vvEPA
821-B-05-004
Preliminary 2005 Review of
Prioritized Categories of
Industrial Dischargers
U.S. Environmental Protection Agency
Engineering and Analysis Division
Office of Water
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
August 2005
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ACKNOWLEDGMENT AND DISCLAIMER
This report was prepared with the technical support of Eastern Research Group,
Inc. under the direction and review of the Office of Science and Technology. Neither the United
States Government nor any of its employees, contractors, subcontractors, or their employees
make any warrant, expressed or implied, or assume any legal liability or responsibility for any
third party's use of, or the results of, such use of any information, apparatus, product, or process
discussed in this report, or represents that its use by such party would not infringe on privately
owned rights.
The primary contacts regarding questions or comments on this document are:
Carey Johnston
U.S. EPA Engineering and Analysis Division (4303T)
1200 Pennsylvania Avenue NW
Washington, DC 20460
(202) 566-1014 (telephone)
(202) 566-1053 (fax)
i oh n ston. carev @ epa. gov
Jan Matuszko
U.S. EPA Engineering and Analysis Division (4303T)
1200 Pennsylvania Avenue NW
Washington, DC 20460
(202) 566-1035 (telephone)
(202) 566-1053 (fax)
matuszko. i an@epa. uov
i
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TABLE OF CONTENTS
Page
1.0 Introduction 1-1
A. Selection of Categories for Review 1-1
B. Purpose and Scope of Preliminary Category Review 1-3
c. Data Sources 1-4
D. Category Review During 2003 and 2004 Annual Reviews 1-5
E. Structure of this Report 1-6
F. References 1-7
2.0 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR 414) 2-1
A. Industry Description 2-2
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 2-3
c. Results of Screening-Level Analysis 2-4
D. Potential New Subcategories 2-6
E. Pollutants of Concern 2-7
F. Stakeholder Outreach 2-11
G. Issues Identified and Additional Review 2-15
H. References 2-16
3.0 Petroleum Refining (40 CFR 419) 3-1
A. Industry Description 3-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 3-2
c. Results of Screening-Level Analysis 3-2
D. Potential New Subcategories 3-3
E. Pollutants of Concern 3-4
F. Issues Identified and Additional Review 3-8
G. References 3-8
4.0 Pesticide Chemicals (40 CFR 455) 4-1
A. Industry Description 4-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 4-2
c. Results of Screening-Level Analysis 4-4
D. Potential New Subcategories 4-5
E. Pollutants of Concern 4-5
F. Issues Identified and Additional Review 4-7
G. References 4-7
5.0 Nonferrous Metals Manufacturing (40 CFR 421) 5-1
A. Industry Description 5-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 5-2
c. Results of Screening-Level Analysis 5-2
D. Potential New Subcategories 5-3
E. Pollutants of Concern 5-3
li
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TABLE OF CONTENTS (Continued)
Page
F. Issues Identified and Additional Review 5-5
G. References 5-6
6.0 Ore Mining and Dressing (40 CFR 440) 6-1
A. Industry Description 6-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 6-2
c. Results of Screening-Level Analysis 6-4
D. Potential New Subcategories 6-4
E. Pollutants of Concern 6-5
F. Issues Identified and Additional Review 6-6
G. References 6-8
7.0 Inorganic Chemicals Manufacturing (40 CFR 415) 7-1
A. Industry Description 7-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 7-2
c. Results of Screening-Level Analysis 7-2
D. Potential New Subcategories 7-4
E. Pollutants of Concern 7-4
F. Issues Identified and Additional Review 7-7
G. References 7-7
8.0 Rubber Manufacturing (40 CFR 428) 8-1
A. Industry Description 8-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 8-2
c. Results of Screening-Level Analysis 8-3
D. Potential New Subcategories 8-4
E. Pollutants of Concern 8-4
F. Issues Identified and Additional Review 8-6
G. References 8-7
9.0 Textile Mills (40 CFR 410) 9-1
A. Industry Description 9-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 9-2
c. Results of Screening-Level Analysis 9-3
D. Potential New Subcategories 9-4
E. Pollutants of Concern 9-4
F. Issues Identified and Additional Review 9-6
G. References 9-7
10.0 Fertilizer Manufacturing (40 CFR 418) 10-1
A. Industry Description 10-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 10-2
c. Results of Screening-Level Analysis 10-3
in
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TABLE OF CONTENTS (Continued)
Page
D. Potential New Subcategories 10-3
E. Pollutants of Concern 10-3
F. Issues Identified and Additional Review 10-5
G. References 10-6
11.0 Plastics Molding and Forming (40 CFR 463) 11-1
A. Industry Description 11-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 11-2
c. Results of Screening-Level Analysis 11-3
D. Potential New Subcategories 11-4
E. Pollutants of Concern 11-5
F. Issues Identified and Additional Review 11-6
G. References 11-7
12.0 Porcelain Enameling (40 CFR 466) 12-1
A. Industry Description 12-1
B. Existing Effluent Limitations Guidelines and Pretreatment Standards 12-2
c. Results of Screening-Level Analysis 12-3
D. Potential New Subcategories 12-4
E. Pollutants of Concern 12-4
F. Issues Identified 12-6
G. References 12-6
iv
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LIST OF TABLES
Page
1-1 Categories Identified for Additional Review, Ranked According to Combined
PCS and TRI TWPE 1-2
1-2 2003 and 2004 Category Reviews 1-6
2-1 Number of OCPSF Facilities 2-2
2-2 Applicability of Subcategories in the OCPSF Point Source Category 2-3
2-3 OCPSF Point Source Category TWPE 2-5
2-4 OCPSF Point Source Category TRI and PCS Discharges for 2000 and 20021 2-6
2-5 Pollutant Loadings From Potential New Subcategories 2-7
2-6 Pollutants of Concern from 2004 Detailed Study of the OCPSF Category 2-7
2-7 OCPSF Point Source Category, Top TRI Chemicals for 2000 and 2002 2-9
2-8 OCSPF Point Source Category, Top PCS Chemicals for 2000 and 2002 2-10
2-9 Dioxin Discharges Reported to TRI by OCPSF Facilities 2-18
3-1 Number of Petroleum Refining Facilities 3-2
3-2 Petroleum Refining Point Source Category TRI and PCS Discharges for 2000 and
2002 3-3
3-3 Pollutant Loadings From Potential New Subcategories 3-4
3-4 Petroleum Refining Point Source Category, Top TRI Chemicals for 2000 and
2002 3-4
3-5 Petroleum Refining Point Source Category, Top PCS Chemicals for 2000 and
2002 3-7
3-6 2000 and 2002 Dioxin Discharges Reported to TRI By Petroleum Refineries 3-10
3-7 2000 and 2002 PACs Discharges Reported to TRI By Petroleum Refineries 3-12
4-1 Number of Pesticide Chemicals Facilities 4-1
4-2 Applicability of Subcategories in the Pesticide Chemicals Point Source Category . . . 4-2
v
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LIST OF TABLES (Continued)
Page
4-3 Pesticide Chemicals Point Source Category TRI and PCS Discharges for 2000
and 2002 4-4
4-4 Pesticide Chemicals Point Source Category, Top TRI Chemicals for 2000 and
2002 4-5
4-5 Pesticide Chemicals Point Source Category, Top PCS Chemicals for 2000 and
2002 4-6
5-1 Number of Nonferrous Metals Manufacturing Facilities 5-1
5-2 NFM Manufacturing Point Source Category TRI and PCS Discharges for 2000
and 2002 5-3
5-3 NFM Manufacturing Point Source Category, Top TRI Chemicals for 2000 and
2002 5-4
5-4 NFM Manufacturing Point Source Category, Top PCS Chemicals for 2000 and
2002 5-5
6-1 Number of Ore Mining and Dressing Facilities 6-1
6-2 Applicability of Subcategories in the Ore Mining and Dressing Point Source
Category 6-2
6-3 Ore Mining and Dressing Point Source Category TRI and PCS Discharges for
2000 and 2002 6-4
6-4 Ore Mining and Dressing Point Source Category, Top TRI Chemicals for 2000
and 2002 6-5
6-5 Ore Mining and Dressing Point Source Category, Top PCS Chemicals for 2000
and 2002 6-6
7-1 Number of Inorganic Chemical Manufacturing Facilities 7-1
7-2 Inorganic Chemicals Manufacturing Point Source Category TWPE 7-2
7-3 Inorganic Chemicals Manufacturing Point Source Category TRI and PCS
Discharges for 2000 and 2002 7-3
7-4 Inorganic Chemicals Manufacturing Point Source Category, Top TRI Chemicals
for 2000 and 2002 7-4
vi
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LIST OF TABLES (Continued)
Page
7-5 Inorganic Chemicals Manufacturing Point Source Category, Top PCS Chemicals
for 2000 and 2002 7-6
8-1 Number of Rubber Manufacturing Facilities 8-1
8-2 Applicability of Subcategories in the Rubber Manufacturing Point Source
Category 8-2
8-3 Rubber Manufacturing Point Source Category TRI and PCS Discharges for 2000
and 2002 8-4
8-4 Rubber Manufacturing Point Source Category, Top TRI Chemicals for 2000 and
2002 8-5
8-5 Rubber Manufacturing Point Source Category, Top PCS Chemicals for 2000 and
2002 8-6
9-1 Number of Textile Mills 9-1
9-2 Applicability of Subcategories in the Textile Mills Point Source Category 9-2
9-3 Textile Mills Point Source Category TRI and PCS Discharges for 2000 and 2002 . . . 9-3
9-4 Pollutant Loadings From Potential New Subcategories 9-4
9-5 Textile Mills Point Source Category, Top TRI Chemicals for 2000 and 2002 9-5
9-6 Textile Mills Point Source Category, Top PCS Chemicals for 2000 and 2002 9-5
10-1 Number of Fertilizer Manufacturing Facilities 10-1
10-2 Applicability of Subcategories in the Fertilizer Manufacturing Point Source
Category 10-2
10-3 Fertilizer Manufacturing Point Source Category TRI and PCS Discharges for
2000 and 2002 10-3
10-4 Fertilizer Manufacturing Point Source Category, Top TRI Chemicals for 2000 and
2002 10-4
10-5 Fertilizer Manufacturing Point Source Category, Top PCS Chemicals for 2000
and 2002 10-5
vii
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LIST OF TABLES (Continued)
Page
11-1 Number of Plastics Molding and Forming Facilities 11-1
11-2 Applicability of Subcategories in the Plastics Molding and Forming Point Source
Category 11-2
11-3 Plastics Molding and Forming Point Source Category TRI and PCS Discharges
for 2000 and 2002 11-3
11-4 Cellulose Manufacturing Facilities in the Plastics Molding and Forming Point
Source Category 11-4
11-5 Plastics Molding and Forming Point Source Category TRI and PCS Discharges
Comparing Total 2002 Discharge to Cellulose Facilities 2002 Discharge 11-4
11-6 Plastics Molding and Forming Point Source Category, Top TRI Chemicals for
2000 and 2002 11-5
11-7 Plastics Molding and Forming Point Source Category, Top PCS Chemicals for
2002 11-6
12-1 Number of Porcelain Enameling Facilities 12-2
12-2 Applicability of Subcategories in the Porcelain Enameling Point Source Category . . 12-3
12-3 Porcelain Enameling Point Source Category TRI and PCS Discharges for 2002 .... 12-4
12-4 Porcelain Enameling Point Source Category, Top TRI Chemicals for 2002 12-5
12-5 Porcelain Enameling Point Source Category, Top PCS Chemicals for 2002 12-5
viii
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l.o Introduction
EPA conducted its 2005 annual review of the existing effluent guidelines it has
promulgated for 56 categories of industrial dischargers. The first component of EPA's annual
review was a screening-level analysis of all promulgated effluent guidelines. During the
screening-level analysis, EPA estimated the pounds of toxic pollutants discharged by industrial
categories with existing effluent guidelines. The second component of EPA's annual review is a
more extensive review of certain categories prioritized based on their high estimated toxic
discharges. EPA is conducting detailed studies of the two categories with the highest estimated
toxic discharges, as well as a less detailed preliminary review for 11 additional categories.
This report describes the results of EPA's 2005 preliminary review of prioritized
categories of industrial dischargers. EPA will continue evaluating these categories during its
2006 annual review, as it prepares the 2006 Effluent Guidelines Program Plan.
This section presents background information about the 2005 preliminary category
review, in the following subsections:
A. Selection of Categories for Review;
B. Purpose and Scope of Preliminary Category Review;
C. Data Sources;
D. Category Review During 2003 and 2004 Annual Reviews;
E. Structure of this Report; and
F. References.
A. Selection of Categories for Review
EPA ranked point source categories according to the reported discharges of toxic and
nonconventional pollutants, based primarily on data from EPA's Toxics Release Inventory (TRI)
and EPA's Permit Compliance System (PCS). EPA calculated the discharge loads in units of
toxic-weighted pound equivalents (TWPE) by multiplying the reported pounds of pollutant
discharged by pollutant-specific toxic weighting factors (TWFs). EPA estimated TWPE for each
of the 56 industrial categories with existing effluent guidelines using data in PCS and TRI. The
1-1
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TRI loadings reflect direct and indirect dischargers, while the PCS loadings reflect only major
direct dischargers. EPA combined the two estimates into a single loading for each category by
adding the TWPE calculated with PCS data to the TWPE calculated with TRI data.
As it developed category rankings, EPA eliminated categories currently subject to an
effluent guidelines rulemaking and categories for which effluent guidelines regulations were
promulgated or revised within the last seven years.
EPA also excluded certain data from the category rankings development. First, because
it is in the process of developing or revising effluent guidelines for discharges from facilities that
produce vinyl chloride and/or that produce chlorine by the chlor-alkali process, EPA subtracted
the TWPE from facilities that produce these chemicals from the TWPE for the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) and Inorganic Chemicals Manufacturing
Point Source Categories. EPA also subtracted the TWPE associated with a single facility that
dominates (>95%) the toxic pollutant discharges for an entire industrial category, because these
anomalous discharges are not likely to be representative of the entire category.
After making these adjustments, EPA prioritized the 13 categories cumulatively
discharging 95% of total TWPE for further review. These categories are listed in Table 1-1.
EPA's process used to prioritize categories for further review is detailed in the 2005 Screening-
Level Analysis Report. [ 1 ]
Table 1-1. Categories Identified for Additional Review, Ranked According to Combined
PCS and TRI TWPE
40 (T'U Part
Point Source Category
Uank
430
Pulp, Paper, and Paperboard
1
423
Steam Electric Power Generation
2
414
Organic Chemicals, Plastics, and Synthetic Fibers
3
419
Petroleum Refining
4
455
Pesticide Chemicals
5
421
Nonferrous Metals Manufacturing
6
440
Ore Mining and Dressing
7
1-2
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Table 1-1 (Continued)
40 CI' U Part
Point Source Category
Uank
415
Inorganic Chemicals
8
428
Rubber Manufacturing
9
410
Textile Mills
10
418
Fertilizer Manufacturing
11
463
Plastics Molding and Forming
12
466
Porcelain Enameling
13
Source: 2005 Screening-Level Analysis Report. [1]
B. Purpose and Scope of Preliminary Category Review
EPA selected the two highest ranking categories, Pulp, Paper, and Paperboard and Steam
Electric Power Generation, for detailed studies. The purpose of the detailed studies is to confirm
that the category discharges present potential harm to human health and the environment and to
identify possible remedies. Preliminary results of the two detailed studies are presented in
separate reports. [2, 3]
EPA is conducting preliminary reviews of the remaining categories in Table 1-1. During
the preliminary category review, EPA first seeks to verify the TRI- and PCS-reported discharges.
This verification entails additional data analysis (e.g., looking at multiple year discharge
monitoring reports in PCS) and communication with individual reporting facilities to verify TRI-
and PCS-reported 2002 discharges. EPA may also review data from additional sources, to
identify the potential process source(s) of discharged pollutants and potential pollution control
alternatives.
Preliminary category review may lead to one of the following EPA decisions:
Additional study is not warranted at this time;
Detailed study should be undertaken in the next planning cycle; or
The category's existing effluent guidelines should be revised.
1-3
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This report describes the status of the preliminary category reviews as of July 1, 2005.
EPA is making progress in verifying TRI- and PCS-reported discharges with industrial facilities,
and is beginning to review additional information to identify and understand potential pollutant
sources and control alternatives.
C. Data Sources
The 2005 annual review, including the preliminary category reviews discussed in this
report, builds upon EPA's 2003, 2004, and earlier annual reviews. In the 2003 and 2004 annual
review, EPA used PCS and TRI data to construct two databases using a relationship between
Standard Industrial Classification (SIC) codes and point source categories along with EPA's
TWFs. The databases, using year 2000 TRI and year 2000 PCS discharge information, were
named TRlReleases2000 v4 and PCSLoads2000 v6, respectively.
EPA constructed similar databases for the 2005 annual review, except the new databases
were based on discharge data for 2002. The development of the databases EPA used for the
2005 annual review, TRIReleases2002 and PCSLoads2002, is described in detail in the 2005
Screening-Level Analysis Report. [1] In addition to updating the discharge information, EPA
made three major types of changes to the databases:
TWFs used to calculate TWPE were revised. Changes to EPA's TWFs are
described in Toxic Weighting Factor Development in Support of the CWA 304(m)
Planning Process. [4] For example, the TWF for benzo(a)pyrene was decreased
from 4,284 to 101. Because EPA uses the benzo(a)pyrene TWF to estimate the
TWPE for the chemical category polycyclic aromatic compounds (which is
commonly reported to TRI), this change had a significant effect on estimated
category TWPEs. The impacts of the changes are discussed in Section 4 of the
2005 Screening-Level Analysis Report. [1]
The relationship between SIC codes and point source categories was refined. In
the previous databases, only pesticide discharges from SIC code 2879, Pesticide
and Agricultural Chemicals, were included in the Pesticide Chemicals category.
For the 2002 databases, EPA included pesticide discharges from facilities with
SIC codes for organic and inorganic chemical manufacturing activities because
the Pesticide Chemicals category regulations apply to these discharges. The
relationship between SIC codes and point source categories is described in
Section 5 of the 2005 Screening-Level Analysis Report. [1]
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Potential new subcategory loads were included in the total loads for existing
categories. EPA determined that, because of the similarity of operations and
wastewater characteristics, several industries with SIC codes not clearly subject to
existing effluent guidelines should be considered as potential new subcategories
of existing effluent guidelines. For the 2005 screening-level analysis, EPA
included pollutant loadings from the potential new subcategories in the totals for
the similar industrial category with existing effluent guidelines. For example, the
pollutant loadings from petroleum bulk stations and terminals (SIC code 5171)
were included in the pollutant loadings for the Petroleum Refining Point Source
Category (40 CFR 419). The relationship between SIC codes and potential new
subcategories is described in Section 5 of the 2005 Screening-Level Analysis
Report. [1]
D. Category Review During 2003 and 2004 Annual Reviews
Similar to the approach used for the 2005 annual review, EPA prioritized its 2003 and
2004 reviews of industries with existing effluent guidelines based on the results of a screening-
level analysis. EPA conducted detailed studies of the two highest ranking categories, OCPSF
and petroleum refining, and conducted preliminary reviews for several other categories. Table
1-2 lists the categories EPA is reviewing as part of its 2005 annual review, the level of review
they received during EPA's 2003 and 2004 annual reviews of existing effluent guidelines, and
the section of EPA's Technical Support Document for the 2004 Effluent Guidelines Program
Plan [5] in which the results of those reviews are reported.
1-5
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Table 1-2. 2003 and 2004 Category Reviews
CsiU'Sion
l.c\cl of 2003 iiml 2004 Kc\ic\\
TSD
Section
Organic Chemicals, Plastics, and Synthetic Fibers
Detailed study
6.0
Petroleum Refining
Detailed study
7.0
Pesticide Chemicals
No category review
5.7
Nonferrous Metals Manufacturing
Preliminary category review
5.3.2
Ore Mining and Dressing
Preliminary category review
5.4.2
Inorganic Chemicals
Preliminary category review
5.3.1
Rubber Manufacturing
No category review
5.7
Textile Mills
Preliminary category review
5.4.5
Fertilizer Manufacturing
Preliminary category review
5.4.1
Plastics Molding and Forming
No category review
5.7
Porcelain Enameling
No category review
5.7
Source: Technical Support Document for the 2004 Effluent Guidelines Program Plan. [5]
As described in Section B, as of July 1, 2005, EPA is continuing to verify TRI- and PCS-
reported 2002 discharges with individual facilities. As the 2002 discharges are verified, EPA
will compare the issues identified with the 2002 discharge data to the issues identified during
earlier category reviews and determine if they continue to be issues. The Agency will locate and
analyze additional information to understand potential pollutant sources and control alternatives.
E. Structure of this Report
The remainder of this report is divided into 11 sections, one for each of the categories
listed in Table 1-2. Each section includes the following:
A. Industry Description;
B. Existing Effluent Limitations Guidelines and Pretreatment Standards;
C. Results of Screening Level Analysis;
D. Potential New Subcategories;
E. Pollutants of Concern;
F. Issues Identified and Additional Review; and
G. References.
1-6
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References
U.S. EPA. 2005 Screening-Level Analysis Report. August 2005. Docket OW-2004-
0032. DCN 02173.
U.S. EPA. Preliminary Engineering Report: Pulp, Paper, and Paperboard Detailed
Study. August 2005. Docket OW-2004-0032. DCN 02177.
U.S. EPA. Preliminary Engineering Report: Steam Electric Detailed Study. August
2005. Docket OW-2004-0032. DCN 02176.
U.S. EPA. Toxic Weighting Factor Development in Support of the CWA 304(m)
Planning Process. August 2005. Docket OW-2004-0032. DCN 02013.
U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, D.C. August 2004. Docket OW-2003-0074. DCN
01088A01.
1-7
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2.0 Organic Chemicals, Plastics, and Synthetic Fibers (40 CFR 414)
In 2004, EPA conducted a detailed study of the Organic Chemicals, Plastics, and
Synthetic Fibers (OCPSF) Point Source Category; see 69 FR 53712 (Sept. 2, 2004). EPA found
that dioxin is, by far, the pollutant primarily responsible for the OCPSF industry's large toxic-
weighted pollutant discharge. EPA believes that the manufacture of ethylene dichloride (EDC),
vinyl chloride monomer (VCM), and polyvinyl chloride (PVC), referred to collectively as vinyl
chloride (VC) manufacturing, are sources of dioxin discharges. EPA found that the largest
dioxin discharges occurred at large integrated facilities that also operated chlor-alkali plants. In
addition, EPA found that dioxin discharges from stand-alone chlor-alkali plants are significant.
As a result, EPA identified VC manufacturing, which is subject to the OCSPF (Part 414) Point
Source Category, and chlor-alkali (CA) manufacturing, which is subject to the Inorganic
Chemicals Manufacturing (Part 415) Point Source Category, for possible effluent guidelines
revisions.
EPA reviewed two additional sectors of the OCPSF Point Source Category for the 2004
detailed study: aniline and dye manufacturers and coal tar refiners. Aniline and dye
manufacturers contributed the majority of aniline discharges reported to TRI for 2000. EPA
learned that most of these facilities discharge their wastewater to POTWs. Aniline is highly
treatable in biological systems and receiving POTWs indicated no interference issues with these
discharges. The coal tar refiners contributed the majority of PACs discharges reported to TRI
for 2000. EPA learned that the coal tar industry was declining, and that the polycyclic aromatic
compounds (PACs) discharges were at concentrations near or at treatability levels. As a result,
EPA determined that, based on the information available at that time, it was not appropriate to
select the aniline and dye manufacturing and coal tar refining sectors of the OCPSF Point Source
Category for possible effluent guidelines revision at that time.
This section describes the results of EPA's 2005 preliminary review of the OCPSF Point
Source Category.
2-1
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A. Industry Description
The OCPSF category includes many chemical industries producing a wide variety of end
products, such as polypropylene, vinyl chloride and 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. This category is divided into five SIC codes, as shown in Table 2-1; however, EPA is
considering including operations from five other SIC codes as potential new subcategories of the
OCPSF Point Source Category. See the Potential New Subcategories section (Section D) for
more details.
Table 2-1. Number of OCPSF Facilities
SIC ( ode
2002 U.S.
l-lconomic
Census
2002 TRI1
2002 PCS2
rw i .s.
I'lconomic
Census
2 I KI
2000 PCS2
2821 Plastic Materials,
Synthetic Resins, and Non-
vulcanized Elastomers
688
403
137
529
429
156
2823 Cellulosic Man-made
Fibers
8
5
4
6
5
4
2824 Synthetic Organic
Fibers, Except Cellulosic
94
40
9
100
22
7
2865 Cyclic Crudes and
Intermediates, Dyes and
Organic Pigments
217
106
33
195
107
34
2869 Industrial Organic
Chemicals NEC
3,215
469
189
740
429
191
l oliil ()( PSI
4,222
1,023
372
1,570
992
392
Pole nihil Now SulK'iik'iiork's
2842 Specialty Cleaning,
Polishing
604
138
3
727
97
6
2844 Perfumes, Cosmetics,
Toilet Preparations
1,586
43
10
737
39
12
2891 Adhesives and
Sealants
585
185
14
694
158
17
2899 Chemicals and
Chemical Preparations,
NEC
3,582
339
45
1,157
284
47
5169 Chemicals and Allied
Products, NEC
54,314
464
20
11,571
380
19
2-2
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Table 2-1 (Continued)
SIC ( ode
2002 U.S.
l-lconomic
Census
2002 TRI1
2002 PCS2
rw i .s.
I'lconomic
Census
2 I KI
2000 PCS2
Tolal Polcnlial Now
Subcalojion
(ğ0.(ğ"ğl
1.1 (ğ')
92
14.XX(i
958
101
Source: U.S. Economic Census, 1997 and 2002 [1, 2]; TRIReleases2002; PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000.
'Releases to any media.
2Major and minor dischargers.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges from OCPSF facilities are regulated under 40 CFRPart 414:
Organic Chemicals, Plastics, and Synthetic Fibers Point Source Category. This category consists
of eight subcategories that apply to the manufacture of products and product groups, as shown in
Table 2-2 with the corresponding SIC codes and applicability.
Table 2-2. Applicability of Subcategories in the OCPSF Point Source Category
Sub-
part
Subpart Title
Related SIC Codc(s)
Su b pa rt A p p I icab ilitv
B
Rayon Fibers
2823 Cellulosic Manmade Fibers
Cellulosic manmade fiber (Rayon)
manufactured by the Viscose process.
C
Other Fibers
2823 Cellulosic Manmade 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.
2-3
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Table 2-2 (Continued)
Suh-
|)
-------
Table 2-3. OCPSF Point Source Category TWPE
TRI 2
TKI 2002
PCS 2000
PCS 2002
Total TWPE
7,611,790
3,424,127
1,803,291
1,726,088
VC Sector Contribution1
5,932,973
2,796,270
31,653
15,083
(% of total)
(78)
(82)
(1.8)
(0.87)
Potential New Subcategories
76,466
50,910
35,356
16,902
Contribution (% of total)
(1.0)
(1.5)
(2.0)
(0.98)
TWPE w/o Potential New
1,602,351
576,947
1,736,282
1,694,103
Subcategories and VC Sector
Source: TRJReleases2002\ PCSLoads2002\ TRlReleases2000_v4; PCSLoads2000jv6.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'The VC sector of the OCPSF category includes facilities that manufacture EDC, VCM, and/or PVC and reported a
primary SIC code associated with OCPSF (see Section 2.A). This sector may include facilities that also perform
chlor-alkali manufacturing operations.
EPA is currently considering revisions to effluent guidelines for discharges from
facilities in the VC sector. Because a rulemaking for this sector is underway, the Agency
excluded discharges from these facilities from further consideration for the OCPSF review under
the current planning cycle.
Table 2-4 presents the total TRI and PCS discharges for 2000 and 2002 from OCPSF
facilities, including new potential subcategories. The table compares the number of facilities
reporting TWPE greater than zero, the pounds of pollutants discharged, and the estimated TWPE
discharged. As explained above, EPA subtracted the TWPE loads from facilities that are
considered part of the VC sector from the OCPSF loads. Even without the loads from the VC
sector, this category ranked in the top three categories in both 2002 TRI-reported TWPE and
2002 PCS-reported TWPE. As a result of the high TRI and PCS TWPE, the OCPSF Point
Source Category ranked third in combined TWPE. Because of this high ranking, EPA selected
this category for preliminary review.
As part of the preliminary review, EPA compared TRI and PCS data for 2002 to the 2000
data used for the detailed study to see if there were any major changes in discharges or number
of dischargers. As shown in Table 2-4, the number of reporters to TRI and PCS remained
somewhat constant. PCS data, however show a large decrease in pounds discharged from 2000
to 2002.
2-5
-------
Table 2-4. OCPSF Point Source Category TRI and PCS Discharges for 2000 and 20021
Number of l-'iicililics
Reporting Non/cm
T\\ IT.
l oliil Pounds
Dischiiriicd (million lbs.)
TWIT.
2002 TRI
792
54,528,174
627,857
2002 PCS
239
1,053,253,290
1,711,005
2002 loliil2
U0VXI.4(.4
2.33X.X(i2
2000 TRI
801
54,284,140
1,678,817
2000 PCS
230
2,320,381,376
1,771,637
2000 loliil2
2.3"74.(i(i5.5I(i
3.450.454
Source: TRIReleases2002\ PCSLoads2002\ TRIReleases2000jv4', PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
'Presents the total TRI and PCS discharges for OCPSF facilities and facilities in potential new subcategories
2Totals may include some double counting if facilities reported the same pollutant discharges to both TRI and PCS.
D. Potential New Subcategories
EPA reviewed industries with SIC codes not clearly subject to existing effluent
guidelines. EPA concluded the processes, operations, wastewaters, and pollutants of facilities in
the SIC codes listed in Table 2-5 are similar to those of the OCPSF category. Table 2-5 shows
the total TRI and PCS combined TWPE for each SIC code that is a potential new subcategory.
The discharges for these SIC codes contribute a negligible percentage of the total OCPSF
category TWPE. Consistent with the conclusions drawn during the 2004 detailed study [4], EPA
found that the majority of these facilities do not discharge wastewater and a small number
discharge significant TWPE. In addition, discharges associated with SIC code 2899 decreased
over 40% from 2000 to 2002.
2-6
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Table 2-5. Pollutant Loadings From Potential New Subcategories
SIC Code
SIC Description
( (mihilled TRI iiml
PCS 2002 TWPi:
Percenliiiie of Tolsil
Csili'fion l \\ PI!
2842
Specialty Cleaning, Polishing
1,048
0.04
2844'
Perfumes, Cosmetics, Toilet Prep
6,909
0.30
2891
Adhesives and Sealants
199
0.008
2899
Chemicals & Chem Prep, NEC
59,070
2.53
5169
Chemicals and Allied Products
587
0.03
Source: TRIReleases2002; PCSLoads2002.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Some operations at facilities that report SIC code 2844 may be subject to Pharmaceutical Manufacturing effluent
limitations guidelines and standards, if they manufacture products containing FDA-regulated pharmaceutical active
ingredients using certain manufacturing processes (see 40 CFR 439).
NEC - Not Elsewhere Classified.
E. Pollutants of Concern
TRI Discharges
During the 2004 detailed study of the OCPSF category [4], EPA identified three
pollutants of concern based on high TWPE discharges reported in TRI for 2000: aniline, PACs,
and dioxin and dioxin-like compounds. EPA reviewed the 2002 data to determine if these
pollutants still drove the OCPSF TWPE and if there were any changes in the reported discharges.
Table 2-6 presents the TRI releases of these pollutants for 2000 and 2002.
Table 2-6. Pollutants of Concern from 2004 Detailed Study of the OCPSF Category
( hcmiciil Niimo
2 TRI1
2002 TRI1
Number of
l-'iicililios
Reporting
Chcmk'iil
loliil
Pounds
Rc'k'iisod
T\\ PI.
Number of
l-'iicililics
Reporting
Chcmk'iil
loliil
Pounds
Roloiisod
i w pi:
PACs2
7
2,021
940,703
8
46
4,613
Sodium nitrite
37
725,517
270,860
43
670,855
250,452
Dioxin and dioxin-like
compounds2
8
0.0294
120,858
9
0.0225
152,200
Aniline2
25
85,637
120,397
21
46,820
321
Source: TRIReleases2002; TRIReleases2000_v4.
'TRI releases do not include releases from VC facilities.
2During the 2004 detailed study, EPA selected dischargers of dioxin, PACs, and aniline for focused review.
2-7
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For the 2004 analysis, EPA examined the highest pollutant discharges at the SIC code
level and determined that:
Facilities that reported PACs to TRI under SIC code 2865 all perform coal tar
refining. As shown in Table 2-6, TRI releases of PACs decreased significantly
from 2000 to 2002. Based on this, EPA concluded that coal tar refining was a
declining industry.
Facilities that reported aniline to TRI under SIC code 2865 either manufacture
aniline or produce dyes. Most discharges are indirect. Based on contact with
POTWs, EPA concluded that the aniline discharge was not interfering with
POTW operations. Pounds of aniline discharged decreased 45% from 2000 to
2002.
Facilities that reported releases of dioxin and dioxin-like compounds to TRI under
SIC codes 2821 and 2869 were mainly manufacturers of ethylene dichloride,
vinyl chloride monomer, and/or polyvinyl chloride, with some also having co-
located chlor-alkali plants. For this review, EPA selected these operations for
possible ELG revision and removed their discharges from the OCPSF category.
The remaining eight dioxin dischargers are manufacturers of "other organics,"
which were not selected for revision. These eight facilities contribute all of the
OCPSF dioxin discharges to TRI in 2000 in Table 2-6. For 2002, nine facilities
reported dioxin discharges to TRI. Table 3-9 lists these facilities and the products
they manufacture. Pounds of dioxin discharged decreased 23% from 2000 to
2002.
The specific pollutants driving the total TWPE estimate for this industry using the 2002
TRI data are similar to those identified in the previous study. Table 2-7 lists the five chemicals
with the highest TWPE of TRI-reported 2002 discharges, as well as the 2000 discharges of these
chemicals, for comparison purposes.
2-8
-------
Table 2-7. OCPSF Point Source Category, Top TRI Chemicals for 2000 and 2002
( homiciil
2002 TRI1
2 TRI1
2002
iwi'i:
Kiink
Nu in her of
l-'iicililios
Reporting
( hcmiciil
Toliil
Pounds
i w pi:
2000
T\\ PI
Riink
Number of
l-'iicililios
Reporting
(hcmiciil
Idlill
Pounds
T\\ PI
Sodium Nitrite
1
43
670,855
250,452
2
39
725,674
270,918
Dioxin and
Dioxin-like
Compounds
2
9
0.022
152,200
3
8
0.029
120,858
Hexachloro-
benzene
3
4
30
59,272
11
3
12
8,724
Chlorine
4
25
58,937
30,009
6
24
60,152
29,293
Dinitrotoluene
5
2
39,985
25,661
8
2
47,068
19,503
Source: TRJReleases2002\ TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Discharges from VC facilities are not included for 2000 or 2002.
Sodium nitrite and dioxin and dioxin-like compounds were large contributors to the TRI
TWPE for both 2000 and 2002. Table 2-9 at the end of this section presents the dioxin releases
reported to TRI for 2000 and 2002 and the products manufactured at each facility.
One facility contributed 41% of the sodium nitrite TWPE for the OCPSF Point Source
Category. EPA contacted this facility and learned that their sodium nitrite releases reported to
TRI are based on releases of nitrite. The facility calculated releases of nitrite by performing a
nitrogen balance on their biological treatment system. The facility assumes that the difference in
nitrogen concentration between the treatment system influent and effluent has been converted to
nitrate, and then applies a nitrite/nitrate ratio to calculate the amount of nitrite released. This
amount is reported to TRI as sodium nitrite. [5]
One facility contributed 77% of the chlorine TWPE for the OCPSF Point Source
Category. EPA contacted this facility to determine the basis of estimate for chlorine releases.
The facility stated that TRI-reported chlorine releases are based on the maximum concentration
of free available chlorine. [6]
2-9
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PCS Discharges
Table 2-8 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges of these chemicals. Hexachlorobenzene discharges
accounted for 64% of the PCS TWPE for 2002. The dramatic increase from 2000 to 2002 in
hexachlorobenzene TWPE is largely due to EPA correcting the TWF for this chemical1.
Hexachlorobenzene, a priority pollutant, is regulated under OCPSF with limitations of 15 ug/L
(monthly average) for direct dischargers with biological treatment and 196 ug/L (monthly
average) for indirect dischargers and direct dischargers without biological treatment.
Table 2-8. OCSPF Point Source Category, Top PCS Chemicals for 2000 and 2002
('lK'lllk';il
2002 PC S
2000 PCS'
2002
T\\ PI.
K;ink
NiIIIiIkT III"
l'';K'ililk's
Ki'|>iirliniirlin
-------
F. Stakeholder Outreach
Overview of Comments on OCPSF Effluent Guidelines
Congress has directed the Office of Management and Budget (OMB) to prepare an
annual report to Congress on the costs and benefits of Federal regulations. See 68 FR 64375
(February 20, 2004). In the 2004 draft report to Congress, OMB also solicited public comment
for "nominations of promising regulatory reforms relevant to the manufacturing sector,
particularly those relevant to the welfare of small and medium-sized enterprises." In particular,
OMB requested suggestions on "specific reforms to rules, guidance documents or paperwork
requirements that would improve manufacturing regulation by reducing unnecessary costs,
increasing effectiveness, enhancing competitiveness, reducing uncertainty and increasing
flexibility." [8]
In response to this solicitation two commenters suggested revisions to the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) effluent guidelines (40 CFR 414). The
commenters suggest that OCPSF facilities are discouraged by existing OCPSF effluent
guidelines from installing water re-use and reduction technologies and pollution prevention
practices and are penalized by more stringent limits because NPDES permit writers recalculate
lower mass-based permit limits based on the reduced wastewater flow rates when re-issuing
NPDES permits. The commenters suggest that OCPSF facilities should be able to retain mass
limits of the original stringency, established prior to wastewater flow reduction, when process
wastewater flows are reduced for purposes of water conservation. The commenters also stated
that if process wastewater flows are decreased for other reasons, the mass-based limits should
continue to be adjusted pursuant to the current rule.
Current Effluent Guidelines Requirements
Following is a brief discussion of the current approach under the existing OCPSF effluent
guidelines for direct dischargers. OCPSF effluent guidelines require NPDES permit writers to
establish flow-normalized mass-based permit limits for OCPSF facilities (see e.g., 40 CFR
2-11
-------
414.91(a). "Any point source subject to this subpart must achieve discharges not exceeding the
quantity (mass) determined by multiplying the process wastewater flow subject to this subpart
times the concentrations in the following table.") EPA explained how to calculate mass-based
permit limits for OCPSF facilities in the proposed and final OCPSF effluent guidelines. See 48
FR 11828 (March 21, 1983), 52 FR 42566 (November 5, 1987), 58 FR 36890 (July 9, 1993) and
the supporting OCPSF Technical Development Document [9], Mass limits for NPDES permits
are developed by multiplying the effluent guidelines limitations (when expressed as a
concentration) by the permittee's actual long-term average daily flow rate (i.e., not the design
flow rate). The objective in using the permittee's actual long-term average daily flow rate for
this calculation is to develop a single estimate of the average daily flow rate, which can
reasonably be expected to prevail during the next term of the permit. [10] Thus, it is necessary
for the permit writer to determine the facility's actual wastewater flow, based on information
supplied by the facility in the permit application.
Historically, EPA uses flow-normalized mass-based permit limits derived from
concentration-based effluent guidelines and a reasonable measure of the permittee's actual
long-term average daily wastewater flow rate because these limits encourage efficient water use,
reduce pollutant discharges, and discourage attempts to meet concentration-based limits through
use of dilution as a substitute for treatment. Facilities whose wastewater discharges are
controlled by flow-normalized mass-based permit limits may elect to control their wastewater
discharges through wastewater control technologies and pollution prevention practices or water
conservation practices, or both. When facilities reduce their long-term average daily wastewater
flow rates, they often maintain the same or better treatment efficiencies and pollutant
concentrations in the discharged effluents, thus leading to reductions in the mass of pollutants
discharged. For example, the record supporting the OCPSF effluent guidelines states: "[A] good
activated sludge plant will usually discharge 20 to 40 mg/L of BOD whether the influent BOD
concentration is 100 mg/L or 500 mg/L, if the plant is well designed and the design loadings are
not exceeded. Similarly, activated carbon adsorption of an organic pollutant will usually
produce a fairly constant effluent concentration over a wide range of influent concentrations as
long as the contact time is adequate and the carbon capacity has not been exhausted." [11] Case
studies demonstrating that reductions in wastewater flow may lead to commensurate reductions
2-12
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in pollutant loadings are presented in the docket. [12] For example, one facility installed water
conservation and re-use technologies and was able to reduce its water consumption by
approximately 60 percent (20,000 gallons per day) and also reduce effluent discharges by
approximately 85 percent.
Options for Promoting Water Conservation Through the Use of OCPSF Mass-based
Limits
As part of the Agency's commitments in the President's Manufacturing Initiative, EPA
began an evaluation of options for promoting water conservation through the use of mass-based
limits as part of its 2005 annual review of existing effluent guidelines. [13] EPA strongly
supports water conservation and encourages all sectors, including municipal, industrial, and
agricultural, to achieve efficient water use. EPA does not intend for its regulations to present a
barrier to efficient water use in any industrial sector.
EPA proposed, and is currently considering finalizing, greater flexibility for control
authorities to convert concentration-based pretreatment standards to flow-normalized mass-based
permit limits for indirect dischargers where necessary to facilitate adoption of water conservation
technologies, provided there is no increase in the discharge of pollutants to the environment. See
64 FR 39563 (July 22, 1999). EPA requests comment on whether it should consider a
rulemaking or other ways that would extend greater flexibility to permitting authorities to retain
mass-based limits based on current wastewater flows for direct discharges where necessary to
facilitate the prospective adoption of water conservation technologies. EPA is particularly
interested in specific, detailed examples of situations where the adoption of water conservation
technologies and practices have or have not made the achievement of new flow-normalized
mass-based permit limits based on the reduced wastewater flow more difficult.
Request for Comment
EPA solicits comment on the suggested revisions to the OCPSF effluent guidelines raised
by commenters. In particular, EPA requests comment on the likely advantages and
2-13
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disadvantages of the commenters' suggestion {i.e., allowing NPDES permittees to keep
flow-normalized mass-based permit limits established at the beginning of the prior permit term
before possible water re-use and reduction technologies and pollution prevention practices may
have been implemented). EPA requests data to evaluate the costs, benefits, and impacts of water
conservation practices advocated by commenters. EPA also solicits comment on whether the
commenters' suggestion could have a broader application to other industrial categories with
flow-normalized mass-based NPDES permit limits.
In particular, EPA requests paired influent and effluent regulated pollutant concentration
and flow data where available, before and after implementation of the increased water
conservation technologies and practices, to determine wastewater treatment performance {i.e.,
percent pollutant removals) and the discharged effluent pollutant concentrations for OCPSF (and
other) facilities that they believe may or may not have adversely impacted their ability to achieve
existing effluent guidelines. EPA also solicits other data on these water re-use and reduction
technologies and pollution prevention practices which may include:
The main reasons why these technologies and practices were adopted, and
whether these technologies and practices are transferrable to other facilities.
Detailed process flow diagrams including wastewater flows from each industrial
unit operation; typical pollutant concentration wastewater data from each
industrial unit operation; descriptions of the water conservation technologies and
practices employed at each of these industrial unit operations; and data and
descriptions on whether these water conservation technologies and practices
reduce the amount of wastewater volume or the mass of wastewater pollutants
resulting from an industrial unit operation or both.
Detailed descriptions of the wastewater treatment and the annual costs of
operating wastewater treatment to maintain compliance with the effluent
guidelines. Detailed descriptions of the capital and annual costs associated with
implementing water conservation technologies and practices and any cost savings
resulting from water conservation technologies and practices.
Additionally, EPA solicits estimates of the amount of increased water conservation and
the number of facilities that would adopt more advanced water conservation technologies and
practices as a sole result of: (1) implementing the commenters' suggestion; or (2) other factors
{e.g., limitations on water source availability, potential costs savings). EPA would be
2-14
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particularly interested in specific, detailed examples of situations where the adoption of water
conservation technologies and practices have or have not made the achievement of new
flow-normalized mass-based permit limits based on the reduced wastewater flow more difficult
for both direct and indirect dischargers. EPA solicits comment on how and when NPDES permit
writers are calculating flow-normalized mass-based permit limits when facilities reduce their
wastewater flow. EPA solicits comment on whether the commenters' suggestion is more or less
relevant to certain industries, treatment technologies, or pollutants. If EPA were to address the
commenters' suggestion, should any rule or guidance changes be limited to one or a few
industries (e.g., OCPSF) or more broadly applicable. EPA solicits comment on whether there
are differences between direct and indirect dischargers that might suggest that different
approaches are warranted.
Comments and data provided to EPA will be evaluated in the context of the CWA factors
required for consideration of effluent guidelines. Were EPA to make any effluent guidelines
revisions, they would need to be supported by an administrative record following an opportunity
for public comment based on available data.
G. Issues Identified and Additional Review
EPA's estimate of the toxicity of OCPSF Point Source Category discharges is due to high
TWPE from both TRI- and PCS-reported discharges. The largest contributors to TRI TWPE are
sodium nitrite and dioxin. The PCS TWPE is driven by discharges of hexachlorobenzene, which
is also a top pollutant in the 2002 TRI data. In addition, as explained in Section IX.G of the
Federal Register notice announcing the Preliminary 2006 Effluent Guidelines Program Plan (see
http://www.epa.gov/guide/plan.htmn. as part of its 2005 review of this category, EPA began an
evaluation of options for promoting water conservation through the use of mass-based limits for
this category. Further review of this category may focus on the following issues:
Analysis of the hexachlorobenzene dischargers, including potential process
sources, review of monthly measurement data in PCS, methods used to estimate
TRI-reported discharges, and verification of annual loads;
2-15
-------
Analysis of a single dioxin reporter in PCS, including the method of analysis for
chlorinated dibenzo-p-dioxin effluent;
Review of dioxin reporters in TRI (see Table 2-9) to determine potential process
sources and methods used to estimate reported discharges;
Further review of other top pollutants in TRI and PCS, including methods of
estimation and reported concentrations; and
Further evaluation of options for promoting water conservation through mass-
based limit.
H. References
I. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
2. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
3. U.S. EPA. 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, D.C. 2005.
4. U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA 821-R-04-014. Washington, D.C. August 2004. Docket OW-2003-0074. DCN
01088A01.
5. Telephone conversation with Dr. Wayne Appleton of DuPont, Belle, WV, and Meghan
KandleofERG. "Sodium Nitrite Discharges Reported to TRI." May 23, 2005.
6. Telephone conversation with Jeff Barnwell of Sterling Chemical, Texas City, TX, and
Meghan Kandle of ERG. "Chlorine Discharges Reported to TRI." May 23, 2005.
7. U.S. EPA. 2005 Screening-Level Analysis Report. Washington, D.C. August 2005.
Docket OW-2004-0032. DCN 02173.
8. Office of Management and Budget. 2004 Draft Report to Congress on the Costs and
Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal
Entities. Washington, D.C. 2004. Available online at:
http://www.whitehouse.gov/omb/inforeg/draft 2004 cbreport.pdf.
9. U.S. EPA. Development Document for Effluent Limitations Guidelines and Standards
for the Organic Chemical, Plastics, and Synthetic Fibers Point Source Category - Final.
EPA 440-1-87-009. Washington, D.C. October 1987. Page IX
2-16
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10. U.S. EPA. NPDES Permit Writers' Manual. EPA-833-B-96-003. Washington, D.C.
December 1996.
11. U.S. EPA. Development Document for Effluent Limitations Guidelines and Standards
for the Organic Chemical, Plastics, and Synthetic Fibers Point Source Category -
Proposed. EPA 440-1-83-009-b. Washington, D.C. February 1983. PageIX-3.
12. Memorandum to Public Record for the 2006 Effluent Guidelines Program Plan EPA
Docket Number OW-2004-0032 (vvvvvv.epa.uov/edockets/) from Carey Johnston, U.S.
EPA. "Options for Promoting Water Conservation Through the Use of Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) Mass-based Limits". August 5, 2005.
Docket OW-2004-0032-0029. DCN 02100.
13. Office of Management and Budget. Regulatory Reform in of the U.S. Manufacturing
Sector. Washington, D.C. March 9, 2005. Available online at:
http://www.whitehouse.gov/omb/inforeg/reports/manufacturing initiative.pdf.
14. Lyondell Chemical Company Web Site. July 18, 2005. Available online at:
http ://vvvvvv. 1 vondel 1 .com.
2-17
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Table 2-9. Dioxin Discharges Reported to TRI by OCPSF Facilities
IO
00
1 l\l II)
l ;u ilil\ Villlr
1 Mciilinii
2 1 l\l
2002 1 l\l
I'kmIiuI-
I'miincI-
1 \\ IT.
|{:iğiğ mI'
l-liiiLilc1
I'miiiiiK
1 \\ IT.
I5;isis mI'
1-liiimli'1
77536FNLND1818B
Atofina Petrochemicals
Inc.
LaPorte, TX
0.00017
1,162
O
0.0031
57,489
O
Polypropylene [4]
B8108VLSOL1 lOOW
Velsicol Chemical Corp.
Memphis, TN
0.0091
16,872
0.0039
37,068
Benzoate esters, polymeries, and monomerics [4]
48667THDWCMICHI
Dow Chemical Midland
Ops
Midland, MI
0.013
52,421
O
0.0095
25,502
M
Wide range of chemical products [4]
70669VSTCHOLDSP
Sasol NA Lake Charles
Complex
Westlake, LA
0.00044
2,974
o
0.00088
17,183
M
Alcohols, alumina, ethylene, linear alkyl
benzene, solvents, paraffins, ethoxylates [4]
06492MRCNCSOUTH
Cytec Industries Inc.
Wallingford, CT
0.0066
44,092
o
0.00020
13,460
O
Aliphatic isocyanate resins, polyurethane, meta
diisopropenybenzene, adhesion polymers,
formaldehyde resins, crosslinking monomers,
aerosol surfactants, coating chemicals [4]
24124HCHSTRT460
Celanese Acetate Celco
Plant
Narrows, VA
0.000030
200
o
0.000030
941
O
Cellulose acetate, flake, filament, and tow [4]
08023DPBNTCRT130
DuPont Chambers Works
Deepwater, NJ
0.00044
2,939
o
0.0023
334
o
Fluorochemicals, elastomers, Hytrel polyester
elastomer [4]
70669RCCHM900A1
Lyondell Chemical Co.2
Westlake, LA
NA3
NA3
NA3
0.0025
219
M
Toluene diisocyanate [14]
21226VSTCH3441F
Sasol NA Inc.
Baltimore, MD
0.000022
147
M
0.000037
3.26
o
Aluminum chloride, linear alkyl benzene,
muriatic acid (hydrochloric acid), specialty
alkylates. [4]
Totill
0.029
120,858
0.023
152,200
Source: TRIReleases2002; TRIReleases2000_v4.
- Monitoring data/measurements and O - Other approaches (e.g., engineering calculations).
2Lyondell Chemical was not included in OCPSF Focus Group 3 for the 2004 detailed study because the facility did not report dioxin to TRI until 2001.
3Facility did not report dioxin releases to surface water to TRI for 2000.
-------
3.0 Petroleum Refining (40 CFR 419)
In 2004, EPA conducted a detailed study of the Petroleum Refining Point Source
Category; see 69 FR 53714 (Sept. 2, 2004). EPA found that dioxins and PACs are the pollutants
primarily responsible for the petroleum refining industry's large toxic-weighted pollutant
discharge. EPA found that petroleum refining facilities may produce dioxins in high
concentrations during catalytic reforming and catalyst regeneration operations. However, based
on the information available at that time, EPA concluded that dioxins are discharged infrequently
and at concentrations close to the analytical minimum level. EPA also found that there is little
evidence that PACs are present in concentrations above the detection limit in refinery
wastewater discharges. Therefore, EPA determined that, based on the information available,
there was no need to revise the effluent guidelines for the Petroleum Refining Point Source
Category at that time.
This section describes the results of EPA's 2005 preliminary review of the Petroleum
Refining Point Source Category.
A. Industry Description
The petroleum refining industry includes facilities that produce gasoline, kerosene,
distillate fuel oils, residual fuel oils, and lubricants through fractionation or straight distillation of
crude oil, redistillation of unfinished petroleum derivatives, cracking, or other processes. This
industry is represented by one SIC code, 2911, as shown in Table 3-1; however, EPA is
considering including operations from four other SIC codes as new subcategories of the
Petroleum Refining Point Source Category; see Section D, Potential New Subcategories, for
more detail. Because the U.S. Economic Census reported data by the NAICS code and TRI and
PCS reported data by SIC code, EPA reclassified the NAICS data under the equivalent SIC code
to standardize the results. Note that because SIC code 5171 does not translate directly to a
NAICS code, EPA could not determine the number of facilities reported for SIC code 5171 for
the 2002 U.S. Economic Census data.
3-1
-------
Table 3-1. Number of Petroleum Refining Facilities
SIC Code
2002 U.S.
Ileonomie
Census
2002 TRI1
2002 PCS2
IW I .S.
r.eonomie
Census
2000
TRI1
2000
PCS2
2911 Petroleum Refining
199
163
153
242
175
159
Polcnliiil Now Siihciileiiories
2992 Lubricating Oils and
Greases
407
144
21
414
98
23
2999 Products of Petroleum
and Coal, NEC
74
22
17
66
20
19
4612 Crude Petroleum
Pipelines
271
0
23
382
22
5171 Petroleum Bulk Stations
and Terminals
NA3
599
446
9,104
503
498
l oliil lor Polcnliiil New
Suhciiloiioi'ios
>752
765
660
621
721
Source: U.S. Economic Census, 2002 and 1997 [1, 2]; TRJReleases2002\ PCSLoads2002; TRIReleases2000_v4;
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3Poor bridging between NAICS and SIC codes.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the petroleum refining industry are regulated under 40 CFR
Part 419: Petroleum Refining Point Source Category. This category consists of five
subcategories. EPA first promulgated effluent guidelines for the Petroleum Refining Point
Source Category in 1985, including BPT, BAT, BCT, PSES, NSPS, and PSNS for all
subcategories. EPA established numerical limitations for the toxic pollutants ammonia as
nitrogen, hexavalent chromium, phenolic compounds, sulfide, and total chromium in at least one
subcategory. For more information on the existing regulations for the Petroleum Refining Point
Source Category, see the 2004 Technical Support Document. [3]
C. Results of Screening-Level Analysis
Table 3-2 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting TWPE discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. The discharges in Table 3-2 include loadings
3-2
-------
from facilities in SIC codes EPA determined are potential new subcategories of the Petroleum
Refining Point Source Category. Between 2000 and 2002, the number of facilities reporting to
PCS increased by 15 (14%), while the number reporting to TRI increased by 19 (6%). While the
TRI and the PCS TWPE are both large, the TRI TWPE is more than three times larger than the
PCS TWPE for both 2000 and 2002. As a result of the high TRI and PCS TWPE, the Petroleum
Refining category ranked fourth in combined TWPE. Because of the high ranking, EPA selected
this category for preliminary review.
Table 3-2. Petroleum Refining Point Source Category TRI and PCS Discharges for 2000
and 2002
Number of li 1 ies
Rcporlinii Noil/cm 1 \\ I'll
loliil Pounds l)iscli;iriic'(l
i w pi:
2002 TRI
352
18,512,185
503,802
2002 PCS
107
7,606,670,158
166,045
2002 loliil
Ĥ'.(.25.1X2.343
(i(i').S4"7
2000 TRI
333
19,961,016
993,911
2000 PCS
107
1,449,784,899
198,994
2000 loliil
1.4(>')."745.<) 15
I.I92.Ğ)05
Source: TRIReleases2002; PCSLoads2002; TRIReleases2000_v4; PCSLoads2000jv6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA reviewed industries with SIC codes not clearly subject to existing ELGs. EPA
concluded the processes, operations, wastewaters, and pollutants of facilities in the SIC codes
listed in Table 3-3 are similar to those of the Petroleum Refining category. Table 3-3 shows the
total TRI and PCS combined TWPE for each SIC code that is a potential new subcategory. As
shown in the table, the discharges for the potential new subcategory SIC codes are a negligible
percentage of the total Petroleum Refining category TWPE. Consistent with the conclusions
drawn during the 2004 detailed study [3], EPA found that large numbers of these facilities
discharge no wastewater and a small number of facilities discharge significant TWPE.
3-3
-------
Table 3-3. Pollutant Loadings From Potential New Subcategories
SIC Code
SIC Description
( oinbilled TRI ;iikI
PCS 2002 I WPI.
Permiliiiie of Toisil
(iiloiion IWPI.
2992
Lubricating Oils and Greases
3,836
0.57
2999
Prod of Petroleum & Coal, NEC
1,915
0.29
4612
Crude Petroleum Pipelines
247
0.04
5171
Petroleum Bulk Stations & Terminals
1,551
0.23
Source: TRIReleases2002\ PCSLoads2002.
NEC - Not Elsewhere Classified.
E. Pollutants of Concern
TRI Discharges
Table 3-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges, as well as the 2000 discharges of these chemicals, for comparison purposes.
Table 3-4. Petroleum Refining Point Source Category, Top TRI Chemicals for 2000 and
2002
( lu'iiiii;il Viiiu-
2002 TRI
2 TRI
2002
T\\ PI.
Riink
NiiiiiIkt ill'
l-';iiililii's
Ki-|>iirlinnrliii
-------
Discharges of dioxin and PACs contributed the majority of the TWPE for both 2000
(87%) and 2002 (76%), according to the TRI data. The pounds of dioxin reportedly released by
petroleum refineries in 2002 is about half of the amount reportedly released in 2000. The PACs
TWPE decreased from 2000 to 2002, even though the pounds reportedly released increased, due
to a decrease in the TWF assigned by EPA.. [3] Metals discharged by petroleum refineries
account for 8.7% of the total TRI TWPE.
Dioxins. As was the case with the 2004 detailed study, EPA found that most petroleum
refineries do not monitor for dioxins. Only 17 refineries reported dioxin discharges to TRI in
2002. Fifteen of these 17 refineries also reported dioxin discharges to TRI in 2000. Table 3-5,
at the end of this section, lists the petroleum refineries reporting dioxin discharges to TRI 2002,
the reported 2000 and 2002 discharges, the basis of estimate for the discharge, and any
information collected from the facilities. The majority of the discharge loads are estimated as
flow multiplied by half the detection limit, or through the use of industry-derived emission
factors. Only 3 of the 17 dioxin discharges reported for 2002 are based on analytical data with
measurements above the detection limit. Conoco Phillips (Wilmington, CA) measured and
detected all 17 dioxin congeners being discharged from the catalytic reformer regeneration unit,
which EPA believes is a source of dioxin discharges. This facility has a wastewater treatment
facility, and the wastewater is then transferred to a POTW. [5] BP Toledo (Oregon, OH)
sampled its effluent once in September 2000. The facility detected nine congeners, including the
most toxic form, 2,3,7,8-TCDD; however, no dioxins were detected above the lower calibration
limit. [6] Tesoro Northwest (Anacortes, WA) measured its effluent four times between 2000 and
2001, and each sample was analyzed by two independent analytical laboratories. The facility
detected between 6 and 14 dioxin congeners in its final effluent, several of which were detected
below the lower calibration limit. The most toxic congener, 2,3,7,8-TCDD, was detected by one
laboratory for one of the samples. [7] The pounds of dioxin reported by petroleum refineries
decreased by about 50% and the TWPE decreased by about 60% from 2000 to 2002. This is due
to changes in the pounds reported and the congeners reported released by refineries.
PACs. Thirty-nine refineries reported PACs discharges to TRI in 2002. Twenty of the
39 refineries also reported PACs discharges to TRI in 2000. One facility, Flint Hills Resources
3-5
-------
(Corpus Christi, TX), accounts for 54% of the PACs TWPE. EPA contacted Flint Hills and
learned that they did not detect any PACs in their refinery effluent. In 2002, their reported PACs
discharge was based on V2 the detection limit times the effluent flow. [8] Table 3-6, at the end of
this section, lists the petroleum refineries reporting PACs discharges to TRI for 2002, the
reported 2000 and 2002 discharges, the basis of estimate for the discharge, and any information
collected from the facilities. The pounds of PACs released by petroleum refineries in 2002
increased by a factor of about six compared to the amount released in 2000; however, the TWPE
released in 2002 decreased compared to 2000. The increase in the amount of pounds released is
due to an increase in the number of facilities; there are 19 more facilities that reported PACs in
2002 than in 2000, including Flint Hills. The decrease in the TWPE released is due to a decrease
in the calculated petroleum refining PAC TWF, which decreased from 230.5 to 26.3. [3] EPA
has verified that one refinery, Marathon Ashland (Detroit, MI), did detect five PACs above the
detection limit in the refinery's final effluent. Other than this one facility, there is little evidence
that PACs are present in concentrations above the detection limit and there is no obvious source
of PACs releases to refinery wastewaters.
Metals. The total metals discharged in TRI 2002, based on TWPE, is almost half as much
as the metals discharged in TRI 2000. One reason for this change is that the TWF for vanadium
decreased from 0.62 to 0.035. Vanadium contributed 66% of the TRI metals TWPE in 2000, but
only contributes 8.1% of the TRI metals TWPE in 2002, even though the pounds of vanadium
released increased. The TWPE for lead is almost 3.5 times larger in 2002 than 2000; however,
the number of facilities reporting lead in 2002 increased by a factor of almost 5. Other metals
reported in TRI by petroleum refineries did not show any significant increases or decreases in
TWPE. In the 2004 detailed study, EPA concluded that the concentrations of metal pollutants in
refinery wastewaters is at or near treatable levels, leaving little to no opportunity to reduce
metals discharges through conventional end-of-pipe treatment. EPA will continue to review the
reported metals discharges for 2002.
3-6
-------
PCS Discharges
Table 3-5 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges of these chemicals. Sulfide accounted for 50% of the
2000 and 2002 PCS TWPE. The total silver discharge was 12 times larger in 2002 than in 2000.
This increase is due to one facility, Premcor Refining Group (Port Arthur, TX), that discharged
zero pounds of silver in 2000, but 752 pounds in 2002. EPA is in the process of contacting this
facility.
Table 3-5. Petroleum Refining Point Source Category, Top PCS Chemicals for 2000 and
2002
( homiciil
2002 PCS
2000 PCS'
2002
T\\ PI.
Kiink
Number of
l-'iicililics
Reporting
Chcmiciil
Ttllill
Pounds
i w pi:
2000
i w pi:
K;ink
Number of
l;icili(k'N
Reporting
(lu'iiiicnl
loliil
Pounds
iwpi:
Sulfide
1
77
29,851
83,626
1
72
36,048
100,954
Chlorine
2
17
45,011
22,918
2
15
52,267
25,453
Fluoride
3
12
406,609
14,231
3
11
462,807
16,198
Silver
4
7
769
12,669
17
5
65
1,073
Selenium
5
17
7,560
8,477
4
18
8,068
9,041
Source: PCSLoads2002; PCSLoads2000_v6.
Note: PCS facilities include major dischargers only.
'Values for 2000 include discharges reported for a variety of pollutant forms and may slightly overestimate
discharges.
Sulfide. Sulfide comprised 50% of the PCS TWPE for both 2000 and 2002. As
mentioned in Section B, sulfide is currently regulated by the petroleum refining effluent
guidelines. Petroleum refineries are currently achieving final effluent concentrations less than
baseline values and less than existing limits at 40 CFR Part 419. EPA will continue to review
the reported sulfide discharges for 2002 compared to existing effluent guidelines and permit
limits.
3-7
-------
F. Issues Identified and Additional Review
EPA's estimate of the toxicity of the Petroleum Refining category discharges is largely
due to the TRI-reported discharges of dioxins and PACs. Further review of this category may
focus on the following issues:
Additional analysis of the TRI-reported dioxin discharges, including methods
used to estimate reported discharges, and process sources;
Additional analysis of the TRI-reported PACs discharges, such as the methods
used to estimate reported discharge, and process sources;
Additional analyses of the TRI-reported metal discharges, such as the methods
used to estimate reported discharges, and process sources;
Additional analysis of the TRI-reported sodium nitrite discharges, such as the
methods used to estimate reported discharge, and process sources;
Additional analysis of the PCS-reported sulfide and silver discharges, such as
process sources, review of monthly measurement data, and concentrations
discharged; and
Pollution control technologies available to reduce dioxin, PACs, and sulfide
discharges.
G. References
1. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
2. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
3. U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, D.C. August 2004. Docket OW-2003-0074. DCN
01088A01.
4. Memorandum to 304(m) Record, EPA Docket Number OW-2004-0074 from Lynn Zipf,
EPA and Jan Matuszko, EPA. "Revisions to TWFs for Dioxin and its Congeners and
Recalculated TWPEs for OCPSF and Petroleum Refining". August 10, 2004.
3-8
-------
5. Telephone conversation with Ernie Hamann and Brian Christlieb of Conoco Phillips,
Wilmington, CA, and TJ Finseth of ERG. "Dioxin Releases from Conoco Phillips
Wilmington CA to TRI 2002." June 13, 2005.
6. Telephone conversation with Jim Nelson of BP Oil Co., Roger Claff of American
Petroleum Institute, Jan Matuszko of U.S. EPA/EAD, and Jill Lucy of ERG. "Dioxin
Discharges from BP Oil Company's Toledo Refinery." July 26, 2004.
7. Telephone conversation with Rebecca Spurling of Tesoro Northwest Co., Anacortes,
WA, and TJ Finseth of ERG. "Tesoro Northwest Dioxin Discharges in TRI 2002." June
29, 2005.
8. Telephone conversation with Jan Golden of Flint Hills Resources, Corpus Christi, TX,
and TJ Finseth of ERG. "Flint Hills PACs Discharges in TRI 2002." May 23, 2005.
9. Telephone conversation with Reed Marton of Conoco Phillips Lake Charles Refinery,
Westlake, LA, and TJ Finseth of ERG. "Conoco Phillips Dioxin and PACs Discharges in
TRI 2002 and Sulfide Discharge in PCS 2002." May 20, 2005.
10. Pierce, D.W. 2005. Chevron Dioxin and PACs Wastewater Discharges. Letter
communication to T.J. Finseth (July).
11. Telephone conversation with David Beener of Exxonmobil Joliet Refinery, Channahon,
IL, and TJ Finseth of ERG. "Exxonmobil Joliet Dioxin Discharges in TRI 2002." May
20, 2005.
12. Telephone conversation with Honor Sheard of Marathon Ashland, Detroit, MI, and TJ
Finseth of ERG. "Marathon Ashland, Detroit, MI, Dioxin and PACs Discharges."
February 3, 2005.
13. Gulf Coast Waste Disposal Authority (GCA). 2003 Peak Performance Award
Application.
14. Telephone conversation with Toni Bennett of Calcasieu, Lake Charles, LA, and TJ
Finseth of ERG. "Calcasieu PACs Discharges in TRI 2002." May 31, 2005.
3-9
-------
Table 3-6. 2000 and 2002 Dioxin Discharges Reported to TRI By Petroleum Refineries
o
1 l\l II) \ her
UrllllrlA
UrllllCIA
1 Mciiiinii
1 l\l
21102 1 l\l
1111Ğği'iiiii1 iĞğn ( ollt'flctl h\ \ v\
<>11 Dioxin Urlt'jiM's Ucporlctl lo
1 Kl in 2002
(.1:1111-'
1 \\ IT.
liii-i- mI'
I'.olilllillr
1 \\ IT.
li:iĞiĞ mI'
I'.olilllillr
98221SHLLLWESTM
Tesoro Northwest Co.
Anacortes,
WA
5.199947
19,264
M
1.6329
45,504
M
Facility collected two samples of
final effluent in both 2000 and
2001. Several congeners detected
above the detection limit. [7]
77590MRTHNFOOTO
Marathon Ashland
Petroleum LLC
Texas City,
TX
2
54,811
O
0.00435
301
O
No comment.
70669CNCLKOLDSP
Conoco Lake Charles
Refinery
Westlake, LA
0.5392
14,777
E
0.5392
48,580
O
Estimate based on emission
factors. [9]
94802CHVRN841ST
Chevron Prods. Co.
Richmond Refinery
Richmond,
CA
0.339997
6,785
O
0.76
19,229
O
Based on detection limit. Two
samples analyzed (no values
above detection limit). [3]
90245CHVRN324WE
Chevron USA Prods. Co.
El Segundo,
CA
0.329997
5,477
M
0.109
11,191
M
Wastewater effluent was analyzed
for dioxins in 2002. None of the
congeners were detected.
Estimate based on V2 the detection
limit. [10].
43616SHLCM4001C
BP Oil Co. Toledo
Refinery
Oregon, OH
0.285997
14,188
M
0.36
51,209
M
One set of samples collected and
analyzed: 9 congeners above the
detection limit. [6]
07036XXN 1400P
Bay way Refining Co.
Linden, NJ
0.253997
10,322
M
0.25
5,229
M
Based on V2 the detection limit.
Treated effluent samples are all
ND. [3]
74603CNCPN1000S
Conoco Inc. Ponca City
Refinery
Ponca City,
OK
0.180878
4,957
O
0.44452
30,803
O
Estimated discharge using
nonrefinery-specific data for
dioxin in petroleum products, pj
59101CNCBL401SO
Conoco Inc. Billings
Refinery
Billings, MT
0.161558
4,428
O
"
"
"
Estimated discharge using
nonrefinery-specific data for
dioxin in petroleum products, pj
08066MBLLCBILLI
Valero Refining Co. New
Jersey
Paulsboro, NJ
0.089999
2,467
O
0.088
6,097
O
Reported wastewater release was
0.0002 grams, pj
00851HSSLVLIMET
Hovensa LLC
Christiansted,
VI
0.069341
1,900
C
0.0335
2,321
c
Based on EPA discharge factors.
[3]
80022CNCDN5801B
Conoco Denver Refinery
Denver, CO
0.059999
1,644
O
0.095
6,583
E
Internally generated factors per
corporate policy. [3]
-------
Table 3-6 (Continued)
1 l\l II) \ her
Kelinerx
Kelinerx
1 Mciilinii
1 l\l
21102 1 l\l
1 llr<>rill:i 1 i<>ll ( nllei leil In I I'V
on 1 >iosin l\eleaM--> Keporleil lo
1 l\l ill 2 anil 20112
(.1:1111-.'
1 \\ IT.
lia-io of
I'.olilllille
(.1:1111-.'
1 \\ IT.
lia-i- of
r.->lim:ile
39567CHVRNPOBOX
Chevron Prods. Co.
Pascagoula Refinery
Pascagoula,
MS
0.035
959
O
0.086
3,677
O
Facility used monitoring data
collected in 2001 from the
catalytic reformer units to
develop an emission factor. [10]
62454MRTHNMARAT
Marathon Ashland
Petroleum LLC
Robinson, IL
0.03
822
O
0.04
2,772
o
No comment.
00654PHLPSPHILI
Chevron Phillips
Chemical Puerto Rico
Guayama, PR
0.00218
60
E
-
-
-
No comment.
70602CTGPTHIGHW
Citgo Petroleum Corp
Lake Charles,
LA
0.0016
44
E
0.002565
178
E
Based on EPA discharge factors.
[3]
79905CHVRN6501T
Chevron USA El Paso
Refinery
El Paso, TX
0.019
512
O
-
-
-
Based on V2 the detection limit.
[3]
90748NCLLS1660W
Conocophillips Co. La
Refinery Wilmington
Plant
Wilmington,
CA
0.054
M
0.277
22,320
M
Facility used monitoring data
collected from catalytic reformer
discharge after regeneration. The
facility detected all 17 congeners.
[5]
60434MBLJLINTER
Exxonmobil Oil Corp.
Joliet Refinery
Channahon,
IL
O
0.434
39,602
O
Facility had monitoring data
reporting TCDD as not detected.
Discharge estimated based on V2
detection limit. [11]
Refineries Not in EPA's Analysis: No Discharge of Dioxins
48217MRTHN1300S
Marathon Ashland
Petroleum LLC
Detroit, MI
1.37
NA3
1.37
O
Facility reported incorrect
number: Discharge changed to
zero. Refinery submitted TRI
correction form for both 2000 and
2002. [12]
Source: TRIReleases2002; Memorandum: Revisions to TWFs for Dioxin and its Congeners and Recalculated TWPEs for OCPSF and Petroleum Refining [4]
'For indirect dischargers, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 83% removal of dioxins
by the POTW.
2Refineries reported basis of estimate in 2000 TRI as: M - Monitoring data/measurements; C - Mass balance calculations; E - Published emission factors; and O - Other
approaches (e.g., engineering calculations).
3No basis of estimate was reported.
-------
Table 3-7. 2000 and 2002 PACs Discharges Reported to TRI By Petroleum Refineries
K>
1 l\l II)
Ul'lllll'IA
Krllncrx 1 Mciiiiiiii
2000 1 l\l
2002 1 l\l
1 iil<I'limli<>11 ( mIIi-i Ii-cI In I I' V mi
2 mill 2002 1' V< l)iM h:irğr
l'>iiiiiiii<">
I'miiiicK1
1 \\ IT.
IJn-K nl'
l'>liniiilc
I'miincI-'
1 \\ IT.
I5;isis mI'
77592TXSCTLOOP1
Valero Refining Co. Texas
Texas City, TX
64
14,748
M
69
1,813
M
Estimate based on V2 the detection
limit. One sample contained PACs.
[3]
94572NCLSNOLDHI
Tosco San Francisco Refinery
Rodeo, CA
57
13,135
M
8
210
M
Estimate based on Vz the detection
limit. [3]
70037LLNCRHIGHW
Tosco Refining Co. Alliance
Refinery
Belle Chasse, LA
40
9,217
O
31
815
M
Estimate based on Vi the detection
limit. [3]
70669CNCLKOLDSP
Conoco Lake Charles Refinery
Westlake, LA
22
5,069
O
31
815
O
Estimate based on emission factors.
[9]
96707CHVRN91480
Chevron Prods. Co. Hawaii
Refinery
Kapolei, HI
20
4,609
M
277
7,279
M
Estimate based on V2 the detection
limit. PACs Sampled from 2000
NPDES Permit renewal were all non-
detect. [10]
99611TSRLSMILE2
Tesoro Alaska Co. Kenai
Refinery
Kenai, AK
19
4,378
O
19
497
O
No change to estimate.
39567CHVRNPOBOX
Chevron Prods. Co.
Pascagoula Refinery
Pascagoula, MS
17
3,917
O
110
2,891
O
Estimates based on EPA's BAT
effluent guidelines estimate for
PACs. [10]
62454MRTHNMARAT
Marathon Ashland Petroleum
L.L.C.
Robinson, IL
15
3,456
o
21
552
o
No comment.
62084SHLLLRTE11
Tosco Wood River Refinery
Roxana, IL
10
2,304
o
9
234
o
Estimate based on V2 the detection
limit. [3]
74603CNCPN1000S
Conoco Inc. Ponca City
Refinery
Ponca City, OK
9
2,074
o
8
210
o
Refinery estimated discharge using
API data for PACs in petroleum
products. [3]
84116CHVRN2351N
Chevron USA Prods. Co.
Salt Lake City, UT
8
1,843
o
59
1,550
M
No comment.
80022CNCDN5801B
Conoco Denver Refinery
Commerce City, CO
5
1,152
o
9
237
o
Estimate based on internally
generated factors. [3]
70047TRNSM14902
Orion Refining Corp.
New Sarpy, LA
4
922
c
9
237
o
Estimate based on V2 the detection
limit. [3]
90744TXCRF2101E
Equilon Enterprises L.L.C.
Los Angeles Refining
Wilmington, CA
3.2
731
o
3.2
83
NA3
No comment.
-------
Table 3-7 (Continued)
U>
U>
1 l\l II)
KcIIiicia
Krllnrrx 1 Mciiiiiiii
2000 1 l\l
2002 1 l\l
1 iil<I'limli<>11 ( nllcilril In I I' V mi
2000 mill 2002 1* W l>iM hiir!!r
I'.ğl iniiil t">
I'miiiicI-.1
1 \\ IT.
U;i-i- ill'
l'.ğl iniiilt-"
I'miincI-'
1 \\ IT.
I5;isis mI'
00851HSSSVLIMET
Hovensa L.L.C
Christiansted, VI
2
461
O
Ĥ
Ĥ
Ĥ
Discharge from accidental spill;
monitoring data indicate zero
discharge of PACs. [3]
77017LYNDL12000
Lyondell-Citgo Refining L.P.
Houston, TX
175
40,360
NA3
163
4,287
M
Indirect discharger - PACs were not
detected in the POTW, Gulf Coast
Waste Authority, effluent. [13]
77506CRWNC111RE
Crown Central Petroleum
Corp. Houston Refinery
Pasadena, TX
7
1,645
NA3
5
121
NA3
Indirect discharger - PACs were not
detected in the POTW effluent. [3]
48217MRTHN1300S
Marathon Ashland Petroleum
L.L.C.
Detroit, MI
6
1,374
NA3
7
180
NA3
Facility detected five PACs in final
effluent. [12]
79905CHVRN6501T
Chevron USA El Paso
Refinery
El Paso, TX
4
933
NA3
2
46
NA3
Estimate based on 2 the detection
limit. [3]
70606CLCSRWESTE
Calcasieu
Lake Charles, LA
1.1*
M
191
5,019
O
Estimate based on emission factors.
[14]
67042TXCRF1401S
Frontier
El Dorado, KS
1.1*
O
1.0
26
O
Not in TRIReleases2000 v4\ 1.1 lb/yr
discharge PACs based on discharges
at similar refinery reported to TRI.
[3]
78410KCHRFSUNTI
Flint Hills Resources
Corpus Christi, TX
"
"
Ĥ
1,771
46,538
M
Estimate based on Vi the detection
limit. Facility did not detect any
PACs in final effluent. [8]
18 other facilities that reported P AC discharges in 2002,
but not in 2000
-
-
-
459
12,058
Source: TRIReleases2002; TRIReleases2000_v4
^or indirect dischargers, the mass shown is the mass transferred to the POTW that is ultimately discharged to surface waters, accounting for an estimated 92.64% removal of PACs by the POTW.
2Refineries reported basis of estimate in 2000 TRI as: M - Monitoring data/measurements; C - Mass balance calculations; E - Published emission factors; and O - Other approaches (e.g., engineering
calculations).
3No basis of estimate was reported.
*The facility discharge is not in TRIReleases2000; however, industry commented that 1.1 pounds of PACs were reported to TRI in 2000 as discharged.
-------
4.0 Pesticide Chemicals (40 CFR 455)
This section describes the results of EPA's 2005 preliminary review of the Pesticide
Chemicals Point Source Category.
A. Industry Description
The pesticide chemicals industry includes facilities that manufacture pesticide active
ingredients and formulate, package, and repackage pesticide products. Although facilities in this
industry primarily fall into SIC code 2879, pesticide operations might also occur at facilities that
manufacture organic and inorganic chemicals and pharmaceuticals. These facilities might be
classified under different SIC codes. Due to the high toxicity associated with most pesticide
discharges, EPA identified the discharges of specific pesticides at these combination facilities
and included them in the Pesticide Chemicals category review under the current planning cycle.
The SIC codes from these other categories are marked with a "P" to indicate that only the
pesticide discharges from facilities reporting that SIC code were included in the Pesticide
Chemicals Point Source Category review. Table 4-1 presents these SIC codes.
Table 4-1. Number of Pesticide Chemicals Facilities
Sl(
Cock'
Point Soiiito ( .itciion
2002 U.S.
I'lconomic
Census
2002
TRI1
2002
PCS2
rw i .s.
I'lconoinic
Census
2000
TRI'
2000
PCS2
2879
Pesticide Chemicals
239
124
29
260
35
16
2048P
None3
1
0
2812P
Inorganic Chemicals
Manufacturing
1
7
2816P
Inorganic Chemicals
Manufacturing
0
1
282 IP
OCPSF
NA4
3
66
NA4
5
5
2823P
OCPSF
1
2
2824P
OCPSF
0
6
2834P
Pharmaceuticals Manufacturing
1
0
2842P
OCPSF (CFPR)
1
0
2844P
OCPSF (CFPR)
0
1
4-1
-------
Table 4-1 (Continued)
2002 U.S.
rw i .s.
Sl(
I'lconoinic
2002
2002
I'lconoinic
2000
2000
(ode
Point Soiiito ( .itciion
Census
TRI1
PCS2
Census
TRI'
PCS2
2865P
OCPSF
2
24
2869P
OCPSF
NA5
13
85
NA5
5
5
2891P
OCPSF (CFPR)
1
0
2899P
OCPSF (CFPR)
6
5
239
154
199
260
Source: U.S. Economic Census, 2002 and 1997 [1, 2]; TRIReleases2002; PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3SIC 2048 consists of establishments that manufacture prepared feeds and feed ingredients for animals. One facility
reported pesticide discharges that are included in the Pesticide Chemicals Point Source Category.
4Census totals cannot be separated between pesticide operations and other manufacturing operations.
'Pesticide discharges reported to PCS and TRI in 2000 from SIC codes other than 2879 were not included in the
2004 review of the Pesticide Chemicals Point Source Category.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the pesticide chemicals industry are regulated under 40 CFR
Part 455: Pesticide Chemicals Point Source Category. This category consists of five
subcategories, as shown in Table 4-2 with a description of each subcategory's applicability.
Table 4-2. Applicability of Subcategories in the Pesticide Chemicals Point Source Category
Sub-
part
Sul>p;irl 1 ilk-
Siihpiirl \pplic;il>ilil>
A
Organic Pesticide
Chemicals Manufacturing
Discharges resulting from the manufacture of organic and organo-tin
pesticide active ingredients. Intermediates used to manufacture the
active ingredients and active ingredients used solely in experimental
pesticides are excluded from coverage.
B
Metallo-Organic Pesticide
Chemicals Manufacturing
Discharges resulting from the manufacture of metallo-organic pesticide
active ingredients containing mercury, cadmium, arsenic, or copper.
Intermediates used to manufacture the active ingredients are excluded
from coverage.
4-2
-------
Table 4-2 (Continued)
Siih-
piirl
Siihpiirl 1 ilk-
Siihpiirl Appliciihililt
C
Pesticide Chemicals
Formulating and Packaging
Discharges resulting from all pesticide formulating, packaging, and
repackaging operations except repackaging of agricultural pesticides
performed at refilling establishments. Formulation, packaging, and/or
repackaging of sanitizer products (including pool chemicals),
microorganisms, inorganic wastewater treatment chemicals, specified
mixtures, and liquid chemical sterilant products as defined in the
Federal Food, Drug and Cosmetic Act and in the Federal Insecticide,
Fungicide and Rodenticide Act is excluded. Also excluded is the
development of new formulations of pesticide products and the
associated efficacy and field testing at on-site or stand-alone research
and development laboratories where the resulting pesticide product is
not produced for sale.
D
Test Methods for Pesticide
Pollutants
Analytical test methods that must be used to determine the
concentration of pesticide active ingredients in the wastewater.
E
Repackaging of
Agricultural Pesticides
Performed at Refilling
Establishments
Discharges resulting from all repackaging of agricultural pesticides
performed by refilling establishments whose primary business is
wholesale or retail sales; and where no pesticide manufacturing,
formulating, or packaging occurs. Does not apply to wastewater
discharges from custom application or custom blending and repackaging
of microorganisms or certain specified mixtures, or non-agricultural
pesticide products.
Source: Pesticide Chemicals Point Source Category - 40 CFR 455.
The effluent guidelines for the Pesticide Chemicals Point Source Category were first
promulgated in 1978 for Subparts A and B. EPA last revised the effluent guidelines for the
pesticide chemicals manufacturing industry (Subparts A, B, and D) in 1998 [3, 4] and for
pesticide chemicals formulating, packaging, and repackaging (Subparts C and E) in 1996. [5] In
addition to BPT, BAT, BCT, and NSPS, Subparts A, C, and E include PSES and PSNS
limitations.
All facilities that manufacture pesticide active ingredients are subject to priority pollutant
limits under Subpart A. In addition, there are numerical limitations for 49 pesticide active
ingredients under BPT. Under Subparts C and E, facilities that formulate, package, or repackage
pesticide products are subject to either a zero discharge limit or a pollution prevention alternative
that allows a small discharge after implementation of specific pollution prevention techniques
and treatment.
4-3
-------
c.
Results of Screening-Level Analysis
Table 4-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. This table reflects a number of significant
changes between 2000 and 2002 that result from EPA's change in methodology for reviewing
this category. The 2002 data include pesticide discharges from SIC codes other than 2879, while
the 2000 data do not. Even with the additional discharges included in 2002, the PCS TWPE
decreased by 72% due to a decrease in the reported discharges of methoxychlor from 168,803
pound-equivalent (lb-eq) (900 pounds) to 52 lb-eq (0.27 pounds). Only one facility, Kincaid
Enterprises (Nitro, WV), reported discharges of methoxychlor to PCS in 2000 and 2002.
However, the TRI TWPE for 2002 is 39 times larger than the 2000 TWPE due to the inclusion of
picloram discharges from two facilities that report primary SIC codes other than 2879.2 The
Pesticide Chemicals Point Source Category ranked fifth in combined PCS and TRI TWPE.
Because of the high ranking, EPA selected this category for preliminary review.
Table 4-3. Pesticide Chemicals Point Source Category TRI and PCS Discharges for 2000
and 2002
Number of l-'iicililics
Reporting l \\ IT. (.renter
Tliiin /.cm 1
loliil Pounds
l)isch;ir;ii'(l
i w pi:
2002 TRI1
64
1,754,350
554,485
2002 PCS1
203
122,209,015
50,690
2002 Tolsil1
123.3.3(>5
605,175
2000 TRI
35
2,284,136
13,848
2000 PCS
16
246,833,549
178,977
2000 loliil
24Ğ>.l l"\(.K5
1 'J2.S25
Source: TRIReleases2002; PCSLoads2002; TRIReleases2000jv4; PCSLoads2000_v6.
'TRI and PCS totals for 2002 include pesticide discharges from SIC codes other than 2879, while 2000 TRI and PCS
totals do not.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
2These discharges of picloram were previously categorized under OCPSF for the
2004 review.
4-4
-------
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Pesticide Chemicals Point
Source Category.
E. Pollutants of Concern
TRI Discharges
Table 4-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges as well as the 2000 discharges of these chemicals, for comparison purposes.
Table 4-4. Pesticide Chemicals Point Source Category, Top TRI Chemicals for 2000 and
2002
( homiciil
2002 TRI
2 TRI
2002
twit.
Kiink
Number of
l-'iicililios
Reporting
( homiciil
Toliil
Pounds
T\\ IT.
2000
T\\ IT.
Riink
Number of
liicililk's
Reporting
( homiciil
Toliil
Pounds
T\\ IT.
Picloram
1
2
240,111
498,021
EPA previously included discharges of this
chemical under the OCPSF category.
Dichlorvos
2
1
6.2
34,935
EPA previously included discharges of this
chemical under the Pharmaceutical
Manufacturing category.
Diazinon
3
3
12.3
7,685
3
1
5.0
3,111
Cyfluthrin
4
1
26.0
5,463
2
1
22.0
4,585
Merphos
5
1
23.0
1,549
18
1
4.0
100
Source: TRIReleases2002; TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
Picloram contributed the majority of the category TWPE in 2002 (90%), but was not
included in the previous screening-level review of the Pesticide Chemicals Point Source
Category. The two facilities that reported picloram discharges to TRI in 2002, Dow Chemical
(Freeport, TX) and Dow Chemical (Midland, MI), also reported picloram discharges to TRI in
2000. Dow Chemical (Freeport, TX) discharged 99.95% of the total 2002 reported picloram
discharges and 99.7% of the total 2000 reported picloram discharges. Picloram does not have
4-5
-------
specific limits set under the current regulations for the Pesticides Chemicals Point Source
Category.
Dichlorvos contributed 6.3% of the category TRI TWPE in 2002. Only one facility,
Boehringer Ingelheim Vetmedica Inc. (Elwood, KS), reported discharges to TRI in 2000 and
2002. Note that in 2000, dichlorvos discharges were included in the Pharmaceutical
Manufacturing Point Source Category.
PCS Discharges
Table 4-5 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges of these chemicals.
Table 4-5. Pesticide Chemicals Point Source Category, Top PCS Chemicals for 2000 and
2002
( hcmk'iil
2002 PCS
2000 PCS
2002
T\\ PI.
Kiink
Number of
l-'iicililios
Reporting
( hcmiciil
Idlill
Pounds
iwpi:
2000
i w pi:
Kiink
Number of
l-'iicililios
Reporting
Chcmk'iil
Toliil
Pounds
IWPI.
Carbaryl
1
1
153
42,918
Not reported to PCS in 2000
Diazinon
2
1
2.1
1,344
Not reported to PCS in 2000
Hexachloro-
cyclohexane
(BHC)
3
1
14.8
1,038
Reported to PCS in 2000 under OCPSF and
Inorganic Chemicals Manufacturing
categories
Chlorine
4
3
1,608
819
6
4
2,205
1,074
1,3-Dichloro-
propene
5
76
1,097
620
Reported to PCS in 2000 under OCPSF and
Inorganic Chemicals Manufacturing
categories
Source: PCSLoads2002; PCSLoads2000_v6.
Note: PCS facilities include major dischargers only.
Carbaryl accounted for 85% of the 2002 PCS TWPE. Only one facility, Bayer Crop
Science Institute (Institute, WV), reported carbaryl discharges to PCS in 2002, with carbaryl
accounting for 99.9% of its pesticide discharges. EPA is in the process of contacting the facility
to determine the source of carbaryl discharges.
4-6
-------
F. Issues Identified and Additional Review
EPA's estimate of the toxicity of Pesticide Chemicals Point Source Category discharges
are largely due to the TRI-reported discharges of picloram and the PCS-reported discharges of
carbaryl. Further review of this category may focus on the following issues:
Analysis of the TRI-reported picloram discharges, including investigation of the
facilities dominating the picloram TWPE, the methods used to estimate reported
discharge, and process sources;
Analysis of the PCS-reported carbaryl discharges, including investigation of the
facility dominating the carbaryl TWPE, the methods used to estimate reported
discharge, process sources, and concentrations discharged; and
Analysis of pollution control technologies available to reduce pesticide
discharges, including wastewater reuse and treatment prior to discharge.
G. References
1. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
2. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
3. U.S. EPA. Development Document for Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance Standards for the Pesticide Chemicals
Manufacturing Point Source Category (Final). EPA-821-R-93-016. September 1993.
4. U.S. EPA. Amendments to the Effluent Limitations Guidelines, Pretreatment Standards,
and New Source Performance Standards for the Organic Pesticide Chemicals
Manufacturing IndustryPesticide Chemicals Point Source Category; Direct Final Rule
and Proposed Rule. Available online at:
http://www.epa.gov/EPA-WATER/1998/Julv/Dav-22/wl9514.pdf Accessed July 1,
2005.
5. U.S. EPA. Pesticide Chemicals Category, Formulating, Packaging and Repackaging
Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance
Standards; Final Rule. Available online at:
http://www.epa.gov/fedrgstr/EPA-WATER/1996/November/Dav-06/pr-21Q52DIR/pr-21
052.pdf. Accessed July 1, 2005.
4-7
-------
5.0 Nonferrous Metals Manufacturing (40 CFR 421)
EPA identified the Nonferrous Metals (NFM) Manufacturing Point Source Category for
review in the 2004 Effluent Guidelines Program Plan. Section 5 of the Technical Support
Document for the Plan [1] summarizes the results of EPA's previous reviews for this industry.
This section describes the results of EPA's 2005 preliminary review of the NFM Manufacturing
Point Source Category.
A. Industry Description
The NFM manufacturing industry includes facilities that smelt and refine metals other
than iron and steel, such as aluminum, copper, and nickel. This industry is divided into five SIC
codes, as shown in Table 5-1.
Table 5-1. Number of Nonferrous Metals Manufacturing Facilities
SIC Click-
2002 U.S.
l-'ciiiiimi i
c Census
2002 IKI'
2002 PCS2
1 Ğ)Ğ)Ĥ' I .S.
r.ciinniiiic
Census
2 IKI'
2000 PCS2
2819N3 Inorganic
Chemicals, NEC
9
3
3
6
4
3
3331 Primary Smelting
and Refining of Copper
15
6
3
16
5
3
3334 Primary Production
of Aluminum
41
21
23
21
25
23
3339 Primary Smelting of
Nonferrous Metals,
Except Copper and
Aluminum
170
30
11
142
30
13
3341 Secondary Smelting
and Refining of
Nonferrous Metals
417
182
13
256
172
14
Inliil
652
242
53
441
236
56
Source: U.S. Economic Census, 2002 and 1997 [2, 3]; TRIReleases2002; PCSLoads2002; TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3Sites known to perform NFM manufacturing operations.
NEC - Not Elsewhere Classified.
5-1
-------
The anomaly in this category is SIC code 2819, which primarily consists of inorganic
chemical facilities. However, NFM manufacturing facilities that make refined bauxite, alumina,
slug uranium, liquid metals, and several other inorganic metals may sometimes be classified
under SIC code 2819. During previous reviews of this industry, EPA identified these facilities,
and labeled them with an SIC code of 2819N, as shown in Table 5-1. [1]
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the NFM manufacturing industry are regulated under 40 CFR
Part 421: Nonferrous Metals Manufacturing Point Source Category. This category consists of 31
subcategories, which are listed in Table 5-13 of the 2004 Technical Support Document with the
related SIC codes [1,4].
EPA first promulgated effluent guidelines for the NFM Manufacturing Point Source
Category in 1984. All subcategories have BPT and BAT limitations, except Bauxite Refining,
Primary Copper Smelting, Secondary Indium, Secondary Mercury, and Primary Rare Earth
Metals. EPA has promulgated NSPS and PSNS for all 31 subcategories. The most commonly
regulated toxic pollutants in the NFM Manufacturing Point Source Category are lead, chromium,
copper, arsenic, and zinc.
C. Results of Screening-Level Analysis
Table 5-2 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. The TWPE associated with TRI discharges
decreased by more than 93% from 2000 to 2002; however, the PCS TWPE dominates the
combined TWPE. As a result of the high PCS TWPE, the NFM Manufacturing Point Source
Category ranked sixth in combined TWPE. Because of the high ranking, EPA selected this
category for preliminary review.
5-2
-------
Table 5-2. NFM Manufacturing Point Source Category TRI and PCS Discharges for
2000 and 2002
Number of I'ncililios
Kcporliii" TWI'l.
(iiviilcr lliiin /.oi(i
Tuliil Pounds
Dischiiriiod
T\\ IT.
2002 TRI
114
2,342,514
63,694
2002 PCS
53
206,952,208
450,524
2002 Tuliil
20').2,M."722
514.2 IX
2000 TRI
113
4,807,761
978,450
2000 PCS
53
321,539,607
434,925
2000 loliil
32(i.34"7.3(iS
1.41
Source: TRJReleases2002\ PCSLoads2002\ TRIReleases2000jv4; PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the NFM Manufacturing Point
Source Category.
E. Pollutants of Concern
TRI Discharges
Table 5-3 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges as well as the 2000 discharges of these chemicals, for comparison purposes.
5-3
-------
Table 5-3. NFM Manufacturing Point Source Category, Top TRI Chemicals for
2000 and 2002
2002 TRI
2 TRI1
('lK'lllk';il
2002
T\\ PI.
R;ink
NiIIIiIkT III'
l'';K'ililk's
Ki-|>iirliniirlin
-------
Table 5-4. NFM Manufacturing Point Source Category, Top PCS Chemicals for
2000 and 2002
2002 PC S
2000 PCS'
2002
T\\ PI.
K;ink
NiiihIkt ill'
l'';ii'ililk's
Ki-|>iirlinuiiin
-------
operations from these facilities that could be transferable to other discharging
facilities in similar subcategories. In addition, metals removal for this industry
might be improved using multiple-stage metals precipitation or newer multimedia
filtration followed by chemical precipitation technologies. [1] EPA will attempt
to identify technologies and practices from zero dischargers that may be
transferrable to other discharging facilities in similar subcategories.
G. References
1. U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA 821-R-04-014. Washington, D.C. August 2004. Docket OW-2003-0074. DCN
01088A01.
2. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
3. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
5-6
-------
6.0 Ore Mining and Dressing (40 CFR 440)
EPA identified the Ore Mining and Dressing Point Source Category for review in the
2004 Effluent Guidelines Program Plan. Section 5 of the Technical Support Document for the
Plan [1] summarizes the results of EPA's previous reviews for this industry. This section
describes the results of EPA's 2005 preliminary review of the Ore Mining and Dressing Point
Source Category.
A. Industry Description
The ore mining and dressing industry includes facilities that mine, mill, or prepare 23
separate metal ores. This industry is divided into nine SIC codes, as shown in Table 6-1. SIC
codes 1011, 1081, and 1094 are not required to report to TRI. Because the U.S. Economic
Census reports data by NAICS code and TRI and PCS reported data by SIC code, EPA
reclassified the 2002 Census data under the equivalent SIC code to standardize the results. Note
that because SIC codes 1061 and 1081 do not translate directly to a NAICS code, EPA could not
determine the number of facilities reported for SIC code 1061 for the 1997 U.S. Economic
Census data or the number of facilities reported for SIC code 1081 for the 2002 U.S. Economic
Census data.
Table 6-1. Number of Ore Mining and Dressing Facilities
SIC ( ode
2002 U.S.
r.conomic
Census
2002 1 Kl1
2002 PCS2
rw i .s.
r.conomic
Census
2 TRI1
2000 PCS2
1011 Iron Ores
24
NA3
6
32
NA3
10
1021 Copper Ores
33
17
15
49
19
13
1031 Lead and Zinc Ores
22
13
27
31
19
29
1041 Gold Ores
180
34
28
300
40
32
1044 Silver Ores
11
3
5
16
5
6
1061 Ferroalloy Ores,
Except Vanadium
72
7
6
NR4
7
7
1081 Metal Mining
Services
NR4
NA3
0
203
NA3
0
1094 Uranium-Radium-
Vanadium Ores
17
NA3
17
29
NA3
23
6-1
-------
Table 6-1 (Continued)
SIC ( ode
2002 U.S.
l-lconomic
Census
2002 TRI1
2002 PCS2
rw i .s.
I'lconomic
Census
2 TRI1
2000 PCS2
1099 Miscellaneous Metal
Ores, NEC
39
6
6
36
6
7
Total
>398
80
110
696
96
128
Source: U.S. Economic Census, 2002 and 1997 [2, 3]; TRIReleases2002; PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major dischargers.
facilities in this SIC code are not required to report to TRI.
4Poor bridging between NAICS and SIC codes.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the ore mining and dressing industry are regulated under 40
CFR Part 440: Ore Mining and Dressing Point Source Category. This category consists of 12
subcategories, as shown in Table 6-2 with related SIC codes and descriptions of the
subcategories' applicability. EPA matched the SIC codes to the subcategories using the SIC
code descriptions from the 2002 U.S. Economic Census and the description of the subcategory
applicability. [4, 5] SIC code 1081 does not directly relate to a subcategory in the ore mining
and dressing category.
Table 6-2. Applicability of Subcategories in the Ore Mining and Dressing Point Source
Category
Suh-
|)
-------
Table 6-2 (Continued)
Sub-
part
Subpart Title
Related SIC Codc(s)
Subpart Applicability
E
Titanium Ore
1099 Miscellaneous
Metal Ores, NEC
Titanium Ore Mines from Lode Deposits and Mills
using Electrostatic, Magnetic & Physical Separation, or
Flotation; Dredge Mines and Mills for Placer Deposits
of Rutile, Ilmenite, Leucoxene, Monazite, Zircon, and
Other Heavy Metals
F
Tungsten Ore
1061 Ferroalloy Ores,
Except Vanadium
Tungsten Mines and Mills using Gravity Separation or
Froth-Flotation
G
Nickel Ore
1061 Ferroalloy Ores,
Except Vanadium
Nickel Ore Mines and Mills
H
Vanadium Ore
(Mined Alone, not
as By-product)
1094 Uranium,
Radium, & Vanadium
Ores
Vanadium Ore Mines and Mills
I
Antimony Ore
1099 Miscellaneous
Metal Ores, NEC
Antimony Ore Mines and Mills
J
Copper, Lead,
Zinc, Gold, Silver,
& Molybdenum
Ores
1021 Copper Ores
1031 Lead and Zinc
Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores,
Except Vanadium
Copper, Lead, Zinc, Gold, Silver, & Molybdenum Ore
Open-Pit or Underground Mines, except for Placer
Deposits, and Mills using Froth-Flotation and/or Other
Separation Techniques; Mines and Mills using Dump,
Heap, In-Situ Leach, or Vat-Leach to Extract Copper
from Ores or Ore Waste Materials; Gold or Silver
Mills using Cyanidation; Except for Mines and Mills
from the Quartz Hill Molybdenum Project in the
Tongass National Forest, Alaska
K
Platinum Ore
1099 Miscellaneous
Metal Ores, NEC
Platinum Ore Mines and Mills
M
Gold Placer Mine
1041 Gold Ores
Placer Deposit Gold Ore Mines, Dredges, & Mills
usine Gravitv Senaration
Source: Ore Mining and Dressing Point Source Category - 40 CFR 440\ U.S. Economic Census, 2002 [2];
Development Document for Effluent Limitations Guidelines and Standards for the Ore Mining and Dressing Point
Source Category [4]; Development Document for Effluent Limitations and Guidelines for New Source Performance
Standards for the Ore Mining and Dressing Point Source Category Gold Placer Mine Subcategory [5].
NEC - Not Elsewhere Classified.
EPA first promulgated effluent guidelines for the Ore Mining and Dressing Point Source
Category in 1982. BAT limitations are set equal to BPT levels for priority pollutants for this
category. The priority pollutants arsenic, cadmium, copper, lead, mercury, nickel, and zinc are
regulated in at least one subcategory. [1] None of the Subparts include PSES and PSNS
limitations.
6-3
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C. Results of Screening-Level Analysis
Table 6-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. Between 2000 and 2002, the number of
facilities reporting to PCS increased by 33%, but the number of facilities reporting to TRI
decreased by 17 percent. The PCS-reported TWPE far exceeds the TRI TWPE, both in 2000 and
2002. As a result of its high PCS TWPE, the Ore Mining and Dressing category ranked seventh
in combined TWPE. Because of the high ranking, EPA selected this category for preliminary
review.
Table 6-3. Ore Mining and Dressing Point Source Category TRI and PCS Discharges for
2000 and 2002
Number of l-';icilitios
Kcporliii" TWI'l.
(Ĥiv.ilcr 1 h;iii /.oro
l oliil Pounds
Dischiiriicd
T\\ PI.
2002 TRI
34
541,214
66,544
2002 PCS
73
625,769,753
406,548
2002 loliil
Wf.JIO.W."7
473,092
2000 TRI
41
491,249
52,627
2000 PCS
55
792,003,769
383,560
2000 loliil
"")2.4Ğ>5.0IX
43(i.lX"7
Source: TRIReleases2002; PCSLoads2002; TRIReleases2000_v4; PCSLoads2000jv6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Ore Mining and Dressing
Point Source Category.
6-4
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E. Pollutants of Concern
TRI Discharges
Table 6-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges as well as the 2000 discharges of these chemicals, for comparison purposes.
Table 6-4. Ore Mining and Dressing Point Source Category, Top TRI Chemicals for 2000
and 2002
( homiciil
2002 TRI
2 TRI1
2002
iwi'i:
Kiink
Nu in her of
l-'iicililics
Reporting
( homiciil
Idlill
Pounds
i w pi:
2000
T\\ PI
Riink
Number of
l-'iicililios
Reporting
( homiciil
Idlill
Pounds
iwpi:
Cadmium and
Cadmium
Compounds
1
10
1,046
24,181
6
8
590
1,541
Lead and Lead
Compounds
2
24
5,672
12,705
2
17
7,187
16,099
Arsenic and
Arsenic
Compounds
3
8
2,562
10,352
1
9
4,988
17,305
Vanadium and
Vanadium
Compounds
4
2
147,060
5,147
16
1
255
159
Silver and Silver
ComDOLinds
5
1
250
4,118
4
4
294
4,842
Source: TRIReleases2002; TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Values shown for 2000 are for releases reported for the metal compounds and do not include the lead, arsenic,
vanadium, and silver.
Cadmium and cadmium compounds contributed 36% of the category TRI TWPE for
2002 and only 3% of the category TWPE for 2000. Cadmium and cadmium compound
discharges increased from 1,541 TWPE in 2000 to 24,181 TWPE in 2002, due to a 77% increase
in the pounds discharged and a 786% increase in the cadmium TWF.
6-5
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PCS Discharges
Table 6-5 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges of these chemicals.
Table 6-5. Ore Mining and Dressing Point Source Category, Top PCS Chemicals for 2000
and 2002
( homiciil
2002 PCS
2000 PCS
2002
iwpi:
Kiink
Number of
l-'iicililios
Reporting
( homiciil
1 (Mill
Pounds
i w pi:
2000
i w pi:
Kiink
Number of
l-'iicililios
Reporting
( homiciil
Tolill
Pounds
IWPI.
Molybdenum
1
4
770,329
155,174
1
3
951,077
191,584
Cyanide
2
9
109,018
121,764
11
10
1,424
1,533
Cadmium
3
29
2,360
54,556
3
31
19,534
51,022
Lead
4
32
10,406
23,309
4
36
6,648
11,892
Arsenic
5
13
3,143
12,701
8
12
1,679
5,826
Source: PCSLoads2002; PCSLoads2000_v6.
Note: PCS facilities include major dischargers only.
'Values for 2000 include discharges reported for a variety of pollutant forms and may slightly overestimate
discharges.
Molybdenum and cyanide accounted for 68% of the 2002 PCS TWPE. Cyanide
discharges increased from 1,533 TWPE in 2000 to 121,764 TWPE in 2002, due to a two-order-
of-magnitude increase in the pounds discharged. The existing 40 CFR Part 440 guidelines do
not include limits for molybdenum or arsenic.
F. Issues Identified and Additional Review
EPA's estimate of the toxicity of Ore Mining and Dressing Point Source Category
discharges results from the PCS-reported discharges of molybdenum and cyanide. EPA also
received stakeholder comments from previous effluent guidelines program plans stating that
discharges from facilities in this category may not be adequately quantified in PCS and TRI and
that these discharges can cause significant water quality impacts. In particular, EPA is
evaluating the impact of discharges from waste rock and overburden piles, which are not now
6-6
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regulated by effluent guidelines, and whether these discharges are adequately controlled by the
Multi-Sector General Permit (MSGP).3 See 65 FR 64746 (Oct. 30, 2000).
The MSGP includes very general benchmark values for sampling and general
requirements to develop a stormwater pollution prevention plan, but does not establish numeric
limits or stormwater containment/treatment requirements. The MSGP establishes benchmark
monitoring for pollutants including TSS, pH, hardness, arsenic, beryllium, cadmium, copper,
iron, lead, manganese, mercury, nickel, selenium, silver, zinc, and uranium.4 The data from this
sampling are now available due to the 2000 MSGP requirements.
Commenters on previous effluent guidelines program plans have requested that EPA
reverse its decision to exclude discharges from waste rock and overburden piles from the Part
440 applicability definition of "mine drainage." Specifically, commenters suggest that EPA
should conduct a rulemaking to address discharges from waste rock piles, overburden piles, and
other sources of water pollution at mine sites that are not currently covered by Part 440. See 63
FR 47285 (Sept. 4, 1998).
The Agency will review the MSGP data for usefulness in revising the effluent guidelines,
for example, to determine the mass and concentrations of pollutants discharged, and effluent
variability associated with these discharges, and to evaluate the performance and effectiveness of
3Mine sites not regulated by the MSGP include: (1) sites with their stormwater
discharges regulated by an individual permit; and (2) sites without any discharge of stormwater.
A facility has the option of obtaining an individual permit for stormwater discharges instead of
requesting coverage under the MSGP; however, in practice this is seldom done. The current
MSGP expires this year, however EPA intends to reissue it. Almost all mine sites discharge
stormwater (e.g., stormwater discharges from haul roads, process areas, equipment storage areas,
mine waste rock).
4Table G-4 of the MSGP listed what wastewaters from mining activities are
covered by Part 440 and what wastewaters are to be covered by the industrial MSGP. In
response to litigation from the National Mining Association, EPA revised its interpretation of
applicability for wastewaters from hard rock mining operations. Under the revised interpretation,
runoff from waste rock and overburden piles is not subject to effluent guidelines unless it
naturally drains (or is intentionally diverted) to a point source and combines with "mine
drainage" that is otherwise subject to the effluent guidelines (65 FR 64774; Oct. 30, 2000;).
6-7
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the permit controls (primarily "best management practices") at reducing pollutants. Additionally,
EPA may gather other relevant data (such as cost data) on wastewater treatment technologies for
this category. Preliminary MSGP data indicate high concentrations of metals in active and
inactive mine site runoff. The volumes of discharge can be significant due to the large land area
covered by the mine sites. Constituents include toxic pollutants such as arsenic, copper, mercury,
and selenium as well as pH problems. Additionally, EPA Regions are evaluating whether states
are adequately addressing mine site runoff. Finally, EPA is also investigating the potential for
facilities in this category to contaminate ground water and, through infiltration and inflow,
adversely affect POTW operations. [6]
Further review of this category may focus on the following:
Analysis of the PCS-reported molybdenum discharges, including the process
sources and concentrations discharged;
Analysis of PCS-reported cyanide discharges, including the process sources and
concentrations discharged; and
Pollution control technologies available to reduce molybdenum and cyanide
discharges, including re-using process water, substitution of less toxic chemicals,
and treatment of wastewater prior to discharge.
G. References
1. U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA 821-R-04-014. Washington, D.C. August 2004. Docket OW-2004-0032, DCN
01088A01.
2. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02 .
3. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
4. U.S. EPA. Development Document for Effluent Limitations Guidelines and Standards
for the Ore Mining and Dressing Point Source Category. EPA-440/1-82/061.
Washington, D.C. 1982.
6-8
-------
5. U.S. EPA. Development Document for Effluent Limitations and Guidelines for New
Source Performance Standards for the Ore Mining and Dressing Point Source Category
Gold Placer Mine Subcategory. EPA-440/1-88-061. Washington, D.C. 1988.
6. U.S. EPA. "EPA Issues Draft Discharge Permits and Proposed Variances for Three
Silver Valley Wastewater Treatment Plants." Environmental Fact Sheet. Available
online at: www.epa.uov/r 1 Oearth/water.htm. August 2002.
6-9
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7.0 Inorganic Chemicals Manufacturing (40 CFR 415)
EPA identified the Inorganic Chemicals Manufacturing Point Source Category for review
in the 2004 Effluent Guidelines Program Plan. Section 5 of the Technical Support Document for
the Plan [1] summarizes the results of EPA's previous reviews for this industry. This section
describes the results of EPA's 2005 preliminary review of the Inorganic Chemicals
Manufacturing Point Source Category.
A. Industry Description
The inorganic chemicals manufacturing industry includes facilities that manufacture a
broad class of substances encompassing those substances that do not include carbon and its
derivatives as their principal elements. This industry is divided into four SIC codes, as shown in
Table 7-1.
Table 7-1. Number of Inorganic Chemical Manufacturing Facilities
SIC ( ode
2002 U.S.
Ilennnmie
Census
2002 TUI1
2002 PCS2
rw i .s.
l-leonomie
Census
2 IKI1
2000 PCS2
2812 Alkalies and
Chlorine
40
7
6
39
24
10
2813 Industrial Gases
568
82
42
630
67
40
2816 Inorganic Pigments
105
50
24
74
46
28
2819 Industrial Inorganic
Chemicals, NEC3
2,396
348
123
667
337
139
3.10')
487
195
1.410
474
217
Source: U.S. Economic Census, 2002 and 1997 [2, 3]; TRJReleases2002\ PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3EPA identified certain facilities reporting under SIC code 2819 as subject to effluent guidelines for the NFM
Manufacturing Point Source Category (see Section 5.0).
NEC - Not Elsewhere Classified.
7-1
-------
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
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 BPT, BAT, BCT and NSPS, the category includes PSES and PSNS
limitations for at least one subcategory. Table 5-6 in the 2004 Technical Support Document
contains details on the pollutants regulated by subpart. The effluent guidelines for the Inorganic
Chemicals Manufacturing Point Source Category were first promulgated in 1974 and revised in
1975, 1976, 1982, and 1986.
C. Results of Screening-Level Analysis
Table 7-2 compares the Inorganic Chemicals Manufacturing Point Source Category
TWPE estimated for 2000 and 2002 using TRI and PCS data. In addition, the table presents the
amount of TWPE contributed by the Chlor-Alkali (CA) sector of the Inorganic Chemicals
Manufacturing Point Source Category.
Table 7-2. Inorganic Chemicals Manufacturing Point Source Category TWPE
TRI 2000
TRI 2002
PCS 2000
PCS 2002
Total TWPE
627,628
7,153,144
887,361
567,016
CA Sector Contribution1
(% of total)
148,361
(24%)
6,872,167
(96%)
205,387
(19%)
427,334
(75%)
Number of CA Facilities
15
16
15
16
TWPE w/o CA Sector
479,267
280,977
681,974
139,682
Source: TRJReleases2002\ PCSLoads2002\ TRIReleases2000jv4; PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'The CA sector of the Inorganics Chemicals category includes facilities that conduct chlor-alkali manufacturing and
reported a primary SIC code associated with Inorganics (see Section 7.A). This sector may also include facilities
that also perform VC manufacturing operations.
EPA is currently considering revisions to effluent guidelines for discharges from
facilities that produce chlorine by the chlor-alkali process. Because a rulemaking for the
chlor-alkali sector of the Inorganics Chemicals Point Source Category is underway, discharges
7-2
-------
from these facilities were excluded from further consideration for the Inorganic Chemicals
review under the current planning cycle.
Table 7-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. As explained above, EPA subtracted the
TWPE loads from facilities that produce chlorine by the chlor-alkali process from the Inorganic
Chemicals Manufacturing Point Source Category loads. Even without the loads from the
chlor-alkali facilities, this category ranked eighth in combined PCS and TRI TWPE. Because of
the high ranking, EPA selected this category for preliminary review.
Table 7-3. Inorganic Chemicals Manufacturing Point Source Category TRI and PCS
Discharges for 2000 and 2002
Number of l-'acililk's
Kcporliii" TWI'l.
(nvnU'r 1 Man 7.om
Tolal Pounds
Discharged
T\\ IT.
2002 TRI
198
9,315,202
280,977
2002 PCS
68
1.258.006.644
139,682
2002 Total
1,267,321,846
420,659
2000 TRI
187
16,711,121
479,267
2000 PCS
64
1,126,421,556
681,974
2000 Tolal
I.I 43.132.(."
1.1 (.1.241
Source: TRIReleases2002\ PCSLoads2002\ TRIReleases2000jv4', PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
The large decrease in PCS TWPE from 2000 to 2002 is driven by a decrease in the
mercury and chlorine discharges reported by two facilities. Norit Americas (Marshall, TX)
reported discharging 355,744 TWPE of mercury in 2000, but reported no discharges in 2002. [4]
Clearon Corporation (South Charleston, WV) reported discharging 73,636 TWPE of chlorine in
2000 but only 43 TWPE in 2002.
The large decrease in TRI TWPE from 2000 to 2002 is driven by a decrease in the
hexachlorobenzene TWPE discharges reported by two DuPont facilities, which accounted for all
reported hexachlorobenzene discharges in 2000. In 2000, New Johnsonville reported 115,868
7-3
-------
TWPE while Edgemoor reported 29,691TWPE. Neither facility reported any hexachlorobenzene
discharges in 2002.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Inorganic Chemicals
Manufacturing Point Source Category.
E. Pollutants of Concern
TRI Discharges
Table 7-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges as wells as the 2000 discharges of these chemicals, for comparison purposes.
Table 7-4. Inorganic Chemicals Manufacturing Point Source Category, Top TRI
Chemicals for 2000 and 2002
('hcmk'iil
2002 TRI
2 TRI
2002
iwi'i:
Kiink
Number of
l-'iicililics
Reporting
( homiciil
Idlill
Pounds
i w pi:
2000
T\\ PI
Riink
Number of
l-'iicililios
Reporting
( homiciil
Idlill
Pounds
T\\ PI
Dioxin and
Dioxin-Like
Compounds
1
7
0.07
74,702
2
7
0.1
123,709
Sodium Nitrite
2
7
186,320
69,560
3
7
243,083
90,751
Chlorine
3
13
77,654
39,539
4
13
95,812
46,659
Lead and Lead
Compounds1
4
54
13,148
29,451
20
2
137
307
Mercury and
Mercury
Compounds1
5
14
206
24,164
21
2
2.6
301
Source: TRIReleases2002; TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Values shown for 2000 are for releases reported for lead and mercury and do not include lead or mercury
compounds.
7-4
-------
Dioxin and dioxin-like compounds contributed 27% of the category TRI TWPE for 2002.
Five of the seven facilities that reported dioxin discharges to TRI in 2002 manufacture titanium
dioxide. [5] According to two of the facilities contacted (DuPont's plants in New Johnsonville,
TN and Edgemoor, DE), the dioxins formed as unintentional trace reaction by-products of
intermediate production in the titanium dioxide manufacturing process. [6]
Sodium nitrite discharges accounted for 25% of the category TRI TWPE for 2002. Seven
facilities reported discharging sodium nitrite to TRI in 2002, with one facility, Repauno Products
(Gibbstown, NJ), contributing 47% of the sodium nitrite discharges.
Chlorine discharges accounted for 14% of the category TRI TWPE for 2002. Thirteen
facilities reported discharges of chlorine to the TRI in 2002, with one facility, GFS Chemicals,
Inc. (Columbus, OH), contributing 92% of the chlorine discharges.
Lead and lead compounds accounted for 10.5% of the 2002 TRI TWPE discharges.
Fifty-four facilities reported discharges of lead and lead compounds to 2002 TRI, with one
facility, PCS Nitrogen Fertilizer L.P. (Geismar, LA), contributing 83% of the discharges.
Mercury and mercury compounds accounted for 8.6% of the 2002 TRI TWPE discharges.
Fourteen facilities reported discharges to 2002 TRI, with one facility, Kerr-McGee Chemical
Pigment Plant (Hamilton, MS), contributing 84% of the mercury and mercury compound
discharges.
PCS Discharges
Table 7-5 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges of these chemicals.
7-5
-------
Table 7-5. Inorganic Chemicals Manufacturing Point Source Category, Top PCS
Chemicals for 2000 and 2002
( Ill-Illii;il
2002 PC S
2000 PCS'
2002
T\\ PI.
K;ink
\uml>i-r III'
l-';uiliiii-s
Ki-|>nrliniirlin
-------
F. Issues Identified and Additional Review
EPA's estimate of the toxicity of Inorganic Chemicals Manufacturing Point Source
Category discharges are largely due to the TRI-reported discharges of dioxin and dioxin-like
compounds and sodium nitrite and PCS-reported discharges of iron. Further review of this
category may focus on the following issues:
Review of titanium dioxide manufacturing segment of the Inorganic Chemicals
Manufacturing Point Source Category, including applicable subcategory, dioxin
measurement data, and methods for estimating dioxin releases to surface water;
Analysis of the TRI-reported sodium nitrite discharges, including facilities
dominating the TWPE, the methods used to estimate reported discharge, and
process sources; and
Analysis of the PCS-reported iron and nitrite-nitrogen discharges, including
facilities dominating the TWPE, the methods used to estimate reported discharge,
process sources, and concentrations discharged.
G. References
1. U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA 821-R-04-014. Washington, D.C. August 2004. Docket OW-2004-0032. DCN
01088A01.
2. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
3. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
4. Silverthorne, Darrell. Norit Americas. Personal Communication. Mercury Releases
Reported to TRI in 2000. June 27, 2005.
5. U.S. EPA. Final Titanium Dioxide Listing Background Document for the Inorganic
Chemical Listing Determination. Washington, D.C. October 2001. Docket OW-2003-
0074. DCN 00892.
6. Wood, Ken. DuPont Edge Moor, DE and New Johnsonville, TN. Personal
Communication. DuPont's Edge Moor, DE and New Johnsonville, TN releases in TRI
2002. February 28, 2005.
7-7
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8.0 Rubber Manufacturing (40 CFR 428)
This section describes the results of EPA's 2005 preliminary review of the Rubber
Manufacturing Point Source Category.
A. Industry Description
The rubber manufacturing industry includes facilities that manufacture natural, synthetic,
and reclaimed rubber. Manufactured rubber becomes finished goods through a variety of
methods, such as molding, extruding, and fabricating. [1,2] This industry is divided into seven
SIC codes, as shown in Table 8-1. Because the U.S. Economic Census reports data by NAICS
code and TRI and PCS reported data by SIC code, EPA reclassified the 2002 Census data under
the equivalent SIC code to standardize the results. Note that because SIC code 3069 does not
translate directly to a NAICS code, the number of facilities reported for SIC code 3069 could not
be determined for the 2002 U.S. Economic Census data.
Table 8-1. Number of Rubber Manufacturing Facilities
SIC Code
2002 U.S.
l-leonomie
Census
2002 1 Kl1
2002 PCS2
IW1 I .S.
l-leonomie
Census
2 TRI1
2000 PCS2
2822 Synthetic Rubber
(Vulcanizable Elastomers)
157
34
18
143
33
21
3011 Tires and Inner
Tubes
158
72
23
162
77
26
3021 Rubber and Plastics
Footwear
62
5
0
59
7
0
3052 Rubber and Plastics
Hose and Belting
260
72
4
218
69
7
3053 Gaskets, Packing,
and Sealing Devices
614
58
4
665
50
6
3061 Molded, Extruded,
and Lathe-Cut Mechanical
Rubber Goods
608
70
19
716
51
23
8-1
-------
Table 8-1 (Continued)
SIC Code
2002 U.S.
l-leonomie
Census
2002 TRI1
2002 PCS2
IW1 I .S.
l-leonomie
Census
2 IKI1
2000 PCS2
3069 Fabricated Rubber
Products, NEC
NA3
216
47
1,012
221
50
1 olid
>1,859
527
1 IS
2,975
508
133
Source: U.S. Economic Census, 2002 and 1997 [3, 4]; TRJReleases2002\ PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3Poor bridging between NAICS and SIC codes.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the rubber manufacturing industry are regulated under 40 CFR
Part 428: Rubber Manufacturing Point Source Category. This category consists of 11
subcategories, as shown in Table 8-2 with the related SIC codes and descriptions of the
subcategories' applicability. EPA matched the SIC codes to the subcategory using information
from the technical development documents for this industry. [1,2]
Table 8-2. Applicability of Subcategories in the Rubber Manufacturing Point Source
Category
Siih-
piiri
Suhp;iri 1 ilk-
Keliiled SIC" Code(s)
Suhp;iri Applicability
A
Tire and Inner Tube Plants
3011 Tires and Inner Tubes
Pneumatic tire and inner tube
B
Emulsion Crumb Rubber
2822 Synthetic Rubber
(Vulcanizable Elastomers)
Emulsion crumb rubber
excludes acrylonitrile butadiene rubber
C
Solution Crumb Rubber
2822 Synthetic Rubber
(Vulcanizable Elastomers)
Crumb rubber
D
Latex Rubber
2822 Synthetic Rubber
(Vulcanizable Elastomers)
Latex rubber
8-2
-------
Table 8-2 (Continued)
Suh-
|)
-------
TWPE, the Rubber Manufacturing Point Source Category ranked ninth in combined TWPE.
Because of the high ranking, EPA selected this category for preliminary review.
Table 8-3. Rubber Manufacturing Point Source Category TRI and PCS Discharges for
2000 and 2002
Number of l-'acililics
Kcporliii" TWI'l.
Ciivalor 1 hail /.om
Tolal Pounds
Discharged
T\\ IT.
2002 TRI
220
1,082,214
173,304
2002 PCS
20
9,530,447
2,386
2002 Tolal
I0.(il2.66l
r5.(ğĞ)o
2000 TRI
230
1,162,444
166,343
2000 PCS
17
35,644,338
8,143
2000 Total
36,806,782
174,486
Source: TRJReleases2002\ PCSLoads2002\ TRIReleases2000jv4; PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Rubber Manufacturing
Point Source Category.
E. Pollutants of Concern
TRI Discharges
Table 8-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges, as well as the 2000 discharges of these chemicals, for comparison purposes.
Sodium nitrite contributed the majority of the category TWPE in 2000 (57%) and 2002
(68%) according to the TRI data. According to facilities EPA contacted, rubber facilities that
use a molten salt curing process may discharge sodium nitrite. The molten salt, which can
contain sodium nitrite, is removed from the rubber products using a water wash that is then
discharged. [5, 6, 7, 8]
8-4
-------
PACs accounted for 20% of the category TWPE for 2000 and 29% in 2002. Five
facilities reported discharge of PACs in 2002.
Table 8-4. Rubber Manufacturing Point Source Category, Top TRI Chemicals for 2000
and 2002
( hcmiciil
2002 TRI
2 TRI1
2002
twit.
Riink
Nu in her of
l;icili(k'N
Reporting
( Ik-iii ic;il
1 oliil
Pounds
T\\ IT.
2000
T\\ IT.
Riink
Number of
l-'iicililios
Reporting
( Ik-iii ic.il
Idlill
Pounds
i w pi:
Sodium Nitrite
1
12
316,929
118,320
1
10
253,334
94,578
PACs
2
4
500
50,293
2
2
8
32,470
1,3-Butadiene
3
4
250
1,208
14
3
33
59
Zinc and Zinc
Compounds
4
166
22,121
1,037
13
3
1,356
63
Chlorine
5
4
1,534
781
3
5
61,493
29,946
Source: TRJReleases2002\ TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Values shown for 2000 are for releases reported for zinc and do not include zinc compounds.
PCS Discharges
Table 8-5 lists the five chemicals with the highest TWPE of PCS reported discharges for
2002 compared to the 2000 discharges of these chemicals.
8-5
-------
Table 8-5. Rubber Manufacturing Point Source Category, Top PCS Chemicals for 2000
and 2002
2002 PCS
2000 PCS'
Number of
Number of
2002
l-'iicililics
2000
l-'iicililios
i w pi:
Reporting
Ttllill
i w pi:
Kcporlin^
Toliil
(hem kill
Kiink
( homiciil
Pounds
iwpi:
Kiink
( homiciil
Pounds
IWPI.
Benzidine
1
1
0.24
667
11
1
0.64
69
Arsenic
2
2
115
466
2
1
208
720
Acrylonitrile
3
3
141
320
23
1
1.4
1.2
Copper
4
8
266
169
6
8
493
309
Vanadium
5
1
4,710
165
1
2
8,254
5,136
Source: PCSLoads2002\ PCSLoads2000_v6.
Note: PCS facilities include major dischargers only.
'Values for 2000 include discharges reported for a variety of pollutant forms and may slightly overestimate
discharges.
Benzidine and arsenic account for 47% of the 2002 PCS TWPE. Vanadium discharges
decreased from 5,136 TWPE in 2000 to 165 TWPE in 2002, due to a 43% decrease in the pounds
discharged and a 94% decrease in the vanadium TWF.
F. Issues Identified and Additional Review
EPA's high TWPE rank for the Rubber Manufacturing Point Source Category discharges
are mostly due to the TRI-reported discharges of sodium nitrite and PACs. Further review of
this category may focus on the following issues:
Analysis of the TRI-reported sodium nitrite discharges, including the methods
used to estimate reported discharge, process sources, and a comparison to PCS
data for nitrogen compound releases;
Analysis of the TRI-reported PACs discharges, including the methods used to
estimate reported discharge and process sources; and
Pollution control technologies available to reduce sodium nitrite discharges,
including reuse of salt bath wash water, substitution of less toxic chemicals, and
treatment of wastewater prior to discharge.
8-6
-------
G. References
1. U.S. EPA. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Fabricated and Reclaimed Rubber Segment of the Rubber
Processing Point Source Category. EPA-440/l-74/030-a. Washington, D.C. 1974.
2. U.S. EPA. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Tire and Synthetic Segment of the Rubber Processing
Point Source Category. EPA-440/l-74-013-a. Washington, D.C. 1974.
3. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
4. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
5. Telephone conversation with John Hines of Avon Automotive, Cadillac, MI, and Jessica
Wolford of ERG. "Clarification of Manufacturing Process and Pollutant Discharges."
June 9, 2005.
6. Telephone conversation with Mike Hough of GDX Automotive, Wabash, IN, and Jessica
Wolford of ERG. "Clarification of Manufacturing Process and Pollutant Discharges."
June 22, 2005.
7. Telephone conversation with Stacey Rader of Cooper Standard Automotive, Bowling
Green, OH, and Jessica Wolford of ERG. "Clarification of Manufacturing Process and
Pollutant Discharges." June 20, 2005.
8. Telephone conversation with Bob Dry den of GDX Automotive, New Haven, MO, and
Jessica Wolford of ERG. "Clarification of Manufacturing Process and Pollutant
Discharges." June 13, 2005.
8-7
-------
9.0 Textile Mills (40 CFR 410)
EPA identified the Textile Mills Point Source Category for review in the 2004 Effluent
Guidelines Program Plan. Section 5 of the Technical Support Document for the Plan [1]
summarizes the results of EPA's previous reviews for this industry. This section describes the
results of EPA's 2005 preliminary review of the Textile Mills Point Source Category.
A. Industry Description
The textile industry includes facilities that manufacture and process textile materials,
such as carpets, broad woven fabrics, and knitwear. The Textile Mills Point Source Category
also includes facilities using wet processes, such as scouring, dyeing, finishing, printing, and
coating, that discharge contact wastewater. These facilities are classified under SIC major group
22, Textile Mill Products. As shown in Table 9-1, EPA is considering including operations from
three other SIC codes as potential new subcategories of the Textile Mills Point Source Category.
See the Potential New Subcategories section (Section D) for more details.
Table 9-1. Number of Textile Mills
SIC Code
2002 U.S.
r.conomic
Census
2002
TRI1
2002
PCS2
1 Ğ)Ğ)Ĥ' I .S.
r.conomic
Census
2000
TRI1
2000
PCS2
tcmiIc Mill h'odiicis (Sic ::i
14.5 l<>
284
145
5.065
296
140
Polcnlhil Now SulK'iik'iioric's
23- Apparel and Other Finished
Products Made From Fabrics and
Other Similar Materials
27,295
16
NA3
4,282
13
1
Source: U.S. Economic Census, 2002 and 1997 [2, 3]; TRIReleases2002; PCSLoads2002\ TRIReleases2000_v4\
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3No facilities reported to PCS under these SIC codes.
9-1
-------
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the textile mills industry are regulated under 40 CFR Part 410:
Textile Mills Point Source Category. EPA first promulgated effluent guidelines for the Textile
Mills Point Source Category in 1982. This category consists of nine subcategories, as shown in
Table 9-2 with the related SIC codes and descriptions of the subcategories' applicability. Along
with BPT, BAT, BCT, and NSPS, the category has PSES and PSNS limitations. Section 5.4.5 of
the 2004 Technical Support Document provides more information on the regulatory background
for the Textile Mills Point Source Category. [1]
Table 9-2. Applicability of Subcategories in the Textile Mills Point Source Category
Suh-
piii'l
Siihpiirl 1 ilk-
Koliilod Sl( ( oriels)
Siihpiii'l Applicability
A
Wool Scouring
2299
Wool scouring, topmaking, and general cleaning of
raw wool
B
Wool Finishing
2231
Wool finishers, including carbonizing, fulling, dyeing,
bleaching, rinsing, fireproofing, and other such similar
processes
C
Low Water Use
Processing
2211,2221,2231,
2241, 2253, 2254,
2259, 2273, 2281,
2282, 2284, 2295,
2296, 2298
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
2261, 2262
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
2251, 2252, 2257, 2258
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
2273
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
2269
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
9-2
-------
Table 9-2 (Continued)
Suh-
p;irl
Siihpiirl lillc
Koliilod Sl( ( oriels)
Siihpiii'l Applicability
H
Nonwoven
Manufacturing
2297
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
2299
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 [4],
C. Results of Screening-Level Analysis
Table 9-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting TWPE discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. Table 9-3 includes discharges from facilities in
SIC codes EPA determined are potential new subcategories of the Textile Mills Point Source
Category. Between 2000 and 2002, the number of facilities reporting to TRI decreased by 29
facilities (24%), while the number reporting to PCS was essentially unchanged. The PCS-
reported TWPE far exceeds the TRI TWPE for both 2000 and 2002. As a result of the high PCS
TWPE, the Textile Mills Point Source Category ranked tenth in combined TWPE. Because of
the high ranking, EPA selected this category for preliminary review.
Table 9-3. Textile Mills Point Source Category TRI and PCS Discharges for 2000 and 2002
Number of l;icili(ks Kcporiin^
TWI'i: (>iv;ilcr lliiin /.cm
l oliil Pounds
Dischiiriii'd
I w pi:
2002 TRI
90
311,615
32,765
2002 PCS
74
77,500,000
124,085
2002 loliil
"".XOO.OOO
I5(ğ.X50
2000 TRI
119
584,190
84,807
2000 PCS
73
106,000,000
296,601
2000 loliil
I0(>,000,000
3X1,40X
Source: TRlReleases2002; PCSLoads2002; TRlReleases2000jv4', PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
9-3
-------
D. Potential New Subcategories
EPA reviewed industries with SIC codes not clearly subject to existing ELGs. EPA
concluded the processes, operations, wastewaters, and pollutants of facilities in the SIC codes
listed in Table 9-4 are similar to those of the Textile Mills category. Table 9-4 shows the total
TRI and PCS combined TWPE for each SIC code that is a potential new subcategory. As shown
in the table, the discharges for the potential new subcategory SIC codes contribute a negligible
percentage to the total Textile Mills Point Source Category TWPE.
Table 9-4. Pollutant Loadings From Potential New Subcategories
SIC Code
SIC Description
( (unbilled TRI iind
PCS 2002 I WPI.
Percen(;iiie of Toisil
C.ili'fion IWPI.
2322
Men's & Boys Underwear & Night
2.55
0.002
2396
Automotive Trimmings, Apparel
0.12
<0.001
2399
Fabricated Textile Products, NEC
0.08
<0.001
Source: TRIReleases2002; PCSLoads2002.
NEC - Not Elsewhere Classified.
E. Pollutants of Concern
TRI Discharges
Table 9-5 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges, as well as the 2000 discharges of these chemicals, for comparison purposes. TRI-
reported chlorine decreased significantly, both in number of reporters and actual pounds
released. Chlorine releases decreased by 80% from 2000 to 2002.
9-4
-------
Table 9-5. Textile Mills Point Source Category, Top TRI Chemicals for 2000 and 2002
2002 TRI
2 TRI
( homiciil Niimo
2002
T\\ IT.
Riink
Nil in hoi' til'
l;ieili(ies
Reporting
( heniieiil
Ttllill
Pounds
twit.
2000
twpi:
Riink
Nil in her of
l;ieili(ies
Reporting
( hcmiciil
Tolnl
Pounds
TW PI
Sodium Nitrite
1
2
44,711
16,692
2
5
43,559
16,262
Chlorine
2
4
25,316
12,890
1
9
128,982
62,812
Chlorine Dioxide
3
1
4,613
738
NA2
NA2
NA2
NA2
Copper and
Copper
Compounds1
4
10
909
577
14
1
70
44
Naphthalene
5
1
22,000
349
5
1
42,000
647
Source: TRJReleases2002\ TRIReleases2000_v4.
'2000 values reflect releases of copper only.
2No textile mills reported releases of chlorine dioxide to TRI for 2000.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
PCS Discharges
Table 9-6 lists the five chemicals with the highest TWPE of PCS-reported discharges for
2002 compared to the 2000 discharges for these chemicals.
Table 9-6. Textile Mills Point Source Category, Top PCS Chemicals for 2000 and 2002
( homiciil
2002 PCS
2000 PCS'
2002
TW IT.
R;ink
Number of
l-'iicililics
Reporting
Chcmiciil
Ttllill
Pounds
i w pi:
2000
TW IT.
R;ink
Number of
l-'iicililii's
Reporting
( hemiciil
loliil
Pounds
TWIT.
Sulfide
1
66
26,013
72,874
1
49
58,778
164,601
Chlorine
2
32
59,576
30,334
2
22
223,975
109,072
Arsenic
3
5
3,989
16,123
11
3
40
139
Toxaphene
4
1
0.046
1,393
NA2
NA2
NA2
NA2
Copper
5
33
1,854
1,177
3
32
19,480
12,212
Source: PCSLoads2002\ PCSLoads2000_v6.
Note: PCS facilities include major dischargers only.
'Values for 2000 include discharges reported for a variety of pollutant forms and may slightly overestimate
discharges.
2No textile mills reported discharges of toxaphene to PCS for 2000.
9-5
-------
Chlorine discharges reported to PCS decreased by 73%, and sulfide discharges decreased
by 53 percent. For both pollutants, a single facility's discharges account for the majority (more
than 50%) of the TWPE reductions from 2000 to 2002.
Arsenic is the only pollutant with a large increase in discharges from 2000 to 2002. One
facility's arsenic discharge accounts for almost all of this increase. EPA reviewed the monthly
reported arsenic discharges for this facility and found that the arsenic concentration for one
month was 7 mg/L, which is two orders of magnitude higher than the other concentrations
reported for 2002. The facility's permit does not include a limit on arsenic; however, the
NPDES fact sheet predicted a maximum arsenic concentration of 402.6 |ig/L. [5] Based on this
information, the PCS arsenic concentration units may be in error.
F. Issues Identified and Additional Review
EPA's high TWPE rank for the Textile Mills Point Source Category discharges are
mostly due to PCS-reported discharges. During the 2004 review of the Textile Mills category,
EPA identified chlorine and sulfide as pollutants of concern based on high TWPE discharges
reported in TRI and PCS for 2000. PCS and TRI data show significant decreases in pollutant
discharges from 2000 to 2002. Further review of this category may focus on the following
issues:
Analysis of PCS-reported arsenic discharges, including review of monthly
measurement data in PCS and verification of annual load;
Analysis of reductions in PCS-reported chlorine discharges, including review of
monthly measurement data and verification of annual load;
Analysis of TRI-reported chlorine and sodium nitrite discharges, including
methods used to estimate reported discharge and process sources; and
Comparison of TRI- and PCS-reported discharges of chlorine and copper.
9-6
-------
References
U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA 821-R-04-014. Washington, D.C. August 2004. Docket OW-2004-0032. DCN
01088A01.
U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
U.S. EPA. Development Document for Effluent Limitations Guidelines and Standards
for the Textile Mills Point Source Category. EPA-440/1-79/022. Washington, D.C.
1979.
North Carolina Division of Water Quality. Fact Sheet for NPDES Permit: NPDES
Permit NC0005312. Raleigh, NC. 2005.
-------
io.o Fertilizer Manufacturing (40 CFR 418)
EPA identified the Fertilizer Manufacturing Point Source Category for review in the
2004 Effluent Guidelines Program Plan. Section 5 of the Technical Support Document for the
Plan [1] summarizes the results of EPA's previous reviews for this industry. This section
describes the results of EPA's 2005 preliminary review of the Fertilizer Manufacturing Point
Source Category.
A. Industry Description
The fertilizer manufacturing industry includes facilities that produce phosphorus and
nitrogen-based fertilizers. The industry is classified by three SIC codes, as shown in Table 10-1.
SIC code 2874 includes both facilities in the Fertilizer Manufacturing category and Phosphate
Manufacturing category. During previous reviews of this industry, EPA identified facilities in
SIC code 2874 with operations in the Fertilizer Manufacturing category. [1] Counts of these
facilities are shown as SIC code 2874F in Table 10-1.
Table 10-1. Number of Fertilizer Manufacturing Facilities
Ken mimic
I'lconomi
Census
TRI1
PCS2
c Census
TRI'
PCS2
SIC Code
2002
2002
2002
1Ğ)Ğ)"ğ
2000
2000
2873 Nitrogenous Fertilizers
143
61
40
143
63
40
2874F Phosphatic Fertilizers
NA3
2
1
NA3
2
1
2875 Fertilizers, Mixing Only
542
57
5
449
42
6
Total
>685
120
46
>592
107
47
Source: U.S. Economic Census, 2002 and 1997 [2, 3]; TRJReleases2002\ TRIReleases2000_v4; PCSLoads2002;
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3Census totals for SIC code 2874 cannot be separated between fertilizer manufacturers and phosphate manufacturers.
10-1
-------
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the fertilizer manufacturing industry are regulated under 40
CFR Part 418: Fertilizer Manufacturing Point Source Category. This category consists of seven
subcategories, as shown in Table 10-2 with the related SIC codes and description of the
subcategories' applicability.
Table 10-2. Applicability of Subcategories in the Fertilizer Manufacturing Point Source
Category
Suh-
piii'l
Siihpiirl 1 ilk-
Kohilod Sl(
Code(s)
Siihpiii'l \|)|)lic;il)ili(>
A
Phosphate Subcategory
2874 Phosphatic
Fertilizers
Manufacture of sulfuric acid by sulfur burning, wet-
process phosphoric acid, normal superphosphate,
triple superphosphate, and ammonium phosphate
B
Ammonia Subcategory
2873 Nitrogenous
Fertilizers
Manufacture of ammonia
C
Urea Subcategory
2873 Nitrogenous
Fertilizers
Manufacture of urea
D
Ammonium Nitrate
Subcategory
2873 Nitrogenous
Fertilizers
Manufacture of ammonia nitrate
E
Nitric Acid
Subcategory
2873 Nitrogenous
Fertilizers
Production of nitric acid in concentrations up to 68%
F
Ammonium Sulfate
Production Subcategory
2873 Nitrogenous
Fertilizers
Production of ammonium sulfate by the synthetic
process and by coke oven by-product recovery
G
Mixed Blend Fertilizer
Production Subcategory
2875 Fertilizers,
Mixing Only
Production of mixed and blend fertilizer
Source: Fertilizer Manufacturing Point Source Category -40 CFR 418.; Technical Support Document for the 2004
Effluent Guidelines Program Plan, Section 5. [1]
EPA first promulgated effluent guidelines for the Fertilizer Manufacturing Point Source
Category in 1974. All of the subcategories have BPT, BAT, and NSPS limitations, including
zero discharge of process wastewater pollutants for Subcategories F and G. Some of the
subcategories also have PSNS limitations. The most commonly regulated pollutants are
ammonia, nitrate, and fluoride.
10-2
-------
C. Results of Screening-Level Analysis
Table 10-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting TWPE discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. In both years, the PCS-reported TWPE far
exceeded the TRI TWPE. As a result of its high PCS TWPE, the Fertilizer Manufacturing Point
Source Category was ranked eleventh in combined TWPE. Because of the high ranking, EPA
selected this category for preliminary review.
Table 10-3. Fertilizer Manufacturing Point Source Category TRI and PCS Discharges for
2000 and 2002
Number of l-'acililics
Reporting Discharges
(iivalcr than /.cm
Total Pounds
Discharged
T\\ IT.
2002 TRI
48
4,980,379
6,403
2002 PCS
24
540,486,797
143,795
2002 Total
545.4(>"7.l"7(>
150. I'M
2000 TRI
57
5,498,232
22,566
2000 PCS
26
508,665,080
116,464
2000 Total
514,163,312
139,030
Source: TRJReleases2002\ PCSLoads2002\ TRIReleases2000jv4', PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Fertilizer Manufacturing
Point Source Category.
E. Pollutants of Concern
TRI Discharges
Table 10-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges, as well as the 2000 discharges of these chemicals, for comparison purposes.
10-3
-------
Table 10-4. Fertilizer Manufacturing Point Source Category, Top TRI Chemicals for 2000
and 2002
('hcmk'iil
2002 TRI
2 TRI
2002
iwi'i:
Kiink
Number of
l-'iicililics
Reporting
( homiciil
Idlill
Pounds
i w pi:
2000
T\\ PI
Riink
Number of
l-'iicililios
Reporting
( homiciil
Idlill
Pounds
T\\ PI
Dioxin and
Dioxin-Like
Compounds
1
2
0.008
2,288
2
2
0.007
6,626
Chlorine
2
9
2,880
1,467
4
9
3,725
1,814
Copper and
Copper
Compounds1
3
11
1,383
878
3
11
3,011
1,888
Ammonia
4
42
396,220
596
7
48
522,929
787
Atrazine
5
1
186
429
NR2
NR2
NR2
NR2
Source: TRIReleases2002; TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Values shown for 2000 are for releases reported for copper compounds and do not include releases of copper.
2No facilities reported atrazine to TRI in 2000.
The TRI TWPE contributed less than 5% of the total category TWPE. No single
pollutant dominated the TRI TWPE; discharges of dioxin and dioxin-like compounds, reported
by two facilities, accounted for 36% of the 2002 TRI TWPE. Of the top ranked pollutants by
TWPE, ammonia is discharged in the greatest load. Discharges of pounds of ammonia decreased
by 24% since 2000.
PCS Discharges
Table 10-5 lists the five chemicals with the highest TWPE of PCS-reported discharges
for 2002 compared to the 2000 discharges of these chemicals.
10-4
-------
Table 10-5. Fertilizer Manufacturing Point Source Category, Top PCS Chemicals for 2000
and 2002
2002 PC S
2000 PCS'
2002
T\\ PI.
K;inkiniirlininiin
-------
Analysis of nutrient discharges, including a review of monthly measurement data,
process sources, and a comparison between PCS and TRI.
References
U.S. EPA. Technical Support Document for the 2004 Effluent Guidelines Program Plan.
EPA-821-R-04-014. Washington, D.C. 2004. Docket OW-2003-0074. DCN
01088A01.
U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
10-6
-------
li.o Plastics Molding and Forming (40 CFR 463)
This section describes the results of EPA's 2005 preliminary review of the Plastics
Molding and Forming Point Source Category.
A. Industry Description
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, calendering, casting,
foaming, cleaning, and finishing. This industry is divided into nine SIC codes, as shown in
Table 11-1. EPA reviewed the facilities in this category and determined that five facilities do
not meet the Plastic Molding and Forming Point Source Category applicability because they
manufacture cellulose products. [1, 2, 3, 4] These facilities have been eliminated from the SIC
code totals, and are included as a separate group. Note that because these facilities do not
translate directly to a NAICS code, EPA could not determine the number of facilities reported
for this group of facilities for the 1997 or 2002 U.S. Economic Census data.
Table 11-1. Number of Plastics Molding and Forming Facilities
SIC Code
2002 U.S.
I'lconomic
Census
2002 TRI1
2002 PCS2
rw i .s.
I'lconomic
Census
2 IKI1
2000 PCS2
3081 Unsupported Plastics
Film & Sheet
866
77
58
832
73
74
3082 Unsupported Plastics
Profile Shapes
670
28
1
791
33
4
3083 Laminated Plastics
Plate, Sheet, & Profile
Shapes
291
68
4
457
75
4
3084 Plastics Pipe
437
25
5
350
12
5
3085 Plastics Bottles
403
3
2
471
5
2
3086 Plastics Foam
Products
1,185
222
6
1,178
193
7
3087 Custom
Compounding of
Purchased Resin
579
200
14
836
174
9
11-1
-------
Table 11-1 (Continued)
SIC ( ode
2002 U.S.
I'lconomic
Census
2002 TRI1
2002 PCS2
rw i .s.
I'lconomic
Census
2 IKI1
2000 PCS2
3088 Plastics Plumbing
Fixtures
541
165
0
572
159
0
3089 Plastics Products,
NEC
12,689
666
32
8,573
608
37
Cellulose Film, Sponge
and Food Casing
Manufacturers
NA3
4
3
NA3
4
4
1 (Hill
>11
1,458
125
> 14.0(ğ0
1.33ft
14ft
Source: U.S. Economic Census, 2002 and 1997 [5, 6]; TRJReleases2002\ PCSLoads2002; TRIReleases2000_v4;
PCSLoads2000 v6.
'Releases to any media.
2Major and minor dischargers.
3Poor bridging between cellulose manufacture and NAICS codes.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the plastics molding and forming industry are regulated under
40 CFR Part 463: Plastics Molding and Forming Point Source Category. This category consists
of three subcategories, as shown in Table 11-2 with the description of the subcategories'
applicability. The discharge limitations and standards do not apply to facilities that manufacture
cellulose. [7]
Table 11-2. Applicability of Subcategories in the Plastics Molding and Forming Point
Source Category
Subpart
Description
Applicability
A
Contact Cooling and Heating Water
Processes where water contacts plastic material or plastic
products for the purpose of heat transfer
B
Cleaning Water
Processes where water contacts the plastic products or
shaping equipment for the purpose of cleaning
C
Finishing Water
Processes where water contacts plastic product during
finishing
Source: Plastics Molding and Forming Point Source Category - 40 CFR 463; Development Document for Effluent
Limitations Guidelines and Standards for the Plastics Molding and Forming Point Source Category [7],
11-2
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The effluent guidelines for the Plastics Molding and Forming Point Source Category
were first promulgated in 1984 and revised in 1985. All of the subcategories have BPT NSPS,
PSES, and PSNS limitations. EPA did not establish limitations guidelines for any priority
pollutants. However, EPA identified one priority pollutant, bis(2-ethylhexyl) phthalate, with
BAT and NSPS effluent guidelines as "reserved" in the Contact Cooling and Heating Water
(Subpart A) and Finishing Water (Subpart C) subcategories. See 49 FR 49040 (Dec. 17, 1984).
C. Results of Screening-Level Analysis
Table 11-3 presents the TRI and PCS discharges for 2000 and 2002. The table compares
the number of facilities reporting discharges greater than zero, the pounds of pollutants
discharged, and the estimated TWPE discharged. Between 2000 and 2002, the number of
facilities reporting to PCS increased by 50% and the TWPE increased by two orders of
magnitude. In 2000, the TRI-reported TWPE far exceeded the PCS TWPE but, based on the
2002 data, the PCS-reported TWPE is similar. As a result of the high 2002 PCS TWPE, the
Plastics Molding and Forming Point Source Category ranked twelfth in combined TWPE.
Because of the high ranking, EPA selected this category for preliminary review.
Table 11-3. Plastics Molding and Forming Point Source Category TRI and PCS
Discharges for 2000 and 2002
Diilii Source
Number of l-'acililics
Kcporlin" TWI'l.
(ircalcr Than /.oro
l oliil Pounds
Discharged
T\\ IT.
2002 TRI
149
1,380,691
97,297
2002 PCS
9
214,533,873
172,483
2002 Total
215.') 14.5(4
269,780
2000 TRI
136
1,115,987
106,189
2000 PCS
6
945,799
3,698
2000 Total
2,061,786
109,887
Source: TRIReleases2002; PCSLoads2002; TRIReleases2000_v4; PCSLoads2000jv6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
11-3
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D. Potential New Subcategories
EPA reviewed this category to identify facilities that are not clearly subject to existing
effluent guidelines. Using company web sites, EPA concluded that there are five facilities that
manufacture cellulose film, sponge, or meat casings that do not meet the applicability of the
category. [1, 2, 3, 4] Table 11-4 shows these facilities along with their discharge types.
Table 11-4. Cellulose Manufacturing Facilities in the Plastics Molding and Forming Point
Source Category
TRI II) Number
NPI 1) Number
l-'acilil> Name
l-'acilil.t l.ocalion
Discharge Tjpe
61832TPKNC915NM
Teepak L.L.C.
Danville, IL
Indirect
KS0003204
Innovia Films Inc
Tecumseh, KS
NA1
38402SPNTXSANTA
Spontex Inc
Columbia, TN
Direct
37774VSKSCEASTL
Viskase
Corporation
Loudon, TN
Indirect
72370VSKSCRT198
Viskase
Corporation
Osceloa, AR
Direct
Source: TRIReleases2002; PCSLoads2002.
Note: TRI ID and NPI D included only for facilities reporting to TRI or PCS as majors in the Plastic Molding and Forming Point
Source Category.
'Discharge type is not applicable to PCS.
Table 11-5 shows the total TRI and PCS TWPE for the category including all five of the
facilities that manufacture cellulose products. Excluding these five facilities from the category
reduces the total combined TRI and PCS TWPE to 40,731 TWPE.
Table 11-5. Plastics Molding and Forming Point Source Category TRI and PCS
Discharges Comparing Total 2002 Discharge to Cellulose Facilities 2002 Discharge
Diilii
Source
Including All l-'acililics
(VIlulose l-'acililics
Toiiil Pounds
Discharged
iwpi:
Total Pounds
Discharged
T\\ PI.
Pcrccnlatic of
l \\ Pi: or All
l-'acililics
2002 TRI
1,380,691
97,297
39,830
56,879
58.5%
2002 PCS
214,533,873
172,483
212,796,835
172,170
99.8%
2002 Total
215,914,564
269,780
212,836,665
229,049
84.9%
Source: TRJReleases2002\ PCSLoads2002.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
11-4
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E. Pollutants of Concern
TRI Discharges
Table 11-5 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges, as well as the 2000 discharges of these chemicals, for comparison purposes.
Table 11-6. Plastics Molding and Forming Point Source Category, Top TRI Chemicals for
2000 and 2002
( homiciil
2002 TRI
2 TRI
2002
iwi'i:
Kiink
Nil nihi l- of
l-'iicililics
Reporting
( homiciil
Tolill
Pounds
i w pi:
2000
T\\ PI
Kiink
Number of
l-'iicililios
Reporting
( hcmk'iil
loliil
Pounds
twim:
Carbon Disulfide
1
4
20,252
56,709
2
4
15,971
44,719
Dioxin and
Dioxin-Like
Compounds
2
1
0.0015
33,452
1
1
0.0085
56,717
Sodium Nitrite
3
1
13,937
5,203
7
1
695
259
Lead and Lead
Compounds1
4
45
274
614
9
3
97
217
Formaldehyde
5
5
191,411
446
5
5
215,833
502
Source: TRIReleases2002\ TRIReleases2000_v4.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
'Values shown for 2000 are for releases reported for lead and do not include lead compounds.
Carbon disulfide contributed 42% of the category TRI TWPE for 2000 and 58% of the
category TWPE for 2002. All of the carbon disulfide discharges come from the four facilities
reporting to TRI that manufacture cellulose food casing and cellulose sponge. [1,3,4]
PCS Discharges
Table 11-6 lists the five chemicals with the highest TWPE PCS-reported discharges for
2002. None of the top five chemicals in PCS for 2002 were reported to PCS in 2000.
11-5
-------
Carbon disulfide accounts for 97% of the 2002 PCS TWPE, but was not reported to PCS
in 2000. All of the carbon disulfide discharges come from one facility, Innovia Films Inc.
(Tecumseh, KS), that manufactures cellulose film. [2]
Table 11-7. Plastics Molding and Forming Point Source Category, Top PCS Chemicals for
2002
( hcmiciil
2002 PCS
2002 TWPI. Kiink
Number of
l-'iicililics Reporting
( homiciil
l oliil Pounds
T\\ PI.
Carbon Disulfide
1
1
60,041
168,125
Magnesium
2
1
1,829,470
1,583
Sulfate
3
1
197,419,795
1,106
Nitrogen, Nitrite
Total (as N)
4
1
144,077
807
Calcium
5
1
10,333,219
289
Source: PCSLoads2002.
Note: PCS facilities include major dischargers only.
F. Issues Identified and Additional Review
EPA's high TWPE ranking for the Plastic Molding and Forming Category discharges are
due, for the most part, to the five facilities manufacturing cellulose. Further review of this
category may focus on the following issues:
Analysis of the carbon disulfide discharges, including the methods used to
estimate reported discharge, process sources, and concentrations discharged;
Analysis of the discharge permits, for the five cellulose plants, including the
NPDES permits for direct discharges, pretreatment agreements for the indirect
dischargers, and contact with the POTWs receiving cellulose plant wastewater;
and
Pollution control technologies available to reduce carbon disulfide discharges,
including recycling wastes, substitution of less toxic chemicals, and treatment of
wastewater prior to discharge.
11-6
-------
G. References
1. Devro. June 22, 2005. Available online at:
http: //www, devro .pic, uk/products/index. htm.
2. Innovia Films. June 22, 2005. Available online at:
http ://www. i nnovi afilms.com/corporate/profi 1 e. htm.
3. MAPA Spontex, Inc. June 22, 2005. Available online at:
http://www.sponte\usa.com/products.cfm'?PR.TlD= 1.
4. Viskase Companies, Inc. June 22, 2005. Available online at: http://vvvvvv.viskase.com/.
5. U.S. Economic Census. 2002. Available online at:
http://vvvvvv.census.uov/econ/census02.
6. U.S. Economic Census. 1997. Available online at:
http ://www. census, gov/epcd/www/ econ97.html.
7. U.S. EPA. 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, D.C. 1984.
11-7
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12.0 Porcelain Enameling (40 CFR 466)
This section describes the results of EPA's 2005 preliminary review of the Porcelain
Enameling (PE) Point Source Category.
A. Industry Description
The porcelain enameling industry includes facilities that prepare the surface of a basis
metal and apply a substantially vitreous or glassy inorganic coating bonded to the basis metal by
fusion at a temperature above 800°F. [1] The coatings can be applied by spraying, dipping, or
flow coating. [2] Facilities in this industry are divided into seven SIC codes listed in Table 12-1.
The SIC codes and manufacturing operations associated with the Porcelain Enameling Point
Source Category (40 CFR 466) overlap with the SIC codes associated with the Metal Finishing
Point Source Category (40 CFR 433). EPA reviewed information about facilities in these SIC
codes that reported wastewater discharges, to determine whether they are regulated by the
Porcelain Enameling Point Source Category or Metal Finishing Point Source Category.
The Metal Finishing category includes 46 different processes, such as electroplating,
etching and chemical milling, machining, hot dip coating including galvanizing, and painting. [3]
To minimize overlapping regulations, the metal finishing effluent guidelines do not regulate
facilities that are regulated under other sets of effluent guidelines including the Porcelain
Enameling effluent guidelines; see 40 CFR 433.10(b). For the purposes of the 2005 annual
review, EPA identified facilities subject to the Porcelain Enameling category. The Agency used
individual company web sites [4] and the main trade association for this industry, the Porcelain
Enamel Institute, to determine if the remaining facilities were porcelain enamelers.5 Table 12-1
presents the number of facilities by SIC code, separated into facilities that are not likely to
manufacture porcelain enameled products and facilities that are likely to manufacture porcelain
enameled products. The table includes only the facilities reporting wastewater discharges to TRI
5EPA reviewed the Porcelain Enamel Institute website, to help identify porcelain
enamelers. See http://vvvvvv.porcelainenamel.com.
12-1
-------
and facilities classified as major dischargers. EPA concluded that 95% of the facilities in the
seven porcelain enameling SIC codes are not likely to manufacture porcelain enameled products.
Table 12-1. Number of Porcelain Enameling Facilities
SIC Code
2002 U.S.
I'lcunomk'
Census
2002 TRI1
\on-IM.
l-iicililk's
2002 1 Kl1
l .ikclv PI!
l-'iicililios
2002 PCS2
Non-PI.
l-'iicililios
2002 PCS2
l.ikclv PI.
l-'iicililios
3431 Enameled Iron and Metal
Sanitary Ware
80
0
4
0
1
3469 Metal Stamping, NEC
2,287
51
4
1
0
3479 Coating, Engraving, and
Allied Services, NEC
5,255
102
0
8
0
3631 Household Cooking
Equipment
97
0
6
0
0
3632 Household Refrigerators
and Home and Farm Freezers
23
0
6
0
1
3633 Household Laundry
Equipment
18
0
7
0
1
3639 Household Appliances,
NEC
1,536
1
3
0
1
TolSlI
154
30
9
4
Source: U.S. Economic Census, 2002 [5]; TRJReleases2002\ PCSLoads2002; TRIReleases2000_v4;
PCSLoads2000 v6.
'Releases to water only.
2Major dischargers only.
NEC - Not Elsewhere Classified.
B. Existing Effluent Limitations Guidelines and Pretreatment Standards
Wastewater discharges for the porcelain enameling industry are regulated under 40 CFR
Part 466: Porcelain Enameling Point Source Category. This category consists of four
subcategories, as shown in Table 12-2 with a description of the subcategories' applicability.
12-2
-------
Table 12-2. Applicability of Subcategories in the Porcelain Enameling Point Source
Category
Siih-
piirl
Siihpiirl 1 ilk-
Siihpiirl Applicability
A
Steel Basis Material
Porcelain enameling on steel basis material
B
Cast Iron Basis Material
Porcelain enameling on cast iron basis material
C
Aluminum Basis Material
Porcelain enameling on aluminum basis material
D
Copper Basis Material
Porcelain enameling on copper basis material
Source: Porcelain Enameling Point Source Category -40 CFR 466\ Development Document for Effluent Limitations
Guidelines and Standards for the Porcelain Enameling Point Source Category [2].
EPA first promulgated effluent guidelines for the Porcelain Enameling Point Source
Category in 1982. All of the subcategories, except for copper basis material, have BPT, BAT,
NSPS, and PSES/PSNS limitations. Only NSPS and PSNS are established for the copper basis
material subcategory. The priority pollutants chromium, lead, nickel, and zinc are regulated in
all of the subcategories.
C. Results of Screening-Level Analysis
Table 12-3 presents the TRI and PCS discharges for 2002. The table compares the
number of facilities reporting discharges greater than zero, the pounds of pollutants discharged,
and the estimated TWPE discharged for the facilities that are not likely to manufacture porcelain
enameled products (Non-PE Facilities) and those that are (Likely PE Facilities). The TRI TWPE
far exceeds the PCS TWPE, both for non-porcelain enamelers and for likely porcelain enamelers.
Because of the combined TRI and PCS TWPE discharges for facilities in these seven SIC codes,
EPA selected this category for preliminary review. However, the first task of this preliminary
category review will be to better identify whether facilities in these seven SIC codes belong in
the Metal Finishing Point Source Category or the Porcelain Enameling Point Source Category.
Based on the results of this sorting, EPA will be better able to assess the pollutant discharges for
the Porcelain Enameling Point Source Category.
12-3
-------
Table 12-3. Porcelain Enameling Point Source Category TRI and PCS Discharges for 2002
Number of l-'acililios
Reporting TWPI.
(ircalcr 1 lian /.cm
Total Pounds
Discharged
twpi:
2002 Tolal
4(..4'79.5'7(.
95,700
2002 TRI Non-PE Facilities
154
406,178
49,395
2002 PCS Non-PE Facilities
9
22,710,347
3,450
2002 Total Non-PE Facilities
23,116,525
52,845
2002 TRI Likely PE Facilities
30
576,059
39,348
2002 PCS Likely PE Facilities
4
38,322
28
2002 Total l.ikclv PI lacililics
(>14.3X1
39,376
Source: TRJReleases2002\ PCSLoads2002\ TRIReleases2000jv4; PCSLoads2000_v6.
Note: TRI discharges include transfers to POTWs and account for POTW removals. PCS facilities include major
dischargers only.
D. Potential New Subcategories
EPA did not identify any potential new subcategories for the Porcelain Enameling Point
Source Category.
E. Pollutants of Concern
TRI Discharges
Table 12-4 lists the five chemicals with the highest TWPE of TRI-reported 2002
discharges for the likely porcelain enameling facilities. The 2000 discharges of these chemicals
for the porcelain enameling facilities are not included because EPA completed an in-depth
review of the facilities only for those reporting discharges in 2002. Sodium nitrite contributed
the majority (80%) of the category TRI TWPE in 2002.
12-4
-------
Table 12-4. Porcelain Enameling Point Source Category, Top TRI Chemicals for 2002
( homiciil
Number of l;icili(ks
Reporting (hcmiciil
Tolsil Pom lids
T\\ IT.
Sodium Nitrite
6
83,998
31,359
Zinc and Zinc Compounds
11
101,790
4,773
Nickel and Nickel Compounds
18
28,575
3,112
Copper and Copper Compounds
6
62
40
Lead and Lead Compounds
8
12
28
Source: TRIReleases2002.
Note: TRI discharges include transfers to POTWs and account for POTW removals.
PCS Discharges
Table 12-5 lists the five chemicals with the highest TWPE of PCS-reported discharges
for 2002 for the four likely porcelain enameling facilities. The 2000 discharges of these
chemicals for the porcelain enameling facilities are not included because EPA conducted an in-
depth review of the facilities only for those reporting discharges in 2002. Nickel, aluminum, and
zinc account for 73% of the 2002 PCS TWPE.
Table 12-5. Porcelain Enameling Point Source Category, Top PCS Chemicals for 2002
( homiciil
Numhi-r of l-'iicililios
Reporting ( hoiniciil
loliil Pounds
T\\ IT.
Nickel
3
86
9.4
Aluminum
2
96
6.2
Zinc
3
103
4.8
Lead
3
1.9
4.4
Iron
3
519
2.9
Source: PCSLoads2002.
Note: PCS facilities include major dischargers only.
12-5
-------
F. Issues Identified
Before completing the final 2006 Plan, EPA will collect more information to better
identify whether facilities in the seven SIC codes belong in the Metal Finishing Point Source
Category or the Porcelain Enameling Point Source Category. Based on the results of this
sorting, EPA will be better able to assess the pollutant discharges for the Porcelain Enameling
Point Source Category. Further review of this category may also focus on the following issues:
Improve identification of the category by contacting facilities dominating the
TWPE to verify point source category; and
Analysis of the TRI-reported sodium nitrite discharges, including the methods
used to estimate reported discharges, process sources, and concentrations
discharged.
G. References
1. Porcelain Enamel Institute. Properties of Porcelain Enamel, Appearance Properties,
Data Bulletin PEI501. Available online at:
http ://www. porcel ai nenamel. com/pei 501 .htm.
2. U.S. EPA. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Porcelain Enameling Point Source Category. EPA-
440/1-82/072. Washington, D.C. 1982.
3. U.S. EPA. Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Metal Finishing Point Source Category. EPA-440/1-
83/091. Washington, D.C. 1983.
4. Memorandum to 2006 Effluent Guidelines Program Plan Docket, EPA Docket Number
OW-2004-032 from Jessica Wolford, ERG. "Identification of Facilities for the Porcelain
Enameling Point Source Category". July 14, 2005. Docket OW-2004-0032. DCN
02195.
5. U.S. Economic Census. 2002. Available online at:
http://www.census.gov/econ/census02.
12-6
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