v>EPA
United States
Environmental Protection
Agency
Technical Support Document for the 2010
Effluent Guidelines Program Plan
September 2011
EPA 820-R-10-021
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CONTENTS
Page
Part I: Introduction I
1. Background 1-1
1.1 EPA's Clean Water Act Program 1-1
1.2 Background on the Effluent Guidelines Program 1-1
1.3 What Are Effluent Limitation Guidelines and Pretreatment Standards? 1-2
1.3.1 Best Practicable Control Technology Currently Available (BPT)
— CWA Sections 301(b)(1)(A) and 304(b)(1) 1-3
1.3.2 Best Conventional Pollutant Control Technology (BCT) — CWA
Sections 301(b)(2)(E) and 304(b)(4) 1-4
1.3.3 Best Available Technology Economically Achievable (BAT) —
CWA Sections 301(b)(2)(A) and 304(b)(2) 1-4
1.3.4 New Source Performance Standards (NSPS) — CWA Section 306 1-4
1.3.5 Pretreatment Standards for Existing Sources (PSES) — CWA
Section 307(b) 1-4
1.3.6 Pretreatment Standards for New Sources (PSNS) — CWA Section
307(c) 1-5
1.4 Success of EPA's Effluent Guidelines Program 1-5
1.5 What Are EPA's Effluent Guidelines Planning and Review Requirements? 1-5
1.6 Background References 1-6
2. Public Comment s on the Final Effluent Guidelines Program Plan for
2008 and Preliminary 2010 Effluent Guidelines Program Plan 2-1
3. The Effluent Guidelines Planning Process 3-1
3.1 Goals of the Effluent Guidelines Planning Process 3-1
3.2 Annual Review of Existing Effluent Guidelines and Pretreatment
Standards 3-1
3.2.1 Factors Considered in Review of Existing Effluent Guidelines and
Pretreatment Standards 3-1
3.2.2 Overview: Review of Existing Point Source Categories 3-5
3.3 Identification of New Categories for Possible Effluent Guidelines
Development 3-7
3.3.1 Direct Discharges 3-8
3.3.2 Indirect Discharges 3-8
3.4 Stakeholder Involvement and Schedule 3-8
3.5 The Effluent Guidelines Planning Process References 3-9
4. Methodology, Data Sources, and Limitations 4-1
4.1 Data Sources and Limitations 4-1
4.1.1 SIC Codes 4-2
4.1.2 NAICS Codes 4-3
4.1.3 Toxic Weighting Factors 4-4
4.1.4 Data from TRI 4-4
4.1.5 Data from PCS and ICIS-NPDES 4-7
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CONTENTS (Continued)
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4.2 Methodology Correction Affecting Both Screening-Level Review
Databases 4-9
4.2.1 Summary of DMRLoads2008 Database Methodology Changes 4-10
4.2.2 Summary of TRIReleases2008 Database Methodology Changes 4-13
4.3 Corrections to the DMRLoads2008 Database 4-15
4.3.1 DMRLoads2008: Categorization of Discharges 4-15
4.3.2 DMRLoads2008: Internal Monitoring 4-16
4.3.3 DMRLoads2008: Intermittent Discharges 4-16
4.3.4 DMRLoads2008: Excluded Pollutant Parameters 4-17
4.3.5 DMRLoads2008: Pollutant Corrections 4-17
4.3.6 DMRLoads2008: Data Quality Review 4-17
4.3.7 DMRLoads2008: Facility Reviews 4-20
4.4 Corrections to the TRlReleases2008 Database 4-35
4.4.1 TRIReleases2008: Categorization of Discharges 4-35
4.4.2 TRIReleases2008: Pollutant Corrections 4-36
4.4.3 TRIReleases2008: Data Quality Review 4-37
4.4.4 TRIReleases2008: Facility Reviews 4-38
4.4.5 Trends in TRI Data 4-43
4.5 TRIReleases2008 Rankings and DMRLoads2008 Rankings 4-43
4.6 Methodology, Data Sources, and Limitations References 4-43
PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF INDUSTRIAL
CATEGORIES WITH EXISTING ELGS II
5. 2010 Annual Review of Existing Effluent Limitations Guidelines and
Standards and Ranking of Point Source Categories 5-1
5.1 Summary of the Results from the 2009 Annual Review 5-1
5.2 Results of the 2010 Screening-Level Review 5-2
5.2.1 Categories for Which EPA is Currently Developing or Revising
ELGs 5-2
5.2.2 Categories for Which EPA Recently Promulgated or Revised
ELGs 5-3
5.2.3 Discharges Not Categorizable 5-3
5.2.4 Categories with One Facility Dominating the TWPE 5-4
5.2.5 Results of the 2010 Screening-Level Review 5-4
5.3 Prioritization of Categories for the 2010 Annual Review 5-10
5.3.1 Detailed Study of Existing ELGs 5-12
5.3.2 Preliminary Category Reviews 5-12
5.4 2010 Annual Review References 5-19
6. Fertilizer Manufacturing (40 CFR Part 418) 6-1
6.1 Fertilizer Manufacturing Category Background 6-1
6.1.1 Fertilizer Manufacturing Industry Profile 6-1
6.1.2 40 CFR Part 418 6-3
6.2 Fertilizer Manufacturing Category 2010 Screening-Level Review 6-4
6.3 Fertilizer Manufacturing Category Pollutants of Concern 6-5
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CONTENTS (Continued)
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6.4 Fertilizer Manufacturing Category Fluoride Discharges in DMR 6-8
6.4.1 Top Facility Permit Compliance 6-10
6.4.2 Mosaic Fertilizers, LLC in Uncle Sam, LA 6-11
6.4.3 IMC Phosphates in St. James, LA 6-12
6.5 Fertilizer Manufacturing Category Conclusions 6-13
6.6 Fertilizer Manufacturing Category References 6-14
7. Inorganic Chemicals Manufacturing (40 CFR Part 415) 7-1
7.1 Inorganic Chemicals Category Background 7-1
7.1.1 Inorganic Chemicals Industry Profile 7-1
7.1.2 40 CFR Part 415 7-5
7.2 Inorganic Chemicals Category Screening-Level Review 7-5
7.3 Inorganic Chemicals Category Pollutants of Concern 7-6
7.4 Inorganic Chemicals Category Top Facility Dischargers in DMR 7-9
7.4.1 UOP LLC in Chickasaw, AL 7-9
7.4.2 AL State Docks Mud Lakes in Mobile, AL 7-10
7.4.3 Elements Chromium LP in Castle Hayne, NC 7-11
7.4.4 Dow Chemical Pittsburg Plant in Pittsburg, OH 7-13
7.5 Inorganic Chemicals Category Conclusions 7-15
7.6 Inorganic Chemicals Category References 7-16
8. Landfills (40 CFR Part 445) 8-1
8.1 Landfills Category Background 8-1
8.1.1 Landfills Industry Profile 8-1
8.1.2 40 CFR Part 445 8-3
8.2 Landfills Category 2010 Screening-Level Review 8-5
8.3 Landfills Pollutants of Concern 8-5
8.4 Landfills Category Facility-Specific DMR Review 8-6
8.5 Landfills Category Iron Discharges in DMR 8-9
8.6 Landfills Category Conclusions 8-12
8.7 Landfills Category References 8-13
9. Mineral Mining and Processing (40 CFR Part 436) 9-1
9.1 Mineral Mining Category Background 9-1
9.1.1 Mineral Mining Industry Profile 9-1
9.1.2 40 CFR Part 436 9-7
9.2 Mineral Mining Category 2010 Screening-Level Review 9-8
9.3 Mineral Mining Category Pollutants of Concern 9-9
9.4 Mineral Mining Category Sulfide Discharges in DMR 9-12
9.5 Mineral Mining Category Fluoride Discharges in DMR 9-14
9.5.1 Wastewater Sources of Fluoride 9-14
9.5.2 Top Facilities Discharging Fluoride 9-15
9.5.3 Fluoride Wastewater Treatment 9-20
9.6 Mineral Mining Category Ammonia as Nitrogen Discharges in DMR 9-20
9.7 Mineral Mining Category Conclusions 9-21
9.8 Mineral Mining Category References 9-23
iii
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CONTENTS (Continued)
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10. Oil & Gas Extraction (40 CFR Part 435) 10-1
10.1 Oil and Gas Category Background 10-1
10.1.1 Oil and Gas Industry Profile 10-1
10.1.2 40 CFR Part 435 10-3
10.2 Oil and Gas Category 2010 Screening-Level Review 10-4
10.3 Oil and Gas Pollutants of Concern 10-4
10.4 Oil and Gas Category Sulfide Discharges in DMR 10-6
10.5 Oil and Gas Category Conclusions 10-7
10.6 Oil and Gas Category References 10-8
11. Ore Mining and Dressing (40 CFR Part 440) 11-1
11.1 Ore Mining and Dressing Category References 11-2
12. Organic Chemicals, Plastics, and Synthetic Fibers (40 CFRPart 414) 12-1
12.1 OCPSF Category Background 12-1
12.1.1 OCPSF Industry Profile 12-1
12.1.2 40 CFR Part 414 12-7
12.2 OCPSF Category 2010 Screening-Level Review 12-8
12.3 OCPSF Pollutants of Concern 12-8
12.4 OCPSF Category Top Facility Dischargers in DMR 12-11
12.4.1 Chevron Oronite Co. LLC in Belle Chasse, LA 12-11
12.4.2 MPM Silicones, LLC in Friendly, WV 12-12
12.4.3 E I DuPont de Nemours & Co. in Washington, WV 12-14
12.5 OCPSF Category Chlorine Discharges in DMR 12-15
12.5.1 Oxea Bay City Plant in Bay City, TX 12-16
12.5.2 Channelview Complex Channelview, TX 12-17
12.6 OCPSF Category Conclusions 12-18
12.7 OCSPF Category References 12-19
13. Plastics Molding and Forming (40 CFR Part 463) 13-1
13.1 PMF Category Background 13-1
13.1.1 PMF Industry Profile 13-1
13.1.2 40 CFRPart 463 13-5
13.1.3 40 CFRPart 63 Subpart II II 13-6
13.2 PMF Category 2010 Screening-Level Review 13-6
13.3 PMF Pollutants of Concern 13-7
13.4 PMF Category Chlorine Discharges in DMR 13-10
13.5 PMF Category Carbon Disulfide Discharges in DMR and TRI 13-11
13.5.1 Regenerated Cellulose Products 13-11
13.5.2 Regenerated Cellulose Facility Information 13-12
13.5.3 Wastewater Sources of Carbon Disulfide 13-16
13.5.4 Regenerated Cellulose Wastewater Treatment 13-17
13.6 PMF Category Diethylhexyl Phthalate Discharges in DMR 13-17
13.7 PMF Category Conclusions 13-18
13.8 PMF Category References 13-19
iv
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CONTENTS (Continued)
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14. Textile Mills (40 (T R Part 410) 14-1
14.1 Textiles Category Background 14-1
14.1.1 Textiles Industry Profile 14-1
14.1.2 40 CFR Part 414 14-5
14.2 Textiles Category 2010 Screening-Level Review 14-6
14.3 Textiles Pollutants of Concern 14-7
14.4 Textiles Category Top Facility Dischargers in DMR 14-10
14.4.1 Kawashima Textile USA, Inc. in Camden, SC 14-10
14.4.2 Kannapolis Water Treatment Plant in Kannapolis, NC 14-11
14.4.3 Mohawk Industries Oak River Plant in Bennettsville, SC 14-12
14.4.4 Mohawk Industries, Inc. in Lyerly, GA 14-15
14.4.5 Deroyal Textiles in Camden, SC 14-15
14.5 Textiles Category Conclusions 14-16
14.6 Textiles Category References 14-17
15. Waste Combustors (40 CFR Part 444) 15-1
15.1 Waste Combustors Category Background 15-1
15.1.1 Waste Combustors Industry Profile 15-1
15.1.2 40 CFR Part 444 15-3
15.2 Waste Combustors Category Screening Level Review 15-3
15.3 Waste Combustors Category Pollutants of Concern 15-4
15.4 Waste Combustors Hexachlorophene Discharges in DMR 15-7
15.5 Waste Combustors Category Conclusions 15-7
15.6 Waste Combustors Category References 15-8
PART III: DETAILED STUDIES Ill
16. Health Care Industry and Hospitals Category (40 CFR Part 460) 16-1
16.1 Health Care Industry and Hospitals Category References 16-2
17. Oil and Gas Extraction (40 CFR Part 43 5) 17-1
17.1 Overview of Operations 17-1
17.2 Produced Water 17-1
17.2.1 Management of Produced Water 17-2
17.2.2 Treatment of Produced Waters 17-2
17.3 Summary of Outreach 17-2
17.4 Oil and Gas Extraction References 17-3
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LIST OF TABLES
Page
2-1 Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program
Plans EPA Docket Number: EPA-HQ-OW-2008-0517 2-2
4-1 Nomenclature and Format of NAICS and SIC Codes 4-3
4-2 Number of Major and Minor Dischargers by State in DMR 2008 4-11
4-3 Dioxin and Dioxin-Like Compounds Distribution Selection Hierarchy for
TRIReleases2008 4-13
4-4 Number of Facilities Assigned Each Dioxin Distribution Hierarchy in TRI 2008 4-15
4-5 Summary of DMRLoads2008 Facility Review 4-21
4-6 Summary of TRIReleases2008 Facility Review 4-39
4-7 Number of Facilities with Data in TRI for Reporting Years 2002 Through 2008 4-43
5-1 Point Source Categories That Have Undergone a Recent Rulemaking or Review 5-3
5-2 Point Source Categories with One Facility Dominating the TWPE Discharges 5-6
5-3 Final TRlReleases2008 and DMRLoads2008 Combined Point Source Category
Rankings 5-7
5-4 2010 Annual Review of Categories with Existing ELGs: Level of Review 5-10
5-5 Previous Reviews for Categories with Preliminary Category Reviews for the 2010
Annual Review 5-19
6-1 Number of Fertilizer Manufacturing Facilities 6-2
6-2 Number of Fertilizer Manufacturing Facilities by Discharge Classification in 2008
DMR Database 6-3
6-3 Number of Fertilizer Manufacturing Facilities by Discharge Type in 2008 TRI
Database 6-3
6-4 Subcategories in the Fertilizer Manufacturing Category 6-4
6-5 Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006
through 2010 Screening-Level Reviews 6-4
6-6 Fertilizer Manufacturing Category 2008 DMR TWPE by Discharge Classification 6-5
6-7 Fertilizer Manufacturing Category Top TRI Pollutants 6-6
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LIST OF TABLES (Continued)
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6-8 Fertilizer Manufacturing Category Top DMR Pollutants 6-7
6-9 Top Fluoride Discharging Facilities in 2007 and 2008 DMR Databases 6-9
6-10 Outfalls and Permit Information for Top Fluoride Dischargers 6-11
6-11 Mosaic Fertilizers 2008 Monthly Fluoride Discharge Data and 40 CFR Part 418
Monthly Average Limitations 6-12
6-12 IMC Phosphates 2008 Fluoride Discharges 6-13
6-13 IMC Phosphates Outfall 002 2008 Monthly Fluoride Discharge Data and 40 CFR
Part 418 Monthly Average Limitations 6-13
7-1 Number of Inorganic Chemicals Manufacturing Facilities 7-3
7-2 Number of Inorganic Chemical Facilities by Facilities by Discharge Classification
in 2008 DMR Database 7-4
7-3 Number of Inorganic Chemicals Facilities by Discharge Type in 2008 TRI
Database 7-4
7-4 Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through
2010 Screening-Level Reviews 7-5
7-5 Inorganic Chemicals Category 2008 DMR TWPE by Discharge Classification 7-6
7-6 Inorganic Chemicals Category Top TRI Pollutants 7-7
7-7 Inorganic Chemicals Category Top DMR Pollutants 7-8
7-8 Inorganic Chemicals Category Top Facility Dischargers in the 2008 DMR
Database 7-9
7-9 UOP LLC 2008 Top Discharges 7-10
7-10 UOP LLC Outfalls 003 and 004 2008 Monthly Aluminum Discharge Data 7-10
7-11 AL State Docks Mud Lakes 2008 Mercury and Aluminum Discharges 7-11
7-12 AL State Docks Mud Lakes Outfall 001 2008 Monthly Mercury Discharge Data 7-11
7-13 Elementis Chromium LP Plant 2008 Top Discharges 7-12
7-14 Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver
Discharge Data 7-12
7-15 Dow Chemical Pittsburg Plant 2008 Top Discharges 7-13
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LIST OF TABLES (Continued)
Page
7-16 Dow Chemical Pittsburg Plant 2008 Monthly Copper Discharge Data 7-14
7-17 Dow Chemical Pittsburg Plant's 2008 Copper Discharges 7-14
8-1 Number of Landfills 8-2
8-2 Number of Landfills by Discharge Classification in 2008 DMR Database 8-2
8-3 Number of Landfills in the DMR Database for Reporting Years 2004, 2007, and
2008 8-3
8-4 Number of Landfills by Discharge Type in 2008 TRI Database 8-3
8-5 Regulated Pollutants and Limits for the Landfills Category (40 CFR Part 445) 8-4
8-6 Landfills Category TRI and DMR Discharges for the 2009 and 2010 Screening-
Level Reviews 8-5
8-7 Landfills Category 2008 DMR TWPE by Discharge Classification 8-5
8-8 Landfills Category Top TRI Pollutants in 2008 8-6
8-9 Landfills Category Top DMR Pollutants in 2008 8-6
8-10 Data Errors Identified in the Landfills Category in 2008 DMR Database 8-8
8-11 Corrected TWPE for Top Pollutants in the Landfills Category in 2008 DMR
Database 8-9
8-12 Iron Concentrations in the 2008 DMR Database Compared to Treatability
Concentrations 8-11
9-1 Number of Mineral Mining Facilities 9-2
9-2 Number of Mineral Mining Facilities 9-4
9-3 Number of Mineral Mining Facilities by Type of Discharger in TRI 2008 9-6
9-4 Applicability of Subcategories in the Mineral Mining Category 9-7
9-5 Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous
Screening-Level Reviews 9-9
9-6 Mineral Mining Category 2008 DMR TWPE by Discharge Classification 9-9
9-7 Mineral Mining Category Top TRI Pollutants 9-10
9-8 Mineral Mining Category Top DMR Pollutants 9-11
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LIST OF TABLES (Continued)
Page
9-9 Mineral Mining Category Top Sulfide Discharging Facility in DMR 2008 9-12
9-10 US Silica Co. 2008 Monthly Sulfide and Flow Discharge Data 9-13
9-11 US Silica Co. 2009 and 2010 Monthly Sulfide and Flow Discharge Data 9-13
9-12 Mineral Mining Category Top Fluoride Discharging Facilities in DMR 2008 9-14
9-13 PCS Phosphates White Springs Outfall Descriptions and Fluoride Limits 9-16
9-14 2008 Monthly Fluoride Concentrations and Limits for PCS Phosphates White
Springs 9-16
9-15 Outfall 001 Monthly Fluoride Concentrations and Limits for PCS Phosphates
White Springs (Jasper) 9-18
9-16 2008 Monthly Fluoride Discharge Data and Limits for US Agri-Chemicals
Corporation 9-19
9-17 Outfall 001 Monthly Fluoride Discharge Data and Limits for Feldspar
Corporation 9-20
9-18 Mineral Mining Category Top Ammonia as Nitrogen Discharging Facilities in
DMR 2008 9-21
9-19 Glen-Gery Corporation's 2008 Quarterly Ammonia as N and Flow Discharge
Data 9-21
10-1 Number of Oil and Gas Facilities 10-2
10-2 Number of Oil and Gas Facilities by Discharge Type in DMR 2008 10-2
10-3 Number of Oil and Gas Facilities in DMR Databases for Reporting Years 2004,
2007, and 2008 10-3
10-4 Subcategories in the Oil and Gas Category 10-3
10-5 Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews 10-4
10-6 Oil and Gas Category 2008 DMR TWPE by Discharge Classification 10-4
10-7 Oil and Gas Category Top DMR Pollutants 10-5
10-8 Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 DMR
Database 10-6
10-9 Marathon Oil Maverick Springs 2008 Sulfide Discharge Data 10-7
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LIST OF TABLES (Continued)
Page
12-1 Number of OCPSF Facilities 12-3
12-2 Number of OCPSF Facilities by Discharge Classification in 2008 DMR Database 12-5
12-3 Number of OCPSF Facilities by Type of Discharger in TRI 2008 12-6
12-4 Applicability of Subcategories in the OCPSF Category 12-7
12-5 OCPSF Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews 12-8
12-6 OCPSF Category 2008 DMR TWPE by Discharge Classification 12-8
12-7 O.CPSF Category Top TRI Pollutants 12-9
12-8 OCPSF Category Top DMR Pollutants 12-10
12-9 OCPSF Category Top Facility Dischargers in the DMR 2008 Database 12-11
12-10 Chevron Oronite 2008 Top Discharges 12-12
12-11 Chevron Oronite Outfall 202 2008 Monthly Discharge Data 12-12
12-12 MPM Silicones 2008 Top Discharges 12-13
12-13 MPM Silicones Outfall 001 2008 Monthly Discharge Data 12-13
12-14 E I DuPont de Nemours 2008 Top Discharges 12-14
12-15 E I DuPont de Nemours 2008 Monthly PACs Discharge Data 12-15
12-16 OCSPF Category Top Chlorine Discharging Facilities in the 2008 DMR Database .. 12-15
12-17 Oxea Bay City 2008 Monthly Chlorine and Flow Discharge Data 12-16
12-18 Channelview Complex 2008 Monthly Chlorine and Flow Discharge Data and
Maximum Chlorine Permit Limitations 12-17
13-1 Number of PMF Facilities 13-3
13-2 Number of PMF Facilities by Discharge Classification in 2008 DMR Database 13-4
13-3 Number of PMF Facilities by Discharge Type in 2008 TRI Database 13-5
13-4 PMF Category TRI and DMR Discharges for the 2006 through 2010 Screening-
Level Reviews 13-7
13-5 PMF Category 2008 DMR TWPE by Discharge Classification 13-7
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LIST OF TABLES (Continued)
Page
13-6 PMF Category Top TRI Pollutants 13-8
13-7 PMF Category Top DMR Pollutants 13-9
13-8 PMF Category Chlorine Discharging Facilities in 2008 DMR Database 13-10
13-9 Kinetico, Inc. 2008 Monthly Chlorine and Flow Discharge Data 13-11
13-10 Cellulose Manufacturers in the United States 13-13
13-11 2008 TRI and DMR Discharges for Cellulose Products Manufacturing Facilities 13-14
13-12 Innovia Films 2008 Monthly Carbon Disulfide Discharge Data 13-15
13-13 Cellulose Products Facilities Wastewater Treatment 13-17
13-14 PMF Category Diethylhexyl Phthalate Discharging Facilities in 2008 DMR
Database 13-17
13-15 Flexco Corp. 2008 Monthly Diethylhexyl Phthalate Discharge Data 13-18
14-1 Number of Textiles Facilities 14-3
14-2 Number of Textiles Facilities by Discharge Classification in 2008 DMR Database .... 14-4
14-3 Number Textiles Facilities by Discharge Type in 2008 TRI Database 14-5
14-4 Applicability of Subcategories in the Textiles Category 14-6
14-5 Textiles Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews 14-7
14-6 Textiles Category 2008 DMR TWPE by Discharge Classification 14-7
14-7 Textiles Category Top TRI Pollutants 14-8
14-8 Textiles Category Top DMR Pollutants 14-9
14-9 Textiles Category Top Pollutant and Facility Dischargers in DMR 2008 14-10
14-10 Kawahima Textile 2008 Top Discharges in the DMR Database 14-11
14-11 Kawashima Textile USA 2008 Monthly Mercury and Flow Discharge Data 14-11
14-12 Kannapolis WTP 2008 Top Discharges in the DMR Database 14-12
14-13 Kannapolis WTP 2008 Monthly Aluminum Discharge Data 14-12
XI
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LIST OF TABLES (Continued)
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14-14 Mohawk Industries Oak River Plant 2008 Top Discharges in the DMR Database 14-13
14-15 Mohawk Industries Oak River Plant 2008 Monthly Toxaphene Discharge Data 14-14
14-16 Mohawk Industries Oak River Plant 2009 and 2010 Monthly Toxaphene
Discharge Data 14-14
14-17 Mohawk Industries 2008 Top Discharges in the DMR Database 14-15
14-18 Mohawk Industries 2008 Monthly Sulfide Discharge Data 14-15
14-19 Deroyal Textiles 2008 Top Discharges in the DMR Database 14-16
14-20 Deroyal Textiles 2008 Monthly Aldrin Discharge Data 14-16
15-1 Number of Facilities in Waste Combustors Category 15-2
15-2 Number of Waste Combustor Facilities by Type of Discharger in DMR 2008 15-2
15-3 Waste Combustor Facilities by Discharge Type in 2008 TRI Database 15-3
15-4 Applicability of Subcategories in the Waste Combustor Category 15-3
15-5 Waste Combustors Category TRI and DMR Discharges for the 2006 through
2010 Screening-Level Reviews 15-4
15-6 Waste Combustors Category 2008 DMR TWPE by Discharge Classification 15-4
15-7 Waste Combustors Category Top TRI Pollutants 15-5
15-8 Waste Combustors Category Top DMR Pollutants 15-6
15-9 Clean Harbors Deer Park 2008 Monthly Hexachlorophene Discharge Data 15-7
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LIST OF FIGURES
Page
1-1 Regulations of Direct and Indirect Wastewater Discharges 1-3
3-1 Flow Chart of Annual Review of Existing ELGs 3-2
3-2 Flow Chart of Further Review of Existing ELGs 3-3
3-3 Flow Chart of Identification of Possible New ELGs 3-4
Xlll
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Part I - Introduction
PART I: INTRODUCTION
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Section 1 - Background
This document supports the Final 2010 Effluent Guidelines Program Plan. It presents the
methodology used to perform the annual reviews of industrial discharges required by the Clean
Water Act and the results of the reviews.
1. 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 describes EPA's process for making effluent guidelines revision and development decisions
(i.e., effluent guidelines planning).
1.1 EPA's Clean Water Act Program
EPA's Office of Water is responsible for developing the programs and tools authorized
under the Clean Water Act (CWA), which enables EPA and the states to protect and restore the
Nation's waters. These programs and tools generally rely either on water quality-based controls,
such as water quality standards and water quality-based effluent limitations, or technology-based
controls, such as effluent guidelines and technology-based effluent limitations.
The CWA gives states the primary responsibility for establishing, reviewing, and revising
water quality standards. These standards consist of designated uses for each water body (e.g.,
fishing, swimming, supporting aquatic life), numeric pollutant concentration limits ("criteria") to
protect those uses, and an antidegradation policy. EPA develops national criteria for many
pollutants, which states may adopt or modify as appropriate to reflect local conditions. In a
parallel track to water quality standards, EPA also develops technology-based effluent limitation
guidelines and standards (ELGs), based on current available technologies. These guidelines and
standards are then incorporated into discharge permits as technology-based effluent limitations
(U.S. EPA, 1996). While technology-based effluent limitations in discharge permits may be as
stringent as or more stringent than water-quality-based effluent limits, the effluent guidelines
program is not specifically designed to ensure that the discharge from each facility meets the
water quality standards of its receiving water body. For this reason, the CWA also requires states
to establish water-quality-based permit limitations, where necessary to attain and maintain water
quality standards. These water-quality-based limits may require industrial facilities to meet
requirements that are more stringent than those in a national effluent guideline regulation. EPA
notes that the various components of water-quality-based permitting (water quality standards,
water-quality-based effluent limits, and total maximum daily loads) are in different stages of
development nationally and by state, which may result in different levels of protection across
states. Therefore, national categorical effluent limitations and standards remain a critical
component of EPA's CWA Program. Consequently, in the overall context of the CWA, effluent
guidelines must be viewed as one tool in the broad arsenal of tools Congress provided to EPA
and the states to protect and restore the Nation's water quality.
1.2 Background on the Effluent Guidelines Program
The 1972 CWA marked a distinct change in Congress's efforts "to restore and maintain
the chemical, physical, and biological integrity of the Nation's waters." See CWA § 101(a), 33
U.S.C. § 1251(a). Prior to 1972, the CWA relied on "water quality standards." This approach
was challenging, however, because it was very difficult to prove that a specific discharger was
responsible for decreasing the water quality of its receiving stream.
1-1
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Section 1 - Background
The 1972 CWA directed EPA to promulgate effluent guidelines that reflect pollutant
reductions that can be achieved by categories or subcategories of industrial point sources. The
effluent guidelines are based on specific technologies (including process changes) that EPA
identifies as meeting the statutorily prescribed level of control. See CWA sections 301(b)(2),
304(b), 306, 307(b), and 307(c). Unlike other CWA tools, effluent guidelines are national in
scope and establish pollution control obligations for all facilities that discharge wastewater
within an industrial category or subcategory. In establishing these controls, EPA assesses: (1) the
performance and availability of the best pollution control technologies or pollution prevention
practices for an industrial category or subcategory as a whole; (2) the economic achievability of
those technologies, which can include consideration of costs, effluent reduction benefits, and
affordability of achieving the reduction in pollutant discharge; (3) non-water-quality
environmental impacts (including energy requirements); and (4) such other factors as the EPA
Administrator deems appropriate.
Creating a single national pollution control requirement for each industrial category
based on the best technology the industry could afford was seen by Congress as a way to reduce
the potential creation of "pollution havens" and to set the Nation's sights on attaining the highest
possible level of water quality. Consequently, EPA's goal in establishing national effluent
guidelines is to ensure that industrial facilities with similar characteristics, regardless of their
location or the nature of their receiving water, will at a minimum meet similar effluent
limitations representing the performance of the best pollution control technologies or pollution
prevention practices.
Unlike other CWA tools, effluent guidelines provide the opportunity to promote pollution
prevention and water conservation. This may be particularly important in controlling persistent,
bioaccumulative, and toxic pollutants discharged in concentrations below analytic detection
levels. Effluent guidelines also control pollutant discharges at the point of discharge from
industrial facilities and cover discharges directly to surface water (direct discharges) and
discharges to publicly owned treatment works (POTWs) (indirect discharges). For industrial
dischargers to POTWs, this can have the added benefit of preventing the untreated discharge of
pollutants to groundwater from leaking sewer pipes or to surface waters due to combined sewer
overflows.
1.3 What Are Effluent Limitation Guidelines and Pretreatment Standards?
The national clean water industrial regulatory program is authorized under sections 301,
304, 306, and 307 of the CWA.
The CWA directs EPA to promulgate ELGs through six levels of control:
1. Best practicable control technology currently available (BPT);
2. Best available control technology economically achievable (BAT);
3. Best conventional control technology (BCT);
4. New source performance standards (NSPS);
5. Pretreatment standards for existing sources (PSES); and
6. Pretreatment standards for new sources (PSNS).
For point sources that discharge pollutants directly into the waters of the United States (direct
dischargers), the limitations and standards promulgated by EPA are implemented through
1-2
-------
Section 1 - Background
National Pollutant Discharge Elimination System (NPDES) permits. See CWA sections 301(a),
301(b), and 402. For sources that discharge to POTWs (indirect dischargers), EPA promulgates
pretreatment standards that apply directly to those sources and are enforced by POTWs and state
and federal authorities. See CWA sections 307(b) and (c). Figure 1-1 illustrates the relationship
between the regulation of direct and indirect dischargers.
Direct Dischargers Indirect Dischargers
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
BAT
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
PSES
• Conventional Pollutants
BCT
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
PSNS
• Conventional Pollutants
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
NSPS
Existing
Sources
BPT
• Conventional Pollutants
• Nonconventional Pollutants
• Priority Pollutants (Toxics)
Figure 1-1. Regulations of Direct and Indirect Wastewater Discharges
1.3.1 Best Practicable Control Technology Currently Available (BPT) — CWA Sections
301(b)(1)(A) and304(b)(1)
EPA develops effluent limitations based on BPT for conventional, toxic, and
nonconventional pollutants. Section 304(a)(4) designates the following as conventional
pollutants: biochemical oxygen demand (BOD5), total suspended solids, fecal coliform, pH, and
any additional pollutants defined by the Administrator as conventional. The Administrator
designated oil and grease as an additional conventional pollutant on July 30, 1979. See 44 FR
44501 (July 30, 1979). EPA has identified 65 pollutants and classes of pollutants as toxic
pollutants, of which 126 specific substances have been designated priority toxic pollutants. See
Appendix A to Part 423, reprinted after 40 CFR Part 423.17. All other pollutants are considered
to be nonconventional.
In specifying BPT, EPA looks at a number of factors. EPA first considers the total cost of
applying the control technology in relation to the effluent reduction benefits. The Agency also
considers the age of the equipment and facilities, the processes employed and any required
process changes, engineering aspects of the control technologies, non-water-quality
environmental impacts (including energy requirements), and such other factors the EPA
Administrator deems appropriate. See CWA section 304(b)(1)(B). Traditionally, EPA establishes
BPT effluent limitations based on the average of the best performances of facilities within the
industry of various ages, sizes, processes, or other common characteristics. Where existing
1-3
-------
Section 1 - Background
performance is uniformly inadequate, BPT may reflect higher levels of control than currently in
place in an industrial category if the Agency determines that the technology can be applied
practically.
1.3.2 Best Conventional Pollutant Control Technology (BCT) — CWA Sections 301(b)(2)(E)
and 304(b)(4)
The 1977 amendments to the CWA required EPA to identify effluent reduction levels for
conventional pollutants associated with BCT for discharges from existing industrial point
sources. In addition to the other factors specified in section 304(b)(4)(B), the CWA requires that
EPA establish BCT limitations after consideration of a two-part "cost-reasonableness" test. EPA
explained its methodology for the development of BCT limitations in 1986. See 51 FR 24974
(July 9, 1986).
1.3.3 Best Available Technology Economically Achievable (BAT) — CWA Sections
301(b)(2)(A) and304(b)(2)
For toxic pollutants and nonconventional pollutants, EPA promulgates effluent guidelines
based on BAT. See CWA sections 301(b)(2)(C), (D), and (F). The factors considered in
assessing BAT include the cost of achieving BAT effluent reductions, the age of equipment and
facilities involved, the process employed, potential process changes, non-water-quality
environmental impacts (including energy requirements), and such other factors the EPA
Administrator deems appropriate. See CWA section 304(b)(2)(B). The technology must also be
economically achievable. See CWA section 301(b)(2)(A). In addition to end-of-pipe wastewater
treatment, BAT limitations may be based on effluent reductions attainable through changes in a
facility's processes and operations. Where existing performance is uniformly inadequate, BAT
may reflect a higher level of performance than is currently being achieved within a particular
subcategory based on technology transferred from a different subcategory or category. BAT may
be based upon process changes or internal controls, even when these technologies are not
common industry practice.
1.3.4 New Source Performance Standards (NSPS) — CWA Section 306
NSPS reflect effluent reductions that are achievable based on the best available
demonstrated control technology. New sources have the opportunity to install the best and most
efficient production processes and wastewater treatment technologies. As a result, NSPS should
represent the most stringent controls attainable through the application of the best available
demonstrated control technology for all pollutants (i.e., conventional, nonconventional, and
priority pollutants). In establishing NSPS, EPA is directed to take into consideration the cost of
achieving the effluent reduction and any non-water-quality environmental impacts and energy
requirements.
1.3.5 Pretreatment Standards for Existing Sources (PSES) — CWA Section 307(b)
PSES apply to indirect dischargers and are designed to prevent the discharge of pollutants
that pass through, interfere with, or are otherwise incompatible with the operation of POTWs,
including wastewater conveyance and sludge disposal. Pretreatment standards are technology-
based and are analogous to BAT effluent limitations guidelines.
1-4
-------
Section 1 - Background
The General Pretreatment Regulations, which set forth the framework for implementing
national pretreatment standards, are found at 40 CFR Part 403.
1.3.6 Pretreatment Standards for New Sources (PSNS) — CWA Section 307(c)
Like PSES, PSNS apply to indirect dischargers and are designed to prevent the
discharges of pollutants that pass through, interfere with, or are otherwise incompatible with the
operation of POTWs. PSNS are to be issued at the same time as NSPS. New indirect dischargers
have the opportunity to incorporate into their plants the best available demonstrated
technologies. The Agency considers the same factors in promulgating PSNS as it considers in
promulgating NSPS.
1.4 Success of EPA's Effluent Guidelines Program
The Effluent Guidelines Program has helped reverse the water quality degradation that
accompanied industrialization in this country. Permits developed using the technology-based
industrial regulations are a critical element of the Nation's clean water program and reduce the
discharge of pollutants that have serious environmental impacts, including pollutants that:
• Kill or impair fish and other aquatic organisms;
• Cause human health problems through contaminated water, fish, or shellfish; and
• Degrade aquatic ecosystems.
EPA has issued effluent guidelines for 57 industrial categories and these regulations
apply to between 35,000 and 45,000 facilities that discharge directly to the Nation's waters, as
well as another 12,000 facilities that discharge to POTWs. These regulations have prevented the
discharge of more than 700 billion pounds of toxic pollutants each year.
1.5 What Are EPA's Effluent Guidelines Planning and Review Requirements?
In addition to establishing new regulations, the CWA also 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, as
required by CWA sections 304(b), 301(d), 304(g), and 307(b). This document explains how EPA
uses reported discharge data and other factors to conduct this review. EPA also reviews
industries consisting of direct discharging facilities not currently subject to effluent guidelines to
identify potential candidates for effluent guidelines rulemakings, as required by CWA section
304(m)(l)(B). Finally, EPA reviews industries consisting entirely or almost entirely of indirect
discharging facilities that are not currently subject to pretreatment standards to identify potential
candidates for pretreatment standards development, as required by CWA sections 304(g) and
307(b).
CWA section 304(m)(l)(A) requires EPA to publish an Effluent Guidelines Program
Plan (Plan) every two years that establishes a schedule for the annual review and revision, in
accordance with section 304(b), of the effluent guidelines that EPA has promulgated under that
section. EPA's Final 2010 Plan presents the results of the section 304(b) reviews. The schedule
is as follows: EPA will coordinate its annual review of existing effluent guidelines under section
304(b) with its publication of the preliminary and final Plans under CWA section 304(m). In
other words, in odd numbered years, EPA intends to complete its annual review upon publication
1-5
-------
Section 1 - Background
of the preliminary Plan that EPA must publish for public review and comment under CWA
section 304(m)(2). In even numbered years, EPA intends to complete its annual review upon the
publication of the final Plan. EPA's 2010 annual review is the review cycle ending upon the
publication of this Final 2010 Plan.
EPA is coordinating its annual reviews under section 304(b) with publication of Plans
under section 304(m) for several reasons. First, the annual review is inextricably linked to the
planning effort, because the results of each annual review can inform the content of the
preliminary and final Plans (e.g., by identifying candidates for ELG revision for which EPA can
schedule rulemaking in the Plan, or by identifying point source categories for which EPA has not
promulgated effluent guidelines). Second, even though not required to do so under either section
304(b) or section 304(m), EPA believes that the public interest is served by periodically
presenting to the public a description of each annual review (including the review process used)
and the results of the review. Doing so at the same time EPA publishes preliminary and final
Plans makes both processes more transparent. Third, by requiring EPA to review all existing
effluent guidelines each year, Congress appears to have intended that each successive review
would build upon the results of earlier reviews. Therefore, by describing the 2010 annual review
along with the Final 2010 Plan, EPA hopes to gather and receive data and information that will
inform its reviews for 2011 and the Preliminary 2012 Plan.
1.6 Background References
1. U.S. EPA. 1996. U.S. EPA NPDES Permit Writers' Manual. Washington, DC.
(December). EPA-833-B-96-003. Available online at: http://cfpub.epa.gov/npdes/
writermanual. cfm?program_i d=4 5.
1-6
-------
Section 2 - Public Comments
2. Public Comments on the Final Effluent Guidelines Program Plan for 2008
and Preliminary 2010 Effluent Guidelines Program Plan
EPA published its Preliminary 2010 Effluent Guidelines Program Plan (Preliminary 2010
Plan) on December 28, 2009 (74 FRN 68599) and requested comments on various aspects of its
analyses, data, and information to inform its 2010 annual review and two detailed studies. The
Agency received five comments on the Final 2008 Plan and 51 comments on the Preliminary
2010 Plan. Table 2-1 lists the commenters as well as a synopsis of the comments.
2-1
-------
Section 2 - Public Comments
Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcntcr Name
EPA
Docket No.
Comment Summary
1
Deborah Goldberg (Earthjustice)
0045
General comments in favor of creating ELGs for a subcategory to Oil and Gas Extraction (40 CFR
Part 435) for wastewater from oil and gas drilling, hydraulic fracturing to retrieve shale gas, and
extraction for all oil and gas exploration, rather than focusing on coalbed methane (CBM)
extraction. Recommends zero discharge of all related wastewater.
2
Lisa Widawsky (Environmental
Integrity Project)
0046
General comments in favor of creating ELGs for toxic metals from coal combustion wastes at Steam
Electric Power Generating plants (40 CFR Part 423). Recommends zero discharge from scrubber
and ash transport systems as BAT because it has been achieved by sources in the industry.
3
Nancy Stewart and Margie Parsley
(League of Women Voters of
Tennessee)
0047
General comments in favor of revising Steam Electric Power Generating ELGs (40 CFR Part 423)
and containment guidelines for coal-ash impoundments. Recommend including inspection and
monitoring for structural integrity, capping to prevent overflows, composite liners to prevent
seepage, monitoring for heavy metals and other pollutants in nearby surface waters, and phase-out
of wet ash storage systems.
4
Abigail Dillen (Earthjustice)
0048
General comments in favor of revising the Steam Electric Power Generating ELGs (40 CFR Part
423). Recommends eliminating all pollutant discharges from scrubber and ash handling systems and
all discharge of leachate from land-based coal combustion waste disposal.
5
Doug Morris (American Petroleum
Institute)
0049
General comments to provide helpful regulatory and scientific background to EPA in response to
comments submitted by Earthjustice (EPA-HQ-OW-2008-0517-0045) regarding creating ELGs for
a subcategory of Oil and Gas Extraction (40 CFR Part 435) for wastewater from oil and gas drilling,
hydraulic fracturing to retrieve shale gas, and extraction for all oil and gas exploration, rather than
focusing on coalbed methane (CBM) extraction.
6
Russel F. Mankes
(Albany Medical Center)
0523
Recommends considering the results of a two-year study funded by U.S. EPA Region 2 on
pharmaceutical waste disposal for consideration of best practices, numeric data, and real-world
solutions diverting pharmaceuticals from wastewater.
7
Edward Berbaum
0524
Opposes hydraulic fracturing to retrieve shale gas activities that may impact water quality due to
drilling for natural gas in Dimock, PA.
8
Roger Graham
0525
Opposes the Chesapeake Appalachian Gas Company dumping wastewater related to hydraulic
fracturing to retrieve shale gas in the well near Keuka Lake in NY.
9
Jeff Bong
0526
Opposes the application of Chesapeake Appalachian Gas Company to store drilling wastewater in
the Finger Lakes Region of NY because of possible contamination of ground and surface water
resulting from hydraulic fracturing to retrieve shale gas.
2-2
-------
Section 2 - Public Comments
Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcntcr Name
EPA
Docket No.
Comment Summary
10
Warren Cole
0527
Opposes storing wastewater from hydraulic fracturing to retrieve shale gas near the Keuka Lake in
NY. Recommends requiring a 10-mile, or more, distance away from the Finger Lakes for storing
wastewater.
11
Bill Hawley
(Tompkins County Senior Citizens'
Council Inc.)
0528
Supports programs that will make it easier and more accessible for the general public and small
long-term care facilities to properly dispose of unwanted pharmaceuticals.
12
Gail Connally
0529
Opposes storing toxic water from hydraulic fracturing to retrieve shale gas in Pulteney, NY near
Keuka Lake.
13
Keith and Annette Toaspern
0530
Recommends expanding the CBM Detailed Study to include all oil and gas exploration, stimulation,
and extraction techniques, including hydraulic fracturing, to retrieve shale gas in all formations.
Specifically have concerns about storing wastewater near Keuka Lake in NY.
14
Eunice Alexander
0531
Recommends expanding the CBM Detailed Study to include hydraulic fracturing to retrieve shale
gas.
15
Ed Gottlieb
(Ithaca Area Wastewater Treatment
Facility)
0532
Supports changes that would allow health care facilities an alternative to flushing unused
pharmaceuticals.
16
Dennis Kucinich
(Michigan Department of Natural
Resources and Environment)
0533
Supports efforts to develop proper disposal of unused pharmaceuticals. Recommends EPA
reconsider and regulate dental mercury. Recommends EPA reexamine Metal Finishing (40 CFR
Part 433) and Electroplating (40 CFR Part 413) ELGs because of new chemical formulas, pollutants
of concern, and treatment technologies.
17
Ken Harward
(Association of Idaho Cities)
0534
Supports adopting best management practices for the proper disposal of unused pharmaceuticals.
Recommends EPA regulate unused pharmaceuticals.
18
Bernard Handler
0535
Recommends EPA examine hydraulic fracturing to retrieve shale gas.
19
Mary Sweeny
0536
Recommends expanding the CBM Detailed Study to include hydraulic fracturing to retrieve shale
gas in all formations, including Barnett and Marcellus Shales.
20
John Wagner
(Wyoming Department of
Environmental Quality)
0537
Recommends that, if it proceeds with CBM ELGs EPA include CBM discharges in the Oil and Gas
Extraction Subpart E applicability (40 CFR Part 435).
21
Laurie Tenace
(Florida Department of
Environmental Protection)
0538
General comments in support of EPA's unused pharmaceuticals detailed study and information
about Florida Department of Environmental Protection guidelines for disposal of unused
pharmaceuticals.
2-3
-------
Section 2 - Public Comments
Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcntcr Name
EPA
Docket No.
Comment Summary
22
Bob LeResche
(Powder River Basin Resource
Council)
0539
Supports moving forward with the CBM ELGs along with including all oil and gas exploration,
stimulation, and extraction techniques that result in surface or groundwater pollution.
23
V. Bruce Thompson
(American Exploration and
Production Council)
0540
Opposes EPA's CBM Detailed Study becoming an ELG and opposes expanding the scope of the
detailed study to include other oil and gas extraction activities.
24
Cynthia Finley
(National Association of Clean
Water Agencies)
0541
General comments in support of EPA's unused Pharmaceuticals Detailed Study.
25
Marcia English
0542
Recommends EPA examine hydraulic fracturing to retrieve shale gas, particularly in the Marcellus
Shale basin.
26
Justine Coffey, JD, LLM
(American Society of Health-System
Pharmacists)
0543
Recommends EPA reconsider using a survey to collect information on unused pharmaceuticals
management. Provided additional information about unused pharmaceuticals management.
27
Becky Jayne
(Illinois Environmental Protection
Agency)
0544
Indicates the Quicksilver Caucus Dental Work Group will provide comments at a later date.
28
Jen Jackson
(Bay Area Pollution Prevention
Group)
0545
Supports moving forward with an ELG for unused pharmaceuticals to limit disposal in the sanitary
sewer.
29
Les and Sheryl Rosenbloom
0546
Oppose trucking toxic wastewater from hydraulic fracturing to retrieve Marcellus Shale gas in
Pennsylvania to store near Keuka Lake in NY.
30
Angie Burckhalter
(Oklahoma Independent Petroleum
Association)
0547
Opposes moving forward with ELGs for CBM and expanding the CBM Detailed Study to include
all oil and gas exploration, stimulation, and extraction.
31
S. J. Tatham
0548
Supports expanding the CBM Detailed Study to include all oil and gas exploration, stimulation, and
extraction, including hydraulic fracturing to retrieve shale gas.
32
Lee Fuller
(Independent Petroleum Association
of America)
0549
Opposes moving forward with ELGs for CBM.
33
Karen Bennett
(National Mining Association)
0550
Opposes moving forward with a preliminary study of the Ore Mining and Dressing ELGs (40 CFR
Part 440).
2-4
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Section 2 - Public Comments
Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcntcr Name
EPA
Docket No.
Comment Summary
34
Charlie Burd
(Independent Oil and Gas
Association of West Virginia, Inc.)
0551
Opposes expanding the CBM Detailed Study to include all oil and gas exploration and production.
35
Thomas Curtis
(American Water Works
Association)
Diane VanDe Hei (Association of
Metropolitan Water Agencies)
0552
General comments on the Effluent Guidelines Program Plan. Supports the CBM Detailed Study and
review of hydraulic fracturing to retrieve shale gas.
36
Elizabeth Tatham
(Delaware River Basin Commission)
0553
Opposes the practice of hydraulic fracturing to retrieve shale gas because of risks to drinking water
aquifers from fracking fluid and discharges to surface water. Supports designating special protected
areas as off limits to mining and other industrial use.
37
Jay Watson
(King County)
0554
Provided information on best management practices (BMPs) for unused pharmaceuticals.
38
Kate Cain-Bell
0555
Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because of harm to human health
and the environment.
39
Winfield Tatham
0556
Opposes hydraulic fracturing to retrieve shale gas in Pennsylvania because of harm to human health
and the environment.
40
Barbara Bickford and Charles
Schuler
(Wisconsin Department of Natural
Resources)
0557
Support developing BMPs for unused pharmaceuticals to safeguard public health. Encourage
streamlining federal regulations to minimize generation of unused pharmaceuticals. Support
expanding the EPA Pharmaceuticals Detailed Study to include unused pharmaceutical disposal from
homes and agriculture. Support expanding the EPA detailed study to quantify volumes of
pharmaceuticals excreted versus disposed as unused.
41
Mark Fix
(Northern Plains Resource Council)
0558
Supports developing ELGs for both CBM and hydraulic fracturing to retrieve shale gas.
42
David Templet
(Chesapeake Energy Corporation)
0559
Opposes developing ELGs for hydraulic fracturing to retrieve shale gas.
43
Jennifer Peterson
(Environmental Integrity Project,
Defenders of Wildlife, Earthjustice,
and Sierra Club)
0560
Supports EPA's selection of Steam Electric Power Generating for revised rulemaking but suggests
expedited schedule for revisions.
2-5
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Section 2 - Public Comments
Table 2-1. Comments on the Final 2008 and Preliminary 2010 Effluent Guidelines Program Plans
EPA Docket Number: EPA-HQ-OW-2008-0517
No.
Commcntcr Name
EPA
Docket No.
Comment Summary
44
Sarah Eckel
(Citizens Campaign for the
Environment)
0561 and
0565
Supports developing ELGs for all oil and gas exploration, stimulation, and extraction techniques in
a detailed study, including a study of environmental impacts. Requests EPA explore potential for
contamination surrounding underground injection disposal for the waste fluids from oil and gas
exploration, stimulation, and extraction.
45
John Smillie
(The Western Organization of
Resource Councils)
0562
Supports developing ELGs for all oil and gas exploration, stimulation, and extraction techniques in
a detailed study, including hydraulic fracturing to retrieve shale gas.
46
Cynthia Miles
(Utility Water Act Group)
0563
Opposes revising the Steam Electric Power Generating Point Source Category (40 CFR Part 423).
47
Deborah Goldberg
(Earthjustice)
0564
Supports developing ELGs for both CBM and hydraulic fracturing.
48
Scott Thomas
(Fennemore Craig, P.C.)
0566
Opposes revising ELGs for the Ore Mining and Dressing Category (40 CFR Part 440).
49
B. Arrindell
(Damascus Citizens for
Sustainability)
0567
Opposes the process of hydraulic fracturing to retrieve shale gas because of risks to drinking water
aquifers from fracking fluid and discharges to surface water.
50
Kathleen Sgamma
(Independent Petroleum Association
of Mountain States)
0568
Opposes developing ELGs to regulate CBM produced water discharges.
51
Leroy Sprang
(Northern Cheyenne Tribe)
0569
Opposes developing ELGs to regulate CBM-produced water discharges and to allow state specific
regulation.
52
Erik Milito
(American Petroleum Institute)
0570
Opposes developing ELGs to regulate CBM-produced water discharges.
53
Charlotte Smith
(PharmEcology Services Waste
Management)
0571
Provides information on BMPs for unused pharmaceuticals handling and disposal.
54
Gayle Gray
(Rx Rescue LLC)
0572
Provides information on BMPs for unused pharmaceuticals handling and disposal.
55
Mark McDermid (Wisconsin
Department of Natural Resources)
0573
Supports developing an ELG to regulate dental amalgam discharges from dentists' offices.
2-6
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Section 3 - The Effluent Guidelines Planning Process
3. The Effluent Guidelines Planning Process
This section provides a general overview of the process EPA used in 2010 to identify
industrial categories for potential development of new or revised effluent limitations guidelines
and pretreatment standards (ELGs). This process consisted of: (1) annual review of existing
ELGs to identify candidates for revision; (2) identification of new categories of direct
dischargers for possible development of effluent guidelines; and (3) identification of new
categories of indirect dischargers for possible development of pretreatment standards. Each of
these components is illustrated in Figure 3-1 through Figure 3-3 and discussed below.
3.1 Goals of the Effluent Guidelines Planning Process
In the effluent guidelines planning process, EPA is guided by the following goals:
• Restore and maintain the chemical, physical, and biological integrity of the
Nation's waters; and
• Provide transparent decision-making and involve stakeholders early and often
during the planning process.
3.2 Annual Review of Existing Effluent Guidelines and Pretreatment Standards
This section describes the four factors used (Section 3.2.1) and how they are used
(Section 3.2.2) in the annual review of existing effluent guidelines and pretreatment standards.
3.2.1 Factors Considered in Review of Existing Effluent Guidelines and Pretreatment
Standards
EPA uses four major factors in prioritizing existing effluent guidelines or pretreatment
standards for possible revision.
The first factor EPA considers is the amount and type of pollutants in an industrial
category's discharge and the relative hazard posed by that discharge. Using this factor enables
the Agency to set priorities for rulemaking to achieve the greatest environmental and health
benefits. EPA estimates the potential hazard of pollutant discharges in terms of toxic-weighted
pound equivalents (TWPE), discussed in detail in Section 4.1.3. To assess the effectiveness of
pollution control, EPA examines the removal of pollutants in terms of pounds and TWPE.
The second factor EPA considers is the performance and cost of applicable and
demonstrated wastewater treatment technologies, process changes, or pollution prevention
alternatives that could effectively reduce the concentrations of pollutants in the industrial
category's wastewater and, consequently, reduce the hazard to human health or the environment
associated with these pollutant discharges.
3-1
-------
Section 3 - The Effluent Guidelines Planning Process
DMR&TRI
database tools
Stakeholder
recommendations
and comments
Yes
Are ELG revisions
currently
— underway?
No
Have ELGs been
developed or
revised within the
past 7 years? .
Yes
No
'Are only a very fewr
facilities responsible
for overall category
v TWPE? .
Yes
No
/ When ranked by \
TWPE, does category
contribute to top 95%
of cumulative TWPE
V of all categories? s
Yes
No
Are there identified
implementation and
efficiency issues
(Factor 4)?
Stakeholder
recommendations
and comments
Yes
No
Do further review
(see Figure 3-2)
f Begin annual ^
review of existing
I ELGs j
Not a priority category;
no further review at this
time
Not a priority
category; no
further review
at this time
Not a priority
category; no
further review
at this time*
Not a priority
category, but
consider
permitting
support for
individual
facilities
Identify
applicable
SIC and
NAICS codes
for each point
source
category
Preliminary Results of Screening-Level
Review = Combined TRIReleases and
DMRLoads database rankings (Factor 1)
• Further review
• BPJ support
• Identify for possible
revision of existing ELGs
• No action
Possible outcome
*lf EPA is aware of new segment growth within such a category or new concerns are identified, EPA may do further review.
Figure 3-1. Flow Chart of Annual Review of Existing ELGs
3-2
-------
Section 3 - The Effluent Guidelines Planning Process
fCategory identified for further*
I review (see Figure 3-1) y
Not enough
information
Stakeholder input
No further review at this
time
Yes
No
Are ELGs
potentially the
appropriate
tool?
Identify for possible
revision of ELGs
Yes
No
Identify other tools (e.g.,
permit-based support or
guidance)
/ Are discharges'^
adequately controlled
by existing
\ ELGs?* /
Detailed studies
Preliminary study
Continue collecting data
(all four factors)
Further review
*Continue further review if not enough data
Figure 3-2. Flow Chart of Further Review of Existing ELGs
3-3
-------
Section 3 - The Effluent Guidelines Planning Process
Stakeholder recommendations
and comments
Yes
Begin industry
identification
DMR& TRI
database tools
No identification or
further review necessary
No
No
Yes
No
Yes
No identification or
further review necessary
No
Yes
Identify other tools \
(e.g., permit-based W-
support or guidance) J
f Identify for possible
¦W new effluent guidelines
V or standards
No
Yes
Are ELGs potentially
the appropriate tool ?
/ Do \
/discharges interfere^
with or otherwise pass
S. through POTW >
operations?*^'
/ Are \
discharges of toxic
or nonconventional
pollutants
\ trivial?* /
/ Is the possible new
category all or nearly all
v. indirect dischargers ?
/Is the SIC/ \
/ NAICS code \
appropriately
considered a potential
new subcategory of an,
existing ELG ?
Identify SIC/NAICS
codes with
discharges not
subject to existing
ELGs
Include in annual review
of existing category (see
Figure 3-1)
'Continue further review if not enough data.
Figure 3-3. Flow Chart of Identification of Possible New ELGs
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Section 3 - The Effluent Guidelines Planning Process
The third factor EPA considers is the affordability or economic achievability of the
wastewater treatment technology, process change, or pollution prevention measures identified
using the second factor. If the financial condition of the industry indicates that it would be
difficult to implement new requirements, EPA might conclude that it would be more cost-
effective to develop less expensive approaches to reduce pollutant loadings that would better
satisfy applicable statutory requirements.
The fourth factor EPA considers is an opportunity to eliminate inefficiencies or
impediments to pollution prevention or technological innovation, or opportunities to promote
innovative approaches such as water quality trading, including within-plant trading. This factor
might also prompt EPA, during an annual review, to decide against revising an existing set of
effluent guidelines or pretreatment standards where the pollutant source is already efficiently and
effectively controlled by other regulatory or nonregulatory programs.
3.2.2 Overview: Review of Existing Point Source Categories
EPA has established ELGs to regulate wastewater discharges from 57 point source
categories and must annually review the ELGs for all of these categories. EPA first conducts a
screening-level review of all categories subject to existing ELGs to prioritize the categories for
further review. The Agency then conducts another review, either an in-depth "detailed study" or
a somewhat less detailed "preliminary category review," to identify existing categories for
potential ELGs revision.
3.2.2.1 Screening-Level Review
The screening-level review is the first step in EPA's annual review. Section 4 provides
details on the database methodology used in the screening-level review. EPA uses this step to
prioritize categories for further review. In conducting the screening-level review, EPA considers
the amount and toxicity of the pollutants in a category's discharge and the extent to which these
pollutants may pose a hazard to human health or the environment (Factor 1).
EPA conducts its screening-level review using data from the Toxics Release Inventory
(TRI) and data from discharge monitoring reports (DMR) contained in the Permit Compliance
System (PCS) and Integrated Compliance Information System - National Pollutant Discharge
Elimination System (ICIS-NPDES). EPA combines the DMR data from both PCS and ICIS-
NPDES in a database called DMRLoads. The Revised Quality Assurance Project Plan for the
2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial Category
Discharge Data describes in detail the quality criteria EPA used to evaluate the TRI and DMR
data (ERG, 2009). 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. Therefore, the first step in EPA's screening-level
review is to relate each SIC and NAICS code to an industrial category.1 The second step is to use
the information reported in TRI and DMR, for a specified year, to calculate the annual pollutant
discharges in pounds, including toxic, nonconventional, and conventional pollutants. For indirect
1 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).
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Section 3 - The Effluent Guidelines Planning Process
dischargers, EPA adjusts the facility discharges to account for removals at the publicly owned
treatment works (POTW). The third step is to apply toxic weighting factors (TWFs)2 to the
annual pollutant discharges to calculate the total discharge of toxic and nonconventional
pollutants (reported in units of TWPE). EPA then sums the TWPE for each facility in a category
to calculate a total TWPE per category for that year. EPA calculates two TWPE estimates for
each category: one based on data in TRI and one based on DMR data. EPA combines the
estimated discharges of toxic and nonconventional pollutants calculated from TRI and DMR data
to estimate a single TWPE value for each industrial category. EPA took 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.3
EPA then ranks point source categories according to their total TWPE discharges. In
identifying categories for further review, EPA prioritizes categories accounting for 95 percent of
the cumulative TWPE from the combined databases (see Section 5.3). Illustrated in Figure 3-1,
EPA also 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. 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. EPA also considers the number of facilities responsible for the majority of the
estimated toxic-weighted pollutant discharges associated with an industrial activity. Where only
a few facilities in a category account for the vast majority of toxic-weighted pollutant discharges,
EPA typically does not prioritize the category for additional review. In this case, EPA believes
that revising individual permits may be more effective in addressing the toxic-weighted pollutant
discharges than a national effluent guidelines rulemaking because requirements can be better
tailored to these few facilities and because individual permitting actions may take considerably
less time than a national rulemaking.
3.2.2.2 Further Review
Based on its screening-level review of all point source categories, EPA prioritizes certain
categories for further review to determine whether it would be appropriate for EPA to identify
those categories in the final Plan for potential effluent guidelines revision. EPA typically
conducts two types of further review: detailed studies and preliminary reviews. EPA selects
categories for further review based on the screening-level review and/or stakeholder input.
EPA's detailed studies generally examine the following: (1) wastewater characteristics
and pollutant sources; (2) the pollutants driving the toxic-weighted pollutant discharges; (3)
availability of pollution prevention and treatment; (4) the geographic distribution of facilities in
the industry; (5) any pollutant discharge trends within the industry; and (6) any relevant
economic factors. First, EPA attempts to verify the screening-level results and to fill in data gaps
(Factor 1). Next, EPA considers costs and performance of applicable and demonstrated
2 For more information on toxic weighting factors, see Toxic Weighting Factor Development in Support of CWA
304(m) Planning Process (U.S. EPA, 2006).
3 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 three
databases focus on different pollutants, double-counting was minimal and did not affect the order of the top ranked
industrial categories.
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Section 3 - The Effluent Guidelines Planning Process
technologies, process changes, or pollution prevention alternatives that can effectively reduce the
pollutants in the point source category's wastewater (Factor 2). Last, EPA considers the
affordability or economic achievability of the technology, process change, or pollution
prevention measure identified using the second factor (Factor 3).
Types of data sources that EPA may consult in conducting its detailed studies include,
but are not limited to: (1) U.S. Economic Census; (2) TRI and DMR data; (3) trade associations
and reporting facilities to verify reported releases and facility categorization; (4) regulatory
authorities (states and EPA regions) to understand how category facilities are permitted; (5)
NPDES permits and their supporting fact sheets; (6) EPA effluent guidelines technical
development documents; (7) relevant EPA preliminary data summaries or study reports; and (8)
technical literature on pollutant sources and control technologies.
Preliminary reviews are similar to detailed studies and have the same purpose. During
preliminary reviews, EPA generally examines the same factors and data sources listed above for
detailed studies. However, in a preliminary review, EPA's examination of a point source
category and available pollution prevention and treatment options is less rigorous than in its
detailed studies. While EPA collects and analyzes hazard and technology performance and cost
information on categories undergoing preliminary review, it assigns a higher priority to
investigating categories undergoing detailed studies.
3.3 Identification of New Categories for Possible Effluent Guidelines Development
Concurrent with its review of existing point source categories, EPA also reviews
industries not currently subject to effluent guidelines to identify potential new point source
categories. To identify possible new categories, EPA conducts a "crosswalk" analysis based on
data in DMR and TRI. Facilities with data in DMR and TRI are identified by a four-digit SIC
code or six-digit NAICS code (Sections 4.1.1 and 4.1.2 provide more details on SIC and NAICS
codes, respectively). EPA links each four-digit SIC code and six-digit NAICS code to an
appropriate industrial category (i.e., "the crosswalk").4 This crosswalk identifies SIC codes and
NAICS codes that EPA associated with industries subject to an existing guideline. The crosswalk
also identifies SIC and NAICS codes not associated with an existing guideline. In addition to the
crosswalk analysis, EPA relies on stakeholder comments to identify potential new point sources
categories. Sections 4.1.4 and 4.1.5 discuss the utility and limitations of TRI and DMR data,
respectively, in detail.
For each industry identified through the crosswalk analysis or stakeholder comments,
EPA evaluates whether it could be identified as a potential new category in the plan or whether it
is properly considered a potential new subcategory of an existing point source category. To
determine this, EPA generally looks at whether the industry produces a similar product or
performs a similar service as an existing category. If so, EPA generally considers the industry to
be a potential new subcategory of that category. If, however, the industry is significantly
different from existing categories in terms of products or services provided, EPA considers the
industry as a potential new stand-alone category subject to identification in the Plan.
4 For additional information on "the crosswalk," see Section 4 of the 2009 Technical Support Document for the
Annual Review of Existing Effluent Guidelines and Identification ofPotential New Point Source Categories (U.S.
EPA, 2009).
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Section 3 - The Effluent Guidelines Planning Process
3.3.1 Direct Discharges
Because the Clean Water Act (CWA) has different requirements for potential new
categories of direct and indirect dischargers, EPA examines new categories to determine if the
category comprises mostly direct dischargers, mostly indirect dischargers, or both direct and
indirect dischargers. If a category consists largely of direct dischargers, EPA evaluates the type
of pollutants discharged by facilities in the category.
3.3.2 Indirect Discharges
For potential new categories with primarily indirect dischargers, EPA evaluates the
potential for the wastewater discharges to "interfere with, pass through, or [be] otherwise
incompatible with" the operation of POTWs. See 33 U.S.C. § 1371(b)(1). Using available data,
EPA reviews the types of pollutants in an industry's wastewater. Then, EPA reviews the
likelihood of those pollutants to pass through a POTW as measured by: (1) the total annual
TWPE discharged by the industrial sector; and (2) the average TWPE discharged among
facilities that discharge to POTWs. EPA also assesses the interference potential of the discharge.
Finally, EPA considers whether the pollutant discharges are already adequately controlled by
general pretreatment standards and/or local pretreatment limits.
3.4 Stakeholder Involvement and Schedule
EPA's goal is to involve stakeholders early and often during its annual reviews of
existing effluent guidelines and the development of the biennial Plan. By doing so, EPA will
likely maximize the data collected to inform its analyses and provide additional transparency and
understanding of its effluent guidelines priorities identified in the biennial Plan.
EPA's annual reviews build on reviews from previous years, and reflect a lengthy
outreach effort to involve stakeholders in the review process. In performing its annual reviews,
EPA considers all public comments, information, and data submitted to EPA as part of its
outreach activities. EPA solicits public comment at the beginning of each annual review of
effluent guidelines and on the preliminary biennial Plan. In each Federal Register Notice, EPA
requests stakeholder comments on specific industries and discharges as well as any general
comments.
EPA completes an annual review of industrial discharges each year, upon publication of
the Preliminary and Final Effluent Guidelines Program Plans. In odd-numbered years, EPA
publishes its preliminary Plan for public review and comment as required under CWA section
304(m)(2). In even-numbered years, EPA publishes its final Plan that incorporates the comments
received on the preliminary Plan.
EPA intends that these contemporaneous reviews will provide meaningful insight into
EPA's effluent guidelines and pretreatment standards program decision-making. Additionally, by
providing notice for these and future reviews, EPA hopes to provide a consolidated source of
information for the Agency's current and future effluent guidelines and pretreatment standards
program reviews.
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Section 3 - The Effluent Guidelines Planning Process
3.5 The Effluent Guidelines Planning Process References
1. ERG. 2009. Revised Quality Assurance Project Plan for 2009 Annual Screening-Level
Analysis of TRI, ICIS-NPDES, and PCS Industrial Category Discharge Data.
(September). EPA-HQ-OW-2008-0517-0507.
2. U.S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.
3. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories. EPA-821-R-09-
007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.
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Section 4 - Methodology, Data Sources, and Limitations
4. Methodology, Data Sources, and Limitations
As discussed in Section 1, the Clean Water Act (CWA) requires EPA to conduct an
annual review of existing effluent limitations guidelines and pretreatment standards (ELGs). It
also requires EPA to identify industrial categories without applicable ELGs. EPA's methodology
for the 2010 annual review and new point source category identification involves several
components, as discussed in Section 3.
First, EPA performs a screening-level review of all point source categories subject to
existing ELGs to identify categories discharging high levels of toxic and nonconventional
pollutants relative to other categories. Second, EPA identifies priority categories as possible
candidate ELGs for revision, as required by CWA sections 304(b), 301(d), 304(g), and 307(b).
EPA then performs further review of the priority categories. Part II of this report (Sections 5
through 15) discusses the findings of EPA's 2010 annual review.
The next component of EPA's review is to identify industrial categories without
applicable ELGs. EPA reviews indirect discharging industries not currently subject to
pretreatment standards to identify potential candidates for pretreatment standards development,
as required by CWA section 307(b). Next, EPA reviews direct discharging industries not
currently subject to ELGs to identify potential candidates for ELG development, as required by
section 304(m)(l)(B) of the CWA.
In performing the screening-level review of existing ELGs and identifying industrial
categories without ELGs, EPA relies on discharge monitoring report (DMR) data, contained in
EPA's Permit Compliance System (PCS) and the Integrated Compliance Information System for
the National Pollutant Discharge Elimination System (ICIS-NPDES), and the Toxics Release
Inventory (TRI). This section discusses these databases, related data sources, and their
limitations.
EPA has developed two screening-level tools, the TRIReleases and DMRLoads databases,
to facilitate analysis of TRI and PCS/ICIS-NPDES data. EPA previously explained the creation
of these screening-level analysis tools in the Technical Support Document for the Annual Review
of Existing Effluent Guidelines and Identification of Potential New Point Source Categories
(2009 Screening-Level Analysis (SLA) Report) (U.S. EPA, 2009). The 2009 SLA Report
provides the detailed methodology used to process thousands of data records and generate
national estimates of industrial effluent discharges. This section does not revisit the details of
creating the database tools. Instead, it lists the methodology corrections made to the DMRLoads
and TRIReleases databases as part of EPA's 2010 annual review. It also presents the preliminary
category rankings from TRIReleases2008 v3 and DMRLoads2008_v2.
4.1 Data Sources and Limitations
This subsection provides general information on the use of Standard Industrial
Classification (SIC) and North American Industry Classification System (NAICS) codes, toxic
weighting factors (TWFs), TRI data, and DMR data. The following reports supplement this
section and discuss EPA's methodology for developing and using the two screening-level tools:
• Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories, (2009
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Section 4 - Methodology, Data Sources, and Limitations
SLA Report) (U.S. EPA, 2009). Documents the methodology and development of
the DMRLoads2008 and TRIReleases2008 databases, including (but not limited
to) matching NAICS and SIC codes to point source categories and using TWFs to
estimate toxic-weighted pound equivalents (TWPE).
• Draft Toxic Weighting Factor Development in Support of the CWA 304(m)
Planning Process (Draft TWF Development Document), dated July 2005 (U.S.
EPA, 2005). Explains how EPA developed the December 2004 TWFs.
• Toxic Weighting Factor Development in Support of the CWA 304(m) Planning
Process (Final TWF Development Document) (U.S. EPA, 2006b). Explains how
EPA developed the April 2006 TWFs.
4.1.1 SIC Codes
The SIC code system was developed to help with the collection, aggregation,
presentation, and analysis of data from the U.S. economy (OMB, 1987). The different parts of
the SIC code signify the following:
• The first two digits represent the major industry group;
• The third digit represents the industry group; and
• The fourth digit represents the industry.
For example, major SIC code 26: Paper and Allied Products includes all pulp, paper, and
paperboard manufacturing operations. Within SIC code 26, the three-digit SIC codes are used to
distinguish the type of facility: 263 for paperboard mills, 265 for paperboard containers and
boxes, etc. Within SIC code 265, the four-digit SIC codes are used to separate facilities by
product type: 2652 for setup paperboard boxes, 2653 for corrugated and solid fiber boxes, etc.
The SIC system is used by many government agencies, including EPA, to promote data
comparability. In the SIC system, each establishment is classified according to its primary
economic activity, which is determined by its principal product or group of products. An
establishment may have activities in more than one SIC code. Some data collection organizations
track only the primary SIC code for each establishment. PCS and ICIS-NPDES include one four-
digit SIC code, reflecting the principal activity causing the discharge at each facility.
Regulations for an individual point source category may apply to one SIC code, multiple
SIC codes, or a portion of the facilities in an SIC code. Therefore, to use databases that identify
facilities by SIC code, EPA linked each four-digit SIC code to an appropriate point source
category, as summarized in the "SIC/Point Source Category Crosswalk" table (Table A-l in
Appendix A).
There are some SIC codes for which EPA has not established national ELGs. Table A-2
in Appendix A lists the SIC codes for which facility discharge data are available in PCS and
ICIS-NPDES, but for which EPA could not identify an applicable point source category. For a
more detailed discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
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Section 4 - Methodology, Data Sources, and Limitations
4.1.2 NAICS Codes
In 1997, the U.S. Census Bureau introduced the NAICS code system, to better represent
the economic structure of countries participating in the North American Free Trade Agreement
and to respond to criticism about the SIC code system. Table 4-1 explains the nomenclature and
format of NAICS and SIC codes.
Table 4-1. Nomenclature and Format of NAICS and SIC Codes
NAICS
SIC
2-digit
Sector
Letter
Division
3-digit
Subsector
2-digit
Major Group
4-digit
Industry Group
3-digit
Industry Group
5-digit
NAICS Industry
4-digit
Industry
6-digit
U.S. Industry
N/A
N/A
For example, below are the SIC and NAICS code for the Folding Paperboard Box
Manufacturing industry.
In the SIC code system the classification is less stratified:
• 26: Paper and Allied Paper Products;
— 265: Paperboard containers and boxes;
• 2657: Folding Paperboard Boxes, Including Sanitary (except
paperboard backs for blister or skin packages).
In the NAICS code system the classification is more stratified:
• 32: Manufacturing;
— 322: Paper Manufacturing;
• 3222: Converted Paper Product Manufacturing;
o 322212: Folding Paperboard Box Manufacturing.
The NAICS system is used for industrial classification purposes at many government
agencies, including EPA. As in the SIC system, each establishment is classified according to its
primary economic activity, which is determined by its principal product or group of products. An
establishment may have activities in more than one NAICS code.
Regulations for an individual point source category may apply to one NAICS code,
multiple NAICS codes, or a portion of the facilities in an NAICS code. Therefore, to use
databases that identify facilities by NAICS code (e.g., TRI), EPA linked each six-digit NAICS
code to an appropriate point source category, as summarized in the "NAICS/Point Source
Category Crosswalk" table (Table A-3 in Appendix A). This table was based on the SIC/Point
Source Category Crosswalk table (Table A-l in Appendix A) and the NAICS/SIC Code
Crosswalk that EPA developed for past comparisons.
There are some NAICS codes for which EPA has not established national ELGs. Table
A-4 in Appendix A lists the NAICS codes for which facility discharge data are available in TRI,
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Section 4 - Methodology, Data Sources, and Limitations
but for which EPA could not identify an applicable point source category. For a more detailed
discussion, see Section 6 of the 2009 SLA Report (U.S. EPA, 2009).
4.1.3 Toxic Weighting Factors
As part of the Effluent Guidelines Program, EPA developed a wide variety of tools and
methodologies to evaluate effluent discharges. EPA's Office of Water, Engineering and Analysis
Division (EAD) maintains a Toxics Database compiled from over 100 references for more than
1,900 pollutants. The Toxics Database includes aquatic life and human health toxicity data, as
well as physical and chemical property data. Each pollutant in this database is identified by a
unique Chemical Abstract Service (CAS) number. EPA calculates TWFs from these data to
account for differences in toxicity across pollutants and to provide the means to compare mass
loadings of different pollutants. In its analyses, EPA multiplies a mass loading of a pollutant in
pounds per year (lb/yr) by a pollutant-specific weighting factor to derive a "toxic-equivalent"
loading (lb-equivalent/yr). Throughout this document, the toxic-equivalent is also referred to as
TWPE. The Draft and Final TWF Development Documents discuss the use and development of
TWFs in detail (U.S. EPA, 2005; U.S. EPA, 2006b).
EPA derives TWFs from chronic aquatic life criteria (or toxic effect levels) and human
health criteria (or toxic effect levels) established for the consumption of fish. In the TWF method
for assessing water-based effects, these aquatic life and human health toxicity levels are
compared to a benchmark value that represents the toxicity level of a specified pollutant. EPA
selected copper, a metal commonly detected and removed from industrial effluent, as the
benchmark pollutant. The Final TWF Development Document contains details on how EPA
developed its TWFs (U.S. EPA, 2006b). Table A-5 in Appendix A lists the TWFs for those
chemicals in the DMRLoads2008 and TRIReleases2008 databases for which EPA has developed
TWFs.
4.1.3.1 New Toxic Weighting Factors Developed During the 2010 Annual Review
During the 2010 annual review, EPA did not revise any TWFs or develop TWFs for any
chemicals that had not previously had TWFs.
4.1.3.2 Calculation of TWPE
EPA weighted the annual pollutant discharges calculated from the TRIReleases (see
Section 4.1.4) and DMRLoads (see Sections 4.1.5) databases using EAD's TWFs to calculate
TWPE for each reported discharge. EPA summed the estimated TWPE discharged by each
facility in a point source category to understand the potential hazard of the discharges from each
category. The following subsections discuss the calculation of TWPE.
4.1.4 Data from TRI
TRI is the common name for Section 313 of the Emergency Planning and Community
Right-to-Know Act. Each year, facilities that meet certain thresholds must report their releases
and other waste management activities for listed toxic chemicals. Facilities must report the
quantities of toxic chemicals recycled, collected, and combusted for energy recovery, treated for
destruction, or disposed of. A separate report must be filed for each chemical that exceeds the
reporting threshold. The TRI list of chemicals for reporting year 2008 includes more than 650
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Section 4 - Methodology, Data Sources, and Limitations
chemicals and chemical categories. For the 2010 screening-level review, EPA used data for
reporting year 2008, because they were the most recent available at the time the review began.
A facility must meet the following three criteria to be required to submit a TRI report for
a given reporting year:
1. NAICS Code Determination. The primary NAICS code determines if TRI
reporting is required. The primary NAICS code is associated with the facility's
revenues, and may not relate to its pollutant discharges (73 FR 324666). Certain
facilities in NAICS codes 11, 21, 22, 31 through 33, 42, 48 through 49, 51, 54, 56
and 81, and federal facilities are potentially subject to TRI reporting. EPA
generally relies on facility claims regarding the NAICS code identification.
2. Number of Employees. Facilities must have 10 or more full-time employees or
their equivalent. EPA defines a "full-time equivalent" as a person that works
2,000 hours in the reporting year (there are several exceptions and special
circumstances that are well defined in the TRI reporting instructions).
3. Activity Thresholds. If the facility is in a covered NAICS code and has 10 or more
full-time employee equivalents, it must conduct an activity threshold analysis for
every chemical and chemical category on the current TRI list. The facility must
determine whether it manufactures, processes, or otherwise uses each chemical at
or above the appropriate activity threshold. Reporting thresholds are not based on
the amount of release. All TRI thresholds are based on mass, not concentration.
Different thresholds apply for persistent bioaccumulative toxic (PBT) chemicals
than for non-PBT chemicals. Generally, non-PBT chemical threshold quantities
are 25,000 pounds for manufacturing and processing activities and 10,000 pounds
for other use activities. All thresholds are determined per chemical over the
calendar year. For example, dioxin and dioxin-like compounds are considered
PBT chemicals. The TRI reporting guidance requires any facility that
manufactures, processes, or otherwise uses 0.1 grams of dioxin and dioxin-like
compounds to report it to TRI (U.S. EPA, 2000).
In TRI, facilities report annual loads released to the environment of each toxic chemical
or chemical category that meets reporting requirements. Facilities must report onsite releases or
disposal to air, receiving streams, land, underground wells, and several other categories. They
must also report the amount of toxic chemicals in wastes transferred to off-site locations, (e.g.,
POTWs, commercial waste disposal facilities).
For its screening-level reviews, EPA focused on the amount of chemicals facilities
reported either discharging directly to a receiving stream or transferring to a POTW. For
facilities discharging directly to a stream, EPA took the annual loads directly from the reported
TRI data for calendar year 2008. For facilities transferring to POTWs, EPA first adjusted the TRI
pollutant loads reported to account for pollutant removal that occurs at the POTWs prior to
discharge to the receiving stream. Table A-6 in Appendix A lists the POTW removals used for
all TRI chemicals reported as transferred to POTWs.
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Section 4 - Methodology, Data Sources, and Limitations
Facilities reporting to TRI are not required to sample and analyze waste streams to
determine the quantities of toxic chemicals released. They may estimate releases based on mass
balance calculations, published emission factors, site-specific emission factors, or other
approaches. Facilities are required to indicate, by a reporting code, the basis of their release
estimate. TRI's reporting guidance is that, for most chemicals reasonably expected to be present
but measured below the detection limit, facilities should use half the detection limit to estimate
the mass released. However, for dioxins and dioxin-like compounds, nondetects should be
treated as zero.
TRI allows facilities to report releases as specific numbers or as ranges, if appropriate.
Specific estimates are encouraged if data are available to ensure the accuracy; however, EPA
allows facilities to report releases in the following ranges: 1 to 10 pounds, 11 to 499 pounds, and
500 to 999 pounds. For its screening-level reviews, EPA used the midpoint of each reported
range to represent a facility's releases, as applicable.
4.1.4.1 Utility of TRI Data
The data collected in TRI are particularly useful for ELG planning for the following
reasons:
• TRI is national in scope, including data from all 50 states and U.S.
territories/tribes;
• TRI includes releases to POTWs, not just direct discharges to surface water;
• TRI includes discharge data from manufacturing NAICS codes and some other
industrial categories; and
• TRI includes releases of many toxic chemicals, not just those in facility discharge
permits.
4.1.4.2 Limitations of TRI
For purposes of ELG planning, limitations of the data collected in TRI include the
following:
• Small establishments (less than 10 employees) are not required to report, nor are
facilities that do not meet the reporting thresholds. Thus, facilities reporting to
TRI may be a subset of an industry.
• Release reports are, in part, based on estimates, not measurements, and, due to
TRI guidance, may overstate releases, especially at facilities with large
wastewater flows.
• Certain chemicals (polycyclic aromatic compounds (PACs), dioxin and dioxin-
like compounds, metal compounds) are reported as a class, not as individual
compounds. Because the individual compounds in most classes have widely
varying toxic effects, the potential toxicity of chemical releases can be
inaccurately estimated.
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Section 4 - Methodology, Data Sources, and Limitations
• Facilities are identified by NAICS code, not point source category. For some
NAICS codes, it may be difficult or impossible to identify the point source
category that is the source of the toxic wastewater releases.
Despite these limitations, EPA determined that the data summarized in TRIReleases2008
were usable for the 2010 screening-level review and prioritization of the toxic-weighted pollutant
loadings discharged by industrial categories.
4.1.5 Data from PCS and ICIS-NPDES
EPA has used data reported to PCS as a part of its screening-level review of existing
effluent guidelines since the 2003 annual review (68 FRN 75515). Since 2002, EPA has been
working to modernize PCS by creating a new data system called ICIS-NPDES. In 2006, some
states began transitioning their DMR reporting from PCS to ICIS-NPDES. Currently 57 of the 71
states and territories/tribes have migrated to ICIS-NPDES. Therefore, for the 2010 annual
review, EPA's view of nationwide discharges was split between two sets of data. EPA created
the 2008 DMR Loadings Tool to combine the two systems (PCS and ICIS-NPDES) and generate
industrial category rankings for all U.S. states and territories/tribes. EPA extracted the loads from
the 2008 DMR Loadings Tool to create the DMRLoads2008 database. Both PCS and ICIS-
NPDES automate entering, updating, and retrieving NPDES data and track permit issuance,
permit limits, monitoring data, and other data pertaining to facilities regulated by the NPDES
program under the CWA.
More than 65,000 industrial facilities and wastewater treatment plants have permits for
wastewater discharges to waters of the United States. To provide an initial framework for setting
permitting priorities, EPA developed a major/minor classification system for industrial and
municipal wastewater discharges. Major discharges usually have the capability to impact
receiving waters if not controlled and, therefore, have received more regulatory attention than
minor discharges. There are approximately 7,000 facilities (including sewerage systems) with
major discharges and 15,000 facilities with minor discharges for which PCS and ICIS-NPDES
have extensive records. Permitting authorities classify discharges as major based on an
assessment of six characteristics:
1. Toxic pollutant potential;
2. Discharge flow: stream flow ratio;
3. Conventional pollutant loading;
4. Public health impact;
5. Water quality factors; and
6. Proximity to coastal waters.
Facilities with major discharges must report compliance with NPDES permit limits via
monthly DMRs submitted to the permitting authority. The permitting authority enters the
reported DMR data into PCS or ICIS-NPDES, including pollutant concentration and quantity
values and identification of any types of permit violations.
Minor discharges may, or may not, adversely impact receiving water if not controlled.
Facilities with minor discharges must report compliance with NPDES permit limits via monthly
DMRs submitted to the permitting authority; however, EPA does not require the permitting
authority to enter data in the PCS and ICIS-NPDES databases. For this reason, the PCS and
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Section 4 - Methodology, Data Sources, and Limitations
ICIS-NPDES databases include data only for a limited set of minor discharges (i.e., if the state or
other permitting authority chooses to include these data).
Parameters in PCS and ICIS-NPDES include water quality parameters (such as pH and
temperature), specific chemicals, conventional parameters (such as biochemical oxygen demand
(BOD5) and total suspended solids (TSS)), and flow rates. Although other pollutants may be
discharged, PCS and ICIS-NPDES contain data only for the parameters identified in the facility's
NPDES permit. Facilities typically report monthly average pounds per day discharged, but also
report daily maxima and average pollutant concentrations.
For the 2010 annual review, EPA used data for reporting year 2008, to correspond to the
data obtained from TRI. For the 2010 annual review, EPA corrected certain aspects of the 2008
data (see Section 4.3). Using the DMR Loadings Tool, EPA calculated annual loads for the PCS
and ICIS-NPDES data and then combined the calculated loads for each set of data. EPA
extracted the results of the annual loads calculations in the DMRLoads2008 database. Section 2
of the 2009 SLA Report provides details on the methodology and development of
DMRLoads2008 (U.S. EPA, 2009).
4.1.5.1 Utility of PSC and ICIS-NPDES
The data collected in the PCS and ICIS-NPDES data systems are particularly useful for
the ELG planning process for the following reasons:
• PCS and ICIS-NPDES combined are national in scope, including data from all 50
states and 21 U.S. territories/tribes.
• Discharge reports included in PCS and ICIS-NPDES are based on effluent
chemical analysis and metered flows.
• PCS and ICIS-NPDES include facilities in all SIC codes.
• PCS and ICIS-NPDES include data on conventional pollutants for most facilities
and for the nutrients nitrogen and phosphorus for many facilities.
4.1.5.2 Limitations of PCS and ICIS-NPDES
Limitations of the data collected in the PCS and ICIS-NPDES data systems include the
following:
The data systems contain data only for pollutants a facility is required by permit
to monitor; the facility is not required to monitor or report all pollutants actually
discharged.
The data systems include limited discharge monitoring data from minor
dischargers.
The data systems do not include data characterizing indirect discharges from
industrial facilities to POTWs.
Many of the pollutant parameters included in the data systems are reported as a
group parameter and not as individual compounds (e.g., "Total Kjeldahl
Nitrogen," "oil and grease"). Because the individual compounds in the group
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Section 4 - Methodology, Data Sources, and Limitations
parameter may have widely varying toxic effects, the potential toxicity of
chemical releases can be inaccurately estimated.
• In some cases, the data systems identify the type of wastewater (e.g., process
wastewater, stormwater, noncontact cooling water) being discharged; however,
most do not and, therefore, total flow rates reported to PCS and ICIS-NPDES may
include stormwater and noncontact cooling water, as well as process wastewater.
• Pipe identification is not always clear. For some facilities, internal monitoring
points are labeled as outfalls, and PCS and ICIS-NPDES may double-count a
facility's discharge. In other cases, an outfall may be labeled as an internal
monitoring point, and PCS and ICIS-NPDES may not account for all of a
facility's discharge.
• Facilities are identified by SIC code, not point source category. For some SIC
codes, it may be difficult or impossible to identify the point source category that
is the source of the reported wastewater discharges5.
• PCS and ICIS-NPDES were designed as a permit compliance tracking system and
do not contain production information.
• PCS and ICIS-NPDES data may be entered into the data systems manually, which
leads to data-entry errors.
• In PCS and ICIS-NPDES, data may be reported as an average quantity, maximum
quantity, average concentration, maximum concentration, and/or minimum
concentration. For many facilities and/or pollutants, average quantity values are
not provided. In these cases, EPA is limited to estimating facility loads based on
the maximum quantity. Section 3.2.3 of the 2009 SLA Report discusses the
maximum quantity issue in detail (U.S. EPA, 2009).
• PCS and ICIS-NPDES data on conventional pollutants and the nutrients nitrogen
and phosphorus are not used because of data quality concerns.
Despite these limitations, EPA determined that the data summarized in DMRLoads2008
were usable for the 2010 screening-level reviews and prioritizations of the toxic-weighted
pollutant loadings discharged by industrial facilities. The combined PCS and ICIS-NPDES
databases remain the only data source quantifying the pounds of regulated pollutants discharged
directly to surface waters of the United States.
4.2 Methodology Correction Affecting Both Screening-Level Review Databases
The 2009 SLA Report provides detailed information on the methodology EPA used to
develop the screening-level review databases (U.S. EPA, 2009). For the 2010 annual review,
EPA made changes to the methodology used to develop the 2008 DMR and TRI databases.
These methodology changes included the processing of the PCS data, the addition of minor
5 ICIS-NPDES includes a data field for applicable ELGs; however, it is not required and typically not populated.
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Section 4 - Methodology, Data Sources, and Limitations
discharges to the 2008 DMR database, and a change to the dioxin distribution hierarchy in the
2008 TRI database. This subsection summarizes the methodology changes made by EPA to the
2010 screening-level review databases.
4.2.1 Summary of DMRLoads2008 Database Methodology Changes
The two major changes made to the DMRLoads2008 database, discussed in the
subsections below, include changes made to the PCS data processing and the addition of minor
dischargers.
PCS Data Processing
For the 2010 annual review, EPA generated the industrial category rankings in
DMRLoads2008 for all U.S. states and territories/tribes from two data sources, PCS and ICIS-
NPDES. As part of the 2010 annual review, EPA estimates the pollutant load for each facility by
multiplying flow and concentration where appropriate. That is, no load is estimated for internal
outfalls, and EPA does not estimate a load for certain pollutants, such as pH. During previous
annual reviews, EPA used a separate database to process PCS data. This year, EPA incorporated
the PCS data processing (i.e., calculation a load using flow and concentration where appropriate)
as an additional subroutine in the DMR Loadings Tool. The data analysis methodology in the
DMR Loadings Tool subroutine is consistent with the PCSLoadCalculator.
Addition of Minor Dischargers
Facilities in the DMRLoads database are classified as either major or minor dischargers
based on EPA's major/minor classification system for industrial and municipal wastewater
discharges. As discussed in the Section 4.1.5, major discharges usually have the capability to
impact receiving waters if not controlled. Minor discharges may or may not adversely impact
receiving water if not controlled. Therefore, EPA does not require permitting authorities to enter
DMR data for facilities with minor discharges into PCS and ICIS-NPDES. As a result, discharge
data for minor discharges in PCS and ICIS-NPDES may be incomplete.
EPA previously reviewed discharges for only major discharging facilities because of the
possible incomplete data for minor discharging facilities. For the 2010 annual review, EPA
determined that including minor discharges would provide a more thorough review by
identifying industries that may consist mostly of minor facilities or have high pollutant
discharges because of contributing minor facilities. To determine if minor discharges are
appropriately represented, EPA compared the number of minor dischargers in the DMR database
to the number of minor dischargers that report water discharges for each state, presented in Table
4-2.
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-2. Number of Major and Minor Dischargers by State in DMR 2008
State or Territory/Tribe
Minors"
Minors with Water
Discharges b
Percent of Minors with
Water Discharges
Alaska
3,302
20
0.6%
Alabama
10,175
961
94%
Arkansas
3,857
374
9.7%
American Samoa
4
0
0.0%
Arizona
104
9
8.7%
California
2,142
1
0.0%
Colorado
3,122
63
2.0%
Connecticut
739
74
10.0%
District of Columbia
128
7
5.5%
Delaware
35
21
60.0%
Florida
244
137
56.1%
Georgia
1,984
148
7.5%
Gulf of Mexico
649
0
0.0%
Guam
62
0
0.0%
Hawaii
3,096
13
0.4%
Iowa
1,535
420
27.4%
Idaho
966
81
8.4%
Illinois
11,487
770
6.7%
Indiana
4,105
1,140
27.8%
Johnston Atoll
1
0
0.0%
Kansas
1,166
24
2.1%
Kentucky
1,731
1,304
75.3%
Louisiana
16,787
28
0.2%
Massachusetts
1,225
156
12.7%
Maryland
4,168
589
14.1%
Maine
270
106
39.3%
Michigan
463
197
42.5%
Minnesota
685
9
1.3%
Missouri
2,894
1,148
39.7%
Northern Mariana Islands
11
0
0.0%
Mississippi
1,507
997
66.2%
Montana
3,869
169
4.4%
North Carolina
1,083
648
59.8%
North Dakota
111
1
0.9%
Nebraska
1,167
210
18.0%
New Hampshire
310
23
7.4%
New Jersey
3,649
498
13.6%
New Mexico
1,594
44
2.8%
Navajo Nation
45
2
4.4%
Nevada
461
1
0.2%
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-2. Number of Major and Minor Dischargers by State in DMR 2008
State or Territory/Tribe
Minors"
Minors with Water
Discharges b
Percent of Minors with
Water Discharges
New York
6,869
805
11.7%
Ohio
3,044
1,465
48.1%
Oklahoma
1,294
149
11.5%
Oregon
324
4
1.2%
Pennsylvania
10,613
20
0.2%
Puerto Rico
701
117
16.7%
Rhode Island
687
70
10.2%
South Carolina
371
250
67.4%
South Dakota
674
55
8.2%
St. Regis Mohawk Tribe
2
0
0.0%
Tennessee
2,050
576
28.1%
Texas
10,030
802
8.0%
Utah
2,815
70
2.5%
Virginia
966
2
0.2%
Virgin Islands
148
23
15.5%
Vermont
147
0
0.0%
Washington
438
34
7.8%
Wisconsin
830
0
0.0%
West Virginia
818
42
5.1%
Wyoming
1,305
11
0.8%
Total
135,059
14,888
11.0%
Source: DMRLoads2008_v2.
a - All minor dischargers in the 2008 DMR database.
b - All minor dischargers with discharge data in the 2008 DMR database.
To consistently compare major and minor facility discharges in the database, EPA used
the same database methodologies and procedures in place for reviewing major facility discharges
to correct and review the minor facility discharge data. For example, EPA used the same flow
methodology for both major and minor facilities to autocorrect flows between 1,000 and 5,000
MGD (see Section 4.3.6). Because the DMRLoads2008 database consists of 90 percent minor
facilities, EPA calculated the 2008 category rankings with and without minor facilities to
determine the impact it had on the 2010 category rankings, shown in Table C-7, in Appendix C.
The addition of the minor dischargers to the 2008 DMR data increased the total number of
facilities reviewed from 2,036 to 16,924. Because of the inconsistent minor water discharging
data, EPA reviewed states where the majority of minors reported water discharges (e.g.,
Kentucky, Mississippi, and South Carolina). However, some states did not include any water
discharge data from minor facilities (e.g., Vermont and Wisconsin).
The addition of minor dischargers also resulted in point source categories that EPA has
not previously reviewed to be included in the top 95 percent of the 2010 annual review, such as:
Landfills (40 CFR Part 445), Oil & Gas Extraction (excluding coalbed methane operations) (40
CFR Part 435), and Metal Molding and Casting (Foundries) (40 CFR Part 464). For the 2010
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Section 4 - Methodology, Data Sources, and Limitations
annual review, EPA reviewed both major and minor top discharging facilities for industrial
categories with high TWPE (see Section 4.3.7).
4.2.2 Summary of TRIReleases2008 Database Methodology Changes
In the TRI database certain chemicals (PACs, dioxin and dioxin-like compounds, metal
compounds) are reported as a class, not as individual compounds. Because the individual
compounds in most classes have widely varying toxic effects, the potential toxicity of chemical
releases can be inaccurately estimated. However, for dioxin and dioxin-like compounds,
reporting facilities are given the opportunity to report facility-specific dioxin distributions that
EPA uses to better estimate the pollutant TWPE.
The dioxin and dioxin-like compounds class includes 17 individual congeners, each with
its own TWF. Facilities report a single mass number for the dioxin and dioxin-like compounds
but can report the mass of each congener in a separate field (referred to as the dioxin
distribution). For previous TRI reporting years, a facility could report only one dioxin congener
distribution, even if dioxins are released to more than one medium. As part of previous annual
reviews, EPA determined that the majority of facilities use the dioxin congener distribution for
air releases rather than water discharges. However, EPA used the reported distribution as it was
the best available information on the wastewater dioxin distribution.
Starting in 2008, facilities could report release-specific distributions. For example, if a
facility had three stream discharges (e.g., surface water discharge, air release, and POTW
transfer), it could report a distribution for each stream. As part of the data processing, the TRI
Program calculates a total surface water release distribution by combining each of the individual
stream release distributions. For direct discharges of dioxin and dioxin-like compounds, EPA
used the total surface water release distribution. For facilities that leave the all congener
distribution fields blank, EPA has worked with some trade associations to identify the most
accurate distribution based on the manufacturing process generating the wastewater. Therefore,
EPA revised the congener distribution hierarchy in the TRIReleases2008 database, presented in
Table 4-3, to reflect the change in the TRI distribution reporting requirements.
Table 4-3. Dioxin and Dioxin-Like Compounds Distribution Selection Hierarchy for
TRIReleases2008
2008 TRI
Prior TRI Databases
1. Assign the distribution reported by the facility, stored in TRI's
Water_Congener_2008 table.
• Direct discharge distribution is from the column "53 Total Water Release" b
• Indirect discharge distribution is from the column "61 POTW Transfer
Amount"
Same a
2. If there are any changes identified from facility-specific follow-up (e.g.
discussions with facilities from prior years), assign that previously identified
distribution. This distribution overwrites distributions applied in Step 1.
Same
If the facility docs not have a congener distribution applied in Steps 1 or 2, then:
3. For facilities in the Pulp and Paper Category assign the "Pulp Default"
distribution.
Same
4. For facilities in the Timber Products Category d, assign the "Wood Preserving
Default" distribution.
Same
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-3. Dioxin and Dioxin-Like Compounds Distribution Selection Hierarchy for
TRIReleases2008
2008 TRI
Prior TRI Databases
5. Use the NAICS average distribution. For facilities in the same category, start with
the smaller subset of the NAICS code, and then if none of that subset reports a
distribution, go to a larger set of NAICS codes.e
Same
6. Assign the distribution reported by the facility for "52 Stack Air" stored in TRI's
Congener_2008 table f.
NA
7. Use the TWF for CAS number N150 (dioxin and dioxin-like compounds), which
is congener 7, the median of the 17 TWFs for dioxin and dioxin-like compounds.
Same
a - Previous TRI data included only one distribution for each facility. The TRI2008 data includes separate
distributions for each release.
b - EPA selected the "Total Water Release" distribution rather than using the distributions for each discharge to a
receiving stream because the majority of facilities did not report distributions for each receiving stream discharge,
c - Congener distribution is applied only to facilities reporting NAICS codes 322110, 322121, 322122, and 322130.
Facilities reporting other NAICS codes that link to the Pulp and Paper Category do not get the "Pulp Default"
congener distribution.
d - Congener distribution is applied only to facilities reporting NAICS codes 321114 and 113310. Facilities
reporting other NAICS codes that link to the Timber Products Category do not get the "Wood Preserving Default"
congener distribution.
e - Step 5 Example for a Pulp and Paper Category facility. Facility A has a primary NAICS code 322291, reported
dioxin, and left distribution blank. Steps 1 through 4 do not apply (therefore, no distribution has been applied using
the hierarchy yet). Facilities B, C, and D primary NAICS codes 322291-2. Facility B reported a distribution (Step 1).
Facilities C and D did not report one, and they did not get one assigned from Steps 1 through 4. In this hierarchy,
first we calculate the NAICS average congener distribution on both 322291 (no distribution available) and then
322291-2 (resulting in a distribution). Then we assign the 322291-2 results to Facilities A, C, and D. Second, we
make another attempt to calculate the average distribution for NAICS 322291. We calculate the average distribution
for NAICS 322291 and 322291-2. This will be assigned to the facility reporting 322291 (Facility A),
f- EPA selected the "Stack Air" distribution because facilities populated this field most frequently in the 2008 TRI
data.
NA - Not applicable.
In TRIReleases2008, 121 facilities reported dioxin and dioxin-like compounds. Table 4-4
presents the number of facilities that reported a dioxin distribution for their water releases and
the number of facilities that were assigned a distribution from the hierarchy. As shown in Table
4-4, approximately 34 percent of facilities reporting dioxin and dioxin-like compounds reported
a specific water release distribution. For the remaining facilities, EPA used the hierarchy to
assign the dioxin distributions.
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-4. Number of Facilities Assigned Each Dioxin Distribution Hierarchy in TRI
2008
Percent of Total Facilities
Hierarchy
Abbreviated
Number of Facilities Assigned the
Reporting Dioxin and Dioxin-
Number
Name
Distribution
Likc Compounds
1
Reported Direct
36
29.7%
Reported Indirect
5
4.1%
2
Manual
5
4.1%
3
Pulp & Paper
31
25.6%
4
Wood Preserving
9
7.4%
5
NAICS Average
11
9.1%
6
Stack Air
15
12.4%
7
N150
9
7.4%
Total
121
100%
Source: TRICalculations2008_v3.
4.3 Corrections to the DMRLoads2008 Database
EPA developed the DMRLoads2008 database as part of the 2010 annual review using the
methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology updates
described in Section 4.2.1.
During previous screening-level analyses, EPA identified numerous facility-specific
corrections for PCS and ICIS-NDPES data reported for calendar years 2000, 2002, 2004, 2006,
and 2007. Several of these corrections similarly apply to the 2008 DMR data. In addition, EPA
reviewed the quality of the 2008 DMR data and facilities with discharges that have the greatest
impact on total category loads and category rankings. Table B-2 in Appendix B of this report
lists all corrections made to the 2008 DMR data in the DMR Loadings Tool.
4.3.1 DMRLoads2008: Categorization of Discharges
This subsection describes database corrections to facility categorization and pollutant
discharges in DMRLoads2008. Section 4 of the 2009 SLA Report describes the SIC/Point Source
Category Crosswalk development, which EPA uses to link between facility SIC codes and
categories with existing ELGs (U.S. EPA, 2009). Because most point source categories are not
defined by SIC code, the relationship between SIC code and point source category is not a one-
to-one correlation. A single SIC code may include facilities in more than one point source
category, and associating an SIC code with only one category may be an oversimplification.
Also, many facilities have operations subject to more than one point source category. Further,
facilities in some categories cannot be identified by SIC code (e.g., Centralized Waste Treatment
facilities). Section 4 of the 2009 SLA Report describes the database changes, summarized below
(U.S. EPA, 2009):
• Facility-Level Point Source Category Assignment. For some SIC codes that
include facilities subject to guidelines from more than one point source category,
EPA was able to assign each facility to the category that best applied to the
majority of its discharges. EPA reviewed information available about each facility
to determine which point source category applied to the facility's operations.
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Section 4 - Methodology, Data Sources, and Limitations
• Pollutant-Level Point Source Category Assignment. Many facilities have
operations subject to more than one point source category. For most of these
facilities, EPA cannot divide the pollutant discharges among the applicable point
source categories. Two exceptions where EPA was able to assign wastewater
discharges of certain chemicals to the appropriate point source category are listed
below:
— Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)/Pesticide
Chemicals. EPA removed all pesticide discharges from the OCPSF
Category and included them as discharges from the Pesticide Chemicals
Category.
— Metal Products and Machinery (MP&M)/Metal Finishing. EPA used the
methodologies described in Section 4 of the 2009 SLA Report (U.S. EPA,
2009) to apportion pollutant loads between the MP&M and Metal
Finishing Categories.
4.3.2 DMRLoads2008: Internal Monitoring
This subsection describes database corrections to identify internal monitoring points in
DMRLoads2008. As discussed in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S.
EPA, 2009), the 2008 DMR Loadings Tool calculated loads only for monitoring locations that
are labeled as effluent. The effluent monitoring locations in the 2008 DMR Loadings Tool are:
• MLOC 1 - Effluent net discharge;
• MLOC 2 - Effluent gross discharge;
• MLOC A - After disinfection;
• MLOC B - Before disinfection; and
• MLOC SC - See comments.
As a result, the DMR Loadings Tool excludes discharges for internal monitoring
locations such as intake water, influent to treatment, and intermediate points in the wastewater
treatment system. However, during previous category reviews and detailed studies, EPA
identified instances of double-counting that resulted from including certain internal monitoring
points in the loads database. For example, a facility monitors for Pollutant A at the effluent from
its wastewater treatment system (internal Outfall 101). Outfall 101 wastewater is later combined
with other plant discharges at final Outfall 001 and is discharged to a receiving stream. The
facility also monitors for Pollutant A at final Outfall 001. Both outfalls are effluent monitoring
points identified as MLOC 1 or MLOC 2; however, Outfall 101 is upstream of the final outfall.
Calculating loads for Pollutant A at both the internal and final outfalls double-counting Pollutant
A discharges. EPA identified instances where pollutant discharges are reported for multiple
monitoring locations along the same discharge line and eliminated the discharges for the
upstream monitoring locations. EPA made these corrections to the 2008 data in the DMR
Loadings Tool. A complete list of these corrections made in the DMR Loadings Tool can be
found in Table B-2 of Appendix B of this report.
4.3.3 DMRLoads2008: Intermittent Discharges
This section describes database corrections made for intermittent discharges in
DMRLoads2008. As described in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S.
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Section 4 - Methodology, Data Sources, and Limitations
EPA, 2009), the DMR Loadings Tool assumes that all discharges in PCS and ICIS-NPDES are
continuous (24 hours per day for all days in the monitoring period). During previous annual
reviews, EPA identified facility discharges that are intermittent and therefore are overestimated
by the DMR Loadings Tool. EPA calculated annual loads for these discharges based on
information obtained from the facility on the frequency and duration of wastewater discharges.
EPA made these corrections in the 2008 data in the DMR Loadings Tool.
4.3.4 DMRLoads2008: Excluded Pollutant Parameters
This section describes database corrections made to exclude selected water quality
parameters and flow from the annual load calculation in 2008 DMR Loadings Tool. As described
in Sections 3.2.1.3 and 3.2.3.2 of the 2009 SLA Report (U.S. EPA, 2009), facilities report
pollutant mass quantities, pollutant concentrations, and wastewater flow rates to PCS and ICIS-
NPDES using a variety of units. EPA's PCS CNVRT program and the ICIS-NPDES Convert
Module convert the discharges into standard units of kilograms per day (kg/day) for mass
quantities, milligrams per liter (mg/L) for concentrations, and millions of gallons per day (MGD)
for flow rates. However, some parameters are reported in units that cannot be converted into
kg/day or mg/L (e.g., temperature, pH, fecal coliform, whole effluent toxicity). EPA excluded
these parameters from the screening-level analysis. Table B-3 of Appendix B lists the excluded
parameters.
4.3.5 DMRLoads2008: Pollutant Corrections
This section describes database changes made to discharges of specific pollutants
reported to the DMR for EPA's 2010 screening-level review in the 2008 DMR Loadings Tool.
During the reasonableness checks of the PCS CNVRT output, EPA identified unusually
high mercury concentrations reported to PCS by facilities located in Ohio in the PCS CNVRT
output. These facilities reported mercury discharges using PRAM 50092 (Mercury Total Low
Level). The PRAM 50092 concentrations in the 2004 CNVRT output ranged from 0.2 to 673
mg/L from 0.001 to 380,000 mg/L in the 2008 CNVRT output. EPA contacted the Ohio
Environmental Protection Agency (Ohio EPA) to determine the correct reporting units for
PRAM 50092 (Stuhlfauth, 2007). An Ohio EPA representative explained that Ohio EPA started
requiring low level mercury analyses in 2002. At that time, some facilities had limits in
micrograms per liter (|ig/L), Currently, all of the limits are in nanograms per liter (ng/L).
As a result of this contact, EPA concluded that the units for the PRAM 50092
concentrations for the 2004 PCS data should be ng/L, not mg/L. The PRAM 50092
concentrations in the 2008 CNVRT output ranged from 0.001 to 380,000 mg/L with greater than
98 percent of these concentrations between 0.1 and 1,000 mg/L. Based on this distribution, EPA
concluded that the error for the 2004 data persisted in 2008. Therefore, EPA corrected the
concentrations by dividing all concentrations for PRAM 50092 reported by facilities in Ohio in
the DMR Pollutant Loadings Tool by one million.
4.3.6 DMRLoads2008: Data Quality Review
EPA evaluated the quality of the PCS and ICIS-NPDES DMR data for use in
DMRLoads2008 as part of the 2010 screening-level review. This evaluation considered data
completeness, accuracy, reasonableness, and comparability. The Quality Assurance Project Plan
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Section 4 - Methodology, Data Sources, and Limitations
for the 2009 Annual Screening-Level Analysis of TRI and PCS Industrial Category Discharge
Data describe the quality objectives in more detail (ERG, 2009). EPA conducted quality reviews
for three stages of the development of DMRLoads2008: 1) PCS CNVRT and ICIS-NPDES
Convert Module outputs; 2) the 2008 DMR Loadings Tool output; and 3) DMRLoads2008
results. The following discussion provides an overview of the quality review steps for each stage:
• PCS CNVRT and ICIS-NPDES Convert Module outputs. EPA conducted an
initial quality review of the extracted PCS CNVRT and ICIS-NPDES DMR data
to evaluate its completeness, reasonableness, and comparability. For
completeness, EPA compared the number of major facilities and the universe of
SIC codes in the 2008 DMR data to the DMR data in 2007.
EPA reviewed the DMR data for reasonableness to identify any data quality
issues, such as misreported units that the PCS CNVRT and ICIS-NPDES Convert
Module did not correct. EPA identified several wastewater flows that exceeded
the reasonable range. EPA reviewed these flows and developed the flow
correction function for the PCS CNVRT and ICIS-NPDES Convert Module
(described in Section 3.2.3 of the 2009 SLA Report (U.S. EPA, 2009)). This
function is designed to identify data entry errors for flows greater than 1,000
MGD. The PCS CNVRT and ICIS-NPDES Convert Module corrects all flows
exceeding 5,000 MGD and applies more conservative criteria to correct flows
from 1,000 to 5,000 MGD. The PCS CNVRT and ICIS-NPDES Convert Module
made the following corrections to the PCS and ICIS-NPDES wastewater flows:
— 559 corrections based on month-to-month variations;
— 379 corrections based on comparing flows to design flows; and
— 470 corrections based on assuming that flows exceeding 5,000 MGD are
reported in units of GPD.
• Load Calculator routines. EPA's quality review for the Load Calculator routines
included accuracy checks for database queries on the 2008 data in the DMR
Loadings Tool. EPA reviewed the programming code used to develop each query
to verify the logic and verified that the number of records in the output table
equaled the number of records in intermediate queries to ensure that no data were
missing and that there were no duplicate data. In addition, EPA performed hand
calculations to verify the accuracy of the Load Calculator module outputs during
reviews of facility discharges for DMRLoads2008 results.
• DMRLoads2008 results. EPA's quality review of the DMRLoads2008 results
included the following:
— Completeness checks. EPA compared counts of dischargers in
DMRLoads2008 to DMRLoads2007 to confirm the completeness of the
database. There were 2,018 major discharging facilities that reported a
load to DMRLoads2007 and 2,036 major discharging facilities that
reported a load to DMRLoads2008. There were 14,888 minor discharging
facilities that reported a load to DMRLoads2008\ however, EPA did not
include minor discharges in previous review. Therefore, EPA cannot
determine if DMRLoads2008 is complete.
4-18
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Section 4 - Methodology, Data Sources, and Limitations
Accuracy of facility discharges. EPA reviewed the accuracy of facilities'
discharges that had the greatest impact on total category loads and
category rankings to identify possible calculation errors. EPA reviewed
monitoring period data in PCS and ICIS-NPDES, measurement data
available on EPA's Envirofacts web page, and information from each
facility's NPDES permit and permit fact sheet. In some cases, EPA
contacted facilities to verify the measurements in their DMR. Section
4.3.7 describes EPA's review of facility discharges in more detail.
Accuracy of category discharges. EPA reviewed the accuracy of category
discharges by verifying that pollutant discharges in PCS and ICIS-NPDES
were assigned to the appropriate point source category. EPA used
engineering judgment to determine if the pollutant discharge was
reasonably associated with the point source category. Section 4.3.1
discusses facility-level and pollutant-level category assignments.
Accuracy of database queries. EPA's quality review for the development
of DMRLoads2008 included accuracy checks for database queries in
DMRLoadsAnalysis20086 and DMRLoads2008. Documentation of
accuracy checks is provided in a QC table in each Microsoft Access™
database.
Reasonableness of pollutant loads. EPA reviewed the DMR Loadings
Tool's 2008 output (i.e., the calculated kg/year for each pollutant at each
discharge pipe and monitoring location) for those pollutant discharges
with the highest toxic-weighted loads (e.g., dioxins, polychlorinated
biphenyls (PCBs), and mercury). To identify possible errors in recording
units of measure, EPA identified calculated discharges that were orders of
magnitude higher than previous years' discharges or discharges from other
facilities within the same category. EPA reviewed quantities or
concentrations and flows that the DMR Loadings Tool database used to
calculate the annual discharge. EPA compared these measurements with
measurements available on EPA's Envirofacts web page. If the
measurements were similar, then EPA concluded that the output was
acceptable. If the data did not match between the databases and
Envirofacts, EPA corrected the data to match Envirofacts. When EPA was
unsure what the correct data were, EPA contacted the facility or permitting
authority for more information (see Section 4.3.7).
Reasonableness of facility loads. EPA identified facility discharges with
the highest TWPE. EPA identified facilities for review whose pollutant
discharges accounted for more than 95 percent of the TWPE for their point
source category. EPA compared 2008 DMR data to other available
6 DMRLoadsAnaysis2008 is a database used to evaluate the impacts of calculation assumptions and corrects SIC
Code classifications for certain facilities and certain discharges (i.e., OCSPF and Pesticide discharges). See Section
3.2 of the 2009 SLA Report for further information (U.S. EPA, 2009).
4-19
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Section 4 - Methodology, Data Sources, and Limitations
information, such as information from EPA's Envirofacts web page, and
the facility's NPDES permit and permit fact sheet. If the data did not
match between the database and Envirofacts, EPA corrected the data to
match Envirofacts. When EPA was unsure what the correct data were,
EPA contacted the facility or permitting authority for more information
(see Section 4.3.7).
— Comparability. EPA compared DMRLoads2008 to DMRLoads2007 to
identify pollutant discharges or wastewater flows that differed more than
the year-to-year variation of other chemicals and facilities. EPA used this
comparison to determine if quantity, concentration, or flow corrections
were needed for facility discharges with the highest TWPE. If the
comparison was unavailable (e.g., the pollutant was not previously
reported) EPA contacted the facility or permitting authority (see Section
4.3.7).
4.3.7 DMRLoads2008: Facility Reviews
EPA reviewed the accuracy of facility discharges that had the greatest impact on total
category loads and category rankings in DMRLoads2008. EPA reviewed facilities with the
highest toxic-weighted discharges of individual pollutant parameters. For the identified facilities,
EPA used the following steps to review the accuracy of the loads calculated from PCS and ICIS-
NPDES data:
1. Reviewed database corrections for DMRLoads2007, PCSLoads2004,
PCSLoads2002, and PCSLoads2000 to determine whether corrections were made
during previous reviews and evaluated whether EPA should apply these
corrections to the 2008 DMR discharges.
2. Reviewed 2008 DMR data, hand-calculated annual pollutant loads, and compared
the results to loads calculated by the DMR Loading Tool and stored in
DMRLoads2008.
3. Reviewed PCS and ICIS-NPDES pipe description information available in PCS,
EPA's on-line Envirofacts data system, ICIS-NPDES supporting tables, or from
the facility's NPDES permit and permit fact sheet to identify monitored pollutant
discharges that are:
— Intermittent (e.g., tidal, seasonal, or occur after a storm event);
— Internal monitoring locations from which wastewater is combined with
other waste streams and monitored again, resulting in double-counting
loads; and
— Not representative of category discharges (e.g., stormwater runoff from
nonprocess areas, noncontact cooling water, or wastewater related to
operations in another point source category).
Table 4-5 presents EPA's facility review and corrections made to the DMRLoads2008
database.
4-20
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Monongahela Power
Company
Willow Island,
WV
Steam Electric
Power Generating
Chlorine
Outfall 001 free chlorine Jul 2008
concentration is 1,000 times
higher than other monthly
concentrations. Outfall 001 total
residual chlorine Sept and Oct
2008 concentrations were in mg/L
in the DMR Loadings Tool, while
Envirofacts concentrations are in
ug/L.
Revise Jul 2008 free chlorine and
Sept and Oct 2008 total residual
chlorine concentrations by
dividing by 1,000.
Fulton County
Commissioners
OH
Sanitary
Low Level
Mercury
Outfall 001 low level mercury
Sept 2008 concentration in the
DMR Loadings Tool is 1,000,000
times higher than the
concentrations reported in
Envirofacts.
Revise Sept 2008 mercury
concentration by dividing by
1,000,000. Revise number of
reporting units and number of
days to reflect annual reporting.
General Electric - Erie
Erie, PA
Metal Finishing
Mercury
Outfall 001 mercury 2008
concentration in the DMR
Loadings Tool is 1,000,000 times
higher than the 2007 concentration
that EPA corrected as a result of
facility-provided information.
Revise all mercury
concentrations by dividing by
1,000,000.
Ohio Valley Coal
Company
Washington TWP,
OH
Coal Mining
Selenium
Outfall 001 selenium Dec 2008
concentration in the DMR
Loadings Tool is 1,000,000 times
higher than other monthly
concentrations.
Revise Dec 2008 selenium
concentration by dividing by
1,000,000. Revise number of
reporting units and number of
days to reflect quarterly
reporting.
4-21
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
TX Eastern Trans-
Gladeville
Gladeville, TN
Electric & Gas
PCBs
Outfall 002 PCB Jan 2008
concentration in the DMR
Loadings Tool is 1,000 times
higher than other monthly
concentrations. Envirofacts units
for Jan 2008 are |ig/L. not mg/L.
Revise Jan 2008 PCB
concentration by dividing by
1,000.
Village of Elida
Elida, OH
Nonclassifiable
Low Level
Mercury
Outfall 001 low level mercury Jun,
Aug, and Sept 2008
concentrations are in the DMR
Loadings Tool as mg/L, while the
concentrations in Envirofacts are
in ng/L.
Revise Jun, Aug, and Sept 2008
low level mercury concentrations
by dividing by 1,000,000. Revise
number of reporting units and
number of days to reflect
quarterly reporting.
Clemson University
WWTF
Clemson, SC
Education
Total Mercury
Outfall 001 Mar, Jun, Sept 2008
total mercury concentrations in the
DMR Loadings Tool do not match
the concentrations in Envirofacts.
Revise total mercury
concentration values. Revise
number of reporting units and
number of days to reflect
quarterly reporting.
Carbon Limestone Landfill
OH
Landfills
Low Level
Mercury
Outfall 001 low level mercury Jan
and Dec 2008 concentrations are
in the DMR Loadings Tool as
mg/L, while concentrations in
Envirofacts are in ng/L.
Revise Jan and Dec 2008
mercury concentrations by
dividing by 1,000,000.
Tysons Foods, Inc.
Carthage, MS
Meat and Poultry
Products
Mercury
Facility contact identified that the
2008 total recoverable mercury
concentrations for outfall 001
were reported as ng/L but were in
the DMR Loadings Tool as mg/L
(Lovitt, 2010).
Revise mercury concentration by
dividing by 1,000,000. Revise
mercury quantities to reflect
concentrations updates.
4-22
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
AKZO Nobel Functional
Chemical
Axis, AL
Inorganic
Chemicals
Total Mercury
Outfall 006 Dec 2008 total
mercury concentration is 1,000
times higher than other
concentrations in the DMR
Loadings Tool. Facility contact
confirmed that the Dec 2008 total
mercury concentration was
reported in |ig/L. but was in the
DMR Loadings Tool as mg/L
(Williams, 2010).
Revise Dec 2008 total mercury
concentration by dividing by
1,000.
Arcelormittal Weirton,
Inc.
Weirton, WV
Iron and Steel
Cyanide
Outfall 003 Aug 2008 cyanide
concentration in the DMR
Loadings Tool is 1,000 times
higher than other monthly
concentrations.
Revise Aug 2008 cyanide
concentration by dividing by
1,000.
USEC PDGDP
McCracken, KY
Nonferrous Metals
Manufacturing
PCBs
Facility contact verified the 2008
PCB concentrations in the DMR
Loadings Tool and indicated that
the outfalls are for stormwater
runoff. The PCBs are due to
legacy activity at the site, and the
facility treats all process water that
may have PCBs using carbon
adsorption (Travis, 2010).
No action.
Cargill Corn Milling
(Progold)
Wahpeton, ND
Grain Mills
Chloride
Outfall 001 Jan 2008 chloride
concentration is 10,000 times
higher than other monthly
concentrations in the DMR
Loadings Tool. Also, Jan 2008
average concentration reported is
10,000 higher than the maximum
concentration.
Revise Jan 2008 average chloride
concentration by dividing by
10,000.
Marathon Oil - Maverick
Springs
Fremont County,
WY
Oil & Gas
Extraction
Sulfur
2008 sulfide concentrations are
comparable to 2007 and 2009
concentrations.
No action.
4-23
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Smithfield Packing Co Inc
Tar Heel, NC
Meat and Poultry
Products
Chlorine
Outfall 001 Apr through Sept
2008 chlorine concentrations are
in the DMR Loadings Tool as
mg/L, while the concentrations in
Envirofacts are in |ig/L.
Revise Apr through Sept 2008
chlorine concentrations by
dividing by 1,000.
Clear Lakes Trout
Company
Buhl, ID
Concentrated
Aquatic Animal
Production
Copper
Outfall 001 Jan 2008 copper
concentration is 9 mg/L, but all
other months are No Data
Indicator (NODI) 9 in the DMR
Loadings Tool. Facility contact
verified that the copper Jan 2008
concentration was a data entry
error (Bogaard, 2010).
Delete Jan 2008 copper
concentration and change NODI
code to 9.
Hercules, Incorporated
Brunswick, GA
Gum and Wood
Toxaphene
Facility contact stated that the
outfall 001 2008 toxaphene
concentrations were reversed with
the total suspended solids (TSS)
concentrations. Facility contact
stated that the toxaphene
concentrations are all below
detection limit (BDL) (Bernarack,
2010).
Reverse all toxaphene
concentrations and TSS
concentrations and add BDL
indicators to all toxaphene
concentrations.
Valley View Landfill
Trimble County,
KY
Landfills
Mercury
Outfall 001 Jun 2008 and outfall
004 Mar 2008 mercury
concentrations were high
compared to the other
concentrations reported. Facility
contact stated that the
concentrations for both outfalls
should be reported as nondetect.
The contact also stated that the
concentration value should be
0.0002, not 40 (Knarr, 2010).
Revise outfall 001 Jun 2008 and
outfall 004 Mar 2008 mercury
concentrations to 0.0002 mg/L
and add BDL indicators to
mercury concentrations.
4-24
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Former Koppers Facility
Kansas City, MO
Timber
TCDD
Facility contact confirmed that all
outfall 004 and 005 2008 TCDD
concentrations were all nondetect
(Rayna, 2010). Number of days
and number of reporting units did
not match reported concentrations.
Add BDL indicators to all 2008
TCDD concentrations for
outfalls 004 and 005. Revise the
number of reporting units and
number of days.
EI DuPont De Nemours &
Co
Washington, WV
OCPSF
Hexachloro-
benzene
Outfall 002, 005, and 102 2008
hexachlorobenzene concentrations
are reported as the same
concentration for all months.
Therefore, assumed that all the
concentrations should be
nondetect.
Add BDL indicators to all 2008
hexachlorobenzene
concentrations for outfalls 002,
005, and 102.
Eastman Chemicals/SC
Operations
Saint Matthews,
SC
OCPSF
Mercury
Outfall 001 Jan 2008 mercury
concentrations has a leading (i.e.,
prior to the decimal place) 4 in the
DMR Loadings Tool, while
Envirofacts has a leading 0.
Revise Jan 2008 mercury
concentration value to remove
the leading 4.
Galey & Lord/Society Hill
Society Hill, SC
Textile mills
Mercury
Outfall 001 2008 total mercury
concentration has a leading (i.e.,
prior to the decimal place) 4 in the
DMR Loadings Tool, while
Envirofacts has leading 0.
Revise 2008 total mercury
concentration value to remove
the leading 4.
Wyeth Research
Chazy, NY
Labs
Mercury
Outfall 001 Jul 2008 mercury
quantity in the DMR Loadings
Tool does not match the quantity
calculated using the concentration
and flow or data in Envirofacts.
EPA used the concentration and
flow to calculate the correct
quantity.
Revise Jul 2008 mercury
quantity.
4-25
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Bridgeport Water Plant
Bridgeport, OH
Drinking Water
Manganese
Outfall 002 Feb, Apr, and Nov
2008 manganese quantities in the
DMR Loadings Tool do not match
quantities calculated using the
concentration and flow or the data
reported in Envirofacts. EPA used
the concentration and flow to
calculate the correct quantity.
Revise hexachlorobenzene
quantity to match data reported
in Envirofacts
Koppers Industries Inc
Follansbee, WV
OCPSF
Hexachloro-
benzene
Outfall 101 Feb 2008
hexachlorobenzene quantities in
the DMR Loadings Tool do not
match data reported in
Envirofacts.
Revise hexachlorobenzene
quantity.
ASA Ethanol
Bloomingburg, LLC
OH
OCSPF
Iron, Fluoride
Outfall 001 Mar and Apr 2008
fluoride quantities are 1,000,000
times higher than the calculated
quantities using the concentrations
and flows in the DMR Loadings
Tool. Iron quantities for May and
Aug through Dec 2008 have a
leading (i.e., prior to the decimal
place) 4 in the DMR Loadings
Tool, while Envirofacts has
leading 0.
Revise Mar and Apr 2008
fluoride quantities by dividing by
1,000,000. Revise May and Aug
through Dec 2008 iron quantities
to remove the leading 4.
Special Metals Corp
New Hartford, NY
Nonferrous metals
manufacturing
PCB-1254
Outfall 001 PCB-1254 quantity
are 1,000 times higher than when
the quantity is calculated using the
concentration and flow in the
DMR Loadings Tool. All
concentrations were also reported
as non-detect in the DMR
Loadings Tool.
Revise PCB-1254 quantity to
match quantity calculated using
concentration and flow. Also,
add BDL indicators to PCB-1254
quantities.
4-26
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Smith's Pleasant Valley
OH
Nonclassifiable
Chlorine
Outfall 001 Jun, Aug, and Oct
2008 flows are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise Jun, Aug, and Oct 2008
flows for Outfall 001 by dividing
by 1,000,000.
Bulk Plant Inc
Flemingsb rg #39
Fleming County,
KY
Petroleum
Refining
Benzene
Outfall 001 flows for Mar, Jun,
and Sept 2008 are extremely high
(between 4,000 and 30,000
MGD). Flows should be reported
as GPD, not MGD.
Revise Mar, Jun, and Sept flows
for Outfall 001 by dividing by
1,000,000.
Pelican Grove
Campground
OH
Hotels & Other
Lodging Places
Chlorine
Outfall 001 flows for 2008 are in
the DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows for Outfall 001 by
dividing by 1,000,000.
SPARTA Water Treatment
Plant
Sparta, TN
Drinking Water
Treatment
Chlorine
Outfall 001 flows for Jan through
Jul 2008 are not consistent with
other months, or the data reported
in Envirofacts for 2009.
Revise Jan through Jul 2008
flows for Outfall 001 by dividing
by 1,000,000.
CAPPS Tavern
OH
Food Service
Establishments
Chlorine
Outfall 001 flows for 2008,
excluding Jan and Oct, are in the
DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows, excluding Jan and
Oct, for Outfall 001 by dividing
by 1,000,000.
Saint Ilija Macadonian
Church
OH
Membership
Organizations
Chlorine
Outfall 001 flows for 2008 are in
the DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows for Outfall 001 by
dividing by 1,000,000.
ContechU.S. LLC
Pierceton, IN
Wholesale Trade-
Durable Goods
Lead
Outfall 001 flow for Feb 2008 is
reported in the DMR Loadings
Tool as MGD, while other flows
in the DMR Loadings Tool are
reported as GPD.
Revise flow for Feb 2008 for
Outfall 001 by dividing by
1,000,000.
4-27
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Norbet Fun Family
Bowling
OH
Amusement &
Recreation
Services
Chlorine
Outfall 001 flows for 2008,
excluding Jan and Apr, are in the
DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows excluding Jan and
Apr, for Outfall 001 by dividing
by 1,000,000.
SAKAS, Inc.
OH
Metal Finishing
Chlorine
Outfall 001 flows for 2008 are in
the DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows for Outfall 001 by
dividing by 1,000,000.
Dowel Town-Liberty WTP
Liberty, TN
Drinking Water
Treatment
Aluminum
Outfall 001 flows for Jan, Mar,
and May 2008 are 1,000,000 times
higher than other reported flows
and the design flow.
Revise flows for Outfall 001
(Jan, Mar, May 2008) by
dividing by 1,000,000.
Speedway Super America
LLC
OH
Automotive
Dealers & Service
Stations
Chlorine
Outfall 001 flows for 2008,
excluding Jul, are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows, excluding Jul, for
Outfall 001 by dividing by
1,000,000.
Le-O-Na Falls Mobile
Home Park
OH
Real Estate
Chlorine
Outfall 001 flows for 2008,
excluding Jul, are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows, excluding Jul, for
Outfall 001 by dividing by
1,000,000.
MSAD #9
Farmington, ME
Education
Chlorine
Outfall 001 flows for 2008, except
Sept and Oct, are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are reported
as GPD.
Revise flows, excluding Sept and
Oct, for Outfall 001 by dividing
by 1,000,000.
MSAD #52
Turner, ME
Education
Chlorine
Outfall 001 flows for 2008, except
Jun through Aug, are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows, except Jun through
Aug, for Outfall 001 by dividing
by 1,000,000.
4-28
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
MEAD Depot Landfill
OH
Waste Combustors
Manganese
Outfall 001 flows for Aug through
Dec 2008 and Outfall 002 flows
for Jan and Mar through Aug 2008
are in the DMR Loadings Tool as
MGD, while flows in Envirofacts
are in GPD.
Revise flows listed as MGD for
Outfall 001 and Outfall 002 by
dividing by 1,000,000.
Charm Countryview Inn,
Inc.
OH
Food Service
Chlorine
Outfall 001 flows for Feb through
Oct 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows for Feb through Oct
2008 for Outfall 001 by dividing
by 1,000,000.
Korner Kitchen
OH
Food Service
Chlorine
Outfall 001 flows for Feb through
Dec 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows for Feb through
Dec 2008 for Outfall 001 by
dividing by 1,000,000.
Envirosystems
Incorporated
Hampton, NH
Independent and
Stand Alone Labs
Cadmium
Outfall 002 flows for Sept and Oct
2008 (DRIDs A and B) were
1,000,000 times higher than other
months reported and the permit
design flow is 400 GPD (U.S.
EPA Region 1, 2006).
Revise Sept and Oct 2008 flows
for Outfall 002 by dividing by
1,000,000.
Bullitt Co Landfill
Bullitt County,
KY
Landfills
Iron
Outfall 001 flows for Jan, July,
and October 2008 were 1,000,000
times higher than other flows
reported. KY DEP Permit
Manager indicated that flows for
Jan, July, and October 2008 were
reported as GPD, not MGD. Also
noted that the facility was a
municipal waste landfill (Becker,
2010).
Revise flows for Jan, July, and
October 2008 for Outfall 001 and
change SIC code to link to the
Landfills Category only.
Stevens Aviation, Inc.
Vandalia, OH
Wholesale Trade-
Nondurable Goods
Lead
Outfall 001 flow for Aug 2008 is
in the DMR Loadings Tool as
MGD, while flow in Envirofacts is
in GPD.
Revise flow for Aug 2008 for
Outfall 001 by dividing by
1,000,000.
4-29
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Reed Duplex Apt BLDG
Madison County,
KY
Real Estate
Chlorine
Outfall 001 flow for Sept 2008
was high compared to other flows.
KY DEP Permit Manager
indicated permit design flow is
0.001 MGD and that the facility
reported incorrect units (MGD
instead of GPD) (Becker, 2010).
Revise flow for Sept 2008 for
Outfall 001 by dividing by
1,000,000.
Deborah K. Schiemann
OH
Social Services
Chlorine
Outfall 001 flows for May through
Oct 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise flows for May through
Oct 2008 for Outfall 001 by
dividing by 1,000,000.
John W Black Aquatic
Center
Oldham County,
KY
Amusement &
Recreation
Services
Chlorine
Outfall 001 flows for May through
Sept 2008 are all reported in the
Loadings Tool as MGD, but
assumed were reported as GPD
because of the nature of the
facility (aquatic center).
Revise flows for May through
Sept 2008 for Outfall 001 by
dividing by 1,000,000.
Sugar Grove Bible Church
OH
Membership
Organizations
Chlorine
Outfall 001 flows for 2008 are in
the DMR Loadings Tool as MGD,
while flows in Envirofacts are in
GPD.
Revise flows for Outfall 001 by
dividing by 1,000,000.
Wullenweber Motors
OH
Wholesale Trade-
Durable Goods
Chlorine
Outfall 001 flows for Jan through
May, July, Aug, and Dec 2008 are
in the DMR Loadings Tool as
MGD, while flows in Envirofacts
are in GPD.
Revise flows for months listing
flow units of MGD for Outfall
001 by dividing by 1,000,000.
Cognis Corporation
OH
OCPSF
Copper
Outfall 010 flows for Oct 2008
and outfall 033 flows for May,
Aug, Nov 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are in GPD.
Revise MGD flows for Outfalls
010 and 033 by dividing by
1,000,000.
4-30
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Holiday Motel WWTF
Cleveland, TX
Hotels & Other
Lodging Places
Chlorine
Outfall 001 flows for Feb, Jun,
and Oct 2008 are 1,000,000 times
higher than flows reported for the
other months.
Revise flows for Feb, June, and
Oct for Outfall 001 by dividing
by 1,000,000.
A.P. Green Refractories,
Co.
Oak Hill, OH
Mineral Mining
Chlorine
Outfall 001 flows for 2008,
excluding Feb, are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are reported
as GPD.
Revise flows, excluding Feb, for
Outfall 001 by dividing by
1,000,000.
Sebasco Harbor Resort
LLC
Phippsburg, ME
Hotels
Chlorine
Outfall 002 flows for May through
Oct 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are GPD.
Revise flows for May through
Oct 2008 for Outfall 002 by
dividing by 1,000,000.
Newagen Seaside Inn
Southport, ME
Hotels
Chlorine
Outfall 001 flows for Jun through
Sept 2008 are in the DMR
Loadings Tool as MGD, while
flows in Envirofacts are GPD
(auto-corrected by the DMR
Loadings Tool).
Revise June, July, and Sept 2008
flows for Outfall 001 by dividing
by 1,000,000.
US Dept of the Interior
Winter Harbor,
ME
National Security
& International
Affairs
Chlorine
Outfall 001 flows for May and Jun
2008 are in the DMR Loadings
Tool as MGD, while flows in
Envirofacts are in GPD.
Revise flows for May and Jun
2008for Outfall 001 by dividing
by 1,000,000.
Engineered Coil Company
High Ridge, MO
Metal Finishing
Copper
Outfall 002 flows for Nov 2008
are in the DMR Loadings Tool as
MGD, while flows in Envirofacts
are in GPD.
Revise flows for Nov 2008 for
Outfall 002 by dividing by
1,000,000.
4-31
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Harbison-Walker
Refractor
Vanalia, OH
Mineral Mining
and Processing
Aluminum
Outfall 001 flows for Mar, Jun,
and Sept 2008, are not consistent
with other months or the design
flow of 230 MGD. The facility
permit stated that the flows are
based on precipitation; however,
the units are suspected to be
incorrect (State of Missouri,
2005).
Revise March, June, and Sept
flows for Outfall 001 by dividing
by 1,000.
Hamilton Water Treatment
Plant
Hamilton, AL
Drinking Water
Treatment
Aluminum
Outfall 001 flows for 2008,
excluding Feb, are 1,000 times
higher than corrected flows from
2007.
Revise all flows for Outfall 001
by dividing by 1,000.
Cook's Hams, Inc.
Lincoln, NE
Meat and Poultry
Products
Sulfur
Outfall 001 flow for Jun 2008 is
1,000 times higher than all other
months, the maximum daily flow
for Jun 2008, and the permit
design flow (0.069 MGD).
Revise Jun 2008 flow for Outfall
001 by dividing by 1,000.
PRASA WTP Miradero
Filter PLT
Mayaguez, PR
Drinking Water
Treatment
Chlorine
Outfall 001 flow for May 2008
was 1,000 times higher than the
flows reported for other months.
Suspect units error during data
entry.
Revise May 2008 flow for
Outfall 001 by dividing by 1,000.
PRASA WTP Sergio
Cuevas
Trujillo Alto, PR
Drinking Water
Treatment
Chlorine
Outfall 001 flows for May and
Aug 2008 are 1,000 times higher
than other monthly flows.
Revise May and Aug 2008 flows
for Outfall 001 by dividing flows
by 1,000.
National Copper and
Smelting
Huntsville, AL
Copper forming
Zinc
Outfall 002 flows for Jul through
Nov 2008 were 1,000 times higher
than other reported monthly flows.
Also, zinc concentrations reported
for July through Sept 2008 for
Outfall 002 were 1,000 times
higher than other monthly
concentrations.
Revise flows for Jul through Nov
2008 for Outfall 002 by dividing
flows by 1,000. Revise
concentrations for July through
Sept 2008 for zinc by dividing
concentrations by 1,000.
4-32
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
Bayview Detention CTR
WWTF
Los Fresnos, TX
Justice, Public
Order, & Safety
Chlorine
Outfall 001 flows for 2008
reported to the DMR Loadings
Tool did not match the Envirofacts
data. TCEQ contact indicated that
the facility is a POTW and the
flow permit limit is 0.16 MGD.
Revise flows for Outfall 001 by
dividing flows by 1,000 and
change SIC code to link to
POTWs.
KODAK Colorado
Division
Windsor, CO
Metal Finishing
Silver
Outfall 006 flow is not consistent
with other flows reported for the
facility in 2008. Facility contact
stated that the average flow for
Outfall 006 is about 150 L/day
(0.000039 MGD) (Peterson,
2010).
Replace flows for Outfall 006.
Catskill State Fish
Hatchery
Livingston Manor,
NY
Concentrated
Aquatic Animal
Production
Formaldehyde
Outfall 001 flows for 2008 were
extremely high. NYSDEC contact
verified that flows for all months
were reported in GPM, not MGD,
based on discussions with the
facility (Sansalone, 2010).
Database Change: Revise flows
for Outfall 002 by dividing by
694.
SEAPAC of Idaho, Inc.
Hagerman, ID
Concentrated
Aquatic Animal
Production
Copper
Outfall 001 flows and outfall OSB
flows for 2008 were reported with
the incorrect units (unknown) in
the DMR Loadings Tool when
compared to Envirofacts (cubic
feet per second (CFS) with
different values).
Database Change: Revise flows
for Outfalls 001 and OSB by
dividing by 1.55.
Upshur Property, Inc.
Tallmansville,
WV
Coal Mining
Selenium
Outfalls 001, 002, and 004 flows
are in the DMR Loadings Tool as
MGD, while Envirofacts flows are
in GPM. Outfall 402 flows are in
the DMR Loadings Tool as MGD
while Envirofacts flows are in
CFS.
Database Change: Revise flows
for Outfalls 001, 002, 004 from
GPM to MGD by dividing by
694. Revise flows for Outfall 402
from CFS to MGD by dividing
by 1.55.
4-33
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-5. Summary of DMRLoads2008 Facility Review
Facility
Location
Point Source
Category
Pollutant(s)
in Question
Review Findings
Action Taken/
Database Correction
US Steel Corp - Mon
Valley Works - Edgar
Thomson
Braddock, PA
Iron and Steel
Iron
Facility contact identified that the
facility measures pollutant
concentrations in their stormwater
prior to commingling with
noncontact cooling water. EPA
developed a flow factor using the
2004 data, to determine the
amount of stormwater in the total
outfall flow for more accurate load
estimates (Belack, 2007).
Database Change: Revise flows
for Outfalls 005, 006, 008, and
009 by applying flow factor.
4-34
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Section 4 - Methodology, Data Sources, and Limitations
4.4 Corrections to the TRIReleases2008 Database
EPA developed the TRIReleases2008 database as part of the 2010 annual review using
the methodology explained in the 2009 SLA Report (U.S. EPA, 2009) with the methodology
updates described in Section 4.2.2.
During previous screening-level analyses, EPA identified numerous facility-specific
corrections for TRI data reported for calendar years 2002 through 2007. Several of these
corrections similarly apply to the 2008 TRI data. In addition, EPA reviewed the quality of the
2008 TRI data for facilities with discharges that have the greatest impact on total category loads
and category rankings. Table B-l in Appendix B of this report lists all corrections made to the
2008 TRI data.
4.4.1 TRIReleases2008: Categorization of Discharges
This section describes database corrections to categorization of facilities and pollutant
discharges in TRIReleases2008. Section 4 of the 2009 SLA Report describes the development of
the NAICS/Point Source Category Crosswalk, which EPA uses to link between facility NAICS
codes and categories with existing ELGs (U.S. EPA, 2009). Because most point source
categories are not defined by NAICS code, the relationship between NAICS code and point
source category is not a one-to-one correlation. A single NAICS code may include facilities in
more than one point source category, and associating an NAICS code with only one category
may be an oversimplification. Also, many facilities have operations subject to more than one
point source category. Further, facilities in some categories report a variety of NAICS codes that
do not correlate directly to a point source category, precluding identification by NAICS code
(e.g., Centralized Waste Treatment facilities). Section 5 of the 2009 SLA Report describes the
database changes, summarized below (U.S. EPA, 2009):
• Facility-Level Point Source Category Assignment. For some NAICS codes that
include facilities subject to guidelines from more than one point source category,
EPA was able to assign each facility to the category that best applied to the
majority of its discharges. EPA reviewed information available about each facility
to determine which point source category applied to the facility's operations.
• Pollutant-Level Point Source Category Assignment. Many facilities have
operations subject to more than one point source category. For most of these
facilities, EPA cannot divide the pollutant discharges among the applicable point
source categories. Below are two exceptions where EPA was able to assign
wastewater discharges of certain chemicals to the appropriate point source
category:
— OCPSF/Pesticide Chemicals. EPA removed all pesticide discharges from
the OCPSF Category and included them as discharges from the Pesticide
Chemicals Category.
— MP&M/Metal Finishing. EPA used the methodologies described in
Section 4 of the 2009 SLA Report to apportion pollutant loads between the
MP&M and Metal Finishing Categories.
4-35
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Section 4 - Methodology, Data Sources, and Limitations
• Categories Not Identified by NAICS Code (e.g., Centralized Waste Treatment,
Waste Combustor, and Landfills). The NAICS/Point Source Category Crosswalk
does not assign any NAICS codes to the Centralized Waste Treatment (CWT)
Point Source Category (40 CFR Part 437), Waste Combustor Point Source
Category (30 CFR Part 444), or Landfills Category (40 CFR Part 445).
Furthermore, the applicability of these three regulations is not defined by NAICS
codes and no NAICS code properly describes the CWT, waste combustor, or
landfill services. Currently, EPA assigns all facilities reporting NAICS code
562213 (Solid Waste Combustors and Incinerators) as part of the Waste
Combustor Category. The remaining facilities, with NAICS codes 562211
(Hazardous Waste Treatment and Disposal) and 562219 (Other Nonhazardous
Waste Treatment and Disposal), are included in all three categories, which over
estimates the category loads. During previous annual reviews, EPA has identified
certain facilities that should be categorized as a CWT, waste combustor, or
landfill. EPA assigned these facilities to the correct industrial category. As
facilities continue to be reviewed due to high TWPE, EPA classifies them into the
correct industrial category based on facility operations.
4.4.2 TRIReleases2008: Pollutant Corrections
This section describes database corrections made to discharges of specific pollutants
reported to the TRI for EPA's 2010 screening-level review in the TRIReleases2008 database.
• Metal Compounds. For TRI reporting, facilities may be required to report
discharges of a metal (e.g., zinc) and its compounds (e.g., zinc compounds) on a
single reporting form. Because the release quantity for the metal compound
reporting is based on the mass of the parent metal, EPA uses the parent metal
TWF to calculate TWPE for the metal and metal compound discharges. For
ranking purposes, EPA combined the TWPEs for the metal and metal compounds
(i.e., TWPE reported for "zinc and zinc compounds"). For more details on this
correction, see Section 3.4.4 of the 2009 SLA Report (U.S. EPA, 2009).
• Sodium Nitrite. For TRI reporting, sodium nitrite release quantities are reported as
the mass of the sodium nitrite. Sodium nitrite is an ionic salt that will fully
dissociate into nitrite and sodium ions in aqueous solutions. In addition, the nitrite
ions are unstable in water and will oxidize to nitrate. Therefore, EPA converted
the pounds of TRI-reported sodium nitrite discharges to pounds of nitrogen in the
discharge and used the TWF for "nitrate as N" (0.0032) to calculate TWPE for
sodium nitrite. In addition, EPA also used the POTW removal for nitrate to
account for the removal of sodium nitrite in POTWs.
• Phosphorus (Yellow or White). Yellow and white phosphorus, both allotropes of
elemental phosphorus, are hazardous chemicals that spontaneously ignite in air.
During the 2006 screening-level review, EPA determined that facilities were
incorrectly reporting discharges of total phosphorus (i.e., the phosphorus portion
of phosphorus-containing compounds) as phosphorus (yellow or white) (U.S.
EPA, 2006a). Therefore, EPA deleted all phosphorus (yellow or white) discharges
reported to TRI for the 2010 screening-level review.
4-36
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Section 4 - Methodology, Data Sources, and Limitations
4.4.3 TRIReleases2008: Data Quality Review
EPA evaluated the quality of TRI data for use in the 2010 screening-level review and
prioritization of loadings of toxic and nonconventional pollutants discharged by industrial
categories based on completeness, accuracy, reasonableness, and comparability. The Quality
Assurance Project Plan for the 2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and
PCS Industrial Category Discharge Data describes the quality objectives in more detail (ERG,
2009). The following discussion provides an overview of the quality review steps:
• Completeness Checks. EPA compared counts of facilities in TRIReleases2008 to
I RI Re lease s200 7, TRIReleases2005, TRIRe lease s2004, TRI Release s2003,
TRIReleases2002, and TRIReleases2000 to describe the completeness of the
database. The comparison showed that for 72 percent of the point source
categories or NAICS code groupings, the number of facilities reporting
wastewater discharges changed by less than 25 percent from 2007 to 2008. EPA
also determined that most NAICS codes exhibiting a large percentage change did
so because only a few facilities in these NAIC codes reported discharges (e.g., a
change from one facility to three facilities is equivalent to a 200 percent increase).
• Accuracy of Facility Discharges. EPA reviewed the accuracy of facilities'
discharges that had the greatest impact on total category loads and category
rankings. EPA identified facilities for review whose pollutant discharges
accounted for more than 95 percent of the TWPE for their point source category.
EPA compared 2008 TRI data to other available information, such as PCS and
ICIS-NPDES, information from EPA's Envirofacts web page, the facilities'
NPDES permits and permit fact sheets, and discussion with facility contacts.
• Accuracy of Category Discharges. EPA reviewed the accuracy of category
discharges by verifying that pollutant discharges in TRI were assigned to the
appropriate point source category. EPA used engineering judgment to determine
if pollutant discharges were reasonably associated with the point source category.
• Accuracy of Database Queries. EPA's quality review for the development of
TRIReleases2008 included accuracy checks for database queries in
TRICalculations20087 and TRIReleases2008. Documentation of accuracy checks
is provided in a QC table in each Microsoft Access™ database.
• Comparability. EPA compared TRIReleases2008 to / RI Re lease2007,
TRIReleases2005, TRIRe lease s2004, TRIReleases2003, TRIReleases2002, and
TRIReleases2000 to identify pollutant discharges that differ more than the year-
to-year variation of other chemicals and facilities. From the comparison, EPA
determined that 42 percent of the pollutants discharged in both 2008 and 2007 had
a change of less than 50 percent in the quantity discharged. EPA also determined
that most of the pollutants with a large percentage change reflected initial
discharges of small quantities. In addition, most of these pollutant discharges
resulted in small TWPEs.
7 TRICalculations2008 is a database EPA created to analyze raw TRI data. See Section 2.4 of the 2009 SLA Report
for more detailed information (U.S. EPA, 2009).
4-37
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Section 4 - Methodology, Data Sources, and Limitations
4.4.4 TRIReleases2008: Facility Reviews
Table 4-6 presents EPA's TRI facility review and corrections made to the
TRIReleases2008 database. EPA reviewed the accuracy of calculated discharges from facilities
with discharges that have the greatest impact on total category loads and category rankings. EPA
used the following criteria to select facilities for review:
• Facilities with the highest toxic-weighted discharges of all facilities reporting to
TRI for reporting year 2008;
• Facilities with the highest toxic-weighted discharges of individual chemicals that
contribute the majority of the toxic-weighted discharges for all categories; and
• Facilities with the highest toxic-weighted discharges from categories that
contribute the majority of the toxic-weighted discharges for all categories.
For the identified facilities, EPA used the following steps to review the accuracy of the
loads calculated from TRI data.
1. Review database corrections for TRIReleases2007, TRIReleases2005,
TRIReleases2004, TRIReleases2003, TRIReleases2002, and TRIReleases2000 to
determine whether corrections were made during previous reviews and evaluate
whether these corrections should be applied to TRIReleases2008.
2. Review discharges reported to TRI for other reporting years (i.e., 2000, 2002,
2003, 2004, 2005, and 2007) and compare to discharges reported to TRI for
reporting year 2008.
3. Review 2008 DMR data in PCS and ICIS-NPDES, if available, to hand-calculate
annual pollutant loads and compare to discharges reported to TRI for reporting
year 2008.
4. Contact the facility to verify whether the pollutant discharges are reported
correctly.
4-38
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-6. Summary of TRIReleases2008 Facility Review
Facility Name
Facility Location
Point Source
Category
Pollutant(s) in
Question
Review Findings
Actions Taken/Database
Correction
Carolina Pole Leland
Leland, NC
Timber
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Facility contact stated that
the reported grams of dioxin are
based on monitoring data - some
congeners were detected in 2008
but all were BDL in 2009. Facility
provided sampling data that
indicated that the dioxin
distribution was based on the TRI
2007 distribution numbering
(House, 2010).
Revise dioxin distribution.
Clean Harbors Deer Park,
LP
La Porte, TX
Waste
Combustors
Benzidene
Reviewed benzidine DMR data in
the DMR Loadings Tool and
determined that all 2008
discharges were 0 mg/L.
Revise benzidine load to zero.
DuPont Chambers Works
Deepwater, NJ
OCPSF
Hexachlorobenzene,
PACs
Facility contact indicated that
hexachlorobenzene loads were
calculated using half the detection
limit. Facility contact confirmed
that hexachlorobenzene and PACs
were never detected at the facility
(Northey, 2007).
Revise hexachlorobenzene and
PACs loads to zero.
DuPont Chemicals - Starke
Facility
Starke, FL
Ore Mining
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Facility contact confirmed
that the dioxin distribution was
incorrect. Facility provided
facility-specific distribution
(Wood, 2010).
Revise dioxin distribution.
4-39
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-6. Summary of TRIReleases2008 Facility Review
Facility Name
Facility Location
Point Source
Category
Pollutant(s) in
Question
Review Findings
Actions Taken/Database
Correction
DuPont Delisle Plant
Pass Christian,
MS
Inorganic
Chemicals
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Facility contact confirmed
that the dioxin distribution was
incorrect. Facility provided
facility-specific distribution
(Wood, 2010).
Revise dioxin distribution.
DuPont Edge Moor
Edgemoor, DE
Inorganic
Chemicals
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Facility contact confirmed
that the dioxin distribution was
incorrect. Facility provided
facility-specific distribution
(Wood, 2010).
Revise dioxin distribution.
DuPont Johnsonville Plant
New Johnsonville,
TN
Inorganic
Chemicals
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Facility contact confirmed
that the dioxin distribution was
incorrect. Facility provided
facility-specific distribution
(Wood, 2010).
Revise dioxin distribution.
ExxonMobil Chemical
Baton Rouge Chemical
Plant
Baton Rouge, LA
OCPSF
PACs
Facility contact confirmed that the
pounds released were based on
half the detection limit and that
PACs were never detected at the
facility (Fellows, 2003).
Revise PACs load to zero.
ExxonMobil Oil Corp
Joliet Refinery
Channahon, IL
Petroleum
Refining
Hexachlorobenzene
Facility contact confirmed that the
pounds released were based on
half the detection limit. Contact
did not recall any previous years
where hexachlorobenzene was
detected (Noga, 2010).
Revise hexachlorobenzene load
to zero.
4-40
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-6. Summary of TRIReleases2008 Facility Review
Facility Name
Facility Location
Point Source
Category
Pollutant(s) in
Question
Review Findings
Actions Taken/Database
Correction
Formosa Plastics
Corporation Louisiana
Baton Rouge, LA
CCH
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Dioxin distribution reported
in 2008 is similar to 2003
distribution (using previous
reporting years' numbering
scheme).
Revise dioxin distribution.
Formosa Plastics
Corporation Texas
Point Comfort,
TX
CCH
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Dioxin distribution reported
in 2008 is similar to 2003
distribution (using previous
reporting years' numbering
scheme).
Revise dioxin distribution.
Graftech International
Holdings, Inc.
Columbia, TN
Carbon Black
Manufacturing
PACs
Facility contact provided PACs
sampling data. Facility reviewed
the monitoring data and
determined they overestimated the
PAC discharges (1091.23
pounds). Facility contact said they
should have reported discharges
as 246 pounds of PACs. The
monitoring results also provided a
distribution for the PAC
compounds to create a facility-
specific TWF (Aslinger, 2010).
Revise PAC annual load (LBY)
from 1,091 to 246. Calculate
TWPE using facility-specific
TWF.
H. Kramer & Co.
Chicago, IL
Nonferrous
Metals
Manufacturing
Phosphorous
(Yellow or White)
Elemental phosphorus is not likely
to be discharged by facilities, and
is likely reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
4-41
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Section 4 - Methodology, Data Sources, and Limitations
Table 4-6. Summary of TRIReleases2008 Facility Review
Facility Name
Facility Location
Point Source
Category
Pollutant(s) in
Question
Review Findings
Actions Taken/Database
Correction
John Morrell & Co.
Sioux Falls, SD
Meat and
Poultry
Mercury
Facility contact confirmed that
mercury discharges are estimated
based on metals testing performed
for the city discharge. Contact
stated that all mercury samples
were BDL (Draveland, 2010).
Revise mercury load to zero.
Lima Refining Co.
Lima, OH
Petroleum
Refining
Phosphorous
(Yellow or White)
Elemental phosphorus is not likely
to be discharged by facilities and
is likely reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
Louisiana Pigment Co L.P.
Westlake, LA
Inorganic
Chemicals
Dioxin Compounds
Facility did not provide a water
congener distribution for 2008.
Use facility provided distribution
from 2007 (Kashyap, 2009).
Revise dioxin distribution.
Occidental Chemical Corp
Columbia, TN
Inorganic
Chemicals
Phosphorous
(Yellow or White)
Elemental phosphorus is not likely
to be discharged by facilities, and
is likely reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
PCS Nitrogen Fertilizer LP
Augusta, GA
Fertilizer
Manufacturing
Dioxin Compounds
Facility did not recognize the
dioxin distribution numbering
change for the 2008 reporting
year. Dioxin distribution reported
in 2008 is similar to 2005
distribution (using previous
reporting years' numbering
scheme).
Revise dioxin distribution.
U.S. Army Pine Bluff
Arsenal
Pine Bluff, AR
National
Security &
International
Affairs
Phosphorous
(Yellow or White)
Elemental phosphorus is not likely
to be discharged by facilities and
is likely reported incorrectly.
Revise phosphorus (yellow or
white) load to zero.
4-42
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Section 4 - Methodology, Data Sources, and Limitations
4.4.5 Trends in TRI Data
EPA has identified a consistent decrease every year since 2002 in the total number of
facilities reporting to TRI. EPA also identified a consistent decrease in the number of facilities
reporting discharges to TRI from 2002 to 2007. However, the number of facilities reporting
discharges to TRI increased from 2007 to 2008. Table 4-7 illustrates the trends since 2002.
Table 4-7. Number of Facilities with Data in TRI for Reporting Years 2002 Through 2008
Reporting Year
Number of Facilities Reporting to
TRI
Number of Facilities Reporting
Discharges to TRI
2002
24,379
8,291
2003
23,811
8,051
2004
23,675
7,930
2005
23,461
7,837
2006
22,880
7,506
2007
21,965
6,572
2008
21,694
6,891
Source: TRJReleases2002\ TRlReleases2003; TRIReleases2004; TRIReleases2005; TRJReleases2006\
TRIReleases2007\ and TRIReleases2008.
EPA does not have sufficient information to determine the cause of the decrease in the
number of facilities reporting to TRI over the past seven years. The aggregate number of
establishments8 reported to the U.S. Economic Census increased from 2002 to 2007. No changes
in reporting requirements occurred that can be attributed to the decrease. EPA will continue to
monitor this change in the future.
4.5 TRIReleases2008 Rankings and DMRLoads2008 Rankings
After incorporating the changes discussed in Sections 4.3 and 4.4, EPA generated the
final versions of the TRIReleases and DMRLoads databases used for the 2010 screening-level
review: TRIReleases2008 v3 and DMRLoads2008_v2. Tables C-l and C-2 in Appendix C
present the category rankings by TWPE from the TRIReleases2008 v3 and DMRLoads2008 v2
databases, respectively. The category rankings presented in these tables reflect all the corrections
made during the 2010 screening-level reviews. Tables C-3 and C-4 in Appendix C present the
six-digit NAICS code rankings by TWPE from TRIReleases2008 v3 and the four-digit SIC code
rankings by TWPE from DMRLoads2008_v2, respectively. Tables C-5 and C-6 in Appendix C
present the chemical rankings by TWPE from TRIReleases2008 v3 and DMRLoads2008 v2,
respectively.
4.6 Methodology, Data Sources, and Limitations References
1. Aslinger, Julia. 2010. Notes from E-mail Communication between Julia Aslinger, Center
for Toxicology, and Environmental Health, LLC and Elizabeth Sabol, Eastern Research
8 EPA reviewed only 3-digit NAICS code industry groups that were eligible for TRI reporting. Refer to Chapter 2 of
the 2009 SLA Report (EPA, 2009) for more detail.
4-43
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Section 4 - Methodology, Data Sources, and Limitations
Group, Inc. "RE: PAC Discharge Summary." (March 22). EPA-HQ-OW-2008-0517
DCN 07253.
2. Becker, Jory. 2010. Notes from Telephone Conversation between Jory Becker, KY DEP,
and Jessica Wolford, Eastern Research Group, Inc. "RE: Review of DMR data and
Permits for Bullitt County Landfill (KY0091651) and Reed Duplex Apt. Bldg.
(KY0095036)." (February 22). EPA-HQ-OW-2008-0517 DCN 07254.
3. Belack, Dan. 2007. Notes from E-mail Communication between Dan Belack, US Steel,
and Jan Matuszko, U.S. EPA. "RE: 2004 PCS Discharges." (May 7). EPA-HQ-OW-
2006-0771-0480.
4. Bernarack, Christopher. 2010. Notes from E-mail Communication between Christopher
Bernarack, GADEQ, and William Swietlik, U.S. EPA. "RE: Resolution of Hercules, Inc.
Toxaphene Outlier." (April 25). EPA-HQ-OW-2008-0517 DCN 07255.
5. Bogaard, Dirk. 2010. Notes from Telephone Conversation between Dirk Bogaard, Clear
Lakes Trout Company, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Copper
concentration reported to DMR in 2008." (April 22). EPA-HQ-OW-2008-0517 DCN
07256.
6. Draveland, Steve. 2010. Notes from Telephone Conversation between Steve Draveland,
John Morrell & Co. and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Basis of
Mercury and Mercury Compound load reported to TRI in 2008." (February 12). EPA-
HQ-OW-2008-0517 DCN 07257.
7. ERG. 2009. Eastern Research Group, Inc. Revised Quality Assurance Project Plan for the
2009 Annual Screening-Level Analysis of TRI, ICIS-NPDES, and PCS Industrial
Category Discharge Data. Chantilly, VA. (September). EPA-HQ-OW-2008-0517-0507.
8. Fellows, Dave. 2003. Notes from Telephone Conversation between Dave Fellows, Exxon
Mobile, and Eastern Research Group, Inc. "RE: Toxic Release Inventory Inquiry."
(August 12). EPA-HQ-OW-2003-0074 DCN 00336.
9. House, Jane. 2010. Notes from Telephone Conversation between Jane House, Carolina
Pole - Leland, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Dioxin
Distribution and Dioxin load reported to TRI in 2008." (March 15). EPA-HQ-OW-2008-
0517 DCN 07258.
10. Kashyap, Vikram. 2009. Notes from E-mail Communication between Vikram Kashyap,
Louisiana Pigment Co., and Eleanor Codding, Eastern Research Group, Inc. "RE:
Response to EPA Questions on 2007 TRI Dioxin Water Releases - Louisiana Pigment
Company." (May 8). EPA-HQ-OW-2008-0517-0094.
11. Knarr, Bill. 2010. Notes from E-mail Communication between Bill Knarr, Kenvirons,
Inc., and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Valley View Landfill -
Mercury Discharges DMR 2008." (March 23). EPA-HQ-OW-2008-0517 DCN 07259.
4-44
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Section 4 - Methodology, Data Sources, and Limitations
12. Lovitt, Faith. 2010. Notes from Telephone Conversation between Faith Lovitt, Tyson
Foods, Inc., and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Mercury
concentration reported to DMR in 2008." (February 19). EPA-HQ-OW-2008-0517 DCN
07260.
13. Noga, Jeff. 2010. Notes from Telephone Conversation between Jeff Noga, ExxonMobil
Oil Corp., and Jessica Wolford, Eastern Research Group, Inc. RE: Joilet Refinery's
hexachlorobenze discharges in 2008. (February 15). EPA-HQ-OW-2008-0517 DCN
07303.
14. Northey, Scott. 2007. Notes from Telephone Conversation between Scott Norhtey,
DuPont Chambers Works, and Chris Krejci, Eastern Research Group, Inc. "RE:
Hexachlorobenzene discharges reported by DuPont Chambers Works." (December 12).
EPA-HQ-OW-2006-0771-1171.
15. OMB. 1987. Office of Management and Budget. Standard Industrial Classification
Manual. Washington, DC. (Unknown). EPA-HQ-OW-2008-0517.
16. Peterson, Eric. 2010. Notes from Telephone Conversation between Eric Peterson, Kodak
Colorado Division, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Silver
concentration reported to DMR in 2008." (February 16). EPA-HQ-OW-2008-0517 DCN
07261.
17. Rayna, Dave. 2010. Notes from Telephone Conversation between Dave Rayna, Former
Koppers, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: TCDD concentrations
reported to DMR in 2008." (March 17). EPA-HQ-OW-2008-0517 DCN 07262.
18. Sansalone, John. 2010. Notes from Telephone Conversation between John Sansalone,
DEC Region 3 Office, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Flows
reported to DMR in 2008." (March 17). EPA-HQ-OW-2008-0517 DCN 07263.
19. State of Missouri. 2005. Department of Natural Resources Water Discharge Permit
NPDES M00000710 - Harbison Walker Refractories Company - Vandalia Plant.
Vandalia, MO. (May 27). EPA-HQ-OW-2008-0517 DCN 07264.
20. Stuhlfauth, Gary. 2007. Notes from Telephone Conversation between Gary Stuhlfauth,
Ohio USEPA, and TJ Finseth, Eastern Research Group, Inc. "RE: Low level mercury
discharge requirements on NPDES permits in Ohio." (January 22). EPA-HQ-OW-2006-
0771-0487.
21. Travis, Chris. 2010. Notes from Telephone Conversation between Chris Travis, USEC
PDGDP, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: PCB concentrations
reported to DMR in 2008." (March 17). EPA-HQ-OW-2008-0517 DCN 07265.
22. U.S. EPA Region 1. 2006. NPDES Fact Sheet: EnviroSystems Inc. - Hampton, New
Hampshire. (April 11). EPA-HQ-OW-2008-0517-0075.
4-45
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Section 4 - Methodology, Data Sources, and Limitations
23. U.S. EPA. 2000. EPCRA Section 313 Guidance for Reporting Toxic Chemicals Within
the Dioxins andDioxin-Like Compounds Category. EPA-745-B-00-021. Washington,
DC. (December). EPA-HQ-OW-2003-0074-1150.
24. U.S. EPA. 2005. Draft Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. June. EPA-HQ-OW-2004-0032-0857.
25. U.S. EPA. 2006b. Toxic Weighting Factor Development in Support of CWA 304(m)
Planning Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634.
26. U.S. EPA. 2006a. Technical Support Document for the 2006 Effluent Guidelines
Program Plan. EPA-821-R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-
0032-2782.
27. U.S. EPA. 2009. Technical Support Document for the Annual Review of Existing Effluent
Guidelines and Identification of Potential New Point Source Categories. EPA-821-R-09-
007. Washington, DC. (October). EPA-HQ-OW-2008-0517-0515.
28. Williams, Sylvia. 2010. Notes from E-mail Communication between Sylvia Williams,
Akzo Noble, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Nobel - DMR 2008
Mercury Discharges." (March 22). EPA-HQ-OW-2008-0517 DCN 07266.
29. Wood, Ken. 2010. Notes from E-mail Communication between Ken Wood, DuPont, and
Ellie Codding, Eastern Research Group, Inc. "RE: Request for Clarification of 2008 TRI
Data for EPA's Annual Review." (April 21). EPA-HQ-OW-2008-0517 DCN 07267.
4-46
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Part II - Results of the 2010 Annual Review
PART II: RESULTS OF THE 2010 ANNUAL REVIEW OF
INDUSTRIAL CATEGORIES WITH EXISTING ELGS
ii
-------
Section 5 - 2010 Annual Review
5. 2010 Annual Review of Existing Effluent Limitations Guidelines and
Standards and Ranking of Point Source Categories
For the 2010 annual review, EPA conducted the following activities:
• Updated the reviews from previous years (i.e., revised the 2009 annual review
results with new or corrected data);
• Performed new researches (i.e., contacted industry to verify discharges, conducted
literature searches, and collected additional data from site visits and state
permitting agencies); and
• Solicited information from stakeholders through comment response and other
stakeholder outreach (e.g., meetings with industry trade groups).
This section presents the results of the 2009 annual review, the results of the 2010
screening-level review, and the prioritization of categories for the 2010 annual review.
5.1 Summary of the Results from the 2009 Annual Review
EPA published its annual review of existing effluent limitation guidelines and standards
(ELGs) as part of the Preliminary 2010 Plan on October 30, 2009 (74 FR 68599). In the 2009
annual review, EPA identified 10 point source categories that represented the bulk of the
estimated toxic discharges (as measured by toxic-weighted pound equivalents (TWPE)) from
existing industrial point source categories. EPA ranked each point source category by the amount
of toxic pollutants in its discharges (as measured by TWPE) and identified the Steam Electric
Power Generating (Steam Electric) Point Source Category (Category) (40 CFR Part 423) as the
category with the highest TWPE (accounting for more than 72 percent of the total TWPE). EPA
identified the following seven additional categories with potentially high TWPE discharge
estimates (accounting for almost 24 percent of existing point source category TWPE):
• Pulp, Paper and Paperboard (40 CFR Part 430);
• Fertilizer Manufacturing (40 CFR Part 418);
• Organic Chemicals, Plastics and Synthetic Fibers (40 CFR Part 414);
• Petroleum Refining (40 CFR Part 419);
• Inorganic Chemicals Manufacturing (40 CFR Part 415);
• Nonferrous Metals Manufacturing (40 CFR Part 421); and
• Ore Mining and Dressing (40 CFR Part 440).
EPA concluded its detailed study of the Steam Electric Category and decided to pursue an
effluent guidelines rulemaking for the category. For the seven categories listed above, EPA
conducted preliminary category reviews based on the results of the 2009 screening-level review
and stakeholder comments. EPA determined that it would continue the preliminary category
review for the Ore Mining and Dressing Category as part of the 2010 annual review to collect
additional information on pollutant discharges and potential treatment technology options. For
the remaining six categories, EPA determined that these categories were not a hazard priority
based on data available for the 2009 annual review.
EPA also conducted detailed studies of the Oil and Gas Extraction Category (40 CFR
Part 435), to assess whether to revise the limits to include Coalbed Methane Extraction as a new
subcategory, and the Health Care Industry (including Hospitals (40 CFR Part 460)) during the
5-1
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Section 5 - 2010 Annual Review
2009 annual review that were conducted as a result of public comments. EPA decided to
continue these two detailed studies as part of the 2010 annual review.
In view of the annual nature of its reviews of existing ELGs, EPA believes that each
annual review can and should influence succeeding annual reviews (e.g., by indicating data gaps,
identifying new pollutants or pollution reduction technologies, or otherwise highlighting
industrial categories for more detailed scrutiny in subsequent years). EPA used the findings, data,
and comments on the 2009 annual review to inform its 2010 annual review. The 2009 review
built on the previous reviews by continuing to use the screening methodology and incorporating
some refinements in assigning discharges to categories. EPA made similar refinements to
assigning discharges to categories for the 2010 annual review.
5.2 Results of the 2010 Screening-Level Review
For the 2010 screening-level review, EPA used the combined results of the
TRIReleases2008 v3 and the DMRLoads2008 v2 databases, discussed in Section 4.5 of this
document. When combining the results of these databases, EPA eliminated from further
consideration the results for the following:
• Discharges from industrial categories for which EPA is currently developing or
revising ELGs;
• Discharges from point source categories for which EPA has recently promulgated
or revised ELGs;
• Discharges from facilities that do not fall into an existing or new point source
category or subcategory; and
• Discharges from facilities determined not to be representative of their category.
Sections 5.2.1 through 5.2.4 discuss the rationale for these decisions. The final combined
database rankings represent the results of the 2010 screening-level review and are presented in
Section 5.2.5.
5.2.1 Categories for Which EPA is Currently Developing or Revising ELGs
EPA is currently considering revisions to ELGs for Organic Chemicals, Pesticides, and
Synthetic Fibers (OCPSF) (40 CFR 414) and the Inorganic Chemicals Manufacturing (40 CFR
415) Point Source Categories for facilities that produce chlorine and chlorinated hydrocarbons
(CCH). Because the CCH rulemaking is underway, EPA excluded discharges from these
facilities from further consideration under the current planning cycle. EPA subtracted the TWPE
loads from facilities that produce chlorine or chlorinated hydrocarbons from the OCPSF and
Inorganic Chemicals Manufacturing Point Source Category loads. Because facilities that produce
chlorine and chlorinated hydrocarbons are only a subset of the OCPSF and Inorganic Chemicals
Manufacturing Categories, EPA included loads for all other facilities in these two categories in
the prioritization of categories for further review.
EPA is also currently considering revisions to ELGs for the Steam Electric (40 CFR 423)
Point Source Category. Because the Steam Electric rulemaking is underway, EPA excluded
discharges from these facilities from further consideration under the current planning cycle.
5-2
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Section 5 - 2010 Annual Review
EPA is also currently considering revisions to ELGs for the following industries: airport
deicing and drinking water treatment. However, the TWPE associated with these categories is
low and does not affect the prioritization of categories.
5.2.2 Categories for Which EPA Recently Promulgated or Revised ELGs
For the 2010 annual review and development of category rankings, EPA excluded point
source categories for which ELGs were recently established or revised but not yet fully
implemented, or were recently reviewed in a rulemaking context but EPA decided to withdraw
the proposal or select the "no action" option. In general, EPA removed an industrial point source
category from further consideration during a review cycle if EPA established, revised, or
reviewed the category's ELGs within seven years prior to the annual review. This seven-year
period allows time for the ELGs to be incorporated into National Pollutant Discharge
Elimination System (NPDES) permits. Table 5-1 lists the categories EPA excluded from the
2009 and 2010 reviews due to this seven year period.
Removing a point source category from further consideration in the development of the
rankings does not mean that EPA eliminates the category from annual review. In cases where
EPA is aware of the growth of a new segment within such category or where new concerns are
identified for previously unevaluated pollutants discharged by facilities in the category, EPA
would apply closer scrutiny to the discharges from the category in deciding whether to consider
it further during the current review cycle. For example, EPA conducted the detailed study of the
Coal Mining Category (40 CFR Part 434) based on comments received on the 2006 Preliminary
Plan, although the Coal Mining ELGs were revised in January 2002.
Table 5-1. Point Source Categories That Have Undergone a Recent Rulemaking or
Review
40 CFR Part
Point Source Category
Date of Rulemaking
450
Construction and Development
December 1, 2009
122 and 412
Concentrated Animal Feeding Operations (CAFOs)
November 20, 2008
451
Concentrated Aquatic Animal Production (or Aquaculture)
August 23, 2004
432
Meat and Poultry Products
September 8, 2004
413, 433, and 438
Metal Products and Machinery
(including Metal Finishing and Electroplating)
May 13, 2003
420
Iron and Steel Manufacturing
October 17, 2002
5.2.3 Discharges Not Categorizable
EPA identified discharges that are not categorizable into existing or new point source
categories or subcategories. In particular, EPA reviewed high TWPE discharges from a
Superfund site (Auchterlonie, 2009).9 Direct discharges from Superfund sites, whether made
onsite or offsite, are subject to NPDES permitting requirements (U.S. EPA, 1988a; U.S. EPA,
1988b). For the reasons discussed below EPA determined that these discharges do not represent
a point source category and excluded these TWPE from the point source category rankings.
9 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as
Superfund, was enacted by Congress on December 11, 1980.
5-3
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Section 5 - 2010 Annual Review
EPA identified that discharges from Superfund sites are too varied to be categorized into
a point source category. In particular, these discharges vary by:
• Contaminants (e.g., metals, pesticides, dioxin);
• Treatment technologies (e.g., air stripping, granular activated carbon,
chemical/ultraviolet oxidation, aerobic biological reactors, chemical
precipitation); and
• Types of facilities causing groundwater contamination (e.g., wood treatment
facilities, metal finishing and electroplating facilities, drum recycling facilities,
mine sites, mineral processing facilities, radium processing facilities).
Moreover, the duration and volume of these direct discharges vary significantly due to
differences in aquifer characteristics and the magnitude, fate, and transport of contaminants in
aquifers and vadose zones. Currently at Superfund sites, permit writers determine technology-
based effluent limits using their best professional judgment (BPJ). EPA selects the remedial
technology and derives numerical effluent discharge limits. The permit must also contain more
stringent effluent limitations when required to comply with state water quality standards. EPA
finds that the current site-specific BPJ approach is workable and flexible within the context of a
Superfund cleanup.
5.2.4 Categories with One Facility Dominating the TWPE
EPA identified point source categories with significant TWPE where only one facility
was responsible for more than 95 percent of the TWPE reported to be discharged even though it
was not the only facility reporting discharges for the category (see Table 5-2). EPA identified six
facilities that dominated the TWPE in the category to which they belonged. EPA investigated
these facilities to determine if their discharges were representative of the category. If they were
not, EPA subtracted the facility's TWPE from the total category TWPE and recalculated the
category's ranking. EPA performed this analysis separately for each of the databases. Based on
EPA's knowledge of these industries and the review of the pollutant discharges for these
facilities, EPA determined that all of the pollutant discharges are representative of the industry
and therefore, EPA did not remove the discharges from the category.
5.2.5 Results of the 2010 Screening-Level Review
After adjusting the category TWPE totals and rankings as described in Sections 5.2.1
through 5.2.4, EPA consolidated the 2008 discharge monitoring report (DMR) and Toxics
Release Inventory (TRI) rankings into one set using the following steps:
• EPA combined the two lists of point source categories by adding each category's
DMRLoads2008 TWPE and TRIReleases2008 TWPE10.
• EPA then ranked the point source categories based on total DMRLoads2008 and
TRIReleases2008 TWPE.
10 EPA notes that this may result in "double-counting" of chemical discharges a facility reported to both PCS/ICIS-
NPDES and TRI, and "single-counting" of chemicals reported in only one of the databases. Further, the combined
databases do not count chemicals that may be discharged but are not reported to PCS/ICIS-NPDES or TRI.
5-4
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Section 5 - 2010 Annual Review
Table 5-3 presents the combined DMRLoads2008 and TRIReleases2008 rankings. These
are the final category rankings accounting for all corrections made to the databases during the
2010 screening-level review and removal of any categories and discharges as discussed in
Sections 5.2.1 through 5.2.4.
5-5
-------
Section 5 - 2010 Annual Review
Table 5-2. Point Source Categories with One Facility Dominating the TWPE Discharges
Point Source Category
Facility with Over
95% of Category
TWPE
Facility
Location
Data
Source
Pollutant Driving
TWPE
Facility
TWPE
Percentage of
Total
Category
TWPE
Action
Miscellaneous Food and
Beverages (Potential New
Category)
Bacardi Corp
Catano, PR
DMR 2008
Sulfur
188,000
97.4%
Did not remove load
from category TWPE.
Independent and Stand Alone
Labs (Potential New
Category)
Battelle Memorial
Institute
Columbus,
OH
DMR 2008
Chloride
186,000
99.1%
Did not remove load
from category TWPE.
Ferroalloy Manufacturing
(Part 424)
Eramet Marietta, Inc.
Marietta,
OH
TRI2008
Manganese and
Manganese
Compounds
12,500
96.9%
Did not remove load
from category TWPE.
Tobacco Products (Potential
New Category)
Philip Morris USA
Park 500 Site
Chester, VA
TRI2008
Chlorine
1,770
98.7%
Did not remove load
from category TWPE.
Coil Coating (Part 465)
Latasde Aluminio
Reynolds
Guayama,
PR
DMR 2008
Sulfur
476
95.1%
Did not remove load
from category TWPE.
Ink Formulation (Part 447)
Superior Printing Ink,
Co, Inc.
Marlboro,
MA
DMR 2008
Chlorine
24.6
99.6%
Did not remove load
from category TWPE.
Source: DMRLoads2008 v2 and TRlReleases2008 v3.
5-6
-------
Fart
430
419
421
418
414
440
415
444
410
463
NA
445
411
435
NA
455
464
NA
436
428
434
429
439
467
471
409
437
Section 5 - 2010 Annual Review
Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Rankings
Point Source Catcuorv
TRIRclcascs200H
TWPE
DMRL»atls2008
TWPE
Total TWPE
Cumulative
Percentage of Total
TWPE
Pulp, Paper And Paperboard
523,000
510,000
1,030,000
12.8%
Petroleum Refining
410,000
618,000
1,030,000
25.6%
Nonferrous Metals Manufacturing
38,700
955,000
994,000
37.9%
Fertilizer Manufacturing
,120
818,000
826,000
48.2%
Organic Chemicals, Plastics And Synthetic Fibers
137,000
512,000
649,000
56.2%
Ore Mining And Dressing
109,000
339,000
448,000
61.8%
Inorganic Chemicals Manufacturing
71,300
228,000
299,000
65.5%
Waste Combustors
,830
245,000
254,000
68.7%
Textile Mills
2,750
247,000
250,000
71.8%
Plastics Molding And Forming
74,700
174,000
249,000
74.9%
Miscellaneous Foods And Beverages
5,210
193,000
198,000
77.3%
Landfills
781
191,000
192,000
79.7%
Cement Manufacturing
529
189,000
190,000
82.1%
Oil & Gas Extraction
NA
189,000
189,000
84.4%
Independent And Stand Alone Labs
49.9
186,000
186,000
86.7%
Pesticide Chemicals
35,500
114,000
150,000
3.6%
Metal Molding And Casting (Foundries)
5,040
122,000
127,000
90.2%
Food Service Establishments
NA
119,000
119,000
91.6%
Mineral Mining And Processing
3,390
100,000
103,000
92.9%
Rubber Manufacturing
7,180
73,700
80,900
93.9%
Coal Mining
1,280
76,400
77,700
94.9%
Timber Products Processing
27,300
31,500
58,800
95.6%
Pharmaceutical Manufacturing
6,890
49,100
56,000
96.3%
Aluminum Forming
5,830
33,700
39,500
96.8%
Nonferrous Metals Forming And Metal Powders
20,900
15,000
35,900
97.3%
Sugar Processing
205
35,300
35,500
97.7%
Centralized Waste Treatment
6,850
25,500
32,400
98.1%
5-7
-------
Fart
458
422
469
460
424
457
406
468
425
407
405
461
442
NA
443
426
408
417
NA
465
446
454
447
466
427
Section 5 - 2010 Annual Review
Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Rankings
Point Source Catcuorv
TRIRclcascs200H
TWPE
DMRL»atls2008
TWPE
Total TWPE
Cumulative
Percentage of Total
TWPE
Carbon Black Manufacturing
27,600
335
27,900
98.5%
Phosphate Manufacturing
657
17,200
17,900
98.7%
Electrical And Electronic Components
3,580
12,300
15,900
98.9%
Hospital
NA
15,700
15,700
99.1%
Ferroalloy Manufacturing
12,900
2,560
15,500
99.3%
Explosives Manufacturing
43.2
10,400
10,400
99.4%
Grain Mills
5,600
4,300
9,900
99.5%
Copper Forming
4,780
2,470
7,250
99.6%
Leather Tanning And Finishing
6,990
17.5
7,010
99.7%
Canned And Preserved Fruits And Vegetables
Processing
4,810
519
5,330
99.8%
Dairy Products Processing
3,750
1,450
5,200
99.8%
Battery Manufacturing
1,580
622
2,200
99.8%
Transportation Equipment Cleaning
NA
1,840
1,840
99.9%
Tobacco Products
1,790
11.3
1,800
99.9%
Paving And Roofing Materials (Tars And Asphalt)
927
751
1,680
99.9%
Glass Manufacturing
473
917
1,390
99.9%
Canned And Preserved Seafood Processing
108
932
1,040
99.9%
Soap And Detergent Manufacturing
776
79.9
856
100.0%
Printing And Publishing
141
671
812
100.0%
Coil Coating
191
501
692
100.0%
Paint Formulating
551
18.3
569
100.0%
Gum And Wood Chemicals Manufacturing
69.5
218
288
100.0%
Ink Formulating
35.4
24.8
60.2
100.0%
Porcelain Enameling
18.5
7.43
25.9
100.0%
Asbestos Manufacturing
NA
1.42
1.42
100.0%
Industrial Laundries
NA
0.321
0.321
100.0%
5-8
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Section 5 - 2010 Annual Review
Table 5-3. Final TRIReleases2008 and DMRLoads2008 Combined Point Source Category Rankings
40 CFR
Part
Point Source Category
TRIRclcascs200H
TWPE
DMRL»atls2008
TWPE
Total TWPE
Cumulative
Percentage of Total
TWPE
Rank
459
Photographic
NA
0.0328
0.0328
100.0%
54
NA
Photo Processing
NA
0.0328
0.0328
100.0%
55
Total
1,590,000
6,460,000
8,050,000
Source: TRlReleases2008 v3 and DMRLoads2008 v2.
NA - Not applicable.
5-9
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Section 5 - 2010 Annual Review
5.3 Prioritization of Categories for the 2010 Annual Review
Based on its screening-level review, EPA was able to prioritize for further review (i.e., a
detailed study or preliminary category review) those industrial categories whose pollutant
discharges potentially pose the greatest hazards to human health or the environment because of
their toxicity (i.e., categories that collectively discharge over 95 percent of the total TWPE). EPA
also considered efficiency and implementation issues raised by stakeholders in identifying
candidates for further review. By using this multilayered screening approach, the Agency
concentrated its resources on those point source categories with the highest estimates of toxic-
weighted pollutant discharges (based on best available data), while assigning a lower priority to
categories that the Agency believes are not good candidates for ELGs revision at this time.
Table 5-4 lists the point source categories with existing ELGs, the level of review EPA
performed as part of the 2010 annual review, and how each category was identified for further
review, if applicable.
Table 5-4. 2010 Annual Review of Categories with Existing ELGs: Level of Review
40 CFR
Part
Point Source Category
Level of Review
Sou rcc of
Identification for
Further Review
405
Dairy Products Processing
Screening-Level Review
NAa
406
Grain Mills Manufacturing
Screening-Level Review
NAa
407
Fruits and Vegetable Processing
Screening-Level Review
NAa
408
Canned and Preserved Seafood
Screening-Level Review
NAa
409
Sugar Processing
Screening-Level Review
NAa
410
Textile Mills
Preliminary Review
TWPE
411
Cement Manufacturing
Preliminary Review
TWPE
412
Concentrated Animal Feeding Operations
Screening-Level Review
NAa
413
Electroplating
Screening-Level Review
NAa
414
Organic Chemicals, Plastics and Synthetic Fibers
Preliminary Review
TWPE
415
Inorganic Chemicals
Preliminary Review
TWPE
417
Soaps and Detergents Manufacturing
Screening-Level Review
NAa
418
Fertilizer Manufacturing
Preliminary Review
TWPE
419
Petroleum Refining
Preliminary Review
TWPE
420
Iron and Steel Manufacturing
Screening-Level Review
NAa
421
Nonferrous Metals Manufacturing
Preliminary Review
TWPE
422
Phosphate Manufacturing
Screening-Level Review
NAa
423
Steam Electric Power Generation
Screening-Level Review
NAa
424
Ferroalloy Manufacturing
Screening-Level Review
NAa
425
Leather Tanning and Finishing
Screening-Level Review
NAa
426
Glass Manufacturing
Screening-Level Review
NAa
427
Asbestos Manufacturing
Screening-Level Review
NAa
428
Rubber Manufacturing
Preliminary Review
TWPE
429
Timber Products Processing
Screening-Level Review
NAa
430
Pulp, Paper and Paperboard
Preliminary Review
TWPE
5-10
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Section 5 - 2010 Annual Review
Table 5-4. 2010 Annual Review of Categories with Existing ELGs: Level of Review
40 CFR
Part
Point Source Category
Level of Review
Sou rcc of
Identification for
Further Review
432
Meat and Poultry Products
Screening-Level Review
NAa
433
Metal Finishing
Screening-Level Review
NAa
434
Coal Mining
Preliminary Review
TWPE
435
Oil and Gas Extraction
Detailed Study of Coalbed
Methane Operations
Comments
Preliminary Review of
Remaining Operations
TWPE
436
Mineral Mining and Processing
Preliminary Review
TWPE
437
Centralized Waste Treaters
Screening-Level Review
NAa
438
Metal Products and Machinery
Screening-Level Review
NAa
439
Pharmaceutical Manufacturing
Screening-Level Review
NAa
440
Ore Mining and Dressing
Preliminary Review
TWPE
442
Transportation Equipment Cleaning
Screening-Level Review
NA a
443
Paving and Roofing Materials (Tars and Asphalt)
Screening-Level Review
NA a
444
Waste Combustors (Commercial Incinerators
Combusting Hazardous Waste)
Preliminary Review
TWPE
445
Landfills
Preliminary Review
TWPE
446
Paint Formulating
Screening-Level Review
NA a
447
Ink Formulating
Screening-Level Review
NA a
450
Construction and Development Industry
Screening-Level Review
NA a
451
Aquatic Animal Production Industry
Screening-Level Review
NA a
454
Gum and Wood Chemicals
Screening-Level Review
NA a
455
Pesticide Chemicals Manufacturing
Preliminary Review
TWPE
457
Explosives
Screening-Level Review
NA a
458
Carbon Black Manufacturing
Screening-Level Review
NA a
459
Photographic
Screening-Level Review
NA a
460
Hospital
Detailed Study (of Health
Care Industry)
Comments
461
Battery Manufacturing
Screening-Level Review
NAa
463
Plastic Molding and Forming
Preliminary Review
TWPE
464
Metal Molding and Casting (Foundries)
Preliminary Review
TWPE
465
Coil Coating
Screening-Level Review
NA a
466
Porcelain Enameling
Screening-Level Review
NA a
467
Aluminum Forming
Screening-Level Review
NA a
468
Copper Forming
Screening-Level Review
NA a
469
Electrical and Electronic Components
Screening-Level Review
NA a
471
Nonferrous Metals Forming and Metal Powders
Screening-Level Review
NA a
NA
Food Service Establishments
Preliminary Review
TWPE
NA
Miscellaneous Food and Beverages
Preliminary Review
TWPE
NA
Independent and Stand Alone Labs
Preliminary Review
TWPE
5-11
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Section 5 - 2010 Annual Review
a - For categories with only a screening-level review, the source of identification is not applicable, as EPA conducts
a screening-level review of all categories subject to existing effluent guidelines. The "source of identification" is
only applicable for those industries selected for further review.
NA - Not applicable.
5.3.1 Detailed Study of Existing ELGs
EPA performed detailed studies on two point source categories as part of its 2010 annual
review based on the results of its 2008 and 2009 annual reviews. Because EPA data collection
was not finished in 2009, EPA continued detailed studies of the Oil and Gas Extraction Category
(40 CFR Part 435) to assess whether to revise the limits to include coalbed methane extraction as
a new subcategory, and the Health Care Industry (includes Hospitals (40 CFR Part 460)). EPA
did not identify additional categories for detailed study as part of the 2010 annual review.
EPA's detailed studies generally examine the following: (1) wastewater characteristics
and pollutant sources; (2) the pollutants driving the toxic-weighted pollutant discharges; (3)
availability of pollution prevention and treatment; (4) the geographic distribution of facilities in
the industry; (5) any pollutant discharge trends within the industry; and (6) any relevant
economic factors. First, EPA attempts to verify the screening-level results and fill in data gaps.
Next, EPA considers costs and performance of applicable and demonstrated control technology,
process change, or pollution prevention alternatives that can effectively reduce the pollutants
remaining in the industrial category's wastewater. Last, EPA considers the affordability or
economic achievability of the technology, process change, or pollution prevention measures
identified above.
Types of data sources that EPA may consult in conducting its detailed studies include,
but are not limited to: (1) the U.S. Economic Census; (2) TRI, Permit Compliance System (PCS),
and the Integrated Information System - National Pollutant Discharge Elimination System
(ICIS-NDPES) data; (3) trade associations and reporting facilities to verify reported releases and
facility categorization; (4) regulatory authorities (states and EPA regions) to understand how
category facilities are permitted; (5) National Pollutant Discharge Elimination System (NPDES)
permits and their supporting fact sheets; (6) EPA effluent guidelines technical development
documents; (7) relevant EPA preliminary data summaries or study reports; and (8) technical
literature on pollutant sources and control technologies.
For more information about the Oil and Gas Extraction Detailed Study (coalbed methane
industry) and the Health Care Industry Detailed Study, see Sections 16.2 and 16.1 of this report,
respectively.
5.3.2 Preliminary Category Reviews
Preliminary category reviews are similar to detailed studies and have the same purpose.
During preliminary reviews, EPA generally examines the same items listed above for detailed
studies. However, EPA's preliminary review of a category and available pollution prevention
and treatment options is less rigorous than its detailed studies. While EPA collects and analyzes
hazard and technology-based information on categories undergoing preliminary review, it
assigns a higher priority to investigating categories undergoing detailed studies.
As shown in Table 5-4, EPA identified for preliminary review 21 industrial categories
that cumulatively discharge more than 95 percent of the combined DMRLoads2008 and
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Section 5 - 2010 Annual Review
TRIReleases2008 total TWPE. Three of the 21 industrial categories identified for preliminary
review are potential new categories. Based on information from the 2010 and previous annual
reviews, EPA concluded that the following 13 industrial categories did not require a detailed
section in this report. For these 13 categories, EPA determined that the conclusions were the
same as made during previous annual reviews or the majority of the TWPE was due to data
errors (e.g., incorrect units)11. These industrial categories, and the reasons for excluding them
from further preliminary review, are listed below. EPA is assigning all of these categories with a
lower priority for revision (i.e., the category is marked with "(3)" in the "Findings" column in
Table V-l in the 2010 Final Plan FR notice).
Cement Manufacturing (40 CFR Part 411)
For the Cement Manufacturing Category, the DMRLoads2008 v2 database accounts for
the majority of the combined estimated TWPE. EPA identified one facility, Lafarge North
America's Alpena Plant in Alpena, MI, that accounts for approximately 89 percent of the 2008
DMR TWPE for the Cement Manufacturing Category. EPA determined that the mercury
quantities are incorrect because they do not match the load calculated using the mercury
concentrations and flows. Correcting these errors reduces the facility's 2008 DMR TWPE from
169,000 to 759 and reduces the Cement Manufacturing Category's combined 2008 DMR and
TRI TWPE from 190,000 to 21,100 (ERG, 2010). The category is no longer a priority for the
2010 annual review.
Petroleum Refining (40 CFR Part 419)
The Petroleum Refining Category total TWPE is approximately 60 percent from the 2008
DMR database and 40 percent from the 2008 TRI database. The top pollutant in the 2008 DMR
database is sulfide, while the top pollutants in the 2008 TRI database are dioxin and dioxin-like
compounds and polycyclic aromatic compounds (PACs). Discharges of these four pollutants
from petroleum refineries have been reviewed in previous annual reviews, and EPA concluded
the following:
• Sulfide: As part of the 2004 detailed study of the Petroleum Refining Category,
EPA determined that petroleum refineries are achieving final effluent
concentrations less than existing limits in 40 CFR Part 419 and refineries are
treating sulfide to concentrations at or near treatable levels (U.S. EPA, 2006b).
• Dioxin and dioxin-like compounds: EPA determined that dioxin and dioxin-like
compounds are produced during catalytic reforming and catalyst regeneration
operations at petroleum refineries. Most facilities reporting dioxin and dioxin-like
compounds in TRI never detected dioxin and dioxin-like compounds in their
process wastewater effluent. Of the 232 refineries in TRI 2007 that report non-
zero TWPE, nine reported discharges of dioxin and dioxin-like compounds. Of
the nine refineries reporting dioxin and dioxin-like compound discharges in 2007,
only five of these refineries reported dioxin discharges based on analytical
11 EPA generated a corrected version of the 2008 DMR database: DMRLoads2008_v3, which is available via
http://www.regulations.gov, EPA-HQ-OW-2008-0517 DCN 07317. This version includes all corrections
documented in this TSD.
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Section 5 - 2010 Annual Review
measurements (see Table 11-5 in the Technical Support Document for the
Preliminary 2010 Effluent Guidelines Program Plan (U.S. EPA, 2009)).
• PACs: EPA determined that petroleum refineries report PAC discharges to TRI
that are either based on half the detection limit multiplied by the flow or using
emission factors. EPA determined that there is little evidence that PACs are being
discharged to surface waters in concentrations above the detection limit (U.S.
EPA, 2009).
EPA determined that the 2008 petroleum refinery discharges were consistent with previous
years' discharges. As a result, EPA will rely on the conclusions from previous annual reviews:
the discharges from this category do not represent a priority hazard at this time. The category is
no longer a priority for the 2010 annual review.
Nonferrous Metals Manufacturing (40 CFR Part 421)
For the Nonferrous Metals Manufacturing Category, the DMRLoads2008 v2 database
accounts for the majority of the combined estimated TWPE. The top facility, USEC PDGDP in
McCracken County, KY, accounts for almost 60 percent of the category's 2008 DMR TWPE.
EPA contacted the facility to discuss discharges of polychlorinated biphenyls (PCBs) as part of
the 2010 annual review. The facility contact verified that EPA's database was properly
characterizing the PCB discharge and indicated that the PCBs are from stormwater due to legacy
activity at the site. The facility contact also indicated that USEC PDGDP treats all process water
that may contain PCBs using carbon adsorption (Travis, 2010). EPA determined that the PCB
discharges are not from nonferrous metals manufacturing processes and, therefore, should be
excluded from the category's TWPE. Therefore, EPA determined that the 2008 nonferrous
metals manufacturing discharges are consistent with the previous year's discharges. As a result,
EPA will rely on the conclusions from previous annual reviews: the discharges from this
category do not represent a priority hazard at this time. See Section 8.0 of the 2009 TSD for
additional information (U.S. EPA, 2009). The category is no longer a priority for the 2010
annual review.
Rubber Manufacturing (40 CFR Part 428)
For the Rubber Manufacturing Category, the DMRLoads2008 v2 database accounts for
the majority of the combined estimated TWPE. EPA identified the following two facilities
accounting for approximately 79 percent of the 2008 DMR TWPE for the Rubber Manufacturing
Category:
• Durakon Industries, Inc. in Lapeer, MI: EPA determined that the January and
December 2008 mercury quantities are incorrect because they do not match the
load calculated using the mercury concentrations and flows. Correcting these data
reduces the facility's 2008 DMR TWPE from 34,900 to 0.11 (ERG, 2010).
• Kraton Polymers, US, LLC in Belpre, OH: EPA determined that the January
through December 2008 arsenic quantities are incorrect because they do not
match the load calculated using the arsenic concentrations and flows. Correcting
these data reduces the facility's 2008 DMR TWPE from 23,200 to 2,900 (ERG,
2010).
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Section 5 - 2010 Annual Review
After reviewing the data, EPA determined that the discharges from the facilities above were
incorrect. Correcting these errors reduces the Rubber Manufacturing Category combined 2008
DMR and TRI TWPE from 80,900 to 25,700 (ERG, 2010). The category is no longer a priority
for the 2010 annual review.
Pulp, Paper, and Paperboard (40 CFR Part 430)
The Pulp, Paper, and Paperboard (Pulp and Paper) Category total TWPE is approximately
50 percent from the 2008 DMR database and 50 percent from the 2008 TRI database. The top
pollutants in the 2008 DMR database are 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD)
and sulfide, while the top pollutants in the 2008 TRI database are manganese and manganese
compounds, lead and lead compounds, and dioxin and dioxin-like compounds. Discharges of
dioxin and dioxin-like compounds, including 2,3,7,8-TCDD, and manganese and manganese
compounds from pulp and paper facilities have been reviewed in previous annual reviews:
• 2,3,7,8-TCDD (DMR) and Dioxin and Dioxin-Like Compounds (TRI): EPA
determined that the 2,3,7,8-TCDD DMR data were not detected in bleach plant
effluent or final mill effluent (U.S. EPA, 2006a). Additionally, EPA determined
that the majority of the underlying data used to estimate releases of dioxin and
dioxin-like compounds reported to TRI were pollutant concentrations below the
Method 1613B minimum level. Therefore, there is substantial uncertainty about
the magnitude of these reported discharges. TRI-reported discharges of dioxin and
dioxin-like compounds for the Pulp and Paper Category are most likely
significantly overestimated and thus do not accurately reflect current industry
discharges (U.S. EPA, 2009).
• Manganese and Manganese Compounds: As part of the Pulp and Paper
Detailed Study performed in the 2006 annual review, EPA determined that the
manganese concentrations were too low to treat using end-of-pipe treatment
technologies for large plant flows (U.S. EPA, 2006a). Although EPA has not
reviewed new discharge concentration data, it has no new data to suggest that
manganese concentrations are above the treatable levels (U.S. EPA, 2009).
EPA has not reviewed discharges of sulfide and lead and lead compounds from pulp and
paper facilities as part of previous annual reviews. EPA's findings as part of the 2010 annual
review for sulfide and lead and lead compound discharges are:
• Sulfide: Approximately 23 percent of the 2008 DMR TWPE for the Pulp and
Paper Category is from sulfide discharges. There are two facilities with sulfide
discharges in the 2008 DMR database: Smurfit-Stone Container in Florence, SC
and Domtar Johnsonburg in Johnsonburg, PA. The 2008 sulfide discharges for
Smurfit-Stone Container ranged from below the detection limit (0.1 mg/L to 1.0
mg/L) to 1.7 mg/L. The Lockwood-Post's Directory of Pulp and Paper Mills
indicates that Smurfit-Stone Container has a 1,600 acre settling basin. Sulfides
may result from an anaerobic portion of the settling basin. EPA determined that
the sulfide concentration for Domtar Johnsonburg was reported below the
detection limit, while the sulfide quantity was reported above the detection limit.
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Section 5 - 2010 Annual Review
Therefore, sulfide discharges from Domtar Johnsonburg are likely below the
detection limit, resulting in a 16,000 TWPE reduction in the Pulp and Paper
Category's sulfide TWPE. EPA will continue to monitor the sulfide discharges to
determine if they are properly controlled.
• Lead and Lead Compounds: Approximately 13 percent (63,800 TWPE) of the
2008 TRI TWPE for the Pulp and Paper Category is from discharges of lead and
lead compounds. There are 185 pulp and paper facilities in the 2008 TRI database
reporting discharges of lead and lead compounds. The top facility with discharges
of lead and lead compounds is Kimberly Clark in Everett, WA that accounts for
approximately 9.6 percent of the Pulp and Paper Category's lead and lead
compound discharges; therefore, there are no outlier pulp and paper facilities
discharging lead and lead compounds. The majority of the lead and lead
compounds are based on monitoring data (54 discharges) or published emission
factors (46 discharges). Because there are no outlier facilities, EPA determined
that the lead and lead compound discharges are likely accurate. EPA suspects
high TWPE from the high volume of lead and lead compound dischargers in the
Pulp and Paper Category. EPA will continue to monitor the lead and lead
compound discharges to determine if they are properly controlled.
EPA determined that the 2008 pulp and paper discharges of dioxin and dioxin-like
compounds and manganese and manganese compounds were consistent with previous years'
discharges. EPA will continue to monitor the Pulp and Paper Category's sulfide and lead and
lead compound discharges to determine if they are properly controlled. As a result, EPA will rely
on the conclusions from previous annual reviews: the discharges from this category do not
represent a priority hazard at this time. The category is no longer a priority for the 2010 annual
review.
Coal Mining (40 CFR Part 434)
For the Coal Mining Category, the DMRLoads2008 v2 database accounts for the
majority of the combined estimated TWPE. The top pollutants in the 2008 DMR database are
manganese and iron. Discharges of these pollutants from coal mines were reviewed as part of the
Coal Mining Detailed Study during the 2007 and 2008 annual reviews. EPA determined that
based on its review of available data, revisions to the pollutant limitations in the Coal Mining
ELGs were not warranted (U.S. EPA, 2008).
Pesticide Chemicals (40 CFR Part 455)
For the Pesticide Chemicals (Pesticides) Category, the DMRLoads2008 v2 database
accounts for the majority of the combined estimated TWPE. EPA identified one facility, Bayer
CropSciences in Institute, WV, that accounted for approximately 83 percent of the 2008 DMR
TWPE for the Pesticides Category. EPA determined that the majority of the of the facility's
estimated load results from total carbaryl. EPA contacted Bayer CropSciences to verify the total
carbaryl quantities and concentrations and flow. Bayer CropSciences indicated that all of the
total carbaryl quantities and concentrations for outfall 005 were reported below the detection
limit, while all but one total carbaryl concentration for outfall 301 was reported below the
detection limit (Smith, 2010). Using the facility-provided quantities and concentrations reduces
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Section 5 - 2010 Annual Review
Bayer CropSciences 2008 DMR TWPE from 94,300 to 532 and reduces the Pesticides
Category's total TWPE from 114,000 to 20,000 (ERG, 2010). The category is no longer a
priority for the 2010 annual review.
Metal Molding and Casting (40 CFR Part 464)
For the Metal Molding and Casting Category, the DMRLoads2008 v2 database accounts
for the majority of the combined estimated TWPE. EPA identified one facility, Eagle-Picher
Industries in Sidney, OH, that accounted for approximately 61 percent of the 2008 DMR TWPE
for the Metal Molding and Casting Category. EPA determined that the outfall 001 flows for
September, October, and December 2008 were incorrectly entered as million gallons per day
(MGD) instead of gallons per day (GPD). Correcting these errors reduces the facility's 2008
DMR TWPE from 74,700 to 32 and reduces the Metal Molding and Casting Category's total
TWPE from 127,000 to 52,300 (ERG, 2010). The category is no longer a priority for the 2010
annual review.
Miscellaneous Food and Beverages (Potential New Category)
For the Miscellaneous Foods and Beverages Potential New Category, the
DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA
identified one facility, Bacardi Corp. in Catano, PR, that accounted for approximately 97 percent
of the 2008 DMR TWPE for the Miscellaneous Food and Beverages Potential New Category.
EPA reviewed this facility's discharges in preparing the 2006 Final Plan as well (U.S. EPA,
2006b).
EPA contacted EPA Region 2 to discuss the Bacardi discharges and determined that the
facility's sulfide discharges were unique to the facility. According to Region 2 staff, the Bacardi
effluent wastewater characteristics include high levels of biochemical oxygen demand -
approximately 15,000 milligrams per liter (mg/L), bacteria, and solids, which complicate its
treatment. As a result, Region 2 worked with the facility to determine treatable levels. The
wastewater discharge commingles with adjacent wastewater treatment discharges from PRASA's
Puerto Nuevo and Bayamon wastewater treatment plants (WWTPs). The wastewater discharges
immediately dilute the discharge from the Bacardi plant. As a result, Region 2 concluded that
certain pollutants, such as sulfide, can be discharged at high concentrations and will be diluted
prior to reaching surface water (O'Brien, 2010). EPA based the water quality based limitations
for this facility on the final Water Quality Certificate issued by the Puerto Rico Environmental
Quality Board (U.S. EPA Region 2, 2007). The resulting permit limit for sulfide is 108 mg/L at
the outfall. The sulfide limit at the edge of the mixing zone, after commingling with the WWTPs
is 2 |ig/L (U.S. EPA Region 2, 2008). Because one facility accounted for the vast majority of the
TWPE, EPA determined that ELGs for the potential new category are not warranted. Therefore,
the category is no longer a priority for the 2010 annual review.
Food Service Establishments (Potential New Category)
For the Food Service Establishments Potential New Category, the DMRLoads2008_v2
database accounts for all of the total TWPE (food service establishments do not report to TRI).
EPA identified one facility, Gionino's Pizza in OH, that accounted for approximately 75 percent
of the 2008 DMR TWPE for the Food Service Establishments Potential New Category. EPA
determined that the outfall 001 flows for January through December 2008 were incorrectly
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Section 5 - 2010 Annual Review
entered as MGD instead of GPD. Correcting these errors reduces the facility's 2008 DMR
TWPE from 90,700 to 3.7 and reduces the Food Service Establishments Potential New
Category's combined 2008 DMR and TRI TWPE from 198,000 to 34,000 (ERG, 2010). The
category is no longer a priority for the 2010 annual review.
Independent and Stand Alone Labs (Potential New Category)
For the Independent and Stand Alone Labs Potential New Category, the
DMRLoads2008_v2 database accounts for the majority of the combined estimated TWPE. EPA
identified one facility, Battelle Memorial Institute in Columbus, OH, that accounted for
approximately 99 percent of the 2008 DMR TWPE for the Independent and Stand Alone Labs
Potential New Category. EPA determined that the outfall 002 flows for January through August
and October through December 2008 were incorrectly entered as MGD instead of GPD.
Correcting these errors reduces the facility's 2008 DMR TWPE from 184,000 to 1.2 and reduces
the Independent and Stand Alone Labs Potential New Category's combined 2008 DMR and TRI
TWPE from 186,000 to 1,810 (ERG, 2010). The category is no longer a priority for the 2010
annual review.
The preliminary reviews for the remaining eight categories involved more than discharge
data errors and, therefore, each have sections in this report. The eight preliminary reviews
identified are listed below, along with a reference to where they are discussed in this report:
• Fertilizer Manufacturing Category (Section 6);
• Inorganic Chemicals Manufacturing Category (Section 7);
• Landfills Category (Section 8);
• Mineral Mining and Processing Category (Section 9);
• Oil and Gas Extraction Category (Excluding CBM) (Section 10);
• Ore Mining and Dressing Category (Section 11);
• Organic Chemicals, Plastics, and Synthetic Fibers Category (Section 12);
• Plastics Molding and Forming Category (Section 13);
• Textile Mills Category (Section 14); and
• Waste Combustors Category (Section 15).
EPA recently conducted detailed studies or preliminary reviews of many of the categories
listed above. Table 5-5 lists these categories and the level of review performed for EPA's 2007
through 2010 annual reviews. For each of these categories, EPA's annual review builds on
previous reviews. For the preliminary category reviews and detailed studies discussed in this
document, EPA primarily looked at the pollutants reported in 2008 and their contribution to their
category's TWPE.
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Section 5 - 2010 Annual Review
Table 5-5. Previous Reviews for Categories with Preliminary Category Reviews for the
2010 Annual Review
40 CFR
Part
Point Source Category
Level of Review for
2007/2008
Level of Review for
2009/2010
410
Textile Mills
Screening-Level Review"
Preliminary Category Review
414
Organic Chemicals, Plastics, and
Synthetic Fibers
Preliminary Category Review
Preliminary Category Review
415
Inorganic Chemicals Manufacturing
Screening-Level Review a
Preliminary Category Review
418
Fertilizer Manufacturing
Screening-Level Review a
Preliminary Category Review
435
Oil and Gas Extraction, excluding
Coalbed Methane operations
NA
Preliminary Category Review
436
Mineral Mining and Processing
NA
Preliminary Category Review
440
Ore Mining and Dressing
Preliminary Category Review
Preliminary Category Review
444
Waste Combustors
Preliminary Category Review
Preliminary Category Review
445
Landfills
NA
Preliminary Category Review
463
Plastics Molding and Forming
Screening-Level Review"
Preliminary Category Review
a - EPA conducted a preliminary category review as part of the 2007 annual review, but not as part of the 2008
annual review.
NA - Not applicable.
5.4 2010 Annual Review References
1. Auchterlonie, Steve. 2009. Notes from Telephone Conversation between Steve
Auchterlonie, Front St. Remedial Action, and Chris Krejci, Eastern Research Group, Inc.
"RE: Verification of magnitude and basis of estimate for dioxin and dioxin-like
compounds discharges in PCS." (March 13). EPA-HQ-OW-2008-0517-0076.
2. ERG. 2010. Eastern Research Group, Inc. Preliminary Category Review - Facility Data
Review and Revised Calculations. (September). EPA-HQ-OW-2008-0517 DCN 07304.
3. O'Brien, Karen. 2010. EPA Region 2. Notes from Telephone Conversation between
Karen O'Brien, EPA Region 2, and Eleanor Codding, Eastern Research Group, Inc. "RE:
Sulfide discharges from Bacardi Corporation in Puerto Rico." (August). EPA-HQ-OW-
2008-0517 DCN 07305.
4. Smith, Gordon. 2010. Telephone and E-mail communication with Gordon Smith, Bayer
CropSciences, and Lauren Wingo, Eastern Research Group, Inc. "Re: Bayer
CropSciences' 2008 DMR Pesticide Discharges." (September 14). EPA-HQ-OW-2008-
0517 DCN 07268.
5. Travis, Chris. 2010. Notes from Telephone Conversation between Chris Travis, USEC
PDGDP, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: PCB concentrations
reported to DMR in 2008." (March 17). EPA-HQ-OW-2008-0517 DCN 07265.
6. U.S. EPA Region 2. 2007. National Pollutant Discharge Elimination System Fact Sheet -
PR0000591 - Bacardi Corporation - Catano, Puerto Rico. (December 12). EPA-HQ-
OW-2008-0517 DCN 07269.
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Section 5 - 2010 Annual Review
7. U.S. EPA Region 2. 2008. National Pollutant Discharge Elimination System Permit -
PR0000591 - Bacardi Corporation - Catano, Puerto Rico. (July 1). EPA-HQ-OW-2008-
0517 DCN 07270.
8. U.S. EPA. 1988a. CERCLA Compliance with Other Laws Manual: Interim Final. EPA-
540-G-89-006. OSWER Publication 9234.1-01. Washington, DC. (August). Available
online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf.
9. U.S. EPA. 1988b. Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites. OSWER Directive 9283.1-2. EPA-540-G-88-003. (December).
Available online at: www.epa.gov/superfund/resources/remedy/pdf/540g-89006-s.pdf.
10. U.S. EPA. 2006a. Final Report: Pulp, Paper, and Paperboard Detailed Study. EPA-821-
R-06-016. Washington, DC. (November). EPA-HQ-OW-2004-0032-2249.
11. U. S. EPA. 2006b. Technical Support Document for the 2006 Effluent Guidelines
Program Plan. EPA-821R-06-018. (December). EPA-HQ-OW-2004-0032-2782.
12. U.S. EPA. 2008. Coal Mining Detailed Study. EPA-821-R-08-012. Washington, DC.
(August). EPA-HQ-OW-2006-0771-1695.
13. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQ-
OW-2008-0517-0515.
5-20
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
6. Fertilizer Manufacturing (40 CFR Part 418)
EPA selected the Fertilizer Manufacturing Category for preliminary review because it
continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source
category rankings (see Table 5-3 for the point source category rankings). The Final 2006 Plan
summarizes the results of EPA's previous review of this industry in 2004 and 2005 (71 FR
76644). EPA also reviewed discharges from the Fertilizer Manufacturing Category as part of the
2009 annual review (74 FR 68599). This section summarizes the results of the 2010 annual
review associated with the Fertilizer Manufacturing Category. EPA focused on discharges of
fluoride from two facilities because of their high TWPE relative to the other facilities in the
Fertilizer Manufacturing Category.
6.1 Fertilizer Manufacturing Category Background
This subsection provides the background on the Fertilizer Manufacturing Category
including a brief profile of the fertilizer manufacturing industry and background on 40 CFR Part
418.
6.1.1 Fertilizer Manufacturing Industry Profile
The fertilizer manufacturing industry includes facilities that produce phosphorus- and
nitrogen-based fertilizers (U.S. EPA, 2006). EPA considered the following three North American
Industrial Classification System (NAICS) codes as part of the Fertilizer Manufacturing Category:
• 325311: Nitrogenous Fertilizer Manufacturing;
• 325312: Phosphatic Fertilizer Manufacturing; and
• 325314: Fertilizer (Mixing Only) Manufacturing.
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the
sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report
facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and
Toxics Release Inventory (TRI) report data by North American Industry Classification System
(NAICS) code, EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 6-1
lists the number of facilities from the U.S. Economic Census and the screening-level databases
for the three NAICS codes with operations in the Fertilizer Manufacturing Category, including
the corresponding SIC codes for reference. The U.S. Economic Census includes more facilities
than the screening-level databases because of many possible factors including: facilities may not
meet TRI-reporting thresholds, facilities may discharge to a publicly owned treatment works
(POTW), and some facilities in the U.S. Economic Census are distributors or sales facilities, not
manufacturers.
6-1
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-1. Number of Fertilizer Manufacturing Facilities
NAICS Code
Corresponding SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008 DMR
Database11
2008 TRI
Database b
325311: Nitrogenous
Fertilizer Manufacturing
2873: Nitrogenous
Fertilizers
144
63
42
325312: Phosphatic
Fertilizer Manufacturing
2874FER: Phosphatic
Fertilizers 0
45
2 d
17 e
325314: Fertilizer (Mixing
Only) Manufacturing
2875: Fertilizer (Mixing
Only) Manufacturing
534
54
57
Total
723
119
116
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2\ and TRIReleases2008_v3.
a - Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an
NAICS to SIC crosswalk for comparison purposes,
b - Facilities reporting releases to any media.
c - Wastewater generated by facilities in SIC code 2874 can be regulated under multiple categories. Most facilities
in SIC code 2874 are grouped under the Phosphate Manufacturing Category (40 CFR Part 422). EPA reviewed
available information about pollutant loads and manufacturing operations for facilities reporting this SIC code. In its
crosswalk, EPA assigned the extension "FER" to the end of the SIC codes for facilities that most likely fall under
the applicability of 40 CFR Part 418, Fertilizer Manufacturing (U.S. EPA, 2006).
d - Includes facilities that EPA determined were subject to the Fertilizer Manufacturing Effluent Limitations
Guidelines and Pretreatment Standards (ELGs) as part of the 2006 annual review reporting SIC code 2874:
Phosphatic Fertilizers (U.S. EPA, 2006).
e - EPA identified an error in the TRIReleases2008_v3 database, and pollutant loads for facilities with NAICS code
325312 are currently associated with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the
Fertilizer Manufacturing Category. The 2008 TRITWPE for these facilities is only 657 TWPE (compared with the
Fertilizer Manufacturing Category total of 826,000 TWPE). Therefore, the TWPE associated with facilities
reporting NAICS code does not affect the category ranking. EPA will correct the error in future annual reviews.
Table 6-2 shows whether permitting authorities designated direct discharging facilities in
the Fertilizer Manufacturing Category as minor or major dischargers (see Section 4.1.5). EPA
included data for minor dischargers in the 2010 annual review, as part of DMRLoads2008 v2
(for previous annual reviews, EPA included only major dischargers). EPA does not require
permitting authorities to submit DMR data for minor dischargers; however, many states do
provide complete DMR data for them. From the 2010 annual review, EPA observed many data
entry or other errors for minor dischargers in addition to those previously identified for major
dischargers, as discussed in Section 4.3. Table 6-2 shows that approximately 81 percent of the
Fertilizer Manufacturing Category dischargers in the 2008 DMR database are minor dischargers.
However, as shown in Table 6-6, the TWPE from the minor dischargers is negligible compared
to the facilities with the greatest TWPE in this category (i.e., major dischargers).
6-2
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-2. Number of Fertilizer Manufacturing Facilities by Discharge Classification in
2008 DMR Database
NAICS Code"
Number of Facilities in 2008 DMR Database
Major Dischargers
Minor Dischargers
All Dischargers
325311: Nitrogenous Fertilizer Manufacturing
21
42
63
325312: Phosphatic Fertilizer Manufacturing
2
0
2
325314: Fertilizer (Mixing Only) Manufacturing
0
54
54
Total
23
96 b
119
Source: DMRLoads2008jv2.
a - DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison
purposes.
b - The DMR data in PCS and ICIS-NPDES do not include discharge data for all minor dischargers. For the
facilities in the Fertilizer Manufacturing Category, 32 of the 96 minor dischargers have DMR data.
Table 6-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of fertilizer manufacturing facilities reporting to TRI reported direct discharges to
surface waters.
Table 6-3. Number of Fertilizer Manufacturing Facilities by Discharge Type in 2008 TRI
Database
NAICS Code
Number of Facilities in 2008 TRI Database
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both Indirect
and Direct
Dischargers
No Water
Discharges
325311: Nitrogenous Fertilizer Manufacturing
23
2
2
15
325312: Phosphatic Fertilizer Manufacturing
8
1
1
7
325314: Fertilizer (Mixing Only) Manufacturing
11
3
1
42
Total
42
6
4
64
Source: TRIReleases2008 v3.
6.1.2 40 CFR Part 418
EPA first promulgated ELGs for the Fertilizer Manufacturing Category (40 CFR Part
418) on April 8, 1974 (39 FR 12836) for the Basic Fertilizer Chemicals Segment and on January
14, 1975 (40 FR 2652) for the Formulated Fertilizer Chemicals Segment. The Fertilizer
Manufacturing ELGs are applicable to process wastewater and contaminated nonprocess
wastewater discharged from the specific subcategories listed in Table 6-4. The seven
subcategories are based on the type of fertilizer produced.
6-3
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-4. Subcategories in the Fertilizer Manufacturing Category
Subpart
Title
Description
A
Phosphate Subcategory a
Manufacture of sulfuric acid by sulfur burning, wet-process
phosphoric acid, normal superphosphate, triple superphosphate,
and ammonium phosphate.
B
Ammonia Subcategory
Manufacture of ammonia.
C
Urea Subcategory
Manufacture of urea.
D
Ammonium Nitrate Subcategory
Manufacture of ammonium nitrate.
E
Nitric Acid Subcategory
Production of nitric acid in concentrations up to 68 percent.
F
Ammonium Sulfate Production
Subcategory
Production of ammonium sulfate by the synthetic process and
by coke oven by-product recovery.
G
Mixed Blend Fertilizer Production
Subcategory
Production of mixed b and blend0 fertilizer.
Source: Fertilizer Manufacturing Point Source Category - 40 CFR Part 418 and Preliminary Review of Prioritized
Categories of Industrial Dischargers (U.S. EPA, 2005).
a - The applicability of Subpart A excludes certain wet-process phosphoric acid processes from best practicable
control technology (BPT) and best available technology economically achievable (BAT) limitations. The exclusion
applies to processes that were under construction either on or before April 8, 1974, at plants located in the state of
Louisiana.
b - Mixed fertilizer means "a mixture of wet and/or dry straight fertilizer material, mixed fertilizer materials, fillers
and additives prepared through chemical reaction to a given formulation."
c - Blend fertilizer means "a mixture of dry, straight and mixed fertilizer materials."
6.2 Fertilizer Manufacturing Category 2010 Screening-Level Review
Table 6-5 compares the screening-level review results for the Fertilizer Manufacturing
Category from the 2006 through 2010 annual reviews. The combined TWPE from discharges in
the DMR and TRI databases decreased from discharge years 2002 to 2008. The estimated 2008
DMR TWPE dominates the estimated 2008 category TWPE, composing approximately 99
percent of the combined 2008 DMR and TRI TWPE, similar to previous years of data.
Table 6-5. Fertilizer Manufacturing Category TRI and DMR Discharges for the 2006
through 2010 Screening-Level Reviews
Year of Discharge
Year of Review
Fertilizer Manufacturing Category
TRI TWPE
DMR TWPE "
Total TWPE
2002
2006
9,100
1,370,000
1,380,000
2004
2007
10,800
1,170,000
1,180,000
2005
2008
7,300
NA
NA
2007
2009
4,460
1,095,000
1,100,000
2008
2010
8,120
818,000
826,000
Source: TRlReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRIReleases2005_v2',
TRlReleases2007_v2; DMRLoads2007_v4; TRlReleases2008_v3; and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 includes only major dischargers. 2008 DMR data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
6-4
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (98 percent) of the TWPE in the 2008 DMR database results from major
dischargers.
Table 6-6. Fertilizer Manufacturing Category 2008 DMR TWPE by Discharge
Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
16,300
802,000
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
6.3 Fertilizer Manufacturing Category Pollutants of Concern
Table 6-7 lists the five pollutants with the highest TRI TWPE based on results from the
2010, 2009, and 2007 annual reviews (TRIReleases2008 v3, 1 RIReleases2007 v2, and
TRlReleases2004 v3, respectively). Table 6-8 lists the five pollutants with the highest TWPE
based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2,
DMRLoads2007_v3, and IyCSLoads2004 v4, respectively).
6-5
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-7. Fertilizer Manufacturing Category Top TRI Pollutants
Pollutant
2004 TRI Data"
2007 TRI Data"
2008 TRI Data"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Nitrate Compounds
1
31
3,560
1
19
2,250
1
27
3,650
Polycyclic Aromatic Compounds
3
1
1,570
Pollutant not reported in the top five
2007 TRI reported pollutants.
2
1
1,170
Chlorine
5
8
1,210
2
5
653
3
4
772
Mercury and Mercury Compounds
Pollutant not reported in the top five
2004 TRI reported pollutants.
3
2
648
4
4
710
Copper and Copper Compounds
4
13
1,240
5
4
228
5
10
517
Zinc and Zinc Compounds
Pollutant not reported in the top five
2004 TRI reported pollutants.
4
5
240
Pollutants not reported in the top five
2008 TRI reported pollutants.
Dioxin and Dioxin-Like
Compounds
2
1
1,960
Pollutant not reported in the top five
2007 TRI reported pollutants.
Fertilizer Manufacturing
Category Total
NA
47 b
10,850
NA
29 b
4,460c
NA
42 b
8,120 c
Source: TRIReleases2004_v3; TRlReleases2007_v2; and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
c - EPA identified an error in the TRlReleases2007_v2 and TRIReleases2008_v3 databases, and pollutant loads associated with facilities reporting NAICS code
325312 are currently associated with the Phosphate Manufacturing Category (40 CFR Part 422) rather than the Fertilizer Manufacturing Category. EPA will
correct the error in future years of the TRI database. The TWPE for these facilities is less than 10 percent of the total TWPE for both years (242 TWPE for 2007
and 657 TWPE for 2008).
NA - Not applicable.
6-6
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-8. Fertilizer Manufacturing Category Top DMR Pollutants
Pollutant
2004 DMR Data"
2007 DMR Data"
2008 DMR Datab
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Fluoride
1
4
1,120,000
1
3
1,055,000
1
3
778,000
Ammonia as Nitrogen
4
19
4,520
4
16
2,400
2
27
16,000
Aluminum
2
1
16,700
3
1
10,600
3
1
13,300
Cadmium
3
2
16,600
2
2
25,400
4
1
6,710
2,4-Dichlorophenoxyacetic Acid
Pollutant not reported in the top five
2004 DMR reported pollutants.
Pollutant not reported in the top five
2007 DMR reported pollutants.
5
1
1,750
Nitrogen, nitrate total (as N)
5
12
4,080
5
11
782
Pollutant not reported in the top five
2008 DMR reported pollutants.
Fertilizer Manufacturing
Category Total
NA
22c
1,170,000
NA
19c
1,100,000
NA
36c
818,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data includes only major dischargers,
b - 2008 DMR data include major and minor dischargers,
c - Number of facilities reporting a TWPE of greater than zero.
NA - Not applicable.
6-7
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
The Fertilizer Manufacturing Category TWPE in the 2008 TRI database is significantly
lower than the TWPE in the 2008 DMR database. Therefore, EPA focused the preliminary
category review on the DMR-reported pollutants that account for the majority of the category
TWPE.
Fluoride is the top DMR-reported pollutant in 2004, 2007, and 2008, contributing more
than 95 percent of the total category TWPE. EPA's preliminary review focused on discharges of
fluoride and the review results are presented in the following subsections. EPA did not
investigate the other top pollutants as part of the 2010 annual review because the other pollutants
represent a small percentage (6 percent) of the combined 2008 DMR and TRI TWPE for the
Fertilizer Manufacturing Category.
6.4 Fertilizer Manufacturing Category Fluoride Discharges in DMR
The 2010 annual review of the Fertilizer Manufacturing Category focused on fluoride
discharges in the 2008 DMR database. Table 6-9 presents the facilities that account for all of the
fluoride discharges in the 2008 and 2007 DMR databases. The decrease in fluoride TWPE from
2007 to 2008 likely results from decreased flow in 2008, as flow fluctuates with rain events.
The majority (91 percent) of the fluoride discharges in 2008 were from Mosaic
Fertilizers, LLC in Uncle Sam, LA. The other two facilities, IMC Phosphates in St. James, LA
and Mississippi Phosphates Corp in Pascagoula, MS account for the remaining 9 percent.
Fluoride is generated in the manufacture of wet-process phosphoric acid that is used in
phosphatic fertilizer manufacturing (U.S. EPA, 1974). See the Technical Support Document for
the 2006 Effluent Guidelines Program Plan (U.S. EPA, 2006) for descriptions of the wet-process
phosphoric acid process (Section 8.5.1), wastewater sources of fluoride (Section 8.5.2), and
wastewater treatment of fluoride (Section 8.5.3). The subsections below provide information on
the facilities that discharge the highest amounts of fluoride.
6-8
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-9. Top Fluoride Discharging Facilities in 2007 and 2008 DMR Databases
Facility Name
Facility Location
2007
2008 a
Pounds of
Fluoride
Discharged
Fluoride TWPE
Percentage of
Fertilizer
Manufacturing
Category's 2007
DMR Fluoride
TWPE
Pounds of
Fluoride
Discharged
Fluoride
TWPE
Percentage of
Fertilizer
Manufacturing
Category's 2008
DMR Fluoride
TWPE
Mosaic Fertilizer, LLC
Uncle Sam, LA
27,300,000
957,000
91%
23,500,000
705,000
91%
IMC Phosphates Co.
St James, LA
2,140,000
75,900
7%
2,000,000
59,900
8%
Mississippi Phosphates Corp.
Pascagoula, MS
665,000
23,300
2%
452,000
13,600
1%
Total
30,200,000
1,055,000
100%
25,900,000
778,000
100%
Source: DMRLoads2007_v3 and DMRLoads2008_v2.
a - Major and minor dischargers.
6-9
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
6.4.1 Top Facility Permit Compliance
Both of the top facilities in the Fertilizer Manufacturing Category are phosphate fertilizer
manufacturers. Phosphate fertilizer manufacturers are subject to 40 CFR Part 418 Subpart A -
Phosphate Subcategory. Subpart A BAT includes limits on flow-based surge capacity and
pollutant discharge concentrations. The flow-based requirements are:
• Zero discharge of wastewater except from the gypsum storage and disposal area;
• Maintenance of a surge capacity for a 10-year, 24-hour storm event (BPT) or a
25-year, 24-hour storm event (BAT) in the gypsum storage and disposal area;
• If stored wastewater reaches 50 percent of the required surge capacity, the facility
is allowed to discharge treated wastewater;
• If stored wastewater exceeds 50 percent of the required surge capacity, the facility
is required to treat and discharge wastewater; and
• During discharge events, facilities are required to meet limitations for
phosphorous, fluoride (25 mg/L monthly average and 75 mg/L daily maximum),
total suspended solids, and pH (U.S. EPA, 1974).
Facilities minimize the volume of wastewater discharged by impounding and
recirculating all direct contact process wastewater, including stormwater runoff from active
gypsum storage and disposal areas. This recirculation leads to an accumulation of fluoride,
phosphorous, and radium in the wastewater with concentrations in excess of 8,500 mg/L
fluoride, 5,000 mg/L phosphorous, and 60 pCi/L radium 226. Additionally, the wastewater is
typically very acidic with a pH of between one and two. Several facilities report that they have
not treated or discharged wastewater for several years. For the 1974 rulemaking, EPA
determined that most facilities would discharge continuously between two and four months of
the year due to excess wastewater in the impoundment from rainfall (U.S. EPA, 1974).
The applicability of Subpart A excludes certain wet-process phosphoric acid processes
from BPT, BAT, and BCT limitations that were under construction either on or before April 8,
1974, at plants located in the state of Louisiana. As a result, the Mosaic Fertilizers facility in
Uncle Sam, LA and IMC Phosphates facility in St. James, LA are excluded from Subpart A.
Permit writers limit discharges from these facilities using best professional judgment (BPJ) (see
52 FR 28428, July 29, 1987). Table 6-10 presents the outfall descriptions and the permit limits
and findings for both facilities. For some portion of the discharges from the Mosaic Fertilizers'
Uncle Sam and IMC Phosphates' St. James facilities, BPJ permits incorporate Subpart A
requirements.
6-10
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-10. Outfalls and Permit Information for Top Fluoride Dischargers
Name
Outfall with
Fluoride
Discharges
Fluoride Permit
Limits
Permit Findings
Mosaic Fertilizers
LLC - Uncle Sam,
LA
001: Once-through
cooling water,
scrubber water,
nonprocess
wastewater, fertilizer
area stormwater,
inactive gypsum
storage area, and
active gypsum
storage area
Limits for outfall
001 excluding
inactive and active
gypsum storage area
discharges:
165,000 lb/day
monthly average
222,800 lb/day daily
maximuma
• Acknowledges exemption of flow
requirements;
• Portion of gypsum storage and disposal are
designated inactive;
• Stormwater from inactive storage and
disposal area discharged without treatment;
Fundamentally Different Factor (FDF)
granted to exempt facility from recycling
process wastewater by installing fluoride
scrubber;
• Gypsum storage area must meet BAT
requirements;
• Optional discharge of treated wastewater
below 50% surge capacity;
• Required discharge of treated wastewater
above 50% storage capacity.
IMC Phosphates -
St. James, LA
001: Active gypsum
storage area, process
wastewater,
stormwater,
nonprocess
wastewater, and
noncontact cooling
water
25 mg/L monthly
average
75 mg/L daily
maximum
• No acknowledgement of exemption of flow
requirements;
• No discharge of process wastewater;
• Gypsum storage area must meet BAT
requirements;
• Optional discharge of treated wastewater
below 50% surge capacity;
• Required discharge of treated wastewater
above 50% storage capacity.
002: Inactive
gypsum storage area
Monitor and report
fluoride discharges
Source: Facility Permits (LDEQ, 2003; LDEQ, 2004a; and LDEQ, 2004b).
a - Mass-based fluoride limitations are based on fluoride removal efficiency of the scrubber.
6.4.2 Mosaic Fertilizers, LLC in Uncle Sam, LA
Table 6-11 presents the monthly discharge data for Mosaic Fertilizers' Uncle Sam
facility, compared to the mass-based fluoride permit limit. Table 6-11 also includes a calculated
monthly average concentration for the facility and the 40 CFR Part 418 concentration-based limit
(25 mg/L). EPA calculated the monthly average concentration using the average quantity and
flow data in the DMR Loadings Tool.
6-11
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-11. Mosaic Fertilizers 2008 Monthly Fluoride Discharge Data and 40 CFR Part
418 Monthly Average Limitations
Outfall
Monitoring
Period Date
Average
Fluoride
Quantity from
DMR data
(lb/day)
Monthly
Average
Fluoride Permit
Limit (Ib/dav)
Calculated
Fluoride
Concentration
(mg/L) a
40 CFR Part 418
Monthly
Average
Fluoride Limit
(mg/L) b
001
31-Jan-08
62,872
165,000
143
25
001
29-Feb-08
74,246
165,000
153
25
001
31-Mar-08
77,855
165,000
156
25
001
30-Apr-08
126,387
165,000
193
25
001
31-May-08
88,278
165,000
139
25
001
30-Jun-08
4,899
165,000
7.26
25
001
31-Jul-08
94,499
165,000
141
25
001
31-Aug-08
102,640
165,000
142
25
001
30-Sep-08
18,978
165,000
72.6
25
001
31-Oct-08
70,030
165,000
117
25
001
30-Nov-08
49,890
165,000
88.6
25
001
31-Dec-08
787
165,000
3.53
25
Source: DMR Loadings Tool and Facility Permit (LDEQ, 2003).
a - Concentration was calculated using the monthly quantity (lb/day) and flow (million gallons per day),
b - The 40 CFR Part 418 Subpart A limit for fluoride discharges is 25 mg/L when the facilities are discharging.
The 2008 DMR database includes over 23 millions pounds of fluoride discharged by
Mosaic Fertilizers' Uncle Sam facility. The facility permit has a maximum fluoride permit limit
of 165,000 lb/day, set by permit writers using BPJ. The facility is not exceeding the mass-based
permit limit; however, the limit is exceedingly high compared to the effluent guidelines that
apply to other facilities in the subcategory. Additionally, the fluoride concentrations from this
outfall range from 3.3 mg/L to 193 mg/L, the majority of which are greater than the treatable
concentrations reported in the Development Document for Effluent Limitations Guidelines and
New Source Performance Standards for the Basic Fertilizer Chemicals Segment of the Fertilizer
Manufacturing Point Source Category (1974 Development Document) (U.S. EPA, 1974).
6.4.3 IMC Phosphates in St. James, LA
Table 6-12 presents the 2008 fluoride discharges for IMC Phosphates' two outfalls. From
the facility permit, outfall 001 is the outfall for the active gypsum storage area, process
wastewater, storm water, nonprocess wastewater, and noncontact cooling water. Discharges from
outfall 001 must meet the 40 CFR Part 418 Subpart A fluoride limits (LDEQ, 2004a; LDEQ,
2004b); IMC Phosphates met these limits in 2008. Outfall 002 is the outfall for the inactive
gypsum storage area. The permit only requires reporting of fluoride discharges from outfall 002
(i.e., no numerical limit). EPA focused the additional review of IMC Phosphates' fluoride
discharges on outfall 002 because the discharges from this outfall contain the majority of the
facility's fluoride TWPE and it does not have the 40 CFR Part 418 Subpart A fluoride limit.
6-12
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
Table 6-12. IMC Phosphates 2008 Fluoride Discharges
Outfall
Fluoride Permit Limits
(mg/L)
Average Fluoride
Concentration (mg/L)
Pounds of Fluoride
Discharged (Ib/vr)
Fluoride TWPE
001
25 mg/L monthly average
75 mg/L daily maximum
2.13
49,700
1,490
002
Report only
382
1,950,000
58,400
Source: DMRLoads2008_v2 and Facility Permits (LDEQ, 2004a and LDEQ, 2004b).
Table 6-13 presents the monthly discharge data for IMC Phosphates outfall 002,
compared to the fluoride permit limit and the 40 CFR Part 418 Subpart A concentration-based
fluoride limit (25 mg/L).
Table 6-13. IMC Phosphates Outfall 002 2008 Monthly Fluoride Discharge Data and 40
CFR Part 418 Monthly Average Limitations
Outfall
Monitoring
Period Date
Average Fluoride
Concentration
(mg/L)
40 CFR Part 418
Monthly Average
Fluoride Limit (mg/L)
Facility Permit Monthly Average
Fluoride Limit (mg/L)
002
31-Jan-08
523
25
Report Only (No Limit)
002
29-Feb-08
454
25
Report Only (No Limit)
002
31-Mar-08
555
25
Report Only (No Limit)
002
30-Apr-08
NA
25
Report Only (No Limit)
002
31-May-08
718
25
Report Only (No Limit)
002
30-Jun-08
365
25
Report Only (No Limit)
002
31-Jul-08
383
25
Report Only (No Limit)
002
31-Aug-08
360
25
Report Only (No Limit)
002
30-Sep-08
297
25
Report Only (No Limit)
002
31-Oct-08
449
25
Report Only (No Limit)
002
30-Nov-08
279
25
Report Only (No Limit)
002
31-Dec-08
234
25
Report Only (No Limit)
Source: DMR Loadings Tool.
NA - Not available. The DMR Loadings Tool does not have a fluoride concentration for IMC Phosphates for April
2008.
The 2008 DMR database includes close to 2 millions pounds of fluoride discharged by
IMC Phosphates for outfall 002. The facility permit does not limit discharges of fluoride from
outfall 002; however, the concentrations are exceeding the effluent guidelines (25 mg/L) that
apply to other outfalls at the facility and at other facilities within the subcategory. Additionally,
the fluoride concentrations from this outfall range from 234 mg/L to 718 mg/L, all of which are
greater than the treatable concentrations reported in the 1974 Development Document (U.S.
EPA, 1974).
6.5 Fertilizer Manufacturing Category Conclusions
The estimated toxicity of the Fertilizer Manufacturing Category discharges results mainly
from the fluoride discharges of two plants (accounting for 95 percent of the category's 2008
6-13
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
DMR TWPE). Data collected for the 2010 annual review demonstrated that wastewater
discharge characteristics for this category are consistent with discharges from prior years. As in
prior years, EPA makes the following conclusions:
• The fluoride discharges were verified in the 2008 DMR database for Mosaic
Fertilizers' Uncle Sam facility and IMC Phosphates' St. James facility, both
phosphate fertilizer manufacturers in Louisiana. These facilities are exempt from
40 CFR Part 418 Subpart A, and the permits are based on BPJ and include
fluoride limits or reporting only requirements. EPA concludes that these facilities
do not represent the category as a whole because they are exempt from Part 418
(see 52 FR 28428, July 29, 1987). However, fluoride is discharged at
concentrations above the treatable concentrations reported in the 1974
Development Document (U.S. EPA, 1974).
• The total 2008 TWPE excluding the fluoride discharges from Mosaic Fertilizers'
Uncle Sam and IMC Phosphates' St. James facilities is 61,100 TWPE.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing ELGs).
6.6 Fertilizer Manufacturing Category References
1. LDEQ. 2003. Louisiana Department of Environmental Quality. Office of Environmental
Services Water Discharge Permit and Fact Sheet NPDES LA0004847 - IMC Phosphates
Company Uncle Sam Plant, Uncle Sam, LA. Baton Rouge, LA. (June 16). EPA-HQ-OW-
2004-0032-1773.
2. LDEQ. 2004a. Louisiana Department of Environmental Quality. Water Discharge Permit
for NPDES LA0029769 - IMC Phosphates Company, Faustina Plant, St. James, LA.
Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134.
3. LDEQ. 2004b. Louisiana Department of Environmental Quality. Water Discharge Permit
Fact Sheet for NPDES LA0029769 - IMC Phosphates Company, Faustina Plant, St.
James, LA. Baton Rouge, LA. EPA-HQ-OW-2004-0032-1134.
4. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
5. U. S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. EPA-440/l-75/042-a. Washington, DC.
(March).
6-14
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Section 6 - Fertilizer Manufacturing (40 CFR Part 418)
6. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-
0053.
7. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
6-15
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
7. Inorganic Chemicals Manufacturing (40 CFR Part 415)
EPA identified the Inorganic Chemicals Manufacturing (Inorganic Chemicals) Point
Source Category (40 CFR Part 415) for preliminary review because it continues to rank high, in
terms of toxic-weighted pound equivalent (TWPE), in point source category rankings (see Table
5-3 for the point source category rankings). This industry was reviewed previously in each of
EPA's Preliminary and Final Effluent Guidelines Program Plans from 2004 to 2009, except for
2008 (U.S. EPA, 2004; U.S. EPA, 2005; U.S. EPA, 2006; U.S. EPA, 2007; U.S. EPA, 2009).
This section summarizes the results of the 2010 annual review associated with the Inorganic
Chemicals Category. EPA focused on discharges of metals because of their high TWPE relative
to the rest of the Inorganic Chemicals Category.
This section describes the results of EPA's 2010 preliminary category review of the
Inorganic Chemicals Category. EPA is currently reviewing discharges from the Chlor-Alkali
Subcategory as part of the Chlorine and Chlorinated Hydrocarbons (CCH) Effluent Limitations
Guidelines and Standards (ELGs) rulemaking. Because a rulemaking for this segment of the
Inorganic Chemicals Category is underway, EPA excluded discharges from these facilities from
further consideration in this review (see Table V-l, 73 FR 53218, September 15, 2008).
7.1 Inorganic Chemicals Category Background
This subsection provides background on the Inorganic Chemicals Category including a
brief profile of the inorganic chemicals industry and background on 40 CFR Part 415.
7.1.1 Inorganic Chemicals Industry Profile
The inorganic chemicals manufacturing industry includes a broad class of facilities
encompassing the manufacture of substances that do not include carbon and its derivatives as
their principal elements. EPA considered the following seven North American Industry
Classification System (NAICS) codes as part of the Inorganic Chemicals Category:
• 325120: Industrial Gases;
• 325131: Inorganic Pigments;
• 325181: Alkalies and Chlorine;
• 325188: All Other Basic Inorganic Chemical Manufacturing;
• 325998INORG: All Other Miscellaneous Chemical Product and Preparation;
• 331311: Alumina Refining; and
• 325510INORG: Paint and Coating Manufacturing.
Wastewater generated by facilities in NAICS codes 325998 and 325510 may be regulated
under multiple point source categories. For example, most facilities in NAICS 325510 are
grouped under Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category (40
CFR Part 414). EPA reviewed available information about pollutant loads and manufacturing
operations for facilities reporting these NAICS codes. In its crosswalk, EPA assigned the
extension "INORG" to the end of the NAICS codes of facilities that most likely fall under the
applicability of the Inorganic Chemicals Point Source Category (40 CFR Part 415).
This list of Standard Industrial Classification (SIC) codes includes facilities that EPA
determined are potential new subcategories to the Inorganic Chemicals Category. As part of the
7-1
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
2004 annual review, EPA reviewed industries with SIC codes not clearly subject to existing
ELGs. EPA concluded that the processes, operations, wastewaters, and pollutants of facilities in
the following SIC codes are similar to those of the Inorganic Chemicals Category (U.S. EPA,
2004):12
• 2812: Alkalies and Chlorine;
• 2813: Industrial Gases;
• 2816: Inorganic Pigments; and
• 2819: Industrial Inorganic Chemicals.
As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes
for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are
reported by NAICS code. However, there is not a direct relationship between one SIC and one
NAICS codes. As a result, EPA included the following NAICS codes in the 2010 annual review
of the Inorganic Chemicals Category because they contain facilities with operations that are
similar to the SIC codes above:
• 325120: Industrial Gases;
• 325131: Inorganic Pigments;
• 325181: Alkalies and Chlorine;
• 325188: All Other Basic Inorganic Chemical Manufacturing;
• 331311: Alumina Refining; and
• 325510INORG: Paint and Coating Manufacturing.
Because Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the
sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report
facilities by SIC codes, and the U.S. Economic Census and TRI report data by NAICS code,
EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 7-1 lists the number
of facilities from the U.S. Economic Census and the screening-level databases for the seven
NAICS codes with operations in the Inorganic Chemicals Category the corresponding SIC codes
are included for reference. The U.S. Economic Census includes more facilities than the
screening-level databases because of many possible factors including not meeting TRI-reporting
thresholds, discharging to a publicly owned treatment works (POTW), and because some of
those in the U.S. Economic Census are distributors or sales facilities, not manufacturers.
12 The tables in this section include discharge information from facilities reporting these SIC codes and the
corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the
conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found
that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge TWPE
greater than zero.
7-2
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-1. Number of Inorganic Chemicals Manufacturing Facilities
NAICS Code
Corresponding
SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008 DMR
Database"
2008 TRI
Database b
325120: Industrial Gas Manufacturing
2813: Industrial
Gases
2816: Inorganic
Pigments
2819: Industrial
Inorganic
572
440
70
325131: Inorganic Dye and Pigment
Manufacturing
81
41
325188: All Other Basic Inorganic
Chemical Manufacturing
631
276
325510INORG: Paint and Coating
Manufacturing
NA
2
325998INORG: All Other Miscellaneous
Chemical Product and Preparation
NA
12
331311: Alumina Refining
Chemicals, NEC
10
6
325181: Alkalies and Chlorine
Manufacturing
2812: Alkalies
and Chlorine
41
12
6
Total
>1,335
452
413
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DAdRLoads20008_v2\ and TRIReleases2008jv3.
a - Includes both major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an
NAICS to SIC crosswalk for comparison purposes,
b - Releases to any media.
NA - Not applicable. These facility-specific NAICS codes do not correspond to NAICS codes in the 2002 U.S.
Economic Census.
NEC - Not elsewhere classified.
Table 7-2 shows whether permitting authorities designated direct discharging facilities in
the Inorganic Chemicals Category as minor or major dischargers (see Section 4.1.5). EPA
included data for minor dischargers for the first time in the 2010 annual review, as part of
DMRLoads2008 v2 database. EPA does not require permitting authorities to submit DMR data
for minor dischargers; however, many states do provide complete DMR data for minor
dischargers. From the 2010 annual review, EPA observed many data entry or other errors for
minor dischargers in addition to those previously identified for major dischargers, as discussed in
Section 4.3. Table 7-2 shows that approximately 86 percent of the Inorganic Chemicals Category
dischargers in the 2008 DMR database are minor dischargers.
7-3
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-2. Number of Inorganic Chemical Facilities by Facilities by Discharge
Classification in 2008 DMR Database
NAICS Code
Number of Facilities in 2008 DMR Database
Major
Dischargers
Minor
Dischargers
All
Dischargers
325120: Industrial Gas Manufacturing
60
380
440
325131: Inorganic Dye and Pigment Manufacturing
325188: All Other Basic Inorganic Chemical
Manufacturing
325510INORG: Paint and Coating Manufacturing
325998INORG: All Other Miscellaneous Chemical
Product and Preparation
331311: Alumina Refining
325181: Alkalis and Chlorine Manufacturing
0
12
12
Total
60
392
452
Source: DMRLoads2008 v2.
Table 7-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of inorganic chemicals facilities reporting to TRI do not report water discharges,
but those that do are almost evenly split between direct dischargers and indirect dischargers.
Table 7-3. Number of Inorganic Chemicals Facilities by Discharge Type in 2008 TRI
Database
NAICS Code
Number of Facilities in TRI 2008 Database
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both Indirect
and Direct
No Water
Discharges
325120: Industrial Gas
Manufacturing
4
6
0
60
325131: Inorganic Dye and Pigment
Manufacturing
14
9
4
14
325181: Alkalis and Chlorine
Manufacturing
0
2
0
4
325188: All Other Basic Inorganic
Chemical Manufacturing
40
44
24
168
325510INORG: Paint and Coating
Manufacturing
1
0
1
0
325998INORG: All Other
Miscellaneous Chemical Product
and Preparation
2
8
0
2
331311: Alumina Refining
2
1
0
3
Total
63
70
29
251
Source: TRlReleases2008 v3.
7-4
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
7.1.2 40 CFR Part 415
Wastewater discharges for the inorganic chemicals manufacturing industry are regulated
under 40 CFR Part 415: Inorganic Chemicals Manufacturing Point Source Category. This
category consists of 67 subcategories defined by the type of inorganic chemical product
manufactured. In addition to best practicable control technology (BPT), best available
technology economically achievable (BAT), best conventional pollutant control technology
(BCT), and new source performance standards (NSPS), the category includes pretreatment
standards for existing sources (PSES) and pretreatment standards for new sources (PSNS)
limitations for at least one subcategory. Table 5-6 in the 2004 Effluent Guidelines Program Plan
contains details on the pollutants regulated by each subpart (U.S. EPA, 2004). The effluent
guidelines for the Inorganic Chemicals Category were first promulgated in 1974 and revised in
1975, 1976, 1982, and 1986.
7.2 Inorganic Chemicals Category Screening-Level Review
Table 7-4 compares the screening-level results for the Inorganic Chemicals Category
from the 2006 through 2010 annual reviews that represented multiple years of data from the
DMR and TRI databases. The combined DMR and TRI TWPE increased slightly from discharge
years 2002 to 2004, but decreased from discharge year 2007 to 2008.
Table 7-4. Inorganic Chemicals Category TRI and DMR Discharges for the 2006 through
2010 Screening-Level Reviews
Year of Discharge
Year of Review
Inorganic Chemicals Category
TRI TWPE
DMR TWPE "
Total TWPE
2002
2006
186,000
107,000
293,000
2004
2007
123,000
316,000
439,000
2005
2008
92,100
NA
NA
2007
2009
54,700
394,000
449,000
2008
2010
71,300
228,000
299,000
Source: TRIReleases2002_v4; PCSLoads2002_v4', TRIReleases2004_v3', PCSLoads2004_v3; TRIReleases2005_v2;
TRlReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3', and DMRLoads2008jv2.
a - DMR data from 2002 through 2007 only includes major dischargers. 2008 DMR data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 7-5 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (61 percent) of the TWPE in the 2008 DMR database is from major
dischargers.
7-5
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-5. Inorganic Chemicals Category 2008 DMR TWPE by Discharge Classification
Year of Discharge11
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
89,000
139,000
Source: DMRLoads2008jv2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
7.3 Inorganic Chemicals Category Pollutants of Concern
Table 7-6 compares the five pollutants with the highest TRI TWPE based on results from
the 2010, 2009, and 2007 annual reviews (TRIReleases2008_v3, TRIReleases2007 v2, and
TRIReleases2004 v3). Table 7-7 lists the five pollutants with the highest TWPE based on results
from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2, DMRLoads2007_v3, and
PCSLoads2004 v4).
7-6
-------
Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-6. Inorganic Chemicals Category Top TRI Pollutants
Pollutant
2004 TRI Data"
2007 TRI Data3
2008 TRI Data "
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Manganese and Manganese
Compounds
1
29
67,400
1
22
14,600
1
26
38,200
Mercury and Mercury Compounds
3
13
4,390
3
12
6,500
2
10
6,680
Arsenic and Arsenic Compounds
Pollutants not reported in the top five
2004 TRI reported pollutants.
4
3
5,480
3
5
6,100
Nitrate Compounds
4
48
3,970
5
41
3,570
4
49
5,340
Polychlorinated biphenyls (PCBs)
Pollutants not reported in the top five
2004 TRI reported pollutants.
Pollutants not reported in the top five
2007 TRI reported pollutants.
5
2
3,570
Dioxin and Dioxin Like
Compounds
2
5
25,000
2
5
11,600
Pollutants not reported in the top five
2008 TRI reported pollutants.
Hexachlorobenzene
5
4
3,600
Pollutants not reported in the top five
2007 TRI reported pollutants.
Inorganic Chemicals Category
Total
NA
191 b
123,000
NA
142 b
54,700
NA
161 b
71,300
Source: TRIReleases2004_v3, TRIReleases2007_v2\ and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
7-7
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-7. Inorganic Chemicals Category Top DMR Pollutants
Pollutant
2004 DMR Data"
2007 DMR Data"
2008 DMR Datab
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Aluminum
Pollutants not reported in the top five
DMR 2004 reported pollutants.
Pollutants not reported in the top five
DMR 2007 reported pollutants.
1
17
55,900
Mercury
2
14
46,500
Copper
5
27
29,800
5
23
2,050
3
40
36,900
Sulfide
1
2
87,900
Pollutants not reported in the top five
DMR 2007 reported pollutants.
4
1
9,960
Silver
Pollutants not reported in the top five
DMR 2004 reported pollutants.
5
5
9,000
Polychlorinated biphenyls
(PCBs)
1
1
363,000
Pollutants not reported in the top five
DMR 2008 reported pollutants.
Chlorine
3
10
40,500
2
9
10,500
Fluoride
Pollutants not reported in the top five
DMR 2004 reported pollutants.
3
7
4,590
Heptachlor
4
1
2,140
Iron
4
8
29,900
Pollutants not reported in the top five
DMR 2007 reported pollutants.
Lead
2
14
52,400
Inorganic Chemicals Category
Total
NA
58 c
316,000
NA
51c
394,000
NA
139 c
228,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data only include major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
7-8
-------
Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
The Inorganic Chemicals Category TWPE in the 2008 TRI database is significantly lower
than the 2008 DMR TWPE. Therefore, EPA focused the additional review on the DMR-reported
pollutants that account for the majority of the category TWPE.
EPA's additional review for the 2008 DMR database metals discharges is presented in
the following sections. During the review of metals discharges, EPA discovered that the majority
of the top pollutants were discharged by the same four facilities in the 2008 DMR database.
Table 7-8 presents the top pollutants discharged in the Inorganic Chemicals Category and the
corresponding top facility discharger.
Table 7-8. Inorganic Chemicals Category Top Facility Dischargers in the 2008 DMR
Database
Top Pollutant
Facility Name
Pounds of
Pollutant
Discharged
Pollutant
TWPE
Total
Facility
TWPE
Other Top
Pollutants
Discharged
Aluminum
UOP LLC
875,000
52,500
58,200
None a
Mercury
AL State Docks - Mud
Lakes
221
25,900
28,400
Aluminum
Elementis Chromium LP
Castle
94.4
11,100
24,000
Silver
Copper
Dow Chemical,
Pittsburg Plant
48,100
30,300
33,900
None3
Source: DMRLoads2008jv2.
a - These facilities do not have discharges of other top five pollutants with significant discharges (TWPE great than
1,000).
7.4 Inorganic Chemicals Category Top Facility Dischargers in DMR
This subsection provides further detail on the top four facility dischargers in the
Inorganic Chemicals Category responsible for the majority of the aluminum, mercury, copper,
and silver TWPE. As a result of EPA's review of discharges from the top facilities in the
Inorganic Chemicals Category, the overall category 2008 DMR TWPE decreased by 121,900
TWPE.
7.4.1 UOP LLC in Chickasaw, AL
Table 7-9 presents the discharges in the 2008 DMR database for UOP LLC. The majority
of the facility TWPE (approximately 90 percent) is from aluminum. Aluminum discharges from
UOP LLC account for 23 percent of the DMR TWPE for the Inorganic Chemicals Category.
7-9
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-9. UOP LLC 2008 Top Discharges
Pollutant
Total Pounds
Total TWPE
Percentage of Facility
Total TWPE
Aluminum
875,000
52,500
90.2%
Iron
783,000
4,380
7.5%
Zinc
20,000
800
1.4%
Chloride
9,230,000
225
0.4%
Nickel
1,590
159
0.3%
Total
191,000,000
58,200
100%
Source: DMRLoads2008_v2.
The majority of the aluminum discharges for UOP LLC are from outfalls 003 and 004.
The facility's permit indicates that outfalls 003 and 004 are "storm water runoff from nonprocess
areas associated with molecular sieve adsorbents and catalysts manufacture." The permit does
include monitoring only requirements for aluminum for outfalls 003 and 004 (ADEM, 2002).
Table 7-10 presents the aluminum discharge data for outfalls 003 and 004 in the DMR Loadings
Tool for 2008. EPA contacted UOP LLC to verify the aluminum concentrations and flows. UOP
LLC verified the aluminum values and units, but indicated that the flows for outfall 003 and 004
had the wrong units (Frain, 2010). Table 7-10 also includes the facility-provided flows. Using
the facility-provided flows for outfalls 003 and 004, UOP LLC's aluminum discharges decrease
by 46,200 TWPE, while the facility's TWPE decreases from 58,200 TWPE to 7,110 TWPE.
Table 7-10. UOP LLC Outfalls 003 and 004 2008 Monthly Aluminum Discharge Data
Outfall
Monitoring Period
Date
Maximum
Concentration
(mg/L)
DMR Loadings Tool
Flow (MGD)
Facility-Provided
Flow (MGD)
003
30-Jun-08
10
31.86
3.186
003
31-Dec-08
0.1
20.33
2.033
004
30-Jun-08
9
25.52
2.552
004
31-Dec-08
1.025
16.29
1.629
Source: DMR Loadings Tool and Facility Contact (Frain, 2010).
7.4.2 AL State Docks Mud Lakes in Mobile, AL
Table 7-11 presents the discharges in the 2008 DMR database for AL State Docks Mud
Lakes. The majority of the facility TWPE (approximately 91 percent) is from mercury. Mercury
discharges from AL State Docks Mud Lakes also account for almost 11 percent of the DMR
TWPE for the Inorganic Chemicals Category.
7-10
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-11. AL State Docks Mud Lakes 2008 Mercury and Aluminum Discharges
Pollutant
Total Pounds
Total TWPE
Percentage of Facility
Total TWPE
Mercury
221
25,900
91.2%
Aluminum
41,600
2,500
8.8%
Total
9,470,000
28,400
100%
Source: DMRLoads2008 v2.
AL State Docks Mud Lakes is a dock that serves as a transfer station for bulk cargo that
is exported and imported. The dock site was a former aluminum ore tailing lakes operated by the
Aluminum Company of America (ALCOA). These lakes are currently used to accumulate and
treat aluminum ore tailings leachate prior to discharge to the Mobile River (ADEM, 2006). The
facility contact indicated that it is not an industrial manufacturing site (Wright, 2010).
All of the mercury discharges for AL State Docks Mud Lakes are from outfall 001.
Outfall 001 is stormwater and groundwater from the aluminum tailings leachate collection
system (ADEM, 2006). Table 7-12 presents the mercury discharge data for outfall 001 in the
DMR Loadings Tool for 2008. EPA contacted AL State Docks Mud Lakes and the Alabama
Department of Environmental Management (ADEM) to verify the mercury quantities. ADEM
confirmed the mercury discharges (Brown, 2010).
EPA determined that the discharges from this facility do not meet the applicability of the
Inorganic Chemicals Category. Because this facility's discharges are from aluminum ore mining,
EPA believes this facility's discharges are applicable to the Nonferrous Metals Manufacturing
(40 CFR Part 421). However, because the facility no longer operates as an aluminum ore mine
and processing facility, EPA believes the discharges should be permitted using best professional
judgment.
Table 7-12. AL State Docks Mud Lakes Outfall 001 2008 Monthly Mercury Discharge
Data
Outfall
Monitoring Period Date
Average Quantity (kg/dav)
001
31-Mar-08
NR
001
30-Jun-08
0.000635
001
30-Sept-08
0.776
001
31-Dec-08
0.313
Source: DMR Loadings Tool.
NR - Not reported.
7.4.3 Elementis Chromium LP in Castle Hayne, NC
Table 7-13 presents the discharges in the 2008 DMR database for Elementis Chromium
LP. The majority of the facility TWPE (approximately 79 percent) is from mercury and silver.
Mercury and silver discharges from Elementis Chromium LP also account for 8 percent of the
DMR TWPE for the Inorganic Chemicals Category.
7-11
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-13. Elementis Chromium LP Plant 2008 Top Discharges
Pollutant
Total Pounds
Total TWPE
Percentage of Facility
Total TWPE
Mercury
94.4
11,100
46.3%
Silver
471
7,760
32.3%
Selenium
2,360
2,640
11.0%
Lead
942
2,110
8.8%
Chloride
7,980,000
194
0.8%
Total
8,010,000
24,000
100%
Source: DMRLoads2008_v2.
All of the mercury discharges for Elementis Chromium LP are from outfall 001. Table
7-14 presents the mercury discharge data for outfall 001 in the DMR Loadings Tool for 2008.
EPA contacted Elementis Chromium LP to verify the mercury and silver concentrations and
flows. Elementis Chromium LP verified the flows, but indicated that the mercury and silver
concentrations were incorrect. The facility contact also indicated that mercury and silver are
reported quarterly rather than monthly (Coury, 2010). Table 7-14 also includes the facility-
provided concentrations. Using the facility-provided concentrations, Elementis Chromium LP's
mercury discharges decrease by 18,800 TWPE, while the facility's TWPE decreases from 24,000
TWPE to 5,190 TWPE.
Table 7-14. Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver
Discharge Data
Outfall
Monitoring
Period Date
NODI Code a
Average
Concentration
(mg/L)
Facility-
Provided
Concentration
(mg/L)
Average Flow
(MGD)
Mercury
001
31-Jan-08
8
NR
0.659129
001
29-Feb-08
0.0003
0.0003
0.668433
001
31-Mar-08
8
NR
0.6071
001
30-Apr-08
8
NR
0.614742
001
31-May-08
0.2
0.0002
0.707
001
30-Jun-08
8
NR
0.589548
001
31-Jul-08
8
NR
0.582452
001
31-Aug-08
0
<0.0002
0.58029
001
30-Sept-08
8
NR
0.595933
001
31-Oct-08
8
NR
0.557667
001
30-Nov-08
0
<0.0002
0.606935
001
31-Dec-08
8
NR
0.691677
7-12
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Table 7-14. Elementis Chromium LP Outfall 001 2008 Monthly Mercury and Silver
Discharge Data
Outfall
Monitoring
Period Date
NODI Codea
Average
Concentration
(mg/L)
Facility-
Provided
Concentration
(mg/L)
Average Flow
(MGD)
Silver
001
31-Jan-08
8
NR
0.659129
001
29-Feb-08
0
<0.001
0.668433
001
31-Mar-08
8
NR
0.6071
001
30-Apr-08
8
NR
0.614742
001
3 l-May-08
1
<0.001
0.707
001
30-Jun-08
8
NR
0.589548
001
31-Jul-08
8
NR
0.582452
001
31-Aug-08
0
<0.001
0.58029
001
30-Sept-08
8
NR
0.595933
001
31-Oct-08
8
NR
0.557667
001
30-Nov-08
0
<0.005
0.606935
001
31-Dec-08
8
NR
0.691677
Source: DMR Loadings Tool and Facility Contact (Coury, 2010).
a - NODI Code 8 is a reporting code for "Other."
NR - Not reported. The facility contact indicated that mercury and silver were reported quarterly rather than
monthly.
7.4.4 Dow Chemical Pittsburg Plant in Pittsburg, OH
Table 7-15 presents the discharges in the 2008 DMR database for Dow Chemical
Pittsburg Plant. The majority of the facility TWPE (approximately 89 percent) is from copper.
Copper discharges from Dow Chemical Pittsburg Plant account for 13 percent of the DMR
TWPE for the Inorganic Chemicals Category.
Table 7-15. Dow Chemical Pittsburg Plant 2008 Top Discharges
Pollutant
Total Pounds
Total TWPE
Percentage of Facility
Total TWPE
Copper
48,100
30,300
89.3%
Nickel
28,100
2,810
8.3%
Mercury
7.11
833
2.4%
Total
2,060,000
33,900
100%
Source: DMRLoads2008_v2.
The majority of the copper discharges for Dow Chemical Pittsburg Plant are from outfalls
001, 004, 005, and 006. Table 7-16 presents the copper discharge data for outfalls 001, 004, 005,
and 006 in the DMR Loadings Tool for 2008. The facility's copper discharges are in the DMR
Loadings Tool as a quantity (i.e., as kilogram per day (kg/day)). EPA also calculated the monthly
average quantity discharge using the average concentration and flow data in the 2008 DMR
7-13
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
Loadings Tool. EPA determined that the reported quantities in the DMR Loadings Tool were
incorrect. The discharge quantities calculated using the flow and concentrations are at least 3
orders of magnitude less. Table 7-16 also presents the calculated monitoring period quantities.
Table 7-17 presents the revised estimated pounds and TWPE for copper from the Dow Chemical
Pittsburg Plant. Using the calculated quantities, Dow Chemical Pittsburg Plant's copper
discharges decrease by 23,600 TWPE, while the facility's TWPE decreases from 33,900 TWPE
to 10,300 TWPE.
Table 7-16. Dow Chemical Pittsburg Plant 2008 Monthly Copper Discharge Data
Outfall
Monitoring
Period Date
NODI
Codea
Average
Quantity
(kg/day)
Average
Concentration
(mg/L)
Average Flow
(MGD)
Calculated
Quantity
(kg/day)
001
31-Jan-08
6.4
0.0064
0.09
0.0021
001
29-Feb-08
2.9
0.0029
0.14
0.0015
001
31-Mar-08
6.1
0.0061
0.2
0.0046
001
30-Apr-08
2.4
0.0024
1.51
0.0137
001
31-May-08
8.7
0.0087
0.18
0.0059
001
30-Jun-08
5.4
0.0054
0.18
0.0036
004
31-Jan-08
15
0.015
2.92
0.1655
004
29-Feb-08
11
0.011
0.36
0.0151
004
31-Mar-08
C
004
30-Apr-08
C
004
31-May-08
C
004
30-Jun-08
C
005
30-Jun-08
7.6
0.0076
97.2
2.79
006
30-Jun-08
43
0.043
64.3
10.46
Source: DMR Loadings Tool.
a - NODI Code C means no discharge occurred for that monitoring period.
Table 7-17. Dow Chemical Pittsburg Plant's 2008 Copper Discharges
Outfall
Old Copper
Total Pounds
Old Copper
TWPE
Revised Copper
Total Pounds
Revised Copper
TWPE
Reduction in
TWPE
001
4,290
2,700
4.21
2.7
2,700
004
3,400
2,150
24.5
15.4
2,130
005
6,070
3,820
2,230
1,410
2,420
006
34,300
21,600
8,350
5,260
16,400
Total
48,000
30,300
10,600
6,690
23,600
Source: DMRLoads2008_v2 and Inorganic Chemicals Category (40 CFR Part 415) Facility Review Calculations
(ERG, 2010).
7-14
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Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
7.5 Inorganic Chemicals Category Conclusions
The estimated toxicity of the Inorganic Chemicals Category discharges resulted from
discharges of metals. Data collected for the 2010 annual review demonstrated that wastewater
discharge characteristics for this category are consistent with discharges from prior years. As in
prior years, EPA makes the following conclusions:
• There were flow units errors for discharges from the UOP LLC facility in
Chickasaw, AL. These discharges accounted for the majority of the Inorganic
Chemicals Category aluminum TWPE in the 2008 DMR database. Correcting the
flow units decreases the 2008 facility TWPE by 51,100 TWPE.
• AL State Docks Mud Lakes facility in Mobile, AL was incorrectly classified in
the Inorganic Chemicals Category. This facility should be classified in the
Nonferrous Metals Manufacturing Category (40 CFR Part 421). Excluding this
facility from the Inorganic Chemicals Category decreases the category's 2008
TWPE by 28,400 TWPE. EPA also determined that best professional judgment
(BPJ) permitting was most appropriate for this facility's discharges.
• The mercury and silver concentrations for Elementis Chromium LP's facility in
Castle Hayne, NC had unit errors and were missing below detection limit
indicators. Correcting the concentrations decreases the 2008 facility TWPE by
18,800 TWPE.
• The reported copper quantities for Dow Chemical Pittsburg Plant's facility in
Pittsburg, CA were significantly higher than the quantities calculated using the
reported concentrations and flows in 2008 DMR Loadings Tool. Using the
calculated quantities decreases the 2008 facility TWPE by 23,600 TWPE.
• Correcting the database errors identified during the 2010 annual review decreases
the 2008 Inorganic Chemicals Category TWPE from 299,000 TWPE to 177,000
TWPE. The Inorganic Chemicals Category continues to rank high because a high
number of facilities (approximately 450) in the industry have data in the
screening-level databases.13 EPA will continue to monitor the Inorganic
Chemicals Category discharges to determine if they are properly controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing ELGs).
13 For the Inorganic Chemicals Manufacturing Point Source Category, TRIReleases2008 contains data from 413
facilities, and DMRLoads2008 contains data from 452 facilities.
7-15
-------
Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
7.6 Inorganic Chemicals Category References
1. ADEM. 2002. Alabama Department of Environmental Management. National Pollutant
Discharge Elimination System Permit NPDES - AL0002666 - for UOP LLC Mobile
Plant. Montgomery, AL. (December 23). EPA-HQ-OW-2008-0517 DCN 07271.
2. ADEM. 2006. Alabama Department of Environmental Management. National Pollutant
Discharge Elimination System Permit NPDES - AL0002976 - for Alabama State Port
Authority Mud Lakes. Mobile, AL. (October 24). EPA-HQ-OW-2008-0517 DCN 07272.
3. Brown, Donald. 2010. Telephone and E-mail communication with Donald Brown,
Alabama Department of Environmental Management, and Elizabeth Sabol, Eastern
Research Group, Inc. "Re: Mercury Discharges Reported to DMR in 2008 for AL State
Docks - Mud Lakes." (August 31). EPA-HQ-OW-2008-0517 DCN 07306.
4. Coury, Sean. 2010. Telephone conversation with Sean Coury, Elementis Chromium, and
Elizabeth Sabol, Eastern Research Group, Inc. "Re: Mercury and Silver Discharges
Reported to DMR in 2008." (June 29). EPA-HQ-OW-2008-0517 DCN 07273.
5. ERG. 2010. Eastern Research Group, Inc. Inorganic Chemicals Category (40 CFR Part
415) Facility Review Calculations. (July 2). EPA-HQ-OW-2008-0517 DCN 07274.
6. Frain, Rick. 2010. Telephone conversation with Rick Frain, UOP LLC and Elizabeth
Sabol, Eastern Research Group, Inc. "Re: Aluminum Discharges Reported to DMR in
2008." (June 29). EPA-HQ-OW-2008-0517 DCN 07275.
7. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
8. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346
through 1352.
9. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-
0016.
10. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
11. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQ-
OW-2006-0771-0819.
12. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQ-
OW-2008-0517-0515.
7-16
-------
Section 7 - Inorganic Chemicals Manufacturing (40 CFR Part 415)
13. Wright, Cliff. 2010. Telephone and E-mail communication with Cliff Wright, AL State
Docks - Mud Lakes and Elizabeth Sabol, Eastern Research Group, Inc. "Re: Mercury
Discharges Reported to DMR in 2008." (June 29). EPA-HQ-OW-2008-0517 DCN
07276.
7-17
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Section 8 - Landfills (40 CFR Part 445)
8. Landfills (40 CFR Part 445)
EPA selected the Landfills Category (40 CFR Part 445) for preliminary review because it
ranks high, in terms of toxic-weighted pound equivalent (TWPE), in point source category
rankings (see Table 5-3 for the point source category rankings). EPA has not previously
reviewed the Landfills Category. This section summarizes the results of the 2010 annual review
associated with the Landfills Category. EPA focused on metal discharges, because of their high
TWPE compared to other pollutants in the category.
8.1 Landfills Category Background
This subsection provides background on the Landfills Category including a brief profile
of the landfills industry and background on 40 CFR Part 445.
8.1.1 Landfills Industry Profile
The landfills industry includes facilities that are operate waste (hazardous and non-
hazardous) treatment or disposal facilities or perform the collecting and/or hauling of waste
materials within a local area, combined with the operation of waste treatment or disposal
facilities. The landfills can either be commercial or municipal. EPA considered the following
four North American Industry Classification System (NAICS) codes as part of the Landfills
Category:
• 562211: Hazardous Waste Treatment and Disposal;
562212: Solid Waste Landfill;
• 562219: Other Nonhazardous Waste Treatment and Disposal; and
LNDFLL: Landfills.
Wastewater generated by facilities in the NAICS codes 562211, 562212, and 562219 may
be regulated under the Landfills Category, Centralized Waste Treatment (CWT) Category (40
CFR Part 437), and the Waste Combustor Category (40 CFR Part 444). EPA reviewed available
information about pollutant loads and operations for facilities reporting these NAICS codes. EPA
was able to assign the "LNDFLL" NAICS code for facilities that most likely fall under the
applicability of Part 445, Landfills Effluent Limitation Guidelines and Standards (ELGs). EPA
was not able to determine which point source category applied to the other facilities in NAICS
codes 562211, 562212, and 562219. The discharges from these facilities that were not assigned
the "LNDFLL" NAICS code are counted in all three point source categories in the 2008
discharge monitoring report (DMR) and Toxics Release Inventory (TRI) databases.
Because Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the
sources of the DMR data used to develop DMRLoads2008, report facilities by Standard
Industrial Classification (SIC) codes, and the U.S. Economic Census and TRI report data by
NAICS code, EPA reclassified the 2008 DMR data by the equivalent NAICS code. Table 8-1
lists the number of facilities from the U.S. Economic Census and the screening-level databases
for the seven NAICS codes with operations in the Inorganic Chemicals Category the
corresponding SIC codes are included for reference. The U.S. Economic Census includes more
facilities than the screening-level databases because of many possible factors including not
meeting TRI-reporting thresholds, discharging to a publicly owned treatment works (POTW),
8-1
-------
Section 8 - Landfills (40 CFR Part 445)
and because some of those in the U.S. Economic Census are distributors or sales facilities, not
manufacturers.
Table 8-1. Number of Landfills
NAICS Code
Corresponding
SIC Code
Number of Facilities
2002 U.S.
Economic Census
2008 DMR
Database"
2008 TRI
Database b
562211: Hazardous Waste
Treatment and Disposal
4953: Refuse
Systems;
4953L: Refuse
Systems
(Landfills)
701
1,295
53
562212: Solid Waste Landfill
1,507
1
562219: Other Nonhazardous
Waste Treatment and Disposal
199
5
LNDFLL: Landfills
NA
8
Total
>2,407
1,295
67
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008jv2; and TRlReleases2008_v3.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-
code crosswalk for comparison purposes,
b - Releases to any media.
NA - Not applicable.
Table 8-2 shows whether permitting authorities designated direct discharges as minor or
major (see Section 4.1.5) for facilities in the Landfills Category. EPA included data for minor
discharges for the first time in the 2010 annual review, as part of DMRLoads2008 v2 database.
EPA does not require permitting authorities to submit DMR data for minor dischargers; however,
many states do provide complete DMR data for them. From this year's review, EPA observed
many data entry or other errors for minor dischargers in addition to those previously identified
for major dischargers, as discussed in Section 4.3. Table 6-2 shows that approximately 99
percent of the Landfills Category dischargers in the 2008 DMR database are minor dischargers.
Table 8-2. Number of Landfills by Discharge Classification in 2008 DMR Database
NAICS Code"
Number of Facilities in 2008 DMR Database
Major Dischargers
Minor Dischargers
All Dischargers
562211: Hazardous Waste Treatment and
Disposal
11
1,284
1,295
562212: Solid Waste Landfill
562219: Other Nonhazardous Waste Treatment
and Disposal
LNDFLL: Landfills
Total
11
1,284
1,295
Source: DMRLoads2008jv2.
a - DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.
Table 8-3 presents the number of landfills included in the DMR databases and whether
discharge data (e.g., pollutant concentrations, flow rates, etc.) were included for reporting years
2004, 2007, and 2008. The table shows a large increase in the number of landfills with discharge
8-2
-------
Section 8 - Landfills (40 CFR Part 445)
data from 2004 and 2007 to 2008 in the DMR database, due to the addition of minors. However,
there are still almost 70 percent of landfills without discharge data in the 2008 DMR database.
Table 8-3. Number of Landfills in the DMR Database for Reporting Years 2004, 2007,
and 2008
Discharge Status
2004 a
2007 a
2008 a
With Water Discharge Data b
18
8
383
Without Water Discharge
Data0
287
1,070
912
Total
305
1,078
1,295
Source: PCSLoads2004_v3; DMRLoads2007jy4\ and DA4RLoads2008_v2.
a - Major and minor dischargers.
b - Includes facilities with DMR data in the DMR databases,
c - Includes facilities with NPDES permits without DMR data in the DMR databases.
Table 8-4 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of landfills reporting to TRI do not report water discharges. However, there is an
even distribution of direct and indirect dischargers for those that do report water discharges.
Table 8-4. Number of Landfills by Discharge Type in 2008 TRI Database
Number of Facilities in 2008 TRI Database
NAICS Code
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both Indirect
and Direct
Dischargers
No Water
Discharges
562211: Hazardous Waste Treatment and
Disposal
4
4
1
44
562212: Solid Waste Landfill
0
0
1
0
562219: Other Nonhazardous Waste Treatment
and Disposal
2
0
0
3
LNDFLL: Landfills
1
3
2
2
Total
7
7
4
49
Source: TRlReleases2008 v3.
8.1.2 40 CFR Part 445
EPA promulgated ELGs for the Landfills Category (40 CFR Part 445) on January 19,
2000 (65 FRN 3007). The Landfills ELGs are applicable to wastewater discharges to surface
water14 from landfill units, excluding wastewater discharges from the following units:
• Land application or land treatment units;
• Surface impoundments;
• Underground injection wells;
• Waste piles;
• Salt dome formations;
14 40 CFR Part 445 does not set limits for discharges to POTWs (i.e., indirect dischargers).
8-3
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Section 8 - Landfills (40 CFR Part 445)
• Salt bed formations;
• Underground mines/caves;
• Wastewater generated offsite;
• Discharges of contaminated ground water or wastewater from recovery pumping
wells;
• Landfills operated in conjunction with other industrial or commercial operations
when the landfill receives facility generated wastes; and
• Landfills in conjunction CWTs.
There are two subcategories in the Landfills Category: Resource Conservation and
Recovery Act (RCRA) Subtitle C Hazardous Waste (Subpart A) and RCRA Subtitle D
Nonhazardous Waste (Subpart B). RCRA Subtitle C Hazardous Waste landfills are authorized by
RCRA to accept hazardous waste (see 40 CFR Part 421). These landfills are required to maintain
a leachate collection and removal system during the active and postclosure period of the landfill
(U.S. EPA, 2000). RCRA Subtitle D NonHazardous Waste landfills can receive municipal
refuse, ash, sludge, construction and demolition debris, and nonhazardous industrial waste. Prior
to 1980 when RCRA was enacted, the older Subtitle D landfills may have received waste that
was later classified as hazardous (U.S. EPA, 2000). Table 8-5 presents the regulated pollutants
and limits for direct dischargers in the two subparts. For RCRA Subtitle C hazardous waste
landfills, EPA developed the limits based on a treatment system consisting of equalization,
chemical precipitation, biological treatment, and multimedia filtration. For RCRA Subtitle D
nonhazardous waste landfills, EPA developed the limits based on a treatment system consisting
of equalization, biological treatment, and multimedia filtration (U.S. EPA, 2000).
Table 8-5. Regulated Pollutants and Limits for the Landfills Category (40 CFR Part 445)
Regulated
Pollutant
RCRA Subtitle C Hazardous Waste
Landfill BAT (Subpart A)
RCRA Subtitle D Nonhazardous Waste
Landfill BAT (Subpart B)
Dailv Maximum
(mg/L)
Monthlv Average
(mg/L)
Daily Maximum
(mg/L)
Monthly Average
(mg/L)
bod5
220
56
140
37
TSS
88
27
88
27
Ammonia (as N)
10
4.9
10
4.9
a-Terpineol
0.042
0.019
0.033
0.016
Aniline
0.024
0.015
NA
NA
Benzoic acid
0.119
0.073
0.12
0.071
Naphthalene
0.059
0.022
NA
NA
p -Cresol
0.024
0.015
0.025
0.014
Phenol
0.048
0.029
0.026
0.015
Pyridine
0.072
0.025
NA
NA
Arsenic
1.1
0.54
NA
NA
Chromium
1.1
0.46
NA
NA
Zinc
0.535
0.296
0.2
0.11
pH
Within the range 6 to 9
Within the range 6 to 9
Source: 40 CFR Part 445.
NA - Not applicable. Subpart B - RCRA Subtitle D Nonhazardous Waste Landfill does not regulate these
pollutants.
8-4
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Section 8 - Landfills (40 CFR Part 445)
8.2 Landfills Category 2010 Screening-Level Review
Table 8-6 compares the screening-level results for the Landfills Category from the 2009
and 2010 annual reviews that represented the 2007 and 2008 DMR and TRI databases,
respectively. The combined DMR and TRI TWPE increased from discharge years 2007 to 2008.
The 2008 DMR TWPE accounts for approximately 99 percent of the total 2008 category TWPE,
similar to the previous year.
Table 8-6. Landfills Category TRI and DMR Discharges for the 2009 and 2010 Screening-
Level Reviews
Year of Discharge
Year of Review
Landfills Category
TRI TWPE b
DMR TWPE "
Total TWPE
2007
2009
83
15,300
15,400
2008
2010
781
191,000
192,000
Source: TRlReleases2008_v3 and DMRLoads2008jv2.
Note: EPA did not previously review the Landfills Category; therefore, the 2007 discharge data is only shown for
comparison to 2008.
a - DMR data from 2007 include only major dischargers. DMR 2008 data include both minor and major
dischargers.
b - Discharges include transfers to POTWs and account for POTW removals.
Table 8-7 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (99 percent) of the TWPE in the 2008 DMR database results from minor
dischargers.
Table 8-7. Landfills Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
190,000
1,260
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
8.3 Landfills Pollutants of Concern
Table 8-8 lists the five pollutants with the highest TWPE in TRIReleases2008_v3, while
Table 8-9 lists the five pollutants with the highest TWPE in DMRLoads2008 v2.
8-5
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Section 8 - Landfills (40 CFR Part 445)
Table 8-8. Landfills Category Top TRI Pollutants in 2008 a
Pollutant
Rank
Number of Facilities
Reporting Pollutant
TWPE
Copper and Copper Compounds
1
5
127
Tetrachloroethylene
2
3
55
Arsenic and Arsenic Compounds
3
1
37
Lead and Lead Compounds
4
4
36
Cadmium and Cadmium Compounds
5
2
14
Landfills Category Total
NA
18 b
781
Source: TRlReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
Table 8-9. Landfills Category Top DMR Pollutants in 2008 a
Pollutant
Rank
Number of Facilities
Reporting Pollutant
TWPE
Vanadium
1
11
45,400
Iron
2
146
31,300
Manganese
3
55
15,700
Arsenic
4
47
15,100
Calcium
5
18
10,900
Landfills Category Total
NA
232 b
191,000
Source: DMRLoads2008jv2.
a - 2008 DMR data includes major and minor dischargers,
b - Number of facilities reporting TWPE greater than zero.
The Landfills Category TWPE in the 2008 TRI database is significantly lower than the
2008 DMR TWPE. Therefore, EPA focused the additional review of the Landfills Category on
the DMR-reported pollutants that account for the majority of the category TWPE.
The top four DMR-reported pollutants in 2008 are metals. Of the top four metals, the
Landfill ELG regulates only arsenic from hazardous waste landfills (Subpart A). The remaining
top metals are not regulated by the Landfill ELG. EPA's additional review of the top metals is
presented in the following section.
8.4 Landfills Category Facility-Specific DMR Review
During the 2010 annual review of the Landfills Category, EPA identified several data
entry or conversion errors in the underlying DMR data used to develop the 2008 DMR database.
These errors inaccurately increased the top pollutants TWPE. All of the errors identified during
the facility review were for minor dischargers, which compose the majority of facilities reporting
discharges in the Landfills Category. Table 8-10 presents the data entry errors identified by EPA
along with the corrected facility TWPE. EPA also identified one facility, American Electric
Power in Ohio, that was incorrectly categorized in the Landfills Category. EPA determined that
this facility only receives waste from American Electric Power's flue gas desulfurization,
gypsum, fly and bottom ash, and purge stream solids (Ohio EPA, 2009). Therefore, this facility
8-6
-------
Section 8 - Landfills (40 CFR Part 445)
should be included in Steam Electric Power Generating Category (40 CFR Part 423) rather than
Part 445 because Part 445 excludes "landfills operated in conjunction with other industrial or
commercial operations when the landfill only receives waste generated by the industrial or
commercial operation directly associated with the landfill" (see 40 CFR Part 445.1(e)).
Table 8-11 presents the revised top pollutant TWPE using the corrected data. Note: these
corrections are not included in DMRLoads2008_v2. EPA will incorporate these corrections into
future versions of the 2008 DMR database.
8-7
-------
Section 8 - Landfills (40 CFR Part 445)
Table 8-10. Data Errors Identified in the Landfills Category in 2008 DMR Database
Facility Name
Facility
Location
Major or
Minor
Facility
Pollutants with
Identified
Errors
Original
Pollutant
TWPE
Original Facility
Total TWPE
Error(s) Identified
Corrected
Facility
TWPE
Percent
Reduction
of Facility
TWPE
Springfield
Sanitary
Landfill
Willard,
MO
Minor
Vanadium
45,100
46,600
Facility contact confirmed vanadium
concentrations were all reported in jxg/1,
not mg/L. Facility contact also
confirmed six discharges that were
missing the nondetect indicator
(i.e. "<"). (Gatlin, 2010)
1,560
97%
Advantage
Metals
Recycling
Kansas
City, MO
Minor
All3
20,300
20,300
Facility contact confirmed a data entry
error (i.e., incorrect value and decimal
location) for the cadmium concentration
for September 2008. Facility contact also
identified data entry errors (i.e., incorrect
decimal location) for all the flows for
outfalls 00land 003. (Palmer, 2010)
240
99%
Onyx Maple
Hill Landfill
Macon, MO
Minor
Magnesium,
Manganese,
Fluoride
20,100 b
20,300
Facility contact confirmed magnesium,
manganese, and fluoride concentrations
were all reported in |ig/L. not mg/L, for
outfalls 001 and 004. (Tipton, 2010)
175
99%
Ashtabula
River
OH
Minor
Arsenic
13,100
16,700
Review of on-line Envirofacts15
confirmed incorrect values for arsenic
quantities.
3,660
78%
Sources: Facility contacts (Gatlin, 2010; Palmer, 2010; and Tipton, 2010).
a - EPA identified a flow-unit error that affected all pollutants for outfalls 001, 002, and 003.
b - Pollutant TWPE is the sum of magnesium, manganese, and fluoride TWPE for outfalls 001 and 004.
15 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts continually accepts and updates corrections
submitted by facilities and states. The DMR Loadings Tool is not continuously updated; therefore, loads may be estimated with erroneous data.
8-8
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Section 8 - Landfills (40 CFR Part 445)
Table 8-11. Corrected TWPE for Top Pollutants in the Landfills Category in 2008 DMR
Database
Pollutant
2008 DMR TWPE
Corrected 2008 DMR TWPE
Vanadium
45,400
300
Iron
31,300
29,900
Manganese
15,700
4,240
Arsenic
15,100
2,060
Calcium
10,900
100 a
Landfills Category Total
191,000
97,000
a - The majority, approximately 99 percent, of the calcium discharges in the Landfills Category was from American
Electric Power Landfills, which EPA determined was incorrectly classified as the Landfills Category (Ohio EPA,
2010).
After the errors identified in Table 8-10 were corrected, EPA determined that vanadium,
manganese, arsenic, and calcium were no longer pollutants of concern. Therefore, EPA did not
include these pollutants in any further review of the Landfills Category. EPA identified that iron
is consistently reported as discharged and is a top pollutant that is not regulated by the Landfill
ELGs. EPA's review of iron is presented in the following subsection.
8.5 Landfills Category Iron Discharges in DMR
As part of the 2010 annual review of the Landfills Category, EPA reviewed iron
discharges in the 2008 DMR database. Iron is not regulated by the Landfill ELGs. The
Development Document for Final Effluent Limitations Guidelines and Standards for the
Landfills Point Source Category (January 2000) indicates that "EPA excluded pollutants that are
naturally occurring compounds in soil or ground water at landfill facilities or pollutants that are
used as treatment chemicals in this industry..." This included iron, along with other pollutants
(U.S. EPA, 2000).
EPA compared the iron concentrations from landfill discharges to treatable levels typical
of chemical precipitation and biological treatment. In order to compare the iron concentrations to
treatment level, EPA determined that there were 3,404 iron concentrations in 2008 DMR
Loadings Tool for facilities in the Landfills Category. EPA removed 0 mg/L concentrations and
concentrations reported below the detection limit (BDL) for all reporting periods, resulting in
1,286 iron concentrations for the analysis. Because facilities report multiple concentrations for
each monitoring period, EPA prioritized the selection of the average concentration and then the
maximum (ERG, 2010).
Then, EPA compared the iron concentrations to the EPA Method 200.7 method detection
limit (MDL) for iron to determine if the concentrations were at detectable levels. EPA excluded
the 58 iron concentrations (approximately 2 percent) that were below MDL. EPA calculated the
resulting median, average, and maximum of the remaining iron concentrations. EPA analyzed
the median concentration rather than the average or maximum because of suspected data entry
errors that would skew the average and maximum iron concentrations (ERG, 2010).
EPA then compared the median iron concentration to available chemical precipitation
and biological treatability data. EPA chose these specific wastewater treatment technologies
8-9
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Section 8 - Landfills (40 CFR Part 445)
because they were the technologies used to determine the best available technology (BAT) basis
used to develop limits for the RCRA Subtitle C Hazardous Waste Landfills. EPA used
treatability data for chemical precipitation and biological treatment already established during
previous annual reviews16 (U.S. EPA, 2009).
Table 8-12 presents the median iron concentration compared to the EPA Method 200.7
MDL and compared to treatability concentrations for chemical precipitation and biological
treatment. Table 8-12 shows that the median iron concentration in landfill discharges is below
the maximum concentrations achievable by chemical precipitation and biological treatment.
16 As part of the Steam Electric Power Generating Point Source Category Detailed Study, EPA collected treatability
data for chemical precipitation and biological treatment systems. Iron was included in the treatability data (U.S.
EPA, 2009).
8-10
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Section 8 - Landfills (40 CFR Part 445)
Table 8-12. Iron Concentrations in the 2008 DMR Database Compared to Treatability Concentrations
Chemical
Percent of
Percent of
Number of
Precipitation
Biological
Concentrations
Concentrations
Facilities
T rcatmcnt
Treatment
Median
above Chemical
above Biological
Reporting
EPA 200.7 MDL
Concentration
Concentration
Concentration
Precipitation
Treatment
Pollutant
Pollutant"
(mg/L)
Range (mg/L)
Range (mg/L)
(mg/L)
Range
Range
Iron
146
0.03
0.019-6
ND (0.0022) - 23
1.21
11%
2%
Source: DMR Loadings Tool; Method 200.7 Determination of Metals and Trace Elements in Water and Wastes by Inductively Couple Plasma-Atomic Emission
Spectrometry (U.S. EPA, 1994); and 2009 Steam Electric Power Generating Point Source Category: Final Detailed Study Report (U.S. EPA, 2009).
a - Number of facilities reporting iron concentrations after EPA excluded outfalls with all nondetect concentrations and concentrations reported as 0 mg/L.
MDL - Method detection limit.
ND -Nondetect. Detection limit indicated in ().
8-11
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Section 8 - Landfills (40 CFR Part 445)
The median iron concentration for all outfalls is less than the biological treatment or
chemical precipitation treatability concentrations. Approximately 89 percent of the iron
concentrations are below the chemical precipitation treatability (below 6 mg/L) and 98 percent
are below the biological treatment treatability (below 23 mg/L). The remaining iron
concentrations above the chemical precipitation treatment range are reported by a total of 24
facilities, seven of which are also above the biological treatment range.
EPA determined that approximately 80 percent of the facilities reporting iron
concentrations above treatable levels are located in Missouri and Kentucky. Because the majority
of the landfills are minor discharges and EPA has not previously reviewed their data, EPA
believes that there may be data quality issues (e.g., incorrect units) with the high iron
concentrations. Additionally, the majority of the facilities have iron concentrations below
treatable levels. Therefore, EPA does not believe that revising the Landfill ELGs to include iron
limits is appropriate.
8.6 Landfills Category Conclusions
The estimated toxicity of the Landfills Category discharges results mainly from the
discharges of metals. During the 2010 annual review, EPA identified many data entry errors in
the Landfill Category DMR data, because they are predominately minor discharges. Based on
corrected discharge data, further review at this time is unnecessary. Therefore, EPA concludes
the following:
• Database errors were identified for vanadium, manganese, arsenic, and iron.
Additionally, one facility, American Electric Power, was incorrectly categorized
in the Landfills Category when it should be included in the Steam Electric Power
Generating Category (40 CFR Part 423). Making these corrections decreases the
Landfills Category TWPE by over 49 percent, from 191,000 TWPE to 97,000
TWPE.
• Eighty-nine percent of iron concentrations in the 2008 DMR database are within
treatability concentration ranges. Twenty-one of the 24 facilities with iron
concentrations in the 2008 DMR database that exceed treatability concentrations
are located in Missouri and Kentucky. Iron is not regulated by the Landfill ELGs.
There are possible quality issues with the iron concentration data in the Landfills
Category. EPA will continue monitoring iron concentrations from landfills as part
of future annual reviews. Based on these data, EPA cannot conclude that an
effluent guideline revision is necessary at this time; however, EPA will collect
additional data for consideration during the 2011 annual review.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing effluent guidelines and
pretreatment standards).
8-12
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Section 8 - Landfills (40 CFR Part 445)
8.7 Landfills Category References
1. ERG. 2010 Eastern Research Group, Inc. Memorandum to William Swietlik, U.S. EPA
EPA, from Jessica Wolford and Elizabeth Sabol, Eastern Research Group, Inc. RE:
Methodology for Analyzing Landfill Iron Concentrations in the 2008 DMR Loadings
Tool. (October). EPA-HQ-OW-2008-0517 DCN 07277.
2. Gatlin, Jacquelin. 2010. E-mail communication between Jacquelin Gatlin, Missouri
Department of Natural Resources, and Eleanor Codding, Eastern Research Group, Inc.
"RE: OR 15133 DMRs for Springfield Sanitary Landfill." (June 24). EPA-HQ-OW-
2008-0517 DCN 07278.
3. Ohio EPA. 2009. Ohio Environmental Protection Agency. Authorization to Discharge
under National Pollutant Discharge Elimination System Permit OH0076627 - Columbus
Southern Power Company, Conesville, OH. Ohio EPA Location. (December). EPA-HQ-
OW-2008-0517 DCN 07279.
4. Palmer, Adria. 2010. E-mail communication between Adria Palmer, Missouri
Department of Natural Resources, and Eleanor Codding, Eastern Research Group, Inc.
"Confirming DMR Data for Advantage Metals Recycling Facility (MO0115801)." (June
28). EPA-HQ-OW-2008-0517 DCN 07280.
5. Tipton, Lantz. 2010. E-mail communication between Lantz Tipton, Missouri Department
of Natural Resources, and Elizabeth Sabol, Eastern Research Group, Inc. "DMRs
Clarification Needed for Onyx Maple Hill Landfill." (June 30). EPA-HQ-OW-2008-0517
DCN 07281.
6. U.S. EPA. 1994. Method 200.7 Determination of Metals and Trace Elements in Water
and Wastes by Inductively Couple Plasma-Atomic Emission Spectrometry Revision 4.4.
Washington, DC. (Unknown). Available online at:
http://www.epa.gov/waterscience/methods/method/files/200_7.pdf.
7. U. S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and
Standards for the Landfills Point Source Category. EPA-821-R-99-019. Washington,
DC. (January). Available online at:
http://www.epa.gov/waterscience/guide/landfills/final/index.html.
8. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final
Detailed Study Report. EPA-821-R-008. Washington, DC. (October). EPA-HQ-OW-
2008-0517-0413.
8-13
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
9. Mineral Mining and Processing (40 CFR Part 436)
EPA selected the Mineral Mining and Processing (Mineral Mining) Category for
preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source
category rankings). This industry was reviewed previously in EPA's Final 2004 Effluent
Guidelines Program Plans (U.S. EPA, 2004). This section summarizes the 2010 annual review
associated with the Mineral Mining Category. EPA focused on discharges of sulfide, fluoride,
and ammonia as nitrogen, because of their high TWPE relative to other pollutants in the Mineral
Mining Category.
9.1 Mineral Mining Category Background
This subsection provides the background on the Mineral Mining Category including a
brief industry profile of the mineral mining and processing industry and background on 40 CFR
Part 436.
9.1.1 Mineral Mining Industry Profile
The Mineral Mining Category includes facilities that mine and process non-metallic
minerals and discharge wastewater. EPA considered the following 28 North American Industry
Classification System (NAICS) codes as part of the Mineral Mining Category:
• 212311: Dimension Stone Mining and Quarrying;
• 212312: Crushed and Broken Limestone Mining and Quarrying;
• 212313: Crushed and Broken Granite Mining and Quarrying;
• 212319: Other Crushed and Broken Stone Mining and Quarrying;
• 212321: Construction Sand and Gravel Mining;
• 212322: Industrial Sand Mining;
• 212324: Kaolin and Ball Clay Mining;
• 212325: Clay and Ceramic and Refractory Minerals Mining;
• 212391: Potash, Soda, and Borate Mineral Mining;
• 2123 92: Phosphate Rock Mining;
• 212393: Other Chemical and Fertilizer Mineral Mining;
• 212399: All Other Nonmetallic Mineral Mining;
• 213115: Support Activities for Nonmetallic Minerals (except Fuels);
• 327111: Vitreous China Plumbing Fixture and China and Earthenware Bathroom
Accessories Manufacturing;
• 327112: Vitreous China, Fine Earthenware, and Other Pottery Product
Manufacturing;
• 327113: Porcelain Electrical Supply Manufacturing;
• 327121: Brick and Structural Clay Tile Manufacturing;
• 327122: Ceramic Wall and Floor Tile Manufacturing;
• 327123: Other Structural Clay Product Manufacturing;
• 327124: Clay Refractory Manufacturing;
• 327125: Nonclay Refractory Manufacturing;
• 327410: Lime Manufacturing;
• 327420: Gypsum Product Manufacturing;
• 327910: Abrasive Product Manufacturing;
9-1
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
• 327992: Ground or Treated Mineral and Earth Manufacturing;
• 327999: All Other Miscellaneous Nonmetallic Mineral Product Manufacturing;
• 339999MIN: All Other Miscellaneous Manufacturing; and
• 423320: Brick, Stone, and Related Construction Material Merchant Wholesalers.
Wastewater generated by facilities in NAICS codes 339999 can be regulated under
multiple categories. EPA reviewed available information about pollutant loads and
manufacturing operations for facilities reporting this NAICS codes. EPA assigned the extension
"MUST" to the end of the NAICS codes of facilities that likely primarily generate wastewater
regulated by the Mineral Mining Effluent Limitation Guidelines and Standards (ELGs). For
example, most facilities in NAICS code 339999 are grouped under the Metal Finishing ELGs.
Because the Permit Compliance System (PCS) and the Integrated Compliance
Information System - National Pollutant Discharge Elimination System (ICIS-NPDES), the
sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report
facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and
Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by
the equivalent NAICS code. Table 9-1 lists the number of facilities from the U.S. Economic
Census and the screening-level databases for the 21 NAICS codes with operations in the Mineral
Mining Category, the corresponding SIC codes are included for reference. The U.S. Economic
Census includes more facilities than the screening-level databases because of many possible
factors including: facilities may not meet TRI-reporting thresholds, facilities may discharge to a
publicly owned treatment works (POTW), and some facilities in the U.S. Economic Census are
distributors or sales facilities, not manufacturers.
Table 9-1. Number of Mineral Mining Facilities
NAICS Code
SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008
DMR"
2008
TRIb
212311: Dimension Stone Mining
and Quarrying
1411: Dimension Stone
179
48
212312: Crushed and Broken
Limestone Mining and Quarrying
1422: Crushed and Broken Limestone
1,523
881
3
212313: Crushed and Broken
Granite Mining and Quarrying
1423: Crushed and Broken Granite
322
91
4
9-2
-------
Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-1. Number of Mineral Mining Facilities
NAICS Code
SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008
DMRa
2008
TRI b
212319: Other Crashed and Broken
Stone Mining and Quarrying
1429: Crushed and Broken Stone, NEC,
1455: Kaolin and Ball Clay,
1459: Clay, Ceramic, and Refractory
Minerals, NEC,
1479: Chemical and Fertilizer Mineral
Mining, NEC,
1499: Miscellaneous Nonmetallic
Minerals, Except Fuels (except
bituminous limestone and bituminous
sandstone),
3295: Minerals and Earths, Ground or
Otherwise Treated (grinding, washing,
separating, etc. of kaolin and ball clay).
1,214
696
4
212324: Kaolin and Ball Clay
Mining
35
2
212325: Clay and Ceramic and
Refractory Minerals Mining
123
3
212393: Other Chemical and
Fertilizer Mineral Mining
47
1
212399: All Other Nonmetallic
Mineral Mining
246
21
327992: Ground or Treated Mineral
and Earth Manufacturing
292
43
212321: Construction Sand and
Gravel Mining
1442: Construction Sand and Gravel
2,612
1288
6
212322: Industrial Sand Mining
1446: Industrial Sand
141
56
212391: Potash, Soda, and Borate
Mineral Mining
1474: Potash, Soda, and Borate Minerals
24
1
212392: Phosphate Rock Mining
1475: Phosphate Rock
15
38
213115: Support Activities for
Nonmetallic Minerals (except Fuels)
1481: Nonmetallic Minerals Services,
Except Fuels (except geophysical
surveying and mapping and site
preparation and related construction
activities performed on a contract or fee
basis)
284
10
1
327111: Vitreous China Plumbing
Fixture and China and Earthenware
Bathroom Accessories
Manufacturing
3261: Vitreous China Plumbing Fixtures
and China and Earthenware Fittings and
Bathroom Accessories
50
15
5
327112: Vitreous China, Fine
Earthenware, and Other Pottery
Product Manufacturing
3262: Vitreous China Table and Kitchen
Articles,
3263: Fine Earthenware (Whiteware)
Table and Kitchen Articles,
3269: Pottery Products, NEC
760
18
8
327113: Porcelain Electrical Supply
Manufacturing
3264: Porcelain Electrical Supplies
138
13
5
327121: Brick and Structural Clay
Tile Manufacturing
3251: Brick and Structural Clay Tile
(except slumped brick)
200
43
96
327122: Ceramic Wall and Floor
Tile Manufacturing
3253: Ceramic Wall and Floor Tile
203
8
17
327123: Other Structural Clay
Product Manufacturing
3259: Structural Clay Products, NEC
50
7
5
327124: Clay Refractory
Manufacturing
3255: Clay Refractories
134
43
12
9-3
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-1. Number of Mineral Mining Facilities
Number of Facilities
NAICS Code
SIC Code
2002 U.S.
Economic
Census
2008
DMRa
2008
TRI b
327125: Nonclay Refractory
Manufacturing
3297: Nonclay Refractories
106
17
19
327410: Lime Manufacturing
3274: Lime
77
35
48
327420: Gypsum Product
Manufacturing
308
85
327910: Abrasive Product
Manufacturing
3275: Gypsum Products,
3291: Abrasive Products (steel wool
with or without soap),
3299: Nonmetallic Mineral Products,
NEC (moldings, ornamental and
architectural plaster work, and gypsum
statuary)
363
28
327999: All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
454
64
45
339999MIN: All Other
Miscellaneous Manufacturing
5,332
1
423320: Brick, Stone, and Related
Construction Material Merchant
Wholesalers
5032: Brick, Stone, and Related
Construction Materials (merchant
wholesalers except construction
materials sold via retail method)
3,592
49
2
Total
18,824
3,421
464
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3; and DMRLoads2008_v2.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC
crosswalk for comparison purposes,
b - Releases to any media.
NA - Not applicable.
Table 9-2 shows how permitting authorities designated direct discharging facilities in the
Mineral Mining Category as minor or major (see Section 4.1.5). EPA included data for minor
dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2. EPA does
not require permitting authorities to submit DMR data for minor dischargers; however, many
states do provide complete DMR data for them. From the 2010 annual review, EPA observed
many data entry or other errors for minor dischargers in addition to those previously identified
for major dischargers, as discussed in Section 4.3. Table 9-2 shows that approximately 99
percent of the Mineral Mining Category dischargers in the 2008 DMR database are minor
dischargers.
Table 9-2. Number of Mineral Mining Facilities
NAICS Codea
Number of Facilities in DMR 2008
Majors
Dischargers
Minor
Dischargers
All Dischargers
212311: Dimension Stone Mining and Quarrying
0
48
48
212312: Crushed and Broken Limestone Mining and
Quarrying
7
874
881
212313: Crushed and Broken Granite Mining and
Quarrying
0
91
91
9-4
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-2. Number of Mineral Mining Facilities
Number of Facilities in DMR 2008
NAICS Codea
Majors
Dischargers
Minor
Dischargers
All Dischargers
212319: Other Crushed and Broken Stone Mining and
Quarrying
212324: Kaolin and Ball Clay Mining
212325: Clay and Ceramic and Refractory Minerals
Mining
2123 93: Other Chemical and Fertilizer Mineral Mining
212399: All Other Nonmetallic Mineral Mining
327992: Ground or Treated Mineral and Earth
Manufacturing
6
690
696
212321: Construction Sand and Gravel Mining
3
1,285
1,288
212322: Industrial Sand Mining
0
56
56
212391: Potash, Soda, and Borate Mineral Mining
0
1
1
212392: Phosphate Rock Mining
15
23
38
213115: Support Activities for Nonmetallic Minerals
(except Fuels)
2
8
10
327111: Vitreous China Plumbing Fixture and China and
Earthenware Bathroom Accessories Manufacturing
0
15
15
327112: Vitreous China, Fine Earthenware, and Other
Pottery Product Manufacturing
0
18
18
327113: Porcelain Electrical Supply Manufacturing
0
13
13
327121: Brick and Structural Clay Tile Manufacturing
1
42
43
327122: Ceramic Wall and Floor Tile Manufacturing
0
8
8
327123: Other Structural Clay Product Manufacturing
0
7
7
327124: Clay Refractory Manufacturing
0
43
43
327125: Nonclay Refractory Manufacturing
1
16
17
327410: Lime Manufacturing
2
33
35
327420: Gypsum Product Manufacturing
327910: Abrasive Product Manufacturing
327999: All Other Miscellaneous Nonmetallic Mineral
Product Manufacturing
339999MIN: All Other Miscellaneous Manufacturing
0
64
64
423320: Brick, Stone, and Related Construction Material
Merchant Wholesalers
0
49
49
Total
37
3,384 b
3,421
Source: DMRLoads2008_v2.
a - DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison
purposes.
b - The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the
facilities in the Mineral Mining Category, 1,109 of the 3,384 minor dischargers have DMR data.
9-5
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of mineral mining facilities reporting to TRI do not report water discharges, but
those that do mostly reported discharging directly.
Table 9-3. Number of Mineral Mining Facilities by Type of Discharger in TRI 2008
NAICS Code
Number of Facilities in TRI 2008
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both
Indirect and
Direct
No Water
Discharges
212311: Dimension Stone Mining and Quarrying
0
0
0
0
212312: Crushed and Broken Limestone Mining and
Quarrying
1
0
0
2
212313: Crushed and Broken Granite Mining and
Quarrying
1
1
0
2
212319: Other Crushed and Broken Stone Mining and
Quarrying
1
0
0
3
212324: Kaolin and Ball Clay Mining
1
0
0
1
212325: Clay and Ceramic and Refractory Minerals
Mining
0
0
0
3
2123 93: Other Chemical and Fertilizer Mineral
Mining
0
0
0
1
212399: All Other Nonmetallic Mineral Mining
1
0
0
20
327992: Ground or Treated Mineral and Earth
Manufacturing
5
2
0
36
212321: Construction Sand and Gravel Mining
5
0
0
1
212322: Industrial Sand Mining
0
0
0
0
212391: Potash, Soda, and Borate Mineral Mining
0
0
0
0
212392: Phosphate Rock Mining
0
0
0
0
213115: Support Activities for Nonmetallic Minerals
(except Fuels)
0
0
0
1
327111: Vitreous China Plumbing Fixture and China
and Earthenware Bathroom Accessories
Manufacturing
3
0
0
2
327112: Vitreous China, Fine Earthenware, and Other
Pottery Product Manufacturing
1
1
1
5
327113: Porcelain Electrical Supply Manufacturing
0
1
0
4
327121: Brick and Structural Clay Tile Manufacturing
2
1
1
92
327122: Ceramic Wall and Floor Tile Manufacturing
1
4
0
12
327123: Other Structural Clay Product Manufacturing
1
1
0
3
327124: Clay Refractory Manufacturing
2
0
0
10
327125: Nonclay Refractory Manufacturing
1
6
1
11
327410: Lime Manufacturing
5
0
0
43
327420: Gypsum Product Manufacturing
31
0
0
54
327910: Abrasive Product Manufacturing
0
4
0
24
327999: All Other Miscellaneous Nonmetallic
Mineral Product Manufacturing
2
5
0
38
9-6
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-3. Number of Mineral Mining Facilities by Type of Discharger in TRI 2008
NAICS Code
Number of Facilities in TRI 2008
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both
Indirect and
Direct
No Water
Discharges
339999MIN: All Other Miscellaneous Manufacturing
0
0
0
1
423320: Brick, Stone, and Related Construction
Material Merchant Wholesalers
0
0
0
2
Total
64
26
3
371
Source: TRlReleases2008 v3.
9.1.2 40 CFR Part 436
There are 38 subcategories for the Mineral Mining ELGs. EPA first promulgated ELGs
for the Mineral Mining Category (40 CFR Part 436) on October 16, 1975 (40 FR 48657) for
selected subparts. EPA proposed regulations on June 10, 1976 for additional subparts, of which
only Subparts B, C, D, and R were promulgated on July 1979. National amendments were made
to the ELGs on December 28, 1979. 17 of the subparts in 40 CFR Part 436 are reserved. The
majority of the remaining subcategories have no discharge requirements or best practical control
technology (BPT) limitations. Table 9-4 lists the 38 subcategories and applicability.
Table 9-4. Applicability of Subcategories in the Mineral Mining Category
Subpart
Subcategory Title
Su bcatcgo ry Applicabi 1 itv
A
Dimension Stone
Reserved
B
Crushed Stone
Crushed and broken stone and riprap, including calcite in
conjunction with the processing of limestone or dolomite
C
Construction Sand and Gravel
Sand and gravel for construction or fill uses, excluding on-board
processing of dredged sand and gravel that is covered by 33 CFR
Part 230
D
Industrial Sand
Sand and gravel for uses other than construction fill including, but
not limited to, glassmaking, molding, abrasives, filtration,
refractories, and refractory bonding
E
Gypsum
Gypsum
F
Asphaltic Mineral
Bituminous limestone, oil-impregnated diatomite and olsonite not
primarily as an energy source
G
Asbestos and Wollastonite
Asbestos and wollastonite
H
Lightweight Aggregates
Reserved
I
Mica and Sericite
Reserved
J
Barite
Barite
K
Fluorspar
Fluorspar
L
Salines from Brine Lakes
Salines from brine lakes
M
Borax
Borate minerals, excluding borax obtained from brine lakes that is
covered by 40 CFR Part 436 Subpart L
N
Potash
Potash, excluding potash obtained from brine lakes that is covered
by 40 CFR Part 436 Subpart L
9-7
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-4. Applicability of Subcategories in the Mineral Mining Category
Subpart
Subcategory Title
S u bcatcgo rv A p p 1 icab ility
O
Sodium Sulfate
Sodium sulfate, excluding sodium sulfate obtained from brine lakes
that is covered by 40 CFR Part 436 Subpart L
P
Trona
Reserved
Q
Rock Salt
Reserved
R
Phosphate Rock
Phosphate bearing rock, ore or earth for the phosphate content
S
Frasch Sulfur
Sulfur on shore and in marshes and estuaries by the Frasch process,
excluding sulfur refining operations that are not performed at the
mining and collection site
T
Mineral Pigments
Reserved
U
Lithium
Reserved
V
Bentonite
Bentonite
W
Magnesite
Magnesite
X
Diatomite
Diatomite
Y
Jade
Jade
Z
Novaculite
Novaculite
AA
Fire Clay
Reserved
AB
Attapulgite and
Montmorillonite
Reserved
AC
Kyanite
Reserved
AD
Shale and Common Clay
Reserved
AE
Aplite
Reserved
AF
Tripoli
Tripoli
AG
Kaolin
Reserved
AH
Ball Clay
Reserved
AI
Feldspar
Reserved
AJ
Talc, Steatite, Soapstone and
Pyrophyllite
Reserved
AK
Garnet
Reserved
AL
Graphite
Graphite
Source: Mineral Mining and Processing Point Source Category - 40 CFR 436.
9.2 Mineral Mining Category 2010 Screening-Level Review
Table 9-5 compares the screening-level results for the Mineral Mining Category from the
2006 through 2010 annual reviews. The combined DMR and TRI TWPE decreased from
discharge years 2004 to 2007, but increased from discharge years 2007 to 2008. The discharge
year 2008 DMR TWPE accounts for approximately 97 percent of the combined 2008 DMR and
TRI TWPE.
9-8
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-5. Mineral Mining Category TRI and DMR Discharges for the 2010 and Previous
Screening-Level Reviews
Year of Discharge
Year of Review
Mineral Mining Category
TRI TWPE
DMRTWPE"
Total TWPE
2002
2006
2,840
50,500
53,340
2004
2007
5,390
49,300
54,700
2005
2008
6,260
NA
NA
2007
2009
2,420
26,700
29,100
2008
2010
3,390
100,000
103,000
Source: TRIReleases2002_v4\ PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRlReleases2005_v2;
TRIReleases2007_v2', DMRLoads2007jv4\ TRIReleases2008_v3; and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 9-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (69 percent) of the TWPE in the 2008 DMR database results from major
dischargers.
Table 9-6. Mineral Mining Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
30,800
69,300
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
9.3 Mineral Mining Category Pollutants of Concern
Table 9-7 compares the five pollutants with the highest TWPE based on the results from
the 2010, 2009, and 2007 annual reviews (7RfRe leases! 008 v3, TRIReleases2007_v2, and
TRIReleases2004 v3, respectively). Table 9-8 lists the five pollutants with the highest DMR
TWPE based on the results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2,
DMRLoads2007_v3, and PCSLoads2004 \>4, respectively).
9-9
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-7. Mineral Mining Category Top TRI Pollutants
Pollutant
2004 TRI Database"
2007 TRI Database"
2008 TRI Database"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Nitrate Compounds
3
6
1,050
1
5
1,300
1
6
2,080
Copper and Copper Compounds
Pollutants not reported in the top five
TRI 2004 reported pollutants.
Pollutants not reported in the top five
TRI 2007 reported pollutants.
2
4
435
Mercury and mercury Compounds
2
4
387
3
16
249
Manganese and Manganese
Compounds
5
11
265
4
8
239
4
10
151
Lead and Lead Compounds
1
51
1,270
3
23
371
5
53
144
Ammonia
Pollutants not reported in the top five
TRI 2004 reported pollutants.
5
3
60
Pollutants not reported in the top five
TRI 2008 reported pollutants.
Nickel and Nickel Compounds
2
7
1,060
Pollutants not reported in the top five
TRI 2007 reported pollutants.
Chromium and Chromium
Compounds
4
13
806
Mineral Mining Category Total
NA
101 b
6,260
NA
60 b
2,420
NA
92 b
3,390
Source: TRIReleases2004_v3; TRlReleases2007_v2; and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
9-10
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-8. Mineral Mining Category Top DMR Pollutants
Pollutant
2004 DMR Database '1
2007 DMR Database"
2008 DMR Database b
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Sulfide
Pollutant not reported in the top five DMR
2004 reported pollutants.
Pollutant not reported in the top five DMR
2007 reported pollutants.
1
5
35,900
Fluoride
1
14
41,800
1
14
18,700
2
20
28,200
Ammonia as Nitrogen
Pollutant not reported in the top five DMR
2004 reported pollutants.
Pollutant not reported in the top five DMR
2007 reported pollutants.
3
28
11,100
Chloride
4
3
1,510
5
6
572
4
27
6,690
Lead
3
2
1,560
3
1
2,760
5
12
5,940
Cadmium
2
1
1,940
2
2
3,060
Pollutant not reported in the top five DMR
2008 reported pollutants.
Zinc
5
3
482
4
1
710
Mineral Mining Category
Total
NA
23 c
49,300
NA
28 c
26,700
NA
120 c
100,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data only include major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
9-11
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
The Mineral Mining Category TWPE in the 2008 TRI database is significantly lower
than the 2008 DMR TWPE. Therefore, EPA focused the preliminary category review on the
DMR-reported pollutants that account for the majority of the category TWPE.
EPA's additional review for the 2008 DMR database pollutants of concern, sulfide,
fluoride, and ammonia as nitrogen, is presented in the following subsections. EPA did not
investigate the other top pollutants as part of the 2010 annual review because they account for a
small percentage (27 percent) of the 2008 Mineral Mining Category combined DMR and TRI
TWPE.
Of the pollutants of concern for the Mineral Mining Category, Part 436 only regulates
fluoride in Subpart D - Industrial Sand Subcategory. EPA's 2010 annual review of the Mineral
Mining Category determined that the majority of fluoride discharges are from facilities covered
by the Phosphate Rock Subcategory (Subpart R). The Phosphate Rock Subcategory does not
regulate fluoride.
9.4 Mineral Mining Category Sulfide Discharges in DMR
As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed sulfide
discharges in the 2008 DMR database. Approximately 36 percent of the 2008 DMR TWPE is
from sulfide discharges. Table 9-9 presents the sulfide discharges from mineral mining facilities
in the 2008 DMR database. US Silica Co. in Rockwood, MI, accounts for 87 percent of the
sulfide discharges in the DMR 2008 database for the Mineral Mining Category. This subsection
provides information on US Silica's sulfide discharges.
Table 9-9. Mineral Mining Category Top Sulfide Discharging Facility in DMR 2008
Facility Name
Pounds of Sulfide
Discharged
Sulfide TWPE
Percentage of
Mineral Mining
Category Sulfide
DMR 2008 TWPE
US Silica Co.
11,200
31,200
87%
Stoneco Inc.
1,150
3,210
9%
US Gypsum Co.
415
1,160
3%
Stoneco Inc. - Maybee
57
159
<1%
Stoneco Inc. - Denniston
40
113
<1%
Total
12,800
35,900
100%
Source: DMRLoads2008_v2.
US Silica discharges sulfide from outfall 002. Table 9-10 presents US Silica's 2008
monthly sulfide discharge data in the DMR Loadings Tool for outfall 002. The facility permit
states that outfall 002 is for sand and limestone mine dewatering water and process wastewater.
The facility permit requires the facility to report dissolved sulfide concentrations monthly
(MDEQ, 2005).
9-12
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
EPA reviewed DMR data from Envirofacts17 for 2008 - 2010. The 2008 sulfide and flow
data from the DMR Loadings Tool corresponds to the Envirofacts, and EPA identified no
corrections for data in the DMR Loadings Tool. EPA did find that US Silica only detected
sulfide during one month from January 2008 through March 2010. Table 9-11 presents US
Silica's available 2009 and 2010 sulfide discharge data from Envirofacts. Given that these
discharges occurred only once in almost three years, EPA finds that the sulfide discharges from
this facility do not represent a consistent discharge for all silica mineral mines. EPA also does
not believe the US Silica sulfide discharges warrant a revision to the Mineral Mining ELGs. For
an individual facility, permit writers can apply best professional judgment to determine the
appropriate control of discharges.
Table 9-10. US Silica Co. 2008 Monthly Sulfide and Flow Discharge Data
Outfall
Monitoring Period
Date
DMR Loadings Tool Maximum
Sulfide Concentration (mg/L)
DMR Loadings Tool Average
Flow (MGD)
002
31-Jan-08
2.20
13.06
002
31-Mar-08
0
13.69
002
30-Apr-08
0
13.38
002
31-Aug-08
0
13.05
002
30-Sep-08
0
12.81
002
31-Oct-08
0
12.61
002
30-Nov-08
0
12.23
002
31-Dec-08
0
11.98
Source: DMR Loadings Tool.
Table 9-11. US Silica Co. 2009 and 2010 Monthly Sulfide and Flow Discharge Data
Outfall
Monitoring Period
Date
Envirofacts Sulfide Concentration
(mg/L)
Envirofacts Flow (MGD)
002
30-Apr-09
0
11.45
002
30-Jun-09
0
11.3
002
31-Aug-09
0
11.68
002
30-Sept-09
0
11.1
002
31-Oct-09
0
11.8
002
30-Nov-09
0
11.4
002
31-Dec-09
0
12.3
002
31-Jan-10
0
11.7
002
28-Feb-10
0
11.9
002
31-Mar-10
0
11.9
Source: Envirofacts.
17 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts
continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not
continuously updated; therefore, loads may be estimated with erroneous data.
9-13
-------
Section 9 - Mineral Mining and Processing (40 CFR Part 436)
9.5 Mineral Mining Category Fluoride Discharges in DMR
As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed
fluoride discharges in the 2008 DMR database. Approximately 28 percent of the 2008 DMR
TWPE is from fluoride discharges. Table 9-12 presents the fluoride discharges from mineral
mining facilities in the 2008 DMR database.
The majority (74 percent) of fluoride discharges in 2008 were from four fluoride
discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper),
US Agri-Chemicals, and Feldspar Corp. These fluoride discharges result from mineral mining
processes that are regulated by Subparts R - Phosphate Rock and AI - Feldspar. Neither Subpart
R nor Subpart AI sets limits for fluoride (Subpart AI is reserved). This subsection provides
information on the fluoride discharges from the top four fluoride discharging facilities.
Table 9-12. Mineral Mining Category Top Fluoride Discharging Facilities in DMR 2008
Facility Name
Location
Pounds of
Fluoride
Discharged
Fluoride TWPE
Percentage of
Mineral Mining
Category
Fluoride DMR
2008 TWPE
PCS Phosphates White Springs
White Springs, FL
334,000
10,000
35.6%
PCS Phosphates White Springs
(Jasper)
Jasper, FL
173,000
5,200
18.4%
US Agri-Chemicals - Ft Meade
Fort Meade, FL
111,000
3,320
11.8%
Feldspar Corp Spruce Pine Fac
Spruce Pine, NC
72,300
2,170
7.7%
Mosaic Fertilizer, LLC - Ft Gr
White Springs, FL
50,500
1,510
5.4%
Mosaic Fertilizer LLC - Four
Polk County, FL
42,200
1,270
4.5%
Remaining Mineral Mining
Fluoride Dischargers a
NA
156,000
4,690
16.7%
Total
940,000
28,200
100%
Source: DMRLoads2008_v2.
a - There are 14 remaining mineral mining facilities that have fluoride discharges in DMRLoads2008jv2 that
account for 16.7 percent of the Mineral Mining Category's 2008 fluoride TWPE.
NA - Not applicable.
9.5.1 Wastewater Sources of Fluoride
The majority of the fluoride discharges for the Mineral Mining and Processing Category
are from phosphate mines in Florida and feldspar mines in North Carolina. EPA previously
compiled information on this category, discussed in the 1976 Development Document for
Interim Final Effluent Limitations Guidelines and Standards of Performance - Mineral Mining
and Processing Industry (Mineral Mining Development Document). For the 2010 Final Plan,
EPA compared current information to data from the Mineral Mining Development Document.
Phosphate mines are located in four major producing areas: Florida, North Carolina,
Tennessee, and western states. The phosphate rock is not a pure compound, but a fluorapitite
mineral containing impurities of fluoride, iron, aluminum, silica, and uranium. In Florida,
phosphate rock washing operations produce large quantities of slurry, very fine clay, and
9-14
-------
Section 9 - Mineral Mining and Processing (40 CFR Part 436)
phosphate minerals called slime. This slime is sent to settling ponds that cover large surface
areas. Wastewater is generated from stormwater runoff from the slime storage and disposal area
(U.S. EPA, 1976). Some of the Florida phosphate mines also appear to manufacture phosphatic
fertilizer on site, which also generates fluoride-containing wastewater. See the Section 8.5.2 of
the Technical Support Document for the 2006 Effluent Guidelines Program Plan (U.S. EPA,
2006) for potential wastewater sources from the phosphate fertilizer operations.
The feldspar mines in North Carolina use hydrofluoric acid flotation to separate the by-
products, which can include mica, quartz, and sand, from the feldspar (U.S. EPA, 1976). The
feldspar processing uses significant quantities of water with little recycle because of possible
build-up of soluble organics and fluoride ions. Facilities can also use sulfuric acid, sulfonic acid,
frothers, amines and oils as the flotation agent. The Mineral Mining Development Document
shows that treated effluent fluoride concentrations in 1976 ranged from 1.3 mg/L to 34 mg/L.
The hydrofluoric acid flotation generates fluoride-containing wastewater, which can be
minimized using a flotation circuit and/or partial recycle of the fluoride, as well as lime
treatment. The Mineral Mining Development Document studied the performance of single stage
chemical precipitation: lime addition with mixing followed by settling ponds. The 1976 data
showed that single-stage chemical precipitation could achieve effluent fluoride concentrations of
less than 10 mg/L through segregation and separate treatment of fluoride-containing streams
(U.S. EPA, 1976).
9.5.2 Top Facilities Discharging Fluoride
The majority (75 percent) of fluoride discharges in 2008 were from the top four fluoride
discharging facilities: PCS Phosphates White Springs, PCS Phosphates White Springs (Jasper),
US Agri-Chemicals, and Feldspar Corp. Fluoride is generated in the open-pit mining of
phosphate rock and the production of feldspar in the Phosphate Rock and Feldspar Subcategories
of the Mineral Mining Category, respectively. This subsection provides information on each
facility's fluoride discharges from the 2008 DMR Loadings Tool and their corresponding permit
limits, if available.
PCS Phosphates White Springs in White Springs, FL
PCS Phosphates White Springs generates wastewater from: open-pit mining of phosphate
rock, beneficiation of the rock, manufacture of sulfuric acid and phosphoric acid, production of
fertilizer components and animal-feed supplements, and stormwater runoff. The facility's
treatment system includes pH adjustment and chemical precipitation, when required, using lime;
settling and sedimentation; and adsorption/absorption on mining waste clay particles in clay
settling areas (FL DEP, 2003 a).
PCS Phosphates White Springs discharges fluoride from outfalls 001, 122, and 128.
Outfall 001 is a surface water monitoring location. Table 9-13 describes outfall descriptions,
fluoride limits, and the basis of the fluoride limits.
9-15
-------
Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-13. PCS Phosphates White Springs Outfall Descriptions and Fluoride Limits
Outfall
Outfall Description
Fluoride Limits
Daily
Maximum
(mg/L)
Monthly
Average
(mg/L)
Limit Basis"
001
Swift Creek surface water monitoring
location
10.0
Report
Only
FL DEP water quality criteria
for Class III predominately
fresh surface water
122
Treated process wastewater, CNPW,
stormwater, and treated sanitary wastewater
75.0
25.0
Fertilizer Manufacturing
ELGs
128
Treated process wastewater, CNPW,
stormwater, treated sanitary wastewater, and
discharges above mid-point of the surge
capacity from the calcium sulfate stormwater
pile runoff system
75.0
25.0
Fertilizer Manufacturing
ELGs
Source: Facility Permit (FL DEP, 2003a).
a - The facility's permit and fact sheet do not state the basis for the fluoride limit. However, the limits set
correspond to FL water quality criteria for Class III predominately fresh surface water. The permit limits may also
be based on permit writer best professional judgment.
Table 9-14 presents the monthly discharge data for the PCS Phosphates White Springs
facility for outfalls 001 and 122, which account for the majority of the fluoride discharges. As
shown in Table 9-14, the fluoride concentrations in the 2008 DMR data are below permit
limitations. Outfall 001 represents a surface water monitoring location; therefore, EPA will
exclude these discharges from future screening-level databases. This exclusion would reduce the
facility's fluoride discharges from 10,000 TWPE to 2,340 TWPE. Additionally, the fluoride
concentrations at outfall 001 are less than the Florida Department of Environmental Protection's
(FL DEP's) water quality standard, showing that PCS Phosphates White Springs' fluoride
discharges are not expected to impact the quality of the receiving stream.
Table 9-14. 2008 Monthly Fluoride Concentrations and Limits for PCS Phosphates White
Springs
Monitoring
Period Date
DMR Loadings Tool
Daily Maximum
Fluoride
Concentration (mg/L)
DMR Loadings Tool
Monthly Average
Fluoride
Concentration (mg/L)
Daily Maximum
Fluoride Permit Limit
(mg/L)
Monthly Average
Fluoride Permit Limit
(mg/L)
Outfall 001 - Surface Water Monitoring
31-Jan-08
2.62
2.34
10
Report
29-Feb-08
2.03
1.92
10
Report
31-Mar-08
1.83
1.73
10
Report
30-Apr-08
2.18
1.97
10
Report
31-May-08
2.26
2.19
10
Report
30-Jun-08
2.33
2.23
10
Report
31-Jul-08
2.55
2.39
10
Report
31-Aug-08
2.26
2.13
10
Report
30-Sep-08
2.59
2.44
10
Report
31-Oct-08
2.52
2.45
10
Report
9-16
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-14. 2008 Monthly Fluoride Concentrations and Limits for PCS Phosphates White
Springs
Monitoring
Period Date
DMR Loadings Tool
Daily Maximum
Fluoride
Concentration (mg/L)
DMR Loadings Tool
Monthly Average
Fluoride
Concentration (mg/L)
Daily Maximum
Fluoride Permit Limit
(mg/L)
Monthly Average
Fluoride Permit Limit
(mg/L)
30-Nov-08
2.7
2.60
10
Report
31-Dec-08
2.45
2.34
10
Report
Outfall 122 - Treated Process Wastewater, CNPW, Stormwater, and Treated Sanitary Wastewater
31-Jan-08
10.19
5.06
75
25
29-Feb-08
4.1
4.10
75
25
31-Mar-08
6.43
5.07
75
25
30-Apr-08
4.38
4.02
75
25
31-May-08
5.92
4.92
75
25
30-Jun-08
5.55
4.70
75
25
31-Jul-08
5.17
4.82
75
25
31-Aug-08
5.5
4.78
75
25
30-Sep-08
3.98
3.26
75
25
31-Oct-08
5.36
4.27
75
25
30-Nov-08
4.77
3.93
75
25
31-Dec-08
3.15
1.81
75
25
Source: DMR Loadings Tool and Facility Permit (FL DEP, 2003a).
PCS Phosphates White Springs (Jasper) in Jasper, FL
PCS Phosphates White Springs (Jasper) generates wastewater from: open-pit mining of
phosphate rock, beneficiation of the rock, and stormwater from the Suwannee River Chemical
Complex and Mine. The facility's treatment system includes pH adjustment and chemical
precipitation, when required, using lime; settling and sedimentation; and adsorption/absorption
on mining waste clay particles in clay settling areas (FL DEP, 2003b).
PCS Phosphates White Springs (Jasper) discharges most of its fluoride from outfall 001,
with minor discharges from outfalls 1A2, 1H8, and 202. Outfall 001 represents a surface water
monitoring location in Swift Creek, the receiving stream for outfalls 1A2, 1H8, and other
outfalls. Outfall 202 is process wastewater from the mining and beneficiation of phosphate rock,
CNPW, stormwater, mine dewatering, and treated sanitary wastewater.
Table 9-15 presents the monthly discharge data for the PCS Phosphates White Springs
(Jasper) facility for outfall 001 (in-stream monitoring location), compared to the fluoride permit
limits. As shown in Table 9-15, the fluoride concentrations in the 2008 DMR data are below
permit limitations. Outfall 001 represents a surface water monitoring location; therefore, EPA
will exclude these discharges from future screening-level databases. This exclusion would reduce
the facility's fluoride discharges from 5,200 TWPE to 720 TWPE. Additionally, the fluoride
concentrations at outfall 001 are less than the FL DEP's water quality standard, showing that
PCS Phosphates White Springs (Jasper)'s fluoride discharges are not expected to impact the
quality of the receiving stream.
9-17
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-15. Outfall 001 Monthly Fluoride Concentrations and Limits for PCS Phosphates
White Springs (Jasper)
Monitoring Period
Date
DMR Loadings Tool
Daily Maximum
Fluoride
Concentration
(mg/L)
DMR Loadings Tool
Monthly Average
Fluoride
Concentration
(mg/L)
Daily Maximum
Fluoride Permit
Limit (mg/L)11
Monthly Average
Fluoride Permit
Limit (mg/L)11
31-Jan-08
2.62
2.34
10
Report Only
29-Feb-08
2.03
1.92
10
Report Only
31-Mar-08
0.3
1.73
10
Report Only
30-Apr-08
2.18
1.97
10
Report Only
31-May-08
2.26
2.19
10
Report Only
30-Jun-08
2.33
2.23
10
Report Only
31-Jul-08
2.55
2.39
10
Report Only
31-Aug-08
2.26
2.13
10
Report Only
30-Sep-08
2.59
2.44
10
Report Only
31-Oct-08
2.52
2.45
10
Report Only
30-Nov-08
2.71
2.60
10
Report Only
31-Dec-08
2.45
2.34
10
Report Only
Source: 2008 DMR Loadings Tool and Facility Permit (FL DEP, 2003b).
a - EPA suspects these fluoride limits are based on FL DEP water quality criteria for Class III predominately fresh
surface water.
US Agri-Chemicals Corporation in Fort Meade, FL
US Agri-Chemicals Corporation manufactures sulfuric acid, phosphoric acid, mono-
ammonium phosphate, di-ammonium phosphate, and fluosilicic acid. US Agri-Chemicals also
has a lined phosphogypsum stack and an un-lined process water cooling pond with a
recirculation system. The facility is working with the state to close the un-lined pond. The
facility's 2004 NPDES permit also allows the facility to construct an additional lined
phosphogypsum stack. The facility treats wastewater from both ponds through a two-stage lime
treatment and spray aeration process prior to discharge (FL DEP, 2004).
Table 9-16 presents the monthly fluoride discharge data for US Agri-Chemicals for
outfall 004, compared to the fluoride permit limits. As shown in Table 9-16, the fluoride
concentrations in the 2008 DMR data are below permit limitations. Additionally, based on the
permit and fact sheet, EPA believes that the facility's operations fall within the applicability of
the Fertilizer Manufacturing ELGs (40 CFR Part 418) and/or Phosphate Manufacturing ELGs
(40 CFR Part 422) rather than the Mineral Mining ELGs (40 CFR Part 436) because the facility
does not have any mining operations. Therefore, discharges from this facility should be excluded
from the 2010 annual review of the Mineral Mining Category, reducing the category's TWPE by
3,530 TWPE. As part of future annual reviews, EPA will continue its review of this facility's
discharges and reassign this facility to the correct category.
9-18
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-16. 2008 Monthly Fluoride Discharge Data and Limits for US Agri-Chemicals
Corporation
Outfall
Monitoring Period
Date
Maximum Fluoride
Concentration from
DMR Data (mg/L)
Daily Maximum
Fluoride Permit
Limit (mg/L)
Monthly Average
Fluoride Permit
Limit (mg/L)
004
31-Jan-08
7.15
10
Report
004
29-Feb-08
5.50
10
Report
004
31-Mar-08
3.07
10
Report
004
30-Apr-08
3.23
10
Report
004
31-May-08
2.96
10
Report
004
30-Jun-08
3.60
10
Report
004
31-Jul-08
4.44
10
Report
004
31-Aug-08
4.01
10
Report
004
30-Sep-08
4.50
10
Report
004
31-Oct-08
5.53
10
Report
004
30-Nov-08
5.10
10
Report
004
31-Dec-08
3.86
10
Report
Source: DMR Loadings Tool and Facility Permit (FL DEP, 2004).
Feldspar Corporation in Spruce Pine, NC
The Feldspar Corporation is an industrial minerals processing facility. The facility
produces feldspar, quartz, and mica. Outfall 001 discharges treated process wastewater to the
North Toe River. The facility's treatment system includes clarifiers, polymer feed system, lime
for pH adjustment, vacuum filters, and an Emico clarifier/thickener to outfall 001 (NC DWQ,
2006).
The facility discharges fluoride from outfall 001. Table 9-17 presents the monthly
fluoride discharge data for Feldspar. The fluoride permit limits for the facility were 225 lb/day
monthly average and 448 lb/day daily maximum when the facility was treating discharges from
Unimum Corporation's Crystal Operation. However, once Unimum began directly discharging,
Feldspar's fluoride limits were revised to 174 lb/day monthly average and 348 lb/day daily
maximum (NC DWQ, 2006). It is unclear which limits applied in 2008. As shown in Table 9-17,
the facility did not meet fluoride permit limits for at least part of 2008. The monthly average
fluoride quantities discharged are above the original permit limit for January and February 2008
and above the revised permit limit for all of 2008. The daily maximum fluoride quantities are
similarly above the original and revised daily maximum fluoride limits for 2008. This facility
appears to be exceeding its mass-based permit fluoride limit.
9-19
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-17. Outfall 001 Monthly Fluoride Discharge Data and Limits for Feldspar
Corporation
Monitoring
Period Date
DMR Loadings Tool Daily Maximum
Fluoride Quantity (lb/day)
DMR Loadings Tool Monthly Average
Fluoride Quantity (Ib/dav)
31-Jan-08
539
221.6
29-Feb-08
623.9
237.9
31-Mar-08
443.7
222.1
30-Apr-08
433.5
211.2
31-May-08
366.9
167.2
30-Jun-08
426.4
217.0
31-Jul-08
376.6
181.4
31-Aug-08
430.4
216.5
30-Sep-08
407.2
186.2
31-Oct-08
445.9
220.1
30-Nov-08
381.5
158.3
31-Dec-08
385.3
139.7
Source: DMR Loadings Tool.
9.5.3 Fluoride Wastewater Treatment
EPA determined that the top fluoride discharging facilities have two-stage chemical
precipitation with lime treatment systems. This process is similar to that at phosphatic fertilizer
manufacturing facilities, which achieve fluoride concentrations of 15 mg/L or less (U.S. EPA,
1974). Current technologies are achieving fluoride concentrations at least as effective, sometimes
achieving 2 mg/L effluent fluoride. The chemical precipitation has improved by using calcium
chloride (CaCh) rather than lime, while solids separation has improved by using polymers and
membrane filters (WC&E, 2006; Ionics, Unknown; GCIP, 2002).
9.6 Mineral Mining Category Ammonia as Nitrogen Discharges in DMR
As part of the 2010 annual review of the Mineral Mining Category, EPA reviewed
ammonia as nitrogen (ammonia as N) discharges in the 2008 DMR database. Approximately 11
percent of the 2008 DMR TWPE is from discharges of ammonia as N. Table 9-18 presents the
ammonia as N discharges from mineral mining facilities in the 2008 DMR database. Glen-Gery
Corporation in Tully Township, OH, accounts for 99 percent of the ammonia as N discharges in
the DMR 2008 database for the Mineral Mining Category. This subsection provides information
on Glen-Gery's ammonia as N discharges.
9-20
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Table 9-18. Mineral Mining Category Top Ammonia as Nitrogen Discharging Facilities in
DMR 2008
Facility Name
Location
Pounds of
Ammonia as N
Discharged
Ammonia as N
TWPE
Percentage of
Mineral Mining
Category
Ammonia as N
DMR 2008
TWPE
Glen-Gery Corporation
Tully Township, OH
9,900,000
11,000
99
Remaining Mineral Mining
Ammonia as N Dischargersa
NA
24,400
27.2
1.3%
Total
10,030,000
11,100
100%
Source: DMRLoads2008_v2.
a - There are 35 remaining mineral mining facilities that have ammonia as N discharges in DMRLoads2008_v2 that
account for approximately 1.3 percent of the Mineral Mining Category's 2008 ammonia as N TWPE.
NA - Not applicable.
Glen-Gery discharges ammonia as N through outfall 002. Table 9-19 presents Glen-
Gery's 2008 quarterly ammonia as N and flow discharge data in the DMR Loadings Tool for
outfall 002. EPA compared the concentration and flow data from the DMR Loadings Tool to the
data in Envirofacts and determined that there is a unit of measurement error for the outfall 002
flows. The flows in the DMR Loadings Tool were 1,000,000 times higher than the data in
Envirofacts, also presented in Table 9-19. Using the outfall 002 flows from Envirofacts, Glen-
Gery's ammonia as N discharges are 6.31 pounds and 0.004 TWPE for 2008, reducing the
facility's total TWPE by 99 percent. This reduction in TWPE decreases the Mineral Mining
Category's 2008 DMR TWPE by 11,000 TWPE, and ammonia as N would no longer be a top
pollutant of concern.
Table 9-19. Glen-Gery Corporation's 2008 Quarterly Ammonia as N and Flow Discharge
Data
Outfall
Monitoring Period
Date
DMR Loadings Tool
Maximum Sulfide
Concentration (mg/L)
DMR Loadings Tool
Average Flow (MGD)
Envirofacts Flow
(MGD)
002
31-Mar-08
6.88
500
0.005
002
30-Jun-08
0.03
500
0.005
002
31-Aug-08
0.19
500
0.005
002
31-Dec-08
18.6
500
0.005
Source: DMR Loadings Tool and Envirofacts.
9.7 Mineral Mining Category Conclusions
Based on available data, the estimated toxicity of the Mineral Mining Category
discharges in the screening-level databases result from sulfide, fluoride, and ammonia as N
discharges. Data collected for the 2010 annual review demonstrated that wastewater discharge
characteristics for this category are consistent with discharges from prior years. As in prior years,
EPA makes the following conclusions:
9-21
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
• The 2008 sulfide discharge from U.S. Silica was restricted to a single month, and
the facility has not reported any sulfide discharges since January 1, 2008. EPA
does not consider this pollutant a concern at this time, but will review the
discharges for sulfide as part of future annual reviews.
• The fluoride discharges in the Mineral Mining Category are from phosphate and
feldspar mining facilities regulated by Subpart R - Phosphate Rock and Subpart
AI - Feldspar (reserved), respectively. These facilities are also located in areas
with naturally occurring fluoride compounds in the ore, Florida and North
Carolina.
• The fluoride discharges from phosphate mines were misrepresented in the
screening level databases:
— The majority of the fluoride discharges from PCS Phosphates White
Springs and PCS Phosphates White Springs (Jasper) represented surface
water monitoring stations, not process wastewater outfalls. Excluding the
fluoride discharges from these outfalls reduces the Mineral Mining
Category's fluoride TWPE by 8,010 TWPE. In addition, fluoride
concentrations measured at these surface water outfalls were below the FL
DEP water quality criteria for Class III predominately fresh surface water.
— The US Agri-Chemicals' operations do not meet the applicability of the
Mineral Mining Category. The facility's operations meet the applicability
of the Fertilizer Manufacturing and/or Phosphate Manufacturing
Categories. EPA will review the facility's discharges in future annual
reviews and will reassign this facility to the correct category.
As a result, EPA will collect additional data on fluoride discharges from mineral
mining facilities for consideration during the 2011 annual review.
• Feldspar Corporation appears to be exceeding its mass based fluoride permit
limits. Subpart AI - Feldspar of the Mineral Mining Category does not currently
regulate fluoride discharges. Permit limit exceedances do not warrant the need for
further regulation but rather better facility compliance. EPA will continue to
monitor fluoride discharges from Feldspar Corporation.
• Database errors were identified for discharges of ammonia as N. After correcting
these errors, the Mineral Mining Category TWPE from ammonia as N decreased
by 99 percent, from 11,100 TWPE to 100 TWPE and does not represent a hazard
priority.
Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2009 annual review of existing effluent guidelines and
pretreatment standards).
9-22
-------
9
1
2
3
4.
5
6
7
8
9
1'
1
Section 9 - Mineral Mining and Processing (40 CFR Part 436)
Mineral Mining Category References
FL DEP. 2003a. Florida Department of Environmental Protection. National Pollution
Discharge System Permit NPDES - FL0036226 - PCS Phosphates White Springs. White
Springs, FL. (May 27). EPA-HQ-OW-2004-0032-1169.
FL DEP. 2003b. Florida Department of Environmental Protection. National Pollution
Discharge System Permit NPDES - FL0000665 - PCS Phosphates White Springs
(Jasper). Jasper, FL. (May 27). EPA-HQ-OW-2008-0517 DCN 07283.
FL DEP. 2004. Florida Department of Environmental Protection. National Pollution
Discharge System Permit NPDES - FL0001902 - U.S. Agri-Chemicals Corporation. Fort
Meade, FL. (January 26). EPA-HQ-OW-2008-0517 DCN 07285.
GCIP. 2002. General Chemical Industrial Products. Chapter 14 - Wastewater and Water
Treatment. Available online at: http://www.genchem.com/calcium/NChl4.html. Date
accessed: July 27, 2006. EPA-HQ-OW-2004-0032-2606.
MDEQ. 2005. Michigan Depart of Environmental Quality. National Pollution Discharge
Elimination System Permit NPDES - MI0001368 - U.S. Silica. Rockwood, MI. (October
1). EPA-HQ-OW-2008-0517 DCN 07287.
Ionics. Unknown. "The EnChem® Process for Fluoride Removal." Wastewater
Treatment for the Microelectronics Industry. Available online at:
http://www.iconics.com/pdf/TS4752EUS.pdf. Date accessed: July 27, 2006. EPA-HQ-
OW-2004-0032-2605.
NC DWQ. 2006. North Carolina Division of Water Quality. National Pollution Discharge
Elimination System Permit NPDES - NC0000353 - Feldspar Corporation. Spruce Pine,
NC. (August 31). EPA-HQ-OW-2008-0517 DCN 07289.
U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
U. S. EPA. 1974. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Basic Fertilizer Chemicals Segment of the
Fertilizer Manufacturing Point Source Category. EPA-440/l-75/042-a. Washington, DC.
(March).
U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations
Guidelines and Standards of Performance for the Mineral Mining and Processing
Industry. EPA-440-l-76-059-a. Washington, DC. (June).
U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346
through 1352.
9-23
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Section 9 - Mineral Mining and Processing (40 CFR Part 436)
12. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
13. WC&E. 2006. Wastech Controls & Engineering, Inc. Fluoride Wastewater Treatment
(FWT) (HF Neutralization or Fluoride Reduction. Available online at:
http://www.wastechengineering.com/papers/hf.htm. Date accessed: July 27. EPA-HQ-
OW-2004-0032-2604.
9-24
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
10. Oil & Gas Extraction (40 CFR Part 435)
EPA selected the Oil and Gas Extraction (Oil and Gas) Category for preliminary review
because it ranks high, in terms of TWPE, in point source category rankings (see Table 5-3 for the
point source category rankings). This section summarizes the results of the 2010 annual review
associated with the Oil and Gas Category. EPA focused on discharges of sulfide from one oil
extraction facility, because of its high toxic-weighted pound equivalent (TWPE) relative to the
other facilities in the Oil and Gas Category. EPA also reviewed stakeholder comments regarding
hydraulic fracturing to retrieve shale gas (see Table 2-1). The Final 2006 Plan summarizes the
results of EPA's previous review of this industry, specifically the coalbed methane (CBM)
sector, in 2004 and 2005 (71 FR 76644). See Section 16.2 of this document for information on
EPA's detailed study of the CBM sector.
10.1 Oil and Gas Category Background
This subsection provides the background on the Oil and Gas Category including a brief
profile of the oil and gas industry and background on 40 CFR Part 435.
10.1.1 Oil and Gas Industry Profile
The oil and gas industry includes facilities that explore, drill, and produce oil or gas,
along with the support operations. The exploration process consists of mapping, aerial
photography, special surveys to find underground conditions favorable to oil or gas deposits, and
exploratory drilling. The drilling process includes drilling to reach oil or gas reservoirs or to gain
knowledge of geologic formations. The production includes separating the fluid fractions (e.g.,
gas from liquid, oil from water), treating the wastes, and further processing to improve the
separations (U.S. EPA, 1976). EPA considered the following two North American Industry
Classification System (NAICS) codes as part of the Oil and Gas Category.
• 211111: Crude Petroleum and Natural Gas Extraction; and
• 213112: Support Activities for Oil Gas Operations.
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the
sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report
facilities by Standard Industrial Classification (SIC) code, and the U.S. Economic Census and
Toxics Release Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR
data by the equivalent NAICS code. Table 10-1 lists the number of facilities from the U.S.
Census and the screening-level databases for the two NAICS codes with operations in the Oil
and Gas Category, including the corresponding SIC codes for reference. Because the only
facility listed in the 2008 TRI database for the Oil and Gas Category does not report water
discharges, the remaining sections for this category review will focus on the data in the 2008
DMR database. The U.S. Economic Census includes more facilities than the screening-level
databases because of many possible factors including: facilities may not meet TRI-reporting
thresholds, facilities may discharge to a publicly owned treatment works (POTW), and some
facilities in the U.S. Economic Census are distributors or sales facilities, not manufacturers.
10-1
-------
Section 10 - Oil & Gas Extraction (40 CFR Part 435)
Table 10-1. Number of Oil and Gas Facilities
NAICS Code
Corresponding SIC
Code
Number of Facilities
2002 U.S.
Economic Census
2008 DMR
Database"
2008 TRI
Database b
211111 Crude Petroleum
and Natural Gas Extraction
1311: Crude Petroleum
and Natural Gas
7,227
2,899
0
213112 Support Activities
for Oil and Gas Operations
1381: Drilling Oil and
Gas Wells;
1382: Oil and Gas Field
Exploration;
1389: Oil and Field
Services, NEC;
4925: Mixed,
Manufactured, or
Liquid Gas Production
6,367
407
lc
Total
>13,594
3,306
1
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008jv2; and TRlReleases2008_v3.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-
code crosswalk for comparison purposes,
b - Releases to any media.
c - Note this facility did not report water discharges in 2008.
Table 6-2 shows whether permitting authorities designated direct discharges as minor or
major (see Section 4.1.5) for facilities in the Oil and Gas Category. EPA included data for minor
discharges for the first time in the 2010 annual review, as part of DMRLoads2008 v2 database.
EPA does not require permitting authorities to submit DMR data for minor discharges; however,
many states do provide complete DMR data for them. From this year's review, EPA observed
many data entry or other errors for minor discharges in addition to those previously identified for
major discharges, as discussed in Section 4.3. Table 10-2 shows that more than 99 percent of the
Oil and Gas Category dischargers in the 2008 DMR database are minor dischargers. Table 10-3
shows the number of facilities with and without discharge data in the 2004, 2007, and 2008
DMR databases.
Table 10-2. Number of Oil and Gas Facilities by Discharge Type in DMR 2008
NAICS Code"
Number of Facilities in 2008 DMR Database
Major Dischargers
Major Dischargers
Major Dischargers
211111 Crude Petroleum and Natural Gas
Extraction
8
2,891
2,899
213112 Support Activities for Oil and Gas
Operations
1
406
407
Total
9
3,297
3,306
Source: DMRLoads2008_v2.
a - DMR data is reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.
10-2
-------
Section 10 - Oil & Gas Extraction (40 CFR Part 435)
Table 10-3. Number of Oil and Gas Facilities in DMR Databases for Reporting Years
2004, 2007, and 2008 a
Discharge Status
2004
2007
2008
With Water Discharge Data b
3
5
135
Without Water Discharge
Data0
291
1,569
3,171
Total
294
1,574
3,306
Source: PCSLoads2004_v3; DMRLoads2007_v4\ and DMRLoads2008jv2.
a - Major and minor dischargers.
b - Includes facilities with DMR data in the DMR databases,
c - Includes facilities with NPDES permits without DMR data in the DMR databases.
10.1.2 40 CFR Part 435
EPA first promulgated effluent limitation guidelines and standards (ELGs) for the Oil and
Gas Category (40 CFR Part 435) on April 13, 1979 (40 FR 22069). Best available technology
(BAT) , best current technology (BCT), and new source performance standards (NSPS)
limitations were promulgated on March 4, 1993 (58 FR 12454) for Subpart A: Offshore
Subcategory and on December 16, 1996 (61 FR 66086) for Subpart D: Coastal Subcategory.
Table 10-4 lists the existing subcategories for the Oil and Gas Category and describes their
applicability. Subpart B is reserved.
Table 10-4. Subcategories in the Oil and Gas Category
Subpart
Title
Description
A
Offshore
Applicable to facilities engaged in field exploration, drilling, well production, and well
treatment that are located in waters that are offshore. Offshore is defined as seaward of
the inner boundary of the territorial seas.
C
Onshore
Applicable to facilities engaged in field exploration, drilling, well completion, and well
treatment that are located onshore. Onshore is defined as landward of the inner
boundary of the territorial seas.
D
Coastal
Applicable to facilities engaged in field exploration, drilling, well production, and well
treatment that are located in coastal waters. Coastal is defined as landward of the inner
boundary of the territorial seas or landward of the inner boundary of the territorial seas
and bounded on the inland side by the line defined by the inner boundary of the
territorial seas.
E
Agricultural
and Wildlife
Water Use
Applicable to onshore facilities engaged in field exploration, drilling, well completion,
and well treatment that are located in the United States west of the 98th meridian for
which the produced water has a use in agriculture or wildlife propagation when
discharged to navigable waters.
F
Strippera
Applicable to onshore facilities engaged in production and well treatment that produce
10 barrels per well per calendar day or less of crude oil and are operating at the
maximum feasible rate of production.
G
General
Provisionsa
Prevents oil and gas facilities applicable to 40 CFR Part 435 Subparts A through F from
circumventing the ELGs by moving effluent discharges from one subcategory to
another for disposal under less stringent requirements.
Source: Development Document for Interim Final Effluent Limitations Guidelines and Proposed New Source
Performance Standards for the Oil and Gas Extraction Point Source Category (U.S. EPA, 1976).
a - No pollutants are regulated in Subparts F or G.
10-3
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
10.2 Oil and Gas Category 2010 Screening-Level Review
Table 10-5 compares the screening-level database results for the Oil and Gas Category
from the 2006 through 2010 annual reviews. The combined DMR and TRI TWPE increased
from discharge years 2007 to 2008. The estimated 2008 DMR TWPE dominates the estimated
2008 category TWPE because no facilities reported water discharges to TRI in 2008, similar to
2007.
Table 10-5. Oil and Gas Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews
Year of Discharge
Year of Review
Oil and Gas Category
TRI TWPE
DMR TWPE 11
Total TWPE
2002
2006
700
1.18
701
2004
2007
596
17.8
614
2005
2008
802
NA
NA
2007
2009
NR
255
255
2008
2010
NR
189,000
189,000
Source: TRIReleases2002_v4; PCSLoads2002_v4\ TRlReleases2004_v3; PCSLoads2004_v3', TRlReleases2005_v2;
TRlReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 include only major dischargers. DMR 2008 data include both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
NR - Not Reported. No facilities reported water discharges to TRI for reporting years 2007 and 2008.
Table 10-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (over 99 percent) of the TWPE in the 2008 DMR database results from
minor dischargers.
Table 10-6. Oil and Gas Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
189,000
36.1
Source: DMRLoads2008jv2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
10.3 Oil and Gas Pollutants of Concern
Table 10-7 lists the five pollutants with the highest TWPE in DMR data from reporting
years 2008, 2007, and 2004 (DMRLoads2008_v2, DMRLoads2007 v3, and PCSLoads2004 v4).
EPA is not presenting the top pollutants for the TRI databases because no facilities reported
water discharges to TRI in 2007 or 2008.
10-4
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
Table 10-7. Oil and Gas Category Top DMR Pollutants
Pollutant
2004 DMR Database"
2007 DMR Database"
2008 DMR Database b
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Sulfide
Pollutants not reported in the top five 2004
DMR reported pollutants.
Pollutants not reported in the top five
2007 DMR reported pollutants.
1
3
170,000
Aluminum
2
2
7,550
Chloride
3
12
7,340
Fluoride
4
2
2,250
Cyanide
5
2
871
Arsenic
1
1
86.2
Pollutants not reported in the top five
2008 DMR reported pollutants.
Lead
4
1
0.073
2
4
60.8
Copper
5
1
0.069
3
3
49.0
Silver
Pollutant not reported in the top five 2004
DMR reported pollutants.
4
1
31.7
Chlorine
1
1
11.2
5
1
24.6
Zinc
2
1
4.91
Pollutants not reported in the top five
2007 DMR reported pollutants.
Sulfide
3
1
1.61
Oil and Gas Category
Total
NA
2 c
17.8
NA
5 c
256
NA
52 c
189,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data include only major dischargers,
b - 2008 DMR data include major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
10-5
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
Sulfide is the top DMR-reported pollutant in 2008, contributing approximately 90 percent
of the total category TWPE for 2008. EPA's additional review for sulfide is presented in the
following subsection. EPA did not investigate the other top pollutants as part of the 2010 annual
review because the remaining TWPE is such a small percentage (10 percent) of the 2008 Oil and
Gas Category combined DMR and TRI TWPE.
10.4 Oil and Gas Category Sulfide Discharges in DMR
The 2010 annual review of the Oil and Gas Category focused on sulfide discharges in the
2008 DMR database. Table 10-8 presents the three facilities that report sulfide discharges in the
2008 DMR database. The majority (99 percent) of the sulfide discharges in 2008 were from
Marathon Oil Maverick Springs in Fremont County, WY. EPA did not review discharges from
the other two facilities because they account for only 1 percent of the remaining 2008 Oil and
Gas Category's sulfide TWPE.
Sulfide may be generated during the stripping process to remove hydrogen sulfide (H2S),
which can be naturally occurring in small amounts in crude petroleum. These trace amounts can
make the petroleum extremely toxic and corrosive, which is referred to as "sour crude". The sour
crude must be "sweetened" to protect personnel, mitigate corrosion, and meet sale specifications
(Manning and Thompson, 1995).
Removing the H2S is usually achieved by stripping with cold or hot natural gas. Because
the H2S is volatile, the compound accompanies the vapor in a gas-oil separation. Due to the
extremely toxic characteristics of H2S, the resulting overhead gas cannot be vented. Therefore,
water is usually used to strip the gas of H2S. This process will produce sour water. In water, H2S
can form a weak acid made of two ions HS and S2" (Manning and Thompson, 1995). This
stripping process could result in the discharge of sulfide from this facility.
Table 10-8. Oil and Gas Category Top Sulfide Discharging Facilities in the 2008 DMR
Database
Facility Name
Facility Location
2008
Pounds of Sulfide
Discharged
Sulfide
TWPE
Percentage of Oil and
Gas Category Sulfide
2008 DMR TWPE
Marathon Oil Maverick
Springs
Fremont County,
WY
60,600
169,800
99%
Soap Creek Oil Field
St. Xavier, MT
107
300
< 1%
Petro Gas Liquids Processing
Corpus Chrisi, TX
5.79
16
< 1%
Total
60,700
170,000
100%
Source: DMRLoads2008 v2.
Marathon Oil Maverick Springs
The Marathon Oil Maverick Springs facility, located in Fremont County, WY, is a crude-
oil refiner. The facility is within the exterior boundaries of the Wind River Indian Reservation.
The facility fact sheet indicates that the limits were developed based on Subparts C and E of the
Oil and Gas Category (WDEQ, 2007b). Table 10-9 presents the sulfide concentration data for
Marathon Oil Maverick Springs.
10-6
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
Table 10-9. Marathon Oil Maverick Springs 2008 Sulfide Discharge Data
Outfall
Monitoring Period
Date
NODI Code3
Maximum
Concentration (mjj/L)
Flow (MGD)
001
30-June-07
C
NR
001
31-Dec-07
9.76
1.645
001
30-June-08
C
1.633
001
31-Dec-08
24
1.645
001
30-June-09
25
1.598
001
31-Dec-09
8
1.576
Note: The 2007 and 2009 discharge data are from EPA's Envirofacts.
NR - Flow not reported
a - No discharge occurred for the monitoring period
ERG contacted Marathon Oil Maverick Springs to verify the sulfide discharges for 2008.
Marathon Oil Maverick Springs confirmed the 2008 sulfide concentrations and flows for outfall
001, a stormwater discharge from the facility. Marathon Oil Maverick Springs also confirmed
that the permit does not specify a limit for sulfide (Taylor, 2010).
According to the 2007 Statement of Basis, the Marathon Oil Maverick Springs' permit
authorizes the discharge of treated wastewater at the oil production facility. Produced oil, water,
and gas are separated in tanks by gravity, heat, and emulsion breaking chemicals. Water is
discharged through settling ponds where the remaining oil is removed by floatation and
skimming prior to discharge to a tributary to Five Mile Creek. The discharge provides wildlife
and stock watering opportunities. In addition, aquatic communities have developed in this
ephemeral drainage, which are dependent upon the flow of this produced water (WDEQ, 2007a).
The effluent guidelines and the facility permit do not list sulfide as a regulated pollutant.
However, the permit includes effluent monitoring requirements for sulfide. Sulfide is required to
be monitored semi-annually.
10.5 Oil and Gas Category Conclusions
The estimated toxicity of the Oil and Gas Category discharges results mainly from the
sulfide discharges of one oil extraction plant (accounting for 99 percent of the category's 2008
TWPE). EPA does not believe that Marathon Oil's sulfide discharges are representative of the
Oil and Category. Without Marathon Oil's sulfide discharges, the Oil and Gas TWPE is not a
concern. Therefore, EPA concludes the following:
• The sulfide discharges in the 2008 DMR database for Marathon Oil Maverick
Springs were verified and do not appear to be erroneous. This facility's sulfide
discharges are not consistent with sulfide discharges from other facilities in the
category. As a result, Marathon Oil's sulfide discharges are best controlled by its
individual permit.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(2)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing ELGs).
10-7
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Section 10 - Oil & Gas Extraction (40 CFR Part 435)
10.6 Oil and Gas Category References
1. Manning, Francis and Thompson, Richard 1995. Oilfield Processing of Petroleum: Crude
Oil. Penn Well Publishing Company. EPA-HQ-OW-2008-0517 DCN 07310.
2. Taylor, Linda. 2010. Telephone conversation with Linda Taylor, Marathon Oil Maverick
Springs, and Elizabeth Sabol, Eastern Research Group, Inc. "Sulfide Discharges Reported
to DMR in 2008." (June 3). EPA-HQ-OW-2008-0517 DCN 07307.
3. WDEQ. 2007a. Wyoming Department of Environmental Quality. State of Wyoming
National Pollutant Discharge Elimination System Permit NPDES WY0000779 -
Marathon Oil Maverick Springs. Fremont County, WY. (November) EPA-HQ-OW-
2008-0517 DCN 07291.
4. WDEQ. 2007b. Wyoming Department of Environmental Quality. State of Wyoming
National Pollutant Discharge Elimination System Statement of Basis NPDES
WY0000779 - Marathon Oil Maverick Springs. Fremont County, WY. (June) EPA-HQ-
OW-2008-0517 DCN 07292.
5. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
6. U.S. EPA. 1976. Development Document for Interim Final Effluent Limitations
Guidelines and Proposed New Source Performance Standards for the Oil and Gas
Extraction Point Source Category. EPA-440/l-76-055-a. Washington, DC. (September).
7. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
10-8
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Section 11 - Ore Mining and Dressing (40 CFR Part 440)
11. Ore Mining and Dressing (40 CFR Part 440)
As discussed in the 2008 Final Plan, EPA conducted a preliminary study of facilities
covered under 40 CFR Part 440, the Ore Mining and Dressing (Ore Mining) Category to
examine why toxic-weighted pollutant discharges by the ore mining industry ranked relatively
high compared to other industries in the 2002 through 2008 annual reviews. The purpose of the
study was to identify, collect, and review readily available existing data and information on toxic
pollutants in wastewater discharges to determine whether additional analysis or revision of 40
CFR Part 440 might be warranted to better control toxic discharges.
The preliminary study focused on active ore mines covered under 40 CFR Part 440
Subpart J: Copper, Lead, Zinc, Gold, Silver, and Molybdenum Ores. These types of mines
comprise approximately 76 percent (263 ore mines) of the approximately 345 ore mines in the
United States. Inactive ore mines were not included as they are not covered by the effluent
guidelines.
Approximately 294 ore mines currently have National Pollutant Discharge Elimination
System (NPDES) wastewater discharge permits. There is a difference between the total number
of ore mines and the number with NPDES permits because not all ore mines have wastewater
discharges. The approximately 1,870 placer mines, covered under 40 CFR Part 440 Subpart M,
were not examined in this study because they employ mining practices and wastewater streams
that are fundamentally different from mines covered under the other subparts of 40 CFR Part
440.
The preliminary study examined information pertaining to the two types of wastewater
discharged by ore mines: process wastewater (including mine drainage) and stormwater. Process
wastewater is covered under 40 CFR Part 440. Stormwater is not covered under 40 CFR Part 440
unless it is commingled with process wastewater prior to discharge to a surface waterbody.
The study was limited by incomplete national-level process wastewater discharge data,
and the lack of any nationally representative stormwater data for the ore mines of interest. EPA
did review available ore mine-specific process wastewater discharge information, available Total
Maximum Daily Load (TMDL) reports, information for ore mine site stormwater discharges, and
an industrial wastewater treatment technology, known as high density sludge recycling, which
was identified during the course of the study.
Based on EPA's review of toxic pollutant data, EPA found that in 2007, the most recent
year for which quality-checked data are available, approximately only two percent of ore mining
facilities were responsible for approximately 90 percent of toxic weighted discharges by the ore
mining industry for toxic pollutants.
Given that only a small percentage of active ore mines account for the majority of toxic
weighted discharges, this can best be addressed through permitting, compliance, and
enforcement activities for the specific ore mining sources, rather than by revision of 40 CFR Part
440.
While the available toxic pollutant data does not suggest that EPA revisit the ELGs for
ore mining and dressing (40 CFR Part 440) at this time, the Agency currently remains concerned
about many other types of mining-related water quality impairments. EPA has a number of
11-1
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Section 11 - Ore Mining and Dressing (40 CFR Part 440)
activities that address discharges of pollutants from mines including: guidance on protective
levels of conductivity for aquatic life in streams affected by mine discharges; plans to revise the
water quality criteria for selenium; increased attention on compliance with, and enforcement of,
individual permit limits; improved permitting guidance; and more stringent discharge monitoring
requirements in permits.
The Ore Mining Preliminary Study Report (U.S. EPA, 2010) is being issued concurrent
with the publication of the final 2010 Plan.
11.1 Ore Mining and Dressing Category References
1. U. S. EPA. 2010. Ore Mining and Dressing Preliminary Study Report. EPA-821 -R-08-
012. Washington, DC. (December). EPA-HQ-OW-2008-0517 DCN 07369.
11-2
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
12. Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
EPA selected the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category
for preliminary review because it continues to rank high, in terms of toxic-weighted pound
equivalent (TWPE), in point source category rankings (see Table 5-3 for the point source
category rankings). This industry was reviewed previously in each of EPA's Preliminary and
Final Effluent Guidelines Program Plans from 2004 to 2009 (U.S. EPA, 2004; U.S. EPA, 2005a;
U.S. EPA, 2006; U.S. EPA, 2007; U.S. EPA, 2008, U.S. EPA, 2009). This section summarizes
the results of the 2010 annual review associated with the OCPSF Category. EPA focused on
discharges of hexachlorobenzene, metals, chlorine, and poly cyclic aromatic compounds (PACs),
because of their high TWPE relative to other pollutants in the OCPSF Category.
EPA is currently reviewing discharges from the Chlorinated Hydrocarbon Manufacturing
Segment of the OCPSF Category as part of the Chlorine and Chlorinated Hydrocarbons (CCH)
effluent guidelines rulemaking. Because a rulemaking for this segment of the OCPSF Category is
underway, EPA excluded discharges from these facilities from further consideration in this
review (see Table V-l, 70 FR 61335, October 30, 2007).
12.1 OCPSF Category Background
This subsection provides the background on the OCPSF Category including a brief
profile of the OCPSF industry and background on 40 CFR Part 414.
12.1.1 OCPSF Industry Profile
The OCPSF industry includes many chemical industries producing a wide variety of end
products, such as polypropylene, vinyl chloride and polyvinyl chloride (PVC), chlorinated
solvents, rubber precursors, styrofoam additives, and polyester. Some OCPSF facilities are
extremely complex and produce hundreds of chemicals, while others are simpler, producing one
or two end products. EPA considered the following 22 North American Industry Classification
System (NAICS) codes as part of the OCPSF Category:
• 3119990CPSF: All Other Miscellaneous Food Manufacturing;
• 3241990CPSF: All Other Petroleum and Coal Products Manufacturing;
• 325110: Petrochemical Manufacturing;
• 325120OCPSF: Industrial Gas Manufacturing;
• 325132: Synthetic Organic Dye and Pigment Manufacturing;
• 3251880CPSF: All Other Basic Inorganic Chemical Manufacturing;
• 325192: Cyclic Crude and Intermediate Manufacturing;
• 325193: Ethyl Alcohol Manufacturing;
• 325199: All Other Basic Organic Chemical Manufacturing;
• 325211: Plastics Material and Resin Manufacturing;
• 325221: Cellulosic Organic Fiber Manufacturing;
• 325222: Noncellulosic Organic Fiber Manufacturing;
• 325510OCPSF: Paint and Coating Manufacturing;
• 325520: Adhesive Manufacturing;
• 325611 OCPSF: Soap and Other Detergent Manufacturing;
• 325612: Polish and Other Sanitation Good Manufacturing;
• 325620: Toilet Preparation Manufacturing;
12-1
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
• 325998: All Other Miscellaneous Chemical Product and Preparation
Manufacturing;
• 3261990CPSF: All Other Plastics Product Manufacturing;
• 3399990CPSF: All Other Miscellaneous Manufacturing;
• 424690: Other Chemical and Allied Products Merchant Wholesalers; and
• 562920: Materials Recovery Facilities.
Wastewater generated by facilities in NAICS codes 311999, 324199, 325120, 325188,
325510, 325611, 326199, 339999 may be regulated under multiple categories. For example,
most facilities in NAICS code 324199 are grouped under the Petroleum Refining Effluent
Limitation Guidelines and Standards (ELGs). EPA reviewed available information about
pollutant loads and manufacturing operations for facilities reporting these NAICS codes. EPA
assigned the extension "OCPSF" to the end of the NAICS codes of facilities that most likely fall
under the applicability of the OCPSF ELGs (40 CFR Part 414).
This list of Standard Industrial Classification (SIC) codes includes facilities that EPA
determined are potential new subcategories of the OCPSF Category. As part of the 2004 annual
review, EPA reviewed industries with SIC codes not clearly subject to existing ELGs. EPA
concluded that the processes, operations, wastewaters, and pollutants of facilities in the eight SIC
codes are similar to those of the OCPSF Category (U.S. EPA, 2004):18
• 2821: Plastics Materials, Synthetic and Resins, and Nonvulcanizable Elastomers;
• 2824: Manmade Organic Fibers, Except Cellulosic;
• 2842: Specialty Cleaning, Polishing, and Sanitation Preparations;
• 2844: Perfumes, Cosmetics, and Other Toilet Preparations (except toothpaste, gel,
and dentifrice powders);
• 2869: Industrial Organic Chemicals, NEC (cyclopropane, diethylcyclohexane,
naphthalene sulfonic acid);
• 2891: Adhesives and Sealants;
• 2899: Chemicals and Chemical Preparations, NEC (table salt); and
• 5169: Chemicals and Allied Products, NEC (merchant wholesalers).
As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes
for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are
reported by NAICS code (U.S. EPA, 2009). However, there is not a direct relationship between
one SIC and one NAICS code. As a result, EPA included the following NAICS codes in the
2010 annual review of the OCPSF Category because they contain facilities with operations that
are similar to the SIC codes above:
• 3119990CPSF: All Other Miscellaneous Food Manufacturing;
• 3251880CPSF: All Other Basic Inorganic Chemical Manufacturing;
• 325199: All Other Basic Organic Chemical Manufacturing;
• 325222: Noncellulosic Organic Fiber Manufacturing;
18 The tables in this section include discharge information from facilities reporting these SIC codes and the
corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the
conclusions drawn during the 2004 detailed study (U.S. EPA, 2004) and 2006 review (U.S. EPA, 2006), EPA found
that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge TWPE
greater than zero.
12-2
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
• 325510OCPSF: Paint and Coating Manufacturing;
• 325520: Adhesive Manufacturing;
• 325611OCPSF: Soap and Other Detergent Manufacturing;
• 325620: Toilet Preparation Manufacturing;
• 325998: All Other Miscellaneous Chemical Product and Preparation
Manufacturing;
• 3261990CPSF: All Other Plastics Product Manufacturing;
• 3399990CPSF: All Other Miscellaneous Manufacturing; and
• 424690: Other Chemical and Allied Products Merchant Wholesalers.
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES) data systems, the
sources of the discharge monitoring report (DMR) data used to develop DMRLoads2008, report
facilities by SIC code and the U.S. Economic Census and TRI report data by NAICS code, EPA
reclassified the 2008 DMR data by the equivalent NAICS code. Table 12-1 lists the number of
facilities from the U.S. Economic Census and the screening-level databases for the 22 NAICS
codes with operations in the OCPSF Category the corresponding SIC codes are included for
reference. The U.S. Economic Census includes more facilities than the screening-level databases
because of many possible factors including: facilities may not meet TRI-reporting thresholds,
facilities may discharge to a publicly owned treatment works (POTW), and some facilities in the
U.S. Economic Census are distributors or sales facilities, not manufacturers.
Table 12-1. Number of OCPSF Facilities
NAICS Code
SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008 DMR
Database"
2008 TRI
Database b
3119990CPSF: All Other Miscellaneous Food
Manufacturing
2821:Plastics Materials,
Synthetic and Resins,
and Nonvulcanizable
Elastomers
2824:Manmade Organic
Fibers, Except
Cellulosic
2842: Specialty
Cleaning, Polishing,
and Sanitation
Preparations
2844: Perfumes,
Cosmetics, and Other
Toilet Preparations
(toothpaste, gel, and
dentifrice powders)
2865: Cyclic Organic
Crudes and
Intermediates and
Organic Dyes and
Pigments (except
aromatics and organic
NA
929
2
3241990CPSF: All Other Petroleum and Coal
Products Manufacturing
NA
1
325110: Petrochemical Manufacturing
56
67
325120OCPSF: Industrial Gas Manufacturing
NA
2
325132: Synthetic Organic Dye and Pigment
Manufacturing
123
32
3251880CPSF: All Other Basic Inorganic
Chemical Manufacturing
NA
1
325192: Cyclic Crude and Intermediate
Manufacturing
37
20
325193: Ethyl Alcohol Manufacturing
72
153
325199: All Other Basic Organic Chemical
Manufacturing
685
379
325211: Plastics Material and Resin
Manufacturing
690
348
325222: Noncellulosic Organic Fiber
Manufacturing
95
25
12-3
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-1. Number of OCPSF Facilities
Number of Facilities
NAICS Code
SIC Code
2002 U.S.
Economic
Census
2008 DMR
Database"
2008 TRI
Database b
325510OCPSF: Paint and Coating
Manufacturing
dyes and pigments)
2869: Industrial
NA
7
325520: Adhesive Manufacturing
Organic Chemicals,
NEC (fluorocarbon
gases);
891: Adhesives and
595
151
3256110CPSF: Soap and Other Detergent
Manufacturing
NA
12
325612: Polish and Other Sanitation Good
Manufacturing
Sealants
2899: Chemicals and
604
84
325620: Toilet Preparation Manufacturing
Chemical Preparations,
NEC (table salt)
867
26
325998: All Other Miscellaneous Chemical
Product and Preparation Manufacturing
1,188
311
3261990CPSF: All Other Plastics Product
Manufacturing
NA
3
3399990CPSF: All Other Miscellaneous
Manufacturing
NA
2
562920: Materials Recovery Facilities
947
32
424690: Other Chemical and Allied Products
Merchant Wholesalers
5169: Chemicals and
Allied Products, NEC
(merchant wholesalers)
11,158
94
443
325221: Cellulosic Organic Fiber Manufacturing
2823: Cellulosic
Manmade Fibers
8
4
4
Total
> 17,125
1,027
2,105
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2007_v2\ and DMRLoads2007_v2.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS to SIC
crosswalk for comparison purposes,
b - Releases to any media.
NA - Not applicable.
Table 9-2 shows whether permitting authorities designated direct dischargers as minor or
major (see Section 4.1.5) for facilities in the OCSPF Category. EPA included data for minor
dischargers for the first time in the 2010 annual review, as part of DMRLoads2008 v2 database.
EPA does not require permitting authorities to submit DMR data for minor dischargers; however,
many states do provide complete DMR data for them. From this year's review, EPA observed
many data entry or other errors for minor dischargers in addition to those previously identified
for major dischargers, as discussed in Section 4.3. Table 12-2 shows that approximately 78
percent of the OCPSF Category dischargers in the 2008 DMR database are minor dischargers.
12-4
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-2. Number of OCPSF Facilities by Discharge Classification in 2008 DMR
Database
Number of Facilities in 2008 DMR
NAICS Code®
Major
Dischargers
Minor
Dischargers
All
Dischargers
3119990CPSF All Other Miscellaneous Food Manufacturing
3241990CPSF All Other Petroleum and Coal Products
Manufacturing
325110 Petrochemical Manufacturing
325120OCPSF Industrial Gas Manufacturing
325132 Synthetic Organic Dye and Pigment Manufacturing
3251880CPSF All Other Basic Inorganic Chemical
Manufacturing
325192 Cyclic Crude and Intermediate Manufacturing
325193 Ethyl Alcohol Manufacturing
325199 All Other Basic Organic Chemical Manufacturing
325211 Plastics Material and Resin Manufacturing
325222 Noncellulosic Organic Fiber Manufacturing
325510OCPSF Paint and Coating Manufacturing
325520 Adhesive Manufacturing
3256110CPSF Soap and Other Detergent Manufacturing
325612 Polish and Other Sanitation Good Manufacturing
325620 Toilet Preparation Manufacturing
325998 All Other Miscellaneous Chemical Product and
Preparation Manufacturing
3261990CPSF All Other Plastics Product Manufacturing
3399990CPSF All Other Miscellaneous Manufacturing
562920 Materials Recovery Facilities
219
710
929
424690 Other Chemical and Allied Products Merchant
Wholesalers
2
92
94
325221 Cellulosic Organic Fiber Manufacturing
2
2
4
Total
223
804
1,027
Source: DMRLoads2008_v2.
a - DMR data is reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison
purposes.
Table 12-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of OCPSF facilities reporting to TRI do not report water discharges, but those that
do mostly reported discharging indirectly.
12-5
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-3. Number of OCPSF Facilities by Type of Discharger in TRI 2008
NAICS Code
Number of Facilities in TRI 2008 Database
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both Indirect
and Direct
No Water
Discharges
3119990CPSF: All Other Miscellaneous Food
Manufacturing
0
2
0
0
3241990CPSF: All Other Petroleum and Coal
Products Manufacturing
0
0
1
0
325110: Petrochemical Manufacturing
30
15
1
21
325120OCPSF: Industrial Gas Manufacturing
1
0
0
1
325132: Synthetic Organic Dye and Pigment
Manufacturing
3
18
0
11
3251880CPSF: All Other Basic Inorganic
Chemical Manufacturing
0
1
0
0
325192: Cyclic Crude and Intermediate
Manufacturing
9
4
2
5
325193: Ethyl Alcohol Manufacturing
4
6
1
142
325199: All Other Basic Organic Chemical
Manufacturing
73
126
17
163
325211: Plastics Material and Resin
Manufacturing
61
80
23
184
325222: Noncellulosic Organic Fiber
Manufacturing
6
9
0
10
325510OCPSF: Paint and Coating Manufacturing
0
6
1
0
325520: Adhesive Manufacturing
4
20
0
127
3256110CPSF: Soap and Other Detergent
Manufacturing
0
11
0
1
325612: Polish and Other Sanitation Good
Manufacturing
1
20
0
63
325620: Toilet Preparation Manufacturing
0
14
1
11
325998: All Other Miscellaneous Chemical
Product and Preparation Manufacturing
14
48
6
243
3261990CPSF: All Other Plastics Product
Manufacturing
0
2
1
0
3399990CPSF: All Other Miscellaneous
Manufacturing
0
0
1
1
562920: Materials Recovery Facilities
0
1
0
31
424690: Other Chemical and Allied Products
Merchant Wholesalers
6
27
0
410
325221: Cellulosic Organic Fiber Manufacturing
2
0
0
2
Total
214
410
55
1,426
Source: TRIReleases2008 v3.
12-6
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
12.1.2 40 CFR Part 414
EPA first promulgated ELGs for the OCPSF Category (40 CFR Part 414) on
November 5, 1987 (52 FR 42568). This category consists of seven subcategories that apply to
the manufacture of products and product groups, as shown in Table 12-4 with corresponding SIC
codes and applicability. Subparts B through H have limitations for biochemical oxygen demand
(BODs), total suspended solids (TSS), and pH. The regulation also includes limitations and/or
pretreatment standards for certain toxic pollutants in three additional subparts:
• Subpart I — Direct Discharge Point Sources That Use End-of-Pipe Biological
Treatment;
• Subpart J — Direct Discharge Point Sources That Do Not Use End-of-Pipe
Biological Treatment; and
• Subpart K — Indirect Discharge Point Sources.
Table 12-4. Applicability of Subcategories in the OCPSF Category
Subpart
Subcategory Title
Corresponding SIC Codc(s)"
Subcatcgory Applicabilitv
B
Rayon Fibers
2823: Cellulosic Manmade Fibers
Cellulosic manmade fiber (Rayon)
manufactured by the Viscose process.
C
Other Fibers
2824: Synthetic Organic Fibers,
Except Cellulosic
All other synthetic fibers (except
Rayon) including, but not limited to,
products listed in Section 414.30.
D
Thermoplastic Resins
28213: Thermoplastic Resins
Any plastic product classified as a
thermoplastic resin including, but not
limited to, products listed in Section
414.40.
E
Thermosetting Resins
28214: Thermosetting Resins
Any plastic product classified as a
thermosetting resin including, but not
limited to, products listed in Section
414.50.
F
Commodity Organic
Chemicals
2865: Cyclic Crudes and
Intermediates, Dyes and Organic
Pigments
2869: Industrial Organic
Chemicals, NEC
Commodity organic chemicals and
commodity organic chemical groups
including, but not limited to, products
listed in Section 414.60.
G
Bulk Organic
Chemicals
2865: Cyclic Crudes and
Intermediates, Dyes and Organic
Pigments
2869: Industrial Organic
Chemicals, NEC
Bulk organic chemicals and bulk
organic chemical groups including,
but not limited to, products listed in
Section 414.70.
H
Specialty Organic
Chemicals
2865: Cyclic Crudes and
Intermediates, Dyes and Organic
Pigments
2869: Industrial Organic
Chemicals, NEC
All other organic chemicals and
organic chemical groups including,
but not limited to, products listed in
the OCPSF Development Document
(Vol. II, Appendix II-A, Table VII).
Source: Product and Product Group Discharges Subject to Effluent Limitations and Standards for the Organic
Chemicals, Plastics, and Synthetic Fibers Point Source Category — 40 CFR 414, Table 2-2 (U.S. EPA, 2005b).
a - During the 2009 annual review EPA developed a crosswalk between SIC codes and NAICS codes. Because there
is not a direct match EPA did not report NAICS codes.
NEC - Not elsewhere classified.
12-7
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
12.2 OCPSF Category 2010 Screening-Level Review
Table 12-5 compares the screening-level database results for the OCPSF Category from
the 2006 through 2010 annual reviews. The combined DMR and TRI TWPE increased from
discharge years 2002 to 2004, but decreased from discharge years 2004 to 2008. The 2008 DMR
TWPE accounts for approximately 79 percent of the combined 2008 DMR and TRI TWPE,
while TRI discharges dominated previous years' combined TWPE.
Table 12-5. OCPSF Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews
Year of Discharge
Year of Review
OCPSF Category
TRI TWPE
DMR TWPE "
Total TWPE
2002
2006
349,000
398,000
747,000
2004
2007
957,000
608,000
1,570,000
2005
2008
759,000
NA
NA
2007
2009
575,000
309,000
884,000
2008
2010
137,000
512,000
649,000
Source: TRIReleases2002_v4; PCSLoads2002_v4\ TRlReleases2004_v3; PCSLoads2004_v3', TRlReleases2005_v2;
TRlReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 12-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (96 percent) of the TWPE in the 2008 DMR database results from major
dischargers.
Table 12-6. OCPSF Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
19,100
493,000
Source: DMRLoads2008jv2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
12.3 OCPSF Pollutants of Concern
Table 12-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and
2004 TRI databases (TRIReleases2008_v3, TRIReleases2007_v2, and TRIReleases2004 v3).
Table 12-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR
databases (DMRLoads2008_v2, DMRLoads2007_v3, and PCSLoads2004_v4).
12-8
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-7. O.CPSF Category Top TRI Pollutants
Pollutant
2004 TRI Data"
2007 TRI Data"
2008 TRI Data "
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Nitrate Compounds
5
130
16,200
Pollutant not reported in the top five 2007
TRI reported pollutants.
1
111
15,000
Lead and Lead Compounds
Pollutants not reported in the top five
2004 TRI reported pollutants.
5
55
16,500
2
50
12,600
Copper and Copper
Compounds
Pollutants not reported in the top five
2007 TRI reported pollutants.
3
44
10,400
Manganese and Manganese
Compounds
4
26
10,200
Hydroquinone
4
6
17,100
3
4
18,500
5
5
10,030
Dioxin and Dioxin Like
Compounds
1
8
693,000
1
4
398,000
Pollutants not reported in the top five 2008
TRI reported pollutants.
Chlorine
3
15
22,900
2
13
27,500
PACs
Pollutant not reported in the top five
2004 TRI reported pollutants.
4
7
18,200
Hexachlorobenzene
2
4
84,500
Pollutant not reported in the top five 2007
TRI reported pollutants.
OCPSF Category Total
NA
744 b
95,700
NA
594 b
57,500
NA
672 b
137,000
Source: TRIReleases2004_v3; TRlReleases2007_v2; and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
12-9
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-8. OCPSF Category Top DMR Pollutants
2004 DMR Data11
2007 DMR Data"
2008 DMR Data
h
Pollutant
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Hexachlorobenzene
2
13
123,000
1
13
62,700
1
11
124,000
Chlorine
4
46
38,200
2
46
45,600
2
104
77,800
Nickel
Pollutants not reported in the top five 2004
DMR reported pollutants.
4
58
23,000
3
68
59,500
Copper
Pollutant not reported in the top five 2007
DMR reported pollutants.
4
133
42,100
Fluoride
5
12
28,200
3
13
35,500
5
16
28,900
Tin
Pollutant not reported in the top five 2004
DMR reported pollutants.
5
3
17,500
Pollutants not reported in the top five 2008
DMR reported pollutants.
Aluminum
1
20
209,000
Pollutant not reported in the top five 2007
Benzidine
3
1
63,800
DMR reported pollutants.
OCPSF Category
Total
NA
202 c
608,000
NA
194 c
309,000
NA
357 c
512,000
Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008jv2.
a - 2004 and 2007 DMR data include only major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
12-10
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
The OCPSF 2008 TRI TWPE accounts for 21 percent of the total category TWPE, while
the 2008 DMR TWPE accounts for 79 percent. Therefore, EPA focused the additional review on
the DMR-reported pollutants that account for the majority of the category TWPE.
EPA's additional review for the 2008 DMR database pollutants of concern,
hexachlorobenze, chlorine, and metals (nickel and copper), is presented in the following
subsections. EPA also reviewed discharges of PACs19 as part of the 2010 annual review, even
though they are not one of the top five pollutants for DMR in 2008. PACs discharges have been
continually monitored by EPA as part of previous annual reviews. During the review of top
pollutants, EPA discovered that the majority of the top pollutants were discharged from the same
three facilities in the 2008 DMR database. Table 12-9 presents the facility dischargers and
corresponding top DMR pollutants discharged in the OCSPF Category.
Table 12-9. OCPSF Category Top Facility Dischargers in the DMR 2008 Database
Top Pollutant
Facility Name
Pounds of
Pollutant
Discharged
Pollutant
TWPE
Total
Facility
TWPE
Other Top
Pollutants
Discharged
Hexachlorobenzene
Chevron Oronite Co.
43.8
85,300
95,600
PACs
Nickel
MPM Silicones, LLC
571,000
57,100
102,000
Hexachlorobenzene,
PACs
Copper
MPM Silicones, LLC
36,600
23,100
Benzo(a)pyrene 11
EI DuPont De Nemours
196
19,700
44,900
Other PACs
Source: DMRLoads2007_v3 and DMRLoads2008jv2.
a - Benzo(a)pyrene is included in the group of pollutants referred to as PACs.
12.4 OCPSF Category Top Facility Dischargers in DMR
The majority of the top pollutants for the OCSPF Category in the 2008 DMR database
are discharged from the top three facility dischargers. This subsection provides further detail on
the top three facility dischargers in the OCSPF Category responsible for the majority of the
hexachlorobenzene, PACs, and metals TWPE. As a result of EPA's review of discharges from
the top facilities in the OCPSF Category, the overall category 2008 DMR TWPE decreased by
239,000 TWPE.
12.4.1 Chevron Oronite Co. LLC in Belle Chasse, LA20
Table 12-10 presents the top five discharges in the 2008 DMR database for Chevron
Oronite Co. LLC. The majority of the facility TWPE (approximately 89 percent) is from
hexachlorobenzene. Hexachlorobenzene discharges from Chevron Oronite also account for
almost 17 percent of the total OCPSF Category TWPE in the 2008 DMR database. The other top
19 PACs include the following pollutants: benzo(a)anthracene, chrysene, benzo(a) pyrene, benzo(b)fluoranthene,
benzo(j)fluoranthene, benzo(k)fluoranthene, fluoranthene, benzo(r,s,t)pentaphene, dibenz(a,h)acridine,
dibenz(a,j)acridine, dibenzo(a,h)anthracene, dibenzo(a,e)fluoranthene, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene,
dibenzo(a,l)pyrene, 7H-dibenzo(c,g)carbozole, 7,12-dimethylbenz(a)anthracene,
indeno(l,2,3-cd)pyrene, 3-methylcholanthrene, 5-methylchrysene, and 1-nitropyrene.
20 Chevron Oronite Co. LLC in Belle Chasse, LA has two NPIDs: LA0005738 and LAG670106. This section
discusses the discharges associated with the NPID LA0005738. Discharges from LAG670106 are not included in
the DMR Loadings Tool.
12-11
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
pollutants (all PACs) are benzo(a)pyrene, chrysene, benzo(a)anthracene, and
b enzo(b)fluoranthene.
Table 12-10. Chevron Oronite 2008 Top Discharges
Pollutant
Total Pounds
Total TWPE
Percentage of Facility
Total TWPE
Hexachlorobenzene
43.8
85,300
89%
Benzo(a)pyrene
43.8
4,410
4.6%
Chrysene
43.8
1,360
1.4%
Benzo(a)anthracene
43.8
1,340
1.4%
B enzo (b)fluoranthene
43.8
1,340
1.4%
Total
362,000
95,600
100%
Source: DMRLoads2008_v2.
All of the pollutant discharges for Chevron Oronite are from outfall 202. Table 12-11
presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted Chevron
Oronite to verify the hexachlorobenzene and PACs quantities. Chevron Oronite indicated that the
hexachlorobenzene, benzo(a)pyrene, chrysene, benzo(a)anthracene, and benzo(b)fluoranthene
concentrations were measured below the detection limit (BDL). Further, Chevron Oronite
provided discharge monitoring data that showed all PAC concentrations in the 2008 DMR
database were reported as nondetect (Sampey, 2010).
Chevron Oronite indicated that they use half the detection limit to calculate the quantities
when the pollutants are measured BDL (Sampey, 2010). Therefore, all of the quantities in the
2008 DMR database were BDL and the loads and TWPE should be zero. This correction leads to
the facility's total TWPE decreased from 95,600 TWPE to 40 TWPE, a reduction of over 99
percent.
Table 12-11. Chevron Oronite Outfall 202 2008 Monthly Discharge Data
Outfall
Pollutant
Monitoring
Period Date
DMR Loadings
Tool Quantity
(kg/day)
Facility-
Provided
Quantity
(kg/day)
Flow (MGD)
202
Hexachlorobenzene
31-Dec-08
0.0544
<0.0544
1.132
202
Benzo(a)pyrene
31-Dec-08
0.0544
<0.0544
1.132
202
Chrysene
31-Dec-08
0.0544
<0.0544
1.132
202
Benzo(a)anthracene
31-Dec-08
0.0544
<0.0544
1.132
202
Benzo(b)fluoranthene
31-Dec-08
0.0544
<0.0544
1.132
Source: DMR Loadings Tool and Facility Contact (Sampey, 2010).
12.4.2 MPM Silicones, LLC in Friendly, WV
Table 12-12 presents the top pollutant discharges in the 2008 DMR database for MPM
Silicones, LLC. The majority of the TWPE results from discharge of nickel and copper.
12-12
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Hexachlorobenzene and benzo(a)pyrene are the 3rd and 4th ranking pollutants, by TWPE, for the
facility in the 2008 DMR database.
Table 12-12. MPM Silicones 2008 Top Discharges
Pollutant
Total Pounds
TWPE
Percentage of Facility
TWPE
Nickel
571,000
57,100
56%
Copper
36,600
23,100
23%
Hexachlorobenzene
10
19,000
19%
Benzo(a)pyrene
12
1,190
1.2%
Total
10,400,000
102,000
100%
Source: DMRLoads2008jv2.
All of MPM Silicones' top pollutant discharges are from outfall 001. Table 12-13
presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted MPM Silicones
to verify the values and units for the nickel, copper, hexachlorobenzene, and benzo(a)pyrene
concentrations. MPM Silicones' facility contact verified that the pollutant concentrations
reported were either incorrect or missing the BDL indicators (i.e., "<"), and all concentrations
should have been reported as |ig/L, not mg/L. The facility contact also indicated that
benzo(a)pyrene should have been reported annually; therefore, there should only be one reported
concentration for December 2008. Table 12-13 also shows the facility-provided concentrations
(Martin, 2010).
Table 12-13. MPM Silicones Outfall 001 2008 Monthly Discharge Data
Outfall
Monitoring Period
Date
DMR Loadings Tool
Average Concentration
(mg/L)
Facility-Corrected
Average
Concentration (mg/L)
Average Flow (MGD)
Nickel
001
31-Mar-08
22
0.022
5.71
001
30-Jun-08
11
a
5.4
001
30-Sept-08
21
0.021
5.32
001
31-Dec-08
83
0.083
5.43
Copper
001
31-Mar-08
3
<0.006
5.71
001
30-Jun-08
<0.5
a
5.4
001
30-Sept-08
<5
<0.01
5.32
001
31-Dec-08
3
< 0.006
5.43
Hexachlorobenzene
001
31-Mar-08
0.000395
< 0.00079
5.71
001
30-Jun-08
0.000435
< 0.00075
5.4
001
30-Sept-08
0.000435
< 0.00075
5.32
001
31-Dec-08
0.00121
< 0.00024
5.43
12-13
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-13. MPM Silicones Outfall 001 2008 Monthly Discharge Data
Outfall
Monitoring Period
Date
DMR Loadings Tool
Average Concentration
(mg/L)
F aci litv-Cor rected
Average
Concentration (mg/L)
Average Flow (MGD)
Benzo(a)pyrene
001
30-Sept-08
0.00095
NRb
5.32
001
31-Oct-08
0.000705
NRb
5.39
001
31-Dec-08
NR
<0.00141 b
5.43
Source: DMR Loadings Tool and Facility Contact (Martin, 2010).
a - Concentration not reported due to sampling error.
b - The facility contact indicated that the benzo(a)pyrene concentration was be reported only once in December
2008, not September or October 2008.
NR - Concentration not reported.
Using the facility-provided concentrations, EPA calculated the revised load and
corresponding TWPE for the top pollutants. The facility's copper, hexachlorobenzene, and
benzo(a)pyrene loads were zeroed because all of the concentrations were measured below the
detection limit. MPM Silicones' nickel discharges decrease from 57,100 TWPE 39 TWPE, while
the facility's total TWPE decreased from 102,000 TWPE to 1,620 TWPE, a reduction of over 98
percent.
12.4.3 EI DuPont de Nemours & Co. in Washington, WV
Table 12-14 presents the top discharges for EI DuPont de Nemours & Co. in the 2008
DMR database. The majority of the facility TWPE (approximately 41 percent) is from
benzo(a)pyrene. The other top pollutants reported are chrysene, benzo(a)anthracene, and
benzo(k)fluoranthene, all PACs.
Table 12-14. E I DuPont de Nemours 2008 Top Discharges
Pollutant
Total Pounds
TWPE
Percentage of Facility
TWPE
Benzo(a)pyrene
196
19,700
44%
Chrysene
196
6,070
14%
Benzo(a)anthracene
196
6,000
13%
B enzo (k)fluoranthene
196
6,000
13%
Total
7,250,000
44,900
100%
Source: DMRLoads2008_v2.
All of the PACs discharges are from outfalls 002 and 005. Table 12-15 presents the
discharge data in the DMR Loadings Tool for 2008. EPA contacted the West Virginia
Department of Environmental Protection (WV DEP) to verify the PACs concentrations. The WV
DEP provided the DMRs and indicated that the all PACs discharges were below the detection
limit in 2008 (Simmons, 2010). Therefore, the facility's PACs loads and TWPE were set to zero.
E I DuPont de Nemours' TWPE decreased from 44,500 TWPE to 1,550 TWPE, a total reduction
of 96 percent.
12-14
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Table 12-15. E I DuPont de Nemours 2008 Monthly PACs Discharge Data
Outfall
Pollutant
Monitoring
Period Date
DMR Loadings
Tool
Concentration
(mg/L)
WV DEP-
Providcd
Concentration
(mg/L)
Flow (MGD)
005
Benzo(a)pyrene
31-Jul-08
0.0013
<0.0013
52.1
002
Benzo(a)pyrene
31-M-08
0.0013
<0.0013
11.7
005
Chrysene
31-Jul-08
0.0013
<0.0013
52.1
005
Benzo(a)anthracene
31-M-08
0.0013
<0.0013
52.1
005
B enzo (k)fluoranthene
31-Jul-08
0.0013
<0.0013
52.1
Source: DMR Loadings Tool and Facility Contact (Simmons, 2010).
12.5 OCPSF Category Chlorine Discharges in DMR
As part of the 2010 annual review of the OCSPF Category, EPA reviewed chlorine
discharges in the 2008 DMR database. Approximately 15 percent of the OCPSF Category 3009
DMR TWPE results from chlorine discharges. Table 12-16 presents the facilities in the 2008
DMR database that discharge chlorine. Two facilities, Oxea Bay City Plant in Bay City, TX, and
Channel View Complex in Channelview, TX, account for approximately 62 percent of the
discharges in the 2008 DMR database. This subsection provides information on Oxea Bay City's
and Channelview's chlorine discharges.
Table 12-16. OCSPF Category Top Chlorine Discharging Facilities in the 2008 DMR
Database
Facility Name
Major/Minor
Discharger
Pounds of Chlorine
Discharged
Chlorine TWPE
Percentage of
OCSPF Category
Chlorine DMR 2008
TWPE
Oxea Bay City Plant
Major
52,500
26,300
34%
Channel View Complex
Major
43,600
21,800
28%
Pasadena Plastics Complex
Major
12,900
6,450
8%
Exxon Mobil Chemical Co.
Major
7,600
3,800
5%
Cytec Industries, Inc.
Major
6,500
3,250
4%
Remaining OCPSF Chlorine Dischargersa
32,400
16,200
21%
Total
156,000
77,800
100%
Source: DMRLoads2008_v2.
a - There are 99 remaining OCPSF facilities with chlorine discharges in DMRLoads2008_v2 that account for about
21 percent of the OCPSF Category's 2008 chlorine TWPE in the DMR database.
12-15
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
12.5.1 Oxea Bay City Plant in Bay City, TX
All of Oxea Bay City's chlorine discharges are from outfall 001. Table 12-17 presents
Oxea Bay City's 2008 chlorine discharge data from DMR Loadings Tool for outfall 001. EPA
confirmed these discharges with information from Envirofacts21.
Table 12-17. Oxea Bay City 2008 Monthly Chlorine and Flow Discharge Data
Monitoring Period Date
DMR Loadings Tool Chlorine
Concentration (mg/L)
DMR Loadings Tool Flow (MGD)
31-Jan-08
45
1.004
29-Feb-08
37.5
0.817
31-Mar-08
16.3
1.052
30-Apr-08
5.9
0.873
31-May-08
37.5
0.581
30-Jun-08
1.6
0.586
31-Jul-08
0.1
0.669
31-Aug-08
85
0.736
30-Sep-08
3
0.839
31-Oct-08
0.1
0.733
30-Nov-08
12
0.711
31-Dec-08
15
0.799
Source: DMR Loadings Tool.
Oxea Bay City Plant discharges treated domestic wastewater and treated process
wastewater from the neutral effluent treatment system, and treated utility wastewater,
stormwater, groundwater recovered during site excavations, stormwater from the old dewatering
area and from landfill cells, groundwater from the bailing of monitor wells, groundwater from
recovery wells, and hydrostatic test discharge water via outfall 001 (TCEQ, 2009).
EPA contacted Oxea Bay City Plant to confirm the chlorine discharges from outfall 001.
The facility contact verified the chlorine concentrations and indicated that the location where
chlorine is monitored is different than the location of the final outfall, where flow rate is
measured. The chlorine is measured at a nearby sewage treatment facility, Honeyhoe. Oxea Bay
indicated that effluent from Honeyhoe commingles with process wastewater in equalization
tanks. The facility contact believed that a majority of the chlorine was removed by microbes in
the equalization tanks. From the equalization tanks, flow is directed to the facility's cooling pond
and is re-circulated. The facility contact stated that the flow from the equalization tank is
typically re-circulated through the cooling pond; however, the facility permit allows for effluent
from the equalization tanks to be rerouted and discharged to outfall 001, if necessary. The
facility contact also indicated that in 2008 the plant had issues with the analyzer that controls the
chlorine feed, which they though may account for the higher chlorine concentrations (Martinez,
2010).
21 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts
continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not
continuously updated; therefore, loads may be estimated with erroneous data.
12-16
-------
Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
Based on information from the facility contact, EPA believes that the DMR Loadings
Tool is overestimating the chlorine discharges for Oxea Bay City Plant. The DMR Loadings
Tool is using the chlorine that is measured at the effluent from Honeyhoe and the flow that is
measured after the equalization tanks to calculate the chlorine load. EPA will continue to
monitor the chlorine discharges from this facility.
12.5.2 Channelview Complex Channelview, TX
All of Channelview's chlorine discharges are from outfall 001. Table 12-18 presents
Channelview's 2008 chlorine discharge data from the DMR Loadings Tool and Envirofacts for
outfall 001. EPA compared data from the DMR Loadings Tool, Envirofacts, and the facility
permit and found that the concentration reported in the 2008 DMR database is the maximum
concentration.
Table 12-18. Channelview Complex 2008 Monthly Chlorine and Flow Discharge Data and
Maximum Chlorine Permit Limitations
Monitoring Period
Date
DMR Loadings
Tool Chlorine
Concentration
(mg/L)
EPA Envirofacts
Minimum Chlorine
Concentration
(mg/L)
EPA Envirofacts
Maximum Chlorine
Concentration
(mg/L)
Facility Maximum
Chlorine Permit
Limit (mg/L)
31-Jan-08
NR
1.03
3.88
4
29-Feb-08
3.89
1.17
3.89
4
31-Mar-08
NR
1
31
4
30-Apr-08
NR
1.2
3.9
4
31-May-08
NR
1.43
3.9
4
30-Jun-08
NR
1
3.98
4
31-Jul-08
NR
1.12
3.93
4
31-Aug-08
NR
NR
NR
4
30-Sep-08
NR
1.24
3.94
4
31-Oct-08
NR
NR
NR
4
30-Nov-08
NR
1.2
NR
4
31-Dec-08
NR
1.2
NR
4
Source: DMR Loadings Tool; Envirofacts; and TPDES Permit for Channelview TX0003531 (TCEQ, 2004).
NR - Not reported.
Outfall 001 at Channelview Complex discharges treated organic chemical manufacturing
process wastewater, auto shop wastewater, laboratory wastewater, cooling tower blowdown,
sanitary wastewater, loading area and process area washdown, tank farm wastewater, heat
exchanger blasting slab waste, steam blowdown, demineralization regeneration blowdown,
methanol neutralization sump wastewater, and process area stormwater runoff. The facility is
required to treat domestic sewage (both primary and secondary) and chlorinate it sufficiently to
maintain at least 1.0 mg/L and at most 4.0 mg/L residual chlorine after at least 20 minutes
contact time (based on peak flow) prior to mixing with any other waters. The domestic sewage is
required to be monitored five times per week, by grab sample. From the facility permit, all
effluent monitoring samples, including flow rate, are taken where all effluents are commingled
together prior to discharge. The facility is required to take the chlorine sample at the exit of the
septic chlorinator prior to commingling with other wastewaters (TCEQ, 2004).
12-17
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
EPA contacted Channelview Complex to confirm the chlorine concentrations and flows
for 2008. The facility contact stated that all of chlorine concentrations and flows were correct.
The facility contact stated that the unusually high chlorine concentration measured during the
March 2008 sampling episode was a result of a septic chlorinator malfunction. The facility
contact also confirmed that the septic chlorinator, where chlorine is measured, is well upstream
of where flow is measured and that no flow is measured at the septic chlorinator (Miller, 2010).
Therefore, EPA believes that the DMR Loadings Tool is overestimating the chlorine discharges
for 2008. EPA will continue to monitor the chlorine concentrations from this facility, but does
not believe the estimated chlorine load accurately represents this facility's discharge.
12.6 OCPSF Category Conclusions
The estimated toxicity of the OCSPF Category discharges result from hexachlorobenze,
metals, chlorine, and PACs discharges. Data collected for the 2010 annual review demonstrated
that wastewater discharge characteristics for this category are consistent with discharges from
prior years. As in prior years, EPA makes the following conclusions:
• There were missing BDL indicators for hexachlorobenzene and PACs discharges
from the Chevron Oronite facility in Belle Chasse, LA. These discharges were
actually reported as nondetect, zeroing their load and TWPE. Correcting this error
decreases the 2008 facility TWPE to 40 TWPE.
• There were missing BDL indicators and a units error for the nickel, copper,
hexachlorobenzene, and PAC discharges reported by MPM Silicones in Friendly,
WV. Correcting these errors decreases the 2008 facility TWPE to 1,620 TWPE.
• There were missing BDL indicators for the PAC discharges reported by EI
DuPont de Nemours in Washington, WV. These discharges were actually reported
nondetect, zeroing their load and TWPE. Correcting this error decreases the 2008
facility TWPE to 1,550 TWPE.
• The chlorine TWPE resulted from flow measurement location errors: two
facilities measure chlorine at a separate location than flow. The flow
measurements occur after the wastewater containing chlorine commingles with
wastewater without chlorine. Therefore, the chlorine load does not accurately
reflect the facility's discharge. EPA will correct this error in the screening-level
databases in future years of review and continue monitoring the chlorine
discharges from OCSPF facilities.
• Correcting the database errors identified during the 2010 annual review decreases
the 2008 OCPSF Category TWPE from 649,000 TWPE to 410,000 TWPE. The
OCSPF Category continues to rank high due to the high number of facilities (over
2,000) in the industry. EPA will continue to monitor the OCSPF Category
discharges to determine if they are properly controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
12-18
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing ELGs).
12.7 OCSPF Category References
1. Martin, Jason. 2010. Notes from Telephone Conversation between Jason Martin, MPM
Silicones, LLC, and Elizabeth Sabol, Eastern Research Group, Inc. "RE: Discharges
Reported to DMR in 2008." (June 29). EPA-HQ-OW-2008-0517 DCN 07293.
2. Martinez, Sylvia. 2010. Notes from Telephone Conversation between Sylvia Martinez,
Oxea Bay City Plant, and Lauren Wingo, Eastern Research Group, Inc. "RE: Oxea Bay
City Plant's 2008 Chlorine and Flow Data in DMR Data." (August 27). EPA-HQ-OW-
2008-0517 DCN 07294.
3. Miller, Tommy. 2010. Notes from Telephone Conversation between Tommy Miller,
Lyondell Bassel, and Lauren Wingo, Eastern Research Group, Inc. "RE: Channel View's
2008 Chlorine and Flow Data in DMR." (August 30). EPA-HQ-OW-2008-0517 DCN
07295.
4. Sampey, Troy. 2010. E-mail Communication between Troy Sampey, Chevron Oronite
Co., and Elizabeth Sabol, Eastern Research Group, Inc. "RE: DMRs Clarification Needed
for Chevron Oronite - Oak Point Plant." (July 13). EPA-HQ-OW-2008-0517 DCN
07296.
5. Simmons, Linda. 2010. Notes from Telephone Conversation between Linda Simmons,
West Virginia Department of Environmental Protection, and Elizabeth Sabol, Eastern
Research Group, Inc. "RE: PAC Discharges Reported to DMR in 2008." (July 13). EPA-
HQ-OW-2008-0517 DCN 07297.
6. TCEQ. 2004. Texas Commission on Environmental Quality. Water Discharge Permit for
NPDES TX0003531 - Channelview Complex, Channelview, TX. EPA-HQ-OW-2008-
0517 DCN 07298.
7. TCEQ. 2009. Texas Commission on Environmental Quality. Notice of Application and
Preliminary Decision for Water Quality TPDES Permit Amendment for Industrial
Wastewater for NPDES TX0006017 - Oxea Bay City Plant, Bay City, TX. EPA-HQ-
OW-2008-0517 DCN 07299.
8. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
9. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346
through 1352.
10. U.S. EPA. 2005a. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-
0016.
12-19
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Section 12 - Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR Part 414)
11. U. S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations
and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source
Category. Washington, DC. (April). EPA-HQ-OW-2004-032-2568.
12. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
13. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQ-
OW-2006-0771-0819.
14. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. EPA-821 -R-08-015 Washington, DC. (August). EPA-HQ-OW-2006-0771-1701.
15. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQ-
OW-2008-0517-0515.
12-20
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
13. Plastics Molding and Forming (40 CFR Part 463)
EPA selected the Plastics Molding and Forming (PMF) Category for preliminary review
because it continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point
source category rankings (see Table 5-3 for the point source category rankings). The Final 2006
Plan summarizes the results of EPA's previous reviews of this industry in 2005 and 2006 (71 FR
76644). This section summarizes the results of the 2010 annual review associated with the PMF
Category. EPA focused on discharges of carbon disulfide from four cellulose products
manufacturers, because of their high TWPE relative to the rest of the PMF Category.
13.1 PMF Category Background
This subsection provides background on the PMF Category including a brief profile of
the PMF industry, background on 40 CFR Part 463,and background on 40 CFR Part 63 Subpart
UUUU, the Cellulose Products National Emission Standards for Hazardous Air Pollutants
(NESHAP).
13.1.1 PMF Industry Profile
The plastics molding and forming industry includes facilities that are engaged in
blending, molding, forming, or other types of processing of plastic materials. These processes
commonly include extrusion, coating and laminating, thermoforming, calendaring, casting,
foaming, cleaning, and finishing (U.S. EPA, 1984). EPA considered the following 13 North
American Industry Classification System (NAICS) codes part of the PMF Category:
• 325991: Custom Compounding of Purchased Resins;
• 326113: Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing;
• 326121: Unlaminated Plastics Profile Shape Manufacturing;
• 326122: Plastics Pipe and Pipe Fitting Manufacturing;
• 326130: Laminated Plastics Plate, Sheet (except Packaging), and Shape
Manufacturing;
• 326140: Polystyrene Foam Product Manufacturing;
• 326150: Urethane and Other Foam Product (except Polystyrene) Manufacturing;
• 326160: Plastics Bottle Manufacturing;
• 326191: Plastics Plumbing Fixture Manufacturing;
• 326199: All Other Plastics Product Manufacturing;
• 332813PMF: Electroplating, Plating, Polishing, Anodizing and Coloring;
• 335921: Fiber Optic Cable Manufacturing; and
• 339999PMF: All Other Miscellaneous Manufacturing.
Wastewater generated by facilities in NAICS codes 332813 and 339999 can be regulated
under multiple categories. EPA reviewed available information about pollutant loads and
manufacturing operations for facilities reporting these NAICS codes. In its crosswalk, EPA
assigned the extension "PMF" to the end of the NAICS codes for facilities that most likely fall
under the applicability of 40 CFR Part 463, PMF. Most facilities in NAICS 332813 are grouped
under the Electroplating Category, while most facilities in NAICS 339999 are grouped under the
Metal Finishing Category.
13-1
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the
discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by
Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release
Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent
NAICS code. Table 13-1 lists the number of facilities from the U.S. Economic Census and the
screening-level databases for the twelve NAICS codes with operations in the PMF Category, the
corresponding SIC codes are included for reference. The U.S. Economic Census includes more
facilities than the screening-level databases because of many possible factors including: facilities
may not meet TRI-reporting thresholds, facilities may discharge to a publicly owned treatment
works (POTW), and some facilities in the U.S. Economic Census are distributors or sales
facilities, not manufacturers.
13-2
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-1. Number of PMF Facilities
Number of Facilities
NAICS Code
Corresponding SIC
Code
2002 U.S.
Economic
Census
2008 DMR
Database"
2008 TRI
Database b
325991: Custom Compounding of
Purchased Resins
3087: Custom
Compounding of
Purchased Plastics
Resins
749
31
179
326113: Unlaminated Plastics Film and
Sheet (except Packaging) Manufacturing
3081: Unsupported
Plastics Film and Sheet
881
162
80
326121: Unlaminated Plastics Profile
Shape Manufacturing
670
47
326122: Plastics Pipe and Pipe Fitting
Manufacturing
441
48
326199: All Other Plastics Product
Manufacturing
3082: Unsupported
Plastics Profile Shapes;
3084: Plastics Pipe; and
3089: Plastics Products,
NEC
7,892
442
332813PMF: Electroplating, Plating,
Polishing, Anodizing and Coloring
NA
4
339999PMF: All Other Miscellaneous
Manufacturing
NA
219
1
326130: Laminated Plastics Plate, Sheet
(except Packaging), and Shape
Manufacturing
3083: Laminated Plastics
Plate, Sheet, and Profile
Shapes
293
9
66
326140: Polystyrene Foam Product
Manufacturing
552
26
326150: Urethane and Other Foam Product
(except Polystyrene) Manufacturing
3086: Plastics Foam
Products
627
39
212
326160: Plastics Bottle Manufacturing
3085: Plastics Bottles
404
32
3
326191: Plastics Plumbing Fixture
Manufacturing
3088: Plastics Plumbing
Fixtures
544
6
129
335921: Fiber Optic Cable Manufacturing
NA0
96
NA0
4
Total
>13,149
498
1,241
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008jv2; and TRlReleases2008_v3.
a - Includes both major and minor dischargers. Also, DMR data is reported by SIC code; therefore EPA used an
NAICS to SIC crosswalk for comparison purposes,
b - Facilities reporting releases to any media.
c - There is not an SIC code that links to the NAICS code 335921 with facilities that have discharges meeting the
applicability of the PMF Category.
NA - Not applicable.
NEC - Not elsewhere classified.
Table 13-2 shows whether permitting authorities designated direct discharging facilities
in the PMF Category as minor or major dischargers (see Section 4.1.5). EPA included data for
minor dischargers for the first time in the 2010 annual review, as part of DMRLoads2008_v2.
EPA does not require permitting authorities to submit DMR data for minor dischargers; however,
many states do provide complete DMR data for them. From this year's review, EPA observed
many data entry or other errors for minor dischargers in addition to those previously identified
13-3
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
for major dischargers, as discussed in Section 4.3. Table 13-2 shows that approximately 99
percent of the PMF Category dischargers in the 2008 DMR database are minor dischargers.
Table 13-2. Number of PMF Facilities by Discharge Classification in 2008 DMR Database
NAICS Codea
Number of Facilities in 2008 DMR Database
Majors
Dischargers
Minors
Dischargers
Total
325991: Custom Compounding of Purchased Resins
0
31
31
326113: Unlaminated Plastics Film and Sheet (except
Packaging) Manufacturing
3
159
162
326121: Unlaminated Plastics Profile Shape
Manufacturing
3
216
219
326122: Plastics Pipe and Pipe Fitting Manufacturing
326199: All Other Plastics Product Manufacturing
332813PMF: Electroplating, Plating, Polishing,
Anodizing and Coloring
339999PMF: All Other Miscellaneous Manufacturing
326130: Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
1
8
9
326140: Polystyrene Foam Product Manufacturing
0
39
39
326150: Urethane and Other Foam Product (except
Polystyrene) Manufacturing
326160: Plastics Bottle Manufacturing
0
32
32
326191: Plastics Plumbing Fixture Manufacturing
0
6
6
335921: Fiber Optic Cable Manufacturing
NA
NA
NA
Total
7
491 b
498
Source: DMRLoads2008_v2.
a - DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-code crosswalk for comparison
purposes.
b - The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the
facilities in the PMF Category, 99 of the 491 minor dischargers have DMR data.
NA - Not applicable. There is not an SIC code that links to the NAICS code 335921 with facilities that have
discharges meeting the applicability of the PMF Category.
Table 13-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of PMF facilities reporting to TRI do not report water discharges, but those that do
mostly reported indirect discharges to POTWs.
13-4
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-3. Number of PMF Facilities by Discharge Type in 2008 TRI Database
NAICS Code
Number of Facilities in 2008 TRI Database
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both Indirect
and Direct
Dischargers
No Water
Discharges
325991 Custom Compounding of Purchased Resins
13
27
8
131
326113 Unlaminated Plastics Film and Sheet
(except Packaging) Manufacturing
7
18
3
52
326121 Unlaminated Plastics Profile Shape
Manufacturing
1
6
0
40
326122 Plastics Pipe and Pipe Fitting
Manufacturing
0
1
0
47
326130 Laminated Plastics Plate, Sheet (except
Packaging), and Shape Manufacturing
1
4
1
60
326140 Polystyrene Foam Product Manufacturing
2
2
0
22
326150 Urethane and Other Foam Product (except
Polystyrene) Manufacturing
1
1
0
210
326160 Plastics Bottle Manufacturing
0
0
0
3
326191 Plastics Plumbing Fixture Manufacturing
2
0
0
127
326199 All Other Plastics Product Manufacturing
3
12
2
425
332813PMF Electroplating, Plating, Polishing,
Anodizing and Coloring
0
4
0
0
335921: Fiber Optic Cable Manufacturing
2
0
1
1
339999PMF All Other Miscellaneous
Manufacturing
0
1
0
0
Total
32
76
15
1,118
Source: TRIReleases2008 v3.
13.1.2 40 CFR Part 463
EPA first promulgated effluent limitation guidelines and standards (ELGs) for the PMF
Category (40 CFR Part 463) on December 17, 1984 (49 FR 49040). There are three
subcategories, all of which have best practicable control technology (BPT), new source
performance standards (NSPS), pretreatment standards for existing sources (PSES), and
pretreatment standards for new sources (PSNS) limitations. See Section 1 l.B of the Preliminary
2005 Review of Prioritized Categories of Industrial Dischargers (U.S. EPA, 2005a) for
additional details on the subpart applicability and discharge limitations and standards.
The remainder of this section focuses on cellulose manufacturing facilities because their
discharges remain the top concern for the PMF Category for the 2010 annual review, as they
were for the 2005 and 2006 annual reviews.
EPA determined in the 2005 and 2006 annual reviews that cellulose film and sponge
manufacturers were discharging large quantities of carbon disulfide (U.S. EPA, 2005a; U.S.
EPA, 2006). The carbon disulfide discharges from the manufacture of cellulose product are not
covered by Part 463 (the PMF Category). The product is made of regenerated cellulose using the
viscose process, and Part 463 specifically excludes products manufactured from regenerated
13-5
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
cellulose, as well as the molding and forming of regenerated cellulose (U.S. EPA, 1984). Further,
the Development Document for Effluent Limitations Guidelines and New Source Performance
Standards for the Plastics Molding and Forming Point Source Category states that 40 CFR Part
414, Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source Category, covers
only the manufacture of rayon, a regenerated cellulose fiber, and excludes the manufacture of
cellulose film, sponge, and meat casings (U.S. EPA, 1987; U.S. EPA, 2005b). Thus, wastewater
discharges from the manufacture of several cellulose products, including film, sponge, and meat
casings, are not covered by any existing categorical ELGs or pretreatment standards.
Additionally, neither PMF nor OCPSF regulate discharges of carbon disulfide, the pollutant of
concern for the cellulose products manufacturers identified in the annual reviews of the PMF
Category.
13.1.3 40 CFR Part 63 Subpart UUUU
On June 11, 2002, a NESHAP for Cellulose Products Manufacturing (40 CFR Part 63,
Subpart UUUU) was promulgated (67 FR 40055). The Cellulose Products Manufacturing
NESHAP regulated the Miscellaneous Viscose Processes and Cellulose Ethers Production
Categories. The Miscellaneous Viscose Process category includes cellulose food casings, rayon,
cellulosic sponge, and cellophane manufacturing facilities. The NESHAP established emissions
limits for hazardous air pollutants (HAPs), such as carbon disulfide, carbonyl sulfide, ethylene
oxide, methanol, methyl chloride, propylene oxide, and toluene. As a result, additional air
pollution control may be transferring more carbon disulfide to the water via scrubbers. For more
information on the Cellulose Products Manufacturing NESHAP see Section 15.1.3 of the
Technical Support Document for the 2006 Effluent Guidelines Program Plan (2006 Technical
Support Document) (U.S. EPA, 2006).
13.2 PMF Category 2010 Screening-Level Review
Table 13-4 compares the screening-level results for the PMF Category from the 2006
through 2010 annual reviews. The combined TWPE from discharges in the DMR and TRI
databases decreased from discharge years 2002 to 2007, but increased from discharge years 2007
to 2008. Both the 2008 DMR TWPE and 2008 TRI TWPE increased significantly from the
previous year. The increase in DMR TWPE is due to the addition of minor dischargers as part of
the 2010 annual review and data entry errors for chlorine and diethylhexyl phthalate discharges
(see Sections 13.4 and 13.6). The 2008 DMR TWPE accounts for approximately 70 percent of
the total category TWPE.
13-6
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-4. PMF Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews
Year of Discharge
Year of Review
PMF Category
TRI TWPE
DMR TWPE 11
Total TWPE
2002
2006
118,000
20,800
139,000
2004
2007
72,700
10,800
83,400
2005
2008
22,300
NA
NA
2007
2009
8,780
12,400
21,200
2008
2010
74,700
174,000
249,000
Source: TRIReleases2002_v4\ PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRlReleases2005_v2;
TRIReleases2007_v2', DMRLoads2007jv4\ TRIReleases2008_v3', and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 includes only major discharges. 2008 DMR data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 13-5 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (70 percent) of the TWPE in the 2008 DMR database is from minor
dischargers.
Table 13-5. PMF Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
121,000
52,900
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
13.3 PMF Pollutants of Concern
Table 13-6 lists the five pollutants with the highest TRI TWPE based on results from the
2010, 2009, and 2007 annual reviews (TRlReleases2008 _v3, TRIReleases2007_v2, and
TRIReleases2004 v3, respectively). Table 13-7 lists the five pollutants with the highest DMR
TWPE based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2,
DMRLoads2007_v3, and PCSLoads2004 \>4, respectively).
13-7
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-6. PMF Category Top TRI Pollutants
2004 TRI Databasea
2007 TRI Database"
2008 TRI Database"
Pollutant
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Carbon Disulfide
1
5
65,400
1
3
6,950
1
4
73,100
Nitrate Compounds
4
11
354
3
10
360
2
11
302
Lead and Lead Compounds
5
56
350
2
46
660
3
37
275
Butyraldehyde
Pollutants not reported in the top five
4
2
310
4
2
188
Diethylhexyl Phthalate
2004 TRI reported pollutants.
5
8
121
5
8
157
Dioxin and Dioxin-like
Compounds
2
1
5,410
Pollutants not reported in the top five
2007 TRI reported pollutants.
Pollutants not reported in the top five
2008 TRI reported pollutants.
Formaldehyde
3
4
389
PMF Category Total
NA
154 b
76,700
NA
121 b
8,780
NA
123 b
74,700
Source: TRIReleases2004_v3, TRIReleases2007_v2; and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
13-8
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-7. PMF Category Top DMR Pollutants
Pollutant
2004 DMR Database"
2007 DMR Databasea
2008 DMR Databasea
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Chlorine
Pollutant not reported in the top five
2004 DMR reported pollutants.
Pollutant not reported in the top five
2007 DMR reported pollutants.
1
13
79,600
Carbon Disulfide
1
1
9,780
1
1
11,800
2
1
52,000
Diethylhexyl Phthalate
Pollutant not reported in the top five
2004 DMR reported pollutants.
Pollutant not reported in the top five
2007 DMR reported pollutants.
3
2
40,200
Copper
2
3
187
4
2
114
4
12
1,120
Sulfate
3
1
185
2
1
175
5
2
175
Ammonia as Nitrogen
Pollutants not reported in the top five
2004 DMR reported pollutants.
3
4
121
Pollutants not reported in the top five
2008 DMR reported pollutants.
Cadmium
5
2
46
Nitrogen, Ammonia
4
5
182
Pollutants not reported in the top five
2007 DMR reported pollutants.
Nitrogen, Nitrate (Total As N)
5
1
106
PMF Category Total
NA
7C
10,800
NA
6 c
12,400
NA
35 c
174,000
Source: PCSLoads2004_v4; DMRLoads2007_v3; and DMRLoads2008_v2.
a - 2004 and 2007 DMR data include only major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
13-9
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
The PMF Category combined TWPE is dominated by carbon disulfide discharges,
accounting for approximately 61 percent of the combined TWPE. Therefore, EPA focused the
preliminary category review on carbon disulfide discharges from TRI and DMR along with the
other top DMR-reported pollutants that account for the majority of the category TWPE.
Chlorine is the top DMR-reported pollutant in 2008, followed by carbon disulfide and
diethylhexyl phthalate. EPA's additional review for chlorine, diethylhexyl phthalate, and carbon
disulfide, the pollutants of concern, is presented in the following subsections. EPA did not
investigate the other top pollutants as part of the 2010 annual review because they account for a
small percentage (1 percent) of the 2008 PMF Category combined DMR and TRI TWPE.
13.4 PMF Category Chlorine Discharges in DMR
As part of the 2010 annual review of the PMF Category, EPA reviewed chlorine
discharges in the 2008 DMR database. Approximately 46 percent of the 2008 DMR TWPE is
from chlorine discharges. Table 13-8 presents the chlorine discharges from PMF facilities in the
2008 DMR database. Kinetico Inc., in Newberry, OH, accounts for 99 percent of the chlorine
discharges in the 2008 DMR database for the PMF Category. This subsection provides
information on Kinetico's chlorine discharges.
Table 13-8. PMF Category Chlorine Discharging Facilities in 2008 DMR Database
Facility Name
Pounds of Chlorine
Discharged
Chlorine TWPE
Percentage of PMF
Category's 2008
DMR Chlorine
TWPE
Kinetico, Inc.
159,000
79,500
99%
Remaining PMF Chlorine Dischargers a
200
100
1%
Total
159,000
79,600
100%
Source: DMRLoads2008_v2.
a - There are 25 remaining PMF facilities that have chlorine discharges in DMRLoads2008_v2 that account for
about 1 percent of the PMF Category's 2008 chlorine TWPE.
Kinetico discharges chlorine from outfalls 001 and 003. The majority of the chlorine
discharges from Kinetico are from outfall 003 (99.9 percent). Table 13-9 presents Kinetico's
2008 monthly discharge data in the DMR Loadings Tool for outfall 003. EPA compared the
concentration and flow data from the DMR Loadings Tool to the data in Envirofacts22 and
determined that there is a unit of measurement error for the outfall 003 flows. The flows in the
DMR Loadings Tool were 1,000,000 times higher than the data in Envirofacts, also presented in
Table 13-9. Using the outfall 003 flows from Envirofacts, Kinetico's chlorine discharges are
0.159 pounds and 0.079 TWPE for 2008, reducing the facility's total TWPE by 99 percent. This
reduction in TWPE decreases the PMF Category's 2008 DMR TWPE by 79,500 TWPE.
22 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts
continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not
continuously updated; therefore, loads may be estimated with erroneous data.
13-10
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-9. Kinetico, Inc. 2008 Monthly Chlorine and Flow Discharge Data
Outfall
Monitoring
Period Date
NODI
Codea
DMR Loadings Tool
Maximum Chlorine
Concentration (mg/L)
DMR Loadings Tool
Flow (MGD)
EPA Envirofacts Flow
(MGD)
003
31-May-08
Q
377
0.000378
003
30-Jun-08
Q
297
0.000297
003
31-Jul-08
Q
305
0.000304
003
31-Aug-08
Q
289
0.000289
003
30-Sep-08
0.1
529
0.000529
003
31-Oct-08
Q
391
0.000391
Source: DMR Loadings Tool and Envirofacts.
a - NODI Code Q means that the concentration is not quantifiable.
13.5 PMF Category Carbon Disulfide Discharges in DMR and TRI
The 2010 annual review of the PMF Category focused on carbon disulfide discharges in
the 2008 DMR and TRI databases. Carbon disulfide discharges accounted for 50 percent of the
combined 2008 DMR and TRI TWPE for the PMF Category. This subsection provides
information on the manufacture of regenerated cellulose products because this industry segment
is responsible for the PMF Category carbon disulfide discharges. This subsection also includes
information on the top carbon disulfide facilities in the 2008 DMR and TRI databases, including
wastewater sources and treatment.
13.5.1 Regenerated Cellulose Products
As part of the 2005 annual review, EPA determined that the carbon disulfide discharges
come from facilities that manufacture regenerated cellulose products, such as cellophane,
cellulosic sponge, and meat casings (U.S. EPA, 2005a). For the 2006 annual review, EPA
reviewed a study of the cellulose products manufacturing facilities that was written in support of
the Cellulose Products Manufacturing NESHAP. The information gathered during the study is
summarized in the memorandum Industry Profile of Cellulose Products Manufacturing Facilities
in the U.S. (Schmidtke, 2000). The findings regarding the regenerated cellulose industry from the
2006 annual review are summarized below. See Section 15.5.1 in the 2006 Technical Support
Document (U.S. EPA, 2006) for additional details.
The viscose process is used to manufacture cellulose film, sponge, meat casings, and
rayon. In the viscose process, sheets of dissolving-grade cellulose pulp are saturated with caustic
to convert the cellulose into alkali cellulose. The alkali cellulose is pressed to remove the excess
caustic and is shredded to increase the surface area for easier processing. After shredding, the
alkali cellulose resembles "white crumbs." The alkali cellulose partially oxidizes and degrades
by aging in ambient air. Gaseous carbon disulfide is mixed with the aged alkali cellulose in a
vessel to form sodium cellulose xanthate, resembling "yellow crumbs." The sodium cellulose
xanthate is dissolved in aqueous caustic solution, creating the viscose solution. The viscose
solution is ripened, filtered, degassed, and extruded and then sulphuric acid is added to the
viscose solution to form regenerated cellulose (Schmidtke, 2000). The manufacture of rayon,
cellophane, and meat casings differ in the type of extrusion dye and the post-regeneration
processing, which includes at least washing and bleaching.
13-11
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
The manufacture of cellulosic sponge differs slightly. The sheets of dissolving-grade pulp
are converted into alkali cellulose, followed by xanthation into sodium cellulose xanthate using
carbon disulfide, and formation of the viscose solution. The viscose solution is then mixed with
sodium sulphate crystals, other fibers, and dyes. The mixture is poured into a mold or extruded
under high temperature to melt the sodium sulphate crystals, leaving the pores characteristic of
sponges. The remaining processing of the cellulose sponges includes bleaching, washing,
cutting, and possibly packaging. Some facilities that manufacture sponges do not make viscose
and thus do not use carbon disulfide. Instead they purchase blocks of hardened viscose that they
dissolve to form the softened viscose for processing (Schmidtke, 2000).
13.5.2 Regenerated Cellulose Facility Information
EPA identified cellulose products manufacturers in the United States using the TRI and
DMR databases and data from a study of the cellulose products manufacturing industry
conducted by EPA's Office of Air Quality Planning and Standards (OAQPS) during their
development of NESHAP regulations (Schmidtke, 2000). Table 13-10 lists the six U.S. cellulose
products manufacturers identified in the PMF Category. There may be additional cellulose
manufacturing facilities in the United States not included in the available sources.
In addition, rayon manufacturers are not discussed in this section. Their manufacturing
process is identical to other cellulose manufacturing processes, but they form fibers instead of
sheets, tubes, or sponges. However, these manufacturers are regulated under Part 414: OCPSF.
OCPSF does not regulate carbon disulfide discharges.
Four of the six facilities reported wastewater discharges of carbon disulfide to TRI in
2008, and one of the 2008 TRI facilities also has discharges of carbon disulfide in the 2008 DMR
database. Although all six regenerated cellulose facilities have National Pollutant Discharge
Elimination System (NPDES) permit IDs, there are data for only three of them in the 2008 DMR
database. Table 13-11 presents the total pollutant discharges for the regenerated cellulose
facilities in the 2008 TRI and DMR databases, along with the discharges of carbon disulfide.
Table 13-11 excludes the 3M Corporation facilities in Elyria, OH and Prairie du Chi en, WI
because these facilities do not have data for 2008 in PCS or ICIS-NPDES and TRI.
EPA reviewed additional information on two of the facilities reporting carbon disulfide
discharges in 2008, Innovia Films in Tecumseh, KS and Viskase in Loudoun, TN. Specific
information regarding these facilities is presented in the following subsections.
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-10. Cellulose Manufacturers in the United States a
TRI ID
(NPDES ID)
Facility Name
Facility Location
Product Type
Discharge
Type
Permit Notes
66542FLXLN6000S
(KS0003204)
Innovia Films Inc.
Tecumseh, KS
Cellophane
Direct
Carbon disulfide monitoring required after
activated sludge basin because it inhibits the
biological process at concentrations above 35
mg/L. Facility must notify regulators if carbon
disulfide exceeds 17.5 mg/L.
61832TPKNC915NM
(ILR000333)
ViscofanUSA Inc.
Danville, IL
Meat Casings
Indirect
Facility only has a general storm water permit; the
facility discharges process wastewater indirectly.
37774VSKSCEASTL
(TN0001457)
Viskase
Corporation
Loudon, TN
Meat Casings
Indirectb
Permit limits are based on state regulations and
treatability.
72370VSKSCRT198
(AR0036544)
Viskase
Corporation
Osceola, AR
Meat Casings
Direct
Facility is a minor discharge facility.
14150GNRLM305SA
(NYR00D034)
3M Corporation
Tonawanda, NY
Cellulosic Sponges
Indirect
Facility does not have DMR data because it
discharges indirectly. No permit available.
44035NYLNG1301L
(NA)
3M Corporation
Elyria, OH
Cellulosic Sponges
Unknown
Does not report discharges to PCS or ICIS-
NPDES. Does not report wastewater discharges to
TRI. No permit available.
53821MCMPN217NO
(NA)
3M Corporation
Prairie du Chien,
WI
Cellulosic Sponges
Indirect
Does not report discharges to PCS or ICIS-
NPDES. Does not report wastewater discharges to
TRI after 2001. No permit available.
38402SPNTXSANTA
(TN0001571)
Spontex Inc.
Columbia, TN
Cellulosic Sponges
Direct
Permit writer used OCPSF Subpart D -
Thermoplastic Resins BPT limitations for NPDES
permit. The permit writer did not apply BAT
limitations because the facility produced less than 5
million pounds of product per year.
Source: Company Websites (Devro, Unknown; Innovia Films, 2004; Spontex, 2004; Viskase, 2002); TRIReleases2002_4\ TRIReleases2003_2; Facility NPDES
Permits (TDEC, 2002; IEPA, 2003; KDHE, 2005; ADEQ, 2000; TDEC, 2005); and Industry Profile of the Cellulose Products Manufacturing Facilities in the
U.S. (Schmidtke, 2000).
a - Rayon is included in cellulose manufacturers; however, these facilities are not presented in this table. Wastewater discharges from rayon manufacturing are
covered under the OCPSF Category (40 CFR Part 414).
b - EPA believes the facility is an indirect discharger because the facility reports POTW transfers and not surface water releases to TRI. DMR does not contain
data for this facility, although they have a NPDES permit that expired in December 2006. EPA believes they began discharging only to a POTW sometime after
1991.
NA - Not applicable.
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
Table 13-11. 2008 TRI and DMR Discharges for Cellulose Products Manufacturing Facilities
Facility Name
2008 TRI
2008 DMR
Total Pounds
Discharged"
Total TWPE
Carbon
Disulfide
Pounds
Discharged"
Carbon
Disulfide
TWPE
Total Pounds
Discharged
Total TWPE
Carbon
Disulfide
Pounds
Discharged
Carbon
Disulfide
TWPE
Innovia Films Inc.
Tecumseh, KS
38,300
55,600
19,900
55,600
84,400,000
52,200
18,600
52,000
ViscofanUSA Inc.
Danville, IL
6,890
10,800
3,810
10,800
NA
NA
NA
NA
Viskase Corporation
Loudon, TN
1,990
5,540
1,920
5,380
NA
NA
NA
NA
Viskase Corporation
Osceola, AR
14,800
1,330
470
1,320
241,000
122
NR
NR
3M Corporation
Tonawanda, NY
768
2,150
NR
NR
NA
NA
NA
NA
Spontex Inc.
Columbia, TN
219
613
NR
NR
40,900
14.4
NR
NR
Source: TRlReleases2008_v3 and DMRLoads2008jv2.
a - Discharges include transfers to POTWs and account for POTW removals (i.e., the amount shown assumes that the POTW removed some of the pollutant).
NA - Not applicable. These facilities are indirect dischargers.
NR - Not reported.
13-14
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
13.5.2.1 Innovia Films in Tecumseh, KS
EPA reviewed the carbon disulfide discharges from Innovia Films in Tecumseh, KS as
part of the 2010 annual review because this facility has the largest discharge of carbon disulfide
in the 2008 TRI and DMR databases. The pounds of carbon disulfide reported in 2008 TRI is
close to the annual pounds discharged calculated in 2008 DMR database. Innovia Films
estimated their carbon disulfide releases based on periodic monitoring data. EPA believes that
Innovia Films used their carbon disulfide DMR data to report to TRI. Therefore, EPA reviewed
the 2008 DMR carbon disulfide discharges from Innovia Films only as part of the 2010 annual
review.
During the 2006 annual review, EPA reviewed carbon disulfide discharges for Innovia
Films. EPA contacted Innovia Films, because it was the only facility reporting discharges of
carbon disulfide for the PMF Category in the 2002 DMR database. The facility provided
corrections to the effluent carbon disulfide concentrations, and EPA corrected the estimated
pounds of pollutant discharged. The facility contact indicated that the carbon disulfide discharges
reported resulted from wet scrubbing of the gaseous by-products (Martin, 2006).
Table 13-12 presents the carbon disulfide discharge data in the DMR Loadings Tool for
2008 along with the facility-corrected carbon disulfide data from 2006, for comparison purposes.
The carbon disulfide concentrations and discharge flows for 2008 are similar to the corrected
2006 data. Therefore, EPA determined that the data are likely accurate, and Innovia Films is
likely discharging more than 18,000 pounds of carbon disulfide from Outfall 001 annually.
Table 13-12. Innovia Films 2008 Monthly Carbon Disulfide Discharge Data
Outfall
Monitoring
Period Date
2006 Facility-
Provided Carbon
Disulfide
Concentration
(mg/L)
2008 DMR
Loadings Tool
Carbon Disulfide
Concentration
(mg/L)
2006 Facility-
Provided Flow
(MGD)
2008 DMR
Loadings Tool
Flow (MGD)
001
31-Jan-08
2.39
2.03
1.94
1.90
001
29-Feb-08
3.41
4.98
2.03
1.98
001
31-Mar-08
0.362
9.48
2.02
2.08
001
31-May-08
0.072
0.747
2.06
1.78
001
30-Jun-08
0.019
0.557
2.08
1.96
001
31-Jul-08
0.005
0.368
1.87
1.68
001
31-Aug-08
0.022
0.75
1.74
1.91
001
30-Sep-08
0.028
5.76
1.96
2.01
001
31-Oct-08
0.095
0
1.93
1.79
001
30-Nov-08
0.609
8.34
2.03
1.71
001
31-Dec-08
2.39
2.15
1.94
1.80
Source: DMR Loading Tool and Facility Contact (Martin, 2006).
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
13.5.2.2 Viskase Corporation in Loudoun, TN
The Viskase facility in Loudoun, TN manufactures cellulose casings and discharges
water to the adjacent POTW. The facility consistently reports releases of approximately 100,000
pounds of carbon disulfide to the POTW (based on TRI data from 2005 through 2008).
As part of its reviews, EPA contacted the facility and the POTW receiving the facility's
wastewater in 2009. The facility contact indicated that they estimate their discharges of carbon
disulfide for TRI using sampling data that is collected every two or three years. The POTW
contact indicated that in addition to Viskase sampling at the point where the discharge leaves the
facility, the POTW samples for carbon disulfide when the discharge enters the POTW facility
from a pipe connecting the two adjacent properties. The combined data show that the facility
releases close to 100,000 pounds of carbon disulfide to the POTW, but the POTW receives less
than 3,000 pounds from the discharge pipe. This decrease in pollutant load suggests the possible
volatilization of 97,000 pounds of carbon disulfide within the discharge pipe, but warrants
further investigation (Birkholtz, 2009; Glarrow, 2009; U.S. EPA, 2009).
The data in TRIReleases2008 v3 are consistent with the information collected from the
facility and POTW. As a result, no corrections were made to the 2008 TRI data.
13.5.3 Wastewater Sources of Carbon Disulfide
At cellulose products manufacturing facilities, the main wastewater sources of carbon
disulfide include railcar unloading, carbon disulfide storage, and air pollution control
(Schmidtke, 2000).
Carbon disulfide gas is delivered to most cellulose products facilities by railcar.
Unloading the railcar requires filling it with water or nitrogen to displace the carbon disulfide
into the storage tank. Facilities using water displacement generate carbon-disulfide-saturated
wastewater during railcar unloading, which is sent to the facility's wastewater treatment system.
Facilities using nitrogen displacement do not produce the carbon-disulfide-saturated wastewater
during railcar unloading. EPA determined that Spontex Inc. was the only facility of the eight
listed in Table 13-10 that uses water to displace carbon disulfide during unloading as of 2000
(Schmidtke, 2000).
Carbon disulfide storage tanks are typically submerged under water in a concrete-lined
pool. This allows any carbon disulfide leaks to collect in the bottom of the pool to avoid
atmospheric releases. In addition to the underwater storage, the tanks have a water or nitrogen
padding system to fill the headspace in the tank and further prevent contact with oxygen. The
padding is in direct contact with the carbon disulfide, creating wastewater saturated with carbon
disulfide if a water padding system is used. The water padding in the storage tank is displaced
into the water pool when the storage tanks are filled. Displaced water in the pool and water
padding is sent to the wastewater treatment system. As of 2000, EPA determined that, of the
facilities listed in Table 13-10, only Viscofan USA Inc, 3M Corporation Tonawanda, and
Spontex Inc. use a water padding system (Schmidtke, 2000).
Gaseous by-products in the regeneration of cellulose, including hydrogen sulfide and
carbon disulfide, are off-gassed from the process equipment. Pollutants in the vented gas can be
removed via a wet gas scrubber, which uses an aqueous solution to remove the air pollutants.
13-16
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
The wet scrubber removal efficiency for carbon disulfide is low but the scrubber effluent may
contain some carbon disulfide (Schmidtke, 2000). Discharges reported by Innovia Films Inc. are
due to wet scrubbing of the gaseous by-products (Martin, 2006).
13.5.4 Regenerated Cellulose Wastewater Treatment
Table 13-13 summarizes the wastewater treatment known to be used by cellulose
products manufacturing facilities.
Table 13-13. Cellulose Products Facilities Wastewater Treatment
Product
Number of
Facilities
Prctrcatmcnt Used by
Indirect Dischargers
Treatment Used bv Direct
Dischargers
Cellophane
1
NA
Neutralization, settling, equalization,
second neutralization, aeration, and
clarification.
Food Casings
3
Neutralization, potential
filtration and settling.
Achieved carbon disulfide
(CS2) concentrations of 5-
20 parts per million (ppm).
Neutralization using lime, equalization,
and clarification.
Cellulosic
Sponges
4
Neutralization and
oxidization
Equalization, aeration, and clarification.
Source: Industry Profile of the Cellulose Products Manufacturing Facilities in the U.S. (Schmidtke, 2000).
NA - Not applicable.
13.6 PMF Category Diethylhexyl Phthalate Discharges in DMR
As part of the 2010 annual review of the PMF Category, EPA reviewed diethylhexyl
phthalate discharges in the 2008 DMR database. Approximately 30 percent of the 2008 DMR
TWPE results from diethylhexyl phthalate discharges. Table 13-14 presents the facilities in 2008
DMR that discharge diethylhexyl phthalate. One facility, Flexco Corp. in Tuscumbia, AL,
accounts for over 99 percent of the discharges in the 2008 DMR. This subsection provides
information on Flexco's diethylhexyl phthalate discharges.
Table 13-14. PMF Category Diethylhexyl Phthalate Discharging Facilities in 2008 DMR
Database
Facility Name
Major/Minor
Facility Discharger
Pounds of
Dicthyhcxyl
Phthalate
Discharged
Dicthyhcxyl
Phthalate TWPE
Percentage of PMF
Category
Dicthyhcxyl
Phthalate TWPE
Flexco Corp.
Minor
969,000
40,200
>99%
DuPont Teijin Films
Major
9.7
2.3
<1%
Total
969,000
40,200
100%
Source: DMRLoads2008 v2.
All of Flexco's diethylhexyl phthalate discharges are from outfall 003. Table 13-15
presents Flexco's 2008 diethylhexyl phthalate discharge data from the DMR Loadings Tool.
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
EPA contacted Flexco to verify the 2008 diethylhexyl phthalate discharges in the DMR Loadings
Tool. The facility contact confirmed that the November 2009 sample concentration was below
detection and should have been reported as NODI Code B (below the detection limit) (Blazer,
2010). Because all of the facility diethylhexyl phthalate concentrations were below detection, the
facility's revised diethylhexyl phthalate load and TWPE are zero, reducing the facility's total
TWPE by 100 percent. This reduction in TWPE decreases the PMF Category's 2008 DMR
TWPE by 40,200 TWPE.
Table 13-15. Flexco Corp. 2008 Monthly Diethylhexyl Phthalate Discharge Data
Outfall
Monitoring Period
Date
NODI Codea
Diethylhexyl Phthalate
Maximum Concentration
(mg/L)
Average Flow
(MGD)
003
31-Jan-08
B
0.173
003
29-Feb-08
B
0.173
003
31-Mar-08
B
0.173
003
31-May-08
B
0.173
003
30-Jun-08
B
0.173
003
31-Jul-08
B
0.258
003
31-Aug-08
B
0.305
003
30-Sep-08
B
0.283
003
31-Oct-08
B
0.283
003
30-Nov-08
109
0.475
003
31-Dec-08
B
0.493
Source: DMR Loadings Tool,
a - Below the detection limit.
13.7 PMF Category Conclusions
The estimated toxicity of the PMF Category discharges result mainly from the carbon
disulfide discharges of regenerated cellulose facilities (accounting for 50 percent of the
category's 2008 combined DMR and TRI TWPE). Data collected for the 2010 annual review
demonstrated that wastewater discharge characteristics for this category are consistent with
discharges from prior years. As in prior years, EPA makes the following conclusions:
• Database errors for discharges of chlorine were identified. After correcting these
errors, the PMF Category total chlorine TWPE decreased by 99 percent, from
79,600 to 100 TWPE.
• Database errors for discharges of diethylhexyl phthalate were identified. After
correcting these errors, the PMF Category total diethylhexyl phthalate pounds and
TWPE decreased to zero (a decrease of 100 percent).
• Carbon disulfide discharges from cellulose manufacturers were identified as a
possible concern. Carbon disulfide discharges are not regulated by the PMF
ELGs. The OCPSF Category does not regulate carbon disulfide for rayon
manufacturers. Therefore, carbon disulfide discharges from cellulose
manufacturers are not regulated under any ELGs.
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
• From available data, 50 percent of regenerated cellulose manufacturers (excluding
rayon fiber facilities) discharge directly to surface waters; 50 percent discharge to
POTWs.
• Many regenerated cellulose facilities do not have permit limits for carbon
disulfide but are required to monitor for it. The facilities that monitor carbon
disulfide are reporting discharges at measurable concentrations, above the
detection limit.
• Based on the 2010 annual review, EPA intends to conduct an expanded
preliminary category review of carbon disulfide discharges as part of the
2011/2012 planning cycle.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2009 annual review of existing ELGs).
13.8 PMF Category References
1. ADEQ. 2000. Arkansas Department of Environmental Quality. National Pollution
Discharge Elimination System Permit Application NPDES - AR0036544 - Viskase
Corporation, Osceola, AR. Little Rock, AR. (December, 31). EPA-HQ-OW-2004-0032-
1205.
2. Birkholtz, Dave. 2009. Telephone conversation with Dave Birkholtz of City of Loudoun,
TN POTW and Eleanor Codding of Eastern Research Group, Inc. "Carbon Disulfide
Discharges Reported to TRI by Viskase Facility in Loudoun, TN." (March 12). EPA-HQ-
OW-2008-0517 DCN 07300.
3. Blazer, Don. 2010. E-mail communication with Don Blazer of Flexco Corp. in
Tuscumbia, AL and Elizabeth Sabol of Eastern Research Group, Inc. "Flexco Corp.
DMR Clarification." (July 8). EPA-HQ-OW-2008-0517 DCN 07301.
4. Devro. Unknown. Product Availability. Available online at:
http://www.devro.plc.uk/products/index.htm. Date accessed: June 22, 2005. EPA-HQ-
OW-2004-0032-0259.
5. Glarrow, Patrick. 2009. Telephone communication with Patrick Glarrow of Viskase in
Loudoun, TN and Eleanor Codding of Eastern Research Group, Inc. "Carbon Disulfide
Discharges Reported to TRI by Viskase Facility in Loudoun, TN." (March 10). EPA-HQ-
OW-2008-0517-0074.
6. IEPA. 2003. Illinois Environmental Protection Agency Division of Water Pollution
Control. General NPDES Permit for Storm Water Discharges from Industrial Activities.
Springfield, IL. EPA-HQ-OW-2004-0032-1209.
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
7. Innovia Films. 2004. Company Profile. Available online at:
http://www.innoviafilms.com/corporate/profile.htm. Date accessed: June 22, 2005. EPA-
HQ-OW-2004-0032-0261.
8. KDHE. 2005. Kansas Department of Health and Environment. Kansas Water Pollution
Control Permit and Authorization to Discharge Under NPDES KS0003204 - Innovia
Films, Tecumseh, KS. Topeka, KS. (December 5). EPA-HQ-OW-2004-0032-1210.
9. Martin, Tony. 2006. Telephone conversation with Tony Martin of Innovia Films Inc. and
Jessica Wolford of Eastern Research Group, Inc. "Discussion of Carbon Disulfide
Discharges for Innovia Films Inc. (KS0003204)." (April 27). EPA-HQ-OW-2004-0032-
2324.
10. Schmidtke, Karen and Thomas Holloway. 2000. Industry Profile of the Cellulose
Products Manufacturing Facilities in the U.S. Preparedfor U.S. EPA National Emissions
Standards for Hazardous Air Pollutants: Cellulose Products Manufacturing. Cary, NC.
(April 11). EPA-HQ-0AR-2003-0193-0004.
11. Spontex. 2004. MAPA Spontex, Inc. Wiping Products. Available online at:
http://www.spontexusa.com/products.cfm?PRTID=l. Date accessed: June 22, 2005.
EPA-HQ-OW-2004-0032-0269.
12. TDEC. 2002. Tennessee Department of Environment and Conservation. State of
Tennessee National Pollutant Discharge Elimination System Permit NPDES TN0001457
- Viskase Corporation, Loudon, TN. Nashville, TN. EPA-HQ-OW-2004-0032-1207.
13. TDEC. 2005. Tennessee Department of Environment and Conservation. State of
Tennessee National Pollutant Discharge Elimination System Permit NPDES Permit
TN0001571 - Spontex Inc., Columbia, TN. Nashville, TN. 2005. EPA-HQ-OW-2004-
0032-1208.
14. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
15. U. S. EPA. 1984. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Plastics Molding and Forming Point Source
Category. EPA 440/1-84/069. Washington, DC. (December).
16. U. S. EPA. 1987. Development Document for Effluent Limitations Guidelines and
Standards for the Organic Chemical, Plastics, and Synthetic Fibers Point Source
Category - Final. EPA 4401-87-009. Washington, DC. (October).
17. U.S. EPA. 2005a. Preliminary Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-
0053.
13-20
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Section 13 - Plastics Molding and Forming (40 CFR Part 463)
18. U. S. EPA. 2005b. Product and Product Group Discharges Subject to Effluent Limitations
and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers Point Source
Category - 40 CFR 414. Washington, DC. EPA-HQ-OW-2004-0032-0941.
19. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821 -R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-
2782.
20. U. S. EPA. 2009. Technical Support Document for the Preliminary 2010 Effluent
Guidelines Program Plan. EPA-821-R-09-006. Washington, DC. (October). EPA-HQ-
OW-2008-0517-0515.
21. Viskase. 2002. Viskase Companies, Inc. Viskase Casing Solutions Worldwide. Available
online at: http://www.viskase.com/. Date accessed: June 22, 2005. EPA-HQ-OW-2004-
0032-0264.
13-21
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Section 14 - Textile Mills (40 CFR Part 410)
14. Textile Mills (40 CFR Part 410)
EPA selected the Textile Mills (Textiles) Category for preliminary review because it
continues to rank high, in terms of toxic-weighted pound equivalent (TWPE), in point source
category rankings (see Table 5-3 for the point source category rankings). This industry was
reviewed previously in EPA's Preliminary and Final 2006 Effluent Guidelines Program Plans
and the Preliminary 2008 Effluent Guidelines Program Plan (U.S. EPA, 2005; U.S. EPA, 2006;
U.S. EPA, 2007). This section summarizes the 2010 annual review associated with the Textiles
Category. EPA focused on discharges of mercury, aluminum, toxaphene, sulfide, and aldrin,
because of their high TWPE relative to other pollutants in the Textiles Category.
14.1 Textiles Category Background
This subsection provides background on the Textiles Category including a brief industry
profile of the textiles industry and background on 40 CFR Part 410.
14.1.1 Textiles Industry Profile
The Textiles Category includes facilities that manufacture and process textile materials,
such as carpets, broad woven fabrics, and knitwear. It also includes facilities using wet
processes, such as scouring, dyeing, finishing, printing, and coating, which discharge contact
wastewater. EPA considered the following 21 North American Industry Classification System
(NAICS) codes as part of the Textiles Category:
313111: Yarn Spinning Mills;
313112: Yarn Texturizing, Throwing, and Twisting Mills;
313113: Thread Mills;
313210: Broadwoven Fabric Mills;
313221: Narrow Fabric Mills;
313230: Nonwoven Fabric Mills;
313241: Weft Knit Fabric Mills;
313249: Other Knit Fabric and Lace Mills;
313311: Broadwoven Fabric Finishing Mills;
313312: Textile and Fabric Finishing (except Broadwoven Fabric) Mills;
313320: Fabric Coating Mills;
314110: Carpet and Rug Mills;
314992: Tire Cord and Tire Fabric Mills;
314999: All Other Miscellaneous Textile Product Mills;
315111: Sheer Hosiery Mills;
315119: Other Hosiery and Sock Mills;
315191: Outerwear Knitting Mills;
315192: Underwear and Nightwear Knitting Mill s;
315992: Glove and Mitten Manufacturing.
315999: Other Apparel Accessories and Other Apparel Manufacturing; and
336360: Motor Vehicle Seating and Interior Trim Manufacturing.
This list of Standard Industrial Classification (SIC) codes includes facilities that EPA
determined are potential new subcategories to the Textiles Category. As part of the 2004 annual
review, EPA reviewed industries with SIC codes not clearly subject to existing effluent
14-1
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Section 14 - Textile Mills (40 CFR Part 410)
limitation guidelines and standards (ELGs). EPA concluded that the processes, operations,
wastewaters, and pollutants of facilities in the following SIC codes are similar to those of the
Textiles Category (U.S. EPA, 2004):23
• 2322: Men's and Boys' Underwear and Nightwear;
• 2396: Automotive Trimmings, Apparel Findings, and Related Products; and
• 2399: Fabricated Textile Products, Not Elsewhere Classified.
As part of the 2009 annual review, EPA reclassified these SIC codes as equivalent NAICS codes
for use with the U.S. Economic Census and Toxics Release Inventory (TRI) data that are
reported by NAICS code. However, there is not a direct relationship between one SIC and one
NAICS code. As a result, EPA included the following NAICS codes in the 2010 annual review
of the Textiles Category because they contain facilities with operations that are similar to the SIC
codes above:
• 314999: All Other Miscellaneous Textile Product Mills; and
• 336360: Motor Vehicle Seating and Interior Trim Manufacturing.
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the
discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by
SIC code, and the U.S. Economic Census and TRI report data by NAICS code, EPA reclassified
the 2008 DMR by the equivalent NAICS code. Table 14-1 lists the number of facilities from the
U.S. Economic Census and the screening-level databases for the 21 NAICS codes with
operations in the Textiles Category, the corresponding SIC codes are included for reference. The
U.S. Economic Census includes more facilities than the screening-level databases because of
many possible factors including: facilities may not meet TRI-reporting thresholds, facilities may
discharge to a publicly owned treatment works (POTW), and some facilities in the U.S.
Economic Census are distributors or sales facilities, not manufacturers.
23 The tables in this section include discharge information from facilities reporting these SIC codes and the
corresponding NAICS codes; however, these facilities contribute negligible amounts of TWPE. Consistent with the
conclusions drawn during the 2004 annual review (U.S. EPA, 2004) and the 2006 review (U.S. EPA, 2006), EPA
found that large numbers of these facilities discharge no wastewater and only a small number of facilities discharge
TWPE greater than zero.
14-2
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-1. Number of Textiles Facilities
NAICS Code
Corresponding SIC Code
Number of Facilities
2002 U.S.
Economic
Census
2008
DMR
Database"
2008
TRI
Database b
313111: Yarn Spinning Mills
2211: Broadwoven Fabric Mills,
Cotton;
2221: Broadwoven Fabric Mills,
Manmade Fiber and Silk;
2231: Broadwoven Fabric Mills, Wool;
2241: Narrow Fabric and Other
Smallware Mills: Cotton, Wool, Silk,
and Manmade Fiber;
2251: Women's Full-Length and Knee-
Length Hosiery, Except Socks;
2252: Hosiery, NEC;
2253: Knit Outerwear Mills;
2254: Knit Underwear and Nightwear
Mills:
2257: Weft Knit Fabric Mills;
2258: Lace and Warp Knit Fabric
Mills:
2259: Knitting Mills, NEC
2261: Finishers of Broadwoven Fabrics
of Cotton;
2262: Finishers of Broadwoven Fabrics
of Manmade Fiber and Silk;
2269: Finishers of Textiles, NEC;
2281: Yarn Spinning Mills;
2284: Thread Mills;
2295: Coated Fabrics, Not Rubberized;
2297: Nonwoven Fabrics;
2299: Textile Goods, NEC
351
214
3
313113: Thread Mills
87
4
313210: Broadwoven Fabric
Mills
762
14
313221: Narrow Fabric Mills
236
2
313230: Nonwoven Fabric Mills
264
10
313312: Textile and Fabric
Finishing (except Broadwoven
Fabric) Mills
365
16
313241: Weft Knit Fabric Mills
180
2
313249: Other Knit Fabric and
Lace Mills
182
1
313311: Broadwoven Fabric
Finishing Mills
1,006
20
313320: Fabric Coating Mills
219
53
315111: Sheer Hosiery Mills
101
0
315119: Other Hosiery and Sock
Mills
308
0
315191: Outerwear Knitting
Mills
398
0
315192: Underwear and
Nightwear Knitting Mills
36
0
315999: Other Apparel
Accessories and Other Apparel
Manufacturing
991
1
313112: Yarn Texturizing,
Throwing, and Twisting Mills
2282: Yarn Texturizing, Throwing,
Twisting and Winding Mills
142
3
0
314110: Carpet and Rug Mills
2273: Carpets and Rugs
405
13
30
314992: Tire Cord and Tire
Fabric Mills
2296: Tire Cord and Fabrics
25
5
14
314999: All Other Miscellaneous
Textile Product Mills
2298: Cordage and Twine;
2399: Fabricated Textile Products,
NEC
2,312
8
8
336360: Motor Vehicle Seating
and Interior Trim Manufacturing
2396: Automotive Trimmings, Apparel
Findings, and Related Products
387
5
33
315992: Glove and Mitten
Manufacturing
NA
96
0
1
Total
8,853
248
212
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); TRIReleases2008_v3; and DMRLoads2008_v2.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore, EPA used an NAICS-to-SIC-
code crosswalk for comparison purposes,
b - Releases to any media.
NA - Not applicable.
14-3
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-2 shows whether permitting authorities designated direct dischargers as minor
or major (see Section 4.1.5) for facilities in the Textiles Category. EPA included data for minor
dischargers for the first time in the 2010 annual review, as part of DMRLoads2008 v2 database.
EPA does not require permitting authorities to submit DMR data for minor dischargers; however,
many states do provide complete DMR data for them. From this year's review, EPA observed
many data entry or other errors for minor dischargers in addition to those previously identified
for major dischargers, as discussed in Section 4.3. Table 14-2 shows that approximately 79
percent of the Textiles Category dischargers in the 2008 DMR database are minor dischargers.
Table 14-2. Number of Textiles Facilities by Discharge Classification in 2008 DMR
Database
Number of Facilities in 2008 DMR
Database
NAICS Code®
Major
Dischargers
Major
Dischargers
Major
Dischargers
313111: Yarn Spinning Mills
313113: Thread Mills
313210: Broadwoven Fabric Mills
313221: Narrow Fabric Mills
313230: Nonwoven Fabric Mills
313312: Textile and Fabric Finishing (except Broadwoven Fabric)
Mills
313241: Weft Knit Fabric Mills
313249: Other Knit Fabric and Lace Mills
313311: Broadwoven Fabric Finishing Mills
313320: Fabric Coating Mills
315111: Sheer Hosiery Mills
315119: Other Hosiery and Sock Mills
315191: Outerwear Knitting Mills
315192: Underwear and Nightwear Knitting Mills
315999: Other Apparel Accessories and Other Apparel Manufacturing
47
167
214
313112: Yarn Texturizing, Throwing, and Twisting Mills
0
3
3
314110: Carpet and Rug Mills
4
9
13
314992: Tire Cord and Tire Fabric Mills
0
5
5
314999: All Other Miscellaneous Textile Product Mills
0
8
8
336360: Motor Vehicle Seating and Interior Trim Manufacturing
0
5
5
Total
51
197
248
Source: DMRLoads2008_v2.
a - DMR data are reported by SIC code; therefore EPA used an NAICS to SIC crosswalk for comparison purposes.
Table 14-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of textile facilities reporting to TRI do not report water discharges, but those that
do mostly reported discharging indirectly.
14-4
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-3. Number Textiles Facilities by Discharge Type in 2008 TRI Database
Number of Facilities in 2008 TRI Database
NAICS Code
Direct
Dischargers
Only
Direct
Dischargers
Only
Direct
Dischargers
Only
Direct
Dischargers
Only
313111: Yarn Spinning Mills
0
0
0
3
313113: Thread Mills
0
2
0
2
313210: Broadwoven Fabric Mills
0
2
1
11
313221: Narrow Fabric Mills
0
1
0
1
313230: Nonwoven Fabric Mills
0
3
1
6
313312: Textile and Fabric Finishing (except
Broadwoven Fabric) Mills
1
9
1
5
313241: Weft Knit Fabric Mills
0
1
0
1
313249: Other Knit Fabric and Lace Mills
0
0
0
1
313311: Broadwoven Fabric Finishing Mills
3
6
0
11
313320: Fabric Coating Mills
0
7
1
45
315111: Sheer Hosiery Mills
0
0
0
0
315119: Other Hosiery and Sock Mills
0
0
0
0
315191: Outerwear Knitting Mills
0
0
0
0
315192: Underwear and Nightwear Knitting Mills
0
0
0
0
315999: Other Apparel Accessories and Other
Apparel Manufacturing
0
1
0
0
313112: Yarn Texturizing, Throwing, and Twisting
Mills
0
0
0
0
314110: Carpet and Rug Mills
0
10
0
20
314992: Tire Cord and Tire Fabric Mills
1
5
3
5
314999: All Other Miscellaneous Textile Product
Mills
0
1
0
7
336360: Motor Vehicle Seating and Interior Trim
Manufacturing
0
2
0
31
315992: Glove and Mitten Manufacturing
0
1
0
0
Total
5
51
7
149
Source: TRIReleases2008 v3.
14.1.2 40 CFR Part 414
EPA first promulgated ELGs for the Textiles Category (40 CFR Part 410) on September
2, 1982 (47 FR 38819). There are nine subcategories, all of which have best practicable control
technology (BPT), best available technology economically achievable (BAT), and new source
performance standards (NSPS) limitations. Some subcategories also have pretreatment standards
for existing sources (PSES), and pretreatment standards for new sources (PSNS) limitations.
Table 9-4 lists the nine subcategories and applicability. Table 14-4 in the Technical Support
Document for the 2006 Effluent Guidelines Program Plan lists the regulated pollutants for the
subcategories (U.S. EPA, 2006).
14-5
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-4. Applicability of Subcategories in the Textiles Category
Subpart
Subcategory Title
S u bcatcgo rv A p p 1 icab ility
A
Wool Scouring
Wool scouring, topmaking, and general cleaning of raw wool
B
Wool Finishing
Wool finishers, including carbonizing, fulling, dyeing, bleaching,
rinsing, fireproofing, and other such similar processes
C
Low Water Use Processing
Yarn manufacture, yarn texturizing, unfinished fabric manufacture,
fabric coating, fabric laminating, tire cord and fabric dipping, and
carpet tufting and carpet backing
D
Woven Fabrics Finishing
Woven fabric finishers, which may include any or all of the
following unit operations: desizing, bleaching, mercerizing, dyeing,
printing, resin treatment, water proofing, flame proofing, soil
repellency application and a special finish application
E
Knit Fabric Finishing
Knit fabric finishers, which may include any or all of the following
unit operations: bleaching, mercerizing, dyeing, printing, resin
treatment, water proofing, flame proofing, soil repellency
application and a special finish application
F
Carpet Finishing
Carpet mills, which may include any or all of the following unit
operations: bleaching, scouring, carbonizing, fulling, dyeing,
printing, resin treatment, waterproofing, flameproofing, soil
repellency, looping, and backing with foamed and unfoamed latex
and jute
G
Stock & Yarn Finishing
Stock or yarn dyeing or finishing, which may include any or all of
the following unit operations and processes: cleaning, scouring,
bleaching, mercerizing, dyeing and special finishing
H
Nonwoven Manufacturing
Facilities that primarily manufacture nonwoven textile products of
wool, cotton, or synthetics, singly or as blends, by mechanical,
thermal, and/or adhesive bonding procedures
I
Felted Fabric Processing
Facilities that primarily manufacture nonwoven products by
employing fulling and felting operations as a means of achieving
fiber bonding
Source: Textile Mills Point Source Category - 40 CFR 410; Development Document for Effluent Limitations
Guidelines and Standards for the Textile Mills Point Source Category (U.S. EPA, 1979).
14.2 Textiles Category 2010 Screening-Level Review
Table 14-5 compares the screening-level database results for the Textiles Category from
the 2006 through 2010 annual reviews that represented multiple years of data from the DMR and
TRI databases. The combined DMR and TRI TWPE decreased from discharge years 2004 to
2007, but increased from discharge years 2007 to 2008. The discharge year 2008 DMR TWPE
accounts for approximately 42 percent of the combined 2008 DMR and TRI TWPE, similar to
previous years.
14-6
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-5. Textiles Category TRI and DMR Discharges for the 2006 through 2010
Screening-Level Reviews
Year of Discharge
Year of Review
Textiles Category
TRI TWPE
DMR TWPE a
Total TWPE
2002
2006
3,710
123,000
127,000
2004
2007
3,040
123,000
126,000
2005
2008
3,040
NA
NA
2007
2009
2,390
79,900
82,300
2008
2010
2,750
247,000
250,000
Source: TRIReleases2002_v4\ PCSLoads2002_v4; TRIReleases2004_v3; PCSLoads2004_v3; TRlReleases2005_v2;
TRIReleases2007_v2', DMRLoads2007jv4\ TRIReleases2008_v3', and DMRLoads2008_v2.
a - DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 14-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (72 percent) of the TWPE in the 2008 DMR database results from major
dischargers.
Table 14-6. Textiles Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
68,200
179,000
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
14.3 Textiles Pollutants of Concern
Table 14-7 compares the five chemicals with the highest TWPE in the 2008, 2007, and
2004 TRI databases (TRIReleases2008 _v3, TRIReleases2007_v2, and TRIReleases2004 v3).
Table 14-8 lists the five pollutants with the highest TWPE in the 2008, 2007, and 2004 DMR
databases (DMRLoads2008_v2, DMRLoads2007_v3, and PCSLoads2004_v4).
14-7
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-7. Textiles Category Top TRI Pollutants
Pollutant
2004 a
2007 a
2008 a
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Ammonia
Pollutants not reported in the top five
2004 TRI reported pollutants.
1
9
970
1
9
1,330
Lead and Lead Compounds
Pollutant not reported in the top five
2007 TRI reported pollutants.
2
8
272
Copper and Copper Compounds
1
12
843
2
9
511
3
7
192
Chlorine Dioxide
2
1
639
3
1
204
4
1
173
Nitrate Compounds
3
5
268
4
6
164
5
6
157
Di(2-ethylhexyl) phthalate
Pollutant not reported in the top five
2004 TRI reported pollutants.
5
1
106
Pollutants not reported in the top five
2008 TRI reported pollutants.
Antimony and Antimony
Compounds
4
18
192
Pollutants not reported in the top five
2007 TRI reported pollutants.
Zinc and Zinc Compounds
5
13
173
Textiles Category Total
NA
83 b
3,040
NA
61 b
2,390
NA
58 b
2,750
Source: TRIReleases2004_v3; TRIReleases2007_v2', and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
14-8
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-8. Textiles Category Top DMR Pollutants
Pollutant
2004 a
2007a
2008 b
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Mercury
Pollutants not reported in the top five 2004
DMR reported pollutants.
4
3
296
1
3
135,000
Aluminum
Pollutants not reported in the top five 2007
DMR reported pollutants.
2
3
34,300
Toxaphene
3
1
32,800
Sulfide
1
35
117,000
4
25
30,100
Aldrin
Pollutant not reported in the top five 2004
DMR reported pollutants.
1
1
76,400
5
1
9,500
Chlorine
2
18
3,440
2
16
1,680
Pollutants not reported in the top five 2008
DMR reported pollutants.
Copper
3
24
1,270
3
18
583
Chromium
Pollutant not reported in the top five 2004
DMR reported pollutants.
5
3
184
Chloride
4
14
340
Pollutant not reported in the top five 2007
DMR reported pollutants.
Nitrogen, Kjeldahl Total (as
N)
5
5
209
Textiles Category Total
NA
62 c
123,000
NA
46 c
79,900
NA
77 c
247,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data include only major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
14-9
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Section 14 - Textile Mills (40 CFR Part 410)
The majority of the Textiles Category total TWPE (over 98 percent) is based on
discharges in the 2008 DMR database. Therefore, EPA focused the preliminary category review
on the DMR-reported pollutants that account for the majority of the category TWPE.
EPA's additional review for the 2008 DMR database pollutants of concern, mercury,
aluminum, toxaphene, sulfide, and aldrin, is presented in the following sections. During the
review of top pollutants, EPA discovered that the majority of the top pollutants were discharged
from the same three facilities in the 2008 DMR database. Table 14-9 presents the top discharging
facilities and top pollutants in the Textiles Category. The following subsections provide details
on EPA's review of the 2008 DMR database discharges.
Table 14-9. Textiles Category Top Pollutant and Facility Dischargers in DMR 2008
Top Pollutant
Facility Name
Pounds of
Pollutant
Discharged
Pollutant
TWPE
Total
Facility
TWPE
Mercury
Kawashima Textile USA, Inc.
1,151
135,000
135,000
Aluminum
Kannapolis Water Treatment
Plant
571,000
34,300
35,000
Toxaphene
Mohawk Industries/ Oak River
Plant
1.09
33,100
32,800
Sulfide
Mohawk Industries, Inc.
5,060
14,200
14,200
Aldrin
Deroyal Textiles
0.853
9,500
9,510
Source: DMRLoads2008 v2.
14.4 Textiles Category Top Facility Dischargers in DMR
This subsection provides further detail on the top five facility dischargers in the Textiles
Category responsible for the majority of the mercury, aluminum, toxaphene, sulfide and aldrin
TWPE. As a result of EPA's identification of data errors, of discharges from the top facilities in
the Textiles Category, the overall category 2008 DMR TWPE decreased by over 170,000 TWPE
from 250,000 TWPE to 78,500 TWPE.
14.4.1 Kawashima Textile USA, Inc. in Camden, SC
Table 14-10 presents the discharges in the 2008 DMR database for Kawashima Textile
USA, Inc. The majority of the facility TWPE (approximately 100 percent) is from mercury.
Mercury discharges from Kawashima Textile also account for approximately 54 percent of the
DMR TWPE for the Textiles Category.
14-10
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Section 14 - Textile Mills (40 CFR Part 410)
Table 14-10. Kawahima Textile 2008 Top Discharges in the DMR Database
Pollutant
Total Pounds
Total TWPE
Percent of Facility Total
TWPE
Mercury
1,150
135,000
100%
Iron
106
0.59
0%
Ammonia
255
0.28
0%
Manganese
3.06
0.21
0%
Phosphorous
0.77
0.00
0%
Total
1,510
135,000
100%
Source: DMRLoads2008_v2.
All of the pollutant discharges for Kawashima Textile USA are from outfall 002. Table
14-11 presents the discharge data in the DMR Loadings Tool for 2008, along with the data from
EPA's Envirofacts24. EPA determined that January, June, July, and August 2008 mercury
concentrations had data errors. Using the corrected concentrations, EPA calculated the revised
load and corresponding TWPE for mercury. The facility's mercury discharges decrease from
135,000 TWPE to 0.9 TWPE, while the facility's total TWPE decreased from 135,000 TWPE to
2 TWPE, a reduction of almost 100 percent.
Table 14-11. Kawashima Textile USA 2008 Monthly Mercury and Flow Discharge Data
Outfall
Pollutant
Monitoring
Period Date"
DMR Loadings Tool
Average
Concentration (mg/L)
Envirofacts Average
Concentration (mg/L)
Average Flow (MGD)
002
Mercury
31-Jan-08
4.0000188
0.0000188
0.2997
002
Mercury
29-Feb-08
0.000012
0.000012
0.2793
002
Mercury
31-Mar-08
0.000013
0.000013
0.2173
002
Mercury
30-Apr-08
0.000011
0.000011
0.1954
002
Mercury
31-May-08
0.00011
0.00011
0.2563
002
Mercury
30-Jun-08
4.0000042
0.0000042
0.2751
002
Mercury
31-Jul-08
4.0000048
0.0000048
0.2548
002
Mercury
31-Aug-08
4.0000061
0.0000061
0.2915
Source: DMR Loadings Tool and Envirofacts.
a - The DMR Loadings Tool and Envirofacts do not have mercury concentrations for Kawashima Textile USA for
September, October, November, and December 2008.
14.4.2 Kannapolis Water Treatment Plant in Kannapolis, NC
Table 14-12 presents the discharges in the 2008 DMR database for Kannapolis Water
Treatment Plant (WTP). The majority of the facility TWPE (almost 98 percent) is from
discharges of aluminum. Aluminum discharges from Kannapolis WTP also account for
approximately 14 percent of the DMR TWPE for the Inorganic Chemicals Category.
24 EPA uses the data in Envirofacts as a source while reviewing the DMR Loadings Tool data because Envirofacts
continually accepts and updates corrections submitted by facilities and states. The DMR Loadings Tool is not
continuously updated; therefore, loads may be estimated with erroneous data.
14-11
-------
Section 14 - Textile Mills (40 CFR Part 410)
Table 14-12. Kannapolis WTP 2008 Top Discharges in the DMR Database
Pollutant
Total Pounds
TWPE
Percent of Facility
TWPE
Aluminum
571,000
34,300
97.90%
Iron
109,000
611
1.75%
Manganese
1,740
122
0.35%
Calcium
6,270
0.18
0.00%
Magnesium
70.6
0.06
0.00%
Total
688,000
35,000
100%
Source: DMRLoads2008_v2.
All of Kannapolis WTP's aluminum discharges are from outfall 001. Table 14-13
presents the aluminum discharge data in the DMR Loadings Tool for 2008, along with the data
from EPA's Envirofacts. EPA determined that aluminum concentrations for January through
November 2008 were in the DMR Loadings Tool as mg/L, but in Envirofacts as (J,g/L. Using the
corrected concentrations, EPA calculated the revised load and corresponding TWPE for
aluminum. The facility's aluminum discharges decrease from 34,300 TWPE to 36 TWPE, while
the facility's total TWPE decreases from 34,900 TWPE to 769 TWPE, a reduction of almost 100
percent.
Table 14-13. Kannapolis WTP 2008 Monthly Aluminum Discharge Data
Outfall
Pollutant
Monitoring
Period Date
DMR Loadings Tool Average
Concentration (mg/L)
Envirofacts Average
Concentration
(Jig/L)
(mg/L)
001
Aluminum
31-Jan-08
659.8
659.8
0.6598
001
Aluminum
29-Feb-08
911.25
911.25
0.91125
001
Aluminum
31-Mar-08
887.5
887.5
0.8875
001
Aluminum
30-Apr-08
537
537
0.537
001
Aluminum
31-May-08
411.75
411.75
0.41175
001
Aluminum
30-Jun-08
657.25
657.25
0.65725
001
Aluminum
31-Jul-08
608.4
608.4
0.6084
001
Aluminum
31-Aug-08
626.25
626.25
0.62625
001
Aluminum
30-Sep-08
1,339
1,339
1.339
001
Aluminum
31-Oct-08
491.6
491.6
0.4916
001
Aluminum
30-Nov-08
440
440
0.440
001
Aluminum
31-Dec-08
0.333
333
0.33
Source: DMR Loadings Tool and Envirofacts.
14.4.3 Mohawk Industries Oak River Plant in Bennettsville, SC
Table 14-14 presents the discharges for Mohawk Industries Oak River Plant in the 2008
DMR database. The majority of the TWPE is from toxaphene (approximately 99 percent).
Toxaphene discharges from Mohawk Industries Oak River Plant also account for approximately
13 percent of the DMR TWPE for the Textiles Category.
14-12
-------
Section 14 - Textile Mills (40 CFR Part 410)
Table 14-14. Mohawk Industries Oak River Plant 2008 Top Discharges in the DMR
Database
Pollutant
Total Pounds
TWPE
Percent of Facility TWPE
Toxaphene
1.09
32,800
99.2%
Sulfur
92.1
258
0.78%
Chlorine
28.1
14.0
0.04%
Ammonia
72.0
0.08
0.00%
Chromium
0.88
0.06
0.00%
Total
194
33,100
100%
Source: DMRLoads2008_v2.
Mohawk Industries Oak River Plant reports toxaphene discharges from outfall 001. Table
14-15 presents the discharge data in the DMR Loadings Tool for 2008. EPA contacted the
facility to confirm the 2008 toxaphene discharges. Mohawk Industries Oak River Plant stated
that the concentrations were correct and that the December 2008 toxaphene concentration was
<0.0005 mg/L. Mohawk Industries Oak River Plant also indicated that the chemical is not used
as a raw material or in any other chemicals at the facility (Wood, 2010). The South Carolina
Department of Health and Environmental Control (SC DHEC) requires Mohawk to monitor for
toxaphene because recent water quality data found it at detectable concentrations. The facility
must monitor toxaphene to determine if a limit is necessary (Vickers, 2010).
EPA evaluated available 2009 and 2010 toxaphene data from Envirofacts, presented in
Table 14-16, and determined that all concentrations were reported below detection limit (BDL).
SC DHEC is monitoring toxaphene discharges, and all 2009 and 2010 discharges are BDL, and
EPA will continue reviewing the discharge data for this facility.
14-13
-------
Section 14 - Textile Mills (40 CFR Part 410)
Table 14-15. Mohawk Industries Oak River Plant 2008 Monthly Toxaphene Discharge
Data
Outfall
Pollutant
Monitoring
Period Date
DMR Loadings
Tool
Concentration
(mg/L)
Facility-Provided
Concentration
(mg/L)
Average Flow
(MGD)
001
Toxaphene
31-Jan-08
< 0.0005
< 0.0005
0.093487
001
Toxaphene
29-Feb-08
< 0.0005
< 0.0005
0.108851
001
Toxaphene
31-Mar-08
< 0.0025
< 0.0025
0.070074
001
Toxaphene
30-Apr-08
0.0025
0.0025
0.09694
001
Toxaphene
31-May-08
0.0005
0.0005
0.073806
001
Toxaphene
30-Jun-08
< 0.0005
< 0.0005
0.08753
001
Toxaphene
31-Jul-08
< 0.0005
< 0.0005
0.131065
001
Toxaphene
31-Aug-08
< 0.0005
< 0.0005
0.164852
001
Toxaphene
30-Sep-08
<0.05
<0.05
0.158837
001
Toxaphene
31-Oct-08
< 0.0005
< 0.0005
0.1335
001
Toxaphene
30-Nov-08
< 0.0005
< 0.0005
NR
001
Toxaphene
31-Dec-08
NR
< 0.0005
NR
Source: DMR Loadings Tool and Facility Contact (Wood, 2010).
NR - Not reported.
Table 14-16. Mohawk Industries Oak River Plant 2009 and 2010 Monthly Toxaphene
Discharge Data
Outfall
Pollutant
Monitoring Period Date
Envirofacts
Concentration (mg/L)
001
Toxaphene
31-Jan-09
< 0.00055
001
Toxaphene
29-Feb-09
< 0.0005
001
Toxaphene
31-Mar-09
< 0.0005
001
Toxaphene
30-Apr-09
<0.0001
001
Toxaphene
31-May-09
<0.00055
001
Toxaphene
30-Jun-09
<0.00055
001
Toxaphene
31-Jul-09
< 0.0005
001
Toxaphene
31-Aug-09
< 0.0003
001
Toxaphene
30-Sep-09
< 0.0005
001
Toxaphene
31-Oct-09
< 0.0005
001
Toxaphene
30-Nov-09
< 0.0005
001
Toxaphene
31-Dec-09
< 0.0005
001
Toxaphene
31-Jan-10
< 0.0005
001
Toxaphene
29-Feb-10
< 0.0005
001
Toxaphene
31-Mar-10
< 0.0005
001
Toxaphene
30-Apr-10
< 0.005
001
Toxaphene
31-May-10
< 0.0005
001
Toxaphene
30-Jun-10
<0.00055
Source: Envirofacts
14-14
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Section 14 - Textile Mills (40 CFR Part 410)
14.4.4 Mohawk Industries, Inc. inLyerly, GA
Table 14-17 presents the discharges for Mohawk Industries in the 2008 DMR database.
Almost all of the TWPE is from sulfide. Sulfide discharges from Mohawk Industries also
account for approximately 6 percent of the DMR TWPE for the Textiles Category.
Table 14-17. Mohawk Industries 2008 Top Discharges in the DMR Database
Pollutant
Total Pounds
TWPE
Percent of Facility TWPE
Sulfide
5,100
14,200
99.98%
Chromium
40.4
2.83
0.02%
Total
5,140
14,200
100%
Source: DMRLoads2008 v2.
All of Mohawk Industries sulfide discharges are from outfalls 0A1. Table 14-18 presents
the discharge data in the DMR Loadings Tool and the back-calculated concentrations associated
with each sulfide quantity. EPA calculated the sulfide concentrations using the average quantity
and flow provided in the 2008 DMR Loadings Tool. EPA contacted the facility to verify the
sulfide quantities in the 2008 DMR database. Mohawk Industries confirmed that the sulfide
quantities were correct and that the permit limit for sulfide is 11 kg/day (Wood, 2010). Mohawk
Industries stated that sulfide present in the wastewater may be from boiler treatment chemicals
and wastewater treatment chemicals used to treat intake water for hardness (Wood, 2010). The
sulfide quantities are below permit limits, therefore, the facility's sulfide discharges are not a
concern for the 2010 annual review.
Table 14-18. Mohawk Industries 2008 Monthly Sulfide Discharge Data
Outfall
Pollutant
.Monitoring Period
Date
DMR Loadings
Tool Average
Quantity (kg/day)
Calculated Sulfide
Concentrations
(mg/L)
Average Flow
(MGD)
0A1
Sulfide
31-Jan-08
6.08
1.2
1.323
0A1
Sulfide
30-Apr-08
8.31
1.3
1.659
0A1
Sulfide
31-Jul-08
7.61
1.9
1.025
0A1
Sulfide
31-Oct-08
2.83
1.1
0.723
Source: DMR Loadings Tool and Facility Contact (Wood, 2010).
14.4.5 Deroyal Textiles in Camden, SC
Table 14-19 presents the discharges for Deroyal Textiles in the 2008 DMR database.
Almost all of the TWPE is from aldrin. Aldrin discharges from Deroyal Textiles also account for
approximately 4 percent of the DMR TWPE for the Textiles Category.
14-15
-------
Section 14 - Textile Mills (40 CFR Part 410)
Table 14-19. Deroyal Textiles 2008 Top Discharges in the DMR Database
Pollutant
Total Pounds
TWPE
Percent of Facility TWPE
Aldrin
0.85
9,500
99.9%
Sulfur
2.05
5.74
0.06%
Hydrogen sulfide
0.45
1.27
0.01%
Chromium
3.93
0.28
0.00%
Ammonia
140
0.16
0.00%
Total
147
9,500
100%
Source: DMRLoads2008_v2.
All of the aldrin discharges are from outfall 001. Table 14-20 presents the discharge data
in the DMR Loadings Tool for 2008. EPA contacted Deroyal Textiles to verify the aldrin
concentrations. Deroyal Textiles indicated that the facility made a conversion error with the
March 2008 DMR data and the aldrin concentration was reported in |ig/L instead of mg/L
although the units were reported as mg/L (Gettys, 2010). Using the facility-provided
concentrations, EPA calculated the revised load and corresponding TWPE for aldrin. The
facility's aldrin discharges decrease from 9,500 TWPE to 353 TWPE, while the facility's total
TWPE decreases from 9,510 TWPE to 361 TWPE, a reduction of over 96 percent.
Table 14-20. Deroyal Textiles 2008 Monthly Aldrin Discharge Data
Outfall
Pollutant
Monitoring Period
Date
DMR Loadings
Tool Average
Concentration
(mg/L)
Facility-Provided
Average
Concentration
(mg/L)
Average Flow
(MGD)
001
Aldrin
31-Jan-08
0
0
0.08
001
Aldrin
29-Feb-08
0
0
0.102
001
Aldrin
31-Mar-08
0.034
0.000034
0.088
001
Aldrin
30-Apr-08
0.00023
0.00023
0.087
001
Aldrin
31-May-08
0.000011
0.000011
0.07
001
Aldrin
30-Jun-08
0.000116
0.000116
0.073
001
Aldrin
31-Jul-08
NR
NR
0.065
001
Aldrin
31-Aug-08
0
0
0.061
001
Aldrin
30-Sep-08
0
0
0.038
001
Aldrin
31-Oct-08
0
0
0.037
001
Aldrin
30-Nov-08
0
0
0.017
001
Aldrin
31-Dec-08
0.000019
0.000019
0.026
Source: DMR Loadings Tool and Facility Contact (Gettys, 2010).
NR - Not reported. The aldrin data for July 2008 includes the NODI code E - analysis not conducted.
14.5 Textiles Category Conclusions
The estimated toxicity of the Textile Mills Category discharges result from mercury,
aluminum, toxaphene, sulfide, and aldrin discharges. Data collected for the 2010 annual review
14-16
-------
Section 14 - Textile Mills (40 CFR Part 410)
demonstrated that wastewater discharge characteristics for this category are consistent with
discharges from prior years. As in prior years, EPA makes the following conclusions:
• There were data errors in the mercury concentrations for Kawashima Textile
USA. Correcting this error decreases the 2008 facility TWPE to 2 TWPE.
• There was a units error for the aluminum concentrations for Kannapolis WTP.
Correcting this error decreases the 2008 facility TWPE to 769 TWPE.
• The screening-level data for toxaphene discharges from Mohawk Industries Oak
River Plant are accurate. The facility does not use toxaphene and is unable to
identify the source of the pesticide. SC DHEC requires the facility to continue
monitoring for toxaphene, and EPA will continue reviewing toxaphene discharges
from this facility as part of future reviews.
• Sulfide discharges from Mohawk Industries in Lyerly, GA are below the permit
limit. EPA will continue monitoring sulfide discharges from this facility as part of
future reviews.
• There was a units error for the March 2008 aldrin concentration for Deroyal
Textiles. Correcting this error decreases the 2008 facility TWPE to 361 TWPE.
• Correcting the database errors identified during the 2010 annual review decreases
the 2008 Textile Mills Category TWPE from 250,000 TWPE to 78,500 TWPE.
EPA will continue to monitor the Textile Mills Category discharges to determine
if they are properly controlled.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusions, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(3)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing ELGs).
14.6 Textiles Category References
1. Gettys, John. 2010. E-mail Communication with John Gettys, Deroyal Textiles, and
Lauren Wingo, Eastern Research Group, Inc. "RE: DMRs Clarification Needed for
Deroyal Textiles - SC0002518." (September 7). EPA-HQ-OW-2008-0517 DCN 07302.
2. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
3. U. S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program
Plan. EPA-821-R-04-014. Washington, DC. (August). EPA-HQ-OW-2003-0074-1346
through 1352.
14-17
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Section 14 - Textile Mills (40 CFR Part 410)
4. U.S. EPA. 2005. Preliminary 2005 Review of Prioritized Categories of Industrial
Dischargers. EPA-821-B-05-004. Washington, DC. (August). EPA-HQ-OW-2004-0032-
0016.
5. U. S. EPA. 2006. Technical Support Document for the 2006 Effluent Guidelines Program
Plan. EPA-821R-06-018. Washington, DC. (December). EPA-HQ-OW-2004-0032-2782.
6. U. S. EPA. 2007. Technical Support Document for the Preliminary 2008 Effluent
Guidelines Program Plan. EPA-821-R-07-007. Washington, DC. (October). EPA-HQ-
OW-2006-0771-0819.
7. Vickers, Melinda. 2010. Telephone communication with Melinda Vickers, South
Carolina Department of Health and Environmental Control (SC DHEC), and Elizabeth
Sabol, Eastern Research Group, Inc. "Re: DMR Clarification for Toxaphene Discharges
from Mohawk Industries Oak River Plant." (September 23). EPA-HQ-OW-2008-0517
DCN 07308.
8. Wood, Denise. 2010. Telephone and E-mail communication with Denise Wood, Mohawk
Industries, and Elizabeth Sabol and Lauren Wingo, Eastern Research Group, Inc. "Re:
DMR Clarification Needed for Mohawk Industries Oak River Plant and Lyerly Plant."
(September 2). EPA-HQ-OW-2008-0517 DCN 07309.
14-18
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Section 15 - Waste Combustors (40 CFR Part 444)
15. Waste Combustors (40 CFR Part 444)
EPA selected the Waste Combustors Category (40 CFR Part 444) for preliminary review
because it ranked high, in terms of toxic-weighted pound equivalent (TWPE) (see Table 5-3 for
the point source category rankings). The Final 2008 Plan summarizes the results of EPA's
previous review of this industry in 2008 (72 FR 61335). This section summarizes the results of
the 2010 annual review associated with the Waste Combustors Category. EPA focused on
discharges of hexachlorophene, because of its high TWPE relative to the rest of the Waste
Combustors Category.
15.1 Waste Combustors Category Background
This subsection provides background on the Waste Combustors Category including a
brief profile of the waste combustors industry and background on 40 CFR Part 444.
15.1.1 Waste Combustors Industry Profile
The waste combustors industry includes facilities that recover energy from or dispose of
wastes (both hazardous and nonhazardous) by incineration (U.S. EPA, 2008). EPA considered
the following four North American Industry Classification System (NAICS) codes as part of the
Waste Combustors Category:
• 562211: Hazardous Waste Treatment and Disposal;
• 562213: Solid Waste Combustors and Incinerators;
• 562219: Other Nonhazardous Waste Treatment and Disposal; and
• WC: Waste Combustors.
Wastewater generated by facilities in NAICS codes 562211, 562213, and 562219 may be
regulated under the Centralized Waste Treatment (CWT) (40 CFR Part 437), Landfills (40 CFR
Part 445) (see Section 8), and/or Waste Combustors Categories. EPA reviewed available
information about pollutant load and manufacturing operations for facilities reporting these
NAICS codes. In its crosswalk, EPA assigned the "WC" NAICS code for facilities that most
likely fall under the applicability of 40 CFR Part 444, Waste Combustors.
Because the Permit Compliance System (PCS) and Integrated Compliance Information
System - National Pollutant Discharge Elimination System (ICIS-NPDES), the sources of the
discharge monitoring report (DMR) data used to develop DMRLoads2008, report facilities by
Standard Industrial Classification (SIC) code, and the U.S. Economic Census and Toxics Release
Inventory (TRI) report data by NAICS code, EPA reclassified the 2008 DMR by the equivalent
NAICS code. Table 15-1 lists the number of facilities from the U.S. Economic Census and the
screening-level databases for the four NAICS codes with operations in the Waste Combustors
Category; the corresponding SIC codes are included for reference. The U.S. Economic Census
includes more facilities than the screening-level databases because of many possible factors
including: facilities may not meet TRI-reporting thresholds, facilities may discharge to a publicly
owned treatment works (POTW), and some facilities in the U.S. Economic Census are
distributors or sales facilities, not manufacturers.
15-1
-------
Section 15 - Waste Combustors (40 CFR Part 444)
Table 15-1. Number of Facilities in Waste Combustors Category
NAICS Code
Corresponding
SIC Code
Number of Facilities
2002 U.S.
Economic Census
2008 DMR
Database"
2008 TRI
Database b
562211: Hazardous Waste
Treatment and Disposal
4953: Refuse
Systems
4953WC °: Refuse
Systems (Waste
Combustors)
701
1,217
53
562213: Solid Waste
Combustors and Incinerators
120
1
562219: Other Nonhazardous
Waste Treatment and Disposal
199
5
WC: Waste Combustors
NA
6
Total
>1,020
1,217
65
Source: U.S. Economic Census, 2002 (U.S. Census, 2002); DMRLoads2008_v2\ and TRIReleases2008_v3.
a - Major and minor dischargers. Also, DMR data are reported by SIC code; therefore EPA used an NAICS-to-SIC-
code crosswalk for comparison purposes,
b - Facilities reporting releases to any media.
c - Wastewater generated by facilities in SIC code 4953 may be regulated under the CWT, Landfills, and Waste
Combustors Categories. In its crosswalk, EPA assigned the extension "WC" to the end of the SIC code for facilities
that most likely fall under the applicability of the Waste Combustors Effluent Limitation Guidelines and Standards
(ELGs).
NA - Not applicable. These facility-specific NAICS codes assigned as part of the annual review do not correspond
to NAICS codes in the 2002 U.S. Economic Census.
Table 15-2 shows whether permitting authorities designated direct discharging facilities
in the Waste Combustors Category as minor or major dischargers (see Section 4.1.5). EPA
included data for minor dischargers for the first time in the 2010 annual review, as part of
DMRLoads2008_v2. EPA does not require permitting authorities to submit DMR data for minor
dischargers; however, many states do provide complete DMR data for minor dischargers. From
the 2010 annual review, EPA observed many data entry or other errors for minor dischargers in
addition to those previously identified for major dischargers, as discussed in Section 4.3. Table
15-2 shows that approximately 99 percent of the Waste Combustor Category dischargers in the
2008 DMR database are minor dischargers.
Table 15-2. Number of Waste Combustor Facilities by Type of Discharger in DMR 2008
Majors Dischargers
Minors Dischargers
Total
8
1,210 a
1,217
Source: DMRLoads2008_v2.
a - The DMR data in PCS and ICIS-NPDES does not include discharge data for all minor dischargers. For the
facilities in the Waste Combustor Category, 301 of the 1,210 minor dischargers have DMR data.
Note: Includes waste combustors reported in both SIC codes 4953 and 4953WC.
Table 15-3 presents the type of discharges reported by facilities in the 2008 TRI database.
The majority of waste combustor facilities reporting to TRI do not report water discharges, but
those that do mostly reported direct discharges to surface waters.
15-2
-------
Section 15 - Waste Combustors (40 CFR Part 444)
Table 15-3. Waste Combustor Facilities by Discharge Type in 2008 TRI Database
NAICS Code
Number of Facilities in 2008 TRI Database
Direct
Dischargers
Only
Indirect
Dischargers
Only
Both
Indirect and
Direct
No Water
Discharges
562211: Hazardous Waste Treatment and Disposal
4
4
1
44
562213: Solid Waste Combustors and Incinerators
1
0
0
0
562219: Other Nonhazardous Waste Treatment and
Disposal
2
0
0
3
WC: Waste Combustors
4
0
0
2
Total
11
4
1
49
Source: TRIReleases2008 v3.
15.1.2 40 CFR Part 444
EPA first promulgated ELGs for the Waste Combustors Category (40 CFR Part 444) on
January 27, 2000 (65 FR 4381). The Waste Combustors ELGs apply to wastewater discharges
from hazardous waste combustors, except cement kilns, regulated as "incinerators" or "boilers
and industrial furnaces" under the Resource Conservation and Recovery Act (RCRA). The rule
applies solely to commercial facilities (i.e., facilities that accept wastes from off-site for fee or
remuneration). At the time of promulgation, EPA estimated that the rule would apply to eight
facilities (U.S. EPA, 2000). Table 15-4 lists the pollutants regulated by Part 444.
Table 15-4. Applicability of Subcategories in the Waste Combustor Category
Subpart Name
Subpart Applicability
Regulated Pollutants
A: Commercial
Hazardous Waste
Combustor
(CWHC)
The discharge of wastewater from a CHWC facility
including any thermal unit, except a cement kiln, if the
thermal unit burns RCRA hazardous wastes received
from off-site for a fee or other remuneration in the
following circumstances. The thermal unit is a
commercial hazardous waste combustor if the off-site
wastes are generated at a facility not under the same
corporate structure or subject to the same ownership as
the thermal unit.
TSS, pH, Arsenic, Cadmium,
Chromium, Copper, Lead,
Mercury, Silver, Titanium, and
Zinc
Source: 40 CFR Part 444; Development Document for Final Effluent Limitations Guidelines and Standards for
Commercial Hazardous Waste Combustors (U.S. EPA, 2000).
15.2 Waste Combustors Category Screening Level Review
Table 15-5 shows the screening-level results for the Waste Combustors Category from
the 2005, 2007, and 2008 TRI and DMR databases. The Waste Combustors Category was
excluded from annual reviews prior to 2008 because EPA promulgated the ELGs on January 27,
2000. The TRI TWPE increased from discharge year 2007 to 2008, but decreased from discharge
year 2005 to 2008. The DMR TWPE increased by two orders of magnitude from discharge year
2007 to 2008, mainly because of discharges from one facility, discussed below.
15-3
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Section 15 - Waste Combustors (40 CFR Part 444)
Table 15-5. Waste Combustors Category TRI and DMR Discharges for the 2006 through
2010 Screening-Level Reviews
Year of Discharge
Year of Review
Waste Combustors Category
TRI TWPE
DMR TWPE "
Total TWPE
2005
2008
52,300
NA
NA
2007
2009
114
3,220
3,260
2008
2010
8,830
245,000
254,000
Source: TRIReleases2002_v4; PCSLoads2002_v4; TRIReleases2004_v3', PCSLoads2004_v3', TRIReleases2005_v2;
TRlReleases2007_v2; DMRLoads2007_v4; TRIReleases2008_v3; and DMRLoads2008jv2.
a - DMR data from 2002 through 2007 includes only major dischargers. DMR 2008 data includes both minor and
major dischargers.
NA - Not applicable. EPA did not evaluate DMR data for 2005.
Table 15-6 presents the 2008 DMR TWPE by facility discharge classification. EPA
excluded minor dischargers from previous annual reviews, but included them in the 2010 annual
review. The majority (70 percent) of the TWPE in the 2008 DMR database is from major
dischargers.
Table 15-6. Waste Combustors Category 2008 DMR TWPE by Discharge Classification
Year of Discharge"
TWPE from Minor Dischargers
TWPE from Major Dischargers
2008
69,900
176,000
Source: DMRLoads2008_v2.
a - Data for previous years of discharge are not included because EPA excluded minor dischargers from previous
annual reviews.
15.3 Waste Combustors Category Pollutants of Concern
Table 15-7 lists the five pollutants with the highest TRI TWPE based on results from the
2010, 2009, and 2007 annual reviews (TRIReleases2008 v3, 1 RIReleases2007 v2, and
TRIReleases2004 \-3, respectively). Table 15-8 lists the five pollutants with the highest DMR
TWPE based on results from the 2010, 2009, and 2007 annual reviews (DMRLoads2008_v2,
DMRLoads2007 v3, and PCSLoads2004 v4, respectively). As noted in Section 15.2, the DMR
TWPE increase from discharge year 2007 to 2008 is mainly because of discharges from one
facility.
15-4
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Section 15 - Waste Combustors (40 CFR Part 444)
Table 15-7. Waste Combustors Category Top TRI Pollutants
Pollutant
2004 TRI Database"
2007 TRI Database"
2008 TRI Database"
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Cadmium and Cadmium
Compounds
4
2
3,190
1
2
13.8
1
3
2,550
Aldrin
Pollutants not reported in the top five
2004 TRI reported pollutants.
Pollutants not reported in the top five 2007
TRI reported pollutants.
2
1
2,230
Heptachlor
3
1
1,710
Chlordane
4
1
797
Silver and Silver Compounds
5
2
2,300
5
2
379
Nitrate Compounds
Pollutants not reported in the top five
2004 TRI reported pollutants.
2
2
8.35
Pollutants not reported in the top five
2008 TRI reported pollutants.
Ethylene Glycol
3
1
5.23
Lead and Lead Compounds
4
2
4.34
Formaldehyde
5
1
3.5
Benzidine
1
1
188,000
Pollutants not reported in the top five 2007
TRI reported pollutants.
Toxaphene
2
1
34,500
Hexachlorobenzene
3
1
11,900
Waste Combustors Category
Total
NA
11 b
243,000
NA
22 b
114
NA
16 b
8,830
Source: TRIReleases2004_v3; TRlReleases2007_v2; and TRIReleases2008_v3.
a - Discharges include transfers to POTWs and account for POTW removals,
b - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
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Section 15 - Waste Combustors (40 CFR Part 444)
Table 15-8. Waste Combustors Category Top DMR Pollutants
Pollutant
2004 DMR Database"
2007 DMR Database"
2008 DMR Databas) b
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Rank
Number of
Facilities
Reporting
Pollutant
TWPE
Hexachlorophene
Pollutants not reported in the top five 2004
DMR reported pollutants.
Pollutant not reported in the top five 2007
DMR reported pollutants.
1
1
172,000
Arsenic
2
1
815
2
26
14,900
Calcium
Pollutants not reported in the top five 2007
DMR reported pollutants.
3
5
10,900
Copper
4
44
8,750
Sulfate
5
50
6,370
Cadmium
1
2
1,290
Pollutants not reported in the top five 2008
DMR reported pollutants.
Mercury
3
2
717
Selenium
4
2
177
Lead
5
3
82
Sulfide
1
2
1,380
Pollutants not reported in the top five DMR
2007 reported pollutants.
Boron
2
1
1,360
PCB-1260
3
1
814
PCB-1248
3
1
814
PCB-1242
3
1
814
Waste Combustors
Category Total
NA
17 c
9,087
NA
4 c
3,220
NA
164 c
245,000
Source: PCSLoads2004_v4\ DMRLoads2007_v3\ and DMRLoads2008jv2.
a - 2004 and 2007 DMR data include only major dischargers,
b - 2008 DMR data includes major and minor dischargers,
c - Number of facilities reporting TWPE greater than zero.
NA - Not applicable.
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Section 15 - Waste Combustors (40 CFR Part 444)
The Waste Combustors Category combined TWPE is dominated by hexachlorophene
discharges, accounting for approximately 68 percent of the combined TWPE. Additionally, the
Waste Combustors Category TWPE in the 2008 TRI database is significantly lower than the
2008 DMR TWPE. Therefore, EPA focused the preliminary category review on
hexachlorophene discharges in the 2008 DMR database.
15.4 Waste Combustors Hexachlorophene Discharges in DMR
As part of the 2010 annual review of the Waste Combustors Category, EPA reviewed
hexachlorophene discharges in the 2008 DMR database. Approximately 70 percent of the 2008
DMR TWPE results from hexachlorophene discharges. Only one facility, Clean Harbors Deer
Park, reported hexachlorophene discharges.
Clean Harbors Deer Park discharges hexachlorophene from outfall 001. Table 15-9
presents Clean Harbors Deer Park's quarterly hexachlorophene discharge data from the DMR
Loadings Tool. EPA contacted the facility to verify the hexachlorophene quantities and flows for
outfall 001. The facility contact indicated that the quantities were reported as lb/day rather than
kg/day. Additionally, the facility contact indicated that the reported quantities were based on
nondetect hexachlorophene concentrations. The quantities were reported without the below
detection limit (BDL) indicator (i.e., "<" sign) because their permit requires them to use the
detection limit to calculate the quantity if the concentrations are nondetect (Honohan, 2010).
Table 15-9 also presents the facility-provided quantities, converted to kg/day. Using the revised
quantities, Clean Harbors Deer Park's hexachlorophene discharges are 0 TWPE, reducing the
Waste Combustors Category 2008 DMR TWPE by approximately 72 percent, from 245,000 to
73,000 TWPE.
Table 15-9. Clean Harbors Deer Park 2008 Monthly Hexachlorophene Discharge Data
Outfall
Monitoring Period Date
DMR Loadings Tool
Average Quantity
(kg/day)
Facility-Provided
Average Quantity
(kg/day)
001
31-Jan-08
0.128
<0.058
001
30-Apr-08
0.120
<0.054
001
31-Jul-08
0.132
<0.060
001
31-Oct-08
0.101
<0.046
Source: DMR Loadings Tool; and Facility Contact (Honohan, 2010).
15.5 Waste Combustors Category Conclusions
The estimated toxicity of the Waste Combustors Category discharges results mainly from
the hexachlorophene discharges of one plant (accounting for 72 percent of the category's 2008
DMR TWPE). The remaining estimated toxicity results mainly from metals discharges. Data
collected for the 2010 annual review demonstrated that wastewater discharge characteristics for
this category are consistent with discharges from prior years. As in prior years, EPA makes the
following conclusions:
• Based on contacts with Clean Harbors Deer Park, in 2008, the facility did not
detect hexachlorophene (i.e., all concentrations were below the detection limit).
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Section 15 - Waste Combustors (40 CFR Part 444)
EPA then set the hexachlorophene load and TWPE to zero. Correcting this error
decreases the Waste Combustors Category combined 2008 DMR and TRI TWPE
to 81,800 TWPE.
• EPA will collect data on metals and pesticides discharges from waste combustors
for consideration during the 2011 annual review because the estimated toxicity is
primarily from these groups of chemicals.
• EPA will continue monitoring discharges from waste combustors as part of future
annual reviews.
EPA prioritizes point source categories with existing regulations for potential revision
based on the greatest estimated toxicity to human health and the environment, measured as
TWPE. Based on the above conclusion, EPA is assigning this category with a lower priority for
revision (i.e., this category is marked with "(5)" in the "Findings" column in Table V-l in the
Federal Register notice that presents the 2010 annual review of existing effluent guidelines and
pretreatment standards).
15.6 Waste Combustors Category References
1. Honohan, Kevin, Craig. 2010. E-mail communication between Kevin Honohan, Clean
Harbors Deer Park, and Eleanor Codding, Eastern Research Group, Inc. "DMRs
Clarification Needed for TX0005941." (July 8). EPA-HQ-OW-2008-0517 DCN 07282.
2. U.S. Census. 2002. U.S. Economic Census. Available online at:
http://www.census.gov/econ/census02.
3. U. S. EPA. 2000. Development Document for Final Effluent Limitations Guidelines and
Standards for Commercial Hazardous Waste Combustors. EPA-821-R-99-020.
Washington, DC. (January). Available online at:
http://epa.gov/guide/chwc/final/technical.html.
4. U. S. EPA. 2008. Technical Support Document for the 2008 Effluent Guidelines Program
Plan. EPA-821 -R-08-015. Washington, DC. (August). EPA-HQ-OW-2006-0771-1701.
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Part III - Detailed Studies
PART III: DETAILED STUDIES
hi
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Section 16 - Health Care Industry and Hospitals Category (40 CFR Part 460)
16. Health Care Industry and Hospitals Category (40 CFR Part 460)
Pharmaceutical chemicals have been detected in our nation's waterways, leading to
concerns that these compounds may affect aquatic life and possible human health through
drinking water sources. As a result of public comments on the 2006 Final 2006 Plan, EPA
initiated a study of unused pharmaceutical disposal practices at health care facilities. The focus
of this study was on disposal to water via sewers. EPA studied medical facilities; including,
hospitals, hospices, long-term care facilities, health care clinics, physician offices, and veterinary
facilities. A standard disposal practice at many health care facilities is to flush unused
pharmaceuticals down the toilet or drain.
Unused pharmaceuticals include leftover medication that is expired, not dispensed, and/or
partially used, and residues from delivery devices. During the study, EPA conducted intensive
outreach to over 700 stakeholders and evaluated a range of management practices to reduce the
generation of unused pharmaceuticals and their disposal down the drain. Based on the
information collected through the outreach, EPA has drafted a guidance document, "Best
Management Practices for Unused Pharmaceuticals at Health Care Facilities" (U.S. EPA, 2010).
The guidance document was made available for a 60 day public review and comment as
announced in a Federal Register Notice, published on September 8, 2010 (75 FR 54627). The
draft guidance document was posted on the Agency's website.
In summary, the guidance recommends the following practices to prevent or minimize
the amount of pharmaceuticals being disposed in water:
• Conduct an inventory of pharmaceuticals and pharmaceutical waste to quantify
the amount of medication the facility is disposing of;
• Reduce pharmaceutical waste by reviewing purchasing practices, use limited dose
or unit dose dispensing, replace pharmaceutical samples with vouchers, and
perform on-going inventory control and stock rotation;
• Reuse or donate unused pharmaceuticals when possible; return unused
pharmaceuticals to the pharmacy; send unused pharmaceuticals to a reverse
distributor for credit and proper disposal in accordance with the facility's state
environmental regulations; properly identify and manage hazardous
pharmaceutical wastes in accordance with federal and state regulations; use EPA
recommended practices to dispose of non-hazardous pharmaceutical waste at the
facility;
• Segregate waste for disposal to ensure regulations are met; and
• Train staff in proper disposal methods.
EPA received 89 comments on the proposed guidance on November 8, 2010 and is
reviewing suggested changes to the document and working with relevant Federal Agencies to
ensure any incorporated comments are consistent with other Federal laws and policies. EPA
plans to issue the study report and final guidance in 2011 and will notify stakeholders directly
and by means of its website at:
http://water.epa.gov/scitech/wastetech/guide/unusedpharms_index.cfm.
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Section 16 - Health Care Industry and Hospitals Category (40 CFR Part 460)
16.1 Health Care Industry and Hospitals Category References
1. U.S. EPA. 2010. Draft Guidance Document: Best Management Practices for Unused
Pharmaceuticals at Health Care Facilities. EPA-821-R-10-006. Washington, DC.
(August 26). Available online at:
http://water.epa.gov/scitech/wastetech/guide/upload/unuseddraft.pdf.
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Section 17 - Oil and Gas Extraction (40 CFR Part 435)
17. Oil and Gas Extraction (40 CFR Part 435)
As a result of prior 304(m) planning, EPA initiated a detailed study of the coalbed
methane industry and its wastewater discharges. Coalbed methane extraction is considered a
subcategory of the Oil and Gas Extraction (Oil and Gas) Category, although it is not currently
subject to the ELGs promulgated for this category. Since 2006, the coalbed methane industry has
expanded. In addition, EPA received comments in 2005, 2008, and again during the 2010 review
from citizens and environmental advocacy groups requesting development of a regulation for
coalbed methane extraction as well as for shale gas extraction, another subcategory of the Oil
and Gas Category. Unlike coalbed methane extraction, however, shale gas extraction is now
subject to the Oil and Gas ELGs, although there are currently no applicable categorical
pretreatment standards for shale gas extraction.
Coalbed methane-produced water discharges can impact receiving surface waters and
soils. Saline discharges from coalbed methane operations can adversely affect aquatic life. The
large volume of water discharged can also cause stream bank erosion and salt deposition,
creating hardpan soil. Long-term impacts include sodium buildup, reduction of plant diversity,
mobilization of salts and other elements, and alteration of surface and subsurface hydrology.
17.1 Overview of Operations
Methane gas is naturally created during the geologic process of converting plant material
to coal (coalification). To extract the methane, coalbed methane operators drill wells into coal
seams and pump out ground water. Removing the ground water from the formation is necessary
to produce coalbed methane, as the water removal reduces the pressure and allows the methane
to release from the coal to produce flowing natural gas. In 2008, 252 coalbed methane operators
managed approximately 55,500 coalbed methane wells in the U.S. in 13 distinct regions, called
basins.
17.2 Produced Water
The ground water that has been pumped out of the well, called "produced water," like
most ground water found deep below the surface of the earth, has high salinity and can include
pollutants such as chloride, sodium, sulfate, bicarbonate, fluoride, iron, barium, magnesium,
ammonia, and arsenic. To quantify the amount of pollutants in coalbed methane produced
waters, EPA relied on measuring total dissolved solids and electrical conductivity, which are
bulk parameters for quantifying the total amount of dissolved solids in a wastewater.
A single coalbed methane well can discharge thousands of gallons of produced water per
day, and may discharge produced water for anywhere from 5 to 15 years. Coalbed methane wells
have a distinctive production history characterized by: an early stage when large amounts of
water are produced to reduce reservoir pressure which in turn encourages release of gas; a stable
stage when quantities of produced gas increase as the quantities of produced water decrease; and
a late stage when the amount of gas produced declines and water production remains low.
The quantity and quality of produced water varies from basin to basin, within a particular
basin, from coal seam to coal seam, and over the lifetime of a coalbed methane well. For
example, coalbed methane produced water volumes range from 1,000 gallons per day (gpd) per
well in the San Juan Basin to 17,000 gpd per well in the Powder River Basin.
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Section 17 - Oil and Gas Extraction (40 CFR Part 435)
17.2.1 Management of Produced Water
Coalbed methane operators need to dispose of thousands of gallons of produced water per
day for each coalbed methane well. Operators can employ a range of options for treatment and
management of this wastewater.
Preliminary estimates based on survey data predict that approximately 47 billion gallons
of produced water are pumped annually from coal seams across the country. Approximately 45
percent of those produced waters are directly discharged to waters of the U.S., for a total national
discharge of 22 billion gallons per year.
Surface water discharge is most prevalent in three U.S. coalbed methane basins:
• The Black Warrior Basin in Alabama and Mississippi (11 percent of total coalbed
methane surface discharges);
• The Powder River Basin in Wyoming and Montana (72 percent of total coalbed
methane surface discharges); and
• The Raton Basin in Colorado and New Mexico (11 percent of total coalbed
methane surface discharges).
Many of these discharges are largely untreated. Surface discharge occurs rarely, if at all, in the
other major commercial basins.
In the other commercial basins in the U.S, coalbed methane operators are, for the most
part, able to prevent discharging their produced water by discharging the water to land (where
there may be other impacts to the soil or vegetation), re-injecting the produced water back into
the ground, or using the water in one of many beneficial use options (e.g., stock watering,
irrigation).
17.2.2 Treatment of Produced Waters
Available technology options for adequately removing pollutants from produced water
include ion exchange and reverse osmosis.
17.3 Summary of Outreach
In 2007, EPA conducted several site visits to coalbed methane basins throughout the
country and gathered information on potential treatment technologies for coalbed methane-
produced water discharges. EPA also conducted widespread outreach with stakeholders, both in
the industry and from the communities adjacent to coalbed methane basins. EPA conducted more
than 30 site visits to locations in 6 coalbed methane basins and met with over 300 different
stakeholders. EPA also conducted 13 meetings and teleconferences with over 150 stakeholders.
In addition to the extensive information collection through site visits and outreach, EPA
acknowledged that an informed decision about rulemaking would require even more detailed
information. EPA developed an industry questionnaire, solicited public comment twice, and in
2009 obtained OMB approval under the Paperwork Reduction Act, to conduct a mandatory
survey directed at operators of coalbed methane projects which consist of a single well or a
group of wells operated by the same company. The questionnaire collected technical and
economic data in a two-part survey, a screener and a detailed survey, on the operations and
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Section 17 - Oil and Gas Extraction (40 CFR Part 435)
operators of coalbed methane projects. Questionnaire responses arrived in early 2010 and the
data was used by EPA to create national estimates of pollutant discharges across the country
from the coalbed methane industry and to develop an economic profile of the industry.
In response to the Preliminary 2010 Plan, EPA received 32 comments on coalbed
methane extraction. Comments from industry sources did not support rulemaking for coalbed
methane, suggesting an effluent guideline was not appropriate due to the variability of produced
water quality, quantity and available management techniques across the country. Additionally,
industry stated that the current regulatory framework of site-specific BPJ permits was adequately
addressing pollutant discharges from produced water discharges.
The final detailed study report for coalbed methane is being issued concurrent with the
Final 2010 Plan (U.S. EPA, 2010).
Coalbed methane production represents about 8 percent of natural gas production in this
country, and coalbed methane extraction is expected to continue for decades. Of the 22 billion
gallons of water discharged to surface water each year some has high total dissolved solids. The
detailed study also found that there are readily available technologies to treat this produced
water. As a result of the information gathered in the detailed study, EPA has decided to initiate
rulemaking for coalbed methane extraction, a currently unregulated subcategory of the Oil and
Gas Category.
17.4 Oil and Gas Extraction References
1. U.S. EPA. 2010. Coalbed Methane Extraction: Detailed Study Report. EPA-821-R-10-
022. Washington, DC. EPA-HQ-OW-2008-0517 DCN 09999.
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