SEPA
821-R-06-017
Final Engineering Report:
Tobacco Products Processing Detailed
Study
U.S. Environmental Protection Agency
Engineering and Analysis Division
Office of Water
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
November 2006
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ACKNOWLEDGMENT AND DISCLAIMER
This report was prepared with the technical support of Eastern Research Group,
Inc. under the direction and review of the Office of Science and Technology. Neither the United
States Government nor any of its employees, contractors, subcontractors, or their employees
make any warrant, expressed or implied, or assume any legal liability or responsibility for any
third party's use of, or the results of such use, of any information, apparatus, product, or process
discussed in this report, or represents that its use by such party would not infringe on privately
owned rights.
The primary contact regarding questions or comments on this document is:
Jan Matuszko
U.S. EPA Engineering and Analysis Division (6233Q)
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
(202) 566-1035 (telephone)
(202) 566-1053 (fax)
Matuszko.Jan@epamail.epa.gov
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
2.0 DATA SOURCES 2-1
2.1 Economic Census 2-1
2.2 U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) 2-1
2.3 Toxics Release Inventory (TRI) 2-2
2.4 Permit Compliance System (PCS) 2-3
2.5 National Pollutant Discharge Elimination System (NPDES) and
Industrial User Permits 2-4
2.6 Site Visits and Sampling Episodes 2-4
2.7 Tobacco Products Manufacturers 2-4
2.8 U.S. Geological Survey (USGS) NWISWeb Database 2-5
2.9 Virginia Department of Environmental Quality (VADEQ) 2-5
2.10 POTW Removal Efficiencies 2-5
2.11 50-POTW Study 2-6
2.12 POTW Monitoring Information 2-6
2.13 Information from Comments on the Preliminary 2006 Effluent
Guidelines Plan 2-7
2.14 Internet Literature Search 2-7
3.0 INDUSTRY PROFILE 3-1
3.1 General Overview 3-1
3.1.1 Facility Counts 3-1
3.1.2 Facility Production and Size 3-2
3.1.3 Direct and Indirect Dischargers 3-3
3.1.4 NPDES Facility Information 3-4
3.2 Overview of the Industrial Sectors of the Tobacco Products Industry.... 3-7
3.2.1 Cigarette Manufacturing and Reconstituted Tobacco
Manufacturing 3-7
3.2.2 Cigar Manufacturing 3-8
3.2.3 Other Tobacco Products Processing 3-10
3.2.4 Tobacco Stemming andRedrying 3-11
3.2.5 Summary of Tobacco Products Industry Wastewater Sources..3-12
4.0 TOBACCO PRODUCTS MANUFACTURING PROCESSES AND WASTEWATER
TREATMENT 4-1
4.1 Primary Tobacco Processing 4-1
4.2 Expanded Tobacco Process 4-3
4.3 Flavor Making 4-3
4.4 Reconstituted Tobacco Manufacturing 4-5
4.5 Cigarette Manufacturing 4-7
4.6 Process Wastewaters Generated 4-9
4.7 Wastewater Treatment Operations at Direct Dischargers 4-10
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TABLE OF CONTENTS (Continued)
Page
5.0 EPA SITE VISITS AND SAMPLING 5-1
5.1 Criteria for Site Selection 5-1
5.2 Sites Selected 5-1
5.3 Wastewater Sampling Points 5-1
5.4 Wastewater Sampling Data 5-2
5.5 Wastewater Characteristics 5-3
5.5.1 Discharge Flow 5-3
5.5.2 Direct Dischargers 5-3
5.5.3 Treatment Effectiveness at Direct Dischargers 5-11
5.5.4 State Regulator Information About Direct Discharges 5-14
5.5.5 Summary of Direct Discharge Wastewater Characteristics
and Analyses 5-15
5.5.6 Indirect Dischargers 5-15
5.5.7 Pass Through and Pollutant Loadings Analysis for Indirect
Dischargers 5-25
5.5.8 Summary of Indirect Discharge Wastewater Characteristics
and Analyses 5-35
6.0 REFERENCES 6-1
Appendix A WASTEWATER SAMPLING DATA
11
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LIST OF TABLES
Page
3-1 Tobacco Products Facility Counts 3-2
3-2 Tobacco Products Facilities with Greatest Employment 3-3
3-3 Number of Tobacco Products Facilities with Information in EPA Databases 3-4
3-4 Tobacco Products Facilities with NPDES Permits in 2002 3-5
5-1 Annual Wastewater Discharge Flows for Sampled Tobacco Products Facilities 5-3
5-2 Sampled Directly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE 5-5
5-3 Comparison of Sampled Directly Discharging Tobacco Products Facility
Effluent Pollutant Concentrations to James River Pollutant Concentrations 5-8
5-4 Comparison of Directly Discharging Tobacco Products Facility Sampling
Data to Facility-Provided Data and PCS Data 5-10
5-5 Sampled Directly Discharging Tobacco Products Facility Wastewater
Treatment Pollutant Removals 5-12
5-6 Sampled Indirectly Discharging Tobacco Products Facility Effluent
Pollutant Loads and TWPE, Episode 6511, Sample Number 66161 5-16
5-7 Sampled Indirectly Discharging Tobacco Products Facility Effluent
Pollutant Loads and TWPE, Episode 6512, Sample Number 66167 5-17
5-8 Sampled Indirectly Discharging Tobacco Products Facility Effluent
Pollutant Loads and TWPE, Episode 6513, Sample Number 66171 5-18
5-9 Sampled Indirectly Discharging Tobacco Products Facility Effluent
Pollutant Loads and TWPE, Episode 6515, Sample Number 66176 5-19
5-10 Metal Contributions to Total Facility Annual TWPE 5-20
5-11 Contributions of All Pollutants to Total Facility Annual TWPE 5-21
5-12 Comparison of Indirectly Discharging Tobacco Products Facility Sampling
Data to Facility-Provided Source Water Data 5-22
5-13 Comparison of Indirectly Discharging Tobacco Products Facility Sampling
Data to Facility-Provided and POTW-Provided Data 5-24
5-14 Pollutant Loadings Analysis for Sampled Indirectly Discharging Tobacco
Products Facilities 5-29
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5-15 Comparison of Pollutant Loadings Discharged To and From POTWs 5-33
5-16 POTW Contact Summary 5-34
5-17 Comparison of Metals Concentrations in Sampled Tobacco Products
Facility Discharges to POTWs to Typical POTW Influent 5-35
IV
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LIST OF FIGURES
Page
4-1 Primary Tobacco Processing 4-2
4-2 Expanded Tobacco Process 4-4
4-3 Reconstituted Tobacco Manufacturing Process 4-6
4-4 Cigarette Manufacturing 4-8
4-5 Wastewater Treatment Operations at a Directly Discharging Tobacco
Products Facility 4-11
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1.0 INTRODUCTION
Section 304(m) of the Clean Water Act (CWA) requires EPA to develop and
publish a biennial plan that establishes a schedule for the annual review and revision of the
national effluent limitations guidelines (effluent guidelines) for industrial wastewater discharges
to surface waters of the United States (direct discharges). This plan must also identify directly
discharging industries discharging more than trivial amounts of toxic or "nonconventional"
pollutants for which the Agency has not yet promulgated effluent guidelines. Similarly, Section
307(b) of the CWA requires EPA to establish pretreatment standards for pollutants that are not
susceptible to treatment by publicly owned treatment works (POTWs) or that would interfere
with the operation of POTWs.
Section 304(m) also requires EPA to solicit public comment on its biennial
effluent guidelines plan prior to issuing a final plan. During the comment period for the
Preliminary 2004 Effluent Guidelines Plan (68 FR 75515), EPA received public comment that it
should consider wastewater discharges from the tobacco products processing (tobacco products)
industry for effluent guidelines rulemaking. Specifically, the commenter questioned the quantity
of carcinogens in wastewater discharges associated with cigarette manufacturing.
At the time of publication of the Final 2004 Effluent Guidelines Plan, EPA was
unable to determine, based on readily available information, the following: 1) whether toxic and
nonconventional discharges from the tobacco products industry are trivial or nontrivial, and 2)
whether the tobacco products industry discharges pollutants that are not susceptible to treatment
by POTWs or that interfere with the operation of POTWs. As a result, EPA initiated a detailed
study of the tobacco products industry to address these questions.
This report presents information EPA collected about the tobacco products
industry during its detailed study as well as analyses of data from sampling episodes EPA
conducted at tobacco products facilities.
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2.0 DATA SOURCES
Data sources used for this study of the tobacco products industry include readily
available information from EPA and other federal, state, and local government agencies,
information EPA collected from site visits and sampling, and information provided by the
industry through site visits, telephone contacts, correspondence, and comments on EPA's
Preliminary 2006 Effluent Guidelines Plan.
2.1 Economic Census
The U.S. Census Bureau publishes a profile of U.S. business, the Economic
Census, every five years. The Economic Census reports the number of U.S. business
establishments and the size of these establishments, based on number of paid employees. EPA
used the 2002 Economic Census along with other sources to develop an economic profile of the
domestic tobacco products industry (Covington, 2006).
The 2002 Economic Census reports data by the North American Industry
Classification System (NAICS) code, while EPA's Toxic Release Inventory (TRI) and Permit
Compliance System (PCS) databases report data by the Standard Industrial Classification (SIC)
code. For this reason, EPA converted the 2002 Economic Census data on the tobacco products
industry into the equivalent SIC codes. Section 3.1 of this report includes descriptions of these
SIC codes.
2.2 U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB)
The TTB is part of the U.S. Department of Treasury. Its mission, in part, is to
collect alcohol, tobacco, firearms and ammunition excise taxes and to ensure that these products
are labeled, advertised, and marketed in accordance with the law. Chapter 52 of the Internal
Revenue Code (IRC) of 1986 requires that everyone who intends to manufacture or import
tobacco products, or warehouse tobacco products for export obtain a permit from the TTB.
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EPA contacted the TTB and requested information it collects on tobacco products
facilities as part of its permitting process. In particular, EPA requested information pertaining to
facilities engaged in manufacturing cigarettes, cigars, snuff, chewing tobacco, pipe tobacco, or
roll-your-own tobacco. The TTB provided spreadsheets containing the name, address, TTB
number, and 2004 production information for all tobacco products facilities subject to its
permitting process (TTB, 2006) \ EPA used the TTB information to supplement and confirm the
industry profile.
2.3 Toxics Release Inventory (TRI)
TRI is a database that contains information on toxic chemical releases that
facilities under certain SIC codes report annually to EPA. These facilities report the amount of
toxic chemicals released to the environment as well as the amount of toxic chemicals transferred
in wastes to off-site locations, including discharges to POTWs. EPA reports these toxic
chemical releases in TRI as pounds per year.
A facility is required to report its toxic chemical releases to EPA if: (1) it is
included in a covered SIC code; (2) it has 10 or more employees (or the equivalent of 20,000
hours per year); and (3) it manufactures, imports, processes, or otherwise uses chemicals in
quantities exceeding the reporting thresholds. For toxic chemicals that are not PBT (persistent,
bioaccumulative, and toxic), facilities must provide release information if they manufacture or
process more than 25,000 pounds of the chemical in a year, or if they otherwise use more than
10,000 pounds of the chemical in a year2. For example, tobacco products facilities process the
TRI chemical group, "nicotine and nicotine salts." To determine if a facility must report releases
of nicotine and nicotine salts, it multiplies the total weight of tobacco it processes by the percent
nicotine and nicotine salts to calculate the total quantity of nicotine and nicotine salts processed.
If this amount is more than 25,000 pounds/year, the facility is required to report releases of
nicotine and nicotine salts. The facility must make a similar analysis for every TRI chemical.
1 Information collected by the TTB is subject to provisions of the U.S. Tax Code. These provisions require federal
agencies to ensure that any information released is not associated with, or does not otherwise identify, directly or
indirectly, a particular taxpayer.
2 Reporting thresholds are much lower for PBT chemicals. Facilities must report releases if they manufacture,
process, or otherwise use the following: more than 100 Ib/yr of PBT chemicals; more than 10 Ib/yr of highly toxic,
highly persistent PBT chemicals; and more than 0.1 gram/year of dioxin and dioxin-like compounds.
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EPA used year 2002 data from TRI to create the TRIReleases2002 database (U.S.
EPA, 2005c), which EPA used in this detailed study of the tobacco products industry. For
additional information on TRI reporting and TRIReleases2002, see the 2005 Annual Screening-
Level Analysis (U.S. EPA, 2005a). EPA used TRlReleases2002 to estimate the number of
directly and indirectly discharging facilities (direct and indirect dischargers) within the tobacco
products industry. However, many facilities within the tobacco products industry (SIC code 21)
are not required to report their toxic chemical releases because their size is below the cutoff or
their chemical use is below the thresholds.
2.4 Permit Compliance System (PCS)
The Office of Enforcement and Compliance Assurance (OECA) manages PCS,
which is a national data system that contains permit, compliance, and enforcement status
information on facilities with National Pollutant Discharge Elimination System (NPDES)
permits. Facilities that discharge wastewaters directly to surface waters of the United States are
required to obtain NPDES permits from EPA or state permitting authorities. NPDES facilities
submit Discharge Monitoring Reports (DMRs) to their state permitting authorities in accordance
with their permit requirements, and the permitting authorities input these DMR data to PCS. The
state permitting authorities are required to input DMR data only for facilities that they judge to
be major sources of pollutants (i.e., facilities that are likely to significantly impact receiving
streams if they discharge without control). Thus, PCS identifies all facilities with NPDES
permits, but does not contain pollutant discharge data for all of these facilities.
EPA used PCS data to identify direct dischargers within the tobacco products
industry. Of the nine direct dischargers identified, PCS contains pollutant concentration
discharge data for only one facility, which is considered a major source of pollutants. EPA
obtained pollutant mass loads for this facility from the PCSLoads2002 database (U.S. EPA,
2005b). EPA created the PCSLoads2002 database using the PCS pollutant discharge data from
2002 and various database development tools. For additional information on PCSLoads2002,
see the 2005 Annual Screening-Level Analysis. EPA used the PCSLoads2002 pollutant mass
loads for comparison to pollutant loads calculated from sampling data.
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2.5 National Pollutant Discharge Elimination System (NPDES) and Industrial
User Permits
EPA used the information in the NPDES permits of the nine direct dischargers to
determine the type and amount of wastewater they generate. Similarly, EPA used the
information in the Industrial User permits of several indirect dischargers to determine the type of
wastewater they generate and their existing discharge requirements.
2.6 Site Visits and Sampling Episodes
EPA conducted site visits and wastewater sampling episodes at six tobacco
products facilities in July 2005. EPA conducted the site visits to gain a better understanding of
tobacco products processing operations, and wastewater generation, treatment, and discharge at
direct and indirect dischargers. During these site visits, EPA collected grab samples to further
characterize the wastewater generated and discharged at these facilities, and evaluate wastewater
treatment effectiveness, as applicable.
2.7 Tobacco Products Manufacturers
In addition to providing information during the site visits, each of the facilities
EPA visited provided supplemental information about its site. This information includes NPDES
permits, Industrial User Pretreatment permits, wastewater treatment system documents, source
water pollutant concentration data, and wastewater monitoring data, which includes
concentrations and loads of certain pollutants contained in its wastewater.
EPA communicated with additional tobacco products manufacturers from various
sectors of the tobacco products industry via meetings, telephone calls, letters, and emails. These
manufacturers provided Industrial User Discharge permits and other information that allowed
EPA to better understand their manufacturing processes, wastewater generation, wastewater
controls, discharge requirements, and treatment processes.
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2.8 U.S. Geological Survey QJSGS) NWISWeb Database
The USGS investigates the occurrence, quantity, quality, distribution, and
movement of surface and underground waters. USGS maintains a water database, the National
Water Information System (NWIS), which can only be accessed by USGS. A large subset of the
NWIS database, however, is available to the public via the online NWISWeb database (USGS,
2002). NWISWeb is organized primarily around water monitoring stations.
The two directly discharging tobacco products facilities that EPA sampled are
both located on the James River and both obtain water from this river. EPA obtained the
concentrations of certain pollutants contained in the James River from NWISWeb. USGS
collected these data at monitoring sites located upstream of the two tobacco products facilities.
EPA used these data, along with the facility-provided source water data, to determine the
pollutants and concentrations that may originate in the tobacco products facility source water.
2.9 Virginia Department of Environmental Quality (VA DEO)
EPA contacted VA DEQ to request information on permit violations and/or
problems associated with pollutant discharges from the tobacco products facilities permitted in
the Richmond, Virginia area. EPA used the information provided by VA DEQ to supplement the
information obtained from the site visits and wastewater sampling.
2.10 POTW Removal Efficiencies
The CWA requires EPA to establish pretreatment standards for pollutants that are
not susceptible to treatment by POTWs. EPA previously assembled a list of POTW pollutant
removal efficiencies for the 612 chemicals reported to TRI in 2002 from various sources
(Codding and Bartram, 2005). EPA used these POTW pollutant removal efficiencies, when
applicable, in its detailed study of the tobacco products industry. EPA also assembled a list of
POTW pollutant removal efficiencies for chemicals that were part of previous detailed studies,
some of which are not included in the 2002 TRI chemical list. From this list, EPA used POTW
pollutant removal efficiencies obtained from the Risk Reduction Engineering Laboratory
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(RREL) Treatability Database (U.S. EPA, 1994) and the 50-POTW Study (U.S. EPA, 1982),
when applicable, in its detailed study of the tobacco products industry.
The tobacco products industry discharges a few pollutants for which EPA had not
previously evaluated POTW pollutant removals (e.g., nicotine, and propylene glycol). EPA
obtained POTW removal information for nicotine from an Internet literature search (Snyder,
2002). EPA was unable to find a published source that provides a POTW percent removal
(based on activated sludge or an equivalent treatment technology) for propylene glycol. In
absence of a POTW removal efficiency for propylene glycol, EPA evaluated its biodegradability
and, thus, its potential to pass through a POTW. This evaluation is summarized in the
memorandum entitled, Fate of Propylene Glycol in the Environment and POTWs (Matuszko,
2006c).
2.11 50-POTW Study
EPA obtained POTW influent pollutant concentration data from the 50-POTW
Study (U.S. EPA, 1982). EPA used the influent data from this study because they represent a
wide range of POTWs. Using these data, EPA compared the concentrations of pollutants found
in indirect discharges from tobacco products facilities to those typically found in POTW
influents. EPA also used POTW pollutant removal efficiencies from the 50-POTW Study, as
described in Section 2.10.
2.12 POTW Monitoring Information
EPA contacted the POTWs that receive wastewater from the largest tobacco
products facilities to determine whether pollutant discharges from the tobacco products industry
create problems for POTWs and whether POTWs would benefit from national pretreatment
standards for the tobacco products industry.
The POTWs that EPA contacted also provided limited wastewater monitoring
data from discharges that they receive from the tobacco products facilities. EPA used these data
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to supplement the pollutant concentration data it obtained from the sampled indirectly
discharging tobacco products facilities.
2.13 Information from Comments on the Preliminary 2006 Effluent Guidelines
Plan
During the comment period for the Preliminary 2006 Effluent Guidelines Plan (70
FR 51042), EPA received comments from two tobacco products manufacturers and one POTW
on EPA's detailed study of the tobacco products industry. RJ. Reynolds (Reynolds American)
provided information on its tobacco products processes and study reports on the biodegradability
of nicotine (OW-2004-0032-1096). For an evaluation of these study reports, see Comments on
the Four Reports Submitted by R.J. Reynolds Tobacco Company in Response to Request for Data
in the Notice of Availability of Preliminary 2006 Effluent Guidelines Program Plan (Upgren,
2006). Lorillard Tobacco Company provided a Sewage Collection and Water Reclamation Plant
Report for 2004 for the City of Greensboro (OW-2004-0032-1105.1). The City of Winston-
Salem, North Carolina provided pollutant concentrations and other information on the
wastewater that tobacco products facilities discharge to one POTW (OW-2004-0032-1061).
EPA also received a comment from the National Association of Clean Water Agencies
(NACWA) stating that indirect dischargers within the tobacco products industry are efficiently
regulated by local pretreatment programs (OW-2004-0032-1093). Where relevant, EPA used
information in these comments to supplement its analysis.
2.14 Internet Literature Search
EPA conducted an Internet literature search on the biodegradability of nicotine
and propylene glycol in an effort to determine the fate of these pollutants in the environment
and/or POTWs. EPA used this information to estimate a POTW percent removal for nicotine.
EPA also conducted an Internet search to obtain information on tobacco products manufacturing
processes.
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3.0 INDUSTRY PROFILE
This section presents an overview of the tobacco products industry, including
tobacco products facility counts, production, size, geographic distribution, manufacturing
processes, and wastewater generation.
3.1 General Overview
The tobacco products industry comprises facilities that manufacture cigarettes,
cigars, smokeless tobacco (i.e., chewing, plug/twist, and snuff tobacco), loose smoking tobacco
(i.e., pipe and roll-your-own cigarette tobacco), and reconstituted (sheet) tobacco, as well as
facilities engaged in stemming and redrying tobacco. For a detailed profile of the tobacco
products industry, see the Economic Profile of Domestic Tobacco Manufacturing Industry: 2006
Update (Covington, 2006).
3.1.1 Facility Counts
Table 3-1 presents a breakdown of the number of tobacco products facilities by
NAICS/SIC code, as estimated by the 2002 Economic Census and the TTB. These two sources
provide different estimates of the number of facilities within each SIC code. Some variation in
estimates is to be expected given that the reporting requirements and year of data collection
varies with the data source. The TTB is likely to provide the most inclusive list of tobacco
products facilities, with the exception of tobacco stemming and redrying. The TTB does not
track the number of facilities within the tobacco stemming and redrying SIC code because
products in that SIC code are not subject to taxes managed by the TTB.
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Table 3-1. Tobacco Products Facility Counts
NAICS
Code
(2002)
312221
312229
312210
Description
Cigarette manufacturing
Other tobacco products
Tobacco stemming and
redrying
SIC Code (1987)
2111
2121 (cigars)
2131 (smokeless and loose
smoking tobacco)
2141 (reconstituted tobacco)
2141
Total
Number of
Facilities
(2002 Census)
15
83
16
114
Number of
Facilities
(2004 TTB)
37
69
43
Not Collected
Not Collected
149
Source: Economic Profile of Domestic Tobacco Manufacturing Industry: 2006 Update (Covington, 2006), and U.S.
Alcohol and Tobacco Tax and Trade Bureau (TTB, 2006).
3.1.2
Facility Production and Size
A small number of facilities in the tobacco products industry accounts for the
majority of the total industry employment and tobacco products processing operations. Table 3-
2 presents manufacturing, employment, and location information for these facilities. Five of the
facilities in Table 3-2 are large (>1,000 employees) and account for greater than 60 percent of
the total industry employment (Covington, 2006). Four of these five facilities manufacture
cigarettes and one manufactures cigars. These large facilities are concentrated in North Carolina,
Florida, and Virginia.
EPA believes that Altria, Reynolds American, and Lorillard conduct nearly all of
their domestic cigarette manufacturing operations at the facilities listed in Table 3-2. Based on
2004 TTB production data, these facilities account for the vast majority of the domestic cigarette
production. EPA believes that Swisher conducts nearly all of its cigar manufacturing operations
at its Jacksonville, Florida facility. Based on TTB production data, Swisher is the largest
manufacturer of cigars in the United States.
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Table 3-2. Tobacco Products Facilities with Greatest Employment
Company
Philip Morris
(Subsidiary of Altria)
Reynolds American
Lorillard
Swisher
Manufacturing Sector
Cigarettes
Cigarettes
Cigarettes
Cigarettes
Cigarettes
Cigars
Employees
3,500
2,700
2,100
Unknown
2,300
1,100
Location
Richmond, VA
Concord, NC
Tobaccoville, NC
Winston-Salem, NC
Greensboro, NC
Jacksonville, FL
Source: Economic Profile of Domestic Tobacco Manufacturing Industry: 2006 Update (Covington, 2006).
3.1.3
Direct and Indirect Dischargers
Relatively few tobacco products facilities report discharges to TRI or PCS. Table
3-3 presents the number of tobacco products facilities with information in the TRI and PCS
databases.
As shown in Table 3-3, nine facilities had active NPDES permits in 2002. Thus,
of the 114 tobacco products facilities reported in the 2002 Economic Census, the remaining 105
facilities either discharge no wastewater or discharge their wastewater to a POTW. Only one of
the direct dischargers is classified as a major pollutant discharger in PCS.
As shown in Table 3-3, 20 facilities reported wastewater discharges to TRI in
2002. Thus, of the 114 tobacco products facilities reported in the 2002 Economic Census, the
remaining 94 facilities either discharge no wastewater or discharge wastewater, but do not meet
the TRI reporting requirements summarized in Section 2.3 of this report.
Most facilities that reported discharges to TRI in 2002 either manufacture
cigarettes or reconstituted tobacco, or perform tobacco stemming and redrying operations. A
small portion of the facilities that reported discharges to TRI in 2002 manufacture smokeless or
loose tobacco. No cigar manufacturers reported discharges.
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Table 3-3. Number of Tobacco Products Facilities with Information in EPA Databases
SIC
Code
2111
2121
2131
2141
Description
Cigarette
Manufacturing
Cigar Manufacturing
Smokeless and Loose
Smoking Tobacco
Tobacco Stemming
and Redrying and
Reconstituting
Tobacco
Total
2002 PCS
Active
Permits
2
1
1
5
9
Major Sources of
Pollutants with
DMR Data in PCS
0
0
0
1
1
2002 TRI
Total
7
0
4
9
20
Direct
1
0
0
1
2
Indirect
5
0
4
6
15
Both
1
0
0
2
3
Source: PCSLoads2002_v02 (U.S. EPA, 2005b) and TRIReleases2002_v02 (U.S. EPA, 2005c).
3.1.4
NPDES Facility Information
EPA gathered information on the nine tobacco products facilities with active
NPDES permits by reviewing the facility permits and/or contacting the companies. Table 3-4
contains the detailed information. The following is a summary of the information:
• Four facilities no longer process tobacco or discharge process wastewater:
— Alliance One (formerly Standard Commercial Tobacco Co),
Wilson City, NC,
— R. J. Reynolds Tobacco Co. (Reynolds American), Hanmer Plant,
Chesterfield County, VA,
— RJ. Reynolds Tobacco Co. Brk Cv (Reynolds American), Walnut
Cove Town, NC, and
— Tobacco Technology, Inc., Upperco, MD;
• One facility, GF Vaughan Tobacco Co., Inc., Fayette County, KY,
discharges only boiler blowdown and steam condensate;
• One facility, RJ. Reynolds Tobacco Co. (Reynolds American),
Tobaccoville Plant, Tobaccoville, NC, discharges all of its wastewater to a
POTW;
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Table 3-4. Tobacco Products Facilities with NPDES Permits in 2002
NPDES ID
Company Name
Facility Location
Information
Tobacco Products Process
Wastewater Flow Rate
NC0081884
Alliance One (formerly
Standard Commercial
Tobacco Co
Wilson City MU,
NC
Now closed. The facility conducted tobacco
stemming while in operation (Matuszko, 2005c).
Little to no wastewater from
tobacco processing
operations
VA0002780
RJ. Reynolds Tobacco
Company - Corp (Hanmer
Facility)
Chesterfield
County, VA
Now closed. The facility conducted reconstituted
tobacco manufacturing while in operation.
0.72 MOD (Reynolds,
2005a)
NC0003492
RJ. Reynolds Tobacco Co.
BrkCv
Walnut Cove
Town, NC
The Walnut Cove facility has a small wastewater
treatment plant for domestic wastewater only. No
tobacco processing occurs at this facility anymore
(Curl, 2005).
NA
MD0059307
Tobacco Technology, Inc.
Upperco, MD
EPA attempted to obtain the permit for this facility,
but determined that the facility no longer has an
NPDES permit. The facility now has a general
stormwater permit (Finseth, 2005a).
NA
KY0096008
GF Vaughan Tobacco Co.
Inc.
Fayette County,
KY
EPA reviewed the facility's permit and some DMR
data. The wastewater discharged from the facility
includes boiler blowdown and steam condensate, less
than 200gpd. (Scott, 2001)
NA
PA0039861
Consolidated Cigar Corp.
(Altadis)
McAdoo, Banks
Township, Carbon
County, PA
EPA reviewed the facility's permit. Permit describes
discharges from reconstituted tobacco manufacturing
process, wastewater treatment facility, and contact
cooling water. (Crowley, 2000) Facility operates a
biological wastewater treatment plant. Facility
described cigar filler and reconstituted tobacco
manufacturing processes (Finseth, 2006).
200-300 GPD equipment
cleaning water from cigar
filler process; 35,000 to
41,000 GPD reconstituted
tobacco manufacturing
process wastewater (est.)
(Finseth, 2006).
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Table 3-4 (Continued)
NPDES ID
PR0001091
VA0026557
NC0055093
Company Name
RJ. Reynolds Tobacco (CI)
Comanufacturing American,
Inc. (Reynolds American)
Philip Morris USA, Inc.,
(Park 500 Facility)
RJ. Reynolds Tobacco Co.
Facility Location
Yabucoa, PR
Chesterfield
County, VA
Tobaccoville, NC
Information
Manufactures cigarettes on a small scale (three
cigarette machines vs. 65 at Tobaccoville) (Curl,
2005).
This facility directly discharges a significant amount
of wastewater from its reconstituted tobacco
manufacturing operations (Matuszko, 2005b).
EPA determined that this facility is an indirect
discharger.
Tobacco Products Process
Wastewater Flow Rate
5,000 GPD process
wastewater flow (est);
includes boiler, cooling
tower, and scrubber
blowdown, and equipment
cleaning; majority is
recycled (Holman, 2006b).
1.77 MOD average flow -
2004 DMR data
(Pickelhaupt, 2005).
0.95 MOD permit effluent
limitation, includes process,
domestic, and cooling water
(Bagwell, 2002)
Source: (Bagwell, 2002), (Crowley, 2000), (Curl, 2005), (Finseth, 2005a and 2006), (Holman, 2006b), (Matuszko, 2005b and 2005c), (Pickelhaupt, 2005),
(Reynolds, 2005a), and (Scott, 2001).
-------
• Two facilities produce a small amount of wastewater from their tobacco
products processing operations:
— Consolidated Cigar Corporation, Banks TWP, PA, and
— R. J. Reynolds Tobacco (CI) Comanufacturing America, Inc.,
(Reynolds American), Yabucoa, PR; and
• One facility, Philip Morris USA, Inc., Park 500 Plant, Chesterfield
County, VA, directly discharges a substantial amount of wastewater from
its tobacco products processing operations.
EPA determined that in 2002, only three of the nine NPDES facilities - Reynolds
American, Hanmer Facility, Chesterfield County, VA; Philip Morris, Park 500 Facility,
Chesterfield County, VA; and Consolidated Cigar Corp. (Altadis), Banks Township, PA -
directly discharged substantial amounts of wastewater from their tobacco products processing
operations. Since EPA assembled this information, one of these three direct dischargers, the
Reynolds American, Hanmer Facility has closed (January 2006). Therefore, there are currently
only two operating facilities that directly discharge significant amounts of wastewater from their
tobacco products processing operations. Of these two, the Altadis facility discharge (up to
41,000 GPD) is significantly less than the Park 500 Facility discharge (1.77 MOD).
3.2 Overview of the Industrial Sectors of the Tobacco Products Industry
This section discusses the manufacturing processes and wastewater generation of
the following sectors of the tobacco products industry: cigarette, reconstituted tobacco, cigar,
smokeless tobacco, and loose tobacco manufacturing; and tobacco stemming and redrying
operations.
3.2.1 Cigarette Manufacturing and Reconstituted Tobacco Manufacturing
Cigarette manufacturing in the United States is dominated by a few companies.
Philip Morris USA (a subsidiary of the Altria Group), Reynolds American (the result of a merger
between RJ. Reynolds and Brown and Williamson, a division of British American Tobacco, in
2004), and Lorillard Tobacco Company (part of the Loews Corporation) collectively produced
over 92 percent of the cigarettes manufactured in the United States in 2004 (TTB, 2006). In
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2004, U.S. companies manufactured approximately 493 billion cigarettes (TTB, 2006). The
three dominant cigarette manufacturers collectively operate six cigarette manufacturing facilities
and one reconstituted tobacco manufacturing facility (Covington, 2006). One of the cigarette
manufacturing facilities also performs reconstituted tobacco manufacturing operations.
Two main processes take place at cigarette manufacturing facilities: primary
processing and cigarette manufacturing. These processes are described in Section 4.0. The vast
majority of the process wastewater at cigarette manufacturing facilities is generated by primary
processing. Cigarette manufacturing itself produces little to no wastewater.
Reconstituted tobacco manufacturing facilities process the waste tobacco from
cigarette manufacturing facilities into paper-like sheets. These facilities ship this reconstituted
product to cigarette manufacturing facilities, which blend the product with other tobacco to make
cigarettes. This process is described in Section 4.4. EPA has identified three facilities in the
United States that manufacture reconstituted tobacco. Similar to primary processing operations,
reconstituted tobacco manufacturing operations also generate wastewater.
3.2.2 Cigar Manufacturing
There are three categories of cigars: premium, large, and small. Premium cigars
are hand-made from the highest quality tobacco; the vast majority of premium cigars sold in the
United States are imported. Large cigars are mass-produced by machines from lower quality
tobacco. Small cigars are machine-made and weigh less than three pounds per thousand cigars.
For machine-made cigars, a machine executes most or all of the processing stages, including leaf
picking, tobacco grinding, and cigar rolling. In 2004, U.S. facilities manufactured approximately
equal numbers of small and large cigars (TTB, 2006). Cigarette production far outweighs cigar
production in the United States; in 2004, U.S. companies manufactured approximately seven
billion cigars and 493 billion cigarettes.
In 2004, the top five cigar manufacturers in the United States (Swisher
International Group, Inc., John Middleton, Inc., Altadis USA, Lane Limited, and Swedish Match
Cigars) controlled 80 percent of the market (in terms of production). Eleven facilities reported
-------
manufacturing small cigars in the United States in 2004, while approximately 60 facilities
manufactured large cigars. Most of the large cigar manufacturers are small, with 40 facilities
producing less than 100,000 cigars annually. Five facilities account for 98 percent of the U.S.
production of large cigars (TTB, 2006).
Cigars consist of three major components: the filler, binder, and wrapper. Long
leaves are bunched together as filler for high quality, handmade cigars, whereas short,
fragmented leaves are bunched together as filler for machine-made cigars. The binder holds the
bunched filler tobacco together. The binder may consist of layers of coarse tobacco leaves for
handmade cigars, but for the majority of cigars, the binder is a paper-like sheet of reconstituted
tobacco. In most cases, cigars are wrapped with natural leaves. (USDA, 2005), (Prudent Peddler,
2006), (CigarHandbook, 2006)
EPA contacted the cigar manufacturer Altadis USA, Inc., which recently
purchased Consolidated Cigar Holdings, Inc., to obtain details on the cigar manufacturing
operation and the types of wastewater it generates (Finseth, 2006). The Altadis facility in
McAdoo, Pennsylvania operates a cigar filler process and a reconstituted tobacco process and
has an NPDES permit.
The cigar filler process generates wastewater only when equipment is cleaned
after production stops. The facility uses roughly 200 to 300 gallons of cleaning water per
operation day. The facility uses air pollution control devices that operate without water.
During the reconstituted tobacco manufacturing process, the facility produces a
sheet of tobacco that is used as the binder for cigars. The facility produces a slurry from waste
tobacco stems and leaves (cellulose pulp), and minor ingredients including gums, plasticizers,
clays, and FD&C dyes. The facility pours the slurry onto stainless steel belts and sends it
through a dryer, which produces a tobacco sheet. The dryer is heated with steam. Noncontact
cooling water cools the tobacco sheet once it exits the dryer. This reconstituted tobacco
manufacturing process generates the following wastewaters: product contact wastewater from the
continuous cleaning of the dryer belt, boiler blowdown, steam condensate, wastewater from
5-9
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intermittent cleaning of process equipment, and noncontact cooling water blowdown. The
facility estimates that it produces 35,000 to 41,000 GPD of wastewater.
The facility sends wastewaters from the cigar filler and reconstituted tobacco
manufacturing processes through a wastewater treatment system, which consists of primary
clarification, activated sludge aeration basin, and secondary clarification. The facility then
discharges the treated wastewater to surface waters.
EPA also contacted Swisher International to obtain information on the wastewater
discharges from the cigar manufacturing operations at Swisher's Jacksonville, Florida facility
(Matuszko, 2006b). The cigar manufacturing process at the Swisher facility generates little to no
wastewater. Most of the process wastewater is generated during the production of the tobacco
binder. The Swisher facility has a wastewater permit to discharge its wastewater to the local
POTW, JEA (Jacksonville Electric Authority). The majority of the wastewater discharged to the
POTW is sanitary wastewater. Swisher provides no pretreatment prior to discharge to the
POTW.
3.2.3 Other Tobacco Products Processing
The "other" tobacco products sector (NAICS code 312229) includes a diverse
range of products. Aside from cigars, the products include smokeless tobacco (i.e., moist snuff,
dry snuff, and plug, twist, and loose leaf chewing tobacco) and loose smoking tobacco (i.e., pipe
tobacco and roll-your-own cigarette tobacco). These other sectors mirror cigarette and cigar
production in that a few facilities dominate production. However, production of these other
sectors is negligible in comparison to cigarette production.
Smokeless tobacco products consist of tobacco leaves. The manufacturing
process varies slightly by product (NCI, 2002). In the moist snuff production process, tobacco
leaves are air- or fire-cured and processed into fine particles or strips. Tobacco stems and seeds
are not removed. The final product is packaged loose or in pouches. In the dry snuff production
process, tobacco leaves are fire-cured, fermented, and processed into a dry powder. The final
product is packaged in metal or glass containers. In the plug tobacco production process,
3-10
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enriched tobacco leaves are wrapped in fine tobacco leaves, pressed into bricks, and may be
sweetened and flavored, and packaged. Twist tobacco is typically handmade. Tobacco leaves
are treated with tar-like tobacco leaf extract, twisted into rope-like strands, and dried. Typically,
no flavorings or sweeteners are added. In the loose leaf chewing tobacco production process,
tobacco leaves are air-cured, stemmed, cut or granulated into small strips of shredded tobacco,
and may be sweetened or flavored. The final product is loosely packaged.
The manufacturing process for loose smoking tobacco varies slightly depending
on product. Stems are removed from tobacco leaves. Various types of tobaccos are blended
together. The tobacco is moistened (sometimes with sugar water) and dried, and flavorings may
be added. Flake-type pipe tobacco is often processed further with additional moistening,
pressing, and cutting stages (Mac Baren Tobacco, 2002). Other types of loose smoking tobacco
may be shredded or cut into ribbons (JRCigars, 2006). The finished product is packaged into tins
or pouches.
3.2.4 Tobacco Stemming and Redrying
According to the 2002 Economic Census, there are 16 tobacco stemming and
redrying facilities in the United States. The TTB does not track these facilities. These facilities
process recently harvested tobacco, creating a product that can be stored until it is needed for the
manufacture of cigarettes, cigars, and smokeless tobacco. Thus, these stemming and redrying
facilities are considered the "middle man" between tobacco farmers and manufacturers.
Stemming and redrying facilities are primarily located on the East Coast, near tobacco farmers.
Two companies dominate the stemming and redrying sector of the tobacco
products industry: Universal Corporation and Alliance One International, Inc (Alliance One).
Alliance One is a result of the merger between DEVION International and Standard Commercial
Corporation on May 13, 2005. EPA contacted Alliance One to obtain information on their
processes and wastewater generation (Matuszko, 2005a and 2005c). The contacts confirmed that
there is little to no wastewater discharged from stemming and redrying operations. The only
water used during these operations is that which is sprayed onto the tobacco during the "misting"
process. All of this water is absorbed by the tobacco. The main wastewater source from
3-11
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stemming and redrying facilities is stormwater, which may come in contact with material from
baghouses that are used for air controls. The Alliance One facilities report their stormwater
discharges to TRI.
3.2.5 Summary of Tobacco Products Industry Wastewater Sources
As described above, cigarette manufacturing facilities and their related
reconstituted tobacco manufacturing operations produce the vast majority of process wastewater
generated from tobacco products processing.
Wastewaters from the reconstituted tobacco manufacturing operations differ from
other cigarette manufacturing wastewaters in volume and content. First, the reconstituted
tobacco sheet-forming process generates a much larger volume of wastewater than other
cigarette manufacturing operations. Second, reconstituted tobacco wastewaters contain the
soluble extracts of tobacco constituents. Thus, reconstituted tobacco wastewaters have higher
pollutant concentrations and higher flows than wastewaters from other cigarette manufacturing
operations.
Other than production of reconstituted tobacco, the manufacturing processes used
for cigars, smokeless tobacco, and loose smoking tobacco products involve many of the same
steps and raw materials (i.e., tobacco) as cigarette manufacturing. EPA concluded that the
characteristics of cigarette manufacturing wastewaters, excluding reconstituted tobacco
wastewaters, should be representative of other tobacco products wastewater in terms of
wastewater constituents and concentrations. Therefore, EPA focused the remainder of its
detailed study on characterizing and evaluating process wastewater generated at cigarette
manufacturing facilities.
EPA also evaluated the wastewaters generated from reconstituted tobacco
manufacturing operations and the treatment of these wastewaters.
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4.0 TOBACCO PRODUCTS MANUFACTURING PROCESSES AND WASTEWATER
TREATMENT
EPA obtained information on cigarette manufacturing, primary processing,
reconstituted tobacco manufacturing operations, and wastewater treatment operations during site
visits to tobacco products facilities and through additional communication with the visited
facilities. This section describes the standard operations involved in the production of cigarettes
and reconstituted tobacco, the typical wastewaters produced from these production operations,
and typical wastewater treatment operations.
4.1 Primary Tobacco Processing
The tobacco processing stage that occurs prior to the manufacture of cigarettes is
known in the tobacco products industry as primary processing. Figure 4-1 depicts the following
steps generally involved in the primary processing operations:
Various types of tobaccos (domestic, off-shore, and reconstituted) are sent
through conditioning cylinders, in which steam is added to loosen and
moisten the tobacco.
The conditioned tobacco is sent to storage silos, where some blending
occurs.
Various blends of tobacco are flavored in cylinders, dried, and
remoisturized. Any domestic, "burley" tobacco used in the blend is
processed separately (flavored and dried) prior to final blending.
The final tobacco blend is cut, dried, and remoisturized.
The cut tobacco is sent to flavoring cylinders for final flavoring.
Expanded tobacco, a low density tobacco, is added to the final tobacco
blend during the final processing steps.
The processed tobacco is sent to storage silos and then to the cigarette
manufacturing process.
4-1
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Domestic
(including Burley)"
Offshore
Reconstituted
Conditioning
Cylinders
Storage Silos
Air
Emissions
Flavoring, Drying,
and
Remoisturizing
Final Blending
Burley
Burley Flavoring
and Drying
Cutting, Drying,
and
Remoisturizing
Burley
Final Flavoring
Slowdown
Wastewater
Air Emissions from
Process Cylinders
Expanded
~ Tobacco
Storage Silos
To Cigarette
Manufacturing
Figure 4-1. Primary Tobacco Processing
-------
4.2 Expanded Tobacco Process
Cigarette manufacturers add a low density tobacco, known as expanded tobacco,
to their tobacco blends during the final steps of the tobacco primary processing stage. Figure 4-2
depicts the following steps generally involved in the expanded tobacco process:
• Various types of tobacco (domestic, off-shore, and/or reconstituted), that
have been moistened, cut, and flavored, are flooded with carbon dioxide.
• The process conditions cause the carbon dioxide to solidify within the
tobacco.
• The frozen tobacco is heated rapidly, causing the carbon dioxide to
vaporize. As the carbon dioxide vaporizes, the tobacco cells expand,
creating a low density tobacco.
4.3 Flavor Making
Cigarette manufacturers blend the flavors they use for different brands of
cigarettes. Flavorings are made in batch processes. The various ingredients for the different
flavors are mixed in tanks and pumped to the flavor cylinders that are used in primary
processing. Occasionally, flavor-mixing tanks are washed out, generating wastewater. These
wastewaters are discharged with other primary processing wastewater and represent a relatively
small portion of the wastewater generated and discharged.
4-3
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Liquid Carbon
Dioxide
Gaseous Carbon
Dioxide
JL
Moistened, Cut, and
Flavored Tobacco
(Domestic, Off-Shore,
andtor Reconstituted)
Flooding with
Carbon Dioxide
Freezing of
Carbon Dioxide/
Tobacco
Rapid Heating of
Frozen Carbon
Dioxide/Tobacco
Low Density,
Expanded Tobacco ^
To Primary Processing
Air
Emissions
Slowdown
Wastewater
Air Emissions from
Process
Figure 4-2. Expanded Tobacco Process
4-4
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4.4 Reconstituted Tobacco Manufacturing
Tobacco products facilities produce paper-like sheets of reconstituted tobacco
from tobacco stems and fines that are unusable for primary processing. The reconstituted
product is cut into shreds and blended with other tobacco during primary processing. Figure 4-3
depicts the following steps generally involved in the reconstituted tobacco manufacturing
process:
• Raw material storage: receipt and storage of the raw materials;
• Extraction phase: extraction of the water-soluble materials;
• Evaporation phase: removal of water from the soluble material to
concentrate the tobacco extract;
• Refining stage: changing the properties of the cellulose material for
optimum sheet forming;
• Sheet formation: formation of the cellulose material into a sheet;
• Reapplication of concentrated tobacco extract: application of the
concentrated tobacco extract onto the sheet; and
• Final drying stage: drying and cutting of the tobacco sheet to its final
product specifications.
4-5
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Raw Material Storage
(Tobacco Stems and
Fines)
Extraction
Soluble
Material
Insoluble
Material
Wastewater
Refining
Sheet Formation
Evaporation
Wastewater
Reapplication of
Concentrated
Tobacco Extract
Concentrated
Soluble Material
Excess
Concentrated
Tobacco Extract
Drying and Cutting
To Primary
Processing
Figure 4-3. Reconstituted Tobacco Manufacturing Process
4-6
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4.5 Cigarette Manufacturing
Cigarette manufacturers use tobacco from the primary processing operations to
manufacture cigarettes. Figure 4-4 depicts the following steps generally involved in the cigarette
manufacturing process:
Blended tobacco, which may include reconstituted, expanded, and other
varieties of tobacco, is conveyed from the primary processing storage silos
to the cigarette manufacturing machines.
The cigarette manufacturing machines place the tobacco onto cigarette
paper as one rod, roll and glue the paper around the tobacco, and cut the
rods to the correct length for cigarettes. Glue containers from the cigarette
manufacturing machines are emptied periodically and washed with hot
water.
The machines place filters between two of the cut cigarettes, wrap the
filters to the cigarettes with filter paper, and cut the filters to create two
cigarettes.
The machines pack the cigarettes and place them in cartons.
Cigarettes that do not meet specification are cut open to reclaim the
tobacco. The cigarette paper and filter are disposed of as trash. The
reclaimed tobacco is returned to primary processing.
4-7
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Blended Tobacco from
Primary Processing
To Cigarette
Manufacturing Machines
Paper is Glued
Around Tobacco
Rods and Rods
are Cut
Reclaimed Tobacco is
Returned to Primary
Processing
Filters are
Wrapped to
Cigarettes and
Filters are Cut
•^
T
Rejected
Cigarettes are
Cut Open
•^
Finished
Cigarettes are
Packed and
Placed in
Cartons
Paper and
Filter are
r Disposed of
Figure 4-4. Cigarette Manufacturing
4-8
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4.6 Process Wastewaters Generated
The following wastewaters, which are listed in order of decreasing volume of
wastewater, are typically generated during the production of cigarettes (relative contribution of
wastewater in overall cigarette production is indicated):
• Reconstituted Tobacco Manufacturing Process (largest wastewater
contribution)
— Excess dilution water from sheet forming process (majority of
wastewater in reconstituted tobacco production),
— Excess concentrated tobacco extract,
— Steam condensate from the evaporators,
— Possible blowdown from air pollution control equipment, and
— Machinery, evaporators, and floor wash water.
• Primary Processing (second largest wastewater contribution)
— Rotoclone blowdown. Some process cylinders (e.g., flavoring
cylinders) are equipped with rotoclone hydrostatic precipitators for
air pollution control. These rotoclones clean dust-laden air
emissions by entrapping dust in water. The rotoclones discharge
the water-dust slurry as a blowdown stream. Rotoclone blowdown
contributes the majority of wastewater in primary processing.
— Wash water from process cylinders.
• Expanded Tobacco Process (third largest wastewater contribution)
— Blowdown from air pollution control equipment.
• Flavor Making (insignificant wastewater contribution)
— Flavor tank wash water.
• Cigarette Manufacturing Process (insignificant wastewater contribution)
— Glue container wash water.
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4.7 Wastewater Treatment Operations at Direct Dischargers
This section does not discuss pretreatment at indirectly discharging tobacco
products facilities because they typically do not use pretreatment steps. Wastewater treatment at
directly discharging tobacco products facilities generally consists of biological treatment with
nutrient removal (BNR). The general steps of the BNR treatment process at direct dischargers
are as follows:
• Primary clarifiers;
• BNR wastewater treatment system that includes activated sludge,
nitrification, denitrification, and phosphorus removal;
• Secondary clarifiers;
• Sludges from clarifiers are dewatered in belt presses; and
• Post clarifiers (possible chlorination).
Figure 4-5 depicts the following detailed steps of the BNR treatment process at a
directly discharging tobacco products facility:
• Process wastewater passes through bar screens and grit chambers where
tobacco stems and other large particles are removed.
• The wastewater is sent to primary clarifiers or a surge basin. The surge
basin is used to keep a constant flow through the wastewater system.
• Overflow from the five primary clarifiers mixes with return activated
sludge from the secondary clarifier and is sent to aeration basins. Sludge
from the primary clarifiers is sent to belt filter presses.
• The first of five aeration basins is divided into four quadrants, and the
wastewater flows sequentially through the four quadrants. Quadrant 1 has
a mixer, but is not aerated (anoxic zone). The other three quadrants have
aerators. The dissolved oxygen concentrations increase from about 1 ppm
in Quadrant 2 to about 4 ppm in Quadrant 4.
4-10
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Process
vvu jicwuicr
Flow p
-------
From the first aeration basin, wastewater flows to a biological phosphorus
removal (BPR) selector tank, which is equipped with a mixer. The oxygen
concentration in the tank selects a bacterial population acclimated for
removal of phosphorus.
The other aeration basins (2, 3, 4, and 5) each use aerators that are turned
on and off to alternate between aerobic and anoxic environments. During
the aerated (aerobic) phase in this basin, carbonaceous BOD is degraded
and ammonia is nitrified to nitrite, which is in turn converted to nitrate.
During the unaerated (anoxic) phase, nitrate and nitrite are converted to
nitrogen gas (denitrified), which is released to the atmosphere.
Ferric chloride is added, as needed, to the aeration basins. Adding ferric
chloride facilitates precipitation of phosphorus, further reducing the
concentration of phosphorus in the wastewater.
From the aeration basins, the wastewater flows to six secondary clarifiers
operated in parallel. A portion of the secondary clarifier sludge is
recycled to the aeration basins to optimize biological treatment. Waste-
activated sludge from the secondary clarifiers mixes with sludge from the
primary clarifiers and is sent to sludge dewatering belt presses.
The overflow from the secondary clarifiers is disinfected with sodium
hypochlorite. Clarified wastewater flows into two chlorine contactors,
which are operated in series. Each of the contactors has a retention time
of at least 30 minutes to disinfect the wastewater.
From the chlorine contactors, the wastewater flows into six multimedia
gravity filters. An in-line (nonmechanical) mixer on the final lift pump is
used to mix air into the wastewater to increase the dissolved oxygen level.
Aerated wastewater is then discharged to a river.
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5.0 EPA SITE VISITS AND SAMPLING
EPA conducted site visits and wastewater sampling episodes at six tobacco
products facilities during July 2005. The purpose of the visits was to: 1) gather information
about the operations, wastewater sources, and wastewater management practices at the facilities;
2) collect data to determine the nature and quantity of pollutants generated and discharged by the
facilities; and 3) collect data to estimate the effectiveness of any wastewater treatment systems in
place at the facilities.
EPA generated reports for the six site visits, which include descriptions of sample
collection activities that occurred during the site visits (see OW-2004-0032).
5.1 Criteria for Site Selection
For site visits and sampling, EPA selected a mixture of direct and indirect
dischargers and facilities with and without wastewater treatment processes. Additionally, EPA
selected facilities that represent a range of tobacco products manufacturing operations, but
focused on those with significant production. Ultimately, EPA selected two of the three direct
dischargers and 4 of the 15 indirect dischargers.
5.2 Sites Selected
Two of the six selected facilities discharge wastewater directly to surface waters
and the remaining four facilities discharge wastewater to POTWs. The two direct dischargers
conduct reconstituted tobacco manufacturing operations and also operate on-site wastewater
treatment plants. The four indirect dischargers manufacture cigarettes, and one of these facilities
also conducts reconstituted tobacco manufacturing operations. These indirect dischargers
perform no wastewater treatment prior to discharging to their respective POTWs.
5.3 Wastewater Sampling Points
At the two direct dischargers, EPA sampled the influent to and the effluent from
the BNR wastewater treatment systems. The influent contains tobacco process wastewater and
5-1
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may also contain nontobacco process wastewater (e.g., noncontact cooling water). The effluent
contains treated tobacco process wastewater and treated nontobacco process wastewater.
At all four indirect dischargers, EPA sampled the final effluent discharged to the
POTWs. This effluent contains tobacco process wastewater and sanitary wastewater, and may
contain other nontobacco process wastewater (e.g., noncontact cooling water). At some of the
indirect dischargers, EPA also collected samples at an in-process sample point. This in-process
wastewater contains tobacco process wastewater and may also contain sanitary wastewater and
nontobacco process wastewater.
5.4 Wastewater Sampling Data
The data tables attached to the Tobacco Products Sampling Data memorandum
(Matuszko, 2006a) contain the analytical results from the six wastewater sampling episodes,
including influent and effluent pollutant concentrations from the two direct dischargers, effluent
pollutant concentrations from the four indirect dischargers, and the trip blank results. No
analytes were detected in any of the trip blank samples. For detailed discussions of the analytical
results, including methods used, see Data Review Narratives for Tobacco Products Sampling
(SCC, 2005).
Appendix A of this report contains a subset of the analytical results for the direct
dischargers and a subset for the indirect dischargers. For the direct dischargers' subset, EPA
included pollutants with measured effluent concentrations that are greater than the baseline
values (for at least one of the two direct dischargers). Likewise, for the indirect dischargers'
subset, EPA included pollutants with measured effluent concentrations that are greater than the
baseline values (for at least one of the four indirect dischargers). EPA develops method-specific
"baseline values" for analyzing measurement data collected for effluent guidelines development.
In most cases, the baseline value is the "nominal quantitation limit" stipulated for the specific
method used to measure a particular pollutant. In general, the term "nominal quantitation limit"
describes the smallest quantity of an analyte that can be measured reliably.
5-2
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EPA organized the analytical data by the following pollutant groups: conventional
pollutants, toxic and nonconventional pollutants, and nutrients. Section 5.5 of this report
includes analyses of the data included in Appendix A.
5.5
Wastewater Characteristics
In this section, the sampled tobacco products facilities are referred to by their
sampling episode numbers. The two sampled direct dischargers are referred to as Episode 6510
and Episode 6516. The four sampled indirect dischargers are referred to as Episodes 6511, 6512,
6513, and 6515.
5.5.1
Discharge Flow
Table 5-1 includes annual discharge flows of the final effluent from the six
sampled tobacco products facilities. EPA obtained these annual discharge flows from the
facilities. EPA used these annual discharge flows to calculate annual pollutant loads from the
pollutant concentrations measured in the facility effluents.
Table 5-1. Annual Wastewater Discharge Flows for Sampled Tobacco Products Facilities
Sampling Episode
6510
6516
6511
6512
6513
6515
Annual Discharge Flow (MGY)
235
720
90
288
127
294
Source: (Porter, 2005aandb), and (Shore, 2006).
5.5.2
Direct Dischargers
Section 5.5.2.1 describes the pollutants discharged in the treated final effluent of
the two sampled directly discharging tobacco products facilities. Section 5.5.2.2 compares the
treated effluent pollutant concentrations to their concentrations in the James River. Section
5.5.2.3 compares the treated effluent pollutant concentrations and loads to facility-provided
pollutant concentrations and loads and to PCS loads.
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5.5.2.1 Direct Discharge Pollutant Loads
Table 5-2 contains a subset of the analytical results from effluent data at the two
direct dischargers. It includes only pollutants that were measured above the pollutant-specific
detection level (for at least one of the facilities). In addition, this table includes an estimate of
the annual discharge loadings and toxic-weighted pound equivalents (TWPE) (based on these
measured concentrations, facility-specific discharge flow, and pollutant-specific toxic-weighting
factors (TWFs)).
The total facility annual TWPE for Episode 6516 (779) is roughly six times
greater than the total facility annual TWPE for Episode 6510 (125). This difference is due, in
part, to Episode 6516's effluent flow rate, which is roughly three times greater than Episode
6510's effluent flow rate (720 MGY vs. 235 MGY). In addition to a higher effluent flow rate,
Episode 6516's treated effluent contains higher concentrations of some metals and other toxics,
such as chloride, which may be due to the variable nature of the one-time grab sampling and/or
variations in facility source water (refer to Sections 5.5.2.2 and 5.5.2.3 for further discussion).
Episode 6516's treated effluent also includes the pollutants bromodichloromethane, chloroform,
and dibromochloromethane, which were not detected in the Episode 6510 discharge. These
pollutants are most likely by-products of a chlorination stage of the facility's wastewater
treatment system.
The majority of the total facility annual TWPE in the treated effluents from both
Episodes 6510 and 6516 is from metals (66.1 percent and 77 percent, respectively).
Additionally, the majority of the total metals annual TWPE of both Episode 6510 and 6516 is
from the combination of boron, copper, and magnesium (85.6 percent and 87.7 percent,
respectively).
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Table 5-2. Sampled Directly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE
Pollutant
Units
Baseline
Value
Episode 6510
Concentration
Annual
Load
(Ibs/yr)
Annual
TWPE
Episode 6516
Concentration
Annual
Load
(Ibs/yr)
Annual
TWPE
Conventional Pollutants
BOD5
TSS
mg/L
mg/L
2
1
6
9
Total Conventional Pollutants
11,800
17,700
29,400
NA
NA
NA
5.6
5
NA
33,700
30,000
63,700
NA
NA
NA
Toxic Pollutants
Bromodichloromethane
Chloroform
Dibromochloromethane
Nicotine
Barium
Boron
Calcium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Chloropicrin
Unknown Dithiocarbamate
Pesticide
Ammonia as Nitrogen
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
ug/L
mg/L
mg/L
10
10
10
20
2
100
50
10
100
200
15
10
500
10
2
10
0.5
0.1
0.04
ND (<10)
ND (<10)
ND(<10)
25.2
10
101
60,800
12.9
380
11,500
52.2
ND (<10)
17,300
28.2
109
26
ND(<0.5)
0.15
0.23
Total Toxic Metals
Total Toxic Pollutants
0
0
0
49.5
19.6
198
119,000
25.3
746
22,600
102
0
34,000
55.4
214,000
51,000
0
294
452
177,000
443,000
0
0
0
0.079
0.039
35.1
3.34
16.1
4.18
19.5
1.48
0
0.186
2.60
5.21
0.286
0
35.9
0.680
82.6
125
315
576
86.2
ND (<20)
8.69
155
75,000
61.1
363
24,600
54.4
27.2
132,000
23.4
426
168
0.6
ND(<0.1)
0.9
NA
NA
1,890
3,460
518
0
52.2
931
451,000
367
2,180
148,000
327
163
793,000
141
2,560,000
1,010,000
3.61
0
5,410
1,400,000
4,980,000
62.3
7.19
23.0
0
0.104
165
12.6
233
12.2
128
4.72
32.9
4.35
6.59
62.3
5.65
10.6
0
8.14
600
779
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
1
0.05
4.5
22.9
Total Nitrogen
8,830
45,000
53,800
NA
NA
NA
8.3
1.16
NA
49,900
6,970
56,800
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
0.02
2.87
Total Phosphorus
Facility Total
5,630
5,630
532,000
NA
NA
125
0.18
NA
NA
1,080
1,080
5,070,000
NA
NA
779
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
Ammonia as nitrogen is included in the Toxic Pollutant category and not in the Nitrogen category because summing ammonia and TKN would
double count the ammonia.
TWPE was calculated using TWFs, as described in 2005 Annual Screening-Level Analysis (U.S. EPA, 2005a).
ND - Not detected; NA - Not applicable; Baseline Value - Analytical detection limit.
5-5
-------
After the TWPE contribution of metals, nearly all of Episode 6510's remaining
total facility annual TWPE is from unknown dithiocarbamate pesticide (28.7 percent of total
facility annual TWPE). Its concentration, 0.15 mg/L, is only slightly higher than the minimum
detection level, 0.1 mg/L. Because EPA has information in its record that tobacco growers
sometimes apply mancozeb, a dithiocarbamate pesticide, EPA used the TWF for mancozeb to
calculate the TWPE of this material. This may overestimate or underestimate the TWPE
associated with the detected pesticide.
Unlike Episode 6510, no unknown dithiocarbamate pesticide was detected in
Episode 6516's effluent. However, a small amount of the pesticide chloropicrin was detected
(1.36 percent of total facility annual TWPE), at a concentration of 0.6 ug/L, which was only
slightly higher than the minimum detection limit, 0.5 ug/L.
After the TWPE contribution of metals, roughly half of Episode 6516's remaining
total facility annual TWPE is from bromodichloromethane, chloroform, and
dibromochloromethane (11.9 percent of total facility annual TWPE). As previously mentioned,
these pollutants are most likely byproducts from a chlorination stage of the facility's wastewater
treatment system.
5.5.2.2 Source Water
Because the James River provides the source water for both of the direct
dischargers sampled, EPA compiled data from the USGS NWISWeb database (USGS, 2002) on
the concentrations of pollutants found in the James JAiver. EPA chose three USGS monitoring
sites that are located upstream and in the general vicinity of the two direct dischargers.
5-6
-------
In addition, the facility at which EPA conducted sampling Episode 6516 provided
EPA with pollutant concentrations that it measured in its source water. Table 5-3 presents these
data along with the USGS data on the James River pollutant concentrations and the sampled
direct discharger effluent pollutant concentrations. The sampled direct discharger effluent
pollutant concentrations and the facility-provided source water pollutant concentrations were
measured as total pollutants. Seven of the USGS pollutant concentrations presented in Table 5-3
were measured as total pollutants (barium, copper, iron, manganese, molybdenum, nickel, and
zinc) and six of the pollutant concentrations (calcium, sodium, chloride, magnesium, sulfate, and
boron) were measured as dissolved pollutants.
As previously shown in Table 5-2, metals appear to contribute the majority of
TWPE detected in the effluent of the two direct dischargers. As shown in Table 5-3, the James
River water appears to contribute significantly to the metals detected in the effluent of the two
direct dischargers. Specifically, the USGS-reported dissolved concentration of boron, and total
pollutant concentrations of barium, iron, and manganese are greater than the EPA-sampled total
pollutant concentrations.
Section 5.5.2.1 highlights three pollutants, boron, copper, and magnesium, that
contribute the greatest percentage of the total metals TWPE for both of the direct dischargers.
The concentration data presented in Table 5-3 suggest that nearly all of the boron and a large
portion of the magnesium concentration detected at both facilities originate from the James River
water. Little, if any, of the copper concentration appears to originate from the James River
water.
5-7
-------
Table 5-3. Comparison of Sampled Directly Discharging Tobacco Products Facility Effluent Pollutant Concentrations to
James River Pollutant Concentrations
Pollutant
Barium
Boron3
Calcium3
Copper
Iron
Magnesium3
Manganese
Molybdenum
Sodium3
Zinc
Chloride3
Sulfate3
Units
ug/L
ug/L
mg/L
ug/L
ug/L
mg/L
ug/L
ug/L
mg/L
ug/L
mg/L
mg/L
Baseline
Value
(for EPA
sampling)
2
100
0.05
10
100
0.2
15
10
0.5
10
2
10
Effluent
Concentration
Episode 6510
10
101
60.8
12.9
380
11.5
52.2
ND (<10)
17.3
28.2
109
26
Effluent
Concentration
Episode 6516
8.69
155
75
61.1
363
24.6
54.4
27.2
132
23.4
426
168
uses
James River
Concentration
Sitel
(203853010)
65.6
158
5.22
0.8
880
1.84
832
<2
13.8
15 (est)
10.4
5.7
uses
James River
Concentration
Site 2
(203853030)
245
409
11.3
<1
78,100
7.65
3,750
<2
69.8
22 (est)
94.2
2
uses
James River
Concentration
Site 3
(203853050)
175
189
14.6
<1
4,210
8.66
1,590
<2
32.5
18 (est)
70.2
5
Facility Provided
Source Water
Concentration
(Episode 6516)
33
<500
100
<13
<100
21
35
<25
110
<100
26
24
oo
Source: (Bridges, 2006), Tobacco Products Sampling Data (Matuszko, 2006a), andUSGS database (USGS, 2002).
3USGS data are dissolved concentrations.
ND - Not detected; Baseline Value - Analytical detection limit.
-------
5.5.2.3 Facility-Provided Data and PCS Data
The direct dischargers at which EPA conducted sampling Episodes 6510 and
6516 provided EPA with monitoring data for the effluent from their wastewater treatment
processes. The facility at which EPA conducted Episode 6510 provided EPA with monitoring
data for the months of January through June, 2005. This facility provided pollutant
concentration (ppm), which EPA converted into Ibs/year based on the facility-provided effluent
flow rate. The facility at which EPA conducted sampling Episode 6516 provided EPA with
monitoring data for the years 2002 through 2004. EPA compared the most recent data (2004) to
the sampling data. This facility provided pollutant concentration in mg/L, pollutant loads in
Ibs/day, and in some cases, pollutant loads in kg/month for each month of 2004. EPA converted
the provided loads into Ibs/month and added all months for an annual load.
Table 5-4 presents the facility-provided data along with EPA sampling data.
Table 5-4 also includes PCSLoads2002 calculated loads for Episode 6510. No 2002 PCS data
are available for Episode 6516, so no PCSLoads2002 loads are presented for Episode 6516 on
Table 5-4. Table 5-4 includes only the pollutants for which the facilities provided data and/or for
which 2002 PCS data is available.
Differences between the annual loads estimated with EPA's sampling data and the
loads estimated with facility-provided data are most likely due to the fact that loads estimated
with EPA's sampling data are based on one grab sample and a rough annual facility flow rate.
The facility-provided data are more representative. Despite the difference in sample
measurement, EPA's estimated loads are within an order of magnitude of the facility-provided
loads. Likewise, EPA's estimated annual loads are within an order of magnitude of the
PCSLoads2002 loads.
5-9
-------
Table 5-4. Comparison of Directly Discharging Tobacco Products Facility Sampling Data to Facility-Provided Data and PCS
Data
Pollutant
Units
EPA-
Measured
Concentration
EPA-Estimated
Annual Load
(Ibs/year)
Facility-Provided
Concentration
(mg/L)
Facility-
Provided Load
(Ibs/year)
PCS Loads 2002
(Ibs/year)
Episode 6510a
Biochemical Oxygen Demand (BOD5)
Total Suspended Solids (TSS)
Ammonia as Nitrogen
Total Kjeldahl Nitrogen (TKN)
Nitrate/Nitrite
Total Phosphorus
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
6
9
0.23
4.5
22.9
2.87
11,800
17,700
452
8,830
45,000
5,630
—
10
1.01
8.15
3.33
1.37
—
19,600
1,980
16,000
6,540
2,690
17,390
39,822
2,143
—
—
3,403
Episode 6516
BOD5
TSS
Ammonia as Nitrogen
TKN
Nitrate/Nitrite
Total Phosphorus
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
5.6
5
0.9
8.3
1.16
0.18
33,700
30,000
5,410
49,900
6,970
1,080
—
10.6
0.37
12.4
2
1.2
—
56,819
1,811
71,132
10,382
6,778
—
—
—
—
—
—
Source: PCSLoads2002_v02 (U.S. EPA, 2005b), (Pickelhaupt, 2005), (Reynolds, 2005b), and Tobacco Products Sampling Data (Matuszko, 2006a).
aThe facility at which EPA conducted sampling Episode 6510 provided concentrations and EPA calculated loads.
A dash (—) indicates that no facility data was provided for the pollutant.
-------
5.5.3 Treatment Effectiveness at Direct Dischargers
Table 5-5 presents the percentage of pollutants removed by the wastewater
treatment systems at the two direct dischargers. In the cases where the detected pollutant
concentrations are greater in the effluent than the influent, a negative percent removal is
indicated.
Overall, the data in Table 5-5 demonstrate that the treatment technology at the
direct dischargers is effective. The calculated pollutant percent removals from Episodes 6510
and 6516 indicate that the direct discharger wastewater treatment technology is capable of
removing the majority of conventional pollutants from the wastewater of the direct dischargers
(greater than 87 percent).
Similarly, the pollutant percent removals indicate that the direct discharger
wastewater treatment technology is capable of removing the majority of the nutrients from the
wastewater. For both episodes, the removal of total nitrogen, ammonia, and total phosphorus is
greater than 71, 93, and 79 percent, respectively. Nitrate/nitrite is higher in the effluent of the
wastewater treatment process than in the influent for Episode 6510, which could be due to
variability in the nitrification stage.
The pollutant percent removals indicate that the treatment technology is capable
of removing nearly all of the nicotine from the direct discharger wastewater (greater than 99.9
percent removal).
In general, the pollutant percent removals indicate that the treatment technology is
capable of removing the majority of the metals from the direct discharger wastewater. The
majority of the metals are reduced by greater than 80 percent and/or reduced to concentrations
that are near the analytical detection limits.
5-11
-------
Table 5-5. Sampled Directly Discharging Tobacco Products Facility Wastewater
Treatment Pollutant Removals
Pollutant
Units
Baseline
Value
Episode
Influent
Concentration
Influent
MeasType11
Effluent
Concentration
Effluent
MeasType11
Percent
Removal"
Conventional Pollutants
BOD5
BOD5
TSS
TSS
Hexane Extractable Material
(HEM)
HEM
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
2
2
1
1
5
5
6510
6516
6510
6516
6510
6516
538
1,230
580
2,940
46.9
88.9
NC
NC
NC
NC
NC
NC
6
5.6
9
5
6
5.6
NC
NC
NC
ND
ND
ND
98.9%
99.5%
98.4%
>99.8%
>87.2%
>93.7%
Toxic Pollutants
2-Propanone
2-Propanone
Bromodichloromethane
Bromodichloromethane
Chloroform
Chloroform
Dibromochloromethane
Dibromochloromethane
Nicotine
Nicotine
Propachlor
Propachlor
Acetaldehyde
Acetaldehyde
Formaldehyde
Formaldehyde
Propylene Glycol
Propylene Glycol
Aluminum
Aluminum
Barium
Barium
Boron
Boron
Cadmium
Cadmium
Calcium
Calcium
Chromium
Chromium
Copper
Copper
Iron
Iron
Magnesium
Magnesium
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
50
50
10
10
10
10
10
10
20
20
0.1
0.1
0.5
0.5
0.5
0.5
10
10
50
50
2
2
100
100
5
5
50
50
10
10
10
10
100
100
200
200
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
89.1
285
10
10
10
10.8
10
10
48,700
48,800
0.18
0.1
0.55
3.02
0.55
0.36
14.3
10
917
3,390
158
646
122
155
5
5.16
84,000
172,000
10
25.3
48.5
90.5
1,250
26,600
20,900
27,200
NC
NC
ND
ND
ND
NC
ND
ND
NC
NC
NC
ND
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
ND
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
50
50
10
315
10
576
10
86.2
25.2
20
0.1
0.1
0.14
0.23
0.18
0.14
10
10
50
50
10
8.69
101
155
5
5
60,800
75,000
10
10
12.9
61.1
380
363
11,500
24,600
ND
ND
ND
NC
ND
NC
ND
NC
NC
ND
ND
ND
NC
NC
NC
NC
ND
ND
ND
ND
NC
NC
NC
NC
ND
ND
NC
NC
ND
ND
NC
NC
NC
NC
NC
NC
—
>82.5%
—
—
—
—
—
—
99.95%
>99.96%
—
—
—
99.4%
—
—
—
—
>94.6%
>98.5%
93.7%
98.7%
—
—
—
—
27.6%
56.4%
—
—
—
32.5%
69.6%
98.6%
45.0%
9.6%
5-12
-------
Table 5-5 (Continued)
Pollutant
Manganese
Manganese
Molybdenum
Molybdenum
Sodium
Sodium
Titanium
Titanium
Zinc
Zinc
Chloride
Chloride
Sulfate
Sulfate
Chloropicrin
Chloropicrin
Unknown Dithiocarbamate
Pesticide
Unknown Dithiocarbamate
Pesticide
Ammonia as Nitrogen
Ammonia as Nitrogen
Units
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
mg/L
ug/L
ug/L
mg/L
mg/L
mg/L
mg/L
Baseline
Value
15
15
10
10
500
500
10
10
10
10
2
2
10
10
0.5
0.5
0.1
0.1
0.04
0.04
Episode
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
Influent
Concentration
435
1,050
12.1
10
8,540
50,800
21.4
10
153
635
93
218
88
89
0.5
0.5
0.1
0.1
21.1
13.1
Influent
MeasType11
NC
NC
NC
ND
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
ND
ND
ND
ND
NC
NC
Effluent
Concentration
52.2
54.4
10
27.2
17,300
132,000
10
10
28.2
23.4
109
426
26
168
0.5
0.6
0.15
0.1
0.23
0.9
Effluent
MeasType11
NC
NC
ND
NC
NC
NC
ND
ND
NC
NC
NC
NC
NC
NC
ND
NC
NC
ND
NC
NC
Percent
Removal1"
88.0%
94.8%
—
—
-103%
-160%
—
—
81.6%
96.3%
-17.2%
-95.4%
70.5%
-88.8%
—
—
—
—
98.9%
93.1%
Nitrogen
TKN
TKN
Nitrate/Nitrite
Nitrate/Nitrite
mg/L
mg/L
mg/L
mg/L
1
1
0.05
0.05
6510
6516
6510
6516
80.4
163
14.4
36.8
NC
NC
NC
NC
4.5
8.3
22.9
1.16
NC
NC
NC
NC
94.4%
94.9%
-59.0%
96.8%
Phosphorus
Total Phosphorus
Total Phosphorus
mg/L
mg/L
0.02
0.02
6510
6516
13.8
45.6
NC
NC
2.87
0.18
NC
NC
79.2%
99.6%
Other Pollutants
Total Dissolved Solids
Total Dissolved Solids
Silica Gel Treated Hexane
Extractable Material (SGT-
HEM)
SGT-HEM
Alkalinity
Alkalinity
Total Organic Carbon (TOC)
TOC
Chemical Oxygen Demand
(COD)
COD
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
10
10
5
5
10
10
1
1
50
50
6510
6516
6510
6516
6510
6516
6510
6516
6510
6516
930
2,350
5.9
11.9
475
620
412
1,090
1,410
4,000
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
721
1,830
6
5.6
270
534
27.8
50.7
82
135
NC
NC
ND
ND
NC
NC
NC
NC
NC
NC
22.5%
22.1%
~
—
43.2%
13.9%
93.3%
95.3%
94.2%
96.6%
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
a MeasType -type of measurement.
bPercent removals were only calculated when the influent concentration was greater than five times the baseline value.
ND - Not detected; NC - Not censored; Baseline Value - Analytical detection limit; a dash (—) indicates that a percent removal was not calculated.
5-13
-------
As reported in Section 5.5.2.1, three pollutants, boron, copper, and magnesium,
contribute the greatest percentage of the total metals annual TWPE for both of the direct
dischargers. The concentration data presented in Table 5-3 suggest that a large portion of the
boron and magnesium detected at both direct dischargers originate from the James River water.
Little, if any, of the copper concentration appears to originate from the James River water. The
wastewater treatment system pollutant removal calculated for copper is only 32.5 percent, as
shown in Table 5-5. Although the percent removed is fairly low (due to low influent
concentration), the copper concentration discharged is relatively close to the minimum detection
limit of the analytical test method.
The wastewater treatment process reduced the propylene glycol concentration to
the analytical detection limit in Episode 6510. Propylene glycol was not detected in the influent
in Episode 6516. Propylene glycol is readily biodegradable, as discussed in the memorandum
entitled, Fate of Propylene Glycol in the Environment andPOTWs (Matuszko, 2006c).
The wastewater treatment process appears to add bromodichloromethane,
chloroform, and dibromochloromethane to the wastewater of Episode 6516. This could be due to
a chlorination stage of the wastewater treatment process.
Two pesticides were detected in the effluent samples, but not in the influent.
Chloropicrin was detected in the treated effluent of Episode 6516 and unknown dithiocarbamate
pesticide was detected in the treated effluent of Episode 6510. However, both pesticide
concentrations are just slightly above the detection limit of the test methods.
5.5.4 State Regulator Information about Direct Discharges
EPA received information from the VA DEQ about two tobacco products
facilities in the Richmond, Virginia area with NPDES permits (Winter, 2006). One of these
facilities recently ceased its operations. While in operation, both facilities operated strong
internal environmental programs. Both facilities discharged wastewaters to a water-quality-
limited segment of the James River. VA DEQ reported that there have been few problems with
5-14
-------
the tobacco products facility wastewater over the years. There have been periodic complaints
from the public about the brown color of the wastewater.
5.5.5 Summary of Direct Discharge Wastewater Characteristics and Analyses
As explained in Section 3.1.4, EPA has identified only two tobacco products
facilities that currently discharge significant quantities of process wastewater directly to waters
of the United States. EPA collected samples and evaluated discharge data from one of these
facilities and from another that has since closed. EPA's review of data from these two directly
discharging tobacco products facilities demonstrates that such discharges are characterized by
low concentrations of toxic and nonconventional pollutants - primarily metals. EPA found
existing on-site wastewater treatment systems to be highly efficient, with BOD5 and nicotine
removals in excess of 99 percent. Remaining metals discharges largely result from source water
contributions. Finally, permitting authorities report few problems with tobacco products
processing discharges.
5.5.6 Indirect Dischargers
Section 5.5.6.1 describes the pollutants discharged in the untreated final effluent
of the four indirectly discharging tobacco products facilities sampled by EPA. Section 5.5.6.2
compares the untreated effluent pollutant concentrations to their concentrations in facility source
water. Section 5.5.6.3 compares the untreated effluent pollutant concentrations and loads to
facility-provided pollutant concentrations and loads and to POTW-provided influent pollutant
concentrations.
5.5.6.1 Indirect Discharge Pollutant Loads and TWPE
Tables 5-6 through 5-9 contain subsets of the analytical results from the four
indirect dischargers sampled by EPA. The tables include only pollutants that were measured
above the pollutant specific detection level (for at least one of the facilities). In addition, these
tables include an estimate of the annual discharge loadings and TWPE (based on these measured
concentrations and facility-specific discharge flow). These loadings are discharged to POTWs
and, as presented, do not account for POTW removals.
5-15
-------
Table 5-6. Sampled Indirectly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE, Episode 6511, Sample Number 66161
Pollutant
Units
Baseline
Value
Concentration
Annual Load
(Ibs/year)
Annual
TWPE
Conventional Pollutants
BOD5
TSS
HEM
mg/L
mg/L
mg/L
2
1
5
1210
341
16.3
Total Conventional Pollutants
909,000
256,000
12,200
1,180,000
NA
NA
NA
NA
Toxic Pollutants
2-Propanone
Benzole Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
2620
ND (<50)
ND (<10)
30,800
0.49
0.2
29.2
145
ND (<10)
43.7
ND (<100)
27,700
ND (<10)
224
1,710
4,480
58.9
69.3
20,900
185
57
58
9.06
Total Toxic Metals
Total Toxic Pollutants
1,970
0
0
23,100
368
150
21,900
109
0
32.8
0
20,800
0
168
1,280
3,370
44.2
52.1
15,700
139
42,800
43,600
6,810
41,700
182,000
0.0167
0
0
37.0
0.811
0.350
1.25
7.05
0
0.0653
0
0.583
0
107
7.19
2.91
0.639
10.5
0.0862
6.52
1.04
0.244
10.2
142
193
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
1
0.05
38.7
0.35
Total Nitrogen
29,100
263
29,300
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
0.02
3.4
Total Phosphorus
Facility Total
2,550
2,550
1,390,000
NA
NA
193
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
ND - Not detected; NA - Not applicable; Baseline Value - Analytical detection limit.
5-16
-------
Table 5-7. Sampled Indirectly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE, Episode 6512, Sample Number 66167
Pollutant
Units
Baseline
Value
Concentration
Annual Load
(Ibs/year)
Annual
TWPE
Conventional Pollutants
BOD
TSS
HEM
mg/L
mg/L
mg/L
2
1
5
1,740
236
12.1
Total Conventional Pollutants
4,180,000
567,000
29,100
4,780,000
NA
NA
NA
NA
Toxic Pollutants
2-Propanone
Benzole Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
2,560
6,470
1290
16,800
0.3
0.41
131
177
ND (<10)
66.8
135
28,100
ND (<10)
41.6
2,020
7,310
55.9
16.7
57,300
104
122
47
5.48
Total Toxic Metals
Total Toxic Pollutants
6,150
15,600
3,100
40,400
721
985
315,000
425
0
161
324
67,500
0
100
4,860
17,600
134
40.1
138,000
250
293,000
113,000
13,200
229,000
1,030,000
0.0521
5.15
17.4
64.6
1.59
2.30
18.0
27.5
0
0.320
57.5
1.89
0
63.5
27.2
15.2
1.94
8.09
0.756
11.7
7.14
0.633
19.8
216
352
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
1
0.05
22.6
ND (<0.05)
Total Nitrogen
54,300
0
54,300
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
0.02
1.86
Total Phosphorus
Facility Total
4,470
4,470
5,870,000
NA
NA
352
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
ND - Not detected; NA - Not applicable; Baseline Value - Analytical detection limit.
5-17
-------
Table 5-8. Sampled Indirectly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE, Episode 6513, Sample Number 66171
Pollutant
Units
Baseline
Value
Concentration
Annual Load
(Ibs/year)
Annual
TWPE
Conventional Pollutants
BOD
TSS
HEM
mg/L
mg/L
mg/L
2
1
5
208
287
9.5
Total Conventional Pollutants
221,000
305,000
10,100
535,000
NA
NA
NA
NA
Toxic Pollutants
2-Propanone
Benzole Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
142
222
ND (<10)
7,490
0.42
0.44
ND (<10)
979
ND (<10)
71.7
ND (<100)
17,700
26.3
135
4,400
4,390
146
ND (<10)
15,700
879
22
19
3.8
Total Toxic Metals
Total Toxic Pollutants
151
236
0
7,950
446
467
0
1,040
0
76.1
0
18,800
27.9
143
4,670
4,660
155
0
16,700
933
23,300
20,200
4,030
47,100
104,000
0.00128
0.078
0
12.7
0.983
1.09
0
67.2
0
0.151
0
0.526
2.11
90.9
26.1
4.03
2.24
0
0.0915
43.7
0.568
0.113
6.07
237
259
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
1
0.05
31.6
0.59
Total Nitrogen
33,500
626
34,200
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
0.02
2.99
Total Phosphorus
Facility Total
3,170
3,170
677,000
NA
NA
259
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
ND - Not detected; NA - Not applicable; Baseline Value - Analytical detection limit.
5-18
-------
Table 5-9. Sampled Indirectly Discharging Tobacco Products Facility Effluent Pollutant
Loads and TWPE, Episode 6515, Sample Number 66176
Pollutant
Units
Baseline
Value
Concentration
Annual Load
(Ibs/year)
Annual
TWPE
Conventional Pollutants
BOD
TSS
HEM
mg/L
mg/L
mg/L
2
1
5
223
182
33.9
Total Conventional Pollutants
548,000
447,000
83,300
1,080,000
NA
NA
NA
NA
Toxic Pollutants
2-Propanone
Benzole Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
51.1
8,690
ND (<10)
12,700
1.83
0.14
ND (<10)
136
14.5
41.1
ND (<100)
18,200
18.3
138
860
4,130
84
ND (<10)
18,200
395
90
37
3.36
Total Toxic Metals
Total Toxic Pollutants
126
21,400
0
31,200
4,500
344
0
334
35.6
101
0
44,700
45
339
2,110
10,100
206
0
44,700
971
221,000
90,900
8,260
104,000
482,000
0.00106
7.07
0
49.9
9.91
0.802
0
21.6
144
0.201
0
1.25
3.40
215
11.8
8.78
2.98
0
0.246
45.5
5.39
0.509
12.4
455
541
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
1
0.05
26.1
6.39
Total Nitrogen
64,100
15,700
79,800
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
0.02
7.41
Total Phosphorus
Facility Total
18,200
18,200
1,660,000
NA
NA
541
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
ND - Not detected; NA - Not applicable; Baseline Value - Analytical detection limit.
5-19
-------
Conventional pollutants contribute the majority of the total facility annual
pollutant load for each of the four indirect dischargers. The total conventional pollutants
contributions are greater than 65 percent of the total facility pollutant load for each sampling
episode. BODs and TSS are the greatest contributors to the total conventional pollutants load for
each of the four facilities.
Of the pollutant groupings analyzed, nutrients contribute the least amount to the
total facility annual pollutant load. The nutrients in the effluent of the four indirect dischargers
contribute 5.9 percent or less to the total facility annual pollutant load.
Similar to the effluent of the two direct dischargers, the metals in the effluent of
the four indirect dischargers are the greatest contributors to the total facility annual TWPE
(greater than 61 percent for each facility). As shown in Table 5-10, copper is the greatest
contributor to the total metals TWPE for each indirect discharger. The contributions from other
significant metals (aluminum, arsenic, boron, iron, and zinc) vary for the four facilities.
Table 5-10. Metal Contributions to Total Facility Annual TWPE
Metal
Pollutant
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Total
Episode 6511
TWPE
7.05
0
0.0653
0
0.583
0
107
7.19
2.91
0.639
10.5
0.0862
6.52
142
%of
Total
4.96%
0%
0.046%
0%
0.411%
0%
75.4%
5.06%
2.05%
0.45%
7.39%
0.0607%
4.59%
Episode 6512
TWPE
27.5
0
0.32
57.5
1.89
0
63.5
27.2
15.2
1.94
8.09
0.756
11.7
216
%of
Total
12.7%
0%
0.148%
26.6%
0.875%
0%
29.4%
12.6%
7.04%
.898%
3.75%
0.35%
5.42%
Episode 6513
TWPE
67.2
0
0.151
0
0.526
2.11
90.9
26.1
4.03
2.24
0
0.0915
43.7
237
%of
Total
28.4%
0%
0.064%
0%
0.222%
0.89%
38.4%
11%
1.7%
0.945%
0%
0.039%
18.4%
Episode 6515
TWPE
21.6
144
0.201
0
1.25
3.4
215
11.8
8.78
2.98
0
0.246
45.5
455
%of
Total
4.75%
31.6%
0.044%
0%
0.275%
0.747%
47.3%
2.59%
1.93%
0.655%
0%
0.054%
10%
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
5-20
-------
As shown in Table 5-11, after metals, nicotine contributes the next highest
amount of TWPE to the facility totals, followed by ammonia (as nitrogen). The most significant
contributions to the remaining total facility TWPEs are from propylene glycol, benzoic acid,
benzyl alcohol, and acetaldehyde.
Table 5-11. Contributions of All Pollutants to Total Facility Annual TWPE
Pollutant
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Total Metals3
Chloride
Sulfate
Ammonia as
Nitrogen
Facility Total
Episode 6511
TWPE
0.0167
0
0
37.0
0.811
0.350
1.25
142
1.04
0.244
10.2
193
%of
Total
0.00865%
0%
0%
19.2%
0.420%
0.181%
0.648%
73.6%
0.539%
0.126%
5.29%
Episode 6512
TWPE
0.0521
5.15
17.4
64.6
1.59
2.3
18
216
7.14
0.633
19.8
352
%of
Total
0.0148%
1.46%
4.94%
18.4%
0.452%
0.653%
5.11%
61.4%
2.03%
0.180%
5.625%
Episode 6513
TWPE
0.00128
0.078
0
12.7
0.983
1.09
0
237
0.568
0.113
6.07
259
%of
Total
0.000494%
0.0301%
0%
4.903%
0.380%
0.421%
0%
91.5%
0.219%
0.0436%
2.34%
Episode 6515
TWPE
0.00106
7.07
0
49.9
9.91
0.802
0
455
5.39
0.509
12.4
541
%of
Total
0.000196%
1.31%
0%
9.22%
1.83%
0.148%
0%
84.1%
0.996%
0.0941%
2.29%
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
Tor a breakout of individual metal TWPEs, see Table 5-10.
5.5.6.2
Facility-Provided Source Water Data
The facilities at which EPA conducted sampling Episodes 6511 and 6512
provided EPA with pollutant concentrations measured in their source water. Table 5-12 presents
these data along with effluent concentration data from EPA's sampling episodes.
As shown in Tables 5-6 through 5-9, metals appear to contribute the majority of
TWPE detected in the effluent of the four indirect dischargers. As shown in Table 5-12, for the
facilities that provided source water data, the source water appears to contribute significantly to
the metals detected in the effluent.
5-21
-------
Table 5-12. Comparison of Indirectly Discharging Tobacco Products Facility Sampling
Data to Facility-Provided Source Water Data
Pollutant
BOD5
TSS
HEM
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia (as nitrogen)
TKN
Nitrate/Nitrite
Total Phosphorus
Units
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Baseline
Value
(for EPA
sampling)
2
1
5
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
1
0.05
0.02
Effluent
Concentration
Episode 6511
1,210
341
16.3
2,620
ND (<50)
ND(<10)
30,800
0.49a
0.2a
29.2
145
ND (<10)
43.7
ND (<100)
27,700
ND(<10)
224
1,710
4,480
58.9
69.3
20,900
185
57
58
9.06
38.7
0.35
3.4
Effluent
Concentration
Episode 6512
1,740
236
12.1
2,560
6,470
1,290
16,800
0.3a
0.41a
131
177
ND(10)
66.8
135
28,100
ND(<10)
41.6
2,020
7,310
55.9
16.7
57,300
104
122
47
5.48
22.6
ND (O.05)
1.86
Facility-
Provided
Source Water
Concentration
(Episode 6511)
5.5
22
<5.0
<25
<50
<10
ND
<0.1
0.05
<5.0
66
<2.5
35
<100
25,000
<5.0
15
<100
4,300
<5.0
<5.0
14,000
87
18
48
0.85
1.1
0.33
0.39
Facility-
Provided
Source Water
Concentration
(Episode 6512)
2.9
6.0
<5.0
<25
<50
<10
ND
<0.1
350 B
<5.0
<50
<2.5
30
<100
9,600
<5.0
72
<100
2,800
<5.0
<5.0
17,000
<20
10
24
0.03
O.2
0.06
0.24
Source: (Bridges, 2006) and Tobacco Products Sampling Data (Matuszko, 2006a).
aThese concentrations are lower than baseline due to sample specific issues.
B - Facility-provided source water data were labeled "B." However, B was not defined.
ND - Not detected.
5-22
-------
As discussed in Section 5.5.6.1, EPA identified copper as the pollutant that
contributes the greatest percentage of the total metals TWPE for all four indirect dischargers.
The facility source water contains a greater concentration of copper than the effluent of Episode
6512, suggesting that the copper in the effluent of this facility may not originate from the process
wastewater.
As also discussed in Section 5.5.6.1, EPA identified aluminum and zinc as
significant contributors to the total metals TWPE for the indirect dischargers. The source water
concentrations of aluminum and zinc (Episode 6511) indicate that the source water contributes
significantly to the aluminum and zinc concentrations detected in the facility effluent.
5.5.6.3 Facility-Provided Data and POTW-Provided Data
The indirect dischargers at which EPA conducted sampling Episodes 6511 and
6512 provided EPA with monitoring data for their effluent wastewater for the years 2002
through 2004. EPA compared the most recent data (2004) to the sampling data. The facility at
which EPA conducted sampling Episode 6511 provided pollutant concentration (mg/L), which
EPA converted into Ibs/year based on the facility-provided effluent flow rate. The facility at
which EPA conducted sampling Episode 6512 provided pollutant concentration in ppm, and
pollutant loads in Ibs/day, averaged for each month. EPA converted the pollutant loads into
Ibs/year based on the facility-provided annual production days.
The POTWs that receive wastewater from the sampled indirect dischargers also
provided EPA with monitoring data for these wastewaters. The POTWs monitor these
wastewaters as they are discharged from the tobacco products facility. The POTWs provided
pollutant monitoring data as concentrations (mg/L) for years 2004 and 2005. EPA compared the
most recent data (2005) to sampling data.
Table 5-13 presents the facility-provided and POTW-provided data along with
EPA sampling data. Table 5-13 includes only the pollutants for which EPA has POTW
monitoring data although additional pollutants were detected in EPA's sampling program (see
Tables 5-6 through 5-9).
5-23
-------
Table 5-13. Comparison of Indirectly Discharging Tobacco Products Facility Sampling
Data to Facility-Provided and POTW-Provided Data
Pollutant
Units
EPA-Measured
Effluent
Concentration
EPA-
Estimated
Annual Load
(Ibs/year)
Facility-
Provided
Effluent
Concentration
Facility-Provided
Effluent Annual
Load
(Ibs/year)
POTW-
Provided
Influent
Concentration
Episode 6511a
BOD5
TSS
HEM
Chromium
Copper
Zinc
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
1210
341
16.3
ND (<10)
224
185
909,000
256,000
12,200
0
168
139
597
420
14.5
30
160
450
448,000
315,000
10,900
22.5
120
338
416
402
3.19
10
140
300
Episode 6512
BOD5
TSS
Arsenic
Chromium
Copper
Zinc
Ammonia as Nitrogen
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
mg/L
1740
236
ND (<10)
ND (<10)
41.6
104
5.48
4,180,000
567,000
0
0
100
250
13,200
723
337
—
—
70
180
3.07
1,066,320
495,720
—
—
102.6
208
4,428
954
325
2
6
78
135
3
Episode 6513
BOD5
TSS
Arsenic
Chromium
Copper
Manganese
Molybdenum
Zinc
Ammonia as Nitrogen
TKN
Total Phosphorus
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
208
287
ND (<10)
26.3
135
146
ND (<10)
879
3.8
31.6
2.99
221,000
305,000
0
27.9
143
155
0
933
4,030
33,500
3,170
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
340
528
<5
15
100
100
<10
800
4.5
20.1
2.88
Episode 6515
BOD5
TSS
Arsenic
Chromium
Copper
Manganese
Molybdenum
Zinc
Ammonia as Nitrogen
TKN
Total Phosphorus
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
223
182
14.5
18.3
138
84
ND (<10)
395
3.36
26.1
7.41
548,000
447,000
35.6
45
339
206
0
971
8,260
64,100
18,200
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
1,009
977
<5
20
670
440
<10
474
3.65
43
9.525
Source: (Pickelhaupt, 2005), POTW-provided data (see OW-2004-0032), and Tobacco Products Sampling Data (Matuszko,
2006a).
aThe facility at which EPA conducted sampling Episode 6511 provided concentrations, from which EPA calculated loads.
A dash (—) indicates that no facility data were provided for the pollutant.
ND-Not detected.
5-24
-------
Differences between the annual loads estimated with EPA's sampling data and the
loads estimated with facility-provided data are most likely due to the fact that loads estimated
with EPA's sampling data are based on one grab sample and a rough annual facility flow rate.
The facility-provided data are more representative. Despite the difference in sample
measurement, EPA's estimated loads are within an order of magnitude of the facility-provided
loads. Likewise, EPA's measured concentrations are within an order of magnitude of the
POTW-provided concentrations.
5.5.7 Pass Through and Pollutant Loadings Analysis for Indirect Dischargers
Pretreatment standards are designed to prevent the discharge of pollutants that
"interfere with, pass through, or otherwise [are] incompatible with" the operation of POTWs.
See 33 U.S.C.§ 1371(b)(l). In establishing pretreatment standards, Congress had two
objectives: (1) that standards for indirect dischargers be equivalent to standards for direct
dischargers, and (2) that the treatment capability and performance of POTWs be recognized and
taken into account in regulating the discharge of pollutants from indirect dischargers. EPA's
approach is consistent with both objectives. Generally, EPA determines whether pollutants "pass
through" by comparing the percentage of the pollutant removed by well operated POTWs
achieving secondary (biological) treatment with the percentage of the pollutant removed by
facilities meeting the best available treatment technology (BAT) effluent limitations. If the
median percentage removed by well operated POTWs is less than the median percentage
removed by BAT facilities, then the pollutant "passes through," and EPA develops pretreatment
standards for facilities that indirectly discharge the pollutant.
EPA performs pass through analyses for industries that are under consideration
for the development of pretreatment standards. As part of a typical pass through analysis, EPA
compares the pollutant loadings in an industry's wastewater that are currently being discharged
to POTWs and surface waters (current loadings) to the pollutant loadings in the industry's
wastewater that would be discharged to POTWs and surface waters upon compliance with a rule
(post-compliance loadings). To reach the goal that standards for indirect dischargers be
equivalent to standards for direct dischargers, EPA generally calculates post-compliance
loadings assuming facilities would achieve treatment at least equivalent to treatment that may be
5-25
-------
achieved by using the directly discharging technology (i.e., the BAT). EPA uses pass through
analyses to select pollutants for regulation, to evaluate the effectiveness of treatment
technologies in addition to POTW removals, and to evaluate the cost of these technologies in
comparison to pollutant removals.
EPA analyzed current loadings from the four indirect dischargers sampled and the
pollutant loadings that would be discharged if these facilities used pretreatment. EPA calculated
current loadings for the sampled facilities as described in Section 5.5.6.1. However, for the
loadings analysis, EPA is interested in the current loadings as discharged to surface waters.
Therefore, EPA reduced the pollutant loadings calculated in Section 5.5.6.1 to account for
removals achieved by the POTW. See Table 5-11 for EPA's estimated POTW removals and
current loadings accounting for POTW reductions.
EPA also needed an estimate of post-compliance pollutant loadings. EPA
estimated post-compliance pollutant loadings assuming pretreatment with BNR wastewater
treatment technology. Both of the direct dischargers sampled by EPA used this technology and
EPA collected effluent data from these treatment systems for an extensive list of pollutants.
Furthermore, as detailed in Section 5.5.3, these systems are generally effective at reducing
pollutants in tobacco products processing wastewaters. Therefore, for this analysis, EPA
considers BNR treatment technology to be the BAT.
To calculate post-compliance pollutant loadings, EPA needed an estimate of the
pollutant concentrations that would be achieved by the four indirect dischargers if they used
BNR. EPA determined the average performance level that a well designed and operated BNR
system is capable of achieving using the effluent pollutant concentrations from the two sampled
direct dischargers. Typically, EPA applies data-editing criteria to the data sets prior to its
performance level calculations. EPA calculates a performance level for a specific pollutant if it
is present in the influent at sufficient concentrations that treatment effectiveness can be
evaluated3. For this analysis, when a pollutant was detected in the facility's influent to treatment
3 EPA typically defines a pollutant to be at treatable levels if it is detected at a concentration in the influent equal to
or greater than 10 times the baseline value. To be conservative with this analysis and to estimate treatment
effectiveness for a wider range of pollutants, EPA selected a concentration equal to or greater than five times the
baseline value.
5-26
-------
in a concentration equal to or greater than five times the baseline value, the corresponding
effluent data were included in the performance level calculations. When the data set for a
pollutant at a facility did not meet this criteria, EPA excluded the data. For example, at Episode
6510, the influent copper concentration is 48.5 ug/L and the baseline value for copper is 10 ug/L.
Because this pollutant failed the data-editing criteria, the corresponding effluent data were not
included in the performance level calculation for copper. After applying the data-editing criteria,
EPA then calculates a performance level for a pollutant by averaging the treated effluent
concentrations, as applicable for that pollutant4. In this report, EPA refers to these averages as
"BNR treatment averages."
Before applying the BNR treatment averages, EPA looked at the data sets to
determine if the pollutant removals for any of the pollutants were negative (i.e., where an
average effluent concentration was greater than an average influent concentration). In these
cases, the treatment was ineffective and did not remove any of the pollutants. EPA removed
such data sets from its BNR treatment averages. If the BNR treatment average for a pollutant
was larger than the indirect discharge effluent concentration for that pollutant at a facility, then
EPA set the BNR treatment average equal to the indirect discharge effluent concentration for that
facility.
To estimate theoretical post-compliance loadings for each of the indirect
dischargers sampled, EPA multiplied the BNR treatment averages for each pollutant by each
indirect discharger's annual discharge flow. Similar to current loadings, EPA then adjusted these
values to account for POTW treatment. Finally, EPA estimated post-compliance pollutant
reductions by subtracting the post-compliance loadings from the current loadings. The resulting
pollutant reductions reflect the pollutant loadings that the BNR treatment is capable of removing
above the POTW reductions.
4 If the effluent was measured as nondetect, EPA used the detection limit value as reported in these calculations.
5-27
-------
Table 5-14 presents the results of the pollutant loadings analysis for the four
indirectly discharging tobacco products facilities, including the current pollutant loadings, post-
compliance pollutant loadings, and post-compliance pollutant reductions. All pollutant loadings
and reductions presented in Table 5-14 take into account the POTW removals. Table 5-14 also
presents the annual TWPE associated with the loadings and reductions. Table 5-14 does not
contain information on conventional pollutants. Because POTWs are designed to effectively
remove conventional pollutants, EPA does not generally regulate conventional pollutants for
indirect dischargers, nor does EPA include conventional pollutants in its pollutant loadings
analyses for indirect dischargers.
As shown in Table 5-14, the post-compliance pollutant reductions indicate that
the BNR treatment is capable of removing a significant amount of the annual TWPE (greater
than 41 percent for each sampling episode) that remains after the wastewater passes through the
POTWs. EPA estimates that the pollutant loadings and annual TWPE that pass through the
POTWs are relatively insignificant, as shown in Table 5-15. Table 5-15 compares the total
pollutant loadings and TWPE that are discharged in the effluent of the four indirect dischargers,
the total pollutant loadings and TWPE that EPA estimates pass through the POTWs, and the
post-compliance annual pollutant TWPE reductions.
Table 5-15 demonstrates that if each of the indirectly discharging tobacco
products facilities used BNR treatment, the average annual facility reduction that would be
achieved is 28.6 TWPE/year. In a previous consideration of pretreatment standards for the
Industrial Laundries category (see 64 FR 45071), EPA determined that pretreatment standards
were not warranted because of the small amount of pollutants removed by the pretreatment
option. For Industrial Laundries, EPA estimated an average annual facility reduction of 32
TWPE/year. EPA also found that POTWs were not generally experiencing problems with
discharges from industrial laundries.
5-28
-------
Table 5-14. Pollutant Loadings Analysis for Sampled Indirectly Discharging Tobacco Products Facilities
Pollutant
BNR Treatment
Units
Averages
POTW
Removals
Current
Pollutant
Loading"
(Ibs/yr)
Current
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Loading"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Reductions"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual TWPE
Reductions"
Episode 6511, 90 MGY
Toxic Pollutants
2-Propanone
Nicotine
Acetaldehyde
Aluminum
Barium
Calcium
Copper
Iron
Magnesium
Manganese
Zinc
Ammonia as Nitrogen
ug/L
ug/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
50
22.6
0.23
50
9.35
27,700
61.1
371.5
4480
53.3
25.8
0.57
0.8375
0.964
0.921
0.91
0.5515
0.0850
0.842
0.82
0.14
0.406
0.7914
0.39
Total Toxic Metals
Total Toxic Pollutants
320
833
29
9.80
14.7
19,000
26.6
231
2,890
26.3
29.0
4,150
22,300
27,600
0.00271
1.33
0.0639
0.634
0.0293
0.533
16.9
1.29
2.51
0.379
1.36
6.25
23.6
31.3
6.11
0.611
13.6
3.38
3.15
19,000
7.25
50.3
2,890
23.8
4.04
261
22,000
22,300
0.0000517
0.000978
0.0300
0.219
0.00627
0.533
4.60
0.281
2.51
0.343
0.190
0.393
8.68
9.10
314
832
15.4
6.42
11.6
0
19.3
181
0
2.48
24.9
3,890
246
5,300
0.00265
1.33
0.0339
0.415
0.0230
0
12.3
1.01
0
0.0359
1.17
5.86
14.9
22.2
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
6.4
0.35
0.57
0.9
Total Nitrogen
12,500
26.3
12,500
NA
NA
NA
2,070
26.3
2,090
NA
NA
NA
10,400
0
10,400
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
1.53
0.57
1,100
NA
494
NA
604
NA
to
VO
-------
Table 5-14 (Continued)
Pollutant
BNR Treatment
Units
Averages
POTW
Removals
Current
Pollutant
Loading"
(Ibs/yr)
Current
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Loading"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Reductions"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual TWPE
Reductions"
Episode 6512, 288 MGY
Toxic Pollutants
2-Propanone
Nicotine
Acetaldehyde
Aluminum
Barium
Calcium
Copper
Iron
Magnesium
Manganese
Zinc
Ammonia as Nitrogen
ug/L
ug/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
50
22.6
0.23
50
9.35
28,100
41.6
371.5
7,310
53.3
25.8
0.57
0.8375
0.964
0.921
0.91
0.5515
0.0850
0.842
0.82
0.14
0.406
0.7914
0.39
Total Toxic Metals
Total Toxic Pollutants
1,000
1,450
56.7
38.3
72.0
61,800
15.8
874
15,100
79.8
52.1
8,030
78,000
88,600
0.00846
2.33
0.125
2.48
0.143
1.73
10.0
4.89
13.1
1.15
2.44
12.1
35.9
50.5
19.5
1.96
43.5
10.8
10.1
61,800
15.8
161
15,100
76.1
12.9
836
77,200
78,100
0.000165
0.00313
0.0959
0.700
0.0201
1.73
10.0
0.900
13.1
1.10
0.607
1.26
28.2
29.5
980
1,450
13.2
27.5
61.9
0
0
713
0
3.67
39.2
7,200
846
10,500
0.00829
2.32
0.029
1.78
0.123
0
0
3.99
0
0.0536
1.84
10.8
7.79
21.0
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
6.4
0.05
0.57
0.9
Total Nitrogen
23,400
12.0
23,400
NA
NA
NA
6,620
12.0
6,630
NA
NA
NA
16,700
0
16,700
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
1.53
0.57
1,920
NA
1,580
NA
341
NA
-------
Table 5-14 (Continued)
Pollutant
BNR Treatment
Units
Averages
POTW
Removals
Current
Pollutant
Loading"
(Ibs/yr)
Current
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Loading"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Reductions"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual TWPE
Reductions"
Episode 6513, 127 MGY
Toxic Pollutants
2-Propanone
Nicotine
Acetaldehyde
Aluminum
Barium
Calcium
Copper
Iron
Magnesium
Manganese
Zinc
Ammonia as Nitrogen
ug/L
ug/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
50
22.6
0.23
50
9.35
17,700
61.1
371.5
4,390
53.3
25.8
0.57
0.8375
0.964
0.921
0.91
0.5515
0.0850
0.842
0.82
0.14
0.406
0.7914
0.39
Total Toxic Metals
Total Toxic Pollutants
24.5
286
35.1
93.5
34.1
17,200
22.6
840
4,010
92.0
195
2,460
22,500
25,300
0.000207
0.458
0.0773
6.05
0.0679
0.481
14.4
4.71
3.47
1.33
9.12
3.70
39.6
43.8
8.63
0.864
19.2
4.78
4.45
17,200
10.2
71.0
4,010
33.6
5.71
369
21,300
21,700
0.0000730
0.00138
0.0423
0.309
0.00886
0.481
6.50
0.397
3.47
0.485
0.268
0.555
11.9
12.5
15.9
285
15.9
88.7
29.7
0
12.4
770
0
58.4
189
2,090
1,150
3,560
0.000134
0.456
0.0350
5.74
0.0591
0
7.87
4.31
0
0.843
8.86
3.15
27.7
31.3
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
6.4
0.59
0.57
0.9
Total Nitrogen
14,400
62.6
14,500
NA
NA
NA
2,920
62.6
2,980
NA
NA
NA
11,500
0
11,500
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
1.53
0.57
1,360
NA
698
NA
666
NA
-------
Table 5-14 (Continued)
Pollutant
BNR Treatment
Units
Averages
POTW
Removals
Current
Pollutant
Loading"
(Ibs/yr)
Current
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Loading"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual
TWPEa
Post-
Compliance
Pollutant
Reductions"
(Ibs/yr)
Post-
Compliance
Pollutant
Annual TWPE
Reductions"
Episode 6515, 294 MGY
Toxic Pollutants
2-Propanone
Nicotine
Acetaldehyde
Aluminum
Barium
Calcium
Copper
Iron
Magnesium
Manganese
Zinc
Ammonia as Nitrogen
ug/L
ug/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
50
22.6
0.23
50
9.35
18,200
61.1
371.5
4,130
53.3
25.8
0.57
0.8375
0.964
0.921
0.91
0.5515
0.0850
0.842
0.82
0.14
0.406
0.7914
0.39
Total Toxic Metals
Total Toxic Pollutants
20.4
1,120
354
30.1
45.3
40,900
53.6
380
8,730
123
202
5,040
50,500
57,000
0.000173
1.80
0.780
1.95
0.0902
1.15
34.0
2.13
7.56
1.77
9.49
7.58
58.1
68.3
20.0
2.00
44.5
11.1
10.3
40,900
23.7
164
8,730
77.8
13.2
855
50,000
50,900
0.000169
0.00320
0.0981
0.715
0.0205
1.15
15.1
0.920
7.56
1.12
0.620
1.29
27.2
28.5
0.428
1,120
309
19.0
35.0
0
29.9
216
0
44.8
189
4,180
534
6,150
0.00000362
1.79
0.682
1.23
0.0697
0
19.0
1.21
0
0.647
8.87
6.30
31.0
39.8
Nitrogen
TKN
Nitrate/Nitrite
mg/L
mg/L
6.4
6.39
0.57
0.9
Total Nitrogen
27,600
1,570
29,200
NA
NA
NA
6,760
1,570
8,330
NA
NA
NA
20,800
0
20,800
NA
NA
NA
Phosphorus
Total Phosphorus
mg/L
1.53
0.57
7,830
NA
1,620
NA
6,210
NA
to
Source: (Codding and Bartram, 2005), Tobacco Products Sampling Data (Matuszko, 2006a), (U.S. EPA, 1982), and (U.S. EPA, 1994).
aAll pollutant loadings and reductions take into account POTW removals. TWPE was calculated using TWFs, as described in 2005 Annual Screening-Level
Analysis (U.S. EPA, 2005a).
NA - Not applicable.
-------
Table 5-15. Comparison of Pollutant Loadings Discharged To and From POTWs
Episode
6511
6512
6513
6515
Pollutant Load
Discharged To POTWs
Facility Total
Current Pollutant
Loading (Ibs/yr)
1,390,000
5,870,000
677,000
1,660,000
Facility Total
Current Pollutant
Annual TWPEa
193
352
259
541
EPA's Estimated Pollutant Load
Discharged From POTWs
Facility Total Current
Pollutant Loading
Accounting for
POTW Removal
(Ibs/yr)
168,000
634,000
97,200
210,000
Facility Total
Current Pollutant
Annual TWPE
Accounting for
POTW Removal"
31.3
50.5
43.8
68.3
Post-Compliance
Pollutant Annual
TWPE
Reductions
Accounting for
POTW Removal3
22.2
21.0
31.3
39.8
Source: Tobacco Products Sampling Data (Matuszko, 2006a).
aTWPE was calculated using TWFs, as described in 2005 Annual Screening-Level Analysis (U. S. EPA, 2005a).
5.5.7.1
Cost of BNR Treatment Technology Relative to Pollutant Removals
EPA calculated the cost of BNR treatment using facility-provided information
that is claimed as confidential business information (CBI). The cost of BNR treatment greatly
exceeds the pollutant loadings removed; the cost effectiveness is well in excess of
$10,000/TWPE of pollutant removed (Holman, 2006a).
EPA examined the tobacco products industry as part of the 304(m) process and
found that the removals associated with pretreatment would be small. Because the screening
process identified that relatively trivial amounts of pollutants would be removed by pretreatment,
EPA did not perform the analyses associated with an effluent limitations guidelines rulemaking
such as an economic impact or affordability analysis.
5.5.7.2
Possible Impact on POTWs
EPA considered the impact of the tobacco products industry on POTWs under
current conditions. EPA conducted four telephone conversations with POTWs about the
wastewater discharges that they receive from tobacco products facilities (Finseth, 2005b -
2005e). The information obtained from the telephone conversations was fairly consistent (Table
5-16). The POTWs reported that the tobacco products facilities only occasionally exceed their
discharge limits. On the occasions when the tobacco products facilities have exceeded their
limits (e.g. zinc, oil and grease, pH, and BOD), the POTWs have not exceeded their own NPDES
5-33
-------
permit limits. POTW operators reported no issues from the nutrient content of the tobacco
products wastewater. None of the POTWs monitors either the facility discharges or their own
discharge for nicotine.
The POTWs reported no significant issues handling the wastewater discharges
from the tobacco products facilities. For this reason, the POTWs reported that they would not
benefit from a national pretreatment standards rulemaking for the tobacco products industry.
One POTW indicated that such standards would be burdensome.
Table 5-16. POTW Contact Summary
Date of Contact
Any instances in which the
tobacco products facilities
exceeded their permit limits?
Any instances in which POTW
exceeded NPDES permit limits
due to tobacco products facility
discharge?
Nicotine monitoring and/or
information on removal
efficiency?
Any issues related to nutrient
discharges from tobacco
products facilities?
Would POTWs benefit from
Federal categorical pretreatment
standards for the tobacco
products industry?
City of Richmond,
VA POTW
12/7/2005
The facility
exceeded its zinc
limit four times
since 2003. The
facility occasionally
exceeds its oil and
grease and pH
limits.
No
No
No
No
City of Winston-
Salem, NC
POTW1
11/17/2005
The facility
occasionally
discharges high
levels of BOD.
No
No
No
No. Such a
standard would
be a burden.
Water and Sewer
Authority of
Cabarrus
County, Concord,
NC
11/18/2005
No
No
No
No
No
City of
Greensboro,
NC POTW
11/21/2005
The facility
exceeded its
BOD limit
once, three
years prior to
call.
No
No
No
No
Source: (Finseth, 2005b - 2005e).
aCity of Winston-Salem also submitted comments on the Preliminary 2006 Effluent Guidelines Plan (OW-2004-
0032-1061).
Table 5-17 compares metals concentrations detected in the effluent of the four
sampled indirectly discharging tobacco products facilities to typical POTW influent. Median
5-34
-------
metals concentrations from EPA's 50-POTW Study were used to represent typical POTW
influent. Table 5-17 includes the metals that are the greatest contributors to the total pollutant
TWPE in the effluent of the sampled indirect dischargers, as discussed in Section 5.5.6.1.
Table 5-17. Comparison of Metals Concentrations in Sampled Tobacco Products Facility
Discharges to POTWs to Typical POTW Influent
Metal Pollutant
Aluminum
Arsenic
Boron
Copper
Iron
Zinc
Units
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Average Effluent Concentrations for
Four Indirect Dischargers3
359
11.1
109
135
2,250
391
50-POTW Study Influent
Concentrations'"
2,650
29
337
229
6,306
885
Source: Tobacco Products Sampling Data (Matuszko, 2006a), (U.S. EPA, 1982).
"Facility effluent discharged to POTW.
b These data reflect the median influent concentrations of POTWs in the study using secondary treatment, where the influent
concentration is equal to or greater that 20 ppb.
See W-00-25, DCNIS04612.
The data presented in Table 5-17 indicate that the metals concentrations
discharged from tobacco products facilities are similar to, though somewhat lower than, the
typical metals concentrations entering POTWs.
5.5.8
Summary of Indirect Discharge Wastewater Characteristics and Analyses
As explained in Section 3.1.3, the majority of discharging tobacco products
facilities discharge indirectly to POTWs. EPA's review of data from indirectly discharging
tobacco products facilities demonstrates that such discharges are generally characterized by low
concentrations of toxic and nonconventional pollutants - primarily metals. One exception is
nicotine, with discharge concentrations ranging from 7,500 ug/L to 31,000 ug/L. Nicotine and
metal discharges account for approximately 91 percent of the total annual TWPE associated with
indirect tobacco products processing discharges. As was the case with direct dischargers, source
water appears to be the biggest contributor to metal discharges at indirect dischargers.
EPA evaluated possible pretreatment standards for these tobacco products
processing discharges assuming a technology basis equivalent to that found at direct dischargers,
biological treatment with nutrient removal. EPA compared the pollutant loadings currently
5-35
-------
discharged to POTWs and surface waters to the pollutant loadings that would be discharged to
POTWs and surface waters upon compliance with pretreatment standards based on biological
treatment with nutrient removal. EPA found that the annual incremental removal per facility
would generally be small, approximately 28.6 TWPE. Furthermore, the costs of such
incremental removals would be in excess of $10,000/TWPE.
Finally, EPA evaluated possible negative effects of discharges from tobacco
products facilities to POTWs. As explained above, nicotine and metals account for
approximately 91 percent of the total annual TWPE associated with indirect discharges from this
category. Based on information obtained in this study, POTWs achieve nicotine removals in
excess of 96 percent. EPA compared the concentrations of metals found in indirect tobacco
products processing discharges to those typically found in POTW influent. This comparison
demonstrated that metals concentrations discharged by tobacco products facilities are lower than
those found in typical POTW influent. As a result of these findings, tobacco products processing
discharges should not have negative impacts on the receiving POTWs. To verify this finding,
EPA contacted POTWs receiving significant tobacco products processing discharges. All
POTWs contacted indicated they had experienced little to no problems with such discharges and
that they had no problem handling and treating tobacco products processing discharges.
5-36
-------
6.0 REFERENCES
Bagwell, Sherry. 2002. City of Winston-Sal em. Industrial User Permit: RJ. Reynolds Tobacco
Company, Tobaccoville. (June 26). DCN 01833.
Bridges, Charles T. 2006. Tobacco Products Facility Source Water Concentration Data.
(January). DCN 03647.
CigarHandbook. 2006. CigarHandbook.com. Manufacturing Process of the Cigar. Available
online at: http://www.cigarhandbook.com/Manufacturing.asp. Accessed: August.
DCN 03519.
Codding, Ellie and Bartram, Deb. 2005. Eastern Research Group (ERG). Memorandum to
Effluent Guidelines Program Plan Docket. "Publicly Owned Treatment Works
(POTW) Percent Removals Used for the TRIReleases2002 Database." (August
12). DCN 02180.
Covington, James III. 2006. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Economic Profile of Domestic Tobacco
Manufacturing Industry: 2006 Update." (April 19). DCN 02948.
Crowley, Kate. 2000. Pennsylvania Department of Environmental Protection. Industrial Waste
NPDES Permit for Consolidated Cigar Corporation, McAdoo, Pennsylvania.
(June 25). DCN03510A2.
Curl, Steve. 2005. Email from Steve Curl of R.J. Reynolds (Reynolds American) to Jan
Matuszko of U.S. EPA. (September 27). DCN 03498.
Finseth, TJ. 2005a. Telephone conversation with Michael Richardson of Maryland Department
of the Environment and TJ Finseth of ERG. "Tobacco Technology Incorporated."
(November 09). DCN 03497.
Finseth, TJ. 2005b. Telephone conversation with Sherry Bagwell of City of Winston-Sal em,
Industrial Waste Control Section, and TJ Finseth of ERG. "R.J. Reynolds
Whitaker Park and Tobaccoville Discharges to the Winston-Salem POTW."
(November 17). DCN 03501.
Finseth, TJ. 2005c. Telephone conversation with Beverly Metcalf of Water & Sewer Authority
of Cabarrus County and TJ Finseth of ERG. "Philip Morris Cabarrus Operations
Discharges to the Cabarrus County POTW." (November 18). DCN 03499.
Finseth, TJ. 2005d. Telephone conversation with Sharon Miller and Martie Groome of City of
Greensboro, Industrial Pretreatment, and TJ Finseth of ERG. "Lorillard
Discharges to the Greensboro POTW." (November 21). DCN 03502.
6-1
-------
Finseth, TJ. 2005e. Telephone conversation with Sherry Crewe of City of Richmond and TJ
Finseth of ERG. "Philip Morris Commerce Road Discharges to the Richmond
POTW." (December 07). DCN 03500.
Finseth, TJ. 2006. Telephone conversation with Atul Govil of Altadis USA and TJ Finseth of
ERG. "Wastewater Discharges from the Altadis Cigar Manufacturing Facility."
(February 28). DCN03510A1.
Holman, Sarah. 2006a. ERG. Cost of BNR Wastewater Treatment. (June 27). DCN 02989.
Holman, Sarah. 2006b. Telephone conversation with Richard Vazquez of R.J. Reynolds
Tobacco (CI) Comanufacturing America, Inc., and Sarah Holman, ERG.
"Wastewater Discharges from Tobacco Processsing/Manufacturing - NPDES ID
PR0001091." (August 29). DCN 03531.
JRCigars. 2006. JR Cigars. Lesson 13: Pipe Tobacco "101". Available online at:
http://www.jrcigars.com/index.cfm?page=jrcu_pipe-tobacco. Copyright 2006.
Accessed: August. DCN 03522.
Mac Baren Tobacco. 2002. Mac Baren Tobacco. The Production of Flake Tobacco. Available
online at: http://www.mac-baren.com/TopMenu/Expert-Knowledge/Flake-
Tobacco/The-Production-of-Flake-Tobacco.aspx. Copyright 2002. Accessed:
August. DCN 03 521.
Matuszko, Jan. 2005a. Meeting with Dimon International (Alliance One International) and Jan
Matuszko, et al. of U.S. EPA. "Meeting Notes - Dimon International." (May
31). DCN 01805.
Matuszko, Jan. 2005b. Meeting with Philip Morris, Inc. and Jan Matuszko, et al. of U.S. EPA.
"Meeting Notes - Philip Morris USA." (May 31). DCN 01922.
Matuszko, Jan. 2005c. Telephone conversation with Gary Foote of Alliance One International,
Environmental Health and Safety, and Jan Matuszko of U.S. EPA. "Telephone
Call Notes - Alliance One International." (July 12). DCN 01804.
Matuszko, Jan. 2006a. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Tobacco Products Sampling Data." (March 21).
DCN 02626.
Matuszko, Jan. 2006b. U.S. EPA. Memorandum to Public Record for the 2006 Effluent
Guidelines Program Plan. "Swisher International Cigar Manufacturing." (May
8). DCN 02719.
Matuszko, Jan. 2006c. U.S. EPA. Memorandum to Effluent Guidelines Program Plan Docket.
"Fate of Propylene Glycol in the Environment and POTWs." (June 29). DCN
03530.
6-2
-------
NCI. 2002. National Cancer Institute (NCI) and Centers for Disease Control and Prevention
(CDC). Smokeless Tobacco Fact Sheets. 3rd International Conference on
Smokeless Tobacco. Stockholm, Sweden. Available online at:
http://cancercontrol.cancer.gov/tcrb/stfact sheet combined 10-23-02.pdf.
Accessed: August 2006. DCN 03520.
Pickelhaupt, John. Jr., P.E. 2005. Philip Morris, USA. Philip Morris Wastewater Discharge
Summaries. (May 16). DCN 01834.
Porter, Kim. 2005a. Pre-sampling telephone interview with Philip Morris, Inc. and Kim Porter
of ERG. "Tobacco Products Processing Wastewater Characterization." (June
29). DCN 01914.
Porter, Kim. 2005b. ERG. Site Visit Notes. (July 19). DCN 03075.
Prudent Peddler. 2006. The Prudent Peddler. Cigar Basics. Available online at:
http://mywebpages.comcast.net/bcabana2/prudentpeddler/cigars/basics.htm.
Accessed: August. DCN 03518.
Reynolds. 2005a. R.J. Reynolds Tobacco Company. Hanmer Division. Chester, VA. Permit
Renewal Application for a Virginia Pollutant Discharge Elimination System
(VPDES) Permit. (April). DCN 01829.
Reynolds. 2005b. R.J. Reynolds Tobacco Company. R.J. Reynolds Effluent Monitoring Data.
(June 1). DCN 01828.
SCC. 2005. Sample Control Center (SCC). Memoranda to Jan Matuszko of U.S. EPA. "Data
Review Narratives for Tobacco Products Sampling." (October 24). DCN 03695.
Scott, Bruce R. 2001. Kentucky Department for Environmental Protection. Kentucky Pollutant
Discharge Elimination System (KPDES) Permit for G.F. Vaughan Tobacco
Company, Inc., Fayette County, Kentucky. (July 10). DCN03506A1.
Shore, Myron. 2006. Email from Myron Shore of R.J. Reynolds (Reynolds American) to Jan
Matuszko of U.S. EPA. "RJ Reynolds Tobacco POTW Flows." (February 23).
DCN 02961.
Snyder, S.A. 2002. "Endocrine Disrupters and Pharmaceutically Active Compounds: U.S.
Regulations and Research." In: Proceedings of the International Water
Association (IWA) 3rd World Water Congress. Melbourne, Australia. DCN
03494.
TTB. 2006. TTB. 2004 TTB information provided to U.S. EPA. (April).
Upgren, Amy. 2006. U.S. EPA. Memorandum to Jan Matuszko of U.S. EPA. "Comments on
the Four Reports Submitted by R.J. Reynolds Tobacco Company in Response to
Request for Data in the Notice of Availability of Preliminary 2006 Effluent
Guidelines Program Plan." (May 18). DCN 02798.
6-3
-------
USDA. 2005. United States Department of Agriculture (USDA). Economics Research Service.
Tobacco: Background. Available online at:
http://www.ers.usda.gov/Briefmg/Tobacco/Background.htm. Updated: October 3,
2005. Accessed: August 2006. DCN 03517.
U.S. EPA. 1982. Effluent Guidelines Division. Fate of Priority Pollutants in Publicly Owned
Treatment Works. EPA 440/1-82/303. Washington, DC. (September).
U.S. EPA. 1994. Office of Research and Development. RREL Treatability Database.
Cincinnati.
U. S. EPA. 2005a. 2005 Annual Screening-Level Analysis: Supporting the Annual Review of
Existing Effluent Limitations Guidelines and Standards and Identification of New
Point Source Categories for Effluent Limitations and Standards. EPA 821 -B-05-
003. Washington, DC. (August). DCN 02173.
U.S. EPA. 2005b. Office of Water. Engineering and Analysis Division. PCSLoads2002 v02.
DCN 02299.
U.S. EPA. 2005c. Office of Water. Engineering and Analysis Division. TRlReleases2002 v02.
DCN 02289.
USGS. 2002. U.S. Geological Survey (USGS) National Water Information System, NWISWeb
Database. Available online at: http://waterdata.usgs.gov/nwis/. Updated:
November 2002. Virginia water quality data is available online via NWISWeb at:
http://waterdata.usgs.gov/va/nwis/. Accessed: February 2006.
Winter, Kyle I, P.E. 2006. Email from Kyle I. Winter, P.E. of VA DEQ, Office of Water
Permit Programs, Division of Water Quality Programs, to Jan Matuszko of U.S.
EPA. "Request for Information for Tobacco Products Permitted Facilities in
Richmond VA Area." (March 22). DCN 02688.
6-4
-------
Appendix A
WASTEWATER SAMPLING DATA
-------
Table A-l. Sampled Directly Discharging Tobacco Products Facility Data
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/yr)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/yr)
PCS
Loads
2002
(Ibs/yr)
Episode 6510, Sample Number 66157, Treated Effluent
Conventional Pollutants
BOD5
TSS
C003
C009
5210B
160.2
mg/L
mg/L
2
1
6
9
NC
NC
Total Conventional Pollutants
11,800
17,700
29,400
NA
NA
NA
NA
NA
NA
-
10
NA
-
19,200
NA
17,390
39,822
NA
Toxic Pollutants
Bromodichloro-
methane
Chloroform
Dibromochloro-
methane
Nicotine
Barium
Boron
Calcium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Chloropicrin
Unknown
Dithiocarbamate
Pesticide
Ammonia as
Nitrogenb
75274
67663
124481
54115
7440393
7440428
7440702
7440508
7439896
7439954
7439965
7439987
7440235
7440666
1688700
6
1480879
8
76062
8018017
7664417
1624C
1624C
1624C
1625C
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
618
630
350.1
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
ug/L
mg/L
mg/L
10
10
10
20
2
100
50
10
100
200
15
10
500
10
2
10
0.5
0.1
0.04
10
10
10
25.2
10
101
60,800
12.9
380
11,500
52.2
10
17,300
28.2
109
26
0.5
0.15
0.23
ND
ND
ND
NC
NC
NC
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
ND
NC
NC
Total Toxic Metals
Total Toxic Pollutants
0
0
0
49.5
19.6
198
119,000
25.3
746
22,600
102
0
34,000
55.4
214,000
51,000
0
294
452
177,000
443,000
0.032918
0.002078
0.044483
0.0016
0.001991
0.177215
0.000028
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
2.947368
0.121907
0.001505
NA
NA
0
0
0
0.079
0.039
35.1
3.34
16.1
4.18
19.5
1.48
0
0.186
2.60
5.21
0.286
0
35.9
0.680
82.6
125
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
"
1.01
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
'
1,940
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
"
2,143
NA
NA
Nitrogen
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
4.5
22.9
NC
NC
Total Nitrogen
8,830
45,000
53,800
NA
NA
NA
NA
NA
NA
8.15
3.33
NA
15,700
6,400
NA
-
-
NA
Phosphorus
Total
Phosphorus
1426544
2
365.1
mg/L
0.02
2.87
NC
Total Phosphorus
Facility Total
5,630
5,630
532,000
NA
NA
NA
NA
NA
125
1.37
NA
NA
2,630
NA
NA
3,403
NA
NA
A-l
-------
Table A-l. Direct Discharge Loads and TWPE (Continued)
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/yr)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/yr)
PCS
Loads
2002
(Ibs/yr)
Episode 6516, Sample Number 66182, Treated Effluent
Conventional Pollutants
BOD5
TSS
C003
C009
5210B
160.2
mg/L
mg/L
2
1
5.6
5
NC
ND
Total Conventional Pollutants
33,700
30,000
63,700
NA
NA
NA
NA
NA
NA
-
10.6
NA
-
56,819
NA
-
-
NA
Toxic Pollutants
Bromodichloro
methane
Chloroform
Dibromochloro
methane
Nicotine
Barium
Boron
Calcium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Chloropicrin
Unknown
Dithiocarbamate
Pesticide
Ammonia as
Nitrogenb
75274
67663
124481
54115
7440393
7440428
7440702
7440508
7439896
7439954
7439965
7439987
7440235
7440666
1688700
6
1480879
8
76062
8018017
7664417
1624C
1624C
1624C
1625C
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
618
630
350.1
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
ug/L
mg/L
mg/L
10
10
10
2
100
50
10
100
200
15
10
500
10
2
10
0.5
0.1
0.04
315
576
86.2
20
8.69
155
75,000
61.1
363
24,600
54.4
27.2
132,000
23.4
426
168
0.6
0.1
0.9
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
ND
NC
Total Toxic Metals
Total Toxic Pollutants
1,890
3,460
518
0
52.2
931
451,000
367
2,180
148,000
327
163
793,000
141
2,560,000
1,010,000
3.61
0
5,410
1,400,000
4,980,000
0.032918
0.002078
0.044483
0.0016
0.001991
0.177215
0.000028
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
2.947368
0.121907
0.001505
NA
NA
62.3
7.19
23.0
0
0.104
165
12.6
233
12.2
128
4.72
32.9
4.35
6.59
62.3
5.65
10.6
0
8.14
600
779
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
"
0.37
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
'
1,811
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
"
-
NA
NA
Nitrogen
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
8.3
1.16
NC
NC
Total Nitrogen
49,900
6,970
56,800
NA
NA
NA
NA
NA
NA
12.4
2
NA
35,566
5,191
NA
-
-
NA
Phosphorus
Total
Phosphorus
1426544
2
365.1
mg/L
0.02
0.18
NC
Total Phosphorus
Facility Total
1,080
1,080
5,070,000
NA
NA
NA
NA
NA
779
1.2
NA
NA
6,778
NA
NA
-
NA
NA
Source: PCSLoads2002_v02 (U.S. EPA, 2005b), (Pickelhaupt, 2005), (Reynolds, 2005b), and Tobacco Products Sampling Data (Matuszko, 2006a).
"MeasType - type of measurement.
bAmmonia as nitrogen is included in the Toxic Pollutant category and not in the Nitrogen category because summing ammonia and TKN would double count
the ammonia.
ND - Not detected; NC - Not censored; NA - Not applicable; Dash (-) - Not provided; Baseline Value - Analytical detection limit.
A-2
-------
Table A-2. Sampled Indirectly Discharging Tobacco Products Facility Data
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/year)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/year)
POTW-
Provided
Data
(mg/L)
Episode 6511, Sample Number 66161, Discharge to POTW
Conventional Pollutants
BOD,
TSS
HEM
C003
C009
C036
5210B
160.2
1664
mg/L
mg/L
mg/L
2
1
5
1210
341
16.3
NC
NC
NC
Total Conventional Pollutants
909,000
256,000
12,200
1,180,000
NA
NA
NA
NA
NA
NA
NA
NA
597
420
14.5
NA
448,000
315,000
10,900
NA
416
402
3.19
NA
Toxic Pollutants
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene
Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
Nitrogen
67641
65850
100516
54115
75070
50000
57556
7429905
7440382
7440393
7440428
7440702
7440473
7440508
7439896
7439954
7439965
7439987
7440235
7440666
16887006
14808798
7664417
1624C
1625C
1625C
1625C
1671
1671
1671
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
350.1
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
2620
50
10
30,800
0.49
0.2
29.2
145
10
43.7
100
27,700
10
224
1,710
4,480
58.9
69.3
20,900
185
57
58
9.06
NC
ND
ND
NC
NC
NC
NC
NC
ND
NC
ND
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
Total Toxic Metals
Total Toxic Pollutants
1,970
0
0
23,100
368
150
21,900
109
0
32.8
0
20,800
0
168
1,280
3,370
44.2
52.1
15,700
139
42,800
43,600
6,810
41,700
182,000
8.46E-06
0.000331
0.005619
0.0016
0.002205
0.002331
5.72E-05
0.064691
4.041333
0.001991
0.177215
0.000028
0.075697
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
0.001505
NA
NA
0.0167
0
0
37.0
0.811
0.35
1.25
7.05
0
0.0653
0
0.583
0
107
7.19
2.91
0.639
10.5
0.0862
6.52
1.04
0.244
10.2
142
193
-
-
-
-
-
-
-
-
-
-
-
-
0.03
0.16
-
-
-
-
-
0.45
-
-
-
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
22.5
120
-
-
-
-
-
338
-
-
-
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
0.01
0.14
-
-
-
-
-
0.3
-
-
-
NA
NA
Nitrogen
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
38.7
0.35
NC
NC
Total Nitrogen
29,100
263
29,300
NA
NA
NA
NA
NA
NA
-
-
NA
-
-
NA
-
-
NA
Phosphorus
Total
Phosphorus
14265442
365.1
mg/L
0.02
3.4
NC
Total Phosphorus
Facility Total
2,550
2,550
1,390,000
NA
NA
NA
NA
NA
193
-
NA
NA
-
NA
NA
-
NA
NA
A-3
-------
Table A-2. Sampled Indirectly Discharging Tobacco Products Facility Data (Continued)
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/year)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/year)
POTW-
Provided
Data
(mg/L)
Episode 6512, Sample Number 66167, Discharge to POTW
Conventional Pollutants
BOD5
TSS
HEM
C003
C009
C036
5210B
160.2
1664
mg/L
mg/L
mg/L
2
1
5
1,740
236
12.1
NC
NC
NC
Total Conventional Pollutants
4,180,000
567,000
29,100
4,780,000
NA
NA
NA
NA
NA
NA
NA
NA
723
337
-
NA
1,066,320
495,720
-
NA
954
325
-
NA
Toxic Pollutants
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene
Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
Nitrogen
67641
65850
100516
54115
75070
50000
57556
7429905
7440382
7440393
7440428
7440702
7440473
7440508
7439896
7439954
7439965
7439987
7440235
7440666
16887006
14808798
7664417
1624C
1625C
1625C
1625C
1671
1671
1671
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
350.1
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
2,560
6,470
1290
16,800
0.3
0.41
131
177
10
66.8
135
28,100
10
41.6
2,020
7,310
55.9
16.7
57,300
104
122
47
5.48
NC
NC
NC
NC
NC
NC
NC
NC
ND
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
Total Toxic Metals
Total Toxic Pollutants
6,150
15,600
3,100
40,400
721
985
315,000
425
0
161
324
67,500
0
100
4,860
17,600
134
40.1
138,000
250
293,000
113,000
13,200
229,000
1,030,000
8.46E-06
0.000331
0.005619
0.0016
0.002205
0.002331
5.72E-05
0.064691
4.041333
0.001991
0.177215
0.000028
0.075697
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
0.001505
NA
NA
0.0521
5.15
17.4
64.6
1.59
2.30
18.0
27.5
0
0.320
57.5
1.89
0
63.5
27.2
15.2
1.94
8.09
0.756
11.7
7.14
0.633
19.8
216
352
-
-
-
-
-
-
-
-
-
-
-
-
-
0.07
-
-
-
-
-
0.18
-
-
3.07
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
102.6
-
-
-
-
-
208
-
-
4,428
NA
NA
-
-
-
-
-
-
-
-
0.002
-
-
-
0.006
0.078
-
-
-
-
-
0.135
-
-
3
NA
NA
Nitrogen
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
22.6
0.05
NC
ND
Total Nitrogen
54,300
0
54,300
NA
NA
NA
NA
NA
NA
-
-
NA
-
-
NA
-
-
NA
Phosphorus
Total
Phosphorus
14265442
365.1
mg/L
0.02
1.86
NC
Total Phosphorus
Facility Total
4,470
4,470
5,870,000
NA
NA
NA
NA
NA
352
-
NA
NA
-
NA
NA
-
NA
NA
A-4
-------
Table A-2. Sampled Indirectly Discharging Tobacco Products Facility Data (Continued)
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/year)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/year)
POTW-
Provided
Data
(mg/L)
Episode 6513, Sample Number 66171, Discharge to POTW
Conventional Pollutants
BOD5
TSS
HEM
C003
C009
C036
5210B
160.2
1664
mg/L
mg/L
mg/L
2
1
5
208
287
9.5
NC
NC
NC
Total Conventional Pollutants
221,000
305,000
10,100
535,000
NA
NA
NA
NA
NA
NA
NA
NA
-
-
-
NA
-
-
-
NA
340
528
-
NA
Toxic Pollutants
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene
Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
Nitrogen
67641
65850
100516
54115
75070
50000
57556
7429905
7440382
7440393
7440428
7440702
7440473
7440508
7439896
7439954
7439965
7439987
7440235
7440666
16887006
14808798
7664417
1624C
1625C
1625C
1625C
1671
1671
1671
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
350.1
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
142
222
10
7,490
0.42
0.44
10
979
10
71.7
100
17,700
26.3
135
4,400
4,390
146
10
15,700
879
22
19
3.8
NC
NC
ND
NC
NC
NC
ND
NC
ND
NC
ND
NC
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
Total Toxic Metals
Total Toxic Pollutants
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
31.6
0.59
NC
NC
Total Nitrogen
151
236
0
7,950
446
467
0
1,040
0
76.1
0
18,800
27.9
143
4,670
4,660
155
0
16,700
933
23,300
20,200
4,030
47,000
104,000
33,500
626
34,200
8.46E-06
0.000331
0.005619
0.0016
0.002205
0.002331
5.72E-05
0.064691
4.041333
0.001991
0.177215
0.000028
0.075697
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
0.001505
NA
NA
NA
NA
NA
0.00128
0.078
0
12.7
0.983
1.09
0
67.2
0
0.151
0
0.526
2.11
90.9
26.1
4.03
2.24
0
0.0915
43.7
0.568
0.113
6.07
237
259
NA
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
NA
NA
-
-
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
NA
NA
-
-
NA
-
-
-
-
-
-
-
<0.005
-
-
-
0.015
0.1
-
-
0.1
<0.01
-
0.8
-
-
4.5
NA
NA
20.1
-
NA
Phosphorus
Total
Phosphorus
14265442
365.1
mg/L
0.02
2.99
NC
Total Phosphorus
Facility Total
3,170
3,170
677,000
NA
NA
NA
NA
NA
259
-
NA
NA
-
NA
NA
2.88
NA
NA
A-5
-------
Table A-2. Sampled Indirectly Discharging Tobacco Products Facility Data (Continued)
Pollutant
CAS
Number
Method
Units
Baseline
Value
Concentration
Meas
Type"
Annual
Load
(Ibs/year)
12/04 TWF
Annual
TWPE
Facility-
Provided
Data
(mg/L)
Facility-
Provided
Data
(Ibs/year)
POTW-
Provided
Data
(mg/L)
Episode 6515, Sample Number 66176, Discharge to POTW
Conventional Pollutants
BOD5
TSS
HEM
C003
C009
C036
5210B
160.2
1664
mg/L
mg/L
mg/L
2
1
5
223
182
33.9
NC
NC
NC
Total Conventional Pollutants
548,000
447,000
83,300
1,080,000
NA
NA
NA
NA
NA
NA
NA
NA
-
-
-
NA
-
-
-
NA
1,009
977
-
NA
Toxic Pollutants
2-Propanone
Benzoic Acid
Benzyl Alcohol
Nicotine
Acetaldehyde
Formaldehyde
Propylene
Glycol
Aluminum
Arsenic
Barium
Boron
Calcium
Chromium
Copper
Iron
Magnesium
Manganese
Molybdenum
Sodium
Zinc
Chloride
Sulfate
Ammonia as
Nitrogen
67641
65850
100516
54115
75070
50000
57556
7429905
7440382
7440393
7440428
7440702
7440473
7440508
7439896
7439954
7439965
7439987
7440235
7440666
16887006
14808798
7664417
1624C
1625C
1625C
1625C
1671
1671
1671
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
200.7
325.3
375.4
350.1
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
mg/L
mg/L
mg/L
50
50
10
20
0.5
0.5
10
50
10
2
100
50
10
10
100
200
15
10
500
10
2
10
0.04
51.1
8,690
10
12,700
1.83
0.14
10
136
14.5
41.1
100
18,200
18.3
138
860
4,130
84
10
18,200
395
90
37
3.36
NC
NC
ND
NC
NC
NC
ND
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
Total Toxic Metals
Total Toxic Pollutants
126
21,400
0
31,200
4,500
344
0
334
35.6
101
0
44,700
45
339
2,110
10,100
206
0
44,700
971
221,000
90,900
8,260
104,000
482,000
8.46E-06
0.000331
0.005619
0.0016
0.002205
0.002331
5.72E-05
0.064691
4.041333
0.001991
0.177215
0.000028
0.075697
0.634822
0.0056
0.000866
0.014433
0.201439
5.49E-06
0.046886
2.43E-05
5.6E-06
0.001505
NA
NA
0.00106
7.07
0
49.9
9.91
0.802
0
21.6
144
0.201
0
1.25
3.40
215
11.8
8.78
2.98
0
0.246
45.5
5.39
0.509
12.4
455
541
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
NA
NA
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
NA
NA
-
-
-
-
-
-
-
-
<0.005
-
-
-
0.02
0.67
-
-
0.44
<0.01
-
0.474
-
-
3.65
NA
NA
Nitrogen
TKN
Nitrate/Nitrite
C021
COOS
351.3
353.2
mg/L
mg/L
1
0.05
26.1
6.39
NC
NC
Total Nitrogen
64,100
15,700
79,800
NA
NA
NA
NA
NA
NA
-
-
NA
-
-
NA
43
-
NA
Phosphorus
Total
Phosphorus
14265442
365.1
mg/L
0.02
7.41
NC
Total Phosphorus
Facility Total
18,200
18,200
1,660,000
NA
NA
NA
NA
NA
541
-
NA
NA
-
NA
NA
9.525
NA
NA
Source: (Matuszko, 2006a), (Pickelhaupt, 2005), and POTW-provided data (see OW-2004-0032); "MeasType -type of measurement; bAmmonia as nitrogen is
included in the Toxic Pollutant category and not in the Nitrogen category because summing ammonia and TKN would double count the ammonia; ND - Not
detected; NC - Not censored; NA - Not applicable; Dash (-) - Not provided; Baseline Value - Analytical detection limit.
A-6
------- |