&EPA
United States
Environmental Protection
Agency
The 2014 Annual Effluent
Guidelines Review Report
July 2015
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U.S. Environmental Protection Agency
Office of Water (43 03 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA-821-R-15-001
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Table of Contents
TABLE OF CONTENTS
Page
PART I: INTRODUCTION I
1. 2014 ANNUAL REVIEW EXECUTIVE SUMMARY 1-1
1.1 References for 2014 Annual Review Executive Summary 1-4
2. BACKGROUND 2-1
2.1 The Clean Water Act and the Effluent Guidelines Program 2-1
2.2 Effluent Guidelines Review and Planning Process 2-2
2.2.1 Effluent Guidelines Review and Prioritization Factors 2-3
2.2.2 Annual Review Process 2-3
2.2.3 Effluent Guidelines Program Plans 2-11
2.3 References for Background 2-12
PART II: EPA's 2014 ANNUAL REVIEW METHODOLOGY AND ANALYSES II
3. INTRODUCTION TO EPA's 2014 ANNUAL REVIEW 3-1
4. PUBLIC COMMENTS AND OTHER STAKEHOLDER INPUT ON THE FINAL
2012 AND PRELIMINARY 2014 EFFLUENT GUIDELINES PROGRAM PLANS 4-1
4.1 Public Comments and Stakeholder Input 4-1
5. CONTINUED REVIEW OF SELECT INDUSTRIAL CATEGORIES 5-1
5.1 Continued Review of the Metal Finishing Category (40 CFR Part
433) 5-1
5.1.1 Overview of Existing ELGs Related to Metal Finishing 5-2
5.1.2 Profile of Metal Finishing Operations in the U.S 5-9
5.1.3 Potential ELG Applicability Issues and Other
Considerations 5-27
5.1.4 Summary of Findings from EPA's Continued Review of
the Metal Finishing Category 5-28
5.1.5 References for the Continued Review of the Metal
Finishing Category 5-30
5.2 Targeted Review of Pesticide Active Ingredients Without Pesticide
Chemical Manufacturing Effluent Limits (40 CFR Part 455) 5-34
5.2.1 Targeted Review of Pesticide Active Ingredients Without
Pesticide Chemical Manufacturing Effluent Limits 5-36
5.2.2 Summary of Findings from EPA's Targeted Review of
Pesticide Active Ingredients Without Pesticide Chemical
Manufacturing Effluent Limits 5-38
5.2.3 References for EPA's Targeted Review of Pesticide Active
Ingredients Without Pesticide Chemical Manufacturing
Effluent Limits 5-39
5.3 Continued Review of Brick and Structural Clay Products
Manufacturing 5-40
5.3.1 Air Regulations for Brick and Structural Clay Products
Manufacturing 5-40
IV
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Table of Contents
TABLE OF CONTENTS (Continued)
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5.3.2 2014 Annual Review of Brick and Structural Clay Products
Manufacturing 5-41
5.3.3 Summary of Findings from EPA's Review of Brick and
Structural Clay Products Manufacturing 5-45
5.3.4 References for the Continued Review of Brick and
Structural Clay Manufacturing 5-45
6. NEW DATA SOURCES AND ADDITIONAL SUPPORTING ANALYSES 6-1
6.1 Review of Engineered Nanomaterials in Industrial Wastewater 6-1
6.1.1 Literature Review and Research Methodology 6-2
6.1.2 Overview of Nanomaterials 6-4
6.1.3 Engineered Nanomaterial Production Methods, Volumes,
and Potential Sources of Industrial Discharge 6-5
6.1.4 Fate, Wastewater Treatment, and Toxicity 6-6
6.1.5 Analytical Methods 6-10
6.1.6 Federal Research and the National Nanotechnology
Initiative 6-12
6.1.7 Summary of Findings 6-13
6.1.8 References for the Review of Engineered Nanomaterials in
Industrial Wastewater 6-14
6.2 Review of Industrial Wastewater Treatment Technologies 6-21
6.2.1 Industrial Wastewater Treatment Technologies Data
Collection Results 6-22
6.2.2 Industrial Wastewater Treatment Technologies Database
Structure and Data Elements 6-24
6.2.3 Database Structure 6-24
6.2.4 Data Elements Captured 6-26
6.2.5 Summary of Data Captured in IWTT 6-27
6.2.6 References for the Review of Industrial Wastewater
Treatment Technologies 6-31
PART III: RESULTS OF EPA'S 2014 ANNUAL REVIEW Ill
7. RESULTS OF THE 2014 ANNUAL REVIEW 7-1
7.1 Continued Review of Select Industrial Categories 7-1
7.2 New Data Sources and Additional Supporting Analyses 7-2
7.3 References for Results of the 2014 Annual Review 7-4
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List of Tables
LIST OF TABLES
Page
Table 4-1. Comments on the Preliminary 2014 Effluent Guidelines Program Plan EPA
Docket Number: EPA-HQ-OW-2014-0170 4-4
Table 5-1. Regulated Pollutants and ELG Limits for the Metal Finishing Category,
SubpartA 5-5
Table 5-2. Unit Operations Regulated by ELGs for the Metal Finishing Category 5-6
Table 5-3. Comparison of Maximum Monthly Average Effluent Limits Between Parts
413 and 433 and the Proposed Limits for Part 438 5-8
Table 5-4. Estimated Number of Metal Finishing Facilities Identified During the MP&M
Rulemaking Efforts 5-9
Table 5-5. Number of Metal Finishing Facilities by Discharge Practice 5-14
Table 5-6. Water Use by Unit Operation 5-15
Table 5-7. Waste Characteristics by Unit Operation 5-16
Table 5-8. Metal Finishing Category Top 2011 DMR Pollutants 5-18
Table 5-9. Metal Finishing Category Top 2011 TRI Pollutants 5-18
Table 5-10. Summary of Wastewater Treatment Technologies for End-of-Pipe Discharge
of Metal Finishing Wastewater 5-22
Table 5-11. Summary of Waste Minimization Technologies for Reuse 5-24
Table 5-12. Summary of Wastewater Treatment Technologies for Reuse of Metal
Finishing Wastewater 5-26
Table 5-13. PAIs Measured by EPA-Approved Methods Without Limits in Subparts A
and B of the Pesticide Chemicals ELGs (40 CFR Part 455) 5-35
Table 5-14. Registration Status for the 30 PAIs of Interest 5-36
Table 5-15. Brick Manufacturing Facilities in theU.S 5-42
Table 5-16. Clay Ceramics Facilities in the U.S 5-44
Table 6-1. Common Types of Engineered Nanomaterials 6-4
Table 6-2. Calculated Model Values for Predicted Environmental Concentrations of
Engineered Nanomaterials in the U.S 6-10
VI
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List of Tables
LIST OF TABLES (Continued)
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Table 6-3. Research Organizations Developing Analytical Methods for ENMs 6-11
Table 6-4. Frequency of Industries Represented in IWTT 6-23
Table 6-5. List of Data Input Tables 6-24
Table 6-6. Overview of Information Captured in IWTT 6-26
Table 6-7. Pilot- or Full- Scale Treatment Technologies Captured in IWTT 6-27
Table 6-8. Industries with Performance data in IWTT 6-29
Table 6-9. Top Parameters with Performance Data in IWTT 6-30
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List of Figures
LIST OF FIGURES
Page
Figure 2-1. Odd-Year Annual Review of Existing ELGs 2-8
Figure 2-2. Odd-Year Identification of Possible New ELGs 2-9
Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of Possible
New ELGs 2-10
Figure 2-4. Further Review of Industrial Categories Identified During Annual Reviews 2-11
Figure 5-1. Metal Finishing Process Application 5-12
Figure 6-1. IWTT Structure 6-26
Vlll
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PART I: INTRODUCTION
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Section 1—2014 Annual Review Executive Summary
1. 2014 ANNUAL REVIEW EXECUTIVE SUMMARY
Effluent limitations guidelines and standards (ELGs) are an essential element of the
nation's clean water program, which was established by the 1972 Clean Water Act (CWA).
ELGs are technology-based regulations used to control industrial wastewater discharges. EPA
issues ELGs for new and existing point source categories that discharge directly to surface
waters, as well as those that discharge indirectly to publicly-owned treatment works (POTWs).
These ELGs are applied in discharge permits as limits to the pollutants that facilities may
discharge. To date, EPA has established ELGs to regulate wastewater discharges from 58 point
source categories. This regulatory program substantially reduces industrial wastewater pollution
and continues to be a critical aspect of the effort to clean the nation's waters.
In addition to developing new ELGs, the CWA requires EPA to revise existing ELGs
when appropriate. Over the years, EPA has revised ELGs in response to developments such as
advances in treatment technology and changes in industry processes. To continue its efforts to
reduce industrial wastewater pollution and fulfill CWA requirements, EPA conducts an annual
review and effluent guidelines planning process. The annual review and planning process has
three main objectives: (1) to review existing ELGs to identify candidates for revision, (2) to
identify new categories of direct dischargers for possible development of effluent guidelines, and
(3) to identify new categories of indirect dischargers for possible development of pretreatment
standards. To achieve these objectives, EPA conducts a two-phase review. First, EPA screens
industrial discharges based on the relative hazard they pose to human health and the
environment. Then, for those categories identified as a hazard priority, EPA conducts a more
detailed evaluation to determine if the category is a candidate for new or revised ELGs.
Beginning with the 2012 Annual Review, EPA began augmenting the methods and data
sources it uses to identify industrial categories for which new or revised ELGs may be
developed. This new approach combines the traditional toxicity rankings analysis (TRA) and the
analyses of new hazard data sources not included in the TRA, coupled with an expanded review
of new or improved treatment technologies. EPA performs these review efforts in alternate
years—completing the TRA in odd years and the analyses of additional industrial hazard data
sources and new treatment technologies in even years. The aim of the even-year review is to
expand EPA's ability to identify new pollutants of concern and to identify wastewater discharges
in industrial categories not currently regulated by ELGs. This review also enables EPA to screen
industrial wastewater discharges based on a broader set of hazard data and to account for
advances in treatment technologies much earlier in the review process. Both of these factors are
keys to improving the effectiveness of the Effluent Guidelines Program. EPA has already
completed its odd-year review for 2013 using the TRA and published the results in the
Preliminary 2014 Effluent Guidelines Program Plan (Preliminary 2014 Plan) (79 FR 55472).l
For the 2014 Annual Review, EPA followed up on several proposed actions identified in
the Preliminary 2014 Plan (79 FR 55472). Specifically, EPA continued the following reviews:
(1) preliminary review of the Metal Finishing Point Source Category; (2) targeted review of
1 The Preliminary 2014 Plan is combined with the Final 2012 Plan in the document Final 2012 and Preliminary
2014 Effluent Guidelines Program Plans. The Plans discuss the findings of both the 2012 and 2013 Annual Reviews
(79 FR 55472).
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Section 1—2014 Annual Review Executive Summary
pesticide active ingredients (PAIs) for which the discharge from manufacturing is not currently
regulated under the Pesticide Chemicals ELGs; and (3) review of the use of wet air pollution
controls within the brick and structural clay products manufacturing industry. EPA also initiated
an investigation of the manufacture and processing of engineered nanomaterials (ENMs) as a
potential new source of industrial wastewater discharge; continued its review of industrial
wastewater treatment technology data for the Industrial Wastewater Treatment Technology
(IWTT) Database; and reviewed public comments submitted on the Preliminary 2014 Plan. For
more information on the 2014 Annual Review analyses, see the bullets below.
• Continued Review of the Metal Finishing Category (40 CFR Part 433). As a
follow up to the findings in its 2012 and 2013 Annual Reviews, and in response to
some public comments on the Preliminary 2012 Effluent Guidelines Program
Plan, EPA continued its preliminary review of the Metal Finishing Category in
the 2014 Annual Review. Specifically, EPA reviewed the scope of the existing
ELGs, examined the current industry profile, and gathered data on wastewater
treatment technologies. EPA also contacted regional EPA pretreatment
coordinators to further discuss metal finishing operations and potential
applicability issues associated with the Metal Finishing ELGs.
• Targeted Review of Pesticide Active Ingredients (PAIs) Without Pesticide
Chemical Manufacturing Effluent Limits (40 CFR Part 455). As part of the 2012
Annual Review, EPA reviewed analytical methods that it recently developed or
revised to facilitate its identification of unregulated pollutants in industrial
wastewater discharge. By examining these methods, EPA identified 30 PAIs that
are now measured by existing analytical methods under 40 CFR Part 136, but that
do not currently have pesticide chemicals manufacturing effluent limits under
Subparts A and B in the Pesticide Chemicals ELGs (40 CFR Part 455) (U.S.
EPA, 2014). For the 2014 Annual Review, EPA began evaluating data sources
that would provide information on the production of the 30 PAIs of interest to
identify and prioritize for further review any that are manufactured in the U.S.
These sources included pesticide registration status under Section 3 of the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) and production information
reported under Section 7 of FIFRA.
• Continued Review of Brick and Structural Clay Products Manufacturing. As part
of EPA's 2012 Annual Review, EPA identified brick and structural clay products
manufacturing as an industry not currently regulated by ELGs that may have
industrial wastewater discharges resulting from federal air pollution control
requirements. For its 2014 Annual Review, EPA reviewed the current National
Emission Standards for Hazardous Air Pollutants (NESHAP) for the industry, and
contacted EPA's Office of Air and Radiation and the Brick Industry Association
to learn more about the NESHAP and the potential impacts on the industry,
specifically regarding the installation of wet air pollution controls.
• Review of Engineered Nanomaterials (ENMs) in Industrial Wastewater. EPA
began evaluating ENMs as a potential emerging industrial wastewater pollutant
category of concern as part of the 2014 Annual Review. EPA reviewed current
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Section 1—2014 Annual Review Executive Summary
literature and communicated with leading researchers and government
stakeholders about the fate, transport, and effects of ENMs on the environment
and human health, and about the presence and discharge of ENMs in industrial
wastewater.
• Review of Industrial Wastewater Treatment Technologies. EPA continued
reviewing technical papers and research articles regarding the performance of new
and improved industrial wastewater treatment technologies and began populating
the performance data and treatment information into a searchable IWTT
Database. As part of the 2014 Annual Review, EPA described its industrial
wastewater treatment technology data collection methodology, data quality
assurance and control, and database design, development, and storage. EPA also
summarized the industrial wastewater treatment technology information collected
to date.
Based on the data and analyses conducted for the 2014 Annual Reviews, and public
comment and stakeholder input, EPA identified several outstanding data gaps and topics that
warrant further investigation. These include:
• New metal finishing processes, pollutants of concern, and advances in wastewater
treatment technologies (see Section 5.1);
• The production of PAIs of interest that do not have pesticide chemicals
manufacturing limits under Subparts A and B of the Pesticides Chemicals ELGs,
particularly for those PAIs that are not currently registered under FIFRA, but that
may be produced in the U.S. for export only (see Section 5.2); and
• ENMs, particularly silver, titanium dioxide, and carbon-based nanomaterials, as
new potential pollutants of concern in industrial wastewater discharge (see
Section 6.1).
From the 2014 Annual Review, EPA determined that one industry, brick and structural
clay products manufacturing, is not generating a potential new source of industrial wastewater
discharge that warrants regulation at this time (see Section 5.3).
As part of the 2014 Annual Review, EPA also compiled and presented the information
collected to date in the IWTT Database from 163 articles, 98 of which provide both treatment
system information and performance data. The treatment system performance data cover 142
pollutant parameters and 35 different industries (see Section 6.2).
This report details EPA's methodology for its 2014 Annual Review and supports EPA
Office of Water's Final 2014 Effluent Guidelines Program Plan (U.S. EPA, 2015). The Plan,
pursuant to Section 304(m) of the Clean Water Act (CWA),2 discusses the findings of the 2014
Annual Review and details EPA's proposed actions and follow-up. The Plan also identifies any
: Available at: http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/.
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Section 1—2014 Annual Review Executive Summary
new or existing industrial categories selected for effluent guidelines rulemaking and provides a
schedule for such rulemaking.
1.1 References for 2014 Annual Review Executive Summary
1. U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C.
(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.
2. U.S. EPA, 2015. Final 2014 Effluent Guidelines Program Plan. Washington, D.C. (July).
EPA-821-R-15-002. EPA-HQ-OW-2014-0170. DCN 08107.
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Section 2—Background
2. BACKGROUND
This section explains how the Effluent Guidelines Program fits into EPA's National
Water Program, describes the general and legal background of the Effluent Guidelines Program,
and summarizes EPA's process for making effluent guidelines revision and development
decisions (i.e., effluent guidelines planning), including details of its annual review process.
2.1 The Clean Water Act and the Effluent Guidelines Program
The Clean Water Act (CWA) is based on the principle of cooperative federalism, with
distinct roles for both EPA and the states, in which the goal is to restore and maintain the
chemical, physical, and biological integrity of the nation's waters. To that end, the Act is
generally focused on two types of controls: (1) water-quality-based controls, based on water
quality standards, and (2) technology-based controls, based on effluent limitations guidelines and
standards (ELGs).
The CWA gives states the primary responsibility for establishing, reviewing, and revising
water quality standards. Water quality standards consist of designated uses for each water body
(e.g., fishing, swimming, supporting aquatic life), criteria that protect the designated uses
(numeric pollutant concentration limits and narrative criteria, for example, "no objectionable
sediment deposits"), and an antidegradation policy. EPA develops recommended national criteria
for many pollutants, pursuant to CWA section 304(a), 33 U.S.C. § 1314(a), which states may
adopt or modify, as appropriate, to reflect local conditions.
EPA is responsible for developing technology-based ELGs, based on currently available
technologies, for controlling industrial wastewater discharges. ELGs apply to pollutant
discharges from industrial facilities directly to surface water (direct discharges) and to publicly
owned treatment works (POTWs) (indirect discharges). For sources discharging directly to
surface waters, permitting authorities—states authorized to administer the National Pollutant
Discharge Elimination System (NPDES) permit program, and EPA in the few states that are not
authorized— must incorporate EPA-promulgated limitations and standards into discharge
permits, where applicable (U.S. EPA, 2010). Categorical pretreatment standards are directly
enforceable.
While technology-based effluent limitations and standards in discharge permits are
sometimes as stringent as, or more stringent than necessary to meet water quality standards, the
effluent guidelines program is not specifically designed to ensure that the discharges from each
facility meet the water quality standards of the receiving water body. For this reason, the CWA
also requires authorized states to establish water-quality-based effluent limitations where
necessary to meet water quality standards. Water-quality-based limits may require industrial
facilities to meet requirements that are more stringent than those of a national effluent guideline
regulation. In the overall context of the CWA, ELGs must be viewed as one tool in the broader
set of tools and authorities Congress provided to EPA and the states to restore and maintain the
quality of the nation's waters.
The 1972 amendments to the CWA marked a distinct change in Congress's efforts "to
restore and maintain the chemical, physical, and biological integrity of the Nation's waters" (see
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Section 2—Background
CWA section 101(a), 33 U.S.C. 125l(a)). Before 1972, the CWA focused principally on water
quality standards. This approach was challenging, however, because of the difficulty in
determining whether a specific discharger, or combination of dischargers, was responsible for
decreasing the water quality in a receiving stream.
The 1972 CWA directed EPA to promulgate effluent limitations guidelines and standards
that reflect pollutant reductions achievable by categories or subcategories of industrial point
sources through the implementation of available treatment and prevention technologies. The
ELGs are based on specific technologies (including process changes) that EPA identifies as
meeting the statutorily prescribed level of control (see CWA sections 301(b)(2), 304(b), 306,
307(b), and 307(c)). See Appendix A of this report for more information on the CWA and an
explanation of the different levels of control for ELGs.
Unlike other CWA tools, ELGs are national in scope and establish pollution control
obligations for all facilities that discharge wastewater within an industrial category or
subcategory. In establishing these controls under the direction of the statute, EPA assesses, for
example: (1) the performance and availability of the best pollution-control technologies or
pollution-prevention practices for an industrial category or subcategory as a whole; (2) the
economic achievability of those technologies, which can include consideration of the
affordability of achieving the reduction in pollutant discharge; (3) the cost of achieving effluent
reductions; (4) non-water-quality environmental impacts (including energy requirements); and
(5) such other factors as the EPA Administrator deems appropriate.
In passing the CWA, congress viewed the creation of a single national pollution control
requirement for each industrial category, based on the best technology the industry can afford, as
a way to reduce the potential creation of "pollution havens" and set the nation's sights on
eliminating pollutant discharge to U.S. waters. Consequently, EPA's goal in establishing national
ELGs is to ensure that industrial facilities with similar characteristics, regardless of their location
or the nature of their receiving water, will, at a minimum, meet similar effluent limitations and
standards representing the performance of the best pollution control technologies or pollution
prevention practices.
ELGs provide the opportunity to promote pollution prevention and water conservation.
This may be particularly important in controlling persistent, bioaccumulative, and toxic
pollutants discharged in concentrations below analytic detection levels.
2.2 Effluent Guidelines Review and Planning Process
In addition to establishing new regulations, the CWA requires EPA to review existing
effluent guidelines annually. EPA reviews all point source categories subject to existing effluent
guidelines and pretreatment standards to identify potential candidates for revision, consistent
with CWA sections 304(b), 301(d), 304(m)(l)(A) and 304(g). EPA also reviews industries
consisting of direct-discharging facilities not currently subject to effluent guidelines to identify
potential candidates for effluent guidelines rulemakings, pursuant to CWA section 304(m)(l)(B).
Finally, EPA reviews industries consisting entirely or almost entirely of indirect-discharging
facilities that are not currently subject to pretreatment standards, to identify potential candidates
for pretreatment standards development under CWA section 307(b).
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Section 2—Background
2.2.1 Effluent Guidelines Review and Prioritization Factors
In its annual reviews, EPA considers four major factors to prioritize existing effluent
guidelines or pretreatment standards for possible revision, or to identify new industries of
concern through alternate analyses. These factors were developed in EPA's draft National
Strategy, described at http://water.epa.gov/scitech/wastetech/guide/strategy/fs.cfm.
The first factor EPA considers is the amount and type of pollutants in an industrial
category's discharge and the relative hazard posed by that discharge. Using this factor enables
EPA to prioritize rulemakings to achieve significant environmental and health benefits.
The second factor EPA considers is the performance and cost of applicable and
demonstrated wastewater treatment technologies, process changes, or pollution prevention
alternatives that could effectively reduce pollutant concentrations in the industrial category's
wastewater and, consequently, reduce the hazard posed by these pollutant discharges to human
health or the environment.
The third factor EPA considers is the affordability or economic achievability of the
wastewater treatment technology, process change, or pollution prevention measures identified
using the second factor. If the financial condition of the industry indicates that it would not be
affordable to implement expensive and stringent new requirements, EPA might conclude a less
stringent, less expensive approach to reduce pollutant loadings would better satisfy applicable
statutory requirements.
The fourth factor EPA considers is the opportunity to eliminate inefficiencies or
impediments to pollution prevention or technological innovation, or opportunities to promote
innovative approaches such as water-quality trading, including within-plant trading. This factor
might also prompt EPA, during annual reviews, to decide against revising an existing set of
effluent guidelines or pretreatment standards where the pollutant source is already efficiently and
effectively controlled by other regulatory or non-regulatory programs.
2.2.2 Annual Review Process
EPA's annual review process includes an odd- and even-year annual review cycle, to
address cohesively and comprehensively the factors laid out in EPA's draft National Strategy. In
the odd-year reviews, EPA screens industrial dischargers through a toxicity ranking analysis
(TRA) that identifies and ranks those categories whose reported pollutant discharges pose a
substantial hazard to human health and the environment (the first draft National Strategy factor).
For the TRA, EPA relies on discharge monitoring report (DMR) and Toxics Release Inventory
(TRI) data to rank industrial discharge categories based on toxic-weighted pound equivalents
(TWPE) released. EPA relies on facility and state contacts, permits, and publicly available data
sources to review top ranking industrial categories (see Section 2.2.2.1 for more detail on the
TRA).
In the even years, EPA reviews additional hazard data sources and conducts alternate
analyses to enhance the identification of industrial categories for which new or revised ELGs
may be appropriate, beyond those that traditionally rank high in the TRA. This is consistent with
the Government Accountability Office's (GAO) recommendation that EPA's annual review
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Section 2—Background
approach include additional industrial hazard data sources to augment its screening-level review
of discharges from industrial categories.3 Furthermore, EPA recognizes the need to consider, in
the screening phase, the availability of treatment technologies, process changes, or pollution
prevention practices that can reduce the identified hazards (the second and fourth draft National
Strategy factors). Specifically, in the even-year reviews, EPA is targeting new data sources that
will provide information on other considerations not previously captured as part of the TRA,
including, but not limited to, the following:
• Industrial process changes;
• Emerging contaminants of concern;
• Advances in treatment technologies and pollution prevention practices;
• Availability of new, more sensitive analytical methods; and
• Other hazard data and information not captured in the TRA and/or suggested by
stakeholders or by public comments.
Using the TRA in the odd-year review in conjunction with additional analyses and hazard
data in the even-year review, EPA is considering more cohesively and comprehensively the
factors laid out in EPA's draft National Strategy. This approach allows the Agency to prioritize
existing effluent guidelines or pretreatment standards for possible revision, or identify new
industries of concern through alternate analyses. See Section 2.2.2.2 for an overview of EPA's
even-year analyses.
EPA also conducts a more detailed preliminary category review of those industrial
discharge categories that rank highest in terms of TWPE (i.e., pose the greatest hazard to human
health and the environment) in the TRA, or are identified as warranting further review during the
even-year analyses. If EPA determines that further review is appropriate for an industrial
category, EPA may complete a preliminary or detailed study of the point source category (see
Section 2.2.2.3 and Section 2.2.2.4, respectively), which may eventually lead to a new or revised
guideline.
2.2.2.1 Overview of the Toxicity Ranking Analysis and Odd-Year Annual Reviews
In the odd-year annual reviews, EPA conducts a TRA using data from the TRI and data
from DMRs contained in the Permit Compliance System (PCS) and the Integrated Compliance
Information System for the National Pollutant Discharge Elimination System (ICIS-NPDES).
Figure 2-1 details how EPA uses the TRA to identify existing ELGs that may warrant revision.
Figure 2-2 addresses how EPA identifies new categories that may warrant regulation.
TRI and DMR data do not identify the effluent guideline(s) applicable to a particular
facility. However, TRI includes information on a facility's North American Industry
Classification System (NAICS) code, while DMR data include information on a facility's
Standard Industrial Classification (SIC) code. Thus, the first step in EPA's TRA is to relate each
3 GAO's recommendations for the review of additional hazard data sources were published in GAO's September
2012 report, Water Pollution: EPA Has Improved Its Review of Effluent Guidelines but Could Benefit from More
Information on Treatment Technologies, available online at http://www.gao.gov/assets/650/647992.pdf.
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Section 2—Background
SIC and NAICS code to an industrial category.4 The second step is to use the information
reported in TRI and DMR for a specific year to calculate the pounds of pollutant discharge to
U.S. waters. These calculations are performed for toxic, nonconventional, and conventional
pollutants. For indirect dischargers, EPA adjusts the facility discharges to account for removals
at the POTW. The third step is to apply toxic weighting factors (TWFs)5 to the annual pollutant
discharges to calculate the total discharge of toxic pollutants as TWPE for each facility. EPA
then sums the TWPE for each facility in a category to calculate a total TWPE per category for
that year. EPA calculates two TWPE estimates for each category: (1) an estimate based on data
in TRI and (2) an estimate based on DMR data. EPA combines these two estimates to generate a
single TWPE value for each industrial category. EPA takes this approach because it found that
combining the TWPE estimates from TRI and DMR data into a single TWPE number offered a
clearer perspective of the industries with the most toxic pollution.6
EPA then ranks point source categories according to their total TWPE discharges. To
identify categories for further review, EPA prioritizes categories accounting for 95 percent of the
cumulative TWPE from the combined DMR and TRI data. For more information on EPA's odd-
year review process and methodology, see Section 3 of EPA's Preliminary 2012 Effluent
Guidelines Program Plan (U.S. EPA, 2013).
As illustrated in Figure 2-1, EPA typically excludes from further review categories for
which an effluent guidelines rulemaking is currently underway, or for which effluent guidelines
have been promulgated or revised within the past seven years.7 EPA also excludes categories in
which only a few facilities account for a large majority of toxic-weighted pollutant discharges.
EPA generally does not prioritize such a category for additional review, but suggests that
individual permits may be more effective in addressing the toxic-weighted pollutant discharges
than a national effluent guidelines rulemaking. For more information on the results of the 2013
Annual Review, see Section 6 of EPA's 2013 Annual Effluent Guidelines Review Report (U.S.
EPA, 2014).
As illustrated in Figure 2-2, EPA may also evaluate discharges in the odd-year TRA that
are associated with SIC or NAICS codes that are not currently regulated or that may be a
potential new subcategory of an existing ELG. EPA evaluates these discharges to determine if
new ELGs are warranted for the new industrial category or subcategory. Similarly, EPA can
supplement this information with findings from new analyses conducted in the even-year annual
4 For more information on how EPA related each SIC and NAICS code to an industrial category, see Section 5.0 of
the 2009 Technical Support Document for the Annual Review of Existing Effluent Guidelines and Identification of
Potential New Point Source Categories (U.S. EPA, 2009).
5 For more information on TWFs, see Toxic Weighting Factor Development in Support ofCWA 304(m) Planning
Process (U.S. EPA, 2006).
6 Different pollutants may dominate the TRI and DMR TWPE estimates for an industrial category due to the
differences in pollutant reporting requirements between the TRI and DMR databases. The single TWPE number for
each category highlights those industries with the most toxic discharge data in both TRI and DMR. Although this
approach could have theoretically led to double-counting, EPA's review of the data indicates that, because the two
databases focus on different pollutants, double-counting is minimal and does not affect the order of the top-ranked
industrial categories.
7 EPA chose seven years because this is the typical length of time for the effects of effluent guidelines or
pretreatment standards to be fully reflected in pollutant loading data and TRI reports.
2-5
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Section 2—Background
review, as well as review of treatment technology performance data, to identify new industrial
categories that may warrant ELGs (see Section 2.2.2.2).
2.2.2.2 Overview of Even-Year Annual Reviews
In the even-year annual reviews, EPA identifies additional hazard data and reviews
treatment technologies to augment the TRA completed in each odd-year review. EPA prioritizes
the review of these additional hazard data sources based on three factors: (1) the likelihood of
identifying unregulated industrial discharges, (2) the utility of identifying new wastewater
treatment technologies or pollution prevention alternatives, and (3) representativeness of the data
for an industrial category. These new analyses take into account a broader set of hazard data and
advancements in treatment technologies. In addition to the new hazard data sources, the even-
year reviews will include information from the public comments received on the Preliminary
Plan and any continuing preliminary category reviews identified during the odd-year review, as
illustrated in Figure 2-3. The specific methodologies and analyses of EPA's 2014 Annual
Review are described in more detail in Part II of this report.
2.2.2.3 Preliminary Category Reviews
EPA may complete preliminary category reviews as part of the annual review cycle,
depending on the industrial categories warranting review at that time. EPA may conduct a
preliminary category review for the industrial categories with the highest hazard potential
identified in the TRA, or identified as a priority from any of the even-year review analyses,
particularly if it lacks sufficient data to determine whether regulatory action would be
appropriate, as illustrated in Figure 2-4. In its preliminary category reviews, EPA typically
examines the following: (1) wastewater characteristics and pollutant sources, (2) the pollutants
driving the toxic-weighted pollutant discharges, (3) availability of pollution prevention and
treatment, (4) the geographic distribution of facilities in the industry, (5) any pollutant discharge
trends within the industry, and (6) any relevant economic factors.
In executing preliminary category reviews, EPA first attempts to verify the toxicity
ranking results and fill in data gaps. These assessments provide an additional level of quality
assurance for the reported pollutant discharges and number of facilities that represent the
majority of toxic-weighted pollutant discharge. After the ranking results are verified, EPA next
considers costs and performance of applicable and demonstrated technologies, process changes,
or pollution prevention alternatives that can effectively reduce the pollutants in the point source
category's wastewater. Finally, and if appropriate based on the other findings, EPA considers the
affordability or economic achievability of the technology, process change, or pollution
prevention measure identified using the second factor.
During a preliminary category review, EPA may consult data sources including, but not
limited to the following: (1) the U.S. Economic Census, (2) TRI and DMR data, (3) trade
associations and reporting facilities that can verify reported releases and facility categorization,
(4) regulatory authorities (states and EPA regions) that can clarify how category facilities are
permitted, (5) NPDES permits and their supporting fact sheets, (6) EPA effluent guidelines
technical development documents, (7) relevant EPA preliminary data summaries or study
reports, and (8) technical literature on pollutant sources and control technologies. If a
2-6
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Section 2—Background
preliminary category review reveals that the reports of toxic discharges are correct, not
geographically isolated, and likely to be the result of the production practices in use broadly
throughout the category, EPA may decide to conduct a preliminary or detailed study prior to
initiating a rulemaking. In many cases, the information and data gathered for a study forms the
basis of information used for the rulemaking. However, in some instances, EPA may decide not
to move forward with a rulemaking following a study, if the data and information gathered
indicates that a new or revised guideline is not warranted. Regardless of the outcome, EPA
announces to the public and other stakeholders decisions to conduct studies, or to develop
rulemakings, in the Effluent Guidelines Program Plan. When a rulemaking is determined
appropriate, schedules are also announced in the Plan.
2.2.2.4 Preliminary and Detailed Studies
After conducting the preliminary category reviews, as shown in Figure 2-4, EPA may
then conduct either a preliminary or detailed study of an industrial category. Typically, these
studies profile an industry category, gather information about the hazards posed by its
wastewater discharges, collect information about availability and cost of treatment and pollution
prevention technologies, assess the financial status of the facilities in the category, and
investigate other factors to determine if it would be appropriate to identify the category for
possible effluent guidelines revision. During preliminary or detailed studies, EPA typically
examines the factors and data sources listed above for preliminary category reviews. However,
during a detailed study EPA's examination of a point source category and available pollution
prevention and treatment options is generally more rigorous than the analysis conducted during a
preliminary category review or study, and may include primary data collection activities (such
as industry questionnaires and wastewater sampling and analysis) to fill data gaps.
2-7
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Section 2—Background
Preliminary results of Toxicity Rankings Analysis
= Combined TRIReleases and DMRLoads
database rankings (Factor 1)
<_ DMR&TRI
database
tools
Stakeholder
recommendations
and comments
Evaluation of treatment technology performance data
Stakeholder recommendations and comments
Not a priority category,
no further review at this time
Not a priority
category, no
further
review at this time
Are ELG revisions
currently
underway?
Have
ELGs been
developed or revised
within the past 7
ears?
Not a priority
category, no further
review at this time*
Are
non-representative
facilities responsible for
overall category
TWPE?
Not a priority
category,
but may recommend
permitting support
for individual facilities
When ranked
by TWPE, does category
contribute to top 95% of
cumulative TWPE of all
categories?
Further review
(see Figure 2-4)
Possible outcomes
-Further review
-BPJ support
-Identify for
possible
revision of existing
ELGs
-No action
Are there
identified implementation
and efficiency
issues (Factor 4)'
* If EPA is aware of new segment growth within such a category or new concerns are identified, EPA may do
further review.
Figure 2-1. Odd-Year Annual Review of Existing ELGs
2-8
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Section 2—Background
Stakeholder recommendations
and comments
Identify SIC/NAICS codes
with discharges not subject
to existing ELGs
Is the SIC/NAICS code
appropriately considered a
otential new subcategory
fan existing ELG?
Include in annual review
of
existing category
(see Figure 2-1)
Begin industry
identification
No identification or
further review necessary
Do
discharges interfere
with or otherwise pass
through POTW
operations?
Are pollutants
potentially present at
significant
concentrations?*
Is the possible new
category all or nearly all
indirect dischargers?
No identification or
further review
necessary
Identify other tools
(e.g. permit-based
support or guidance
Are ELGs the
appropriate tool?
Further review
(see Figure 2-4)
* Significant concentrations include levels above minimum levels from 40 CFR Part 136 or other EPA-approved
methods, levels above treatability levels, or at levels of concern to human health and toxicity.
Figure 2-2. Odd-Year Identification of Possible New ELGs
2-9
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Section 2—Background
Begin even-year review
of hazard data sources and
treatment technology
performance data
Continued review from
odd-year (as necessary)
Identify industries with
pollutant
discharges not previously
reviewed
Stakeholder
recommendations
and comments
Collect additional data from
industry groups, published
reports from EPA, and peer-
reviewed publications
Are pollutants
potentially present at
significant
concentrations?
Determine if an
existing industry point source
category is applicable
to discharges
Do ELGs
appropriately
regulate all pollutant
ischarges identified
Not a priority
category, no
further
review at this time
Further review
(see Figure 2-4)
Not a priority
category, no further
review at this time
* Significant concentrations include levels above minimum levels from 40 CFR Part 136 or other EPA-approved
methods, levels above treatability levels, or at levels of concern to human health and toxicity.
Figure 2-3. Even-Year Annual Review of Existing ELGs and Identification of
Possible New ELGs
2-10
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Section 2—Background
Category identified for further
review (see Figures 2-1, 2-2, and 2-3),
Not enough
information
Further Review
- Preliminary category
review
- Preliminary or detailed
study
(continue collecting data
covering all four factors)
Stakeholder
input
Are discharges
adequately controlled
by existing ELGs?
No further review at this time
Identify for possible
promulgation or revision
of ELGs
Are ELGs potentially
the appropriate tool?
Identify other tools (e. g.,
permit-based support or guidance)
Figure 2-4. Further Review of Industrial Categories Identified During Annual Reviews
2.2.3 Effluent Guidelines Program Plans
CWA section 304(m)(l)(A) requires EPA to publish an Effluent Guidelines Program
Plan (Plan) every two years that establishes a schedule for the annual review and revision, in
accordance with section 304(b), of the effluent limitations guidelines that EPA has promulgated
under that section. EPA publishes the results of the TRA and preliminary category review
conducted during the odd-year review in a Preliminary Plan, and takes public comment. In the
even year following publication of the Preliminary Plan, EPA identifies and evaluates additional
data sources and hazard analyses to supplement the TRA. EPA then publishes a Final Plan in the
even year. The Final Plan presents the compilation of the odd- and even-year reviews and any
public comments received on the Preliminary Plan. EPA may initiate, continue, or complete
preliminary category reviews or in-depth studies during the odd- or even-year reviews,
depending upon when it identifies a category warranting further review. Additionally, EPA may
2-11
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Section 2—Background
publish the findings from these studies as part of the Preliminary Plan or Final Plan, based on
when during the planning cycle the study or review is completed.
EPA has several reasons for coordinating its annual reviews under section 304(b) with
publication of Plans under section 304(m). First, the annual reviews are inextricably linked to the
planning effort because each review year's results may inform the content of the Preliminary and
Final Plans (e.g., by identifying candidates for effluent guidelines revision, or by identifying
point source categories for which EPA has never promulgated effluent limitations guidelines).
Second, even though it is not required to do so under either section 304(b) or section 304(m),
EPA believes it can serve the public interest by periodically describing the annual reviews
(including the review process used) and review results to the public. Doing so while
simultaneously publishing the Preliminary and Final Plans makes both processes more
transparent. Third, by requiring EPA to review existing effluent limitations guidelines each year,
Congress appears to have intended for each successive review to build on the results of earlier
reviews.
2.3 References for Background
1. U.S. EPA. 2010. U.S. EPA NPDES Permit Writers'Manual. Washington, D.C.
(September). Available online at:
http://cfpub.epa.gov/npdes/writermanual.cfm?program_id=45. EPA-833-K-10-001. EPA-
HQ-OW-2010-0824-023 6.
2. U.S. EPA. 2013. Preliminary 2012 Effluent Guidelines Program Plan. Washington, D.C.
(May). EPA-821-R-12-002. EPA-HQ-OW-2010-0824-0194.
3. U.S. EPA. 2014. The 2013 Annual Effluent Guidelines Review Report. Washington, D.C.
(September). EPA-821-R-12-003. EPA-HQ-OW-2014-0170-0077.
2-12
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PART II: EPA'S 2014 ANNUAL
REVIEW METHOLOLOGY AND
ANALYSES
ii
-------
Section 3—Introduction to EPA's 2014 Annual Review
3. INTRODUCTION TO EPA's 2014 ANNUAL REVIEW
The even-year review provides EPA with an opportunity to identify additional available
hazard data sources and conduct further analyses at the pollutant, industry, or wastewater
treatment technology levels. As described above in Section 2.2.2.2, EPA identified and
prioritized additional data sources and analyses for the 2014 Annual Review based on (1) the
likelihood that they would assist in identifying unregulated industrial discharges, (2) their utility
in identifying new wastewater treatment technologies or pollution prevention alternatives, and
(3) how well the data represent the activity of an industrial category.
EPA is using the data sources and analyses identified in this 2014 Annual Review to
screen additional industrial discharge categories and pollutants of concern and to identify for
further review those that potentially pose a hazard to human health or the environment. The 2014
Annual Review consisted of three components:
• Consideration of public comments on the Preliminary 2014 Effluent Guidelines
Program Plan and other stakeholder input (see Section 4).
• Continuation of the industrial category reviews (e.g., collecting additional data,
contacting permit writers, evaluating available treatment technology information)
of specific industrial categories that EPA identified as warranting additional
review in the Final 2012 and Preliminary 2014 Plan Effluent Guidelines Program
Plans (see Section 5).
• Identification and evaluation of new industrial hazard data sources and analyses
of these data to identify new wastewater discharges or pollutants not previously
regulated and to identify wastewater discharges that can be more effectively
treated or eliminated (see Section 6).
The specific data sources, analyses, and findings for each of the 2014 Annual Review
components listed above are described in detail in Sections 4, 5, and 6. A summary of the 2014
Annual Review findings is presented in Part III of this report.
3-1
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
4. PUBLIC COMMENTS AND OTHER STAKEHOLDER INPUT ON THE FINAL 2012 AND
PRELIMINARY 2014 EFFLUENT GUIDELINES PROGRAM PLANS
EPA's annual review process considers information provided by the public and other
stakeholders regarding the need for new or revised effluent limitations guidelines and
pretreatment standards. Public comments received on EPA's prior reviews and pans helped the
Agency prioritize its analysis of existing effluent guidelines and pretreatment standards. This
section presents a summary of the public comments and stakeholder input received on the
Preliminary 2014 Effluent Guidelines Program Plan (Preliminary 2014 Plan).
4.1 Public Comments and Stakeholder Input
EPA published its Preliminary 2014 Plan together with the Final 2012 Plan and provided
a 60-day public comment period on the Preliminary 2014 Plan starting on September 16, 2014
(see 79 FRN 55472). The Docket supporting the Final 2014 Effluent Guidelines Program Plan
(Final 2014 Plan) includes a complete set of the comments submitted, as well as the Agency's
responses (see DCN 08110). EPA received comments on the Preliminary 2014 Plan from 18
organizations; Table 4-1 presents a summary of these comments.
Commenting organizations representing industry included:
• American Petroleum Institute;
• Coalbed Methane Association of Alabama;
• American Forest & Paper Association;
• National Association for Surface Finishing;
• American Chemistry Council Nanotechnology Panel;
• American Fuel & Petrochemical Manufacturers;
• Valero Companies;
• Greenway Products, Inc.; and
• NORA: an Association of Responsible Recyclers.
Commenting organizations representing environmental groups included:8
• Clean Water Action;
• Earthjustice;
• Earthworks;
• Environmental Defense Fund;
• League of Conservation Voters;
• Natural Resources Defense Fund; and
• Sierra Club.
8 Seven environmental organizations submitted one combined public comment on the Preliminary 2014 Plan. One of
the environmental organizations also submitted a separate public comment on the Preliminary 2014 Plan.
4-1
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
Additionally, one consultant to pretreatment programs for local governments, CWA
Consulting Services, LLC and one state representing organization, the Association of Clean
Water Administrators (ACWA).
EPA received five comments on its proposed CWTs detailed study from one consultant
to local government pretreatment programs, two industry representatives, and several
environmental organizations. The consultant to local government pretreatment programs
commented that EPA should review and clearly define the applicability of CWT effluent
limitations guidelines and standards (40 CFR Part 437) as they relate to accepting oil and natural
gas produced wastewater. One industry representative questioned the intent and basis for the
CWTs detailed study, citing a lack of definition for what qualifies as a CWT, a lack of a
reasonable basis for initiating the study, and potential overlap with the Oil and Gas Extraction
ELGs for shale gas facilities that direct their wastewater to CWTs. The other industry
representative commented that revising the CWT ELG may not be necessary to address
discharges of oil and gas extraction wastewater (to CWTs, POTWs, or surface water) and that
any new regulations and/or guidelines for CWT facilities could be aided by direct meetings
between EPA, industry experts in the field, and the operators of CWT facilities.
The environmental organizations supported EPA's decision to undertake a detailed study
of CWTs that accept oil and gas wastewaters and requested the study be expedited, citing that (1)
the CWT ELGs are out of date in light of the developments in the oil and gas extraction industry;
(2) CWTs may not have treatments in place for pollutants in oil and gas wastewaters; (3) oil and
gas wastewaters may have potential impacts on drinking water sources; and (4) pretreatment
standards under development for discharges to POTWs from onshore unconventional oil and gas
extraction could result in more discharges to CWTs. One environmental organization also
provided recommendations for resources and information in support of the CWT detailed study.
For the Petroleum Refining Category (40 CFR Part 419), EPA received three comments
from industry representatives questioning the quality and appropriateness of data used as the
basis for initiating the study. Industry representatives also questioned EPA's objective for
examining feedstock metals. One industry representative questioned the basis for EPA's
investigation of polynuclear aromatic hydrocarbons. EPA also received a comment from the
consultant to local government pretreatment programs supporting the detailed study and
suggesting that EPA specifically evaluate common problem pollutants, including benzene and
sulfides. In addition the commenter indicated that EPA should evaluate groundwater pump-and-
treat operations to clearly define regulated, unregulated, and dilute waste streams.
EPA received comments on its proposed continued preliminary review of the Metal
Finishing Category (40 CFR Part 433) from the consultant to local government pretreatment
programs, one industry representative, and an organization representing states. The consultant to
the local government pretreatment programs did not support reopening the regulation because it
could make the regulation vulnerable to weakening by special interest groups. The industry
representative did not support further review of the Metal Finishing Category, stating that EPA
recently reviewed the industry as part of the Metal Products and Machinery ELGs rulemaking
and determined that revised guidelines were not necessary. Further, the industry representative
commented that the industry is not using new processes or treatment technologies that would
suggest the need to revise the applicable Metal Finishing ELGs, and POTWs have the ability to
4-2
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
impose stricter limits to address specific concerns. The organization representing states
supported further review of the Metal Finishing Category, stating that the industry has changed
significantly since the existing regulations were developed. These changes include updated
chemical formulas and processes, new pollutants of concern, new treatment technologies, and a
broader scope for the metal finishing universe. The organization representing states also
commented that clarification is needed regarding classification of a facility as an existing or new
source, that there are inconsistencies in categorical determinations across the country for certain
metal finishing applications (etching vs. cleaning, coating vs. adsorption, phosphate coating vs.
cleaning), and that EPA should consider adopting a sunset provision for the Electroplating ELGs
(40 CFR Part 413) to require eventual compliance with the Metal Finishing ELGs (40 CFR Part
433).
For nanomaterials, the consultant to local government pretreatment programs and one
industry representative supported EPA's effort to characterize nanomaterials in industrial
wastewater discharges. Specifically, the industry representative urged EPA to recognize the
diversity of nanomaterials and their applications across multiple industries in its future reports;
coordinate closely with EPA's New Chemicals Program to understand nanomaterial releases in
water; consider work on the fate and transport of nanomaterials completed or currently
underway; and recognize the potential for nanotechnology to provide new and improved tools for
wastewater treatment. One wastewater treatment products manufacturer also commented that he
is currently testing a coagulant/flocculent/filter aid that has shown success at settling nano-
particles, E. coli, phosphorus and other particulates.
The group of seven environmental groups commented that ongoing revisions to
pretreatment standards for discharges to POTWs need to reflect changes in onshore oil and gas
exploration, stimulation, and extraction. One environmental organization commented that the oil
and gas ELG rulemaking for the unconventional oil and gas facilities be finalized as soon as
possible, and provided recommendations for resources and information in support of the
rulemaking.
The organization representing states supported EPA's new even-year review
methodology, used in the 2012 Annual Review, as well as inclusion of the current status of ELGs
under development in the Final 2012 Plan. This commenter also suggested improvements to the
ELG review and planning processes, including an increase in EPA staff allocated to work on
ELGs and pretreatment standards, and publication of Annual Review Reports earlier in the
planning process, as well as more timely publication of future ELG Plans.
The consultant to local government pretreatment programs commented that EPA should
add biodiesel manufacturing to the list of industrial sectors to evaluate.
Lastly, EPA received three unsolicited comments on final decisions announced in the
Final 2012 Plan. EPA did not solicit public comment on the content of the Final 2012 Plan since
public comments were solicited on the actions and decisions when they were proposed in the
Preliminary 2012 Plan on August 7, 2013. Regardless, one industry commenter indicated
support for EPA's decision in the Final 2012 Plan to delist coalbed methane as a new
subcategory under the Oil and Gas Extraction Category (40 CFR Part 435), and an
environmental organization indicated they did not support EPA's decision to delist coalbed
4-3
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
methane. The third unsolicited comment by an industry organization indicated support for
EPA's final decision in the Final 2012 Plan not to further review Pulp and Paper industry
discharges.
In general, the public comments submitted on the Preliminary 2014 Plan did not result in
any new direction or determinations with respect to the proposed actions announced in the
Preliminary 2014 Plan, or EPA's final decisions and actions indicated in this Final 2014 Plan.
EPA did, however, receive useful information and input from the public review that will help
inform ongoing studies, in particular Petroleum Refining, Metal Finishing and CWTs. EPA's
responses to the specific comments can be found in EPA's comment response document (DCN
08110).
Table 4-1. Comments on the Preliminary 2014 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2014-0170
No.
1
Commenter
Name
Curt A.
McCormick
Commenter
Organization
CWA Consulting
Services, LLC
(CWACS)
EPA
Docket
No.
0081
Comment Summary
Supports EPA's evaluation of centralized waste
treatment (CWTs) facilities to clarify whether
facilities that accept oil and natural gas produced
wastewaters by truck for treatment, which is
subsequently discharged to publicly -owned
treatment works (POTWs) meet the definition of a
CWT (and whether they are subject to 40 CFR Part
437 (CWTs) or 40 CFR Part 403 (General
Pretreatment Regulations). Supports EPA's study of
the Petroleum Refining (40 CFR Part 419) industry
and suggests that that EPA specifically evaluate
common problem pollutants such as benzene and
sulfides, as well as groundwater pump-and-treat
operations to clearly define regulated, unregulated,
and dilute wastestreams. Opposes reopening of the
Metal Finishing ELGs (40 CFR Part 433) because it
could make the regulation vulnerable to weakening
by special interest groups. Supports EPA's efforts to
characterize nanopollutants and requests that EPA
add biodiesel manufacturing to the list of industrial
sectors to evaluate.
4-4
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
Table 4-1. Comments on the Preliminary 2014 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2014-0170
No,
2
3
4
5
6
Commenter
Name
Roger E.
Claff
Dennis
Lathem
Jerry
Schwartz
Jeffrey S.
Hannapel
Jay West
Commenter
Organization
American Petroleum
Institute (API)
Coalbed Methane
Association of
Alabama (CMAA)
American Forest &
Paper Association
(AF&PA)
National Association
for Surface Finishing
(NASF)
American Chemistry
Council (ACC)
Nanotechnology
Panel
EPA
Docket
No.
0082
0083
0084
0085,
0093
(duplicate
comment)
0086
Comment Summary
Raises several issues related to the proposed
Petroleum Refining (40 CFR Part 419) study,
specifically the use of TRI data, EPA's objectives
for examining petroleum refinery feedstock metals,
the basis for evaluating polynuclear aromatic
hydrocarbons (PNAs), and EPA's request for
information on oil refining processes. Also raises
several issues related to the proposed CWTs (40
CFR Part 437) study including the lack of criteria
used to define CWTs, the basis for initiating the
study, and the need for consistency with ELGs for
oil and gas extraction for shale gas facilities that
direct their wastewaters to CWTs. Supports
continued engagement and communication with
EPA during the studies.
Supports EPA's decision to delist coalbed methane
as a new subcategory under the Oil & Gas
Extraction Category (40 CFR Part 435) because
EPA did not identify a new wastewater treatment
technology that would be economically achievable.
Supports EPA's decisions in the Final 2012 Plan that
no further review of the Pulp, Paper, and
Paperboard (40 CFR Part 430) industry is necessary
and its decision not to include the category for
further review in the Preliminary 20 14 Plan.
Opposes EPA's continued preliminary review of the
Metal Finishing Category (40 CFR Part 433)
because EPA's recent review of the industry under
the Metal Products and Machinery (MP&M)
rulemaking (40 CFR Part 438) determined further
revisions to the guidelines are not necessary, the
industry is not using new processes or treatment
technologies that would suggest the need for ELG
revisions, and POTWs may impose more stringent
limits as necessary.
Supports EPA's review of nanomaterials; however,
urges EPA to recognize the diversity of
nanomaterial substances and their applications,
work with the New Chemicals Program to
understand nanomaterial releases in water, consider
work on nanomaterials completed or currently
underway, and recognize the potential for
nanotechnology to provide new and improved tools
for wastewater treatment.
4-5
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
Table 4-1. Comments on the Preliminary 2014 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2014-0170
No,
7
8
9
10
Commenter
Name
Jeff
Gunnulfsen
Matthew H.
Hodges
Michael
Fulton
Bryan Holt
Commenter
Organization
American Fuel &
Petrochemical
Manufacturers
(AFPM)
Valero Companies
Association of Clean
Water Administrators
(ACWA)
Greenway Products
Inc.
EPA
Docket
No.
0087
0088
0089
0090
Comment Summary
Urges EPA to demonstrate the specific concerns
with the current Petroleum Refining ELGs (40 CFR
Part 419). Specifically, questions the data, data
quality, and information evaluated as part of the
annual reviews and used to form the basis for the
proposed study. Urges EPA to work with industry
representatives to develop a path forward.
Opposes further study of the Petroleum Refining (40
CFR Part 419) industry, citing that EPA has not
fully considered the data or data quality to support
the decision to conduct a detailed study. Specifically
raised issues related to the data demonstrating
discharges of metals and dioxins, the correlation of
crude feedstock to pollutant discharges, and EPA's
demonstration that the current ELGs are not
sufficient to protect human health and the
environment.
Supports further study of the Metal Finishing (40
CFR Part 433) industry, stating that there have been
drastic changes in the industry, including new
chemical formulas and processes, new pollutants of
concern, new treatment technologies, and changes
in the scope of the metal finishing industry.
Encourages EPA to more clearly define gray areas
in the current regulations, such as the definition of
etching vs. cleaning, coating vs. absorption, and
phosphate coating vs. phosphate cleaning.
Recommend that EPA clarify new and existing
sources and sunset the Electroplating ELGs (40
CFR Part 413) to require eventual compliance with
the Metal Finishing ELGs (40 CFR Part 433).
Recommends EPA increase the staff allocated to
working on ELGs and pretreatment standards and
issue future ELG Plans and Annual Review Reports
in a timelier manner. Supports EPA's new
methodology used in the 2012 Annual Review
Report.
Stated that their company is currently testing a
coagulant/flocculent/filter aid to remove
nanoparticles, E.coli, phosphorus, and other
particulates.
4-6
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Section 4—Public Comments and Other Stakeholder Input on
the Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans
Table 4-1. Comments on the Preliminary 2014 Effluent Guidelines Program Plan
EPA Docket Number: EPA-HQ-OW-2014-0170
No,
11
12
13
Commenter
Name
Lynn Thorp
Jessica Ennis
Lauren Pagel
Scott
Anderson
Madeleine
Foote
Amy Mall
Deborah J.
Nardone
Scott
Anderson
Christopher
Harris
Commenter
Organization
Clean Water Action
Earthjustice
Earthworks
Environmental
Defense Fund
League of
Conservation Voters
Natural Resources
Defense Fund
Sierra Club
Environmental
Defense Fund (EOF)
NORA: Association
of Responsible
Recyclers, Inc.
EPA
Docket
No.
0091
0092
0094
Comment Summary
Oppose EPA's decision to delist coalbed methane
extraction and discontinue the ELG rulemaking
because the industry produces large volumes of
wastewater with contaminants at potentially high
concentrations. Stated that inadequate treatment and
discharge of these wastewaters could jeopardize the
integrity of the surface water, that EPA's decision to
delist was premature, that ELGs are necessary, and
that affordable treatments are available. Support
EPA's decision to undertake a detailed study of the
CWTs (40 CFR Part 437) that accept oil and gas
wastewaters because the ELGs are out of date,
CWTs may be lacking treatment for pollutants in oil
and gas wastewaters, these wastewaters could have
impacts on drinking water sources, and pretreatment
standards under development for discharges to
POTWs from onshore unconventional oil and gas
extraction could results in more discharges to
CWTs. Additionally, commented that ongoing
revisions to pretreatment standards for discharges to
POTWs need to be revised to reflect changes in oil
and gas exploration, stimulation, and extraction.
Supports comments from the group of
environmental organizations. Encourages EPA to
finalize the oil and gas ELG rulemaking as fast as
possible due to the potential severity of the
consequences if discharges too significantly outpace
regulation. Supports a detailed study of the CWTs
(40 CFR Part 437) that accept oil and gas
wastewaters, but reminds EPA that conducting the
CWT study is only a first steps toward materially
improving oversight of CWTs. Provided additional
resources and studies on oil and gas wastewaters
and CWTs.
States that revising the CWT ELG may not be
necessary to address discharges of oil and gas
extraction wastewater (to CWTs, POTWs, or
surface water) and that the organization plans to be
closely involved with any regulatory changes and/or
guidelines for CWTs (40 CFR Part 437). Suggested
that any new regulations and/or guidelines for CWT
facilities could be aided by direct meetings between
EPA, NORA's experts in this field, and the
operators of CWT facilities.
4-7
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Section 5—Continued Review of Select Industrial Categories
5. CONTINUED REVIEW OF SELECT INDUSTRIAL CATEGORIES
For the 2014 Annual Review, EPA continued to evaluate several industrial categories that
the Preliminary 2014 Plan identified as warranting further review: Metal Finishing (40 CFR Part
433), Pesticide Chemicals (40 CFR Part 455) and brick and structural clay products
manufacturing (not currently regulated) (U.S. EPA, 2014).
EPA documented the usability and quality of the data supporting its continued review of
these industrial categories, analyzed how the data could be used to improve the characterization
of industrial wastewater discharges (universe of facilities with known or potential discharges,
concentration and quantity of pollutants, availability and performance of advances in wastewater
treatment), and prioritized the findings for further review. See Appendix B of this report for
more information on data usability and quality of the data sources supporting these reviews.
Section 5.1 through Section 5.3 of this report details EPA's continued review of these
three industrial categories.
5.1 Continued Review of the Metal Finishing Category (40 CFR Part 433)
EPA reviewed the Metal Finishing Category (40 CFR Part 433) as part of the 2012 and
2013 Annual Reviews and determined that the category warranted further review. EPA
continued its review of this category in its 2014 Annual Review.
During the 2012 Annual Review, EPA's review of the Targeted National Sewage Sludge
Survey (TNSSS), combined with available indirect discharge data from the Toxics Release
Inventory (TRI), suggested further investigation of the Metal Finishing Category relating to the
indirect discharge of metals, particularly chromium, nickel, and zinc, to publicly-owned
treatment works (POTWs). These metals could transfer to sewage sludge, where their
concentrations could diminish the sludge's beneficial use. EPA evaluated beneficial use by
comparing the metal concentrations against the regulatory ceiling concentrations for sewage land
application (40 CFR 503 Subcategory B) and sewage sludge concentration limits for surface
disposal (40 CFR 503 Subcategory C) (U.S. EPA, 2014a). EPA also received comments from the
Association of Clean Water Administrators (ACWA) urging EPA to revise regulations or issue
new guidance for the industry due to applicability concerns and advancements in process and
treatment technology for metal finishing and metal finishing wastewater (ACWA, 2013). In the
2013 Annual Review, the Metal Finishing Category also ranked high, in terms of toxic weighted
pound equivalents (TWPE), in EPA's toxicity ranking analysis (U.S. EPA, 2014b).
As part of this 2014 Annual Review, EPA reviewed the scope of the existing Metal
Finishing Effluent Limitations Guidelines and Standards (ELGs), examined the current profile of
metal finishing operations in the U.S., and gathered data on existing and advanced metal
finishing wastewater treatment technologies. EPA also held discussions with regional EPA
pretreatment coordinators who are involved in the implementation of POTW pretreatment
programs throughout the U.S. to further understand metal finishing operations and potential
applicability issues with the Metal Finishing ELGs. The following sections present the findings
of EPA's continued review of the Metal Finishing Category.
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Section 5—Continued Review of Select Industrial Categories
5.1.1 Overview of Existing ELGs Related to Metal Finishing
To provide background and context for EPA's continued review of the Metal Finishing
Category (40 CFR Part 433), this section provides a brief history of the development and review
of the existing ELGs related to metal finishing operations. Metal finishing is defined as the
process of changing the surface of an obj ect for the purpose of improving its appearance and/or
durability. Wastewater discharges from metal finishing operations are primarily regulated by two
ELGs:9 pretreatment standards for existing sources (PSES) for the Electroplating Category (40
CFR Part 413) and the effluent limitations, pretreatment standards, and new source performance
standards (NSPS) for the Metal Finishing Category (40 CFR Part 433).
5.1.1.1 Pretreatment Standards for Existing Sources in the Electroplating Category
EPA promulgated PSES for the Electroplating Category (40 CFR Part 413) on September
7, 1979. The rule established pretreatment standards for facilities that indirectly discharge to
POTWs above and below a discharge threshold of 10,000 gallons per day (gpd). Standards for
new sources and direct dischargers were not established under this rule. The pretreatment
standards include concentration-based limits with alternate mass-based limits for metals,
cyanide, and total toxic organics. Facilities had the option of complying with either
concentration- or mass-based limits. At promulgation, these standards applied to existing
facilities that perform one or more of six electroplating operations, which are defined below and
in the Development Document for Existing Source Pretreatment Standards for the Electroplating
Point Source Category (U.S. EPA, 1979):
• Electroplating: the production of a thin surface coating of one metal upon another
by electrodeposition. This surface coating is applied to provide corrosion
protection, wear or erosion resistance, or anti-frictional characteristics, or for
decorative purposes.
• Electrolessplating: a chemical reduction process that depends on the catalytic
reduction of a metallic ion in an aqueous solution containing a reducing agent and
the subsequent deposition of metal without the use of external electrical energy.
• Anodizing: an electrolytic oxidation process that converts the surface of the metal
to an insoluble oxide.
• Coating: the process of chromating, phosphating, metal coloring, and immersion
plating.10 In chromating, a portion of the base metal is converted to a component
of the film by reaction with aqueous solutions containing hexavalent chromium
and active organic or inorganic compounds. Phosphate coatings are used to
provide a good base for paints and other organic coatings, to condition the
surfaces for cold forming operations by providing a base for drawing compounds
and lubricants, and to impart corrosion resistance to the metal surface by the
9 Discharges from facilities performing metal finishing operations may also be regulated under other ELGs (e.g.,
aluminum forming, iron and steel) that take precedence over the Metal Finishing ELGs, as discussed in Section
5.1.1.2.
10 The Metal Finishing ELGs refer to immersion plating as passivation.
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Section 5—Continued Review of Select Industrial Categories
coating itself or by providing a suitable base for rust-preventative oils or waxes.
Metal coloring by chemical conversion methods produces a large group of
decorative finishes. Immersion plating is a chemical plating process in which a
thin metal deposit is obtained by chemical displacement of the basis metal. A
common example of immersion plating is the deposition of copper on steel from
an acid copper solution.
• Etching and chemical milling: producing specific design configurations and
tolerances on metal parts by controlled dissolution with chemical reagents or
etchants. Included in this classification are the processes of chemical milling,
chemical etching, bright dipping, electropolishing, and electrochemical
machining.11 Chemical etching is the same process as chemical milling, but with
much lower rates and depths of metal removal. Bright dipping is a specialized
form of etching, used to remove oxide and tarnish from ferrous and nonferrous
materials. This unit operation also includes the stripping of metallic coatings.
• Printed circuit board manufacturing: the formation of a circuit pattern of
conductive metal (usually copper) on nonconductive board materials such as
plastic or glass. It usually involves cleaning and surface preparation, catalyst and
electroless plating, pattern printing and masking, electroplating, and etching.
The National Association of Metal Finishers and the Institute of Interconnecting and
Packaging Electronic Circuits challenged the PSES for the Electroplating Category. On March 7,
1980, EPA entered into a settlement agreement with these two organizations, agreeing to publish
amendments to the final electroplating pretreatment standards if the petitioners dismissed their
petition for review of the standards. These amendments were implemented on January 28, 1981
(U.S. EPA, 1981). As a result, EPA agreed to develop best available technology economically
achievable (BAT) effluent limits, NSPS, and pretreatment standards for new and existing sources
(PSNS and PSES) under a new regulation for the Metal Finishing Category.
Metal finishing facilities are categorized as either captive facilities or job shops, which
EPA defined as follows (U.S. EPA, 1984):
• Captive facility: a facility that in a calendar year owns more than 50 percent (on
an area basis) of the materials undergoing metal finishing. Captive facilities were
further categorized as integrated or non-integrated to characterize the wastewater
discharges generated. Integrated facilities combine electroplating waste streams
with significant process waste streams not covered by the Electroplating
Category, whereas non-integrated facilities have significant wastewater
discharges only from electroplating operations covered under the Electroplating
Category.
• Job shop: a facility that in a calendar year owns less than 50 percent (on an area
basis) of the materials undergoing metal finishing. Although job shops can be also
11 The Metal Finishing ELGs do not include electropolishing or electrochemical machining in the classification of
etching and chemical milling.
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Section 5—Continued Review of Select Industrial Categories
categorized as integrated and non-integrated, approximately 97 percent were
found to be non-integrated during the development of the new regulation.
By February 15, 1986, all existing captive facilities under the Electroplating Category
shifted to the Metal Finishing Category and were required to comply with the Metal Finishing
ELGs. Any new sources of wastewater discharges (both direct and indirect) as well as existing,
direct discharging sources from metal finishing facilities that were not regulated under the
Electroplating Category would also fall under the Metal Finishing Category. Only existing
indirect discharging job shops, including independent printed circuit board (IPCB)
manufacturers, remained in the existing Electroplating Category after the final compliance date
for the Metal Finishing ELGs.
5.1.1.2 Effluent Guidelines for the Metal Finishing Category
The Metal Finishing ELGs were promulgated on July 15, 1983. They establish one set of
concentration-based limitations, summarized in Table 5-1, that apply across a single subpart
(subpart A: Metal Finishing). Direct dischargers comply with BAT and NSPS limits, whereas
indirect dischargers comply with PSES and PSNS limits for existing and new sources,
respectively. As the table shows, the limits are the same between new sources and existing
sources of industry wastewater, except for cadmium, which has a lower limit for direct or
indirect new sources of metal finishing wastewater. The Metal Finishing ELGs regulate
wastewater discharges from the same six core operations addressed in the PSES for the
Electroplating Category. If any of these six operations is present, the Metal Finishing ELGs
apply to an additional 40 unit operations (summarized in Table 5-2) (U.S. EPA, 1983).
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Section 5—Continued Review of Select Industrial Categories
Table 5-1. Regulated Pollutants and ELG Limits for the Metal Finishing Category,
Subpart A
Process Operations Covered
See Table 5-2 for the list of 46 unit operations3
For industrial facilities with cyanide treatment, and
upon agreement between a source subject to those
limits and the pollution control authority, the
following amenable cyanide limit may apply in
place of the total cyanide limit.
Pollutant
Silver
Copper
Lead
Cyanideb
Cadmium
Chromium
Nickel
Zinc
Cyanide
amenable to
alkaline
chlorination
BAT/PSES
Daily Max
(Monthly Average)
(mg/L)
0.43 (0.24)
3.38 (2.07)
0.69 (0.43)
1.20 (0.65)
0.69 (0.26)
2.77(1.71)
3.98(2.38)
2.61 (1.48)
0.86 (0.32)
NSPS/PSNS
Daily Max
(Monthly Average)
(mg/L)
0.43 (0.24)
3.38 (2.07)
0.69 (0.43)
1.20 (0.65)
0.11(0.07)
2.77(1.71)
3.98 (2.38)
2.61 (1.48)
0.86 (0.32)
Source: 40 CFRPart 433.
a The provisions of this subpart apply to discharges from six electroplating operations on any basis material:
electroplating, electroless plating, anodizing, coating (chromating, phosphating, and coloring), chemical etching
and milling, and printed circuit board manufacturing. If any of these six operations are present, the provisions of
this subpart also apply to discharges from 40 additional metal finishing operations, listed in Table 5-2. These
limits do not apply to (1) metallic platemaking and gravure cylinder preparation conducted within or for printing
and publishing facilities or (2) existing indirect discharging job shops and independent printed circuit board
manufacturers, which are covered by 40 CFR part 413.
Anti-dilution provisions are stipulated in 40 CFR Part 433, which require self-monitoring for cyanide after
cyanide treatment and before dilution with other waste streams.
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Section 5—Continued Review of Select Industrial Categories
Table 5-2. Unit Operations Regulated by ELGs for the Metal Finishing Category
Six Electroplating Operations
(Introduced in 40 CFRPart 413)
• Electroplating
• Electroless plating
• Anodizing
• Coating
• Etching and chemical milling
• Printed circuit board manufacturing
40 Additional Metal Processing Unit Operations
(Introduced in 40 CFRPart 433)
• Cleaning
• Machining
• Grinding
• Polishing
• Barrel finishing
• Burnishing
• Impact deformation
• Pressure deformation
• Shearing
• Heat treating
• Thermal cutting
• Welding
• Brazing
• Soldering
• Flame spraying
• Sand blasting
• Abrasive jet machining
• Electrical discharge machining
• Electrochemical machining
• Electron beam machining
• Laser beam machining
• Plasma arch machining
• Ultrasonic machining
• Sintering
• Laminating
• Hot dip coating
• Sputtering
• Vapor plating
• Thermal infusion
• Salt bath descaling
• Solvent degreasing
• Paint stripping
• Painting
• Electrostatic painting
• Electropainting
• Vacuum metalizing
• Assembly
• Calibration
• Testing
• Mechanical plating
Source: 40 CFRPart433.
In some cases, ELGs for other industrial categories may be effective and applicable to
wastewater discharges from metal finishing operations. The rule specified the following
regulations that take precedence over 40 CFR Parts 413 and 433 when such an overlap occurs:
Nonferrous Smelting and Refining (40 CFR Part 421);
Coil Coating (40 CFR Part 465);
Porcelain Enameling (40 CFR Part 466);
Battery Manufacturing (40 CFR Part 461);
Iron and Steel Manufacturing (40 CFR Part 420);
Metal Casting Foundries (40 CFR Part 464);
Aluminum Forming (40 CFR Part 467);
Copper Forming (40 CFR Part 468);
Plastic Molding and Forming (40 CFR Part 463);
Electrical and Electronic Components (40 CFR Part 469);4 and
Nonferrous Forming (40 CFR Part 471).12
During the development of the Metal Products and Machinery (MP&M) rule (40 CFR
Part 438, promulgated in 2003), EPA evaluated all industries involved in the "manufacture,
rebuild or maintenance of metal parts, products, or machines," including facilities in the
12 40 CFR Parts 469 and 471 were added in the corrections to the final rule dated September 26, 1983.
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Section 5—Continued Review of Select Industrial Categories
Electroplating and Metal Finishing Categories. EPA proposed limits for these facilities under
fourMP&M subcategories: general metals, metal finishing job shops, non-chromium anodizing,
and printed wiring board (U.S. EPA, 2000). However, following consideration of comments
submitted on the proposed MP&M regulation, EPA decided not to promulgate limits for these
subcategories (68 FR 25690). Table 5-3 summarizes and compares these limits from the
proposed MP&M regulation to the existing limits from the Metal Finishing and Electroplating
ELGs.
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Section 5—Continued Review of Select Industrial Categories
Table 5-3. Comparison of Maximum Monthly Average Effluent Limits Between Parts 413 and 433 and the Proposed Limits
for Part 438
Regulation
Subcategories
Standards
Pollutant
TSSd
Oil and greased
TOC
Total organics
parameter
Total metals
Aluminum
Cadmium
Chromium
Copper
Total cyanide
Amenable cyanide
Lead
Manganese
Molybdenum
Nickel
Silver
Sulfide, total
Tin
Zinc
Unit
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Electroplating
40CFRPart413a
>10,000
gpdb
<10,000
gpdb
PSES Only
5.0
0.5
2.5
1.8
0.23
0.3
1.8
0.5e
1.8
0.5
1.5
0.3
Metal Finishing
40 CFR Part 433
Metal Finishing
NSPS/
PSNS
/
/
0.07
1.71
2.07
0.65
0.32
0.43
2.38
0.24
1.48
BAT/
PSES
0.26
1.71
2.07
0.65
0.32
0.43
2.38
0.24
1.48
Metal Products and Machinery
40 CFR Part 438 Proposed Limits
General Metals
NSPS/
PSNS
18
12
50
4.3
0.01
0.07
0.16
0.13
0.07
0.03
0.18
0.49
0.75
0.03
13
0.03
0.06
BAT/
PSESC
18
12
50
4.3
0.09
0.14
0.28
0.13
0.07
0.03
0.09
0.49
0.31
0.09
13
0.67
0.22
Metal Finishing
Job Shops
NSPS/
PSNS
18
12
59
4.3
0.01
0.07
0.16
0.13
0.07
0.03
0.18
0.49
0.75
0.03
13
0.03
0.06
BAT/
PSES
31
26
59
4.3
/
0.09
0.55
0.57
0.13
0.07
0.09
0.10
0.49
0.64
0.06
13
1.4
0.17
Non-Cr
Anodizing
NSPS
Only
22
12
4.0
/
0.09
0.31
/
/
0.22
BAT
Only
31
26
4.0
0.09
0.31
0.22
Printed Wiring
Board
NSPS/
PSNS
18
12
67
4.3
0.07
0.01
0.13
0.07
0.03
0.18
0.75
13
0.07
0.06
BAT/
PSES
31
26
67
4.3
/
0.14
0.28
0.13
0.07
0.03
0.64
0.14
/
13
0.14
0.22
Sources: (U.S. EPA, 1979; U.S. EPA, 1983; U.S. EPA, 2000).
Gray highlighting indicates that no limits were set for the pollutant.
a See 40 CFR Part 413 for alternative mass-based limits. Facilities could comply with either concentration-based or mass
b EPA established discharge limits based on a wastewater production threshold of 10,000 gallons per day. Similar limits
413, except where noted in footnote e.
0 Part 438 proposed a minimal flow rate of 1 million gallons per year to trigger compliance with PSES.
d Part 438 did not propose TSS and oil and grease limits for PSES or PSNS.
e The silver pretreatment standard applies only to Subpart B, precious metals plating.
-based limits.
were set for all six subparts of Part
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Section 5—Continued Review of Select Industrial Categories
5.1.2 Profile of Metal Finishing Operations In the U.S.
As part of the 2014 Annual Review, EPA updated and evaluated the current industry
profile for the Metal Finishing Category. This section identifies the number of facilities currently
regulated under the category (40 CFR Part 433), the types of metal finishing operations and
discharge practices that are in use, and the types of wastewater treatment technologies that are
available or are being evaluated for treating metal finishing wastewater.
5.1.2.1 Number of Facilities
At promulgation of the 1983 Metal Finishing ELGs, the Metal Finishing and
Electroplating Categories included a total of 13,470 facilities, consisting of 10,000 captive
facilities and 3,470 job shops and IPCB manufacturers (U.S. EPA, 1984). The existing captive
facilities ultimately fell into the Metal Finishing Category (after the final compliance date) and
the 3,470 job shops and IPCB manufacturers remained in the Electroplating Category.
EPA evaluated the metal finishing industry, as part of the MP&M Rulemaking efforts.
EPA estimated that about 12,700 facilities were performing metal finishing operations, classified
into four general subcategories (U.S. EPA, 2000): general metals, metal finishing job shops, non-
chromium anodizing, and printed wiring boards (see Table 5-4). These estimates were primarily
based on responses to industry surveys sent to facilities in 1989 and 1996.
Table 5-4. Estimated Number of Metal Finishing Facilities Identified During the MP&M
Rulemaking Efforts
Applicable Subpart in
Proposed Part 438
General Metals
Metal Finishing Job Shops
Non-Chromium Anodizing
Printed Wiring Boards3
Subpart Description
This subcategory was created as a catch-all for facilities that
discharge metal-bearing wastewater (with or without oil-bearing
wastewater) but do not fall under the other MP&M subcategories. It
may cover more than just facilities in the Metal Finishing Category.
This subcategory included facilities covered under 40 CFR Part 413.
This subcategory includes facilities that perform aluminum
anodizing without using chromic acid or dichromate sealants.
This subcategory covers wastewater discharges from the
manufacture, maintenance, and repair of printed wiring boards (i.e.,
circuit boards), excluding IPCB manufacturers that are job shops.
Total Number of Facilities
Number of
Facilities
10,484
1,491
93
609
12,677
Source: (U.S. EPA, 2000)
a Also known as IPCB manufacturers in Parts 413 and 433.
The scope of facilities included in the Metal Finishing Category is based on process
operations rather than industry sectors; therefore, facilities to which the Metal Finishing ELGs
may apply can be classified under various metal processing and metal forming industry
classifications. The Guidance Manual for Electroplating and Metal Finishing Pretreatment
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Section 5—Continued Review of Select Industrial Categories
Standards identified the following two-digit Standard Industrial Classification (SIC) codes under
which regulated facilities generally fall (U.S. EPA, 1984):13
• 34: Fabricated Metal Products, Except Machinery and Transportation;
• 35: Machinery, Except Electrical;
• 36: Electrical and Electronic Machinery, Equipment and Supplies;
• 37: Transportation Equipment;
• 38: Measuring, Analyzing and Controlling Instruments: Photograph; Optical
Goods; Watches and Clocks; and
• 39: Miscellaneous Manufacturing Industries.
In the conversion of the SIC system to the North American Industry Classification
System (NAICS) in the late 1990s, EPA reviewed these SIC codes and determined that they
corresponded to 200 NAICS codes under which facilities for the Metal Finishing Category could
be identified. See EPA's Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories, known as the 2009
Screening-Level Analysis or SLA Report, for additional details (U.S. EPA, 2009).
As part of the 2014 Annual Review, EPA searched for more recent data to determine the
number of facilities that fall into the Metal Finishing Category. The 2007 Economic Census
provides a general industry description for each NAICS code under which these facilities may
fall; however, it does not detail facility-specific process operations or wastewater discharge
practices, which is the basis for determining whether the Metal Finishing ELGs would apply to
specific facilities. In the 2011 Annual Review, EPA identified 166,356 facilities included in the
2007 Economic Census for the 200 NAICS codes. However, this number includes establishments
that are distributors or sales facilities, not just manufacturers (U.S. EPA, 2012). It may also
include facilities that do not conduct the six core operations and would not be regulated under the
Metal Finishing ELGs. In previous annual reviews, EPA has identified the number of facilities
submitting discharge monitoring reports (DMRs) and reporting to EPA's TRI. However, EPA
determined that these data sources include only a fraction of the facilities that would fall under
the applicability of the Metal Finishing Category due to the limitations of the data sets. For
example, small establishments (less than 10 employees) are not required to report to TRI, and
DMR data are limited concerning indirect discharges from industrial facilities to POTWs. See
the 2009 SLA Report (U.S. EPA, 2009) for more details on the limitations of these data sets.
Therefore, these data sources do not provide a complete picture of the metal finishing industry.
The scope of facilities reporting to DMR and TRI is further discussed in Section 5.1.2.3.
Some EPA regions have maintained lists of industrial users subject to 40 CFR Part 433
that discharge metal finishing wastewater to POTWs; however, a national inventory of metal
finishing facilities does not exist. For the 2014 Annual Review, EPA was not able to determine
how the industry is currently distributed between job shops, IPCB manufacturers, and captive
13 Although facilities performing metal finishing operations generally fall under these SIC codes, not all facilities
under the codes may be subject to the Metal Finishing ELGs. These facilities may not perform the six electroplating
operations that would require them to comply with the Metal Finishing ELGs. Additionally, these facilities may be
subject to other metal ELGs that take precedence over the Metal Finishing ELGs.
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Section 5—Continued Review of Select Industrial Categories
integrated and non-integrated facilities based on available information. This is primarily because
the applicability of the ELGs are based on operations not industry sectors; therefore, it is difficult
to identify how many of the estimated facilities would be covered by the rule and how the
distribution of facilities may have changed over time. EPA did not conduct a survey as part of
the 2014 Annual Review to obtain updated industry profile information.
Based on a recent 2008 National Center for Manufacturing Sciences review of the surface
finishing industry (including metal finishing), the industry has trended toward an extremely
fragmented market since 1983, with market competition dispersed among many companies. With
expanding global markets, U.S. firms have more recently attempted to concentrate the industry
(i.e., incorporate the smaller job shops into larger companies) to achieve economies of scale,
expand niche markets, and provide a larger range of finishing services in a global market. Many
firms have also shifted surfacing operations to non-U.S. locations such as Asia, India, Mexico,
Canada, and Europe to further reduce costs (Chalmer, 2008).
5.1.2.2 Metal Finishing Operations
Metal finishing is the process of changing the surface of an object by creating a thin layer
of metal or metal precipitate on the surface to impart the desired surface characteristics to the
final product, such as corrosion resistance, wear resistance, and hardness. The operations
performed and the sequence of operations at a metal finishing facility can vary and depend on a
number of factors (e.g., raw materials used, industry sector, product specifications) and may
result in significant wastewater generation (U.S. EPA, 2000).
The Metal Finishing ELGs cover wastewater discharges from six primary metal finishing
operations and where these operations apply; the ELGs also cover wastewater discharges from
40 supplemental metal finishing operations (as listed in Table 5-2, and further described in
Appendix C). Metal finishing operations usually begin with materials in the form of raw stock
(rods, bars, sheets, castings, forgings, etc.) and can progress to the most sophisticated surface
finishing operations. Because of the differences in facility size and processes, production
facilities are custom-tailored to the specific needs of each individual plant. Figure 5-1 illustrates
the variation in the number of unit operations that can be performed in facilities within the metal
finishing industry, depending upon the complexity of the product. The possible variations of unit
operations within the metal finishing industry are extensive and could require the use of nearly
all unit operations, while a simple product might require only a single operation (U.S. EPA,
1983).
Many different raw materials are used by facilities in the Metal Finishing Category.
During the development of the 1983 Metal Finishing ELGs, the basis materials were almost
exclusively metals which range from common copper and steel to extremely expensive high
grade alloys and precious metals, but may also include glass, plastic, and other non-conductive
materials. The materials used in metal finishing unit operations can contain acids, bases, cyanide,
metals, complexing agents, organic additives, oils and detergents. All of the basis materials and
finishing raw materials can potentially enter wastewater streams during the production sequence.
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Section 5—Continued Review of Select Industrial Categories
COMPLEX PRODUCT
' It !
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Section 5—Continued Review of Select Industrial Categories
eliminate cadmium in wastewater generated during this process (Ogundiran,
2011). Metal Finishing ELGs contain limitations for cadmium, zinc, and nickel,
but do not contain limitations for aluminum.
• Molybdate-based self-healing coatings, to replace self-healing hexavalent
chromium coatings on aluminum in the defense and aerospace industry. The
coating formulation performs comparably to hexavalent chromium coatings and
can be applied to all aluminum products to provide a corrosion protective surface
that will heal itself when damaged (Wolterbeek, 2012). Use of this alternative
coating eliminates hexavalent chromium in wastewater generated during this
process.
• Graphene nanocomposite coatings, to replace hexavalent chromium for hard
chromium plating applications. Use of this process technology eliminates the use
and subsequent handling of hexavalent chromium in spent plating baths and
rinsewater (Dennis, 2014).
• High-velocity oxygen-fueled thermal spray application, to replace hard chromium
electroplating. This process technology provides a dry coating application
process, which eliminates the need for spent chromium plating baths and reduces
the amount of wastewater generated. Use of this process may generate additional
waste streams, including overspray powder and post-treatment grinding coolant
wastes (Legg, n.d.).
These emerging processes have not yet been widely applied for many metal finishing
operations, and Chalmer anticipates that many operations will continue to use traditional inputs
through 2020 (Chalmer, 2008).
5.1.2.3 Discharge Practices
Metal finishing wastewater comprises primarily rinsewater from rinsing and drying steps
during the metal finishing process. In the Metal Finishing Rulemaking development, EPA
identified 10,561 out of 13,470 facilities (or 78 percent) that indirectly discharge to surface water
via POTWs. These facilities were evenly distributed between job shops, non-integrated captive
facilities, and integrated captive facilities. The remaining 2,909 facilities (or 22 percent) directly
discharged to surface water, with captive facilities (both integrated and non-integrated)
predominantly performing this practice (U.S. EPA, 1983). The 1983 rule did not capture the
number of facilities in the industry that reused wastewater.
During the MP&M Rulemaking development, EPA looked at a broad range of industries,
including the metal finishing industry, and estimated that 92 percent of the facilities to which the
rule would apply were indirect dischargers and 7 percent were direct dischargers. A small
percentage of facilities performed both direct and indirect discharge practices (U.S. EPA, 2000).
As with the Metal Finishing ELGs, EPA did not evaluate the number of facilities reusing
wastewater.
Using the DMR Pollutant Loading Tool, EPA reviewed the number of facilities with
NPDES permits that allow them to directly discharge to surface waters as well as the number of
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Section 5—Continued Review of Select Industrial Categories
facilities reporting direct and indirect discharges to EPA's TRI program, which may provide a
relative indication of current discharge practices. Table 5-5 provides a summary of the facilities
reporting to DMR and TRI from 2010 to 2012. The DMR data represent the universe of direct
dischargers reporting under the 200 NAICS codes that generally cover facilities in the Metal
Finishing Category. Compared to the approximate 12,700 facilities in the Metal Finishing
Category (see Section 5.1.2.1), fewer than 6 percent of the facilities had permits to directly
discharge in 2012. Additionally, nearly 90 percent of the direct dischargers are classified as
minor dischargers.14 The majority of facilities reporting to TRI are indirect dischargers, which is
consistent with the historic profiles of the Metal Finishing industry. However, the number of
facilities and estimated discharges associated with both indirect and direct discharging facilities
reporting to TRI provide an incomplete representation of the industry. TRI data are limited
because reporting is required for a select number of facilities depending on the industry sector,
number of employees, and activity thresholds (see the 2009 SLA Report (U.S. EPA, 2009) for
additional details on limitations of the data sets).
Table 5-5. Number of Metal Finishing Facilities by Discharge Practice
Year
2010
2011
2012
DMRa
Minor
Dischargers
807
714
639
Major
Dischargers
79
76
72
Total
886
790
711
TRI
Indirect
Discharge
Only
1,290
1,241
1,218
Direct
Discharge
Only
276
279
267
Both Indirect and
Direct Discharge
268
270
247
Total
1,834
1,790
1,732
Source: DMR Pollutant Loading Tool.
a Facilities reporting to DMR are direct dischargers only.
Because facilities reusing wastewater are not required to report metal finishing operations
and wastewater handling practices under DMR or TRI, EPA could not determine the number of
facilities engaged in and the currently employed practices for wastewater recovery and reuse.
However, according to regional EPA pretreatment coordinators, efforts to minimize and
eliminate wastewater discharges are becoming more common for the industry.
5.1.2.4 Metal Finishing Wastewater Characteristics
Water is used for rinsing workpieces, washing away spills, air scrubbing, process fluid
replenishment, cooling and lubrication, washing of equipment and workpieces, quenching, spray
booths and assembly and testing during the metal finishing process. Plating and cleaning
operations are typically the biggest water users. While the majority of metal finishing operations
use water, some of them are completely dry. Table 5-6 provides a summary of the anticipated
water usage by unit operation, as evaluated during the development of the 1983 Metal Finishing
14 To provide an initial framework for permitting priorities, EPA developed a major/minor classification system for
industrial and municipal wastewater discharges. Major discharges usually have the capability to impact receiving
waters if not controlled and, therefore, have received more regulatory attention than minor discharges. Major/minor
classifications are determined by permitting authorities and vary state to state. See Section 3.2.4 from EPA's 2013
Annual Review Report for more information (U.S. EPA, 2014b).
5-14
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Section 5—Continued Review of Select Industrial Categories
ELGs. The type of rinsing can have a marked effect on water use as can the flow rates within the
particular rinse types. Product quality requirements often dictate the amount of rinsing needed
for specific parts. Parts requiring extensive surface preparation will generally necessitate the use
of larger amounts of water (U.S. EPA, 1983). This wastewater may require further treatment
before discharge and can be directly discharged to surface water, indirectly discharged through
POTWs, or recycled/reused.
Table 5-6. Water Use by Unit Operation
Unit Operation
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Electroplating
Electroless Plating
Anodizing
Conversion Coating
Etching (Chemical Milling)
Cleaning
Machining
Grinding
Polishing
Tumbling (Barrel Finishing)
Burnishing
Impact Deformation
Pressure Deformation
Shearing
Heat Treating
Thermal Cutting
Welding
Brazing
Soldering
Flame Spraying
Sand Blasting
Other Abrasive Jet Machining
Electric Discharge Machining
Electrochemical Machining
Electron Beam Machining
Laser Beam Machining
Plasma Arc Machining
Ultrasonic Machining
Sintering
Laminating
Hot Dip Coating
Sputtering
Vapor Plating
Thermal Infusion
Salt Bath Descaling
Solvent Degreasing
Paint Stripping
Painting
Electrostatic Painting
Electropainting
Major Water
Use
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Minimal Water
Use
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Zero Discharge
X
X
X
X
X
X
X
X
5-15
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Section 5—Continued Review of Select Industrial Categories
Table 5-6. Water Use by Unit Operation
Unit Operation
41
42
43
44
45
46
Vacuum Metalizing
Assembly
Calibration
Testing
Mechanical Plating
Printed Circuit Board Manufacturing
Major Water
Use
X
X
X
Minimal Water
Use
X
Zero Discharge
X
X
Source: (U.S. EPA, 1983)
Although wastestream characteristics may vary depending on the unit operations used in
the metal finishing process, according to the 1983 Metal Finishing ELGs, wastestreams were
generally characterized by the types of inorganic and organic constituents, as listed in Table 5-7
(U.S. EPA, 1983).
Table 5-7. Waste Characteristics by Unit Operation
Waste Characteristics
Unit Operation
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Electroplating
Electroless Plating
Andodizing
Conversion Coating
Etching (Chemical
Milling)
Cleaning
Machining
Grinding
Polishing
Tumbling
Burnishing
Impact Deformation
Pressure
Deformation
Shearing
Heat Treating
Thermal Cutting
Welding
Brazing
Soldering
Flame Spraying
Sand Blasting
Other Abrasive Jet
Machining
Electric Discharge
Machining
Electrochemical
Machining
Inorganics
Common
Metals
Precious
Metals
Complexed
Metals
Chromium
(Hexavalent)
Organics
Cyanide
Oils
Toxic
Organics
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5-16
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Section 5—Continued Review of Select Industrial Categories
Table 5-7. Waste Characteristics by Unit Operation
Waste Characteristics
Unit Operation
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
Electron Beam
Machining
Laser Beam
Machining
Plasma Arc
Machining
Ultrasonic
Machining
Sintering
Laminating
Hot Dip Coating
Sputtering
Vapor Plating
Thermal Infusion
Salt Bath Descaling
Solvent Degreasing
Paint Stripping
Painting
Electrostatic Painting
Electropainting
Vacuum Metalizing
Assembly
Calibration
Testing
Mechanical Plating
Printed Circuit
Board
Manufacturing
Inorganics
Common
Metals
Precious
Metals
Complexed
Metals
Chromium
(Hexavalent)
Organics
Cyanide
Oils
Toxic
Organics
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Source: (U.S. EPA, 1983)
During the 2012 Annual Review, EPA's review of the TNSSS, combined with available
TRI indirect discharge data, identified the Metal Finishing Category (40 CFR Part 433) as
potentially discharging high concentrations of metals, particularly chromium, nickel, and zinc, to
POTWs. These metals could transfer to sewage sludge and diminish its beneficial use (U.S. EPA,
2014a). For the 2014 Annual Review, EPA reviewed 2011 DMR and TRI facility pollutant
discharge data for the Metal Finishing Category and identified the top pollutants discharged by
the industry in terms of TWPE, as listed in Table 5-8 and Table 5-9, respectively. Table 5-8 and
Table 5-9 also identify whether the pollutants are currently regulated under 40 CFR Part 433.
This analysis confirms discharges of nickel and zinc, which are currently regulated by the Metal
Finishing ELGs. As stated above, however, TRI reporting is only required for select facilities. In
addition, TRI discharges may be estimated, not actually measured. Therefore, the number of
facilities and estimated discharges associated with both indirect- and direct-discharging facilities
reporting to TRI is an incomplete representation of the industry; see the 2009 SLA Report (U.S.
EPA, 2009) for additional details on limitations of TRI.
5-17
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Section 5—Continued Review of Select Industrial Categories
Table 5-8. Metal Finishing Category Top 2011 DMR Pollutants
Reported Pollutant
PCB-12483
Polychlorinated biphenyls (PCBs)3
Chrysene
Silver, total (as Ag)
PCB-12683
Zinc, total (as Zn)
Chlorine, total residual
PCB-12603
Lead, total (as Pb)
Copper, total (as Cu)
Copper, total recoverable
Number of Facilities
Reporting Pollutant
Discharges
2
o
J
8
13
1
113
83
1
41
111
28
Top Pollutant Total
Metal Finishing Category Total
TWPE
44,200
28,200
24,400
10,700
9,310
5,560
3,570
3,220
3,040
2,950
2,870
138,000
152,000
%of
TWPE
29.1
18.5
16.0
7.0
6.1
3.7
2.3
2.1
2.0
1.9
1.9
90.7
100.0
Regulated Pollutant
Under 40 CFR Part
433
No
No
No
Yes
No
Yes
No
No
Yes
No
Yes
NA
NA
Source: DMR Pollutant Loading Tool.
NA: Not applicable.
a "Polychlorinated biphenyls (PCBs)" refers to the grouping of PCB compounds; PCB-1248, PCB-1268, and
PCB-1260 are individual PCB compounds. Facilities may report PCBs as a grouping or as individual
compounds, depending on what is specified in their permits.
Table 5-9. Metal Finishing Category Top 2011 TRI Pollutants
Reported Pollutant
Copper and copper compounds
Lead and lead compounds
Silver and silver compounds
Mercury and mercury compounds
Nitrate compounds
Manganese and manganese
compounds
Zinc and zinc compounds
Nickel and nickel compounds
Number of Facilities
Reporting Pollutant
Discharges
692
734
15
13
208
357
268
599
Top Pollutant Total
Metal Finishing Category Total
TWPE
13,600
11,100
10,800
5,160
2,710
2,070
1,640
1,400
48,500
51,700
%of
TWPE
18.7
15.1
14.9
7.1
3.7
2.8
2.2
1.9
94.3
100
Regulated Pollutant
Under 40 CFR Part
433
Yes (as total copper)
Yes (as total lead)
Yes (as total silver)
No
No
No
Yes (as total zinc)
Yes (as total nickel)
NA
NA
Source: TRILTOutput2011_vl.
NA: Not applicable.
As discussed in Section 5.1.2.2, EPA determined that new chemical alternatives in the
industry could generate wastewater containing pollutants that are not currently regulated under
the Metal Finishing ELGs (40 CFR Part 433). Existing processes have used base metals such as
aluminum, calcium, magnesium, manganese, iron, and tin. Some emerging processes use
titanium, zirconium, vanadium, and nanocomposites that were not considered in the Metal
Finishing ELGs (Dennis, 2014; Dunham, 2013). Additionally, there are new chemical
formulations used in cleaning, surface treatment, and post-treatment operations, including
fluorides, sulfides, borates, phosphates, nitrates, and sulfates. These potential new pollutants of
concern are not currently regulated by the Metal Finishing ELGs and are not currently reported
5-18
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Section 5—Continued Review of Select Industrial Categories
to DMR or TRI; therefore, EPA is uncertain at this point about the extent of their presence in
metal finishing wastewater.
In EPA's discussions with regional EPA pretreatment coordinators, the coordinators did
not identify any issues related to the treatability of metal finishing wastewater at POTWs,
particularly related to chromium, nickel, and zinc. However, the pretreatment coordinators did
note concern about potential new pollutants introduced by more recent chemical alternatives
used in metal finishing. For example, coordinators were concerned about the increasing use of
nanotechnologies in metal finishing processes, which involve nanoscale metal particles that may
not have existing methods of detection, regulation, and treatment. (EPA's review of engineered
nanomaterials in industrial wastewater is discussed in Section 6.1 of this report). In addition,
pretreatment coordinators expressed concern about new pollutants generated as a result of the
use of wet air pollution controls on metal finishing operations to comply with air regulations.
Specifically, chemical additives used in wet air pollution controls may be introduced into facility
wastewater, which is subsequently sent to POTWs or is discharged directly to surface water.
EPA did not further explore the impact of wet air pollution controls during the 2014 Annual
Review.
The regional EPA pretreatment coordinators also mentioned the need for hexavalent
chromium limits for metal finishing wastewaters. In the Metal Finishing ELGs, total chromium
limits are set without any specific limits for the discharge of hexavalent chromium, chromium's
more toxic form. The pretreatment coordinators indicated that smaller metal finishing facilities
generally do not employ chromium reduction operations to reduce hexavalent chromium to its
less toxic form (i.e., trivalent chromium) if the total chromium limits are met before discharge.
Some POTWs are setting more stringent local limits on hexavalent chromium from metal
finishing wastewater. Several pretreatment coordinators suggested that EPA consider developing
limits specific to hexavalent chromium to reduce its potential discharge to POTWs and surface
water.
5.1.2.5 Review of Metal Finishing Wastewater Treatment Technologies
In 1983, EPA set BAT and PSES limits to control discharges of toxic metals, toxic
organics, and cyanide from the Metal Finishing Category. These standards were based on the
best practicable control technology (BPT) for the industry at that time and include physical-
chemical precipitation followed by clarification with additional cyanide oxidation and chromium
reduction pretreatment steps where these pollutants are present in the wastewater stream (U.S.
EPA, 1983). This section further discusses the wastewater treatment technologies that are
prevalent in the industry, as well as advanced treatment technologies and zero-discharge or reuse
practices that are emerging within the industry for the treatment and/or recycling of metal
finishing wastewater.
5.1.2.5.1 Commonly Used Technologies for the Treatment of Metal Finishing Wastewater
EPA's review indicates that physical-chemical precipitation, clarification, chromium
reduction, and cyanide oxidation are prevalent technologies for the treatment of metal finishing
wastewater. The regional EPA pretreatment coordinators have observed that a vast majority of
metal finishing operations that treat metal finishing wastewater for discharge can meet the
5-19
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Section 5—Continued Review of Select Industrial Categories
current Metal Finishing ELGs using these treatment technologies. Industry literature also
confirms the prevalence of these technologies, with minor modifications to improve the solids
separation stage. Facilities may also add a filtration/polishing step or replace the flocculation and
clarification steps with direct microfiltration to improve solids removal (Weber, 2013).
During the development of the MP&M rule in 2003, EPA identified more advanced
technologies for reducing metal discharges from metal finishing operations than those used as
the basis for limitations in the Metal Finishing ELGs. The proposed rule's technology options for
the subcategories encompassing the Metal Finishing Category included chemical precipitation
with clarification, microfiltration, and ion exchange (to target removal of colloidal particles,
heavy metal particulates, and their hydroxides).
EPA further reviewed the technologies that are prevalent for the treatment of metal
finishing wastewater and identified limitations associated with their current application.
Chromium reduction means reducing the oxidation state of hexavalent chromium to
trivalent chromium, which is less toxic and more amenable to chemical precipitation and
clarification. Metal finishing operations using hexavalent chromium generally include a
chromium reduction pretreatment step prior to chemical precipitation (U.S. EPA, 2000) . Recent
efforts to replace hexavalent chromium with trivalent chromium in metal finishing operations
(such as those described in Section 5.1.2.2) would eliminate this pretreatment step; however,
according to industry literature, trivalent chromium may cause its own problems in wastewater
treatment. Operations using trivalent chromium may generate chromium complexes in the
wastewater that would require a separate pretreatment step to breakdown these complexes into
treatable constituents prior to chemical precipitation (Weber, 2013).
Cyanide oxidation most commonly uses an alkaline chlorination process that treats
simple cyanides in the process wastewater prior to the chemical precipitation step. Complexed
cyanides must be treated separately using a high-pressure, high-temperature thermal process.
Industry sources indicate that complexed cyanides are generally the cause of pretreatment
violations (Weber, 2013).
Metal finishing wastewater may contain complexing and chelating agents, which are
important constituents of some plating operations, especially electroless plating, immersion
plating, and printed circuit board manufacturing. These agents may also produce metal
complexes that present a problem for effective metal removal, since they hinder the formation of
precipitates in the chemical precipitation system (U.S. EPA, 1979; U.S. EPA, 1984). During the
development of the Metal Finishing ELGs, EPA recommended segregated treatment of the
complexed metal wastes. Among the proposed technologies were high-pH precipitation to break
down the complexes and precipitate the metal ions, sulfide precipitation, and ferrous sulfate
precipitation. In the MP&M proposed rule, EPA identified pretreatment steps to break down the
chelates using reducing agents such as sodium borohydride, hydrazine, dithiocarbamate
(measured analytically as ziram), or sodium hydrosulfite; using high-pH precipitation with
calcium hydroxide or ferrous sulfate addition; or filtering the chelated metals out of solution
prior to chemical precipitation (U.S. EPA, 2000). EPA is not certain which current technologies
are most commonly used to treat complexed metal waste from metal finishing operations.
5-20
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Section 5—Continued Review of Select Industrial Categories
Regional EPA pretreatment coordinators indicate that some smaller facilities can meet
pretreatment standards without implementing chemical precipitation and clarification treatment
of metal finishing wastewater. These smaller facilities may generate small volumes of metal
finishing wastewater for which they can store, monitor, and control the frequency of discharge.
The smaller facilities may also discharge dilute rinse water, but use other management practices
for plating baths, such as wastewater disposal at centralized waste treatment facilities or in onsite
evaporations tanks or they may use advanced closed-loop/reuse practices. The practice of
diluting rinse water as a partial or total substitute for adequate treatment to achieve compliance
with discharge limits is in violation of the National Pretreatment Standards: Categorical
Standards (40 CFR Part 403.6(d)). See below for more discussion on advanced closed-loop/reuse
practices.
5.1.2.5.2 Emerging Technologies for the Treatment of Metal Finishing Wastewater
In most cases, the use of chemical precipitation and clarification with optional
pretreatment of chromium and cyanide has been sufficient to meet the Metal Finishing ELGs.
However, more advanced treatment technologies are emerging. Based on more recent
observations from the regional EPA pretreatment coordinators and industry sources, emerging
technologies are being used to some extent, but are not yet widespread within the industry.
To identify emerging technologies that are being evaluated and/or implemented, EPA
reviewed recent literature gathered to develop and populate the Industrial Wastewater Treatment
Technology (IWTT) database (for more information on the IWTT database, see Section 6.2 of
this report). A query of the IWTT database produced nine articles with performance data on the
treatment of metal finishing wastewater. A majority of these articles document the performance
of pilot-scale systems that facilities are implementing to evaluate treatment performance. Table
5-10 summarizes these systems' treatment effectiveness.
As the table shows, a variety of wastewater treatment technologies (or combinations of
technologies) have been tested to treat metal finishing wastewater, including electrocoagulation
and membrane bioreactors. These systems target a range of regulated pollutants such as
cadmium, chromium, nickel, and zinc, as well as non-regulated pollutants such as iron,
manganese, and tin. The majority of the treatment performance data for these technologies target
metal removals and show a percent removal of greater than 90 percent, reaching effluent
concentrations sometimes orders of magnitude below current effluent limitations.
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Section 5—Continued Review of Select Industrial Categories
Table 5-10. Summary of Wastewater Treatment Technologies for End-of-Pipe Discharge of Metal Finishing Wastewater
Wastewater
Treatment
(Order of Unit
Processes)
Adsorptive media
Aerobic fixed film
biological treatment,
chemical
precipitation,
powdered activated
carbon
Biological activated
filters3
Electrocoagulation
Electrocoagulation
followed by
membrane filtration
Flow equalization,
anaerobic fixed film
biological treatment,
aerobic fixed film
biological treatment
Liquid extraction3
Type of Wastewater
Treated
Electroplating process
wastewater
Electroplating process
wastewater
Chromium plating
process wastewater
Aircraft maintenance
operations wastewater
subject to 40 CFR Part
43 3 and 40 CFR Part
413 effluent limits
Aircraft maintenance
operations wastewater
subject to 40 CFR Part
43 3 and 40 CFR Part
413 effluent limits
Metal working process
wastewater
Metal plating
wastewater
Treatment
Scale (Pilot-
or Full-
Scale)
Pilot
Pilot
Pilot
Pilot
Pilot
Pilot
Pilot
Metals Treated
Chromium,
hexavalent
Chromium,
hexavalent
Chromium, total
Iron
Manganese
Tin
Zinc
Chromium,
hexavalent
Cadmium
Chromium
Nickel
Cadmium
Chromium
Nickel
Not provided
Chromium,
hexavalent
Chromium, total
Effluent
Concentration
(mg/L)
Not provided
0.05
0.7
0.2
0.15
0.1
0.02
30,000
0.012-0.126
0.031-7.204
0.022-1.317
0.004
0.018
0.07
Not provided
0.06
0.72
Percent
Removal
79
>99.8
98.6
67.21
53.13
>66.67
81.82
45.75
75-99.9
84-99.91
65.1-
99.77
98.58
99.94
99.48
Not
provided
99.50
96.57
Metal Finishing Monthly
Average ELG Limit
(40 CFR Part 433)
NSPS/PSNS
NA
NA
1.71
NA
NA
NA
1.48
NA
0.07
1.71
2.38
0.07
1.71
2.38
NA
NA
1.71
BAT/PSES
NA
NA
1.71
NA
NA
NA
1.48
NA
0.26
1.71
2.38
0.26
1.71
2.38
NA
NA
1.71
Article Source
(Lv, 2013)
(Ahmad, 2010)
(Colica, 2012)
(Firouzi, 2009a;
Firouzi, 2009b;
Firouzi, 2010)
(Firouzi, 2009b)
(Schuch, 2000)
(Usinowicz,
2005)
5-22
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Section 5—Continued Review of Select Industrial Categories
Table 5-10. Summary of Wastewater Treatment Technologies for End-of-Pipe Discharge of Metal Finishing Wastewater
Wastewater
Treatment
(Order of Unit
Processes)
Membrane bioreactor
Membrane
bioreactor, aerobic
digestion13
Type of Wastewater
Treated
Barge cleaning
wastewater
Metal fabrication
process wastewater
from the automotive
industry
Treatment
Scale (Pilot-
or Full-
Scale)
Pilot
Pilot and
Full
Metals Treated
Copper
Lead
Not provided
Effluent
Concentration
(mg/L)
0.0105
0.001
Not provided
Percent
Removal
70.60
77.30
Not
provided
Metal Finishing Monthly
Average ELG Limit
(40 CFR Part 433)
NSPS/PSNS
2.07
0.43
NA
BAT/PSES
2.07
0.43
NA
Article Source
(Buckles, 2003)
(Sutton, 2001)
NA: Not applicable.
a The article discusses wastewater treatment technology as applicable for end-of-pipe discharge and zero discharge.
b The article presents treatment information for pollutants such as chemical oxygen demand and oil and grease, but provides no treatment information for
metals.
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Section 5—Continued Review of Select Industrial Categories
5.1.2.5.3 Technologies to Achieve a Zero-Discharge, Closed-Loop Process
A closed-loop process is a system that treats process wastewater to an acceptable quality
to be returned back to the process for reuse (Candiloro, 2012). Unwanted contaminants removed
from the wastewater are disposed of as solid waste; no wastewater is discharged. During the
development of the MP&M rule EPA identified technology options that included wastewater
management alternatives such as closed-loop and reuse practices using reverse osmosis and
evaporation (U.S. EPA, 2000). Recent industry literature also identified technologies to purify
process wastewater for recycling, which minimizes overall wastewater generation and discharge
(McLay, 2013). Table 5-11 summarizes these waste minimization technologies and practices
available to reduce the volume of wastewater discharged from metal finishing operations and to
recover other process waste streams, such as plating baths, to be reused in the process.
Table 5-11. Summary of Waste Minimization Technologies for Reuse
Technology
Technology Description
Types of Wastewater Treated
Evaporation
An energy-intensive process of concentrating and
returning a stream back to process by converting
some of the liquid to vapor. The only process that can
treat plating rinse waters back to or beyond original
strength.
Plating baths, rinse waters,
pretreated wastewater (brine for
disposal)
Reverse osmosis
Separation of solutes from solvent using a high-
pressure differential across a membrane. Limited
application due to the high pressure requirement to
overcome the significant osmotic pressure from the
feed solution. Limited application to nickel plating
rinsewater because the water returned is at too low a
concentration to be completely recycled.
High total dissolved solids
wastewater, nickel plating
rinsewater (limited)
Electrodialysis
Configuration of stacked ion exchange membranes
with two electrodes at both ends of the stacks to
separate desirable compounds across a concentration
(voltage) gradient with minimal energy consumption.
Requires careful maintenance and periodic membrane
regeneration.
Gold, silver, nickel, tin-
containing solutions; nickel
electroplating bath (slow
circulation process)
Membrane electrolysis
Single-membrane process driven by electrolytic
potential across an ion exchange membrane or
diaphragm to remove metallic impurities.
Plating, anodizing, etching,
stripping, and other metal-
finishing process solutions,
chromium plating baths, chrome
conversion coating solutions
Diffusion dialysis
Multi-membrane technology to recover clean acid
from spent acid solutions using a concentration
gradient between deionized water and the process
acid. Also generates an acidic waste stream that
requires treatment.
Spent acid solutions,
hydrofluoric/nitric acids,
sulfuric/nitric and
sulfuric/hydrochloric acids,
battery acids
Ion exchange
Separation process for removing low concentrations
of ionic compounds from dilute wastewater.
Noble metal recovery (including
gold), chromate baths, rinse
water
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Section 5—Continued Review of Select Industrial Categories
Table 5-11. Summary of Waste Minimization Technologies for Reuse
Technology
Electrowinning
Electrodeposition/
electrocoagulation
Electroflotation
Technology Description
Consists of three main components to recover metals
from electroplating rinse water: an electrolytic cell, a
rectifier, and a pump. The electrolytic cell is a tank in
which cathodes and anodes are typically arranged in
alternating order, attached to their respective bus bars,
which supply the electrical potential to the unit.
Metals recovery though cathodic deposition. Types of
reactors include tank cells, plate and frame cells,
rotating cells, fluidized beds, packed bed cells, and
porous carbon packing cells.
A process that floats pollutants to the surface of a
water body by tiny bubbles of hydrogen and oxygen
gases generated from water electrolysis.
Types of Wastewater Treated
Electroplating rinse water
containing gold, silver, copper,
cadmium, and zinc
Manganese-phosphate coating
wastewater; cadmium-, copper-,
zinc, and hexavalent chromium-
containing water
Heavy-metal-containing
wastewaters, gold and silver
recovered from cyanide solutions
Sources: (Adhoum, 2004;
EPA, 2000).
Bloch, 2000; Chen, 2004; Firouzi, 2009a; Ince, 2013; Mahvi, 2007; McLay, 2013; U.S.
In addition, EPA identified six articles in a query of the IWTT database that presented
performance data for the treatment of metal finishing wastewater for reuse. Table 5-12
summarizes the treatment effectiveness of these systems. A majority of the articles document the
performance of pilot-scale systems that facilities are implementing to evaluate treatment
performance and the quality of reuse water. As the results show, a variety of technologies (or
combinations of technologies) have been tested to treat metal finishing wastewater for reuse,
targeting a range of regulated pollutants such as chromium and nickel, as well as non-regulated
pollutants such as calcium, magnesium, and sodium. The treatment technologies discussed in
Table 5-12 do not always result in zero discharge: in some cases, they produce a concentrated
waste stream that is handled as a hazardous waste.
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Section 5—Continued Review of Select Industrial Categories
Table 5-12. Summary of Wastewater Treatment Technologies for Reuse of Metal Finishing Wastewater
Wastewater Treatment
(Order of Unit
Processes)
Biological activated
filters3
Clarification, granular-
media filtration,
membrane filtration, bag
and cartridge filtration,
ultraviolet, reverse
osmosis
Flow equalization, ion
exchange, chemical
precipitation, membrane
filtration, reverse
osmosis, evaporation
Granular-media filtration,
bag and cartridge
filtration, ultraviolet,
granular activated carbon
unit, membrane filtration,
nanofiltration, ion
exchange
Liquid extraction3
Membrane filtration
Type of Wastewater
Treated
Chromium plating
process wastewater
Electroless nickel-
plating process
wastewater
Automotive
components
manufacturing
process wastewater
Final rinse process
wastewater from
electroless plating
operations
Metal plating
wastewater
Solvent cleaning
rinse water from
nickel-plating
operations
Treatment
Scale
(Pilot- or
Full-Scale)
Pilot
Pilot
Full
Pilot
Pilot
Pilot
Metals Treated
Chromium,
hexavalent
Calcium
Nickel
Sodium
Calcium
Magnesium
Sodium, total
(as Na)
Not provided
Chromium,
hexavalent
Chromium, total
Not provided
Effluent
Concentration
(mg/L)
30,000
0.02
0.003
1.45
<1
0.5
<60
Not provided
0.06
0.72
Not provided
Percent
Removal
45.75
99.90
>99.90
98.70
>99.67
>99.8
>95.00
Not
provided
99.50
96.57
Not
provided
Metal Finishing Monthly
Average ELG Limit
(40 CFR Part 433)
NSPS/PSNS
NA
NA
2.38
NA
NA
NA
NA
NA
NA
1.71
NA
BAT/PSES
NA
NA
2.38
NA
NA
NA
NA
NA
NA
1.71
NA
Article Source
(Colica, 2012)
(Qin, 2004)
(Chan, 2011)
(Wong, 2002)
(Usinowicz,
2005)
(Qin, 2006)
NA: Not applicable.
3 The article discusses wastewater treatment technology as applicable for end-of-pipe discharge and zero discharge.
b The article presents treatment information for pollutants such as chemical oxygen demand and oil and grease, but provides no treatment information for
metals.
5-26
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Section 5—Continued Review of Select Industrial Categories
EPA regional pretreatment coordinators noted they have observed that smaller facilities,
with smaller volumes of wastewater, can achieve zero discharge by implementing cost-effective
alternatives. These alternatives include technologies such as evaporation tanks, which combined
with storage and reuse, eliminate wastewater discharges. A 2008 study observed an increasing
trend towards wastewater minimization practices during metal finishing operations at both small
and large facilities throughout the industry (Chalmer, 2008). Larger facilities may use some of
these practices, but because of the larger volumes of water used, they may not completely
eliminate discharges. The extent of the use of the technologies identified in Table 5-11 is
unknown.
5.1.3 Potential ELG Applicability Issues and Other Considerations
As part of the 2014 Annual Review, EPA discussed with regional EPA pretreatment
coordinators any noticeable changes to the metal finishing industry over time and whether those
changes may be impacting the POTW treatability of metal finishing wastewater. The regional
pretreatment coordinators indicated that they have not encountered recent issues with POTW
treatability of metal finishing wastewater; this includes issues involving nickel, chromium, and
zinc, which were identified as pollutants of concern in the 2012 Annual Review (U.S. EPA,
2014a).
However, the regional pretreatment coordinators provided observations on issues arising
from the implementation of the Metal Finishing ELGs. They noted some key topic areas for
EPA's consideration:
• Misapplication of the limits in permit applications. Unlike other metal-related
industries (e.g., aluminum forming, iron and steel), the Metal Finishing ELGs are
concentration-based and are easier to apply in wastewater permits than the
production-based standards. As a result, the regional pretreatment coordinators
have observed the application of the Metal Finishing ELGs for wastewater
generated from operations that should be regulated by other ELGs. Additionally,
the pretreatment coordinators noted that POTWs may still be implementing 40
CFR Part 413 pretreatment standards for metal finishing wastewater. Most metal
finishing facilities should be covered by 40 CFR Part 433 pretreatment standards,
not 40 CFR Part 413 standards. The scope of facilities still regulated under 40
CFR Part 413 should be limited to job shops and IPCB manufacturers that were
considered existing at the time of the 1983 promulgation of the Metal Finishing
ELGs.
• Applicability of the 46 metal finishing unit operations. The regional pretreatment
coordinators also noted that there is uncertainty about the applicability of the
existing ELGs and how to determine which of the 46 metal finishing operations
listed in the 1983 Metal Finishing ELGs would apply to current industry
practices, including:
• Whether using acid for cleaning and preparing metal surfaces prior to metal
finishing would constitute "acid cleaning" or "acid etching";
5-27
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Section 5—Continued Review of Select Industrial Categories
• When the use of phosphoric acid or chromic acid constitutes "cleaning" and when
it is "conversion coating";
• Whether the use of brighteners during cleaning would be considered "acid
cleaning" or "bright dipping," which is identified in the Metal Finishing ELGs as
a form of etching; and
• How the rule applies to new processes and process chemistries.
• New source criteria development. The Metal Finishing ELGs identify new
sources as new sites that are discharging wastewater. Pretreatment coordinators
suggested that additional guidance is needed to specify the criteria for identifying
new sources. Existing facilities that develop new or revise existing processes
question whether certain process changes classify them as new sources. Similarly,
ACWA commented that a facility covered under the PSES for the Electroplating
Category (40 CFR Part 413) may upgrade its plant incrementally, which makes it
difficult to determine when the plant is a new source and subject to the Metal
Finishing ELGs (40 CFR Part 433) (ACWA, 2013). Additionally, metal finishing
operations have expanded to product markets that did not exist during the
development of the ELGs. Pretreatment coordinators noted products such as solar
panels and cell phone screens as newer metal finishing applications that require
interpretation as to their applicability under the Metal Finishing ELGs.
5.1.4 Summary of Findings from EPA's Continued Review of the Metal Finishing Category
Based on EPA's continued preliminary category review, the Metal Finishing Category
has not experienced significant growth in the last 30 years. However, an industry source suggests
that the industry is consolidating into larger companies that tend to compete better with the
expanding global market; this consolidation may have slightly reduced the size of the U.S. metal
finishing industry (Chalmer, 2008).
Discussions with regional EPA pretreatment coordinators and a review of literature on
existing process technologies and advances in wastewater treatment show that a portion of the
industry is employing new technologies. These new technologies include improved technologies
for reusing baths and other metal finishing chemicals that reduce the quantities of pollutants
discharged. The new technologies also include improved wastewater treatment technologies that
reduce the concentration of pollutants in treated metal finishing wastewater. Implementation of
these new technologies results in effluent concentrations that are well below the limits
established in the Metal Finishing ELGs. However, the regional pretreatment coordinators
reported that despite the emergence of these new technologies, a majority of the industry seems
to be continuing to meet the ELGs using common treatment technologies (described in Section
5.1.2.5). Further, they have not observed any notable issues with pass-through or interference at
POTWs receiving metal finishing wastewater, which would indicate that the industry can
achieve pretreatment standards for the nine pollutants currently regulated in the Metal Finishing
ELGs even with the change in surface finishing chemistries over the past three decades.
5-28
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Section 5—Continued Review of Select Industrial Categories
At the time the existing ELGs were developed, metal finishers used base metals such as
aluminum, magnesium, iron, and tin. In addition to those metals, they are now using metals such
as titanium, zirconium, vanadium, and also nanocomposites. Metal finishers are also employing
alternative metal finishing processes and chemicals. These changes may introduce additional
pollutants into metal finishing wastewater that EPA did not consider in the development of the
1983 Metal Finishing ELGs.
require
EPA's continued review of the Metal Finishing Category identified several topics that
further review:
Potential new pollutants of concern not currently regulated, including transition
metal coatings and nanoscale particles that are becoming more common in metal
finishing operations.
The characteristics of current metal finishing wastewater discharges, including:
— The need for hexavalent chromium limits in addition to total chromium
limits to explicitly limit the discharge of the more toxic form of
chromium.
— Treatment technologies available for metal finishing wastewater and the
more stringent discharge concentrations these technologies can achieve.
The prevalence of and the potential pollutants of concern associated with
wastewater generated from the use of wet air pollution control devices, which
may contribute additional pollutants to metal finishing wastewater.
The need for clarifying descriptions of metal finishing operations listed in the
ELGs to help permit writers properly apply the Metal Finishing ELGs,
specifically:
— Providing guidance to help distinguish between metal finishing operations,
such as etching and chemical milling, acid cleaning, chemical conversion
coating, and similar cases in which the same acid is used for different
functions.
— Clarifying how the Metal Finishing ELGs apply to current industry
practices (i.e., practices that evolved after the promulgation of the Metal
Finishing ELGs) that may use chemical alternatives (e.g., alternatives to
hexavalent chromium, phosphate-free formulations) and are not
specifically identified in the ELGs.
— Clarifying applicability of the Metal Finishing ELGs to newer
manufacturing operations that use metal finishing, such as solar panel
manufacturing and cell phone manufacturing.
How advanced wastewater treatment technologies are used and the prevalence of
zero discharge practices in the industry.
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Section 5—Continued Review of Select Industrial Categories
5.1.5 References for the Continued Review of the Metal Finishing Category
1. ACWA, 2013. Association of Clean Water Administrators. Public Comment Submitted
by the Association of Clean Water Administrators on the Preliminary 2012 Effluent
Guidelines Program Plan. Re: Docket ID No. EPA-HQ-OW-2010-0824/Preliminary 2012
Effluent Guidelines Program Plan and 2011 Annual Effluent Guidelines Review Report.
(October 7). EPA-HQ-OW-2010-0824-0218-A2.
2. Adhoum, N. L. Monser, N. Belakal, and J-E Belgaied. 2004. Treatment of electroplating
wastewater containing Cu2+, Zn2+ and Cr(vi) by electrocoagulation. Journal of
Hazardous Materials. B112: 207-213. EPA-HQ-OW-2014-0170. DCN 08004.
3. Ahmad, W.A. Z.A. Zakaria, A.R. Khasim, M.A. Alias, and S.M.H.S. Ismail. 2010. Pilot-
scale removal of chromium from industrial wastewater using the chromebac system.
Bioresource Technology. 101 (12): 4371-4378. (June). EPA-HQ-OW-2014-0170. DCN
08005.
4. Bloch, L. 2000. Metal recovery and wastewater reduction using electrowinning. Products
Finishing. (January 1). Available online at: http://www.pfonline.com/articles/metal-
recovery-and-wastewater-reduction-using-electrowinning. EPA-HQ-OW-2014-0170.
DCN 08007.
5. Buckles, J. A. Kuljian, K. Olmstead, and J. Merritt. 2003. Treatment of oily wastes by
membrane biological reactor. Water Environment Federation's 2003 Technical Exibition
and Conference. Los Angeles, CA. (October 11-15). EPA-HQ-OW-2014-0170. DCN
08008.
6. Candiloro, S. 2012. Close loop for zero waste water discharge, Epner Technology Inc.
(May 17). EPA-HQ-OW-2014-0170. DCN 08009.
7. Chalmer, P. 2008. The future of finishing. National Center for Manufacturing Services.
(January 1). EPA-HQ-OW-2014-0170. DCN 08010.
8. Chan, M. 2011. Recovery and recycling of industrial side-stream wastewater.
International Water Conference. Orlando, FL. (November 13-17). EPA-HQ-OW-2014-
0170. DCN 08011.
9. Chen, G. 2004. Electrochemical technologies in wastewater treatment. Separation and
Purification Technology. 38: 11-41. (January 1). EPA-HQ-OW-2014-0170. DCN 08012.
10. Colica, G. P.C. Mecarozzi, and R. DePhilippis. 2012. Biosorption and recovery of
chromium from industrial wastewaters by using saccharomyces cerevisiae in a flow-
through system. Industrial & Engineering Chemistry Research. 51 (11): 4452-4457.
(March 8). EPA-HQ-OW-2014-0170. DCN 08013.
11. Dennis, R. L.T. Viyannalage, A.V. Gaikwad, T.K. Rout, and S. Banerjee. 2014.
Graphene nanocomposite coatings for protecting low-alloy steels from corrosion.
5-30
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Section 5—Continued Review of Select Industrial Categories
American Ceramic Society Bulletin. 92 (5): 18-24. EPA-HQ-OW-2014-0170. DCN
08014.
12. Dunham, B. D. Chalk. 2013. Non-phosphate transition metal coatings, 81st universal
metal finishing guidebook. Metal Finishing Magazine. Ill (7): 116-122. (Fall).
(September 1). EPA-HQ-OW-2014-0170. DCN 08015.
13. Firouzi, F. M.A. Ross, G. Champneys and MJ. McFarland. 2009a. Treatment of metal
finishing wastewater from aircraft maintenance operations using an electrocoagulation
treatment process. Microconstituents and Industrial Water Quality. 8: 473-480. EPA-
HQ-OW-2014-0170. DCN 08017.
14. Firouzi, F. M.A. Ross, G. Champneys andMJ. McFarland. 2009b. Treatment of metal
finishing wastewaters in the presence of chelating substances. Water Environment
Federation's 2009 Technical Exibition and Conference. Orlando, FL. (October 10-14).
EPA-HQ-OW-2014-0170. DCN 08018.
15. Firouzi, F. M.A. Ross, G. Champneys and MJ. McFarland. 2010. Needs more work.
Industrial Wastewater. 10-12. (April/May). EPA-HQ-OW-2014-0170. DCN 08019.
16. Hopwood, D. 2012. Zirconium pretreatments: Not just for early adopters anymore. Metal
Finishing: The Plating and Coating Industries'Technology Magazine. 110(6): 18-21.
(July/August). EPA-HQ-OW-2014-0170. DCN 08021.
17. Ince, M. 2013. Treatment of manganese-phosphate coating wastewater by
electrocoagulation. Separation Science and Technology. 48: 515-522. (January 18). EPA-
HQ-OW-2014-0170. DCN 08023.
18. LaFlamme, D. 2009. Going low-temp. Products Finishing. (January 1). Available online
at: http://www.pfonline.com/articles/going-low-temp. EPA-HQ-OW-2014-0170. DCN
08025.
19. Legg, K. n.d. Rowan Technology Group. Chrome replacements for internals and small
parts. Available online at: http://www.asetsdefense.org/documents/DoD-
Reports/Cr_Plating_Alts/Cr_Rplcmnt-IDs&Sm_Parts.PDF. EPA-HQ-OW-2014-0170.
DCN 08026.
20. Lv, X. Z. Chen, Y. Wang, F. Huang, and Z. Lin. 2013. Use of high-pressure CO2 for
concentrating CrVI from electroplating wastewater by Mg-Al layered double hydroxide.
Applied Materials & Interfaces. 5 (21): 11271-11275. (October 1). EPA-HQ-OW-2014-
0170. DCN 08027.
21. Mahvi, A.H. E. Bazrafshan. 2007. Removal of cadmium from industrial effluents by
electrocoagulation process using aluminum electrodes. World Applied Sciences Journal.
2 (1): 34-39. EPA-HQ-OW-2014-0170. DCN 08028.
22. Manavbasi, A. 2012. Non-chromated conversion coating for magnesium alloys and zinc-
nickel plated steel. Products Finishing. (November 13). Available online at:
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Section 5—Continued Review of Select Industrial Categories
http://www.pfonline.com/articles/non-chromated-conversion-coating-for-magnesium-
alloys-and-zinc-nickel-plated-steel. EPA-HQ-OW-2014-0170. DCN 08029.
23. McLay, WJ. 2013. Waste minimization and recovery technologies, 81st universal metal
finishing guidebook. Metal Finishing Magazine. Ill (7): 595-619. (Fall). (September 1).
EPA-HQ-OW-2014-0170. DCN 08030.
24. Ogundiran, O. 2011. A Study of Zinc-Nickel as an Alternate Coating to Cadmium for
Electrical Connector Shells Used in Aerospace Applications. A Thesis Submitted to the
Graduate Faculty of Rensselaer Polytechnic Institute. (April). EPA-HQ-OW-2014-0170.
DCN 08032.
25. Qin, J-J. M.N. Wai, M.H. Oo, and H. Lee. 2004. A pilot study for reclamation of a
combined rinse from a nickel-plating operation using a dual-membrane UF/RO process.
Desalination. 161 (2): 155-167. (February 20). EPA-HQ-OW-2014-0170. DCN 08033.
26. Qin, J-J. M.H. Oo and F.S. Wong. 2006. Pilot study on the treatment of spent solvent
cleaning rinse in metal plating. Desalination. 191: 359-364. (May 10). EPA-HQ-OW-
2014-0170. DCN 08034.
27. Schuch, R. R. Gensicke, K. Merkel, and J. Winter. 2000. Nitrogen and DOC removal
from wastewater streams of the metal-working industry. Water Research. 34 (1): 295-
303. (January). EPA-HQ-OW-2014-0170. DCN 08037.
28. Sutton, P.M. P. Mishra, J. Roberts, L. Abreu, and P. Gignac. 2001. Optimization of oily
wastewater membrane bioreactor treatment: Pilot to full scale results. Water
Environment Federation's 2001 Technical Exposition and Conference. Atlanta, GA.
(October 13-17). EPA-HQ-OW-2014-0170. DCN 08038.
29. U.S. EPA. 1979. Development Document for Existing Source Pretreatment Standards for
the Electroplating Point Source Category. Washington, D.C. (August). EPA-HQ-OW-
2014-0170-0007.
30. U.S. EPA. 1981. Federal Register Notice: Effluent Guidelines and Standards;
Electroplating Point Source Category Pretreatment Standards for Existing Sources.
Washington, D.C. (January). EPA-HQ-OW-2014-0170. DCN 08039.
31. U.S. EPA. 1983. Development Document for Effluent Limitations Guidelines andNew
Source Performance Standards for the Metal Finishing Point Source Category.
Washington, D.C. (June). EPA-HQ-OW-2004-0032-0110.
32. U.S. EPA. 1984. Guidance Manual for Electroplating and Metal Finishing Pretreatment
Standards. Washington, D.C. (February). EPA-HQ-OW-2014-0170. DCN 08040.
33. U.S. EPA. 2000. Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Metal Products & Machinery Point Source Category.
Washington, D.C. (December). EPA-HQ-OW-2014-0170-0005.
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Section 5—Continued Review of Select Industrial Categories
34. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories. Washington,
D.C. (October). EPA-821-R-09-007. EPA-HQ-OW-2008-0517-0515.
35. U.S. EPA. 2012. The 2011 Annual Effluent Guidelines Review Report. Washington, D.C.
(December). EPA-821-R-12-001. EPA-HQ-OW-2010-0824-0195.
36. U.S. EPA. 2013. EPA Small Business Innovation Research (SBIR) Program. 2013
Presidential Green Chemistry Award Winner - Faraday Technology, Inc. Functional
Trivalent Chromium Plating Process to Replace Hexavalent Chromium Plating.
Available online at: http://www.epa.gov/ncer/sbir/success/pdf/faraday_success.pdf. EPA-
HQ-OW-2014-0170. DCN 08041.
37. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.
38. U.S. EPA. 2014b. The 2013 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-003. EPA-HQ-OW-2014-0170-0077.
39. Usinowicz, PJ. B.F. Monzyk, H.N. Conkle, J.K. Rose, and S.P. Chauhan. 2005. The use
of liquid-liquid extraction for heavy metals recovery and reuse from plating wastewaters.
Water Environment Federation's 2005 Technical Exposition and Conference. Washington
D.C. (October 30 - November 2). EPA-HQ-OW-2014-0170. DCN 08042.
40. Weber, T. 2013. Wastewater treatment, 81st universal metal finishing guidebook. Metal
Finishing Magazine. Ill (7): 582-594. (Fall). (September 1). EPA-HQ-OW-2014-0170.
DCN 08043.
41. Wolterbeek, M. 2012. New coating for aluminum developed to replace cancer-causing
product. Nevada Today. University of Nevada, Reno. EPA-HQ-OW-2014-0170. DCN
08044.
42. Wong, F.S. J.-J. Qin, M.N. Wai, A.L. Lim, and M. Adiga. 2002. A pilot study on a
membrane process for the treatment and recycling of spent final rinse water from
electroless plating. Separation and Purification Technology. 29 (1): 41-51. (October).
EPA-HQ-OW-2014-0170. DCN 08045.
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Section 5—Continued Review of Select Industrial Categories
5.2 Targeted Review of Pesticide Active Ingredients Without Pesticide Chemical
Manufacturing Effluent Limits (40 CFR Part 455)
As part of the 2012 Annual Review, EPA reviewed analytical methods it had recently
developed or revised to facilitate its identification of unregulated pollutants in industrial
wastewater discharges. This review included the EPA Office of Water's 2012 updates to the test
procedures for analysis of pollutants under the Clean Water Act (CWA) (2012 Method Update
Rule) (77 FR 29758). Under the authority of the CWA, EPA publishes laboratory methods at 40
CFR Part 136 (U.S. EPA, 2012a). Industries and municipalities use these methods to analyze the
chemical, physical, and biological properties of wastewater and other environmental samples that
require measurement by regulation. As part of the 2012 Method Update Rule, EPA added some
of the methods for pesticide active ingredients (PAIs) from Table IG in Part 136 to applicable
parameters listed in Table ID for general use. EPA reviewed these methods and identified 30
PAIs (listed below in Table 5-13) that are measured by existing analytical methods listed in 40
CFR Part 136, but discharges of which from manufacturers are not currently regulated under the
Pesticide Chemicals effluent limitation guidelines and standards (ELGs) (40 CFR Part 455) (U.S.
EPA, 2014a).
The Pesticide Chemicals ELGs regulate wastewater discharges from four subcategories:
1. Subpart A: Organic Pesticide Chemicals Manufacturing;
2. Subpart B: Metallo-Organic Pesticide Chemicals Manufacturing;
3. Subpart C: Pesticide Chemicals Formulating and Packaging; and
4. Subpart E: Repackaging of Agricultural Pesticides Performed at Refilling
Establishments.
EPA established specific limitations for the discharge of PAIs from pesticide chemicals
manufacturing under Subparts A and B in Tables 2 and 3 of 40 CFR Part 455. EPA also
established specific limitations for discharge of PAIs from pesticide formulating, packaging, and
repackaging (PFPR) under Subparts C and E. The PAIs with limitations under Subparts C and E
are limited to zero discharge unless the facility decides to incorporate certain pollution
prevention alternative practices (see Table 10 in 40 CFR Part 455). For the purposes of this
review, EPA is focusing on the list of 30 PAIs of interest (listed below in Table 5-13) as they
relate to Subparts A and B.
The Pesticide Chemicals ELGs regulate PAIs, but several other terms can refer to
pesticides. The ELG defines these terms as:
1. Pesticide: any substance or mixture of substances intended for preventing,
destroying, repelling, or mitigating any pest.
2. Active ingredient: an ingredient of a pesticide that is intended to prevent, destroy,
repel, or mitigate any pest.
3. Pesticide chemicals: the sum of all active ingredients manufactured at each
facility covered by 40 CFR Part 455.
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Section 5—Continued Review of Select Industrial Categories
4. Formulation of pesticide products: the process of mixing, blending, or diluting
one or more PAIs with one or more active or inert ingredients, without an
intended chemical reaction to obtain a manufacturing use product or an end use
product.
For the 2014 Annual Review, EPA began investigating whether U.S. manufacturers
produced the 30 PAIs of interest, listed in Table 5-13, and whether these ingredients may be
present in industrial wastewater discharges from pesticide chemical manufacturing. For
reference, Table 5-13 also indicates whether each PAI is regulated under Subparts C and E in the
Pesticide Chemicals ELGs (discharges are prohibited under Subparts C and E unless certain
pollution prevention alternatives are employed). As previously stated, EPA is focusing these 30
PAIs as they relate to Subparts A and B.
Table 5-13. PAIs Measured by EPA-Approved Methods Without Limits in Subparts A
and B of the Pesticide Chemicals ELGs (40 CFR Part 455)
EPA
Method
608.1
614.1
615
617
619
622
622.1
Chemical
Chlorobenzilate
Chloropropylate
Dibromochloropropane
Etridiazole
EPN
Dalapon
Carbophenothion
Endosulfan sulfate
Endrin aldehyde
Heptachlor epoxide
Isodrin
Strobane
Atraton
Secbumeton
Simetryn
Chlorpyrifos methyl
Coumaphos
Ethoprop
Ronnel
Tokuthion
Trichloronate
Aspon
Dichlofenthion
Famphur
Fenitrothion
CAS Number
510-15-6
5836-10-2
96-12-8
2593-15-9
2104-64-5
75-99-0
786-19-6
1031-07-8
7421-93-4
1024-57-3
465-73-6
8001-50-1
1610-17-9
26259-45-0
1014-70-6
5598-13-0
56-72-4
13194-48-4
299-84-3
34643-46-4
327-98-0
3244-90-4
97-17-6
52-85-7
122-14-5
Limitations Under
Subparts A and B in 40
CFR Part 455?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Limitations Under
Subparts C and E in 40
CFR Part 455?a
Yes
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
Yes
5-35
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Section 5—Continued Review of Select Industrial Categories
Table 5-13 PAIs Measured by EPA-Approved Methods Without Limits in Subparts A
and B of the Pesticide Chemicals ELGs (40 CFR Part 455)
EPA
Method
632
Chemical
Fonophos
Thionazin
Fluometuron
Neburon
Oxamyl
CAS Number
944-22-9
297-97-2
2164-17-2
555-37-3
23135-22-0
Limitations Under
Subparts A and B in 40
CFR Part 455?
No
No
No
No
No
Limitations Under
Subparts C and E in 40
CFR Part 455?a
No
No
Yes
Yes
Yes
Source: 40 CFR Part 455, 2012 Method Update Rule (77 FR 29758).
a Limits under Subparts C and E are zero discharge unless the facility decides to incorporate pollution prevention
alternative practices (see Table 10 in 40 CFR Part 455).
5.2.1 Targeted Review of Pesticide Active Ingredients Without Pesticide Chemical
Manufacturing Effluent Limits
To determine if U.S. manufacturers are producing the 30 PAIs of interest and identify if
they are present in industrial wastewater discharges from pesticide chemicals manufacturing,
EPA's Office of Water contacted EPA's Office of Pesticide Programs (OPP) to review the
registration status for each active ingredient. Section 3 of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) governs pesticide registration and provides the authority to regulate the
content and labeling of pesticide products (U.S. EPA, 2012b). Registration is required when a
pesticide product is produced in the U.S. for distribution, sale, or use within the U.S. (Keigwin,
R., 2014). The pesticide product may contain PAIs (U.S. EPA, 2014b).
FIFRA Section 4 requires that pesticide product registrations be reviewed every 15 years
and requires EPA to reregister all pesticide products that were registered before 1984 in order to
update labeling and use requirements. EPA may cancel a registration if it determines that the
pesticide product does not comply with any of the FIFRA requirements. After cancellation, any
production of the pesticide product for distribution, sale, or use within the U.S. is prohibited
(U.S. EPA, 2012b). OPP provided the registration status for each of the 30 PAIs of interest,
shown in Table 5-14 (Keigwin, R., 2014).
Table 5-14. Registration Status for the 30 PAIs of Interest
EPA Method
608.1
614.1
615
617
Chemical
Chlorobenzilate
Chloropropylate
Dibromochloropropane
Etridiazole
EPN
Dalapon
Carbophenothion
Endosulfan sulfate
CAS Number
510-15-6
5836-10-2
96-12-8
2593-15-9
2104-64-5
75-99-0
786-19-6
1031-07-8
Registration Status
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
Never registered in the U.S.
First registered in 1962; under registration review.
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
Never registered in the U.S.
5-36
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Section 5—Continued Review of Select Industrial Categories
Table 5-14. Registration Status for the 30 PAIs of Interest
EPA Method
619
622
622.1
632
Chemical
Endrin aldehyde3
Heptachlor epoxideb
Isodrin
Strobane
Atraton
Secbumeton
Simetryn
Chlorpyrifos methyl
Coumaphos
Ethoprop
Ronnel
Tokuthion
Trichloronate
Aspon
Dichlofenthion
Famphur
Fenitrothion
Fonofos
Thionazin
Fluometuron
Neburon
Oxamyl
CAS Number
7421-93-4
1024-57-3
465-73-6
8001-50-1
1610-17-9
26259-45-0
1014-70-6
5598-13-0
56-72-4
13194-48-4
299-84-3
34643-46-4
327-98-0
3244-90-4
97-17-6
52-85-7
122-14-5
944-22-9
297-97-2
2164-17-2
555-37-3
23135-22-0
Registration Status
Never registered in the U.S. All U.S. registrations of
the parent compound, endrin, have been canceled.
Never registered in the U.S. All U.S. registrations of
the parent compound, heptachlor, have been canceled.
Never registered in the U.S.
All U.S. registrations have been canceled.
Never registered in the U.S.
Never registered in the U.S.
Never registered in the U.S.
First registered in 1985; under registration review.
First registered in 1958; under registration review.
First registered in 1967; under registration review.
All U.S. registrations have been canceled.
Never registered in the U.S.
Never registered in the U.S.
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
First registered in 1975; under registration review. Only
product registered in the U.S. is for formulating other
insecticides. No end-use products registered in the U.S.
All U.S. registrations have been canceled.
All U.S. registrations have been canceled.
First registered in 1974; under registration review.
All U.S. registrations have been canceled.
First registered in 1974; under registration review.
Source: (Keigwin, R., 2014).
a Endrin aldehyde has never been a registered pesticide, but is an impurity and breakdown product of a previously
registered pesticide, endrin. Endrin is also a regulated PAI under the Pesticide Chemicals ELGs (40 CFR Part
455).
b Heptachlor epoxide has never been a registered pesticide, but is a metabolite of a previously registered
pesticide, heptachlor. Heptachlor is also a regulated PAI under the Pesticide Chemicals ELGs (40 CFR
Part 455).
Although FIFRA Section 3 provides authority to regulate the content and labeling of
pesticide products through registration, it does not provide the authority to regulate pesticide
production or production facilities. Manufacturers can only produce pesticide products in the
U.S. for distribution within the U.S. or for export. As stated above, pesticide products
manufactured for distribution within the U.S. require registration. However, pesticide products
manufactured solely for export do not require U.S. registration. Therefore, the registration status
of a particular PAI (e.g., canceled, never registered) may not indicate which pesticide products
are produced in the U.S., especially if produced only for export (Keigwin, R., 2014).
5-37
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Section 5—Continued Review of Select Industrial Categories
Under FIFRA Section 7, establishments producing pesticides, PAIs, or devices must
register with the appropriate EPA Regional office and report the types and amounts of pesticide
products they produce. This includes facilities manufacturing pesticide products solely for export
(Keigwin, R., 2014; U.S. EPA, 2012b). The FIFRA Section 7 data are compiled in the Pesticide
Registration Information System (PRISM), Section Seven Tracking System (SSTS). The SSTS
database contains the following information, which may be useful for determining whether any
of the 30 PAIs of interest are produced in the U.S. (U.S. EPA, 2013):
1. General establishment and company information (name, contact information);
2. Product registration status and information;
3. Product name (common brand names, alternate brand names);
4. Product classification (e.g., insect repellant, herbicide, rodenticide);
5. Product type (technical formulation or active ingredient, end-use product,
repackaged or relabeled, device);
6. Market status in the U.S. (marketed in the U.S., marketed in the U.S. and
exported, solely exported);
7. "Restricted Use" pesticide status;
8. Amount produced;
9. Amount sold or distributed in the U.S.;
10. Amount sold or distributed to foreign markets; and
11. Amount estimated to be produced in the following year.
5.2.2 Summary of Findings from EPA's Targeted Review of Pesticide Active Ingredients
Without Pesticide Chemical Manufacturing Effluent Limits
EPA's review identified that only seven of the 30 PAIs of interest are currently registered
or are under registration review in accordance with FIFRA Section 3. The remaining 23 have
either never been registered or had their registrations canceled. However, discussions with OPP
suggest that registration status may not be an indicator of whether the PAI is produced in the
U.S. (and potentially present in industrial wastewater discharge), as unregistered pesticides may
still be produced in the U.S. for export. Therefore, EPA was not at this time able to prioritize for
further review a subset of the PAIs of interest that are produced in the U.S. However, EPA did
identify follow up questions and types of information that will indicate which of the 30 PAIs of
interest are produced in the U.S. and are thus potentially present in industrial wastewater
discharges. These sources of information include examining the SSTS production data in
conjunction with reviews of permit applications, fact sheets, and permits for the facilities that
produce the PAIs of interest. The information will help EPA answer the following questions and
determine whether revisions to the Pesticide Chemicals ELGs are warranted:
• Are any of the 30 PAIs of interest produced in the U.S.? If so, which facilities
produce the PAIs?
• What is the manufacturing process of the PAIs at a particular facility?
• Does the manufacturing process of the PAIs produce a wastewater discharge?
5^38
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Section 5—Continued Review of Select Industrial Categories
• Are the PAIs at treatable concentrations in the wastewater discharge?
• Are discharge data available for the PAIs?
• Does the permit have any limitations for the PAIs?
• Is permitting support necessary for plants identified as likely discharging the
PAIs?
5.2.3 References for EPA's Targeted Review of Pesticide Active Ingredients Without
Pesticide Chemical Manufacturing Effluent Limits
1. Keigwin, R. 2014. Email Communication Between Richard Keigwin, U.S. EPA Office of
Pesticide Programs, and William Swietlik, U.S. EPA Office of Water. Re: Questions for
OPP About Pesticides. (April 30). EPA-HQ-OW-2014-0170. DCN 07996.
2. U.S. EPA. 2012a. Clean Water Act Analytical Methods. Available online at:
http://water.epa.gov/scitech/methods/cwa/index.cfm.EPA-HQ-OW-2010-0824.DCN
07746.
3. U.S. EPA. 2012b. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Washington, D.C. . (March 30). Available online at:
http://www.epa.gov/agriculture/lfra.html. EPA-HQ-OW-2014-0170. DCN 07997.
4. U.S. EPA. 2013. Instructions for Completing EPA Form 3540-16 Pesticide Report for
Pesticide-Producing and Device-Producing Establishments, Reporting Year 2013.
Available online at:
http://www.epa.gOv/compliance/resources/publications/monitoring/fifra/estabreportinst.p
df. EPA-HQ-OW-2014-0170. DCN 07998.
5. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.
6. U.S. EPA. 2014b. Pesticide Registration Manual: Chapter 1: Overview of Requirements
for Pesticide Registration and Registrant Obligations. (June 26). Available online at:
http://www2.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-l-
overview-requirements-pesticide. EPA-HQ-OW-2014-0170. DCN 07999.
5-39
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Section 5—Continued Review of Select Industrial Categories
5.3 Continued Review of Brick and Structural Clay Products Manufacturing
As part of the 2012 Annual Review, EPA reviewed air quality regulations, including New
Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air
Pollutants (NESHAP), to determine if they result in the generation of unregulated wastewater
discharges or changes to currently regulated wastewater streams (containing new pollutants of
concern) (U.S. EPA, 2014). From that review, EPA identified brick and structural clay products
manufacturing as an industry that is not currently regulated by effluent limitations guidelines
(ELGs) and that may have industrial wastewater discharges resulting from air pollution control
requirements.
The brick and structural clay products production process consists of preparing the raw
materials (primarily clay and shale), forming the processed materials into bricks or other shapes,
and drying and frying the bricks and shapes (U.S. EPA, 2005). During its review of this industry
sector in 2012 (U.S. EPA, 2014), EPA identified 93 facilities associated with brick and structural
clay products manufacturing Standard Industrial Classification (SIC) codes15 reporting discharge
monitoring report (DMR) data in 2009. Only 37 of the facilities had reported pollutant
discharges greater than zero. However, none of the facilities holds an individual National
Pollutant Discharge Elimination System (NPDES) permit; all reported discharges were
associated with general stormwater permits.
Because a majority of the brick and structural clay manufacturers reporting DMR data in
2009 were in Alabama, EPA contacted the Alabama Department of Environmental Management
(ADEM). The ADEM contact stated that the brick manufacturing facilities have general permits
for stone, glass, and clay that cover stormwater discharges; they do not have individual NPDES
permits (Warren, L., 2012). The 2012 review suggested that brick and structural clay products
manufacturers may have only stormwater discharges, and may not have wastewater discharges
associated with manufacturing or wet air pollution control systems. However, EPA continued its
review of the brick and structural clay products manufacturing industry because the evaluation of
2009 data may not have fully captured the potential impacts of the NESHAP. This possibility
arises due to the time allowed for implementation of the NESHAP requirements (through 2006)
and the timing of the NPDES permit renewal schedule (every five years).
5.3.1 Air Regulations for Brick and Structural Clay Products Manufacturing
On May 16, 2003, EPA promulgated the NESHAP for brick and structural clay products
manufacturing, as well as the NESHAP for clay ceramics manufacturing (68 FR 26689). The
NESHAP for brick and structural clay products manufacturing requires affected manufacturers to
control the following substances, beginning in 2006: hydrogen fluoride, hydrogen chloride,
sulfur dioxide, and some metal emissions, including antimony, arsenic, beryllium, cadmium,
chromium, cobalt, mercury, manganese, nickel, lead, and selenium (68 FR 26692). The
15 SIC codes associated with the Brick and Structural Clay Products Manufacturing industry include: SIC 1455,
Kaolin & Ball Clay (NAICS 212324); SIC 1459, Clay, Ceramic & Refractory Minerals (NAICS 212325); 3251,
Brick and Structural Clay Tile (NAICS 327121); SIC 3255, Clay Refractories (NAICS 327120); SIC 3259,
Structural Clay Products (NAICS 327123); SIC 3271, Concrete Block and Brick (NAICS 327331); and SIC 5032,
Brick, Stone, and Related Materials (NAICS 423320).
5-40
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Section 5—Continued Review of Select Industrial Categories
NESHAP states that entities potentially affected are those industrial facilities that manufacture
brick and structural clay products, specifically those classified under the following SIC codes:
• 3251 (NAICS 327121): Brick and structural clay tile manufacturing facilities;
• 3253 (NAICS 327122): Extruded tile manufacturing facilities; and
• 3259 (NAICS 327123): Other structural clay products manufacturing facilities.
The NESHAP for brick and structural clay products manufacturing mentions wet air
pollution control devices, such as wet scrubbers, as one of three methods to comply with the
standard. The other two potential methods are dry lime injection fabric filters (DIFF) and dry
lime scrubbers/fabric filters (DLS/FF) (68 FR 26694). Wet scrubbers have the potential to
generate new wastewater discharges not regulated by ELGs.
The Clay Ceramics Manufacturing NESHAP states that potentially affected facilities are
manufacturers of ceramic wall and floor tile or vitreous plumbing fixtures, specifically those
classified under the following SIC codes:
• 3253 (NAICS 327122): Ceramic wall and floor tile manufacturing facilities; and16
• 3261 (NAICS 327111): Vitreous plumbing fixtures (sanitaryware) manufacturing
facilities.
However, EPA did not review the Clay Ceramics Manufacturing NESHAP as part of its
initial review of air quality regulations in 2012 because the preamble states that no water or solid
waste impacts are projected for existing or new sources (68 FR 26717).
Brick and structural clay products manufacturing facilities were required to comply with
the 2003 NESHAP by May 2006. However, in 2007, in response to a complaint filed by the
Sierra Club, the U.S. District Court for the District of Columbia vacated the rule. The lawsuit
claimed EPA failed to meet its obligations under the Clean Air Act by not including all
technologies in developing the standards, including technologies that were not necessarily
achievable by all sources (Sierra Club vs. EPA, 2007). Currently, EPA is planning to propose a
revised rule in August 2014 and issue final regulations by June 2015 (OMB, 2014).
5.3.2 2014 Annual Review of Brick and Structural Clay Products Manufacturing
EPA's review of the brick and structural clay products manufacturing industry, as part of
the 2012 Annual Review, suggested that the majority of brick and structural clay manufacturing
facilities only have stormwater discharges, not process discharges, associated with
manufacturing or wet air pollution control. However, because of the timing allowed for
implementation of the NESHAP requirements (through 2006) and the NPDES permit renewal
schedule (every five years), EPA's evaluation of 2009 DMR data may not have fully captured
16 Facilities in SIC Code 3253 (ceramic wall and floor tile manufacturing facilities and extruded tile manufacturing
facilities) are subject to both the Clay Ceramics Manufacturing NESHAP and the Brick and Structural Clay Products
Manufacturing NESHAP (68 FR 26690).
-------
Section 5—Continued Review of Select Industrial Categories
the potential impact of the NESHAP. Therefore, EPA continued its investigation of brick and
structural clay manufacturing facilities during the 2014 Annual Review.
As part of this 2014 Annual Review, EPA's Office of Water contacted EPA's Office of
Air and Radiation (OAR) and the Brick Industry Association (BIA) to learn more about the
NESHAP and the potential impacts on the industry, specifically regarding the installation of wet
air pollution controls. Both contacts stated that wet scrubbers are not a common air pollution
control method within the industry and that only a small number of brick and structural clay
manufacturing facilities have them installed (Miller, S., 2014; Telander, J., 2014). OAR also
provided information on the number of brick manufacturing facilities and clay ceramics facilities
that have installed wet scrubbers, as discussed in the sections below.
5.3.2.1 Review of Brick Manufacturing Facilities
As of 2014, only two of the 345 brick manufacturing facilities in the U.S. (as identified
by SIC Codes 3251, 3253, and 3259) have wet scrubbers (Telander, J., 2014; U.S. Census,
2011). Table 5-15 presents these facilities. However, both facilities are synthetic minor sources
and would not be subject to the brick and structural clay products manufacturing NESHAP
(Telander, J., 2014). Synthetic minor sources are those facilities using some emission control
device (or devices) required by a Federally Enforceable State Operating Permit (FESOP) and
which thereby emit fewer than 10 tons per year of any hazardous air pollutants (HAP) and fewer
than 25 tons per year of any combination of HAP. In the absence of such controls, these sources
would be major17 (68 FR 26697).
The first facility, Interstate Brick, in West Jordan, UT, has two wet scrubbers, the first
installed in 1996, and the second in 2000 (Telander, J., 2014). Interstate Brick manufactures a
full line of standard brick products used in residential and commercial construction (Interstate
Brick, 2014). The facility is included in the DMR Loading Tool, but it has no reported
wastewater discharges between 2007 and 2011.
The second facility, Glen-Gery Corporation's Hanley Plant in Summerville, PA, has one
wet scrubber, installed in 2003 (Telander, J., 2014). Glen-Gery produces high quality
architectural brick at the Hanley Plant, which the company has owned since 1986 (Glen-Gery
Brick, 2014). The facility is not included in the DMR Loading Tool and has no reported
wastewater discharges between 2007 and 2011.
Table 5-15. Brick Manufacturing Facilities in the U.S.
Company Name
Pacific Coast
Building Products
Facility
Name
Interstate
Brick
Facility
Location
West Jordan,
UT
Type of
Source
Kiln
DMR
Discharges
None
Facility SIC Codes
3271 - Concrete Block and Brick
325 1 - Brick and Structural Clay
Tile
17 A major source is any stationary source or group of stationary sources that emits or has the potential to emit 10
tons per year or more of any hazardous air pollutant, or 25 tons per year or more of any combination of hazardous
air pollutants.
5-42
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Section 5—Continued Review of Select Industrial Categories
Table 5-15. Brick Manufacturing Facilities in the U.S.
Company Name
Glen-Gery
Corporation
Facility
Name
Hanley Plant
Facility
Location
Summerville,
PA
Type of
Source
Kiln
DMR
Discharges
None
Facility SIC Codes
3251 - Brick and Structural Clay
Tile
Source: (EPA Envirofacts; Telander, I, 2014).
5.3.2.2 Review of Clay Ceramics Facilities
EPA did not review the Clay Ceramics Manufacturing NESHAP as part of the initial
review of air quality regulations in 2012 because the preamble of the rule stated that no water or
solid waste impacts were projected for existing or new sources (68 FR 26717). However, OAR
indicated and provided information regarding several clay ceramics facilities in the U.S. that
have installed wet scrubbers. Table 5-16 presents these facilities.
As of 2014, two out of 24 facilities in the clay ceramics industry, SIC code 3261, have
wet scrubbers, both of which are at major sources. Kohler, Co. owns both facilities and each
facility has one wet scrubber (Telander, J., 2014). Neither facility has reported DMR discharge
data for years 2007 to 2011 (DMR Loading Tool).
Three out of 127 facilities in the ceramic tile category, SIC code 3253, have wet
scrubbers. Dal Italia and the Dai-Tile Dallas Plant each have two wet scrubbers to control air
emissions from kilns. Florim USA has three wet scrubbers and the Dai-Tile Dallas Plant has two
wet scrubbers to control air emissions from glaze lines (Telander, J., 2014). None of the facilities
has reported DMR discharge data for years 2007 to 2011 (DMR Loading Tool). In addition, all
three of the facilities are synthetic area sources and are therefore not subject to the clay ceramics
manufacturing NESHAP (Telander, J., 2014).
5-43
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Section 5—Continued Review of Select Industrial Categories
Table 5-16. Clay Ceramics Facilities in the U.S.
Category
Clay
Ceramics
Clay
Ceramics
Ceramic Tile
Ceramic Tile
Ceramic Tile
Company
Name
Kohler Co.
Kohler Co.
Dai-Tile
Corporation
Mohawk
Industries
Florim
Ceramiche
S.p.A.
Facility
Name
Spartanburg
Plant
Wisconsin
Plant
Dal Italia
Dai-Tile
Dallas Plant
Florim USA
Facility
Location
Spartanburg,
SC
Kohler, WI
Muskogee, OK
Dallas, TX
Clarksville, TN
Type of
Source
Kiln
Glaze spray
booth
Kiln
Kiln & Glaze
spray booth
Glaze Spray
Booth
DMR
Discharges
None
None
None
None
None
Facility SIC Codes
3088 - Plastics Plumbing Fixtures
3261 - Vitreous China Plumbing Fixtures and China and
Earthenware Fittings and Bathroom Accessories
3261 - Vitreous China Plumbing Fixtures and China and
Earthenware Fittings and Bathroom Accessories3
343 1 - Enameled Iron and Metal Sanitary Ware
3432 - Plumbing Fixtures and Trim
3519 - Internal Combustion Engines, not elsewhere classified
3541 - Machine Tools, Metal Cutting Types
3471 -Electroplating, Plating, Polishing, Anodizing, and
Coloring
3253 - Ceramic Wall and Floor Tile
3253 - Ceramic Wall and Floor Tile
3251 - Brick and Structural Clay Tile
3253 - Ceramic Wall and Floor Tile
Source: (EPA Envirofacts; Telander, I, 2014).
a Kohler Co. is major plant with many operations. This analysis focused on operations related to SIC 3261 - Vitreous China Plumbing Fixtures and China and
Earthenware Fittings and Bathroom Accessories, which corresponds to the SIC code covered by the Clay Ceramics Manufacturing NESHAP.
5-44
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Section 5—Continued Review of Select Industrial Categories
5.3.3 Summary of Findings from EPA's Review of Brick and Structural Clay Products
Manufacturing
EPA's investigation of the brick and structural clay products manufacturing industry,
outlined above, determined that only seven out of approximately 496 facilities producing brick,
structural clay, and clay ceramics currently have wet scrubbers installed. Some of these were
installed prior to the 2003 NESHAPs. EPA also found that the seven facilities with wet scrubbers
did not report any DMR discharges for reporting years 2007 through 2011. These findings
suggest that wet scrubbers are not a common air pollution control method within the industry and
not expected to increase; therefore, they are not a potential new source of industrial wastewater
discharge warranting regulation.
5.3.4 References for the Continued Review of Brick and Structural Clay Manufacturing
1. Glen-Gery Brick. 2014. History of Glen-Gery Brick. Available online at:
http://www.glengery.com/about-us/history. Accessed: June 20, 2014. EPA-HQ-OW-
2014-0170. DCN 07988.
2. Interstate Brick. 2014. Interstate Brick History. Available online at:
http://www.interstatebrick.com/history.html. Accessed: June 20, 2014. EPA-HQ-OW-
2014-0170. DCN 07989.
3. Miller, S. 2014. Telephone Communication Between Susan Miller, Brick Industry
Assocoation, and Amie Aguiar, Eastern Research Group, Inc. Re: Brick Manufacturing
Process. (April 17). EPA-HQ-OW-2014-0170. DCN 07990.
4. OMB. 2014. Office of Management and Budget. RIN data for National Emission
Standards for Hazardous Air Pollutants (NESHAP): Brick and Structural Clay Products
Manufacturing and Clay Ceramics Manufacturing. Available online at:
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201404&RIN=2060-AP69.
EPA-HQ-OW-2014-0170. DCN 07991.
5. Sierra Club vs. EPA, 2007. U.S. Court of Appeals for the District of Columbia Circuit,
No. 03-1202. March 13, 2007. Available online at:
http://www.cadc.uscourts.gov/internet/opinions.nsf/3DE6EA395F4B40A6852574400045
37C7/$file/03-1202a.pdf. EPA-HQ-OW-2014-0170. DCN 07992.
6. Telander, J. 2014. Email Communication Between Jeff Telander, U.S. EPA Office of Air
and Radiation, and William Swietlik, U.S. EPA Office of Water. Re: Brick and Clay
Follow-up. (May 21). EPA-HQ-OW-2014-0170. DCN 07993.
7. U.S. Census. 2011. U.S. Economic Census: 2011 County Business Patterns. Available
online at: http://factfmder2.census.gOv/faces/nav/jsf/pages/searchresults.xhtml?refresh=t.
Accessed: March 26, 2014. EPA-HQ-OW-2014-0170. DCN 07994.
8. U.S. EPA. 2005. Fact Sheet for National Emission Standards for Hazardous Air
Pollutants for Brick and Structural Clay Products Manufacturing: Reconsideration.
Washington, D.C. (April 22). EPA-HQ-OW-2014-0170. DCN 07995.
5-45
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Section 5—Continued Review of Select Industrial Categories
9. U.S. EPA. 2014. The 2012 Annual Effluent Guidelines Review Report. Washington, D.C.
(September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.
10. Warren, L. 2012. Telephone Communication Between Lee Warren, Alabama Department
of Environmental Management, and Kimberly Landick, Eastern Research Group, Inc. Re:
Brick Manufacturing Process. (March 21). EPA-HQ-OW-2010-0824. DCN 07737.
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6. NEW DATA SOURCES AND ADDITIONAL SUPPORTING ANALYSES
For the 2014 Annual Review, EPA initiated a review of engineered nanomaterials, which
are an emerging pollutant group of concern, and continued its review of industrial wastewater
treatment technology performance data and population of the Industrial Wastewater Treatment
Technology (IWTT) Database. EPA's goals in conducting these reviews were to identify new
wastewater discharges or pollutants not previously regulated and to identify wastewater
discharges that can be eliminated or treated more effectively.
EPA documented the usability and quality of the data supporting these reviews, analyzed
how the data could be used to improve the characterization of industrial wastewater discharges
(detection or monitoring of pollutants, wastewater treatment available for new
industries/concentrations), and prioritized the findings for further review. See Appendix B of this
report for more information on data usability and quality of the data supporting these reviews.
Sections 6.1 and 6.2 of this report provide details of each of these reviews.
6.1 Review of Engineered Nanomaterials in Industrial Wastewater
As part of the 2014 Annual Review, EPA began evaluating engineered nanomaterials
(ENMs) as a potential emerging industrial wastewater pollutant category. Nanotechnology is a
rapidly advancing field of research and commerce and offers potential benefits for health,
consumer products, and electronics applications. According to the Woodrow Wilson
International Center for Scholars' Project on Emerging Nanotechnology's Nanotechnology
Consumer Product Inventory, ENMs are currently used in over 800 consumer products in the
U.S. (Project on Emerging Nanotechnologies, 2014).
In its Final 2010 Effluent Guidelines Program Plan, EPA solicited data and information
for future annual reviews on the manufacture, use, and environmental release of silver materials,
including nanosilver, due to their anti-microbial activity and potential to create a source of silver
in associated industrial wastewater discharges (U.S. EPA, 201 la). Several commenters indicated
that EPA should investigate the impact of nanosilver; a few in particular indicated that EPA
should investigate all nanomaterials (U.S. EPA, 2013c). In addition, recent research presented at
the Society of Environmental Toxicology and Chemistry (SETAC) North America 33rd Annual
Meeting in November 2012 indicates that ENMs may impact human health and the environment.
Although researchers have conducted little direct sampling and analysis of industrial wastewater
discharges, they have identified industrial discharges as a possible route for ENMs to enter the
environment (Gottschalk and Nowack, 2011; Hendren et al., 2011; Musee, 2011).
As part of the 2014 Annual Review, EPA responded to the recent interest, research, and
concerns raised in comments by reviewing current literature about the fate, transport, and effects
of nanomaterials on the environment and human health and about the presence and discharge of
nanomaterials in industrial wastewater. This review summarizes EPA's current knowledge of,
and outstanding data gaps related to, characterizing and quantifying the presence and impact of
ENMs in industrial wastewater discharges.
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Section 6—New Data Sources and Additional Supporting Analyses
6.1.1 Literature Review and Research Methodology
EPA assessed available information to support the evaluation of potential industrial
wastewater discharges and associated risks of discharged ENMs. EPA's review focused on:
• Production methods and potential aqueous waste streams from manufacturing and
processing ENMs;
• Fate, transport, and potential effects of nanomaterials on human health and the
environment;
• Analytical techniques available to detect nanomaterials in industrial wastewater;
• Presence of nanomaterials in industrial wastewater; and
• Treatment technologies to remove nanomaterials from wastewater.
SETAC's 2012 conference proceedings included over 125 presentations and posters
about nanomaterial-related research, which primarily focused on fate and transport, toxicity, and
analytical techniques (SETAC, 2012). EPA reviewed this nanomaterial-related research and
catalogued relevant abstracts as a starting point for further research.
Next, EPA identified (partly through the SETAC abstracts) principal government and
university researchers and organizations that focus on studying the environmental impacts of
ENMs. Several EPA offices are currently assessing the potential effects of ENMs on human
health and the environment through research into chemical safety, characterization techniques,
life cycle assessment, and risk assessment of these nanomaterials in air, water, and soil (U.S.
EPA, 2013a). EPA identified additional stakeholders based on nanomaterials-related research
conducted by these EPA offices, including the Office of Pollution Prevention and Toxics (OPPT)
and the Office of Research and Development's (ORD's) National Exposure Research Laboratory
(NERL).
EPA communicated with the following researchers and government stakeholders between
March and June 2013:
• Mark Wiesner, James L. Meriam Professor, Department of Civil and
Environmental Engineering, Duke University; Director of the Center for the
Environmental Implications of Nanotechnology (CEJJSTT).
• Michael Hochella Jr., University Distinguished Professor, Department of
Geosciences, Virginia Tech; member of CEINT.
• Paul Westerhoff, Professor, School of Sustainable Engineering and the Built
Environment, Associate Dean for Research and Graduate Affairs, Ira A. Fulton
Schools of Engineering, Arizona State University.
• David Meyer, Chemical Engineer, EPA ORD National Risk Management
Research Laboratory (NRMRL), Sustainable Technologies Division.
• Thabet Tolaymat, Environmental Engineer, EPA ORD NRMRL.
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Section 6—New Data Sources and Additional Supporting Analyses
• Katrina Varner, Research Chemist, EPA ORD NERL-Las Vegas/Environmental
Sciences Division/Environmental Chemistry Branch.
• Steve Diamond, EPA National Health and Environmental Effects Research
Laboratory, Mid-Continent Ecology Division-Duluth.
• Jeff Morris, Deputy Director for Programs, EPA OPPT.
• Phil Sayre, EPA Deputy National Program Director for the Chemical Safety for
Sustainability Research Program.
• Jim Alwood, Program Manager and Toxic Substances Control Act
Nanotechnology Coordinator, EPA OPPT, Chemical Control Division.
• Barbara Karn, Program Director, National Science Foundation; Vice President,
Sustainable Nanotechnology Organization.
• Suzanne Davis, Hazardous Substances Engineer, California Department of Toxic
Substances Control.
EPA reviewed literature and research identified using the following search engines:
• American Chemical Society Publications (http://pubs.acs.org), a comprehensive
collection of the most-cited peer-reviewed journals in chemistry and related
sciences;
• ScienceDirect (http://www.sciencedirect.com/), a full-text scientific database
offering over 2,500 peer-reviewed journals; and
• Google Scholar (http://scholar.google.com), which provides a broad search of
scholarly literature across disciplines, publishers, and online databases.
In addition, EPA searched for articles written by SET AC 2012 conference participants
and scanned titles and abstracts to identify relevant articles, using various keyword combinations
to further focus the literature search. From the articles identified, EPA performed additional
searches to find other relevant articles from co-authors and references.
EPA created a comprehensive EndNote® reference library to store and organize
references (ERG, 2014). Because nanotechnology is an emerging field of study, EPA strived to
collect the most recent research, gathering material published from 2006 to December 2013. All
articles are government publications, peer-reviewed, or conference proceedings and meet the
data quality objectives outlined in the Environmental Engineering Support for Clean Water
Regulations Programmatic Quality Assurance Project Plan (ERG, 2013).
EPA's literature review and research methodology are further documented in the
memorandum Engineered Nanomaterials in Industrial Wastewater: Literature Review and
Implications for 304m (ERG, 2015).
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Section 6—New Data Sources and Additional Supporting Analyses
6.1.2 Overview of Nanomaterials
Nanomaterials are generally defined as engineered or naturally occurring materials
composed of primary particles, with sizes on the order of 1 to 100 nanometers (nm) in at least
one dimension, that show physical, chemical, and biological properties not found in bulk samples
of the same material (U.S. EPA, 201 Ib). These primary particles, termed nanoparticles, may
exhibit novel, size-dependent characteristics such as increased strength, chemical reactivity, and
conductivity due to their high surface area-to-volume ratio. This proportionally large surface area
makes nanoparticles more reactive and responsive to their surroundings and influences mobility,
aggregation, and stability in soil and water (Gavankar et al., 2012).
Naturally occurring nanomaterials are ubiquitous in the environment, but have only
recently been discovered due to advances in microscopy (Hochella et al., 2008). Their
background levels and mass distribution are largely unknown. In some cases, nanomaterials may
also be incidental, meaning that they are unintentionally produced through industrial activities,
notably through emissions from fossil fuel combustion and manufacturing (Wiesner et al., 2009).
Engineered nanomaterials are produced to serve a particular purpose and represent a
new or additional input to the environment. The most common ENMs are classified into two
categories: carbon-based and inorganic or metal-containing ENMs. Table 6-1 lists common types
of ENMs.
Table 6-1. Common Types of Engineered Nanomaterials
Category
Carbon-based ENMs
Inorganic 'or metal-containing ENMs
Engineered Nanomaterial
Carbon nanotubes
Fullerenes
Graphene
Silver
Titanium dioxide
Quantum Dots
Cerium Oxide
Zinc Oxide
Iron
Copper
Silicon
Gold
Bi- and tri-metallic
alloys
Source: SETAC (2012) and U.S. EPA (2013a).
Some ENMs, such as cadmium selenide quantum dots and some complex carbon-based
nanomaterials, are completely novel and do not occur in nature. Any of these materials detected
in the environment can be assumed to be anthropogenic (ERG, 2008; Hochella, 2013). However,
many types of nanomaterials that can be engineered also occur naturally in the environment,
particularly silver and metal oxides. Silver ENMs are used extensively as an antimicrobial agent
in consumer products, but silver particles on the nanoscale are also found in nature. In addition,
titanium dioxide (TiCh) nanoparticles that are identical to engineered nanoparticles have been
found in rivers that do not receive wastewater discharges and are remote from industrial
activities (Hochella, 2013).
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Section 6—New Data Sources and Additional Supporting Analyses
Based on the recommendation of several leading researchers, EPA's review of current
research focused on three classes of ENMs: silver, TiCh, and carbon-based nanomaterials
(Hochella, 2013; Wiesner, 2013). Researchers estimate that these three classes are produced in
the largest volumes and are commonly used in commercial and consumer products. In addition,
research has more fully classified their impact on human health and the environment relative to
the impacts of other types of ENMs (for which there is little information).
6.1.3 Engineered Nanomaterial Production Methods, Volumes, and Potential Sources of
Industrial Discharge
To understand the potential sources and magnitude of ENMs in industrial wastewater
discharges, EPA gathered available information on both ENM manufacturing and ENM
processing into nano-enabled products (products containing nanomaterials). Manufacturing is the
synthesis of ENMs; processing (or formulating) includes any industrial transformation or
processing of ENMs into a form that could be used to make nano-enabled products, as well as
manufacturing of nano-enabled products. EPA also collected information about the generation
and handling of aqueous waste streams produced during manufacturing and processing.
ENM manufacturing occurs by both wet (chemical) and dry (gas) phase processes. Wet-
phase chemical synthesis, including chemical reduction, sulfate, sol-gel, and hydrothermal
methods (Fabrega et al., 2011; Liu et al., 2013; Mulfmger et al., 2007; Robichaud et al., 2009),
may generate aqueous waste streams (Eckelman et al., 2012; Musee, 2011). Wet-phase processes
are more common in the manufacture of silver and nano-TiCh, though research suggests that
about 60 percent of the world's manufactured nano-TiCh is synthesized through a gas-phase
chloride process (Liu et al., 2013). Carbon nanotubes (CNTs) are most commonly manufactured
using dry-phase processes, including chemical vapor deposition, arc ablation, or high-pressure
carbon monoxide (Eckelman et al., 2012; Healy et al., 2008). Although dry-phase processes do
not generate an aqueous waste stream, common procedures following both wet- and dry-phase
synthesis, such as purification and washing, may also generate aqueous waste.
ENMs are formulated into industrial and domestic products, chemicals, and other
materials to create nano-enabled products for many industrial sectors. Nano-TiCh is used as a
catalyst and incorporated into paints, coatings, plastics, paper, and cosmetics. Nano-TiCh is also
used as a semiconductor and in water treatment and remediation applications. Silver ENMs are
widely used in consumer products, textiles, and biomedical applications for their antimicrobial
properties (U.S. EPA, 2013a). CNTs are used in the electronics, polymer, and biomedical
industries, with ongoing research into their applications for the energy and consumer goods
sectors (Mueller and Nowack, 2008).
Researchers indicate that processing ENMs into nano-enabled products may be more
likely to produce an aqueous waste stream than manufacturing ENMs because many of the nano-
enabled products may be formulated with the ENMs in solution (Wiesner, 2013). The extent of
processing, however, is likely proprietary and could be highly variable, depending on the
intended use. As a result, EPA could not identify adequate information to characterize and
quantify the waste streams generated from ENM processing.
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Section 6—New Data Sources and Additional Supporting Analyses
Although available literature suggests that aqueous waste streams are likely generated
through manufacturing and processing of ENMs, it is unclear how these waste streams are
managed and ultimately disposed, particularly from industrial manufacturing and processing. In
laboratory synthesis of ENMs, unused reagents and chemical wastes are strictly managed, and
are likely to be handled as hazardous waste and not released as wastewater (Eckelman et al.,
2012). In addition, researchers suggest that laboratory-generated waste streams are probably
recovered or reused due to the high cost of producing ENMs (Wiesner, 2013).
To understand the magnitude of potential industrial wastewater discharges, EPA searched
for information on the number of facilities manufacturing and processing ENMs and the
production quantities and waste volumes generated. Commercial ENM manufacturing methods,
processing methods, and production volumes are often proprietary in nature. The EPA Nanoscale
Materials Stewardship Program solicited voluntary reports from U.S. companies producing
ENMs in 2008 (U.S. EPA, 2013b). The program estimated that about 600 companies
manufactured, processed, or used nanotechnology in 2005; although the program expected
reports from 240 entities, it received only 31. Of the companies that responded, only two
publicly reported any production data. These two companies reported manufacturing capacity,
but not the actual quantities of nanomaterials manufactured (Hendren et al., 2011). In a separate
effort, Duke University researchers, using data from patents, company websites, and requests,
identified 30 companies producing either silver, nano-TiO2, or CNTs (provided in Appendix D)
(Hendren et al., 2011).
EPA's OPPT recently promulgated Significant New Use Rules (SNURs) for CNTs under
the authority of the Toxic Substances Control Act, which became effective in August and
October 2013 (U.S. EPA, 2013d, 2013e). These SNURs require entities that intend to
manufacture, process, or use certain CNTs to notify EPA at least 90 days before engaging in a
significant new use. Any Significant New Use notices made under these SNURs will give EPA
the opportunity to evaluate the intended new uses of the CNTs and, if necessary, to limit or
prohibit activity to mitigate any unreasonable risks to human health and the environment.
In general, EPA found that manufacturing and processing ENMs, particularly silver
nanoparticles, is likely to generate aqueous waste streams; however, very little publically
available information exists to characterize the waste streams or describe how the aqueous
wastes are managed and disposed. Further, the universe of facilities manufacturing and
processing ENMs and the associated production volumes are not well understood.
6.1.4 Fate, Wastewater Treatment, and Toxicity
ENMs are likely to be transformed and exist in different forms in the environment than
the original form in which they were created. ENMs undergo complex and dynamic
transformations in aqueous media, the extent of which are not fully understood (Lowry et al.,
2012b). The different forms in which a nanomaterial may exist will influence its fate, reactivity,
and toxicity in the environment.
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Section 6—New Data Sources and Additional Supporting Analyses
6.1.4.1 Fate and Environmental Transformations
Particle size and surface area influence the degree of interaction ENMs will have with
substances and organisms in the environment. A larger surface area (smaller particle) allows for
greater reaction rates (Healy et al., 2008). Surface coatings that are either engineered onto the
nanomaterial or attached through transformations can strongly influence the solubility and
reactivity of the ENM. Nanoparticles may be transformed in water through any of the following
mechanisms (Lowry et al., 2012b; Wiesner et al., 2011):
• Nanoparticle aggregation;
• Formation of complexes with other molecules in water, soil, or biological
systems;
• Sorption processes;
• Degradation; and
• Dissolution of coatings or the core particle.
The interactions and transformations that occur are also dependent on the chemistry of
the environment, which will affect the mobility and bioavailability of the nanomaterial. In
addition, most nanomaterials in the environment tend to aggregate and do not exist as single,
dispersed nanoparticles in water (Zhang et al., 2008). The fate and common interactions of silver,
CNTs, and nano-TiC>2 with the aqueous environment are discussed below.
Silver nanoparticles readily form complexes with sulfur in various aqueous media,
which can transform the nanoparticle into many different forms. The nanoparticle can be
oxidized into silver ions or remain a nanoparticle and form complexes with other chemicals in
the environment, such as sulfur (Dale et al., 2013). Silver nanoparticle sulfidation has been
demonstrated in many environmental media, notably during activated sludge treatment in
wastewater treatment plants (WWTPs) (Doolette et al., 2013; Kim et al., 2010), in the laboratory
(Levard et al., 2011), and in the natural environment (Levard et al., 2012; Lowry et al., 2012a).
Researchers at CEINT constructed wetland mesocosms to study the long-term behavior of silver
nanoparticles. A study of polyvinylpyrrolidone-coated silver nanoparticles indicated that a
majority of the silver nanoparticles were transformed to silver-sulfide compounds and primarily
partitioned to soils and sediments (70 percent by weight) (Lowry et al., 2012a). Researchers at
Carnegie Mellon University reported that silver nanoparticles are transformed to similar
chemical forms as bulk silver in a pilot WWTP (Ma et al., 2013).
TiCh nanoparticles are highly reactive with sunlight and can act as catalysts. This
behavior can vary depending on the form and surface coatings of nano-TiO2, which has certain
implications for toxicity (U.S. EPA, 2010b). Nano-TiO2 is fairly soluble in water and solubility
increases when organic material is present. Studies on environmental transformations of nano-
TiO2 are limited (Liu et al., 2013). The nanoparticles have a strong tendency to form aggregates
at neutral pH, but aggregation strongly depends on the chemistry of the medium (Liu et al.,
2013).
Carbon nanotubes have a high affinity to partition to solid phases. However, CNTs may
stay suspended in water in aqueous environments with high concentrations of dissolved organic
6-7
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Section 6—New Data Sources and Additional Supporting Analyses
matter. The environmental transformations CNTs undergo are not well understood, and may vary
depending on the structure of the CNTs (Petersen et al., 2011). The chemistry of the environment
can also change the physiochemical properties of CNTs, which can affect their behavior. For
example, high-salinity environments increase CNT aggregation (Eckelman et al., 2012).
6.1.4.2 Wastewater Treatment
The transformation, fate and behavior, and treatment of nanomaterials in industrial
wastewaters have not been studied. However, their presence and fate has been studied in
municipal wastewater, in part to determine how well current municipal treatment systems
remove ENMs from wastewater. Common treatment technologies employed in municipal
WWTPs, such as activated sludge, settling, and filtration, are effective at removing
nanomaterials from the wastewater, although nanoparticles likely partition to the sewage sludge
(biosolids generated as a byproduct of wastewater treatment). More than 90 percent of
nanomaterials may leave wastewater by sorption to biomass and subsequent settling or filtration
during wastewater treatment; however, removal efficiency strongly depends on the size of the
nanomaterials (Westerhoff et al., 2011).
In addition, nanomaterials tend to aggregate in water, so conventional sedimentation
processes can be effective in removing nanomaterials from wastewater. Conventional
coagulation and sedimentation can remove 20 to 60 percent of total nanoparticles, as measured
by mass (Zhang et al., 2008). After conventional treatment, tertiary filtration processes can
further remove nanomaterials from the water. For example, WWTPs using microfiltration
removed TiO2 nanoparticles more effectively than those using conventional settling methods
(Westerhoff etal., 2011).
The applicability of municipal wastewater research to industrial wastewater is unknown.
Nanomaterial reactions and transformations may vary depending on the aqueous environments,
and industrial wastewater tends to have higher concentrations and varieties of constituents than
either municipal wastewater or the ambient environment. In addition, industrial wastewater
quality varies greatly between point source categories and industrial processes. For these reasons,
the behavior of nanomaterials in industrial wastewater treatment systems warrants further study.
6.1.4.3 Toxicity and Exposure
Though toxicity studies have been conducted, research has focused on ENM toxicity in
controlled laboratory environments using ENMs in the form in which they were created. To date,
EPA has not identified any studies on toxicity from exposures to ENMs in industrial wastewater.
Research on ENM toxicity, described below, largely has not considered relevant forms and
concentrations of nanomaterials that may be present in complex media, such as industrial
wastewater (Gottschalk and Nowack, 2011; Lowry et al., 2012b). In addition, few toxicity
studies have been conducted within complex media and ecosystems, where exposures will likely
be at lower concentrations and where a diversity of organisms is present (Colman et al., 2013).
The complex interactions and interdependences within an ecosystem, especially at the microbial
level, will influence the hazardous effects of ENMs. Some researchers recommend that fate and
toxicity measurements should be made in complex, natural systems in order to accurately assess
hazards (Lowry et al., 2012b; Wiesner et al., 2009).
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Section 6—New Data Sources and Additional Supporting Analyses
ENM toxicity testing has shown adverse effects on aquatic organisms and the
environment. The primary toxicity mechanism for silver nanomaterials is their dissolution into
silver ions (Arnaout and Gunsch, 2012; Nowack et al., 2011). Silver ions cause oxidative stress
in microorganisms and aquatic organisms (Yang et al., 2012), but toxic impacts in humans are
only observed at very high concentrations (Nowack et al., 2011). However, it is unclear whether
silver nanoparticles exhibit novel toxicity mechanisms, outside of generating silver ions.
Therefore, the observed toxicity effects in silver nanoparticles may not differ from those of bulk
or colloidal silver (Nowack et al., 2011).
Titanium dioxide nanomaterials may exhibit ecotoxicity impacts because of their
catalytic surfaces (Hochella, 2013). Nano-TiO2 can be activated by sunlight to produce reactive
oxygen species, which cause cellular damage. Nano-TiO2 has been shown to suppress the growth
of freshwater green algae, which is a concern for freshwater habitats (Cardinale et al., 2012).
Researchers have observed photo-dependent mortality effects in model organisms exposed to
nano-TiO2 in the part per billion range (Alloy and Roberts, 2012; Heideman et al., 2012). This
implies that exposure to sunlight in ecosystems with nano-TiCh may threaten organisms in
shallow surface waters and soils. However, more research is needed to determine nano-TiCh
impacts on aquatic ecosystems and microorganisms in particular.
A main mechanism for carbon nanotubes toxicity is the production of reactive oxygen
species, which is strongly affected by nanotube structure, as the ability to generate reactive
oxygen species may increase as the size of the nanotubes decrease (Chae et al., 2011). Various
studies have shown that exposure to CNTs can cause growth inhibition, hatching delays, and
mortality in some aquatic organisms (Petersen et al., 2011).
Though the majority of toxicity studies to date were conducted using untransformed
nanoparticles in laboratory environments, toxicity studies conducted in simulated natural
environments (mesocosms) and natural environments have reported fewer toxic effects. This
suggests that ENM impacts are affected and potentially dampened by environmental
transformations, microbial activity, and the physical and chemical properties of the environment
(Colman et al., 2012; Unrine et al., 2012). For example, researchers at CEINT have shown that
the short-term impacts of silver nanoparticles on microbes are attenuated by stream water and
sediment (Colman et al., 2012). However, even low doses of silver nanoparticles may have
appreciable effects on an environment, such as shifting wetland microorganism populations
(Colman etal., 2013).
Currently, human health effects of nanomaterials in any environmental medium are not
fully understood, but risks are presumed to be rather low. However, there have been recent
efforts to minimize airborne exposure to nanomaterials in the workplace due to concern for
inhalation hazards. In 2013, the National Institute for Occupational Safety and Health (NIOSH)
published guidelines to minimize workplace exposure to nanomaterials (NIOSH, 2013). In
addition, the Occupational Safety and Health Administration (OSHA) published recommended
best practices and exposure limits for airborne CNTs and nano-TiO2(OSHA, 2013). While
airborne exposure is not a direct concern for the Effluent Guidelines Program, concerns about
airborne ENM concentrations may increase future use of wet scrubbers for air pollution control,
with possible generation of an ENM-containing wastewater.
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Section 6—New Data Sources and Additional Supporting Analyses
Biosolids generated from wastewater treatment are often used as fertilizers, and land
application of biosolids is considered a potential major source of environmental exposure to
ENMs (Lowry et al., 2012b; Westerhoff et al., 2013). Researchers have identified and
characterized silver and TiCh nanoparticles in U.S. municipal wastewater sludge samples, which
raises concerns about this potential exposure pathway (Kim et al., 2010; Kim et al., 2012).
To estimate the potential exposure and risk to aquatic organisms, researchers have
developed models that predict the ENM concentrations in the environment. Researchers at the
Swiss Federal Laboratories for Materials Testing and Research (Empa) calculated predicted
environmental concentrations (PECs) of several ENMs in WWTP effluent (from a combination
of industrial and domestic sources) and surface waters in the U.S. based on probabilistic material
flow analysis of current production volumes (Gottschalk et al., 2009). As shown in Table 6-2, the
PECs of ENMs in WWTP effluent are orders of magnitude larger than what is predicted for
surface waters. The researchers then compared the PECs to predicted no effect concentrations
(PNEC) from ecotoxicological studies and concluded that silver and TiO2 ENMs in WWTP
effluent may pose a risk to aquatic organisms based on their risk quotients (Table 6-2). A risk
quotient greater than one indicates a need to further evaluate the risks posed to aquatic
organisms.
Table 6-2. Calculated Model Values for Predicted Environmental Concentrations of
Engineered Nanomaterials in the U.S.
Engineered
Nanomaterial
Silver
Nano-TiCh
CNTs
Fullerenes
Predicted Environmental
Concentration (PEC) (ng/L)
WWTP Effluent
21.0
1,750
8.6
4.6
Surface Water
0.116
2.0
0.001
0.003
WWTP Effluent Risk Quotient
(PEC/PNEC)
WWTP Effluent
30.1
1.8
O.0005
0.023
Surface Water
0.17
0.002
O.0005
O.0005
Source: Gottschalk et al. (2009)
Risk quotients greater than one are indicated in bold.
The Empa model was based on estimated worldwide production volumes, which are
incomplete and uncertain. Therefore, the significance of the Empa study's results to the U.S. is
uncertain. The results do suggest, however, that aquatic ecosystems may be at risk from exposure
to silver and TiO2 ENMs released into the environment, though the study did not clearly
distinguish between the impact of potential inputs from manufacturing, processing, and
dissolution or degradation of ENMs from end-use products. In the absence of discharge data,
quantifying production and waste volumes for industrial ENM manufacturing and processing is
critical for developing models that accurately assess the risk associated with environmental
releases.
6.1.5 A nalytical Methods
Methods for detecting, quantifying, and characterizing nanomaterials in complex
environmental media, like industrial wastewater, are not fully developed; many of the analytical
methods developed to date characterize pure nanomaterials in simple media. With additional
research, some of these methods may be refined and adapted to characterize ENMs in complex
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Section 6—New Data Sources and Additional Supporting Analyses
environmental media. Table 6-3 lists some of the current efforts to develop analytical methods
forENMs. The organizations listed (among others) are currently researching and developing
analytical methods to characterize ENMs in both simple and complex media. There is also
significant effort under way to develop new tools to characterize nanomaterials in the
environment. Currently, more research characterizing analytical method development for metal-
containing nanomaterials in complex media has been published than for carbon-based
nanomaterials.
Table 6-3. Research Organizations Developing Analytical Methods for ENMs
Organization
EPA Office of Research and Development,
National Exposure Research Laboratory
Environmental Sciences Division
(EPA ORD/NERL/ESD)
Swiss Federal Institute of Aquatic Science
and Technology (Eawag)
Center for the Environmental Implications of
Nanotechnology (CEINT)
University of California's Center for
Environmental Implications of
Nanotechnology (UC-CEIN)
Arizona State University (ASU)
Trent University (Ontario, Canada)
Binghamton University, State University of
New York
Analytical Method
Screening and characterization
methods
Electron microscopy, mobile laser-
induced breakdown detection
Testing protocols; hyperspectral
imagery with enhanced darkfield
microscopy
Testing protocols; microscopic and
spectroscopic methods
Detection and characterization of
ENMs during water treatment and
monitoring in complex media
Monitoring in complex media
Membrane sensor to detect and
quantify ENMs
Nanomaterial
Metal-containing
nanomaterials
Not specified
Silver, TiO2 and other
metal-oxides
Metal oxides, CNTs,
and others not
specified
Silver, TiO2, CNTs
Silver
Silver, TiO2, and
quantum dots
Many U.S. and international organizations are working to develop guidance and
standards for ENM characterization. These organizations include, but are not limited to,
standard-setting groups such as the International Standardization Organization, ASTM
International, and the American National Standards Institute; U.S. federal research led by the
National Institute of Standards and Technology (NIST) is also relevant (NNI, 2013b). The
Organization for Economic Co-operation and Development has published guidance for safety
testing and characterization of toxicological properties of ENMs. It is recognized as a living
document, subject to refinement as research into the development of nanomaterial test methods
progresses (OECD, 2012).
Because method development is in its infancy, EPA has not approved standardized
methods for sampling, detecting, monitoring, quantifying, or characterizing nanomaterials in
aqueous media. This is a critical area of research because the ability to detect and characterize
nanomaterials is essential to understanding the implications of their release into the environment
(U.S. EPA, 2010a). The National Nanotechnology Initiative (NNI) identified the development of
devices to detect and identify ENMs across their life cycles as a priority; through its initiatives,
NNI aims to accelerate research. The NNI strategic plan and research priorities are further
described in Section 6.1.6. Standard method development will also support research into the
environmental implications of nanomaterials and especially aid in fate and transport research
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Section 6—New Data Sources and Additional Supporting Analyses
needed for more accurate exposure and risk assessments. EPA-approved methods are also
needed before EPA can consider regulating discharges of ENMs in industrial wastewater.
Once standardized methods are developed to detect, characterize, and quantify ENMs
discharges to, and concentrations in, the environment, strategies will be needed to distinguish
between engineered and naturally occurring nanomaterials to fully inform monitoring.
Engineered and naturally occurring nanoparticles are often indistinguishable under a microscope
(Hochella, 2013; Wiesner et al., 2011). For example, TiCh nanoparticles that are identical to
engineered nanoparticles have been found in rivers that do not receive wastewater discharges and
are remote from industrial activities (Hochella, 2013). In addition, background levels of naturally
occurring nanomaterials, as well as nanomaterials incidentally generated during nanomaterial
processing as a result of chemical transformations, may need to be considered as part of any
future potential regulatory structure for industrial discharges of ENMs.
6.1.6 Federal Research and the National Nanotechnology Initiative
The NNI is a collaborative, interagency U.S. government research and development
initiative. The NNI provides a framework for individual and cooperative nanotechnology-related
activities for 20 federal department and agency units, including EPA, with a range of research
and regulatory roles and responsibilities. The NNI expedites the discovery, development, and
deployment of nanoscale science and technology to serve the public good; this is accomplished
through a program of coordinated research and development aligned with the missions of the
participating agencies (NNI, 2013a). NNI agencies and academic research centers coordinate
research that may facilitate EPA's understanding of the potential for wastewater discharges from
ENM manufacture and processing and potential impacts on the environment.
The 2014 NNI Strategic Plan describes the high-level goals, priorities, and specific
objectives, for at least the next three years, related to nanotechnology research but does not
provide performance measures or timeframes for meeting the objectives (NSET, 2014). The NNI
Strategic Plan describes several areas of research focused on the environmental, health, and
safety implications of nanotechnology (NSET, 2014). A subset of these research areas, listed
below, may inform EPA's understanding of the presence and impact of nanomaterials in
industrial wastewater discharge:
• Nanomaterial measurement infrastructure;
• Predictive modeling and informatics;
• Human exposure and health;
• Environmental health; and
• Risk assessment and risk management.
The NNI Strategic Plan also establishes Nanotechnology Signature Initiatives to spotlight
topical areas that exhibit particular promise, existing effort, and significant opportunity, and to
accelerate their development (NSET, 2014). One initiative in particular applies to the needs of
the Effluent Guidelines program: Nanotechnology for Sensors and Sensors for Nanotechnology.
This initiative aims, in part, to support research and development methods and devices to detect
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Section 6—New Data Sources and Additional Supporting Analyses
and identify ENMs across their life cycles; this will allow researchers to assess the potential
human health and environment impacts of ENMs.
NNI member agencies also fund much of the ongoing research discussed in this section
(e.g., research by the National Science Foundation, NIST, NIOSH, OSHA, and others). In
particular, EPA supports research on environmental exposure, impacts, risk assessment, and
analytical method development through the National Center for Environmental Research and
extramural grant, fellowship, and research contract programs (NNI, 2013c).
6.1.7 Summary of Findings
Nanotechnology is a rapidly progressing field, expected to continue to grow as the
number of products and technological applications increases. Some manufacturing and
processing methods likely generate wastewater, potentially for each of the ENMs of interest
(silver, nano-TiCh, and CNTs), but the quantity generated and waste management practices are
not documented. ENM manufacturing and processing span multiple industrial categories, but
little progress has been made to date to quantify production volumes.
While some exposure hazards have been demonstrated, the environmental and human
health risks associated with these materials are largely unknown. Fate and toxicity assessments
for ENMs, in the forms and relevant concentrations to which organisms will be exposed, are
needed to accurately determine risk. Industrial wastewater releases of ENMs to the environment
have not been studied.
The growth in ENM manufacturing has been accompanied by some research into ENMs'
presence and fate in wastewater. Methods for detecting and characterizing nanomaterials in
complex media, including industrial wastewater, are under development. Research has also
shown that common treatment technologies employed in municipal WWTPs are effective at
removing nanomaterials from the wastewater, and some nanomaterials (e.g., silver, nano-TiCh)
have been detected in U.S. WWTP biosolids.
Despite the body of current research, ENMs present a challenge for environmental
monitoring, risk assessment, and regulation due to their small size, unique properties, and
complexity. EPA has not approved any standardized methods for sampling, detection, or
quantification of nanomaterials in aqueous media. New methods and means of quantification
need to be developed to understand the environmental implications of ENMs and inform future
regulatory decisions.
From its review of current literature and research, EPA has identified the following data
gaps and research appropriate to better assess the potential presence and impact of ENMs in
industrial wastewater:
• Development of standard methods and sampling techniques to detect and
characterize nanomaterials in industrial wastewater;
• Development of methods to distinguish between naturally occurring and
engineered nanomaterials in aqueous media;
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Section 6—New Data Sources and Additional Supporting Analyses
• Evaluation of ENM toxicity impacts and potential occurrence in industrial
wastewater, taking into consideration relevant forms and concentrations of ENMs;
• Identification of the universe of facilities, production volumes, and waste
generated and disposed of from ENM manufacturing and processing; and
• Evaluation and characterization of the fate, transformation, and treatment of
ENMs in industrial wastewaters.
While EPA, academic institutions and research centers, and international organizations
are currently researching many of these areas, more focused research is needed to understand the
hazards and implications from the environmental release of nanomaterials via industrial
wastewater discharges.
6.1.8 References for the Review of Engineered Nanomaterials in Industrial Wastewater
1. Alloy, M., and A. Roberts. 2012. Photo-enhanced toxicity of nano-titanium dioxide
(anatase) on freshwater zooplankton. Proceedings from the SETAC 33rd Annual
Meeting. Long Beach, California. (November 15). EPA-HQ-OW-2014-0170. DCN
08046.
2. Arnaout, C. L., and C.K. Gunsch. 2012. Impacts of silver nanoparticle coating on the
nitrification potential of nitrosomonas europaea. Environmental Science & Technology.
46(10): 5387-5395. www.dx.doi.org/10.1021/es204540z. EPA-HQ-OW-2014-0170.
DCN 08047.
3. Cardinale, B. J., R. Bier, and C. Kwan. 2012. Effects of TiCh nanoparticles on the growth
and metabolism of three species of freshwater algae. Journal of Nanoparticle Research.
14(8): 1-8. www.dx.doi.org/10.1007/sll051-012-0913-6. EPA-HQ-OW-2014-0170.
DCN 08048.
4. Chae, S. R., M. Therezien, J.F. Budarz, L. Wessel, S.H. Lin, Y. Xiao, and M.R. Wiesner.
2011. Comparison of the photosensitivity and bacterial toxicity of spherical and tubular
fullerenes of variable aggregate size. Journal of Nanoparticle Research. 13: 5121-5127.
EPA-HQ-OW-2014-0170. DCN 08049.
5. Colman, B. P., C.L. Arnaout, S. Anciaux, C.K. Gunsch, M.F. Hochella, B. Kim, G.V.
Lowry, B. M. McGill, B.C. Reinsch, CJ. Richardson, J.M. Unrine, J.P. Wright, L. Yin,
and E.S. Bernhardt. 2013. Low concentrations of silver nanoparticles in biosolids cause
adverse ecosystem responses under realistic field scenario. PLoS ONE. 8(2): e57189.
Available online at:
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0057189. EPA-HQ-OW-
2014-0170. DCN 08050.
6. Colman, B. P., S.Y. Wang, M. Auffan, M.R. Wiesner, and E.S., Bernhardt. 2012.
Antimicrobial effects of commercial silver nanoparticles are attenuated in natural
streamwater and sediment. Ecotoxicology. 21(7): 1867-1877.
www.dx.doi.org/10.1007/sl0646-012-0920-5.EPA-HQ-OW-2014-0170.DCN08051.
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1. Dale, A. L., G.V. Lowry, and E.A. Gasman. 2013. Modeling nanosilver transformations
in freshwater sediments. Environmental Science & Technology. 47(22): 12920-12928.
www.dx.doi.org/10.1021/es402341t. EPA-HQ-OW-2014-0170. DCN 08052.
8. Doolette, C. L., MJ. McLaughlin, J.K. Kirby, DJ. Batstone, H. H. Harris, H. Ge, and G.
Cornells. 2013. Transformation of PVP coated silver nanoparticles in a simulated
wastewater treatment process and the effect on microbial communities. Chemistry
Central Journal 7(1): 46. (March 4). EPA-HQ-OW-2014-0170. DCN 08053.
9. Eckelman, M. J., M.S. Mauter, J.A. Isaacs, and M. Elimelech. 2012. New perspectives on
nanomaterial aquatic ecotoxicity: Production impacts exceed direct exposure impacts for
carbon nanotoubes. Environmental Science & Technology. 46(5): 2902-2910.
www.dx.doi.org/10.1021/es203409a. EPA-HQ-OW-2014-0170. DCN 08054.
10. ERG. 2008. Eastern Research Group, Inc. Sampling and Analysis ofNanomaterials in the
Environment: A State-Of-The-Science Review [Final Report]. (August). EPA-HQ-OW-
2014-0170. DCN 08055.
11. ERG. 2013. Eastern Research Group, Inc. Environmental Engineering Support for Clean
Water Regulations Programmatic Quality Assurance Project Plan (PQAPP, Rev. 1,
Approved October 20, 2013). EPA-HQ-OW-2010-0824. DCN 07754.
12. ERG. 2014. Eastern Research Group, Inc. EngineeredNanomaterials EndNote Reference
Library. (August). EPA-HQ-OW-2014-0170. DCN 08056.
13. ERG. 2015. Eastern Research Group, Inc. Engineered Nanomaterials in Industrial
Wastewater: Literature Review and Implications for 304m. (January). EPA-HQ-OW-
2014-0170. DCN 08108.
14. Fabrega, J., S.N. Luoma, C.R. Tyler, T.S. Galloway, and J.R. Lead. 2011. Silver
nanoparticles: Behaviour and effects in the aquatic environment. Environment
International. 37(2): 517-531. www.dx.doi.org/10.1016/j.envint.2010.10.012. EPA-HQ-
OW-2014-0170. DCN 08058.
15. Gavankar, S., S. Suh, and A. Keller. 2012. Life cycle assessment at nanoscale: Review
and recommendations. The InternationalJournal of Life Cycle Assessment. 17(3): 295-
303. www.dx.doi.org/10.1007/sll367-011-0368-5. EPA-HQ-OW-2014-0170. DCN
08059.
16. Gottschalk, F., and B. Nowack. 2011. The release of engineered nanomaterials to the
environment. Journal of Environmental Monitoring. 13(5): 1145-1155. EPA-HQ-OW-
2014-0170. DCN 08060.
17. Gottschalk, F., T. Sonderer, R.W. Scholz, and B. Nowack. 2009. Modeled environmental
concentrations of engineered nanomaterials (TiO2, ZnO, Ag, CNT, fullerenes) for
different regions. Environmental Science & Technology. 43(24): 9216-9222.
www.dx.doi.org/10.1021/es9015553. EPA-HQ-OW-2014-0170. DCN 08061.
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Section 6—New Data Sources and Additional Supporting Analyses
18. Healy, M. L., LJ. Dahlben, and J.A. Isaacs. 2008. Environmental assessment of single-
walled carbon nanotube processes. Journal of Industrial Ecology. 12(3): 376-393.
www.dx.doi.org/lO.llll/j. 1530-9290.2008.00058.x. EPA-HQ-OW-2014-0170. DCN
08062.
19. Heideman, W., O. Bar-Han, R. Peterson, J. Pedersen, and H. Robert. 2012. TiO2
nanoparticle exposure and illumination during zebrafish development: Mortality at parts
per billion concentrations. Proceedings from the SETAC 33rd Annual Meeting. Long
Beach, California. Available online at:
http://longbeach.setac.org/sites/default/files/SETAC-abstract-book-2012.pdf
EPA-HQ-OW-2014-0170. DCN 08063.
20. Hendren, C. O., X. Mesnard, J. Droge, and M.R. Wiesner. 2011. Estimating production
data for five engineered nanomaterials as a basis for exposure assessment. Environmental
Science & Technology. 45: 2562-2569. EPA-HQ-OW-2014-0170. DCN 08064.
21. Hochella, M. F. 2013. Telephone Communication between Michael Hochella, Virginia
Tech, and Eva Knoth and Kim Wagoner, Eastern Research Group, Inc. Re: Request for
Information on Nanomaterials Research.(March 15). EPA-HQ-OW-2014-0170. DCN
08065.
22. Hochella, M. F., S.K. Lower, P.A. Maurice, R.L. Penn, N. Sahai, D. Sparks, and B.S.
Twining. 2008. Nanominerals, mineral nanoparticles, and earth systems. Science.
319(5870): 1631-1635. www.dx.doi.org/10.1126/science.1141134. EPA-HQ-
OW-2014-0170. DCN 08066.
23. Kim, B., M. Murayama, B.P. Colman, and M.F. Hochella. 2012. Characterization and
environmental implications of nano- and larger TiO2 particles in sewage sludge, and soils
amended with sewage sludge. Journal of Environmental Monitor ing. 14(4): 1128-1136.
www.dx.doi.org/10.1039/C2EM10809G. EPA-HQ-OW-2014-0170. DCN 08067.
24. Kim, B., C.S. Park, M. Murayama, and M.F. Hochella. 2010. Discovery and
characterization of silver sulfide nanoparticles in final sewage sludge products.
Environmental Science & Technology. 44(19). www.dx.doi.org/10.1021/esl01565j. EPA-
HQ-OW-2014-0170. DCN 08068.
25. Levard, C., E.M. Hotze, G.V. Lowry, and G.E. Brown. 2012. Environmental
transformations of silver nanoparticles: Impact on stability and toxicity. Environmental
Science & Technology, www.dx.doi.org/10.1021/es2037405. EPA-HQ-OW-2014-0170.
DCN 08069.
26. Levard, C., B.C. Reinsch, F.M. Michel, C. Oumahi, G.V. Lowry, and G.E. Brown. 2011.
Sulfidation processes of PVP-coated silver nanoparticles in aqueous solution: Impact on
dissolution rate. Environmental Science & Technology. ¥5(12): 5260-5266.
www.dx.doi.org/10.1021/es2007758. EPA-HQ-OW-2014-0170. DCN 08070.
27. Liu, X., G. Chen, A. A. Keller, and C. Su. 2013. Effects of dominant material properties
on the stability and transport of TiO2 nanoparticles and carbon nanotubes in aquatic
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Section 6—New Data Sources and Additional Supporting Analyses
environments: from synthesis to fate. Environmental Science: Processes & Impacts.
15(1): 169-189. EPA-HQ-OW-2014-0170. DCN 08071.
28. Lowry, G. V., B.P. Espinasse, A.R. Badireddy, CJ. Richardson, B.C. Reinsch, L.D.
Bryant, AJ. Bone, A. Deonarine, S. Chae, M. Therezien, B.P. Colman, H. Hsu-Kim, E.S.
Bernhardt, C.W., Matson, and M.R. Wiesner. 2012a. Long-term transformation and fate
of manufactured Ag nanoparticles in a simulated large scale freshwater emergent
wetland. Environmental Science & Technology. 46(13): 7027-7036.
www.dx.doi.org/10.1021/es204608d. EPA-HQ-OW-2014-0170. DCN 08072.
29. Lowry, G. V., K.B. Gregory, S.C. Apte, and J.R. Lead. 2012b. Transformations of
nanomaterials in the environment. Environmental Science & Technology. 46(13): 6893-
6899. www.dx.doi.org/10.1021/es300839e. EPA-HQ-OW-2014-0170. DCN 08073.
30. Ma, R., C. Levard, J.D. Judy, J.M. Unrine, M. Durenkamp, B. Martin, B. Jefferson, and
G.V. Lowry. 2013. Fate of zinc oxide and silver nanoparticles in a pilot wastewater
treatment plant and in processed biosolids. Environmental Science & Technology.
www.dx.doi.org/10.1021/es403646x. EPA-HQ-OW-2014-0170. DCN 08074.
31. Mueller, N. C., and B. Nowack. 2008. Exposure modeling of engineered nanoparticles in
the environment. Environmental Science & Technology. 42(12): 4447-4453.
www.dx.doi.org/10.1021/es7029637. EPA-HQ-OW-2014-0170. DCN 08075.
32. Mulfmger, L., S.D. Solomon, M. Bahadory, A.V. Jeyarajasingam, S.A. Rutkowsky, and
C. Boritz. 2007. Synthesis and study of silver nanoparticles. Journal of Chemical
Education. 84(2): 322. EPA-HQ-OW-2014-0170. DCN 08076.
33. Musee, N. 2011. Nanowastes and the environment: Potential new waste management
paradigm. Environment International. 37(1): 112-128.
www.dx.doi.org/10.1016/j.envint.2010.08.005. EPA-HQ-OW-2014-0170. DCN 08077.
34. NIOSH. 2013. National Institute for Occupational Safety and Health. Current Strategies
for Engineering Controls in Nanomaterial Production and Downstream Handling
Processes. Cincinnati, OH. (November). DHHS (NIOSH) Publication No. 2014-102.
EPA-HQ-OW-2014-0170. DCN 08078.
35. NNI. 2013a. National Nanotechnology Initiative. About the NNI. Available online at:
http://nano.gov/about-nni. EPA-HQ-OW-2014-0170. DCN 08079.
36. NNI. 2013b. National Nanotechnology Initiative. Standards for nanotechnology.
Available online at: http://nano.gov/you/standards. EPA-HQ-OW-2014-0170. DCN
08080.
37. NNI. 2013c. NSI: Nanotechnology for sensors and sensors for nanotechnology:
Improving and protecting health, safety, and the environment. Available online at:
http://www.nano.gov/NSISensors. EPA-HQ-OW-2014-0170. DCN 08081.
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38. Nowack, B., H.F. Krug, and M. Height. 2011. 120 years of nanosilver history:
Implications for policy makers. Environmental Science & Technology. 45(4): 1177-1183.
www.dx.doi.org/10.1021/esl03316q. EPA-HQ-OW-2014-0170. DCN 08082.
39. NSET. 2014. National Science and Technology Council, Committee on Technology,
Subcommittee on Nanoscale Science, Engineering, and Technology. National
Nanotechnology Initiative Strategic Plan. Washington, D.C. (February). Available online
at: http://www.nano.gov/sites/default/files/pub_resource/2014_nni_strategic_plan.pdf.
EPA-HQ-OW-2014-0170. DCN 08083.
40. OECD. 2012. Organisation for Economic Co-operation and Development. Guidance on
Sample Preparation and Dosimetry for the Safety Testing of Manufactured
Nanomaterials Series on the Safety of Manufactured Nanomaterials. (December 18).
Available online at:
http://search.oecd.org/officialdocuments/displaydocumentpdf/?cote=env/jm/mono(2012)
40&doclanguage=en. EPA-HQ-OW-2014-0170. DCN 08084.
41. OSHA. 2013. Occupational Saftey and Health Administration. OSHA Fact Sheet:
Working Safely with Nanomaterials. Available online at:
https://www.osha.gov/Publications/OSHA_FS-3634.pdf EPA-HQ-OW-2014-0170. DCN
08085.
42. Petersen, E. I, L. Zhang, N.T. Mattison, D.M. O'Carroll, AJ. Whelton, N. Uddin, T.
Nguyen, Q. Huang, T.B. Henry, R.D. Holbrook, and K.L. Chen. 2011. Potential release
pathways, environmental fate, and ecological risks of carbon nanotubes. Environmental
Science & Technology. 45(23): 9837-9856. www.dx.doi.org/10.1021/es201579y. EPA-
HQ-OW-2014-0170. DCN 08086.
43. Project on Emerging Nanotechnologies. 2014. Consumer Products Inventory. Available
online at: http://www.nanotechproject.org/cpi. EPA-HQ-OW-2014-0170. DCN 08087.
44. Robichaud, C. O., A.E. Uyar, M.R. Darby, L.G. Zucker, and M.R., Wiesner. 2009.
Estimates of upper bounds and trends in nano-TiO2 production as a basis for exposure
assessment. Environmental Science & Technology. 43: 4227-4233. EPA-HQ-OW-2014-
0170. DCN 08088.
45. SETAC. 2012. Society of Environmental Toxicology and Chemistry. SETAC North
America 33rd Annual Meeting Abstract Book. Long Beach, California. (November 15).
Available online at: http://longbeach.setac.org/sites/default/files/SETAC-abstract-book-
2012.pdf. EPA-HQ-OW-2014-0170. DCN 08089.
46. U.S. EPA. 2010a. Characterizing Concentrations and Size Distributions of Metal-
Containing Nanoparticles in Waste Water. Washington, D.C. EPA/600/R-10/117. EPA-
HQ-OW-2014-0170. DCN 08090.
47. U.S. EPA. 2010b. Nanomaterial Case Studies: Nanoscale Titanium Dioxide in Water
Treatment and in Topical Sunscreen. Washington, D.C. EPA/600/R-09/057F. EPA-HQ-
OW-2014-0170. DCN 08091.
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48. U.S. EPA. 201 la. Final 2010 Effluent Guidelines Program Plan. Washington, D.C.
(October). EPA-HQ-OW-2008-0517-0575.
49. U.S. EPA. 201 Ib. Nanotechnology basic information. Available online at:
http://epa.gov/ncer/nano/questions/. EPA-HQ-OW-2014-0170. DCN 08092.
50. U.S. EPA. 2013a. Nanomaterials EPA is assessing. (February 12). Available online at:
http://www.epa.gov/nanoscience/quickfmder/nanomaterials.htm#carnan. EPA-HQ-OW-
2014-0170. DCN 08093.
51. U.S. EPA. 2013b. Nanoscale Materials Stewardship Program. Available online at:
http://epa.gov/oppt/nano/stewardship.htm. EPA-HQ-OW-2014-0170. DCN 08094.
52. U.S. EPA. 2013c. Response to Comments for the Final 2010 Effluent Guidelines
Program Plan. Washington, D.C. (May) EPA-HQ-OW-2010-0824-0196.
53. U.S. EPA. 2013d. Significant New Use Rules on Certain Chemical Substances.
Washington, D.C. (August 7). EPA-HQ-OPPT-2013-0399-0001.
54. U.S. EPA. 2013e. Significant New Use Rules on Certain Chemical Substances.
Washington, D.C. (June 26). EPA-HQ-OPPT-2010-0279-0134.
55. Unrine, J. M., P. Bertsch, O. Tsyusko, W.A. Shoults-Wilson, G.V. Lowry, B.P. Colman,
and E.S. Bernhardt. 2012. Fate and effects of silver nanoparticles in terrestrial
environments. Proceedings from the SETAC 33rd Annual Meeting, Long Beach,
California. (November 15). EPA-HQ-OW-2014-0170. DCN 08095.
56. Westerhoff, P., G. Song, K. Hristovski, and M.A. Kiser. 2011. Occurrence and removal
of titanium at full scale wastewater treatment plants: implications for TiO2nanomaterials.
Journal of Environmental Monitoring. 13(5): 1195-1203.
www.dx.doi.org/10.1039/cleml0017c. EPA-HQ-OW-2014-0170. DCN 08096.
57. Westerhoff, P. K., M.A. Kiser, and K. Hristovski. 2013. Nanomaterial removal and
transformation during biological wastewater treatment. Environmental Engineering
Science. 30(3): 109-117. www.dx.doi.org/10.1089/ees.2012.0340. EPA-HQ-OW-2014-
0170. DCN 08097.
58. Wiesner, M. 2013. Telephone Communication between Mark Wiesner, Duke University,
and Eva Knoth and Kim Wagoner, Eastern Research Group, Inc. Re: Request for
Information on Nanomaterials Research.(March 13). EPA-HQ-OW-2014-0170. DCN
08098.
59. Wiesner, M. R., G.V. Lowry, E. Casman, P.M. Bertsch, C.W. Matson, R.T. Di Giulio, J.
Liu, and M.F. Hochella. 2011. Meditations on the ubiquity and mutability of nano-sized
materials in the environment. ACSNano. 5(11): 8466-8470.
www.dx.doi.org/10.1021/nn204118p. EPA-HQ-OW-2014-0170. DCN 08099.
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60. Wiesner, M. R., G.V. Lowry, K.L. Jones, M.F. Hochella, R.T. Di Giulio, E. Gasman, and
E.S. Bernhardt. 2009. Decreasing uncertainties in assessing environmental exposure, risk,
and ecological implications of nanomaterials. Environmental Science & Technology.
43(17): 6458-6462. www.dx.doi.org/10.1021/es803621k. EPA-HQ-OW-2014-0170.
DCN 08100.
61. Yang, X., A.P. Gondikas, S.M. Marinakos, M. Auffan, J. Liu, H. Hsu-Kim, and IN.
Meyer. 2012. Mechanism of silver nanoparticle toxicity is dependent on dissolved silver
and surface coating in Caenorhabditis elegans. Environmental Science & Technology.
46(2): 1119-1127. www.dx.doi.org/10.1021/es202417t. EPA-HQ-OW-2014-0170. DCN
08101.
62. Zhang, Y., Y. Chen, P. Westerhoff, K. Hristovski, and J.C. Crittenden. 2008. Stability of
commercial metal oxide nanoparticles in water. Water Research. 42(8-9): 2204-2212.
EPA-HQ-OW-2014-0170. DCN 08102.
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6.2 Review of Industrial Wastewater Treatment Technologies
The Clean Water Act (CWA) directs EPA to establish Effluent Limitations Guidelines
and Standards (ELGs) based on the performance of particular treatment technologies, application
of best management practices, or implementation of process changes. As described in EPA's
2002 Draft National Strategy (67 FR 71165), EPA considers several factors when developing its
Effluent Guidelines Program Plans, including the availability of wastewater treatment
technologies. EPA may choose to revise existing ELGs for a point source category if it identifies
an applicable and demonstrated technology, process change, or pollution prevention approach
that would reduce the concentrations of pollutants in the discharged wastewater and,
consequently, reduce the hazard to human health or the environment associated with the
pollutant discharges.
Traditionally, EPA has reviewed the use and availability of improved treatment
technologies when conducting specific facility, industry, and/or pollutant evaluations. In 2012,
the Government Accountability Office (GAO) examined the Effluent Guidelines Program,
including 1) the process EPA follows to screen and review industrial categories potentially
needing new or revised guidelines, 2) any limitations to the process that could hinder EPA's
effectiveness in advancing CWA goals, and 3) EPA's actions to address any such limitations
(U.S. GAO, 2012). GAO's review determined that EPA focused its screening phase on the
hazards associated with industrial categories without considering the availability of treatment
technologies or process changes that could reduce those hazards. As a result, GAO concluded
that the screening phase of the process might exclude some industrial categories for which
treatment technologies or production changes may be available to serve as the basis for new or
revised effluent guidelines.
EPA recognizes the need for a more coordinated approach to considering advances in
treatment technologies across all industries as part of its initial screening of effluent guidelines.
Furthermore, EPA believes it is important to consider technology advances when evaluating the
effectiveness of older ELGs, some of which date back to the late 1970s or early 1980s. In some
cases, more advanced treatment may be available that would allow EPA to establish ELGs for
new pollutants or to strengthen existing requirements for regulated pollutants. As a result, in its
Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans (79 FR 55472), EPA
announced that it had initiated a review of relevant literature to document the performance of
new and improved industrial wastewater treatment technologies. This included plans to capture
these performance data in a searchable Industrial Wastewater Treatment Technology (IWTT)
Database. EPA intends to use IWTT as part of its annual reviews to quantify the effectiveness of
technologies for removing pollutants of concern from specific industrial wastewater discharges.
EPA will use the database, in part, to answer the following questions:
• What new technologies or changes to existing technologies are specific industries
using to treat their waste streams?
• Are there technologies that can reduce or eliminate wastewater pollutants not
currently regulated by ELGs, or remove pollutants to a greater degree than
industries currently achieve?
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Section 6—New Data Sources and Additional Supporting Analyses
The IWTT Database, which is responsive to GAO's recommendation for the Effluent
Guidelines Program, will be a critical tool for enhancing EPA's ability to identify industrial
categories or pollutants that warrant further review for new or revised ELGs, particularly based
on improvements in treatment technologies.
This section summarizes the literature EPA has evaluated to date for inclusion in IWTT,
describes the database structure and data elements captured, and provides an overview and
detailed output of the data collected thus far. The data collection methodology, data sources, data
quality assurance and control criteria, and the proposed plan for data storage are described in
detail in EPA's 2012 Annual Effluent Guidelines Review Report (2012 Annual Review Report)
(U.S. EPA, 2014a).
6.2.1 Industrial Wastewater Treatment Technologies Data Collection Results
To date, EPA's efforts to build and populate IWTT have included two literature reviews
to collect information on wastewater treatment performance (U.S. EPA, 2014a). EPA first
conducted a brief and general literature search for studies that documented pilot- or full-scale
performance data for industrial wastewater treatment technologies in 2011. This initial literature
search assessed the availability and quality of industrial treatment technology performance data.
In addition, EPA evaluated the feasibility of developing a searchable database that it could use as
a tool to screen industrial wastewater discharges based on advances in treatment.
As described in EPA's 2012 Annual Review Report, a follow-on literature search in 2012
and 2013 yielded more comprehensive wastewater treatment performance data related to a few
key industries of interest (U.S. EPA, 2014a). These industries included petroleum refining (40
CFR Part 419), metal finishing (40 CFR Part 433), and electroplating (40 CFR Part 413), as well
as metals removal in general. Using the key words indicated in Appendix E, EPA reviewed data
on new or improved treatment technology performance related to these industries from the
following technical literature sources:
• Conference proceedings. EPA reviewed references from three key technical
conferences on wastewater that included presentations across a broad range of
industries: the Water Environment Federation's Technical Exhibit and Conference
(2000-2013), the International Water Conference (2011), and the Water
Environment Federation's Industrial Wastewater Seminar (2011).
• Water-related journals. EPA reviewed peer-reviewed journal articles from water-
related societies that may provide information on new, more effective industrial
wastewater treatment technologies.
• Industry-specific organizations. EPA reviewed industry trade organization
publications, such as treatment publications from the American Petroleum
Institute and the American Chemical Society.
EPA screened all identified literature and data sources against the established data quality
criteria described in Section 6.6.1.3 of the 2012 Annual Review Report (U.S. EPA, 2014a) and
the Supplemental Quality Assurance and Control Plan for Development and Population of the
Industrial Wastewater Treatment Database (ERG, 2013).
6-22
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Section 6—New Data Sources and Additional Supporting Analyses
To date, EPA has identified and screened 283 articles. Of those, 163 met the quality
criteria and were entered into IWTT (See Appendix F for a bibliography of the articles currently
included in the database). Table 6-4 provides an overview of the number of industries
represented in IWTT as well as the degree to which EPA has collected relevant literature
describing new or improved treatment technologies.
Table 6-4. Frequency of Industries Represented in IWTT
Industry
Petroleum refining
Metal finishing
Nonclassifiable establishments (industry not provided)
Coal mining
Oil and gas extraction
Steam electric power generating
Ore mining and dressing
Miscellaneous foods and beverages
Meat and poultry products
Pharmaceutical manufacturing
Pulp, paper and paperboard
Organic chemicals, plastics and synthetic fibers
Electrical and electronic components
Iron and steel manufacturing
Textile mills
Nonferrous metals manufacturing
Aluminum forming
Canned and preserved fruits and vegetables processing
Centralized waste treatment
Dairy products processing
Inorganic chemicals manufacturing
Grain mills
Fertilizer manufacturing
Mineral mining and processing
Hospital
Leather tanning and finishing
Transportation equipment cleaning
Agricultural services
CAFO
Wholesale trade - durable goods
PSC
419
433
-
434
435
423
440
-
432
439
430
414
469
420
410
421
467
407
437
405
415
406
418
436
460
425
442
-
412
-
Number of Articles"
31
21
14
13
13
11
9
9
5
5
4
4
3
3
3
3
2
2
2
2
2
1
1
1
1
1
1
1
1
1
6-23
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-4. Frequency of Industries Represented in IWTT
Industry
Airport deicing
Ferroalloy manufacturing
PSC
449
424
Number of Articles"
1
1
a Some articles may describe wastewater treatment technologies for more than one industry.
6.2.2 Industrial Wastewater Treatment Technologies Database Structure and Data Elements
IWTT captures wastewater treatment technology data identified from the reviewed data
sources. This section describes the structure of the database and data elements in detail. EPA
structured IWTT in Microsoft Access™ to collect data on the following:
• Treatment systems (i.e., treatment units included in the system, unit order,
chemical additions, system operating conditions and costs, and process diagrams);
• Industries implementing the technologies or industries for which the technology
has been tested;
• Pollutants removed, including influent and effluent quality, and percent removals
achieved; and
• Specific industry motivations for evaluating and employing new technologies.
6.2.3 Database Structure
EPA created several data tables in IWTT to organize article information and minimize
redundancy and dependency within the database (ERG, 2013). Table 6-5 provides a brief
description of the primary data input tables. EPA also established several lookup tables, which
provide guidance or selection options for populating specific data input fields. Appendix H
contains each of the key lookup tables.
Table 6-5. List of Data Input Tables
Table Name
Table Description
Where to Find More
Information
Input Data (Data Obtained from the Articles)
1 INPUT Reference Information
2 INPUT Treatment Technology
2_INPUT_Treatment_Technology
_Codes
3_INPUT_Detection_Limits
4_INPUT_Performance_Data
Contains article bibliographical information.
Contains information on treatment design,
operations, and costs.
Crosswalk between treatment technology
operations codes and each treatment system
reported.
Contains information on pollutant sample
detection limits.
Contains influent and effluent pollutant
concentration data and percent removal.
Export of IWTT Database
Tables (ERG, 2014)
6-24
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-5. List of Data Input Tables
Table Name
Table Description
Where to Find More
Information
Lookup
KEY_Document_Types
KEY_Lab_Scale
KEY_Motivation
KEY_NAICS
KEY_PerformStat
KEY_Parameter_Code
KEY_PSCSIC_Crosswalk
KEY_TreatmentTechCode
Identifies the list of document types.
Identifies the scale in which the measurements
were conducted.
Identifies the motivation categories for the
implementation of the treatment system.
Identifies the NAICS code in which the
treatment technology is used.
Identifies the value type reported (e.g., average,
minimum, maximum).
Identifies the parameter names and Chemical
Abstract Service (CAS) numbers.
Identifies the PSCs and respective SIC codes.
Identifies the treatment technology codes.
Table H-2
Table H-3
Table H-4
20 12 NAICS Index File
(U.S. Census, 2012)
Table H-5
EPA DMR Pollutant
Loading Tool (U.S. EPA,
2014c)
2013 Annual Review Report
Table B-l (U.S. EPA,
2014b)
Table H-6
EPA developed four data entry forms to facilitate data entry, promote standardization of
data fields, and improve data security. The forms populate the corresponding fields in each of the
input tables with relevant information. The purpose of each form is described below:
• Form 0, "Main Menu. " Contains a listing of the existing articles entered into the
database and allows data entry staff to edit an existing article entry or create a
new article entry. Form 0 provides access to Form 1.
• Form 1, "Reference Information. " Contains all of the data fields that identify and
summarize the article reference, including bibliographical information, abstract,
and key findings. Form 1 provides access to Form 2.
• Form 2, "Treatment Technology. " Contains all of the data fields that capture the
treatment system design, unit order, operating conditions, and cost information. If
an article discusses more than one treatment system, an additional Form 2 is
populated for each system. Form 2 provides access to Form 3.
• Form 3, "Removal Performance. " Contains all of the data fields that capture
performance data for each parameter removed by each treatment system. If an
article discusses the removal of more than one parameter, an additional Form 3 is
populated for each parameter.
Figure 6-1 illustrates the overall database structure and navigation between the forms.
6-25
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Section 6—New Data Sources and Additional Supporting Analyses
ForniO
Main Menu
Form 1
Reference information
Form 2
Treatment Technology
(System with Performance Data)
Forra 2
Treatment Technology ;
(System without PerfocBtanee Data),.'
form 3
Parameter Performance j
(Parameter 1)
Form 3
Parameter Performance !
x (Parameter 2)
Fonn3
[ Parameter Performance ,
(Parameter 3) /
Figure 6-1. IWTT Structure
6.2.4 Data Elements Captured
Table 6-6 below provides an overview of the type of specific information captured in
IWTT. For a complete list and description of the captured data elements, see Table H-l.
Table 6-6. Overview of Information Captured in IWTT
Forml
Form 2
Form3
Reference Information
Treatment Technology
Information
Parameter Performance
Title
Publication year
Number of pages
Authors/affiliation
Country
Source (journal, publisher,
conference)
Document type (e.g., conference
proceedings, peer-reviewed
journal, government report)
Abstract
Key findings
Motivation (e.g., effluent limits,
cost savings, water reuse, capacity
increase, environmental
impairment, resource recovery)
Key parameters treated
Relevant point source category,
SIC, and NAICS codes
Scale (pilot or full)
Treatment system units
comprising the system (in order of
the treatment train)
Operating parameters (e.g., pH,
media)
Narrative description of the
system
Chemical additions required
Notes on other relevant
parameters
Process diagrams
Wastewater discharge type (direct
or indirect, if identified)
Pollutant parameter (each system
may have performance data for
multiple parameters)
Analytical method (if identified)
Influent and effluent detection
limits (if identified)
Influent and effluent
concentrations and qualifier flags
(if identified)
Reported percent removal (if
identified)
Information about what the data
represent (e.g., average,
maximum, median)
Effluent limits required for
discharge (if identified)
6-26
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-6. Overview of Information Captured in IWTT
Forml
Reference Information
• Type of wastestream (e.g., process
wastewater, commingled
stormwater and process water)
• Scale (lab, full, pilot)
Form 2
Treatment Technology
Information
• System manufacturer (if
identified)
• Capital costs (if identified)
• Operation and maintenance costs
(if identified)
Form 3
Parameter Performance
6.2.5 Summary of Data Captured in IWTT
EPA began populating IWTT in 2012 and continues to collect literature and populate the
database. As of September 2014, there were 163 captured articles. While EPA focuses on
capturing data about pilot- and full-scale treatment systems, it also documents limited
information about lab-scale systems. Of the 163 articles, 98 have both treatment system
information and pollutant removal information. Table 6-7 through Table 6-9 summarize the
treatment technologies, industries, and parameters captured in the database. The spreadsheet
IWTT Export.xls provides a detailed output of the data captured in the IWTT Database (ERG,
2014).
EPA conducted specific quality assurance and control measures to validate the quality of
the data as they were entered into IWTT. For more information on the quality assurance and
control measures, see the methodology documented in the Supplemental Quality Assurance and
Control Plan for the Development and Population of the Industrial Wastewater Treatment
Database (ERG, 2013).
There are currently 53 pilot- or full-scale treatment technologies captured in IWTT. Table
6-7 lists the number of articles and treatment systems that include each technology. Twenty-eight
treatment technologies, or 53 percent of those included in the database, are described in five or
more articles. Appendix H provides additional reference tables on the treatment technologies.
Table H-6 provides descriptions of each treatment technology. Table H-7 provides definitions of
the treatment categories.
Table 6-7. Pilot- or Full- Scale Treatment Technologies Captured in IWTT
Treatment Technology
Chemical Precipitation
Clarification
Membrane Bioreactor
Flow Equalization
Membrane Filtration
Dissolved Air Flotation
Reverse Osmosis
Ion Exchange
Category"
Chemical
Physical, NEC
Biological
Physical, NEC
Membrane
Physical, NEC
Membrane
Chemical
Code
ChemPre
CLAR
MBR
EQ
MF
DAF
RO
ION
Article Count
32
25
24
24
19
19
18
16
Treatment
Systems Count
42
29
33
26
25
25
20
20
6-27
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-7. Pilot- or Full- Scale Treatment Technologies Captured in IWTT
Treatment Technology
Granular-Media Filtration
Mechanical Pre-Treatment
Aerobic Suspended Growth
Aeration
Bag and Cartridge Filtration
Oil/Water Separation
Anaerobic Fixed Film Biological
Treatment
Aerobic Fixed Film Biological Treatment
Electrocoagulation
Anaerobic Biological Treatment
Granular Activated Carbon Unit
Liquid Extraction
UV
Adsorptive Media
Biologically Active Filters
Moving Bed Bioreactor
Evaporation
Constructed Wetlands
Aerobic Biological Treatment
Biological Nutrient Removal
Advanced Oxidation Processes, NEC
Chemical Oxidation
Stripping
Chemical Disinfection
Ballasted Clarification
Degasification
Nanofiltration
Crystallization
Centrifugal Separator
Anaerobic Suspended Growth
Biological Treatment
Controlled Hydrodynamic Cavitation
Denitrification Filters
Ozonation
Powdered Activated Carbon
Dechlorination
Hydrolysis, Acid or Alkaline
Cloth Filtration
Biofilm Airlift Suspension Reactor
Category"
Filtration
Physical, NEC
Biological
Physical, NEC
Filtration
Physical, NEC
Biological
Biological
Physical, NEC
Biological
Sorption
Chemical
Chemical
Sorption
Biological
Biological
Physical, NEC
Biological
Biological
Biological
Chemical
Chemical
Physical, NEC
Chemical
Physical, NEC
Physical, NEC
Membrane
Physical, NEC
Physical, NEC
Biological
Biological
Physical, NEC
Biological
Chemical
Sorption
Chemical
Chemical
Filtration
Biological
Code
FI
MPT
ASG
AIR
BCF
OW
ANFF
AFF
EC
AND
GAC
LE
UV
ADSM
BAC
MBBR
EVAP
WET
AD
BNR
AOP
CO
ST
CD
BCLAR
DOS
NANO
CYS
CS
ANSG
BIO
CHC
FDN
oz
PAC
DCL
AKH
CF
BASR
Article Count
16
15
13
12
9
8
7
7
6
6
6
6
6
6
6
6
5
5
5
5
4
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
1
1
1
Treatment
Systems Count
18
21
13
13
10
8
11
9
9
8
7
7
7
6
6
6
10
8
6
5
4
4
4
3
3
3
3
7
3
2
2
2
2
2
2
2
2
1
1
6-28
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-7. Pilot- or Full- Scale Treatment Technologies Captured in IWTT
Treatment Technology
Zero Valent Iron
Anaerobic Membrane Bioreactor
Dissolved Gas Flotation
Distillation
Granular Sludge Sequencing Batch
Reactor
Integrated Fixed-Film Activated Sludge
Category"
Chemical
Biological
Physical, NEC
Physical, NEC
Biological
Biological
Code
ZVI
AnMBR
DGF
DST
GSBR
IFAS
Article Count
1
1
1
1
1
1
Treatment
Systems Count
1
1
1
1
1
1
a See Table H-7 for descriptions of each category.
Table 6-8 presents the number of full- and pilot-scale systems that have performance data
for the industries captured in IWTT. Of the 163 articles entered in the database, 98 have
wastewater treatment system and performance data for end-of-pipe treatment (i.e., parameter
influent concentration, effluent concentration, and/or percent removal). IWTT captured removal
performance of 142 parameters for these wastewater treatment systems. Table 6-9 lists the
parameters with the greatest number of systems for which EPA documented treatment
performance. Table G-l, in Appendix G presents the complete list of parameters with
documented treatment performance.
Table 6-8. Industries with Performance data in IWTT
Industry
Dairy products processing
Canned and preserved fruits and vegetables processing
Textile mills
CAFO
Petroleum refining
Iron and steel manufacturing
Nonferrous metals manufacturing
Steam electric power generating
Ferroalloy manufacturing
Leather tanning and finishing
Pulp, paper and paperboard
Meat and poultry products
Metal finishing
Coal mining
PSC
405
407
410
412
419
420
421
423
424
425
430
432
433
434
Scale of Treatment
System
Full
Full
Pilot
Full
Full
Pilot
Pilot
Pilot
Full
Pilot
Pilot
Full
Pilot
Full
Pilot
Full
Pilot
Full
Pilot
Number of Treatment
Systems
1
1
2
2
6
12
1
3
1
3
1
4
1
4
2
2
18
2
7
6-29
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-8. Industries with Performance data in IWTT
Industry
Oil and gas extraction
Centralized waste treatment
Pharmaceutical manufacturing
Ore mining and dressing
Transportation equipment cleaning
Hospital
Aluminum forming
Electrical and electronic components
Agricultural services
Miscellaneous foods and beverages
Nonclassifiable establishments
PSC
435
437
439
440
442
460
467
469
-
-
-
Scale of Treatment
System
Full
Pilot
Full
Full
Pilot
Full
Pilot
Full
Pilot
Full
Pilot
Pilot
Full
Pilot
Full
Pilot
Number of Treatment
Systems
2
8
1
1
1
1
2
1
1
1
2
1
3
6
1
5
Table 6-9. Top Parameters with Performance Data in IWTT
Parameter11
Chemical oxygen demand
Total suspended solids
BOD
Solids, total dissolved (TDS)
Carbon, total organic (TOC)
Chemical oxygen demand, total
Nickel
Phosphorus, total
Conductivity
Chloride
Oil and grease
Selenium, total
Ammonia (as NH3)
Nitrogen, total
Cadmium
Chromium
Ammonia (as N)
Copper
Frequency
43
38
21
17
13
12
12
12
11
11
10
10
10
10
10
9
9
9
6-30
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Section 6—New Data Sources and Additional Supporting Analyses
Table 6-9. Top Parameters with Performance Data in IWTT
Parameter"
Zinc
Sulfate
BODS
Nitrogen, Kjeldahl total (TKN)
Calcium
Turbidity
Iron
Fats, oils and grease (FOG)
Ammonia, total
Nitrate (as N)
Arsenic
Dissolved oxygen (DO)
Naphthenic acid
Phenol
Nitrate
Magnesium
Ammonia-nitrogen
Phosphorus
Solids, volatile suspended
Chromium, hexavalent
Chemical oxygen demand, soluble
Selenium
Sodium
Frequency
9
9
9
9
8
8
7
7
6
6
6
6
5
5
5
5
5
5
5
5
5
5
5
a Parameter names are only as specific as the names stated in each article.
6.2.6 References for the Review of Industrial Wastewater Treatment Technologies
1. ERG. 2013. Eastern Research Group, Inc. Supplemental Quality Assurance and Control
Plan for the Development and Population of the Industrial Wastewater Treatment
Technology Database. Chantilly, VA. (November 22). EPA-HQ-OW-2010-0824-0263.
2. ERG. 2014. Eastern Research Group, Inc. Export of Industrial Wastewater Treatment
Technology (IWTT) Database Tables. Chantilly, VA. (September). EPA-HQ-OW-2014-
0170. DCN 08000.
3. U.S. Census. 2012. 2012 NAICS Index File. Available online at:
http://www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2012. EPA-HQ-OW-2014-
0170. DCN 08001.
4. U.S. EPA. 2014a. The 2012 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-004. EPA-HQ-OW-2010-0824-0320.
6-31
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Section 6—New Data Sources and Additional Supporting Analyses
5. U.S. EPA. 2014b. The 2013 Annual Effluent Guidelines Review Report. Washington,
D.C. (September). EPA-821-R-14-003. EPA-HQ-OW-2014-0170-0077.
6. U.S. EPA. 2014c. DMR Pollutant Loading Tool. DMR Pollutant Parameters Used and
Not Used by the Loading Tool (CSV). Available online at:
http://cfpub.epa.gov/dmr/technical-support-documents.cfm. Accessed: June 24, 2014.
EPA-HQ-OW-2014-0170. DCN 08002.
7. U.S. GAO. 2012. United States Government Accountability Office. Water Pollution:
EPA Has Improved Its Review of Effluent Guidelines but Could Benefit from More
Information on Treatment Technologies. (September). EPA-HQ-OW-2010-0824 -0264.
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PART III: RESULTS OF EPA'S 2014 ANNUAL REVIEW
in
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Section 7—Results of the 2014 Annual Review
7. RESULTS OF THE 2014 ANNUAL REVIEW
For the 2014 Annual Review, EPA evaluated public comments and stakeholder input
received on the Preliminary 2014 Effluent Guidelines Program Plan., and initiated its review of
industrial categories identified as warranting further investigation during the previous annual
reviews (U.S. EPA, 2014). Additionally, EPA initiated a review of an emerging pollutant group
of concern and continued its review of industrial wastewater treatment technology performance
data. This section presents a summary of the findings from the 2014 Annual Review.
7.1 Continued Review of Select Industrial Categories
During previous annual reviews, EPA identified several industrial categories warranting
further review: Metal Finishing (40 CFR Part 433), Pesticide Chemicals (40 CFR Part 455), and
brick and structural clay products manufacturing (not currently regulated). EPA continued its
review of these categories as part of the 2014 Annual Review. Below are the findings from the
2014 continued category reviews.
• Continued Review of the Metal Finishing Category (40 CFR Part 433). EPA's
continued review of the Metal Finishing Category in 2014 indicates that the
industry has not experienced significant growth in the last 30 years. However,
research suggests that the industry is consolidating into larger companies that tend
to compete better with the expanding global market. This consolidation may have
slightly reduced the size of the U.S. metal finishing industry. Further, the industry
is exploring the use of new chemicals that improve surface finishing quality
and/or eliminate the need for toxic chemicals that generate wastewater requiring
further treatment to meet discharge requirements. These alternatives may be
changing the characteristics of metal finishing wastewater over time. In addition,
at least some portion of the industry is employing more advanced wastewater
treatment technologies, including reuse, although a majority of the industry
continues to meet the effluent limitations guidelines and standards (ELGs) using
the more common treatment technologies, based on best available technology
economically achievable as defined in the ELGs.
EPA's continued preliminary review of the Metal Finishing Category identified several
topics that warrant further review, including:
• Potential new pollutants of concern not currently regulated that are increasingly
used in metal finishing processes.
• Prevalence of potential pollutants of concern associated with wastewater
generated from the use of wet air pollution control devices to control air
emissions from metal finishing operations.
• The application of advanced wastewater treatment technologies and the
prevalence of zero discharge practices in the industry.
7-1
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Section 7—Results of the 2014 Annual Review
• In addition there are several questions that are often raised regarding the
applicability of the metal finishing requirements, such as the distinction between
cleaning and etching of the base material.
• Targeted Review of Pesticide Active Ingredients (PAIs) without Pesticide
Chemical Manufacturing Effluent Limits (40 CFRPart 455). EPA's 2014 review
identified that only seven of the 30 PAIs of interest for which discharges from
manufacturing are not currently regulated under 40 CFR Part 455 are currently
registered or are under registration review in accordance with Section 3 of
FIFRA. The remaining 23 PAIs of interest have either never been registered or
have had their registrations canceled. However, discussions with EPA's Office of
Pesticide Programs suggested that registration status may not be an indicator of
whether the PAI is manufactured in the U.S. (and hence potentially present in
industrial wastewater discharge), as unregistered pesticides may still be
manufactured in the U.S. for export. Therefore, based on the information
reviewed in 2014, EPA was not able to prioritize for further review a subset of the
PAIs of interest that are produced in the U.S. However, EPA did identify several
follow-up questions and sources of information that will indicate whether any of
the PAIs of interest are produced in the U.S. and are thus potentially present in
industrial wastewater discharge. These sources of information include the
Pesticide Registration Information System (PRISM), Section Seven Tracking
System (SSTS) production data, and permit applications, fact sheets, and facility
permits for producers of the PAIs in the U.S.
• Continued Review of Brick and Structural Clay Products Manufacturing. EPA's
review of the current National Emission Standards for Hazardous Air Pollutants
(NESHAP) for the brick and structural clay products manufacturing industry, and
discussions with EPA's Office of Air and Radiation and the Brick Industry
Association, identified only two of the 345 brick manufacturing facilities, two of
the 24 clay ceramics facilities, and three of 127 ceramic tile facilities in the U.S.
as currently having wet scrubbers installed. The findings suggest that the use of
wet scrubbers to control air pollution is limited in this industry; therefore, the
brick and structural clay products manufacturing industry is not generating a
potential new source of industrial wastewater discharge that warrants regulation.
7.2 New Data Sources and Additional Supporting Analyses
EPA initiated a review of emerging pollutants of concern and continued its review of
industrial wastewater treatment technology performance data as part of the 2014 Annual Review.
Below are the findings from these analyses.
• Review of Engineered Nanomaterials (ENMs) in Industrial Wastewater. EPA
identified outstanding data gaps related to characterizing and quantifying the
presence and impact of ENMs in industrial wastewater discharges. EPA focused
its review on three classes on ENMs: silver, titanium dioxide, and carbon-based
nanomaterials. These are estimated to be produced in the largest volumes, and
research has more fully classified their impacts on human health and the
7-2
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Section 7—Results of the 2014 Annual Review
environment relative to the impacts of other types of ENMs (for which there is
little information). EPA's review determined the following:
— Some ENM manufacturing and processing methods likely generate
wastewater, but the quantity generated and waste management practices
are not documented.
— Toxicity hazards from ENMs have been demonstrated, but the
environmental and human health risks are largely unknown.
— Fate and exposure to industrial wastewater releases of ENMs to the
environment have not been studied.
— The small size, unique properties, and complexity of ENMs present a
challenge for environmental monitoring, risk assessment, and regulation.
— Methods for detecting and characterizing nanomaterials in complex media
like industrial wastewater are under development.
— EPA has not approved any standardized methods for sampling, detecting,
or quantifying nanomaterials in aqueous media.
— Research has shown that common treatment technologies employed at
municipal wastewater treatment plants are effective at removing
nanomaterials from the wastewater.
• From its review of the current body of research, EPA has identified several areas
of further research appropriate to better assess the potential presence and impact
of ENMs in industrial wastewater. Much of this research may be addressed by
ongoing academic and government research, including research coordinated
through the National Nanotechnology Initiative.
• Review of Industrial Wastewater Treatment Technologies. From its review of
literature regarding the performance of industrial wastewater treatment
technologies, EPA has identified and captured treatment information from 163
articles in its IWTT Database, as of September 2014. Of the 163 articles, 98
provide both treatment system information and performance data (i.e., pollutant
removal efficiencies). The 98 articles with performance data represent 35
industrial categories; however most of the literature reviews conducted to date
have focused on collecting treatment technology information for the petroleum
refining and metal finishing industries. IWTT documents the removal efficiencies
relating to 142 parameters, including many metals, chemical oxygen demand,
total suspended solids, and total dissolved solids. Though performance data are
captured for pilot- and full-scale treatment systems as a whole, 53 individual
treatment technologies (which constitute the various treatment systems) are
currently included in IWTT, with chemical precipitation, membrane bioreactors,
and clarification described in the greatest number of articles.
7-3
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Section 7—Results of the 2014 Annual Review
7.3 References for Results of the 2014 Annual Review
1. U.S. EPA. 2014. Final 2012 and Preliminary 2014 Effluent Guidelines Program Plans.
Washington, D.C. (September). EPA-820-R-14-001. EPA-HQ-OW-2014-0170-0002.
7-4
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