliminary category review of this category to evaluate further the need to revise
the existing effluent limitations guidelines and standards (ELGs).
5.6.1 Summary of Metal Finishing ELGs
In 1979, EPA promulgated pretreatment standards for existing sources (PSES) for the
Electroplating Category (40 CFR Part 413). These standards covered only existing indirect
dischargers. Subsequently, EPA built upon the 1979 electroplating regulations and promulgated
ELGs for the Metal Finishing Category (40 CFR Part 433) on September 15, 1983 (48 FR
41409).
The Metal Finishing ELGs consist of one subcategory (Subpart A, "Metal Finishing
Sub category"), with limitations that apply to wastewater discharges from six metal finishing
operations. The applicability is not defined by industry sector, but by the six core electroplating
operations originally identified in Part 413, and 40 additional process operations (Table 5-48). In
addition to best practicable control technology (BPT), best available technology economically
achievable (BAT), and new source performance standards (NSPS), Part 433 includes PSES and
pretreatment standards for new sources (PSNS) limitations. Table 5-49 lists the metal finishing
(40 CFR Part 433) applicability, regulated pollutants, and limitations. Part 433 supersedes most
of Part 413, with the exception of discharges from independent job shops and printed circuit
board manufacturers. Another Categorical Pretreatment Standard may cover wastewater
discharges from metal finishing operations, in which case, the specific standard will apply. The
following regulations take precedence over Part 433:
• Nonferrous Smelting and Refining (40 CFR Part 421);
• Coil Coating (40 CFR Part 465);
• Porcelain Enameling (40 CFR Part 466);
• Battery Manufacturing (40 CFR Part 461);
• Iron and Steel Manufacturing (40 CFR Part 420);
• Metal Casting Foundries (40 CFR Part 464);
• Aluminum Forming (40 CFR Part 467);
• Copper Forming (40 CFR Part 468);
• Plastic Molding and Forming (40 CFR Part 463);
• Electrical and Electronic Components (40 CFR Part 469); and
• Nonferrous Forming (40 CFR Part 471).
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
Table 5-48. Unit Operations Regulated by ELGs for the Metal Finishing Category
Six Core Electroplating Operations
(Introduced in Part 413)
• Electroplating
• Electroless Plating
• Anodizing
• Coating
• Etching And Chemical Milling
• Printed Circuit Board Manufacturing
40 Additional Metal Processing Operations
(Introduced in Part 433)
• Cleaning
• Machining
• Grinding
• Polishing
• Barrel Finishing
• Burnishing
• Impact Deformation
• Pressure Deformation
• Shearing
• Heat Treating
• Thermal Cutting
• Welding
• Brazing
• Soldering
• Flame Spraying
• Sand Blasting
• Abrasive Jet Machining
• Electrical Discharge Machining
• Electrochemical Machining
• Electron Beam Machining
• Laser Beam Machining
• Plasma Arc Machining
• Ultrasonic Machining
• Sintering
• Laminating
• Hot Dip Coating
• Sputtering
• Vapor Plating
• Thermal Infusion
• Salt Bath Descaling
• Solvent Degreasing
• Paint Stripping
• Painting
• Electrostatic Painting
• Electropainting
• Vacuum Metalizing
• Assembly
• Calibration
• Testing
• Mechanical Plating
Table 5-49. Applicability, Regulated Pollutants, and ELG Limits for the
Metal Finishing Category
Subpart
Subpart A -
Metal
Finishing
Subcategory
Applicability
The provisions of this subpart apply to
discharges from the following six metal
finishing operations on any basis material:
Electroplating, Electroless Plating,
Anodizing, Coating (chromating,
phosphating, and coloring), Chemical
Etching and Milling, and Printed Circuit
Board Manufacture.3
For industrial facilities with cyanide
treatment, and upon agreement between a
source subject to those limits and the
pollution control authority, the following
amenable cyanide limit may apply in
place of the total cyanide limit.
Pollutant
Silver
Copper
Lead
Cyanide
Cadmium
Chromium
Nickel
Zinc
Cyanide
amenable to
alkaline
chlorination
BAT/PSES
Daily Max
(Monthly
Average) (mg/L)
0.43 (0.24)
3.38 (2.07)
0.69 (0.43)
1.20 (0.65)
0.69 (0.26)
2.77(1.71)
3.98 (2.38)
2.61 (1.48)
0.86 (0.32)
NSPS/PSNS Daily
Max (Monthly
Average) (mg/L) a
0.43 (0.24)
3.38 (2.07)
0.69 (0.43)
1.20 (0.65)
0.11(0.07)
2.77(1.71)
3.98 (2.38)
2.61 (1.48)
0.86 (0.32)
Source: 40 CFR §433.10.
a This part does not apply to (1) metallic platemaking and gravure cylinder preparation conducted within or for
printing and publishing facilities or (2) existing indirect discharging job shops and independent printed circuit board
manufacturers which are covered by 40 CFR part 413.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
5.6.2 History of EPA Reviews of the Metal Finishing Category
EPA first conducts a screening-level review of all categories subject to existing ELGs in
its TRA. In 2009, EPA conducted a screening-level review of the Metal Finishing Category (U.S.
EPA, 2009). In the 2011 Annual Review, EPA selected the Metal Finishing Category (40 CFR
Part 433) for a preliminary category review because it ranked high in the point source category
rankings, in terms of TWPE (U.S. EPA, 2012). EPA assigned this category lower priority for
revision in the Preliminary 2012 Plan after correcting reported discharges from facilities
contributing to the high TWPE (U.S. EPA, 2013).
EPA did not complete a preliminary category review of the category during the 2012
Annual Review. However, during the 2012 Annual Review, EPA identified additional data
sources that suggest further review of this category (U.S. EPA, 2014). Further, the category
continued to rank high in the point source category rankings in EPA's 2013 Annual Review.
EPA plans to conduct a more detailed preliminary category review of the Metal Finishing
Category during the 2014 Annual Review for the following reasons:
1. As part of the 2012 Annual Review (U. S. EPA, 2014), EPA reviewed the TNS S S
conducted by EPA's Office of Water (OW), which measured contaminant
concentrations in sewage sludge from 74 POTWs. Although the TNSSS did not
specifically identify the industrial wastewater discharged to the sampled POTWs,
EPA used information from TRI to examine pollutants discharged to POTWs, and
explored how those pollutants might interfere with beneficial use of sewage sludge.
This review suggested further investigation of pollutants discharged to POTWs by the
metal finishing industry, particularly metals, including chromium, nickel and zinc,
which were above the POTW sludge limits. EPA did not identify for further review
any new pollutants of concern or wastewater discharges from industrial categories not
currently regulated by ELGs.
Additionally, the Metal Finishing Category (40 CFR Part 433) has 52 facilities
reporting discharges to TNSSS POTWs, more than any other category. When
facilities with discharges covered by Electroplating (40 CFR Part 413) are added, the
two point source categories comprise nearly 50 percent of the facilities reporting
discharges to the 35 TNSSS POTWs, indicating that these two categories may be
primary sources of metals discharged to POTWs.
2. EPA received comments from regional EPA offices and State pretreatment
coordinators regarding POTW treatability issues arising from wastewater discharges
received from metal processing facilities. One such issue was that the limits for this
category might be improperly applied to metals industries regulated by other ELGs
that take precedence over 40 CFR Part 433.
3. EPA received comments from the Association of Clean Water Administrators
(ACWA) recommending that EPA revise regulations or issue new guidance regarding
pretreatment standards for the metal finishing industry because new technologies used
by the industry may introduce new pollutants of concern that are not currently
addressed in POTW or NPDES permits (InsideEPA, 2013). Such new technologies
may also not be covered under the 46 existing metal finishing operations.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
4. EPA evaluated the metal finishing industry (among other metals industries) during
the development of the Metal Products and Machinery (MP&M) rule (40 CFR Part
438), promulgated in 2003. As part of the rulemaking, EPA conducted sampling
episodes at 84 sites between 1986 and 2001 to obtain data on the characteristics of
wastewater and solid wastes, including sites with metal finishing operations. This
sampling program revealed the impact of technological advances in treating
wastewater since EPA promulgated Part 433 in 1983. Table 5-50 compares the
maximum monthly average effluent limits established by the 1983 Metal Finishing
ELGs with the limits observed for the metal finishing industry during the MP&M rule
development (covered by four subcategories in 40 CFR Part 438). EPA proposed
these limits in 2001, but they were not promulgated.
5. As outlined in the 2012 Annual Review Report (U.S. EPA, 2012), EPA is collecting
data on new treatment technologies used to treat metals in industrial wastewater and
is evaluating newer treatment performance levels to supplant the limits established by
the Metal Finishing ELGs in 1983. From a preliminary comparison, it appears that
treatment technologies developed after 1983 can reduce metals in wastewater to
significantly lower levels than technologies that were available when the 1983 ELGs
were developed.
Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and
Proposed Part 438
Pollutant
TSS
Oil and Grease
TOC
Total organics
parameter
Total Metals
Aluminum
Cadmium
Chromium
Copper
Total Cyanide
Amenable
Cyanide
Lead
Manganese
Molybdenum
Nickel
Silver
Unit
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
40CFRPart413a
>10,000
gpd
5.0
0.5
2.5
1.8
0.23
0.3
1.8
0.5 d
<10,000
gpd
0.5
1.5
0.3
40 CFR
Part 433b
NSPS&
PSNS
0.07
1.71
2.07
0.65
0.32
0.43
2.38
0.24
PSES
0.26
1.71
2.07
0.65
0.32
0.43
2.38
0.24
40CFRPart438c
General
Metals
18
12
50
4.3
0.09
0.14
0.28
0.13
0.07
0.03
0.09
0.49
0.31
0.09
MFJob
Shops
31
26
59
4.3
0.09
0.55
0.57
0.13
0.07
0.09
0.10
0.49
0.64
0.06
Non-Cr
Anodizing
31
26
0.09
0.31
Printed
Wiring
Board
31
26
67
4.3
4.0
0.14
0.28
0.13
0.07
0.03
0.64
0.14
5-53
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
Table 5-50. Maximum Monthly Average Effluent Limits of Part 413, Part 433, and
Proposed Part 438
Pollutant
Sulfide, Total
Tin
Zinc
Unit
mg/L
mg/L
mg/L
40CFRPart413a
>10,000
gpd
1.8
<10,000
gpd
40 CFR
Part 433b
NSPS&
PSNS
1.48
PSES
1.48
40 CFR Part 438C
General
Metals
13
0.67
0.22
MFJob
Shops
13
1.4
0.17
Non-Cr
Anodizing
0.22
Printed
Wiring
Board
13
0.14
0.22
Sources: U.S. EPA, 1979; U.S. EPA, 1983; U.S. EPA 2000.
Gray highlighting indicates no limits were set for the pollutant.
a EPA established discharge limits based on a wastewater production threshold of 10,000 gallons per day (gpd).
bNSPS - New Source Performance Standards; PSNS - Pretreatment Standards for New Sources; PSES -
Pretreatment Standards for Existing Sources.
°Part 438 developed proposed limits for 8 subcategories, of which 4 subcategories are relevant to the metal finishing
industry: General Metals, Metal Finishing (MF) Job Shops, Non-chromium (Non-Cr) Anodizing, and Printed Wiring
Board.
d The silver pretreatment standard applies only to Subpart B, precious metals plating.
Although EPA has not revised the Part 433 ELGs since 1983, the Agency has reviewed
annual discharge data as part of the 304m review process. Table 5-51 compares the top three
pollutants with the highest contribution to the 2011 DMR TWPE (PCB-1248, copper, and
cyanide) and shows the 2009 DMR TWPE for these top pollutants based on the results of the
2011 Annual Review (U.S. EPA, 2012). The top three pollutants contribute 45 percent of the
total 2011 DMR TWPE.
Table 5-52 shows that the top three pollutants, copper and copper compounds, lead and
lead compounds, and silver and silver compounds, contribute 69 percent of the total 2011 TRI
TWPE. For comparison, the table shows the 2009 TRI TWPE for these top pollutants, based on
the results of the 2011 Annual Review (U.S. EPA, 2012).
EPA's review of the TNSSS identified chromium, nickel, and zinc as the top pollutants of
concern at POTWs, which are most likely contributed by metal finishing facilities. The top
pollutants identified in the DMR and TRI data indicate additional pollutants that do not overlap
with EPA's review of the TNSSS data. Further review is warranted to understand more fully the
pollutants of concern for the Metal Finishing Category.
5-54
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
Table 5-51. Metal Finishing Category Top DMR Pollutants
Pollutant
PCB-1248
Copper
Cyanide
Top Pollutant Total
Metal Finishing Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant b
2
243
68
NA
626
TWPE
44,200
40,200
35,500
120,000
265,000
2009 DMR Data3
TWPE
24,200
9,400
39,400
73,000
197,000
Sources: DMRLoads2009_v2; DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Number of DMR facilities reporting TWPE greater than zero.
Table 5-52. Metal Finishing Category Top TRI Pollutants
Pollutant
Copper and Copper Compounds
Lead and Lead Compounds
Silver and Silver Compounds
Top Pollutant Total
Metal Finishing Category Total
2011 TRI Data
Number of Facilities
Reporting Pollutant a
1,540
2,256
27
NA
1,785
TWPE
13,600
11,100
10,800
35,500
51,700
2009 TRI Data
TWPE
12,900
10,700
41,700
65,300
86,100
Sources: TRIReleases2009_v2; TRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a Number of facilities reporting TWPE greater than zero.
For the continuing preliminary review of the Metal Finishing Category, EPA plans to:
• Collect updated industry information on the number of facilities (including
indirect dischargers and small businesses) and how metal finishing operations and
processes currently employed by the industry compare to the operations and
processes used in 1983.
• Review data collected during the development of the MP&M ELGs to profile the
metal finishing industry, further evaluate the proposed limits for metal finishing
operations, and to review the POTW survey results for additional metals
concentration data from POTWs that receive wastewater from metal finishing
operations.
• Continue to analyze trends in DMR and TRI data to identify pollutants of interest.
• Review data from other EPA and government programs or industry sources (e.g.,
regional EPA pretreatment programs, ACWA) to understand changes in
technologies and identify potential new pollutants of concern.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.6—Metal Finishing (40 CFR Part 433)
• Review new information on treatment technology performance to determine
which technologies, if any, can reduce pollutants in metal finishing wastewater to
concentrations lower than the Part 433 ELGs.
EPA will use the findings from the preliminary category review to identify:
• Additional data needs for this industry, including information on industry
economics and potential environmental impacts of current discharges.
• Metal finishing operations that are not covered by the 46 existing unit operations.
• Pollutants present in metal finishing wastewater that may not be included in the
ELGs and that may warrant further study.
• Alternative manufacturing operations or chemistries that reduce or eliminate
pollutant discharges.
• Current best available treatment technologies for removing pollutants from metal
finishing wastewater.
5.6.3 References for Metal Finishing Category
1. Inside EPA. 2013. States Say 'Green' Metal Finishing Technology Requires New Effluent
Limitations Guidelines Guide. InsideEPA.com. Doc ID: 2440462. (July 16). EPA-HQ-
OW-2014-0170. DCN 07870.
2. U.S. EPA. 1979. Development Document for Existing Source Pretreatment Standards for
the Electroplating Point Source Category. Washington, D.C. (August). EPA-HQ-OW-
2014-0170. DCN 07871.
3. U.S. EPA. 1983. Federal Register Notice: Electroplating and Metal Finishing Point
Source Categories; Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards. Washington, D.C., (July 15). EPA-HQ-OW-2014-0170.
DCN 07868.
4. U.S. EPA. 2000. Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Metal Products & Machinery Point Source Category.
Washington, D.C. (December). EPA-HQ-OW-2014-0170. DCN 07869.
5. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
6. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December) EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195.
7. U.S. EPA, 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C.
(May). EPA-HQ-OW-2010-0824. DCN 07684.
8. U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C.
(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07933.
5-56
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
5.7 Nonferrous Metals Manufacturing (40 CFR Part 421)
EPA selected the Nonferrous Metals Manufacturing (NFMM) Category for preliminary
review because it continues to rank high, in terms of toxic-weighted pound equivalents (TWPE),
in the point source category rankings. EPA reviewed discharges from the NFMM Category as
part of the 2004, 2006, 2007, 2009, and 2011 reviews (U.S. EPA, 2004, 2006, 2007, 2009, 2012).
This section summarizes the results of the 2013 Annual Review associated with the NFMM
Category. EPA focused on discharges of cadmium, copper, mercury, polychlorinated biphenyls
(PCBs), and lead from discharge monitoring reports (DMR) because of their high TWPE relative
to other pollutants in the NFMM Category. Cadmium, mercury, and lead, reviewed as part of the
2011 Annual Review, continue to be top pollutants of concern. For the 2013 Annual Review,
available discharge data also showed significant contributions of copper and PCBs to the NFMM
Category TWPE.
5.7.1 NFMM Category 2013 Toxicity Rankings Analysis
Table 5-35 compares the toxicity rankings analysis (TRA) results for the NFMM
Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but
instead reviewed additional data sources as part of the even-year annual review as discussed in
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As
discussed below, EPA's review of the NFMM Category identified a data error that affected the
2011 DMR data and TWPE. The bottom row of Table 5-35 shows the corrected data resulting
from this review.
Table 5-53. NFMM Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
NFMM Category Facility Counts
Total TRI
Facilities
121
119
Total DMR
Major Facilities
29
28
Total DMR
Minor Facilities"
19
23
NFMM Category TWPE
TRI
TWPEb
40,500
42,900
42,900
DMR
TWPEC
160,000
383,000
330,000
Total
TWPE
201,000
426,000
373,000
Sources: 2011 Annual Review Report (for 2009aDMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_vl
(for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities are reporting facilities and contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2009 data after corrections made during the 2011 Annual Review.
e 2011 data after corrections made during the 2013 Annual Review.
As shown in Table 5-35, the total TWPE (incorporating data corrections) has increased
from 2009 to 2011. During that period, the number of TRI facilities and minor DMR facilities
decreased, while the number of major DMR facilities increased.
5-57
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
5.7.2 NFMM Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the NFMM Category focused on the 2011
DMR discharges because the 2011 DMR data account for 90 percent of the category's combined
TWPE. Table 5-54 lists the five pollutants with the highest contribution to the 2011 DMR
TWPE. Table 5-54 also presents the 2011 DMR TWPE after EPA corrected an error identified in
this preliminary category review (discussed in the sections below). In addition, as a point of
comparison, Table 5-54 shows the 2009 DMR TWPE for these top five pollutants based on the
results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012).
Cadmium, copper, mercury, PCBs, and lead contribute more than 82 percent of the total
2011 category DMR TWPE. EPA's investigations of reported discharges of the top five
pollutants are presented in Section 5.7.3 to 5.7.7. EPA did not investigate the other pollutants as
part of the 2013 Annual Review because they account only 18 percent of the 2011 DMR TWPE
for the NFMM Category.
Table 5-54. 2011 NFMM Category Top DMR Pollutants
Pollutant
Cadmium
Copper
Mercury
PCBs
Lead
Top Pollutants, Total
NFMM Category, Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
9
22
6
2
21
NA
55"
Original
TWPE
114,000
60,300
59,200
59,100
19,400
312,000
383,000
Corrected
TWPE
114,000
7,380
59,200
59,100
19,400
259,000
330,000
2009 DMR Data3
TWPE
22,900
754
29,100
4,140
24,300
81,200
160,000
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Number of facilities reporting TWPE greater than zero.
5.7.3 NFMM Category Cadmium Discharges in DMR
EPA's investigation of the cadmium discharges revealed thatNyrstar Clarksville Inc.
(Nyrstar), in Clarksville, TN accounts for over 98 percent of the 2011 DMR cadmium compound
discharges (shown in Table 5-55). EPA did not investigate the remaining facilities discharging
cadmium.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 5-55. Top 2011 DMR Cadmium Discharging Facilities
Facility Name
Nyrstar Clarksville Inc.
Facility Location
Clarksville, TN
Remaining Facilities Reporting Cadmium3
Total
Pounds of Pollutant
Discharged
4,850
98.4
4,950
Pollutant
TWPE
112,000
2,270
114,000
Facility Percent of
Category TWPE
98%
2%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are eight remaining facilities that have cadmium discharges in the 2011 DMR data.
Nyrstar produces zinc metal from benefielation of zinc concentrate ore by a
hydrometallurgical process. As secondary products, this facility also co-produces cadmium
metal, sulfuric acid, and metallurgically valuable byproducts (TN DEC, 2005). Nyrstar
discharges cadmium from outfalls 001, SW3, SW4, and SW5. Outfall 001 discharges treated
process wastewater, sanitary wastewater, and cooling water (TN DEC, 2006). Outfalls SW3,
SW4, and SW5 discharge stormwater runoff from the main production area, materials handling
areas, and ancillary facility areas, respectively (Crocker, 2014).
As part of the 2013 Annual Review, EPA contacted Nyrstar about the cadmium
discharges; the facility contact confirmed the 2011 flow rates and concentrations. Table 5-56
presents Nyrstar's 2011 cadmium concentrations, along with the average monthly flow for the
four outfalls. Because the facility reported a cadmium quantity in kilograms per day (kg/day) for
outfall 001, EPA calculated the concentrations using the pollutant load discharged and the
average monthly flow. The 2011 quantities discharged from outfall 001 range from 0.16 to 0.68
kg/day. The facility's permit limits cadmium for outfall 001 at 0.798 kg/day monthly average
and 1.99 kg/day daily maximum. It does not limit cadmium discharges for outfalls SW3, SW4,
and SW5 (TN DEC, 2006), but requires monitoring. As shown in Table 5-56, 2011 cadmium
concentrations for outfall 001 are below the facility's permit limits.
Table 5-56. Nyrstar's 2011 DMR Monthly Cadmium Discharges
Outfall
001
001
001
001
001
001
001
001
001
001
001
001
Date
31-Jan-ll
28-Feb-ll
31-Mar-ll
30-Apr-ll
31 -May- 11
30-Jun-ll
31-Jul-ll
31-Aug-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31-Dec-ll
Quantity
(kg/day)
0.470
0.580
0.440
0.680
0.560
0.430
0.204
0.160
0.410
0.650
0.290
0.190
NPDES Monthly
Average Permit
Limit (kg/day) a
0.798
0.798
0.798
0.798
0.798
0.798
0.798
0.798
0.798
0.798
0.798
0.798
Flow (MGD)
0.590
0.740
0.804
0.806
0.820
0.720
0.170
0.140
0.690
0.610
0.605
0.660
Concentration
(mg/L)
0.210
0.207
0.145
0.223
0.180
0.158
0.317
0.302
0.157
0.282
0.127
0.076
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 5-56. Nyrstar's 2011 DMR Monthly Cadmium Discharges
Outfall
SW3
SW3
SW3
SW3
SW4
SW4
SW4
SW4
SW5
SW5
Date
31-Mar-ll
30-Jun-ll
30-Sep-ll
31 -Dec- 11
31-Mar-ll
30-Jun-ll
30-Sep-ll
31 -Dec- 11
30-Jun-ll
31 -Dec- 11
Quantity
(kg/day)
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NPDES Monthly
Average Permit
Limit (kg/day) a
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Monitoring only
Flow (MGD)
0.320
0.083
0.940
0.640
0.204
0.039
0.490
0.430
1.77
4.28
Concentration
(mg/L)
0.510
0.330
2.05
1.90
0.290
0.980
1.57
0.025
0.025
0.180
Sources: DMRLTOutput2011_vl; TN DEC, 2006.
NR: Not reported.
a Indicates limits that were in effect when 2009 and 2011 discharge data were submitted.
Nyrstar was issued a new permit, which took effect January 2012. The revised permit set
a daily maximum cadmium limit of 0.0159 milligrams per liter (mg/L) for outfalls SW3, SW4,
and SW5, with a quarterly monitoring requirement (but no monthly average limit); it adjusted the
limit for cadmium discharges from outfall 001 to 1.03 kg/day monthly average and 2.4 kg/day
daily maximum. The cadmium limits for outfall 001 were revised based on additional site
information, further insight on the facility's operation/performance, and a revised best
professional judgment determination (TN DEC, 2011). EPA anticipates that the facility's new
permit limits for the stormwater outfalls will result in a reduction in cadmium discharges and
associated TWPE from this facility; therefore, further review of the NFMM Category's cadmium
discharges is not warranted at this time.
5.7.4 NFMM Category Copper Discharges in DMR
EPA's investigation of the copper discharges revealed that Alcoa World Alumina LLC
(Alcoa), in Point Comfort, TX accounts for over 88 percent of the 2011 DMR copper discharges
(shown in Table 5-57). EPA did not investigate the remaining facilities discharging copper.
Table 5-57. Top 2011 DMR Copper Discharging Facilities
Facility Name
Alcoa World Alumina, LLC
Facility Location
Point Comfort, TX
Remaining Facilities Reporting Copper3
Total
Pounds of Pollutant
Discharged
84,100
11,700
95,800
Pollutant
TWPE
53,000
7,370
60,300
Facility Percent of
Category TWPE
88%
12%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 21 remaining facilities that have copper discharges in the 2011 DMR data.
Alcoa discharges copper from three outfalls. As part of the 2013 Annual Review, EPA
compared discharge concentrations for all outfalls and identified a unit error for the June 2011
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
copper concentration for outfall 015. Table 5-58 presents Alcoa's original and corrected average
copper concentrations along with the average flow values for the three outfalls. With the
corrected discharge concentrations incorporated, Alcoa's copper TWPE decreases from 53,000
to 7.19, reducing the NFMM Category's copper TWPE from 60,300 to 7,380, as shown in Table
5-54.
Table 5-58. Alcoa's 2011 DMR Original and Corrected Monthly Copper Discharges
Outfall
006
006
008
008
008
008
008
008
008
008
008
008
015
015
015
015
015
015
Monitoring Period
Date3
28-Feb-ll
30-Apr-ll
31 -Jan- 11
28-Feb-ll
31 -Mar- 11
31-May-ll
30-Jun-ll
31-Jul-ll
30-Sep-ll
31-Oct-ll
30-Nov-ll
31 -Dec- 11
31 -Jan- 11
28-Feb-ll
31-May-ll
30-June-ll
30-Sep-ll
31-Oct-ll
Average Flow
(MGD)
0.77
0.018
0.0017
0.013
0.0012
0.0013
0.0005
0.0008
0.001
0.001
0.000062
0.00026
0.15
0.021
0.016
0.52
0.063
0.072
Original Copper
Concentration (mg/L)
0.0039
0.0065
0
0.014
0.019
0
0.015
0.14
0.074
0.022
0.041
0.11
0.0068
0
0
642
0.012
0.094
Corrected Copper
Concentration (mg/L)
0.0039
0.0065
0
0.014
0.019
0
0.015
0.14
0.074
0.022
0.041
0.11
0.0068
0
0
0.0642
0.012
0.094
Source: DMRLTOutput2011_vl.
a The facility reported no flow for January, March, May, June, July, August, September, October, November, or
December 2011 from Outfall 006; April or August 2011 from Outfall 008; or March, April, July, August,
November, or December 2011 from Outfall 115. Therefore, copper concentrations were not reported for those
months.
5.7.5 NFMM Category Mercury Discharges in DMR
EPA's investigation of the mercury discharges revealed that Alabama State Docks-Mud
Lakes, (AL State Docks), in Mobile, AL accounts for over 99 percent of the 2011 DMR mercury
discharges (shown in Table 5-59). EPA did not investigate the remaining facilities discharging
mercury.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 5-59. Top 2011 DMR Mercury Discharging Facilities
Facility Name
Alabama State Docks-Mud Lakes
Facility Location
Mobile, AL
Remaining Facilities Reporting Mercury Discharges3
Total
Pounds of Pollutant
Discharged
499
6.16
505
Pollutant
TWPE
58,500
721
59,200
Facility Percent of
Category TWPE
99%
1%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are five remaining facilities that have mercury discharges in the 2011 DMR data.
EPA reviewed the mercury discharges from AL State Docks as part of the 2010 and 2011
Annual Review (U.S. EPA, 2011, 2012). As discussed in the 2010 Annual Review, AL State
Docks is a dock that serves as a transfer station for bulk cargo that is exported and imported. The
site contains former aluminum ore tailings lakes, now used to accumulate and treat aluminum ore
tailings leachate before discharge to the Mobile River. The site is not an industrial manufacturing
site (U.S. EPA, 2011). EPA determined that the facility's discharges result from the aluminum
ore tailings lakes, not current manufacturing. EPA verified the facility's 2008 mercury
discharges of 25,900 TWPE; the 2011 discharge data are similar in order of magnitude. Because
the facility no longer operates as an aluminum ore mine and processing facility and the
discharges are similar to those in previous years, facility-specific permitting action may be
appropriate to address this facility's mercury discharges.
5.7.6 NFMM Category PCB Discharges in DMR
EPA's investigation of the PCB discharges revealed that U.S. Enrichment Corporation-
Paducah Gaseous Diffusion Plant (U.S. Enrichment Corp.), in Paducah, KY accounts for 96
percent of the 2011 DMR PCB discharges (shown in Table 5-60). Only two facilities have 2011
DMR PCB discharges; the other was Alcoa Lafayette Operations, which EPA did not investigate
as part of the 2013 Annual Review because it contributes only 4 percent of PCB TWPE in the
NFMM Category.
Table 5-60. Top 2011 DMR PCB Discharging Facilities
Facility Name
U.S. Enrichment Corp. - Paducah Gaseous
Diffusion Plant
Alcoa Lafayette Operations
Facility Location
Paducah, KY
Lafayette, IN
Total
Pounds of
Pollutant
Discharged
1.67
0.0686
1.74
Pollutant
TWPE
56,700
2,330
59,100
Facility Percent
of Category
TWPE
96%
4%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
U.S. Enrichment Corp. is a large uranium enrichment facility currently owned by the U.S.
Department of Energy. The facility opened in 1952, and its enrichment operations ceased in
2013. The plant produced low-enriched-uranium fuel for commercial nuclear power plants in the
U.S. and around the world (USEC, 2014). The site was listed on the National Priorities List as a
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Superfund site in 1994. EPA has been working with federal and state partners to clean up the site
since the late 1980s, and expects the process to take many more years (U.S. EPA, 2013).
U.S Enrichment Corp. discharges PCBs from outfalls 002, 009, 010, Oil, and 012. PCB
discharges from outfalls 002, 010, Oil, and 012 are generated from stormwater runoff and onsite
uranium enrichment processes and are discharged to Little Bayou Creek. Discharges from outfall
009 are generated from stormwater runoff combined with cooling water and are discharged to
Big Bayou Creek. The facility permit does not set a limit for PCB discharges, but requires
monitoring for the five outfalls (KY DEP, 1998). Table 5-61 presents the facility's PCB
discharge flow rates and concentrations for 2011. EPA contacted the Kentucky Department of
Environmental Protection, which verified the facility's PCB discharges. As shown, the PCB
concentrations range from 0.00019 to 0.0014 mg/L.
U.S. Enrichment Corp. shut down its uranium enrichment process in 2013, and EPA has
been working to clean up the site for many years. Therefore, the facility's PCB discharges are
likely not representative of other facilities in the category, and EPA is not performing further
review of PCB discharges from this facility at this time.
Table 5-61. U.S. Enrichment Corporation's 2011 PCB Discharge and Flow Data
Outfall
002
009
010
Oil
Oil
Oil
012
Monitoring Period Date
31-Mar-2011
30-Apr-2011
30-Apr-2011
28-Feb-2011
31 -Mar -20 11
31-M-2011
31 -Mar -20 11
Average Flow (MGD)
2.60
1.29
0.680
1.60
0.760
0.010
2.60
PCB Concentration (mg/L)
0.0014
0.00019
0.00033
0.00029
0.00048
0.0002
0.00053
Source: DMRLTOutput2011_vl.
5.7.7 NFMM Category Lead Discharges in DMR
EPA's investigation of the lead discharges revealed thatNyrstar Clarksville Inc.
(Nyrstar), Clarksville, TN and Sanders Lead Company, Troy, AL account for 93 percent of the
2011 DMR lead discharges (shown in Table 5-62). EPA did not investigate the remaining
facilities discharging lead.
Table 5-62. Top 2011 DMR Lead Discharging Facilities
Facility Name
Nyrstar Clarksville Inc.
Sanders Lead Company Inc.
Facility Location
Clarksville, TN
Troy, AL
Remaining Facilities Reporting Lead3
Total
Pounds of Pollutant
Discharged
5,400
2,690
568
8,660
Pollutant
TWPE
12,100
6,020
1,270
19,400
Facility Percent of
Category TWPE
62%
31%
7%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a 18 remaining facilities reported lead discharges in the 2011 DMR data.
5-63
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Nyrstar Clarksville, Inc.
Manufacturing and outfall information for Nyrstar is summarized in Section 5.7.3 as part
of the cadmium discussion. Nyrstar discharges lead from outfalls SW3, SW4, and SW5
(Crocker, 2014). Discharges from these outfalls are the result of stormwater runoff from the main
production area, materials handling areas, and ancillary facility areas, respectively. As part of the
2013 Annual Review, EPA contacted Nyrstar about the lead discharges from these outfalls; the
facility contact confirmed the 2011 lead discharge flow rates and concentrations. Table 5-63
presents Nyrstar's 2011 lead concentrations along with the average monthly flow for the
stormwater outfalls.
Table 5-63. Nyrstar's 2011 DMR Monthly Lead Discharges
Outfall
SW3
SW3
SW3
SW3
SW4
SW4
SW4
SW4
SW5
SW5
Date
31-Mar-ll
30-Jun-ll
30-Sep-ll
31 -Dec- 11
31-Mar-ll
30-Jun-ll
30-Sep-ll
31-Dec-ll
30-Jun-ll
31-Dec-ll
Concentration (mg/L)
0.170
0.050
2.39
0.350
1.60
3.54
3.95
0.050
0.050
0.220
Flow (MGD)
0.320
0.083
0.940
0.640
0.204
0.039
0.490
0.430
1.77
4.28
Source: DMRLTOutput2011_vl.
At the time of discharge in 2011, the facility's permit did not include lead discharge
limits for outfalls SW3, SW4, and SW5 (TN DEC, 2006). In January 2012, a new permit took
effect, setting a daily maximum of 0.156 mg/L for outfalls SW3, SW4, and SW5 with quarterly
monitoring required (but no monthly average limit) (TN DEC, 2011). Lead discharges at this
facility are now regulated by the updated permit limits. Because lead limits have been added to
the most recent facility permit, EPA expects that lead discharges from the stormwater outfalls at
this facility will decrease on future DMRs.
Sanders Lead Company, Inc.
Sanders Lead Company Inc. in Troy, AL, is a secondary lead smelting plant that recycles
lead-acid batteries. The wastes are recycled to recover the lead (Rutherford, 2013). Sanders Lead
Company discharges wastewater from two outfalls, 003 and 004. Outfall 003 discharges
stormwater runoff from maintenance areas and roof drains from the lead smelting plant; outfall
004 discharges stormwater runoff from non-process portions of the lead smelting operation
(ADEM, 2008).
As part of the 2013 Annual Review, EPA contacted the facility about their lead
discharges. The facility contact provided 2012 and 2013 lead concentration information
(Rutherford, 2013). Table 5-64 presents Sanders Lead Company's 2011, 2012, and 2013 bi-
annual lead concentration information for outfalls 003 and 004. As shown, 2012 and 2013 lead
concentrations are lower than 2011 lead concentrations.
5-64
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
Table 5-64. 2011, 2012, and 2013 Lead Discharges from Sanders Lead Company, Inc.
Date
30-Jun-ll
31-Dec-ll
30-Jun-12
31 -Dec- 12
30-Jun-13
30-Jun-ll
31-Dec-ll
30-Jun-12
31-Dec-12
30-Jun-13
Outfall
003
003
003
003
003
004
004
004
004
004
Concentration (mg/L)
0.019
0.034
0.0054
0.012
0.002
0.0089
0.03
0.0052
0.009
0.002
Flow (MGD)
1.69
7.3
1.9
5.9
3.3
10.7
45.9
11.9
37.7
20.1
Source: DMRLTOutput2011_vl.
The facility contact explained the decrease in lead concentrations was due to a number of
improvements to the facility's particulate and stormwater containment capabilities (Rutherford,
2013):
• Performing operations indoors, self-enclosed, and under negative pressure.
• Construction of a new vehicle maintenance shop and machinery fabrication shop
to eliminate the potential for tracking metal constituents.
• Sweeping of the internal roadway to remove dust, dirt and debris.
• Replacement of asphalt pavement with new concrete in major traffic roadways to
ensure more effective sweeping.
The facility's permit requirement only requires that they report lead discharges. It does not
establish a limit. Based on the decreasing lead concentrations, EPA does not consider lead
discharges from this facility to be a priority for further review.
5.7.8 NFMM Category Findings
The estimated toxicity of the NFMM Category discharges resulted from DMR cadmium,
copper, mercury, PCBs, and lead discharges. From the 2013 Annual Review, EPA has identified
the following:
• One facility, Nyrstar Clarksville Inc., contributes the majority of the cadmium
discharges to the 2011 DMR data. This facility was issued a new permit in 2012
to control cadmium discharges from its stormwater outfalls and further review
from EPA is not warranted at this time.
• One facility, Alcoa World Alumina, contributes the majority of the copper
discharges to the 2011 DMR data. In reviewing the facility discharge information,
EPA found an error in the concentrations reported for the facility. Correcting the
data resulted in a reduction in the NFMM Category's copper TWPE from 60,300
to 7,380.
5-65
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
• One facility, AL State Docks, contributes the majority of the mercury discharges
to the 2011 DMR data. EPA reviewed these discharges as part of the 2010 and
2011 Annual Reviews and determined that they result from former aluminum ore
tailings lakes, not from current manufacturing. Because the facility no longer
operates as an aluminum ore mine and processing facility and the discharges are
similar to those in previous years, facility-specific permitting action may be
appropriate to address this facility's mercury discharges.
• One facility, the U.S. Enrichment Corporation-Paducah Gaseous Diffusion Plant,
contributes the majority of the PCB discharges to the 2011 DMR data. This
facility shut down its uranium enrichment process in 2013, and cleanup efforts
have been active at the site since the late 1980s. For these reasons, EPA is not
performing further review of PCB discharges from this facility at this time.
• Two facilities, Nyrstar Clarksville Inc. and Sanders Lead Company, contribute the
majority of the lead discharges to the 2011 DMR data. Nyrstar was issued a new
permit in 2012, and further review from EPA is not warranted at this time. EPA
determined that new containment technology and better management practices at
Sanders Lead Company facility have allowed steady reductions in the
concentration of lead discharges.
• Correcting the reporting errors identified during the 2013 Annual Review
decreases the 2011 NFMM Category TWPE from 426,000 to 373,000. The total
TWPE, incorporating data corrections, increased from 201,000 in 2009 to 373,000
in 2011, while the number of facilities reporting discharges stayed about the same.
However, for the majority of the top pollutants, one or two facilities contribute a
majority of the TWPE. EPA has determined that those facilities either warrant
individual permitting action or have already received revised permit limits that
will reduce wastewater discharges in the future. A category-wide discharge issue,
warranting an effluent guidelines revision, is not apparent.
5.7.9 References for NFMM Category
1. ADEM. 2008. Alabama Department of Environmental Management. NPDES Permit:
Sanders Lead Co. Inc. (October 29). EPA-HQ-OW-2014-0170. DCN 07908.
2. Crocker, William. 2013. Telephone and Email Communication Between William
Crocker, Nyrstar, and Julia Kolberg, Eastern Research Group, Inc., Re: 2011 DMR
Cadmium and Lead Discharges. (December 11). EPA-HQ-OW-2014-0170. DCN 07904.
3. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category - 421 - NFMM. (March). EPA-HQ-OW-2014-
0170. DCN 07918.
4. KY DEP. 1998. Kentucky Department of Environmental Protection. NPDES Permit: U.S.
Enrichment Corporation-Paducah Gaseous Diffusion Plant. (March 13). EPA-HQ-OW-
2014-0170. DCN 07903.
5-66
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Section 5—EPA's 2013 Preliminary Category Reviews
5.7—Nonferrous Metals Manufacturing (40 CFR Part 421)
5. Rutherford, Chris. 2013. Telephone and Email Communication Between Chris
Rutherford, Sanders Lead Company, Inc., and Julia Kolberg, Eastern Research Group,
Inc., Re: 2011 DMR Lead Discharges. (December 20). EPA-HQ-OW-2014-0170. DCN
07907.
6. TN DEC. 2005. Tennessee Department of Environment and Conservation. NPDES
Permit Fact Sheet: Nyrstar Clarksville, Inc., Clarksville, Tennessee. (May 31). EPA-HQ-
OW-2010-0824. DCN 07573.
7. TN DEC. 2006. Tennessee Department of Environment and Conservation. NPDES
Permit: Nyrstar Clarksville, Inc, Clarksville, Tennessee. (June 1). EPA-HQ-OW-2010-
0824. DCN 07574.
8. TN DEC. 2011. Tennessee Department of Environment and Conservation. NPDES
Permit: Nyrstar Clarksville, Inc, Clarksville, Tennessee. (November 30). EPA-HQ-OW-
2014-0170. DCN 07906.
9. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
10. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
11. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
12. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
13. U. S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN
07320.
14. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA-820-R-10-021. EPA-HQ-OW-2008-0517. DCN 07685.
15. U.S. EPA. 2013. Region 4: Superfund Site - U.S. DOE Gaseous Diffusion Plant.
Available online at: http://www.epa.gov/region4/superfund/sites/fedfacs/pgasdifky.html.
Date accessed: February 17, 2014. EPA-HQ-OW-2014-0170.DCN 07909.
16. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
17. USEC. 2014. Paducah Gaseous Diffusion Plant. Available online at:
http://www.usec.com/gaseous-diffusion/paducah-gdp. Accessed February 17, 2014. EPA-
HQ-OW-2014-0170. DCN 07910.
5^67
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
5.8 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category
for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalents (TWPE), in point source category rankings. EPA reviewed discharges from the
OCPSF Category as part of the 2004 through 2011 reviews (U.S. EPA, 2004, 2005a, 2005b,
2006, 2007, 2008, 2009a, 2011, 2012). This section summarizes the results of the 2013 Annual
Review pertaining to the OCPSF Category. EPA focused on discharges of hexachlorobenzene,
total residual chlorine, and polychlorinated biphenyls (PCBs) because of their high TWPE
relative to other pollutants in the OCPSF Category. Hexachlorobenzene, reviewed as part of the
2011 Annual Review, continues to be a top pollutant of concern. For the 2013 Annual Review,
available discharge data also showed significant contributions of total residual chlorine and
PCBs to the OCPSF Category TWPE.
5.8.1 OCPSF Category 2013 Toxicity Rankings Analysis
Table 5-65 compares the toxicity rankings analysis (TRA) results for the OCPSF
Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but
instead reviewed additional data sources as part of the even-year annual review as discussed in
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As
discussed in this section, EPA's review of the OCPSF Category identified several data errors that
affected the 2011 DMR data and TWPE. The bottom row of Table 5-65 shows the corrected data
resulting from this review.
Table 5-65. OCPSF Category TRI and DMR Facility Counts and Discharges for the
2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
OCPSF Category Facility Counts
Total TRI
Facilities
671
631
Total DMR
Major
Facilities
169
165
Total DMR
Minor
Facilities"
150
180
OCPSF Category TWPE
TRI
TWPEb
146,000
148,000
148,000
DMR
TWPEC
491,000
1,540,000
658,000
Total
TWPE
637,000
1,690,000
806,000
Sources: 2011 Annual Review Report (for 200
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
5.8.2 OCPSF Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the OCPSF Category focused on the 2011
DMR discharges because the 2011 DMR data dominate the category's combined TWPE. Table
5-66 compares the five pollutants with the highest contribution to the 2011 DMR TWPE. It also
presents the 2011 DMR TWPE after EPA corrected errors identified in this preliminary category
review (discussed in the sections below). In addition, as a point of comparison, Table 5-66 shows
the 2009 DMR TWPE for these top five pollutants based on the results of (and corrections
identified in) the 2011 Annual Review (U.S. EPA, 2012).
Hexachlorobenzene, total residual chlorine, and PCBs contribute more than 65 percent of
the total 2011 DMR TWPE. EPA's investigations of reported discharges of the top three
pollutants are presented in Sections 5.8.3 to 5.8.5. EPA did not investigate the other top
pollutants as part of the 2013 Annual Review (i.e., mercury and lead), because they represent
less than 35 percent of the 2011 DMR TWPE for the OCPSF Category.
Table 5-66. OCPSF Category Top DMR Pollutants
Pollutant
Hexachlorobenzene
Total Residual Chlorine
PCBs
Lead
Mercury
Top Pollutant Total
OCPSF Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
11
110
1
51
34
NA
345C
Original TWPE
689,000
169,000
147,000
114,000
110,000
1,230,000
1,540,000
Corrected
TWPE
61,800
59,500
0
114,000b
110,000b
345,000
658,000
2009 DMR Data3
TWPE
81,300
75,800
0
2,550
741
160,000
491,000
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Mercury and lead discharges combined contribute less than 15 percent of the 2011 category DMR TWPE.
Therefore, EPA did not review mercury or lead discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
5.8.3 OCPSF Category Hexachlorobenzene Dischargers in DMR
EPA's investigation of hexachlorobenzene discharges revealed that Honeywell
International Incorporated-Hopewell (Honeywell), in Hopewell, VA, accounts for more than 91
percent of the 2011 DMR hexachlorobenzene discharges (shown in Table 5-67). EPA did not
investigate the remaining facilities discharging hexachlorobenzene.
5-69
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 5-67. Top 2011 DMR Hexachlorobenzene Discharging Facilities
Facility Name
Honeywell International Incorporated -
Hopewell
Facility
Location
Hopewell, VA
Remaining Facilities Reporting Hexachlorobenzene
Discharges3
Total
Pounds of Pollutant
Discharged
322
31.7
354
Pollutant
TWPE
627,000
61,800
689,000
Facility Percent of
Category TWPE
91%
9%
100%
Source: DMRLTOutput2011_vl.
Note: Values presented in the table are rounded to three significant figures. Sums of individual values may not equal
the total presented, due to rounding.
a There are 10 remaining facilities that have hexachlorobenzene discharges in the 2011 DMR data.
Honeywell reported hexachlorobenzene discharges from outfall 101, which discharges
contact cooling water from two barometric condensers (VA DEQ, 2008). As part of the 2013
Annual Review, EPA contacted Honeywell about the facility's hexachlorobenzene discharges.
Honeywell stated that the hexachlorobenzene discharges were measured at levels below
detection and confirmed that below-detection-limit (BDL) indicators were not properly marked
on the DMR (Parker, 2013). As described in Section 3.2.2.2 in EPA's Technical Support
Document for the Annual Review of Existing Effluent Guidelines and Identification of Potential
New Point Source Categories (2009 Screening-Level Analysis (SLA) Report), EPA zeros the
load when all concentrations of a specific pollutant are BDL for all monitoring periods (U.S.
EPA, 2009b). Therefore, EPA zeroed Honeywell's hexachlorobenzene discharges, which
decreases the corrected total hexachlorobenzene TWPE for the OCPSF category from 689,000 to
61,800, as shown in Table 5-66.
5.8.4 OCPSF Category Total Residual Chlorine Dischargers in DMR
EPA's investigation of the total residual chlorine discharges revealed that Celanese LTD-
Bay City Plant (Celanese), in Bay City, TX, accounts for more than 65 percent of the 2011 DMR
chlorine discharges (shown in Table 5-68). EPA did not investigate the remaining facilities
discharging total residual chlorine.
Table 5-68. Top 2011 DMR Total Residual Chlorine Discharging Facilities
Facility Name
Celanese LTD -Bay City Plant
Facility Location
Bay City, TX
Remaining Facilities Reporting Total Residual
Chlorine Discharges3
Total
Pounds of Pollutant
Discharged
218,000
119,000
337,000
Pollutant
TWPE
109,000
59,500
169,000
Facility Percent of
Category TWPE
65%
35%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 109 remaining facilities that have total residual chlorine discharges in the 2011 DMR data.
5-70
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Celanese17 discharges total residual chlorine from outfall 001. As part of the 2013 Annual
Review, EPA contacted Celanese about its total residual chlorine discharges. The facility contact
explained that process wastewater from the facility enters an internal domestic wastewater
treatment plant and then is transferred to a permitted onsite neutral effluent treatment (NET)
system via an internal outfall. Wastewater from the NET system is discharged via outfall 001 to
the Colorado River. The contact explained that the facility's permit has a minimum chlorine limit
of 1 milligram per liter for the internal outfall between the internal wastewater treatment plant
and the NET system. The facility adds chlorine in the internal domestic wastewater treatment
plant and the chlorine level must meet the minimum limit upon entering the NET system. Outfall
001 discharges treated domestic wastewater and treated process wastewater (commingled) from
the facility (TCEQ, 2007). Outfall 001 does not have a chlorine limit; however, the facility is
reporting the chlorine concentrations at the internal outfall as part of its DMRs. The facility is
working to remove the internal outfall chlorine limit listing from the DMRs in its current permit
renewal cycle to avoid further confusion (Gavranovic, 2013).
Since the total residual chlorine discharges from Celanese are from an internal outfall
rather than outfall 001, EPA removed the chlorine discharges from the DMR TWPE total for this
facility. With this correction, the total residual chlorine TWPE for the OCPSF category decreases
from 169,000 to 59,500, as shown in Table 5-66.
5.8.5 OCPSF Category PCB Dischargers in DMR
EPA's investigation of PCB discharges revealed that Aventis Cropscience USA, in
Institute, WV, accounts for 100 percent of the 2011 DMR PCB discharges (shown in Table
5-69). There were no remaining facilities discharging PCBs.
Table 5-69. 2011 DMR PCB Discharging Facility
Facility Name
Aventis Cropscience USA
Facility Location
Institute, WV
Pounds of Pollutant
Discharged
4.31
Pollutant
TWPE
147,000
Facility Percent of
Category TWPE
100%
Source: DMRLTOutput2011_vl.
Aventis reported PCB discharges from outfall 001. As part of the 2013 Annual Review,
EPA contacted Aventis about the facility's PCB discharges. Aventis stated that all PCB
discharges for 2011 were measured at levels below detection and that proper BDL indicators
were not marked on the DMR (Smith, 2014). As described in Section 3.2.2.2 in EPA's Technical
Support Document for the Annual Review of Existing Effluent Guidelines and Identification of
Potential New Point Source Categories (2009 Screening-Level Analysis (SLA) Report), EPA
zeros the load when all concentrations of a specific pollutant are BDL for all monitoring periods
(U.S. EPA, 2009b). Therefore, EPA zeroed Aventis' PCB discharges, which decreases the
corrected total PCB TWPE from the OCPSF category from 147,000 to 0, as shown in Table
5-66.
17 The facility is also referred to as OXEA Corporation, because Celanese sold parts of the company to OXEA in
2007.
-------
Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
5.8.6 OCPSF Category Findings
The estimated toxicity of the OCPSF Category discharges resulted from DMR
hexachlorobenzene, total residual chlorine, and PCB discharges. From the 2013 Annual Review,
EPA has identified the following:
• One facility, Honeywell International Incorporated, contributes the majority of the
reported hexachlorobenzene discharges to the 2011 DMR data. The facility
contact confirmed that BDL indicators were not properly marked on the DMR.
Because all hexachlorobenzene discharges were non-detect, EPA zeroed the
hexachlorobenzene load and TWPE for Honeywell. With this error corrected, the
hexachlorobenzene TWPE for the OCPSF category decreased from 689,000 to
61,800.
• One facility, Celanese, contributes the majority of the total residual chlorine
discharges to the 2011 DMR data. The facility contact confirmed that the total
residual chlorine discharges on the 2011 DMRs are from an internal outfall, not
an external outfall. Therefore, EPA removed the total residual chlorine discharges
for Celanese from the TWPE total for this category. With this error corrected, the
total residual chlorine TWPE for the OCPSF category decreased from 169,000 to
59,500.
• The PCB discharges are reported by one facility, Aventis Cropscience USA. The
facility contact confirmed that below detection limit indicators were not properly
marked on the DMR. Because all PCB discharges were non-detect, EPA zeroed
the PCB load and TWPE for Aventis Cropscience. With this error corrected, the
PCB TWPE for the OCPSF category decreased from 147,000 to 0.
• EPA corrected errors for discharges reported by three facilities. Correcting the
errors identified during the 2013 Annual Review decreases the 2011 OCPSF
Category TWPE from 1,690,000 to 806,000. The total corrected TWPE has
increased from 2009 to 2011, likely a result of an increase in the number of minor
discharging facilities, and thus the total number of facilities, submitting DMR
data from 2009 to 2011. In addition, the total TWPE continues to remain high,
which EPA attributes to the large number of facilities in the OCPSF industry.
5.8.7 References for OCPSF Category
1. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 414 - OCPSF. (March). EPA-HQ-OW-2014-
0170. DCN 07926.
2. Gavranovic, Gladys. 2013. Telephone and Email Communication Between Gladys
Gavranovic, Celanese LTD, and Kimberly Bartell, Eastern Research Group, Inc., Re:
2011 DMR Chlorine Discharges for Celanese LTD. (December 13). EPA-HQ-OW-2014-
0170. DCN 07922.
5-72
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
3. Parker, Andrew. 2013. Telephone and Email Communication Between Andrew Parker,
Honeywell International Inc., and Kimberly Bartell, Eastern Research Group, Inc., Re:
2011 DMR Discharges for Honeywell International. (December 13). EPA-HQ-OW-2014-
0170. DCN 07919.
4. Smith, Gordon. 2014. Telephone and Email Communication Between Gordon Smith,
Aventis Cropscience, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011
DMR PCB Discharges. (January 15). EPA-HQ-OW-2014-0170. DCN 07920.
5. TCEQ. 2007. Texas Commission on Environmental Quality. NPDES Permit: Oxea
Corporation, Bay City, Texas. (March 26). EPA-HQ-OW-2014-0170. DCN 07923.
6. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
7. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. Washington, D.C. (August). EPA-821-B-05-004. EPA-HQ-OW-2004-
0032-0016.
8. U.S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations
and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source
Category. Washington, D.C. (April). EPA-HQ-OW-2004-032-2568.
9. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-0032-
2782.
10. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
11. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
12. U. S. EPA. 2009a. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-0517-0515.
13. U.S. EPA. 2009b. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, D.C. (October). EPA-HQ-OW-2008-0517-0515.
14. U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA-820-R-10-021. EPA-HQ-OW-2008-0517 DCN
07320.
15. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195.
5-73
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Section 5—EPA's 2013 Preliminary Category Reviews
5.8—Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
16. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
17. VA DEQ. 2008. Virginia Department of Environmental Quality. NPDES Permit:
Honeywell International, Inc., Hopewell, VA. (September 30). EPA-HQ-OW-2014-0170.
DCN 07921.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.9—Petroleum Refining (40 CFR Part 419)
5.9 Petroleum Refining (40 CFR Part 419)
During the 2011 Annual Review, EPA selected the Petroleum Refining Category (40
CFR Part 419) for a preliminary review because it ranked high, in terms of toxic-weighted pound
equivalents (TWPE) (U.S. EPA, 2012). At that time, EPA found that the TWPE was largely due
to Toxics Release Inventory (TRI) reported discharges of dioxin and dioxin-like compounds,
polycyclic aromatic compounds (PACs), and discharge monitoring report (DMR) reported
discharges of sulfides, chlorine, and metals. EPA continued to review this category during the
2012 Annual Review to verify facilities' discharges and confirmed the 2011 Annual Review
results. EPA also reviewed new air pollution control regulations to identify whether the
regulations could result in new wastewater streams. EPA now plans to conduct a more detailed
study of this industry to further investigate the findings from the 2011 and 2012 Annual
Reviews.
The effluent limitations guidelines and standards (ELGs) for petroleum refining (40 CFR
Part 419) were promulgated in 1982. EPA established Best Practicable Control Technology
(BPT), Best Available Technology Economically Achievable (BAT), and New Source
Performance Standards (NSPS) production-based mass limitations for the following pollutants:
• Ammonia as nitrogen;
• Biochemical oxygen demand;
• Chemical oxygen demand (or total organic compounds for high-chloride
effluents);
• Hexavalent chromium;
• Oil and grease;
pH;
• Phenolic compounds;
• Sulfide;
• Total chromium; and
• Total suspended solids.
As shown in the list above, only one metal (chromium) is currently regulated. EPA has
not revised the ELGs since 1982, but has subsequently reviewed annual discharge data from
2004 to 2011. Table 5-1 compares the toxicity rankings analysis results for the Petroleum
Refining Category from the 2011 and 2013 Annual Reviews.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.9—Petroleum Refining (40 CFR Part 419)
Table 5-70. Petroleum Refining Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews
Year of
Discharge
2009
2011
Year of
Review
2011
2013
Petroleum Refining Category Facility
Counts
Total TRI
Facilities
280
274
Total DMR
Major
Facilities
96
91
Total DMR
Minor
Facilities"
153
172
Petroleum Refining Category TWPE
TRI TWPEb
436,000
681,000
DMR
TWPEC
260,000
752,000
Total TWPE
697,000
1,430,000
Sources: 2011 Annual Review Report (for 2009 DMR and TRI TWPE) (U.S. EPA, 2012); DMRLTOutput2011_vl
(for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR or TRI data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to publicly owned treatment works (POTWs).
Transfers to POTWs account for POTW removals.
0 DMR discharges from both minor and major facilities.
Table 5-71 presents the top five pollutants with the highest contribution to the 2011 DMR
TWPE and Table 5-72 presents the top five pollutants with the highest contribution to the 2011
TRI TWPE. In addition, as a point of comparison, Table 5-71 and Table 5-72 show the 2009
DMR and TRI TWPE, respectively, for the top five pollutants based on the results of (and
corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). As shown in the tables,
organic compounds, such as dioxin and dioxin-like compounds and PACs, rank high in both the
2011 DMR and TRI pollutants. Mercury and mercury compounds also rank high. EPA did not
review the facility-specific discharges for this industry during the 2013 Annual Review because
EPA plans to conduct a more detailed study of this industry in 2014. As a result, some of the
TWPE may be attributed to data errors.
Table 5-71. Petroleum Refining Category Top DMR Pollutants
Pollutant
Indeno( 1 ,2,3 -cd)pyreneb
2,3,7,8-tetrachlorodibenzo-p-dioxin
Methylmercury
Sulfide
Total Residual Chlorine
Top Pollutant Total
Petroleum Refining Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
6
1
5
63
21
NA
263C
TWPE
280,000
219,000
77,300
62,400
37,200
676,000
752,000
2009 DMR Data3
TWPE
256
0.329
306
136,000
11,300
148,000
261,000
Sources: DMRLTOutput2011_vl (for 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) (U.S.
EPA, 2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a DMR data include major and minor dischargers.
b Indeno(l,2,3-cd)pyrene is a PAC.
0 Number of facilities reporting TWPE greater than zero.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.9—Petroleum Refining (40 CFR Part 419)
Table 5-72. Petroleum Refining Category Top TRI Pollutants
Pollutant
Dioxin and Dioxin-Like Compounds
Mercury And Mercury Compounds
Pacs
Hexachlorobenzene
Nitrate Compounds
Top Pollutant Total
Petroleum Refining Category Total
2011 TRI Data
Number of Facilities
Reporting Pollutant
18
69
68
1
64
NA
274a
TWPE
435,000
118,000
42,700
23,400
16,700
636,000
681,000
2009 TRI Data
TWPE
315,000
22,600
35,000
0
14,600
387,000
436,000
Sources: TRILTOutput2011_vl (for 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE) (U.S. EPA,
2012).
Note: Sums of individual values may not equal the total presented, due to rounding.
NA: Not applicable.
a Number of facilities reporting TWPE greater than zero.
EPA conducted a detailed study of this industry as part of the 2004 Final Effluent
Guidelines Program Plan reviews (U.S. EPA, 2004). However, the industry has since changed.
Refineries are processing heavier feedstocks (e.g., Canadian crude, tar sands), which may be a
source of the increased metals in the discharges. In addition, changes in air pollution control
regulations may have increased the use of wet scrubbers to control air emissions. EPA revised
NSPS for petroleum refineries in 2012 (40 CFR 60 Subparts J and Ja) and issued National
Emission Standards for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming
Units, and Sulfur Recovery Units on April 11, 2002 (amended February 9, 2005) (40 CFR 63
Subpart UUU). These revised air regulations may be another reason why petroleum refinery
discharges are showing higher levels of metals. EPA needs to study this further.
As part of the 2011 and 2012 Petroleum Refining Annual Reviews, EPA (U.S. EPA,
2012, 2014) found that:
• The catalytic reforming process may form dioxin and dioxin-like compounds.
• Discharges of metal pollutants are increasing.
As shown in Table 5-73, the number of facilities reporting non-zero metals TWPE
increased and the DMR metals discharges doubled from 2000 to 2009.
Table 5-73. Petroleum Refining Metals DMR Discharges
Year of Discharge
2000
2009
Number of Facilities
Reporting Metals"
104
253
Number of Facilities Reporting
Non-Zero TWPEa
77
117
Total Metal TWPE
30,100
66,300
Sources: 2011 Annual Review Report, Tables 19-12 and 19-13 (U.S. EPA, 2012).
a Includes all facilities reporting metals discharges.
5-77
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Section 5—EPA's 2013 Preliminary Category Reviews
5.9—Petroleum Refining (40 CFR Part 419)
In addition to the refinery-specific findings, EPA has been collecting data on new
treatment technologies to evaluate if new technologies demonstrate better performance than
technologies used as the basis for existing ELGs from 1982.
In summary, EPA plans to conduct the study of this industry to determine if changes to
the existing ELGs are needed because:
• Recent changes to the industry may have resulted in new wastestreams or
wastewater characteristics.
• EPA has observed an increase in metals discharges.
• EPA has observed an increase in the number of refineries reporting metals
discharges.
• Only one metal (chromium) was included in the current Petroleum Refining
ELGs.
As part of the preliminary study, EPA plans to:
• Collect updated industry profile information to identify refineries that:
— Use catalytic reforming;
— Process heavy crude; and
— Installed new air pollution control equipment that generates wastewater.
• Continue to analyze trends in DMR and TRI data to identify pollutants of interest.
• Review data from other EPA and government programs, or industry sources (e.g.,
Office of Air and Radiation, Department of Energy's Energy Information
Administration, Oil and Gas Journal).
• Review information on new treatment technologies to determine if they can
remove pollutants in petroleum wastewater to a better degree than the technology
upon which the current ELG was based.
EPA will use the study to identify:
• Additional data needs for this industry, including information on its economics
and potential environmental impacts of current discharges.
• Pollutants in petroleum refining wastewater that may not be included in permits
and may warrant further study.
• Treatment technologies that more effectively remove pollutants from petroleum
wastewater.
Pending the preliminary study's findings, EPA may collect additional data through permit and
permit application reviews, site visits, or other methods.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.9—Petroleum Refining (40 CFR Part 419)
5.9.1 References for Petroleu m Refining Category
1. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
2. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
3. U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C.
(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824. DCN 07756.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
5.10 Pulp, Paper, and Paperboard (40 CFR Part 430)
EPA identified the Pulp, Paper, and Paperboard (Pulp and Paper) Category (40 CFR Part
430) for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalents (TWPE), in point source category rankings. EPA previously reviewed discharges
from pulp and paper facilities as part of the Preliminary and Final Effluent Guidelines Program
Plans in 2004-2011 (U.S. EPA, 2004a, 2006a, 2007, 2008, 2009a, 2011, 2012). During its 2006
Final Effluent Guidelines Program Plan reviews, EPA also conducted a detailed study of this
industry (U.S. EPA, 2006b). This section summarizes the results of the 2013 Annual Review
associated with the Pulp and Paper Category.
The estimated toxicity of the Pulp and Paper Category discharges resulted from discharge
monitoring report (DMR)-reported discharges of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
and sulfide, and Toxics Release Inventory (TRI)-reported discharges of dioxin and dioxin-like
compounds and manganese and manganese compounds. Sulfide, dioxin and dioxin-like
compounds, and manganese and manganese-like compounds, reviewed as part of the 2011
Annual Review, continue to be top pollutants of concern. For the 2013 Annual Review, 2011
DMR data also showed significant contributions of TCDD to the Pulp and Paper Category
TWPE.
5.10.1 Pulp and Paper Category 2013 Toxicity Rankings Analysis
Table 5-74 compares the toxicity rankings analysis (TRA) results for the Pulp and Paper
Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but
instead reviewed additional data sources as part of the even-year annual review as discussed in
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plan (U.S. EPA, 2014a). As
discussed in this section, EPA's review of the Pulp and Paper Category identified a data error
that affected the 2011 DMR data and TWPE. The bottom row of Table 5-74 shows the corrected
data resulting from this review.
Table 5-74. Pulp and Paper Category TRI and DMR Facility Counts and Discharges for
2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
Pulp and Paper Category Facility Counts
Total of TRI
Facilities
250
219
Total DMR
Major
Facilities
137
130
Total DMR
Minor
Facilities"
20
24
Pulp and Paper Category TWPE
TRI TWPEb
1,080,000
651,000
651,000
DMR
TWPEC
260,000
1,020,000
576,000
Total
1,340,000
1,670,000
1,230,000
Sources: 2011 Annual Review Report (for 200
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
As shown in Table 5-74, the number of facilities in TRI and the number of major DMR
facilities decreased from 2009 to 2011, while the number of minor DMR facilities increased.
During that period, the TRI TWPE has decreased, while the DMR TWPE has increased.
5.10.2 Pulp and Paper Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the Pulp and Paper Category focused on
the 2011 TRI and DMR discharges because both contribute to the category's combined TWPE.
Table 5-75 compares the five pollutants with the highest contribution to the 2011 DMR TWPE.
For comparison, it also shows the 2009 DMR TWPE for these top five pollutants based on the
results of (and corrections identified in) the 2011 Annual Review (U.S. EPA, 2012). Table 5-75
also presents the 2011 DMR TWPE after EPA corrected an error identified in this preliminary
category review (discussed in the sections below). TCDD and sulfide contribute more than 85
percent of the total 2011 DMR TWPE. EPA's investigations of the top two DMR pollutants are
presented in Sections 5.10.3 and 5.10.4. EPA did not investigate the other top DMR pollutants as
part of the 2013 Annual Review, including 2,3,7,8-tetrachlorodibenzofuran, aluminum, and
mercury because they represent less than 11 percent of the total DMR TWPE for the Pulp and
Paper Category.
Table 5-75 compares the five pollutants with the highest contribution to the 2011 TRI
TWPE. In addition, as a point of comparison, Table 5-3 shows the 2009 TRI TWPE for these
top five pollutants based on the results of (and corrections identified in) the 2011 Annual Review
(U.S. EPA, 2012). Manganese and manganese compounds and dioxin and dioxin-like
compounds contribute more than 77 percent of the total 2011 TRI TWPE. EPA's investigations
of the top two TRI pollutants are presented in Sections 5.10.3 and 5.10.5. EPA did not
investigate the other top TRI pollutants as part of the 2013 Annual Review, including mercury,
lead, and polycyclic aromatic compounds (PACs) for TRI, because they represent less than 18
percent of the total TRI TWPE for the Pulp and Paper Category.
Table 5-75. Pulp and Paper Category Top DMR Pollutants
Pollutant
TCDD
Sulfide
2,3 ,7,8-tetrachlorodibenzofuran
Aluminum
Mercury
Top Pollutant Total
Pulp and Paper Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
6
2
5
30
25
NA
147C
Original
TWPE
626,000
241,000
67,600
26,900
20,300
982,000
1,020,000
Corrected
TWPE
183,000
241,000
67,600b
26,900b
20,300b
539,000
576,000
2009 DMR Data3
TWPE
26,100
147,000
1,260
36,100
10,100
221,000
260,000
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012).
NA: Not applicable.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR data include major and minor dischargers.
b 2,3,7,8-tetrachlorodibenzofuran, aluminum, and mercury discharges combined contribute less than 11 percent of
the 2011 category TWPE. Therefore, EPA did not review these discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-76. Pulp and Paper Category Top TRI Pollutants
Pollutant
Manganese and manganese compounds
Dioxin and dioxin-like compounds
Mercury and mercury compounds
Lead and lead compounds
PACs
Top Pollutant Total
Pulp and Paper Category Total
2011 TRI Data
Number of Facilities
Reporting Pollutant
104
38
81
157
21
NA
221C
Original
TWPE
266,000
238,000
52,700
48,000
14,000
619,000
651,000
Corrected
TWPEa
266,000
238,000
52,700b
48,000b
14,000b
619,000
651,000
2009 TRI Data
TWPE
298,000
613,000
16,300
61,100
15,900
1,000,000
1,080,000
Sources: TRILTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 TRI TWPE)
(U.S. EPA, 2012).
NA: Not applicable.
Note: Sums of individual values may not equal the total presented, due to rounding.
a EPA reviewed the 2011 TRI manganese and manganese compound and dioxin and dioxin-like compound
discharges but determined that no data corrections were needed. Therefore, the corrected TWPE for these pollutants
matches the original TWPE.
b Mercury, lead, and PAC discharges combined contribute less than 18 percent of the 2011 category TWPE.
Therefore, EPA did not review these discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
5.10.3 Pulp and Paper Category Dioxin Discharges in DMR and TRI
EPA reviewed 2011 DMR and TRI data on dioxin and dioxin-like compounds from pulp
and paper mills for the 2013 Annual Review. EPA's investigation of the 2011 DMR dioxin data
revealed that one facility, Rayonier Performance Fibers (Rayonier), in Jesup, GA, accounts for
71 percent of the 2011 DMR TCDD18 discharges (shown in Table 5-77). EPA did not investigate
the remaining facilities discharging TCDD.
Table 5-77. Top 2011 DMR TCDD Discharging Facilities
Facility Name
Rayonier Performance Fibers
Facility Location
Jesup, GA
Remaining Facilities Reporting TCDD Discharges3
Total
Pounds of
Pollutant
Discharged
0.000629
0.00026
0.000889
Pollutant
TWPE
443,000
183,000
626,000
Facility Percent of
Category TWPE
71%
29%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are five remaining facilities that have TCDD discharges in the 2011 DMR data.
EPA's investigation of the 2011 TRI dioxin and dioxin-like compounds discharges
revealed that four facilities account for 74 percent of the dioxin and dioxin-like compound
18 TCDD is a dioxin compound. Facilities can submit DMR data for individual dioxin compounds. In TRI, facilities
report dioxin compounds as the group of dioxin and dioxin-like compounds.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
discharges (shown in Table 5-78). EPA did not investigate the remaining facilities discharging
dioxin and dioxin-like compounds.
Table 5-78. Top 2011 TRI Dioxin and Dioxin-Like Compound Discharging Facilities
Facility Name
Kimberly-Clark Worldwide
SD Warren Co.
Rayonier Performance Fibers LLC
Simpson Tacoma Kraft Co. LLC
Facility Location
Everett, WA
Skowhegan, ME
Fernandina Beach, FL
Tacoma, WA
Remaining Facilities Reporting Dioxin and Dioxin-Like
Compound Discharges3
Total
Pounds of
Pollutant
Discharged
0.00101
0.000366
0.0162
0.00174
0.0766
0.0959
Pollutant
TWPE
67,700
42,200
38,900
27,100
61,800
238,000
Facility Percent of
Category TWPE
28%
18%
16%
11%
26%
100%
Source: TRILTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 34 remaining facilities that have dioxin and dioxin-like compound discharges in the 2011 TRI data.
Rayonier Performance Fibers, Jesup, GA
Rayonier in Jesup, GA, is the top 2011 DMR TCDD discharger. The facility discharges
TCDD from outfall OAO. As part of the 2013 Annual Review, EPA contacted Rayonier about the
facility's TCDD discharges. Rayonier stated that the TCDD discharges were measured at levels
below the detection limit (BDL). Rayonier confirmed that the BDL indicators for the TCDD
discharges were not properly marked on the 2011 DMR (Mooney, 2014). As described in
Section 3.2.2.2 in EPA's Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories (2009 Screening-Level
Analysis (SLA) Report), EPA zeros the load when all concentrations of a specific pollutant are
BDL for all monitoring periods (U.S. EPA, 2009b). Therefore, EPA zeroed Rayonier's
discharges, which decreases the 2011 DMR TCDD TWPE for the Pulp and Paper category from
626,000 to 183,000, as shown in Table 5-75.
Kimberly-Clark
EPA reviewed the TRI dioxin and dioxin-like compound discharges from Kimberly-
Clark in Everett, WA, as part of the 2011 and 2012 Annual Reviews. EPA determined that the
mill calculated its dioxin and dioxin-like compound releases using mass balances using historical
congener data, not actual discharge measurements. In addition, this mill shut down in April 2012
(U.S. EPA, 2012, 2014b). For these reasons, Kimberly-Clark's dioxin and dioxin-like compound
discharges do not represent discharges across the Pulp and Paper Category.
SD Warren Co.
As part of the 2011 and 2012 Annual Reviews, EPA reviewed the TRI dioxin and dioxin-
like compound discharges from SD Warren Co. From these earlier reviews, EPA determined that
the mill calculated its dioxin and dioxin-like compound releases using May 2002 final effluent
sampling data, corrected for the annual flow and the naturally occurring congeners contained in
the mill's receiving water, pulp wood, and kaolin clay (U.S. EPA, 2012). In 2009, EPA also
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
determined that the mill's dioxin and dioxin-like compound discharges, measured in May 2002,
were less than EPA's Method 1613 Minimum Levels (MLs) (U.S. EPA, 2014b). EPA previously
concluded that concentrations below the MLs may not be accurate, and the measurements may
not accurately reflect industry discharges.
During the 2013 Annual Review, to verify SD Warren Co.'s reported 2011 TRI dioxin
and dioxin-like compound discharges, EPA contacted the American Forest and Paper
Association (AF&PA) and NCASI. AF&PA is the national trade association of the forest, pulp,
paper, paperboard, and wood products industry. NCASI is a nonprofit research institute funded
by North American forest products industry, including pulp and paper facilities. AF&PA
confirmed with the mill that the 2011 dioxin and dioxin-like compound discharges reported to
TRI were correct and stated that the mill continues to follow the same TRI calculation
methodology discussed in the 2011 and 2012 Annual Review Reports (Schwartz, 2013). EPA
observed that the mill's reported TRI dioxin and dioxin-like compound TWPEs were similar in
magnitude in 2011 (42,200) and 2009 (37,900). For these reasons, EPA concluded that SD
Warren Co.'s dioxin and dioxin-like compound discharges are not a hazard priority at this time.
Royonier Performance Fibers, Fernandina Beach, FL
EPA reviewed TRI dioxin and dioxin-like compound discharges from Rayonier
Performance Fibers (Rayonier) in Fernandina Beach, FL, as part of the 2011 and 2012 Annual
Reviews. From these earlier reviews, EPA confirmed that the mill bases its reported dioxin and
dioxin-like compound discharges on quarterly measurements (U.S. EPA, 2012). Rayonier
reported that they detected seven dioxin congeners19 in their effluent wastewater in 2009. Two of
these congeners, 1,2,3,4,6,7,8,9-OCDD and 2,3,7,8-TCDF, were detected above EPA's Method
1613 MLs; however, in its 2012 Annual Review, EPA concluded that the concentrations are low
and that the discharges do not warrant further review (U.S. EPA, 2014b).
Rayonier reported to TRI that it released five dioxin congeners in its wastewater
discharges in 2011.20 As part of the 2013 Annual Review, EPA contacted AF&PA and NCASI
about the mill's 2011 dioxin and dioxin-like compound discharges. NCASI confirmed with the
mill that the 2011 dioxin and dioxin-like compound discharges reported to TRI were correct and
stated that the same calculation methodology is used (Schwartz, 2013). As in the 2009 data, in
2011 Rayonier reported detecting two congeners, 1,2,3,4,6,7,8,9-OCDD and 2,3,7,8-TCDF,
above EPA's Method 1613 MLs. Further, the 2011 TWPE (38,900) is similar in magnitude to the
2009 TWPE (37,800). Therefore, EPA concluded that the dioxin and dioxin-like compound
discharges from Rayonier are not a hazard priority at this time.
Simpson Tacoma Kraft Co. LLC
EPA reviewed TRI dioxin and dioxin-like compound discharges from Simpson Tacoma
Kraft Co, LLC (Simpson Tacoma), in Tacoma, WA, as part of the 2011 and 2012 Annual
Reviews. These earlier reviews demonstrated that Simpson Tacoma based its reported dioxin and
19 Rayonier detected concentrations of 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; 2,3,4,7,8-PeCDF; 1,2,3,4,6,7,8-HpCDF; and 1,2,3,4,6,7,8,9-OCDF in 2009. See Section 5.3.2 in the 2012
Annual Review Report (U.S.EPA, 2014b).
20 Rayonier detected concentrations of 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8,9-OCDD; 2,3,7,8-TCDF; 1,2,3,4,6,7,8-
HpCDF; and 1,2,3,4,6,7,8,9-OCDF in 2011.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
dioxin-like compound releases on full congener testing sampled annually and detected dioxin
congeners in the effluent wastewater are below EPA's Method 1613B ML (U.S. EPA, 2012,
2014b).
As part of the 2013 Annual Review, EPA contacted AF&PA and NCASI about the mill's
2011 dioxin and dioxin-like compound discharges. AF&PA confirmed with the mill that the
2011 dioxin and dioxin-like compound discharges reported to TRI were correct and provided
results of Simpson Tacoma's analysis of 2011 and 2012 wastewater discharges (Schwartz, 2013).
Table 5-79 presents the results of the 2011 and 2012 analyses provided by the mill. As shown, all
measured concentrations are below EPA's Method 1613B MLs. Therefore, EPA concludes that
the dioxin and dioxin-like compound discharges from Simpson Tacoma do not warrant further
review at this time.
Table 5-79. 2011 and 2012 Concentrations of Dioxin and Dioxin-Like Compounds from
Simpson Tacoma (pg/L) and EPA Method 1613B Minimum Levels
Congener
1613B ML (pg/L)
2011 Average
Concentration (pg/L)
2012 Average
Concentration (pg/L)
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
0.385
0.454
0.5
Oa
0.347
0.351
Oa
0.92
Oa
1.05
Oa
0.35
Oa
0.42
0.42
Oa
Oa
1.01
oa
1.01
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
Oa
0.258
Oa
0.418
0.175
4.01
23.7
oa
0.4
Oa
0.92
Oa
14.0
39.8
Source: Schwartz, 2013.
ML: Minimum level established for EPA Method 1613B (U.S. EPA, 2004b).
a Simpson Tacoma did not include reporting limits for any congeners but stated that all zero values were BDL
(Schwartz, 2013).
5.10.4 Pulp and Paper Category Sulfide Discharges in DMR
EPA's investigation of the sulfide discharge revealed that one facility, Smurfit-Stone
Container (Smurfit-Stone), in Florence, SC, accounts for 97 percent of the 2011 DMR sulfide
discharges (shown in Table 5-80). Because the Smurfit-Stone mill dominated the reported
discharges, EPA did not investigate the remaining facility discharging sulfide.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-80. Top 2011 DMR Sulfide Discharging Facilities
Facility Name
Smurfit-Stone Container
Domtar - Johnsonburg Mill
Facility Location
Florence, SC
Johnsonburg, PA
Total
Pounds of Pollutant
Discharged
83,500
2,590
86,100
Pollutant
TWPE
234,000
7,250
241,000
Facility Percent of
Category TWPE
97%
3%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
Smurfit-Stone discharges sulfide from outfall 001. EPA reviewed the mill's sulfide
discharges as part of the 2011 Annual Review and contacted AF&PA about the sulfide
discharges. The mill's permit includes monitoring and reporting requirements for sulfide, but
there are no numeric sulfide discharge limits. The Pulp and Paper Category effluent limitations
guidelines and standards do not regulate sulfide (U.S. EPA, 2012).
The mill's kraft pulping process uses sodium-based alkaline pulping solution (liquor)
which consists of sodium sulfide and sodium hydroxide in 10 percent solution. This is the
primary source of sulfides in the wastewater. Smurfit-Stone's permit states that sulfide
discharges from the facility have a reasonable potential to exceed water quality criteria for
aquatic life; therefore, monitoring and reporting requirements for sulfide were added to the
permit (SCDHEC, 2006). EPA determined in the 2011 Annual Review that the mill's sulfide
concentrations range from <0.38 to 4 milligrams per liter and are below or near treatable levels.
Therefore, the mill's sulfide discharges did not warrant further review (U.S. EPA, 2012).
As part of the 2013 Annual Review, EPA contacted AF&PA about Smurfit-Stone's 2011
DMR sulfide discharges. AF&PA confirmed with the mill that these discharges were correct and
stated that sulfide measurements for January and February 2011 appear to be anomalies, which
skew the average sulfide concentration for 2011. The mill reviewed its DMR sulfide data from
2009 to 2013, determining that the January and February 2011 concentrations are anomalies and
that the sulfide concentrations in the effluent are decreasing. Figure 5-1 presents the downward
trend of sulfide concentrations for years 2009 to 2013.The mill contact also explained that no
process changes have occurred that would affect the source of sulfide at the mill (Schwartz,
2014a). For these reasons, EPA concluded that the sulfide discharges from Smurfit-Stone do not
warrant further review at this time.
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5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
Date
Source: Schwartz, 2014b.
Note: Non-detects are shown at half of non-detect value.
Figure 5-1. 2009-2013 Sulfide Concentrations for Smurfit-Stone Mill
5.10.5 Pulp and Paper Category Manganese and Manganese Compound Discharges in TRI
Manganese and manganese compound discharges account for 41 percent of the total 2011
TRI TWPE. In 2011, 104 facilities reported discharges of manganese and manganese compounds
to TRI; no facility accounts for more than 6 percent of the TWPE. EPA reviewed the TRI
manganese and manganese compound discharges for the Pulp and Paper Category as part of the
2011 Annual Review and confirmed its previous conclusions from the Pulp and Paper Detailed
Study: manganese and manganese compound discharges in this category are below treatable
levels (U.S. EPA, 2006b, 2012).
Table 5-81 presents the manganese and manganese compound discharges in TRI and
DMR from 2002 to 2011. As shown, 2011 manganese and manganese compound discharges are
similar to those in previous years. Therefore, EPA continues to conclude that manganese and
manganese compound discharges in the Pulp and Paper Category are below treatable levels.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-81. 2002-2011 Manganese and Manganese Compound Discharges in TRI and
DMR
Discharge Year
2002
2004
2007
2008
2009
2011
Review Year
2006
2007
2009
2010
2011
2013
TRI Data
Number of
Dischargers
112
117
79
117
115
104
Total TWPE
304,000
316,000
231,000
308,000
298,000
266,000
DMR Data
Number of
Dischargers
4
5
5
o
J
o
J
5
Total TWPE
287
5,190
3,210
3,040
2,960
522
Sources: TRIReleases2002; PCSLoads2002; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; DMRLoads2009_v2;
DMRLTOutput201 l_vl; TRILTOutput201 l_vl.
5.10.6 Pulp and Paper Category Findings
The estimated toxicity of the Pulp and Paper Category discharges resulted from DMR-
reported discharges of dioxin (TCDD) and sulfide, and TRI-reported discharges of dioxin and
dioxin-like compounds and manganese and manganese compounds. In the 2013 Annual Review,
EPA has identified the following:
• One facility, Rayonier Performance Fibers in Jesup, GA, accounts for 71 percent
of the category's DMR TCDD discharges. The facility contact confirmed that
BDL indicators were not properly marked on the DMR. Because all TCDD
discharges were non-detect, EPA zeroed the TCDD load and TWPE for Rayonier,
which decreased the 2011 TCDD Pulp and Paper Category TWPE from 626,000
to 183,000.
• Four facilities account for 74 percent of the category's TRI dioxin and dioxin-like
compound discharges. EPA previously reviewed these facilities as part of the
2011 and 2012 Annual Reviews. One of them, Kimberly-Clark in Everett, WA,
shut down in 2012. For the other three facilities, EPA determined that 2011 dioxin
and dioxin-like compound discharges are either below or near EPA Method 1613
MLs and are similar to 2009 dioxin and dioxin-like compound discharges.
Accordingly, dioxin and dioxin-like compound discharges do not warrant further
review at this time.
• One facility, Smurfit-Stone in Florence, SC, accounts for 97 percent of the
category's DMR sulfide discharges. EPA determined that the January and
February 2011 sulfide concentrations for Smurfit-Stone were anomalies and
skewed the 2011 total sulfide discharge. The sulfide concentrations have since
decreased over time. Therefore, further review of the facility's sulfide discharges
is not warranted at this time.
• In 2011, 104 facilities reported discharges of manganese and manganese
compounds to TRI. No facility accounts for more than 6 percent of the TWPE.
EPA's 2011 Annual Review and 2006 Detailed Study determined that manganese
5-8
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
and manganese compound concentrations in pulp and paper mill discharges were
below treatable levels, which is still true for the 2013 Annual Review.
• EPA corrected errors for discharges reported by one mill. This decreases the 2011
Pulp and Paper Category TWPE from 1,670,000 to 1,230,000. EPA reviewed
discharges reported by five other mills, but made no corrections. For these mills,
EPA either determined that discharges were anomalies for the 2011 reporting year
or are below method MLs or treatable levels and a category-wide discharge issue,
warranting an effluent guidelines revision, is not apparent.
5.10.7 References for Pulp and Paper Category
1. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 430 - Pulp and Paper. (March). EPA-HQ-OW-
2014-0170. DCN 07932.
2. Mooney, Brian. 2014. Telephone and Email Communication Between Brian Mooney,
Rayonier Performance Fibers, Jesup Mill, and Kimberly Bartell, Eastern Research Group,
Inc., Re: 2011 DMR Clarification for TCDD Discharges. (January). EPA-HQ-OW-2014-
0170. DCN 07927.
3. SCDHEC. 2006. South Carolina Department of Health and Environmental Control.
NPDES Permit: Smurfit-Stone Container Enterprises, Inc., Florence, SC. (August 29).
EPA-HQ-OW-2014-0170. DCN 07928.
4. Schwartz, Jerry, and Paul Wiegand. 2013.Telephone and Email Communication Between
Jerry Schwartz, American Forest and Paper Association, Paul Wiegand, National Council
for Air and Stream Improvement, and Kimberly Bartell, Eastern Research Group, Inc.,
Re: 2011 TRIPulp and Paper Dioxin Dischargers. (March). EPA-HQ-OW-2014-0170.
DCN 07929.
5. Schwartz, Jerry. 2014a. Email Communication Between Jerry Schwartz, American Forest
and Paper Association, and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011
DMR Sulfide Discharges. (February). EPA-HQ-OW-2014-0170. DCN 07930.
6. Schwartz, Jerry. 2014b. Sulfide Data Chart for Smurfit-Stone Enterprises, Florence, SC -
SC000876 from Jerry Schwartz, American Forest and Paper Association. (January).
EPA-HQ-OW-2014-0170. DCN 07931.
7. U.S. EPA. 2004a. Technical Support Document for the 2004 Effluent Guidelines
Program Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-
0074-1346 through 1352.
8. U.S. EPA. 2004b. Method 1613B: Tetra- Through Octa-Chlorinated Dioxins and Furans
by Isotope Dilution HRGC/HRMS. Washington, D.C. (October). EPA-HQ-OW-2004-
0032-2653.
9. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines
Program Plan. Washington, D.C. (December). EPA-821-R-06-018. EPA-HQ-OW-2004-
0032-2782.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.10—Pulp, Paper, and Paperboard (40 CFR Part 430)
10. U.S. EPA. 2006b. Final Report: Pulp, Paper, and Paperboard Detailed Study .
Washington, D.C. (December). EPA-821-R-06-016. EPA-HQ-OW-2004-0032-2249.
11. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-07-007. EPA-HQ-
OW-2006-0771-0819.
12. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-08-015. EPA-HQ-OW-2006-0771-1701.
13. U. S. EPA. 2009a. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. Washington, D.C. (October). EPA-821-R-09-006. EPA-HQ-
OW-2008-05 17-05 15.
14. U.S. EPA. 2009b. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories. EPA-
821-R-09-007. Washington, DC. (October). EPA-HQ-OW-2008-05 17-05 15.
15. U. S. EPA. 20 1 1 . Technical Support Document for the 2010 Effluent Guidelines Program
Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-05 17. DCN
07320.
16. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-20 10-0824-0 195.
17. U.S. EPA. 2Q14&. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R- 14-001. EPA-HQ-OW-20 14-0 170. DCN
07756.
18. U.S. EPA. 2014b. The 2012 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-20 10-0824. DCN 07933.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
5.11 Timber Products Processing (40 CFR Part 429)
EPA selected the Timber Products Processing (Timber Products) Category for
preliminary review because it ranks high, in terms of toxic-weighted pound equivalents (TWPE),
in the point source category rankings. EPA reviewed discharges from the Timber Products
Category as part of the 2004 and 2011 Annual Reviews (U.S. EPA, 2004, 2012). This section
summarizes the results of the 2013 Annual Review associated with the Timber Products
Category. EPA focused on discharges of chlorine, copper, and arsenic from discharge monitoring
reports (DMR) because of their high TWPE relative to the other pollutants in the Timber
Products Category. Copper, reviewed as part of the 2011 Annual Review, continues to be a top
pollutant of concern. For the 2013 Annual Review, available discharge data also showed
significant contributions of chlorine and arsenic to the Timber Products Category TWPE.
5.11.1 Timber Products Category 2013 Toxicity Rankings Analysis
Table 5-82 compares the toxicity rankings analysis (TRA) results for the Timber Products
Category from the 2011 and 2013 Annual Reviews. EPA did not conduct the TRA in 2012, but
instead reviewed additional data sources as part of the even-year annual review as discussed in
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014). As
discussed in this section, EPA's review of the Timber Products Category identified several data
errors that affected the 2011 DMR data and TWPE. The bottom row of Table 5-82 shows the
corrected data resulting from this review.
Table 5-82. Timber Products Category TRI and DMR Facility Counts and Discharges
for the 2011 and 2013 Annual Reviews
Year of
Discharge
2009d
2011
2011e
Year of
Review
2011
2013
2013
Timber Category Facility Counts
Total TRI
Facilities
101
102
Total DMR
Major
Facilities
1
2
Total DMR
Minor
Facilities"
54
80
Timber Category TWPE
TRI
TWPEb
22,700
32,300
32,300
DMR
TWPEC
11,800
99,600
72,800
Total
TWPE
34,500
132,000
105,000
Sources: 2011 Annual Review Report (for 20091JDMR and Toxics Release Inventory (TRI) TWPE) (U.S. EPA,
2012); DMRLTOutput2011_vl (for 2011 DMR); TRILTOutput2011_vl (for 2011 TRI).
Note: EPA did not evaluate DMR data for 2010.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR minor facilities report pollutant discharges that contribute to the total DMR TWPE.
b Discharges include direct discharges to surface waters and transfers to POTWs. Transfers to POTWs account for
POTW removals.
0 DMR discharges from both minor and major facilities.
d 2009 data after corrections made during the 2011 Annual Review.
e 2011 data after corrections made during the 2013 Annual Review.
As shown in Table 5-82, the total TWPE (incorporating data corrections) increased from
2009 to 2011. During that period, the number of TRI and major and minor DMR facilities
increased.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
5.11.2 Timber Products Category Pollutants of Concern
For its 2013 Annual Review, EPA's review of the Timber Products Category focused on
the 2011 DMR discharges because the 2011 DMR data dominate the category's combined
TWPE. Table 5-83 compares the five pollutants with the highest contribution to the 2011 DMR
TWPE. It also presents the 2011 DMR TWPE after EPA corrected errors identified in this
preliminary category review (discussed in the sections below). For comparison, it also shows the
2009 DMR TWPE for these top five pollutants based on the results of (and corrections identified
in) the 2011 Annual Review (U.S. EPA, 2012).
Total residual chlorine, copper, and arsenic contribute more than 93 percent of the total
2011 DMR TWPE. EPA's investigations of reported discharges of the top three pollutants are
presented in Sections 5.11.3 to 5.11.5. EPA did not investigate the other pollutants as part of the
2013 Annual Review, including pentachlorophenol and iron, because they represent less than 7
percent of the 2011 DMR TWPE for the Timber Products Category.
Table 5-83. Timber Products Category Top DMR Pollutants
Pollutant
Total residual chlorine
Copper
Arsenic
Pentachlorophenol
Iron
Top Pollutant Total
Timber Products Category Total
2011 DMR Data3
Number of Facilities
Reporting Pollutant
9
39
27
10
9
NA
82C
Original
TWPE
60,800
16,500
15,600
2,190
1,100
96,200
99,600
Corrected
TWPE
60,800
2,150
3,190
2,190b
l,100b
69,400
72,800
2009 DMR Data3
TWPE
155
300
336
238
7,930
8,960
11,800
Sources: DMRLTOutput2011_vl (for Original 2011 TWPE); 2011 Annual Review Report (for 2009 DMR TWPE)
(U.S. EPA, 2012).
NA: Not applicable.
Note: Sums of individual values may not equal the total presented, due to rounding.
a DMR data include major and minor dischargers.
b Pentachlorophenol and iron discharges combined contribute less than 3 percent of the 2011 category DMR TWPE.
Therefore, EPA did not review pentachlorophenol or iron discharges as part of the 2013 Annual Review.
0 Number of facilities reporting TWPE greater than zero.
5.11.3 Timber Products Category Total Residual Chlorine Discharges in DMR
EPA's investigation of the total residual chlorine discharges revealed that Cahaba Timber
Co. (Cahaba Timber), in Brierfield, AL, accounts for greater than 99 percent of the 2011 DMR
chlorine discharges (shown in Table 5-84). EPA did not investigate the remaining facilities
discharging total residual chlorine.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
Table 5-84. Top 2011 DMR Total Residual Chlorine Discharging Facilities
Facility Name
Cahaba Timber Co.
Facility Location
Brierfield, AL
All Other Chlorine Dischargers in the Timber Products
Category3
Total
Pounds of
Pollutant
Discharged
121,000
274
122,000
Pollutant
TWPE
60,600
137
60,800
Facility Percent of
Category TWPE
>99%
<1%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are eight remaining facilities that have total residual chlorine dischargers in the 2011 DMR data.
Cahaba Timber discharges total residual chlorine through five outfalls. The facility
performs wood preserving operations, mainly for poles (e.g., telephone poles). As part of the
2013 Annual Review, EPA contacted Cahaba Timber about its total residual chlorine discharges.
The facility contact confirmed the 2011 discharges and explained that a permit change required
the facility to start reporting total residual chlorine discharge data in its DMRs in 2011; the
facility did not submit total residual chlorine DMR data before 2011 (Woodruff, 2013). Total
residual chlorine is not a regulated pollutant in the Timber Products Category effluent limitations
guidelines and standards. Additionally, the facility's permit requires monitoring of total residual
chlorine discharges from all outfalls, but does not include specific permit limitations for total
residual chlorine (ADEM, 2011).
The facility has no treatment processes in place for total residual chlorine. The facility
contact explained that the facility uses three wood preservatives, one of which is
pentachlorophenol. Minor chlorine discharges may be coming from contact stormwater due to
the storage of poles treated with the pentachlorophenol preservative. All five outfalls are
stormwater outfalls that co-mingle with discharges from the cooling tower and boiler blowdown.
The facility contact stated that chlorine discharges may also be from the cooling tower/boiler
blowdown discharges (Woodruff, 2013).
Table 5-85 presents Cahaba Timber's 2011 DMR total residual chlorine and flow
discharge data. Because this facility is contributing more than 99 percent of the total 2011 DMR
residual chlorine TWPE, EPA does not consider these discharges to be representative of the
Timber Category.
Table 5-85. Cahaba Timber's 2011 DMR Total Residual Chlorine and
Flow Discharge Data
Outfall
001
001
002
002
003
003
Monitoring Period Date
30-Sep-2011
31-Dec-2011
30-Sep-2011
31-Dec-2011
30-Sep-2011
31-Dec-2011
Concentration (mg/L)
24.1
7.2
9.24
5.73
33
6.55
Flow (MGD)
0.78
0.19
0.78
0.19
0.78
0.19
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
Table 5-85. Cahaba Timber's 2011 DMR Total Residual Chlorine and
Flow Discharge Data
Outfall
004
004
005
005
Monitoring Period Date
30-Sep-2011
31-Dec-2011
30-Sep-2011
31-Dec-2011
Concentration (mg/L)
18.4
7.19
8.89
3.8
Flow (MGD)
0.78
0.19
0.78
0.19
Source: DMRLTOutput2011_vl.
5.11.4 Timber Products Category Copper Discharges in DMR
EPA's investigation of the copper discharges revealed that Ed Arey & Sons, Inc. (Ed
Arey), in Buckhannon, WV, accounts for more than 87 percent of the 2011 DMR copper
discharges (shown in Table 5-86). EPA did not investigate the remaining facilities discharging
copper.
Table 5-86. Top 2011 DMR Copper Discharging Facilities
Facility Name
Ed Arey & Sons Inc.
Facility Location
Buckhannon, WV
All Other Copper Dischargers in the Timber Products
Category3
Total
Pounds of Pollutant
Discharged
22,800
3,420
26,200
Pollutant
TWPE
14,300
2,150
16,500
Facility Percent of
Category TWPE
87%
13%
100%
Source: DMRLTOutput201 l_v 1.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 38 remaining facilities that have copper dischargers in the 2011 DMR data.
Ed Arey discharges copper through three outfalls, 001, 002, and 003. Table 5-87 presents
Ed Arey's 2011 DMR copper concentration and flow discharge data. EPA previously reviewed
copper discharges from Ed Arey as part of the 2011 Annual Review. During that review, EPA
compared the 2009 DMR concentration and flow values to 2008 and 2009 flow values from
Envirofacts and found that the 2009 DMR flow values were 1,000,000 times higher than the
2008 flow values in Envirofacts. Therefore, EPA corrected the 2009 flow values. The 2011 flow
data is also 1,000,000 times higher than the 2008 flow data values in Envirofacts; again, EPA
corrected the 2011 values. Using the corrected flows, Ed Arey's copper discharges decrease to
0.0228 pounds and 0.0143 TWPE for 2011, reducing the facility's total TWPE by over 99
percent. This reduction in TWPE decreases the Timber Products Category's 2011 DMR copper
TWPE from 16,500 to 2,150, as shown in Table 5-83.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
Table 5-87. Ed Arey's 2011 DMR Copper and Flow Discharge Data
Outfall
001
001
002
003
Monitoring Period
Date
30-Apr-2011
31-Oct-2011
31-Oct-2011
31-Oct-2011
Maximum
Concentration (mg/L)
0.017
0.026
0.0025
0.015
Original Flow
(MGD)
235
200
180
160
Corrected Flow
(MGD)
0.000235
0.0002
0.00018
0.00016
Source: DMRLTOutput2011_vl.
5.11.5 Timber Products Category Arsenic Discharges in DMR
EPA's investigation of the arsenic discharges revealed that Free State Lumber Inc., in
Haleyville, AL, accounts for 80 percent of the 2011 DMR arsenic discharges (shown in Table
5-88). EPA did not investigate the remaining facilities discharging arsenic as part of the 2013
Annual Review.
Table 5-88. Top 2011 DMR Arsenic Discharging Facilities
Facility Name
Free State Lumber Co. Inc.
Facility Location
Haleyville, AL
All other Arsenic Dischargers in the Timber Products
Category3
Total
Pounds of
Pollutant
Discharged
3,090
781
3,870
Pollutant
TWPE
12,500
3,150
15,600
Facility Percent of
Category TWPE
80%
20%
100%
Source: DMRLTOutput2011_vl.
Note: Sums of individual values may not equal the total presented, due to rounding.
a There are 26 remaining facilities that have arsenic dischargers in the 2011 DMR data.
Free State Lumber discharges arsenic through two outfalls, 001 and 002. The arsenic
concentrations for both outfalls are much higher in September and December 2011 than in March
and June 2011. The facility permit requires monitoring for arsenic discharges from both outfalls;
no permit limit is set (ADEM, 2009). As part of the 2013 Annual Review, EPA contacted Free
State Lumber about its arsenic discharges. The facility contact stated that the September and
December 2011 arsenic concentrations should be in units of micrograms per liter instead of
milligrams per liter (Hubbard, 2013). Table 5-89 presents the original and corrected
concentrations, along with average flow rates from the facility. Using the corrected
concentrations, the facility's arsenic TWPE decreases from 12,500 to 36.3, reducing the Timber
Products Category's arsenic TWPE from 15,600 to 3,190, as shown in Table 5-83.
Table 5-89. Free State Lumber's 2011 DMR Original and Corrected Arsenic Discharges
Outfall
001
001
Monitoring Period
31-Mar-2011
30-Jun-2011
Average Flow
(MGD)
0
0.46
Original Average
Arsenic Concentration
(mg/L)
0.005
0.005
Corrected Average
Arsenic Concentration
(mg/L)
0.005
0.005
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
Table 5-89. Free State Lumber's 2011 DMR Original and Corrected Arsenic Discharges
Outfall
001
001
002
002
002
002
Monitoring Period
30-Sep-2011
31-Dec-2011
31-Mar-2011
30-Jun-2011
30-Sep-2011
31-Dec-2011
Average Flow
(MGD)
0
0.35
0
1.1
0
0.82
Original Average
Arsenic Concentration
(mg/L)
1.72
3.36
0.005
0.005
1.9
3.43
Corrected Average
Arsenic Concentration
(mg/L)
0.00172
0.00336
0.005
0.005
0.0019
0.00343
Sources: DMRLTOutput2011_vl; Hubbard, 2013.
5.11.6 Timber Products Category Findings
The estimated toxicity of the Timber Products Category discharges resulted from DMR
total residual chlorine, copper, and arsenic discharges. From the 2013 Annual Review, EPA has
identified the following:
• One facility, Cahaba Timber, contributes the majority of the total residual
chlorine discharges to the 2011 DMR data. The facility only began reporting
discharges of total residual chlorine in 2011 due to a permit change, but does not
have a specific permit limit for total residual chlorine. As a result, the facility is
contributing more than 99 percent of the total 2011 DMR total residual chlorine
TWPE. Therefore, EPA does not consider these discharges to be representative of
the Timber Products Category.
• One facility, Ed Arey & Sons, Inc., contributes 87 percent of the category's
copper DMR discharges. EPA identified errors in the flow values from the
facility. With these errors corrected, the Timber Products Category's 2011 copper
DMR decreased from 16,500 to 2,150.
• One facility, Free State Lumber, contributes the majority of the arsenic discharges
to the 2011 DMR data. EPA identified an error in the concentrations reported for
the facility, which the facility contact corrected. This change decreases the
facility's arsenic TWPE from 12,500 to 36.4, reducing the Timber Products
Category's arsenic TWPE from 15,600 to 3,190.
• Correcting the errors mentioned above decreases the 2011 Timber Products
Category TWPE from 132,000 to 105,000. For the remaining facility reviewed as
part of the 2013 Annual Review, EPA determined that the discharges were not
representative of the industry.
5.11.7 References for Timber Products Category
1. ADEM. 2009. Alabama Department of Environmental Management. NPDES Permit:
Free State Lumber Company Inc., Haleyville, AL. (March 27). EPA-HQ-OW-2014-0170.
DCN 07934.
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Section 5—EPA's 2013 Preliminary Category Reviews
5.11—Timber Products Processing (40 CFR Part 429)
2. ADEM. 2011. Alabama Department of Environmental Management. NPDES Permit:
Cahaba Pressure Treated Forest Products Inc., Brier field, AL. (June 2). EPA-HQ-OW-
2014-0170. DCN 07935.
3. ERG. 2014. Preliminary Category Review - Facility Data Review and Revised
Calculations for Point Source Category 429 - Timber Products Processing. (March).
EPA-HQ-OW-2014-0170. DCN 07941.
4. Hubbard, Tabitha. 2013. Telephone and Email Communication Between Tabitha
Hubbard, Free State Lumber Co, Inc., William Swietlik, U.S. EPA, and Kimberly Bartell,
Eastern Research Group, Inc. Re: 2011 DMR Clarification for Arsenic Discharges.
(December 13). EPA-HQ-OW-2014-0170. DCN 07936.
5. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. Washington, D.C. (August). EPA-821-R-04-014. EPA-HQ-OW-2003-0074-1346
through 1352.
6. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 821-R-12-001. EPA-HQ-OW-2010-0824-0195.
7. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170. DCN
07756.
8. Woodruff, Al, and Ken Layton. 2013. Telephone and Email Communication Between Al
Woodruff, Cahaba Timber Co., Ken Layton, Layton Environmental Engineering LLC,
and Kimberly Bartell, Eastern Research Group, Inc., Re: 2011 DMR Chlorine Discharges
for Cahaba Timber Co. (December 13). EPA-HQ-OW-2014-0170. DCN 07937.
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PART III: RESULTS OF
EPA's 2013 ANNUAL REVIEW
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Section &—Results of the 2013 Annual Review
6. RESULTS OF THE 2013 ANNUAL REVIEW
For the 2013 Annual Review, EPA evaluated the results of the toxicity rankings analysis
(TRA) and the preliminary category reviews. Based on its TRA, EPA prioritized for further
review 17 industrial categories whose pollutant discharges may pose the greatest hazards to
human health or the environment because of their toxicity based on toxic-weighted pound
equivalents (TWPE).
During its review, EPA determined that seven of the 17 categories that cumulatively
discharge 95 percent of the TWPE did not warrant a detailed preliminary category review. For
these seven categories, many of which have been reviewed in detail in prior annual reviews, EPA
found that the majority of the TWPE resulted from easily identifiable errors (e.g., incorrect
reporting units) associated with one or two facilities. For TWPE not associated with data entry
errors, EPA did not identify any new information to alter the conclusions made during previous
annual reviews. These industrial categories include:
• Concentrated Aquatic Animal Production (40 CFR Part 451);
• Meat and Poultry Products (40 CFR Part 432);
• Oil and Gas Extraction (40 CFR Part 435);
• Ore Mining and Dressing (40 CFR Part 440);
• Pesticide Chemicals (40 CFR Part 455);
• Fertilizer Manufacturing (40 CFR Part 418); and
• Sugar Processing (40 CFR Part 409).
For the remaining 10 of the 17 industrial categories that collectively discharge over 95
percent of the total TWPE, EPA completed a detailed preliminary category reviews to evaluate
whether the categories warrant further review. From these reviews, EPA identified only two
categories that warrant further review: Metal Finishing (40 CFR 433) and Petroleum Refining
(40 CFR 419). Below are the findings from EPA's 2013 preliminary category reviews:
• Coal Mining (40 CFR Part 434). EPA identified and corrected data errors for
2011 discharge monitoring report (DMR) discharges of iron, mercury, sulfate, and
manganese (the top pollutants). Correcting these reporting errors removes the
category from the top 95 percent in the point source category rankings.
• Drinking Water Treatment (potential new category). EPA reviewed total
residual chlorine, aluminum, copper, mercury, and lead (the top pollutants) for the
2013 Annual Review. EPA identified and corrected flow errors at four facilities
accounting for the majority of the 2011 DMR total residual chorine and aluminum
discharges. Further, EPA examined the findings from its 2011 review of the
drinking water industrial, category which found that discharges from drinking
water treatment plants are best addressed through National Pollutant Discharge
Elimination System (NPDES) permits and that some pollutants are present in the
wastewater from source water contributions or treatment chemicals. EPA
compared the 2011 DMR top pollutants and concentrations to the findings from
the 2011 review of the industrial category and determined that the same
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Section &—Results of the 2013 Annual Review
conclusions apply. Therefore, EPA did not identify this category for further
review.
Inorganic Chemicals Manufacturing (40 CFR Part 415). EPA reviewed dioxin
and dioxin-like compounds, manganese and manganese compounds, and
polychlorinated biphenyls (PCBs) (the top pollutants), which result from three
titanium dioxide manufacturing plants, for the 2013 Annual Review.
— One facility reported dioxin discharges that account for 98 percent of the
2011 TRI dioxin category TWPE. EPA determined that the facility
inadvertently reported 2011 dioxin and dioxin-like compound discharges
using the minimum detection limit, when historically they have reported
non-detect data as zero. Additionally, EPA determined that the 2011
concentrations for all congeners are below EPA's Method 1613B
Minimum Level (ML).
— One facility accounted for 39 percent of the 2011 TRI manganese category
TWPE. EPA determined that the 2011 manganese and manganese
compound TRI discharge for the facility is an anomaly due to an increase
in flow at the facility during 2011, which is supported by a decrease in the
discharge in 2012.
— One facility accounted for 97 percent of the 2011 TRI PCB category
TWPE. EPA determined that the facility's 2011 PCB discharges were
accurate and increased from previous years. Therefore, facility-specific
permitting action may be appropriate to address PCB discharges from this
facility.
EPA has determined that further review of the Inorganic Category as a
whole is not warranted at this time.
Iron and Steel Manufacturing (40 CFR Part 420). EPA reviewed discharges of
fluoride, aluminum, cyanide, and total residual chlorine (top pollutants) for the
2013 Annual Review. EPA determined that:
— Three facilities account for 73 percent of the 2011 DMR fluoride category
TWPE. EPA identified and corrected a data error in one facility's 2011
DMR fluoride concentrations. EPA compared fluoride concentrations
from all three facilities to concentrations achieved by current treatment
technologies (although not specific to iron and steel manufacturing) and
determined that all concentrations from two facilities were below treatable
levels. EPA determined that fluoride concentrations from the third facility
may exceed the concentration ranges achieved by current treatment
technologies and that facility-specific permitting action may be
appropriate to address fluoride discharges at this facility.
— The majority (76 percent) of the 2011 DMR aluminum category TWPE
was from one facility. EPA identified and corrected a data error for the
facility's aluminum concentration, which decreased the aluminum TWPE
for the category.
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Section &—Results of the 2013 Annual Review
— Two facilities contribute the majority (60 percent) of the 2011 DMR
cyanide category TWPE. For one facility, EPA determined that the 2011
cyanide concentrations do not exceed permit limitations or the long-term
average concentration calculated for the 2002 category rulemaking. EPA
suspects that this facility's TWPE is high due to the large amount of
industrial activity at the facility, as it historically has been the top coke
producer in the U.S. For the other facility, EPA found that several months
of cyanide discharges from two different outfalls exceed the facility's
mass-based permit limits; therefore, facility-specific permitting action may
be appropriate to address cyanide discharges at this facility.
— One facility, historically the top coke producer in the U.S., accounts for 49
percent of the 2011 DMR total residual chlorine discharges. EPA
determined that the total residual chlorine concentrations for this plant are
a result of the large amount of industrial activity at the facility and do not
exceed permit limitations.
EPA has determined that the data do not support the need to further review
the Iron and Steel Category as a whole.
Metal Finishing (40 CFR Part 433). During the 2012 Annual Review, EPA's
review of the Targeted National Sewage Sludge Survey, combined with available
indirect discharge data from TRI, identified the Metal Finishing Point Source
Category as potentially discharging high concentrations of metals, particularly
chromium, nickel, and zinc, to publicly owned treatment works. Additionally, this
category ranked high, in terms of TWPE, in the 2013 TRA. These findings
indicate that further review of this category may be warranted.
Nonferrous Metals Manufacturing (40 CFR Part 421). EPA reviewed
discharges of cadmium, copper, mercury PCBs, and lead (the top pollutants) for
the 2013 Annual Review. EPA determined that:
— One facility accounts for 98 percent of the 2011 DMR cadmium category
discharges. In 2012, the facility was issued a new permit to control
cadmium discharges from its storm water outfalls. EPA determined that
further review of the facility's discharges is not needed at this time.
— One facility accounts for 88 percent of the 2011 DMR copper category
discharges. EPA identified and corrected a data entry error for the
facility's copper concentrations, which decreased the copper TWPE for
the category.
— One facility contributes 99 percent of the 2011 DMR mercury category
discharges. EPA previously reviewed these discharges as part of the 2010
and 2011 Annual Reviews. EPA determined that the facility's discharges
result from former aluminum ore tailings lakes, not from current
manufacturing. Because the facility no longer operates as an aluminum ore
mine and processing facility and the discharges are similar to those in
previous years, facility-specific permitting action may be appropriate to
address this facility's mercury discharges.
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Section &—Results of the 2013 Annual Review
— One facility accounts for 96 percent of the 2011 DMR PCB category
discharges. EPA determined that this facility shut down its uranium
enrichment process in 2013 and that cleanup efforts have been active at
the site since the late 1980s. For these reasons, EPA is not performing
further review of PCB discharges from this facility at this time.
— Two facilities account for 93 percent of the 2011 DMR lead category
discharges. One facility was issued a new permit in 2012, which contains
new permit limitations for lead. The second facility is steadily reducing
the concentrations of lead discharges by installing new contaminant
technology and using better management practices. Therefore, EPA did
not identify lead discharges for further review at this time.
EPA has determined that the data do not support the need to further review
the Nonferrous Metal Manufacturing Category as a whole.
Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414). EPA
reviewed discharges of hexachlorobenzene, total residual chlorine, and PCBs (the
top pollutants) for the 2013 Annual Review. EPA identified that, for each of these
pollutants, a majority of the discharges are attributed to a single facility whose
reported discharges were in error. After correcting the data errors, EPA found that
the TWPE has increased by 26.5 percent from 2009 to 2011. EPA expects that the
high TWPE is a result of the increase in the number of minor facilities reporting
discharges and the large number of facilities in the category.
Petroleum Refining (40 CFR Part 419). During the 2011 Annual Review, EPA
selected the Petroleum Refining Category (40 CFR Part 419) for a preliminary
category review because it ranked high, in terms of TWPE (U.S. EPA, 2012). At
that time, EPA found that the TWPE was largely due to TRI-reported discharges
of dioxin and dioxin-like compounds, polycyclic aromatic compounds, and DMR-
reported discharges of sulfides, chlorine, and metals. EPA continued to review
this category during the 2012 Annual Review to verify facilities' discharges and
confirmed the 2011 Annual Review results. EPA also reviewed new air pollution
control regulations to identify whether the regulations could result in new
wastewater streams. Additionally, this category ranked high, in terms of TWPE,
in the 2013 TRA. These findings indicate that further study of this category may
be warranted.
Pulp, Paper, and Paperboard (40 CFR Part 430). EPA reviewed discharges of
dioxin and dioxin-like compounds, manganese and manganese compounds, and
sulfide (the top pollutants) for the 2013 Annual Review. EPA's review identified
the following:
— One facility accounts for the majority (71 percent) of the 2011 DMR
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) category discharges. EPA
identified and corrected a data entry error for the facility's TCDD
concentrations, which decreased the TCDD TWPE for this category.
— Four facilities account for the majority (74 percent) of the 2011 TRI
dioxin and dioxin-like compound discharges. EPA previously reviewed
these four facilities as part of the 2011 and 2012 Annual Reviews. One of
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Section &—Results of the 2013 Annual Review
them shut down in 2012. For the other three, EPA determined that 2011
dioxin and dioxin-like compound discharges are either below or near EPA
Method 1613 MLs and are similar to 2009 dioxin and dioxin-like
compound discharges. As a result, further review of dioxin and dioxin-like
compound discharges from this category is not warranted at this time.
— In 2011, 104 facilities reported discharges of manganese and manganese
compounds to TRI. No facility accounts for more than 6 percent of the
TWPE. EPA's 2011 Annual Review and 2006 Detailed Study of the
industry determined that metals concentrations in pulp and paper mill
discharges were below treatable levels. EPA did not identify any new
information to alter its previous findings.
EPA has determined that the data do not support the need to further review
the Pulp and Paper Category as a whole.
Timber Products Processing (40 CFR Part 429). For this category, the top
pollutants, in terms of TWPE, are total residual chorine, copper, and arsenic.
EPA's review identified the following:
— One facility accounts for more than 99 percent of the 2011 DMR total
residual chlorine category discharges. The facility only began reporting
total residual chlorine discharges in 2011 and is not exceeding any permit
limitations for total residual chlorine. As a result, EPA does not consider
these discharges to be representative of the category; they do not warrant
further review at this time.
— One facility accounts for 87 percent of the 2011 DMR copper category
discharges. EPA identified and corrected a data entry error for the
facility's copper concentrations.
— One facility accounts for 80 percent of the 2011 DMR arsenic category
discharges. EPA identified and corrected a data entry error for the
facility's arsenic concentrations, which decreased the arsenic TWPE for
this category.
EPA has determined that the data do not support the need to further review
the Timber Category as a whole.
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