&EPA—
United States
Environmental Protection
Agency
The 2012 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-14-004
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TABLE OF CONTENTS
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PART I: INTRODUCTION I
1. 2012 ANNUAL REVIEW EXECUTIVE SUMMARY 1-1
1.1 References for 2012 Annual Review Executive Summary 1-5
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 2012 ANNUAL REVIEW METHODOLOGY AND ANALYSES II
3. INTRODUCTION TO EPA's 2012 ANNUAL REVIEW 3-1
4. PUBLIC COMMENTS AND OTHER STAKEHOLDER INPUT ON THE PRELIMINARY
2012 EFFLUENT GUIDELINES PROGRAM PLAN 4-1
4.1 Public Comments and Stakeholder Input 4-1
5. CONTINUED REVIEW OF SELECT POINT SOURCE CATEGORIES 5-1
5.1 Meat and Poultry Products (40 CFR Part 432) 5-1
5.1.1 Meat and Poultry Products Category Background 5-1
5.1.2 Results of the 2011 Annual Review 5-5
5.1.3 Results of the 2012 Annual Review 5-8
5.1.4 Summary of Findings from EPA's Review of Meat and Poultry
Products Category 5-18
5.1.5 References for Meat and Poultry Products Category 5-18
5.2 Petroleum Refining (40 CFR Part 419) 5-21
5.2.1 Petroleum Refining Category Background 5-21
5.2.2 Results of the 2011 Annual Review 5-22
5.2.3 Results of the 2012 Annual Review 5-23
5.2.4 Summary of Findings from EPA's Review of Petroleum Refining
Category 5-29
5.2.5 References for Petroleum Refining Category 5-29
5.3 Pulp, Paper, and Paperboard (40 CFR Part 430) 5-42
5.3.1 Pulp and Paper Category Background 5-42
5.3.2 Results of the 2011 Annual Review 5-43
5.3.3 Results of the 2012 Annual Review 5-43
5.3.4 Summary of Findings from EPA's Review of Pulp and Paper
Category 5-50
5.3.5 References for Pulp and Paper Category 5-51
6. NEW DATA SOURCES AND HAZARD ANALYSES 6-1
6.1 Identification of Industrial Wastewater Pollutants in Sewage Sludge 6-2
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TABLE OF CONTENTS (Continued)
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6.1.1 Background 6-3
6.1.2 OW'sTNSSS 6-5
6.1.3 EPA's 2012 Annual Review of Sewage Sludge Analyses 6-8
6.1.4 Additional Analyses Completed 6-35
6.1.5 Summary of Findings from EPA's Review of Industrial
Wastewater Pollutants in Sewage Sludge 6-38
6.1.6 References for Industrial Wastewater Pollutants in Sewage Sludge 6-39
6.2 Review of Chemical Action Plans 6-48
6.2.1 OPPT Chemical Action Plans Background 6-49
6.2.2 OPPT Chemicals Reviewed 6-51
6.2.3 Additional Review of Long-Chain PFCs 6-72
6.2.4 Summary of OW's Findings from Chemical Action Plans Review 6-80
6.2.5 References for Review of Chemical Action Plans 6-82
6.3 Identification of Wastewater Discharges Related to Air Pollution Control
Not Currently Covered by ELGs 6-86
6.3.1 Air Pollution Control Regulations Background 6-86
6.3.2 Review of NSPS and NESHAPs 6-87
6.3.3 Summary of Findings from EPA's Review of Air Pollution Control
Regulations 6-93
6.3.4 References for Air Pollution Control Regulations 6-94
6.4 Review of TRI Industry Sectors Expansion 6-117
6.4.1 TRI Industry Sectors Expansion Background 6-117
6.4.2 Iron Ore Mining (40 CFR Part 440) 6-118
6.4.3 Phosphate Mining (40 CFR Part 436) 6-120
6.4.4 Steam Generation from Coal and/or Oil (Not Currently Regulated)... 6-121
6.4.5 Petroleum Bulk Storage (Not Currently Regulated) 6-121
6.4.6 Solid Waste Combustors and Incinerators (40 CFR Parts 437 and
444) 6-122
6.4.7 Large Dry Cleaning (Not Currently Regulated) 6-123
6.4.8 Summary of Findings from EPA's Review of TRI Industry Sectors
Expansion 6-124
6.4.9 References for Review of TRI Industry Sectors Expansion 6-125
6.5 Review of Analytical Methods 6-127
6.5.1 Data Sources 6-127
6.5.2 EAD 6-128
6.5.3 OGWDW 6-130
6.5.4 ORD 6-132
6.5.5 Summary of EPA's Findings from Analytical Methods Review 6-133
6.5.6 References for Review of Analytical Methods 6-134
6.6 Review of Industrial Wastewater Treatment Technologies 6-141
6.6.1 Industrial Wastewater Treatment Technologies Data Collection 6-142
6.6.2 Industrial Wastewater Treatment Technologies Data Storage 6-145
VI
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TABLE OF CONTENTS (Continued)
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6.6.3 References for Review of Industrial Wastewater Treatment
Technologies 6-146
PART III: RESULTS OF EPA's 2012 ANNUAL REVIEW Ill
7. RESULTS OF THE 2012 ANNUAL REVIEW 7-1
7.1 Continued Review of Select Point Source Categories 7-1
7.2 New Data Sources and Hazard Analyses Results 7-2
7.3 References for Results of the 2012 Annual Review 7-3
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LIST OF TABLES
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Table 4-1. Comments on the Preliminary 2012 Effluent Guidelines Program Plan EPA
Docket Number: EPA-HQ-OW-2010-0824 4-4
Table 5-1. BAT ELG Limitations for the Meat and Poultry Products Category21 5-2
Table 5-2. Meat and Poultry Category TRI and DMR Discharges for the 2009
Through 2011 Toxicity Rankings Analyses 5-4
Table 5-3. Meat and Poultry Category Nitrate Compounds Dischargers in the 2009 TRI
Database 5-7
Table 5-4. Permit Status as of January 2012 and DMR Total Nitrogen Concentrations for
Meat and Poultry Treated Process Wastewater Outfalls 5-16
Table 5-5. Petroleum Refining Category TRI and DMR Discharges for 2007 Through
2011 Toxicity Rankings Analysis 5-22
Table 5-6. 2010 DMR Petroleum Refinery Dioxin and Dioxin-Like Compounds Effluent
Discharge Data (pg/L) 5-25
Table 5-7. DMR Metal Discharges, 2000-2010 5-26
Table 5-8. Treatability Data from 2009 Steam Electric Power Generation Detailed
Study Report 5-27
Table 5-9. 2010 Petroleum Refineries Metals Data from DMR 5-28
Table 5-10. Dioxin and Dioxin-Like Discharges from Petroleum Refineries Reported to
TRI in 2004-2009 5-32
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool 5-35
Table 5-12. List of Full Refinery Names 5-40
Table 5-13. Pulp and Paper Category TRI and DMR Discharges for 2007 Through 2011
Toxicity Rankings Analysis 5-42
Table 5-14. Facilities Using Monitoring Data to Estimate 2009 TRI Dioxin and
Furans Discharges 5-45
Table 5-15. Pulp and Paper Dioxin and Furans at Mills with Detectable Concentrations
(pg/L)a 5-47
Table 5-16. Grams and TWPE Associated with Discharges Above the ML 5-48
Table 5-17. Facilities Using Engineering Calculations to Estimate 2009 TRI Discharges 5-48
Vlll
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LIST OF TABLES (Continued)
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Table 5-18. Facilities Using Other Methods to Estimate 2009 TRI Discharges 5-49
Table 5-19. Dioxin Data from WADOE 5-50
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported
to TRI in 2004-2009 5-53
Table 6-1. Additional Hazard Data Sources Evaluated for the 2012 Annual Review 6-1
Table 6-2. TNSSS Analyte Groups and Applicability to EPA Programs and Regulations 6-6
Table 6-3. TNSSS-Sampled POTWs That Receive Wastewater from Industrial Facilities
Reporting to TRI 6-10
Table 6-4. Ranking of Point Source Categories21 by the Count of Facilities Discharging to
a TNSSS POTW Included in TRI 6-12
Table 6-5. Pollutants Included in Both the TNSSS and TRI 6-14
Table 6-6. Pollutant Differences between TNSSS and TRI 6-15
Table 6-7. Pollutants Transferred21 to POTWs, Ranked by TWPE 6-16
Table 6-8. Point Source Category Rankings by Metals TWPE Potentially Transferred to
Sewage Sludgea 6-17
Table 6-9. Comparison of TNSSS Maximum Sewage Sludge Concentration to 40 CFR
Part 503 Regulatory Limits" 6-18
Table 6-10. POTWs with Highest Chromium Sewage Sludge Concentrations 6-19
Table 6-11. TRI Point Source Categories Ranked by Total Chromium TWPE Transferred
toPOTWsa 6-21
Table 6-12. TNSSS POTWs Receiving Chromium Transfers from TRI Facilities 6-22
Table 6-13. Chromium Sewage Sludge Concentrations from TNSSS POTWs With and
Without Reporting TRI Facilities (mg/kg) 6-23
Table 6-14. Identification Information for Top-Ranking TNSSS POTWs for Nickel 6-23
Table 6-15. TRI Point Source Categories Ranked by Total Nickel TWPEa 6-25
Table 6-16. TNSSS POTWs Receiving Nickel Transfers from TRI Facilities 6-26
Table 6-17. Nickel Sewage Sludge Concentrations from TNSSS POTWs With and
Without Reporting TRI Facilities (mg/kg) 6-28
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LIST OF TABLES (Continued)
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Table 6-18. Identification Information for Top-Ranking TNSSS POTWs for Zinc 6-28
Table 6-19. TRI Point Source Categories Ranked by Total Zinc TWPE Transferred to
POTWsa 6-30
Table 6-20. TNSSS POTWs Receiving Zinc Transfers from TRI Facilities 6-31
Table 6-21. Zinc Sewage Sludge Concentrations from TNSSS POTWs With and Without
Reporting TRI Facilities (mg/kg) 6-32
Table 6-22. Top TNSSS POTWs Sampled for Triclosan 6-33
Table 6-23. Data for All TNSSS POTWs Sampled for Triclosan 6-33
Table 6-24. Top Estriol and Estrone Sewage Sludge Concentrations from TNSSS POTWs.... 6-35
Table 6-25. Data for All TNSSS POTWs Sampled for Estriol and Estrone 6-35
Table 6-26. Receiving Watershed Data for TNSSS POTWs 6-36
Table 6-27. Analytes Sampled in the TNSSSa 6-41
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs 6-43
Table 6-29. Potential Actions Identified in CAPs 6-50
Table 6-30. Discharges of BPA by Point Source Category as Reported to TRI in 2011 6-54
Table 6-3l.NP Water Quality Criteria 6-60
Table 6-32. Phthalates in CAP Regulated by ELGs and/or Listed in TRI 6-66
Table 6-33. ELG Limits for Regulated Phthalates 6-67
Table 6-34. Discharge of Di-n-butyl phthalate by Point Source Category as Reported to
DMR and TRI (2011) 6-67
Table 6-35. Discharge of Bis(2-ethylhexyl)phthalate by Point Source Category as
Reported to DMR and TRI (2011) 6-68
Table 6-36. Range of Average Phthalate Discharges Reported to DMR (201 l)a 6-69
Table 6-37. Mean DuPont Chambers Works Monthly PFOA Concentrations and Mass
Loadings at Outfall 662, 2006-2009 6-76
Table 6-38. Detailed DuPont Chambers Works Monthly PFOA Concentrations and Mass
Loadings at Outfall 662, 2010-2011 6-78
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LIST OF TABLES (Continued)
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Table 6-39. Summary of the 2011 Maximum Concentration Data for 3M Decatur Plant,
Outfall 001 (Process Wastewater Discharge) 6-79
Table 6-40. Summary of the 2011 Maximum PFOA Concentration Data for Daikin
America, Inc 6-79
Table 6-41. Summary of the 2010 Average PFOA Concentration and Data for El DuPont
de Nemours 6-80
Table 6-42. Counts of Brick and Structural Clay Products Manufacturing Facilities in the
U.S 6-89
Table 6-43. Existing ELGs for Industries Affected by the NESHAP for Industrial,
Commercial, or Institutional Boilers 6-90
Table 6-44. Air Regulations Potentially Resulting in Wastewater Discharges in Industries
with No Existing Effluent Limitations Guidelines 6-96
Table 6-45. Air Regulations Potentially Resulting in Wastewater Discharges not Included
in the Scope of Existing ELGs Prioritized for Further Review During EPA's
2012 Annual Reviews 6-99
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included
in the Scope of Existing ELGs Requiring Further Investigation in Future
Annual Reviews 6-101
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air
Regulation and Applicable ELG 6-111
Table 6-48. Analytes in OGWDW's 2012 UCMR 6-130
Table 6-49. ORD Drinking Water Methods Developed Within Last Five Years 6-132
Table 6-50. 2012 CWA Method Update Rule 6-135
Table 6-51. Pesticide Chemicals Measured by EPA Approved Methods Without Limits
Under the Pesticide Chemicals Manufacturing, Formulating, and Packaging
ELGs (40 CFR Part 455) 6-140
XI
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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. Relationship Between Total Nitrogen Compounds 5-5
Figure 6-1. Industrial Facility Wastewater Discharge Options 6-4
Figure 6-2. Universe of Industrial Facilities and Connection to POTWs Included in
TNSSS 6-13
Figure 6-3. POTW Universe and POTWs Used to Analyze Industrial Wastewater
Pollutants in Sewage Sludge 6-14
Figure 6-4. Top Chromium Discharges to POTWs in TRI 6-20
Figure 6-5. Top Nickel Dischargers in TRI 6-24
Figure 6-6. Top Zinc Dischargers in TRI 6-29
Figure 6-7. Triclosan (2,4,4'-Trichloro-2'-Hydroxy-Diphenyl Ether) 6-33
Figure 6-8. Estriol and Estrone Chemical Structures 6-34
Figure 6-9. Perfluorooctanoic Acid (CAS Number: 335-67-1) 6-73
xn
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PART I: INTRODUCTION
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Section 1—2012 Annual Review Executive Summary
1. 2012 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-phase 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.
Beginning with the 2012 Annual Review, EPA is augmenting the methods and data
sources it uses to identify industrial categories for which new or revised effluent limitations
guidelines and standards may be developed. This new approach, described in detail in this report,
combines the traditional toxicity rankings analysis (TRA) and the analyses of new hazard data
sources (not included in the TRA) coupled with an expanded review of new or improved
treatment technologies. EPA will perform these review efforts in alternate years—completing the
TRA in odd years and the analyses of additional industrial hazard data sources and new
treatment technologies in even years. EPA has already completed its review for 2011 using the
TRA and published the results in the Preliminary 2012 Plan (78 FR 48159).
For the 2012 Annual Review, EPA is primarily evaluating new hazard data sources and
initiating a review of new treatment technologies. These new, even-year reviews will expand
EPA's ability to identify new pollutants of concern and to identify wastewater discharges in
industrial categories not currently regulated by ELGs. The new reviews will also enhance EPA's
ability to screen industrial wastewater discharges based on a broader set of hazard data and
enable EPA to account for advances in treatment technologies much earlier in the review
process. Both of these factors are keys to improving the effectiveness of the Effluent Guidelines
Program.
For the 2012 Annual Review, EPA reviewed public comments submitted on the
Preliminary 2012 Plan, continued preliminary category reviews for three categories identified as
warranting additional review in the Preliminary 2012 Plan (meat and poultry products (40 CFR
Part 432); petroleum refining (40 CFR Part 419); and pulp, paper, and paperboard (40 CFR Part
430)), and investigated and conducted analyses on six new industrial wastewater hazard data
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Section 1—2012 Annual Review Executive Summary
sources (described below), the first four of which it had identified during the 2011 Annual
Review (78 FR 48159). EPA selected these new hazard data sources based on how likely they
are to be useful in identifying unregulated pollutants or industrial discharges, as well as their
utility in identifying new wastewater treatment technologies and pollution prevention practices.
• Identification of Industrial Wastewater Pollutants in Sewage Sludge. EPA
examined the Targeted National Sewage Sludge Survey (TNSSS), which includes
data on pollutants of concern in sewage sludge, to determine if the pollutants
could be attributed to specific industrial wastewater discharges (or point source
categories), particularly for the pollutants that may impact the beneficial use of
sewage sludge. For more information on the TNSSS see-
http://wa.ter. epa.gov/scitech/wastetech/biosolids/tnsss-overview. cfm.
• Review of Chemical Action Plans. EPA reviewed data and plans from its Toxic
Chemical Control Programs, specifically the Office of Pollution Prevention and
Toxics (OPPT) Chemical Action Plans (CAPs), to determine whether the
information identified new pollutants of concern or industrial wastewater
discharges that are not currently regulated.
• Identification of Wastewater Discharges Related to Air Pollution Control Not
Currently Covered by ELGs. Changes to or implementation of new air
regulations may lead to new air pollution control requirements. As a result, some
of these regulations have the potential to generate new or changed wastewater
discharges with new pollutants of interest, depending upon the type of pollutants
removed from the air and whether the affected industry adopts wet air pollution
controls. For example, the wet scrubbers for flue-gas desulfurization at steam
electric generating plants generate a wastewater discharge that is regulated by 40
CFR Part 423 (Steam Electric Power Generation); however, the only pollutants
currently regulated are total suspended solids, oil and grease, and pH. Discharges
of flue-gas desulfurization wet scrubber blowdown contain toxic metal pollutants,
which are now the focus of the proposed Steam Electric Rulemaking (78 FR
34432). EPA assessed current federal air regulations to identify industries that, as
a result, may be discharging new wastestreams or specific pollutant discharges not
currently regulated.
• Review of Toxic Release Inventory (TRI) Industry Sectors Expansion. EPA's
Office of Environmental Information (OEI) is currently evaluating expanding the
TRI Program to include several new industrial sectors including Iron Ore Mining,
Phosphate Mining, Steam Generation from Coal and/or Oil, Petroleum Bulk
Storage, Solid Waste Combustors and Incinerators, and Large Dry Cleaning (the
TRI expansion is schedule to be proposed in December 2014). This expansion
would require covered facilities in these industries to report data for specific toxic
chemicals or other waste released. EPA reviewed publically available industry
profile information, pollutants of concern, and public comments submitted on the
rulemaking to date to determine if these industries represent new wastestreams
and/or discharge pollutants not currently regulated.
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Section 1—2012 Annual Review Executive Summary
• Review of Analytical Methods. EPA periodically develops new analytical
methods, or updates existing ones, in response to developments, such as the
identification of a new class of pollutants, or impairments to water bodies that
indicate the need for altered or new methods. EPA focused its review on recent
updates to the wastewater analytical methods listed in 40 CFR Part 136 as well as
drinking water methods developed by EPA's Office of Ground Water and
Drinking Water and Office of Research and Development to determine whether
new methods are available that apply to unregulated pollutants in industrial
wastewater discharges, or if changes to existing analytical methods provide for
increased sensitivity. Such new or altered methods might allow EPA to identify
previously undetected pollutants or regulate the discharge of currently-regulated
pollutants to more stringent levels.
• Review of Wastewater Treatment Technologies. EPA began reviewing
technical papers and research articles regarding the performance of new and
improved industrial wastewater treatment technologies. EPA is working to
capture this data and information in a searchable industrial wastewater treatment
technology database to facilitate screening of industrial categories for new or
revised ELGs based on the availability and effectiveness of technologies for
removing pollutants of concern from the specific industrial wastewater
discharges.
Based on the data and analyses conducted for the 2011 and 2012 Annual Reviews, and
public comment and stakeholder input, EPA has identified the following:
• EPA's TRA in 2011 identified a recent increase in dioxins and dioxin-like
compounds as well as metals discharges from petroleum refineries (40 CFR Part
419) (U.S. EPA, 2012). In the 2012 Annual Review, EPA's preliminary category
review for petroleum refineries indicated that the metals discharges may be
attributed to new air pollution control requirements and a change in feedstock (see
Section 5.2). EPA's review of air regulations in the 2012 Annual Review
confirmed that new and revised regulations for petroleum refineries may result in
a new wastestream containing metals, resulting from the use of wet air pollution
controls (see Section 6.3). In addition, from EPA's preliminary category review
for petroleum refineries in 2012 EPA has not been able to confirm whether dioxin
is being discharged at concentrations above 1613B Minimum Levels or
conclusively identify the primary source of the discharge (e.g., stormwater or
process wastewater from catalytic reforming and catalyst regeneration
operations).
• EPA's TRA in 2011 (U.S. EPA, 2012) and review of TNSSS data in the 2012
Annual Review (see Section 6.1) identified the metal finishing point source
category (40 CFR Part 433) as potentially discharging high concentrations of
metals, particularly chromium, nickel, and zinc to POTWs that could then transfer
to sewage sludge and impact its beneficial use.
• EPA's review of CAPs (see Section 6.2) identified the following pollutants that
are potentially present (and unregulated) in industrial wastewater discharges:
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Section 1—2012 Annual Review Executive Summary
benzidine dyes, bisphenol A (BPA), hexabromocyclododecane (HBCD),
nonylphenol and nonylphenol ethoxylates, perfluorinated chemicals (PFCs),
phthalates, short-chain chlorinated paraffins (SCCPs), hydrolysis byproducts of
toluene diisocyanate (TDI) and methylene diphenyl diisocyanate (MDI).
• EPA's review of new wastewater discharges from air pollution controls (see
Section 6.3) identified three industries that have air regulations that may result in
an unregulated wastewater discharge; brick and structural clay product
manufacturing, industrial, commercial, and institutional boilers, and industrial,
commercial, and institutional steam generating units. In addition, EPA identified
13 industries with existing ELGs, for which new air regulations may result in the
discharge of new or additional pollutants.
• EPA's review of the planned TRI sector expansion information (see Section 6.4)
in the 2012 Annual Review suggests that selenium discharges from phosphate
mines (regulated under 40 CFR Part 136) may be a new pollutant of concern.
However, because the TRI sector expansion rulemaking and supporting
information have not yet been published (projected publication is December
2014), EPA was not able to fully evaluate the impact of selenium discharges from
phosphate mines at this time.
• EPA's review of recent analytical method developments (see Section 6.5),
identified that there are reduced detection limits for some metals and additions of
new methods for detecting other pollutants of concern from industrial wastewater
discharges, including: free cyanide, acid mine drainage, nonylphenol, and
bisphenol A.
In addition, EPA identified several pesticides measured by some of the approved
pesticide analytical methods (listed in 40 CFR Part 136) that do not currently have
effluent limits under the Pesticide Chemicals Manufacturing, Formulating, and
Packaging ELGs (40 CFR Part 455).
EPA also reviewed OGWDW and ORD drinking water analytical methods and
identified two relatively new methods developed by ORD to measure
concentrations of PFCs and 1,4-dioxane. OGWDW is using these methods in its
UCMR to evaluate PFCs and 1,4-dioxane in drinking water. EPA has identified
industrial wastewater discharges for both PFCs and 1,4-dioxane.
This report details EPA's methodology for its 2012 Annual Review and supports EPA
Office of Water's Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S.
EPA, 2014). The Plans, pursuant to Section 304(m) of the Clean Water Act (CWA),1 discuss the
findings of the 2011 and 2012 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.
Available at: http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/.
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Section 1—2012 Annual Review Executive Summary
1.1 References for 2012 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. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2010-0824. DCN
07756.
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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 states the 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 of 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
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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.
Creating a single national pollution-control requirement for each industrial category,
based on the best technology the industry can afford was seen by Congress as a way to reduce
the potential creation of "pollution havens" and to set the nation's sights on eliminating the
discharge of pollutants to waters of the U.S. 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
-------
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 more detail on the 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) 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-
prevention practices that can reduce the identified hazards (the second and fourth draft National
Strategy factors). Specifically, in the even-year reviews, EPA plans to target new data sources
2 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.
-------
Section 2—Background
that will provide information on other considerations not currently captured as part of the TRA,
including, but not limited to:
• Industrial process changes.
• Emerging contaminants of concern.
• Advances in treatment technologies and pollution prevention practices.
• Availability of new, more sensitive analytical methods.
• Other hazard data and information not captured in the TRI or DMR databases
and/or suggested by stakeholders or from public comments.
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 EPA's draft National Strategy. This approach allows the Agency to prioritize
existing effluent guidelines or pretreatment standards for possible revision or identifying new
industries of concern through alternate analyses. See Section 2.2.2.2 for an overview of EPA's
even-year 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 discharge 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
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).
2-4
-------
Section 2—Background
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
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. For more information on EPA's odd-
year review process and methodology, see Section 3 of EPA's Preliminary 2012 Plan (U.S. EPA,
2013). 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 2011
Annual Review, see Section 4 of EPA's Preliminary 2012 Plan (U.S. EPA, 2013).
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 EPA's 2012 Annual
Review are described in more detail in Part II of this report.
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 have theoretically led to double-counting, EPA's review of the data indicates that, because the two
databases 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.
2-5
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Section 2—Background
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
preliminary category review, particularly if it lacks sufficient data to determine whether
regulatory action would be appropriate, as illustrated in Figure 2-4. EPA will complete
preliminary category reviews as part of the odd- or even-year review cycle depending on the
industrial categories warranting 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
Preliminary results of Toxicity Rankings Analysis
= Combined TRIReleases and DMRLoads
database rankings (Factor 1)
<: DMR&TRI
database
tools
Not a priority
category, no
further
review at this time
AreELG revisions
currently
underway?
Have
ELGs been
developed or revised
within the past?
ears?
Not a priority
category, no further
review at this time*
Are
non-representative
facilities responsible for
overall category
TWPE?
Not a priority
category,
but may recommend
permitting support
for individual facilities
When ranked
by TWPE, does category
contribute to top 95% of
cumulative TWPE of all
categories?
Further review
(see Figure 2-4)
Possible outcome
-Further review
-BPJ support
-Identify for
possible
revision of
existing
ELGs
-No action
Are there
identified implementation
and efficiency
^ssues (Factor4)
No
Evaluation of treatment technology performance data
Stakeholder recommendations and comments
' If EPA is aware of new segment growth within such a category or new concerns are identified, EPA may do further review.
Figure 2-1. Odd-Year Annual Review of Existing ELGs
2-7
-------
Section 2—Background
St 3'k eholder record mendations
and comments
identify SIC/MAILS codes
with discharges not subject
to existing ELC'S
Is the SIC/NAICS code
appropriately considered a
potential new sutcategory
of an twisting ELG?
Include in annual review
of
existing category
(see Figure 2-1)
gin industry
identification
TRA databases
/No identification or
yuither review necessary
Do
discharges interfere
with or otherwise pass
through POTW
opera" ions"?
Are pollutants
potentially present at
significant
concentrations?'
Is the possible nev»
category an & nearly all
indirect dischargers?
No identification or
further review
necessary
Identify otlw tool
e g permit-based
support or quidanc
Are.EI.i3s the
appropriate tool?
Further review
(seeFiqure 2-4)
"Sigrwhcant concentrattons include levels above mini mum levels from 40 CFR Part 136 or other EPA-approved methods,
levels above treatabihty levels, or at teveis of concern to human health and toxicity
Figure 2-2. Odd-Year Identification of Possible New ELGs
2-8
-------
Section 2—Background
Begin even-year review
of hazard data sources and
treatment technology
performance data
Continued review from
odd-year (as necessary!
1
identify industries with
pollutant
discharges not previously
reviewed
Collect additional date from
industry groups , published
reports from EPA, and peer-
review publications
Are pollutants
potentially present at
significant
concentrations'"
Determine if an
existing industry point source
;3tegory is applicable
to discharges
Do ELGs
appropriately
regulate all pollutant
discharges identified'?
Not a priority
category, no
further
review at this time
Further review
(see Figure 2-4)
Not a priority
category, no further
review at this time
'Significant concentrations includelevels above minimum levels from 40 CFR Part 136 or other EPA-approved methods.
levels above treatability 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
-------
Section 2—Background
Category identified for further
review (see Figures 2-1, 2-2, and 2-3).
Not enough
information
Stakeholder
input
Further Review
- 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 rev lew at this time
Identify for possible
promulgation or revision
of ELGs
Are ELGs potentially
the appropriate tool?
dentify 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 review 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 several 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. 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C.
(May). EPA-821-R-12-002. EPA-HQ-OW-2010-0824-0194.
2-11
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PART II: EPA's 2012 ANNUAL REVIEW
METHODOLOGY AND ANALYSES
-------
Section J—Introduction to EPA's 2012 Annual Review
3. INTRODUCTION TO EPA's 2012 ANNUAL REVIEW
The even-year review provides EPA with an opportunity to identify additional available
hazard data sources and conduct further analyses at the pollutant, industry, or wastewater
treatment technology levels. As described above in Section 2.2.2.2, EPA identified and
prioritized additional hazard data sources for the 2012 Annual Review based on (1) the
likelihood that they would assist in identifying unregulated industrial discharges, (2) their utility
in identifying new wastewater treatment technologies or pollution prevention alternatives, and
(3) how well the data represent the activity of an industrial category.
EPA is using the data sources and hazard analyses identified in this 2012 Annual Review
to screen additional industrial discharge categories and pollutants of concern and to identify for
further review those that potentially pose a hazard to human health or the environment. The 2012
Annual Review consisted of three components:
• Considering public comments and other stakeholder input received on the
Preliminary 2012 Plan (see Section 4).
• Continuing the preliminary category reviews (e.g., collecting more data,
contacting permit writers, evaluating available treatment technology information)
of specific point source categories that EPA identified as warranting additional
review in the Preliminary 2012 Plan (i.e., odd-numbered years) (see Sections 5.1,
5.2, and 5.3).
• Identifying and evaluating new industrial hazard data sources and analyzing these
data to (see Section 6.1 through Section 6.6):
— Identify new wastewater discharges or pollutants not previously regulated;
and
— Identify wastewater discharges that can be more effectively treated or
eliminated.
The specific data sources, analyses, and findings for each of the 2012 Annual Review
components listed above are described in detail in Section 4 through Section 6.6. A summary of
the 2012 Annual Review findings is presented in Part III of this report.
3-1
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
4. PUBLIC COMMENTS AND OTHER STAKEHOLDER INPUT ON THE
PRELIMINARY 2012 EFFLUENT GUIDELINES PROGRAM PLAN
EPA's annual review process considers information provided by the public and other
stakeholders regarding the need for new or revised effluent limitations guidelines and
pretreatment standards. Public comments received on EPA's prior reviews and Plans helped the
Agency prioritize its analysis of existing effluent guidelines and pretreatment standards. This
section presents a summary of the public comments and stakeholder input received on the
Preliminary 2012 Plan.
4.1 Public Comments and Stakeholder Input
EPA published its Preliminary 2012 Effluent Guidelines Program Plan (Preliminary 2012
Plan) and provided a 60-day public comment period starting on August 7, 2013 (see 78 FRN
48159). The Docket supporting this Final Plan includes a complete set of the comments
submitted, as well as the Agency's responses (see DCN 07979).
Commenting organizations representing industry included:
Westlake Vinyls Company
CONSOL Energy, Inc.
American Petroleum Institute
WPX Energy, Inc.
Enervest Operating, LLC
At Sea Processors Association
Western Energy Alliance
American Chemistry Council
Freezer Longline Coalition
Vinyl Institute
Petroleum Association of Wyoming
Ohio Oil and Gas Association
Pioneer Natural Resources USA, Inc.
Coalbed Methane Association of Alabama
American Forest & Paper Association
Independent Petroleum Association of America
Pacific Seafood Processors Association
Montana Petroleum Association, Inc.
Independent Oil and Gas Association of West
Virginia
Six environmental groups commented, including:
Cook Inletkeeper
Clean Water Action
Wyoming Outdoor Council
Northern Plains Resource Council
Powder River Basin Resource Council
Natural Resources Defense Council
Four additional organizations also provided comments including the Association of Clean
Water Administrators (a state representing organization), the National Association of Clean
Water Agencies (a publicly owned treatment works (POTWs) group), the Native Village of
Eklutna (a tribal government), and the Tuscaloosa County Commission (county government).
Comments addressed the following subject areas:
• Coalbed methane and shale gas extraction (17 comments)
• Chlorine and chlorinated hydrocarbon (3 comments)
• Oil and gas coastal subcategory (2 comments)
4-1
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
• Alaska offshore seafood processors (2 comments)
• Dental amalgam (1 comment)
• Effluent limitations guidelines and standards (ELGs) and Plan process in general
(1 comment)
• Other (1 comment)
For coalbed methane extraction (CBM extraction), EPA received 13 comments from
industry representatives and county government supporting the delisting of CBM extraction for
three main reasons:
• Additional costs would further reduce the feasibility of production, due to the
declining economics of the industry.
• CBM extraction production and discharges are declining.
• Discharges are already effectively permitted.
Environmental groups commented that EPA should move forward with developing
regulations for CBM extraction because EPA should not rely solely on economic considerations.
The environmental groups suggest that changes in gas production processes, gas demand, and
wastewater treatment costs could change EPA's findings. The environmental groups also noted
there are environmental impacts from CBM extraction discharges that need to be addressed and
provided data on new produced water treatment technologies that EPA should consider.
For chlorine and chlorinated hydrocarbon (CCH), two industry trade groups supported
the delisting for the reasons EPA presented in the Preliminary 2012 Effluent Guidelines Program
Plan. One company provided a comment correcting EPA's classification of their facility in
EPA's Chlorine and Chlorinated Hydrocarbon Data Collection and Analysis Summary report.
Two commenters, one environmental organization and one tribal government, asked EPA
to remove the exemption for Cook Inlet, Alaska from the nationwide zero discharge
requirements in the oil and gas coastal ELGs. One industry trade group requested that EPA
revise the requirements under the Alaska Offshore Seafood Processors General Permit AK-G2-
4000. Additionally, two industry trade groups petitioned EPA to initiate a rulemaking to add a
subpart to the Canned and Preserved Seafood Processing point source category, adding ELGs for
discharges resulting from the processing of seafood on mobile seafood processing vessels.
For Dental Amalgam, one POTW group requested that EPA take clear action on the draft
dental amalgam separator rule and expressed support for dropping it from consideration if EPA
did take such action.
One organization representing a number of states suggested improvements to the ELGs
and 304m process in general, including using additional data sources to consider improved
hazard data and advances in treatment technology. The commenter suggested that EPA
incorporate information from other EPA offices and states into the ELG program. The
commenter also stated that the metal finishing category should be re-examined because there
have been significant changes in the industry over the last few years.
4-2
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
One industry trade group expressed support for EPA's finding that pulp and paper mills
present a low risk and that the ELGs should be a lower priority for revision.
4-3
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
Table 4-1. Comments on the Preliminary 2012 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2010-0824
No.
1
2
o
J
4
5
6
7
8
9
10
11
Commenter Name
Eric VanderBeek
Wayne Stock
Lee O. Fuller
Kathleen M.
Sgamma
Carrie B. Crumpton
Judith Nordgren
David Gait
Richard P. Krock
W. Hardy
McCollum
Charlie Burd
Gretchen Kern
Commenter Organization
Northern Plains Resource
Council
Westlake Vinyls Company
Independent Petroleum
Association of America
(IPAA)
Western Energy Alliance
CONSOL Energy, Inc.
American Chemistry Council
(ACC)
Montana Petroleum
Association, Inc.
The Vinyl Institute
Tuscaloosa County
Commission
Independent Oil and Gas
Association of West
Virginia, Inc.
Pioneer Natural Resources
USA, Inc.
EPA
Docket
No.
0198
0200
0201
0202
0203
0204
0205
0206
0207
0208
0209
Comment Summary
Supports the development of CBM extraction ELGs. Also recommends that EPA
expand their study to include other oil and gas impacts from processes such as
hydraulic fracturing.
Provided data to correct facility information in the Chlorine and Chlorinated
Hydrocarbon (CCH) Data Collection and Analysis Summary.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan because many CBM extraction projects are no longer
economically feasible and because additional technology costs would further reduce
the feasibility of existing and future projects.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production and
sufficient state regulation of CBM extraction effluent.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production.
Supports EPA's decision to delist the CCH manufacturing industry from the Effluent
Guidelines Program Plan.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production and
sufficient state regulation of CBM extraction effluent.
Supports EPA's decision to delist the CCH manufacturing industry from the Effluent
Guidelines Program Plan for the reasons provided in the 2012 Program Plan and
because it is consistent with the results of the Voluntary Sampling Program, which
shows that current discharge levels are superior to international benchmark standards.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production and the fact
that ELGs are ill-suited to apply to CBM extraction operations.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production.
4-4
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
Table 4-1. Comments on the Preliminary 2012 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2010-0824
No.
12
13
14
15
16
17
18
Commenter Name
Ryan D.Elliott
Suzanne Bostrom,
Sarah Mackie
Joe Olson,
Gretchen Kohler
Chad I. See
Amy Emmert
Dennis Lathem
Cynthia A. Finley
Commenter Organization
Vorys on behalf of Ohio Oil
and Gas Association
Trustees for Alaska on behalf
of Cook Inletkeeper
WPX Energy, Inc.
Freezer Longline Coalition
American Petroleum Institute
(API)
Coalbed Methane
Association of Alabama
National Association of
Clean Water Agencies
(NACWA)
EPA
Docket
No.
0210
0211
0212
0213
0214
0215
0217
Comment Summary
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan because the state has adequate regulations for CBM
extraction effluent, the declining economic viability of the CBM extraction industry,
and the unreasonable burden such an ELG would impose on producers.
Recommends and provides information supporting that EPA remove the exemption
for Cook Inlet from the nationwide zero discharge requirement in the Oil and Gas
Coastal ELGs.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production.
Recommends EPA consider revising requirements under the Alaska Offshore Seafood
Processors General Permit AK-G2-4000, specifically the requirement to grind fish
waste to 0.5 inches and the quarterly water quality testing requirement.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production and
sufficient federal, state, and local level regulation of CBM extraction effluent.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan because of the adverse economic impact and the fact that
state regulation has proven effective to accomplish the same goals as the ELG.
Requests that EPA take action on the draft dental amalgam separator rule, but
expresses support for dropping it from consideration. Recommends that EPA allow
POTWs, states, and regions to develop their own dental amalgam separator programs,
as necessary, thereby addressing local needs better.
4-5
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
Table 4-1. Comments on the Preliminary 2012 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2010-0824
No.
19
20
21
22
23
Commenter Name
Susan Kirsch
Jerry Schwartz
Lynn Thorp
Marc Lamoreaux,
Lee Stephen
Jim Pritt, Barry Lay
Commenter Organization
Association of Clean Water
Administrators (ACWA)
American Forest & Paper
Association (AF&PA)
Clean Water Action et al.
Native Village of Eklutna
(NVE)
Enervest Operating, LLC
EPA
Docket
No.
0218
0219
0220
0221
0222
Comment Summary
Recommends EPA improve the ELG planning process and move the program forward
with the 20 14 Preliminary Plan, increase the staff allocated to working on ELGs, issue
future ELG Plans and Annual Review Reports in a more timely manner, incorporate
information from other parts of EPA into the ELG program, engage states early and in
ongoing dialogue during the planning process, prioritize facilities for review based on
the time elapsed since ELG revision and on the number of facilities regulated, and
expand its use of industry surveys to gather information. Recommends EPA
reexamine the metal finishing category due to significant changes in the industry over
the last few years. Recommends EPA acknowledge the status of ELGs under
development in future plans, particularly the rulemaking for dental amalgam.
Recommends EPA use information aside from TWFs to prioritize industries for
review, based on the toxicity of the discharge. Encourages EPA to expand its
screening process beyond DMR and TRI data to consider improved hazard data and
treatment technology advances.
Supports EPA's conclusion that pulp and paper mills present a low risk and the ELGs
should be a lower priority for revision.
Opposes EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan because CBM extraction produces large volumes of
wastewater characterized by the presence of numerous contaminants at potentially
high concentrations. Shifts in gas prices, demand, and costs of wastewater treatment
should also be considered. CBM extraction ELGs are necessary to prevent "pollution
havens." Commenter supports the ongoing revisions to the Onshore Oil and Gas ELGs
to address pollution from the unconventional oil and gas extraction industry.
Recommends and provides information supporting that EPA remove the exemption
for Cook Inlet from the nationwide zero discharge requirement in the Oil and Gas
Coastal ELGs.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production, economic
impacts, and effectiveness of current permits.
4-6
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Section 4—Public Comments and Other Stakeholder Input
on the Preliminary 2012 Effluent Guidelines Program Plan
Table 4-1. Comments on the Preliminary 2012 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2010-0824
No.
24
25
26
27
Commenter Name
L. John lani,
Charles R
Brumfield
John Robitaille
Amy Mall
Amber Wilson, Jill
Morrison
Commenter Organization
Perkins Cole on behalf of the
At Sea Processors
Association and the Pacific
Seafood Processors
Association
Petroleum Association of
Wyoming
Natural Resources Defense
Council
Wyoming Outdoor
Council/Powder River Basin
Resource Council
EPA
Docket
No.
0223
0224
0225
0226
Comment Summary
Provided a petition for EPA to initiate a rulemaking to add a subpart to the Canned
and Preserved Seafood Processing point source category which would establish ELGs
for discharges resulting from the processing of seafood on mobile seafood processing
vessels.
Supports EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan due to the decline in CBM extraction production.
Provides data on new technologies EPA should consider for CBM Extraction.
Opposes EPA's decision to delist the CBM Extraction subcategory from the Effluent
Guidelines Program Plan because EPA considered only the financial cost to industry
and overlooked the cost and impacts of untreated discharges.
4-7
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5. CONTINUED REVIEW OF SELECT POINT SOURCE CATEGORIES
For the 2012 Annual Review, EPA continued to evaluate three point source categories
requiring further review as identified in the Preliminary 2012 Plan: meat and poultry products
(40 CFR Part 432); petroleum refining (40 CFR Part 419); and pulp, paper, and paperboard (40
CFR Part 430) (U.S. EPA, 2013). EPA's continued review consisted of collecting additional
discharge data from permit writers, publicly available data sources (e.g., EPA's DMR Pollutant
Loading Tool), trade associations, and specific facility contacts to confirm the discharges
reported in the toxicity rankings analysis (TRA) databases. Additionally, EPA collected
information on available treatment technologies for specific industrial categories to compare
current discharges to discharge levels that are treatable with available technologies. Section 5.1
through Section 5.3 of this report details EPA's continued review of these three point source
categories.
5.1 Meat and Poultry Products (40 CFR Part 432)
During the 2011 Annual Review, EPA identified the Meat and Poultry Products Category
(40 CFR Part 432) for preliminary review because it ranked high, in terms of toxic-weighted
pound equivalents (TWPE), in the 2011 toxicity rankings analysis. See Table 4-3 in Section 4.1.6
of the Preliminary 2012 Effluent Guidelines Program Plan (U.S. EPA, 2013). EPA required
additional data to complete the preliminary category review and continued its review of the Meat
and Poultry Category during the 2012 review (U.S. EPA, 2012). Based on findings from the
2011 Annual Review, EPA continued to review discharges of nitrate compounds reported in the
Toxics Release Inventory (TRI), because of their high TWPE relative to other pollutants in the
Meat and Poultry Category. This section summarizes the findings from the 2011 and 2012
Annual Reviews associated with the Meat and Poultry Products Category.
5.1.1 Meat and Poultry Products Category Background
The meat and poultry industry includes facilities engaged in the slaughtering, dressing,
and packing of meat and poultry products for human consumption and/or animal food and feeds.
Meat and poultry products for human consumption include:
• Meat and poultry from cattle, hogs, sheep, chickens, turkeys, ducks, and other
fowl; and
• Sausages, luncheon meats, and cured, smoked, canned, or otherwise prepared
meat and poultry products from purchased carcasses and other materials.
Meat and poultry products for animal food and feeds include animal oils, meat meal, and
rendered grease and tallow from animal fat, bones, and meat scraps (40 CFR Part 32.1).
Part 432 regulates wastewater discharges from meat and poultry processing plants in 12
subcategories of products and product groups. EPA last updated effluent limitations guidelines
and standards (ELGs) for the Meat and Poultry Category (40 CFR Part 432) on September 8,
2004 (69 FR 54476). In addition to best practicable control technology (BPT) limitations, Part
432 includes limitations based on the best available technology economically achievable (BAT)
and new source performance standards (NSPS). Part 432 regulates conventional pollutants
5-1
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
(biological oxygen demand (BOD), fecal coliform, oil and grease, and TSS) for all subparts.
Excluding Subpart E (Small Processors), all subparts also regulate ammonia as nitrogen (N) and
total nitrogen, at plants exceeding a threshold pounds of annual live weight kill (LWK) (40 CFR
§432).
Table 5-1 presents the subpart applicability and ammonia as N and total nitrogen
limitations for each subpart. EPA focuses on the ammonia as N and total nitrogen regulations in
this section because nitrates are a top pollutant, in terms of TWPE, in the toxicity rankings
analysis databases. No pretreatment standards currently exist for meat and poultry products
facility discharges to publicly owned treatment works (POTWs).
Table 5-1. BAT ELG Limitations for the Meat and Poultry Products Category"
Subpart
Ac
Bc
Cc
Dc
Ed
F«
Subpart Title
Simple
Slaughterhouses
Complex
Slaughterhouses
Low-processing
Packinghouses
High-processing
Packinghouses
Small Processors
Meat Cutters
Subcategory Applicability
Process wastewater discharges
resulting from production of meat
carcasses by simple
slaughterhouses
Process wastewater discharges
resulting from production of meat
carcasses by complex
slaughterhouses
Process wastewater discharges
resulting from production of meat
carcasses by low-processing
packinghouses
Process wastewater discharges
resulting from production of meat
carcasses by high-processing
packinghouses
Process wastewater discharges
resulting from production of
finished meat products (i.e., fresh
meat cuts, smoked products,
canned products, hams, sausages,
and luncheon meats) by a small
processor
Process wastewater discharges
resulting from production of fresh
meat cuts (i.e., steaks, roasts, and
chops) by a meat cutter
Ammonia as Na
Max
Daily
(mg/L)
8.0
8.0
8.0
8.0
NA
8.0
Max
Monthly
Average
(mg/L)
4.0
4.0
4.0
4.0
NA
4.0
Total Nitrogenb
Max Daily
(mg/L)
194
194
194
194
NA
194
Max
Monthly
Average
(mg/L)
134
134
134
134
NA
134
5-2
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Table 5-1. BAT ELG Limitations for the Meat and Poultry Products Category"
Subpart
Ge
He
r
j
Kr
Lg
Subpart Title
Sausage and
Luncheon Meats
Processors
Ham Processors
Canned Meats
Processors
Renderers
Poultry First
Processing
Poultry Further
Processing
Subcategory Applicability
Process wastewater discharges
resulting from production of fresh
meat cuts, sausage, bologna, and
other luncheon meats by a
sausage and luncheon meat
processor
Process wastewater discharges
resulting from production of
hams by a ham processor
Process wastewater discharges
resulting from production of
canned meats by a canned meats
processor
Process wastewater discharges
resulting from production of meat
meal, dried animal byproduct
residues (tankage), animal oils,
grease and tallow, and hide
curing, by a Tenderer
Process wastewater discharges
resulting from slaughtering of
poultry, further processing of
poultry and rendering of material
derived from slaughtered poultry
Process wastewater discharges
resulting from further processing
of poultry
Ammonia as Na
Max
Daily
(mg/L)
8.0
8.0
8.0
0.14
(pounds
per 1,000
pounds
(g/kg) of
raw
material)
8.0
8.0
Max
Monthly
Average
(mg/L)
4.0
4.0
4.0
0.07
(pounds
per 1,000
pounds
(g/kg) of
raw
material)
4.0
4.0
Total Nitrogenb
Max Daily
(mg/L)
194
194
194
194
147
147
Max
Monthly
Average
(mg/L)
134
134
134
134
103
103
Source: 40 CFR §432.
NA: Not applicable.
a BPT limits include BOD5, fecal coliform, oil and grease, and TSS.
b Units are mg/L unless otherwise noted.
0 Any existing point source subject to this subpart that slaughters more than 50 million pounds per year (in units
LWK) must achieve the applicable BAT-based limits for total nitrogen and ammonia as N.
dThe Small Processors Subcategory has no BAT-based limits and therefore no limits for ammonia or total nitrogen;
however, it does have BPT- and NSPS-based limits for BODS, fecal coliform, oil and grease, and TSS.
e Any existing point source subject to this subpart that produces more than 50 million pounds per year of final
product must achieve the applicable BAT-based limit for total nitrogen. The ammonia as N BAT-based limit applies
to all facilities.
f Any existing point source subject to this subpart that slaughters more than 100 million pounds per year (in units
LWK) must achieve the applicable BAT-based limits for total nitrogen and ammonia as N.
g Any existing point source subject to this subpart that slaughters more than 7 million pounds per year (in units
LWK) must achieve the applicable BAT-based limits for total nitrogen and ammonia as N.
5-3
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5.1.1.1 Historic DMR and TRI Data for Meat and Poultry Products
Table 5-2 compares the toxicity rankings analysis results for the Meat and Poultry
Products Category from the 2009 through 2011 Annual Reviews.
Table 5-2. Meat and Poultry Category TRI and DMR Discharges for the 2009
Through 2011 Toxicity Rankings Analyses
Year of Discharge
2007C
2008C
2009
Year of Review
2009
2010
2011
Meat and Poultry Category
TRI TWPEa
35,900
61,600
53,800
DMR TWPEb
536,000d
15,700
17,200
Total TWPE
572,000
77,300
71,000
Sources: TRI Releases 2007 v2, DMRLoads2007_v4, TRIReleases2008_v3, DMRLoads2008_v3;
TRIReleases2009_v2; and DMRLoads2009_v2.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major dischargers.
0 EPA did not include the Meat and Poultry Products Category discharges in its 2009 and 2010 Annual Reviews
because the category ELGs were promulgated in 2004. In general, EPA does not review discharge data for an
industrial point source category if EPA established, revised, or reviewed the category's ELGs within seven years of
the annual review.
d In 2007, one facility's erroneous data caused the larger TWPE. This facility's reported fluoride discharges of
12,600,000 pounds and 439,500 TWPE are likely an error. The facility did not have any fluoride discharge in 2008,
2009, or 2010, therefore EPA believes this data to be erroneous.
Overall, the TWPE has decreased from 2007 to 2009, possibly resulting from
implementation of the 2004 ELGs. However, because the category ranked high, in terms of
TWPE, compared to other industry categories, EPA reviewed TRI and DMR data in detail for
the 2011 and 2012 reviews.
5.1.1.2 Nitrogen Compounds
The primary pollutants of concern in meat and poultry products wastewater are nitrogen
and specific nitrogen components including total Kjeldahl nitrogen (TKN),7 ammonia nitrogen,
and nitrite plus nitrate nitrogen. Because protein, which is the principal component of meat and
poultry, contains nitrogen, wastewaters from meat and poultry processing contain relatively high
concentrations of nitrogen (U.S. EPA, 2002).
Organic nitrogen, either soluble or particulate, is a mix of amino acids, amino sugars, and
proteins. In wastewater, organic nitrogen is readily converted to ammonia nitrogen by bacterial
decomposition. Ammonia nitrogen exists in water as the ammonium ion or ammonia gas,
depending on the pH of the water. In the presence of oxygen, oxidizing bacteria, different from
the bacteria that decompose organic nitrogen to ammonia, can oxidize the ammonia nitrogen to
nitrites and nitrates by nitrification. In the absence of oxygen, denitrifying bacteria will reduce
TKN is the portion of the total nitrogen that is organic and ammonia nitrogen only.
5-4
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
nitrate to nitrogen gas. The nitrogen gas will evaporate from the wastewater and enter the
atmosphere (Metcalf and Eddy, 2003).
As shown in Table 5-1, the ELGs for the meat and poultry products category include
limitations for both total nitrogen and ammonia as N. Figure 5-1 shows the relationship between
nitrogen compounds. EPA learned from facility contacts that they often measure nitrate (NOs) or
nitrate as nitrogen (NO3-N) (the amount of nitrogen in the nitrate form) regularly. Facilities that
estimate nitrate loads using nitrate as nitrogen measurements assume that all nitrogen compounds
convert to nitrate, and that nitrate as nitrogen therefore measures total nitrogen.
Total Nitrogen
TKN
.Nitrate
Nitrite
Ammonia
3 3
Adds
Proteins
Ammo
Snears
Amines, such as
Dinieth.vlaro.itis
Amides, such as
Dimethvlfonnanii de
Figure 5-1. Relationship Between Total Nitrogen Compounds
5.1.2 Results of the 2011 Annual Review
The following subsections describe the results of EPA's 2011 Annual Review of the
Meat and Poultry Products Category.
5.1.2.1 Meat and Poultry Pollutants of Concern
EPA's 2011 review of the Meat and Poultry Category focused on the 2009 TRI
discharges because the 2009 TRI data dominated the combined category TWPE. During the 2011
Annual Review, EPA identified nitrate compounds, accounting for 87 percent of the total 2009
Meat and Poultry TRI TWPE, as the top TRI pollutants of concern for the Meat and Poultry
5-5
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Category. See Table 11-4 of the 2011 Annual Review Report for the remaining top pollutants
identified during the 2011 Annual Review (U.S. EPA, 2012).
5.1.2.2 Meat and Poultry Nitrate Compound Discharges in TRI
Table 5-3 presents the facilities that account for the nitrate compound discharges in the
2009 TRI database. As shown in Table 5-3, EPA determined that the top 13 nitrate discharging
plants are located in nine states and include operations covered by Subpart B (Complex
Slaughterhouses), K (Poultry First Processing), or L (Poultry Further Processing). All three of
these subparts include ELGs for ammonia as N and total nitrogen.
During the 2011 Annual Review, EPA reviewed available permit and discharge data for
five of the 13 facilities. From the review of available data, EPA determined that all five facilities
are complex slaughterhouses, with operations covered by Subpart B of the Meat and Poultry
Products ELGs. EPA did not review the remaining eight facilities because the facility subpart
could not be determined during the 2011 Annual Review. EPA found that for the five complex
slaughterhouses, the facility permits include limitations for ammonia as N, but not total nitrogen.
EPA determined that the wastewater treatment operations at these five plants, matching the BAT
treatment basis of nitrification followed by partial denitrification, include some combination of
screening, anaerobic lagoons, aeration basins, chlorination, and dechlorination. See Section 11.4
in the 2011 Annual Review Report for more detailed information for each facility reviewed (U.S.
EPA, 2012).
5-6
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Table 5-3. Meat and Poultry Category Nitrate Compounds Dischargers in the 2009 TRI Database
Facility Name
Tyson Fresh Meats, Inc.
Tyson Fresh Meats, Inc., JoslinIL
Cargill Meat Solutions Corp.
Smithfield Packing, Co., Inc. Tar Heel Div.
Cargill Meat Solutions Corp.
Lewiston Processing Plant
Accomac Processing Plant
Farmland Foods, Inc.
JBS Plainwell
Cargill Meat Solutions Corp.
Tyson Fresh Meats, Inc.
Tyson Foods, Inc., Blountsville Processing Plant
Pilgrim's Pride Corp., Mt. Pleasant Complex
Location
Lexington, NE
Hillsdale, IL
Schuyler, NE
Tar Heel, NC
Beardstown, IL
Lewiston Woodville, NC
Accomac, VA
Crete, NE
Plainwell, MI
Wyalusing, PA
Columbus Junction, IA
Blountsville, AL
Mount Pleasant, TX
Subpart3
B
B
B
B
NDb
L
K
B
B
B
B
L
K
Remaining facilities reporting nitrate compound discharges0
Total
Nitrate Compound
Pounds Released
4,990,000
4,450,000
3,850,000
3,750,000
3,650,000
3,260,000
2,080,000
1,780,000
1,750,000
1,670,000
1,620,000
1,490,000
1,390,000
27,100,000
62,900,000
Nitrate Compound
TWPE
3,730
3,320
2,870
2,800
2,730
2,440
1,550
1,330
1,300
1,250
1,210
1,110
1,040
20,300
46,900
Facility Percent of
Nitrate Compound
Category TWPE
7.94%
7.08%
6.12%
5.96%
5.81%
5.19%
3.30%
2.84%
2.78%
2.66%
2.58%
2.37%
2.22%
43.20%
100%
Source: TRIReleases2009_v2.
ND: Not determined.
Note: Sums of individual values may not equal the total presented, due to rounding.
a See Table 5-1 for the description and applicability of the Subparts B, L, and K. During the 2011 Annual Review, EPA only determined the applicable subparts
for five of the 13 plants (U.S. EPA, 2012, see Section 11.4). EPA determined the subparts of the remaining eight plants as part of the 2012 Annual Review.
b EPA contacted Cargill Meat Solutions Corp in Beardstown, IL to determine the applicable subpart. Based on conversations with the facility contact, Cargill
Meat Solutions Corp is a slaughterhouse that processes pork. The processes at the facility include live rendering, boxing, and filling finished product. In 2012,
Cargill Meat Solutions processed 1.4 billion pounds (in units LWK) of pork. Cargill Meat Solutions Corp explained that the facility NPDES permit (last expired
in 2009) is still under review for revision by Illinois EPA (IEPA) (Barnes, 2013). Based on the facility information, EPA expects that with the revised facility
permit, Cargill Meat Solutions Corp will be regulated under 40 CFR Part 432, Subpart B (Complex Slaughterhouses), with total nitrogen limits.
0 103 additional facilities reported nitrate compounds discharges in the 2009 TRI, accounting for approximately 43 percent of the category's nitrate compounds
2009 TRI TWPE.
5-7
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5.1.3 Results of the 2012 Annual Review
EPA continued its review of the Meat and Poultry Products Category in 2012 by focusing
on the facilities with the highest nitrate compound discharges reported to TRI. EPA reviewed the
TRI nitrate compound reporting requirements and guidance. Additionally, EPA contacted the
nine state permitting authorities corresponding to the top 13 nitrate compounds discharging
facilities in Table 5-3 to evaluate nitrate discharges. To determine how the facilities estimated
TRI-reported nitrate discharges, EPA also contacted the two facilities with the highest reported
nitrate discharges. Finally, EPA reviewed 2010 and 2011 DMR discharge data from the DMR
Loading Tool to review the total nitrogen concentration ranges discharged from the top 13
facilities. The following subsections present EPA's findings from the 2012 Annual Review.
5.1.3.1 Reporting Nitrate Compounds to TRI
In the 2009 TRI, facilities report nitrate discharges under the chemical name "nitrate
compounds," if they estimate releases of nitrate compounds greater than 10,000 pounds per year.
According to the TRI Program's guidance document, the List of Toxic Chemicals Within the
Water Dissociable Nitrate Compounds Category and Guidance for Reporting., all dissociable
nitrate compounds, in aqueous solution, are included in nitrate compounds (U.S. EPA, 2000).
However, based on recent contacts, meat and poultry facilities typically measure either
nitrate or nitrate as nitrogen (NO3- N) and not total nitrogen. To estimate their nitrate loads, they
simply convert the pounds of nitrate as nitrogen to pounds of nitrate as shown in Equation 5-3
below.
1. Measurement of nitrate as nitrogen nitrate as nitrogen. From sampling data, a facility
might estimate that it releases 800 pounds of nitrate as nitrogen (or the amount of
nitrogen in the nitrate form) based on wastewater measurements.
2 Conversion of pounds of nitrate as nitrogen generated to pounds of nitrate. Using
molecular weights (MWs), the facility would convert the 800 pounds of nitrate as
nitrogen to the equivalent pounds of nitrate using the following equations.
Nitrate MW (NO3~) = 14 + (3 x 16) = 62 (Eq. 5-1)
Nitrogen MW (N) = 14 (Eq. 5-2)
NO3-MW
Estimated pounds of NO3 from nitrate as nitrogen = Estimated pounds of N x
or
Estimated pounds of NO3" from nitrate as nitrogen = 800 x — = 800 x 4.43 =
3,543 Pounds of N03' (Eq. 5-3)
5-8
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5.1.3.2 State Contacts
EPA contacted state permitting authorities for the 13 facilities with the highest TRI-
reported nitrate discharges. EPA contacted the state permitting authorities to determine the status
of the facilities' most recent permits, the nitrogen pollutants regulated by the facility permits, the
wastewater treatment operations at the plants, and any changes resulting from the revised Part
432 ELGs. Additionally, EPA requested the most recent facility permits and fact sheets. The
following subsections summarize EPA's contact with the state permitting authorities and review
of facility permits and fact sheets. Table 5-4 also summarizes EPA's findings from the
permitting authorities.
Nebraska Department of Environmental Quality (NE DEQ)
EPA contacted the NE DEQ to obtain facility permit information for Tyson Fresh
Meats, Inc., in Lexington; Cargill Meat Solutions Corp. in Schuyler; and Farmland Foods,
Inc., in Crete.
The permit writer for Tyson Fresh Meats, Inc. stated that the facility is a complex beef
slaughterhouse, with a production of approximately 6,000,000 pounds per day in LWK. Treated
process wastewater is discharged via outfall 001 to the Tri-County Canal. Wastewater is treated
in an onsite activated sludge treatment plant prior to discharge. Outfall 002 is maintained for
emergency purposes only and would discharge treated process wastewater to the Platte River
directly. Outfall 002 has never discharged.
The facility permit, issued October 2010, includes limitations for total nitrogen and
seasonal limitations for ammonia as N for outfalls 001 and 002. The total nitrogen permit
limitations are based on Part 432 and are 134 mg/L monthly average, 194 mg/L daily maximum.
The ammonia as N permit limitations are based on water-quality-based effluent limitations
(WQBELs) and Part 432. They are (NE DEQ, 2010a):
• Spring/winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum; and
• Summer: 2.4 mg/L monthly average, 5.4 mg/L daily maximum.
Cargill Meat Solutions Corporation is a complex beef slaughterhouse, with a production
of approximately 6,500,000 pounds per day in LWK. Treated process wastewater is discharged
via outfalls 001 and 003 to surface water and agricultural land application sites, respectively.
Process wastewater discharged to outfall 001 is treated with a dissolved air floatation unit,
anaerobic lagoon cells, a four chambered sequential batch reactor (an activated sludge plant), a
chlorine contact basin, and dechlorination. Discharges of nutrient-rich water from outfall 003
(treated process wastewater and non-contact cooling water) are used on agricultural land. (The
facility does not have an outfall 002) (NE DEQ, 2009).
The facility permit, issued October 2009, includes seasonal limitations for ammonia as N
for outfalls 001 and 003. The permit does not include limitations for total nitrogen. The permit
writer for Cargill Meat Solutions Corp. stated that the ammonia as N limitations were more
stringent than the water quality criteria; however, there are no limitations for total nitrogen
(Ewoldt, 2012). The ammonia as N permit limitations are (NE DEQ, 2009):
• Winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum;
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
• Spring: 2.58 mg/L monthly average, 5.17 mg/L daily maximum; and
• Summer: 1.89 mg/L monthly average, 3.79 mg/L daily maximum/
Farmland Foods, Inc., is a complex swine slaughterhouse, with a production of
approximately 2,800,000 pounds per day in LWK. Treated process wastewater is discharged via
outfall 001 to surface water. The process wastewater is treated by a dissolved air flotation unit,
two anaerobic lagoon cells, an anoxic tank, three aeration basins, two final clarifiers (activated
sludge plant), a chlorine contact basin and a dechlorination step, a v-notch weir, and a sludge
holding lagoon.
The facility permit, issued April 2010, includes limitations for total nitrogen and
ammonia as N for outfall 001. The total nitrogen permit limitations are based on Part 432 and are
134 mg/L monthly average, 194 mg/L daily maximum. Similarly, ammonia as N permit
limitations are based on Part 432 and are 4.0 mg/L monthly average, 8.0 mg/L daily maximum
(NEDEQ, 201 Ob).
Illinois Environmental Protection Agency (IEPA)
EPA contacted the IEPA to obtain the updated permits and facility information for Tyson
Fresh Meats, Inc., in Hillsdale and Cargill Meat Solutions, Corp., in Beardstown.
The Tyson Fresh Meats, Inc., facility is a beef slaughter and processing plant with
rendering activities. The maximum onsite slaughter LWK is 3,950,000 pounds per day. Treated
process wastewater, boiler blowdown, sanitary wastewater, miscellaneous wastewater,
storm water, and cooling water are discharged via outfall 001 to surface water.
The facility permit public notice, issued June 2011, includes limitations for total nitrogen
and seasonal limitations for ammonia as N for outfall 001. The total nitrogen permit limitations
are based on Part 432 and are 134 mg/L monthly average, 194 mg/L daily maximum. The
ammonia as N permit limitations are based on WQBELs and are (IEPA, 2011):
• Winter: 3.2 mg/L daily maximum;
• Spring/fall: 3.3 mg/L daily maximum; and
• Summer: 3.1 mg/L daily maximum.
Cargill Meat Solutions, Corp., is a minor discharger in the Meat and Poultry Products
Category. The facility is a pork processor that produces 5.6 million 8 oz servings per day. The
facility processes also include slaughtering, live rendering, and boxing and filling final product.
In 2012, the plant processed 1.4 billion pounds of pork (in units LWK) (Barnes, 2013). The
facility's old permit (expired in October 2009) includes seasonal limitations for ammonia as N
for outfalls 001 and 002. Non-contact cooling water is discharged via outfall 001 and treated
process wastewater and stormwater are discharged via outfall 002 to the Illinois River and an
unnamed tributary. The ammonia as N permit limitations for outfalls 001 and 002 are (IEPA,
2004):
• Winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum; and
• Summer: 2.5 mg/L monthly average, 5.0 mg/L daily maximum.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
In order to determine the status of the revised facility permit, EPA contacted Cargill Meat
Solutions, Corp. and determined that the new facility permit is still under review. Currently, the
facility has permission from IEPA to discharge in compliance with the expired permit. Because
the expired permit was issued prior to the revised 2004 ELGs, it does not include limitations for
total nitrogen. EPA expects that with the revised facility permit, Cargill Meat Solutions Corp will
be regulated under 40 CFR Part 432, Subpart B (Complex Slaughterhouses), with total nitrogen
limits.
North Carolina Department of Environmental and Natural Resources (NC DENR)
EPA contacted NC DENR to obtain the most recent permit information for Smithfield
Packing Co. in Tar Heel and Lewiston Processing Plant in Lewistown Woodville.
The Smithfield Packing Company, Tar Heel Division, is a hog slaughtering and pork
packing plant constructed in 1992 that currently harvests an average of 32,000 hogs per day
weighing approximately 267 pound per hog. The complex slaughterhouse processes more than
50 million pounds per year. The primary products are fresh cuts. Byproduct operations include
blood and hair collection, viscera handling, and inedible rendering (NC DENR, 2011). Treated
process wastewater is discharged through outfall 001. The facility treatment system includes
dissolved air flotation, anaerobic treatment, aeration, clarification, filtration, re-aeration, UV
disinfection, and chlorination/dechlorination.
The facility permit, issued February 2012, includes limitations for total nitrogen and
seasonal limitations for ammonia as N at outfall 001. The total nitrogen permit limitations are
based on Part 432 and are 134 mg/L monthly average, 194 mg/L daily maximum. The ammonia
as N permit limitations are more stringent than Part 432 and are (NC DENR, 2012):
• Winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum; and
• Summer: 2.0 mg/L monthly average, 7.5 mg/L daily maximum.
During the previous permit renewal period, Smithfield did not comply with new effluent
guideline requirements for total nitrogen. DENR pursued legal enforcement against Smithfield
on July 13, 2007. The company entered into a consent decree requiring the company to adhere to
a schedule of compliance. In response, Smithfield constructed new treatment systems, including
two 10,000- gallon carbon source storage tanks. Smithfield has made additional improvements to
its treatment systems since July 2007 including installation of three new floating surface aerators,
a two million gallon aeration basin, a centrifuge sludge dewatering system, a backup liquid
chlorination/dechlorination system, replacement of existing diffusers in three aeration basins, and
sludge facility improvements (NC DENR, 2011).
The Lewiston Processing Plant is a poultry further processing plant that slaughters broiler
chickens. Other plant operations include cutting, de-boning, marinating, packing, and rendering
of byproducts. The facility processes 400,000 birds per day (NC DENR, 2007). Outfall 001
discharges process wastewater. Wastewater treatment includes sedimentation, screening, two
anaerobic lagoons, an equalization basin, oxidation ditch for nitrification/denitrification,
secondary clarifier, chlorination and dechlorination, sludge gravity thickener, and digestion.
5-11
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
The facility permit, issued February 2008, includes total nitrogen and ammonia as N
limitations for outfall 001. The total nitrogen permit limitations are based on Part 432 and are
103 mg/L monthly average, 147 mg/L daily maximum. The ammonia as N permit limitations are
also based on Part 432 and are 4.0 mg/L monthly average, 8.0 mg/L daily maximum (NC DENR,
2008).
Virginia Department of Environmental Quality (VA DEQ)
EPA contacted VA DEQ to obtain the most recent permitting information for the
Accomac Processing Plant in Accomac. The Accomac Processing Plant is a poultry first
processing plant with a production of approximately 450,000,000 pounds per year in LWK (VA
DEQ, 2010). The facility permit, issued September 2011, includes limitations for total nitrogen
and seasonal limitations for ammonia as N for outfall 001, which discharges to the Atlantic
Ocean. The total nitrogen permit limitations are based on Part 432 and are 103 mg/L monthly
average, 147 mg/L daily maximum. The ammonia as N limitations are based on WQBELs and
are (VA DEQ, 2011):
• Winter: 4.0 mg/L monthly average, 8.0 mg/L daily maximum; and
• Summer: 2.0 mg/L monthly average, 7.5 mg/L daily maximum.
Michigan Department of Environmental Quality (MI DEQ)
EPA contacted MI DEQ to obtain the recent permitting information for JBS Plainwell in
Plainwell. The facility is a complex slaughterhouse with a production of approximately
520,000,000 pounds per year in LWK (MI DEQ, 2011). The facility permit, issued November
2011, does not include limitations for total nitrogen. The only nitrogen compound permit
limitation included is ammonia nitrogen (as N) for outfall 001, which discharges to the
Kalamazoo River (MI DEQ, 2011). Based on Part 432, the facility permit should also include
limitations for total nitrogen.
Pennsylvania Department of Environmental Protection (PA DEP)
EPA contacted PA DEP to obtain the most recent permit information for Cargill Meat
Solutions in Wyalusing. PA DEP stated that the facility is a large complex slaughterhouse that
discharges to the Chesapeake Bay. PA DEP further explained that it recently revised the
facility's permit, which last expired in March 2009, developing total nitrogen limitations based
on Chesapeake Bay water quality criteria requirements, which are more stringent than the ELGs.
EPA has not yet approved the state's permit for this facility (i.e., the permit limits may change)
(Randis, 2012).
PA DEP and Cargill are negotiating a compliance schedule to be in effect in 2012. To
meet the new permit limits, the plant will add an aerobic and anaerobic treatment system. The
compliance schedule currently requires the Cargill Meat Solutions facility to meet new permit
limitations for total nitrogen by August 2013 (Randis, 2012).
Iowa Department of Natural Resources (IA DNR)
EPA contacted IA DNR to obtain facility permit information for Tyson Fresh Meats,
Inc., in Columbus Junction. The facility permit writer stated that the permit is very old and is
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
currently under revision. The permit currently only requires monitoring of total nitrogen (no
numerical limitations); however, numerical limitations will be included in the revised permit as
required by the 2004 revised ELGs. The permit revision is on hold until the state classifies the
receiving water stream to determine if total nitrogen limitations will be developed based on Part
432 or WQBELs (Heeb, 2012).
Alabama Department of Environmental Management (ADEM)
EPA contacted ADEM to obtain facility permit information for Tyson Foods, Inc., in
Blountsville. Tyson Foods is a poultry processing plant with a production of over 50,000,000
pounds per year. The facility discharges treated process wastewater via outfall 001.
The facility permit, issued October 2005, requires the facility to monitor for nitrate and
nitrite and limits total nitrogen, ammonia as N, and TKN. The total nitrogen permit limitations
are based on Part 432 and are 103 mg/L monthly average, 147 mg/L daily maximum. The
ammonia as N permit limitations are more stringent than Part 432, requiringl.6 mg/L monthly
average, 2.4 mg/L daily maximum (ADEM, 2005).
Texas Commission of Environmental Quality (TCEQ)
EPA contacted TCEQ to obtain the most recent facility permit information for Pilgrim's
Pride Corp. in Mount Pleasant. The facility is a poultry first processing plant, recently under
new ownership. Its permit, which is currently under revision, includes limitations for total
nitrogen and seasonal limitations for ammonia as N. According to the draft facility permit, the
facility discharges treated process wastewater via outfall 001. The process wastewater is treated
by primary and secondary screening for solids removal, flow equalization, dissolved air flotation
with chemical addition, biotower treatment, two activated sludge aeration basins, two final
clarifiers, sand filtration, chlorination, and dechlorination.
The draft total nitrogen permit limitations are based on Part 432 and are 103 mg/L
monthly average, 147 mg/L daily maximum. The ammonia as N draft permit limitations are
based on water quality criteria. They are (TCEQ, 2011):
• Winter: 8.0 mg/L monthly average, 16.0 mg/L daily maximum; and
• Summer: 1.0 mg/L monthly average, 2.0 mg/L daily maximum.
5.1.3.3 Facility-Specific Contacts
In addition to the state contacts described above, EPA also contacted the top two 2009
TRI nitrate dischargers, Tyson Fresh Meats, Inc. (Lexington) and Tyson Fresh Meats, Inc.
(Hillsdale), to determine how they were estimating the nitrate loads reported in the 2009 TRI
database. To report discharges to the TRI database, facilities can use available monitoring data,
emission factors, engineering calculations or other estimations including mass balance equations.
Therefore, EPA contacted these facilities to determine if the nitrate loads reported were based on
monitoring data, engineering calculations, or other estimation methods.
5-13
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Tyson Fresh Meats, Inc., in Lexington, Nebraska
Tyson Fresh Meats, a complex slaughterhouse, reported 4.99 million pounds of nitrate
compound discharges in the 2009 TRI database. This facility accounted for approximately 8
percent of the total 2009 TRI nitrate compound TWPE. The facility contact confirmed the 2009
TRI nitrate load and explained that they estimate the load using nitrogen monitoring data. The
plant collects samples three times weekly and analyzes them onsite for nitrate as nitrogen. To
estimate the nitrate compound load for TRI, the facility multiplies its nitrate as nitrogen
concentration and flow to calculate a nitrate as nitrogen load. They then convert to pounds of
nitrate by multiplying by the factor of 4.43. See Equations 5-1 through 5-3 for the more detailed
calculations. The facility assumes that all of the nitrogen is completely oxidized to nitrate by
nitrification and that their reported TRI amount reflects their total nitrogen release (Loeg, 2012).
Additionally, the facility contact stated that due to the 2010 permit revision to include
total nitrogen limitations, they estimate that their nitrate loads decreased to 3.4 million pounds in
2010. To meet the new total nitrogen limitations, the facility changed two complete mixing
basins (previously part of the extended air basin) to an on/off system, so aeration is occurring
half of the time in the wastewater treatment system. This creates an anoxic environment, and
achieves both nitrification and denitrification (Loeg, 2012).
Tyson Fresh Meats, Inc., in Hillsdale, Illinois
Similar to the Tyson Fresh Meats in Nebraska, the Tyson Fresh Meats in Hillsdale is a
complex slaughterhouse. The facility reported 4.45 million pounds of nitrate compound
discharges in the 2009 TRI database, accounting for approximately 7 percent of the total 2009
TRI nitrate compound TWPE. The facility contact confirmed the 2009 TRI nitrate load and
explained that the facility estimates its load using the same approach as the Tyson Fresh Meats in
Nebraska. The facility multiplies its nitrate as nitrogen concentration and flow to calculate a
nitrate as nitrogen load. They then convert to pounds of nitrate by multiplying by the factor of
4.43. See Equations 5-1 through 5-3 for the more detailed calculations (Rastessin, 2012).
Additionally, the facility recently received its new discharge permit from the state, which
implements the total nitrogen permit limitations in Part 432.The facility is currently evaluating
its wastewater treatment system to determine if it needs to make any changes to meet the new
total nitrogen limitations (Rastessin, 2012).
5.1.3.4 DMR Data for Top Nitrate Dischargers
EPA reviewed 2010 and 2011 DMR data for the top 13 facilities discharging nitrate
compounds to determine if total nitrogen loads, including nitrate, are decreasing as a result of the
2004 ELGs. In addition to determining if any plants exceed the total nitrogen limitations, the
availability of 2010 and 2011 DMR data also suggest that some plants are still receiving revised
permits with total nitrogen limitations through the reporting year 2011.
By comparing the DMR data to the data from permit writers, facility permits, facilities,
and TRI, EPA determined that the top 13 facilities from Table 5-3 are:
• Currently meeting permit limitations for total nitrogen, which includes the nitrate
discharges;
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
• Receiving revised permit with total nitrogen limitations by the end of 2012; or
• Currently waiting for a revised permit from the state that are expected to include
total nitrogen limitations based on subpart applicability.
Additionally, two facilities are taking action to improve wastewater treatment to address
new total nitrogen permit limitations.
However, EPA also determined that two facilities do not have total nitrogen limitations in
renewed permits, even though they appear to meet the production threshold to be considered
regulated by 40 CFR Part 432. Table 5-4 lists the top nitrate dischargers in the 2009 TRI
database, their most recent permit issue date, the range of total nitrogen concentrations reported
from 2010 through 2011, and EPA's findings from the 2012 Annual Review. EPA selected the
range from 2010 through 2011 to capture those facilities that received revised permits in late
2010 or early 2011.
From the data provided in Table 5-4, EPA determined that:
• Six facilities have permits with total nitrogen limitations and are not reporting
concentrations that exceed the ELG-based limitations;
• Four facilities have recently received revised permits or are still waiting for
revised permits that will include total nitrogen limitations;
• One facility is still waiting for a revised permit, but EPA was still unable to
confirm the applicable subpart with the facility contact. Based on information
from the facility contact, EPA expects that the facility will be regulated under 40
CFR Part 432, Subpart B (Complex Slaughterhouses), with total nitrogen limits in
the revised facility permit; and
• Two facilities have recently revised permits that do not include total nitrogen
limitations.
For the five facilities with recently revised, or pending revised, permit limitations for
total nitrogen, EPA expects a decrease in total nitrogen, including nitrate compounds, as facilities
comply with their new permit limitations. For the two facilities that do not have total nitrogen
limitations, facility-specific permitting action may be warranted to ensure permits appropriately
incorporate the 2004 ELGs.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Table 5-4. Permit Status as of January 2012 and DMR Total Nitrogen Concentrations for Meat and Poultry Treated Process
Wastewater Outfalls
Facility Name
Tyson Fresh Meats, Inc.
Tyson Fresh Meats, Inc.,
Joslin, IL
Cargill Meat Solutions
Corp.
Smithfield Packing, Co.,
Inc., Tar Heel Div.
Cargill Meat Solutions
Corp.
Lewiston Processing Plant
Accomac Processing Plant
Farmland Foods, Inc.
JBS Plain-well
Cargill Meat Solutions
Corp.
State
NE
IL
NE
NC
IL
NC
VA
NE
MI
PA
Subpart
B
B
B
B
NDb
L
K
B
B
B
Date Most
Recent Permit
Issued
October 2010
June 20 IT
October 2009
February 20 12
Under Revision
February 2008
September 20 11
April 20 10
November 20 11
Under Revision
Part 432 Total
Nitrogen Max
Daily (mg/L)
194
194
194
194
NA
147
147
194
194
194
Part 432 Total
Nitrogen Max
Monthly
Average
(mg/L)
134
134
134
134
NA
103
103
134
134
134
2010-2011 Monthly
Average Total
Nitrogen
Concentration
Range (mg/L)
38-80.7
NA
NA
80.8-119
NA
94.8C
69-85
30-97.8
NA
NA
EPA Findings
In compliance with Part 432 total
nitrogen limitations.
Public announcement for facility
permit released in 201 1, facility still
waiting to receive revised permit with
total nitrogen limitations.
Facility appears to meet requirements
for Part 432; however, permit does not
limit total nitrogen.
In compliance with Part 432 total
nitrogen limitations.
IEPA is still reviewing this facility
before issuing a new permit, currently
the facility discharges in compliance
with the old permit (expired 10/2009)
In compliance with Part 432 total
nitrogen limitations.
In compliance with Part 432 total
nitrogen limitations.
In compliance with Part 432 total
nitrogen limitations.
Facility appears to meet requirements
for Part 432; however, permit does not
limit total nitrogen.
Permit is currently under revision,
plant has not yet received revised
permit.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
Table 5-4. Permit Status as of January 2012 and DMR Total Nitrogen Concentrations for Meat and Poultry Treated Process
Wastewater Outfalls
Facility Name
Tyson Fresh Meats, Inc.
Tyson Foods, Inc.,
Blountsville Processing
Plant
Pilgrim's Pride Corp., Mt.
Pleasant Complex
State
IA
AL
TX
Subpart
B
L
K
Date Most
Recent Permit
Issued
Under Revision
October 2005
Under Revision
Part 432 Total
Nitrogen Max
Daily (mg/L)
194
147
147
Part 432 Total
Nitrogen Max
Monthly
Average
(mg/L)
134
103
103
2010-2011 Monthly
Average Total
Nitrogen
Concentration
Range (mg/L)
NA
70.6-94.8
NA
EPA Findings
Permit is currently under revision,
plant has not yet received revised
permit.
In compliance with Part 432 total
nitrogen limitations.
Permit is currently under revision,
plant has not yet received revised
permit.
Source: EPA Envirofacts.
NA: Not applicable.
ND: Not determined.
Under revision: The facility permit is under revision to include total nitrogen limitations. Therefore, total nitrogen concentrations are not included in the 2010
through 2011 DMR data.
a IEPA issued the permit notice for the Tyson Fresh Meats, Inc., Joslin facility in June 2011; not the actual final permit.
b EPA contacted Cargill Meat Solutions Corp in Beardstown, IL to determine the applicable subpart. Based on conversations with the facility contact, Cargill
Meat Solutions Corp is a slaughterhouse that processes pork. The processes at the facility include live rendering, boxing, and filling finished product. In 2012,
Cargill Meat Solutions processed 1.4 billion pounds (in units LWK) of pork. Cargill Meat Solutions Corp explained that the facility NPDES permit (last expired
in 2009) is still under review for revision by Illinois EPA (IEPA) (Barnes, 2013). Based on the facility information, EPA expects that with the revised facility
permit, Cargill Meat Solutions Corp will be regulated under 40 CFR Part 432, Subpart B (Complex Slaughterhouses), with total nitrogen limits.
0 Facility reported total nitrogen concentration for only one month in 2011.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5.1.4 Summary of Findings from EPA's Review of Meat and Poultry Products Category
Using data collected for the 2012 Annual Review, EPA identified the following for the
Meat and Poultry Category:
• Some facilities are estimating nitrate compounds loads in the TRI database using
nitrate as nitrogen concentrations from effluent discharges, and converting the
load based on molecular weight to nitrate.
• EPA reviewed the 2009 DMR total nitrogen discharges for the top nitrate
compound discharging TRI facilities. EPA determined that the majority of these
facilities are in compliance with the ELGs for total nitrogen or are currently
awaiting revised permits that will include total nitrogen permit limitations. One
facility documented a reduction in nitrate load as a result of more stringent total
nitrogen limits. EPA expects a decrease in total nitrogen, including the nitrate
compounds, as new permits include the 2004 ELG revisions.
• Two facilities do not currently have total nitrogen permit limitations; however,
Part 432 appears to apply to them. These facility's total nitrogen/nitrate
discharges may best be handled by facility-specific permitting action.
• Eight of thirteen facilities have, or are projected to have, WQBELs for ammonia
as N rather than ELG-based limitations. The WQBELs are more stringent in most
cases than limits based on Part 432.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above findings, EPA is assigning this category a lower priority for revision
— i.e., this category is marked "(3)" in the "Findings" column in Table 7-1 in the Final 2012 and
Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014).
5.1.5 References for Meat and Poultry Products Category
1. ADEM. 2005. Alabama Department of Environmental Management. Facility Permit for
NPDES ALOOO1449—Tyson Foods, Inc., Blountsville, AL. (November 6). EPA-HQ-
OW-2010-0824. DCN 07524.
2. Barnes, Courtney. 2013. Telephone Communication Between Courtney Barnes, Cargill
Meat Solutions, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Facility Permit
Status. (May 13). EPA-HQ-OW-2010-0824. DCN 07799.
3. Ewoldt, Cay. 2012. Telephone and Email Communication Between Cay Ewoldt, NPDES
Permits and Compliance Unit, NE DEQ, and Kimberly Landick, Eastern Research
Group, Inc., Re: Meat and Poultry Facility Nitrogen Discharges. (January 25). EPA-HQ-
OW-2010-0824. DCN 07800.
4. Heeb, Wendy. 2012. Telephone Communication Between Wendy Heeb, Iowa
Department of Natural Resources, and Elizabeth Sabol, Eastern Research Group, Inc.,
Re: 2009 TRI Total Nitrogen and Nitrate Discharges. (January). EPA-HQ-OW-2010-
0824. DCN 07801.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
5. IEPA. 2004. Illinois Environmental Protection Agency. Facility Permit for NPDES
IL0023914—Cargill Meat Solution Corporation—Beardstown, IL. (September 24). EPA-
HQ-OW-2010-0824. DCN 07802.
6. IEPA. 2011. Illinois Environmental Protection Agency. Public Notice of Facility Permit
for NPDES IL0003913—Tyson Fresh Meats, Inc., Hillsdale, IL. (June 3). EPA-HQ-OW-
2010-0824. DCN 07803.
7. Loeg, Chris. 2012. Telephone Communication Between Chris Loeg, Tyson Fresh Meats,
Inc., and Elizabeth Sabol, Eastern Research Group, Inc., Re: Total Nitrogen Discharges,
Tyson Fresh Meats, Inc. (March 16). EPA-HQ-OW-2010-0824. DCN 07805.
8. Metcalf and Eddy. 2003. Wastewater Engineering Treatment and Reuse. Fourth Edition.
McGraw-Hill. New York, New York. DCN 07804.
9. MI DEQ. 2011. Michigan Department of Environmental Quality. Treatment Technology
Based Effluent Limits (TTBELs) Recommendation for NPDES ID MI0050628—IBS
Plainwell, Inc., Plainwell, MI. (April 5). EPA-HQ-OW-2010-0824. DCN 07806.
10. NC DENR. 2007. North Carolina Department of Environment and Natural Resources.
Facility Fact Sheet for NPDES NC0028835—Purdue Farms, Inc —Lewistown Plant,
Lewistown, NC. (October 15). EPA-HQ-OW-2010-0824. DCN 07807.
11. NC DENR. 2008. North Carolina Department of Environment and Natural Resources.
Facility Permit for NPDES NC0028835—Purdue Farms, Inc.—Lewistown Plant,
Lewistown, NC. (February 1). EPA-HQ-OW-2010-0824. DCN 07808.
12. NC DENR. 2011. North Carolina Department of Environment and Natural Resources.
Facility Fact Sheet for NPDES NC0078344—Smithfield Packing Company Inc., Tar
Heel, NC. (November 22). EPA-HQ-OW-2010-0824. DCN 07809.
13. NC DENR. 2012. North Carolina Department of Environment and Natural Resources.
Facility Permit for NPDS NC0078344—Smithfield Packing Company Inc., Tar Heel,
NC. (February 1). EPA-HQ-OW-2010-0824. DCN 07810.
14. NE DEQ. 2009. Nebraska Department of Environmental Quality. Facility Permit and
Fact Sheet for NPDES NE0000795—Cargill Meat Solutions Corp., Schuyler, NE.
(October 1). EPA-HQ-OW-2010-0824. DCN 07811.
15. NE DEQ. 2010a. Nebraska Department of Environmental Quality. Facility Permit and
Fact Sheet for NPDES NE0123501—Tyson Fresh Meats, Inc., Lexington, NE. (October
1). EPA-HQ-OW-2010-0824. DCN 07812.
16. NE DEQ. 2010b. Nebraska Department of Environmental Quality. Facility Permit and
Fact Sheet for NDPES 0032191—Farmland Foods Inc., Crete, NE. (April 1). EPA-HQ-
OW-2010-0824. DCN 07813.
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Section 5—Continued Review of Select Point Source Categories
5.1—Meat and Poultry Products (40 CFR Part 432)
17. Randis, Tom. 2012. Telephone and Email Communication Between Tom Randis,
Pennsylvania Department of Environmental Protection, and Elizabeth Sabol, Eastern
Research Group, Inc., Re: Cargill Meat Facility Total Nitrogen Discharges. (January).
EPA-HQ-OW-2010-0824. DCN 07814.
18. Rastessin, Kim. 2012. Telephone Communication Between Kim Rastessin, Tyson Fresh
Meats, Inc., and Elizabeth Sabol, Eastern Research Group, Inc., Re: Total Nitrogen
Discharges and Permit Changes, Tyson Fresh Meats, Inc. (March 20). EPA-HQ-OW-
2010-0824. DCN 07815.
19. TCEQ. 2011. Texas Commission on Environmental Quality. Draft Facility Permit for
NPDES TX0062936—Pilgrim's Pride Corp., Mount Pleasant, TX. (January). EPA-HQ-
OW-2010-0824. DCN 07816.
20. U.S. EPA. 2000. Toxic Release Inventory List of Chemicals within the Water Dissociable
Nitrate Compounds Category and Guidance for Reporting. Washington, DC. (December).
EPA 745-R-00-006. EPA-HQ-OW-2004-0032-0816.
21. U. S. EPA. 2002. Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Meat and Poultry Products Industry Point Source
Category. Washington, D.C. (January). EPA-821-B-01-007. EPA-HQ-OW-2010-0824.
DCN 07817.
22. U.S. EPA. 2012. 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA-821 -R-12-001 .EPA-HQ-OW-2010-0824-0195.
23. U.S. EPA. 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C.
(May). EPA-821-R-12-002. EPA-HQ-OW-2010-0824-0194.
24. 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-2010-0824. DCN
07756.
25. VA DEQ. 2010. Virginia Department of Environmental Quality. Facility Permit
Application for NPDES VA0003808—Purdue Farms, Inc.—Accomac Processing Plant,
Accomac, VA. (December 1). EPA-HQ-OW-2010-0824. DCN 07818.
26. VA DEQ. 2011. Virginia Department of Environmental Quality. Facility Permit for
NPDES VA0003808—Purdue Farms, Inc.—Accomac Processing Plant, Accomac, VA.
(September 29). EPA-HQ-OW-2010-0824. DCN 07819.
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
5.2 Petroleum Refining (40 CFR Part 419)
During the 2011 Annual Review, EPA identified the Petroleum Refining Category (40
CFR Part 419) for preliminary review because it ranked high, in terms of toxic-weighted pound
equivalents (TWPE), in the 2011 toxicity rankings analysis. See Table 4-3 in Section 4.1.6 of the
Preliminary 2012 Effluent Guidelines Program Plan (U.S. EPA, 2013a). EPA needed additional
data to complete the preliminary category review, so this review continued in the 2012 Annual
Review (U.S. EPA, 2012).
This section summarizes the findings from the 2011 and 2012 Annual Reviews associated
with the Petroleum Refining Category. Based on findings from the 2011 Annual Review, EPA
continued to review discharges of dioxin and dioxin-like compounds from the Toxics Release
Inventory (TRI) because of their high TWPE. EPA reviewed metals discharges because of high
TWPE and industry trends that might affect metals discharges. These industry trends include the
use of new feedstock such as Canadian crude oil and tar sands (Purdue-Argonne Task Force,
2011), and additional air pollution control (see Section 6.3). EPA compared the concentrations of
metals that refineries report in their wastewater discharges to recent academia and effluent
guidelines industry studies (see Section 5.2.3.2) on the performance of chemical precipitation,
biological, and ultrafiltration treatment and found that the highest 2010 daily maximum
discharge concentrations reported by many refineries exceed the concentrations achievable by
these treatments.
5.2.1 Petroleum Refining Category Background
The Petroleum Refining ELGs (40 CFR Part 419) were promulgated in 1982. EPA has
not revised the ELGs, but has subsequently reviewed discharges from petroleum refineries as
part of the Preliminary and Final Effluent Guidelines Program Plans in 2004-2010 (U.S. EPA,
2004, 2005, 2006, 2007, 2008, 2009a, 2011). During its 2004 Final Effluent Guidelines Program
Plan reviews, EPA also conducted a detailed study of this industry (U.S. EPA, 2004). Table 5-5
compares the toxicity rankings analysis results for the Petroleum Refining Category from the
2007 through 2011 Annual Reviews. See Section 19.1 of EPA's 2011 Annual Review Report for
more background on the petroleum refining category (U.S. EPA, 2012).
5-21
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-5. Petroleum Refining Category TRI and DMR Discharges for 2007 Through
2011 Toxicity Rankings Analysis
Year of Discharge
2004
2005
2007
2008
2009
Year of Review
2007
2008
2009
2010
2011
Petroleum Refining Category
TRI TWPEa
669,000
628,000
172,000
410,000
436,000
DMR TWPEb
819,000
NA
403,000
680,000
295,000
Total TWPE
1,490,000
NA
575,000
1,090,000
731,000
Sources: TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; and DMRLoads2009_v2.
NA: Not applicable. EPA did not evaluate DMR data for 2005.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Discharges include transfers to publicly owned treatment works (POTWs) and account for POTW removals.
b MR data from 2004 through 2007 include only major dischargers. 2008 and 2009 DMR data include both minor
and major dischargers.
5.2.2 Results of the 2011 Annual Review
EPA's 2011 review of the Petroleum Refining Category focused on the 2009 TRI and
discharge monitoring report (DMR) discharges because both contribute to the category's
combined TWPE. Tables 19-2 and 19-3 in Section 19.2 of the 2011 Annual Review Report
present the top 2009 TRI and DMR pollutants for the petroleum refining category (U.S. EPA,
2012). EPA investigated the top TRI pollutants, dioxin and dioxin-like compounds and
polycyclic aromatic compounds (PACs), because they account for 80 percent of the total 2009
TRI TWPE. EPA investigated the top DMR pollutants, sulfide and chlorine, because they
account for more than 61 percent of the total 2009 DMR TWPE. Additionally, EPA reviewed
DMR metals discharges because of high TWPE and changes in industry trends that might affect
metals discharges. In reviewing the 2009 TRI and DMR database pollutants of concern, EPA
reached the following conclusions as part of the 2011 Annual Review:
• In a 2004 detailed study EPA concluded that the petroleum refining PAC
discharges reported to TRI are either (1) based on half the detection limit
multiplied by the flow or (2) estimated using emission factors and; therefore,
concluded that there is little evidence that PACs are being discharged to surface
waters in concentrations above the detection limit (U.S., EPA 2004). The
petroleum refining PAC TWPE is consistent from discharge years 2004 to 2009;
therefore, EPA determined findings from the 2004 detailed study of the industry
still apply, and that PAC discharges do not present a hazard priority at this time.
• During the 2011 Annual Review, EPA found that four facilities account for 54
percent of the 2009 DMR sulfide discharges. The majority of discharges for all
four facilities were below or near treatable levels; therefore, EPA does not
consider these sulfide discharges a hazard priority at this time;
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
• During the 2011 Annual Review, EPA identified and corrected an error in DMR
chlorine discharges; EPA accordingly concludes that chlorine discharges do not
present a hazard at this time (U.S. EPA, 2012);
• EPA previously determined that refineries form dioxin and dioxin-like
compounds during catalyst regeneration operations for the catalytic reforming
process. One refinery, Hovensa, accounts for 65 percent of the dioxin and dioxin-
like compound discharges reported by the category in TRI2009. The facility
reported an increase in dioxin and dioxin-like compound discharges from 2008 to
2009. According to the facility contact, the increase in dioxin and dioxin-like
compound discharges was due to an increase in the number of catalyst
regenerations in 2009. For other refineries, EPA needed more information to
verify the refinery-specific data for 2009. Therefore, EPA continued to review
dioxin and dioxin-like compound discharges from petroleum refineries during the
2012 Annual Review (U.S. EPA, 2012); and
• EPA identified the need for more information about discharges of metal pollutants
during the 2011 Annual Review. Therefore, EPA continued to review metals
discharges from petroleum refineries during the 2012 Annual Review (U.S. EPA,
2012).
5.2.3 Results of the 2012 Annual Review
EPA's continued review of the Petroleum Refining Category as part of the 2012 Annual
Review focused on dioxin and dioxin-like compound discharges reported to TRI and metals
discharges reported in DMR. The following subsections present the findings from EPA's review.
5.2.3.1 Petroleum Refining Dioxin and Dioxin-Like Compound Discharges
EPA continued to review dioxin and dioxin-like compound discharges from petroleum
refineries during the 2012 Annual Review by collecting additional data to verify facility
discharges. EPA determined in its 2011 Annual Review Report that dioxin and dioxin-like
compounds contribute 72 percent of the total petroleum refining category 2009 TRI TWPE and
increased by approximately 15,000 TWPE from reporting years 2008 to 2009. Table 5-10 lists
the petroleum refineries that reported dioxin and dioxin-like compound discharges to TRI in
2009.
EPA's 2004 detailed study of petroleum refineries indicated that refineries produce
dioxin and dioxin-like compounds during catalytic reforming and catalyst regeneration
operations (U.S. EPA, 2004). The study also showed that the estimated releases of dioxin and
dioxin-like compounds reported to TRI are based on pollutant concentrations below the Method
1613B Minimum Levels (ML). Measurements of concentrations below the Method 1613B ML
may not be accurate and may not accurately reflect industry discharges.
During the 2011 Annual Review, EPA investigated the basis of estimates for the
petroleum dioxin discharges in the 2009 TRI data, which could include actual sampling data,
mass balance calculations, or some other type of estimation (U.S. EPA, 2012). Of the 19
refineries reporting dioxin and dioxin-like compound discharges to TRI in 2009, nine reported
5^23
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
discharges based on analytical measurements (designated as "Ml" or "M2" in the TRI database)
and the other 10 used mass balance, emission factors, or other estimation techniques to determine
discharges.
During the 2011 Annual Review, EPA also identified that Hovensa LLC in
Christiansted, VI, accounts for 65 percent of the category's dioxin and dioxin-like compound
discharges in the 2009 TRI database. EPA contacted the facility about its dioxin and dioxin-like
compound discharges and determined that the dioxin discharges are estimated using literature
values associated with dioxin formation from reformer catalyst regeneration. The facility
indicated that the increase in dioxin discharges from 2008 to 2009 was due to the number of
times the facility regenerated the reformer catalyst, once in 2008 compared to three times in
2009. The facility contact stated that the number of regenerations required in a given year could
vary between zero and three, depending on different operating factors (Vernon, 2011). The
facility used the dioxin distributions given in the Dioxins and Refineries: Analysis in the San
Francisco Bay Area report (CBE, 2000) to estimate the dioxin load and distribution. The source
of these dioxin distributions is the 1996 EPA Preliminary Data Summary for the Petroleum
Refining Category (U.S. EPA, 1996).
During the 2012 Annual Review, EPA confirmed with Hovensa that its dioxin discharges
are based on estimations from literature. Hovensa did not analyze its wastewater for dioxins or
furans; therefore, EPA is not certain dioxins and furans are actually present in the wastewater at
concentrations above the Method 1613B ML. Although Hovensa's estimate of releases follows
TRI program guidance, it may not represent actual wastewater discharges.
Because Hovensa represented a majority of the TRI TWPE, EPA did not review TRI data
on dioxins and furans from any other petroleum refineries during the 2012 Annual Review.
However, EPA searched 2010 DMR data to see what dioxins and furans might have been
measured in effluent from petroleum refineries. Table 5-6. presents final outfall data for six
refineries that reported dioxin and dioxin-like compound discharges in the 2010 DMR. As
shown, only one refinery, Tosco Corporation in Martinez, CA, reported detecting dioxins and
furans above the Method 1613B ML in 2010. This refinery reported detecting three congeners:
OCDD, OCDF, and an HpCDD congener, but its outfall includes process wastewater and
stormwater.
In the 2004 detailed study, EPA reviewed similar 2000 DMR discharges from this facility
(U.S. EPA, 2004). As explained in the 2004 detailed study, the Tosco refinery completed an
extensive study in 1997 to find the source of dioxin in the final effluent. The study determined
that 98 percent of the dioxin loading is from non-process wastewater (discharges from
stormwater and the coke pond and clean canal forebay). The refinery reported that wastewater
from the treatment plant (treated with granular activated carbon) contributed two percent of the
dioxin in the final effluent. The 1997 report suggests that the dioxin in the wastewater discharges
from stormwater and the coke pond and clean canal forebay are from aerial deposition in the
surrounding area (U.S. EPA, 2004).
5-24
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-6. 2010 DMR Petroleum Refinery Dioxin and Dioxin-Like Compounds Effluent Discharge Data (pg/L)
Dioxin Congener
Number
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
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
1613B
ML
10
50
50
50
50
50
100
10
50
50
50
50
50
50
50
50
100
Tesoro Alaska
Petroleum Co.
Kenai, AK
Avg
ND
Max
ND
Shell Chemical
Company
Saraland, AL
Avg
ND
Max
ND
Tosco Corp.
Amorco Wharf
Martinez, CA
Avg
ND
ND
ND
ND
ND
153a
l,600a
ND
ND
ND
ND
ND
ND
ND
ND
ND
ior
Max
ND
ND
ND
ND
ND
293a
3,100a
ND
ND
ND
ND
ND
ND
ND
ND
ND
101a
Valero Refining
Co. — California
Benicia Refinery
Benicia, CA
Avg
ND
Max
ND
Exxon Mobil Oil
Corp. - Torrance
Refinery
Torrance, CA
Avg
ND
Max
ND
Conoco Phillips
Carson Plant
Carson, CA
Avg
ND
Max
ND
Source: DMR Loading Tool; Isorena, 2012.
ND: Not detected.
Blank cells indicate the refinery did not monitor for this parameter.
aDischarges are above the Method 1613B ML.
5-25
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
5.2.3.2 Petroleum Refining Metals Discharges
Petroleum refinery wastewater contains a number of metals. EPA has observed changes
in the petroleum industry in recent years that have led to an increase in discharges of metal
compounds. These changes include the use of different feedstock such as Canadian crude oil and
tar sands (Purdue-Argonne Task Force, 2011) and changes in air pollution control (see Section
6.3). Crude petroleum is the major source of metals in petroleum refinery wastewater; pipe
corrosion, catalyst additives, other refinery raw materials, cooling water biocide, and supply
water also contribute metals to the water (U.S. EPA, 2004).
EPA continued to review metals discharges from petroleum refineries during the 2012
Annual Review. EPA reviewed 2010 DMR data in detail and collected readily available
treatment performance data for metals discharges. Table 5-7 presents the pounds and TWPE for
DMR metals discharges from 2000 to 2010. Part 419 includes limitations for only one metal,
chromium. EPA compared 2010 DMR metals concentrations for petroleum refineries to readily
available treatability data from three sources:
• The Emerging Technologies and Approaches to Minimize Discharges into Lake
Michigan Study (Purdue-Argonne Task Force, 2011);
• The Steam Detailed Study Report (DSR) (U.S. EPA, 2009b); and
• Historical Effluent Limitations Guidelines and Standards (ELGs) (U.S. EPA,
2000; ERG, 2006).
The Argonne National Laboratory and Purdue University studied treatment technologies
that could help the BP Whiting (Indiana) Refinery meet wastewater discharge permit limits. The
study focused on ultrafiltration treatment for mercury, with a treatability to 0.0000013 mg/L. The
Steam DSR represents performance of chemical precipitation and biological treatment at power
plants, specifically of flue gas desulfurization wastewater treatment systems. Although the
untreated wastestream differs from petroleum refining wastewater, EPA used this readily
available data to obtain a sense of the treatability of metals using these more recent technologies,
as compared to current metals discharges from petroleum refineries. Table 5-8 presents the
Steam DSR performance data used for a preliminary comparison to the 2010 DMR petroleum
refinery metals data. EPA also evaluated, as a point of comparison, metals removals achieved by
chemical precipitation systems collected during development of the Metal Products and
Machinery ELGs (Part 438), Iron and Steel (Part 420), and Centralized Waste Treatment (Part
437) ELGs. Treatability concentrations from the BP Whiting (Argonne National Laboratory and
Purdue University) study and Steam DSR are more current and demonstrated better performance
(compared to historical ELGs ); therefore, EPA used data from these two sources as the point of
comparison for metals removal.
Table 5-7. DMR Metal Discharges, 2000-2010
Total Metals TWPE
2010
93,600
2009
66,300
2008
56,300
2007
134,000
2004
63,700
2000
33,500
Sources: PCSLoads2000; PCSLoads2004_v3; DMRLoads2007_v4; DMRLoads2008_v3; DMRLoads2009_v2; and
DMR Loading Tool (2010).
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-8. Treatability Data from 2009 Steam Electric Power Generation Detailed
Study Report
Metal
Aluminum
Arsenic
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Vanadium
Zinc
2009 Steam DSR: Chemical
Precipitation Treatment (mg/L)
0.05
0.0103
0.01-0.0253
0.0025-0.0162
0.0015-0.05
0.0000753
0.05-0.221
0.0825-2.91
0.0021-0.02
0.01-0.0254
2009 Steam DSR: Chemical
Precipitation Followed by
Anoxic/ Anaerobic Biological
Treatment (mg/L)
0.05
0.002
0.0242
0.0025
0.0015
0.0000753
0.001
0.0005 a
0.0005
0.025
Source: U.S. EPA, 2009b and U.S. EPA, 2013b.
NA: Not applicable.
a Calculated long term average values from Table 13-7 in EPA's Technical Development Document for the Proposed
Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category
(U.S. EPA, 2013b).
Table 5-9 lists the metals commonly reported in DMR data in 2010,8 along with the
number of refineries reporting each metal, the range of concentrations, and the method detection
limit (MDL) associated with 40 CFR Part 136 methods.9 The daily maximum concentration
range is the highest concentration reported for the metal by each refinery in 2010; it is the worst-
case scenario and not reflective of average discharges.
Table 5-9 also compares the 2010 DMR petroleum refinery daily maximum metals
discharge concentrations to the lowest metals concentrations identified in the Steam DSR and the
Argonne National Laboratory and Purdue University study. This table shows that the metals
discharges from petroleum refineries often exceed comparable treatment performance
concentrations (though the treatment technologies from the Steam DSR listed were applied to
steam electric power generation wastewater, the data does not indicate the performance of these
technologies on petroleum refinery wastewater):
• For aluminum, arsenic, copper, lead, mercury, and zinc, the highest 2010 daily
maximum metals concentrations exceeded comparable treatment performance
concentrations for more than 50 percent of the refineries with data.
8 During the 2004 detailed study, EPA concluded that 10 metals are most commonly found in discharges from
petroleum refineries (U.S. EPA, 2004).
9
Mercury limits are from EPA Method 163 IE.
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
• One refinery reported vanadium discharge concentrations, and its highest 2010
daily maximum concentration exceeded comparable treatment performance
concentrations.
• Forty percent of the refineries' highest 2010 chromium daily maximum
concentrations exceeded comparable treatment performance concentrations.
• For nickel and selenium, 25 percent of the refineries' highest 2010 daily
maximum concentrations exceeded comparable treatment performance
concentrations.
Table 5-11, at the end of this section, lists all of the refineries reporting metals DMR data
in 2010 compared to the lowest metals concentrations taken from the Steam DSR and Argonne
National Laboratory and Purdue University study (see row Lowest Treatment Performance Level
in Table 5-11).
Table 5-9. 2010 Petroleum Refineries Metals Data from DMR
Metal
Aluminum
Arsenic
Chromium
Copper
Lead
Mercury
(pg/L)
Nickel
Selenium
Vanadium
Zinc
Range of Daily
Maximum
Concentration s
(mg/L)a
0.085-5.14
0.0018-0.32
0.00032-0.31
0.00047-1.705
0.00076-0.14
0.00587-
18,000,000
0.005-0.093
0-0.42
0.012-0.012
0-6.42
Number of
Refineries
Reporting
Metals
7
12
47
29
21
23
12
24
1
33
MDLb
(mg/L)
0.045
0.053
0.0061
0.0054
0.042
200
0.015
0.075
0.0075
0.0018
Lowest
Comparison
Treatment
Performance
Data (mg/L)a
0.05
0.0103
0.01
0.0025
0.0015
1300
0.05
0.0825
0.0021
0.01
Number of
Refineries with
Concentrations
Exceeding
Comparison
Treatment
Performance
Datac
7
7
19
27
17
18
3
6
1
30
Total Percentage
of Refineries
with
Concentrations
Exceeding
Comparison
Treatment
Performance
Datac (%)
100
58
40
93
81
78
25
25
100
91
Sources: DMR Loading Tool; Purdue-Argonne Task Force, 2011; U.S. EPA, 2009b.
a Except mercury, which is presented in pg/L.
b Method Detection Limit from 40 CFR Part 136, except for mercury, which is from EPA Method 163 IE.
0 As described in the text above, EPA used the Argonne National Laboratory and Purdue University study and the
Steam DSR to determine lowest comparison treatment performance concentrations.
5-28
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
5.2.4 Summary of Findings from EPA's Review of Petroleum Refining Category
EPA continued to review TRI and DMR data on dioxin and dioxin-like compound and
metals discharges from petroleum refineries. Using data collected for the 2012 Annual Review,
EPA identified the following:
• EPA previously determined that refineries form dioxin and dioxin-like
compounds during catalyst regeneration operations for the catalytic reforming
process. The 2004 detailed study report found all reported petroleum refinery
dioxin and dioxin compound discharges to be below the Method 1613B ML. EPA
reviewed 2009 dioxin and dioxin-like compound discharges from TRI. One
facility, the Hovensa Refinery in Christiansted represented a majority of the TRI
TWPE, however, this facility estimates its dioxin discharges based on TRI
guidance, and EPA is uncertain whether the data represent actual wastewater
discharges.
• EPA also reviewed 2010 DMR data and found that only one refinery reported
discharging detectable concentrations of dioxins and furans, with three congeners
detected above the Method 1613 ML. This facility performed a study in 1997 that
suggests that 98 percent of the dioxin discharges are from stormwater (from aerial
deposition), not process wastewater.
• Petroleum refinery wastewater contains a number of metal pollutants. EPA has
observed changes in the petroleum industry in recent years that have led to an
increase in discharges of metal compounds, including the use of different
feedstock such as Canadian crude oil and tar sands, as well as changes in air
pollution control. Seventy-six out of 163 petroleum refineries in the U.S. monitor
for at least one of 10 metals commonly found in refinery discharges. Of the 10
metals, all are detected, with the maximum detected concentration often
exceeding comparison treatability performance data (from the Steam DSR and
Argonne National Laboratory and Purdue University study).
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above findings, EPA is assigning this category a moderate priority for
revision—i.e., this category is marked "(5)" in the "Findings" column in Table 7-1 in the Final
2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014).
5.2.5 References for Petroleu m Refining Category
1. CBE. 2000. Communities for a Better Environment. Dioxins and Refineries: Analysis in
the San Francisco Bay Area. Report No. 2000-2. (August). EPA-HQ-OW-2010-0824 -
0078.
2. ERG. 2006. Eastern Research Group, Inc. Combined Metals Database. EPA-HQ-OW-
2010-0824-0039.
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
3. Isorena, Phillip. 2012. Telephone Communication Between Phillip Isorena, California
EPA Water Resources Board, and Kimberly Bartell, Eastern Research Group, Inc., Re:
Tosco Corporation Petroleum Refinery 2010 Dioxin Discharges. (September 24). EPA-
HQ-OW-2010-0824. DCN 07832.
4. Purdue-Argonne Task Force. 2011. Emerging Technologies and Approaches to Minimize
Discharges into Lake Michigan. Purdue University Calumet Water Institute-Argonne
National Laboratory Task force. (May). Available online at:
http://webs.purduecal.edU/pwi/phase-ii-comprehensive-report/.EPA-HQ-OW-2010-0824.
DCN 07831.
5. U. S. EPA. 1996. Preliminary Data Summary for the Petroleum Refining Category.
Washington, D.C. (April). EPA-821-R-96-015. EPA-HQ-OW-2003-0074-0304 through
0305.
6. U. S. EPA. 2000. Development Document for the Final Effluent Limitations Guidelines
and Standards for the Centralized Waste Treatment Industry, Final, Volume 1.
Washington, D.C. (August). EPA-821-R-00-020. EPA-HQ-OW-2004-0032-2223.
7. 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.
8. 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.
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. Steam Electric Power Generating Point Source Category: Final
Detailed Study Report. Washington, D.C. (October). EPA-821-R-09-008. EPA-HQ-OW-
2009-0819-0004.
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-2008-0517-0618.
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
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.
16. U.S. EPA. 2013a. Preliminary 2012 Effluent Guidelines Program Plan. Washington,
D.C. (May). EPA 821-R-12-002. EPA-HQ-OW-2010-0824-0194.
17. U.S. EPA. 2013b. Technical Development Document for the Proposed Effluent
Limitations Guidelines and Standards for the Steam Electric Power Generating Point
Source Category. Washington, D.C. (April). EPA-821-R-13-002. EPA-HQ-OW-2009-
0819-2257.
18. 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-2010-0824. DCN
07756.
5-31
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-10. Dioxin and Dioxin-Like Discharges from Petroleum Refineries Reported to TRI in 2004-2009
Refinery Name
Hovensa, LLC
Chevron Products
Co. Richmond
Refinery
Valero Refining
Co, Oklahoma
Valero Ardmore
Refinery
Conoco Phillips
Co, Billings
Refinery
Chevron Products
Co. Div of
Chevron USA
Inc.
Marathon
Ashland
Petroleum LLC,
Illinois Refining
Div
Chevron Products
Co. Salt Lake
City Refinery
Shell Oil Co.,
Deer Park
Refining LP
Location
Christiansted,
VI
Richmond, CA
Ardmore, OK
Billings, MT
El Segundo,
CA
Robinson, IL
Salt Lake City,
UT
Deer Park, TX
Comments
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
No DMR data; new
to report in 2009
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data; new
to report in 2009
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
2009
Grams
Released
1.65
0.25
0.18053
0.08
0.599
0.0404
0.097
0.1003
TWPE
205,073
20,621
16,463
16,169
13,283
12,622
12,611
8,532
Basis of
Estimate
O
M2
C
M2
M2
M2
El
M2
2008
Grams
Released
0.55
0.65
NR
0.091
0.8912
0.0405
NR
0.1303
TWPE
12,848
84,423
NR
3,125
81,266
28,571
NR
3,044
Basis of
Estimate
O
M2
NR
M2
M2
O
NR
M2
2007
Grams
Released
NR
0.32
NR
NR
0
0.04
0.02
0.14
TWPE
NR
33,397
NR
NR
0
1,094
541
13,306
Basis of
Estimate
NR
M2
NR
NR
M2
O
M2
M2
2005
Grams
Released
2.2
0.94
NR
NR
0.158
0.0404
NR
0.114
TWPE
180,442
121,521
NR
NR
16,221
3,314
NR
10,850
Basis of
Estimate
E
M
NR
NR
M
O
NR
M
2004
Grams
Released
1.7
1.35
NR
NR
0.2
0.04
NR
0.16
TWPE
148,653
141,106
NR
NR
20,533
3,604
NR
15,477
Basis of
Estimate
C
O
NR
NR
M
O
NR
M
5-32
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-10. Dioxin and Dioxin-Like Discharges from Petroleum Refineries Reported to TRI in 2004-2009
Refinery Name
Chevron Products
Co., Pascagoula
Refinery
Tesoro Refining
& Marketing Co
Conoco Phillips,
San Francisco
Refinery
BP Products
North America
Inc, Toledo
Refinery
Citgo Petroleum
Corp
Conoco Phillips,
Santa Maria
Refinery
BP Products
North American
Whiting
Premcor Refining
Group, Inc.
Location
Pascagoula,
MS
Anacortes, WA
Rodeo, CA
Oregon, OH
Westlake, LA
Arroyo
Grande, CA
Whiting, IN
Delaware City,
DE
Comments
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
DMR TWPE is
zero; grams is
driving force for
08-09 change in
discharge
No DMR data;
TWPE is driving
force for 08-09
change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data; new
to report in 2009
2009
Grams
Released
0.07265
0.41
0.0623205
0.481
0.00128
0.0675
0.000015
0.0000363
TWPE
3,595
2.905
2,276
785
126
26
8
4
Basis of
Estimate
O
M2
C
M2
El
M2
O
O
2008
Grams
Released
0.03709
0.519
0.16818
0.264
0.00257
0.0133
0.000013
NR
TWPE
4,592
12,124
15,610
6,167
60
311
12
NR
Basis of
Estimate
O
O
C
0
El
M2
O
NR
2007
Grams
Released
NR
NR
NR
0.29
0.002
NR
NR
0.0001
TWPE
NR
NR
NR
41,963
69
NR
NR
3.13
Basis of
Estimate
NR
NR
NR
0
0
NR
NR
O
2005
Grams
Released
0.099
1.94
NR
0.331
0.00256
NR
NR
0.000097
TWPE
4,234
55,248
NR
47,084
210
NR
NR
2
Basis of
Estimate
O
M
NR
0
E
NR
NR
O
2004
Grams
Released
0.12
1.95
NR
0.34
0.0026
NR
0.000011
0.022
TWPE
5,217
54,406
NR
47,795
231
NR
1.8
559
Basis of
Estimate
O
M
NR
M
E
NR
O
O
5-33
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-10. Dioxin and Dioxin-Like Discharges from Petroleum Refineries Reported to TRI in 2004-2009
Refinery Name
Suncor Energy
Commerce City
Refinery
Conoco Phillips,
Ferndale
Refinery
Martin Operating
PtnrLP
Location
Commerce
City, CO
Ferndale, WA
Smackover,
AR
Comments
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
No DMR data;
grams is driving
force for 08-09
change in
discharge
2009
Grams
Released
0.35
0.2251
0.0005
TWPE
4
3
0.1
Basis of
Estimate
El
M2
0
2008
Grams
Released
0.35
0.2284
0.00005
TWPE
8,176
25,883
1
Basis of
Estimate
El
M2
0
2007
Grams
Released
NR
NR
NR
TWPE
NR
NR
NR
Basis of
Estimate
NR
NR
NR
2005
Grams
Released
0.111
NR
NR
TWPE
9,104
NR
NR
Basis of
Estimate
M
NR
NR
2004
Grams
Released
0.037
NR
NR
TWPE
3,333
NR
NR
Basis of
Estimate
M
NR
NR
Sources: TRIReleases2009_v2; TRIReleases2008_v3; TRIReleases2007_v2; TRIReleases2005_v2; and TRIReleases2004_v3.
NR: Not reported.
For indirect discharges, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 83% removal of dioxin and dioxin-like compounds by the
POTW.
Refineries reported basis of estimate in TRI as: M (monitoring data/measurements); M2 (periodic monitoring data/measurements); C (mass balance calculations); E (published emission factors); and O (other
approaches, such as engineering calculations).
5-34
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool
Refinery Name "
(Location)
Tesoro Kenai
(Kenai, AK)
Hunt Tuscaloosa
(Tuscaloosa, AL)
Shell Saraland
(Saraland, AL)
Lion Oil
(El Dorado, AR)
Berry
(Stephens, AR)
Conoco Arroyo
(Arroyo Grande, CA)
Chevron El Segundo
(El Segundo, CA)
Tosco Martinez
(Martinez, CA)
Conoco Rodeo
(Rodeo, CA)
Chevron Richmond
(Richmond, CA)
Valero Benicia
(Benicia, CA)
Martinez
(Martinez, CA)
Suncor
(Commerce City, CO)
Conoco Roxana
(Roxana, IL)
Citgo Lemont
(Lemont, IL)
Marathon Robinson
(Robinson, IL)
American Western
(Lawrenceville, IL)
BP Whiting
(Whiting, IN)
Aluminum
Avg
0.051
0.057
0.22
Max
0.12
0.085
1.7
Arsenic
Avg
0.0086
0.0042
0.0034
0.0017
0.0065
Max
0.0094
0.0042
0.0049
0.0018
0.023
Chromium
Avg
0.0027
0.018
0.00046
0.0019
0.00022
0.00042
0.0014
0.00015
0.0015
0.011
0.0104
0.00066
0.019
Max
0.0056
0.072
0.0108
0.0035
0.0058
0.00072
0.00407
0.00069
0.0059
0.31
0.015
0.002
0.048
Copper
Avg
0.015
0.0071
0.0014
0.0057
0.0033
0.0037
0.0023
0.0011
0.0018
Max
0.015
0.008
0.0026
0.0096
0.0044
0.008
0.0041
0.013
0.0029
Lead
Avg
0.00068
0.0015
0.00062
0.00048
0.00041
0.00801
Max
0.019
0.0027
0.0019
0.00076
0.006
0.043
Mercury
Avg
0.00011
0.00022
0.00022
0.0000053
4.39E-09
2.37E-08
0.0000098
7.42E-09
0.000044
0.0000034
Max
0.00011
0.00072
0.00022
0.00001
4.39E-09
2.37E-08
0.000061
7.42E-09
0.00038
0.0000069
Nickel
Avg
0.0095
0.0092
0.0036
0.013
0.011
0.019
0.022
Max
0.01
0.011
0.0095
0.0207
0.011
0.056
0.093
Selenium
Avg
0.015
0.13
0.0108
0.013
0.013
0.0203
0.028
0.022
0.026
Max
0.0903
0.2
0.032
0.0309
0.018
0.023
0.033
0.106
0.032
Vanadium
Avg
Max
Zinc
Avg
0.012
0.0066
0.11
0.0052
0.024
0.017
0.019
0.025
Max
0.11
0.12
0.74
0.0052
0.037
0.051
0.038
0.19
5-35
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool
Refinery Name "
(Location)
Country Mark
(Mt. Vernon, IN)
Farmland
(Coffeyville, KS)
Catlettsburg
(Catlettsburg, KY)
Conoco Westlake
(Westlake, LA)
BP Belle Chasse
(Belle Chasse, LA)
Motiva Norco
(Norco, LA)
ExxonMobil
(Chalmette, LA)
Citgo Lake Charles
(Lake Charles, LA)
Motiva Convent
(Convent, LA)
Calumet Shreveport
(Shreveport, LA)
Marathon Garyville
(Garyville, LA)
Valero Norco
(Norco, LA)
Calcasieu
(Lake Charles, LA)
Marathon Saint Paul
Park
(Saint Paul Park, MN)
Koch
(Rosemount, MN)
Chevron Pascagoula
(Pascagoula, MS)
Hunt Sandersville
(Sandersville, MS)
Aluminum
Avg
0.82
Max
1.89
Arsenic
Avg
0.013
Max
0.019
Chromium
Avg
0.0058
0.0036
0.00035
0.0088
0.0072
0.016
0.0094
0.0068
0.012
Max
0.008
0.00909
0.0042
0.039
0.0072
0.016
0.0094
0.036
0.025
Copper
Avg
0.0076
0.005
0.00094
0.028
0.004005
Max
0.05
0.01
0.0045
0.081
0.0072
Lead
Avg
0.016
0.000204
0.01
Max
0.016
0.001
0.01
Mercury
Avg
0.0034
0.000052
0.0000065
0.0016
0.00000207
0.000013
Max
0.0059
0.00071
0.000018
0.018
0.0000046
0.0000402
Nickel
Avg
0.00308
0.0035
0.0069
Max
0.005
0.069
0.016
Selenium
Avg
0.015
0.39
Max
0.022
0.42
Vanadium
Avg
Max
Zinc
Avg
0.28
0.109
0.45
0.015
0.0072
Max
1
0.202
6.42
0.025
0.013
5-36
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool
Refinery Name "
(Location)
Ergon
(Vicksburg, MS)
Conoco Billings
(Billings, MT)
Tesoro Mandan
(Mandan, ND)
Coastal
(Westville, NJ)
BP Oregon
(Oregon, OH)
Premcor Lima
(Lima, OH)
Marathon Canton
(Canton, OH)
Chevron Hooven
(Hooven, OH)
Tulsa Refinery
(Tulsa, OK)
Valero Ardmore
(Ardmore, OK)
Sinclair
(Tulsa, OK)
Calumet Penreco
(Karns City, PA)
American Refining
(Bradford, PA)
Sunoco PI
(Philadelphia, PA)
Sunoco P2
(Philadelphia, PA)
Conoco Trainer
(Trainer, PA)
Caribbean
(Bayamon, PR)
Shell Yabucoa
(Yabucoa, PR)
Aluminum
Avg
0.26
1.73
Max
0.42
4.48
Arsenic
Avg
0.0905
Max
0.0905
Chromium
Avg
0.00206
0.00042
0.00201
0.0069
0.00095
0.0054
0.0089
0.0017
0.0013
0.00089
Max
0.00405
0.0079
0.00806
0.013
0.011
0.0104
0.0089
0.0048
0.0018
0.0012
Copper
Avg
0.0057
0.0016
0.00039
0.017
0.0061
0.037
Max
0.0101
0.0064
0.0033
0.02
0.01
0.075
Lead
Avg
0.00207
0.0034
0.00078
0.00076
0.0087
0.0017
0.00098
Max
0.0023
0.028
0.0015
0.0011
0.01
0.005
0.002
Mercury
Avg
2.35E-12
2.018E-12
0.0000025
0.00035
Max
9.309E-12
5.87E-12
0.0000059
0.004
Nickel
Avg
0.0073
0.0029
Max
0.0107
0.0061
Selenium
Avg
0.109
0.0102
0.0045
0.0106
0.026
0
0.00095
Max
0.27
0.03
0.018
0.032
0.059
0
0.001
Vanadium
Avg
Max
Zinc
Avg
0.029
0.012
0.0095
0.032
0.0408
0.022
0.0059
0.0109
Max
0.042
0.057
0.018
0.054
0.071
0.031
0.016
0.024
5-37
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool
Refinery Name "
(Location)
Phillips PR
(Guayama, PR)
Valero Memphis
(Memphis, TN)
Delek (Tyler, TX)
Valero Houston
(Houston, TX)
Houston Refinery
(Houston, TX)
BP Texas City
(Texas City, TX)
Atofma
(Port Arthur, AR)
Shell Deer Park
(Deer Park, TX)
Port Arthur
(Port Arthur, TX)
Premcor Port Arthur
(Port Arthur, TX)
Valero Texas City
(Texas City, TX)
Citgo CC
(Corpus Christi, TX)
Valero CC E.
(Corpus Christi, TX)
Phillips Brazoria
(Brazoria, TX)
Borger
(Borger, TX)
LNVA
(Beaumont, TX)
Valero CC
(Corpus Christi, TX)
Diamond
(Three Rivers, TX)
Aluminum
Avg
1.98
Max
5.14
Arsenic
Avg
0.034
0.01
0.011
Max
0.034
0.02
0.036
Chromium
Avg
0.0016
0.00507
0.0033
0.0033
0.015
0.000086
0.0092
0.0052
0.0063
0.0027
0.022
0.020005
Max
0.0031
0.0055
0.01
0.0098
0.0904
0.00103
0.036
0.013
0.0308
0.0041
0.04
0.029
Copper
Avg
0.00039
0.052
0.0053
0.19
0.0021
0.0012
0.039
Max
0.00047
0.21
0.011
1.705
0.0052
0.0018
0.056
Lead
Avg
0.0017
0.013
0.006009
0.0019
0.0087
Max
0.0069
0.065
0.014
0.0024
0.14
Mercury
Avg
0.0000058
0.000109
Max
0.000028
0.0002
Nickel
Avg
Max
Selenium
Avg
0
0.064
0.13
0.0044
0.011
Max
0
0.08
0.15
0.017
0.014
Vanadium
Avg
0.012
Max
0.012
Zinc
Avg
0.16
0.091
0.072
0.46
0.014
0
0.06
0.011
0.012
Max
0.76
0.17
0.12
1.2
0.036
0
0.15
0.035
0.024
5-38
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-11. 2010 DMR Metals Data from DMR Loading Tool
Refinery Name "
(Location)
Seadrift Coke, L.P.
(Seadrift, TX)
BTP Refining LLC
(Corpus Christi, TX)
Hess
(St. Croix, VI)
Murphy Oil
(Superior, WI)
Newell
(Newell, WV)
Method Detection Limit
(from 40 CFR 136,
except Hg which is from
EPA Method 1613E)
5XMDL
Lowest Comparison
Treatment Performance
Data (taken from Table
5-9)b
Total Number of
Refineries with
Monitoring Data
Total Number of
Refineries with Cone >
Treatment Performance
Levels
Percent of Refineries
with Cone > Treatment
Performance Levels
Aluminum
Avg
0.045
0.225
0.05
7
7
100
Max
0.045
0.225
0.05
7
7
100
Arsenic
Avg
0.01
0.22
0.053
0.265
0.0103
12
5
42
Max
0.01
0.32
0.053
0.265
0.0103
12
7
58
Chromium
Avg
0.024
0.00054
0.00025
0.0061
0.0305
0.01
47
10
21
Max
0.065
0.00061
0.00032
0.0061
0.0305
0.01
47
19
40
Copper
Avg
0.00051
0.044
0.0054
0.027
0.0025
29
18
62
Max
0.0052
0.075
0.0054
0.027
0.0025
29
27
93
Lead
Avg
0.042
0.21
0.0015
21
12
57
Max
0.042
0.21
0.0015
21
17
81
Mercury
Avg
0.0000024
0.0000002
0.000001
0.0000013
23
18
78
Max
0.0000034
0.0000002
0.000001
0.0000013
23
18
78
Nickel
Avg
0.015
0.075
0.05
12
0
0
Max
0.015
0.075
0.05
12
3
25
Selenium
Avg
0.026
0.075
0.375
0.0825
24
4
17
Max
0.029
0.075
0.375
0.0825
24
6
25
Vanadium
Avg
0.0075
0.0375
0.0021
1
1
100
Max
0.0075
0.0375
0.0021
1
1
100
Zinc
Avg
0.071
0.01
0.061
0.0018
0.009
0.01
33
26
79
Max
0.13
0.01
0.085
0.0018
0.009
0.01
33
30
91
Source: DMR Loading Tool.
Note: Pink shading denotes when the average or maximum concentration of the metal exceeded the "Lowest Treatment Performance Level" for that metal (as identified for each metal in the fourth row from the
bottom of the table).
Note: All concentrations provided in mg/L.
a-For the purpose of this table, refinery names have been abbreviated. See Table 5-12 for list of the full refinery names.
b - Lowest comparison treatment performance data represents the treatability concentrations from the Steam DSR (Table 5-8) and the Argonne National Laboratory and Purdue University study.
5-39
-------
Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-12. List of Full Refinery Names
Refinery Abbreviation
(As Shown in Table 5-11)
Tesoro Kenai
Hunt Tuscaloosa
Shell Saraland
Lion Oil
Berry
Conoco Arroyo
Chevron El Segundo
Tosco Martinez
Conoco Rodeo
Chevron Richmond
Valero Benicia
Martinez
Suncor
Conoco Roxana
Citgo Lemont
Marathon Robinson
American Western
BP Whiting
Country Mark
Farmland
Catlettsburg
Conoco Westlake
BP Belle Chasse
Motiva Norco
ExxonMobil
Citgo Lake Charles
Motiva Convent
Calumet Shreveport
Marathon Garyville
Valero Norco
Calcasieu
Marathon Saint Paul Park
Koch
Chevron Pascagoula
Hunt Sandersville
Ergon
Conoco Billings
Tesoro Mandan
Coastal
Full Refinery Name
Tesoro Alaska Petroleum Co.
Hunt Refining Company A Corporation
Shell Chemical Company
Lion Oil Co. El Dorado Refinery
Berry Petroleum Company
ConocoPhillips Co.
Chevron USA Products Company
Tosco Corp Amorco Wharf
ConocoPhillip San Francisco Area Refinery at Rodeo
Chevron Prods. Co. Richmond Refy
Valero Refining Co. California Benicia Refinery
Martinez Refinery
Suncor Denver Refinery
ConocoPhillips Co.
Citgo Petroleum Corp.
Marathon Petroleum Co. LLC.
American Western Ref Acquis-LC
BP Amoco Oil Company Whiting Refinery
CountryMark Cooperative Inc.
Farmland Industries
Catlettsburg Refining, LLC
ConocoPhillips Co., Lake Charles Refinery
BP Oil Company Alliance Refinery
Motiva Enterprises LLC, Norco Refinery
ExxonMobil Refinery Complex
Citgo Petroleum Corporation
Motiva Enterprises Convent Refinery
Calumet Lubricants and Waxes LLC
Marathon Ashland Petroleum LLC
Valero Refining, New Orleans
Calcasieu Refining Company
Marathon Petroleum Co. LLC
Koch Pipeline Co., Rosemount
Chevron Products Company, Pascagoula Refinery
Hunt Southland Refining Company
Ergon Refining Inc.
Conoco Incorporated Refinery
Tesoro Mandan Refinery Wastewater Laboratory
Coastal Eagle Point Oil Co.
5-40
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Section 5—Continued Review of Select Point Source Categories
5.2—Petroleum Refining (40 CFR Part 419)
Table 5-12. List of Full Refinery Names
Refinery Abbreviation
(As Shown in Table 5-11)
BP Oregon
Premcor Lima
Marathon Canton
Chevron Hooven
Tulsa Refinery
Valero Ardmore
Sinclair
Calumet Penreco
American Refining
Sunoco PI
Sunoco P2
Conoco Trainer
Caribbean
Shell Yabucoa
Phillips PR
Valero Memphis
Delek
Valero Houston
Houston Refinery
BP Texas City
Atofina
Shell Deer Park
Port Arthur
Premcor Port Arthur
Valero Texas City
Citgo CC
Valero CC E.
Phillips Brazoria
Borger
LNVA
Valero CC
Diamond
Seadrift Coke, L.P.
BTP Refining LLC
Hess
Murphy Oil
Newell
Full Refinery Name
BP Oil Co. Toledo Refinery
Premcor Refining Group Inc.
Marathon Ashland Petroleum LLC Canton Refinery
Chevron USA Inc. Cincinnati Refinery
Tulsa Refinery
Valero Refining Co. Oklahoma Valero Ardmore Refinery
Sinclair Oil Tulsa Refinery Tulsa Trucking
Calumet Penreco
American Refining Group Inc.
Sunoco Point Breeze Processing Area 1
Sunoco Point Breeze Processing Area 2
ConocoPhillips Trainer Ref
Caribbean Petroleum Refining LP
Shell Chemical Yabucoa Inc.
Phillips Puerto Rico Core Incorporated
Valero Memphis Refinery
Delek Tyler Refinery
Valero Refining Houston Refinery
Houston Refinery
BP Products North America
Atofina Petrochemicals Incorporated
Shell Chemical Shell Oil Deer Park
Port Arthur Refinery
Premcor Refining Group Incorporated Port Arthur Refinery
Valero Refining Company Texas
Citgo Corpus Christi Refinery East Plant
Valero Corpus Christi Refinery East Plant
Phillips 66 Company Sweeny Complex
Borger Refinery
LNVA North Regional Treatment Plant
Valero Corpus Christi Refinery
Diamond Shamrock Refining Valero
Seadrift Coke, L.P.
BTP Refining LLC
Hess Oil Virgin Islands Corp.
Murphy Oil USA Inc.
Newell West Virginia Refinery
Source: DMR Loading Tool.
5-41
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
5.3 Pulp, Paper, and Paperboard (40 CFR Part 430)
During the 2011 Annual Review, EPA identified the Pulp, Paper, and Paperboard (Pulp
and Paper) Category (40 CFR Part 430) for preliminary review because it ranked high, in terms
of toxic-weighted pound equivalents (TWPE), in the 2011 toxicity rankings analysis. See Table
4-3 in Section 4.1.6 of the Preliminary 2012 Effluent Guidelines Program Plan (U.S. EPA,
2013). EPA needed additional data to complete the preliminary category review and continued
its review of the Pulp and Paper Category in the 2012 review (U.S. EPA, 2012). EPA previously
reviewed discharges from pulp and paper facilities as part of the Preliminary and Final Effluent
Guidelines Program Plans in 2004-2010 (U.S. EPA, 2004, 2006a, 2007, 2008, 2009, 2011).
During its 2006 Final Effluent Guidelines Program Plan review, EPA also conducted a detailed
study of this industry (U.S. EPA, 2006b). This section summarizes the findings from the 2011
and 2012 Annual Reviews associated with the Pulp and Paper Category. Based on findings from
the 2011 Annual Review, EPA continued to review discharges of dioxin and dioxin-like
compounds from the 2009 Toxics Release Inventory (TRI), because of their high TWPE relative
to other pollutants in the Pulp and Paper Category.
5.3.1 Pulp and Paper Category Background
Table 5-13 compares the toxicity rankings analysis results for all pollutants for the Pulp
and Paper Category from the 2007 through 2011 Annual Reviews. See Section 20.1 of EPA's
2011 Annual Review Report for more background on the category (U.S. EPA, 2012).
Table 5-13. Pulp and Paper Category TRI and DMR Discharges for 2007 Through 2011
Toxicity Rankings Analysis
Year of Discharge
2004
2007
2008
2009
Year of Review
2007
2009
2010
2011
Pulp and Paper Manufacturing Category
TRI TWPEa
669,000
460,000C
523,000
956,000
DMR TWPEb
165,000
2,730,000d
348,000
287,000
Total
833,000
3,190,000d
871,000
1,240,000
Sources: TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2; TRIReleases2007_v2;
DMRLoads2007_v4; TRIReleases2008_v3; DMRLoads2008_v3; TRIReleases2009_v2; and DMRLoads2009_v2.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Discharges include transfers to POTWs and account for POTW removals.
b DMR data from 2004 through 2007 include only major dischargers. 2008 and 2009 DMR data include both minor
and major dischargers.
0 Includes discharges from facilities reporting NAICS code 326112. These discharges should be associated with the
Plastics Molding and Forming Category (40 CFR Part 463). EPA has corrected recent versions of the database to
reflect this change.
d During the 2009 Annual Review, EPA contacted facilities to verify the concentrations of dioxin and dioxin-like
compounds in PCS and ICIS-NPDES and found that for all facilities contacted, there were either unit errors (e.g.,
measurements reported in ng/L but in the database as mg/L) or missing non-detect indicators. After corrections, the
new 2009 category total TWPE was 712,000.
5-42
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
5.3.2 Results of the 2011 Annual Review
EPA's 2011 review of the Pulp and Paper Category focused on the 2009 TRI and
discharge monitoring report (DMR) discharges because both contribute to the category's
combined TWPE. During the 2011 Annual Review EPA identified dioxin and dioxin-like
compounds and manganese and manganese compounds as the top TRI pollutants of concern
because they account for 83 percent of the total 2009 TRI TWPE (see Table 20-2 in Section 20.2
of the 2011 Annual Review Report) (U.S. EPA, 2012). Similarly, EPA identified sulfide and
aluminum as the top DMR pollutants, because they account for more than 73 percent of the total
2009 DMR TWPE. In reviewing the 2009 TRI and DMR database pollutants of concern, EPA
reached the following conclusions as part of the 2011 Annual Review:
• Manganese, sulfide, and aluminum in pulp and paper wastewater were all
measured at concentrations below treatable levels and do not present a hazard
based on current data (U.S. EPA, 2012);
• Dioxin and dioxin-like compounds contributed 52 percent of the total 2009 TRI
TWPE and increased by more than 14 times from reporting years 2008 to 2009;
and
• EPA's 2006 Pulp and Paper Detailed Study showed that the estimated releases of
dioxin and dioxin-like compounds reported to TRI are based on pollutant
concentrations below the Method 1613B Minimum Levels (MLs). Measurements
of concentrations below the MLs may not be accurate and may not accurately
reflect industry discharges. During the 2011 Annual Review, EPA began
collecting data to verify the 2009 loads. EPA continued to review dioxin and
dioxin-like compounds discharges from pulp and paper category facilities during
the 2012 Annual Review (U.S. EPA, 2012).
5.3.3 Results of the 2012 Annual Review
EPA's review for the Pulp and Paper Category as part of the 2012 Annual Review
focused on dioxin and dioxin-like compound discharges. The goal was to determine if the dioxin
and dioxin-like compounds are being discharged at concentrations above the Method 1613B ML.
EPA evaluated the discharges by reviewing detailed TRI dioxin distribution data, contacting pulp
and paper facilities and trade associations, and contacting the Washington Department of
Ecology (WADOE). This level of review parallels the review done for the 2006 Pulp and Paper
Detailed Study.
5.3.3.1 Top Dioxin and Dioxin-Like Compound Discharging Facilities in the
2009 TRI Database
EPA's review focused on 2007 and 200910 TRI dioxin data. Before 2008, TRI allowed a
facility to report only one dioxin congener distribution, even if dioxin compounds were released
to more than one medium (releases to air, receiving streams, land, underground wells, and
several other categories). Starting in 2008, TRI allowed facilities to report release-specific
10EPA did not use 2008 dioxin discharge data to compare to 2009 dioxin discharges due to errors with downloading
2008 TRI data on dioxin distributions.
5-43
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
distributions, possibly resulting in increased water-specific dioxin discharge reporting. For more
information, see Section 4.2.2 of the Technical Support Document for the 2010 Effluent
Guidelines Program Plan (U.S. EPA, 2011). Table 5-20, presented at the end of this section, lists
the pulp and paper mills that reported dioxin and dioxin-like compound discharges to TRI in
2004 through 2009.
To verify the accuracy of the 2009 TRI loads, EPA collected data directly from mills with
the highest loads, in terms of TWPE. EPA identified 20 mills that account for 98 percent of the
2009 dioxin and dioxin-like compound TRI TWPE during the 2011 Annual Review. As part of
the 2012 Annual Review, EPA contacted the American Forest and Paper Association (AF&PA)
and the National Council for Air and Stream Improvement (NCASI) about the 2009 dioxin
discharges from these 20 facilities. 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 the North American forest products industry, including pulp and paper facilities. Many of the
companies that fund NCASI are also members of AF&PA. Along with AF&PA and NCASI,
EPA contacted some of the pulp and paper facilities directly.
When reporting chemical releases to TRI, pulp and paper mills estimate their releases
using monitoring data, NCASI engineering calculations, or other engineering estimation methods
(TRICalculations2009 v2.mdb). Reporting facilities may use data collected before the year for
which they are reporting discharges if they believe the data are representative of reporting-year
operations. For example, some facilities base discharges on 2002 monitoring data concentrations
and an updated flow for the reporting year. NCASI's engineering calculations are based on its
published emission factors, found in Table 14, PCDD/F Concentrations in Eight ECFBleached
Chemical Pulp Mill Treated Effluents of The SARA Handbook (Wiegand, 2005a, 2005b). The
pulp and paper mills multiply their annual wastewater discharge flow by the average total
concentration from the NCASI emission factors to calculate the annual mass discharge of dioxin
and dioxin-like compounds reported to TRI. Other estimation methods include those based on
emission factors or mass balance and can include a combination of the two methods already
mentioned. In the following sections, EPA presents the results of the information collected from
AF&PA, NCASI, and specific facilities by grouping the pulp and paper facilities by the method
of reporting dioxin and dioxin-like compounds to TRI. The reporting methods EPA identified for
the above mentioned 20 facilities are monitoring data, NCASI engineering calculations, and
other estimation methods.
5.3.3.2 Monitoring Data
Twelve facilities reported that they used monitoring data to estimate 2009 dioxin TRI
discharges. The dioxin and dioxin-like compound category includes 17 individual congeners,
each with its own toxicity weighting factor (TWF). Facilities report a single mass number for the
dioxin and dioxin-like compounds, but can also report the proportion of individual congeners in
a separate field (referred to as the dioxin distribution). For facilities that indicated they estimated
releases based on monitoring data, EPA collected facility-measured effluent concentrations to
determine if the congener concentration exceeded the Method 1613B ML. Table 5-14 lists the 12
facilities and their TRI dioxin discharges for 2009, provided by the specific mills through
AF&PA and NCASI. In some cases, the facilities updated the estimated grams of dioxin released
5-44
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
when submitting data to EPA, compared to their 2009 TRI submission. Table 5-14 presents the
most current data.
Table 5-14. Facilities Using Monitoring Data to Estimate 2009 TRI Dioxin and
Furans Discharges
Name of Mill
Simpson Tacoma Kraft Co., LLC
Boise White Paper, LLC
S.D. Warren Co.
Rayonier Performance Fibers
Boise White Paper
Rock-TennMillCo.
International Paper
Weyerhauser
Domtar Paper Co.
Clearwater Paper Corp.
Nippon Paper Industries
AbitibiBowater Calhoun Operations
Location
Tacoma, WA
Wallula, WA
Skowhegan, ME
Fernandina Beach, FL
Jackson, AL
Demopolis, AL
Riegelwood, NC
Vanceboro, NC
Plymouth, NC
Arkansas City, AR
Port Angeles, WA
Calhoun, TN
Total Dioxin Grams
2.24
2.3
0.184
5.2
2.28
2.17
0.07
1.36
3.48
1.83
0
0
TWPE
229,000
156,000
37,900
37,800
4,030
3,840
3,510
2,720
2,370
1,250
0
0
Sources: Wiegand, 201 la, 20lib.
Note: Green shading denotes those facilities with detected dioxin congeners in their effluent wastewater.
• Six facilities estimated discharges based on non-detect dioxin and furan values.
These facilities assumed that dioxin was present in the wastewater at
concentrations below detection, although no dioxin was ever measured above
detection limits. This estimation method is consistent with EPA's TRI program
guidance. However, because there is more uncertainty in quantifying a
concentration measurement when it is below the detection level, EPA assumes a
concentration of zero for annual review purposes.
Two facilities, Nippon Paper Industries and AbitibiBowater Calhoun
Operations, used monitoring data to estimate their 2009 TRI discharges, but all
congeners were measured at concentrations below detection. Therefore, as for
previous annual reviews, EPA zeroed the total dioxin grams and TWPE for these
two facilities.
Four facilities, Boise White Paper (Jackson), Rock-Tenn Mill Co., Domtar
Paper Co., and Clearwater Paper Co., sampled for 2,3,7,8-TCDD or 2,3,7,8-
TCDF and used NCASI engineering calculations to estimate discharges for the
remaining dioxin congeners. None of the facilities detected 2,3,7,8-TCDD or
2,3,7,8-TCDF in their effluent.
For all six of these facilities, EPA considers their discharges as either zero or too
low to be considered a hazard priority at this time.
5-45
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
The other six facilities, Simpson Tacoma Kraft Co., LLC, Boise White Paper,
LLC (Wallula), S.D. Warren Co., Rayonier Performance Fibers, International
Paper, and Weyerhauser (highlighted green in Table 5-14), detected dioxin
congeners in their effluent wastewater, as shown in Table 5-15. Of these, only two
facilities detected congener concentrations above the Method 1613B ML: Boise
White Paper, LLC, and Rayonier Performance Fibers. EPA does not typically
consider regulating pollutants at concentrations below a parameter ML because
measurements below the method ML may not be accurate.
Boise White Paper, LLC (Wallula) detected 2,3,7,8-TCDF at 18.2 pg/L and
estimated a release of 0.47 grams in 2009. EPA estimates the TWPE associated
with the discharged congener as 45,400, shown in Table 5-16.
Rayonier Performance Fibers detected 1,2,3,4,6,7,8,9-OCDD at 172.6 pg/L and
2,3,7,8-TCDF at 14.5 pg/L, and estimated a release of 3.75 grams of these
congeners in 2009. EPA estimates the TWPE associated with those discharged
congeners as 27,700, shown in Table 5-16.
5-46
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-15. Pulp and Paper Dioxin and Furans at Mills with Detectable Concentrations (pg/L)a
Dioxin
Congener
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Dioxin Congener
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
Method
1613B ML
(pg/L)
10
50
50
50
50
50
100
10
50
50
50
50
50
50
50
50
100
Total
Data Source
Simpson
Tacoma
ND
ND
3.05
5.07
4.03
19.3
38.4
4.76
3.52
7.01
2.45
2.97
ND
2.95
ND
ND
4.51
99.02
2009 Effluent
Sampling
Boise White
Paper
1.34
ND
ND
ND
ND
15.1
87.1
18.2b
1.17
1.76
ND
ND
ND
ND
ND
ND
6.84
131.51
2009 Effluent
Sampling
S.D. Warren
ND
0.702
ND
ND
ND
1.91
13.2
ND
ND
ND
1.11
ND
ND
0.665
0.773
ND
2.68
22.04
2002 Effluent
Sampling
Rayonier
Performance
Fibers
ND
ND
ND
ND
0.8
23.9
176.2b
14.5b
ND
0.4
ND
ND
ND
ND
3.6
ND
44.5
263.9
2009 Effluent
Sampling
International
Paper
ND
ND
ND
ND
ND
ND
0.6323
0.8079
0.0522
ND
ND
ND
ND
ND
ND
ND
ND
1.4924
2000 Effluent
Sampling
Weyerhauser
ND
ND
ND
ND
ND
ND
63.3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
63.3
2009 Effluent
Sampling
Sources: Wiegand, 201 la, 20lib.
ND: Non-detect results.
a Of the mills with monitoring data, only six measured dioxins and furans at detectable concentrations. The other six mills measured dioxins and furans at
concentrations below detection.
b Discharges are above the Method 1613 ML.
5-47
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-16. Grams and TWPE Associated with Discharges Above the ML
Congener Above the ML
Congener TWF
Grams of Congener
Released"
Total TWPE Released
Boise White Paper
2,3,7,8-TCDF
43,819,554
0.47
45,400
Rayonier Performance Fibers
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
6,586
43,819,554
Total
3.47
0.286
4.23
50.4
27,600
73,100
Sources: Wiegand, 201 la, 20lib, TRIReleases2009_v2.mdb.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Data obtained from the facility through AF&PA and NCASI.
EPA found that only six of the twelve mills measured dioxin and furan concentrations
above detection limits, and only two above the Method 1613B ML. This is consistent with the
2006 Pulp and Paper Detailed Study (U.S. EPA, 2006b), in which EPA found that a majority of
the estimated releases of dioxin are based on pollutant concentrations measured below the ML.
EPA has previously concluded that concentrations below the ML may not be accurate, and the
measurements may not accurately reflect industry discharges. For the two mills with analytical
data showing dioxin and furan concentrations above the ML, EPA estimated a load of 73,100
TWPE per year.
5.3.3.3 NCASI Engineering Calculations
Five facilities, presented in Table 5-17, stated that they estimated their 2009 dioxin TRI
discharges using NCASI engineering calculations, which are based on published emission
factors. For details on the calculations underlying the NCASI-published emission factors, see
Section 5.3.2 of the 2006 Pulp and Paper Detailed Study (U.S. EPA, 2006b). The monitoring-
based average concentrations used by NCASI, described in the 2006 Pulp and Paper Detailed
Study, are all less than the Method 1613B ML (U.S. EPA, 2006b).
Table 5-17. Facilities Using Engineering Calculations to Estimate 2009 TRI Discharges
Name of Mill
Georgia-Pacific, Naheola Mill
International Paper
Georgia-Pacific
Evergreen Packaging
Georgia-Pacific Corp.
Location
Pennington, AL
Franklin, VA
Crossett, AR
Pine Bluff, AR
Palatka, FL
Total Dioxin Grams
3.6
2.14
5.09
3.21
1.4
TWPE
10,800
10,400
8,900
5,690
2,480
Source: Wiegand, 2011 a.
5.3.3.4 Other Estimation Methods
Three facilities, listed in Table 5-18, stated that they use a different method to estimate
their 2009 dioxin TRI discharges:
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
• Kimberly-Clark (Everett) confirmed that they use mass balances based on
historical congener data—not actual discharge measurements—to estimate their
dioxin TRI discharges. This mill shut down in April 2012 (Fryer, 2012; Wiegand,
201 Ib).
• Clearwater Paper Corp. (formerly Potlatch Corporation) in Lewiston
documented that its 2009 dioxin TRI discharges were estimated using data from
an experimental methodology known as "high-volume sampling." EPA Region 10
conducted the procedure, which involved the separate collection of solid and
dissolved fractions of up to 1,000 liters of effluent that were then filtered to a
more concentrated aliquot (Wiegand, 201 Ib). EPA conducted the procedure as
part of the Tier 1 Endangered Species Act Monitoring and NPDES Permit
Compliance Monitoring between 2005 and 2007 in order to monitor the effluent
and natural waters above and below the Clearwater facility. Using this
methodology, Region 10 detected all dioxin congeners and furans during the
study, but all at concentrations below the 1613B ML. 1,2,3,4,6,7,8,9-OCDD was
detected most frequently but the maximum detection was 5.47 pg/L in 2007,
which is well below the 1613B ML of 100 pg/L. Region 10 concluded that the
Clearwater's effluent has no influence on downstream dioxin measurements
(Nickel, 2012).
• Procter & Gamble Paper Products (Mehoopany) documented that the mill
used its Dioxin Congener Tool to calculate 2009 dioxin TRI discharges. The
Dioxin Congener Tool is a company-specific tool that uses Procter & Gamble
pulp analysis data and the mill-specific pulp usage data to determine a weight
percentage for each of the dioxin congeners. The mill applies the weight
percentage breakdown to each estimated release value to provide a dioxin-
congener specification of each reportable release. The pulp congener analysis data
are based on the best available data, obtained directly from the pulp vendors.
Depending on the pulp, these data may come from direct sampling from the pulp
vendors, NCASI data, or estimates based on other pulps from the same supplier
(Childress, 2011). Because the mill's TRI estimate is not calculated using actual
wastewater sampling data, and the discharges are partially based on NCASI
engineering calculations, there are no analytical data to confirm the presence of
dioxin at measureable concentrations.
Table 5-18. Facilities Using Other Methods to Estimate 2009 TRI Discharges
Name of Mill
Kimberly-Clark
Clearwater Paper Corp.
Procter & Gamble Paper Products
Location
Everett, WA
Lewiston, ID
Mehoopany, PA
Total Dioxin Grams
0.419
0.4
0.02
TWPE
55,300
15,500
4,520
Sources: Wiegand, 20lib; Childress, 2011.
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
5.3.3.5 Washington State Department of Ecology Data
In addition to obtaining monitoring data from facilities, EPA contacted WADOE about
monitoring data from pulp and paper mill discharges in Washington State. EPA previously
contacted WADOE as part of the 2006 Pulp and Paper Detailed Study. WADOE provided mill
effluent dioxin sampling data for one dioxin congener, 2,3,7,8-TCDD, for three facilities,
presented in Table 5-19. The 2011 concentration in wastewater from Boise White Paper, LLC,
was found to be equal to the Method 1613B ML; the remaining concentrations provided by
WADOE are below the Method 1613B ML. WADOE stated that the concentration for 2011 was
not a permit violation because a footnote in the mill's NPDES permit states that compliance is
demonstrated if the 2,3,7,8-TCDD concentrations are equal to or less than the Method 1613 ML
(McCormack, 2012).
Table 5-19. Dioxin Data from WADOE
Mill Name
Simpson Tacoma
Kimberly-Clark
Boise White Paper, LLC
Mill Location
Tacoma, WA
Everett, WA
Wallula, WA
Year of Measurement
2005
2005
2007
2008
2009
2011
2,3,7,8-TCDD
Measurement (pg/L)
2.09
0.848
4
1
1
10a
Source: McCormack, 2012.
a Discharges are equal to the Method 1613 ML for 2,3,7,8-TCDD of 10 pg/L.
5.3.4 Summary of Findings from EPA's Review of Pulp and Paper Category
Using data collected for the 2012 Annual Review, EPA identified the following for the
pulp and paper category:
• Several pulp and paper mills do appear to discharge dioxins and furans, but at
concentrations that are below the ML (or potential regulatory action level). Only
two facilities measured dioxins and furans at concentrations above the ML. This
updated data collected for the 2012 Annual Review is largely consistent with the
findings of the 2006 Pulp and Paper Detailed Study.
• Since the vast majority of data underlying the estimated releases of dioxin and
dioxin-like compounds reported to TRI are based on pollutant concentrations
below the Method 1613B MLs, EPA is suspect about the magnitude of these
discharges from facilities in the Pulp and Paper Category. TRI-reported
discharges of dioxin and dioxin-like compounds for this category are most likely
significantly overestimated, and thus may not accurately reflect current industry
discharges.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
5-50
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
TWPE. Based on the above findings, EPA is assigning this category a lower priority for
revision—i.e., this category is marked "(3)" in the "Findings" column in Table 7-1 in the Final
2012 and Preliminary 2014 Effluent Guidelines Program Plans (U.S. EPA, 2014).
5.3.5 References for Pulp and Paper Category
1. Childress, Michael. 2011. Telephone and Email Communication Between Michael
Childress, Procter and Gamble, and Kimberly Landick, Eastern Research Group, Inc., Re:
2009 TRIDioxin Discharges. (October 18). EPA-HQ-OW-2010-0824. DCN 07836.
2. Fryer, John. 2012. Kimberly-Clark Paper Mill Shuts Down. Everett News. (April 16).
Available online at: http://www.king5.com/news/local/Kimberly-Clark-paper-mill-
officially-closes-its-doors-147535885.html. EPA-HQ-OW-2010-0824. DCN 07837.
3. McCormack, Craig. 2012. Telephone and Email Communication Between Craig
McCormack, Washington State Department of Ecology, and Kimberly Landick, Eastern
Research Group, Inc., Re: 2009 Dioxin Discharges. (February 28). EPA-HQ-OW-2010-
0824. DCN 07838.
4. Nickel, Brian. 2012. Telephone and Email Communication Between Brian Nickel, EPA
Region 10, and Kimberly Landick, Eastern Research Group, Inc., Re: 2009 High Volume
Dioxin Sampling at Pulp Mills. (February 28). EPA-HQ-OW-2010-0824. DCN 07729.
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. 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.
7. 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.
8. 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.
9. 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.
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-2008-0517-0618.
5-51
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
12. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA 830-R-12-001. EPA-HQ-OW-2010-0824-0195.
13. U.S. EPA. 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C.
(May). EPA 830-R-12-002. EPA-HQ-OW-2010-0824-0194.
14. 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-2010-0824. DCN
07756.
15. Wiegand, Paul. 2005a. Memorandum from Paul Wiegand, National Council for Air and
Stream Improvement, to Jerry Schwartz, American Forest and Paper Association. Table
14: PCDD/F Concentrations in Eight EFC Bleached Chemical Pulp Mill Treated
Effluents (NCASI2002). (April 29). EPA-HQ-OW-2004-0032-0500.
16. Wiegand, Paul. 2005b. Memorandum from Paul Wiegand, National Council for Air and
Stream Improvement, to Jerry Schwartz, American Forest and Paper Association. Table
12: Mean PCDD/F Concentrations in Eight Bleached Chemical Pulp Mill (Mostly Non-
ECF) Treated Effluents from EPA's Guidance Document. (April 29). EPA-HQ-OW-
2004-0032-0502.
17. Wiegand, Paul. 201 la. Email Communication Between Paul Wiegand, National Council
for Air and Stream Improvement, and Elizabeth Sabol, Eastern Research Group, Inc., Re:
Pulp and Paper TRI Questions. (August). EPA-HQ-OW-2010-0824-0084.
18. Wiegand, Paul. 201 Ib. Email Communication Between Paul Wiegand, National Council
for Air and Stream Improvement, and Kimberly Landick, Eastern Research Group, Inc.,
Re: Pulp and Paper Dioxin Data. (November). EPA-HQ-OW-2010-0824. DCN 07839.
5-52
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Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported to TRI in 2004-2009
TRI ID
98421-
SMPSN-
801PO
98201-
SCTTP-
2600F
04976-
SDWRR-
RFD3U
32034-
TTRYN-
FOOTO
37309-
BWTRS-
ROUTE
83501-
PTLTC-
805MI
99363-
BSCSC-
POBOX
23851-
NNCMP-
HIGHW
71635-
GRGPC-
PAPER
36916-
JMSRV-
ROUTE
98362-
DSHWM-
MARIN
71611-
NTRNT-
FAIRF
Mill Name
Simpson Tacoma
Kraft Co.
Kimberly-Clark
Worldwide
S.D. Warren Co.
Rayonier
Performance
Fibers, LLC
AbitibiBowater
Calhoun
Operations
Clearwater Paper
Corp, Idaho Pulp
& Paperboard
Boise White Paper
LLC
International
Paper-Franklin
Mill
Georgia-Pacific
Crossett Ops.
Georgia-Pacific
Consumer
Products LP
Nippon Paper
Industries USA
Co. Ltd.
Evergreen
Packaging
Location
Tacoma, WA
Everett, WV
Skowhegan,
ME
Fernandina
Beach, FL
Calhoun, TN
Lewiston, ID
Wallula, WA
Franklin, VA
Crossett, AR
Pennington,
AL
Port Angeles,
WA
Pine Bluff,
AR
2009
Grains
Released
2.243
0.419
0.184
5.197
0.6854
0.4
0.20886
2.1364
5.0851
2
0.034969
3.2139
TWPE
228,696
55,269
37,877
37,842
24,888
15,465
13,745
10,440
8,993
8,488
8,367
5,684
Basis of
Estimate
M2
C
E2
Ml
El
M2
0
El
El
El
M2
0
2008
Grams
Released
NR
0.487
0.187
0.66
0.6875
0.4
0.205513
1.3677
5.327
3.44
0.03689
3.3431
TWPE
NR
874
335
1,184
1,234
718
369
2,454
77
50
66
49
Basis of
Estimate
NR
C
E2
Ml
El
M2
0
El
El
El
M2
0
2007
Grams
Released
0.12
NR
0.15
NR
0.73
0.44
5.58
NR
5.6
3.2
NR
3.4
TWPE
208
NR
269
NR
1,319
789
10,014
NR
10,043
5,742
NR
6,101
Basis of
Estimate
El
NR
E2
NR
El
M2
0
NR
El
El
NR
0
2005
Grams
Released
0.154
1.33
0.168
0.56
0.87
0.441
0.083
NR
4.87
3.6
0.92
3.7
TWPE
277
2,380
302
1,000
1,560
792
149
NR
8,740
6,460
1,650
6,640
Basis of
Estimate
E
C
0
M
M
E
0
NR
E
M
M
0
2004
Grams
Released
0.135
2.7
0.17
1
0.94
4.18
0.83
2.28
5.49
3.3
1.82
3.6
TWPE
242
4,846
305
1,794
1,690
7,501
1,496
4,086
9,850
5,921
3,266
6,459
Basis of
Estimate
E
C
0
M
M
E
0
E
E
M
M
0
5-53
-------
Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported to TRI in 2004-2009
TRI ID
18629-
PRCTR-
ROUTE
36545-
BSCSC-
307WE
36732-
GLFST-
HIGHW
28456-
FDRLP-
RIEGE
71654-
PTLTC-
HIGHW
28560-
WYRHS-
STREE
32078-
GRGPC-
STATE
27962-
WYRHS-
TROWB
75504-
NTRNT-
POBOX
32533-
CHMPN-
375MU
37662-
MDPPR-
POBOX
32347-
BCKYC-
ROUTE
Mill Name
Procter & Gamble
Paper Products
Co.
Boise White Paper
LLC
Rock-Term Mill
Co., LLC
International
Paper Riegelwood
Mill
Clearwater Paper
Corp., Arkansas
City
Weyerhaeuser
Georgia-Pacific
Corp, Palatka
Domtar Paper Co.
Plymouth Mill
International
Paper Texarkana
Mill
International
Paper Pensacola
Mill
Weyerhaeuser Co
Kingsport Paper
Mill
Buckeye Florida
LP
Location
Mehoopany,
PA
Jackson, AL
Demopolis,
AL
Riegelwood,
NC
Arkansas
City, AR
Vanceboro,
NC
Palatka, FL
Plymouth,
NC
Queen City,
TX
Cantonment,
FL
Kingsport,
TN
Perry, FL
2009
Grains
Released
0.020003
2.2812
2.1694
0.0663
0.456
1.35604
1.4041
3.4794
1.552
2.309
0.83272
0.123152
TWPE
4,517
4,032
3,838
3,507
3,222
2,715
2,483
2,373
1,752
1,568
1,473
1,141
Basis of
Estimate
El
El
El
El
0
El
El
El
M2
El
El
M2
2008
Grams
Released
0.018
2.3119
1.9993
0.0304881
0.984
1.657323
1.4
4.2028
1.302
0.88
0.8617
1.221887
TWPE
32
34
29
55
1,766
24
20
7,541
19
1,579
1,546
18
Basis of
Estimate
El
El
El
El
0
El
El
El
M2
El
0
M2
2007
Grams
Released
0.02
2.21
1.84
0.0304
NR
1.71
NR
4.33
2.68
NR
NR
NR
TWPE
29
3,965
3,301
54
NR
3,069
NR
7,777
4,809
NR
NR
NR
Basis of
Estimate
El
El
El
El
NR
El
NR
El
M2
NR
NR
NR
2005
Grams
Released
0.087
2.1
0.292
0.0304
0.204
1.7
NR
0.989
0.68
0.8
3.45
1.32
TWPE
156
3,770
524
55
365
3,050
NR
1,770
1,220
1,440
6,190
2,380
Basis of
Estimate
E
E
E
E
0
E
NR
E
M
E
M
M
2004
Grams
Released
0.012
2.1
0.32
0.0305
0.97
1.74
NR
0.91
3.87
0.93
3.4
1.3
TWPE
22
3,768
575
55
1,737
3,119
NR
1,638
6,944
1,669
6,101
2,330
Basis of
Estimate
C
E
E
E
0
E
NR
E
M
E
M
M
5-54
-------
Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported to TRI in 2004-2009
TRI ID
63702-
PRCTR-
POBOX
31521-
BRNSW-
14W9T
29442-
NTRNT-
KAMIN
31545-
TTRYN-
SAVAN
70634-
BSSTH-
USHIG
3676W-
NTRNT-
76HIG
49829-
MDPBL-
COUNT
54308-
THPRC-
501EA
17362-
PHGLT-
228SO
12883-
NTRNT-
SHORE
36426-
CNTNR-
HIGHW
18653-
PPTLB-
MAINS
Mill Name
Procter & Gamble
Paper Products
Co.
Brunswick
Cellulose Inc.
International
Paper Georgetown
Mill
Rayonier
Performance
Fibers, Jesup Mill
Boise Packaging
& Newsprint LLC
International
Paper, Pine Hill
Mill
Escanaba Paper
Co.
Procter & Gamble
Paper Products
Co.
P. H. Glatfelter
Co Spring Grove
Mill
International
Paper
Smurfit-Stone
Container
Enterprises Inc.
Cascades Tissue
Group PA Inc,
Ransom Mill
Location
Jackson, MO
Brunswick,
GA
Georgetown,
SC
Jesup, GA
Deridder, LA
Pine Hill, AL
Escanaba, MI
Green Bay,
WI
Spring
Grove, PA
Ticonderoga,
NY
Brewton, AL
Ransom, PA
2009
Grains
Released
0.005099
0.2271
0.6383
0.00023
0.0893
3.0065
0.890943
0.000300
1.0633
0.4166
3.0053
0.0179
TWPE
802
309
214
191
156
116
85
83
70
62
44
32
Basis of
Estimate
0
El
C
0
El
El
M2
C
El
M2
M2
C
2008
Grams
Released
0.0051
0.218
0.683
0.0003
0.1455
3.02814
5.612
0.0006
1.105
0.4223
3.0053
0.0153
TWPE
0
391
1,225
1
261
44
81
0
1,983
758
44
27
Basis of
Estimate
0
El
C
0
El
E2
M2
C
El
M2
M2
C
2007
Grams
Released
0.004
0.19
NR
NR
0.12
NR
NR
0.0008
1.02
0.44
NR
0.0179
TWPE
8.8
341
NR
NR
215
NR
NR
1
1,830
790
NR
32
Basis of
Estimate
0
El
NR
NR
El
NR
NR
C
El
M2
NR
C
2005
Grams
Released
0.0042
0.186
0.753
NR
0.19
NR
NR
0.0003
0.946
0.46
NR
NR
TWPE
8
335
1,350
NR
341
NR
NR
1
1,700
826
NR
NR
Basis of
Estimate
0
E
C
NR
E
NR
NR
C
E
E
NR
NR
2004
Grams
Released
0.0051
0.19
0.75
NR
0.22
NR
NR
0.0005
0.9
0.46
2.5
NR
TWPE
9.2
335
1,351
NR
395
NR
NR
0.9
1.616
834
4,486
NR
Basis of
Estimate
0
E
C
NR
E
NR
NR
C
E
E
E
NR
5-55
-------
Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported to TRI in 2004-2009
TRI ID
29704-
BWTRC-
5300C
31407-
STNCN-
1BONN
29044-
NNCMP-
ROUTE
54474-
WYRHS-
200GR
98607-
JMSRV-
NE4TH
70791-
GRGPC-
ZACHA
31068-
BCKYC-
OLDST
Mill Name
Bowater Coated &
Specialty Papers
Div.
Weyerhaeuser
Port Wentworth
International
Paper
Weyerhaeuser
Fort James Camas
LLC
Georgia-Pacific
Consumer
Products LLC
Weyerhaeuser Co.
Location
Catawba, SC
Port
Wentworth,
GA
Eastover, SC
Rothschild,
WI
Camas, WA
Zachary, LA
Oglethorpe,
GA
2009
Grams
Released
2.161
1.273
0.119
0.063972
0.0025
0.00163
0.0011
TWPE
31
18
2
1
0.2311
0.0237
0.0160
Basis of
Estimate
M2
El
M2
M2
El
M2
O
2008
Grams
Released
1.9695
1.3648
0.1077
0.0633
0.0034
10
0.001
TWPE
29
2,449
193
114
6
2,337
2
Basis of
Estimate
C
El
M2
M2
M2
El
O
2007
Grams
Released
NR
0.61
NR
NR
NR
2.77
0.001
TWPE
NR
1,094
NR
NR
NR
4,974
1.79
Basis of
Estimate
NR
El
NR
NR
NR
El
O
2005
Grams
Released
NR
0.679
0.183
0.042
NR
2.77
0.001
TWPE
NR
1,220
328
75
NR
4,970
2
Basis of
Estimate
NR
E
0
M
NR
E
O
2004
Grams
Released
NR
0.69
0.16
0.048
NR
2.77
0.0005
TWPE
NR
1,239
282
86
NR
4,974
0.9
Basis of
Estimate
NR
E
0
M
NR
E
O
Indirect
07407-
MRCLP-
1MARK
29681-
WRGRC-
803NO
32401-
STNCN-
1EVER
54308-
THPRC-
501EA
31702-
THPRC-
USROU
Marcal Paper
Mills Inc.
Sealed Air Corp,
Cryovac Div.
Smurfit-Stone
Container Corp.
Procter & Gamble
Paper Products
Co.
Procter & Gamble
Paper Products
Co.
Elmwood
Park, NJ
Simpsonville,
SC
Panama City,
FL
Green Bay,
WI
Albany, GA
0.379098
0.011185
0.074799
0.000850
0.000663
1,273
989
256
234
111
M2
O
El
C
O
0.1699
NR
NR
NR
NR
2.468
NR
NR
NR
NR
M2
NR
NR
NR
NR
0.16
0.0187
0.082
0.00081
0.001
1,315
1,654
146
0.997
109
M2
O
El
C
O
0.02499
NR
0.0782
0.00034
0.001989
45
NR
140
1
4
M
NR
E
C
O
0.00799
NR
0.078
0.00051
0.0036
14
NR
140
0.9
6.4
M
NR
E
C
O
5-56
-------
Section 5—Continued Review of Select Point Source Categories
5.3—Pulp, Paper, and Paperboard (40 CFR Part 430)
Table 5-20. Dioxin and Dioxin-Like Discharges from Pulp and Paper Category Reported to TRI in 2004-2009
TRI ID
55744-
BLNDN-
115SW
93030-
PRCTR-
800NO
23860-
STNHP-
910IN
55720-
PTLTC-
NORTH
63702-
PRCTR-
POBOX
MU1 Name
UPM Blandin
Paper Co.
Procter & Gamble
Paper Products
Co.
Smurfit-Stone
Container Corp.
Sappi Cloquet
LLC
Procter & Gamble
Paper Products
Co.
Location
Grand
Rapids, MN
Oxnard, CA
Hopewell,
VA
Cloquet, MN
Jackson, MO
2009
Grains
Released
2.19
0.000134
0.000045
0.04131
0.000000
238
TWPE
59.33
20.27
1.239
0.5998
0.027
Basis of
Estimate
E2
C
C
M2
El
2008
Grams
Released
2.379
NR
NR
NR
NR
TWPE
175.7
NR
NR
NR
NR
Basis of
Estimate
E2
NR
NR
NR
NR
2007
Grams
Released
2.11
0.00016
0.221
0.04
0.00392
TWPE
3,782
0.45
397
78
9
Basis of
Estimate
El
C
C
M2
0
2005
Grams
Released
2.261
0.000021
4
0.21
0.04811
NR
TWPE
4,060
0
378
86
NR
Basis of
Estimate
M
C
0
E
NR
2004
Grams
Released
2
0.0034
NR
0.044
NR
TWPE
3,599
6.1
NR
78
NR
Basis of
Estimate
M
C
NR
E
NR
Sources: TRIReleases2009_v2; TRIReleases2008_v3; TRIReleases2007_v2; TRIReleases2005_v2; and TRIReleases2004_v3.
NR: Not reported.
For indirect discharges, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 83 percent removal of dioxin
and dioxin-like compounds by the POTW.
The TWPEs in this table were calculated using the 2006 TWFs (the 2006 dioxin and dioxin-like compound TWFs did not change from the August or December 2004 TWFs).
Refineries reported basis of estimate in TRI as: M (monitoring data/measurements), M2 (periodic monitoring data/measurements), C (mass balance calculations), E (published
emission factors), and O (other approaches, such as engineering calculation).
5-57
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
6.
NEW DATA SOURCES AND HAZARD ANALYSES
For the 2012 Annual Review, EPA explored six new data sources to supplement the
toxicity rankings analysis (TRA) conducted as part of the 2011 Annual Review (78 FR 48159).
EPA primarily focused on the four data sources identified during the 2011 Annual Review:
Targeted National Sewage Sludge Survey (TNSSS) data, Office of Pollution Prevention and
Toxics (OPPT) Chemical Action Plans, Office of Air Quality Planning and Standards (OAQPS)
air regulations, and Toxics Release Inventory (TRI) sectors expansion data. EPA's goals in
selecting these specific data sources were to identify new wastewater discharges or pollutants not
previously regulated and to identify wastewater discharges that can be eliminated or treated more
effectively.
EPA documented the data usability and quality of each source, analyzed how the data
could be used to improve the characterization of industrial wastewater discharges (concentration
and quantity of pollutants, wastewater treatment available for new industries/concentrations), and
prioritized the findings for further review. See Appendix B of this report for more information on
data usability and quality of the new data and hazard sources.
Table 6-1 lists the six data sources and provides a summary of the relevant content EPA
evaluated as part of its 2012 Annual Review. EPA identified these data sources by evaluating
information available within EPA Office of Water, information from other EPA offices (e.g.,
Office of Pollution Prevention and Toxics, Office of Research and Development), information
from technical conferences and research articles, or stakeholder input and determined whether
these data sources would be useful in fulfilling the objectives of the effluent guidelines planning
process. Sections 6.1 through 6.6 of this report provide the detail for each of the analyses.
Section 7 summarizes EPA's findings from the new data sources and hazard analyses.
Table 6-1. Additional Hazard Data Sources Evaluated for the 2012 Annual Review
Data Source
Relevant Content
Office of Water 2009 TNSSS
The Office of Water's Targeted National Sewage Sludge Survey
(TNSSS) measured contaminant concentrations in sewage sludge
from 74 publicly owned treatment works (POTWs). EPA reviewed
the TNSSS survey results in combination with indirect discharges
from the 2009 TPJ database to determine if the pollutants could be
attributed to specific industrial wastewater discharges (or point
source categories), particularly for the pollutants that may impact the
beneficial use of sewage sludge.
Office for Chemical Safety and Pollution
Prevention/Office of Pollution Prevention and
Toxics(OCSPP/OPPT) Chemical Action Plans
Under TSCA, OPPT developed Chemical Action Plans for 10
classes of chemicals that potentially create health and/or
environmental hazards when manufactured in or imported into the
U.S. EPA reviewed these chemicals and corresponding industries to
identify new pollutants or wastestreams that might warrant
regulation.
6-1
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-1. Additional Hazard Data Sources Evaluated for the 2012 Annual Review
Data Source
Relevant Content
Office of Air Quality Planning and Standards
(OAQPS) Air Regulations:
• National Emission Standards for Hazardous
Air Pollutants (NESHAPs)
• New Source Performance Standards (NSPS)
Air regulations may require air pollution controls that generate new
wastewater discharges for industrial categories that did not
previously exist (e.g., the use of wet scrubbers to remove air
pollutants). EPA reviewed air regulations to identify any new
wastewater discharges, or specific pollutant discharges, that may be
associated with air pollution control requirements established for
specific industrial categories, particularly since the promulgation of
the respective ELGs.
Office of Environmental Information's (OEI)
2011 Proposed TRI Expansion Sectors
OEI is exploring the expansion of TRI reporting requirements to
additional industrial sectors. The proposed rulemaking is scheduled
to be published in December 2014. EPA reviewed the publicly
available industry profile information and corresponding data on
pollutants of concern considered as part of this rulemaking. EPA
also reviewed any monitoring data and literature submitted as public
comment to the rulemaking to date.
EPA Office of Water, Office of Ground Water
and Drinking Water (OGWDW), and Office of
Research and Development (ORD) Analytical
Methods
Several Offices within the Agency have developed or recently
revised analytical methods for measuring pollutants in industrial
wastewater or in drinking water (e.g., perfluorinated compounds and
other contaminants of emerging concern). EPA evaluated these new
or recently revised analytical methods to help identify unregulated
pollutants in industrial wastewater discharges, or changes to existing
analytical methods that may provide for increased sensitivity and
potentially lower detection limits for regulated pollutants.
Technical Papers and Research Articles on
Industrial Wastewater Treatment Technologies
Industry and academic experts are continually evaluating the
performance and viability of new and innovative treatment
technologies to remove pollutants of concern from industrial
wastewater.EPA is conducting a literature review and developing a
database to capture and catalog wastewater treatment performance
data as they pertain to specific point source categories and their
related wastewater discharges.
6.1 Identification of Industrial Wastewater Pollutants in Sewage Sludge
EPA is augmenting its traditional toxicity ranking analysis by examining data from
additional sources—for example, existing sewage sludge data that characterize pollutants
associated with industrial activity. Specifically, EPA reviewed the Targeted National Sewage
Sludge Survey (TNSSS), conducted by EPA's Office of Water (OW), that measured contaminant
concentrations in sewage sludge from 74 publicly owned treatment works (POTWs). Although
the TNSSS did not identify the industrial wastewater discharged to the sampled POTWs, EPA
used other publicly available data, including data reported to the Toxics Release Inventory (TRI)
in 2009, to examine pollutants discharged to POTWs and explored how those pollutants might
interfere with beneficial use of sewage sludge or "biosolids".
This review suggests the metal finishing industry may be discharging high concentrations
of metals, particularly chromium, nickel, and zinc, to POTWs, which could transfer to sewage
sludge and impact its beneficial use. Based on its review of the TNSSS and 2009 TRI data sets,
EPA could not identify for further review any new pollutants of concern or wastewater
discharges from industrial categories not currently regulated by effluent limitations guidelines
and standards (ELGs). EPA focused its review on the pollutants in the TNSSS with discharge
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
information available in TRI since TRI provided a means to link industrial wastewater sources to
the pollutants found in POTW sludge.
The following subsections present background on POTW sewage sludge as it relates to
ELGs, data sources used in the analysis, and an overview of EPA's analyses and findings from
its review of the TNSSS. Throughout this section, EPA refers to sewage sludge, the solid,
semisolid, or liquid residue generated during the treatment of domestic sewage in a treatment
facility; rather than sludge, the term commonly used for untreated or raw wastewater. For more
information on the TNSSS, see http://water.epa.gov/scitech/wastetech/biosolids/tnsss-
overview.cfm.
6.1.1 Background
Under the Clean Water Act (CWA), EPA develops categorical pretreatment standards for
industrial wastewater discharged to POTWs. These standards are intended to prevent discharge
to POTWs of industrial wastewater pollutants that pass through the POTW without adequate
treatment. They also prevent discharges of industrial wastewater pollutants that may interfere
with POTW operation. Among other things, this includes pollutants that may interfere with
sewage sludge beneficial use—for example, land application of sewage sludge as a soil
amendment in agriculture and landscaping.11
As shown in Figure 6-1, an industrial facility may discharge wastewater to a POTW,
discharge directly to a receiving stream, or split its wastewater between the two discharge
options. At the POTW, industrial wastewater is typically combined with sanitary wastewater,
stormwater runoff, and treatment chemicals. Because all of these discharges contribute to the
pollutants in sewage sludge, it is difficult to relate pollutants found in sewage sludge from
POTWs to specific industrial wastewater discharges.
11 Current EPA regulations exist for the land application of sewage sludge, also referred to as biosolids. Biosolids
are regulated under 40 CFR Part 503. For more information about the EPA Biosolids program, see
http://water.epa.gov/scitech/wastetech/biosolids/
6-3
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Industrial
Facilities
Industrial
Wastewater
On-site
Treatment
Sewage
Sludge
Sanitary
Wastewater
Stormwater
Runoff
Discharge to POTW
(TRI)
Direct
Discharge to
Streama
Treatment
Chemicals
POTW
Sewage Sludge
(TNSSS)
Effluent to
Strsam
Direct discharge facilities discharge wastewater directly to surface water. Indirect discharge facilities discharge wastewater to a POTW, which then discharge
to a receiving stream.
Figure 6-1. Industrial Facility Wastewater Discharge Options
6-4
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
6.1.2 OW's TNSSS
OW conducted the TNSSS to advance the understanding of pollutants present in treated
sewage sludge (biosolids) and to develop national estimates of the concentrations of selected
analytes. The collected information was intended to help OW assess if exposures to analytes
were occurring and whether the concentrations in sewage sludge may be of concern for public
health and the environment. For this 2012 Annual Review, EPA used the TNSSS results to
examine how the quality of POTW sewage sludge and its beneficial use may be affected by
industrial wastewater discharges. The following subsections provide additional background on
sewage sludge regulations and the TNSSS.
6.1.2.1 Sewage Sludge Regulations
Under 40 CFR Part 503 EPA regulates sewage sludge disposal and use. The regulations
establish numeric limits, management practices, and operational standards to protect public
health and the environment from the adverse effects of pollutants in sewage sludge. Part 503
regulates three disposal options for sewage sludge: land application, landfill/surface disposal,
and incineration.
Section 405(d) of the CWA requires EPA to complete a biennial review of sewage sludge
regulations. The biennial review looks at 40 CFR Part 503 standards for purposes of regulating
new pollutants where sufficient data exist.12 OW's 2003 biennial review of sewage sludge
regulations identified new pollutants of concern that became the starting point for the TNSSS
analysis.
6.1.2.2 OW's TNSSS Analysis
In 2006 and 2007, OW collected sewage sludge samples from 74 POTWs in 35 states.
For reference, there are approximately 16,000 POTWs in the U.S. (DMR Loading Tool). OW
selected the sampled POTWs based on:
• Size (must treat more than one million gallons of wastewater per day);
• Geography (must be located in the contiguous U.S.); and,
• Treatment type (must employ secondary treatment or better).
The selection criteria did not account for the variety of industrial discharges to the
POTWs. OW analyzed 84 sewage sludge samples, one from each facility plus and additional
sample at 10 facilities for quality control purposes or because the facility had more than one
treatment system. Therefore, 84 samples were collected from 74 POTWs during the TNSSS
(U.S. EPA, 2009a).
Through the 2003 biennial review13 of sewage sludge regulations and a subsequent
biosolids exposure and hazard assessment, OW identified nine pollutants warranting further
12 See EPA's webpage on the use and disposal of biosolids for further information on the biennial review:
http://water.epa.gov/scitech/wastetech/biosolids/.
13 See 68 FR 75531: https://federalregister.gov/a/03-32217.
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
evaluation.14 To conduct a more refined risk evaluation and risk characterization for the nine
pollutants, OW needed updated sewage sludge concentration data. OW expanded the list of
analytes for the TNSSS from nine to 145 to include analytes that could be analyzed at little extra
cost or because of their widespread use and emerging concern.
OW analyzed the sewage sludge samples for 145 analytes, listed in Table 6-27 at the end
of this section. The analytes included metals, organics, inorganic anions, polybrominated
diphenyl ethers, steroids and hormones, and pharmaceutical chemicals. Table 6-28, also at the
end of this section, presents detailed information about each of the analytes including the EPA
programs that address the analyte, and datasets or regulations that are relevant to the 2012 304m
Annual Review.15 For example, for the pollutant arsenic, Table 6-28 provides a toxic weighting
factor (TWF) value and notes that it is listed as a CWA priority pollutant, regulated under 40
CFR Part 503, and included in TRI. Table 6-2 summarizes this information for each pollutant
group. For more information on POTW and analyte selection criteria and sampling methodology,
refer to the Targeted National Sewage Sludge Survey Overview Report (U.S. EPA, 2009a) or the
Targeted National Sewage Sludge Survey Sampling and Analysis Technical Report (U.S. EPA,
2009b).
Table 6-2. TNSSS Analyte Groups and Applicability to EPA Programs and Regulations
Pollutant Group
Metals
Organics
Inorganic anions
Polybrominated diphenyl
ethers (PBDEs)
Steroids and hormones
Pharmaceutical chemicals
Total
Number of
Pollutants
28
6
3
11
25
72
145
Number
with
TWFs
25
5
1
0
0
1
32
Number
of CWA
Priority
Pollutants
13
4
0
0
0
0
17
Number
Regulated
under
40 CFR 503
10
0
0
0
0
0
10
Number
with
Chemical
Action
Plans3
0
1
0
11
0
0
12
Number
of TRI-
Listed
Chemical
17
3
1
0
0
0
21
Source: U.S. EPA, 2009a.
a See Section 6.2 of this report for discussion of the EPA Chemical Action Plans.
6.1.2.3 Findings of TNSSS
Briefly, the survey found (U.S. EPA, 2009a):
• Of the 28 metals in the study, 27 were found in virtually every sample; one metal
(antimony) was found in 72 of the 84 samples.
• Of the six semivolatile organics and polycyclic aromatic hydrocarbons, four were
found in at least 72 of 84 samples, one was found in 63 of 84 samples, and one
was found in 39 of 84 samples.
14 The pollutants identified for further evaluation were barium, beryllium, manganese, silver, fluoranthene, pyrene,
4-chloroaniline, nitrate, and nitrite.
15 EPA programs, datasets and regulations reviewed include TWF values, CWA priority pollutants, 40 CFR Part 503
regulations, chemical action plans, and TRI-listed chemicals.
6-6
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
• Four anions were found in every sample.
• All but one flame retardant (BDE-138) were found in essentially every sample;
BDE-138 was found in 54 out of 84 samples.
• Of the 25 steroids and hormones measured, three steroids (campesterol,
cholestanol, and coprostanol) were found in all 84 samples and six steroids were
found in at least 80 of the samples. One hormone (17a-ethynyl estradiol) was not
found in any sample and five hormones were found in fewer than six samples.
• Of the 72 pharmaceuticals, three (cyprofloxacin, diphenhydramine, and
triclocarban16) were found in all 84 samples and nine were found in at least 80 of
the samples. However, 15 pharmaceuticals were not found in any sample and 29
were found in fewer than three samples.
As part of the TNSSS analysis, OW compared the maximum sewage sludge metals
concentrations to the existing regulatory ceilings for sewage sludge land application
(subcategory B) in 40 CFR Part 503. Exceedances of the ceilings were identified for
molybdenum, zinc, and nickel. In the TNSSS, OW did not compare analyte concentrations with
other regulatory ceilings or limits for sewage sludge disposal, such as surface disposal
(subcategory C) and incineration (subcategory E).
In its TNSSS report, OW concluded that it is not appropriate to speculate on the
significance of the results until it completes a proper evaluation and review. OW is currently
evaluating the pollutants the survey identified in sewage sludge and plans to conduct an exposure
and hazard assessment for these pollutants if sufficient data are available (U.S. EPA, 2009a;
Stevens, 2013).
6.1.2.4 Limitations of the TNSSS for EPA's 2012 Annual Review
The TNSSS has certain limitations that prevented EPA from exploring how pollutants
discharged to POTWs might interfere with beneficial use of sewage sludge as part of its 2012
Annual Review:
• It does not address sources of the influent wastewater to the POTW. Specifically,
industrial discharges were not identified and thus are not easily distinguished
from other sources such as domestic wastewater.
• It does not consider variations in water quality, either the influent or the effluent
wastewater that may affect the contaminants in sewage sludge and their quantity.
• The type and performance of the sampled treatment systems were not considered,
including variations that affect sewage sludge quantity and quality.
• Although the TNSSS was a statistical sample of the 3,337 POTWs that met the
study criteria,17 because only 74 POTWs were sampled out of approximately
16 Although trichlocarban is not a pharmaceutical, it is included in the pharmaceutical chemicals group because it is
detected by the same analytical method used to measure pharmaceutical concentrations in sludge.
17 Study criteria included: facilities that treated more than one MOD, were located in the contiguous U.S., and
employ secondary treatment or better. (U.S. EPA, 2009b).
6-7
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
16,000 in the U.S., the study was limited in its ability to characterize pollutants
from industries not discharging to the sampled POTWs.
These limitations provide challenges in using the TNSSS data to identify industrial
wastewater discharges potentially affecting the quality of POTW sewage sludge and its
beneficial use.
6.1.3 EPA's 2012 Annual Review of Sewage Sludge Analyses
EPA used TNSSS data in combination with other publicly available data to examine
pollutants identified in sewage sludge that are discharged to POTWs in industrial wastewater.
The following sections discuss the completed analyses.
6.1.3.1 Identifying Industrial Discharges to TNSSS POTWs
POTWs accept wastewater from a variety of domestic and industrial sources. Over
100,000 non-domestic users discharge to POTWs across the U.S. (U.S. EPA, 1991). These non-
domestic users include significant industrial users (SIUs),18 retail and commercial
establishments, and industrial dischargers that do not meet EPA's definition of significant
industrial user (U.S. EPA, 1991).
The TNSSS did not identify the source of the wastewater treated by the sampled POTWs.
Specifically, it omitted information on the type and magnitude of industrial wastewater
discharges that may be treated at the POTWs. Because of this omission, for this analysis, EPA
used TRI data to identify some of the industrial facilities that discharge wastewater to the
sampled POTWs. EPA also used TRI data to analyze the possible sources of the pollutants
TNSSS identified in POTW sewage sludge.
TRI includes industry-reported data for 682 chemicals and chemical categories. In TRI,
facilities report annual mass loads released to the environment of each chemical or chemical
category. They must report the amount transferred to offsite locations, which may include direct
discharges to surface water or discharges to POTWs. For discharges to POTWs, they must
identify the specific POTW that receives their wastewater. With the information facilities
reported to TRI, EPA evaluated industrial pollutant transfers to the POTWs included in the
TNSSS and also evaluated specific industrial pollutants that may pass through the POTW and
accumulate in sewage sludge.19
A facility must meet three criteria to be required to submit a TRI report (U.S. EPA,
2009c):
1. Be categorized in North American Industry Classification System (NAICS) code
11, 21, 22, 31 through 33, 42, 48 through 49, 51, 54, or 81 or be a federal facility.
2. Have 10 or more full-time employees or their equivalent.
18 The CWA defines an SIU as an indirect discharger that is the focus of control efforts under the national
pretreatment program; includes all indirect dischargers subject to national categorical pretreatment standards, and all
other indirect dischargers that contribute 25,000 gallons per day or more of process wastewater, or which make up
five percent or more of the hydraulic or organic loading to the municipal treatment plant, subject to certain
expectations (40 CFR 403.3(t)).
19 For more information on TRI, see http://www2.epa.gov/toxics-release-inventory-tri-program.
6-8
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
3. Manufacture, process, or otherwise use a chemical or chemical category on the
TRI list above the appropriate activity threshold.
Due to these reporting requirements, TRI does not have data for all of the industrial
facilities (particularly smaller facilities) that discharge to the POTWs included in the TNSSS.
EPA used information from the 2009 TRI database to identify the number of facilities
that discharge directly and the number that discharge indirectly for each point source category.
For some point source categories, such as petroleum refining, most facilities discharge directly to
surface waters. For the analyses presented in this section, EPA only included point source
categories composed primarily of indirect dischargers because these categories are most likely to
have widespread impacts on POTW sewage sludge (i.e., excluded categories within which less
than 30 percent of the facilities discharge to POTWs).20
To relate TRI data to the TNSSS, EPA used the following TRI data fields for each
facility: TRI ID, release code, chemical name and Chemical Abstracts Service (CAS) number,
total transfer to POTWs,21 and NAICS code. For some of the analyses of pollutants in sewage
sludge described in this section, EPA also applied a TWF to estimate toxic-weighted pound
equivalents (TWPE)22 to rank pollutant discharges and point source categories discharging to
POTWs based on the toxicity of their discharge and identify trends in the data.
Of the 74 POTWs sampled in the TNSSS, EPA identified 35 POTWs that receive
wastewater from industrial facilities that reported to TRI in 2009. EPA identified these 35
POTWs by matching POTW name and location between the two datasets. Table 6-3 presents all
POTWs sampled in the TNSSS that are reported as receiving wastewater in TRI.
EPA identified and analyzed information for 153 industrial facilities that transfer
pollutants to the 35 TNSSS POTWs that receive wastewater from industrial facilities that report
to TRI. Using the facility NAICS codes, EPA matched these 153 facilities to 28 point source
categories. Table 6-3 identifies the specific point source categories that are discharging to each
of the 35 TNSSS POTWs. EPA then ranked the 28 point source categories by the number of
facilities in TRI that reported discharges to these POTWs, shown in Table 6-4. Metal Finishing
(40 CFR Part 433) was the point source category with the greatest number of facilities reporting
discharges to TNSSS POTWs, with 52 facilities reporting wastewater transfers. Together with
the next point source category, Electroplating (40 CFR Part 413), the two point source categories
contain nearly 50 percent of the facilities reporting discharges to the 35 TNSSS POTWs.
20 Sixteen point source categories were omitted from the sewage sludge analyses because they had greater than 70
percent direct discharges: National Security & International Affairs (Part 97); Sugar Processing (Part 409); Cement
Manufacturing (Part 411); Chlorine and Chlorinated Hydrocarbons (Part 414.1); Fertilizer Manufacturing (Part 418);
Petroleum Refining (Part 419); Iron and Steel Manufacturing (Part 420); Phosphate Manufacturing (Part 422);
Steam Electric Power Generating (Part 423); Timber Products Processing (Part 429); Pulp, Paper and Paperboard
(Part 430); Metal Products and Machinery (Part 438); Ore Mining and Dressing (Part 440); Waste Combustors (Part
444); Explosives Manufacturing (Part 457); and Drinking Water Treatment (Part 501). BAD identified that four of
these 16 categories discharged to a TNSSS POTW: Petroleum Refining (Part 419), Iron and Steel Manufacturing
(Part 420), Steam Electric Power Generating (Part 423), and Pulp, Paper and Paperboard (Part 430).
21 To evaluate industrial discharges' effects on sewage sludge, EPA examined the releases reported as transferred to
POTWs. For toxicity rankings and TRIReleases2009, EPA applies an assumed percent of pollutant removed at the
POTW, before the sewage sludge reaches the surface water. See Section 3 of the 2011 Annual Review Report (U.S.
EPA, 2012) for details on POTW removals and the toxicity rankings.
22 See the 2011 Annual Review Report for details on TWFs and TWPE (U.S. EPA, 2012).
6-9
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-3. TNSSS-Sampled POTWs That Receive Wastewater from Industrial Facilities Reporting to TRI
POTW Name from TNSSS
Duncan PUAWWT
Salisbury WWTF
Everett WWTP
Buffalo Bird Island STP
Little Miami Drainage Basin/WWTP
Albany (WPCP No. 2)
Stockton WWTF
Southeast WPCP
Middlesex Cnty UA
Wixom STP
Benton Harbor - St. Joseph
Canajoharie STP
Geneva Marsh Creek WWTP
Topeka North WWTP
Boone WWTP
Huntsville Aldridge Creek WWTP
Boulder 75th Street WWTP
Texarkana City of
Santa Barbara WWTF
Southside STP #2
State
OK
MD
WA
NY
OH
GA
CA
CA
NJ
MI
MI
NY
NY
KS
IA
AL
CO
TX
CA
TX
POTW Name in TRI
City of Duncan - OMI Duncan
Wastewater Treatment
City of Salisbury Wastewater
Treatment Plant
City of Everett Department of
Public Works
Buffalo Sewer Authority
Metropolitan Sewer District of
Greater Cincinnati
Albany WPCP
Stockton Municipal Utilities
Department of Public Works
Middlesex Cnty Util Auth Water
Reclaim Center
Wixom Sewage Disposal Plant
Benton Harbor-St Joseph Sewage
Dspl Pit
Canajoharie (V) WWTP
Marsh Creek WWTP - Geneva
City of Topeka WPCD
Boone Water Pollution Control
Aldridge Wastewater Treatment
City of Boulder Wastewater
Treatment Plant
Texarkana South Regional WWTP
Goleta West Sanitary District
City of Tyler Treatment Plant West
Side
Point Source Categories in TRI Discharging to POTWa
433 - Metal Finishing
463 - Plastics Molding and Forming; 432 - Meat and Poultry Products
433 - Metal Finishing
405 - Dairy Products Processing; 415 - Inorganic Chemicals Manufacturing;
433 - Metal Finishing; 436 - Mineral Mining and Processing; 471 -
Nonferrous Metals Forming and Metal Powders; 463 - Plastics Molding and
Forming; 508 - Printing and Publishing
433 - Metal Finishing; 413 - Electroplating
428 - Rubber Manufacturing
406 - Grain Mills;
433 - Metal Finishing
73 - Business Services; 414 - Organic Chemicals, Plastics And Synthetic
Fibers; 415 - Inorganic Chemicals Manufacturing; 428 - Rubber
Manufacturing; 439 - Pharmaceutical Manufacturing; 455 - Pesticide
Chemicals; 471 - Nonferrous Metals Forming And Metal Powders; 503 -
Miscellaneous Foods and Beverages
413 - Electroplating; 433 - Metal Finishing
50 - Wholesale Trade - Durable Goods; 413 - Electroplating; 433 - Metal
Finishing
503 - Miscellaneous Foods and Beverages
426 - Glass Manufacturing
407 - Canned And Preserved Fruits and Vegetables Processing; 406 - Grain
Mills
432 - Meat and Poultry Products
433 - Metal Finishing
433 - Metal Finishing; 439 - Pharmaceutical Manufacturing; 507 -
Independent And Stand Alone Labs
414 - Organic Chemicals, Plastics and Synthetic Fibers; 428 - Rubber
Manufacturing
433 - Metal Finishing
414 - Organic Chemicals, Plastics And Synthetic Fibers; 428 - Rubber
Manufacturing; 433 - Metal Finishing
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-3. TNSSS-Sampled POTWs That Receive Wastewater from Industrial Facilities Reporting to TRI
POTW Name from TNSSS
Spanish Fork
ElizabethtonWWTP
Trinity River Authority; Ellis County
WWTP
SSSD/Lawson Fork Plant
Valencia WRP
Phoenix 23rd Ave WWTP
Beaver Dam WWTP
Alcosan STP (Allegheny County)
Bedford WWTP & Sewer System
Northeast Ohio Regional Sewer
District, Southerly WWTP
River Road WWTP
Mayfield STP
Bloomington STP North
Richmond SD
Huntington City Of
State
UT
TN
TX
sc
CA
AZ
WI
PA
OH
OH
TX
KY
IN
IN
WV
POTW Name in TRI
Spanish Fork City POTW
Elizabethton
Trinity River Authority
Spartanburg Sanitary Sewer District
Valencia WRP
23rd Ave Wastewater Treatment
Plant
Beaver Dam Wastewater Treatment
Facility
Allegheny County Sanitation
Authority
Bedford POTW
Northeast Ohio Sewer District
Southerly WWTP
City of Amarillo Industrial Waste
Mayfield Electric and Water
Systems
Bloomington Utilities
Richmond Sanitary District
City of Huntington
Point Source Categories in TRI Discharging to POTWa
413 -Electroplating
433 - Metal Finishing
433 - Metal Finishing
414 - Organic Chemicals, Plastics And Synthetic Fibers; 417 - Soap And
Detergent Manufacturing; 428 - Rubber Manufacturing; 433 - Metal
Finishing; 508 - Printing & Publishing
433 - Metal Finishing
405 - Dairy Products Processing; 413 - Electroplating; 417 - Soap And
Detergent Manufacturing; 421 - Nonferrous Metals Manufacturing; 433 -
Metal Finishing; 436 - Mineral Mining And Processing; 464 - Metal Molding
And Casting (Foundries); 465 - Coil Coating; 469 - Electrical And Electronic
Components; 503 - Miscellaneous Foods And Beverages
405 - Dairy Products Processing; 433 - Metal Finishing
426 - Glass Manufacturing; 433 - Metal Finishing
433 - Metal Finishing
413 - Electroplating; 433 - Metal Finishing; 464 - Metal Molding And
Casting (Foundries); 467 - Aluminum Forming; 468 - Copper Forming; 471 -
Nonferrous Metals Forming And Metal Powders
405 - Dairy Products Processing
433 - Metal Finishing
433 - Metal Finishing
20 - Food & Kindred Products; 405 - Dairy Products Processing; 433 - Metal
Finishing; 468 - Copper Forming
No point source categories discharge to this POTW with less than 70 percent
direct discharges.
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a Excluding point source categories with less than 30 percent indirect discharges in the TRI database.
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-4. Ranking of Point Source Categories3 by the Count of Facilities Discharging to
a TNSSS POTW Included in TRI
Point
Source
Category
Code
433
413
414
405
428
415
469
468
508b
471
503b
417
464
406
436
421
432
426
463
439
507b
467
407
465
50b
73b
455
20b'c
Total
Point Source Category
Metal Finishing
Electroplating
Organic Chemicals, Plastics and Synthetic Fibers
Dairy Products Processing
Rubber Manufacturing
Inorganic Chemicals Manufacturing
Electrical and Electronic Components
Copper forming
Printing and Publishing
Nonferrous Metals Forming and Metal Powders
Miscellaneous Foods and Beverages
Soap and Detergent Manufacturing
Metal Molding and Casting (Foundries)
Grain mills
Mineral Mining and Processing
Nonferrous Metals Manufacturing
Meat and Poultry Products
Glass Manufacturing
Plastics Molding and Forming
Pharmaceutical Manufacturing
Independent and Stand Alone Labs
Aluminum Forming
Canned and Preserved Fruits and Vegetables Processing
Coil Coating
Wholesale Trade — Durable Goods
Business Services
Pesticide Chemicals
Food and Kindred Products
Count of TRI Facilities
Discharging to a
TNSSS POTW
52
19
17
7
6
6
5
4
4
o
J
3
o
J
2
2
2
2
2
2
2
2
153
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a Excluding point source categories with less than 30 percent indirect discharges in the TRI database.
b Industries in this category (503) are not EPA-regulated point source categories. The point source categories with a
500 series code are potential new point source categories identified during previous annual reviews. EPA is
evaluating discharges from these industries.
0 Point source categories with two-digit code are similar industries grouped by SIC code that have not been
thoroughly reviewed. Industrial discharges from Food and Kindered Products are potentially part of point source
category 503 - Miscellaneous Foods and Beverages, however the discharges have not been analyzed in detail.
6.1.3.2 Limitations of Using TRI and TNSSS to Characterize Industrial Discharges'
Impacts on Sewage Sludge
TRI is the best available dataset to identify industrial discharges to POTWs; however, it
does not represent all industrial discharges to each POTW due to the criteria for inclusion in TRI.
As shown in Figure 6-2 below, of the more than 100,000 industrial facilities discharging to
POTWs, approximately 25,000 SIUs are not required to report to TRI. Further, using the TRI
data, EPA identified only 153 facilities reporting discharging to POTWs in the TNSSS. An
6-12
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
additional, unknown number of facilities also discharge to these POTWs, but are not required to
report to TRI.
Figure 6-3 depicts the relationship between all POTWs in the U.S., the POTWs in the
TNSSS, and the POTWs receiving wastewater from facilities that report to TRI. Of the 74
POTWs in the TNSSS, EPA identified only 35 receiving wastewater from facilities that report to
TRI. As a result, these 35 POTWs were the source of the information EPA used to analyze the
accumulation of industrial wastewater pollutants in sewage sludge.
All Industrial Facilities Discharging to POTWs: >100,000 :
I
All Significant Industrial Users:
-30,000
Report to TRI in 2009: 3,204
Did not Report to TRI in 2009:
-26,500b
Receiving POTW not Indicated
Indicated POTW Receiving Wastewater
Transfer
t '
. Receiving POTW in TNSSS: ' [ Receiving POTW not in TNSSS
a Includes nondomestic users such as retail and commercial establishments and industries that do not meet EPA's
definition of significant industrial user.
b An unknown number of significant industrial users discharge to the POTWs included in the TNSSS.
Figure 6-2. Universe of Industrial Facilities and Connection to POTWs Included in TNSSS
6-13
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
All POTWs
(inlCIS-NPDES):
^16.000
POTWs
Receiving
Transfers
fromTRI
Facilities:
1.160
Used to Analyze Industrial
Wastewater Pollutants in
POTW Sludge
Figure 6-3. POTW Universe and POTWs Used to Analyze Industrial Wastewater
Pollutants in Sewage Sludge
6.1.3.3 Pollutants Included in Both TNSSS and TRI
To evaluate industrial wastewater discharges potentially affecting the quality of POTW
sewage sludge, EPA identified pollutants included in the TNSSS that are also reported in TRI.
Most pollutants in the TNSSS are not reported in TRI: of the 145 pollutants included in the
TNSSS, EPA indentified only 21 pollutants or pollutant groups that facilities reported
transferring to any POTW in TRI in 2009. These pollutants are shown in Table 6-5. Several of
these 21 pollutants are grouped or named slightly differently. Table 6-6 explains these pollutant
discrepancies and the action EPA took and/or the assumptions EPA made in order to use the data
in its analyses.
Table 6-5. Pollutants Included in Both the TNSSS and TRI
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Fluoranthene3
Lead
Manganese
Mercury
Molybdenumb
Nickel
Nitrate/Nitrite"
Selenium
Silver
Thallium
Vanadium
Zinc
Benzo(a)pyrenea
Bis(2-ethylhexyl) phthalatec
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a Represented by TRI chemical polycyclic aromatic compounds.
b Represented by TRI chemical molybdenum trioxide.
0 Represented by TRI chemical di(2-ethylhexyl).
d Represented by TRI chemical nitrate compounds.
6-14
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-6. Pollutant Differences between TNSSS and TRI
Pollutant Difference between TNSSS and TRI
TRI includes only molybdenum trioxide, not any other molybdenum
compounds.
TRI's nitrate compounds category is the closest to TNSSS's
nitrate/nitrite.
Bis(2-ethylhexyl)phthalate in TNSSS is called di(2-ethylhexyl) phthalate
in TRI.
Benzo(a)pyrene and fluoranthene are polycyclic aromatic compounds
(PACs), and TRI requires facilities to report PACs as a set of chemicals,
not individually.
TRI only lists releases of elemental phosphorus (yellow or white), a
hazardous material. TRI does not include releases of phosphate, the form
of phosphorus found in wastewater. TNSSS included "water extractable
phosphorus," a measure of the phosphates and organo-phosphorus
compounds extractable from sewage sludge.
EPA Action
Included the TRI pollutant
molybdenum trioxide in the analysis
to represent the TNSSS molybdenum.
Included the TRI pollutant nitrate
compounds in the analysis to
represent the TNSSS nitrate/nitrite.
Included the TRI pollutant di(2-
ethylhexyl) phthalate in the analysis
to represent the TNSSS bis(2-
ethylhexyl) phthalate.
Included the TRI pollutant PACs in
the analysis to represent the TNSSS
benzo(a)pyrene and fluoranthene.
Did not include phosphorus in the
analysis, because the TRI chemical
and TNSS analyte are not
comparable.
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
6.1.3.4 TRI-Reported Transfers of Pollutants Included in the TNSSS
EPA used information in TNSSS and TRI to learn more about how industrial wastewater
discharges can affect the quality of POTW sewage sludge. EPA's analyses were limited to the 21
pollutants, listed in Table 6-5, that were included both in TNSSS and TRI. As stated in Section
6.1.3.1, EPA only included point source categories composed primarily of indirect dischargers
because these categories are most likely to have widespread impacts on POTW sewage sludge.
Using information from the limited TRI data, EPA tallied the number of facilities
reporting transfers of the pollutants included both in TNSSS and TRI, shown in Table 6-7. Of the
21 pollutants included in both TNSSS and TRI, all pollutants had reported TRI discharges to the
TNSSS POTWs with the exception of thallium. No facilities, associated with point source
categories composed primarily of indirect dischargers, reported transfers of thallium in TRI.
Additionally, the TRI chemical polycyclic aromatic compounds, listed in Table 6-7, is
represented by the TNSSS analytes fluoranthene and benzo(a)pyrene.
EPA also calculated the total pounds of each of the pollutants TRI facilities reported
transferring to the TNSSS POTWs. EPA's toxicity ranking analysis calculates the mass of
pollutants discharged to the receiving stream, after POTW removals. For the sewage sludge
analysis, EPA looked instead at the transfers to the POTW, before any removal. As shown in
Figure 6-1, an unknown portion of the pollutant mass transferred to the POTW may partition to
the sewage sludge. To understand industrial wastewater pollutants that may affect POTW
sewage sludge, Table 6-7 presents the total pounds transferred to the POTW, which is the
quantity before any of the pollutant is removed in the POTW treatment system, and the
maximum amount that may partition to sewage sludge.
Chemicals have varying toxicity. In order to compare groups of unrelated chemicals,
EPA developed TWFs for use in its ELG development program. The TWF accounts for the
human health and environmental hazard potential of a chemical. Using the TWF and the pounds
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
of pollutant, EPA calculates TWPE—in other words, a weighted mass of a chemical that
accounts for its relative toxicity. For further information on TWFs and TWPE calculation, see
Section 5 of EPA's Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories (U.S. EPA, 2009c).
Table 6-7 also shows the top TNSSS pollutants included in TRI, ranked by total TWPE
transferred to POTWs, and includes the number of facilities reporting transfers of each pollutant.
The TRI chemical category with the highest TWPE is "nitrate compounds"; however, the TRI
chemical category may differ from nitrate/nitrite compounds analyzed in the TNSSS.
Table 6-7. Pollutants Transferred" to POTWs, Ranked by TWPE
Pollutant
Nitrate compounds
Copper and copper compounds
Cadmium and cadmium compounds
Lead and lead compounds
Mercury and mercury compounds
Silver and silver compounds
Nickel and nickel compounds
Zinc and zinc compounds
Manganese and manganese compounds
Polycyclic aromatic compounds0
Chromium and chromium compounds
Arsenic and arsenic compounds
Cobalt and cobalt compounds
Selenium and selenium compounds
Di(2-ethylhexyl) phthalate
Antimony and antimony compounds
Barium and barium compounds
Vanadium and vanadium compounds
Molybdenum trioxide
Total
Total Pounds Discharged
Before POTW Removals
107,000,000
100,000
1,030
10,400
178
997
58,400
124,000
81,400
56.8
63,500
289
7,500
519
1,600
23,500
87,800
3,000
5,910
108,000,000
TWPE Before
POTW Removals
79,600
63,500
23,800
23,400
20,800
16,400
6,360
5,810
5,730
5,720
4,810
1,170
857
582
407
288
175
105
4.73
260,000
Facility Count
813
1,060
28
1,381
45
38
785
717
399
20
677
21
116
7
31
96
64
9
9
6,316
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Excluding point source categories with less than 30 percent indirect discharges in the TRI database.
b No facilities reported discharges of thallium in TRI.
0 The TRI chemical polycyclic aromatic compounds is represented by fluoranthene and benzo(a)pyrene in the
TNSSS.
Based on available data from TRI, which is the only current data source linking industrial
wastewater sources to pollutants found in POTW sludge, (with the exception of nitrate
compounds), metals make up the largest contribution of pollutant discharges from industrial
sources to POTWs. As a result, EPA focused the remainder of its review on metals discharges.
6.1.3.5 Metals Analysis
As shown in Table 6-7, more than 200,000 TWPE of metals are potentially transferred to
POTW sewage sludge from industrial wastewater discharges reported in TRI. These metals
discharges can affect the quality and potential beneficial reuse of POTW sewage sludge.
6-16
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
POTWs use biological treatment to remove the organic material and pathogens found in
sanitary wastewater, but metals (which are found in many industrial wastewater discharges) are
not easily degraded in these biological treatment systems. As a result, the mass of the metals
coming into the treatment system that are not discharged (that is, the portion that is removed) is
potentially transferred to sewage sludge, as shown in the equation below:
Influent = discharged + removed (potentially transferred to sewage sludge)
EPA calculated the mass of metals potentially transferred to sewage sludge using the
reported mass of metals transferred to POTWs and the assumed removal efficiency for each
metal in the 2009 TRI database (TRIReleoses2009_v2.mdb). EPA calculated the pounds and
TWPE of metals potentially transferred to sewage sludge for point source categories composed
primarily of indirect dischargers. (This analysis included all TRI-reported transfers to POTWs,
not just those facilities and point source categories that discharged to the 35 POTWs included in
the TNSSS.)
Table 6-8 presents the results of this analysis, with categories ranked by TWPE. The
metals included in this table are the parent metals and compounds in the TRI database; the data
presented in Table 6-8 do not take into account how pollutants were matched between TRI and
the TNSSS. As shown, the Metal Finishing (40 CFR Part 433) point source category accounts for
the highest amount of metals TWPE potentially transferred to sewage sludge.
Table 6-8. Point Source Category Rankings by Metals TWPE Potentially Transferred to
Sewage Sludge3
Point
Source
Category
Code
433
432
421
413
414
471
464
406
415
463
467
425
468
410
Point Source Category
Metal Finishing
Meat and Poultry Products
Nonferrous Metals Manufacturing
Electroplating
Organic Chemicals, Plastics and Synthetic
Fibers
Nonferrous Metals Forming and Metal Powders
Metal Molding and Casting (Foundries)
Grain Mills
Inorganic Chemicals Manufacturing
Plastics Molding and Forming
Aluminum Forming
Leather Tanning and Finishing
Copper Forming
Textile Mills
Remaining point source categories
Total
Facility
Count
3,940
6
377
464
416
340
590
28
344
163
277
12
314
54
1,066
8,391
Metals Pounds
Potentially
Transferred to
Sewage Sludgeb
107,000
1,050
16,000
21,200
47,000
12,200
8,290
5,120
47,100
5,770
4,170
29,000
3,690
27,700
36,600
372,000
Metals TWPE
Potentially
Transferred to
Sewage Sludgeb
55,400
13,700
12,800
12,500
10,200
7,680
4,290
3,500
3,500
2,580
2,310
2,160
2,120
1,630
7,160
142,000
Sources: TRIReleases2009_v2.mdb.
Note: Sums of individual values may not equal the total presented, due to rounding.
a Excluding point source categories with less than 30 percent indirect discharges in the TRI database.
b EPA calculated the pounds and TWPE of metals potentially transferred to sewage sludge by evaluating
difference between the discharges to the POTWs and the discharges from the POTWs.
the
6-17
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
As part of the TNSSS analysis, OW compared the maximum sewage sludge metals
concentrations to the existing regulatory ceilings for sewage sludge land application
(subcategory B) in 40 CFR Part 503. For this 2012 Annual Review, EPA included an additional
comparison of the TNSSS data to surface disposal limits (subcategory C) in order to compare the
sewage sludge concentrations to the most stringent limitations in 40 CFR Part 503,23 while
capturing as many pollutants as possible for the comparison. Sewage sludge land application
(Subcategory B) concentrations are referred to as ceiling concentrations, while surface disposal
(Subcategory C) concentrations are referred to as concentration limits in 40 CFR Part 503. Table
6-9 presents the 40 CFR Part 503 comparisons. EPA identified four pollutants with sewage
sludge concentrations that exceed 40 CFR Part 503 ceilings/limits: three exceedances for land
application (molybdenum, nickel, and zinc) and two exceedances for surface disposal (chromium
and nickel).
Table 6-9. Comparison of TNSSS Maximum Sewage Sludge Concentration to 40 CFR Part
503 Regulatory Limits3
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
TNSSS
Maximum
Concentration
(mg/kg)
49.2
11.8
1,160
2,580
450
8.3
132
526
24.7
8,550
Land
Application
Ceilings
(mg/kg)
75
85
-
4,300
840
57
75
420
100
7,500
Number of Samples
Exceeding Land
Application Ceiling
0
0
-
0
0
0
2
3
0
1
Surface
Disposal
Limits
(mg/kg)b
73
-
600
-
-
-
-
420
-
-
Number of
Samples
Exceeding Surface
Disposal Limit
0
-
1
-
-
-
-
3
-
-
Sources: 40 CFR Part 503; U.S. EPA, 2009b.
a Bold indicates pollutants with sewage sludge concentrations that exceed 40 CFR 503 ceilings/limits.
b The surface disposal limits for Subcategory C depend on the distance to the property line. The limits listed in
Table 6-9 apply to distances greater than 150 meters from the property line.
For the 2012 Annual Review analysis, EPA focused on three of the pollutants that have
maximum sewage sludge concentrations exceeding 40 CFR Part 503 ceilings or limits from the
comparison shown in Table 6-9: chromium, nickel, and zinc. Nickel concentrations exceeded the
ceiling/limit in three of 84 sewage sludge samples; chromium and zinc concentrations exceeded
the ceiling/limit in one of 84 samples. The TNSSS identified nickel and zinc as pollutants of
concern because sewage sludge concentrations exceeded 40 CFR Part 503 land application
ceilings; EPA also considered chromium a pollutant of concern because the TNSSS sewage
sludge concentrations exceeded 40 CFR Part 503 surface disposal limits (U.S. EPA, 2009b).
Molybdenum discharges were not reviewed further, even though sewage sludge concentrations
exceeded land application ceilings, because the pollutant is not fully represented in the 2009 TRI
database (TRI includes only molybdenum trioxide, not any other molybdenum compounds). As
23 40 CFR 503 Subcategory E, "Incineration," has limits for risk-specific concentration. Because these limits are in
units of mass per volume (milligrams per cubic meter), they are not directly comparable to the land application or
surface disposal limits.
6-18
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
part of the TNSSS analysis, OW found that of the POTWs observed exceeding the land
application ceilings, one incinerated its treated sewage sludge on site, while the others sent their
sewage sludge to landfills. Thus, results from the TNSSS indicated that POTWs were generally
complying with the existing land application standards for metals (U.S. EPA, 2009b).
For each metal that exceeded a limit in 40 CRF Part 503 (except molybdenum), EPA
ranked the 74 TNSSS POTWs according to sewage sludge concentration of that metal. EPA also
identified the facilities in TRI that reported discharging the metal of concern to these POTWs.
Chromium Results
Table 6-10 presents the POTWs with the highest chromium sewage sludge concentrations
in the TNSSS. EPA could only identify TRI facilities that reported transferring chromium to one
of these POTWs. EPA could not identify TRI facilities for the POTW with the highest TNSSS
sewage sludge chromium concentration (Punxsutawney Boro STP), suggesting that the
chromium in its sewage sludge may not originate from industrial wastewater discharges of the
type that must be reported to TRI.
Table 6-10. POTWs with Highest Chromium Sewage Sludge Concentrations
POTW Name from
TNSSS
Punxsutawney Boro
STpb
Huntington City Of
Topeka North WWTP
Northeast Ohio
Regional Sewer District,
Southerly WWTP
North Tonawanda (c)
WWTPb
Wixom STP
Buena Vista STPb
City
Punxsutawney
Huntington
Topeka
Cleveland
North
Tonawanda
Wixom
Buena Vista
State
PA
WV
KS
OH
NY
MI
VA
Chromium
Concentration
(mg/kg)a
1,160C
310
282
271
262
261
260
TRI Facilities
Discharging
Chromium to the
POTW
0
0
0
o
6
0
0
0
TRI Reporters
Discharging
Chromium to the
POTW
None
None
None
Sifco Forge Group,
Alcoa Cleveland
Works, Plastic
Platers, Inc
None
None
None
Sources: U.S. EPA, 2009a, 2009b.
a The 40 CFR Part 503 concentration limit for chromium is 600 mg/kg.
b These two POTWs are not found in TRI.
0 Chromium discharge exceeds 40 CFR Part 503 limitations.
Only three TRI facilities reported transferring chromium to the TNSSS POTWs with high
sewage sludge chromium concentrations. To learn more about facilities that discharge chromium
to POTWs, EPA analyzed the TRI data by performing the following steps:
• Ranked all TRI facilities discharging chromium to POTWs by total discharge (in
pounds).
• Linked the top chromium discharging facilities to point source categories.
• Ranked the point source categories by total TWPE before POTW removals.
6-19
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Figure 6-4 presents the facilities that reported the greatest amounts of chromium transfers
to POTWs in TRI. The top two facilities presented in the figure are in the Leather Tanning and
Finishing Category (40 CFR Part 425) and account for 39 percent of the total chromium
discharge.
12000
Leather Tannins and Finishing
Metal Finishing
NoufeiTous Metals Forming
Electroplating
Source: TRIReleases2009_v2.mdb.
Figure 6-4. Top Chromium Discharges to POTWs in TRI
Table 6-11 presents point source categories for the TRI facilities reporting indirect
discharges of chromium, ranked by total TWPE before POTW removals. Table 6-11 also
presents the total number of facilities reporting transfers of chromium to POTWs for each point
source category. As shown, metal finishing has the largest number of facilities that discharge
chromium (426), but ranks lower than leather tanning and finishing in terms of total TWPE
before POTW removals.
6-20
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-11. TRI Point Source Categories Ranked by Total Chromium TWPE Transferred
to POTWsa
Point Source Category
Leather Tanning and Finishing
(Part 425)
Metal Finishing (Part 433)
Nonferrous Metals Forming and
Metal Powders (Part 471)
Electroplating (Part 413)
Textile Mills (Part 4 10)
Plastics Molding and Forming
(Part 463)
Meat and Poultry Products (Part
432)
Inorganic Chemicals (Part 415)
Remaining Point Source
Categories
Number of
Establishments in
the U.S. (2007
Economic Census)
240
142,805
873
2,720
6,842
11,962
3,757
1,366
NA
Number of
Facilities
Reporting
Transfers to
POTWs
8
426
22
65
9
12
1
17
117
TWPE before
POTW
Removals1"
2,120
1,080
469
390
245
92
83.9
72.6
258
Percent of
Total TWPE
before POTW
Removals'"
44%
22%
10%
8%
5%
2%
2%
2%
5%
Source: 2007 U.S. Economic Census (U.S. Census, 2007) and TRIReleases2009_v2.mdb.
NA: Not Applicable.
a The data presented in Table 6-11 were not compared to TNSSS POTWs.
b The TWPE before POTW removals is the total TRI-reported chromium discharges transferred to POTWs.
EPA then identified the point source categories of TRI facilities reporting transfers of
chromium to the 35 TNSSS POTWs. Table 6-12 shows that these POTWs most commonly
receive wastewater from TRI facilities in the metal finishing point source category, which is to
be expected due to the large number of facilities reporting discharges of chromium.
To determine if industrial discharges may be contributing to higher concentrations of
chromium in POTW sewage sludge, EPA compared the mean and median chromium
concentrations for the POTWs in the TNSSS that are receiving discharges from industrial
facilities reporting chromium to TRI to the POTWs in the TNSSS that are not receiving
discharges from facilities reporting chromium to TRI. The TNSSS POTWs not in TRI were
included as "TNSSS POTWs without TRI Facilities Reporting Chromium Transfers." Table 6-13
presents these results. The TNSSS POTWs with reported chromium discharges from TRI
facilities have a higher mean and median chromium sewage sludge concentration. This suggests
that industrial discharges of chromium in general may be contributing to higher concentrations of
chromium in sewage sludge.
6-21
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-12. TNSSS POTWs Receiving Chromium Transfers from TRI Facilities
TNSSS
POTW Name
Northeast Ohio Regional
Sewer District, Southerly
WWTP
Phoenix 23rd Ave
WWTP
Duncan PUAWWT
Buffalo (Sewer Auth.)
Bird Island STP
Beaver Dam WWTP
Mayfield STP
SSSD/LawsonFork
Plant
City
Cleveland
Phoenix
Duncan
Buffalo
Beaver Dam
Mayfield
Spartanburg
State
OH
AZ
OK
NY
WI
KY
SC
Sewage Sludge
Chromium
Concentration
(mg/kg)a
271
215
213
136
72.8
26
13.9
TRI
Name of Facility
Plastic Platers Inc.
Alcoa Cleveland Works
Alcoa Cleveland Works
Alcoa Cleveland Works
Sifco Forge Group Inc.
Honeywell Aerospace - Phoenix
Repair & Overhaul
Honeywell Engines Systems &
Services
Dolphin Inc.
Halliburton Energy Services -
Duncan Manufacturing Center
ITT Heat Transfer
Apache Stainless Equipment Corp.
Mayville Engineering Co Inc.,
Phoenix Coaters Division
Remington Arms Co Inc.
Circor Instrumentation
Technologies
Total
Chromium
Transfer
(LEY)
2,260
8
8
8
5.4
55
26
10
4.8
1.5
5
1.1
24.2
1.29
Point Source Category
Electroplating (Part 413)
Aluminum forming (Part 467)
Copper forming (Part 468)
Nonferrous Metals Forming and Metal
Powders (Part 471)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Molding and Casting (Foundries)
(Part 464)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a The 40 CFR Part 503 concentration limit for chromium is 600 mg/kg.
6-22
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-13. Chromium Sewage Sludge Concentrations from TNSSS POTWs With and
Without Reporting TRI Facilities (mg/kg)
Chromium Sewage Sludge
Concentrations at TNSSS POTWs
With TRI Facilities Reporting Chromium
Without TRI Facilities Reporting
Chromium
Mean
123.73
80.06
Median
104.4
33
Minimum
13.9
6.74
Maximum
271
1,160
POTW
Count
8
66
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
Nickel Results
EPA conducted a similar set of analyses for nickel. Table 6-14 presents the nine POTWs
with the highest nickel sewage sludge concentrations in the TNSSS. EPA was able to identify
facilities that reported to TRI transfers of nickel to seven of the top nine TNSSS POTWs.
Table 6-14. Identification Information for Top-Ranking TNSSS POTWs for Nickel
POTW Name from
TNSSS
Duncan PUAWWT
O J Riedel WWTPC
ElizabethtonWWTP
Benton Harbor - St.
Joseph
Wixom STP
Northeast Ohio
Regional Sewer
District, Southerly
WWTP
Larkfield-Wikiup
WWTFC
Buffalo (Sewer Auth.)
Bird Island STP
City
Duncan
Schertz
Elizabethton
St. Joseph
Wixom
Cleveland
Wikiup
Buffalo
State
OK
TX
TN
MI
MI
OH
CA
NY
Nickel
Concentration
(mg/kg)a
516b
255
217
174
122
120
120
110
TRI
Facilities
Discharging
Nickel to the
POTW
1
0
1
2
1
4
0
1
TRI Reporters Discharging
Nickel to the POTW
Halliburton Energy Services,
Duncan Manufacturing Center
None
Snap-on Tools Co.
Siemens Industry, Inc., Whirlpool
Corp, Benton Harbor Division
Adept Plastic Finishing Plant #4
Sifco Forge Group, Alcoa
Cleveland Works, Ford Motor Co.
Cleveland Casting, Plastic Platers
Inc.
None
ITT Heat Transfer
Sources: U.S. EPA, 2009a, 2009b.
a The 40 CFR Part 503 concentration ceiling/limit for nickel is 420 mg/kg.
b Nickel discharge exceeds 40 CFR Part 503 limitations.
c POTWs are not found in TRI.
Eleven TRI facilities reported transferring nickel to TNSSS POTWs with high sewage
sludge nickel concentrations. To learn more about facilities that discharge nickel to POTWs,
EPA analyzed the TRI data by performing the following steps:
• Ranked all TRI facilities discharging nickel to POTWs by total discharge (in
pounds).
• Linked the top nickel discharging facilities to point source categories.
• Ranked the point source categories by total TWPE before POTW removals.
6-23
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Figure 6-5 presents the facilities that reported the greatest amounts of nickel transfers to
POTWs in TRI. The top facility presented in the figure is in the OCPSF category (40 CFR Part
414) and accounts for 13 percent of the total nickel discharge to POTWs in the TNSSS.
Table 6-15 presents point source categories for the TRI facilities reporting transfers of
nickel to POTWs, ranked by total TWPE before POTW removals. Table 6-15 also presents the
total number of facilities reporting transfers of nickel to POTWs for each point source category.
As shown, the metal fishing category has the largest number of facilities reporting transfers of
nickel to POTWs and the highest total TWPE. This is similar to the results from the chromium
analysis; the metal finishing category had the largest number of facilities reporting transfers of
chromium to POTWs. However, for nickel discharges, the metal finishing category also ranks
highest, in terms of total TWPE before POTW removals.
4500
4000
OCPSF
Inorganic Chem icals Manufacturing
Grain Mills
Electroplating
Nonferrous Metals Forming and Metal Powders
Metal Finishing
Paint Formulating
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-15. TRI Point Source Categories Ranked by Total Nickel TWPEa
Point Source Category
Metal Finishing (Part 433)
Electroplating (Part 413)
Inorganic Chemicals Manufacturing
(Part 4 15)
Organic Chemicals, Plastics and
Synthetic Fibers (Part 414)
Grain Mills (Part 406)
Nonferrous Metals Forming and
Metal Powders (Part 471)
Aluminum Forming (Part 467)
Miscellaneous Foods and Beverages
(Part 503)
Paint Formulating (Part 446)
Remaining Point Source Categories
Number of
Establishments in
the U.S. (2007
Economic
Census)
142,805
2,720
1,366
5,434
676
873
1,087
12,778
1,369
NA
Number of
Facilities
Reporting
Transfers to
POTWs
474
101
20
18
2
27
15
5
4
119
TWPE before
POTW
Removals1"
1,990
1,080
1,000
872
260
255
185
138
130
444
Percent of Total
TWPE before
POTW
Removals'"
31%
17%
16%
14%
4%
4%
3%
2%
2%
7%
Source: 2007 U.S. Economic Census (U.S. Census, 2007) and TRIReleases2009_v2.mdb.
NA: Not Applicable
a The data presented in Table 6-15 were not compared to TNSSS POTWs.
b The TWPE before POTW removals is the total TRI-reported nickel discharges transferred to POTWs.
EPA identified the point source categories of TRI facilities reporting transfers of nickel to
the 35 TNSSS POTWs. Table 6-16 shows that TNSSS POTWs most commonly receive
wastewater from TRI facilities in the metal finishing point source category, which is to be
expected due to the large number of metal finishing facilities reporting discharges of nickel,
shown in Table 6-15.
To determine if industrial discharges of nickel may be contributing to higher
concentrations of nickel in POTW sewage sludge, EPA compared the mean and median nickel
concentrations for the POTWs in the TNSSS that are receiving discharges from industrial
facilities reporting nickel to TRI to the POTWs in the TNSSS that are not receiving discharges
from facilities reporting nickel to TRI. The TNSSS POTWs not in TRI were included as "Nickel
Sewage Sludge Concentrations at TNSSS POTWs Without Reporting TRI Facilities." Table 6-17
presents these results. As shown, the TNSSS POTWs with reported nickel discharges from TRI
facilities have a higher mean and median nickel sewage sludge concentration. As with the
chromium analysis results, this suggests that industrial discharges of nickel in general may be
related to higher concentrations of nickel in sewage sludge.
6-25
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-16. TNSSS POTWs Receiving Nickel Transfers from TRI Facilities
TNSSS
POTW Name
Duncan PUAWWT
ElizabethtonWWTP
Benton Harbor-St. Joseph
Wixom STP
Northeast Ohio Regional Sewer
District, Southerly WWTP
Buffalo (Sewer Auth.) Bird Island
STP
Phoenix 23rd Ave WWTP
Little Miami Drainage
Basin/WWTP
Southeast WPCP
Boulder 75th Street WWTP
Beaver Dam WWTP
Huntsville Aldridge Creek
WWTP
Trinity River Authority, Ellis
City
Duncan
Elizabethton
St. Joseph
Wixom
Cleveland
Buffalo
Phoenix
Cincinnati
San
Francisco
Boulder
Beaver Dam
Huntsville
Arlington
State
OK
TN
MI
MI
OH
NY
AZ
OH
CA
CO
WI
AL
TX
Sewage
Sludge Nickel
Concentration
(mg/kg)a
516
217
174
122
120
110
79
40.4
31
27.1
26.5
23.6
19.5
TRI
Name of Facility in TRI
Halliburton Energy Services - Duncan
Manufacturing Center
Snap-on Tools
Whirlpool Corp Benton Harbor Div
Siemens Industry Inc.
Adept Plastic Finishing Plant #4
Plastic Platers Inc.
Ford Motor Co. Cleveland Casting
Alcoa Cleveland Works
Alcoa Cleveland Works
Alcoa Cleveland Works
Sifco Forge Group Inc.
ITT Heat Transfer
Hydro Aluminum NA
Honeywell Engines Systems & Services
Dolphin Inc.
Honeywell Aerospace - Phoenix Repair
& Overhaul
D-G Custom Chrome LLC
U.S. Department of the Treasury U.S.
Mint San Francisco CA
Dieterich Standard Inc.
Apache Stainless Equipment Corp.
TW Cylinders LLC
GMC Truck Group Arlington Assembly
Total
Discharge
(LEY)
7.4
21
63
1.31
2
750
47
9
9
9
4.4
6.13
65.3
16
10
5
10
5
1
5
11
540
Point Source Category
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Electroplating (Part 413)
Electroplating (Part 413)
Electroplating (Part 413)
Metal Molding and Casting
(Foundries) (Part 464)
Nonferrous Metals Forming
and Metal Powders (Part 471)
Aluminum Forming (Part 467)
Copper Forming (Part 468)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Nonferrous Metals
Manufacturing (Part 421)
Metal Finishing (Part 433)
Metal Molding and Casting
(Foundries) Part 464
Metal Finishing (Part 433)
Electroplating (Part 413)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
6-26
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-16. TNSSS POTWs Receiving Nickel Transfers from TRI Facilities
TNSSS
POTW Name
County WWTP
Bloomington STP North
SSSD/Lawson Fork Plant
City
Bloomington
Spartanburg
State
IN
SC
Sewage
Sludge Nickel
Concentration
(mg/kg)a
18.6
12.9
TRI
Name of Facility in TRI
Plant
GEABPOLLC
Circor Instrumentation Technologies
Total
Discharge
(LEY)
44
0.7
Point Source Category
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a The 40 CFR Part 503 concentration ceiling/limit for nickel is 420 mg/kg.
6-27
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-17. Nickel Sewage Sludge Concentrations from TNSSS POTWs With and
Without Reporting TRI Facilities (mg/kg)
Nickel Sewage Sludge Concentrations
at TNSSS POTWs
With TRI Facilities Reporting Nickel
Without TRI Facilities Reporting Nickel
Mean
118.50
28.2
Median
39.70
19.4
Minimum
12.9
7.77
Maximum
526
255
POTW
Count
18
56
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
Zinc Results
Table 6-18 presents the 12 POTWs with the highest zinc sewage sludge concentrations in
the TNSSS. EPA was able to identify facilities that reported to TRI that reported transfers of zinc
to three of the top 12 POTWs.
Table 6-18. Identification Information for Top-Ranking TNSSS POTWs for Zinc
POTW Name from TNSSS
Punxsutawney Boro STP b
Wixom STP
Verona STP b
O J Riedel WWTP b
Benton Harbor-St. Joseph
River Road WWTP
Alum Creek WWTP & Sewers b
Everett WWTP
Topeka North WWTP
GTR Pottsville Area - Main STPb
Salisbury WWTF
Three Oaks WWTPb
City
Punxsutawney
Wixom
Verona
Schertz
St. Joseph
Amarillo
Columbus
Everett
Topeka
Pottsville
Salisbury
Fort Meyers
State
PA
MI
NY
TX
MI
TX
OH
WA
KS
PA
MD
FL
Zinc
Concent
ration
(mg/kg)a
8,550C
5,050
4,150
2,120
2,040
1,730
1,730
1,570
1,530
1,340
1,310
1,300
TRI
Facilities
Discharging
Zinc to the
POTW
0
1
0
0
0
0
0
0
1
0
1
0
TRI Reporters
Discharging Zinc to the
POTW
None
Tiodize/Michigan Inc.
None
None
None
None
None
None
Delmonte Topeka Pet
Food
None
SpartechFCDLLC
None
Sources: U.S. EPA, 2009a, 2009b.
a The 40 CFR Part 503 land application ceiling for zinc is 7,500 mg/kg.
b These POTWs are not found in TRI.
0 Zinc discharge exceeds 40 CFR Part 503 limitations.
Only three TRI facilities reported transferring zinc to TNSSS POTWs with high sewage
sludge zinc concentrations. To learn more about facilities that discharge zinc to POTWs, EPA
analyzed the TRI data by performing the following steps:
• Ranked all TRI facilities discharging zinc to POTWs by total discharge (in
pounds).
• Linked the top zinc discharging facilities to point source categories.
• Ranked the point source categories by total TWPE before POTW removals.
6-28
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Figure 6-6 presents the facilities that reported the greatest amounts of zinc transfer to
POTWs in TRI. The top facility presented in the figure is in the Textile Mills category (40 CFR
Part 410) and accounts for 10 percent of the total zinc discharge to POTWs in TRI.
Table 6-19 presents point source categories for the TRI facilities reporting transfers of
zinc to POTWs, ranked by total TWPE before POTW removals. Table 6-19 also presents the
total number of facilities reporting transfers of zinc to POTWs for each point source category. As
shown, the metal fishing category has the largest number of facilities reporting transfers of zinc
to POTWs and the highest total TWPE. This is similar to the results from the chromium and
nickel analyses; the metal finishing category had the largest number of facilities reporting
transfers of chromium to POTWs. Additionally, for the nickel and zinc analysis, the metal
finishing category also ranks highest, in terms of total TWPE before POTW removals.
Textile Mills
Nonferrous Metals Manufacturing
I Miscellaneous Foods and Beverages
Pharmaceutical Manufacturing
Aladdin Mills -
Antioch Rd,
Dalton, GA
Big River Zinc, Red Star Yeast Co Pharmacia & Up
Sauget, H LLC Cedar JohnCoLLC.,
Rapids, IA Kalamazoo, MI
Source: TRIReleases2009 v2.mdb.
Figure 6-6. Top Zinc Dischargers in TRI
6-29
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-19. TRI Point Source Categories Ranked by Total Zinc TWPE Transferred to
POTWsa
Point Source Category
Metal Finishing (Part 433)
Organic Chemicals, Plastics and
Synthetic Fibers (Part 414)
Textile Mills (Part 4 10)
Nonferrous Metals Manufacturing
(Part 421)
Rubber Manufacturing (Part 428)
Electroplating (Part 413)
Pharmaceutical Manufacturing (Part
439)
Grain Mills (Part 406)
Miscellaneous Foods and Beverages
Inorganic Chemicals Manufacturing
(Part 4 15)
Gum and Wood Chemicals
Manufacturing (Part 454)
Soap and Detergent Manufacturing
(Part 4 17)
Paint Formulating (Part 446)
Remaining Point Source Categories
Number of
Establishments
in the U.S.
(2007
Economic
Census)
142,805
5,434
6,842
944
2,843
2,720
1,960
676
12,778
1,366
51
878
1,369
NA
Number of
Facilities
Reporting
Transfers to
POTWs
222
59
8
14
116
90
8
13
2
26
2
7
17
133
TWPE before
POTW
Removals1"
1,060
966
933
551
537
369
223
221
193
156
123
104
82.9
288
Percent of
Total TWPE
before POTW
Removals'"
18%
17%
16%
9%
9%
6%
4%
4%
3%
3%
2%
2%
1%
5%
Source: 2007 U.S. Economic Census (U.S. Census, 2007) and TRIReleases2009_v2.mdb.
NA: Not Applicable.
a The data presented in Table 6-19 were not compared to TNSSS POTWs.
b The TWPE before POTW removals is the total TRI-reported zinc discharges transferred to POTWs.
EPA identified the point source categories of TRI facilities reporting transfers of zinc to
the 35 TNSSS POTWs. Table 6-20 shows that TNSSS POTWs most commonly receive
wastewater from TRI facilities in the metal finishing and rubber manufacturing point source
categories, which is to be expected due to the large number of metal finishing and rubber
manufacturing facilities reporting discharges of zinc, shown in Table 6-19.
To determine if industrial discharges of zinc may be contributing to higher concentrations
of zinc in POTW sewage sludge, EPA compared the mean and median zinc concentrations for
the POTWs in the TNSSS that are receiving discharges from industrial facilities reporting zinc to
TRI to the POTWs in the TNSSS that are not receiving discharges from facilities reporting zinc
to TRI. The TNSSS POTWs not in TRI were included as "Zinc Sewage Sludge Concentrations at
TNSSS POTWs Without Reporting TRI Facilities." Table 6-21 presents these results. As shown,
the TNSSS POTWs with reported zinc discharges from TRI facilities have a higher mean and
median zinc sewage sludge concentration. Similar to the chromium and nickel analysis results,
this suggests that industrial discharges of zinc in general may be related to higher concentrations
of zinc in sewage sludge.
6-30
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-20. TNSSS POTWs Receiving Zinc Transfers from TRI Facilities
TNSSS
POTW Name
Wixom STP
Topeka North WWTP
Salisbury WWTF
Huntsville Aldridge
Creek WWTP
Middlesex Cnty UA
Albany (WPCP No 2)
Bloomington STP
North
Trinity River
Authority; Ellis
County WWTP
Richmond SD
SSSD/LawsonFork
Plant
Southside STP #2
City of Texarkana
City
Wixom
Topeka
Salisbury
Huntsville
Sayreville
Albany
Bloomington
Arlington
Richmond
Spartanburg
Tyler
Texarkana
State
MI
KS
MD
AL
NJ
GA
IN
TX
IN
SC
TX
TX
Sewage
Sludge Zinc
Concentration
(mg/kg)
5,050
1,530
1,310
1,240
1,190
1,100
872
770
659
392
324
308
TRI
Name of Facility
Tiodize/Michigan Inc.
Delmonte Topeka Pet Food
SpartechFCDLLC
TW Cylinders LLC
Gary Compounds LLC
Veolia Es Technical Solutions
LLC
Madison Industries
Akcros Chemicals Inc.
NBTY NJ (Nutro Laboratories)
Cooper Tire & Rubber Co.
GEABPOLLC.
GMC Truck Group Arlington
Assembly Plant
Provimi North America Inc.
Belden
RR Donnelley & Sons
Circor Instrumentation
Technologies
Michelin NA Inc.
Goodyear Tire & Rubber Co.
Rex-Hide Industries Inc.
Hargis Industries LP
Cooper Tire Co.
Total
Zinc
Transfer
(LEY)
95
37.2
5
18
7.4
7.33
250
4
25
390
49
250
0.001
23
24
3.04
110
9
250
13.2
244
Point Source Category
Metal Finishing (Part 433)
Grain Mills (Part 406)
Plastics Molding and Forming (Part 463)
Metal Finishing (Part 433)
Rubber Manufacturing (Part 428)
Business Services (Part 73)
Inorganic Chemicals Manufacturing (Part 415)
Organic Chemicals, Plastics and Synthetic Fibers
(Part 414)
Miscellaneous Foods and Beverages (Part 503)
Rubber Manufacturing (Part 428)
Metal Finishing (Part 433)
Metal Finishing (Part 433)
Food & Kindred Products (Part 20)
Copper Forming (Part 468)
Printing & Publishing (Part 508)
Metal Finishing (Part 433)
Rubber Manufacturing (Part 428)
Rubber Manufacturing (Part 428)
Rubber Manufacturing (Part 428)
Metal Finishing (Part 433)
Rubber Manufacturing (Part 428)
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
a The 40 CFR Part 503 concentration ceiling for zinc is 7,500 mg/kg.
6-31
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-21. Zinc Sewage Sludge Concentrations from TNSSS POTWs With and Without
Reporting TRI Facilities (mg/kg)
Zinc Sewage Sludge Concentrations at
TNSSS POTWs
With TRI Facilities Reporting Zinc
Without TRI Facilities Reporting Zinc
Mean
1,210
1,010
Median
991
750
Minimum
308
216
Maximum
5,050
8,550
POTW
Count
14
60
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
6.1.3.6 Evaluation of Pollutants Without a TWF
To compare the human health and environmental hazard potential of different chemicals,
EPA uses TWFs and calculates a toxic-equivalent mass value. However, EPA has not developed
TWFs for all chemicals found in wastewater. The TNSSS included many chemicals without
TWFs, such as Pharmaceuticals, detergents, and natural and synthetic hormones. EPA is studying
the environmental contamination of pharmaceuticals, detergents, and natural and synthetic
hormones, collectively referred to contaminants of emerging concern (CECs).24 EPA began
studying the fate of these contaminants in POTWS because POTW treatment systems are not
designed to specifically remove CECs (U.S. EPA, 2009d).
The CECs OW included in the TNSSS were pharmaceutical chemicals, steroids and
hormones, and polybrominated diphenyl ethers (PBDEs) (see Table 6-27). Most CECs found in
the wastewater routed to POTWs are from domestic sources (U.S. EPA, 2009d), but they may
also come from industrial sources, such as discharges from organic chemical or pharmaceutical
manufacturing facilities.
EPA examined the POTWs in the TNSSS that receive wastewater from pharmaceutical
manufacturers or OCPSF facilities (as reported to TRI) to determine if any have detectable
concentrations of pharmaceuticals, steroids, or hormones in sewage sludge. EPA found that two
facilities in TRI discharge wastewater from pharmaceutical operations to two of the TNSSS
POTWs. However, as discussed below, the two pharmaceutical facilities do not report
transferring pharmaceutical chemicals to the POTWs, because pharmaceuticals are not EPCRA
§313 chemicals.
In the TNSSS, OW analyzed samples for 72 CECs including pharmaceutical chemicals,
steroids and hormones, and PBDEs (see Table 6-27), but none of the CECs are EPCRA §313
chemicals and therefore facilities are not required to report their discharges of these chemicals to
TRI. Because of the lack of useful information from TRI, EPA analyzed the results of the
TNSSS, in the general context of industrial wastewater discharges. EPA focused on three
contaminants to review in detail for this analysis: the disinfectant triclosan and hormones estriol
and estrone. Note, however, that past EPA studies have found that triclosan, estriol, and estrone
are present at highest concentrations in domestic wastewater, not industrial discharges (U.S.
EPA, 2009d).
24 For further information on EPA's review of CECs, see http://water.epa.gov/scitech/cec/. For further information
on pharmaceuticals and personal care products in water, see http://water.epa.gov/scitech/swguidance/ppcp/.
6-32
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Triclomn
Triclosan is a chlorinated aromatic compound, shown in Figure 6-7. It is manufactured in
the U.S. by several companies, including pharmaceutical companies. Triclosan's beneficial
antibacterial, antifungal, and antiviral properties make it a popular ingredient in hundreds of
common commercial products. These products include soaps, dishwashing products, laundry
detergents and softeners, plastics, toothpaste and mouthwashes, deodorants, cosmetics, bedding,
trash bags, and surgical scrubs. Triclosan is also a registered pesticide. The primary transfer of
triclosan to domestic wastewater is from household use of triclosan-containing commercial
products (APUA, 2011; U.S. EPA, 2010). Up to 95 percent of triclosan is removed at POTWs
that employ mechanical clarification, biological treatment or nitrification, flocculation, and
filtration. The majority of triclosan is removed via biological degradation while less than 15
percent is adsorbed to the sewage sludge (APUA, 2011).
OH
Source: APUA, 2011.
Figure 6-7. Triclosan (2,4,4'-Trichloro-2'-Hydroxy-Diphenyl Ether)
The TNSSS POTWs with the highest concentrations of triclosan in their sewage sludge
are listed in Table 6-22. Table 6-23 presents statistical data for all TNSSS POTWs sampled for
triclosan. The one TNSSS POTW included in TRI did not receive discharges from facilities
identified in TRI as pharmaceutical manufacturers or other companies that likely manufacture
triclosan.
Table 6-22. Top TNSSS POTWs Sampled for Triclosan
POTW Name
O J Riedel WWTP, Schertz, TX
Verona STP, Verona, NJ
Buena Vista STP, Buena Vista,
VA
Stockton WWTF, Stockton, CA
Concentration
(Mg/kg)
133,000
37,500
34,000
33,300
Point Source Categories in TRI Discharging to POTW
POTW not found in TRI
POTW not found in TRI
POTW not found in TRI
406 - Grain Mills; 423 - Steam Electric Generating
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009_v2.mdb.
Table 6-23. Data for All TNSSS POTWs Sampled for Triclosan
Statistical Measurement
Range of concentration
Median concentration
Triclosan Sewage Sludge Concentration (jig/kg)
334-133,000
8,245
Sources: U.S. EPA, 2009a, 2009b.
6-33
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Estriol andEstrone
Estriol and estrone are steroidal estrogen hormones with chemical structures shown in
Figure 6-8. The naturally occurring female hormones estradiol, estriol, and estrone are all types
of estrogen. Estrogen compounds are essential for the growth and function of tissues in humans
(NTP, 2011; U.S. EPA, 2013).
"ill OH
Estriol
Estrone
Source: U.S. EPA, 2013.
Figure 6-8. Estriol and Estrone Chemical Structures
Both natural and synthetic estriol and estrone are found in urine from men and non-
pregnant women. In addition, estriol is found in elevated concentrations in the urine from
pregnant women and estrone is used in combination with a progestogen for hormone-
replacement therapy, in oral contraceptives, and in veterinary pharmaceuticals, all of which lead
to discharges in domestic wastewater. Some cosmetic products also include traces of estrone.
Consequently, although estriol and estrone are manufactured in the U.S., the primary transfer of
estriol and estrone to wastewater streams is through household domestic use and sanitary
wastewater, rather than industrial discharges (NTP, 2011).
EPA identified the three TNSSS POTWs with the highest concentrations of estriol and
estrone in their sewage sludge. As shown in Table 6-24, two of the TNSSS POTWs received
transfers of estriol and estrone reported in TRI, but neither receive wastewater from
pharmaceutical manufactures or other companies that likely manufacture estriol or estrone. Table
6-25 presents statistical data for all TNSSS POTWs sampled for estriol and estrone. Both tables
further support studies documenting that estriol and estrone discharges result from domestic
rather than industrial sources (U.S. EPA, 2009d).
6-34
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-24. Top Estriol and Estrone Sewage Sludge Concentrations from TNSSS POTWs
POTW Name
Concentration
(US/kg)
Point Source Categories
in TRI Discharging to POTW
Estriol Concentrations
Benton Harbor-St. Joseph, St.
Joseph, MI
Wixom STP, Wixom, MI
Verona STP, Verona, NJ
232
189
157
413 -Electroplating; 433 -
413 -Electroplating; 433 -
- Metal Finishing
- Metal Finishing
POTW not found in TRI
Estrone Concentrations
Benton Harbor-St. Joseph, St.
Joseph, MI
Bloomington STP North,
Bloomington, IN
965
768
413 -Electroplating; 433 -
- Metal Finishing
433 - Metal Finishing
Sources: U.S. EPA, 2009a, 2009b; TRIReleases2009 v2.mdb.
Table 6-25. Data for All TNSSS POTWs Sampled for Estriol and Estrone
Statistical Measurement
Estriol/Estrone
Sewage Sludge Concentration (jig/kg)
POTWs Sampled for Estriol
Range of concentration
Median concentration
6.49-232
24.95
POTWs Sampled for Estrone
Range of concentration
Median concentration
19.7-965
60.5
Sources: U.S. EPA, 2009a, 2009b.
6.1.4 Additional Analyses Completed
In addition to the sewage sludge analyses discussed above, EPA identified the watersheds
receiving treated effluent from the TNSSS POTWs and their impairment status. EPA used data
available in EPA's Watershed Assessment, Tracking & Environmental Results (WATERS)
database to identify the TNSSS POTWs' receiving watersheds and their identified water quality
impairments. EPA investigated relationships between industries discharging to TNSSS POTWs
and impairments in receiving waterways.
Table 6-26 presents the receiving watersheds, impairment status, and point source
categories covered by the TRI facilities discharging to each POTW for the 25 TNSSS POTWs
with data available in the WATERS database. EPA only included point source categories
composed primarily of indirect dischargers because these categories are most likely to have
widespread impacts on POTW sewage sludge. As shown, about half of the waterways are not
impaired. Of the waterways that are listed as impaired, the majority are impaired by sediments
and fecal coliform. These pollutants are often associated with non-point source discharges and
are not likely to originate from industrial wastewater that passes through the POTW. Waterways
receiving wastewater from two POTWs, Buffalo Bird Island STP in Buffalo, New York, and
Alcosan STP in Pittsburgh, Pennsylvania, are impaired for pollutants that could be linked to the
point source categories in TRI discharging to the POTWs. This is a tentative association; EPA
found no clear relationship between industries discharging to TNSSS POTWs and impairments
in receiving waterways.
6-35
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-26. Receiving Watershed Data for TNSSS POTWs
POTW Name3
Salisbury WWTF
Buffalo (Sewer Auth.) Bird
Island STP
North Tonawanda WWTP
Little Miami Drainage
Basin/WWTP
Southeast WPCP
Wixom STP
Geneva Marsh Creek WWTP
Elizabeth City WWTP
Buena Vista STP
Elizabethton WWTP
Elkins WWTF
SSSD/Lawson Fork Plant0
Hillsborough WWTP
Alcosan STP (Allegheny
County)
City
Salisbury
Buffalo
North
Tonawanda
Cincinnati
San Francisco
Wixom
Geneva
Elizabeth City
Buena Vista
Elizabethton
Elkins
Spartanburg
Hillsborough
Pittsburgh
State
MD
NY
NY
OH
CA
MI
NY
NC
VA
TN
WV
sc
NC
PA
Receiving Watershed
Name
Tonytank Creek- Wicomico
River
Twomile Creek-Niagara
River
City of North Tonawanda-
Niagara River
Duck Creek
San Francisco Bay Estuaries
Newburgh Lake-Middle
River Rouge
Castle Creek-Seneca Lake
Elizabeth City-Pasquotank
River
Bennetts Run-Maury River
Gap Creek- Watauga river
Files Creek
Lawson Fork Creek
Stony Creek-Eno River
Kilbuck Run-Ohio River
Impairment Status
Impaired by fecal coliform
Impaired by PCBs, phosphorus,
PAHs, floatables, pathogens,
sediment/siltation, organochlorine
pesticides, oxygen demand
Impaired by PAHs, organochlorine
pesticides, PCBs
Impaired by siltation, habitat
alteration, unknown toxicity, flow
alteration, organic enrichment/low
dissolved oxygen
Impaired by ammonia, dieldrin
(sediment), contaminated sediments
(PAHs), chlordane (sediment),
hydrogen sulfide, sediment toxicity
Impaired by dissolved oxygen,
PCBs, PCBs in fish tissue
Not impaired
Not impaired
Not impaired
Not impaired
Not impaired
Not impaired
Not impaired
Impaired by Suspended Solids, pH,
Metals (other than mercury)
Point Source Categories in TRI
Discharging to POTWb
432 - Meat and Poultry Products;
463 - Plastics Molding and Forming
405 - Dairy Products Processing;
415 - Inorganic Chemicals
Manufacturing; 433 -Metal
Finishing; 436 - Mineral Mining and
Processing; 463 - Plastics Molding
and Forming; 471 - Nonferrous
Metals Forming and Metal Powders
POTW not found in TRI
413 -Electroplating; 433 -Metal
Finishing
433 - Metal Finishing
413 -Electroplating; 433 -Metal
Finishing
426 - Glass Manufacturing
POTW not found in TRI
POTW not found in TRI
433 - Metal Finishing
POTW not found in TRI
414 - Organic Chemicals, Plastics
And Synthetic Fibers; 417 - Soap
And Detergent Manufacturing; 428 -
Rubber Manufacturing; 433 -Metal
Finishing
POTW not found in TRI
426 - Glass Manufacturing; 433 -
Metal Finishing
6-36
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-26. Receiving Watershed Data for TNSSS POTWs
POTW Name3
Bedford WWTP & Sewer
System
Alum Creek WWTP &
Sewers
Mingo Junction WWTP &
Sewer System
Punxsutawney Boro STP
Brush Creek STP
Northeast Ohio Regional
Sewer District, Southerly
WWTP
Dale Mabry AWWTP
Bloomington STP North
Richmond SD
Huntington City Of
Middle East Fork WWTP &
Sewers
City
Bedford
Columbus
Mingo
Junction
Punxsutawney
Irwin
Cleveland
Tampa
Bloomington
Richmond
Huntington
Batavia
State
OH
OH
OH
PA
PA
OH
FL
IN
IN
WV
OH
Receiving Watershed
Name
Brandywine Creek
Kebler Run
Wills Creek-Ohio River
Perryville Run-Mahoning
Creek
Brush Creek
City of Cleveland-Cuyahoga
River
Double Bayou-Rocky Creek
Frontal
Buck Creek-Beanblossom
Creek
Rocky Fork-East Fork
Whitewater River
Smith Creek-Guyandotte
River
Fivemile Creek-East Fork
Little Miami River
Impairment Status
Impaired by PCBs in fish tissue
Not impaired
Impaired by iron, bacteria, 2,3,7,8-
tetrachlorodibenzo-p-dioxin; PCBs,
PCBs in fish tissue
Not impaired
Not impaired
Impaired by PCBs in fish tissue
Impaired by turbidity, nutrients,
fecal coliform, total conform,
dissolved oxygen, total suspended
solids, coliforms
Not impaired
Not impaired
Not impaired
Impaired by nutrients, organic
enrichment/low DO, siltation
Point Source Categories in TRI
Discharging to POTWb
433 - Metal Finishing
POTW not found in TRI
POTW not found in TRI
POTW not found in TRI
POTW not found in TRI
413 -Electroplating; 433 -Metal
Finishing; 464 - Metal Molding and
Casting (Foundries); 467 -
Aluminum Forming; 468 - Copper
Forming; 471 - Nonferrous Metals
Forming and Metal Powders
POTW not found in TRI
433 - Metal Finishing
405 - Dairy Products Processing;
433 - Metal Finishing; 468 - Copper
Forming
POTW not found in TRI
POTW not found in TRI
Sources: DMR Loading Tool; Envirofacts; U.S. EPA, 2009a, 2009b.
a EPA is updating the WATERS database, so the analysis relied on an incomplete dataset: only 25 of 74 POTWs had data available.
b Excluding point source categories with less than 30 percent indirect discharges in the TRI database.
0 The SSSD/Lawson Fork Plant is not found in the DMR databases. According to Envirofacts, the facility is inactive. Receiving waters information was pulled
from Envirofacts.
6-37
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
6.1.5 Summary of Findings from EPA's Review of Industrial Wastewater Pollutants in
Sewage Sludge
EPA used TNSSS data in combination with data from TRI to identify industrial
wastewater discharges potentially affecting the quality of POTW sewage sludge and its
beneficial use. Because the TNSSS did not identify industrial discharges to POTWs, EPA used
TRI reports of transfers of toxic chemicals to identify possible industrial dischargers to the
POTWs included in the TNSSS. EPA identified the following:
• Of the 74 POTWs in the TNSSS, 35 POTWs receive wastewater from at least one
industrial facility reporting to TRI, representing 47 percent of the POTWs in the
TNSSS. The remaining 39 TNSSS POTWs likely also receive industrial
wastewater, but the specific facilities discharging to the POTWs are not required
to report to TRI.
• In TRI, 153 facilities reported transferring toxic chemicals to 35 of 74 POTWs
that were included in the TNSSS. Because of the TRI reporting thresholds, it is
likely that additional industrial facilities discharged to these POTWs, but are not
required to report to TRI.
• The 153 facilities that reported transferring toxic chemicals to TNSSS POTWs
have wastewater discharges covered by ELGs for 28 different point source
categories.25 Of the reported TRI transfers to the TNSSS POTWs, the Metal
Finishing point source category (40 CFR Part 433) had the highest number of
facilities reporting discharges to TNSSS POTWs (52 out of 153).
• Only 21 pollutants are included in both the TNSSS and TRI. When the TNSSS
pollutant transfers reported in TRI are ranked by TWPE before POTW removals,
nitrate compounds is the top pollutant. TNSSS measured nitrite/nitrate in every
sewage sludge sample.
• Of the 21 pollutants in both the TNSSS and TRI, 17 are metals. Because the
metals will not easily biodegrade, they are expected to accumulate in sewage
sludge. TNSSS found the metals in virtually every sewage sludge sample.
Of the point source categories in TRI, Metal Finishing (40 CFR Part 433)
contributes the greatest amount of TWPE potentially transferred to sewage sludge
(to all POTWs with TRI reported data, not just the POTWs included in the
TNSSS).
• Chromium, nickel, and zinc concentrations in some of the TNSSS samples
exceeded 40 CFR Part 503 land application ceilings/surface disposal limits.
Nickel concentrations exceeded the ceiling/limit in three of 84 sewage sludge
samples; chromium and zinc concentrations exceeded the ceiling/limit in one of
84 samples.
As Table 6-13, Table 6-17, and Table 6-21 show, EPA found that POTWs for
which industrial wastewater transfers were reported in TRI have higher mean and
25 EPA only included point source categories composed primarily of indirect dischargers because these categories
are most likely to have widespread impacts on POTW sludge.
6-38
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
median chromium, nickel, and zinc concentrations than those without TRI-
reported discharges. This suggests that industrial discharges of chromium, nickel,
and zinc in general may be related to higher concentrations of these metals in
sewage sludge.
• As part of the TNSSS analysis, OW found that of the POTWs observed exceeding
the land application ceilings, one incinerated its treated sewage sludge on site,
while the others sent their sewage sludge to landfills. Thus, results from the
TNSSS indicated that POTWs were generally complying with the existing land
application standards for metals.
• In reviewing CECs discharges, EPA could not identify industrial facilities
discharging triclosan, estriol, and estrone. Because of the source and use of these
chemicals, triclosan, estriol, and estrone present in sewage sludge most likely
result from domestic wastewater discharges, not industrial discharges.
6.1.6 References for Industrial Wastewater Pollutants in Sewage Sludge
1. APUA. 2011. Alliance for the Prudent Use of Antibiotics. Triclosan. White paper.
(January). EPA-HQ-OW-2010-0824. DCN 07844.
2. Bicknell, Betsy, and TJ. Finseth. 2006. Memorandum to Carey Johnston and Jan
Matuszko, U.S. EPA, from Betsy Bicknell and T.J. Finseth, Eastern Research Group,
Inc., Re: Comments Received Regarding POTW Removals. (September 8). EPA-HQ-
OW-2004-0032-2399.
3. NTP. 2011. U.S. Department of Health and Human Services, Public Health Service,
National Toxicology Program. Report on Carcinogens. Twelfth edition. EPA-HQ-OW-
2010-0824. DCN 07845.
4. Stevens, Richard. 2013. Email Communication Between Rick Stevens, U.S. EPA Office
of Science and Technology, and Kimberly Bartell, Eastern Research Group, Inc., Re:
Follow up on TNSSS. (June 13). EPA-HQ-OW-2010-0824. DCN 07730.
5. U.S. Census. 2007. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census07.
6. U.S. EPA.1991. NationalPretreatmentProgram Report to Congress. Available online
at: http://www.epa.gov/npdes/pubs/owm0244.pdf EPA-HQ-OW-2010-0824. DCN
07846.
7. U.S. EPA. 2009a. Targeted National Sewage Sludge Survey: Overview Report.
Washington, D.C. (January). EPA-822-R-08-014. EPA-HQ-OW-2008-0517-0139.
8. U.S. EPA. 2009b. Targeted National Sewage Sludge Survey: Sampling and Analysis
Technical Report. Washington, D.C. (January). EPA-822-R-08-016. EPA-HQ-OW-2008-
0517-0141.
6-39
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
9. U.S. EPA. 2009c. Technical Support Document for the Annual Review of Existing
Effluent Guidelines and Identification of Potential New Point Source Categories.
Washington, D.C. (October). EPA 821-R-09-007. EPA-HQ-OW-2008-0517-0515.
10. U.S. EPA. 2009d. Occurrence of Contaminants of Emerging Concern in Wastewater
from Nine Publicly Owned Treatment Works. Washington, D.C. (August). EPA-HQ-OW-
2010-0824. DCN 07843.
11. U. S. EPA. 2010. Triclosan Facts. U. S. EPA Office of Pesticide Programs. (March).
Available online at: http://www.epa.gov/oppsrrdl/REDs/factsheets/triclosan_fs.htm.
EPA-HQ-OW-2010-0824. DCN 07847.
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. 2013. U.S. EPA Aggregated Computational Toxicology Resource (ACToR).
Available online at: http://actor.epa.gov/actor/faces/ACToRHome.jsp. EPA-HQ-OW-
2010-0824. DCN 07848.
6-40
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-27. Analytes Sampled in the TNSSSa
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenumb
Nickel
Phosphorus0
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Cobalt
Organics
2-Methylnaphthalene
4-Chloroaniline
Benzo (a)pyrened
Bis(2-ethylhexyl)phthalatee
Fluoranthened
Pyrene
Inorganic Anions
Fluoride
Water-extractable phosphorus
Nitrate/nitrite/
PBDEs
BDE-28
BDE-47
BDE-66
BDE-85
BDE-99
BDE-100
BDE-138
BDE-153
BDE-154
BDE-183
BDE-209
Steroids and Hormones
17 alpha-dihydroequilin
17 alpha-estradiol
17 alpha-ethinyl-estradiol
17 beta-estradiol
Androstenedione
Andrasterone
Beta stigmastanol
Beta-estradiol 3-benzoate
Campesterol
Cholestanol
Cholesterol
Coprostanol
Desmosterol
Epicoprostanol
Equilenin
Equilin
Ergosterol
Estriol
Estrone
Norethindrone
Norgestrel
Progesterone
Stigmasterol
Testosterone
Beta-sitosterol
Pharmaceutical Chemicals
1 ,7-dimethylxanthine
4-epianhydrochlortetracycline
(EACTC)
4-epianhydrotetracycline (EATC)
4-epichlortetracycline (ECTC)
4-epioxytetracycline (EOTC)
4-epitetracycline (ETC)
Acetaminophen
Albuterol
Anhydrochlortetracycline (ACTC)
Anhydrotetracycline (ATC)
Azithromycin
Caffeine
Carbadox
Carbamazepine
Cefotaxime
Chlortetracycline (CTC)
Cimetidine
Ciprofloxacin
Demeclocycline
Digoxigenin
Digoxin
Diltiazem
Diphenhydramine
Doxycycline
Enrofloxacin
Erythromycin-total
Flumequine
Fluoxetine
Gemfibrozil
Ibuprofen
Isochlortetracycline (ICTC)
Lincomycin
Lomefloxacin
Metformin
Miconazole
Minocycline
Oxolinic acid
Oxytetracycline (OTC)
Penicillin G
Penicillin V
Ranitidine
Roxithromycin
Sarafloxacin
Sulfachloropyridazine
Sulfadiazine
Sulfadimethoxine
Sulfamerazine
Sulfamethazine
Sulfamethizole
Sulfamethoxazole
Sulfanilamide
Sulfathiazole
Tetracycline (TC)
Thiabendazole
6-41
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-27. Analytes Sampled in the TNSSSa
Clarithromycin
Clinafloxacin
Cloxacillin
Codeine
Cotinine
Dehydronifedipine
Naproxen
Norfloxacin
Norgestimate
Ofloxacin
Ormetoprim
Oxacillin
Triclocarban8
Triclosan8
Trimethoprim
Tylosin
Virginiamycin
Warfarin
Sources: U.S. EPA, 2009a, 2009b.
a Italics indicate pollutants reported as discharged in the 2009 TRI Database.
b TRI includes only molybdenum trioxide, not any other molybdenum compounds; EPA included the TRI pollutant
molybdenum trioxide in the analysis to represent the TNSSS molybdenum.
0 TRI only lists discharges from phosphorus (yellow or white), and facilities have incorrectly reported discharges of
total phosphorus as phosphorus (yellow or white); therefore, TRI phosphorus discharges to POTWs or surface
water do not necessarily represent industrial discharges (Bicknell and Finseth, 2006). EPA did not include
phosphorus in the analysis.
d Benzo(a)pyrene and fluoranthene are polycyclic aromatic compounds (PACs), and TRI requires facilities to
report total PACs, not individual chemicals; EPA included the TRI pollutant PACs in the analysis to represent the
TNSSS benzo(a)pyrene and fluoranthene.
e Bis(2-ethylhexyl) phthalate in TNSSS is called di(2-ethylhexyl) phthalate in TRI; EPA included the TRI pollutant
di(2-ethylhexyl)phthalate in the analysis to represent the TNSSS bis(2-ethylhexyl) phthalate.
f TRI includes the toxic chemical group nitrate compounds." Because "nitrate compounds" is the TRI chemical
group that is closest to the TNSSS analyte, "nitrate/nitrite," EPA used "nitrate compounds" in the analysis to
represent the TNSSS analyte "nitrate/nitrite." Nitrate/nitrite compounds in sewage sludge are of concern because
they are nutrients.
g Triclocarban and triclosan are disinfectants, not pharmaceutical chemicals. However, in the TNSSS disinfectants
are grouped under pharmaceutical chemicals because they are detected with the same analytical method.
6-42
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs
Pollutant
Group
Inorganic
Anions
Metals
Organics
Pollutant3
Fluoride
Nitrate/nitrite
Water-extractable phosphorus
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus'
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
2-Methylnaphthalene
Benzo(a)pyrene
CAS Number3
16984488
COOS (14797558/
14797650)
C055 (7723 140)
7429905
7440360
7440382
7440393
7440417
7440428
7440439
7440702
7440473
7440484
7440508
7439896
7439921
7439954
7439965
7439976
7439987
7440020
7723140
7782492
7440224
7440235
7440280
7440315
7440326
7440622
7440655
7440666
91576
50328
TWFb
NA
7.47E-04
NA
0.06
0.01
4.04
1.99E-03
1.05
8.34E-03
23.1
NA
0.07
0.11
0.63
5.60E-03
2.24
8.66E-04
0.07
117
0.2
0.1
NA
1.12
16.5
5.49E-06
1.02
0.3
0.02
0.03
NA
0.04
NA
101
CWA Priority
Pollutant0
No
No
No
No
Yes
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
No
Yes
No
Yes
No
Yes
Yes
No
Yes
No
No
No
No
Yes
No
Yes
Regulated under
40 CFR 503d
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
CAPS'
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
TRI-Listed
Chemicalb
No
Yes
No
No
Yes
Yes
Yes
No
No
Yes
No
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
No
No
Yes
No
Yes
No
Yes
6-43
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs
Pollutant
Group
PBDEs
Pharmaceutic
al chemicals
Pollutant3
Fluoranthene
Pyrene
4-chloroaniline
Bis(2-ethylhexyl)phthalate
BDE-138
BDE-153
BDE-154
BDE-183
BDE-209
BDE-28
BDE-47
BDE-66
BDE-85
BDE-99
BDE-100
4-epi-anhydrochlortetracycline
(EACTC)
4-epi-anhydrotetracycline
(EATC)
4-epi-chlortetracycline (ECTC)
4-epi-oxytetracycline (EOTC)
4-epi-tetracycline (ETC)
Anhydrochlortetracycline
(ACTC)
Anhydrotetracycline (ATC)
Azithromycin
Carbadox
Cefotaxime
Chlortetracycline (CTC)
Ciprofloxacin
Clarithromycin
Clinafloxacin
Cloxacillin
Demeclocycline
CAS Number3
206440
129000
106478
117817
182677301
68631492
207122154
207122165
1163195
41318756
5436431
189084615
182346210
60348609
189084648
158018532
4465650
14297939
14206587
23313806
4497089
4496859
83905015
6804075
63527526
57625
85721331
81103119
105956976
61723
127333
TWFb
1.28
0.09
0.02
0.25
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CWA Priority
Pollutant0
Yes
Yes
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Regulated under
40 CFR 503d
No
No
CAPS'
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
TRI-Listed
Chemicalb
Yes
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
6-44
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Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs
Pollutant
Group
Pollutant3
Doxycycline
Enrofloxacin
Erythromycin — total
Flumequine
Isochlortetracycline (ICTC)
Lincomycin
Lomefloxacin
Minocycline
Norfloxacin
Ofloxacin
Ormetoprim
Oxacillin
Oxolinic acid
Oxytetracycline (OTC)
Penicillin G
Penicillin V
Roxithromycin
Sarafloxacin
Sulfachloropyridazine
Sulfadiazine
Sulfadimethoxine
Sulfamerazine
Sulfamethazine
Sulfamethizole
Sulfamethoxazole
Sulfanilamide
Sulfathiazole
Tetracycline (TC)
Triclocarban
Triclosan
Trimethoprim
Tylosin
Virginiamycin
1 ,7-dimethylxanthine
CAS Number3
564250
93106606
114078
42835256
514534
154212
98079517
10118908
70458967
82419361
6981186
66795
14698294
79572
61336
87081
80214831
98105998
80320
68359
122112
127797
57681
144821
723466
63741
72140
60548
101202
3380345
738705
1401690
11006761
611596
TWFb
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CWA Priority
Pollutant0
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Regulated under
40 CFR 503d
No
CAPS'
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
TRI-Listed
Chemicalb
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
6-45
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs
Pollutant
Group
Steroids and
Hormones
Pollutant3
Acetaminophen
Albuterol
Caffeine
Carbamazepine
Cimetidine
Codeine
Cotinine
Dehydronifedipine
Digoxigenin
Digoxin
Diltiazem
Diphenhydramine
Fluoxetine
Gemfibrozil
Ibuprofen
Metformin
Miconazole
Naproxen
Norgestimate
Ranitidine
Thiabendazole
Warfarin
17 alpha-dihydroequilin
17 alpha-estradiol
17 alpha-ethinyl estradiol
17 beta-estradiol
Androstenedione
Androsterone
Beta-estradiol-3 -benzoate
Equilenin
Equilin
Estriol
Estrone
Norethindrone
CAS Number3
103902
18559949
58082
298464
51481619
76573
486566
67035227
1672464
20830755
42399417
58731
54910893
25812300
15687271
657249
22916478
22204531
35189287
66357355
148798
81812
651558
57910
57636
50282
63058
53418
50500
517099
474862
50271
53167
68224
TWFb
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
7.99E-03
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CWA Priority
Pollutant0
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Regulated under
40 CFR 503d
No
CAPS'
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
TRI-Listed
Chemicalb
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
6-46
-------
Section 6—New Data Sources and Hazard Analyses
6.1—Identification of Industrial Wastewater Pollutants in Sewage Sludge
Table 6-28. Analytes Analyzed in the TNSSS: Applicability of Relevant EPA Programs
Pollutant
Group
Pollutant3
Norgestrel
Progesterone
Testosterone
Beta-sitosterol
Beta-stigmastanol
Campesterol
Cholestanol
Cholesterol
Coprostanol
Desmosterol
Epi-coprostanol
Ergosterol
Stigmasterol
CAS Number3
6533002
57830
58220
83465
19466478
474624
80977
57885
360689
313042
516927
57874
83487
TWFb
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CWA Priority
Pollutant0
No
No
No
No
No
No
No
No
No
No
No
No
No
Regulated under
40 CFR 503d
No
CAPS'
No
No
No
No
No
No
No
No
No
No
No
No
No
TRI-Listed
Chemicalb
No
No
No
No
No
No
No
No
No
No
No
No
No
NA: Not applicable.
No: Information was not available for the pollutant.
a U.S. EPA, 2009b.
b DMR Loading Tool.
c 40 CFR 423, Appendix A.
d 40 CFR 503.
e U.S. EPA Chemical Action Plans.
f Phosphorus (yellow or white) is a TRI-listed chemical. Yellow and white phosphorus, both allotropes of elemental phosphorus, are hazardous chemicals that
spontaneously ignite in air. EPA determined that facilities were incorrectly reporting discharges of total phosphorus (i.e., the phosphorus portion of
phosphorus-containing compounds) as phosphorus (yellow or white). Elemental phosphorus is insoluble in water and POTWs do not accept wastewater
containing it because of the hazard associated with the chemical (Bicknell and Finseth, 2006). The phosphorus measured in the TNSSS was total phosphorus
and is not applicable to TRI.
6-47
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
6.2 Review of Chemical Action Plans
As part of EPA's chemicals management program under the Toxic Substances Control
Act (TSCA), the Office of Chemical Safety and Pollution Prevention's (OCSPP) Office of
Pollution Prevention and Toxic Substances (OPPT) had developed chemical action plans (CAPs)
for commercial chemicals that it determined posed a concern to the public. Between 2009 and
2011, OPPT published CAPs for 10 chemicals or classes of chemicals. The CAPs summarize
each chemical's available hazard, exposure, and use information; outline the risks that each
chemical may present; and identify the specific steps OPPT is taking to address those risks.
In February 2012, OPPT modified its approach for evaluating existing chemicals under
TSCA and began the Work Plan Chemicals initiative. For this effort, OPPT identified a work
plan of 83 chemicals for further assessment. OPPT initially identified seven chemicals from the
plan for detailed risk assessment in 2012 and continues to identify new chemical for risk
assessment each year. OPPT intends to use the TSCA Work Plan Chemicals list to help focus
and direct the activities of the Existing Chemicals Program over the next several years.
For its 2012 Annual Review, EPA's Office of Water (OW) reviewed the 10 existing
CAPs as a source of data to augment its traditional toxicity rankings analysis (TRA) conducted
in the odd-year reviews. OW reviewed the CAPs to determine which industries may produce,
process, or release the chemicals to the environment, particularly through wastewater discharges
directly to surface water or indirectly to publicly owned treatment works (POTWs). This section
summarizes information contained in the CAPs related to chemical manufacturing and use and
potential wastewater discharges. Where possible, OW used information from the CAPs, along
with data from other sources (such as discharge monitoring reports (DMR) and/or the Toxics
Release Inventory (TRI)), to identify any unregulated industrial wastewater discharges or new
pollutant discharges from regulated industries that are not addressed or adequately controlled by
existing ELGs. OW used information in the CAPs to identify chemicals for potential further
review.
From this initial CAP review, OW found the following:
• Of the 10 chemicals for which OPPT developed CAPs, one category is being
phased out of U.S. commerce; OW does not intend to pursue further review for
Penta, Octa, and Decabromodiphenyl Ethers (PBDEs).
• Six of the chemicals or classes of chemicals for which OPPT developed CAPs
have continued production and known or potential wastewater discharges:
Benzidine dyes, Bisphenol A (BPA), Hexabromocyclododecane (HBCD),
Nonylphenol and Nonylphenol Ethoxylates, Perfluorinated Chemicals (PFCs),
and Phthalates.
• Although SCCPs are no longer manufactured in the U.S., they have been used in
metal working and have the potential to be discharged in wastewater from this
industry.
• Two of the chemicals, Methylene Diphenyl Diisocyanate (MDI) and Toluene
Diisocyanate (TDI) do not have significant wastewater discharges. However, OW
identified that the hydrolysis byproducts of TDI and MDI, toluene diamine and
methyl diphenyl diamine, may be present in industrial wastewater.
6^48
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
6.2.1 OPPT Chemical Action Plans Background
OPPT's existing chemicals program addresses pollution prevention, risk assessment,
hazard and exposure assessment and characterization, and risk management for chemical
substances in commercial use, as authorized by TSCA. The TSCA Inventory of chemicals in
commerce now exceeds 84,000 chemicals. Periodic TSCA chemical data reporting indicates that
there are approximately 7,000 chemicals currently produced at volumes of 25,000 pounds or
greater. For chemicals with well-characterized hazard concerns and the possibility of significant
exposure, OPPT performs risk assessments and may evaluate risk mitigation strategies. The
existing chemicals program focuses assessments on consumer exposure from product use, but
may include some data on wastewater pollutant generation from chemical manufacturing, where
it is available or relevant (U.S. EPA, 2012a).
In 2009, OPPT began to identify chemicals that pose a concern to the public and initiated
appropriate actions to alleviate those concerns. OPPT selected 10 commercial chemicals for
initial action plan development based on whether they were:
• Identified as persistent, bioaccumulative, and toxic.
• High production volume chemicals.
• Found in consumer products.
• Potentially of concern for their impact on children's health due to reproductive or
developmental effects.
• Subject to review and potential action in international forums.
• Found in human bio-monitoring programs.
• Part of a category generally identified as being of potential concern in the new
chemicals program.
From 2009 through 2011, OPPT developed CAPs for the following 10 commercial
chemicals or classes of chemicals:
1. Benzidine dyes (August 2010);
2. Bisphenol A (March 2010);
3. Hexabromocyclododecane (August 2010);
4. Methylene diphenyl diisocyanate (April 2011);
5. Nonylphenol and nonylphenol ethoxylates (August 2010);
6. Perfluorinated chemicals (December 2009);
7. Penta-, octa-, and decabromodiphenyl ethers (December 2009);
8. Phthalates (March 2012);
9. Short-chain chlorinated paraffins (December 2009); and
10. Toluene diisocyanate (April 2011).26
26 Toluene diisocyanate is similar to methylene diphenyl diisocyanate; therefore, OW discusses both chemicals
together in Section 6.2.2.4.
6^49
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
OPPT also identified actions it intends to take to address the outlined concerns. Table
6-29 describes some of the specific actions OPPT may take.
Table 6-29. Potential Actions Identified in CAPs
Action
Add chemical to the
Toxics Release Inventory
(TRI)
Develop additional data
(Section 4 test rules)
Develop or revise
Significant New Use Rule
(SNUR) for specific new
uses of the chemical
Prohibit or limit the
chemical's manufacture,
processing, or distribution
into commerce
Issue a data call-in
Require reporting of
relevant data
Conduct Design for the
Environment (DfE)
alternatives assessment
Other voluntary initiatives
Authorization
Section 3 13 of the
Emergency Planning
and Community
Right-to-Know Act
(EPCRA)
Section 4(a) of
TSCA
Section 5 (a) of
TSCA
Section 6 of TSCA
Section 8(c) of
TSCA
Section 8(d) of
TSCA
None, EPA
Partnership Program
None
Description
Section 313 of EPCRA requires U.S. facilities to report
annually how much of specific listed chemicals they release
into the environment through emissions to air, water, or land
disposal. This information is stored in the TRI database and is
available to the public.
Section 4(a) of TSCA allows EPA to require the development
of data to determine whether a specific chemical presents an
unreasonable risk of injury to the environment. This may
include hazard data and exposure monitoring.
A SNUR requires manufacturers who intend to use a chemical
for the identified significant new use to submit an application
to the Agency for review prior to beginning that activity. This
process gives OPPT a chance to regulate the manufacture,
import, or processing of that chemical substance.
If EPA finds that there is a reasonable basis to conclude that a
chemical's manufacture, processing, distribution, use, or
disposal presents an unreasonable risk, EPA may take action to:
• Prohibit or limit manufacture, processing, or distribution in
commerce.
• Prohibit or limit the manufacture, processing, or distribution
in commerce of the chemical substance above a specified
concentration.
• Require adequate warnings and instructions with respect to
use, distribution, or disposal.
• Require manufacturers or processors to make and retain
records.
• Prohibit or regulate any manner of commercial use.
• Prohibit or regulate any manner of disposal.
• Require manufacturers or processors to give notice of
unreasonable risk of injury, and to recall products if
required.
EPA can require companies to record, retain, and report
allegations of significant adverse reactions to any
substance/mixture that they produce, import, process, or
distribute.
EPA can initiate rulemaking for one-time reporting of relevant
unpublished health and safety studies.
Through DfE, EPA may assess alternatives to specific
chemicals that it can encourage industry to use, and to move
away from using certain chemicals, instead of, or in addition to
any regulatory action taken under TSCA.
EPA may work with industry to develop voluntary agreements
to phase out the use of certain chemicals.
Depending upon the action initiated, OPPT may generate or have access to data that can
characterize industrial wastewater sources, determine the presence of the chemical in industrial
wastewater, and potentially quantify the amount of chemical discharged. For instance, if a
chemical is added to TRI, the quantity of chemical released directly to surface waters or
indirectly to POTWs must be reported. In addition, if OPPT takes action to ban certain
6^50
-------
Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
chemicals, the chemicals likely will not be of concern in the future. In its review of the CAPs in
the following sections, OW outlines OPPT's current or planned actions for each chemical.
6.2.2 OPPT Chemicals Reviewed
OW reviewed the 10 CAPs available on OPPT's website to identify industrial categories
currently manufacturing and using the chemicals. OW also reviewed information in the CAPs on
whether the chemicals, or any of their degradation products, enter the wastewater and are
discharged to surface waters or POTWs.
The following subsections provide a brief overview of OPPT's CAPs, including:
• Chemical production and use data.
• Potential presence and, if available, quantity of the chemicals in industrial
wastewater discharge.
• Toxicity and exposure routes.
• Actions that OPPT is initiating that may generate additional industrial wastewater
discharge data in the future.
In each section, OW also identifies, based on the chemical production and use data
described in the CAP, which industries may produce or process the chemical and thus may be
potential sources of release into the environment.
In addition, OW includes a discussion of toxic weighting factors (TWFs), if available, in
the "toxicity and exposure routes" discussion for each chemical. OW has calculated TWFs for
1,064 chemicals based on the concentrations in water at which they become harmful to aquatic
life, and the levels in fish tissue at which they become harmful to humans. OW uses this
information to weight the toxicity of chemicals relative to copper, a common toxic pollutant in
industrial waste streams. TWFs range from 0.000000131 to over 940 million for the most toxic
pollutants, such as Radium 228 (U.S. EPA, 2007). TWFs enable OW to assess the toxicity of a
wastestream containing varying amounts of different chemicals (each with a different toxicity)
by calculating the total toxic-weighted pounds in the wastestream, referred to as toxic-weighted
pound equivalents (TWPE). OW uses the TWPE during effluent guidelines program planning to
rank industries by their total annual toxic weighted discharges, identifying those that may
warrant additional research (U.S. EPA, 2012b).
Finally, each section ends with a summary of OPPT's planned actions and OW's findings
from its initial review of each chemical.
6.2.2.1 Benzidine Dyes
Chemical Production and Use
The Dyes Derived from Benzidine and Its Congeners CAP (Benzidine Dyes CAP)
focuses on four benzidine-based dyes and 44 benzidine congener-based dyes (U.S. EPA, 2010a).
For a complete list of the chemicals, see Appendix 1 of the Benzidine Dyes CAP.
-------
Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
Benzidine based-dyes and congener-based dyes (also called azo dyes) are used in textiles,
paints and coatings, and pharmaceutical production; paper and leather dyeing; and plastics
converting and compounding (U.S. EPA, 2010a). Dye production in the U.S. has been steadily
declining for the past decade, largely due to the increase in imported finished textiles. Only two
of the 48 benzidine dyes were reported on the 2006 Inventory Update Rule (IUR),27 which
required manufacturers and importers of over 25,000 pounds of chemical per year to provide
OPPT with information on the production and use of the chemicals. OPPT further indicates that
only 12 of the 44 congener-based dyes are likely available in the U.S., and all in quantities below
the IUR threshold of 25,000 pounds per year (U.S. EPA, 2010a).
Presence in Industrial Wastewater
The industrial categories that produce or use benzidine or its congener dyes in the
processes listed above may include:
• Textiles (40 CFR Part 410)
• Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) (40 CFR Part 414)
• Leather Tanning and Finishing (40 CFR Part 425)
• Pulp, Paper and Paperboard (40 CFR Part 430)
• Paint Formulating (40 CFR Part 446)
• Ink Formulating (40 CFR Part 447)
• Plastics Molding and Forming (40 CFR Part 463)
OW was not able to identify any readily available wastewater generation or discharge
data from the CAP or other sources, including DMR and TRI data.
Toxicity and Exposure Routes
Benzidine and its congeners are important precursors in the synthesis of dyes. Some of
these dyes have the potential to metabolize to carcinogenic aromatic amines; therefore, OPPT's
focus is on human exposure, particularly oral, dermal, or inhalation routes (U.S. EPA, 2010a).
OPPT is currently not certain of the risk to the general population from release to the
environment. Biodegradation studies indicate that the dyes biodegrade at negligible to slow rates
under aerobic conditions in the environment. In anaerobic soils, the dyes may be reduced, but it
is unclear whether metabolites from these reductions exist in large concentrations or locations of
concern to the public (U.S. EPA, 2010a).
Benzidine and its congeners do not currently have TWFs. If OW identifies discharges of
these chemicals in industrial wastewater in the future, it may consider developing a TWF to
characterize the relative toxicity of the discharges more fully.
27 During the time in which OW reviewed OPPT's CAPs as part of the 2012 Annual Review, the 2006 IUR provided
the most recent data source for chemical manufacturing, processing, and use as well as production volume
information. InFebruary 2013, EPA released the results of its 2012 Chemical Data Reporting (CDR) Rule, which
provides updated chemical inventory and use data (see http://epa.gov/cdr/). Due to the timing of its release, OW did
not consider the 2012 CDR in its 2012 Annual Review.
6-52
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
OPPTActions
OPPT has taken and is planning the following actions related to benzidine and its
congener-based dyes:
• In March 2012, proposed a rulemaking to add nine benzidine dyes to an existing
SNUR for benzidine-based chemical substances, di-n-pentyl phthalate, and
alkanes C12-13, chloro (77 FR 18752). Potentially affected entities include
manufacturers, importers, or processors of any of these chemicals; entities that
plan to use the chemicals in conjunction with apparel and other finished products
made from fabrics, leather, and similar materials; entities which plan to use the
chemicals in conjunction with paper and allied products; and manufacturers,
importers, or processors of the chemical substances in printing inks.
• Consider additional regulatory action, if OPPT determines that there are other
ongoing uses for these dyes and that it needs information to determine whether
those uses present concerns that should be addressed.
OW's Findings
Dye production has been declining over the past decade due to an increase in imported
finished textiles and, as a result, OPPT is focused on consumer exposure to finished products.
However, based on the available information, OW has determined that benzidine dyes may be
present in industrial wastewater discharges from several regulated industrial categories most
likely including OCPSF; textiles; leather tanning and finishing; pulp, paper, and paperboard; and
ink formulating.
6.2.2.2 Bisphenol A
Chemical Production and Use
Bisphenol A (BPA) is widely used in the manufacture of plastics and epoxy resins for
containers (food and beverage containers, containers used in the healthcare industry), flame
retardants, coatings (such as those used in the electronics, appliances, and the automobile
industry), and pipes and tanks requiring chemical resistant resins (U.S. EPA, 2010b). A small
number of companies manufacture most of the BPA in the U.S., but numerous companies
process BPA-based materials into final goods.
Presence in Industrial Wastewater
BPA is listed under the TRI28 as 4-4' Isopropylidenediphenol (CAS 80-05-7). Table 6-30
shows the industrial categories reporting direct and indirect discharges of BPA to TRI in 2011.
The ELGs for the regulated point source categories listed in Table 6-30 (denoted with a 40 CFR
Part number) do not regulate BPA.
28 For a complete listing of the TRI listed chemicals see: http://www2.epa.gov/toxics-release-inventory-tri-
program/tri-listed-chemicals.
6-53
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
Table 6-30. Discharges of BPA by Point Source Category as Reported to TRI in 2011
40CFR
Part
430
433
464
414
417
446
Point Source Category
Description
Industry Category Not Assigned in
TRI
Pulp, paper and paperboard
Metal Finishing
Metal molding and casting
(foundries)
Organic chemicals, plastics and
synthetic fibers (OCPSF)
Soap and detergent manufacturing
Paint formulating
Total
Direct
Release
(Ib/yr)
2,750
0
0
0
1,910
—
—
4,660
Indirect
Release
(Ib/yr)
4
1,100
118
22
14
4
4
1,260
Total
Release
(Ib/yr)
2,760a
1,100
118
22
1,930
4
4
5,930
Total
TWPE (Ibs-
eq/yr)
6.49
2.58
0.278
0.051
4.53
0.010
0.009
13.9
Source: DMR Loading Tool
Note: Sums of individual values may not equal the total presented, due to rounding.
a A majority of the releases are from a single facility without an assigned industry category in TRI, however, this
facility also reports to DMR and is assigned to OCPSF (40 CFR Part 414).
Washing manufactured products that contain BPA can release BPA into facility
wastewater. However, discharges to wastewater are minor compared to releases to air and land.
Wastewater releases accounted for less than 1 percent of the BPA releases reported to TRI in
2011 (TRI Explorer). In 2011, less than 6,000 pounds of BPA were discharged to surface waters
or indirectly to POTWs.
Based on the limited data available in the CAP, OPPT only identified one study from
2001 to 2002 that assessed the discharge of BPA from a wastewater treatment plant in Louisiana.
BPA was not detected in the plant's effluent (detection limit was 0.001 ug/L) (U.S. EPA, 2010b).
Toxicity and Exposure Routes
BPA is a reproductive, developmental, and systemic toxicant in animal studies and is
weakly estrogenic, therefore OPPT has concerns about its potential impact particularly on
children's health and the environment. Most human exposures come from food packaging
materials, and are under FDA's jurisdiction. However, this exposure accounts for only about five
percent of the BPA produced (U.S. EPA, 2010b). As a result, OPPT's focus is on human and
environmental exposure from manufacturing, processing, and industrial uses, commercial uses,
select consumer uses, incidental ingestion from consumer products, and ingestion of BPA in
drinking water contaminated by wastewater releases to surface water, by landfill leachate, or
from distribution systems with BPA-based pipes (U.S. EPA, 2010b).
OPPT assessed limited data regarding the concentrations of BPA in the environment.
Most environmental monitoring results show concentrations of BPA in waterbodies at levels less
than 1 ug/L, with a median concentration of 0.14 ug/L. This median concentration is lower than
any calculated predicted no effect concentration (PNEC) (U.S. EPA, 2010b). However, OPPT
indicates additional data are needed to determine how many areas exceed PNEC values or
concentrations of concern, how often these concentrations are exceeded, and what pathways lead
6-54
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
to BPA presence in the environment from manufacturing, processing, distribution in commerce,
use, or disposal.
Further, recent and novel low-dose studies describe subtle effects in laboratory animals at
very low concentrations, though the translation to human health effects is currently unclear. The
studies are of concern because they indicate effects at or approaching levels measured in the
environment. In addition, endocrine-related effects in fish, aquatic invertebrates, amphibians, and
reptiles have been reported at exposure levels lower than those required for acute toxicity (U.S.
EPA, 201 Ob).
BPA has a TWF of 0.002354074 (U.S. EPA, 2007), though this TWF has not been
updated since at least 2003. According to the CAP, several government assessments and
numerous toxicological studies have evaluated the effects of BPA since 2004. Some of the
assessments suggest that BPA potentially elicits endocrine-related effects at low doses, lower
than those usually seen to elicit effects in standard toxicity tests (U.S. EPA, 201 Ob). Though total
reported releases of BPA (as shown in Table 6-30) are low, OW is concerned that the current
TWF may be underestimating the discharge hazard.
OPPTActions
OPPT has taken and is planning the following actions related to BPA:
• On January 29, 2014, EPA published a final alternatives assessment for Bisphenol
A (BPA) Alternatives in Thermal Paper (U.S. EPA, 2014a). A draft of this
assessment was open for public review and comment period from July 31, 2012,
to October 1,2012.
• Consider initiating a rulemaking to develop additional data to determine whether
BPA presents an unreasonable risk of injury to the environment. This rulemaking
may include testing or monitoring data near landfills, manufacturing facilities, or
similar locations to determine the potential for BPA to enter surface water, ground
water, and drinking water.
OW's Findings
Several industrial categories reported discharges of BPA in 2011 to TRI; however, BPA
is not currently regulated by existing ELGs. Though quantity and total TWPE of reported BPA
discharges are low (less than 15 Ib-eq/yr) (DMR Loading Tool), OW has concerns that the
associated risks are underestimated and the TWF may need to be reevaluated. The current TWF
does not account for new toxicity data, which suggests endocrine-related affects may occur at
much lower doses.
6.2.2.3 Hexabromocyclododecane
Chemical Production and Use
Hexabromocyclododecane (FfflCD) is a category of brominated flame retardants
consisting of 16 possible isomers. It is used to make flame retardant additives, thermal insulation
foam, and plastic enclosures. HBCD may also be used as a flame retardant in the backcoating of
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textiles for upholstered furniture, upholstery seating, draperies, wall coverings, mattress ticking,
and interior textiles (though the 2006 IUR indicated that less than one percent of the total
commercial and consumer use of HBCD was used for fabrics, textiles, and apparel). In addition,
HBCD is used in high-impact polystyrene in electrical and electronic appliances (U.S. EPA,
2010c).
In the 2006 IUR, five facilities reported either manufacturing or importing at least 25,000
pounds (the IUR reporting threshold) of HBCD: Albemarle (2 facilities), BASF, LG Chem
America, and Chemtura (U.S. EPA, 2006).
Presence in Industrial Wastewater
The industrial categories that produce or use HBCD in the processes listed above may
include:
• Textiles (40 CFR Part 410);
• OCPSF (40 CFR Part 414);
• Rubber Manufacturing (40 CFR Part 428);
• Plastics Molding and Forming (40 CFR Part 463); and
• Electrical and Electronic Components (40 CFR 469).
The ELGs for the categories listed above do not regulate HBCDs.
HBCD is an additive flame retardant, meaning it is not chemically bound to the matrix of
the material it protects, and thus may enter the environment when finished products are washed
(U.S. EPA, 2010c).The HBCD CAP and other readily available information did not provide
wastewater generation or discharge information relevant to the U.S. However, the European
Chemicals Agency (ECHA) reported that in 2008, 50 percent of the releases of HBCD were to
wastewater, as compared to other environmental media (U.S. EPA, 2010c). A Swedish source
indicated that the primary source of release in Europe is from textile applications, though these
data may not translate to the U.S. Based on the 2006 IUR, less than one percent of the total
volume of HBCD was used for textile applications, therefore OPPT expects releases from this
source to be relatively small (U.S. EPA, 2010c).
Toxicity and Exposure Routes
HBCD is typically manufactured as a powder, a portion of which is micronized. The
small size of the particles make human inhalation a concern. HBCD also is persistent,
bioaccumulative, and has toxic properties (PBT), particularly to aquatic organisms. It has been
measured in a variety of environmental media including air, sediment, marine mammals,
freshwater fish, aquatic invertebrates, and birds (U.S. EPA, 2010c).
OPPT did not identify any readily available information on the release of HBCD to the
environment in the U.S. However, ECHA reported a release of 3,100 kg/year in Europe, 50
percent of which went to wastewater, 29 percent to surface water, and 21 percent to air (ECHA,
2009). Data from the United Kingdom indicate that the primary sources of HBCD release are
fugitive emissions during its manufacture and subsequent use in products, leaching from
landfills, and incinerator emissions (U.S. EPA. 2010c).
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Currently, HBCD does not have a TWF. If OW identifies discharges of HBCD in
industrial wastewater in the future, it may need to consider developing a TWF to more fully
characterize and understand the relative toxicity of the discharges.
OPPTActions
OPPT has taken and is planning the following actions related to FffiCD:
• In March 2012, proposed a SNUR covering HBCD's use in consumer textiles
other than motor vehicles (77 FR 17386).
• Consider initiating a rulemaking to add HBCD to TRI.
• In April 2011, began coordinating with DfE on a Partnership on Flame Retardant
Alternatives for Hexabromocyclododecane (HBCD).29 In September 2013, EPA
posted the draft DfE alternatives assessment for public comment.
OW's Findings
Based on the available information, HBCD may be present in industrial wastewater
discharges from several industrial point source categories. Studies in Europe suggest that there
could be significant wastewater discharges, though OW is currently uncertain about the specific
sources and significance of the discharge in the U.S.
6.2.2.4 Methylene Diphenyl Diisocyanate and Toluene Diisocyanate
Chemical Production and Use
Methylene diphenyl diisocyanate (MDI) and toluene diisocyanate (TDI) are chemically
similar, but may be used in different applications. According to the 2006 IUR, MDI is used in
adhesives and sealants, paints and coatings, transportation products, rubber and plastic products,
and lubricants, greases and fuel additives (U.S. EPA, 201 la). TDI is primarily used in the
production of flexible foams, but may also be used in coatings, adhesives, binders, and sealants
(U.S. EPA, 201 Ib). MDI and TDI are generally supplied as raw materials to formulators who
combine them with other chemicals to create different polyurethanes with a wide variety of
applications (U.S. EPA, 201 la, 201 Ib).
Presence in Industrial Wastewater
The industrial categories that produce or use MDI or TDI in the processes listed above
may include:
• Textiles (40 CFR Part 410);
• OCSPF (40 CFR Part 414);
• Rubber Manufacturing (40 CFR Part 428);
• Paint Formulating (40 CFR Part 446);
• Plastics Molding and Forming (40 CFR Part 463); and
29 For more information on the DfE Partnership on Flame Retardant Alternatives for Hexabromocyclododecane see
http://www.epa.gov/dfe/pubs/projects/hbcd/index.htm.
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• Electrical and Electronic Components (40 CFR Part 469).
In water, TDI will hydrolyze into toluene diamine (U.S. EPA, 201 Ib) and MDI will
hydrolyze into methyl diphenyl diamine (U.S. EPA, 201 la). Toluene diamine is a TRI listed
chemical. In 2011, only one facility reported discharges of toluene diamine to TRI, with a total
discharge of 5 pounds per year (DMR Loading Tool). OPPT has not regulated methyl diphenyl
diamine under TRI; therefore, OW does not have any data to characterize its presence in
industrial wastewater.
The ELGs for the categories listed above do not regulate TDI, MDI or their hydrolysis
byproducts.
Toxicity and Exposure Routes
The hazards associated with TDI and MDI have centered on human health effects
because of their low ecotoxicity profiles. Toxicological data indicate moderate to low toxicity in
aquatic organisms (U.S. EPA, 201 la, 201 Ib).
In humans, diisocyanates are documented as dermal and inhalation sensitizers. However,
exposure to products containing cured polyurethanes has not generally been a concern because
cured products are considered inert and nontoxic. OPPT developed CAPs for MDI and TDI to
address more recent concerns about the presence of uncured MDI and TDI in products used by or
around consumers as well as unprotected building occupants (primarily as an inhalation and
dermal exposure concern) (U.S. EPA, 201 la, 201 Ib).
MDI and TDI do not currently have TWFs; however, toluene diamine (a TDI hydrolysis
byproduct) is a TRI-listed chemical and has a TWF of 0.3388 (U.S. EPA, 2007). OPPT has not
regulated methyl diphenyl diamine (an MDI hydrolysis byproduct) under TRI, and OW has not
developed an associated TWF. If OW identifies discharges of methyl diphenyl diamine in
industrial wastewater in the future, it may need to consider developing a TWF to more fully
characterize and understand the relative toxicity of the discharges.
OPPT Actions
OPPT is planning the following actions related to MDI:
• In September 2012, sent a letter to nine companies requesting information on
curing times for polyisocyanate products. OPPT is in the process of looking at
data received in response to the letter for exposure information. If, after
considering the data submitted, OPPT determines more information is still
needed, the Agency will consider developing a proposed rule under TSCA
Section 8(d) to require chemical manufacturers (including importers) to submit
unpublished health and safety data on diisocyanates.
OPPT is planning the following actions related to TDI:
• Develop a SNUR for uncured TDI and its related polyisocyanates in consumer
products. The Proposed SNUR for TDI and related compounds for consumer use
is scheduled for publication in Fall 2014. The SNUR contains a SNU for seven
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TDI and related compounds. For this proposed rule, the general SNUR article
exemption for persons who import or process TDI and related compounds would
not apply.
• In September 2012, sent a letter to nine companies requesting information on
curing times for polyisocyanate products. OPPT is in the process of looking at
data received in response to the letter for exposure information. If, after
considering the data submitted, OPPT still believes more data is needed, the
Agency will consider developing a proposed rule under TSCA Section 8(d) to
require chemical manufacturers (including importers) to submit unpublished
health and safety data on diisocyanates.
OW's Findings
In water, TDI will hydrolyze into toluene diamine and MDI will hydrolyze into methyl
diphenyl diamine; therefore, MDI and TDI may not directly pose a significant source or hazard
in industrial wastewater discharge. However, available information suggests that the MDI and
TDI hydrolysis byproducts may be present in industrial wastewater, though OW is currently
uncertain of the extent of concern. In 2011, one facility reported discharges of toluene diamine to
TRI, with a total discharge of 5 pounds per year (DMR Loading Tool). OW does not currently
have any data characterizing discharges of methyl diphenyl diamine.
6.2.2.5 Nonylphenol and Nonylphenol Ethoxylates
Chemical Production and Use
Nonylphenol (NP) and nonylphenol ethoxylates (NPEs) are used to manufacture resin
and synthetic rubber (stabilizer), printing ink, and soap (including industrial laundry detergents)
and cleaning products (U.S. EPA, 2010d). Kirk-Othmer states that the major use for NPEs is in
the production of nonionic surfactants, constituting 80 percent of the total use (Kirk-Othmer,
2003). The primary use of NP is as an intermediate in the manufacture of NPEs (U.S. EPA,
2010d).
Presence in Industrial Wastewater
The industrial categories that produce or use NP or NPEs in the processes listed above
may include:
• Textiles (40 CFR Part 410);
• OCSPF (40 CFR Part 414);
• Soap and Detergent Manufacturing (40 CFR Part 417);
• Rubber Manufacturing (40 CFR Part 428);
• Pulp, Paper and Paperboard (40 CFR Part 430);
• Oil and Gas Extraction (40 CFR Part 435);
• Paint Formulating (40 CFR Part 446); and
• Ink Formulating (40 CFR Part 447).
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The ELGs for the categories listed above do not regulate NP or NPEs. Further, OW was
not able to identify, through either the CAP or other readily available information, data on
wastewater generation or discharge of NP and NPEs in the U.S. However, information from the
European Union and Canada indicates environmental releases to water during the manufacture
and use of NP and NPEs (EU, 2002 and Environment Canada, 2001).
Industrial laundries, which are not currently regulated by ELGs, may also be significant
sources of discharge because of the continued use of detergents containing NPEs. In fact,
industrial laundry detergents are the current focus of OPPTs voluntary initiatives to phase out the
use of NPEs.
OW previously evaluated industrial laundry discharges when it developed proposed
pretreatment standards for this industry in 1997. The proposed pretreatment standards included
limits for 11 pollutants, but did not include NPs or NPEs (U.S. EPA, 2000). In 1999, OW
ultimately decided not to promulgate national pretreatment standards for industrial laundries (64
FR 45071). OW determined that the discharges to POTWs did not represent a problem
warranting national regulation because the pretreatment options determined to be economically
achievable would remove only a small amount of pollutants. In addition, OW believed that
POTWs were generally not experiencing problems from industrial laundry discharges, and that
any discharges would be adequately controlled by the existing pretreatment program.
Toxicity and Exposure Routes
NP is persistent in the aquatic environment, moderately bioaccumulative, and extremely
toxic to aquatic organisms. NPEs, though less toxic than NP, are also highly toxic to aquatic
organisms and, in the environment, tend to degrade to NP, which is more environmentally
persistent (U.S. EPA, 2010d). EPA has developed water quality criteria for NP, as shown in
Table 6-31 (U.S. EPA, 2005).
Table 6-31. NP Water Quality Criteria
Species
Freshwater species
Saltwater species
Acute Water Quality Criteria
28ug/L
7ug/L
Chronic Water Quality Criteria
6.6ug/L
1.7ug/L
According to the CAP, there is likely significant environmental exposure to NP and NPEs
from facilities that manufacture NP- and NPE-containing products and that are discharging to
surface waters. A range of surface water and sediment levels have been measured in the U.S:
some measurements of NP near industrial discharges exceeded the water quality criteria (U.S.
EPA, 2010d). In addition, sewage treatment plants are common receivers of NPE discharges,
possibly due to the use of industrial laundry detergents. At sewage treatment plants, NPEs
degrade to shorter-chain NPEs and are expected to partition to sludge (U.S. EPA, 2010d).
Currently NP and NPEs do not have TWFs. If OW identifies discharges of NP and NPEs
in industrial wastewater in the future, it may need to consider developing TWFs to more fully
characterize and understand the relative toxicity of the discharges.
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OPPJActions
OPPT has taken and is planning the following actions related to NP and NPEs:
• In May 2012, coordinated with DfE to release An Alternatives Assessment for
NonylphenolEthoxylates (U.S. EPA, 2012c).
• Support and encourage the voluntary phase-out of NPEs in industrial laundry
detergents in coordination with DfE Safer Detergents Stewardship Initiative.30
This program will end the use of NPEs in industrial laundry detergents by 2013
for liquid detergents and 2014 for powdered detergents.
• Encourage manufacturers of all NPE-containing direct release products to move
to NPE-free formulations.
• Develop an alternatives analysis and encourage the elimination of NPEs in other
industries that discharge NPEs to water, such as the pulp and paper and textile
processing sectors.
• Initiate rulemaking to propose a SNUR for NP and NPEs for use of NPEs no
longer being manufactured. The Proposed NP/NPE SNUR is currently scheduled
for publication in 2014.
• In June 2009, issued an advanced notice of proposed rule under TSCA Section 4
test rules to require the development of information necessary to determine the
effects that NP and NPEs have on human health or the environment (74 FR
28654). EPA intends to evaluate how releases and exposures are mitigated
through the phase-out action; and plans to finalize any proposed testing actions
accordingly.
• Initiate rulemaking to add NP and NPEs to TRI. On June 20, 2013 EPA published
a proposed Nonylphenol Category to TRI (78 FR 37176).
OW's Findings
Though NP and NPEs may phase out of use in industrial laundry detergents over the next
few years, available data and information suggest that they likely are present in wastewater
discharge from several industrial categories. NP and NPEs have been measured in surface water
and sediment in the U.S. and data from the European Union and Canada suggest there have been
environmental releases to water during the manufacture and use of NP and NPEs.
6.2.2.6 Perfluorinated Chemicals (Long-Chain)
Chemical Production and Use
Long-chain perfluorinated compounds (PFCs) are a family of fluorine-containing
chemicals with unique properties that make materials resistant to stains and to sticking. PFCs are
used to manufacture wire, cable, and apparel. Additionally, PFCs are used as cookware coatings
30 For more information on the Safer Detergent Stewardship Initiative see
http://www.epa.gov/oppt/dfe/pubs/projects/formulat/sdsi.htm
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and other miscellaneous coatings including carpets, paper products, and other precursor products
(U.S. EPA, 2009a).
There are two subcategories of PFCs: perfluoroalkyl sulfonates (PFAS) and long-chain
perfluoroalkyl carboxylates (PFAC). The PFAS subcategory includes perfluorohexane sulfonic
acid (PFHxS) and perfluorooctane sulfonic acid (PFOS). The PFAC subcategory includes
perfluorooctanoic acid (PFOA).
PFAS manufacturing has dwindled significantly since 2003 when 3M, the principal U.S.
producer of PFOS, phased out production. According to OPPT, PFAS are no longer
manufactured in the U.S. (U.S. EPA, 2009a).
PFAC on the other hand is still widely produced. The U.S. accounts for more than 50
percent of the world's fluorotelomer production (fluorotelomers are precursors to some long
chain PFACs). Half the fluorotelomer production is in textiles and apparel, followed by carpet,
carpet care products, and coatings—including coatings for paper products (U.S. EPA, 2009a).
To address concerns surrounding releases of PFOA, OPPT initiated a 2010/2015
Stewardship Program (U.S. EPA, 2012d). Under the program, manufacturing companies
voluntarily committed to reducing PFOA emissions and product content by 95 percent by 2010.
Additionally companies that chose to participate in the program would work to eliminate PFOA
emissions and product content by 2015. In 2006, the eight major PFOA manufacturers joined the
PFOA Stewardship Program (see Section 6.2.3 for more details).
Presence in Industrial Wastewater
PFCs are manufactured by OCPSF (40 CFR Part 414) facilities and used in products
covered by many other industrial categories; however, no ELGs currently regulate the discharge
of PFCs. These chemicals can enter the wastewater during manufacture and via washing of
manufactured products (U.S. EPA, 2009a). PFOA, in particular, has been detected in industrial
wastewater discharges from OCPSF facilities. These discharges in some cases are causing
surface water concentrations above a provisional health advisory level for drinking water. In
addition, OPPT has suggested that PFOA may be present in industrial wastewater discharges
from a variety of other industries that use imported PFOA in the manufacture of products such as
clothing and cookware (U.S. EPA, 2009a). Because of the extent of information and available
data, OW presents its review of wastewater discharges related to PFCs, and PFOA in particular,
below in Section 6.2.3. Section 6.2.3 also briefly discusses PFOA wastewater treatment.
Toxicity and Exposure Routes
PFCs have been found worldwide in the environment, wildlife, and in humans. PFCs are
persistent in the environment and bioaccumulative in wildlife and humans. Significant adverse
effects have been observed in laboratory animals and wildlife, though not in humans (U.S. EPA,
2009a).
PFAS and PFAC contamination and entry points into the environment seem to vary by
location and among species, suggesting multiple sources of emissions (U.S. EPA, 2009a). PFAC
and PFAS have been found in untreated groundwater, rivers, streams, bays, estuaries, oceans,
and even rainwater. OPPT has documented specific releases from manufacturing (see the
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discussion in Section 6.2.3 for more details on industrial discharges of PFOA). In some cases,
PFOA releases near industrial facilities have contaminated drinking water supplies. As of April
2013, citizens in Woods County, West Virginia continue to express concerns related to drinking
water supplies contaminated with PFOA from operations at a DuPont-owned plant. The citizens
contend that DuPont is not meeting its end of the agreement under the Stewardship Program
(Inside EPA, 2013).
Currently PFCs, including PFOA, do not have TWFs. OW may consider developing
TWFs for these pollutants, as additional discharge data become available, to more fully
characterize and understand the relative toxicity of the discharges.
OPPTActions
OPPT has taken and is planning the following actions related to PFCs:
• On September 30, 2013, EPA issued a rule requiring companies to report all new
uses of long-chain perfluoroalkyl carboxylates (LCPFAC) as part of carpets or to
treat carpets. Companies now must report to EPA their intent to manufacture
(including import) LCPF AC-containing products intended for use as part of
carpets or to treat carpets, as well as import carpets already containing these
chemical substances (78 FR 62443).
• EPA intends to propose a SNUR under section 5(a)(2) of the Toxic Substances
Control Act (TSCA) for long-chain perfluoroalkyl carboxylate (LCPFAC)
chemical substances, and for perfluorooctanoic acid (PFOA) or its salts. EPA also
intends to propose to make the article exemption inapplicable to the import of
certain identified chemical substances.
• Evaluate the potential for disproportionate impact on children and other sub-
populations; incorporating this effort as a part of published rules.
• Continue to work with companies to eliminate long-chain PFCs from emissions
and products through the 2010/2015 PFOA Stewardship Program (U.S. EPA,
2012d). OPPT will also continue to evaluate alternatives under EPA's New
Chemicals Program and collaborate with other countries on managing PFCs.
OW's Findings
OW has found that PFCs, specifically PFOA, are present in industrial wastewater
discharge from OCPSF facilities (40 CFR Part 414) and that the discharges in some cases are
resulting in surface water concentrations above a provisional health advisory level for drinking
water. OPPT has suggested that PFOA may be present in industrial wastewater discharge from a
variety of other industries that use imported PFOA in the manufacture of various products such
as clothing and cookware (U.S. EPA, 2009a). However, PFCs are not currently regulated by
existing ELGs.
OPPT also investigated potential wastewater treatment options and determined that
biological treatment systems are not successful in treating PFOA (U.S. EPA, 2009a). EPA's
Office of Ground Water and Drinking Water (OGWDW) drinking water treatment technology
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data suggest that granular activated carbon (GAC) may be a viable solution for eliminating
PFOA in drinking water (U.S. EPA, 2012e), but it is unclear if that technology could be effective
in an industrial wastewater matrix.
6.2.2.7 Penta, Octa, and Decabromodiphenyl Ethers
Chemical Production and Use
Penta-, octa-, and decabromodiphenyl ethers (PBDEs) are flame retardants. OPPT's CAP
reported that the sole domestic manufacturer of commercial mixtures of pentaBDE and octaBDE
phased out their production in 2004 (U.S. EPA, 2009b). DecaBDE is still manufactured and used
in the U.S. The three major product categories that use decaBDE as an additive flame retardant
include textiles, electronics equipment, and building and construction materials, with its primary
use being in high impact polystyrene-based products. However, through the U.S. EPA DecaBDE
Phase-Out Initiative (U.S. EPA, 2012f), OPPT received commitments from the primary
manufacturers and importers of decaBDE to reduce production beginning in 2010.
Presence in Industrial Wastewater
The industrial categories that produce or use PBDEs in the processes listed above may
include:
• Textiles (40 CFR Part 410);
• OCSPF (40 CFR Part 414);
• Plastic Molding and Forming (40 CFR Part 463); and
• Electrical and Electrical Components (40 CFR Part 469).
PBDEs are not regulated by these ELGs and OW was not able to identify any data
regarding their presence in industrial wastewater discharge.
Toxicity and Exposure Routes
OPPT is concerned that some of the component congeners of PBDEs are persistent,
bioaccumulative, and toxic. The mechanisms by which PBDEs enter the environment are not
known, but likely include releases from manufacturing of the chemicals, manufacturing of
products such as textiles and plastics that use the chemicals, and from wear and disposal of
treated products over time (U.S. EPA, 2009b). Studies indicate that the primary exposure for
humans is the use of PBDEs in commercial products that are part of the indoor environment
(foam cushions, computer circuitry, fabrics, etc.). PBDEs are not chemically bound to plastics,
foam, fabrics, or other products in which they are used, making them more likely to leach out of
these products (U.S. EPA, 2009b). Despite phase-out of production in the U.S., some reports
indicate that levels of PBDEs in humans and the environment are increasing (U.S. EPA, 2009b).
One potential source is imported articles to which these compounds have been added. Another is
the possible breakdown of decaBDE into more toxic and bioaccumulative PBDE congeners.
Currently PBDEs do not have TWFs. If OW identifies discharges of PBDEs in industrial
wastewater in the future, it may need to consider developing TWFs to more fully characterize
and understand the relative toxicity of the discharges.
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OPPJActions
OPPT has taken and is planning the following actions related to PBDEs:
• In April 2012, proposed to amend the PBDE SNUR to add processing of the six
PBDE congeners in penta- and octaPBDE as a significant new use; add
manufacturing, importing, or processing of decaBDE as a significant new use;
and designate the manufacture or processing of any article to which PBDEs have
been added as a significant new use (77 FR 19861).
• In April 2012, issued a proposed TSCA Section 4 test rule for penta-, octa-, and
decaBDE to require development of information necessary to determine the
effects of manufacturing, processing, or other activities on human health and the
environment (77 FR 19861).
• Support and encourage the voluntary phase-out of the manufacture and import of
decaBDE (U.S. EPA, 2012f).
• In support of the phase-out, on January 29th, 2014, EPA published An Alternatives
Assessment for the Flame-Retardant Decabromodiphenyl Ether (DecaBDE) (U.S.
EPA, 2014b). A draft of this assessment was open for public review and comment
from July 30, 2012 to September 30, 2012.
OW's Findings
Based on review of the CAP and other readily available information, OW has found that
PBDEs in industrial wastewater discharges are not a significant source that needs to be
considered in ELG development. According to OPPT, pentaBDE and octaBDE are no longer
produced in the U.S., and OPPT is working to phase out decaBDE.
6.2.2.8 Phthalates
Chemical Production and Use
Phthalates are used as plasticizers in polyvinyl chloride (PVC) products and to
manufacture paints and coatings, cement, carpet and rugs, wood kitchen cabinets and
countertops, and explosives. The CAP identifies eight individual phthalate esters, with ten
separate CAS numbers, that warrant an assessment and management strategy (see Table 6-32 for
the list of phthalates covered in the CAP) (U.S. EPA, 2012g).
Presence in Industrial Wastewater
Two point source categories, OCPSF (40 CFR Part 414) and Centralized Waste
Treatment (CWT) (40 CFR Part 437), regulate three of the eight phthalates identified in the
CAP. In addition, two of the eight phthalates are TRI-listed chemicals. Table 6-32 presents the
phthalates discussed in the CAP and identifies those that are regulated by the existing ELGs
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and/or are listed under TRI. Table 6-33 presents the phthalate limits from Parts 414
respectively.32
31
and 437,
Table 6-32. Phthalates in CAP Regulated by ELGs and/or Listed in TRI
Phthalate Ester Identified in
CAP
,2-Benzenedicarboxylic acid,
,2-dibutyl ester (DBF)
,2-Benzenedicarboxylic acid,
,2-bis-(2methylpropyl) ester
(DIBP)
,2-Benzenedicarboxylic acid,
-butyl 2(phenylmethyl) ester
(BBP)
,2-Benzenedicarboxylid acid,
,2-dipentyl ester (DnPP)
,2-Benzenedicarboxylic acid,
,2-bis(2ethylhexyl) ester
(DEHP)
,2-Benzenedicarboxylic acid,
,2-dioctyl ester (DnOP)
,2-Benzenedicarboxylic acid,
,2-diisononyl ester (DINP)
,2-benzenedicarboxylic acid,
di-C8-C10-branched alkyl esters,
C9-rich (Part of DINP)
1,2-Benzenedicarboxylic acid,
1,2-diisodecyl ester (DIDP)
1,2-Benzenedicarboxylic acid,
di-C9-Cn -branched alkyl esters,
do-rich (Part of DIDP)
CAS No.
84-74-2
84-69-5
85-68-7
131-18-0
117-81-7
117-84-0
28553-12-0
68515-48-0
26761-40-0
68515-49-1
Common Name(s)
Dibutyl phthalate, Di-
n-butyl phthalate
Diisobutyl phthalate
Butylbenzyl phthalate
Di-n-pentyl phthalate
Bis(2-
ethylhexyl)phthalate,
Di(2-
ethylhexyl)phthalate
OP Di-n-octyl
phthalate
Diisononyl phthalate
Di-(C9-rich branched
C8-C10 - alkyl)
phthalate
Diisodecyl phthalate
Di-(Cio-rich branched
C9-Cn- alkyl) phthalate
Regulated
under Part
414
X
X
Regulated
under Part
437
X
X
TRI
Listed
Chemical
X
X
Sources: 40 CFR 414, 40 CFR 437, EPCRA Section 313 Chemical List for Reporting Year 2011.
31 Part 414 also regulates diethyl and dimethyl phthalate, which are not discussed in the Phthalates CAP.
32 For a complete listing of the TRI listed chemicals see: http://www2.epa.gov/toxics-release-inventory-tri-
program/tri-listed-chemicals.
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6.2—Review of Chemical Action Plans
Table 6-33. ELG Limits for Regulated Phthalates
Point
Source
Category
OCPSF
CWT
Pollutant Name
Bis(2-ethylhexyl)phthalate (DEHP)
Di-n-butyl phthalate (DBF)
Diethyl phthalate a
Dimethyl phthalate3
Bis(2-ethylhexyl)phthalate (DEHP)
Di-n-butyl phthalate (DBF)
Diethyl phthalate a
Dimethyl phthalate a
Bis(2-ethylhexyl)phthalate (DEHP)
Di-n-butyl phthalate (DBF)
Diethyl phthalate a
Dimethyl phthalate a
Bis(2-ethylhexyl)phthalate (DEHP)
Butylbenzyl phthalate (BBP)
Bis(2-ethylhexyl)phthalate (DEHP)
Daily
Maximum
(mg/L)
279
57
203
47
258
43
113
47
258
43
113
47
0.215
0.188
0.267
Monthly
Average
(mg/L)
103
27
81
19
95
20
46
19
95
20
46
19
0.101
0.0887
0.158
Type of Limit
BAT and NSPS, Subpart I—
Direct Discharge Point Sources
That Use End-of-Pipe
Biological Treatment
BAT and NSPS, Subpart J—
Direct Discharge Point Sources
That Do Not Use End-of-Pipe
Biological Treatment
PSES and PSNS, Subpart K—
Indirect Discharge Point
Sources
BPT, BAT and NSPS, Subpart
B — Oils Treatment and
Recovery
PSES and PSNS, Subpart B—
Oils Treatment and Recovery
Sources: 40 CFR 414.91, 414.101, 414.111, 437.21, 23-24, 437.25-26.
a Diethyl phthalate and dimethyl phthalate are regulated by the ELGs, but are not included in the Phthalates CAP.
In addition to OCPSF, four other regulated point source categories reported di-n-butyl
phthalate discharges to DMR or TRI in 2011, shown in Table 6-34. Additionally, nineteen
regulated point source categories reported discharges of bis(2-ethylhexyl)phthalate to DMR or
TRI in 2011, shown in Table 6-35. Only three facilities reported discharges of butylbenzyl
phthalate. Two of these facilities are CWTs and one did not report an SIC code that corresponds
to a specific industrial point source category (DMR Loading Tool).
Table 6-34. Discharge of Di-n-butyl phthalate by Point Source Category as Reported to
DMR and TRI (2011)
PSC
Code
415
414
428
417
438
Point Source Category
Inorganic Chemicals
Manufacturing
OCPSF
Rubber Manufacturing
Soap and Detergent
Manufacturing
Metal Products and
Machinery
Total
Di-n-butyl phthalate
Total DMR
Pounds
(Ibs/yr)
71.1
558
NR
21.5
0.14
651
Total DMR
TWPE
(Ibs-eq/yr)
0.88
5.54
NR
0.21
0.0014
6.63
Total TRI
Pounds
(Ibs/yr)
2,460
132
7.84
0.8
NR
2,605
Total TRI
TWPE
(Ibs-eq/yr)
24.6
1.31
0.078
0.008
NR
26.0
Facility
Counts
(DMR/TRI)
1/1
17/4
0/2
1/1
1/0
20/8
Source: DMR Loading Tool
NR: Not reported
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6.2—Review of Chemical Action Plans
Table 6-35. Discharge of Bis(2-ethylhexyl)phthalate by Point Source Category as
Reported to DMR and TRI (2011)
PSC
Code
415
414
428
463
455
439
417
419
420
421
423
438
430
432
435
437
445
460
410
Point Source Category
Inorganic Chemicals
Manufacturing
Organic Chemicals,
Plastics And Synthetic
Fibers (OCPSF)
Rubber Manufacturing
Plastics Molding and
Casting (Foundries)
Pesticide Chemicals
Pharmaceutical
Manufacturing
Soap and Detergent
Manufacturing
Petroleum Refining
Iron and Steel
Manufacturing
Nonferrous Metals
Manufacturing
Steam Electric Power
Generating
Metal Products and
Machinery
Pulp, Paper and
Paperboard
Meat and Poultry
Products
Oil & Gas Extraction
Centralized Waste
Treatment
Landfills
Hospital
Textile Mills
Total
Bis(2-ethylhexyl)phthalate
Total DMR
Pounds
(Ibs/yr)
190
3,450
NR
10,600
NR
0.14
21.5
669
311
10.7
0.409
3.75
49.4
32.2
56.6
6.98
50.7
0.45
NR
15,500
Total
DMR TWPE
(Ibs-eq/yr)
48.3
862
NR
2,650
NR
0.037
5.38
167
77.6
2.68
0.102
0.937
12.3
8.06
14.1
1.73
12.7
0.11
NR
3,870
Total TRI
Pounds
(Ibs/yr)
NR
2,090
379
151
2.05
2.1
NR
NR
NR
NR
NR
9.36
NR
NR
NR
NR
NR
NR
353
2,980
Total
TWPE
(Ibs-eq/yr)
NR
523
94.7
37.8
0.513
0.525
NR
NR
NR
NR
NR
2.34
NR
NR
NR
NR
NR
NR
88.2
747
Facility
Counts
(DMR/
TRI)
3/0
33/3
0/14
1/8
0/1
1/1
1/0
1/0
3/0
1/0
3/0
6/4
2/0
1/0
1/0
2/0
3/0
1/0
0/1
63/32
Source: DMR Loading Tool.
NR: Not reported.
Note: Sums of individual values may not equal the total presented, due to rounding.
Table 6-36 shows that the discharges of the three phthalates reported in DMR are
generally at concentrations significantly below the most stringent limits established by the
existing ELGs. OW was not able to identify any data regarding the source, presence, or quantity
of the other five unregulated phthalates in industrial wastewater discharge.
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6.2—Review of Chemical Action Plans
Table 6-36. Range of Average Phthalate Discharges Reported to DMR (201 l)a
Pollutant Name
Butylbenzyl phthalate
Di-n-butyl phthalate
Bis(2-ethylhexyl)phthalate
Monthly Average
Concentrations (mg/L)a
0.005-0.006
0.0002-0.019
0.0003- 7d
Facility Countb
2
20
64
Most Stringent ELG Limits
(mg/L)c
0.0887
(40 CFR 437 BPT, BAT, NSPS
Subpart B)
20
(40 CFR 414 BAT and NSPS,
Subpart J and PSES and PSNS,
Subpart K)
0.101
(40 CFR 437 BPT, BAT, NSPS
Subpart B)
Source: DMR Loading Tool.
a Monthly average represents the range of concentrations for all point source categories reporting discharges.
b Facility counts only include those facilities with reported loads greater than zero.
0 Most stringent ELG limits taken from Table 6-33. This information is provided for comparison purposes only. Not
all facilities are subject to the ELG limits for these pollutants.
d There are only three facilities that reported discharges greater than the most stringent ELG limit.
Toxicity and Exposure Routes
Studies indicate that exposure to some phthalates may cause reproductive issues in the
human population and in studied animal groups. Effects in the environment have been observed
at measured environmental concentrations. Di-n-butyl phthalate, bis(2-ethylhexyl)phthalate, and
butylbenzyl phthalate were included in the first group of 67 chemicals to be screened as part of
the Endocrine Disrupter Screening Program (EDSP) (U.S. EPA, 2009b).
Phthalates have been observed in most environmental media and may be released to the
environment from multiple sources including industrial releases, disposal of industrial waste,
municipal solid waste, land application of sewage sludge, and release from products containing
phthalates. Based on 2007 TRI data, for two regulated phthalates (di-n-butyl phthalate and bis(2-
ethylhexyl)phthalate), releases to water are less significant than releases to land and air.
OW has established TWFs for three regulated phthalates; butylbenzyl phthalate, di-n-
butyl phthalate, and bis(2-ethylhexyl)phthalate as well as one of the unregulated phthalates, OP
di-n-octyl phthalate (U.S. EPA, 2007). OW has not established TWFs for the remaining
phthalates. If OW identifies discharges of these phthalates in industrial wastewater in the future,
it may need to consider developing TWFs to more fully characterize and understand the relative
toxicity of the discharge.
OPPTActions
OPPT has taken and is planning the following actions related to phthalates:
• Coordinate with Consumer Product Safety Commission and Food and Drug
Administration to more fully assess use, exposure, and substitutes for phthalates.
• In March 2012, proposed a SNUR covering most uses of di-n-pentyl phthalate (77
FR 18752).
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• In August 2011, began coordinating with DfE on the Alternatives to Certain
Phthalates Partnership.33 The alternatives assessment would build upon existing
knowledge and would consider exposures to all human subpopulations, including
children, as well as environmental exposure.
OW's Findings
Three of the eight phthalates identified in the CAP are regulated by existing ELGs
(OCPSF and CWTs) and two are TRI-listed chemicals. Available data suggests that these
regulated phthalates are present in industrial wastewater discharge from several point source
categories (beyond OCPSF and CWT), though the concentrations and TWPE are low. OW was
not able to readily identify data to characterize the presence of the remaining five unregulated
phthalates in industrial wastewater discharge.
6.2.2.9 Short-Chain Chlorinated Paraffins
Chemical Production and Use
Short-chain chlorinated paraffins (SCCPs) are used in the formulation of metalworking
fluids (as a component of lubricants and coolants in metal cutting and forming operations),
plastics compounding (as a secondary plasticizer and flame retardant in PVC), rubber
compounding, paint and coating formulation, petroleum lubricating oil and grease
manufacturing, and adhesive and sealant formulation. In the U.S., SCCPs are most frequently
used as components of lubricants and coolants in metal cutting and metal forming operations.
The second largest use is as a secondary plasticizer and flame retardant in plastics, particularly
PVC (U.S. EPA, 2009c).
In 2012, EPA initiated enforcement action against Dover Chemical, requiring the facility
to cease manufacturing SCCPs. Dover was the last U.S. manufacturer of SCCPs (U.S. EPA,
2009c). Several companies import SCCPs (U.S. EPA, 2006).
Presence in Industrial Wastewater
The industrial categories that produce or use SCCPs in the processes listed above may
include:
OCPSF (40 CFR Part 414);
Petroleum Refining (40 CFR Part 419);
Iron and Steel Manufacturing (40 CFR Part 426);
Pulp, Paper and Paperboard (40 CFR Part 430);
Metal Finishing (40 CFR Part 433);
Paint Formulating (40 CFR Part 446);
Plastics Molding and Forming (40 CFR Part 463);
Aluminum Forming (40 CFR Part 467);
33 For more information on the Alternatives to Certain Phthalates Partnership see
http://www.epa.gov/dfe/pubs/projects/phthalates/index.html.
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• Copper Forming (40 CFR Part 468);
• Nonferrous Metals Forming and Metals Powders (40 CFR Part 471); and
• Miscellaneous Foods and Beverages (40 CFR Part 503).
During manufacture, SCCPs are most likely to enter wastewater through container
cleaning, dragout, and disposal of filter media and spent metal working fluid. Using generic
scenario methodology, OPPT estimated total releases to wastewater from these activities to be
approximately 2,400 kg per site per year (U.S. EPA, 2009c). The ELGs for the categories listed
above do not regulate SCCPs.
According to the CAP, releases from industrial sources often end up in sewage treatment
plants. Concentrations of SCCPs in sewage sludge are much higher than in river and lake
sediments, especially from wastewater treatment plants serving industrial areas (U.S. EPA,
2009c).
SCCPs were added to TRI in 1995 as polychlorinated alkanes. The 2005 through 2007
TRI databases included reported releases of SCCPs to air from only one company manufacturing
SCCPs, Dover Chemical in Hammond, Indiana. The facility reported no water releases in 2009
(U.S. EPA, 2009c). Further, in 2011, one metal finishing manufacturer reported discharges of
polychlorinated alkanes to TRI, totaling 5.62 pounds per year (DMR Loading Tool). OW did not
identify any additional wastewater generation information for SCCPs.
Toxicity and Exposure Routes
OPPT has identified manufacturing and lubricant applications as the likely sources of
environmental release and exposure. SCCPs have been found worldwide, in the environment,
wildlife, and humans. SCCPs are bioaccumulative in humans and wildlife, are persistent in the
environment, and are toxic to aquatic organisms at low concentrations (U.S. EPA, 2009c).
Currently SCCPs do not have TWFs. If OW identifies discharges of SCCPs in industrial
wastewater in the future, it may need to consider developing TWFs to more fully characterize
and understand the relative toxicity of the discharges.
OPPT Actions
OPPT has taken and is planning the following actions related to SCCP:
• In February 2012, announced enforcement action against Dover Chemical,
requiring them to pay $1.4 million and cease manufacturing of SCCPs.34 Dover is
the last remaining chlorinated paraffin manufacturer in the U.S.
• In March 2012, proposed a SNUR for certain SCCPs (77 FR 18752). The
proposal would require companies to notify EPA of plans to manufacture, import
or process these chemicals, and would provide EPA an opportunity to review new
uses and take any action needed to protect human health or the environment.
34 For more information on the enforcement action against Dover Chemical, see
http://www.epa.gov/compliance/resources/cases/civil/tsca/doverchemical.html.
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6.2—Review of Chemical Action Plans
• In August 2012, announced a settlement with INEOS Chlor Americas, Inc,
requiring them to end the importation of SCCPs into the U.S.35
• Further evaluate action under TSCA Section 5 and Section 6(a) for medium and
long chain chlorinated paraffins.
OW's Findings
SCCPs are no longer manufactured in the U.S., and only a single manufacturer reported a
very small discharge of polychlorinated alkanes (which may include SCCP) to TRI in 2011. In
addition, EPA has taken action against some companies importing SCCPs into the U.S.
However, SCCPs have been used in metal working industries and have the potential to be
released into wastewater.
6.2.3 Additional Review of Long-Chain PFCs
Two PFCs have gained recent attention due to their persistence in the environment and
their ability to bioaccumulate in the food chain: perfluorooctyl sulfonate (PFOS) and
perfluorooctanoic acid (PFOA). This section focuses on PFOA discharges, because PFOS is no
longer manufactured in the U.S.; industries have nearly completely replaced it with shorter-chain
substitutes, such as perfluorobutane sulfonate (PFBS), except in some niche markets (U.S. EPA,
2009a, 2012d). For additional background on PFCs, see Section 6.2.2.6.
PFOA continues to be synthetically manufactured, imported, and used in the U.S. (U.S.
EPA, 2009a). In addition to the data provided in the PFCs CAP, OW also reviewed data
supporting OPPT's 2010/2015 PFOA Stewardship Program (Stewardship Program). The
Stewardship Program was developed to help minimize the potential impact of PFOA in the
environment by asking manufacturing companies to voluntarily commit to reducing PFOA
emissions and product content by 95 percent by 2010. Additionally, companies that chose to
participate in the program would work to eliminate PFOA emissions and product content by
2015 (U.S. EPA, 2012d).
The following sections present OW's findings on PFOA, including an overview of
manufacturing and use, a summary of the OPPT 2010/2015 PFOA Stewardship Program, and a
review of available discharge data and wastewater treatment options for PFOA.
6.2.3.1 Overview of Manufacture and Use of PFOA
PFOA is a long-chain perfluoroalkyl carboxylate (PFAC). PFACs are synthetic chemicals
that do not occur naturally in the environment. PFACs also include higher homologues, salts, and
PFOA precursors. PFOA is an eight-carbon chain length chemical. Higher homologues are
chemicals with similar structure to PFOA but with nine or more carbons in the chain (U.S. EPA,
2012d). PFOA chemical precursors are chemicals that can break down to form PFOA (U.S. EPA,
2012d).
35 For more information on the settlement with INEOS Chlor Americas, Inc., see
http://www.epa.gov/compliance/resources/cases/civil/tsca/ineoschlor.html.
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The recent focus of industry and environmental groups has been on PFOAs and their
fluorochemical precursors, which can degrade or metabolize to form perfluorocarboxylic acids
(PFCAs). Fluoropolymers, fluorotelomers, and fluorotelomer-based compounds are precursors to
PFOA and the main source of PFOA in the environment.36 PFOA (see chemical structure in
Figure 6-9) has a molecular formula of CyFisCOOH.
F F F F F F O
FF FF FF
Figure 6-9. Perfluorooctanoic Acid (CAS Number: 335-67-1)
Plants primarily manufacture PFOA as an aqueous dispersion agent subsequently used
for the manufacture of fluoropolymers. OW reviewed the PFCs CAP to determine the industrial
categories manufacturing and using PFOA and its precursors (U.S. EPA, 2009a). PFOA and its
fluorotelomer precursors are manufactured at facilities regulated by 40 CFR Part 414 (OCPSF).
In addition to manufacturing, the degradation of fluorotelomers can also unintentionally
result in the production of PFOA. For example, some residual monomer chemicals from the
telomer manufacturing process such as telomer alcohols and telomer iodides may remain in the
final product and break down into PFOA (U.S. EPA, 2012d). These fluorotelomer products are
likely used in products that require even flow, which may include paints, coatings, cleaning
products, and fire-fighting foams. Both manufacturers and consumers apply (spray) these
products in after-market uses such as carpet treatments and water repellent sprays (U.S. EPA,
2009a). Examples of industrial categories that use PFOA and its precursors include:
• Automotive;
• Defense/aerospace;
• Power generation;
• Pollution control;
• Electronics/telecommunications;
• Chemical/petrochemicals;
• Consumer products such as cookware;
• Building/construction;
• Semiconductors;
• Textiles; and
• Paper products.
36 Fluoropolymers have thousands of important manufacturing and industrial applications such as plastic gears,
gaskets and sealants, and pipes and tubing. Fluorotelomers are used to make polymers that impart resistance to soil,
stain, grease, and water to coated articles. Consumers and commercial applicators in after-market uses such as carpet
treatment and water repellent sprays use fluorotelomer-based compounds (U.S. EPA, 2009a).
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6.2—Review of Chemical Action Plans
6.2.3.2 Industry Trends Observed in the OPPT 2010/15 PFOA Stewardship
Program
In 2006, eight major PFOA manufacturers joined the OPPT Stewardship Program. They
committed to reducing facility emissions (including water discharges) and product content of
PFOA, precursors, and higher homologues by 95 percent by 2010, and to work toward
eliminating emissions and product content of these chemicals by 2015. The PFOA Stewardship
Program also developed a non-exhaustive list of PFOA precursors, PFOA salts, and higher
homologues. The companies that participate in the PFOA Stewardship Program are (U.S. EPA,
2012d):
• 3M/Dyneon;
• Arkema, Inc.;
• Asahi Glass Company;
• BASF Corporation;
• Clariant Corporation;
• Daikin America, Inc.;
• E.I. DuPont de Nemours and Company; and
• Solvay Solexis.
These companies submit annual progress reports on their reductions of PFOA, PFOA
precursors, and higher homologues in facility emissions and product content.
OW contacted OPPT personnel to obtain additional information on the discharge data
collected as part of the program. The OPPT contact stated that the eight companies participating
in the program likely supply 80 percent of the market with PFOA and PFOS. Because the
Stewardship Program aims to decrease the manufacture and discharge of these chemicals, the
manufacturers are transitioning to using C4 and C6 length chemicals. However, OPPT
determined that C8 chemicals are still imported and used in the U.S. Therefore, the OPPT
contact stated, manufacturing of these chemicals in the U.S. has decreased, but the discharges
have not. C8 chemicals are manufactured in Italy, India, Russia, and China. Companies in the
U.S. continue using C8 chemicals because they are more effective and cost half as much as the
C4 and C6 chemicals produced in the U.S. (Libelo, 2012).
OPPT confirmed that all of the large manufacturing facilities are participating in the
Stewardship Program and monitoring for PFOA and other C8 chemicals. However, hundreds of
users continue to apply PFOA to products such as cookware and clothes. The users have not all
been identified and are not monitoring wastewater discharges for PFOA or PFOS (Libelo, 2012).
Additionally, OPPT determined that larger facilities manufacturing PFOA and other
PFCs likely have onsite wastewater treatment systems. Medium or smaller facilities send
wastewater to publicly owned treatment works (POTW) or collect it in drums and send it offsite
in batches for treatment (Libelo, 2012). The concentration of PFCs in wastewater discharged
from medium and smaller facilities to surface water and POTWs has not been measured, based
on available data from OPPT and the DMR Loading Tool.
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OPPT confirmed that there are 12 facilities monitoring discharges for PFOA and PFOS.
Additionally, some states include PFCs monitoring requirements in NPDES discharge permits,
namely West Virginia, Ohio, New Jersey, Alabama, and Minnesota (Libelo, 2012).
6.2.3.3 Available Data on PFCs in Industrial Wastewater Discharges
OW collected publicly available data characterizing PFCs in industrial discharges.
Specifically, OW reviewed the docket supporting the PFOA enforceable consent agreement
(EGA) process. OPPT used the EGA process to identify and generate information to strengthen
its PFOA draft risk assessment. Materials used and generated by the PFOA EGA are available in
docket EPA-HQ-OPPT-2003-0012. The docket contains reports provided by DuPont Chambers
Works to document its progress in meeting its commitments to the EPA 2010/15 PFOA
Stewardship Program. In 2005, Chambers Works implemented a sampling program, focused on
wastewater discharges, to measure the effectiveness of the reduction efforts. OW reviewed these
monthly discharge data.
Additionally, OW searched the Envirofacts website and DMR Loading Tool to identify
publicly available PFOA discharge data and found data for four facilities:
• DuPont Chambers Works in Deepwater, New Jersey;
• 3M Decatur Plant in Decatur, Alabama;
• Daikin America, Inc. in Decatur, Alabama; and
• E.I. DuPont de Nemours and Company in Chesterfield County, Virginia.
The following subsections present the PFC discharge data that OW identified for these
four facilities. To put these concentrations into context (because PFCs do not have ELGs or safe
drinking water standards), OW compared concentrations of PFOA in wastewater discharges to
the Provisional Health Advisory (PHA) PFOA drinking water concentration of 0.4 |ig/L (U.S.
EPA, 201 Ic), as shown in Table 6-37 through Table 6-41. EPA has also established a PHA of
0.2 ug/L for one additional PFC, perfluorooctanesulfonate (U.S. EPA, 201 Ic). PHAs are not
legally enforceable by federal standards; however, OW recommends taking action to reduce
PFOA concentrations in drinking water at levels above the PHA concentration.
DuPont Chambers Works Facility—Deepwater, New Jersey (NJ0005100)
The OPPT EGA docket includes DuPont's Status Report on PFOA Emissions Reductions
and Data Summary for 2009 for the Chambers Works Manufacturing Facility (URS Corporation,
2010). The facility has been working to reduce PFOA emissions through process improvements
and source elimination. In 2006, DuPont committed to participate in the EPA 2010/2015 PFOA
Stewardship Program. From 2000 to 2008, Chambers Works reduced PFOA emissions by 95
percent.
As described in DuPont's 2009 status report, site process areas at DuPont Chambers
Works associated with PFOA include (URS Corporation, 2010):
• Fluoroeslastomers (DPE): PFOA is a polymerization aid in the manufacture of
specialty fluoroelastomers and perfluoroelastomers. In 2001, the site discontinued
PFOA used in the standard fluoroelastomers, and in 2004 it installed a carbon
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
treatment system to treat washwaters and process cleanouts for the specialty
fluoroelastomer and perfluoroelastomer manufacturing process.
• Fluorotelomers: PFOA is present in trace quantities as an unintended byproduct in
portions of the fluorotelomer manufacturing process. The amounts of PFOA in
fluorotelomer intermediates, while low, vary from levels below detection to
concentrations in the parts per million.
• Chambers Works Wastewater Treatment Plant (WWTP): PFOA is present in trace
quantities in some commercial wastewater streams that this central waste
treatment facility accepts. PFOA continues to be used as a processing aid by
industry and can be present as an unintended by-product in other wastestreams. In
addition, PFOA is present in wastewaters from the Chambers Works onsite
landfill leachate and groundwater treatment system. (Since 2003, many PFOA-
containing wastewater streams to the WWTP have been eliminated through
treatment at the generation site or finding an alternative treatment).
DuPont Regional Analytical Services analyzed wastewater PFOA concentrations
according to a laboratory standard operating procedure. The analytical method uses liquid
chromatography/tandem mass spectrometry (LC/MS/MS). The sampling program focuses on
measuring wastewater discharges from the Chambers Works Complex, specifically outfall
DSN662 (662), the treated effluent from the WWTP.
Table 6-37 shows the average monthly concentrations of PFOA for 2006 through 2009
for outfall 662. Table 6-37 also includes the average concentration for each year. It is clear that
the concentrations are decreasing, but all monthly average concentrations exceed the 0.4 jig/L
drinking water PHA. Table 6-38 shows some detailed weekly discharge data for 2010 and for
one month in2011 for outfall 662, which continue to exceed the PHA. On three occasions in
2010-2011, the PFOA concentration spiked to concentrations higher than the 2009
concentrations.
Table 6-37. Mean DuPont Chambers Works Monthly PFOA Concentrations and Mass
Loadings at Outfall 662, 2006-2009
Year
2006
Month
January
February
March
April
May
June
July
August
September
October
November
December
Concentration
(Mg/L)
26
27.7
36.2
51
39
55.8
40
70
66
58
98
39
Estimated Mass
(Ib/day)
3.74
3.15
3.54
5.51
3.29
4.17
4.43
5.62
7.57
5.28
6.76
4.1
Average Concentration for
the Reporting Year
(HS/L)
50.6
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Table 6-37. Mean DuPont Chambers Works Monthly PFOA Concentrations and Mass
Loadings at Outfall 662, 2006-2009
Year
2007
2008
2009
Month
January
February
March
April
May
June
July
August
September
October
November
December
January
February
March
April
May
June
July
August
September
October
November
December
January
February
March
April
May
June
July
August
September
October
November
December
Concentration
(Mg/L)
66.3
56.8
65.3
44.6
30.9
41.2
24.3
31.1
58.1
40.6
20.3
23.5
30.3
41.8
43.1
18.6
18.1
30.4
25.1
21.1
19.2
13.1
10.2
7.6
3.5
4.1
4.4
5.7
8.2
13.4
10.8
10.7
12.5
14.4
21.2
28.4
Estimated Mass
(Ib/day)
6.48
5.39
6.26
4.47
2.74
3.59
2.35
3.01
4.48
3.71
1.9
2.33
3.01
4.2
4.12
1.72
1.7
2.87
2.49
1.99
1.7
1.19
0.86
0.69
0.3
0.36
0.36
0.45
0.69
1.1
0.8
0.89
0.97
1.25
1.69
2.39
Average Concentration for
the Reporting Year
(HS/L)
41.9
23.2
11.4
Source: EPA-HQ-OPPT-2003-0012-1315.
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
Table 6-38. Detailed DuPont Chambers Works Monthly PFOA Concentrations and Mass
Loadings at Outfall 662, 2010-2011
Date
1/11/2010
1/18/2010
1/25/2010
2/1/2010
2/8/2010
2/15/2010
2/22/2010
4/5/2010
4/12/2010
4/19/2010
4/26/2010
6/1/2010
6/7/2010
6/14/2010
6/21/2010
6/28/2010
7/6/2010
7/12/2010
7/19/2010
7/26/2010
9/7/2010
9/13/2010
9/20/2010
9/27/2010
10/4/2010
10/11/2010
10/18/2010
10/25/2010
12/6/2010
12/13/2010
12/20/2010
12/27/2010
4/4/2011
4/11/2011
4/18/2011
4/25/2011
Concentration of PFOA (Total, (ig/L)
14.6
9.87
8.7
7.83
7.67
10.6
19.7
10.3
11.2
10.5
7.7
10
21.7
20.4
9.85
14
13.8
10.7
41.5a
24.4
13
12.9
8.28
12.4
15.6
35.4a
16.4
8.46
5.32
5.19
19.5
42.4a
7.49
7.25
5.61
7.24
Sources: EPA-HQ-OPPT-2003-0012-1307, 1313, 1317, 1318, 1319, 1321.
a DuPont 2010-2011 PFOA concentrations greater than the highest 2009 PFOA concentrations (28.4 ug/L)
reported in Table 6-37.
3M Decatur Plant (AL0000205)
EPA's Envirofacts website contains 2011 discharge data for the 3M Decatur plant. The
3M Decatur plant is a major discharger that monitors for six PFCs from outfall 001, the
discharge of process wastewater. Table 6-39 summarizes the 2011 minimum, maximum, and
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
mean concentrations for the six PFCs monitored. As shown in Table 6-39, the 2011 PFOA
concentrations exceed the 0.4 |ig/L drinking water PHA, and the perfluorooctanesulfonate
concentrations exceed the 0.2 ug/L drinking water PHA.
Table 6-39. Summary of the 2011 Maximum Concentration Data for 3M Decatur Plant,
Outfall 001 (Process Wastewater Discharge)
Pollutant
Perfluorobutanesulfonamide
Perfluorobutanoic acid
Perfluorobutanoicsulfonate
Perfluorooctanesulfonamide
Perfluorooctanesulfonate
Perfluorooctanoic acid (PFOA)
Outfall
001
001
001
001
001
001
Minimum
Concentration
(Hg/L)
23.4
1.54
17.7
0.816
10.7a
1.76b
Maximum
Concentration
(HS/L)
51.9
3.05
74.1
1.58
11.5a
4.17b
Mean
Concentration
(HS/L)
33.3
1.94
46.3
1.08
11. la
3.24b
Source: Envirofacts.
a Concentrations greater than the 0.2 ug/L PHA.
b Concentrations greater than the 0.4 ug/L PHA.
Daikin America, Inc. (AL0064351)
EPA's Envirofacts website contains 2011 discharge data for the Daikin America, Inc.,
plant. The Daikin plant is a major discharger that monitors for PFOA from outfalls 001, 002, and
003. Table 6-40 summarizes the 2011 minimum, maximum, and mean PFOA concentrations. All
2011 PFOA concentrations exceed the 0.4 |ig/L PHA.
Table 6-40. Summary of the 2011 Maximum PFOA Concentration Data for Daikin
America, Inc.
Outfall
001
002
003
Minimum
Concentration (jig/L)
1.3
5.39
4.54
Maximum
Concentration (jig/L)
7.59
25
96.9
Mean Concentration
(HS/L)
5.09
15.2
50.8
Source: Envirofacts.
E.I. DuPontde Nemours (VA0004669)
EPA's DMR Loading Tool contains 2011 discharge data for the E.I. DuPont de Nemours
plant. The DuPont plant is a major discharger that monitors for PFOA from two outfalls, 001O
and 101O. Table 6-41 presents the minimum, maximum, and mean of the 2011 monthly average
PFOA concentrations reported in the DMR Loading Tool. For this particular facility, only one
monitoring period from outfall 101O exceeded the 0.4 |ig/L PHA.
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
Table 6-41. Summary of the 2010 Average PFOA Concentration and Data for El DuPont
de Nemours
Outfall
001O
101O
Minimum
Concentration (jig/L)a
0.03
0.04
Maximum
Concentration (jig/L)a
0.1
0.67b
Mean Concentration
(Hg/L)a
0.05
0.14
Source: DMR Loading Tool.
a Minimum and maximum concentrations represent an individual monthly monitoring period. Mean concentration
is an annual mean calculated by the DMR Loading Tool across all monitoring periods.
b Concentrations greater than the 0.4 ug/L PHA. Only one month in 2011 exceeded the PHA.
6.2.3.4 PFOA Wastewater Treatment
OPPT has investigated the fate of PFCs in wastewater and found that discharges of PFCs
from POTWs have increased with the increase in products manufactured with or containing
PFCs. Larger facilities manufacturing or using PFCs likely have onsite wastewater treatment,
while medium sized facilities likely send wastewater to a POTW. Smaller facilities may collect
wastewater in drums in a batch process. CWT and on-site treatment typically include biological
treatment and incineration. However, OPPT determined that biological treatment systems are not
successful in treating these chemicals. Because the wastewater likely contains precursors to
PFOA and PFOS, which then degrade in the biological treatment plant, the effluent PFOA and
PFOS concentrations are higher than the influent concentrations. Additionally, PFCs with more
than eight carbons are more likely to stay in treatment sludge and be land-applied. OPPT
identified incineration as an effective but energy-intensive treatment option for wastewater
containing PFOA and other C8 chemicals (Libelo, 2012).
OGWDW's Drinking Water Treatability Database (TDB) collected information on
technologies that treat PFOA in drinking water. Although the data evaluated how effective
technologies were at removing PFOA from a cleaner matrix (drinking water compared to
wastewater), the technologies might apply to wastewater as a polishing step following pre-
treatment.
The TDB found that granular activated carbon (GAC) and ultraviolet irradiation, at
wavelengths in the 185-200 nm range, remove PFOA from drinking water. OGWDW estimated
that GAC could remove up to 100 percent of PFOA from drinking water. However, GAC
treatment performance can vary based on water quality and treatment characteristics. According
to the TDB, the bench-scale removal studies of ultraviolet irradiation using wavelengths in the
range of 185-220 nm reported PFOA removals ranging from 62 to 90 percent (U.S. EPA,
2012e).
6.2.4 Summary of O W's Findings from Chemical A ction Plans Review
In reviewing OPPT's 10 CAPs, OW identified that one chemical category is being phased
out of U.S. commerce. EPA does not intend to pursue further review for this class of chemicals:
Penta, Octa, and Decabromodiphenyl Ethers (PBDEs).
OW found that the following chemicals or classes of chemicals have continued
production and/or known or potential wastewater discharges:
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
Benzidine Dyes. Dye production has been declining over the past decade due to
an increase in imported finished textiles and, as a result, OPPT is focused on
consumer exposure to finished products. However, based on the available
information, OW has found that benzidine dyes may still be present in industrial
wastewater discharge from several regulated industrial categories including
OCPSF, textiles, leather tanning and finishing, pulp, paper, and paperboard, and
ink formulating.
BPA. BPA is not currently regulated by existing ELGs, but is a TRI-listed
chemical. OW reviewed BPA discharge data reported to TRI in 2011 and
identified several industrial categories with discharges. The quantity and total
TWPE of reported BPA discharges is low (less than 15 Ib-eq/yr total); however,
the current TWF for BPA is over 10 years old, and therefore does not take into
consideration new studies showing that endocrine-related effects may occur at
much lower doses.
HBCD. HBCDs are used in the manufacture of products covered by several point
source categories, but are not currently regulated by any of the existing ELGs.
OW was not able to identify specific wastewater generation information from the
CAP or other readily available data sources, but did identify, based on studies in
Europe, that there could be significant discharges of HBCD to wastewater.
Toluene Diamine and Methyl Diphenyl Diamine. During its review of the
Methylene Diphenyl Diisocyanate (MDI) and Toluene Diphenyl Diisocyanate
(TDI) CAPs, OW determined that, in the presence of water, TDI hydrolyzes to
toluene diamine and MDI hydrolyzes to methyl diphenyl diamine, suggesting that
these hydrolysis byproducts may be present in industrial wastewater. OW
reviewed TRI data and identified one facility that discharged toluene diamine in
2011, but at low levels. OW was not able to identify any readily available
discharge data for methyl diphenyl diamine.
NP/NPEs. NPs and NPEs are used in the manufacture of products covered by
several industrial point source categories, but are not currently regulated by
existing ELGs. Though OPPT has initiated a voluntary phase out of their use in
industrial laundry detergent by 2014 and is considering similar initiatives for
other NPE-containing products, OW has identified that NP and NPEs are still
likely present in industrial wastewater discharge. OW was not able to find any
readily available wastewater generation or discharge data in the U.S., however,
data from the European Union and Canada indicate environmental releases to
water during the manufacture and use of NP and NPEs.
PFCs. OPPT identified several manufacturers that are discharging PFCs, to
surface waters at levels above a provisional health advisory level for drinking
water. ELGs do not currently regulate PFCs. OPPT also investigated potential
wastewater treatment options and determined that biological treatment systems
are not successful in treating PFOA, a PFC of interest due to its persistence in the
environment and ability to bioaccumulate in the food chain. OGWDW drinking
water treatment technology data suggest that GAC and UV irradiation may be a
viable solution for eliminating PFOA in drinking water, but it is unclear if that
technology would effectively translate to an industrial wastewater matrix.
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
• Phthalates. OW found that 40 CFR Parts 414 (OCPSF) and 437(CWTs) currently
regulate three of the eight phthalates listed in the CAP. Further, two of the
regulated phthalates are also TRI listed chemicals. Review of DMR and TRI data
show that there are several other point source categories besides OCPSF and
centralized waste treatment that discharge phthalates, though at concentrations
orders of magnitude lower than the existing ELGs' limits.
OW was not able to determine if the remaining five unregulated phthalates are
present in industrial wastewater discharge. As indicated in the CAP, OPPT
intends to add the other six phthalates to TRI, which may provide OW with data
on the sources and quantity of their discharge.
• SCCPs. SCCPs are no longer manufactured in the U.S. and EPA has taken action
against some companies importing SCCPs into the U.S. Although OW was not
able to readily identify data to characterize the presence of SCCPs in industrial
wastewater discharge, SCCPs have been used in metal working industries and
may have the potential to be released into wastewater.
6.2.5 References for Review of Chemical A ction Plans
1. Environment Canada. 2001. Priority Substances List Assessment Report: Nonylphenol
anditsEthoxylates. (April). EPA-HQ-OW-2010-0824. DCN 07757.
2. Libelo, Laurence, Toni Krasnic. 2012. Telephone Communication between Laurence
Libelo, U.S. EPA PFOA Stewardship Program, and Elizabeth Sabol, Eastern Research
Group, Inc. Re: Long Chain PFCs Discharge Data. (March 16). EPA-HQ-OW-2010-
0824. DCN 07728.
3. Kirk-Othmer. 2003. Kirk-Othmer Encyclopedia of Chemical Technology. (September
19). Available online at: http://onlinelibrary.wiley.com/book/10.1002/0471238961. EPA-
HQ-OW-2010-0824. DCN 07758.
4. ECHA. 2009. European Chemicals Agency. Data on Manufacture, Import, Export Uses
and Releases ofHBCDD as well as Information on Potential Alternatives to Its Use.
(December). Available online at:
http://echa.europa.eu/doc/consultations/recommendations/tech_reports/tech_rep_hbcdd.p
df. EPA-HQ-OW-2010-0824. DCN 07759.
5. EU. 2002. European Union Risk Assessment Report. 4-Nonylphenol (Branched) and
Nonylphenol. 2nd Priority List Volume: 10. EUR 20387 EN. Available online at:
http://www.bfr.bund.de/cm/343/4_nonylphenol_und_nonylphenol.pdf. EPA-HQ-OW-
2010-0824. DCN 07760.
6. Inside EPA. 2013. EPA Urged to Require Additional PFOA Data from DuPont to Aid
Rules. (April 19). EPA-HQ-OW-2010-0824. DCN 07761.
7. URS Corporation. 2010. Status Report on PFOA Emissions Reductions and Data
Summary for 2009 DuPont Chambers Works Deepwater, New Jersey. (May). EPA-HQ-
OW-2010-0824. DCN 07762.
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Section 6—New Data Sources and Hazard Analyses
6.2—Review of Chemical Action Plans
8. U.S. EPA. 2000. Technical Development Document for the Final Action Regarding
Pretreatment Standards for the Industrial Laundries Point Source Category (Revised
March 2000). (March). EPA-821-R-00-006. EPA-HQ-OW-2010-0824. DCN 07763.
9. U.S. EPA. 2005. Ambient Aquatic Life Water Quality Criteria-Nonylphenol Final.
Washington, DC. (December). EPA-822-R-05-005. EPA-HQ-OW-2010-0824. DCN
07764.
10. U.S. EPA. 2006. Toxic Substance Control Act (TSCA) Chemical Substance Inventory.
2006 Inventory Update Rule Public Database. Washington, D.C. Available online at:
http://cfpub.epa.gov/iursearch/. EPA-HQ-OW-2010-0824. DCN 07765.
11. U.S. EPA. 2007. Toxic Weighting Factor Database. Washington, D.C. (September).
EPA-HQ-OW-2008-0517-0713.
12. U.S. EPA. 2009a. Long-Chain PerfluorinatedChemicals (PFCs) Action Plan.
Washington, D.C. (December 30). Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/pfcs_action_planl230_09.pdf. EPA-
HQ-OW-2010-0824. DCN 07766.
13. U.S. EPA. 2009b. PolybrominatedDiphenylEthers (PBDEs) Action Plan. Washington,
D.C. (December 30). Available online at:
http://www.epa.gov/oppt/existingchemical s/pubs/actionplans/pbdes_ap_2009_1230_fmal
.pdf EPA-HQ-OW-2010-0824. DCN 07767.
14. U. S. EPA. 2009c. Short-Chain Chlorinated Paraffins (SCCPs) and Other Chlorinated
Paraffins Action Plan. Washington, D.C. (December 30). Available online at:
http://www.epa.gov/oppt/existingchemical s/pubs/actionplans/sccps_ap_2009_1230_final.
pdf. EPA-HQ-OW-2010-0824. DCN 07768.
15. U.S. EPA. 2010a. Dyes Derivedfrom Benzidine andlts Congeners Action Plan.
Washington, D.C. (August 18). Available online at:
http://www.epa.gov/oppt/existingchemical s/pubs/actionplans/DCB%20Action%20Plan_0
6232010.noheader.pdf. EPA-HQ-OW-2010-0824. DCN 07769.
16. U.S. EPA. 2010b. BisphenolA Chemical Action Plan. Washington, D.C. (March 29).
Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/bpa_action_plan.pdf EPA-
HQ-OW-2010-0824. DCN 07770.
17. U.S. EPA. 2010c. Hexabromocyclododecane (HBCD) Action Plan. Washington, D.C.
(August 18). Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/RIN2070-
AZ10_HBCD%20action%20plan_Final_2010-08-09.pdf. EPA-HQ-OW-2010-0824.
DCN 07771.
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6.2—Review of Chemical Action Plans
18. U.S. EPA. 2010d. Nonylphenol (NP) andNonylphenolEthoxylates (NPEs) Action Plan.
Washington, D.C. (August 18). Available online at:
http://ex change, regulations. gov/exchange/sites/default/files/doc_files/Nonylphenol%20A
ction%20Plan%20Final_0.pdf. EPA-HQ-OW-2010-0824. DCN 07772.
19. U.S. EPA. 2011 a. Methylene Diphenyl Diisocyanate (MDI) and Related Compounds
Action Plan. Washington, D.C. (April). Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/mdi.html. EPA-HQ-OW-
2010-0824. DCN 07774.
20. U.S. EPA. 2011b. Toluene Diisocyanate (TD1) and Related Compounds Action Plan.
Washington, D.C. (April). Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/tdi.pdf. EPA-HQ-OW-
2010-0824. DCN 07773.
21. U.S. EPA. 201 Ic. 2011 Edition of the Drinking Water Standards and Health Advisories.
Washington, D.C. (January). Available online at:
http://water.epa.gov/action/advisories/drinking/upload/dwstandards201 l.pdf. EPA 820-
R-l 1-002. EPA-HQ-OW-2010-0824. DCN 07775.
22. U.S. EPA. 2012a. U.S. EPA 's Office of Pollution Prevention and Toxic Substances, Basic
Information. Washington, D.C. (July 10). Available online at:
http://www.epa.gov/oppt/pubs/opptabt.htm. EPA-HQ-OW-2010-0824. DCN 07776.
23. U.S. EPA. 2012b. Toxic Weighting Factors Methodology. Washington D.C. (March).
EPA-820-R-12-005.EPA-HQ-OW-2010-0824-0004.
24. U.S. EPA. 2012c. DfE Alternatives Assessment for Nonylphenol Ethoxylates. Washington
D.C. (May). Available online at: http://www.epa.gov/oppt/dfe/pubs/projects/npe/aa-for-
NPEs-fmal-version5-3-12.pdf EPA-HQ-OW-2010-0824. DCN 07779.
25. U.S. EPA. 2012d. 2010/2015 PFOA Stewardship Program. (August 8). Available online
at: http://www.epa.gov/oppt/pfoa/pubs/stewardship/index.html.EPA-HQ-OW-2010-0824
DCN 07780.
26. U.S. EPA. 2012e. Drinking Water Treatability Database. (August 16). Available online
at: http://iaspub.epa.gov/tdb/pages/general/home.do. EPA-HQ-OW-2010-0824. DCN
07781.
27. U.S. EPA. 2012f DecaBDE Phase-out Initiative. (July 25). Available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/deccadbe.html. EPA-HQ-
OW-2010-0824. DCN 07782.
28. U.S. EPA. 2012g. Phthalates Action Plan. Washington D.C. (March 14). Available
online at:
http://www.epa.gov/oppt/existingchemical s/pubs/actionplans/phthalates_actionplan_revis
ed_2012-03-14.pdf EPA-HQ-OW-2010-0824. DCN 07784.
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6.2—Review of Chemical Action Plans
29. U.S. EPA. 2014a. BisphenolA Alternatives in Thermal Paper. Washington D.C.
(January). Available online at: http://www.epa.gov/oppt/dfe/pubs/projects/bpa/bpa-
report-complete.pdf. EPA-HQ-OW-2010-0824. DCN 07778.
30. U.S. EPA. 2014b. An Alternatives Assessment for the Flame Retardant
DecabromodiphenylEther (DecaBDE). Washington D.C. (January). Available online at:
http://www.epa.gov/oppt/dfe/pubs/projects/decaBDE/deca-report-complete.pdf. EPA-
HQ-OW-2010-0824. DCN 07783.
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Wastewater Discharges Related to
Air Pollution Control Not Currently Covered by ELGs
6.3 Identification of Wastewater Discharges Related to Air Pollution Control Not
Currently Covered by ELGs
EPA is reviewing federal air pollution control regulations as a new source of data that
EPA will use to augment its traditional toxicity rankings analysis (TRA) conducted in the odd-
year reviews. Specifically, EPA is examining air pollution control regulations to determine if
they result in the generation of unregulated wastewater discharges or changes to currently
regulated wastewater streams (containing new pollutants of concern). For example, the wet
scrubbers for flue-gas desulfurization at steam electric generating plants generate a wastewater
discharge that is regulated by 40 CFR Part 423 (Steam Electric Power Generation) effluent
limitations guidelines and standards (ELGs); however, the only pollutants regulated by the
current ELGs are total suspended solids, oil and grease, and pH. Discharges of flue-gas
desulfurization (FGD) wet scrubber blowdown contain toxic metal pollutants, which are now the
focus of the proposed Steam Electric Rulemaking (78 FR 34432).
EPA's review revealed that industry compliance with air regulations potentially result in
the generation of metal-containing wastewater discharges not included in the scope of the
existing petroleum refinery ELGs (40 CFR Part 419).
6.3.1 Air Pollution Control Regulations Background
Under the Clean Air Act (CAA), EPA controls emissions of air pollutants through several
programs, including New Source Performance Standards (NSPS) and National Emission
Standards for Hazardous Air Pollutants (NESHAP).
EPA reviewed NSPS and NESHAP requirements to identify industries that may generate
wastewater discharges due to complying with the regulations. EPA conducted this review by
evaluating rules promulgated or revised after 1990, as well as supporting documentation
published in the Federal Register (FR). In some cases, the rules supplemented older rules from
the 1970s or 1980s, and EPA reviewed the older documentation as well. EPA prioritized the
review of rules enacted or revised after 1990 because many ELGs were established before that
year. EPA reviewed the air regulation documentation to determine if affected facilities were
likely to use wet air pollution control devices to meet the requirements of the rule.
For many rules, the NSPS and NESHAP language specifically prescribes wet air
pollution control devices, such as wet scrubbers. However, the rules do not always specify a
means of compliance, or may specify more than one acceptable type of control device. Through
evaluation of the rules and supporting documentation, EPA identified which rules may result in
wastewater discharges (e.g., an air regulation that specifically prescribes wet air pollution
control) from industries without existing ELGs or from industries whose wastewater discharges
are not in the scope of the existing ELGs.
6.3.1.1 NSPS
Section 111 of the CAA requires EPA to develop "standards of performance" for new
stationary sources of air pollutant emissions—i.e., NSPS. These regulations apply to specific
emission units such as boilers, storage tanks, and landfills. NSPS apply to newly built emission
units, but because the definition of "new source" also includes modifications to existing sources,
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Wastewater Discharges Related to
Air Pollution Control Not Currently Covered by ELGs
some existing units may also be subject to NSPS. NSPS primarily control emissions of criteria
pollutants such as sulfur dioxide (862), nitrogen oxides (NOX), volatile organic compounds
(VOCs), particulate matter (PM), lead, and carbon monoxide (CO).
6.3.1.2 NESHAP
Section 112 of the CAA requires EPA to control emissions of hazardous air pollutants
from a published list of industrial sources (i.e., source categories) through NESHAP regulations.
EPA maintains a list of 187 specific hazardous air pollutants currently regulated under the
NESHAP program.37 CAA Section 112(d) states that EPA must promulgate regulations
establishing emission standards (NESHAPs) for each category or subcategory of major sources
and area sources of hazardous air pollutants (HAPs) listed pursuant to CAA Section 112(c). The
standards must use Maximum Achievable Control Technology (MACT) and require the
maximum degree of emission reduction that the EPA determines to be achievable by each
particular source category. The definition of MACT differs for new and existing sources.
6.3.2 Review of NSPS and NESHAPs
EPA reviewed NSPS and NESHAPs to identify those regulations that could result
in wastewater discharges. EPA next determined whether the industries to which the NSPS and
NESHAP applied were covered by existing ELGs. For industries covered by an existing ELG,
EPA explored if the ELG applied to the wastewater discharge from air pollution control. Table
6-44 through Table 6-47, presented at the end of this section, list the results of EPA's review.
EPA examined language in the regulations and supporting documentation and noted which rules
specified air pollution control that would potentially generate wastewater (e.g., use of a wet
scrubber). If the air regulation included language that mentioned wet air pollution control as an
option, EPA designated the affected industries as "potentially resulting in a wastewater impact
from the air regulation" (see Table 6-44 through Table 6-46 for a list of these air regulations and
affected industries). If the air regulation specifically prescribed dry air pollution control, EPA
designated the affected industries as "less likely to have wastewater impacts" (see Table 6-47 for
a list of these air regulations and affected industries).
Air Regulations Potentially Resulting in Wastewater Discharges in Industries with No
Existing ELGs
Of the 38 NESHAP rules and 46 NSPS rules reviewed, EPA found that six rules affected
the following four industries not currently regulated by ELGs:
• Brick and structural clay products manufacturing;
• Perchloroethylene (PCE)-based and petroleum-based dry cleaning;
• Industrial, commercial, and institutional boilers; and
• Industrial, commercial, and institutional steam generating units.
Table 6-44 at the end of this section details how these air regulations relate to these
industries. EPA reviewed available industry and discharge data for these industries and discusses
the results in Sections 6.3.2.1 through 6.3.2.4.
37 The list of 187 regulated pollutants can be found at: http://www.epa.gov/ttn/atw/origl89.html
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Wastewater Discharges Related to
Air Pollution Control Not Currently Covered by ELGs
Air Regulations Potentially Resulting in Wastewater Discharges Not Included in the
Scope of Existing ELGs.
In addition to the industries not currently regulated by ELGs, EPA found that six
NESHAP and NSPS rules affected two industries currently regulated by ELGs, but for which
wet air pollution control discharges were not included in the scope of the existing ELGs:
• Steam electric power generating industry
• Petroleum refineries
Table 6-45 at the end of this section presents air regulations as they relate to these
industries. EPA reviewed available industry and discharge data for these industries and discusses
the results in Sections 6.3.2.5 and 6.3.2.6.
EPA also reviewed 38 other air regulations that it identified as potentially generating
wastewater discharges, presented in Table 6-46 at the end of this section. These regulations may
affect 13 additional industries with existing ELGs. However, EPA has not yet completed
thorough reviews of these air rules as they may affect the related industries. EPA prioritized the
review of air rules for industries without ELGs and for petroleum refining and steam electric
because these industries continually rank high, in terms of TWPE, in EPA's TRA.
Air Regulations with Less Likely Wastewater Impacts
Table 6-47 at the end of this section presents the 34 rules and 23 affected industries EPA
identified as less likely to generate a wastewater stream resulting from their air pollution
controls, based on the air regulations prescription of dry air pollution controls.
6.3.2.1 Brick and Structural Clay Products Manufacturing (Not Currently
Regulated by ELGs)
EPA promulgated the NESHAP for Brick and Structural Clay Products Manufacturing on
May 16, 2003 (68 FR 26689). The HAPs emitted in the brick and structural clay products
manufacturing process and covered by the NESHAP are hydrogen fluoride, hydrogen chloride,
and certain metals, which can be controlled with wet or dry air pollution control. Based on the
brick manufacturing process, the likely pollutants in brick and structural clay manufacturing
wastewater discharges include suspended solids and metals.
EPA searched for data on wastewater discharges from brick manufacturers. Table 6-42
presents the counts of brick and structural clay products manufacturing facilities in the U.S. as of
2012, by SIC code. It also presents the number of brick and structural clay products
manufacturing facilities in the DMR database with discharge data as of 2009. There are 93
facilities in the DMR database; none of them has an individual NPDES permit, and all of them
have general storm water permits.
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Table 6-42. Counts of Brick and Structural Clay Products Manufacturing
Facilities in the U.S.
SIC Code
1455
1459
3251
3255
3259
3271
5032
SIC Code Description
Kaolin & Ball Clay
Clay, Ceramic & Refractory Minerals
Brick & Structural Clay Tile
Clay Refractories
Structural Clay Products
Concrete Block & Brick
Brick, Stone & Related Materials
Total Brick and Clay Manufacturing Facilities
Number of Facilities in
the U.S. (2012)
283
887
399
270
65
1,037
720
3,671
Number of Facilities in
the DMR Database with
Discharge Data Greater
than Zero (2009)
5
14
10
4
0
3
1
37
Sources: Envirofacts and DMRLoads2009_v2.
The fact that the only NPDES permits identified in the above analysis are stormwater
permits suggests that brick manufacturers have no wastewater discharges and use dry air
pollution control or fully recycle any water from wet air pollution control. To confirm that brick
and structural clay products manufacturers do not discharge wastewater other than stormwater,
EPA contacted permit writers of brick and clay manufacturers in Alabama, who confirmed they
had not identified any industrial wastewater discharges at brick and structural clay products
manufacturers (Warren, 2012).
6.3.2.2 Perchloroethylene (PCE)-Based and Petroleum-Based Dry Cleaning (Not
Currently Regulated by ELGs)
EPA promulgated NESHAP for PCE Dry Cleaners on September 22, 1993. On July 27,
2006, EPA revised these standards to account for new developments in production practices,
processes, and control technologies and to reduce PCE emissions beyond the 1993 NESHAP.
From the 1993 and 2006 NESHAP rule documentation, carbon adsorbers and/or refrigerated
condensers control PCE emissions from process vents at dry cleaners and generate wastewater.
A carbon adsorber is a bed of activated carbon that adsorbs PCE from the PCE-
containing vapor stream routed through it. When the carbon adsorber is saturated with PCE, it is
"desorbed" by passing steam through the carbon adsorber. PCE is collected in the steam
condensate from desorption. A typical machine with an existing carbon adsorber is estimated to
generate 1.9 pounds of PCE in wastewater per year. A refrigerated condenser is a vapor recovery
system that cools vapor streams containing PCE. After cooling, the PCE and water are separated,
the PCE is returned to the process, and the condensed water is discharged. A typical dry cleaning
machine controlled with a refrigerated condenser can generate 0.07 pounds of PCE in wastewater
each year (58 FR 49354). As of 1996, the NESHAP required that 3,200 of the 17,400 existing
industrial and commercial facilities subject to the standards must install process vent control
devices (i.e., a refrigerator condenser and/or carbon adsorber) to be in compliance (58 FR
49354). The documentation for the revised 2006 NESHAP did not specifically state any changes
to the estimation of wastewater impacts from wet air pollution control or the number of affected
facilities.
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EPA promulgated NSPS for VOC emissions from dry cleaners using petroleum-based
solvents in 1984. The rule documentation does not clearly identify if wet air pollution control is a
method for controlling VOC emissions and, therefore, does not indicate if this air regulation
results in wastewater discharges. Because EPA is investigating wastewater discharges generated
from air pollution control for PCE-based dry cleaners, EPA included petroleum-based dry
cleaners this review (49 FR 37331).
The TRI and DMR databases do not include wastewater discharge data for dry cleaning
facilities. EPA's Office of Pollution Prevention and Toxic Substances (OPPT) is collecting data
from dry cleaners as part of its TRI expansion sector initiative (U.S. EPA, 2012, see Section 6.4).
If this industry is required to report to TRI, EPA will be able to evaluate the impact of the
discharges of dry cleaners as part of the TRA.
As explained in Section 6.4, EPA proposed pretreatment standards for pollutant
discharges from industrial laundries in 1997. During its study of industrial laundries, EPA
reviewed discharges of some large dry cleaners. EPA found that the dry cleaning process
generates minimal amounts of wastewater, ranging from zero to 0.25 gallons of water per pound
of laundry processed. Further, EPA determined that many facilities are moving away from dry
cleaning because of the hazardous nature of the dry cleaning solvents and the expense of their
disposal. EPA also determined that facilities that do operate dry cleaning units are moving away
from the use of PCE as a solvent in favor of petroleum-based solvents (U.S. EPA, 2000).
Because EPA investigated this industry in 1997, after the air regulations were in effect (1984 and
1993), EPA expects that the review captured discharges from air pollution controls. EPA does
not expect the 2006 revision to the 1993 NESHAP for PCE-based dry cleaners to affect the
wastewater discharges because the air pollution controls for the emissions (carbon adsorbers and
refrigerated condensers) did not change.
6.3.2.3 Industrial, Commercial, and Institutional Boilers (Not Directly Regulated by
ELGs)
EPA promulgated NESHAP for industrial, commercial, and institutional boilers on
January 31, 2013. The regulation potentially regulates emissions of over ten industrial categories
(78 FR 7138). Table 6-43 lists the potentially affected industries and the corresponding point
source category for each. The regulation requires control of carbon monoxide, hydrogen
chloride, mercury, particulate matter, and total selected metals (i.e., arsenic, beryllium, cadmium,
chromium, lead, manganese, nickel, and selenium). It allows the use of a variety of control
technologies, including wet scrubbers, fabric filters, electrostatic precipitators, or any other
controls. In the text of the rule, EPA estimated that the rule would affect 14,136 boilers and
process heaters at 1,700 facilities (78 FR 7138).
Table 6-43. Existing ELGs for Industries Affected by the NESHAP for Industrial,
Commercial, or Institutional Boilers
Industry
Petroleum refineries
Lumber and wood products
Pulp and paper
Applicable Point Source Category
40 CFR Part 419 (Petroleum Refining)
40 CFR Part 429 (Timber Products Processing)
40 CFR Part 430 (Pulp, Paper, and Paperboard)
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Table 6-43. Existing ELGs for Industries Affected by the NESHAP for Industrial,
Commercial, or Institutional Boilers
Industry
Chemical manufacturers
Rubber manufacturers
Plastics manufacturers
Steel works
Electroplating
Motor vehicle parts manufacturers
Electric services
Gas services
Sanitary services
Health services
Educational services
Applicable Point Source Category
40 CFR Part 414 (OCPSF);
40 CFR Part 415 (Inorganic Chemicals Manufacturers);
40 CFR Part 454 (Gum and Wood Chemicals Manufacturing)
40 CFR Part 4 14 (OCPSF);
40 CFR Part 428 (Rubber Manufacturers)
40 CFR Part 4 14 (OCPSF);
40 CFR Part 463 (Plastics Molding and Forming)
40 CFR Part 420 (Iron and Steel Manufacturing)
40 CFR Part 413 (Electroplating);
40 CFR Part 433 (Metal Finishing)
40 CFR Part 433 (Metal Finishing);
40 CFR Part 438 (Metal Products and Machinery)
40 CFR Part 423 (Steam Electric)
NA
40 CFR Part 403 (General Pretreatment Regulations for Existing and
New Sources of Pollution)
40 CFR Part 460 (Hospitals)
NA
NA - Not applicable. Industry does not have a corresponding point source category.
EPA expects that wastewater discharges from boiler air pollution control devices are
commingled and discharged with wastewater from other plant processes. However, EPA has not
evaluated the pollutants in the boiler air pollution control wastewater for these industries.
6.3.2.4 Industrial, Commercial, and Institutional Steam Generating Units (Not
Directly Regulated by ELGs)
EPA promulgated NSPS for large and small industrial, commercial, and institutional
steam generating units on June 19, 1984 (40 CFR 60 Subpart Db) and June 9, 1989 (40 CFR 60
Subpart DC), respectively. The regulations require control of PM, NOX, and SC>2, regardless of
the fuel source, for more than 30 industries. Discharges from these steam generating units are not
regulated by 40 CFR Part 423 (Steam Electric Power Generation) because they do not produce
electric power for distribution and/or sale as their primary purpose (U.S. EPA, 2009). During
EPA's detailed study of the steam electric industry, EPA reviewed discharges from these units
(including cogenerators38). EPA found that, with the exception of certain instances (e.g., certain
subcategories of the Pulp, Paper, and Paperboard ELGs—see 40 CFR Part 430.01 (m)),
wastewaters from these steam units are not specifically regulated by ELGs (i.e., there are no
regulations specifically for discharges from wet air pollution control on steam generating units).
Additionally, EPA discovered that most industrial plants commingle the wastewaters associated
with the air pollution control devices from these steam generating units with wastewater from
other plant processes, which may be treated in the plant's wastewater treatment system. EPA
38 A cogenerator is defined as "a generating plant that produces electricity and another form of useful thermal energy
(such as heat or steam), used for industrial commercial, heating, or cooling purposes" (U.S. DOE, 2006).
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determined that the Steam Electric ELGs are not typically used to set BPJ-based limits for these
discharges; instead, permit writers typically develop discharge limits based on the industry-
specific ELGs (U.S. EPA, 2009).
Generally, the industry-specific ELGs do not explicitly address the wastewater discharges
from the steam generating units, though discharge permits for some of these facilities may
include limits for pollutants in wastewater discharges from the air pollution control devices on
the steam generating units. These discharges are likely captured in the TRA databases in the
plant's specific point source category. However, some discharge permits may not include limits
for these pollutants, in which case these discharges are not captured in the TRA databases.
6.3.2.5 Steam Electric Power Generating Units (Currently Regulated Under 40 CFR
Part 423)
EPA promulgated NSPS for steam generating units in August 1971 (40 CFR 60 Subpart
D) and September 1978 (40 CFR 60 Subpart Da). The rules required control of particulate
matter, nitrogen oxides, and sulfur dioxides from fossil fuel-fired steam generators and electric
utility steam generating units. Additionally, EPA promulgated NESHAP in February 2012 to
control particulate matter, antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead,
manganese, nickel, selenium, hydrogen chloride, sulfur dioxide, and mercury from coal- and oil-
fired steam generating units. Wastewater discharges from these steam generating units are
regulated by 40 CFR Part 423 (Steam Electric Power Generation) because they produce electric
power for distribution and/or sale (U.S. EPA, 2009).
EPA completed a detailed study of the steam electric power generating industry in 2009,
which resulted in a rulemaking to revise the 1982 Steam Electric ELGs. The proposed revisions
to the ELGs include limitations for metals in wastewater discharges from FGD air pollution
control systems (e.g., wet FGD scrubbers). FGD scrubber wastewater is regulated by the 1982
ELGs for total suspended solids, oil and grease, and pH only. However, these discharges also
contain toxic metal pollutants not previously captured in EPA's review of this industrial
category. EPA proposed the revised ELGs, including metals in wastewater discharges from FGD
scrubbers, for Part 423 in April 2013 (78 FR 34432).
6.3.2.6 Petroleum Refineries (Currently Regulated Under 40 CFR Part 419)
EPA promulgated NSPS (40 CFR 60 Subparts J and Ja) for petroleum refineries March 8,
1974 (revised and amended many times since, most recently in 2012). These rules require control
of particulate matter, nitrogen oxides, and sulfur dioxides. The 2012 revised NSPS (77 FR
56463) reflect demonstrated improvements in emissions control technologies and work practices.
Specifically, EPA estimated that refineries would use wet scrubbers to control emissions from
fluid catalytic cracking units and fluid coking units. EPA estimated that the rule would generate
1.6 billion gallons of water per year for the 5 years following the proposal for new sources (73
FR 56463).
EPA promulgated NESHAP in 1995 to control organic compounds, reduced sulfur
compounds, inorganics, and particulate metals from process units at petroleum refineries. In
addition, EPA promulgated NESHAP in 2002 (amended in February 2005) to control organic
compounds, reduced sulfur compounds, inorganics, and particulate metals emissions from
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catalytic cracking, catalytic reforming, and sulfur units at petroleum refineries. EPA expected a
small increase in water usage from the increased use of wet scrubbers because of the NESHAP
(67 FR 17761). EPA also sent a comprehensive industry-wide information collection request to
all petroleum refineries in the U.S. in April 2011. EPA conducted the ICR to collect information
needed to reevaluate air emission standards. In the ICR, EPA requested processing
characteristics at the refineries (including wastewater collection and treatment).
In 1982 (before EPA promulgated the NESHAPs for petroleum refineries) EPA
promulgated an ELG for wastewater discharges (Part 419 Petroleum Refining). EPA conducted a
detailed study of petroleum refinery wastewaters in 2004, specifically looking at concentrations
of dioxins, polycyclic aromatic compounds, and metals discharged in 2000. In 2004, EPA
determined that revisions to the ELGs were not warranted for controlling wastewater discharges
from refineries.
During its 2011 and 2012 Annual Reviews, EPA began a review of the petroleum
refining point source category because it ranked high in terms of TWPE. The annual reviews
show a recent increase in metals discharges in the DMR database (see Section 5.2). Currently,
except for chromium, the petroleum refineries ELG does not regulate the discharge of metals.
The reviews of petroleum refineries in 1982 and 2004 did not capture changes in the industry
resulting from the 2002 NESHAP and the 2008 revisions to NSPS, which identified wet
scrubbers as a method for controlling particulate metal emissions and other HAPs.
6.3.3 Summary of Findings from EPA's Review of Air Pollution Control Regulations
EPA evaluated whether air pollution control regulations might result in the generation of
wastewater discharges not included in the scope of existing ELGs and identified the following:
• Of the 38 NESHAP rules and 46 NSPS rules reviewed, EPA found that six of
these rules affected four industries not currently regulated by ELGs. Findings for
these industries are summarized below:
— Brick and Structural Clay Products Manufacturing: Currently brick and
structural clay product manufacturers only have stormwater NPDES
permits. Further, permit writers that EPA contacted explained that they
have not identified industrial wastewater discharges at brick and clay
products manufacturers.
— PCE-Based and Petroleum-Based Dry Cleaning: EPA's review of the
industrial laundries industry in 1997 found that many facilities are moving
away from dry cleaning because of the hazardous nature of the solvents
and the expense of their disposal. Because EPA investigated wastewater
discharges from this industry after promulgation of air regulations, EPA
does not expect the revised 2006 NESHAP to affect wastewater
discharges.
— Industrial, Commercial, and Institutional Boilers: EPA expects that
wastewater discharges from boiler air pollution control devices are
commingled and discharged with other industrial plant process
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wastewaters, and are not specifically addressed in ELGs. EPA has not
evaluated the pollutants in the boiler air pollution control at this time.
— Industrial, Commercial, and Institutional Steam Generating Units:
Discharges from steam generating units are not regulated by 40 CFR Part
423 (Steam Electric Power Generating ELGs) because they do not produce
electric power for distribution and/or sale. However, in its 2009 detailed
study of the steam industry, EPA found that industry-specific ELGs do not
specifically address wastewater discharges from these units either. EPA
expects that some discharge permits, but not all, may include permit
limitations for pollutants in wastewater from air pollution controls on
steam generating units based on the facility-specific ELGs. EPA has not
evaluated pollutants in these wastewater discharges at this time.
• Additionally, EPA found that for two industries with existing ELGs, five air rules
might result in wastewater discharges not included in the scope of existing ELGs.
Findings for these industries are summarized below:
— Steam Electric Generating Units: EPA promulgated NSPS for steam
generating units in 1971 and 1978 (40 CFR 60 Subparts D and Da). These
air regulations address electric generating units that are covered under 40
CFR Part 423 (Steam Electric Power Generating ELGs) because they
produce electric power for distribution and/or sale. EPA is currently
proposing to revise the 1982 Steam Electric Power Generation ELGs to
include limitations for toxic metal pollutants in FGD scrubber wastewater.
— Petroleum Refining: EPA revised NSPS for petroleum refineries in 2012
to control particulate matter, nitrogen oxides, and sulfur dioxides.
Additionally, EPA promulgated the 2002 NESHAP (amended in
September 2009) to control organic compounds, reduced sulfur
compounds, inorganics, and particulate metals emissions from catalytic
cracking, catalytic reforming, and sulfur plant units at petroleum
refineries. EPA began a category review of the petroleum refining point
source category in the 2011 and 2012 Annual Reviews, which show a
recent increase in metals discharges in the DMR database.
6.3.4 References for Air Pollution Control Regulations
1. U.S. DOE. 2006. U.S. Department of Energy. Glossary. Energy Information
Administration (EIA). Available online at: http://www.eia.doe.gov/glossary/index.html.
Date accessed: June 2006. EPA-HQ-OW-2004-0032-2005. DCN 03359.
2. U.S. EPA. 2000. Technical Development Document for the Final Action Regarding
Pretreatment Standards for the Industrial Laundries Point Source Category. Washington,
D.C. (March). EPA-821-R-00-006. EPA-HQ-OW-2010-0824. DCN 07763.
3. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final
Detailed Study Report. Washington, D.C. (October). EPA-821-R-09-008. EPA-HQ-OW-
2008-0517-0413.
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4. U.S. EPA. 2012. Expansion of Industry Sectors Covered by the Toxics Release Inventory
(TRI), EPCRA section 313. (May 16). Available online at:
http://yosemite.epa.gov/opei/rulegate.nsf7byRIN/2025-AA33tfl.EPA-HQ-OW-2010-
0824. DCN 07735.
5. Warren, Lee. 2012. Telephone Communication Between Lee Warren, Alabama
Department of Environmental Management, and Kimberly Landick, Eastern Research
Group, Inc., Re: Brick Manufacturing Process. (March 21). EPA-HQ-OW-2010-0824.
DCN 07737.
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Table 6-44. Air Regulations Potentially Resulting in Wastewater Discharges in Industries with No Existing Effluent Limitations Guidelines
Industry
NSPS/NESHAP
Regulated Pollutants
Latest Date of
Required
Compliance
Citation
Further Review?
Brick and
Structural Clay
NESHAP for Brick and
Structural Clay Products
Manufacturing
Hydrogen fluoride, Hydrogen
chloride, Antimony, Arsenic,
Beryllium, Cadmium,
Chromium, Cobalt, Mercury,
Manganese, Nickel, Lead and
Selenium
2006
40 CFR 63 Subpart JJJJJ
Final Rule: May 16, 2003
(68 FR 26689)
Wet scrubbers are listed as an optional air
pollution control device in the final rule.
EPA's initial review of brick and structural
clay industrial wastewater discharges
suggests that most of the NPDES permits
are stormwater permits for the 93 permits
in the 2009 DMR database. Therefore, EPA
expects that discharges in the TRA
databases are from stormwater, not air
pollution control, at this time.
Dry Cleaning
NESHAP for
Perchloroethylene (PCE)
Dry Cleaners
Perchloroethylene (PCE)
2009a
40 CFR 63 Subpart M
• Final Rule: July 27, 2006
• (71FR42724)
Dry Cleaning
NSPS for Petroleum Dry
Cleaners.
VOC emissions
1984
40 CFR 60 Subpart JJJ
Final Rule: September 1984
(49 FR 37331)
Yes. The NESHAP prescribes refrigerator
condensers (wet air pollution control) for
all PCE dry cleaning facilities (major
sources, large area sources, and small area
sources). Additionally, the NESHAP
prescribes carbon adsorbers in addition to
refrigerator condensers (wet air pollution
controls) for major sources. The NSPS
applies to facilities located at a petroleum
dry cleaning plant with a total
manufacturers' rated dryer capacity equal to
or greater than 38 kilograms. Dry cleaners
are not required to report to TRI and only
16 laundries reported DMR discharges (in
2009). Top pollutants reported in
discharges include fluoride and chlorine.
Therefore, EPA concludes that the TRA
database to not capture discharges from
PCE or petroleum-based dry cleaning
facilities.
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Table 6-44. Air Regulations Potentially Resulting in Wastewater Discharges in Industries with No Existing Effluent Limitations Guidelines
Industry
NSPS/NESHAP
Regulated Pollutants
Latest Date of
Required
Compliance
Citation
Further Review?
Printing and
Publishing b
NSPS Publication
Rotogravure Printing
SO2, NOX, VOCs, PM, or CO
1980
40 CFR 63 Subpart QQ
Final Rule: November 1982
(47 FR 50649)
No. Final Rule lists the following wet air
pollution control devices: carbon
adsorption, condensation/solvent recovery,
biological treatment, stream stripping, and
liquid- phase carbon adsorption.
However, based on the date of the NSPS
publication (1980), EPA expects that the
2006 Preliminary Study of the Printing and
Publishing industry reviewed the
discharges from this air regulation.
Industrial,
Commercial, and
Institutional
Boilers and
Process
Heaters—Major
Sources
NESHAP for Major
Sources: Industrial,
Commercial, and
Institutional Boilers and
Process Heaters
CO, HC1, Hg, and PM or TSM
2016
40 CFR 63 Subpart DDDDD
Final Rule: January 31, 2013
(78 FR 7138)
Yes. The NESHAP potentially affects over
ten industrial categories. Wastewater
discharges from boiler air pollution control
devices (e.g., wet scrubbers) are likely
commingled with plant wastewater and
therefore categorized as part of a plant's
point source category in the TRA
databases.
Therefore, the TRA databases likely
capture these discharges for some point
source categories, but not all.
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Table 6-44. Air Regulations Potentially Resulting in Wastewater Discharges in Industries with No Existing Effluent Limitations Guidelines
Industry
NSPS/NESHAP
Regulated Pollutants
Latest Date of
Required
Compliance
Citation
Further Review?
Industrial-
Co mmercial-
Institutional
Steam
Generating
Units
NSPS for Industrial-
Commercial-Institutional
Steam Generating
Units/NSPS for Small
Industrial- Commercial-
Institutional Steam
Generating Units
PM, SO2, NOX
1984 and 1989
40 CFR 60 Subpart Db and DC
Final Rule: June 1984 and 1989
Yes. 40 CR Subparts Db and DC potentially
affect over 30 industrial categories.
Wastewater discharges from steam
generating unit air pollution control devices
(e.g., wet scrubbers) are likely commingled
with plant wastewater and therefore
categorized as part of a plant's point source
category in the TRA databases.
Therefore, the TRA databases likely
capture these discharges for some point
source categories, but not all.
Note: EPA examined language in the regulations and supporting documentation and noted which rules specified air pollution control that would potentially
generate wastewater (e.g., use of a wet scrubber). If the air regulation included language that mentioned wet air pollution control as an option, EPA
designated the affected industries as potentially having a wastewater impact from the air regulation.
a On September 22, 1993, EPA promulgated technology-based emission standards to control emissions of PCE from dry cleaning facilities. On July 27, 2006,
EPA promulgated revised standards to take into account new developments in production practices, processes, and control technology. The 2006 standards
are expected to provide further reductions of PCE beyond the 1993 NESHAP. On July 11, 2008, EPA published revisions to the 2006 regulations based on
adverse comments. The latest date of compliance for these regulations is July 27, 2009.
b EPA reviewed the MACT standards for the Printing and Publishing industry in April 2011 (76 FR 22566). EPA did not identify any advances in practices,
processes, and control technologies applicable to the emission sources in the Printing and Publishing Industry source category in the technology review (75
FR 65067). EPA determined that the current MACT standards for Printing and Publishing facilities reduce risk to an acceptable level, provide an ample
margin of safety to protect public health, and prevent adverse environmental effects. Therefore, EPA re-adopted the existing MACT standards.
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Table 6-45. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Prioritized for Further Review During EPA's 2012 Annual Reviews
Industry
Steam
Generating
Units
NSPS/NESHAP
NSPS for Fossil-
Fuel-Fired Steam
Generators
NSPS for Electric
Utility Steam
Generating Units
NESHAP for Coal-
and Oil-Fired Electric
Utility Steam
Generating Units
Regulated Pollutants
SO2, NOX, VOCs, PM,
or CO
SO2, NOX, VOCs, PM,
or CO
PM, Antimony,
Arsenic, Beryllium,
Cadmium, Chromium,
Cobalt, Lead,
Manganese, Nickel,
Selenium, Hydrogen
Chloride, Sulfur
Dioxide, Mercury
Latest Date
of Required
Compliance
1976
(Amendment:
2007)
1978
(Amendment:
2007)
2015
Citation
40CFR60SubpartD
Final Rule:
August 17, 1971
40CFR60SubpartDa
Final Rule:
September 18, 1978
40 CFR 63 Subpart
uuuuu
Final Rule:
February 16, 2012
(77 FR 9303)
ELG (Date of
Promulgation or
Last Revision)
ELG currently
under review; Part
423 Steam
Electric ELGs
(1982)
Further Review?
Yes. Likely not captured in TRA
databases because potentially
contains pollutants without ELGs,
such as selenium and arsenic.
Ongoing EPA rulemaking is
addressing wastewaters
discharges from air pollution
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Table 6-45. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Prioritized for Further Review During EPA's 2012 Annual Reviews
Industry
Petroleum
Refineries
NSPS/NESHAP
NSPS for Refineries
NESHAP for
Petroleum Refineries
NESHAP for
Petroleum Refineries
(Catalytic Cracking,
Catalytic Reforming,
Sulfur Plant Units).
Regulated Pollutants
SO2, NOX, VOCs, PM,
or CO.
Organic compounds,
Reduced sulfur
compounds, Inorganics,
and Paniculate metals
Organic compounds,
Reduced sulfur
compounds, Inorganics,
and Paniculate metals
Latest Date
of Required
Compliance
1977
(Updated:
2012)
1998
2005
Citation
40 CFR 60 Subparts J and
Ja
Final Rule for NSPS J:
March 8, 1974 (39 FR
9315)
Final Rule for NSPS Ja:
June 24, 2008
(73 FR 35837); Updated
September 12, 2012 (77
FR 56422)
40 CFR 63 Subpart CC
Final Rule: August 18,
1995 (60 FR 43244)
40 CFR 60 Subpart UUU
Final Rule: April 11,
2002 (67 FR 17761);
Amendment: February 5,
2005 (70 FR 6929)
ELG (Date of
Promulgation or
Last Revision)
Petroleum
Refining - 40
CFR Part 4 19
(1982)
Further Review?
Yes. EPA suspects that the 2012
NSPS Ja and the 2002 (amended
in 2005) NESHAP may result in
wastewater discharges from wet
scrubbers. The NESHAP expects
a small increase in annual water
usage would result from the
increased use of wet scrubbers.
EPA conducted a Preliminary
Study of this category in 2004;
however, this review did not
capture any changes in the
industry potentially resulting
from the 2012 NSPS amendment
and the 2005 NESHAP.
Note: EPA examined language in the regulations and supporting documentation and noted which rules specified air pollution control that would potentially
generate wastewater (e.g., use of a wet scrubber). If the air regulation included language that mentioned wet air pollution control as an option, EPA designated
the affected industries as potentially having a wastewater impact from the air regulation.
6-100
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Battery
Manufacturing
OCPSF
NSPS/NESHAP
NSPS for Lead
Acid Battery
Manufacturing
Plants
NESHAP for Lead
Acid Battery
Manufacturing\
NSPS for Pressure
Sensitive Tape and
Label Surface
Coding Operations
NSPS for Flexible
Vinyl/Ure thane
Coating and
Printing
Regulated
Pollutants
Lead
Lead
SO2, NOX, VOCs,
PM, or CO
SO2, NOX, VOCs,
PM, or CO
Latest Date
of Required
Compliance
1980
2008
1983
1984
Citation
40CFR60SubpartKK
Final Rule: April 1982
(47 FR 16573)
40 CFR 63 Subpart PPPPPP
Final Rule: July 16, 2007
(72 FR 16636)
40 CFR 60 Subpart RR
Final Rule: October 18,
1983
(48 FR 48375)
40 CFR 60 Subpart FFF
Final Rule: June 29, 1984
(49 FR 26892)
ELG (Date of
Promulgation or
Last Revision)
Part 461 Battery
Manufacturing
ELGs (1984)
Part414OCSPF
ELGs (1987)
Further Review?
No. Wastewater discharges from
manufacture of lead acid batteries
are regulated under Subpart C
(Lead Subcategory) of 40 CFR
Part 461. EPA reviewed lead acid
battery manufacturing
(specifically including wastewater
streams from wet scrubbers)
during the development of the
ELG (promulgated in 1984).
No. The NESHAP for Lead Acid
Battery Manufacturing adopts the
numerical emissions limits in 40
CFR 60 Subpart KK (NSPS for
Lead Acid Batteries). EPA does
not expect the NESHAP to change
wastewater discharges.
Not yet determined. EPA will
determine if the regulated
pollutants are accurately
represented in the TRA databases
in future annual reviews.
6-101
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
NSPS/NESHAP
NESHAP for
Acrylic/Modacrylic
Fiber
NESHAP for
Cellulose Products
Manufacturing
NESHAP for
Flexible
Polyurethane Foam
Fabrication
Operation
NESHAP for
Generic MACT I-
Acetal Resins
NESHAP for
Generic MACT I-
Polycarbonates
Production
Regulated
Pollutants
Acrylonitrile
Carbon Bisulfide,
Carbonyl Sulfide,
Ethylene Oxide,
Methanol, Methyl
Chloride,
Propylene Oxide,
Toluene
Hydrochloric
Acid, 2,4-
Toluene
Diisocyanate,
Hydrogen
Cyanide,
Methylene
Chloride
Latest Date
of Required
Compliance
2008
2005
2003
2002
2002
Citation
40 CFR 63 Subpart
LLLLLL
Final Rule: July 16, 2007
(72 FR 38864)
40 CFR 63 Subpart UUUU
Final Rule: June 11, 2002
(67 FR 40043)
40 CFR 63 Subpart
MMMMM
Final Rule: April 14, 2003
(68 FR 18061)
40 CFR 63 Subpart YY&
UU
Final Rule: June 29, 1999
(64 FR 34853)
40 CFR 63 Subpart YY&
UU
Final Rule: June 29, 1999
(64 FR 34853)
ELG (Date of
Promulgation or
Last Revision)
Further Review?
Not yet determined. EPA will
determine if all cellulose products
manufacturing facilities are
reporting these pollutants in the
TRA databases in future annual
reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-102
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
NSPS/NESHAP
NESHAP for
Generic MACT I-
Acrylic/Modacrylic
Fibers
NESHAP for
Miscellaneous.
Organic Chemical
Production and
Processes
NESHAP for
Polyether Polyols
Production
NESHAP for
Polymers and
Resins I
Regulated
Pollutants
Toluene,
Methanol,
Xylene, Hydrogen
Chloride,
Methylene
Chloride
Ethylene Oxide,
Propylene Oxide,
Hexane, Toluene
Organic
hazardous air
pollutants
including Styrene,
n-Hexane, 1,3-
Butadiene,
Acrylonitrile,
Methyl Chloride,
Hydrogen
Chloride, Carbon
Tetrachloride,
Chloroprene,
Toluene
Latest Date
of Required
Compliance
2002
2008
2002
2001
Citation
40CFR63SubpartYY&
UU
Final Rule: June 29, 1999
(64 FR 34853)
40 CFR 63 Subpart FFFF
Final Rule: November 10,
2003 (68 FR 63851)
40 CFR 63 Subpart PPP
Final Rule: June 1, 1999
(64 FR 294 19)
40 CFR 63 Subpart U
Final Rule: Septembers,
1996
(61FR46906)
ELG (Date of
Promulgation or
Last Revision)
Further Review?
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
6-103
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
NSPS/NESHAP
NESHAP for
Polymers & Resins
II
NESHAP for
Polymers & Resins
III
NESHAP for
Polymers & Resins
IV
Regulated
Pollutants
Organic
hazardous air
pollutants
including
Formaldehyde,
Methanol, Phenol,
Xylene, Toluene
Organic
hazardous air
pollutants
including
Acrylonitrile,
Butadiene,
Styrene Resin,
Styrene
Acrylonitrile
Resin, Methyl
Methacrylate
Polystyrene
Resin, Poly Resin,
and Nitrile Resin.
Latest Date
of Required
Compliance
1998
2003
2001
Citation
40 CFR 63 Subpart W
Final Rule: March 8, 1995
(60 FR 12670)
40 CFR 63 Subpart OOO
Final Rule: January 20,
2000
(65 FR 3275)
40 CFR 63 Subpart JJJ
Final Rule: September 12,
1996(61FR48208)
ELG (Date of
Promulgation or
Last Revision)
Further Review?
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-104
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Paving and
Roofing
Materials
Glass
Manufacturing
Textiles
NSPS/NESHAP
NESHAP for
Polyvinyl Chloride
and Copolymers
Production
NSPS for Asphalt
Processing and
Asphalt Roofing
Manufacture for
either SO2, NOX,
VOCs, PM, or CO.
NSPS for Wool
Fiberglass
Insulation
Manufacturing
NESHAP for Fabric
Printing, Coating
and Dyeing
Regulated
Pollutants
SO2, NOX, VOCs,
PM, or CO
SO2, NOX, VOCs,
PM, or CO.
Toluene, Methyl
Ethyl Ketone
(MEK),
Methanol,
Xylenes, Methyl
Isobutyl Ketone
(MIBK),
Methylene
Chloride,
Trichloroethylene,
N-Hexane, Glycol
Ethers,
Formaldehyde.
Latest Date
of Required
Compliance
2002
1982
1985
2006
Citation
40 CFR 63 Subpart J
Final Rule: July 10, 2002
(67 FR 45885)
40 CFR 60 Subpart UU
Final Rule: August 6, 1982
(47 FR 34 143)
40 CFR 60 Subpart PPP
Final Rule: February 1985
(50 FR 7699)
40 CFR 63 Subpart OOOO
Final Rule: May 29, 2003
(68 FR 32 171)
ELG (Date of
Promulgation or
Last Revision)
Part 443 Paving
and Roofing
Materials ELGs
(1975)
Part 426 Glass
Manufacturing
ELGs (1974)
Part 4 10 Textiles
ELGs (1982)
Further Review?
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
determine if the regulated
pollutants are accurately
represented in the TRA databases
in future annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-105
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Waste
Combustors
NSPS/NESHAP
NSPS for New or
Modified
Construction of
Commercial and
Industrial Solid
Waste Incineration
Units for Which
Construction Is
Commenced
NSPS for Existing
Commercial and
Industrial Solid
Waste Incineration
Units
NESHAP for
Hazardous Waste
Combustion
NESHAP for Off-
Site Waste
Recovery
Operations
Regulated
Pollutants
SO2, NOX, VOCs,
PM, or CO
SO2, NOX, VOCs,
PM, or CO
Chlorinated
Dioxins and
Furans, Other
toxic organic
compounds,
Toxic metals,
Hydrochloric
Acid, Chlorine
Gas, PM.
Latest Date
of Required
Compliance
2013
2011
2003
2000
Citation
40 CFR 60 Subpart CCCC
Final Rule: December 1,
2000 (65 FR 75350)
40 CFR 60 Subpart DDDD
Final Rule: December 2000
(65 FR 75362)
40 CFR 63 Subpart EEE
Final Rule: September 30,
1999 (64 FR 52827)
40 CFR 63 Subpart DD
Final Rule: July 1, 1996(61
FR34140)
ELG (Date of
Promulgation or
Last Revision)
Part 444 Waste
Combustors ELGs
(2000)
Further Review?
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-106
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Benzene Waste
Operations
Inorganic
Chemicals
Manufacturing
NSPS/NESHAP
NESHAP for Such
Operations
NESHAP for the
Chemical
Manufacturing
Industry
NESHAP for
Hydrochloric Acid
Production
NESHAP for Lime
Manufacturing
Regulated
Pollutants
Hydrochloric
Acid
Hydrogen
Chloride,
Antimony,
arsenic,
Beryllium,
Cadmium,
Chromium, Lead,
Manganese,
Mercury, Nickel,
Selenium
Latest Date
of Required
Compliance
2006
2012
2006
2007
Citation
40CFR61SubpartFF
Final Rule: December 4,
2003 (68 FR 67931)
40 CFR 63 Subpart
WWW
Final Rule: October 29,
2009 (74 FR 56008)
40 CFR 63 NNNNN
Final Rule: April 17, 2003
(68 FR 19075)
40 CFR 63 AAAAA
Final Rule: January 5, 2004
(69 FR 393)
ELG (Date of
Promulgation or
Last Revision)
Many - Not yet
determined.
Part 415 Inorganic
Chemicals
Manufacturing
ELGs (1982)
Further Review?
Not yet determined. This
NESHAP affects many industries.
EPA will review additional air
regulation documentation and
ELGs of affected industries to
determine if ELGs accurately
regulate discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
6-107
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Metal Finishing
Iron and Steel
Manufacturing
Coil Coating
NSPS/NESHAP
NESHAP for
Mercury Cell
Chlor- Alkali Plants
NESHAP for
Magnetic Tape
(surface coating)
NESHAP for
Integrated Iron and
Steel
NESHAP for Steel
Pickling-HCL
Process
NESHAP for Metal
Coil (surface
coating)
Regulated
Pollutants
Metals, Trace
amounts of
organics
Hydrochloric
Acid and Chlorine
Methyl Ethyl
Ketone, Glycol
Ethers, Xylenes,
Toluene, and
Isophorone
Latest Date
of Required
Compliance
2006
1996
2006
2001
2005
Citation
40 CFR 63 Subpart IIIII
Final Rule: December 19,
2003 (68 FR 70903)
40 CFR 63 Subpart EE
Final Rule: December 15,
1994 (59 FR 64580)
40 CFR 63 Subpart FFFFF
Final Rule: May 20, 2003
(68 FR 27645)
40 CFR 63 Subpart CCC
Final Rule: June 22, 1999
(64 FR 33202)
40 CFR 63 Subpart SSSS
Final Rule: June 10, 2002
(67 FR 39793)
ELG (Date of
Promulgation or
Last Revision)
Part 43 3 Metal
Finishing ELGs
(1983)
Part 420 Iron and
Steel
Manufacturing
ELGs (2002)
Part 465 Coil
Coating ELGs
(1983)
Further Review?
NA. These facilities are being
phased out.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-108
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Pulp, Paper, and
Paperboard
Pesticides
Chemicals
Pharmaceuticals
Production
Gum and Wood
Chemicals
NSPS/NESHAP
NESHAP for Paper
and Other Web
(surface coating)
NESHAP for
Pesticide Active
Ingredient
Production
NESHAP for
Pharmaceuticals
Production
NESHAP for
Plywood and
Composite Wood
Products
Regulated
Pollutants
Organics
including
Toluene,
Methanol, Methyl
Ethyl Ketone,
Xylenes, Phenols
Toluene,
Methanol, Methyl
Chloride,
Hydrogen
Chloride
Acetaldehyde,
Acrolein,
Formaldehyde,
Methanol, Phenol,
Propionaldehyde
Latest Date
of Required
Compliance
2005
2003
2001
2007
Citation
40 CFR 63 Subpart JJJJ
Final Rule: December 4,
2002 (67 FR 72329)
40 CFR 63 Subpart MMM
Final Rule: June 23, 1999
(64 FR 33549)
40 CFR 63 Subpart GGG
Final Rule: September 21,
1998 (63 FR 50280)
40 CFR 63 Subpart DDDD
Final Rule: July 30, 2004
(69 FR 45943)
ELG (Date of
Promulgation or
Last Revision)
Part 430 Pulp,
Paper, and
Paperboard ELGs
(1998)
Part 455 Pesticides
Chemicals ELGs
(1978)
Part 43 9
Pharmaceutical
Manufacturing
ELGs (1998)
Part 454 Gum and
Wood Chemicals
Manufacturing
ELGs (1976)
Further Review?
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
determine if all applicable
facilities are reporting these
pollutants in the TRA databases in
future annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
6-109
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-46. Air Regulations Potentially Resulting in Wastewater Discharges not Included in the Scope of Existing ELGs
Requiring Further Investigation in Future Annual Reviews
Industry
Ore Mining
NSPS/NESHAP
NESHAP for
Taconite Iron Ore
Processing
Regulated
Pollutants
Metal compounds
including
Manganese,
Arsenic, Lead,
Nickel,
Chromium,
Mercury;
Products of
incomplete
combustion
including
Formaldehyde;
Hydrogen
Chloride and
Hydrogen
Fluoride.
Latest Date
of Required
Compliance
2006
Citation
40CFRPart63 Subpart
RRRRR
Final Rule: October 30,
2003 (68 FR 6 1867)
ELG (Date of
Promulgation or
Last Revision)
Part 440 Ore
Mining ELGs
(1982; Detailed
Study completed
in 20 11)
Further Review?
Not yet determined. EPA will
review additional air regulation
documentation to determine the
affects of wet air pollution control
on industrial discharges in future
annual reviews.
Note: EPA examined language in the regulations and supporting documentation and noted which rules specified air pollution control that would potentially
generate wastewater (e.g., use of a wet scrubber). If the air regulation included language that mentioned wet air pollution control as an option, EPA designated
the affected industries as potentially having a wastewater impact from the air regulation.
6-110
-------
Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Fertilizer
Manufacturing,
Inorganic Chemicals
Manufacturing
Fertilizer
Manufacturing,
Inorganic Chemicals
Manufacturing
Fertilizer
Manufacturing
Fertilizer
Manufacturing
Paving and Roofing
Materials
Nonferrous Metals
Manufacturing
Scope
NSPS for sulfuric acid production units for
sulfuric acid mist and SO2.
NSPS for nitric acid plants for NOx and
opacity.
NSPS for phosphate fertilizer industry: wet
process phosphoric acid plants. This rule
requires control of fluoride emissions.
NSPS for phosphate fertilizer industry:
superphosphoric acid plants. This rule
requires control of fluoride emissions.
NSPS for hot mix asphalt facilities. This rule
requires control of PM emissions and opacity.
NSPS for Secondary Lead Smelters. This rule
requires control of paniculate emissions and
opacity.
NSPS for Secondary Brass and Bronze
Production Plants. This rule requires control
of paniculate emissions and opacity.
Latest Date of
Required
Compliance
1995
1977
1977
1977
1977
1977
1977
Citation
40 CFR Part 60 Subpart Cd
Final Rule: December 19,
1995 (60 FR 65414)
40 CFR Part 60 Subpart G
Final Rule: July 25, 1977
(42 FR 37936)
40 CFR Part 60 Subpart T
Final Rule: July 25, 1977
(42 FR 37937)
40 CFR Part 60 Subpart U
Final Rule: July 25, 1977
(42 FR 37937)
40 CFR Part 60 Subpart I
Final Rule: July 25, 1977
(42 FR 37937)
40 CFR Part 60 Subpart L
Final Rule: July 25, 1977
(42 FR 37937)
40 CFR Part 60 Subpart M
Final Rule: July 25, 1977
(42 FR 37937)
Existing ELG?
(Date of Promulgation or Revision)
Undetermined. Possibly Part 418
Fertilizer Manufacturing ELGs (1974)
or Part 415 Inorganic Chemicals
Manufacturing (1982)
Undetermined. Possibly Part 418
Fertilizer Manufacturing ELGs (1974)
or Part 415 Inorganic Chemicals
Manufacturing (1982)
Part 418 Fertilizer Manufacturing ELGs
(1974)
Part 418 Fertilizer Manufacturing ELGs
(1974)
Part 443Paving and Roofing Materials
(Tars and Asphalt) ELGs (1975)
Part 421 Nonferrous Metals
Manufacturing ELGs (1984)
6-111
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Scope
Latest Date of
Required
Compliance
Citation
Existing ELG?
(Date of Promulgation or Revision)
NSPS for primary copper smelters. This rule
requires control of paniculate, SO2 emissions,
and opacity.
1976
40 CFR Part 60 Subpart P
Final Rule: January 15,
1976(41FR2338)
NSPS for primary zinc smelters. This rule
requires control of paniculate, SO2 emissions,
and opacity.
1976
40 CFR Part 60 Subpart Q
Final Rule: January 15,
1976 (41 FR 2340)
NSPS for primary lead smelters. This rule
requires control of paniculate, SO2 emissions,
and opacity.
1976
40 CFR Part 60 Subpart R
Final Rule: January 15,
1976 (41 FR 2340)
NSPS for primary aluminum reduction plants.
This rule requires control of fluoride
emissions and opacity.
1980
40 CFR Part 60 Subpart S
Final Rule: June 30, 1980
(45 FR 44207)
Iron and Steel
Manufacturing
NSPS for primary emissions for Basic
Oxygen Process Furnaces. This rule requires
control of paniculate emissions and opacity.
1977
40 CFR Part 60 Subpart N
Final Rule: July 25, 1977
(42 FR 37937)
Part 420 Iron and Steel Manufacturing
ELGs (2002)
Ferroalloy
Manufacturing
NSPS for ferroalloy production facilities. This
rule requires control of paniculate emissions
and carbon monoxide.
1976
40 CFR Part 60 Subpart Z
Final Rule: May 4, 1976
(41 FR 18501)
Part 424 Ferroalloy Manufacturing
ELGs (1974)
Coil Coating and Metal
Finishing
NSPS for surface coating of metal furniture.
This rule requires control of VOC emissions.
1982
40 CFR Part 60 Subpart EE
Final Rule: October 29,
1982 (47 FR 49287)
Part 465 Coil Coating ELGs (1983) and
Metal Finishing ELGs (1986)
6-112
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Section 6—New Data Sources and Hazard Analyses
6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Inorganic Chemicals
Manufacturing
Mineral Mining and
Processing
Metal Products and
Machinery
Phosphate
Manufacturing
Coil Coating
Rubber Manufacturing
Scope
NSPS for lime manufacturing plants. This rule
requires control of paniculate emissions.
NSPS for metallic mineral processing plants.
This rule requires control of paniculate
emissions.
NSPS for automobile and light duty trucks
surface coating operations. This rule requires
control of VOC emissions.
NSPS for phosphate rock plants. This rule
requires control of paniculate emissions.
NSPS for metal coil surface coating. This rule
requires control of VOC emissions.
NSPS for rubber tire manufacturing industry.
This rule requires control of VOC emissions.
Latest Date of
Required
Compliance
1984
1984
1980
1982
1982
1987
Citation
40 CFR Part 60 Subpart
HH
Final Rule: April 26, 1984
(49 FR 18080)
40 CFR Part 60 Subpart LL
Final Rule: February 21,
1984 (49 FR 6464)
40 CFR Part 60 Subpart
MM
Final Rule: December 24,
1980 (45 FR 85415)
40 CFR Part 60 Subpart
NN
Final Rule: April 16, 1982
(47 FR 16589)
40 CFR Part 60 Subpart TT
Final Rule: November 1,
1982 (47 FR 49612)
40 CFR Part 60 Subpart
BBB
Final Rule: September 15,
1987 (52 FR 34874)
Existing ELG?
(Date of Promulgation or Revision)
Part 415 Inorganic Chemicals
Manufacturing ELGs (1982)
Part 436 Mineral Mining and
Processing ELGs (1975)
Part 438 Metal Products and Machinery
ELGs (2003)
Part 422 Phosphate Manufacturing
ELGs (1974)
Part 465 Coil Coating ELGs (1983)
Part 428 Rubber Manufacturing ELGs
(1974)
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6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Scope
NSPS for synthetic organic chemical
manufacturing industry (SOCMI) distillation
and reactor process. This rule requires control
of VOC emissions.
Latest Date of
Required
Compliance
Citation
Existing ELG?
(Date of Promulgation or Revision)
OCPSF
1990
40 CFR Part 60 Subpart
NNN
Final Rule: June 29, 1990
(55 FR 26942)
Part 414 OCPSF ELGs (1987)
Mineral Mining and
Processing
NSPS for nonmetallic mineral processing
plants.
2009
40 CFR Part 60 Subpart
000
Final Rule: April 28, 2009
(74 FR 19309)
Part 436 Mineral Mining and
Processing ELGs (1975)
Waste Combustors
NSPS for Large Municipal Waste
Combustors. This rule requires control of
MWC metals (cadmium, lead, mercury, PM),
organics (dioxin/furan), acid gases (HC1, SO2,
NOX, and opacity).
1996
40 CFR Part 60 Subpart Cb
Final Rule: December 19,
1995 (60 FR 65415)
Part 444 Waste Combustors ELGs
(2000)
NSPS for Municipal Waste Combustors. This
rule requires control of MWC metals
(cadmium, lead, mercury, PM), organics
(dioxin/furan), acid gases (HC1, SO2, NOX,
and opacity).
1991/1995
40 CFR Part 60 Subpart Ea
andEb
Final Rule: February 11,
1991 (56 FR 5507)and
December 19, 1995 (60 FR
65419)
Waste Combustors
NSPS for incinerators for paniculate matter.
1977
40 CFR Part 60 Subpart E
Final Rule: July 25, 1977
(42 FR 37936)
Part 444 Waste Combustors ELGs
(2000)
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6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Scope
Latest Date of
Required
Compliance
Citation
Existing ELG?
(Date of Promulgation or Revision)
Iron and Steel
NSPS for steel plants, electric arc furnaces,
and argon-oxygen decarburization vessels.
This rule requires control of paniculate
emissions and opacity.
1984
40 CFR Part 60 Subpart
AA and AAa
Final Rule: October 31,
1984 (49 FR 43 843 and 49
FR 43845)
Part 420 Iron and Steel ELGs (2002)
Pulp and Paper
NSPS for kraft pulp mills. This rule requires
control of paniculate emissions and total
reduced sulfur.
1986
40 CFR Part 60 Subpart BB
Final Rule: May 20, 1986
(51FR18544)
Part 430 Pulp and Paper (1998)
Glass Manufacturing
NSPS for glass manufacturing plants. This
rule requires control of paniculate emissions.
1980
40 CFR Part 60 Subpart CC
Final Rule: October 7,
(45 FR 66751)
Part 426 Glass Manufacturing ELGs
(1974)
1980
Steam Generating Units
NSPS for coal-fired electric steam generating
units. This rule limits nationwide emissions of
mercury by setting a cap on emissions and
allowing trading.
2005
40 CFR Part 60 Subpart
HHHH
Final Rule: May 2005 (70
FR 28657)
Part 423 Steam Electric ELGs (ELG
currently under review)
Ore Mining
NESHAP for Gold Mine Ore Processing and
Production.
2014
40 CFR Part 60 Subpart
EEEEEEE
Final Rule: February 17,
2011 (76 FR 9450)
Part 440 Ore Mining ELGs (1982;
Detailed Study completed in 2011)
Sewage Treatment
Plants
NSPS for sewage treatment plants. This rule
requires control of paniculate emissions and
opacity.
1977
40 CFR Part 60 Subpart O
Final Rule: November 10,
1977 (42 FR 58521)
Sewage treatment plants are outside the
scope of ELGs
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6.J—Identification of Air Pollution Control Wastewater
Discharges Not Currently Regulated by ELGs
Table 6-47. Air Regulations with Less Likely Wastewater Impacts - Scope of Air Regulation and Applicable ELG
Industry
Scope
Latest Date of
Required
Compliance
Citation
Existing ELG?
(Date of Promulgation or Revision)
Sewage Sludge
Incineration
NSPS for performance standards for New
Sewage Sludge Incineration units for either
SO2, NOX, VOCs, PM, or CO.
2011
40 CFR Part 60 Subpart
LLLL
Final Rule: March 31, 2011
(76 FR 15372)
Sewage sludge incineration is covered
under Part 503
Sewage Sludge
Incineration
NSPS for emission guidelines and compliance
times for Existing Sewage Sludge Incineration
units for either SO2, NOX, VOCs, PM, or CO.
2011
40 CFR Part 60 Subpart
MMMM
Final Rule: March 31, 2011
(76 FR 15372)
Sewage sludge incineration is covered
under Part 503
Note: EPA examined language in the regulations and supporting documentation and noted which rules specified air pollution control that would potentially
generate wastewater (e.g., use of a wet scrubber). If the air regulation specifically prescribed dry air pollution control, EPA designated the affected industries as
less likely to have wastewater impacts.
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6.4 Review of TRI Industry Sectors Expansion
The Toxics Release Inventory (TRI) is an integral part of EPA's annual review of
effluent discharges. Each year, under TRI, facilities that meet certain thresholds must report their
releases and other waste management activities for listed toxic chemicals. For facilities
discharging toxic chemicals directly to receiving streams and indirectly to publicly owned
treatment works (POTWs), EPA uses the annual load data reported to TRI to estimate the toxic-
weighted pound equivalents (TWPE) released and assesses the potential hazard of discharges
from specific industrial categories. Currently, more than 20,000 U.S. industrial facilities are
required to report information to TRI on disposal and other releases of over 650 toxic chemicals
(U.S. EPA, 201 la).
In June 2011, EPA's Office of Environmental Information (OEI) initiated a rulemaking
to add or expand the coverage of TRI for six industries, including phosphate mining, iron ore
mining, solid waste combustors and incinerators, large dry cleaning facilities, bulk petroleum
storage, and steam generating facilities. EPA reviewed the proposed expansion of TRI to
evaluate whether new hazard data were used as a basis for the expansion proposal for the
identified sectors, or if the identified sectors represent new or unregulated wastewater discharges
that are not adequately regulated by effluent limitations guidelines and standards (ELGs). EPA
examined the TRI sector expansion as a new source of hazard data to augment its traditional
toxicity rankings analysis (TRA) conducted in the odd-year review.
The TRI sector expansion rulemaking is still under development, with an expected
proposal date of December 2014. Though the available information for the planned expansion is
limited, EPA's initial review suggests that selenium discharges from phosphate mines (regulated
under 40 CFR Part 136) may be a new pollutant of concern.
6.4.1 TRI Industry Sectors Expansion Background
As discussed above, OEI is considering expanding the facilities required to report to TRI.
Currently, facilities with more than 10 employees in certain industrial point source categories are
required to report their toxic chemical releases under the Section 313 of the Emergency Planning
and Community Right-to-Know Act (EPCRA) of 1986 and the Pollution Prevention Act of 1990.
As originally enacted, EPCRA only applied to manufacturing industry sectors. However, Section
313 allows EPA to add industrial sectors to the scope of TRI. TRI currently covers the following
industries:39
• Mining: coal, metal, and nonmetallic mineral mining and quarrying.
• Utilities: electric, water, sewage, and other systems.
• Manufacturing: food, beverage and tobacco, textile mills and products, apparel,
leather and allied products, wood products, paper, printing and publishing,
petroleum and coal products, chemicals, plastics and rubber products, nonmetallic
mineral products, primary metals, fabricated metals, machinery, computer and
39 See the list of TRI-covered industries available online at http://www2.epa.gov/toxics-release-inventory-tri-
program/my-facilitys-six-digit-naics-code-tri-covered-industry.
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electronic products, electrical equipment, transportation equipment and allied
services, furniture, miscellaneous manufacturing.
• Merchant wholesalers, non-durable goods: chemical and allied products merchant
wholesalers, petroleum and petroleum products merchant wholesalers.
• Wholesale electronic markets and agents brokers.
• Publishing.
• Hazardous waste: waste collection, waste treatment and disposal, remediation and
other waste management services.
• Federal facilities.
In June 2011, OEI initiated a rulemaking to add or expand coverage of TRI to the
following industry sectors. This rule is still under development, with an anticipated proposal date
in December 2014; therefore, the supporting docket is not yet available.
• Iron Ore Mining;
• Phosphate Mining;
• Steam Generation from Coal and/or Oil;
• Petroleum Bulk Storage;
• Solid Waste Combustors and Incinerators; and
• Large Dry Cleaning.
EPA reviewed the scope of the planned TRI sector expansion and information available
on the TRI exchange to identify potential toxic chemical releases not adequately regulated by
ELGs. For each industrial sector considered under the TRI sector expansion, EPA reviewed
available information on the scope of the expansion, any targeted pollutants specific to the
industry sector, and any public comments on the TRI exchange website to date. After
determining the scope of the TRI expansion for each industry sector, EPA compared the
information to the applicable point source categories to determine each sector's regulatory status
(i.e., covered by existing ELGs or not regulated). For regulated point source categories, EPA
summarized the findings from the most recent annual reviews. For unregulated industries, EPA
reviewed any prior industrial category reviews or publicly available information as part of the
TRI sector expansion. EPA will continue to review TRI sector expansion data in future annual
reviews and as supporting data become available through the public docket.
The following sections present EPA's initial findings and potential next steps related to
the six industry sectors proposed for inclusion in the TRI sector expansion.
6.4.2 Iron Ore Mining (40 CFR Part 440)
The TRI sector expansion may add facilities classified under North American Industrial
Classification System (NAICS) code 212210 (Iron Ore Mining) to the list of facilities subject to
EPCRA Section 313. This expansion would potentially require these facilities to report chemical
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constituents from iron ore, waste rock, and other mining operations. OEI added metal mining to
TRI as part of the 1997 Industry Expansion Rule, but at the time deferred action on iron ore
mining facilities, citing that listed toxic chemicals did not appear to be "processed" or "otherwise
used" above de minimis concentrations. Further, it did not appear that listed toxic chemicals were
coincidentally manufactured above the "manufacturing" threshold during the extraction or
beneficiation of iron ores (62 FR 23859). However, OEI left open the possibility to reconsider
iron ore mining as new information became available and has since indicated that the rationale
for deferring action may no longer be applicable. The TRI exchange website did not list specific
pollutants targeted as part of the TRI sector expansion for iron ore mining.
ELGs for the Ore Mining and Dressing Point Source Category (40 CFR Part 440),
Subpart A (Iron Ore) limit pollutant discharges from iron ore mines. The original ELGs were
established in 1982 (47 FR 54609). In each of its annual reviews, EPA has identified the Ore
Mining Point Source Category as one of the top ranking industries, in terms of TWPE discharged
annually. As a result, each year EPA has performed a preliminary review of ore mining
discharges, including iron ore mines. EPA also recently conducted a preliminary study of the Ore
Mining and Dressing Point Source Category as a whole, and performed a separate preliminary
review for the Iron Ore subcategory, as part of the 2009 Annual Reviews and Preliminary 2010
Plan (U.S. EPA, 2009b; U.S. EPA, 201 Ib).
EPA's reviews have consistently found that much of the pollutant loads from iron ore
mines result from stormwater discharges that are regulated by stormwater general permits and
are not subject to Part 440. EPA and state stormwater Multi-Sector General Permits (MSGPs)
regulate discharges from waste rock and overburden piles (see 65 FR 64746, October 30, 2000,
and 70 FR 72116, December 1, 2005). Because the majority of loads result from stormwater
covered by a general permit, they fall outside the current applicability of the national ELGs (U.S.
EPA, 20lib).
The U.S. has only 13 active iron ore mines (U.S. Geological Survey, 2011). In 2009, EPA
found that one facility, North Shore Mining in Minnesota, reported the majority of the toxic
weighted discharges in EPA's toxicity ranking analysis (U.S. EPA, 2009b). After following up
with the Minnesota permit writer for North Shore, EPA corrected database errors in the
screening level database, and the facility no longer ranked high in terms of TWPE.
Part 440 Subpart A regulates iron, pH, and total suspended solids (TSS) in ore mine
drainage. However, EPA regulated TSS as an indicator of metals in mine discharges. EPA
describes all the chemicals considered during the 1982 rulemaking in the Proposed Development
Document for Effluent Limitations Guidelines and Standards for the Ore Mining and Dressing
Point Source Category (Ore Mining TDD). In 1982, EPA concluded that the wastewater
concentrations of the chemicals reviewed corresponded directly to the TSS concentrations. At
the time of the regulation, EPA found that if TSS in the wastewater discharge from the mining
operation were reduced, the specific metal concentrations would also decrease (U.S. EPA, 1982).
Based on EPA's previous years of review, the coverage of the existing Part 440 Subpart
A, and the regulation of some mine drainage by MSGPs, EPA previously concluded that no
additional review of discharges from iron ore mines is warranted. EPA's review of available TRI
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sector expansion data did not provide any further information regarding the discharge of specific
pollutants from the iron ore mining category.
6.4.3 Phosphate Mining (40 CFR Part 436)
The TRI sector expansion may add facilities classified under NAICS 212392 (Phosphate
Rock Mining) to the list of facilities subject to EPCRA Section 313, which would potentially
require these facilities to report chemical constituents from phosphate ore, waste rock, and other
mining operations. According to the 2007 U.S. Economic Census, NAICS 212392 includes
seven mines (U.S. Census, 2007). The TRI exchange website did not list specific pollutants
targeted as part of the TRI sector expansion for phosphate mining.
OEI has received two petitions, in 2006 and 2009, from the Greater Yellowstone
Coalition requesting the addition of phosphate mining as part of the TRI sector expansion.
Through the petitions, public commenters raised concerns about selenium discharges from
phosphate mines in Idaho (Hoyt, 2006; Hoyt, 2009). Further, in public comments submitted to
the TRI exchange, Earthworks also urged EPA to add phosphate mining to TRI due to significant
releases of selenium from mines in Idaho (U.S. EPA, 201 Ic).
ELGs for the Mineral Mining Point Source Category (40 CFR Part 436), Subpart R
(Phosphate Mining) limit pollutant discharges from phosphate mines. The original ELGs were
established in 1978 (43 FR 9809). EPA recently reviewed the Mineral Mining Point Source
Category as part of its 2010 and 2011 Annual Reviews (U.S. EPA, 201 Id; U.S. EPA, 2012).
Currently, Part 436 only regulates TSS and pH; it does not regulate selenium or discharges of
other metals.
EPA's 2010 and 2011 Annual Review identified 14 phosphate mines with discharge data
in the 2009 DMR database, all of which are in Florida (U.S. EPA, 2012). Discharges of fluoride
account for a large percentage of the TWPE from these mines. Though fluoride is not regulated
by Part 436 ELGs, it is controlled in Florida by permit limitations in accordance with the State's
water quality standards (10.0 mg/L). EPA did not identify in the TRA databases any phosphate
mines in Idaho reporting discharges, nor did it identify any mines reporting discharges of
selenium because 40 CFR Part 436 does not regulate selenium (or any other metals). In 2011,
EPA contacted the Florida Department of Environmental Protection (FL DEP) Phosphate
Management Permit Manager and Program Administrator. The contact stated that the usual
fluoride concentration from the phosphate mines in Florida is approximately 3 mg/L; therefore,
there has been no action to revise the state's fluoride water quality criteria or research new
treatment technologies for fluoride discharges (Champion, 2011). In addition, FL DEP identified
no additional chemicals of concern or treatment technologies for phosphate mines in the area,
and concluded that phosphate mine discharges were not degrading receiving stream quality
(Champion, 2011).
Based on the data collected for EPA's 2010 and 2011 Annual Reviews, EPA previously
concluded that no additional review of discharges from phosphate mines was warranted. Because
data to support TRI's sector expansion to cover phosphate mining are not yet available, and
because phosphate mines are not currently reporting selenium discharges to DMR, EPA is unable
to complete its review of phosphate mining, or determine the impact of selenium discharges.
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6.4.4 Steam Generation from Coal and/or Oil (Not Currently Regulated)
The TRI sector expansion may add facilities classified under NAICS 221330 (Steam and
Air-Conditioning Supply) to the list of facilities subject to EPCRA Section 313. Currently,
coverage of NAICS 221330 is limited to facilities that generate a combination of electric, gas,
and other services (e.g., facilities that cogenerate steam and electricity). The expansion may
include facilities that combust coal and/or oil to generate steam for distribution in commerce,
regardless of whether they cogenerate electricity. According to the 2007 U.S. Economic Census,
NAICS 221330 includes 69 facilities (U.S. Census, 2007). The TRI exchange website did not list
specific pollutants targeted as part of the TRI sector expansion for steam generation from coal
and/or oil.
Wastewater discharges from steam electric generation from coal and/or oil are regulated
by 40 CFR Part 423 (Steam Electric Power Generating Point Source Category). The Steam
Electric Power Generating ELGs cover plants primarily engaged in the generation of electricity
for distribution and sale, which results primarily from a process utilizing fossil-type fuel or
nuclear fuel in conjunction with a thermal cycle employing the steam water system as the
thermodynamic medium. The ELGs do not cover the proposed TRI sector expansion for facilities
that combust coal and/or oil to generate steam for distribution into commerce because these
facilities may not be engaged in the generation of electricity. However, EPA collected
information regarding steam and air conditioning supply plants (that use a variety of fuels
including natural gas, oil, and coal) as part of its 2009 Steam Electric Power Generating Detailed
Study (U.S. EPA, 2009a).
From the detailed study, EPA determined that steam and air-conditioning supply plants
generate similar types of wastewaters as steam electric plants regulated under the Steam Electric
Power Generating ELGs. However, most of the plants combust natural gas or oil and, therefore,
do not generate the quantity of flue gas desulfurization (FGD) and/or ash transport wastewaters
that are generated by coal-fired power plants. EPA identified that some of the wastewater
discharges contain similar pollutants to those discharged by steam electric plants. Additionally,
some of the wastewaters from these plants are regulated using the Steam Electric Power
Generating ELGs as the basis for best professional judgment (BPJ)-derived limits. EPA also
identified that there are relatively few of these plants in operation and most of them discharge a
small amount of wastewater compared to the steam electric plants regulated under the Steam
Electric Power Generating ELGs. (U.S. EPA, 2009a). EPA's review of available TRI sector
expansion data did not provide any further information regarding the discharge of specific
pollutants from steam generation from coal and/or oil.
6.4.5 Petroleum Bulk Storage (Not Currently Regulated)
The TRI sector expansion may add facilities classified under NAICS 493190 (Other
Warehousing and Storage) to the list of facilities subject to EPCRA Section 313. In the 1997
Industry Expansion Rule, OEI added to TRI bulk petroleum facilities classified under NAICS
424710 (Petroleum Bulk Stations and Terminals). The TRI rulemaking may expand coverage to
include bulk petroleum storage facilities and bulk petroleum stations and terminals for hire. EPA
plans to clarify the specific scope and industries covered under this TRI sector expansion once
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TRI publishes additional information and data. The TRI exchange website did not list specific
pollutants targeted as part of the TRI sector expansion for petroleum bulk storage.
Discharges from petroleum bulk storage facilities are not currently regulated by ELGs.
However, EPA conducted a detailed study of Petroleum Bulk Storage Terminals (PBSTs) in
2003 and 2004 (U.S. EPA, 2004). For this study, EPA visited PBSTs and collected data on the
chemicals of concern: total petroleum hydrocarbons, phenols, naphthenic acids, aromatic
hydrocarbons, and surfactants.
EPA found that PBST wastewaters were limited to stormwater discharges. The detailed
study data indicated these stormwater discharges contained low concentrations of toxic
chemicals. In addition, general or individual stormwater permits regulated the majority of the
chemicals. EPA found that permit writers were issuing stormwater permits to control discharges
from PBSTs. As a result, EPA concluded that the discharges were adequately regulated and did
not warrant national ELGs (U.S. EPA, 2004). EPA's review of available TRI sector expansion
data did not provide any further information regarding the discharge of specific pollutants from
petroleum bulk storage facilities.
6.4.6 Solid Waste Combustors and Incinerators (40 CFR Parts 43 7 and 444)
The TRI sector expansion may add facilities classified under NAICS 562213 (Solid
Waste Combustors and Incinerators) to the list of facilities subject to EPCRA Section 313.
According to the 2007 U.S. Economic Census, NAICS 562213 includes 117 facilities (U.S.
Census, 2007).40 EPA previously added combustors and incinerators regulated under subtitle C
of the Resource Conservation and Recovery Act (RCRA). These facilities collect, transport,
treat, stabilize, or dispose of RCRA subtitle C hazardous waste. The TRI sector expansion
rulemaking considers the addition of all facilities classified under NAICS 562213, whether or not
facilities have subtitle C permits. The TRI exchange website did not list specific pollutants
targeted as part of the TRI sector expansion for solid waste combustors and incinerators.
ELGs for the Centralized Waste Treatment (CWT) and Waste Combustor Point Source
Categories (40 CFR Part 437 and 40 CFR Part 444, respectively) limit pollutant discharges from
incinerators and hazardous waste combustors, as well as from other types of non-hazardous
centralized waste treatment. These regulations may not address all potential solid waste
combustors and incinerators that are being considered under the TRI sector expansion. EPA
originally promulgated the ELGs in 2000 for CWTs and waste combustors (65 FR 81300 and 65
FR 4381, respectively). In addition, in 2009 and 2011, EPA performed preliminary category
reviews of both of these point source categories (U.S. EPA, 2009b; U.S. EPA, 2012). EPA found
that the majority of the pollutant load associated with these categories resulted from an
individual facility and/or from estimations of pollutant discharge loads using values measured
below the detection limit. EPA concluded that these categories did not warrant further revision,
but that individual facilities would benefit from permitting and compliance support (U.S. EPA,
2009b; U.S. EPA, 2012). EPA has not evaluated discharge data associated with other types of
40 The U.S. Economic Census includes more facilities than EPA's toxicity rankings databases. Many factors might
contribute to this discrepancy, including: facilities may not meet TRI-reporting thresholds; facilities discharging to
POTWs are not required to report to ICIS-NPDES; and some facilities in the U.S. Economic Census are distributors
or sales facilities, not manufacturers.
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solid waste combustors that may be included under the TRI sector expansion. In addition, EPA's
review of available TRI sector expansion data did not provide any further information regarding
the discharge of specific pollutants from solid waste combustors and incinerators.
6.4.7 Large Dry Cleaning (Not Currently Regulated)
The TRI sector expansion may add large dry cleaning facilities to the list of facilities
subject to EPCRA Section 313. This includes multiple sectors classified under NAICS 8123
(Drycleaning and Laundry Services). Large dry cleaning facilities have not previously been
required to report to TRI. Particularly, the TRI sector expansion is targeting this industry to
report the TRI-listed chemical perchloroethylene (PCE), a non-aqueous solvent used to wash
garments. The TRI exchange website did not list any other specific pollutants targeted as part of
the TRI sector expansion for large dry cleaning facilities.
On December 17, 1997 (62 FR 66183), EPA published proposed pretreatment standards
for pollutant discharges from industrial laundries. At the time, EPA determined that a majority of
industrial laundries did not discharge directly to surface water, but rather to POTWs. The
proposed pretreatment standards included limits for 11 pollutants including:
• Bis (2-Ethylhexyl) Phthalate;
• Ethylbenzene;
• Naphthalene;
• Tetrachloroethene (also known as PCE);
• Toluene;
• m-Xylene;
• o&p-Xylene;
• Copper;
• LEPA;
• Zinc; and
• TPH (as measured by SGT-HEM).
During a review and detailed study of industrial laundries, EPA reviewed discharges of
some large dry cleaners. EPA found that the dry cleaning process generates minimal amounts of
wastewater, ranging from zero to 0.25 gallons of water per pound of laundry processed. Further,
EPA determined that many facilities were moving away from dry cleaning because of the
hazardous nature of dry cleaning solvents and the expense of their disposal. EPA also determined
that facilities operating dry cleaning units were moving away from the use of PCE as a solvent in
favor of petroleum-based solvents (U.S. EPA, 2000). The proposed pretreatment standards for
industrial laundries considered dry cleaning only within the context of facilities that include
water washing following dry cleaning.
In 1999, EPA ultimately decided not to promulgate national pretreatment standards for
industrial laundries (64 FR 45071). EPA determined that the discharges to POTWs did not
represent a problem warranting national regulation because the pretreatment options determined
to be economically achievable would remove only a small amount of pollutants. In addition,
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EPA believed that POTWs were generally not experiencing problems from industrial laundry
discharges, or that the discharges would be adequately controlled by the existing pretreatment
program. EPA's review of available TRI sector expansion data did not provide any further
information regarding the discharge of specific pollutants from large dry cleaning facilities.
6.4.8 Summary of Findings from EPA's Review of TRI Industry Sectors Expansion
The TRI industry sectors expansion rule is still under development and is expected to be
proposed by December 2014. From the available information, EPA has conducted a limited
review of the six industries proposed to be included in the TRI and has preliminary found:
• The iron ore mining industry sector is regulated by 40 CFR Part 440 (Ore Mining
and Dressing), Subpart A (Iron Ore). EPA previously reviewed discharges from
iron ore mines in 2009 and 2010, as part of a preliminary study of the point source
category. EPA then concluded that no additional review of discharges from iron
ore mines was warranted. EPA's review of the TRI sector expansion proposal
added no new data or information to alter this prior finding.
• The phosphate mining industry sector is regulated by 40 CFR Part 436 (Mineral
Mining), Subpart R (Phosphate Mining). As part of the TRI sector expansion,
public commenters have urged EPA to consider including selenium discharges
from phosphate mines, specifically citing concerns over phosphate mine
discharges in Idaho.
• The steam generation from coal and/or oil industry sector is not currently
regulated by ELGs. EPA investigated this sector as part of its 2009 Steam Electric
Power Generation Detailed Study and determined that some of the discharges
contain similar pollutants to those discharged by steam electric plants; however,
there are relatively few of these plants in operation (and even fewer that use coal,
which would result in flue gas desulfurization (FGD) and/or ash transport
wastewaters). In addition, most of the plants discharge a relatively small amount
of wastewater compared to the steam electric plants. The review of the TRI sector
expansion proposal information published to date added no new data or
information for EPA to consider.
• The petroleum bulk storage industry sector is not currently regulated by ELGs. In
2003 and 2004, EPA performed a detailed study of the industrial category and
found that PBST wastewaters are limited to stormwater discharges. As a result,
EPA concluded that the discharges were adequately regulated and did not warrant
national ELGs. EPA's review of the TRI sector expansion proposal information
published to date found no new data or information to alter this prior finding.
• TRI is proposing to expand coverage to all solid waste combustor facilities
classified under NAICS 562213, regardless of whether the facility is a hazardous
waste combustor. ELGs for the CWT and Waste Combustor Point Source
Categories (40 CFR Part 437 and 40 CFR Part 444, respectively) limit pollutant
discharges from incinerators and hazardous waste combustors, as well as from
other types of centralized waste treatment. This may not include all solid waste
combustors that would be included in the TRI sector expansion. EPA previously
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6.4—Review of TRIIndustry Sectors Expansion
reviewed discharges from hazardous waste combustors and CWTs as part of
EPA's 2009 and 2010 Annual Reviews. EPA concluded that these categories did
not warrant further revision, but that individual facilities would benefit from
permitting and compliance support. EPA's review of the TRI sector expansion
proposal information published to date found no new data or information to alter
this prior finding.
• The large dry cleaning industry category is not regulated by ELGs. In 1999, EPA
reviewed the industrial laundries point source category (which includes some dry
cleaning operations) as part of a proposed rule to establish industrial laundry
pretreatment standards. At the time, EPA considered dry cleaning operations, and
determined that they are not a significant source of wastewater discharge, unless
coupled with a water washing process. EPA also determined that the discharges
from industrial laundries to POTWs in general did not represent a problem
warranting national regulation. Therefore, EPA did not promulgate national
pretreatment standards for this industry. As part of the TRI sector expansion, OEI
is considering adding PCE; however, EPA's prior review of industrial laundries
indicated that many dry cleaning facilities were moving away from PCE toward
less hazardous alternatives. EPA's review of the TRI sector expansion proposal
information published to date added no new data or information to alter this prior
finding not to regulate discharges from industrial laundries, or dry cleaning
operations in particular.
6.4.9 References for Review of TRI Industry Sectors Expansion
1. Champion, Jacquelyn. 2011. Telephone Communications Between Jacquelyn Champion,
FL DEP, and Elizabeth Sabol, Eastern Research Group, Inc., Re: Fluoride Discharges
from Phosphate Mines in Florida. (August 26). EPA-HQ-OW-2010-0824-0024.
6. Hoyt, Marv. 2006. Letter from Marv Hoyt, Greater Yellowstone Coalition, to Steven
Johnson, U.S. EPA, Re: Petition to Add Phosphate Rock Mining to the List of Facilities
Required to Report Releases of Chemicals Under SIC Code 1475. (January 27). EPA-
HQ-OW-2010-0824. DCN 07849.
7. Hoyt, Marv. 2009. Letter from Marv Hoyt, Greater Yellowstone Coalition, to Lisa
Jackson, U.S. EPA Administrator, Re: Petition to Add Phosphate Rock Mining to the List
of Facilities Subject to the Toxic Release Inventory Program of the Emergency Planning
and Community Right to Know Act. (November 3). EPA-HQ-OW-2010-0824. DCN
07850.
8. U.S. Census. 2007. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census07.
9. U.S. EPA. 1982. Proposed Development Document for Effluent Limitations Guidelines
and Standards for the Ore Mining and Dressing Point Source Category. Washington, D.C.
(May). EPA-440-1-82-061.
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6.4—Review of TRIIndustry Sectors Expansion
10. U.S. EPA. 2000. Technical Development Document for the Final Action Regarding
Pretreatment Standards for the Industrial Laundries Point Source Category. Washington,
D.C. (March). EPA-R-00-006. EPA-HQ-OW-2010-0824. DCN 07763.
11. 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.
12. U.S. EPA. 2009a. Steam Electric Power Generating Point Source Category: Final
Detailed Study Report. Washington, D.C. (October). EPA 821-R-09-008. EPA-HQ-OW-
2009-0819-0413.
13. U.S. EPA. 2009b. 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.
14. U.S. EPA. 201 la. Toxics Release Inventory (Fact Sheet). Available online at:
http://www2.epa.gOv/sites/production/files/documents/RY_2011_TRI_Factsheet.pdf
EPA-HQ-OW-2010-0824. DCN 07851.
15. U.S. EPA. 2011 b. Ore Mining and Dressing Preliminary Study Report. Washington, D.C.
(September). EPA-820-R-10-025. EPA-HQ-OW-2008-0517-0712.
16. U.S. EPA. 201 Ic. Phosphate Mining Discussion. Re: Toxic Chemicals Associated with
this Sector. Public comment submitted by Earthworks. Available online at:
http://exchange.regulations.gov/topic/trisectorsrule/discussion/tri-phosphate-mining-
chemicals. (October 6). EPA-HQ-OW-2010-0824. DCN 07852.
17. U. S. EPA. 2011 d. Technical Support Document for the 2010 Effluent Guidelines
Program Plan. Washington, D.C. (October). EPA 820-R-10-021. EPA-HQ-OW-2008-
0517-0618.
18. 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.
19. U.S. Geological Survey. 2011. 2009Minerals Yearbook. (June). Available online at:
http://minerals.usgs.gov/minerals/pubs/myb.html.EPA-HQ-OW-2010-0824.DCN
07853.
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6.5—Review of Analytical Methods
6.5 Review of Analytical Methods
As part of this 2012 Annual Review, EPA reviewed analytical methods recently
developed or revised by the Agency to facilitate its identification of unregulated pollutants in
industrial wastewater discharges. The Agency periodically develops new analytical methods, or
updates existing ones, in response to developments such as the identification of a new class of
pollutants, or if impairments to water bodies indicate the need for altered or new methods.
In some instances, EPA is limited in its ability to regulate pollutants in industrial
wastewater based on the availability or sensitivity of analytical methods. This is particularly true
for emerging contaminants of concern, which may be present in industrial wastewater, but which
EPA cannot definitively detect and/or quantify. In addition, as technology and analytical
techniques evolve, the Agency may improve the accuracy and sensitivity of its existing analytical
methods. EPA recognizes the need to assess these improvements and their potential impacts on
wastewater pollution control. Lower detection limits may reveal the presence of additional
pollutants in regulated wastewater streams that EPA had been unable to detect. EPA reviewed
recent analytical method development activities for two reasons:
• To identify new analytical methods that might help identify unregulated pollutants
in industrial wastewater discharges.
• To identify changes to existing analytical methods that provide for increased
sensitivity, which might allow EPA to identify previously undetected pollutants or
strengthen existing requirements for regulated pollutants.
EPA's review of the wastewater analytical methods included in the 2012 Method Update
Rule identified improved detection limits for some metals and new methods for several other
pollutants of concern in industrial wastewater. These included free cyanide, acid mine drainage
(as a parameter), nonylphenol (NP), and bisphenol A (BPA). EPA also identified several
pesticides, measured by existing analytical methods, that do not currently have effluent limits
under the Pesticide Chemicals Manufacturing, Formulating, and Packaging ELGs (40 CFR Part
455).
EPA also reviewed drinking water analytical methods to determine if new methods have
been developed to detect emerging drinking water contaminants that may be attributed to
industrial wastewater sources. EPA's review of drinking water analytical methods revealed
relatively new methods developed by EPA's Office of Research and Development (ORD) for
perfluorinated chemicals (PFCs) and 1,4-dioxane. EPA's Office of Ground Water and Drinking
Water (OGWDW) is using these methods in its Unregulated Contaminant Monitoring Rule
(UCMR) to evaluate PFCs and 1,4-dioxane in drinking water. EPA has also identified industrial
wastewater discharges for both PFCs and 1,4-dioxane.
The following sections present EPA's 2012 review of analytical methods.
6.5.1 Data Sources
An analytical method is a procedure that determines the concentration of a contaminant
in wastewater or drinking water. Though the analytical methods established for drinking water
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6.5—Review of Analytical Methods
may not be directly applicable to industrial wastewater, EPA included them in this analysis to
identify emerging pollutants in drinking water that may be attributed to sources of industrial
wastewater.
EPA reviewed available information from the following EPA offices to determine if
recently developed analytical methods identify unregulated pollutants in industrial discharges or,
if established wastewater methods have significantly improved sensitivity and lower detection
limits.
• EPA's Office of Water, Office of Science and Technology, Engineering and
Analysis Division (EAD). EAD develops, reviews, and approves analytical
methods used for measuring contaminants in wastewater, both domestic and
industrial.
• EPA's Office of Ground Water and Drinking Water (OGWDW). OGWDW
develops, reviews, and approves analytical methods used for measuring drinking
water contaminants.
• EPA's Office of Research and Development (ORD). ORD supports research
programs that identify the most pressing environmental health research needs with
input from EPA offices, partners, and stakeholders. Currently, ORD is also
developing analytical methods for measuring contaminants in drinking water.
The following sections present the findings of the new analytical methods reviews for
each of these EPA offices.
6.5.2 EAD
• EAD publishes laboratory methods used by industries and municipalities to
analyze the chemical, physical, and biological properties of wastewater and other
environmental samples that are required by regulation. EAD publishes these
methods under the authority of the Clean Water Act (CWA) at 40 CFR Part 136.
EAD develops and updates these analytical methods by working with the EPA
Regions, states, and stakeholders to determine current analytical needs (U.S. EPA,
2012a).
• EAD published a Methods Update Rule in May 2012 (2012 Method Update Rule)
(77 FR 29758) Table 6-50 at the end of this section lists the actions taken in that
rule and their relevance to the 304m annual review process. The updates to the
rule include new and revised methods by EAD, commercial entities, and
voluntary consensus organizations (e.g., Standards Methods Committee).
From its review of the 2012 Method Update Rule, EPA identified five analytical method
updates that may help identify new or unregulated pollutants:
• Metals: EAD added EPA Method 200.5 (Revision 4.2), "Determination of Trace
Elements in Drinking Water by Axially Viewed ICP-AES," to Table IB of Part
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6.5—Review of Analytical Methods
136 as an alternative to EPA Method 200.7. BAD also clarified that the axial
orientation of the torch is allowed for use with EPA Method 200.7 (Revision 4.4),
"Determination of Metals and Trace Elements in Water and Wastes by ICP-AES."
Both methods are acceptable under Part 136 and both methods employ ICP-AES
technology. The use of the axial orientation under both methods allows for greater
sensitivity and lower detection limits for some metals.
• Pesticides: As part of the update of pesticide analytical methods, EAD added
some of the methods for Pesticide Active Ingredients from Table IG in Part 136 to
applicable parameters listed in Table ID for general use. EPA reviewed these
methods and identified 30 pesticides that the methods measure, which do not
currently have effluent limits under the Pesticide Chemicals Manufacturing,
Formulating, and Packaging ELGs (40 CFR Part 455) (see Table 6-51 at the end
of this section).
• Acid Mine Drainage: EAD added EPA Method 1627, "Kinetic Test Method for
the Prediction of Mine Drainage Quality," to Table IB of Part 136 as a new
parameter termed "Acid Mine Drainage." This method may provide additional
characterization of coal mine drainage discharges.
• Free Cyanide: EAD added free cyanide as a new parameter to Table IB of Part
136. The addition of this parameter may affect ELGs for industries that discharge
cyanide.
• Nonylphenol (NP), Bisphenol A (BPA), p-tert-Octylphenol (OP), Nonylphenol
Monoethoxylate (NP1EO), and Nonylphenol Diethoxylate (NP2EO): EAD added
ASTM D7065-06 "Standard Test Method for Determination of Bisphenol A, p-
tert-Octylphenol, Nonylphenol Monoethoxylate, and Nonylphenol Diethoxylate"
to Table 1C of Part 136, which covers these five new chemicals. EPA reviewed
NP and BPA as part of the review of OPPT's Chemical Action Plans and
determined that these pollutants may be present in industrial wastewater discharge
(see Section 6.2 for details). EPA does not currently have information or data
regarding the presence of OP, NP1EO, or NP2EO in industrial wastewater
discharge.
In addition to the 2012 Method Update Rule, EAD is also supporting several initiatives to
add or improve methods for additional contaminants through the following actions:
• Developed revised holding times and preservation conditions for pharmaceuticals
and personal care products in EPA Method 1694 and steroids and hormones in
EPA Method 1698 (U.S. EPA, 2010).
• Developing a draft procedure for measuring perfluorinated carboxylic acids
(PFAC) and perfluorinated sulfonic acids (PFAS) in sewage sludge and biosolids;
(U.S. EPA, 2011; Gomez-Taylor and Walker, 2012).
• Preparing a protocol with which to validate rapid methods for pathogens using
real-time polymerase chain reaction (qPCR).
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6.5.3 OGWDW
• OGWDW requires public water systems (PWSs) to demonstrate that their
drinking water source, water treatment process, and treated waters meet certain
health-based standards, using methods and laboratories approved by EPA or the
states. The approved OGWDW analytical methods include methods developed by
other EPA offices (including ORD and EAD). However, OGWDW also approves
methods developed by consensus method organizations, universities, or
commercial vendors. When OGWDW publishes new regulations, it lists at least
one analytical method (new or existing) for analyzing the regulated pollutants
(U.S. EPA, 2012b).
OGWDW has promulgated drinking water regulations for more than 90 contaminants.
Under the Safe Drinking Water Act, OGWDW established a program requiring PWSs to monitor
unregulated contaminants. In March 2012, OGWDW issued a final action for its Unregulated
Contaminant Monitoring Rule (UCMR) (77 FR 26071). This rule requires PWSs to monitor their
influent water supply for the 29 contaminants listed in Table 6-48. Over the next several years,
OGWDW will work with PWSs, states, and laboratories to evaluate the results of UCMR testing
and determine if further drinking water regulations are warranted.
EPA recognizes that the analytical methods for the pollutants included in the UCMR are
applicable to drinking water and may not necessarily be transferrable for detecting and
quantifying pollutants in industrial wastewater. EPA reviewed the pollutants included in the
UCMR to determine if any are likely attributable to industrial wastewater sources.
Table 6-48. Analytes in OGWDW's 2012 UCMR
29 Unregulated Analytes and Associated Methods
Method
Pollutants Measured
Assessment Monitoring: Targets contaminants that are analyzed with methods that use existing and widely
used technology.
EPA Method 524.3 (GC/MS)
EPA Method 522 (GC/MS)
EPA Method 200.8 (TCP/MS) or alternate SM 3 125
or ASTM D5673-10 Methods
EPA Method 300.1 (IC/Conductivity) or alternate
SM 41 10D or ASTM D6581-08 Methods
Volatile organic compounds:
• 1,2,3-Trichloropropane
• 1,3 -Butadiene
• Chloromethane (methyl chloride)
• 1,1-Dichloroethane
• Bromomethane (methyl bromide)
• Bromochloromethane (Halon 1011)
• Chlorodifluoromethane (HCFC-22)
Synthetic organic compounds:
• 1,4-Dioxane
Metals:
• Cobalt
• Molybdenum
• Strontium
• Vanadium
Oxyhalide anion:
• Chlorate
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Table 6-48. Analytes in OGWDW's 2012 UCMR
29 Unregulated Analytes and Associated Methods
EPA Method 537 (LC/MS/MS)
EPA Method 218.7 (IC/UV-VIS):
Perfluorinated chemicals:
• Perfluorooctanesulfonic acid (PFOS)
• Perfluorooctanoic acid (PFOA)
• Perfluorononanoic acid (PFNA)
• Perfluorohexanesulfonic acid (PFHxS)
• Perfluoroheptanoic acid (PFHpA)
• Perfluorobutanesulfonic acid (PFBS)
• Chromium-6
Screening Survey: Addresses contaminants with analytical methods
that rely on sophisticated technology that may not be widely used in drinking water laboratories.
EPA Method 539 (LC/MS/MS):
Hormones:
• 17-(3-Estradiol
• 17-a-Ethynylestradiol (ethinyl estradiol)
• Estriol (16-a-hydroxy-17-p-estradiol)
• Equilin
• Estrone
• Testosterone
• 4-Androstene-3,17-dione
Pre-Screen Testing: Addresses contaminants that are analyzed with methods that utilize very new or
specialized technology.
See Section III.D.5 of the FR notice for methods
discussion3:
Viruses:
• Enterovirus
• Norovirus
Source: 77 FR 26072.
a Monitoring also includes sampling for pathogen indicators (i.e., total conforms, E. coli, bacteriophage,
Enterococci, and aerobic spores).
From Table 6-48 EPA identified and further reviewed PFCs and 1,4-dioxane, as these
pollutants in drinking water may be attributed to industrial discharges.
EPA did not investigate further the other chemicals listed in Table 6-48. The seven
volatile organic compounds (VOCs) included in the UCMR are discharged by industrial
facilities, but not at significant concentrations. The sum total of all discharges of these seven
VOCs is 1,500 pounds and less than 8 TWPE (DMR Loading Tool). EPA did not identify
industrial wastewater discharge data for hormones, viruses, or chlorate, and EPA historically
reviews metals discharges as part of its annual review process.
PFCs are manmade and do not occur naturally in the environment (U.S. EPA, 2009).
Review of EPA's Office of Pollution Prevention and Toxics (OPPT's) Chemical Action Plan for
long-chain PFCs revealed that several chemical manufacturers in the OCPSF point source
category are discharging PFCs, and PFOA in particular, at levels above the provisional health
advisory level for drinking water (see Section 6.2 for more detail).
• EPA also identified 40 facilities that reported discharges of 1,4-dioxane in 2011
(DMR Loading Tool). EPA's lexicological Review of 1,4-Dioxane (U.S. EPA,
2010) indicates that 1,4-dioxane is a contaminant of some ingredients used in the
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manufacture of personal care products and cosmetics. 1,4-dioxane is used as a
solvent for cellulosics, organic products, lacquers, paints, varnishes, paint and
varnish removers, resins, oils, waxes, dyes, cements, fumigants, emulsions, and
polishing compositions. It has also been used as a solvent in the formulation of
inks, coatings, and adhesives and in the extraction of animal and vegetable oil
(U.S. EPA, 2010).
6.5.4 ORD
ORD's water research provides the science and tools necessary to develop sustainable
solutions for water resource problems, ensuring water quality and availability to protect human
and ecosystem health. This includes development of new methods to measure water
contaminants. ORD currently develops methods for:41
• Bacteria;
• Biological indicators;
• Coliphages;
• Drinking water;
• Protozoa; and
• Viruses.
EPA is focusing on ORD's methods established for pollutants in drinking water to
determine if any are likely attributable to industrial wastewater sources. EPA's Exposure
Research Program has actively conducted drinking water methods research and has developed or
revised several analytical methods within the last five years, shown in Table 6-49. EPA has
identified two of ORD's methods that cover pollutants that OGWDW has included in the UCMR
as new pollutants of concern in drinking water: PFCs and 1,4,-dioxane. EPA's review of these
pollutants is presented above in Section 6.5.3. EPA did not investigate the remainder of these
pollutants or ORD methods further as part of this annual review.
Table 6-49. ORD Drinking Water Methods Developed Within Last Five Years
Method
415.3 Rev 1.1, 1.2
522
Pollutants Addressed
Total Organic Carbon
(TOC)
1,4-Dioxane
Method Description
Determination of Total
Organic Carbon and
Specific UV Absorbance
at 254 nm in Source
Water and Drinking
Water.
Determination of 1,4-
Dioxane in Drinking
Water by Solid Phase
Extraction (SPE) and Gas
Chromatography/Mass
Spectrometry (GC/MS)
with Selected Ion
Monitoring (SIM).
Latest Revision
September 2009
September 2008
41 For more details see EPA's Water Research webpage at http://www.epa.gov/research/mmtd/water.htm.
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Table 6-49. OKD Drinking Water Methods Developed Within Last Five Years
Method
Pollutants Addressed
Method Description
Latest Revision
525.3
Semivolatile organics
(SVOCs)
Determination of
Semivolatile Organic
Chemicals in Drinking
Water by Solid Phase
Extraction and Capillary
Column Gas
Chromatography/Mass
Spectrometry (GC/MS).
February 2012
537 Rev 1.1
Perfluorinated Alkyl Acids
Determination of
Selected Perfluorinated
Alkyl Acids in Drinking
Water by Solid Phase
Extraction and Liquid
Chromatography/Tandem
Mass Spectrometry
(LC/MS/MS).
September 2009
538
Acephate
Aldicarb
Aldicarb sulfoxide
Dicrotophos
Diisopropyl
methylphosphonate
(DIMP)
Fenamiphos sulfone
Fenamiphos sulfoxide
Methamidophos
Oxydemeton-methyl
Quinoline
Thiofanox
Determination of
Selected Organic
Contaminants in Drinking
Water by Direct Aqueous
Injection-Liquid
Chromatography/Tandem
Mass Spectrometry (DAI-
LC/MS/MS).
November 2009
Source: Drinking Water Methods Developed by EPA's Exposure Research Program. Available online at:
http ://www. epa. gov/nerlcwww/ordmeth. htm
6.5.5 Summary of EPA's Findings from Analytical Methods Review
Recent BAD analytical method developments as part of the 2012 Method Update Rule
have reduced detection limits for some metals and added new methods for detecting other
pollutants of concern from industrial wastewater discharge including free cyanide, acid mine
drainage, NP, and BPA. The lowered metals detection limits are significant to the annual review
process because industries may be discharging metals at levels that were previously undetected.
In addition, EPA identified several pesticides measured by some of the approved pesticide
analytical methods that do not currently have effluent limits under the Pesticide Chemicals
Manufacturing, Formulating, and Packaging ELGs (40 CFR Part 455).
In EPA's review of OGWDW and ORD drinking water analytical methods, EPA
identified two relatively new analytical methods that ORD has developed to measure
concentrations of PFCs and 1,4-dioxane in drinking water. OGWDW is referencing these
methods in its UCMR to gather data related to the presence of PFCs and 1,4-dioxane in drinking
water. In addition, EPA determined that these pollutants are discharged in industrial wastewater.
Though the analytical methods may not be transferrable for detecting PFCs in industrial
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6.5—Review of Analytical Methods
wastewater, their use through the UCMR will allow EPA to better characterize the impact of
PFC and 1,4-dioxane discharges from industrial sources on drinking water supplies.
6.5.6 References for Review of A nolytical Methods
1. Gomez-Taylor, Maria and Walker, Lemuel. 2012. Notes from Telephone
Communications Between Maria Gomez-Taylor, U.S. EPA, Lemuel Walker, U.S. EPA,
William Swietlik, U.S. EPA, Eleanor Codding, Eastern Research Group, Inc., and
Elizabeth Sabol, Eastern Research Group, Inc., Re: OW EAD New Analytical Methods.
(January 4). EPA-HQ-OW-2010-0824. DCN 07727.
2. U.S. EPA. 2009. Long-Chain Perfluorinated Chemicals (PFCs) Action Plan.
Washington, D.C. (December 30). Available online at:
http://www.epa.gov/opptintr/existingchemicals/pubs/pfcs_action_plan 1230_09.pdf. EPA-
HQ-OW-2010-0824. DCN 07766.
3. U. S. EPA. 2011. Draft Procedure for Analysis of Perfluorinated Carboxylic Acids and
Sulfonic Acids in Sewage Sludge andBiosolids by HPLC/MS/MS. Washington, D.C.
(December). Available online at: http://water.epa.gov/scitech/methods/cwa/upload/Draft-
Procedure-for-Analysis-of-Perfluorinated-Carboxylic-Acids-and-Sulfonic-Acids-in-
Sewage-Sludge-and-Biosolids-by-HPLC-MS-MS.pdf EPA-821-R-11-007. EPA-HQ-
OW-2010-0824. DCN 07749.
4. U.S. EPA. 2012a. Clean Water Act Analytical Methods. Available online at:
http://water.epa.gov/scitech/methods/cwa/index.cfm.EPA-HQ-OW-2010-0824.DCN
07746.
5. U.S. EPA. 2012b. Safe Drinking Water Act Analytical Methods and Laboratory
Certification. Available online at:
http://water.epa.gov/scitech/drinkingwater/labcert/methods_index.cfm. EPA-HQ-OW-
2010-0824. DCN 07747.
6. U.S. EPA. 2013. ToxicologicalReview of 1,4-Dioxane. Washington, D.C. (September).
Available online: http://www.epa.gov/iris/toxreviews/0326tr.pdf EPA/635/R-09/005-F.
EPA-HQ-OW-2010-0824. DCN 07748.
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Table 6-50 2012 CWA Method Update Rule
Changes EPA Made in May 2012 to Part 136 of the CWA Method Update Rule
77 FR 29758
Pollutant Affected
Summary of Change
New EPA Methods and new versions of previously approved EPA Methods (six categories of pollutants)
Oil and grease
Metals
Pesticides
Microbiologicals
Non-conventionals
Organics
Adds new version of EPA Method 1664, 1664 Revision B: n-Hexane Extractable
Material (HEM) and Silica Gel Treated n-Hexane Extractable Material (SGT-HEM)
by extraction and gravimetry.
This new version of the method describes modifications that are allowed and
modifications that are not allowed when using this method for compliance with
Clean Water Act regulations. EPA will continue to allow Method 1664 Revision A
for current permits because this method is not significantly different from Revision
B.
Approval of EPA Method 200.5 (Revision 4.2), "Determination of Trace Elements
in Drinking Water by Axially Viewed ICP-AES."
Method 200.5 includes performance data for the axial configuration that is not in
Method 200.7 because the axial technology torch results were not available when
Method 200.7 was developed. For some parameters listed in Table IB, the axial
orientation using ICP/AES technology results in greater sensitivity and lower
detection limits than the radial orientation. Both Methods 200.5 and 200.7 are
acceptable methods under Part 136 and both methods employ ICP/AES technology.
Adds EPA Method 525.2 to Table IG in Part 136 as an additional approved method
for all parameters for which EPA previously approved EPA Method 525.1. Adds
EPA Methods 525. 1 and 525.2 to Table ID in Part 136 for the same parameters for
which EPA previously approved EPA Method 525.1 in Table IG. Adds some of the
methods for pesticide active ingredients from Table IG to applicable parameters
listed in Table ID for general use.
Approves new EPA Methods 1622 and 1623 to measure Cryptosporidium and
Giardia. Approves revisions to EPAMethods 1103.1, 1106.1, 1600, 1603, and
1680.
Adds EPA Method 1627, "Kinetic Test Method for the Prediction of Mine Drainage
Quality," to Table IB as a new parameter termed "Acid Mine Drainage."
Approves EPA Method 624, "Purgeables," as an alternative to EPA Method 603 for
the determination of acrolein and acrylonitrile in wastewater.
Relevance to 304m
Annual Review
None currently.
Potential lower detection limits for metals.
EPA reviewed the specific pesticides measured
by the methods for pesticide active ingredients
(referenced in Table IG) and identified several
that are not currently regulated by the Pesticide
Chemicals Manufacturing, Formulating, and
Packaging ELG (40 CFR Part 455).
None currently.
May advise any future reviews of coal mining
discharges.
None currently.
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Table 6-50 2012 CWA Method Update Rule
Changes EPA Made in May 2012 to Part 136 of the CWA Method Update Rule
77 FR 29758
Pollutant Affected
Summary of Change
Relevance to 304m
Annual Review
New standard methods and new versions of approved standard methods (23 methods)
Oil and grease
Ammonia (as N) and
total Kjeldahl
nitrogen
Boron
Inorganic ions
(bromide, chloride,
fluoride,
orthophosphate, and
sulfate)
Arsenic and
selenium,
Aluminum and
beryllium
Chemical oxygen
demand
Chromium
Kjeldahl nitrogen
Mercury
Total Phosphorus
Total Phosphorus
Oxygen, dissolved
Approves SM 5520 B-2001 and SM 5520 F-2001, which provide alternative gravimetric standard
methods for measuring oil and grease.
Approves SM 4500-NH3 G-1997, which provides an alternative automated phenate standard method for
measuring Ammonia and TKN.
Approves SM 4500-B B-2000, which provides an alternative colorimetric (curcumin) standard method for
measuring total boron.
Approves SM 4140 B-1997, which provides an alternative capillary ion electrophoresis with indirection
UV detection standard method for measuring bromide, chloride, fluoride, orthophosphate, and sulfate.
Approves SM 3 1 14 B and 3 1 14C-2009, which provide alternative AA gaseous hydride standard methods
for arsenic and selenium.
Approves SM 3111 E-1999, which provides an alternative direct aspiration atomic absorption
spectrometry standard method for aluminum and beryllium.
Approves SM 5220 B-1997, which provides an alternative titrimetric standard method for chemical
oxygen demand.
Approves SM 3500-CR B-2009, which provides an alternative colorimetric (diphenyl carbazide) standard
method for chromium.
Approves SM 4500-Norg D-1997, which provides an alternative semi-automated block digester
colorimetric standard method for Total Kjeldahl Nitrogen.
Approves SM 3112 B-2009, which provides an alternative cold vapor, manual standard method for total
mercury.
Approves SM 4500-P G-1999 and SM 4500-P H-1999, which provide alternative total, automated
ascorbic acid reduction standard methods for total phosphorous.
Approves SM 4500-P E-1999 and SM 4500-P F-1999, which provide alternative manual and automated
ascorbic acid reduction standard methods for total phosphorous.
Approves SM 4500-O B, D, E and F-2001, which provide alternative Winkler (azide modification)
standard methods for dissolved oxygen.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
6-136
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Section 6—New Data Sources and Hazard Analyses
6.5—Review of Analytical Methods
Table 6-50 2012 CWA Method Update Rule
Changes EPA Made in May 2012 to Part 136 of the CWA Method Update Rule
77 FR 29758
Pollutant Affected
Oxygen, dissolved
Phenols
Phenols
Potassium
Residues
Silica, dissolved
Sulfate
Sulfide
Summary of Change
Approves SM 4500-O E-2001, which provides an alternative Winkler alum flocculation modification
standard method for dissolved oxygen.
Approves SM 5530 B-2005, which provides an alternative manual distillation standard method for
phenols.
Approves SM 5530 D-2005, which provides an alternative colorimetric standard method for phenols.
Approves SM 3500-K C-1997, which provides an option for a selective electrode standard method for
total potassium.
Approves SM 2540 E-1997, which provides an alternative volatile gravimetric standard method for total
residue.
Approves SM 4500-SiO2 E-1997 and SM 4500-SiO2 F-1997, which provide alternative automated
(molybdosilicate) standard methods for dissolved silica.
Approves SM 4500-SO42" C-1997, D-1997, E-1997, F-1997, and G-1997, which provide alternative
gravimetric (C-1997 and D-1997), turbidimetric (E-1997), and automated colorimetric (F-1997) standard
methods for sulfate.
Approves SM 4500-S2 B-2000 and C-2000, which provide alternative sample pretreatment standard
methods for sulfide.
Relevance to 304m
Annual Review
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
New ASTM Methods and new versions of previously approved ASTM Methods (eight methods)
Cyanide, available
Cyanide, available
Cyanide, total
Cyanide, total
Free cyanide
Oxygen, dissolved
Organic carbon
Approves ASTM D2036-09 (B), which provides an alternative cyanide amenable to chlorination; manual
distillation with MgCl2 followed by titrimetric or spectrophotometric ASTM method for available
cyanide.
Approval of ASTM D6888-09, which provides an alternative flow injection and ligand exchange
followed by gas diffusion amperometry ASTM method for available cyanide.
Approval of ASTM D7284-08, which provides an alternative manual distillation with MgCl2 ASTM
method for total cyanide.
Approval of ASTM D75 1 1-09, which provides an option for using segmented flow injection, in-line
ultraviolet digestion followed by gas diffusion amperometry for total cyanide.
Added free cyanide as a new parameter (24A in Table IB). Added two ASTM methods (D4282-02 and
D7237-10) and a new version of OIA1677 (2009) as approved test methods for this parameter.
Approval of ASTM D888-09 (A), which provides an alternative for the Winkler (Azide modification)
ASTM method for dissolved oxygen.
Approval of ASTM D7573-09, which provides an alternative combustion ASTM method for total organic
carbon.
None currently.
None currently.
None currently.
None currently.
May affect ELGs for
industries that discharge
cyanide.
None currently.
None currently.
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Section 6—New Data Sources and Hazard Analyses
6.5—Review of Analytical Methods
Table 6-50 2012 CWA Method Update Rule
Changes EPA Made in May 2012 to Part 136 of the CWA Method Update Rule
77 FR 29758
Pollutant Affected
Nonylphenol,
bisphenol A, p-tert-
octylphenol,
nonylphenol
monoethoxylate, and
nonylphenol
diethoxylate
Summary of Change
Added nonylphenol, bisphenol A, p-tert-octylphenol, nonylphenol monoethoxylate, and nonylphenol
diethoxylate as new parameters (114-118 in Table 1C). Added ASTM D7065-06 as an approved test
method for these parameters.
Relevance to 304m
Annual Review
Unknown. EPA does not
currently have a clear
understanding of the
sources or presence of
these chemicals in
industrial wastewater
discharge.
New alternate test procedures at 40 CFR 136.3 (eight methods)
Oxygen, dissolved,
BODS, cBOD5
Oxygen, dissolved
BODS
CBOD5
Turbidity
Turbidity
Turbidity
Nitrate, nitrite and
combined
nitrate/nitrite
Added Hach Company's Method 10360 as an alternative luminescence measurement of dissolved oxygen
for determination of dissolved oxygen.
Added In-Situ Incorporated' s Method 1002-8-2009 as an alternative luminescence measurement of
dissolved oxygen.
Added In-Situ Incorporated' s Method 1003-8-2009 as an alternative method for BODS.
Added In-Situ Incorporated' s Method 1004-8-2009 as an alternative method for CBOD5.
Added Mitchell Method M5271 as an alternative method for turbidity.
Added Mitchell Method M533 1 as an alternative method for turbidity.
Added Thermo Scientific's Orion Method AQ4500 as an alternative method for turbidity.
Added Easy (1 -Reagent) Nitrate Method as an alternative method for nitrate, nitrite, and combined
nitrate/nitrite.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
None currently.
Clarifications and corrections to previously approved methods in 40 CFR 136.3
Orthophosphate
Clarifies the purpose of the immediate filtration requirement in Orthophosphate measurements, which is to
assess the dissolved or bio-available form of orthophosphorous.
None currently.
Revisions to Table II at 40 CFR 136.3(e) to required containers, preservation techniques, and holding times
Whole Effluent
Toxicity (WET) Test
Cyanide
Alkylated phenols,
adsorbable organic
halides, chlorinated
phenolics
Clarifies sample holding time and handling.
Revises cyanide sample handling instructions.
Adds containers, preservation, and holding times.
None currently.
None currently.
None currently.
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Section 6—New Data Sources and Hazard Analyses
6.5—Review of Analytical Methods
Table 6-50 2012 CWA Method Update Rule
Changes EPA Made in May 2012 to Part 136 of the CWA Method Update Rule
77 FR 29758
Pollutant Affected
Summary of Change
Relevance to 304m
Annual Review
Revisions to 40 CFR 136.4 and 136.5
NA
Changes Part 136.4 and 136.5 to clarify the procedures for obtaining review and approval for the use of
alternate test procedures for those methods for which EPA has published an ATP protocol.
None currently.
Revisions to method modification provisions at 40 CFR 136. 6
NA
Allows users to make certain modifications to an approved method to address matrix interferences
without the extensive review and approval process specified for an alternate test procedure at 136.4 and
136.5.
None currently.
New quality assurance and quality control language at 40 CFR 136. 7
NA
Specifies "essential" quality control elements at 136.7 for use in conducting an analysis for CWA
compliance monitoring.
None currently.
Revisions at 40 CFR Part 423 (Steam)
Total residual
chlorine, free
available chlorine
Revises the 40 CFR Part 423 definitions for total residual chlorine and free available chlorine at 423. 1 l(a)
and 423.11(1) to allow the use of "chlorine — total residual" and "chlorine — free available" methods in
136. 3(a), Table IB, or other methods approved by the permitting authority.
None currently.
NA: Change is general in nature and not applicable to any specific pollutant.
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Section 6—New Data Sources and Hazard Analyses
6.5—Review of Analytical Methods
Table 6-51 Pesticide Chemicals Measured by EPA Approved
Under the Pesticide Chemicals Manufacturing, Formulating,
CFR Part 455)
Methods Without Limits
and Packaging ELGs (40
EPA Method
608.1
614.1
615
617
619
622
622.1
632
Chemical
Chlorobenzilate
Chloropropylate
Dibromochloropropane
Etridiazole
EPN
Dalapon
Carbophenothion
Endosulfan sulfate
Endrin aldehyde
Heptachlor epoxide
Isodrin
Strobane
Atraton
Secbumeton
Simetryn
Chlorpyrifos methyl
Coumaphos
Ethoprop
Ronnel
Tokuthion
Trichloronate
Aspon
Dichlofenthion
Famphur
Fenitrothion
Fonophos
Thionazin
Fluometuron
Neburon
Oxamyl
CAS Number
510156
5836402
96128
2593159
2104645
75990
786196
1031078
7421934
1024573
465736
8001501
1610179
26259450
1014706
5598130
56724
13194484
299843
34643464
327980
3244904
97176
52857
122145
944229
297972
2164172
555373
23135220
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
6.6 Review of Industrial Wastewater Treatment Technologies
The Clean Water Act (CWA) directs EPA to establish Effluent Limitations Guidelines
and Standards (ELGs) based on the performance of particular treatment technologies, application
of best management practices, or implementation of process changes. As described in the EPA's
2002 Draft National Strategy (67 FR 71165), EPA considers several factors when developing its
Effluent Guidelines Program Plans, including the availability of wastewater treatment
technologies. EPA may choose to revise existing ELGs for a point source category if it identifies
an applicable and demonstrated technology, process change, or pollution prevention approach
that would substantially reduce the concentrations of pollutants in the discharged wastewater,
and, consequently, reduce the hazard to human health or the environment associated with the
pollutant discharges.
Traditionally, EPA has reviewed the use and availability of improved treatment
technologies when conducting specific facility-, industry-, and/or pollutant evaluations.
However, EPA recognizes the utility in considering advances in treatment technologies in a more
coordinated manner across all industries as part of its initial screening process. In this way, EPA
will enhance its ability to identify industrial categories or pollutants that warrant further review
for new or revised ELGs. EPA believes it is especially important to consider technology
advances when evaluating the effectiveness of older ELGs, some of which date back to the late
1970s or early 1980s. In some cases, more advanced treatment may be available that would
allow EPA to establish ELGs for new pollutants or to strengthen existing requirements for
regulated pollutants. Further, in considering advances in treatment technologies in its initial
screening of industrial discharges, EPA is addressing one of the key recommendations from a
recent Government Accountability Office (GAO) review of the Effluent Guidelines Program
(GAO, 2012).
As a first step in EPA's efforts to consider treatment technology advances in its screening
of industrial wastewater discharges, EPA has initiated a review of relevant literature regarding
the performance of new and improved industrial wastewater treatment technologies. EPA plans
to capture these data in a searchable industrial wastewater treatment technology (IWTT)
database. EPA intends to use the IWTT database in its screening process in future annual reviews
to quantify the effectiveness of technologies for removing pollutants of concern from specific
industrial wastewater discharges. EPA will use the database, in part, to answer the following
questions:
• What new technologies or changes to existing technologies are specific industries
using to treat their waste streams?
• Are there technologies that can reduce or eliminate wastewater pollutants not
currently regulated by ELGs, or remove pollutants to a greater degree than
industries are currently achieving?
This section summarizes the information sources EPA is currently reviewing and the
treatment technology data EPA is collecting.
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
6.6.1 Industrial Wastewater Treatment Technologies Data Collection
In 2011, EPA began developing an approach to identify and capture, in a searchable
database, performance data for technologies that reduce, remove, or eliminate pollutants from
industrial wastewater. EPA first conducted a brief and general literature search for studies that
documented pilot- or full-scale performance data for industrial wastewater treatment
technologies. This search was not limited to peer-reviewed literature. The purpose of this initial
literature search was to assess the availability and quality of treatment technology performance
data. In addition, EPA evaluated the feasibility of developing a searchable database that it could
use as a tool to screen industrial wastewater discharges based on advances in technologies. EPA
included the following sources in its initial literature search:
• Water Environment Federation Technical Exhibition and Conference (WEFTEC)
(2011 and 2012);
• International Water Conference (IWC) (2011);
• Industrial WaterWorld;
• Pollution Engineering;
• WaterWorld; and
• WEF Industrial Wastewater.
From the initial literature search, EPA identified several articles that were of sufficient
quality for use (see Section 6.6.1.3 for more details) and began cataloging the information in a
searchable IWTT database (see Section 6.6.2 for more details). EPA is now focusing on
collecting a more comprehensive set of data on wastewater treatment performance related to a
few key industries of interest, as identified in recent annual reviews or through stakeholder input
(see Section 6.6.1.1 for more details).
The subsections below discuss the initial key industries, data sources, and quality
assurance and control criteria EPA used to evaluate and document the data included to date in the
IWTT database.
6.6.1.1 Initial Key Industries for Treatment Technology Data Collection
During recent annual reviews, EPA identified new data for the Petroleum Refining (40
CFR Part 419), Metal Finishing (40 CFR Part 433), and Electroplating (40 CFR Part 413) point
source categories suggesting that discharges of metals and other emerging and potentially
hazardous compounds (for the metal finishing and electroplating industries in particular) are of
increasing concern. Further, EPA has identified recent technology advancements that have
significantly improved metals removal since promulgation of the ELGs for these industries. As a
result, EPA is initially focusing on collecting and reviewing performance data for technologies
that remove metals and that treat wastewater discharges from these three industries in particular.
The subsections below detail how EPA selected these initial key industries and pollutant
category.
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
Petroleum Refining
EPA finalized the ELGs for Petroleum Refining (40 CFR Part 419) in 1982 and has made
no significant revisions since that time. However, EPA has periodically reviewed petroleum
refinery discharges as part of the Preliminary and Final Effluent Guidelines Program Plans in
2004-2010 (U.S. EPA, 2004, 2005, 2006, 2007, 2008, 2009, 2011). During its 2004 Final
Effluent Guidelines Program Plan reviews, EPA also conducted a detailed study of this industry
(U.S. EPA, 2004). These reviews focused on discharges of polycyclic aromatic compounds
(PACs), dioxin and dioxin-like compounds, and metals. EPA previously determined that PACs
and the most toxic dioxin congeners were likely not present in the discharge at concentrations
above detectable levels. In addition, EPA determined the concentration of metal pollutants in
refinery wastewaters is at or near treatable levels, leaving little to no opportunity to reduce
metals discharges through conventional end-of-pipe treatment.
During the 2011 Annual Review, EPA again identified the Petroleum Refining Category
for preliminary review because it ranked high, in terms of toxic-weighted pound equivalents
(TWPE), in the 2011 toxicity rankings analysis. EPA conducted a more detailed evaluation of
petroleum refineries in this 2012 Annual Review (see Section 5.2 for details on the continued
review of petroleum refineries in 2012) and, based on new data and information, determined that
changes in the petroleum industry in recent years have led to an increase in the discharge of
metal compounds. These changes include the use of different feedstock, such as Canadian crude
oil and tar sands (Purdue-Argonne Task Force, 2011), and changes in air pollution controls (see
Section 6.3 for additional detail on EPA's review of air pollution controls).
Further, EPA compared 2010 metals concentrations discharge monitoring report (DMR)
data to more recent treatability data for chemical precipitation systems. The data suggests that
technologies are available that could mitigate recent increases in the concentrations of metals
discharged in petroleum refinery wastewater (see Section 5.2). This finding is of particular
interest to EPA because the existing ELGs for petroleum refining only include limitations for
hexavalent and trivalent chromium and do not address the discharge of other metals.
Metal Finishing and Electroplating
EPA finalized the ELGs for Electroplating (40 CFR Part 413) in 1981 and Metal
Finishing (40 CFR Part 433) in 1983. EPA reviewed the ELGs for these industries as part of its
development of the ELGs for Metal Products and Machinery (40 CFR Part 438), which were
promulgated in 2003 (U.S. EPA, 2003). EPA has also periodically reviewed these industries as
part of its annual reviews, including its most recent 2011 Annual Review (U.S. EPA, 2012), but
has not made significant revisions to either regulation since the 1980s.
As part of this 2012 Annual Review, EPA identified that metal finishing wastewater
transfers to POTW sludge may be contributing to higher POTW sludge concentrations of metals,
particularly chromium and nickel (see Section 6.1 for more details). In addition, in a recent letter
to EPA and in its public comments on the Preliminary 2012 Plan, the Association of Clean Water
Administrators (ACWA) urged EPA to revise the ELGs for metal finishing and electroplating, or
prioritize providing additional guidance regarding the pretreatment standards to address recent
changes in wastewater chemistry and the use of "green" technologies (ACWA, 2013a, 2013b).
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
Metals Removal
In the late 1970s and early 1980s, EPA compiled metals treatment and removal data for
several industries (including aluminum forming, battery manufacturing, coil coating, copper
forming, electroplating, and porcelain enameling) into the Combined Metals Database (CMDB).
EPA used the CMDB as the basis for developing metals limits for several of these industry
categories. Since the promulgation of these ELGs, EPA has identified advances in treatment
technologies that may significantly improve metals removals.
6.6.1.2 Data Sources
EPA is collecting and reviewing studies on new or improved IWTT from the following
technical literature:
• Conference proceedings. EPA is reviewing references from three key technical
conferences in the wastewater field that present information on a broad range of
industries: the Water Environment Federation's Technical Exhibit and
Conference, the International Water Conference, and the Water Environment
Federation's Industrial Wastewater Seminar.
• Water-related journals. EPA is reviewing peer-reviewed journal articles from
water-related societies that may provide information on new, more effective
industrial wastewater treatment technologies.
• Industry-specific organizations. EPA is reviewing industry trade organization
publications, such as treatment publications from the American Petroleum
Institute and the American Chemical Society.
EPA is preferentially reviewing literature published since 2000 that documents
wastewater treatment technologies for the metal finishing, electroplating, and petroleum refining
industries, or metals removal in general. EPA selected this date to capture advances in
technologies that have become available since its last in-depth review of metals removals as part
of the development of the Metal Products and Machinery ELGs. To search for relevant literature,
EPA entered various combinations of general and specific keyword search terms related to these
industries and metals removal in online search engines and water industry websites.
EPA has ensured that all data sources entered into the database meet the data quality
criteria described in Section 6.6.1.3.
6.6.1.3 Data Quality Assurance and Control Criteria
EPA is ensuring the quality of the treatment technology data by evaluating the data
sources for accuracy, reliability, representativeness, and reasonableness. The Environmental
Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project
Plan (PQAPP) generally describes the quality objectives in more detail (ERG, 2013a). However,
EPA has established the following criteria specific to its efforts to document and evaluate
treatment technology performance data and sources:
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
• Accuracy. EPA is evaluating the accuracy of the treatment technology
performance data based on whether the documented data are consistent with the
body of information collected as part of the literature search. For the purposes of
this analysis, EPA assumes that the underlying data and information contained in
state and federal reports, selected conference proceedings and peer-reviewed
journal articles are accurate. Although industry publications and conference
proceedings are not peer-reviewed, these resources may provide useful
information for capturing the full range of processes and/or wastes generated by a
specified industry point source or a range of information on specified treatment
technologies.
• Reliability. EPA is evaluating the reliability of the treatment technology
performance data based on whether the data source incorporates the following
attributes:
— Scientific work is clearly written, so that all assumptions and
methodologies can be identified.
— Assumptions and methodologies are consistently applied throughout the
analysis, as reported in the source (when appropriate).
• Representativeness. EPA is evaluating whether the data are representative of a
modern treatment technology applied to industrial wastewater. Therefore, EPA is
collecting industrial wastewater treatment technology information and
performance data published since 2000 so that the data are representative of
current industrial processes and treatment challenges.
• Reasonableness. EPA is evaluating the reasonableness of the treatment
technology performance data based on historical knowledge of each industry's
wastewater characteristics, such as:
— Range of concentrations expected in the untreated waste stream.
— Types of pollutants expected in the untreated waste stream.
— Wastewater generation rates and the expected capacities of the evaluated
treatment technologies.
For more information on EPA's efforts to ensure that the data sources meet the data
quality criteria, see the methodology documented in the Supplemental Quality Assurance and
Control Plan for the Development and Population of the Industrial Wastewater Treatment
Database (ERG, 2013b).
6.6.2 Industrial Wastewater Treatment Technologies Data Storage
As discussed above, EPA is developing a database to capture the wastewater treatment
technology data identified from the reviewed data sources. EPA is structuring the IWTT database
in Microsoft Access™ to collect data on the following:
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
• Treatment systems (i.e., treatment units included in the system, unit order,
chemical additions, system operating conditions and costs, and process diagrams).
• Industries implementing the technologies or industries for which the technology
has been tested.
• Pollutants removed, including influent and effluent quality and pollutant removals
achieved.
• Specific industry motivations for evaluating and employing new technologies.
In addition, EPA is conducting specific quality assurance and control measures to
validate the quality of the data as they are entered into the IWTT database. For more information
on the quality assurance and control measures, see the methodology documented in the
Supplemental Quality Assurance and Control Plan for the Development and Population of the
Industrial Wastewater Treatment Database (ERG, 2013b).
6.6.3 References for Review of Industrial Wastewater Treatment Technologies
1. ACWA. 2013a. Recommendations for Prioritization for the U.S. EPA National
Pretreatment Program. Letter prepared by the Association of Clean Water Administrators
(ACWA). Washington, D.C. (June 20). EPA-HQ-OW-2010-0824. DCN 07858.
2. ACWA. 2013b. Public Comment on the Preliminary 2012 Effluent Guidelines Program
Plan and 2011 Annual Effluent Guidelines Review Report. Letter prepared by the
Association of Clean Water Administrators (ACWA). Washington, D.C. (October 7).
EPA-HQ-OW-2010-0824-0218.
3. ERG. 2013 a. Eastern Research Group, Inc. Environmental Engineering Support for
Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP).
Chantilly, VA. (May). EPA-HQ-OW-2010-0824. DCN 07754.
4. ERG. 2013b. Eastern Research Group, Inc. Supplemental Quality Assurance and Control
Plan for the Development and Population of the Industrial Wastewater Treatment
Technology Database. Chantilly, VA. (November 22). EPA-HQ-OW-2010-0824. DCN
07753.
5. GAO. 2012. Government Accountability Office. Water Pollution: EPA Has Improved Its
Review of Effluent Guidelines but Could Benefit from More Information on Treatment
Technologies. (September). EPA-HQ-OW-2010-0824. DCN 07859.
6. Purdue-Argonne Task Force. 2011. Emerging Technologies and Approaches to Minimize
Discharges into Lake Michigan. Purdue University Calumet Water Institute-Argonne
National Laboratory Task Force. (May). Available online at:
http://webs.purduecal.edu/pwi/phase-ii-comprehensive-report/. EPA-HQ-OW-2010-
0824. DCN 07831.
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Section 6—New Data Sources and Hazard Analyses
6.6—Review of Industrial Wastewater Treatment Technologies
7. U. S. EPA. 2003. Development Document For The Final Effluent Limitations Guidelines
and Standards For The Metal Products & Machinery Point Source Category.
Washington, D.C. (February). EPA-821-B-03-001. EPA-HQ-OW-2010-0824. DCN
07860.
8. 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.
9. 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.
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. 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. 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.
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-2008-0517-0618.
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.
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PART III: RESULTS OF EPA's 2012
ANNUAL REVIEW
-------
Section 7—Results of the 2012 Annual Review
7. RESULTS OF THE 2012 ANNUAL REVIEW
For the 2012 Annual Review, EPA evaluated public comments and stakeholder input
received on the Preliminary 2012 Plan and continued its review of the industrial categories
identified as warranting further investigation during the 2011 toxicity rankings analysis (TRA).
Additionally, EPA reviewed the six new industrial wastewater hazard data sources described in
Section 6. This section presents a summary of the findings and results of the 2012 Annual
Review.
7.1 Continued Review of Select Point Source Categories
During the 2011 TRA, EPA identified three point source categories warranting further
review: meat and poultry products (40 CFR Part 432); petroleum refining (40 CFR Part 419);
and pulp, paper, and paperboard (40 CFR Part 430). EPA continued review of these categories as
part of the 2012 Annual Review. Below are the findings from the 2012 continued category
reviews.
• Meat and Poultry Products (40 CFR Part 432). EPA completed further review
of Toxic Releases Inventory (TRI) reported nitrate discharges and found that the
majority of the top nitrate compound dischargers in the 2009 TRI database are in
compliance with the Part 432 total nitrogen limitations, based on a comparison of
their discharge monitoring report (DMR) discharges to the ELGs. EPA contacted
the permit writers of the remaining top nitrate compound dischargers and
determined that the majority are receiving new permits and meeting Part 432 total
nitrogen limitations. Therefore, EPA concludes that nitrate discharges from meat
and poultry products facilities are decreasing due to the 2004 Part 432 effluent
guidelines revisions, and no further review is warranted at this time.
• Petroleum Refining (40 CFR Part 419). EPA further reviewed discharges of
dioxin and dioxin-like compounds and metals, identified as pollutants of concern
in the TRA for the petroleum refining category during the 2011 Annual Review.
For dioxins, EPA found that one facility's reported discharges contributed to the
majority (65 percent) of the dioxin and dioxin-like compound TRI TWPE,
however this facility's reported dioxin discharges are estimated (based on the
number of reformer catalyst regenerations) and not directly measured. EPA also
reviewed 2010 DMR data for dioxin. EPA only identified one refinery reporting
discharging detectable concentrations of dioxin and furan (above the Method
1613B Minimum Level (ML)), though available data indicates this facility's
discharges result largely from stormwater (from aerial deposition), not the
discharge of treated process wastewater (U.S. EPA, 2004). For metals discharges,
EPA reviewed DMR data from 76 refineries from across the country and
identified metals present in most petroleum refineries' effluent discharges that
exceeded comparable treatability data for metals removals achieved by more
recent technologies.
• Pulp, Paper, and Paperboard (40 CFR Part 430). EPA further reviewed
discharges of dioxin and dioxin-like compounds and found that the majority of
7-1
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Section 7—Results of the 2012 Annual Review
estimated releases reported to TRI were based on pollutant concentrations below
the Method 1613B minimum level. EPA concluded that dioxin and dioxin-like
compounds from pulp and paper facilities are not a hazard priority at this time.
7.2 New Data Sources and Hazard Analyses Results
EPA identified six data new industrial wastewater discharge hazard data sources to
review as part of the 2012 Annual Review. Below are the findings from EPA's review of these
data sources.
• Identification of Industrial Pollutants in Sewage Sludge. EPA's review of the
Targeted National Sewage Sludge Survey (TNSSS) data, combined with available
indirect discharge data from the 2009 TRI database identified the metal finishing
point source category (40 CFR Part 433) as potentially discharging high
concentrations of metals, particularly chromium, nickel, and zinc, to publically
owned treatment works (POTWs). These metals could transfer to sewage sludge
and impact its beneficial use. Based on the TNSSS and 2009 TRI datasets, EPA
did not identify for further review any new pollutants of concern or wastewater
discharges from industrial categories not currently regulated by ELGs. EPA
focused its review on the pollutants in the TNSSS with discharge information
available in TRI since TRI provided a means to link industrial wastewater sources
to the pollutants found in POTW sludge.
• Review of Chemical Action Plans. EPA's review of the Office of Pollution
Prevention and Toxics (OPPT) Chemical Action Plans (CAPs) identified one
chemical category that is being phased out of U.S. commerce; EPA does not
intend to pursue further review for Penta, Octa, and Decabromodiphenyl Ethers
(PBDEs). Two additional chemicals, Methylene Diphenyl Diisocyanate (MDI)
and Toluene Diisocyanate (TDI) do not have significant wastewater discharges.
However, EPA identified that the hydrolysis byproducts of TDI and MDI, toluene
diamine and methyl diphenyl diamine, may be present in industrial wastewater.
EPA found that six of the chemical categories have continued production or
known or potential wastewater discharges (Benzidine dyes, Bisphenol A (BPA),
Hexabromocyclododecane (HBCD), Nonylphenol and Nonylphenol Ethoxylates,
Perfluorinated Chemicals (PFCs), and Phthalates). In addition, EPA found that
short-chain chlorinated paraffins (SCCPs) are used in metal working and have the
potential to be discharged in wastewater even though they are no longer
manufactured in the U.S.
• Identification of Wastewater Discharges Related to Air Pollution Control Not
Currently Covered by ELGs. EPA identified new and revised air regulations
that likely result in the generation of new wastestreams at petroleum refineries
that contain metals. EPA also identified three industries that have air regulations
that may result in an unregulated wastewater discharge; brick and structural clay
product manufacturing, industrial, commercial, and institutional boilers, and
industrial, commercial, and institutional steam generating units. In addition, EPA
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Section 7—Results of the 2012 Annual Review
identified 13 industries with existing ELGs, for which new air regulations may
result in the discharge of new or additional pollutants.
• Review of TRI Industry Sectors Expansion. The TRI sector expansion
rulemaking is still under development, with an expected proposal date of
December 2014. Available TRI sector expansion information suggests that
selenium discharges from phosphate mines (regulated under 40 CFR Part 136)
may be a new pollutant of concern.
• Review of Analytical Methods. EPA reviewed recent analytical method
developments as part of the 2012 Method Update Rule and determined that there
are reduced detection limits for some metals and additions of new methods for
detecting other pollutants of concern from industrial wastewater discharges (e.g.,
free cyanide, acid mine drainage, nonyphenol, and bisphenol A).
In addition, EPA identified several pesticides measured by some of the approved
pesticide analytical methods (listed in 40 CFR Part 136) that do not currently have
effluent limits under the Pesticide Chemicals Manufacturing, Formulating, and
Packaging ELGs (40 CFR Part 455).
EPA also reviewed Office of Ground Water and Drinking Water (OGWDW) and
Office of Research and Development (ORD) drinking water analytical methods
and identified two relatively new methods developed by ORD to measure
concentrations of PFCs and 1,4-dioxane. OGWDW is using these methods in its
Unregulated Contaminant Monitoring Rule (UCMR) to evaluate PFCs and 1,4-
dioxane in drinking water. EPA has identified industrial wastewater discharges
for both PFCs and 1,4-dioxane.
• Review of Industrial Wastewater Treatment Technologies. EPA is identifying
and reviewing wastewater treatment technology performance data related to
petroleum refining, metal finishing, and electroplating industries (and metals
removal in general) and is working to capture this data in a searchable industrial
wastewater treatment technology database.
7.3 References for Results of the 2012 Annual Review
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.
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